Attachment A

5-Cities Alliance
Comment Letter
& Technical Studies
Technical Appendix 1: Transportation
Technical Appendix 2: Noise and Vibration
Technical Appendix 3: Geology, Seismic,
Soils and Groundwater
Technical Appendix 4: Air Quality

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396 HAYES STREET, SAN FRANCISCO, CA 941 02
T: (a15) ss2-7272 F: (a1s) ss2-s816

Rachel B. Hooper

Laurel L. lmpett

www.smwlaw.com

July 9,2015
Garrett Damrath, Chief Environmental Planner
Division of Environmental Planning
Department of Transportation, District 7
100 S. Main St., MS-164
Los Angeles, CA 90012

Re:

Draft Environmental ImpactReport/Environmental Impact

Statement SR 710 North Study

Dear Mr. Damrath:

This firm represents the cities of Glendale,La Caiada Flintridge, Pasadena,

South Pasadena and Sierra Madre ("S-Cities Alliance") in connection with the State
Route ("SR") 710 North Project ("Project").t On behalf of 5-Cities Alliance, we
respectfully submit these comments to help ensure that agency decision-makers fully
comply with the California Environmental Quality Act ("CEQA"), Public Resources
Code section 21000 et seq., and the National Environmental Policy Act ("NEPA"), 42
U.S.C. section 4321 et seq. C)ur client is deeply concerned about the far-ranging
environmental impacts the Project may have on their cities.

After carefully reviewing the SR 710 Draft Environmental Impact

Reporstatement ("DEIR/S") for the Project, we have concluded that it fundamentally
fails to cornply with the requirements of CEQA and NEPA in numerous respects. As
described below, the DEIR/S violates these laws because it: (1) fails to identiff
t

For purposes of this letter, the "Project" refers collectively to the build
alternatives unless we indicate otherwise. The build alternatives include: Transportation
System Management/Transportation Demand Managernent ("TSM/TDM"); Bus Rapid
Transit ("BRT"); Light Rail Transit ("LRT"); and single bore and dual bore variations of
the Freeway Tunnel alternative (collectively, 'oFreeway Tunnel").

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thresholds of signifcance for the vast majority of the environmental impact analyses; (2)
fails to provide significance determinations for numerous environmental impact
categories; (3) fails to properly describe the Project's environmental setting; (4) defers
analysis of critical environmental impacts and fails to adequately analyze those impacts it
does address; (5) fails to support its conclusions with substantial evidence; (6) fails to
propose adequate mitigation measuros for the Project's numerous significant
environmental impacts; and (7) fails to undertake a sufficient study of alternatives to the
Project.

Of critical importance, the DEIR/S fails in its role as an informational

document. In order to fully understand the analyses and conclusions in the DEIR/S, the
public must wade through over 25,000 pages. While one would expect that the main
body of the EIR/S would contain an accurate sumary of the information contained in
the technical appendices, this is not the case. In certain instances, the DEIVS's
conclusions are contradicted by analyzes in the technical appendices. For example, the
DEIR/S concludes the Project would result in a benefit to public health while the
technical appendix shows that that certain of the Project alternatives would harm public
health by increasing the risk of cancer in certain locations. Such fundamental errors
undermine the integrity of the EM.
The EIR is "the heart of CEQA." Laurel Heights Improvement Ass'n v.
(Jnversity
of Calrnia (1988) 47 Ca1.3d376,392 ("Laurel Heights")
Regents of
(citations omitted), It is "an environmental 'alarm bell' whose purpose it is to alert the
public and its responsible officials to environmental changes before they have reached
oto
demonstrate to an
ecological points of no return. The EIR is also intended
and considered the
has,
in
fact,
analyzed
apprehensive citizenry that the agency
ecological implications of its action.' Because the EIR must be certified or rejected by
public offcials, it is a document of accountability." Id. (citations omitted). Likewise,
NEPA requires that federal agencies 'oconsider every significant aspect of the
environmental impact of a proposed action . . . [and] inform the public that fthey have]
indeed considered environmental concerns in [their] decision-making process[esf ." Earth
Island Institute v. U.S. Forest Servce (9th Cir. 2003) 351 F.3d 1291,1300 (citations
omitted).

CEQA requires the EIR not only to identify a project's significant effects,
but also to identiff ways to avoid or minimize them. Pub. Res. Code $ 21002.1. An EIR

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generally may not defer evaluation of mitigation to alater date. CEQA Guidelin"s'
15126.4(aX1XB). Rather, an EIR must assess each mitigation proposal that is not
"facially infeasible," even if such measures would not completely eliminate an impact or
render it less than significant. Los Angeles Unffied School Dst. v. City of Los Angeles
(1997) 58 Cal.App.4th 1019, 1029-31. Furthermore, for every mitigation measure
evaluated, the agency must demonstrate that the mitigation measure either: (1) will be
effective in reducing a significant environmental impact; or (2) is ineffective or infeasible
due to speciflrc legal or "economic, environmental, social and technological factors."
Friends of Oroville v. City of Oroville (2013) 219 Cal.App.4th 1352, 1359-61; Pub. Res.
Code $$ 21002, 21061.1;CEQA Guidelines $$ 15021(b), 15364.

NEPA's requirements are similar. NEPA requires an EIS to contain a

detailed discussion of all unavoidable environmental impacts. 42 U.S.C. $ 4332(CXii).
In its discussion of the proposed actions and alternatives, the EIS must "fi]nclude
appropriate mitigation measures" and discuss the "n]eans to mitigate adverse
environmental irnpacts." 40 CFR $$ 1502.14(,1502.16(h). The statuteoorequire[s] that
an EIS discuss mitigation measures, with 'sufficient detail to ensure that environmental
consequences have been fairly evaluated.' An essential component of a reasonably
complete mitigation discussion is an assessment of whether the proposed mitigation
measuros can be effective." South Fork Band Councl of W. Shoshone of Nevada v. U.S.
Dep't of Interor (9th Cir. 2009) 588 F.3d 718,727 (quoting Robertsonv. Methow Valley
Ctizens Councl (1989) 490 U.S. 332,352).
'Where,

review document fails to fully and

accurately inform decision-makers and the public of the environmental consequences of
proposed actions, or identify ways to mitigate or avoid those impacts, it does not satisff
the basic goals of either CEQA or NEPA. ,See Pub. Res. Code $ 2 i 061 ("The purpose of
an environmental impact report is to provide public agencies and the public in general
with detailed information about the effect that a proposed project is likely to have on the
environment; to list ways in which the significant effects of such a project might be
minimized; and to indicate alternatives to such a project."); 40 C.F.R. $ 1500.1(b)
("NEPA procedures must insure that environmental information is available to public
officials and citizens before decisions are made and before actions are taken."). As a

'

as here, the environmental

14 California Code of Regulations $ 15000 et seq

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result of the SR 710 DEIR/S's numerous and serious inadequacies, there can be no
meaningful public review of the Project.

This letter, along with the report by Nelson Nygaard on transportation

(Exhibit 1), the report by Landrum & Brown on air quality and greenhouse gas ("GHG")
(Exhibit 2),the report by Landrum & Brown on noise (Exhibit 3), and the report by
Wilson Geosciences Inc. on geology and groundwater resources (Exhibit 4), constitutes
S-Cities Alliance's comments on the DEIR/S. We respectfully request that the Final
EIR/S respond separately to each of the points raised in the technical consultants' reports
as well as to the points raised in this letter. In addition, each of the 5-Cities Alliance
member cities will be submitting letters under separate cover. The Alliance joins in the
CEQA and NEPA comments of all of its member cities.

THE PROPOSED FREEWAY TUNNEL ALTERNATIVB IS FLAWED AND

UNNECESSARY.
This letter focuses primarily on the DEIR/S's failure to comply with CEQA
and NEPA, Nevertheless, it is important to emphasize at the outset that the Project's
primary alternative,3 the Freeway Tunnel, is itself flawed and unnecessary. The DEIVS
has posited an ill-defined Project objective and, consequently, the Freeway Tunnel
alternative does not address the region's transportation needs. According to the DEIR/S,
the Project's primary objective is to resolve the lack of continuous north-south
transportation facilities in the San Gabriel Valley. DEM at 3. The DEIR/S suggests
that it is this lack of facilities that results in congestion on freeways and "cut-through"
traffic that affects local streets. Id. Yet, as the Nelson Nygaard Report explains, the
region actually lacks east-west transportation facilities, not north-south. Moreover, very
little - about 14 percent - of current peak period traffic is cut-through traffic. By
providing a new freeway link, the Freeway Tunnel alternative would reduce this cutthrough traffic from about 14 percent to betweenT percent and 11 percent. By reducing
analyze Project alternatives on equal footing,
without giving priority to any single one. However, the document subtly reveals an
implicit bias in favor of the Freeway Tunnel alternative based, for example, on its
selection of Caltrans (not Metro) as lead agecy, and SCAG's inclusion of the Freeway
Tunnel in the 2012 Regional Transportation Plan/Sustainable Communities Strategy.

'The DEIR/S purports to

,See

Section I.B, below.

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this cut-through traffic, approximat ely 7 percent to 13 percent of all motorists throughout
the study area would receive a nominal travel time savings of 2.5 minutes.o This means
that about 90 percent of motorists in the study would receive no significant travel tirne
savings, or their travel time would worsen, as a result of this alternative.
Nor would the Freeway Tunnel actually improve regional traffic. Instead,
it would shift congestion around. Traffic would significantly worsen on various
connecting freeways as a result of the tunnel, in part because the Freeway Tunnel induces
extra driving. The Freeway Tunnel would also increase traffic congestion in parts of
Alhambra, Rosemead, San Marino, Pasadena and South Pasadena.
The Freeway Tunnel would also bypass many of the destinations people
want to go. According to the New Initiative for Mobility and Community, the San
Gabriel Valley is a community of diverse people with widely varying commute patterns.
See "New Initiative for Mobility and Community," prepared by Nelson Nygaard for
Connected Cities and Communities, attached as Exhibit 5. Eighty-five percent of
commuters exiting the 710 Freeway at Valley Boulevard are intent on reaching local
destinations. Employees need to make short commutes to Pasadena and longer
commutes to Burbank (Metro has found that70 percent of study-area vehicle trips start
and end within the San Gabriel Valley). Students attending Cal State LA and East LA
College need ways to make short commutes to school. The Freeway Tunnel Alternative
simply would not serve these types of transportation needs,

In addition, the Freeway Tunnel does not provide a sustainale solution to

the region's transportation needs, and confers no support for active transportation. Every
trip starts by walking, and the people of San Gabriel Valley deserve to be able to walk
safety and comfortably. The region should be striving toward a transportation solution
that will make car ownership an option rather than a necessity. Projects such as the
Freeway Tunnel that facilitate the automobile and promote increased vehicular speeds
threaten the walkability of a community. Clearly, there must be a better solution to
meeting the region's transportation needs, especially given the Freeway Tunnel's hefty
a

2.5 minutes is the threshold used to count vehicle hours travelled during
peak periods; some savings may be greater but the DEIR/S does not contain this granular
information. See DEIR/S Transportation Technical Report at 4.3.

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$5.5 billion price

have asserted.

tag-and the fact that it will not "pay for itself'through tolls as sorre

Furthermore, the Freeway Tunnel's increase in vehicular capacity will

cause a substantial increase in vehicle miles travelled ("VMT"), with resulting increases
in greenhouse gas ("GHG") emissions and other air pollution. As explained further
below, ample studies demonstrate that increased highway capacity increases VMT and
GHG emissions in the long-run.s Consequently, providing increased roadway capacity is
unlikely to relieve congestion. The DEIR/S provides a real-world example of this effect,
as it acknowledges that the Freeway Tunnel would result in a sizable increase in
vehicular travel. Total VMT under all freeway tunnel alternatives would increase by as
many as 460,000 miles per day. This increase in VMT demonstrates that adding highway
capacity is a temporary solution, at best, to the complex problem of traffic congestion.
Because the Freeway Tunnel alternative would increase capacity and
induce travel, it would take the region in a direction that prevents achieving the State's
preeminent climate goals. Governor Brown's Executive Order issued on April 29,2015
directs the state to cut its GHG emissions 40 percent below 1990 levels by 2030; this
directive reiterates Gvernor Schwarzenegger's 2005 Executive Order, which calls for
reducing statewide GHG emissions 80 percent below 1990 levels by 2050. The State will
not be able to meet these goals without a reduction in motor vehicle travel. Tellingly,
Caltrans itself specifically recognized this fact when it noted that achieving the State's
climate change goals requires a "fundamental, holistic transformation of the
transportation systems." See California's2040 Transportation Plan, March 2015 at4,
attached as Exhibit 6 (stating that one of the main strategies to reduce future GHG
emissions for the movement of people and freight is reducing vehicle miles traveled and
increasing a shift to more sustainable transportation).

In addition, it is important to understand that even if a freeway tunnel were

the appropriate solution to meet the region's transportation needs-which it is not-the
Freeway Tunnel design being considered here is entirely unprecedented. The proposed
5

S. Handy and M. Boarnet, California Air Resources Board (CARB),

Polcy Bref n the Impact of Hghway Capacity and Induced Travel on Passenger
Vehicle (Jse and Greenhouse Gas Emissions, September, 30, 2014, at 4,5, attached as
^See

Exhibit

7.

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60-foot diameter tunnel would be the widest subsurface tunnel attempted anywhere in the
world. In December 2013, the tunnel boring machine ("TBM") used to construct
Washington State's Alaskan Way Viaduct replacement project-the largest such tunnel
to date (57-foot diameter)-became stuck after tunneling only one thousand feet of the
tunnel's 1.7-mile length. Workers had to construct an access pit 120 feet deep and 80
feet wide to lift the TBM out in order to repair it. Had it not failed so early, accessing the
machine for repairs would have been even more difficult-or irnpossible-because the
tunnel's route takes it beneath downtown Seattle. The Seattle project is now at least two
years behind schedule and it is unclear whether it can or will be successfully completed.
That project serves as a cautionary tale for the proposed Freeway Tunnel alternative, yet
the DEIR/S fails to address the impacts that could result if a TBM were stuck along the
SR 710 route alignment, which is located in a densely developed area.

In sum, selection of the Freeway Tunnel alternative would result in the loss
of a critical opportunity to fundamentally, holistically transform the region's
transportation system. Indeed, this alternative reflects strategies from the 1960's, when
the state pursued road-building projects without regard to global climate change and other
environmental threats. The agencies should deny the proposed Project and go back to the
drawing board, to design a project that is capable of rneeting the region's transportation
needs in a manner that is sustainable and environmentally responsible. In particular, as
discussed more fully below, the 5-Cities Alliance urges the agencies to consider its
"Beyond the 710" alternative, a multimodal option that combines mass transit, "great
strsets," and bikeways.

THB DEIR/S FAILS TO COMPLY WITH CEQA AND NEPA.

I.

The DEIWS's Description of the Project Violates NEPA and CEQA.

An accurate description of a proposed project is "the heart of the EIR

process" and necessary for an intelligent evaluation of the project's environmental
effects. Sacratnento Old City Ass'n. v. City Council (1991) 229 Cal.App.3d 1011,1023;
see also Rio Vsta Farm Bureauv. County of Solano (1992) 5 Cal.App.4th35l,369-370
(project description is the 'osine qua non" of an informative and legally sufficient EIR);
see also Westlands Water Dist. v. U.S. Dep't of Interior (9thCir.2004) 376 F.3d 853,
866-86S (the purpose and need statement of an EIS must "reasonably define[ ] the
objectives of the project"). Consequently, courts have found that, even if an EIR is
adequate in all other respects, the use of a "truncated project concept" violates CEQA and
mandates the conclusion that the lead agency did not proceed in a manner required by
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Iaw. San Joaquin Raptor/Wildlife Rescue Center v. County of Stanislaus (1994) 27

Cal.App.4th713,730. Furthermore, "[a]n accurate project description is necessary for an
intelligent evaluation of the potential environmental effects of a proposed activity." Id.
(citation omitted).
Thus, an inaccurate or incomplete project description renders the analysis
of significant environmental impacts inherently unreliable. While extensive detail is not
necessary, the law mandates that EIRs should describe proposed projects with sufficient
detail and accuracy to permit informed decision-making. See CEQA Guidelines $15124
(requirements of an EIR). NEPA similarly requires an accurate and consistent project
description in order to fulfill its purpose of faciiitating inforrned decision-making. 43
u.s.c. s 4332(2)(c).
The DEIR/S's description of the Project fails to fulfill these requirements.
It lacks adequate detail regarding project construction, obscures the alternative preferred
by Caltrans and Metro, fails to identiff the standards by which the agencies will select an
alternative, and lacks critical information about Project funding. As a result, the DEIR/S
does not come close to meeting the basic thresholds for legal adequacy.

A.

The DEIR/S Fails to Identify Performance Criteria or Objective

Standards by Which Caltrans and Metro Will Evaluate the
Alternatives.

The DEIR/S provides no objectives or standards by which the lead agency

may evaluate the various alternatives' comparative performance. This omission
undermines the public process, leaving interested parties without guidance as to how
project selection will transpire. The document's lack of transparency violates CEQA's
and NEPA's fundamental goals of ensuring that, especially for projects involving
potentially significant environmental impacts, decisions are made with a maximum of
transparency and public input. See, e.g., Save Tara v. City of W. Hollywood (2008) 45
Cal. th 116, 136 ("CEQA's goal. . .[is] transparency in environmental decisionmaking.");SierraClubv. Gates (S.D. Ind.2007) 499F.Supp.2d1101, 1132 (lackof
transparency in decision-making process was "troubling in light of the goal of NEPA to
ensure public input into the process").
The DEIVS's omission is surprising, given that some objectives and
performanee measures were identified in Metro's Alternatives Analysis Report. That
report included eight performance objectives related to transportation system

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performance, environmental imp acts, planning considerations, and co st efficiency.

Alternatives Analysis Report (2012) ES-3 to -4. For each of these eight objectives, the
document identified one or more performance measures. Id. at2-4. It also described the
screening criterion selection process Metro used to select the alternatives it would
consider in the DEIR/S. Id. atES-4. Yet, such criteria are entirely lacking in the
DEIR/S, where their presence is even more crucial. The public is thus left in the dark as
to whether Caltrans and Metro will be relying on these same objectives and performance
measures to select from among the proposed project alternatives, or whether the agencies
will be using a different set of objectives and performance measures.

Of course, Caltrans commonly relies on performance measures and criteria.

For example, Caltrans' Strategic Management Plan 2015-2020 sets very specific targets
for transportation mode shift and VMT reduction. Similarly, Caltrans' Smart Mobility
Caltrans Report (2010) describes specific performance measures to advance "smart
mobility," Smart Mobility Caltrans Report (2010) at 8, 50, attached as Exhibit 8. Neither
document is even mentioned in the DEIR/S, however. Readers need to know if the
agencies will be using these, or other performance measures, to assess the alternatives.
Equally troubling, the DEIVS fails to clariff the respective roles of
Caltrans and Metro in rnaking the ultimate selection among project alternatives. The
DEIR/S states that "Caltrans, in consultation with Metro, will identiff a Preferred
Alternative and make the final determination of the project's effect on the environment."
DEIR/S at2-107. But the document does not address how the two agencies will share
responsibility for the choice among alternatives, or how they will each bring their distinct
expertise to bear in that decision. This is especially confusing, as the lead agency for the
Project will differ depending on the alternative eventually chosen. ,See DEIVS at
preface. As the City of South Pasadena's comment letter explains, changing the lead
agency depending on the selected alternative is unlawful and improperly skews the
analysis in favor of the Freeway Tunnel alternative. Letter from Rossmat &. Moore for
City of South Pasadena, pp._.

B.

The DEIR/S Does Not Acknowledge That the Freeway Tunnel Is the
Preferred Alternative.

The CEQ's regulations for implementing NEPA require the alternatives

section of an EIS to "identi$z the agency's preferred alternative if one or more exists, in
the draft statement, and identi$t such alternative in the final statement . . . ." 40 C.F.R. $
1502.1a(e). Therefore, if the agenoy has a preferred alternative at the draft EIS stage,

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that alternative must be labeled or identified as such in the draft EIS. Se also Council on
Environmental Quality, Mernorandum to Agencies: Forty Most Asked Questions
Concerning CE,Q's National Environmental Policy Act Regulations, 46 Fed. Reg. 18026,
18028 (March 23,1981).

Although the DEIWS purports to evaluate the alternatives without giving

priority to any single one, there are strong indications that the Freeway Tunnel is
Caltrans' and Metro's preferred alternative, and that the agencies have already rnade their
decision to select it for project approval. For example, the DEIR/S states, when
discussing the Project generally: "Because the proposed project would add a new freeway
tunnel to the project area andlor would widen existing local roads, it would potentially
worsen air quality." DEIR/S at3.13-16 (emphasis added).

Tellingly, unlike the other alternatives, the freeway tunnel is included in

SCAG's 2015 Federal Transportation Improvement Program ("FTIP") and its 2012
Regional Transportation Plan/Sustainable Communities Strategy ("RTP/SCS"). DEIR/S
at 1-51; 3.13-14. Accordingly, the DEIVS states that "[t]he forecast revenues in the
RTP/SCS financial plan include toll revenues from the SR 710 freeway tunnel." Id. at l51. This is revealing. By acknowledging that SCAG's transportation plan includes, and
actually relies on the toll revenues from the freeway tunnel, the DEIVS suggests that the
freeway tunnel is a foregone conclusion in the eyes of Metro and SCAG.
Together, these statements indicate that despite the DEIVS's ostensible
lack of a preferred alternative, Caltrans and Metro have already determined to approve
and construct the Freeway Tunnel alternative. The DEM must acknowledge that the
Freeway Tunnel alternative is in fact the preferred alternative. By failing to do so, the
document rnisleads readers and obscures the institutional momenturn behind the Freeway
Tunnel alternative.
C.

The DEIR/S Lacks an Adequate Description of Potential Funding

Sources for Each Alternative.

The DEIR/S's discussion of funding for each of the alternatives is

altogether opaque, and the public therefore has no way to determine the Project's true
costs. The DEIR/S should contain a separate, detailed description (accompanied by a
summary in table forrnat) of both: (1) the estirnated costs of each project component, and
(2) the estimated funding sources for each alternative.

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Given the size and cost of the proposed Project, the public has a keen
interest in ready access to cost and funding data for the various alternatives. Indeed, the
environmental impacts of project alternatives cannot be fully considered without an
understanding of this crucial information. As it stands, the DEIVS addresses cost
inforrnation only superficially, in one short paragraph at the end of the description of
each project alternative. This approach is entirely unhelpful.

As for potential funding sources, the DEIVS fails to discuss this topic in
any focused manner. Instead, it sprinkles references to possible funding sources
throughout the document, but with insufficient detail. The most specific discussion of
funding for the alternatives appears, of all places, in two rows of the Table 3 .1.3 , which
addresses the Project's consistency with state, regional, and local plans. DEIR/S at3.l36; 3 .1-47 (Poli cy 4.2.3 and Policy L2l). But these explanations merely state that "state
and local funding sources are anticipated to be used" for all build alternatives, and that
the TSM/TDM, LRT, and Freeway Tunnel alternatives would need to be added to the
FTIP6 to be eligible for federal funding. Id. Again, this information is too nebulous to be
useful.
The DEIR/S's other statements about Project funding are vague or
inconsistent. For example, the DEIR/S states that "[t]he Project is proposed to be funded
entirely or in part by Measure R, a halcent sales tax dedicated to transportation projects in
Los Angeles County." DEIR/S at 1-1. Elsewhere, however, it explains that only $780
millionln funding has been committed by Measure R to the SR 710 improvements.T Id. at
1-6; 1-51. This is a small fraction of the cost of the Project, which is estimated to be $5.5
billion for the Freeway Tunnel alternative. There is little mention of the other sources of
local or regional funding, or how those funding sources may differ depending on the
alternative selected.
6

Confusingly, the document elsewhere states that the Freeway Tunnel

Alternative is already included in SCAG's 2015 FTIP. DEIR/S at3.13-14.
7

Although the DEIR/S states that Measure R includes a "comrnitment" of

$780 million to the 710 Project, DEIR/S at l-52, Metro has previously taken the position
that Measure R does not constitute a binding commitment to spend in a parlicular
manner. Exhibit 9 al37 (Opening Brief of Respondent Los Angeles County Metropolitan
Transportation Authority, City of South Pasadena v, Los Angeles County Metropolitn
Transp. Authorty (Cal. Ct. App., }i4:ar.22,2011,8221118) 2011 WL 989553).

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Nor does the DEIR/S analyze the revenues expected from the toll version of
the Freeway Tunnel alternative despite earlier indications that this analysis would be
conducted at this stage. Specifically, Metro's 2012 Altematives Analysis Report stated that
'oMetro . . . concludes that freeway tunnel alternatives could be funded by future toll
revenues. However, no analysis of toll revenues has been conducted in this Alternatives
Analysis so this conclusion will be verified in the PAD f"Project Approval &
Environmental Documentation"] phase." Alternatives Analysis Report Appx. X, Cost of
Alternatives Technical Memorandum at 5. Nevertheless, the DEIR/S includes only a
single, offhand mention of toll revenues, noting that toll revenues from the freeway tunnel
are included in SCAG's2012 RTP/SCS financial forecast. DEM at 1-51.
The DEIVS's discussion of federal funding is similarly incornplete. It
explains that the Project is classified as a "Type I" project because federal aid is proposed
for construction for the Freeway Tunnel, BRT, and TSM/TDM alternatives. Id. at3.l4-7.
But the document nowhere explains what a "Type I project" is. Nor does it explain in the
project description why federal aid is proposed for all build alternatives except the LRT,
and whether the (un)availability of federal funding will influence selection of the project
alternative. Sirnply stating that federal funding is "proposed" provides little useful
information. The reader is left guessing as to: (1) the likelihood that such funding will
actually be secured, (2) the expected grant amount, and (3) what portion of the Project's
overall cost would be covered by that funding.s

The absence of meaningful discussion of project funding is surprising, since

the issue is not new. In 2003,the Federal Highway Administration ("FHWA") informed
Caltrans that the FHWA was rescinding its 1998 Record of Decision (the NEPA approval
document) for a prior version of the SR 710 project and requiring Caltrans to conduct a
supplemental EIS. The FHWA based this decision, in part, on "fc]ontinued uncertainty
regarding the financing of this project and the failure to develop a comprehensive financial
plan for its implementation." Exhibit l0 at7 (G. Hamby Letter to J. Morales, December

t7,2003).
I As noted above, simply referring to appendices or technical documents is
not sufficient. The DEIVS's information on costs and funding sources must be presented
to the reader in a straightforward, comprehensible format. See Californa Oak Found. v,
City of Santa Clarta (2005) 133 Cal. App. 4th 1219,1239 (relevant information may not
be "buried in an appendix").

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The DEIVS's omission of any useful information as to Project cost and

funding is glaring. These monetary issues are vital, as they dictate not only whether the
Project's purported benefit justifies the cost, but also whether the Project will ever be
completed. Other tunnel-boring projects with lesser risks have encountered serious
difficulties, resulting in huge cost-overruns and long delays. The Alaskan Way Viaduct
tunnel, whose pre-project cost estimate was about half that of the dual-bore Freeway
Tunnel alternative, again is illustrative. As noted previously, work has been stalled on
the Seattle project since 2013,when the tunnel boiing machine broke down in situ.e
Additional costs are unknowr,l0 although the Washington State Department of
1l
Transportation hopes to hold the contractor liable for such costs.
The Alaskan Way Viaduct replacement project is not the only example of
an underground infrastructure project involving the use of tunnel boring machines that is
afflicted by high costs and delays. Contractors operating a tunnel boring machine for a
similar project in Miami demanded an extra 5150 million three months before the start of
excavation based on the results of new geotechnical analysis.l2 Indeed, studies have
shown that for large-scale transportation infrastructure projects like the SR 710 North
Project, the likelihood of cost ovenuns correlates with the length of the project's
n

Galloway, P., et al., Alaskan Way Viaduct Replacement Program Expert

Review Panel Updated Report, April 3,2075 at 4, attached as Exhibit 1 1 .
to

The Washington State Department of Transportation currently estimates

that additional costs could exceed $300 million. Alaskan Way Viaduct Replacernent
Expert Review Panel Update Report at28.
rr
See Kovto NEws, Transportation fficals; New cracks on Alaskan Way
(April
Vaduct
7 ,2015), available at:
ccrm/news ll ocal lTransoortation-offcials-Nerv- cracks-on-Alaskanhttlr://www
V/ay-Viaduct -298%A7 41.html
.

Buitding Port of Mami Tunnel Seeks More

Money (July 8, 2011), available at httrt I I miuni. cb sl ocal. coml 20 11 107 l08lcoffnanvhr ri I rli n o-nnrf-n -nr i nrn i -tunnel-seeks-more-mon
see also TI-tp CoIUMBUS DtsPatcg,
cost overrun(Dec.6,2014),
mllion
Project to bore tunnel under Columbusfaces 829,5
available at: htto I I www. dispa tch. com/content/stories/local/20 1 ll2lA6ldauntinsdrill .html (Cleveland project involving tunnel boring machine delayed two years with
$29.5 million cost overrun).

" Snn CBS Mravrr, Company

:

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implementation phase; here, the dual-bore Freeway Tunnel alternative is expected to take
five years to construct, three years longer than the initial time estimate for the Seattle
project. In addition, tunnel projects are especially likely to fall prey to higher levels of
cost escalation. See generally Bent Flyvbjerg, et al. "What Causes Cost Overrun in
Transportation Infrastructure Projects?" Tronsport Reviews (2004), attached as Exhibit
l2;BentFlyvbjerg,'oWhat You Should Know About Megaprojects and Why: An
Overview" Project Management Journal (2014), attached as Exhibit 13.

D.

The DEIR/S's Description of the Project Fails to Include Adequate

Detail Regarding Construction of the Tunnel Alternatives.

The description of a Project's construction details should be commensurate

with its size and scope. Given the irnmense cost, size, and scope of the alternatives
proposed in the DEIR/S, the Project description should have supplied more detail
regarding their construction. Below are just three examples of the ways in which the
Project description's discussion of construction details falls short.

First, the DEIVS states that for the LRT and Freeway Tunnel alternatives,
the tunnel would be fabricated from a precast concrete segmental lining systern. DEIVS
at2-52;2-80. There is no explanation of how the precast concrete tunnel rings will be
transported to, or fabricated at, the Project site. The precast concrete tunnel rings
required to build very large diameter tunnels such as the dual bore are enormous: nearly
60 feet in diameter. Given the 4.2 miles of tunnel, the Freeway Tunnel alternative would
require 1056 tunnel rings if they are 20 feet long, or 2,112 rings if they are 10 feet long.
Concrete structures that are 60 feet in diameter would cover about five traffic lanes on a
freeway and must be hauled to the tunnel entrance portal from the fabrication site. Given
their size, they likely would be designed in several pieces to be assembled on site. The
DEIR/S provides no description of this process, despite the obvious impacts. For
example, the possibility of unaccounted-for truck trips implicates the transportation, air
quality, noise, and GHG analyses.
Second, the DEIR/S states that the Project would be built in phases.
However, the DEIR/S addresses construction phasing only in the most general terms; it
even lacks factual detail about when the phases would occur. ,See DEIR/S at2-24
(TSM/TDM);2-38 to -39 (BRT); 2-57 to -60 (LRT);2-85 to -86 (Freeway Tunnel).
Construction is estimated to take up to five to six years, depending on the alternative
selected. Details of the timing of construction are critical to understanding Project
impacts, yet the DEIR/S lacks any description of this critical Project component.

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Third, the DEIVS contains no description of how repairs will be made to

the tunnel boring machines in the event that they malfunction during Project construction.
The DEIVS must address this issue. As noted previously, the TBM for the Alaskan Way
Viaduct Replacement Project tunnel malfunctioned during the early stages of tunnel
construction and became stuck, requiring workers to lift it out to perform repairs. This
intensive work, which involved the use of heavy equipment to excavate an access pit 120
feet deep and 80 feet wide, has delayed that project by at least two years. Given Seattle's
experience, and the fact that the Freeway Tunnel alternative proposes to use up to ur
TBMs (thereby quadrupling the risk of mechanical failure), the DEIR/S should have
addressed how repairs would be made in the event of a TBM malfunction.
Unfortunately, this flaw in the Project description resulted in an incomplete analysis of
the tunnel alternatives' impacts in a number of areas. For example, because the DEIVS
does not describe a TBM repair plan or strategy, it does not analyze the potential impacts
from repair-related excavation and extended tunnel construction. Such impacts may
include ground settlement and additional noise, vibration, and air quality impacts. In a
worst-case scenario, homes and businesses above or adjacent to the Project site would
need to be relocated in order to allow workers access to a TBM from the surface.

In sum, the DEIR/S's description of the Project suffers from serious flaws
and omissions. Consequently, the DEIWS does not meet CE,QA and NEPA's basic
requirements.

II.

The DEIR/S's Analysis of and Mitigation for the Project's Environmental

Impacts Are Inadequate.

The evaluation of a proposed project's environmental impacts is the core

purpose of an EIR. ,Se CEQA Guidelines $ 15 126.2(a) ("[a]n EIR shall identify and
focus on the significant environmental effects of the proposed project"). Likewise,
NEPA requires that federal agencies "consider every significant aspect of the
environmental impact of a proposed action . . . [and] inform the public that fthey have]
indeed considered environmental concerns in its decision-making process." Earth Island
Insttute,351 F.3d at i300 (citations ornitted). Each statute also requires that the EIR/S
identify rneasures that would effectively mitigate a proposed project's significant effects
on the environment. Pub. Res. Code $ 21002.l(a); Robertson,490 U.S. at352-352. As
explained below, the DEIVS fails to analyze the Project's numerous environrnental
impacts, including those affecting air quality, climate change, traffic and transportation,
noise, geology, hydrology and water quality. It also fails to identify effective mitigation
measures for the Project's significant effects.

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A.

The DEIR/S's Analysis of and Mitigation for

Inadequate.

Air Quality Impacts Are

The Project is located within the South Coast Air Basin, which has the
worst air quality - with the highest observed ozone concentrations - in the United States.
SeeLetter to Michael Miles, Caltrans from USEPA, September 28,2012 regarding the I710 Project from Ocean Boulevard to State Route 60, at pdf page 6, attached as Exhibit
14. The South Coast Air Basin also has the greatest number of unhealthy air quality
days.13 Direct and indirect air pollutant emissions from transportation-related activities is
a major contributor to this poor air quality. ,See Exhibit 14 (J. Blurnenfeld Letter to M.
Miles, September 28, 2012).
Given the severe air pollution in the Project study area, and the Project's
potential to contribute to that pollution (particularly if the Freeway Tunnel is selected),
one would expect the DEIVS to provide a comprehensive analysis of the Project's
irnpacts and to thoroughly mitigate for these impacts. Yet, the DEIR/S fails to achieve
CEQA's and NEPA's most basic purpose: informing governmental decision-makers and
the public about the potential significant environmental effects of a proposed activity.
CEQA Guidelines $ 15002 (a) (1); 40 C.F.R. $ 1500.1(b). Because the attached air
quality report by Landrum & Brown discusses the inadequacies of the DEIR/S's air
quality analysis in detail, this letter will highlight just a few of these deficiencies. See
alsoLetter of the City of La CaiadaFlintridge (presenting detailed discussion of
DEIVS's defective air quality analysis).

1.

The DEIWSos Analysis of Construction'Related Air Quality

Impacts Is Flawed, and the Proposed Mitigation Insuffcient.

Determining whether a project may result in a significant adverse

environmental effect is one of the key aspects of CEQA and NEPA. CEQA Guidelines $
15064(a) (determination of significant effects "plays a critical role in the CEQA
process"); 40 C.F.R. $ 1502.16 (Discussion of environmental consequences "shall
include discussions of...[d]irect effects and their significance [and] fi]ndirect effects and
their significance."). CEQA specifically anticipates that agencies will use thresholds of

tt Sur "State of the Air," American Lung Association, available at

-fi ndin ss/ozone-oollution.html. accessed on Mav
htto ://www. stateo ft he air, or p,120 | 4
26,2015

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Pae 17

significance as an analytical tool for judging the significance of a Project's impacts. 1d. $
15064.7. Because the requirement to provide mitigation is triggered by the identification
of a significant impact, an EIR's failure to identify a project's significant impacts also
results in a failure to mitigate these impacts. Here, the DEIR/S fails to identi$r
construction-related thresholds of signif,rcance; as a result, it never coes to a conclusion
regarding the significance of the Project's construction-related impacts, or identifies
adequate mitigation for those impacts.
The DEIVS quantifies the increase in construction-related criteria air
pollutant emissions (Table 3.t3.4 af page 3.13-11) and states that "short-term degradation
of air quality may occur due to the release of particulate emissions generated by
excavation, grading, hauling, and other construction equipment." Id. at 4-6. The DEIR/S
then fails to take the next critical step in the analysis: to disclose whether the Project's
increase in ernissions constitutes a significant impact. According to the Landrum &
Brown Air Quality Report, the Project's construction emission levels before mitigation
are well above the regional significance thresholds recommended by the South Coast Air
Quality Management District ("SCAQMD"). ,See SCAQMD Air Quality Significance
Thresholds, attached as Exhibit 15. The LRT and Freeway Tunnel alternatives would
exceed relevant thresholds for reactive organic gasses ("ROGs"), and carbon monoxide
("CO") emissions. SeeLandrum & Brown Air Quality Report. All of the build
alternatives greatly exceed the SCAQMD thresholds for particulates and NO" emissions.
Indeed, For the LRT and Freeway Tunnel alternatives, particulate emissions are between
3.8 and 9.7 times greater than the SCAQMD thresholds. NO* emissions are22.4 times
greater than the SCAQMD thresholds for the LRT alternative and 43.9 and 49.3 times
greater for the two Freeway Tunnel alternatives. Id. The DEIVS does not disclose these
exceedances of regional air quality standards.

Notwithstanding the Proj ect' s clearly signifi cant construction-related

emissions, the DEIVS errs further by failing to evaluate whether these emissions also
violate federal and state ambient air quality standards. The SCAQMD recommends using
an approach called a"localized construction impact assessment" to deterrnine whether
construction emissions will create any exceedances of these ambient air quality standards,
or worsen any existing exceedances. ^See SCAQMD's Localized Significance Threshold
("LST") Methodology, attached as Exhibit 16. LSTs, which are developed based on the
ambient concentrations of pollutants for each source receptor area, represent the
maximum emissions from a project that will not cause or contribute to an exceedance of
the most stringent applicable federal or state ambient air quality standard. Projects larger

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than fve acres typically are not exempt from this analysis but must perform their own
dispersion modeling to determine pollutant concentrations at nearby receptors. We can
find no indication that the DEIR/S conducted the necessary dispersion modeling to
evaluate whether construction emissions from the Freeway Tunnel alternative would
violate federal or state air quality standards even though the proposed freeway tunnel(s)
would be rnuch larger than fve acres in size. The DEIR/S also should have analyzed the
construction-related emissions from the other Project alternatives under this threshold.
This omission alone constitutes afatal flaw in the DEIVS.

Although the DEIR/S fails to come to a determination regarding the

significance of the Project's construction-related emissions, it nonetheless identifies some
air quality mitigation measures. DEIR/S at3.13-40 - 42. Yet, here too, the DEIR/S fails
because it does not provide any information as to the expected effectiveness of these
measures. See Friends of Oroville, 219 Cal.App.4th 1352, 1359-61. Consequently, it
does not provide any evidentiary support for the DEIR/S's conclusion that the Project's
construction-related air ernissions would be less than significant.
the Landrum & Brown Air Quality Report makes clear, does the
DEIR/S propose the most effective measures to control construction-related emissions,
particularly for the Freeway Tunnel alternative. For example, the DEIR/S identifies a
very stringent rneasure (complying with Metro's Green Construction Policy) for the
TSM/TDM, LRT, and BRT alternatives, but it does not require this same protective
measure for the Freeway Tunnel alternative . Id. aI3,13-42. Metro's Green Construction
Policy requires, among other things, all construction equipment greater than 50
horsepower to rneet Tier 4 standards and be equipped with diesel particulate fi.lters after
January l,2015.ra Yet the sole mitigation measure for reducing emissions from
construction of the Freeway Tunnel alternative requires only compliance with Tier 3
standards. Id. at3.13-41. The DEIR/S provides no explanation as to why the Freeway
Tunnel alternatives would not be mitigated using the most stringent Ieasures, especially
since they would have greater emissions than the other alternatives. DEIVS at 3.13- I i .
Indeed, according to Landrum & Brown, this less restrictive measure means that the NO*
emissions under the tunnel alternative would be reduced only by about 33 percent, as
compared to a 90 percent reduction if the tunnel alternative were required to rneet Tier 4
standards. Notably, the less restrictive measure would not reduce particulate emissions at

Nor,

t*

as

Ti.r 4 standards

are the most stringent.

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Page 19

all. The failure to require the most effective mitigation

measures for these signif,rcant

effects violates CEQA. Pub. Res. Code $$ 21002,21081.

2.

The DEIR/S's Analysis of Operation-Related Air Quality

Impacts Is Flawed, and the Proposed Mitigation Insuffcient.

(a)

The DEIR/S Underestimates the Project's Increase in

Operation-Related Regional Emissions.

As discussed below, the DEIR/S underestimates predicted traffic volumes

because it fails to take into account all of the Freeway Tunnel alternative's induced travel
demand beyond the first 10 years of operation. It also grealy understates increased delay
where the Freeway Tunnel would create new bottlenecks or make existing bottlenecks
worse. Inasmuch as the Project's air quality emissions are dependent on the
transportation assumptions, any underestimation of vehicular trips andlor vehicle delay
necessarily results in an underestimation of vehicular emissions. Moreover, as the
Landrum & Brown Air Quality Report explains, the DEIVS also underestimates
vehicular emissions because it overestimates the increase in vehicle speeds that would
occur as a result of the Freeway Tunnel.
Because Metro's inaccurate modeling leads to flawed conclusions
regarding the severity of these impacts, the EIR violates both CEQA and NEPA.
Santiago County Water Dist. v. CounQ of Orange (1981) 118 Cal.App.3d 818, 829 (EIR
must provide accurate information regarding "how adverse the adverse impact will be");
see 40 C.F.R. 1502.24 ("Agencies shall insure the professional integrity, including
scientific integrity, of the discussions and analyses in environmental impact statements");
Natural Resources Defense Councl v. U.S. Forest Service (9th Cir. 2005) 421F.3d797,
812-813 (EIS's erroneous calculations based on improper assumptions subverted NEPA's
purpose and presented a "tnisleading. . .evaluation of alternatives").

(b)

The DEIR/S Fails to Adequately Analyze oY Mitigate

Impacts Relating to Particulate Hotspots.

It is critical that the DEIVS conduct an adequate analysis of particulate

impacts given the well documented serious health risks associated with PMz.s exposure.
In its final rule designating attainment and non-attainment of PM2.5 standards, the U.S.
EPA noted the "signifcant relationship between PMz.s levels and premature mortality,
aggravation of respiratory and cardiovascular disease . . . , lung disease, decreased lung
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function, asthma attacks, and certain cardiovascular problems such as heart attacks and
cardiac arrhythmia," particularly among "older adults, people with heart and lung disease,
and childre." See generally Air Quality Designations and Classifications for the Fine
Particles (PMz.s) National Ambient Air Quality Standards, 70 Fed. Reg. 944, 945 (Jan. 5,
2005) [Vol. 2, Ex. 28-e]; see also Assessment and Mitigation of Air Pollutant Health
Effects from Intra-urban Roadways: Guidance for Land Use Planning and Environmental
Review, Rajiv Bhatia and Thomas Rivard, May 6, 2008, attached as Exhibit 17. The
study by Bhatia and Rivard, in particular, elaborates on the health effects of particulate
matter exposure and the epidemiology of roadway proximity health effects, providing
guidance for assessing these effects.
The purpose of aparticulate hotspot analysis, such as the one the DEIR/S
purports to undertake, is to determine whether a project would: (a) conflict with or
obstruct implementation of an applicable air quality plan, or (b) violate the ambient air
quality standard or contribute substantially to an existing or projected air quality
violation. DEIR/S at3.I3-I9. In order to determine if a project would result in
exceedances of air quality standards, the DEIR/S must describe existing air pollutant
concentrations, identi$u the increase in emission concentrations frorn the Project, and
then rnodel the Project-related concentrations together with ambient concentrations.

Unfortunately, the DEIVS's particulate hotspot analysis is flawed. Critical

analytical details are missing altogether, while others are clearly effoneous. First, the
DEIR/S does not describe the existing environmental setting. For example, the DEIR/S
does not appear to take into account existing sources of particulate emissions in the
Project arca. Data from areas immediately adjacent to the proposed alignment are
necessary to predict local impacts.
Second, the DEIVS does not identify any of the technical data andlor
assumptions that were used to conduct the quantitative particulate hotspot dispersion
modeling. The document does not provide any specific input parameters such as specif,rc
roadways included in the model and their traffic volumes, speeds and emission rates.

Third, the DEIR/S appears to rely on faulty methodology for evaluating the
Project's particulate concentrations. While the document never actually discloses its
particulate hot spot methodology, the technical report for the DEIR/S's health risk
assessment ("HRA"), provides a reasonable amount of documentation of the input
parameters used for the mobile source air toxics ("MSAT") dispersion modeling. It is
likely that the DEIR/S preparers used the same methodology and assumptions for the

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Page2I
particulate hotspot analysis as they did for the HRA. According to Landrum & Brown,
the methodology and dataused for the MSAT dispersion modeling show that the
consultants used average daily traffic volumes and speeds in the modeling. Yet, as
discussed more fully below, the use of average data does not properly account for diurnal
variations in traffic characteristics, e.g., increased emissions during peak commute hours.
Consequently, this averaging underestimates the Project's particulate emissions and
concentrations.
Fourth, the DEIVS fails to provide any thresholds of significance for
determining whether the Project's particulate concentrations would be significant. How
high would the Project's particulate concentrations have to be in order to exceed the state
or federal ambient air quality standards? The DEIVS never identifies this critical
numerical threshold. In fact, the DEIVS never explains the results of its "analysis" at all.
While the document identifes PM1 and PM2.5 concentrations for each Project alternative
in 2025 (see Tables 3.13 .7 , 8 and 9 at page 3 .13-25), these values have no context other
than indicating that concentrations would be less than the "no-build" alternatives. Id.
CEQA is clear that the no-project alternative is not the baseline for determining whether
the proposed project's environmental impacts may be signifrcant. CEQA Guidelines
$ 15126.6. The DEIVS should have identified a threshold of significance and then
evaluated the Project's increase in particulate concentrations against a baseline of
existing conditions.

Fifth, the DEIR/S asserts that it modeled particulate concentrations at

thirteen freeway locations that arc considered "areas that are potentially of air quality
concarn" (at3.13-20), but the document never explains the effect the Project's increase in
particulate pollution would have at these locations. This information is of critical
irnportance. Members of the public who reside in homes or attend schools near these
freeway locations must be informed as to whether they could be exposed to excessive
particulate concentrations. In order to disclose the effects of the Freeway Tunnel
alternative, the specific receptor locations must be presented graphically to show the
particulate concentrations in each modeled location, along with sorne indication as to
whether these concentrations result in particulate hotspots.
Sixth, the DEIVS does not mention, let alone analyze, the Freeway Tunnel
alternative's potential to exceed California's ambient air quality standards. The flawed
analysis discussed above, relates only to the Project's potential to exceed the federal air
quality standards. The South Coast Air Basin, which is the setting for the Project, is
designated "nonattainment" of the State PM16 and PMz.s standards. DEIR/S at3.l3-7.

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California's standards for particulate matter are more protective of public health - and
therefore more stringent - than respective federal standards. See California Air
Resources Board ("CARB"), "California Ambient Air Quality Standards" available at:
15
Accordingly, it is critical that
http ://www. arb. ca. gov/research/aaq$qaaqycaq.h1m.
the DEIR/S analyze the Project's potential to violate the state standards.
For all of these reasons, the DEIVS's analysis of particulate hotspots
violates CEQA and NEPA by failing to accurately assess health impacts, thereby
precluding Proj ect approval.

3.

The DEIR/S Fails to Adequately Analyze or Mitigate the

Project's Health Risks.

(a)

The DEIR/S Substantially Underestimates the Project's

Health Risk Because the HRA Relied on Inappropriate
Methodology.

As the Landrum & Brown Air Quality Report explains, the DEIVS
substantially underestimates the Project's cancer and chronic-non-cancer risks because
the health risk assessment ("HRA"; relied on flawed methodology. First, as with the
DEIVS's particulate hot spot analysis, the HRA's dispersion modelling utilized average
variables, such as average daily trips and daily average speed, to characterizethe
Project's pollutant concentrations. In other words, the modeling assumed that each
roadway link generated the exact same amount of pollutants each hour of the day. Thus,
according to the DEIR/S, total daily emissions: average daily traffic volume X emission

tt Ambient air quality standards ("AAQS") define the maximum amount of

pollution that can be present in outdoor air without harm to the public's health. The
Federal Clean Air Act requires the U.S. EPA to set ambient air quality standards for the
nation. It also permits states to adopt additional or more protective air quality standards
if needed. The California Legislature authorized CARB to set ambient air pollution
standards for the state. Health & Safety Code section 39606. Accordingly, CARB has
set standards for certain pollutants, such as particulate matter and ozone, which are more
protective of public health than the respective federal standards. CARB has also set
standards for some pollutants that are not addressed by federal standards

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rate based on average speed. This approach is inaccurate, of course; in reality, emissions
from a roadway source vary throughout the day as traffic volumes and speeds change.

A vehicle's travelling speed affects the amount of emissions it generates.

However, emission rates are not linearly correlated with speed. For most pollutants,
emissions per mile are grea.est at low and high speeds and lower at medium speeds.
Because emission rates and speed are not linearly correlated, multiplying the average
traffic volume with an emission rate based on average speed does not result in the
average emissions. This averaging improperly minimizes a project's emissions.

An accurate prediction of emissions thus requires modeling across time of

year, day of week, and hour of the day. Here the DEIR/S's use of extremely simplified
modeling inputs - a single hourly average based on the daily average - filtered out
differences such as traff,rc volumes, speed and weather conditions. Consequently, the
DEIR/S underestimates the Project's increase in mobile soutce air toxics ("MSAT")
emissions and therefore understates the Project's potential to result in cancer and chronicnon-cancer risks.
The U.S. EPA's PMro Hotspot Guidance identifies an appropriate
methodology to model health risks (and particulate concentrations). EPA suggests that a
health risk model use four different emission factors for each highway link, one each for
the AM and PM peak periods, one for the midday period, and one for the overnight
period. We can fnd no plausible explanation why the DEIR/S did not rely on the EPA
approach. As the Landrum & Brown Air Quality Report explains, the traffic rnodel used
for the DEIVS provides AM and PM peak period traffic volumes speeds as well as
avercge daily volumes and speeds. Emission factors could easily have been developed
based on these data. The agencies' decision to rely on a methodology that understates
impacts violates CEQA. Berkeley Keep Jets Over the Bay Com. v. Bd. of Port Cmrs.
(2001) 91 Cal.App.4th 1344 ("Berkeley Keep Jets").

Equally concerning, the DEIR/S fails to take into account revisions to the
Air Toxics Hot Spots Program Risk Assessment Guidelines adopted by the Office of
Environmental HealthEazardAssessment ("OEHHA") earlier this year. See Air Toxics
Hot Spots Program, Risk Assessment Guidelines, Guidance Manual for Preparation of
Health Risk Assessments, OEHHA, February 2015, attached as Exhibit 18. The revised
guidelines recognize the Children's Environmental Health Protection Act of 1999 (Health
and Safety Code Section 39606), which requires explicit consideration of infants and
children in assessing risks from air toxics. Id. The HRA prepared for the SR 710 Project

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should consider this guidance in order to ensure that risks from the Project are properly
identifi ed and rnitigated.

(b)

The DEIR/S Fails to Disclose the Project's Potential to

Cause a Significant Increase in Cancer Risk, and Fails to

Identify Any Mitigation.

The DEIVS asserts that the Project would result in substantial regional
benefits that will reduce health risks from exposure to mobile source air toxics
("MSATs") in the majority of the study area. DEIR/S at 4-8. The DEIR/S attributes this
o'The
No Build Alternative and all the Build Alternatives would
benefit to the Project:
cause a net decrease of cancer risks compared to the 2012 existing condition everywhere
in the study area." Id. (emphasis added). But the DEIR's claim is unsupported by
evidence. In fact, evidence in the record overwhelmingly demonstrates that the Projectparticularly the Freeway Tunnel alternative-would result in a signihcant increase in
cancer risk.
The DEIR/S's technical appendix discloses that all of the freeway tunnel
alternatives could cause a localized cancer increase due to the added vehicle emissions
from the new freeway corridor and the roadways directly connected to it. Health Risk
Assessment Appendix at page 3-8. The appendix identifies the particular tunnel
alternative variants that would have the worst case localizedimpacts (dual-bore without
toll tunnel variation) and the specific locations with the largest cancer impact (a narrow
strip around the north and south tunnel portals and the adjacent interchanges). Id.,
Chapter 3. Many of these locations would result in cancer increases that greatly exceed
the SCAQMD's 10-in-1-million cancer risk significance threshold established in its Air
Toxics Hotspot Rule (Rule 140l). Id. The appendix acknowledges that the increased
cancer risk at certain locations would be a staggering 149 in I million. Id. at ES-4 and
Table 3-4.
Given the Freeway Tunnel alternative's potential to greatly irtcrease the risk
of cancer in numerous locations, the DEIR/S's assertion that it would improve health is
deeply misleading. MSATs are expected to decline substantially in the future - not as a
result of building a new freeway-based tunnel, but due to stringent environmental
regulations. EPA's 2007 rule, in particular, requires controls that will dramatically
decrease MSAT emissions through cleaner fuels and cleaner engines. DEIR/S at 3.13-31.
Accordingly, the DEIR/S errs in giving the Project credit for these improvements. Se
Neighbors for Smart Ral v. Expositon Metro Lne Const. Auth. (2013) 57 Cal4th 439,

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445,457. In fact, without the Freeway Tunnel and the substantial VMT that will
accompany it, the region's residents would likely be far healthier.
Furthermore, the lead agencies' decision to present the cancer risk
information in the DEIR/S's technical appendix is wholly improper under CEQA.
Essential information of this sort must be included the text of the EIR, not buried in some
appendix.

Finally, the DEIVS's failure to disclose the increased cancer risk

associated with the Freeway Tunnel alternative as a significant impact is yet another fatal
flaw. As a result of this error, the document fails entirely to identify rnitigation measures
capable of eliminating or offsetting these impacts, as required by CEQA and NEPA.
CEQA Guidelines $$ 15121(a);15123(bxl);see 40 C.F.R. 1502.16(h) (EIS mustdiscuss
"[m]eans to rnitigate adverse environmental impacts").
Because the DEIR/S misleads the public and decision-makers about the
Freeway Tunnel's potential to increase cancer in the region, and identifies no mitigation
for this impact, the document cannot support approval of the Freeway Tunnel alternative.

The DEIR/S Fails to Adequately Evaluate or Mitigate Impacts Related

to Climate Change.
1.

Analyzing Climate Change Impacts Is Required Under CEQA

and NEPA.

The law is clear that lead agencies must thoroughly evaluate a project's
impacts on climate change under CEQA. See Communities for a Better Env't v. City of
Rchmond (2010) 184 Cal. App. 4th 70,89-91. In2007, the state Legislature passed
Senate Bili 97, which required the Governor's Office of Planning and Research to
prepare guidelines "for the mitigation of greenhouse gas emissions or the effects of
greenhouse gas emissions as required by [CF'QA], including, but not limited to, effects
associated with transportation or energy consumption." SB 97 (2007), codified as Pub.
Res. Code $ 210S3.05 (emphasis added). Consistent with this mandate, the state Natural
Resources Agency adopted revisions to the CEQA Guidelines that require lead agencies
to determine the significance of a proposed project's greenhouse gas ("GHG") emissions
CEQA Guidelines $ 15064.4.

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Climate change is the classic example of a cumulative effects problem;

emissions from numerous sources combine to create the most pressing environmental and
societal problem of our time. See Ctr. r Biological Diversty v. Nat'l Highway Trffic
Safety Admin. (9th Cir. 2003) 53I F.3d 1172, l2l7 ("the irnpact of greenhouse gas
emissions on climate change is precisely the kind of cumulative impacts analysis that
NEPA requires agencies to conduct."); Kngs County Farm Bureau v. City of Hanrd
(1990) 22I Cal.App.3d 692,720 ("Perhaps the best example fof a cumulative impact] is
air pollution, where thousands of relatively small sources of pollution cause serious a
serious environmental health problem."). If an agency's analysis indicates thata
proposed project will have a significant project-speciflrc or cumulative impact on climate
change, the agency must identiff and adopt feasible mitigation measures to address this
impact. CEQA Guidelines $ 15126,4(c).

NEPA also requires an analysis of the Project's GHG emissions. Ctr. r

Biological Diversity, 538 F.3d at l2l7 (NEPA requires agencies to assess impacts of
project on GHG emissions); Earth Island Institute, 351 F.3d at 1300 (NEPA requires that
federal agencies "consider every significant aspect of the environmental impact of a
proposed action . . . .") (emphasis added) (citations omitted). The President's Council on
Environmental Quality has issued draft guidance on analyzingthis issue under NEPA.
,See December 18, 2014, Revised Draft NEPA Guidance on Consideration of the Effects
of Climate Change and Greenhouse Gas Emissions, attached as Exhibit 19. This
document recognizes that during the NEPA process, agencies should consider both "the
potential effects of a proposed action on climate change as indicated by its GHG
emissions" and o'the implications of clirnate change for the environmental effects of a
proposed action." Id. atFF.77824. Specifcally, the proposed regulations require that
agencies analyze a project's GHG emissions and consider reasonable mitigation measures
and alternatives to lower the level of the potential GHG emissions. See generally, id.
Agencies are not excused from analyzingimpacts from GHG emissions just because
these regulations are not yet in effect; instead, as the draft document states, the new
regulations are "on par with the consideration of any other environmental effects and this
guidance is designed to be implemented without requiring agencies to develop new
NEPA implementing procedures." Id. atFPt77824. The draft document also urges
agencies to make a determination as to whether emissions from a project are consistent
with relevant emissions targets and reduction goals, and specifically references
California's AB 32 as an example. Id. at FR 77826.

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The DEIR/S's Perfunctory Climate Change Analysis Fails to

Inform the Public and Decision-makers About the Freeway
Tunnel Alternative's Greenhouse Gas Emissions.

The DEIVS is seriously flawed because ittrivializes the Project's

contribution to climate change, particularly that of the Freeway Tunnel alternative. The
DEIR/S labels impacts due to climate change as o'speculative" and then fails to conduct
an adequate analysis of these potential impacts. However, the Freeway Tunnel
alternative's GHG emissions from construction activities, increased VMT, and energy
use are far from speculative. As detailed below, the DEIR/S's failure to properly assess
the Freeway Tunnel's significant impacts on global climate change, and to identifu
enforceable mitigation for them, is fatal.
The United States Supreme Court has noted that "[t]he harms associated
with climate change are serious and well recognized." Massachusetts v. EPA (2007) 549
tJ.5. 497 ,499. Reducing greenhouse gas emissions in order to limit these harms is one of
the most urgent challenges of our time. In recognition of this urgency, in 2005, Governor
Schwarzenegger's signed Executive Order S-3-05. The order established a long-term
goal of reducing California's emissions to 80 percent below 1990 levels by 2050. The
order also directed several state agencies (collectively known as the "Climate Action
Team") to carry its goals forward. The following year, the Legislature enacted the Global
Warming Solutions Act of 2006 ("AB 32"), codihed at Health and Safety Code $ 38500,
et seq. By these authorities, California has committed to reducing emissions to 1990
levels by 2020, and to 80 percent below 1990 levels by 2050. Most recently, Governor
Brown took further action to meet this challenge by issuing a new executive order, B-3015. It sets an interim target of 40 percent below 1990 levels by the year 2030. This
order, like EO S-3-05, is binding on state agencies such as Caltrans.
The California Climate Action Team's 2009 Repofi to Governor
Schwarzenegger details the science behind, and the environmental impacts of, global
warming.i6 This report makes clear that the release of greenhouse gases into the
tu

California Environmental Protection Agency, Climate Action Team

Biennial Report to Governor Schwarzeegg and the Legislature, December 2010,
available athttp:llwww.climatechange.ca.gov/clirnate_action_team/reports/#2010. The
entire Report is incorporated herein by reference.
Suu

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atmosphere leads to global warming, which in turn leads to rnyriad environmental

impacts. As the report explains, "fc]limate change poses serious risks to California's
natural resources. California-specific impacts are expected to include changes in
temperature, precipitation patterns, and water availability, as well as rising sea levels and
altered coastal conditions."

Despite all of this-the scientifc consensus, the potentially catastrophic

impacts on the State, and California's well-founded commitrnent to reducing emissionsthe DEIR/S's climate change analysis is perfunctory. It fails to determine a threshold of
significance, it calculates only a portion of the GHG emissions for which the Project
alternatives will be responsible, and then it ignores its obligation to deterrnine whether
the impact is significant. It thus fails to satisff the most basic purpose of an EIR/EIS: to
disclose to decision-makers and the public a project's significant environmental impacts.
See Pub. Res. Code $ 21061 ("The purpose of an environmental irnpact report is to
provide public agencies and the public in general with detailed information about the
effect that a proposed project is likely to have on the environment"); 40 C.F.R.
$ 1500.1(b) ("NEPA procedures must insure that environmental information is available
to public officials and citizens before decisions are made and before actions are taken.").

Having avoided its obligation to make a significance determination, as

CEQA and NEPA require, the DEIVS then fails to identiff credible mitigation measures
to reduce or avoid the Project's contributions to global warming. This approach, which
ignores science and law, stands in stark contrast to the conscientious treatment of global
warming impacts undertaken by other lead agencies throughout the state. The agencies
must make substantial modifcations to the DEIR/S's clirnate change analysis to achieve
compliance with CEQA and NEPA.

3.

The DEIWS's Refusal to Make a Significance Determination

Regarding the Project's Contribution to Climate Change Is

Unlawful.
The DEIR/S contains no thresholds of significance for the Project's
potential impacts on climate change. Instead, the DEIR/S states that "in the absence of
further regulatory scientific information related to GHG emissions and CEQA
significance, it is too speculative" to make a significance determination. DEIVS at 4102. This approach is unlawful, as the statute expressly requires a lead agency to
determine if a project's irnpacts are signifcant. Pub. Res. Code $ 21002. 1(a) ("The
purpose of an environmental impact report is to identiff the significant effects on the

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environment of a project. . . ."). Accordingly, the CEQA Guidelines require agencies to

"make a good-faith effort . . . to describe, calculate or estimate the amount of greenhouse
gas ernissions resulting from a project." CEQA Guidelines $ 15064.4. The Guidelines
also include a section entitled "Determining the Significance of Impacts from
Greenhouse Gas Emissions." Id. There is nothing in CEQA that relieves a lead agency
from its obligation to determine significant effects simply because the impact is related to
a rapidly-evolving area of science and policy . See Protect the Historc Amador
l4/aterways v. Amador Water Agency (2004) 116 Cal.App.4th 1099,1106-12 (CEQA
o'speculative" based on lack of
does not allow irrpact analysis to be labeled too
threshold) . See a/so CEQA Guidelines $ i5065 (entitled "Mandatory Findings of
Significance") (emphasis added). Thus, there is no justification for the DEIR/S's failure
to contain a significance finding for GHG emissions.

CEQA Guidelines section 15064,4(aX1) & (2) provides two methods for
making a significance determination related to GHG emissions. An agency may either:
(1) use "a model or methodology to quantify greenhouse gas emissions
resulting from a project . . . fthat] it considers most appropriate provided it
supports its decision with substantial evidence," or

(2) "[r]ely on a qualitative analysis or performance based standard []."

The DEIVS follows neither approach here, opting to make no significance determination
at all. The Guidelines do not sanction such approach.

Deterrnining whether a project may have a significant effect plays a critical

role in the CEQA and NEPA processes, and this determination must be "based to the
extent possible on scientific and factual data." CEQA Guideline $ 1506a(a) and (b).
Accordingly, a significance threshold for greenhouse gases must reflect the grave threats
posed by the cumulative impact of adding new sources of GHG emissions into an
environment when deep reductions from existing emission levels are necessary to avert
the worst consequences of global warming. See Center for Biological Diversity,508 F.3d
at 550 ("we cannot afford to ignore even modest contributions to global warming.").
Although the CEQA Guidelines do not prescribe a particular methodology
for making the signifcance determination, other agencies and groups have established

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rnethodologies, and their analysis may be useful for Caltrans. The California Air
Pollution Control Officers Association ("CAPCO4::r7 has issued a "CEQA & Climate
Change" white paper to assist lead agencies in analyzing greenhouse gas impacts under
CEQA. Se Exhibit2}. Noting that "the absence of an adopted threshold does not
relieve the agency frorn the obligation to determine significartce" of a project's impacts
on climate change, CAPCOA explored various approaches to determining significance
and then evaluated the effectiveness of each approach. ,See Exhibit2}. According to
CAPCOA's analysis, the only two thresholds that are highly effective at reducing
emissions and highly consistent with AB 32 and Executive Order 5-3-05 are a threshold
of zero o. u quutrtitative threshold of 900-tons CO2 Equivalent ("CO2 eq.")t8. Id. A zero
threshold is preferable in light of ongoing scientific advances showing that global
warming is more significant than originally anticipated. For example, even the ambitious
emissions reduction targets set by Executive Order S-3-05 in 2005, which were consistent
with contemporaneous science indicating that this level of reductions by developed
countries would be sufficient to stabilize the climate, are now believed to be insufficient.
Given the recent extrerne losses in arctic sea ice, scientists at the National Snow and Ice
Data Center have concluded that the observed changes in the arctic indicate that this
feedback loop is now stafiing to take hold.re
Based on these and other recent climate change observations, leading
scientists now agree that "humanity must aim for an even lower level of GHGs."2O Thus,
the scientific and factual data now support a threshold of significance of zerc in order to
17

CAPCOA is an association of air pollution control officers representing

all local air quality agencies and air districts in California.
18

Carbon dioxide equivalents (CO2 eq.) provide a universal standard of

measurement against which the impacts of releasing different greenhouse gases can be
evaluated. As the base unit, carbon dioxide's numeric value is 1.0 while other fitore
potent greenhouse gases have a higher numeric value.

t'

Suu

Oct. 3, 2006 press release by National Snow and Ice Data Center,

available at:
http ://nsidc.org/news/newsrooml2006 seaicemi nirnum/2O061
document is incorporated herein by reference.

nressrelease.html. This

'0 Ja-es Hansen et al,, Target Atmospheric CO2: Where Should Humanity
Am? 2 OpenArlrospseRlc ScI. J.217,226 (2008).

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ensure that new projects do not have a cumulatively significant impact on global
warming. Consistent with this data, many EIRs have adopted a zero threshold of
significance as the most scientifically supportable threshold. See, e.g., San Francisco
Metropolitan Transportation Commission, Transportation 2035 Plan DEIR, at2.5-15,
SCH # 2008022101 (project would have a significant impact if it resulted in an increase
in CO2 eq. emissions from on-road mobile sources compared to existing conditions); San
Francisco Metropolitan Transportation Commission & Association of Bay Area
Governments, Plan Bay Area 2040 DEIR, at2.5-41, SCH # 2012062029 (project would
have a potentially significant impact if it wouid result in a net increase in direct and
indirect GHG emissions in2040 when compared to existing conditions). These
examples, and others, demonstrate that, contrary to this DEIVS's assertion, it is feasible
to establish thresholds of significance.

The Bay Area Air Quality Management District ("BAAQMD") has also
adopted guidelines to establish thresholds for GHG emissions. See BAAQMD Air
Quality Guidelines, excerpts attached as Exhibit 21. These thresholds establish 1,100
metric tons of CO2 eq. as the standard for most new development, and no net ncrease in
emissions for transportation and other regional plans. Id. atpp.2-I to 2-4.

Although the DEIVS fails to make a significance determination, it offers

minimal, unsupported data purporting to demonstrate that the Project, including even the
Freeway Tunnel alternative, would actually reduce GHG emissions. DEIR/S at 4-98 to
4-100. The DEIR/S preparers may have intended that these data show the Project would
not result in significant impacts to climate change, yet the paltry analysis is insufficient
for a true significance determination and, in any event, is faulty itselt as described below
Pub. Res. Code $ 15064( (significance determination must "be based on substantial
evidence in the record").

4.

The DEIR/S's Claim That the Project Will Reduce Greenhouse

Gas Emissions Is Flawed.

The DEIVS concludes that all of the Project's build alternativesincluding construction of 4,2 new miles of an eight-lane freeway-will actually reduce
vehicle emissions, and therefore GHG emissions. DEIR/S at 4-98 to -99. This
conclusion is contradicted by current transportation research and is also unsupported by
substantial evidence in the record. As the DEIR/S acknowledges, total VMT will
increase in the Project area as a result of all of the tunnel alternatives by as many 460,000
DEIVS Transportation Technical Report Table 4-8 atpg.,4-15. Per
miles per day.
^9ee

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capitavMT also increases with all freeway tunnel alternatives. Id. These impacts
directly contradict, or undermine, State and regional efforts to reduce GHG emissions,
the increase in VMT from operation of the Freeway Tunnel will lead to substantial
increases in emissions.

as

The link between increased VMT and increased GHG emissions is wellestablished. Studies show how the nation's increase in VMT is projected to overwhelm
planned improvements in vehicle efficiency, thus making reductions in GHG emissions
impossible without concomitant reductions in VMT. See Growing Cooler: Evidence on
Urban Development and Clirnate Change at 3, excerpts attached asBxhibit22.
Recognizing the nation's unsustainable growth in driving, the American Association of
State Highway and Transportation Off,rcials, representing state departments of
transportation, has urged that the growth of VMT be cut in half. Id. Under these
circumstances, the DEIR/S's contention that the Freeway Tunnel will result in reduced
GHG emissions is sirnply untenable.
The DEIR/S attempts to circumvent the well-established link between
increased VMT and increased GHG emissions by concluding that purported reductions in
congestion resulting from the Project will reduce the amount of fuel that vehicles waste in
stop-and-go traffic, leading to reduced emissions of climate-warming gases from cars and
trucks. DEIR/S at 4-98. Yet, as the attached Sightline Institute article explains, this
claim - which is frequently used by proponents of road-building - is mistaken. See
"Increases in Greenhouse-gas Emissions From Highway-widening Projects," Sightline
Institute, October 2007 , attached as Exhibit 23. In fact, under almost any set of plausible
assumptions, increasing highway capacity in a congested urban area will substantially
increase long-term GHG emissions. 1d Over the short term-perhaps 5 to 10 years after
new lanes are opened to traffic-the DEIVS's conclusion may find some support. But
the docurnent's prediction of congestion reduction fails over the long terrn. ,See Nelson
Nygaard Report. Considering the full increase in emissions from highway construction
and additional VMT, experts at Sightline conclude that adding one mile of new highway
lane will increase CO2 eq. emissions by more than 100,000 tons over 50 years. Id.

This research is corroborated by the Surface Transportation Policy Project

("STPP"). The STPP cites a growing body of research showing that, in the long run,
wider highways actually create additional traffic, above and beyond what can be
attributed to population increases and economic growth. ,See Surface Transportation
Policy Project, Build It and They'11 Come, attached as Exhibit 24. According to the
STPP, 100 percent of additional VMT in Los Angeles County, and72.6 percent of
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additional VMT in San Diego County, is attributable to "induced traffic." Id. This
neans that increases in highway capacity actually induces additional traffic-it does not
simply "accommodate" existing or predicted traffic.
CARB has also now weighed in on the relationship between increases in
highway capacity, induced travel and increased GHG emissions. In its recent report
entitledoolmpact of Highway Capacity and Induced Travel on Passenger Vehicle Use and
Greenhouse Gas Emissions," CARB further confirms that increased capacity induces
additional VMT." ,Se ExhibitT at 3. CARB attributes this phenomenon to the basic
economic principles of supply and demand: adding capacity decreases travel time, in
effect lowering the "price" of driving; when prices go down, the quantity of driving goes
up (Noland and Lem, 2002). Id. As CARB explains, "[a]ny induced travel that occurs
reduces the effectiveness of capacity expansion as a strategy for alleviating traffic
congestion and ofets any reductions in GHG emissions that would result from reduced
congestion

." Id. at 2.

Accordingly, while agencies generally have discretion to choose

appropriate methodological approaches under CEQA and NEPA, the DEIR/S appears to
ignore mounting evidence that building highway capacity induces traffltc, thereby
increasing emissions. As the Nelson Nygaard Report on transportation explains, the
DEIR/S's traffic dernand model does not disclose the assumptions it uses to calculate
induced demand and likely understates true induced demand. Furtherrnore, the dernand
model inaccurately forecasts traff,rc volumes on a segment-by-segment basis, meaning
that it cannot be trusted to accurately estimate induced travel. ,See Nelson Nygaard
Report. Moreover, the DEIVS analyzes traffic demand only through 2035-that is,
during the short-term window when congestion may actually be reduced. It does not
analyze impacts during the period following 2035 when the purported efficiency gains,
any, can be expected to dissipate as a result of induced demand. Id.

if

A third-party audit of Caltrans recently conducted by the State Smart

Transportation Initiative specif,rcally faulted Caltrans' approach to induced demand,
finding that "the department has not come to grips with the reality of induced traffic."
,See State Smart Transportation Initiative Assessment and Recommendations California
Department of Transportation, January 2014 at iv, attached as Exhibit 25. The auditors
concluded that Caltrans has almost completely ignored important recommendations
(including for reducing VMT) contained in its own Smart Mobilty 2010 report. Id. atv.
The audit went on to say that "despite a rich literature on induced demand, [Caltrans
employees] frequently disrnissed the phenomenon." Id. at 62. Given Caltrans' history of

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ignoring or downplaying induced traffr,c, it is especially important that the DEIVS

support its prediction of induced demand with substantial evidence. It has failed to do so.

Finally, the DEIR/S's calculation of the Project's future emissions assumes

that future regulatory controls will be imposed and will be effective in reducing tailpipe
emissions. Landrum & Brown Air Quality Report (EMFAC2011 modeling included
assurnption that low carbon fuel standards would be implemented). The document thus
compares future conditions to existing conditions without providing an independent
measure of the Project's impacts. In this manner, the DEIR/S effectively assigns the
Project credit for technological and regulatory advances that will occur regardless of its
irnplementation. Because the DEIVS thus fails to disclose the full climate irnpacts of the
Project's increase in VMT, it violates CEQA and NEPA. Indeed, this Project serves as a
cautionary example of how statewide improvements in emissions reductions due to
regulatory measures-such as California's low carbon fuel standard-can be erased by
increases in VMT.2I
5.

The DEIR/S Fails to Account for Non-Vehicular Sources of

Greenhouse Gas Emissions From the Project.

The GHG emissions calculations presented in the Air Quality Assessment

Report and the DEIVS include only those ernitted from vehicles driving within the study
area, and fail to recognize that the Project will contribute to GHG emissions through
other sources. For example, electricity generated for use by the Project will also create
GHG emissions. SeeLandrum & Brown Air Quality Report. The Freeway Tunnel
alternative would consume electricity for tunnel lighting and the tunnel ventilation
system. This could result in considerable GHG emissions that should have been included
in the Project's GHG emissions' inventory. The LRT would consume the most electricity
of the build alternatives, as it relies on electrically-powered railcars. Failure to include
the GHG emissions associated with electricity generation for the LRT alternative in the
DEIVS's reported GHG emissions is a particularly egregious omission.

21

Experts have pointed out that increases in the amount of driving cause
CO2 emissions to rise despite technological advances, because the growth in driving
overwhelms planned improvernents in vehicle efficiency and fuel carbon content.
Growing Cooler: Evidence on lJrban Development and Climate Change at l3-I4.

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The Landrum & Brown Air Quality Report estimates that the electricity
consumption required for propulsion of the railcars for the LRT alternative would
generate between 65 and 170 metric tons of CO2 eQ. per day, equivalent to approximately
23,400 and 61,700 metric tons of CO2 ee. per year. These fi.gures do not include
electricity consumed by other components of the LRT alternative, such as lighting and
ventilation. The DEIWS anticipates that the LRT alternative would reduce vehicular
emissions by 20.0 metric tons per day in the2025 opening year and by 2,2 metric tons
per day in2035. DEIR/S at 4-100. For the LRT alternative, this means that increased
GHG emissions due to electrical generation would outweigh the anticipated reductions in
GHG emissions from vehicular travel. It is irrelevant that some of the emissions from
new electrical generation might come from outside the Project area; because GHG
emissions are a cumulative global effect, the location of the sources of emissions is not
important.

To evaluate the Project's actual effect on climate change, the DEIR/S must
inventory the carbon emissions generated through non-vehicular means. This should
include electricity generation for the Project, and also the manufacturing and lifecycle of
the Project's building materials. Without an inventory of these additional emissions, the
DEIVS's analysis is incomplete, making the formulation of appropriate mitigation
impossible

6.

The DEIWS Must Calculate Greenhouse Gas Emissions From

the Project Through 2050.

The DEIR/S calculates fuel consumption and related carbon emissions only
to the year 2035. See DEIR/S at 4-100. This time horizon fails to provide the public with
a meaningful assessment of the Project's long-term impacts. Indeed, the dual-bore
freeway tunnel alternative is not scheduled to be cornpleted until after 2020, and that is
assuming that it stays on schedule. Id. (calculating emissions for the Freeway Tunnel
alternative only from operational year 2025 onward). As a result, the document considers
at rnost only 15 years' worth of emissions-a small fraction of the expected lifetime of
the Project.22 The DEIR/S should have analyzed GHG emissions through the year 2050.

" Although

the

DEIVS's description of the Project is inexplicably silent on

its expected lifetime, Metro's Cost Beneft Analysis for the Project states that the tunnels
(footnote continued on next page)

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'Without

examining impacts through the year 2050, the DEIR/S cannot

provide meaningful assessment of the Project's long-term impacts, particularly those of
the Freeway Tunnel. And there is reason to believe that these long-term impacts will be
more signiflrcant than in the short term. As described previously, CARB's report states
that increases in highway capacity induce travel, which, in turn reduces the effectiveness
of capacity expansion as a strategy for alleviating traffic congestion. Exhibit 7 (Impact of
Highway Capacity and Induced Travel on Passenger Vehicle Use and Greenhouse Gas
Emissions). This induced growth offsets any reductions in GHG emissions that would
result from improved traffic flow. Id. Therefore, over the long term, increases in
highway capacity will result in increased GHG emissions. This phenomenon is not
captured by the DEIVS's analysis, which looks, at most, only 15 years beyond the
completion date of the dual-bore freeway tunnel alternative.

Tellingly, the DEIR/S does provide some evidence that emissions will
increase after the 2035 end-date. The document states that in 2025, the GHG emissions
from the Freeway Tunnel alternative (dual-bore freervay tunnel with tolls) would decline
by 35.7 metric tons per day compared to existing conditions. DEM at 4-100. In2035,
however, the Project's GHG emissions would creep upwards, resulting in a decline of
only 24.2 metric tons per day cornpared to existing conditions. Id. (In fact, this decline
in purported reductions is estimated to occur for all of the freeway alternatives.) In other
words, the Freeway Tunnel aiternative does not appear to result in sustained GHG
emission reductions; the opposite appears to be true. But because the DEIR/S does not
analyze 2050 conditions, the public has no way of knowing the extent of the Freeway
Tunnel's long term increase in GHG emissions.
Analysis of the Project's impacts in 2050 is essential to determining if the
Project achieves the long-term emissions reductions needed for climate stabilization and
required by EO S-3-05, B-30-15, and AB 32. The statewide reduction goals set forth in
EO 5-3-05 and AB 32 call for reducing emissions levels to 80 percent below 1990 levels
by the year 2050. Accordingly, 2050 is the appropriate planning horizon for analyzing
the Project' s emissions.

(footnote continued from previous page)

are expected to have a lifetime of 100 years. Analysis of Costs and Benefits for the State
Route 710 North Study Alternatives at 2-8.

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The DEIR/S Fails to Analyze the Project's Consistency with

Applicable State Plans and Policies for Greenhouse Gas
Emissions Reductions.

The DEIR/S fails to analyze the Project's consistency with the state's plans
and policies for reducing GHG emissions. In fact, the document barely mentions these
critical plans. It merely lists eight state bills and executive orders aimed at reducing
GHG emissions in bullet-point format under the heading "Regulatory Setting - State"
(DEIR/S at 4-95); it provides no discussion or analysis of whether the Project is
consistent with these rnandates, or whether it will help the State meet the reduction
targets that they prescribe. The DEIR/S cannot ignore the question of whether its
emissions trajectory is consistent with the trajectory embodied in EO 5-3-05 , the AB 32
Scoping Plan, and the First Update to the Scoping Plan. These are based on the scientific
consensus that "the 2050 [reduction] target represents the level of greenhouse gas
emissions that advanced economies must reach if the climate is to be stabilized in the
latter.half of the 21st century." Climate Change Scoping Plan: A Framework for Change
(2008), p, ll7, attached as Exhibit 26.23

California climate policy, as reflected in EO S-3-05, requires reducing

GHG emissions to 80 percent below 1990 levels by 2050 so as to avoid catastrophic
climate impacts. This Executive Order embodies the reductions that climate scientists
have concluded are needed to provide a 50-50 chance of limiting global average
temperature rise to 2"C above pre-industrial levels. The AB 32 Scoping Plan incorporates
this goal, establishin g a "trajectory" for reaching it over time. Exhibit 26 at 15 (Climate
Change Scoping Plan: A Framework for Change (2008)).
In May 2014, CARB approved an Update to the Scoping Plan that
examines California's progress toward meeting the "near-term" 2020 GHG emission
reduction goals defined in the initial Scoping Plan. First Update to the Climate Change
Scoping Pian: Building on the Framework ,2014, attached as Exhibit 27 ,24 It also

" S also full scoping plan at

hltp://r.vrvw.arb.ca.gov/cclscopingplan/document/ adoptecl_scopingJlan.pdf (referencing

the 2050 reduction goals throughout the document)

'o The full update is available at

d

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evaluates how to align the State's "longer-term" GHG reduction strategies with other
State policy priorities for water, waste, natural resources, clean energy, transportation,
and land use. Additionally, on April 29,2015, Governor Brown signed Executive Order
B-30-15, which sets an interim target in order to help state agencies achieve California's
redr.rctions goals. This interim target calls for reductions in GHG emissions to 40 percent
below 1990 levels by the year 2030. EO B-30-15. This newest executive order confirms
that GHG emissions reductions are a top state priority and that interim targets are crucial
for achieving the 2050 reductions goal.

Meeting the statewide 2050 trajectory requires continuing and steady

annual reductions in both total and per capita emissions. Climate Change Scoping Plan, p.
E,S-1. Because state policy aims to reduce GHG emissions over time, it is imperative that
environmental review documents inform the public and decision-makers whether a
project will advance or impede the state's reduction goals, and how. As the California
Supreme Court has held, an agency "abuses its discretion if it exercises it in a manner
that causes an EIR's analysis to be misleading or without informational value."
Neighbors for Smart Rail, 57 CaI.4th at 445,457.

Accordingly, the DEIR/S should have included a climate change analysis

discussing whether the Project: (1) is consistent with these policies, (2) will help advance
these policies, or (3) will impede the achievement of these policies. In addition, it should
have used the EO 5-3-05 trajectory as a threshold of significance in evaluating the
Project's environmental impacts, See Friends of Orovlle,2l9 Cal.App.4th at 841 (AB
32's reduction targets were a proper threshold of significance in determining whether the
Project's GHG emissions constituted a significant impact).
As lead agency, Caltrans must consider statewide climate policy. As the
DEIR/S acknowledges, Caltrans' parent agency, the California State Transportation
Agency, is a member of the Governor's Climate Action Team, which is charged with
coordinating and carrying forward the state's climate goals established in EO 5-3-05 and
AB 32. Although the DEIR/S mentions this fact, the document provides no analysis of
the Project's consistency with these goals.

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8.

The DEIR/S Fails to Include Bnforceable, Feasible Measures to

Mitigate or Offset the Project's Greenhouse Gas Impacts Even
Though Such Measures Exist.

Had the DEIR/S established a threshold of significance, as required under

CEQA and NEPA, and properly accounted for emissions generated by the Project,
particularly the Freeway Tunnel, including emissions from induced traffr.c, it would have
found that Project-generated emissions and cumulative emissions exceed all of the
potential thresholds of significance discussed above. The Freeway Tunnel's contribution
to climate change must therefore be considered significant.
The DEIR/S makes only a halfirearted attempt to identify feasible
mitigation measures for the Project's climate change impacts. For construction-related
GHG emissions, which it estimates could exceed 48,000 metric tons of CO2 eq. for the
Freeway Tunnel, the DEIVS appears to suggest that it rnay rely on measures intended to
mitigate the Project's air quality impacts. But the document is confusing on this point. A
reader rnight infer this reliance from one line of a table in the Executive Summary, listing
air quality mitigation measures AQ-l through AQ-5 as the rnitigation for constructionrelated climate impacts. DEIR/S at ES-40. Yet, the DEITVS does not identi$' these
measures anywhere in the two-paragraph discussion that constitutes the docutnent's
entire analysis of construction-related GHG emissions. Id. at 4-101. This confusing,
contradictory approach is impermissible under CEQA. The DEIR/S must identiff
specific, enforceable rnitigation measures and describe how, and to what extent, they are
expected to avoid or rninimizethe Project's construction-related GHG irnpacts. Pub.
Res. Code $ 2108i.6(b); CEQA Guidelines $ 15126.a@)Q).
Even more troublesome, the DEIVS does not propose any mitigation for
the Project's operational impacts to climate change. See DEIfuS at ES-40 ("No measures
are proposed."). Instead, it suggests that the Project will incorporate three apparently
voluntary reduction measures to reduce these impacts: (1) using landscaping; (2)
recornmending energy-efficient lighting; and (3) restricting idling time during laneclosure for construction. Id. at 4-103-104.
The proposed voluntary "reduction measures" are unlawful because they
are hortatory rather than binding commitments. Under CEQA, mitigation measures must
be "fully enforceable" through permit conditions, agreerents, or other legally binding
instruments. Pub. Res. Code $ 21081.6(b); CEQA Guidelines $ 15126.a@)Q).
Similarly, CEQA and NEPA require that any proposed mitigation must provide assurance

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that such implementation will in fact occur. Anderson First Coalition v. City of Anderson
(2005)130 Cal.App.4th 1173,1186-87; Fed'n of Hllside & Canyon Ass'ns v. City of Los
Angeles (2000) 83 Cal.App.4th 1252,1261; South Fork Band Council of W. Shoshone of
Nevada,588 F.3d af 727 (NEPA requires discussion of whether mitigation will actually
be effective). Moreover, a conclusion that ameasure will be effective in mitigating an
impact must be supported by substantial evidence-evidence that is lacking here. Gray
v. County of Madera (2003) 167 Cal.App.4th 1099, 1 1 1 5- 1 8; see also San Francscans
for Reasonable Growthv. Cty & County of San Francisco (1984)151 Cal.App.3d 61,79
(measures must not be so vague that it is impossible to gauge their effectiveness). The
DEIR/S's proposed mitigation does not come close to rneeting these standards.
The DEIVS's paltry selection of mitigation measures is puzzling, as there
is an impressive affay of obvious measures that could actually reduce the Project's GHG
emissions. Numerous mitigation measures are detailed in Appendix B and C to the 2008
CAPCOA report, attached as Exhibit 20, and the SR 710 North DEIR/S must consider all
feasible, applicable measures therein. Most importantly, it rnust consider the following
sampling:

Requiring that off-road diesel-powered vehicles used for construction be

new low-emission vehicles or use retrof,rt emission control devices such as
diesel oxidation catalysts and diesel particulate filters verified by CARB.

Requiring the Project to generate all or a portion of its own power through
alternative means, such as photovoltaic arrays.

Requiring use of a catalyzed diesel particulate filter on both new and

existing diesel engines (because black carbon is a component of diesel
particulate matter, strategies that reduce particulate matter will also reduce
black carbon).

Minimizing and recycling construction-related waste.

Using salvaged and recycled-content materials for hard surfaces and nonplant landscaping materials.

Maximizing water conservation measures in landscaping, using droughttolerant plants in lieu of turt planting shade trees.

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Landscaping to preserve natural vegetation and maintain watershed

integrity.

Utilizingthe combination of construction materials with the lowest carbon

footprint.

Requiring the use of "cool pavement" that reflects more solar energy. Such
measures, which can markedly reduce heat islands, have been used
effectively in California and elsewhere. In fact, new building standards in
California, called "CalGreen", will require use of such pavement in certain
instances. See http.llwww.arb.ca.gov/research/serninars/gilbert/gilbert.pdf
for a complete description of cool pavement issues, technology and use.

result in direct reductions in GHG emissions

that would otherwise be attributable to the Project. In addition, through a combination of
other on-site and off-site measures, the agencies could require all aspects of the Project to
be "carbon neutral." An important aspect of such mitigation would be the adoption of an
off-set requirement for any reductions that could not be achieved directly. CEQA and
NEPA specifically envision such offsets for the mitigation of GHG emissions. CEQA
Guidelines g 15126.a@)Q) ("Measures to mitigate the significant effects of greenhouse
gas emissions may include . . . [o]fsite measures, including offsets that are not
otherwise required"); December 18,2014, Revised Draft NEPA Guidance on
Consideration of the Effects of Climate Change and Greenhouse Gas Emissions, attached
as Exhibit 19 at FR 71828. Emissions could be offset either through financial
contributions to sustainable energy projects or through the purchase of carbon credits.
Such programs are increasingly common and thus raise no issue of infeasibility.

All of these measures would

In sum, development of the Project, specifically the Freeway Tunnel, will

make it more difficult for the State to meet its commitments to reduce GHG emissions.
To comply with applicable law, the DEIR/S was required to, but did not, include: (1) a
complete and adequate inventory of the Project's greenhouse gas emissions, including
those from induced traff,rc; (2) a significance determination regarding the Project's
cumulative climate impacts; (3) an analysis of the Project's consistency with state climate
policy; and (4) a thorough and quantitative analysis of rnitigation measures to reduce
impacts. The agencies cannot lawfully approve the Project in the absence of this
analysis.

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C.

The DEIR/S's Analysis of and Mitigation for the Project's Impacts on

Transportation Are Inadequate.

1.

The DEIR/S's Traffic Analysis Does Not Adequately Analyze the

Freeway Tunnel Alternative's Traffic Impacts.

The DEIVS fails to disclose the traffic impacts that would actually occur as
a result of the Freeway Tunnel alternative. The DEIVS demonstrates that rather than
resolve regional traffrc congestion, the Freeway Tunnel alternative would cause
bottlenecks to shift between locations. Yet, as the Nelson Nygaard Report explains, the
EIVS's travel demand model is incapable of propey analyzing how these bottlenecks
function.
Numerous segments along the I-10, SR 134,I-210, I-5 andl-710 would
operate at Level of Service (LOS) F in 2035 under the Freeway Tunnel alternative . See
Nelson Nygaard Report, Figure 7. This means that the modeled demand is far greater
than the traffc volume that can actually travel across these freeway segments. When
demand exceeds capacity, the Highway CapacQ Manual requires that the excess volume
"spill over into adjacent upstream segments" and be accumulated unless demand drops
enough that the bottleneck can clear. This phenomenon is referred to as "spillback."
Unfortunately, the EM model does not account for this spillback. Instead, it
mistakenly assurnes that all modeled vehicles will get through the bottleneck. If the
DEIR/S's traffic demand forecast had been accurate, it would have shown that traffic
begins spilling back at J a.m. and the queue gets longer and longer during the day,
eventually reaching 3 hours in length. It would take much longer than 3 hours for such a
queue to clear because vehicles would continue to arrive after 7 p.m.
The DEIVS's failure to recognize the potential for this extensive traffic
congestion is a serious flaw. As a case in point, in the a.m. peak period under the No
Build alternative, the northbound section of I-710 at I-10 is modeled as the 280th most
congested freeway segment in the greater Los Angeles region. In the Dual-Bore Tunnel
alternative, this segment moves up the list 256 places to become the 24th most congested
freeway segment in the region. Nevertheless, the DEIR/S assumes the increase in travel

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time on this segment is only one minute relative to the No Build alternative. Clearly,
sizeable traffic bottleneck produces more than one minute of delay.25

This flaw in the DEIR/S's travel demand model calls into question the
accuracy of the entire traffc irnpact analysis. For example, it is highly unlikely that the
DEIVS accurately estimates the Project's induced travel. The flawed traffic analysis
also irnplicates the DEIVS's analysis of environmental irnpacts. The DEIR/S's estimates
for criteria pollutants, air toxics, and greenhouse gas emissions, for example, are
predicated on an accurate accounting of the volume and nature of traffic operations. The
DEIVS's failure to accurately document how the Freeway Tunnel alternative will affect
regional traffic undermines the accuracy of these other analyses.

2.

The DEIR/S Relies on an ArtifTcially Constrained Study Area

and Therefore Fails to Identify All of the Project's
Transportation Impacts.

The DEIVS chooses certain freeway segments near SR 710 to establish the
study area over which to conduct a detailed transportation analysis. Yet, the study area
does not include ail of the potentially impacted highways and interchanges. Cars and
trucks do not stop at arbitrary locations identified on a map; numerous vehicles that will
be affected by the Project will travel to and from destinations outside the study area. The
California Supreme Court emphasized that an EIR may not ignore a project's regional
impacts, including those occurring outside of its borders; on the contrary, a regional
perspective is requir ed." Ctizens of Goleta Valley v. Board of Supervisors (1990) 52
Ca1.3d 553,575. Rather, an EIR must analyze environmental impacts over the entire area
where one might reasonably expect these impacts to occur. See Kings County Farm
Bureeu,22l Cal.App.3d at 721-23. This principle stems from the requirement that an
EIR analyze all signif,rcant or potentially significant environmental impacts. Pub. Res.
25

In reality, a queue of more than 3 hours may never happen because travelers
would likely adjust their travel to avoid the extreme bottleneck. Yet, even if travelers
adjust their behavior to avoid the bottleneck, the congestion would just be transferred
elsewhere. Accordingly, the DEIVS erred in omitting reference to the extensive traffic
congestion resulting from the Freeway Tunnel alternatives. Analyzing the potential for a
3-hour queue would have more accurately portrayed the Freeway Tunnel alternatives'
impact than the DEIVS's rosy assessment does.

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Code $$ 21061, 21068. Similarly, NEPA requires that an EIS fully discuss the
foreseeable cumulative impacts of the action on surrounding areas. Earth Island
Institute,351 F.3d 1291 (gth Cir. 2003) (EIS for timber sale was inadequate where it
failed to consider impacts on owl species in neighboring national forest); see also 40
C.F.R. $ 150S.25(c) (requiring agencies to consider direct, indirect, and cumulative
impacts).
Here, as the Nelson Nygaard Report explains, the Freeway Tunnel
alternative will signif,rcantly worsen congestion at several locations, yet the DEIVS fails
to evaluate these areas. For example, project-related traffic volumes under the Freeway
Tunnel alternative wili be heavy on I-210 from SR 710 to I-5, but the DEIVS does not
analyze transportation impacts any further north thanLa Cartada Flintridge. The DEIR/S
also omits an analysis of the Freeway Tunnel's impact on I-5 north of I-210 and the I2l0ll'-5 interchange. It also fails to examine the effects on SR-710 south of SR 60, which
means that it ignores effects on the SR 710/I-10 interchange. Based on the volume of
traffic at all of these locations, the Freeway Tunnel's impacts are likely to be significant.
Certain locations just beyond the DEIVS study area's boundaries have the
highest concentrations of truck accidents per mile annually in Los Angeles County and
the Inland Empire. See "California Commute -- 4 stretches of freeways tally most big rig
crashes per mile annually," Los Angeles Times, June2,2015, attached as Exhibit 28. In
its latest analysis of California Highway Patrol data, SCAG identified the following
freeways sections as having the highest concentrations of truck crashes per mile annually:
SR 7i0 at the SR 60 interchange with 7.2 accidents and the I-5 between the 710 and the
10 with 6.6 crashes. Id. The Freeway Tunnel alternative has the potential to worsen
traffic congestion in these locations. However, because the DEIR/S does not include
these locations in its study area, it does not atalyze the potential for the Freeway Tunnel
alternative's increase in congestion to contribute to big rig accidents.

In short, the DEIR/S should have analyzed a study areathat includes all of
the freeways and interchanges that will experience increased traffic congestion as a result
of the Freeway Tunnel alternative. The absence of this analysis is a serious omission,
precluding any agency action on the Project.

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3.

The DEIR/S Fails to Mitigate Numerous SignifTcant

Transportation Impacts Due to Operation of the Project.

While the DEIVS identifies intersections and freeway segments that would
be significantly impacted by the Project, the document admits that the measures that
would rnitigate the impacts at these locations are not recomrended for implementation.
For example, the Freeway Tunnel alternative would result in an additional2,500 vehicles
per hour (the level of service ("LOS") would decline from C to F) in the AM peak hour
and 2,700 vehicles per hour (LOS would decline from B to E) in the PM peak hour on I710 northbound between the I-10 off-ramp and the eastbound I-10 on-ramp. DEIVS at
3.5-52 (under the dual-bore operational variation: no tolls). The DEIR/S identifies a
rnitigation measure (adding a lane between the I-10 oframp and the eastbound I-10 onramp), but this roadway improvement is not recornmended for implementation, Id.
In fact, each freeway tunnel alternative would result in significant
transporlation impacts that remain unmitigated. For example, under the "single bore
operational variation: with tolls and no trucks alternative", the 4 intersections and 11
freeway segments that would be significantly impacted as a result of the Project receive
no mitigation. DEIVS at3.5-42; 3.5-48 to -49. CEQA does not permit this approach.
When an EIR makes a finding of signifcant environmental harm from a project, as it
does here, CEQA requires the lead public agency to adopt all feasible mitigation
measures to lessen that harm, or to adopt a feasible alternative that will do less
environmental damage. Pub. Res. Code, $$ 21002,21081. Here, the DEIVS fails to
provide substantial evidence that all feasible mitigation has even been identified.
Certainly, the agencies could have made some attempt to alleviate the traffic congestion
at intersections and along freeways through measuros that do not require widening
freeways or adding intersection and arterial capacity. For example, the agencies could
have evaluated meeting travel needs by funding increases in local and regional transit
service. The agencies' failure to identify such measures, or other effective mitigation,
violates CEQA.
Finally, notwithstanding the agencies' refusal to mitigate the significant
irnpacts at these and dozens of other locations, the DEIR/S does not identi$r these
impacts as significant and unavoidable. See DEM at 4-85 (indicating that Project
would have less than significant impact on transportation). This omission also violates
CEQA and NEPA. See CEQA Guidelines $ 15126.2(b); 42 IJ.S.C. $ 4332(CXii)
(requiring the EIS to discuss "any adverse environmental effects which cannot be avoided
should the proposal be implemented").
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4.

The DEIR/S Fails to Analyze or Mitigate the Project's

Construction-Related Transportation Impacts.

According to the DEIR/S, construction of the Freeway Tunnel alternative

would occur over a five-year period. DEIR/S at 14. Construction of the LRT alternative
would occur over a six-year period. Id. at 10. One would expect that, given the massive
scale and prolonged duration of such construction, the DEIVS would have
comprehensively analyzed its extensive impacts on local and regionai traffic. Project
construction will generate traffc and alter traffic patterns from lane closures, delivery of
materials, hauling of excavated material, and construction ernployees' commuting
to/from the job site.
Despite these obvious effects, the DEIR/S includes only vague, cursory
statements about construction-related transportation impacts. For example, it devotes one
sentence to potential impacts in Alhambra, El Sereno, Monterey Park and Pasadena:
The single-bore design variation of the Freeway Tunnel
Alternative could result in delays at 5 locations and detours in
7 locations in Alhambra, El Sereno, and Monterey Park in the
vicinity of the south tunnel portal, as well as delays at 8
locations and detours in 11 locations in Pasadena in the
vicinity of the north tunnel portal. DEIR/S at3.24-4.
The document never identifies the specific locations where these delays or detours would
occur, or provides any estimate of their duration. In another instance, the DEIR/S states
that "prior to the estimated time of construction, coordination would take place to ensure
that the proposed closures andlor detours would be coordinated with other transportation
improvement projects in the areathat may be impacted and that potential traffic impacts
during the construction of this ftunnel] alternative are adequately addressed." Id. at3.245. These types of vague, generic statements fail to assure the public that the traffltc
impacts during construction will in fact be "adequately addressed."
The document's failure to supply this information is not a superficial
deficiency. Recently, Metro undertook a major expansion project for the I-405. As the
attached article explains, construction of that project wreaked havoc on travelers for
several years:

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The four-turned-five-year, $1.1 billion project became a

long-running nightmare of sudden ramp closures, poorly
adverlised by Metro and made all the worse by baffling
detours that led drivers into the unfamiliar Bel Air Hills and
Sherman Oaks hills, dead ends and unlit canyons. As Metro's
closures and delays reached their heightit2013, L.A.
Weekly encountered stranded motorists merely by following
Metro's official detours
which in many cases were roads
to nowhere. There is one crystal-clear improvement: With
barricades gone and ramp closures less frequent, commuters
are at least getting relief from problems Metro itself created
particularly its widely mocked detours, which proved
-indecipherable on its website and could not be explained by
road crews.

SeeL.A, WnEKLY, ILI Bllon and Five Years Later, the 405 Congestion Relief Project
Is a Fail (March 4,2015), attached as Exhibit29.
Instead of analyzing the Project's five to six-year long construction-related
transportation effects for the Freeway Tunnel and LRT alternatives, the DEIR/S looks to
a future "Traffic Management Plan" ("TMP") to minimize the effects of construction
activities. Id. But this deferral of rnitigation violates CEQA. ,See CEQA Guidelines $
15126.4(aXlXB) ("Formulation of mitigation measures should not be deferred until some
future time."); Comntunties for a Better Envronment v. Cty of Richmond (2010) 184
Cal.App.4th70,93. Indeed, the DEIR/S's approach to these transportation impacts is a
"mere expressionf] of hope" that the agencies will be able to devise a way around the
problems created by construction of this massive Project. Lincoln Place Tenants Ass'n v.
CEQA requires rore.
City of Los Angeles (2005) 130 Cal.App.4th

lll2.

Importantly, a court may consider lead agencies' prior actions when it

adjudicates the adequacy of mitigation measures. As the Supreme Court explained,
"fb]ecause an EIR cannot be meaningfull) considered in a vacuum devoid of reality, a
project proponent's prior environmental record is properly a subject of close
consideration in determining the sufficiency of the proponent's promises in an EIR."
Laurel Heights, 47 Cal3d at 420. As one of the agencies routinely responsible for largescale transportation projects, Metro has not demonstrated that it is able to protect
travelers from the adverse effects of their construction projects. The agency's inability to

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manage traffic during the I-405 Project construction period raises significant red flags for
the effectiveness of the TMP.

In short, the DEIVS's failure to provide a complete analysis of the

Project's hve to six-year long construction-related impacts for the Freeway Tunnel and
LRT alternatives, or an actual mitigation plan, violates CEQA and NEPA.

D.

The DEIR/S's Analysis of and Mitigation for the Project's Noise

Impacts Are Inadequate.

The Project will generate two distinct categories of noise impacts:

construction-related noise and permanent operational noise. Depending on the alternative
selected, the latter category will include: traffic noise from the cars, trucks, motorcycles,
and buses that will travel along the route, and/or noise from operation of the light rail
trains. The World Health Organization recognizes noise, and in particular traffic noise,
as a serious public health problem. See, e.g., excerpts from Traffic Noise Reduction in
Europe, attached as Exhibit 30. Given the magnitude of the Project's potential noise
impacts, coupled with the effect that elevated noise levels has on public health, the
DEIR/S should have rigorously examined this issue. Unfortunately, the document's
analysis of noise impacts is riddled with errors and critical omissions. The Landrum &
Brown Report Noise Report provides detailed comments on the shortcomings in the
DEIVS's noise analysis; a few of the most troubling errors are briefly described here.

1.

The DEIR/S Fails to Clarify the Significance Thresholds

for Analyzing Noise Impacts.

It

Uses

The CEQA Guidelines, Appendix G, state that a project will have a

significant noise impact if it would result in a substantial permanent increase in arnbient
noise levels in the project vicinity above levels existing without the project. CEQA
oocareful judgment . . .
requires that a deterrnination of an impact's signifrcance employ
based to the extent possible on scientific and factual data." CEQA Guidelines $
l

s064(b).

The f,rrst step in any discussion of an environmental impact is to select a

threshold of significance. Here, the DEIVS contains no thresholds of signif,rcance for the
Project's noise impacts. Instead, the document simply reprints the questions contained in
Appendix G of the CEQA Guidelines. DEIR/S at 4-69 to -70. But these questions do not
alone constitute a threshold of significance. For instance, Appendix G, question XII(o)

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asks whether the project would result in a "substantial permanent increase in ambient
noise levels in the project vicinity above levels existing without the project." Id. In order
to apply this standard, the DEIVS must define "substantial permanent increase" and
provide a numerical threshold upon which it bases its finding of no significance.

The DEIVS preparers failed to take this crucial first step. This flaw in turn
leads to a host of other failures: without a threshold, the DEIR/S cannot do its job. For
example, the DEIR/S concludes that the Project would mitigate all significant noise
impacts to less-than-significant levels (DEIR/S at 4-69 to 4-70), yet the document
provides no standard by which to judge the impact's signifcance. Because the DEIR/S
provides no standard or threshold on which to base its conclusion as to the Project's
impacts, its conclusions regarding the significance of the Project's noise impacts are
meaningless.

Moreover, the DEIR/S should have adopted thresholds that acknowledge

that where existing ambient noise is already elevated, tolerance is very \ow for any
increase in noise. Existing ambient noise at various receptors in the Project area is
already in excess of 65 dBA, the typical outdoor residential noise level deemed
acceptable by local municipalities. Here, the proper question is not the relative amount of
noise resulting from the Project, but "whether any additional amount of [] noise should be
considered significant . . ." in light of existing conditions. Los Angeles Unified School
Distrct,58 Cal.App.4th at 1025-26 (emphasis added). Therefore, the DEIVS erred in
failing to evaluate whether residents who already experience elevated noise levels will be
adversely affected by the Project.

2.

The DEIR/S Does Not Adequately Analyze the Projectos

Construction-Related Noise Impacts.

Although construction of the Project would take five to six years for the
Freeway Tunnel and LRT alternatives, respectively, and construction equipment would
operate immediately adjacent to residences, businesses, open space, and parks, the
DEIR/S never discusses the specifc noise impacts of this massive construction. As
anyone notices while walking next to a construction site, construction equipment can be
extraordinarily noisy. The DEIR/S acknowledges, generally, that construction will
involve a variety of noise-producing activities. Noise levels from construction trucks and
equipment can be as high at 87 dBA at 50 feet. DEIR/S at3.l4-7 to 3.14-8. Noise
generated from excavation activities, in particular, carreach 88 dBA at 50 feet. Id. And
the DEIR/S notes that noise associated with pile-driving activities is estimated to
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approach 93 dBA at 50 feet. Id. To put this in perspective, a noise level of

approximately 88 dBA is as loud as the sound that a food blender makes at a distance
one meter . Id. at3.I4-2.

of

Given the potential for the ear-splitting noise levels associated with Project
construction, the proximity of sensitive receptors, and the protracted construction
schedule, the DEIVS should have made at least some attempt to evaluate the Project's
construction-related noise impacts. Instead, the DEIR/S merely presents generic
information about typical noise levels for construction equipment and for construction
activities, and speaks in hypothetical terms. For example, in discussing noise generated
during excavation, grading, and facility construction, the document refers to "typical"
construction equipment noise levels (DEIR/S at3.l4-8, a-70); it provides no discussion
or analysis of how or why these 'otypical" levels will be generated by the Project
alternatives.
The DEIVS is similarly vague and dismissive with respect to haul truck
trips associated with construction. Although the dual-bore freeway tunnel design would
require 360,000 truck trips, at arate of 15 trucks per hour to export material from the
excavation site, the document states that noise impacts associated with hauling for tunnel
excavation activities is expected to be less than significant and no mitigation is required.
Id. at 4-70. The only evidence it provides for this statement is the unsupporled
oototal
number of delivery trucks per day is also a very small
conclusion that the
percentage of the daily volumes on the haul route roadways." Id. As the attached
Landrum & Brown Noise Report explains, this amounts to an average of 720 daily heavy
truck passes per day, which, at 35 miles per hour, would generate the same level of noise
as a typical arterial roadway with a daily trafflrc volume of 36,000 vehicles, and would
increase the noise level along the roadway by 3 dB. Landrum & Brown Noise Repoft.
The DEIR/S's analysis should present the traffic volumes and speeds on the roadways
that will be carrying haul trucks and demonstrate, based on substantial evidence, that the
additional truck trips will not have a significant impact on sensitive receptors along the
haul routes.
The DEIR/S generic description of typical noise levels fails to inform
decision-makers, let alone the affected public, of the noise events from this particular
Project. Although the DEIVS admits that atemporary noise increase would occur, the
public is given no specific information as to the type, severity or even the duration of the
construction-related noise impacts. Nor does the DEIR/S provide any assurance that
sensitive receptors would be sufficiently protected during the Project's protracted

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construction process, i.e., five to six years depending on the alternative selected.
Omission of a detailed and specific construction noise analysis is particularly troubling
given that the Federal Highway Adrninistration requires that construction noise must be
considered during the development of any transportation facility, and identifies the
specific FHWA model that agencies should use to predict noise levels for highway
construction proj ects.26
The DEIVS's failure to include a useful and legally-sufficient analysis of
construction-related noise impacts is a serious shortcoming. An adequate analysis would
have described existing ambient noise levels at receptor locations, established appropriate
significance thresholds for both interior and exterior noise levels to assess if the increase
would be substantial, predicted noise levels during each phase of construction at each
sensitive receiver location, compared noise levels during construction to the existing
ambient noise levels, and reached a conclusion as to whether noise levels would
substantially increase. This type of evaluation is necessarily complex, requiring a
thorough description of the type, duration, amplitude, topological conditions, relationship
of sensitive receptors to construction areas, construction techniques, construction
phasing, and construction durations for each project alternative.

A conclusion regarding the signifcance of an environmental impact that is

not based on an analysis of the relevant facts fails to fulfill CEQA's inforrnational goal.
See Stanislaus Natural Hertage Project v. County of Stanislaus (1996) 48 Cal.App.4th
1,82; Citizens of Goleta Valley, 52 CaL3d at 568. Similarly, NEPA places upon an
agency the "obligation to consider every significant aspect of the environmental impact
of a proposed action ." Baltintore Gas & Elec. Co. v. Natural Res. Def. Council (1983)
462U.5. 87 ,97 (internal quotation omitted). The DEIVS fails to fulfill these paramount
statutory purposes both because it neglects to present all relevant facts relating to the
Project's construction noise impacts and because its cursory conclusions are based upon
no analysis. Without a detailed quantitative analysis of construction-related noise, it is
not possible to determine the severity of these impacts or whether the proposed
mitigation measures would effectively reduce such effects.

(emphasis added)
'u S FHWA, Highway Traffic Noise Handbook
andbook/
noise/construction
dot.sov/en
available at: htto ://rvu,r,v.

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3.

The DEIR/S Does Not Adequately Analyze the Project's

Construction-Related Vibration Impacts.

The def,rciencies in the DEIVS's noise analysis extend beyond its failure to
analyze construction-related noise impacts. The DEIVS also inadequately analyzes
construction-related vibration impacts resulting from construction of the tunnel
alternatives. Construction-related vibration not only can contribute to high levels of
annoyance, but also can cause substantial property damage, Even at levels below those
that darnage structures, the effects of ground-borne vibration include perceptible
movement of the building floors, rattling of windows, shaking of iterns on shelves or
hanging on walls, and rurnbiing sounds. Federal Transit Administration Noise and
Vibiatin Manual (20027 at7-L The Project's tunnel alternatives require the use of up
to four tunnel boring machines, which will operate underground continuously to excavate
the tunnels by crushing rock into sediment. This will occur directly below residences and
businesses in the Project area. Additionally, the DEIR/S proposes to use supply and
muck trains to remove excavated material from the tunnel portals. These and other
construction activities will result in ground-borne vibration affecting sensitive receptors
within the Project area.
The DEIVS is legally deficient because it does not include a
comprehensive assessment of construction-related vibration impacts, and downplays their
significance. The Federal Transit Administration ("FTA") has established criteria
thresholds for annoyance from ground-borne vibration. The criteria are72 VdB for
frequent events (more thanl} events daily); 75 VdB for occasional events (between 30
and70 events daily); and 80 VdB for infrequent events (fewer than 30 events daily).
FTA Noise and Vibration Manual (2008) at 8-3. The DEIR/S's technical report on
vibration impacts concludes that the tunnel boring machines used for the LRT and
Freeway Tunnel alternatives may generate levels as high as 77 VdB at homes directly
above the tunnel. Ground-borne Noise and Vibration Impacts Report at 6-1. It also
states that these vibration levels would last two or three days, and possibly longer. Id.
The tunnel boring machines will operate continuously, generating relatively constant
levels of vibration while they are in operation. This activity means that residences and
other sensitive receptors near the tunnel construction activities will experience nearly

"

The manual is available at h ttn //wwi,v. fta. dot. gov 112347 2233.hfml
:

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continuous ground-shaking day and night for up to three days, at levels above those
permitted by the FTA criteria.
Therefore, the DEIR/S's own analysis indicates that ground-borne vibration
levels would exceed the FTA's thresholds for annoyance. Instead of acknowledging the
significance of this impact, however, the DEIR/S dismisses it as unimportant because it
will not produce structural damage to residences and the impact will not be permanent.
DEIR/S at3.l4-9 to -10. This approach is unlawful. The DEIVS has no basis for
concluding that the vibration impacts from the tunnel boring machines would be less than
significant. See DEIR/S at 4-7 5. Any conclusion that an impact is less than significant
must be supported with substantial evidence. Substantiai evidence consists of "facts, a
reasonable presumption predicated on fact, or expert opinion supported by fact," not
"argurnent, speculation, unsubstantiated opinion or narrative." Pub. Res. Code $
210S0(e)(1)-(2). Similarly, under NEPA, agencies may not rest on "bald conclusions,"
but must take a "hard look" at the environmental impacts of a project. Maryland-Nat'l
Capitat Park & Planning Comm'n v. (J.5. Postal Serv. (D.C. Cir 1973) 487 F.2d 1029,
1040. Because the DEIR/S's conclusion of insignificance is premised on unsupported
assumptions and bald conclusions, it falls far short of complying with this legal standard.

Moreover, the DEIR/S does not even analyze the potentially significant
effects of blasting. The document acknowledges that blasting may occur if high strength
bedrock is discovered in the cut-and-cover tunnel sections or in the excavation of cross
passages. DEIVS at3.l4-9;3.24-13. However, rather than analyzethe significance of
any such blasting, it elects instead to defer analysis of controlled blasting rnethods until a
future date. Id. This is not an acceptable approach. As the attached Landrum & Brown
Noise Report explains, impacts from blasting can vary widely, and there are control
measures available to minimize impacts. For example, several small blasts can perform
the same work as one large blast but result in lower maximum vibration levels. Landrum
& Brown Noise Report. The DEIR/S cannot simply raise the possibility of underground
blasting in a densely-populated urban environment and decline to address its impacts and
potential mitigation measures altogether. Instead, the document should indicate where
blasting may be used, and how likely it is to occur. It should also develop rnitigation
measures, based on a quantitative performance standard, to ensure that any blasting
would not result in significant vibration impacts.

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4.

The DEIR/S Does Not Adequately Analyze the Project's

Operational Impacts.

The DEIR/S systematically understates or outright ignores the Project's

operational noise impacts. First, as the Landrum & Brown Noise Report explains, while
the DEIR/S focuses myopically on traffic noise level changes along numbered highways,
it completely overlooks potential increases along arterial roadways in the Project area.
,See DEIR/S at 4-76 to -82 (Tables 4.3 through 4.7). But traffic volumes and noise levels
along arterial roadways will be affected by the Project and significant impacts will likely
occur along these roadways as well. The DEIR/S's analysis must be extended to arterial
roadways to assess potential impacts along these roadways.
Second, the DEIR/S ignores multiple receptor locations that will experience
significant noise impacts due to prevailing wind conditions. Studies have shown that
noise can be affected by atmospheric conditions, including wind, which can cause noise
to travel farther from its source. ^See Nick Ovenden, et al. How the weather affects the
scale of urban noise pollution (2011), attached as Exhibit 31. The prevailing winds in the
San Gabriel and La CresceralCafrada valleys are from the west, so the operational noise
from increased traffic caused by the Project would carcy in the direction of the foothills
of the San Gabriel mountains. Thus, receptors in the following cities, sorte of which are
outside the area studied in the DEIVS, could be affected by operational noise from the
Project: La Crescenta,LaCafladaFlintridge, Altadena, Pasadena, Sierra Madre, Arcadia,
Monrovia, Azvza and Glendale. The DEIVS overlooks these potentially significant
noise impacts.

Third, the DEIR/S completely ignores impacts to receptors for which

Caltrans asserts mitigation is infeasible or unreasonable. The result is not only illogical,
it is completely contrary to CE,QA and NEPA's tnandate to disclose significant
environmental impacts, especially those that are significant and unavoidable. As
explained in the Landrum & Brown Noise Report, the DEIVS and the Noise Study
Report reveal a large number of receptors where noise levels under the freeway tunnel
alternatives would exceed federal criteria, but for which noise abatement measures wero
deemed unreasonable or infeasible. DEIVS at3.14-12. Many of these receptors, .o
representing hundreds of dwelling units, would be subject to Project-related CNEL'"

CNEL stands for "Community Noise Equivalent Level" and is a

weighted average sound level over a24-hour period.

"

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noise increases of 3 dB or greater over existing conditions and an exterior noise level
greater than 65 dB under the Freeway Tunnel alternative. Landrum & Brown Noise
Report. Although the DEIR/S fails to establish a threshold of significance for noise
impacts, these increases exceed the typical CEQA significance threshold for highway
noise impacts-and the document proposes no feasible rnitigation to reduce these
significant impacts to less than significant levels. The DEIVS fails to acknowledge this
significant and apparently unavoidable impact, a critical error.
Fourth, the DEIR/S improperly excludes analysis of operational noise
irnpacts on interior noise levels. This is a key omission, since, for those receptors where
exterior noise exposure will exceed 65 dB CNEL, interior noise levels could exceed 45
CNEL with closed windows, and could exceed 57 dB CNEL with the windows open. By
comparison, the State of California's Title 24 building regulations establish 45 dB CNEL
as the interior noise standard for new residential dwellings. Landrum & Brown Noise
Report. What's more, the DEIR/S fails to consider second floor noise exposure, where
noise barrier mitigation is often ineffective. The DEIR/S preparers should also have
modeled these second floor noise exposures to those receptors located behind barriers
that will be constructed to comply with FHWA criteria.
These serious errors in the
render the document legally infirm.

5.

DEIVS's analysis of operational noise impacts

The DEIR/S Fails to Evaluate Single Noise Events and Nighttime

Noise.

Another significant oversight is the DEIR/S's failure to evaluate single

noise events or nighttirne noise. In fact, the noise analysis discusses the Project's
potential irnpacts only in terms of Leq and CNEL, both of which are averaging metrics.
Motor vehicle noise is characterized by a high number of individual events, which often
create a higher sustained noise level in proximity to areas sensitive to noise exposure.
The light rail trips associated with the LRT alternative will give rise to single noise
events. And construction activities, including pile driving and possibly blasting, will also
contribute to single noise events. The DEIVS should have evaluated the effect that
single noise events from traffic, light rail car trips, and construction activities will have
on the communities in the Project area. Yet, rather than atalyze how these singie noise
svents will impact receptors, the DEIR/S focuses only on average noise.

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Analyzing average noise impacts only has been rejected by California

courts because irnpacted residents do not hear noise averages, but single events. ,See
Berkeley Keep Jets,91 Cal.App .4th at 1382. The DEIR/S must also analyze single event
noise impacts. Single event noise levels have been shown to be likely to result in sleep
disruption and speech interference, and heightened levels of stress and annoyance.
Noting that "sound exposure level [SEL] has been found to be the rnost appropriate and
useful descriptor for most types of single event sounds," the court in Berkeley Keep Jets
held that the Port of Oakland's noise analysis was deficient for failing to consider these
impacts. Id. Accordingly, the DEIR/S should have analyzedthe impacts of single noise
events on sleep, speech, stress and annoyance levels, and analyze adequate measures to
mitigate those impacts.

Nor does the DEIVS differentiate between daytime and nighttime noise.
Noise can be far more intrusive during the evening and nighttime hours, when ambient
noise levels are attheir lowest and when people are sleeping. Since the surrounding area
is quieter at these times, the masking effect of other noise does not screen the freeway
noise. The DEIR/S should have taken into account this higher sensitivity to noise and
evaluated how the increase in noise from the Project, including construction activities,
would affect receptors during these sensitive time periods.

6.

The Proposed Mitigation for Noise Impacts Is Inadequate.

The DEIR/S's proposed mitigation for construction-related noise impacts is

legally inadequate. The DEIR/S concludes that implementation of Measures N-l and N2 would reduce construction noise impacts under the build alternatives to a less than
significant level. DEIVS at 4-70. These measures simply require compliance with the
Caltrans Standard Specifications, the County Code, and city rnunicipal codes, as
applicable . Id. at 4-70,3.14-16 to -17 . This sweeping conclusion obscures the fact that
the Freeway Tunnel alternative, for which construction-related impacts are arguably the
greatest, is not subject to Measure N-2. Id. at 3.14-16 to -I7 (Measure N-2 states that it
"applies [only] to the Transportation System Management/Transportation Demand
Management [TSM/TDM], Bus Rapid Transit [BRT] and Light Rail Transit [LRT]
Alternatives"). Caltrans is thus free to conduct freeway tunnel construction activities
unrestrained by the limits on such noise contained in local jurisdictions' municipal codes.

At any rate, merely requiring compliance with agency regulations does not
conclusively indicate that aproposed project would not have a significant and adverse
impact. It Kings CounQ Farm Bureau, for example, the court found that the fact that the

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EPA and the local air pollution control district had issued the necessary air emission
permits for the construction of a coal-fired cogeneration plant did not nulliff the CEQA
requirement that the lead agency analyze the signifi cant air quality irnpacts of the entire
project. 221 Cal.App.3d at 692.
Furthermore, the DEIR/S does not consider whether compliance with local
noise ordinances is actually feasible. An EIR must describefeasible measures that could
minimize the project's significant adverse impacts. CEQA Guidelines $ i5126.4(aX1).
The DEIVS fails in this respect because it does not analyze the feasibility of compliance
with local noise ordinances. In fact, if nighttime construction occurs near residential
areas, compliance may not be feasible. For example, Pasadena Municipal Code 9,36.070
(A) reads: "No person shall operate any pile driver, power shovel, pneumatic hammer,
derrick power hoist, forklift, cement mixer or any other similar construction equiprnent
within a residential district or within a radius of 500 feet therefrom at any time other than
as listed below. . ." Section9.36.070 (B) reads: "No person shall perform any
construction or repair work on buildings, structures or projects within a residential district
or within a radius of 500 feet therefrom in such a manner that a reasonable person of
normal sensitiveness residing in the area is caused discomfort or annoyance at any time
other than as listed below. . ." The allowable times are 7 am to 7 pm Monday through
Friday and I am to 5 pm on Saturday. The only way to comply with the first provision is
to forego nighttime and Sunday construction with the equipment listed. The DEIR/S
must demonstrate that the anticipated construction activities can actually be completed
without violating the applicable noise ordinances in order to conclude these measures will
reduce construction noise impacts to a level of insignificance.
The proposed mitigation for construction-related vibration impacts is
equally deficient. These impacts are addressed in Measure N-5, a sprawling, multi-part
mitigation lneasure that proves to be largely empty when scrutinized. For example,
Measure N-5 would require LRT construction activities to comply with applicable
Federal Transit Adrninistration ("FTA") criteria and guidelines and any local regulations
related to ground-borne noise and vibration. It also would require the Freeway Tunnel
alternative to cornply with the Federal Highway Administration ("FHWA") and Caltrans
guidelines and any applicable local regulations. DEIR/S at3.14-17 to -18. However, the
document provides no discussion of what these guidelines require, whether compliance
with them is feasible, and whether and how such compliance would actually mitigate
significant vibration impacts. Indeed, the requirement that construction activities comply

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with "any appiicable local regulations related to ground-borne noise and vibration" is a
nonstarter as the document does not identiff, let alone discuss, any such regulations.
Measure N-5 also requires the Project Engineer to develop specific property
line vibration limits during final design for inclusion in the construction vibration
specifications. DEIR/S at 3,14-18. The DEIR/S cannot defer the preparation of these
vibration limits until after Project approval. Mitigation for the Project's noise impacts
must be identified in this DEIR/S. See CEQA Guidelines $ 15126.a@)Q)@). Similarly,
the measure calls for a variety of future "control and minirnization" measures that ate
"anticipated to be applied during construction." DEIR/S at 3.14-18. These include
monitoring, a public notice and complaint resolution program, and the vague promise that
the Project Engineer will "incorporate comprehensive construction vibration
specifications in all construction bid documents." Id. These vague gestures do not come
anywhere near meeting CEQA's exacting standards for mitigation. Agencies may defer
mitigation only in very limited circumstances. ,See CEQA Guidelines $ 15126.4(aX1XB).
In those cases, the agency must commit itself to the mitigation, which must contain
specifc quantifiable performance criteria to ensure that it is effective. Endangered
Habtats League, Inc. v. Cnty. of Orange (2005) 13 I Cal. App. 4th 717 , 793 (measure
requiring acoustic analysis and reports to be submitted prior to permit approval
inappropriately defened mitigation). Here, because the DEIVS failed to include such
performance measures, it cannot justiff the decision to defer the bulk of mitigation for
vibration impacts until after Project approval.

In the absence of other feasible mitigation, and to ensure that no significant

impacts to residents will occur, the DEIVS should provide for compensation for
residents who will be adversely affected by tunnel boring machines passing beneath their
homes.

E.

The DEIWS's Analysis of and Mitigation for Geology/Soils Impacts

Are Inadequate.

CEQA provides that a "significant effect on the environment" exists where,

among other things, "[t]he environmental effects of a project will cause substantial
adverse effects on human beings, either directly or indirectly." Pub. Res. Code
$ 21083(b)(3). The CEQA Guidelines further explain: "The EIR shall . . . analyze any
signifcant environmental effects the project might cause by bringing development and
people into the arca affected." CEQA Guidelines $ 15126.2(a). Accordingly, the
DEIR/S must thoroughly study whether the seismic risks involved in constructing

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tunnel(s) through a region of Los Angeles County that contains numerous earthquake
fault zones would create signif,rcant risks to users and residents of the Project area.
Courts do not hesitate to scrutinize the adequacy of an agency's discussion
of a project's potential seismic risks to the occupants of the project, and have held the
agency's analysis to the same standards applicable to any other environtnental impact
analyzed under CEQA. California Oak Foundation v. Regents of University of
California (2010) i88 Cal.App.4th 227,263-264 (applying Guidelines, $ 15126.2fo
analysis of geologichazards to project); People v. County of Kern (1974) 39 Cal.App.3d
830, 836, 842 (EIR improperly failed to respond to cornments that development was
directly over active fault and adjacent to other active faults); see also Bozung v. Local
Agency Formation Corn. (1975) 13 Cal.3d 263,279-280, fn. 21 (observing that the
omay
have a significant effect on the
CEQA Guidelines have long provided a project 'o
environment"' if it " '[c]ould expose people or structures to major geologic hazards"').

To further highlight the importance of a project's seismic impacts, the

Legislature has provided that several types of projects that would otherwise be exernpt
from CEQA must undergo CEQA review if they are located near geologic features that
present seismic risks.2e Finally, as the DEIR/S acknowledges, the CEQA Appendix G
checklist asks whether proposed projects would expose people or structures to the risks
including fault rupture, seismic ground-shaking, and seismic related ground failure.
CEQA Guidelines Appx. G, $ VI. Given the Legislature's obvious concern that geologic
and seismic impacts be analyzed thoroughly during the CEQA process to protect public
health and safety, the DEIR/S's failure to do so here is troubling. As discussed below
and in the attached report by Wilson Geosciences, Inc., the DEIR/S's analysis of
geological and seismic impacts, including fault offset, ground-shaking, and ground
settlement, is inadequate. Further, the DEIR/S has not shown that the mitigation it
proposes for these impacts will actually reduce them to less than significant levels.

" Su, Pub. Res. Code $$ 21155.1(a)(6XD); 21159.21(hXa);

| I s9 .22(bX3 ) ; 2r I s9 .23 (aX2XA) ; 2t t s 9 .24 (aX3 ).

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1.

The DEIR/S Fails to Properly Analyze the Project's Seismic

Impacts.

The Southern California region is particularly seismically active because of

the influence of several earthquake fault systems resulting from the Pacific and North
American plates. The Proje ct area contains at least one active fault-the Rayrnond
fault-deflrned by the State of California as a well-defined fault line that has exhibited
surface displacement within the last 11,000 years. DEIR/S at3.l0-4. Additionally, two
potentially active faults-the Eagle Rock and San Rafael faults-are present within the
Project study area. Id. The DEIR/S acknowledges that an earthquake on the Raymond
may result in ground rupture. /d. Nonetheless, both the Freeway Tunnel alternative and
the LRT alternative designs (collectively, "tunnel alternatives") cross the Raymond and
Eagle Rock faults, and the Freeway Tunnel alternative also crosses the San Rafael fault.
Id. The regional faults may also cause strong grouird-shaking to occur in the Project area.
Id. Ground settlement is also a potentialhazard of tunnel construction, due to the area's
geological makeup. Id. at3.10-10 to -12. It is against this backdrop of seismic activity
that the DEIR/S must evaluate the impacts of the Project. Unfortunately, critical flaws in
this analysis lead the DEIR/S to substantially understate these potential irnpacts.

2.

The DEIR/S Fails to Support Its Analysis of Fault Offset

Potential With Substantial Evidence.

A fault rupture offset is the ground movement along an earthquake fault,

measured from one side of the fault to the other. The DEIR/S recognizes that "there is
the potential for substantial adverse effects due to fault rupture" in the Project area.
DEIR/S page 4-59. This is unsurprising, as all of the tunnel designs cross multiple
mapped faults. 1d. Despite the obvious need for careful analysis of these impacts in
order to protect the public safety and welfare, the DEIR/S mistakenly relies on an
outdated rnethodology to determine fault rupture offset, thereby underestimating the
tunnel alternatives' threat to public safety.

Using outdated methodology, the DEIVS's analysis of the tunnel

alternatives' potential fault offset mischaracterizes the active fault rupture offset for the
Raymond, Eagle Rock, and San Rafael faults at the point where the tunnels will cross.
This error results in an inaccurate and understated estimation of the tunnel alternatives'
risk to public safety. There are two principal methodologies for estimating the magnitude
of fault ruptures. Of the two, the EIR/S preparers elected to use the older methodology,
published over twenty years ago. See Preliminary Geotechnical Report, Appx. E at 11;

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Wilson Geosciences Report. In doing so, they rejected a newer methodology that takes
into account data obtained from more recent earthquakes.
The irnplications of this error are more than theoretical. The newer
methodology predicts a fault offset more fhanfour times the size of the offset prediction
yielded Uy tire older rnethodology for the Raymond fault.3O In fact, the new
methodology's fault offset prediction for the Raymond fault is nearly the same as the
fault offset observed in the 1971 San Fernando earthquake at avery similar fault. Wilson
Geosciences Report. By "selecting" and then designing for the lower offset prediction,
the DEIR/S greatly underestimates the risk of damage to the tunnel(s) in the case of an
earthquake. Id.
The DEIR/S's approach, which eschews current information in favor of
outdated material, violates basic principles of CEQA. Berkeley Keep Jets,9l
Cal.App.4th at 1367 (EIR's use of scientifically outdated information caused it to fall
short of a "reasoned and good faith effort to inform decision-makers and the public").
Moreover, an agency's reliance on inadequate data or assumptions amounts to a
fundamental failure to take the "hard look" required by NEPA. See, e.g., Natural
Resources Defense Council,42IF.3dat8l2 (EIS's analysis of economic impacts based
on inaccurate models and flawed assumptions "subverted NEPA's purpose").

3.

The DEIR/S Does Not Adequately Bvaluate Impacts on the

Tunnel Design From Ground-Shaking.

As with its approach to fault rupture, the DEIR/S falls short in addressing
and evaluating the potential impact of near-source ground-shaking on the tunnel from an
earthquake on the Raymond, Eagle Rock, andlor San Rafael faults. Seisrnic groundshaking occurs during an earthquake, with the intensity of the shaking at a location
depending on the location's distance from the earthquake epicenter. Ground-shaking,
like fault rupture, can cause significant damage to structures within 50 feet of fault traces'
Wilson Geosciences Report. Effects can include ground and grout cracking, and local
permanent ground deforrnation.

30

Caltrans elected to use

the "average" 0.5 meter Wells and Coppersmith (1994) predicted offset value instead of
the "maxit1um" 2.2 meter Wesnousky (2003) value for the Raymond fault.

Su, Wilson Geosciences Report, explaining that

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The DEIR/S does not evaluate the potential impact of the near-source
ground-shaking hazard on the tunnel. Because this specifichazard is simply not
addressed, there is no evidence that the recommended design measures, which are
intended to accommodate vertical and lateral ofet movements, would be sufficient to
address near-source ground-shaking hazards. Wilson Geosciences Report (citing the
DEIR/S's Preliminary Geotechnical Report, Appx. at 8). Furthermore, as described
below, the DEIR/S fails to identify seismic design criteria for freeway tunnels that would
account for the potential hazards associated with near-source ground-shaking. This
omission undermines the effectiveness of any tunnel design Ieasures it proposes.

4.

The DEIR/S's Conclusion That Ground Settlement Will Not

Occur Is Not Supported By Substantial Evidence.

The DEIR/S states that the Project's proposed excavation and tunneling
could cause ground settlement and differential settlement immediately above and
adjacent to the bored tunnel portion, and the portal and station excavations of the tunnel
alternatives. DEIR/S at i. i0- l0 to -12. Unless properly controlled, these activities could
result in groundwater inflows and flowing ground conditions at the head of the tunnel
excavation, which would lead to ground surface settlement. 1d. Such groundwater
inflow into excavation areas may require dewatering, which in turn could cause more
ground settlernent. Wilson Geosciences Report. ^Ground settlement can, of course, cause
significant damage to existing surface structures.3l

Many of the areas above and adjacent to the tunnel location are occupied
with residences, roads, and businesses, which stand to be damaged in the event of ground
settlement. Remarkably, however, the DEIR/S does not fully describe the impact of
ground settlement on these existing structures and infrastructure. Instead, the DEIR/S
defcrs proper alluvial deposit and groundwater characterization studies until after Project
31

Seattle residents experienced this problem firsthand, in conjunction with

the Alaskan Way Viaduct replacement project. Efforts to excavate a broken tunnel
boring machine coincided with ground settlement that caused considerable damage to
surface structures, including commercial office buildings. See Ngw YoRt< TIMES,lz
Seattle, a Sinking Feeling About a Troubled Tunnel (Dec. 10,2014), available at:
I 4 I 12 I t 0 I us/in-seattle-a-sinking-f-eelin s-about-a-troubledhtto://www.nvtimes.

tunnel.htrnl?& r:0.

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approval. Yet, these studies are necess ary at the outset, to deterrnine whether the
proposed excavation and tunneling techniques require adjustment or augmentation
through mitigation. In particular, the studies would evaluate the specific groundwater
conditions within the alluvial deposit portions of the tunnel alignrnents, including the
densities, porosities, and transmissivities of the rnaterials. Only with such evidence can
the DEIVS analyze the impacts of dewatering in these areas, and identiS necessary
design changes and mitigation.
In lieu of this required analysis, the DEIR/S speculates that use of certain
construction techniques may limit ground settlement: "tunneling equipment and
procedures as well as portal and station support methods are capable of controlling
ground movements to limit surface settlements and in turn rninimize damage to existing
structures." DEIR/S at 3 . 1 0- 1 1 . However, according to Wilson Geosciences, the
techniques identified in the document are not likely to be effective in reducing or
avoiding most of the surface settlement. Wilson Geosciences Report. Although the
DEIR/S provides a cursory discussion of ground improvement measures, such as
chemical or cement grouting, its analysis is entirely perfunctory'
In order to evaluate properly the potentialhazards associated with the soil
settlement and the consequent impact on existing improvements, the DEIR/S rnust
estimate: (1) the anticipated total and differential settlements, and (2) the tolerance limits
of the existing improvements to such settlements. Wilson Geosciences Report. The
document does neither. Accordingly, the DEIR/S lacks an adequate assessmont of the
potential adverse impacts on existing improvements from ground settlement associated
with the Project, in violation of CEQA and NEPA.

5.

The DEIR/S Fails to Identify and Justify Thresholds of

Significance for Impacts to Geology and Soils.

The DEIR/S does not clearly identify the standards of significance it used
to evaluate geological and seismic impacts, in violation of CEQA. In order to perform its
function of identifying significant impacts, an EIR must first provide a reasonable
discussion of the significance criteria the lead agency will be using to evaluate those
impacts. This discussion must not only identify the specific standards of significance, but
also provide a justifcation for why their use is appropriate. Here, the DEIR/S's mere
recitation of generic questions from the CEQA Guidelines Appendix G does not serve
this function. Guidelines $ 15064(b) (CEQA recognizes that the signif,rcance of an
activity may vary with the setting); see Bowman v, City of Berkeley (2004) 122

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Cal.App.4th 572,589 ("The Guidelines confirm that the significance of an activity may
vary with the setting. For example, an activity which may not be significant in an urban
area may be signifcant in a rural area.") (internal quotation marks omitted). Given the
unique size, scope, and technical complexity of the tunnel alternatives, it is not sufficient
simply to incorporate the suggested standards from the CEQA Guidelines wholesale and
without any explanation.
For example, the DEIVS implies that state and local design standards,
building codes, and regulations will ensure that no significant impacts result from Project
implementation. DEIR/S at 4-59 (reliance on 'ocompliance with applicable Caltrans,
FHWA, Metro, andlor local jurisdiction seismic design standards for construction and
operation"); id. (reliance on "compliance with applicable building and seismic design
standards"). But the document does not actually identiff these standards or codes, nor
does it describe the specific requirements that they would impose. Further, the DEIR/S
never explains how these design standards and codes will actually mitigate seismic
impacts to a less than significant level. Notably, the Appendix G Checklist for geology
and soils, section VI, does not even mention standards established by regional or local
jurisdictions, in contrast to its treatment of noise impacts. ,Se Appendix G Checklist
$ XII(a). Since tunnel construction of this scale is urrprecedented in California, it is
speculative to assert that state and local design standards will ensure that there will be no
significant impacts. The problem is further amplified by the DEIR/S's failure to identiff
specific design standards for tunnel construction, as described below and in the Wilson
Geosciences Report.

In short, the DEIVS must develop meaningful significance criteria to guide

its analysis of these impacts.

6.

The DEIR/S Improperly Relies on Seismic Design Criteria

Developed for Bridges to Mitigate Impacts to Tunnels.

Compounding its analytic elrors, the DEIVS relies on seismic design

criteria for bridges rather than for tunnels. As the DEM explains, Project "fs]tructures
are designed using the Caltrans Seismic Design Criteria ("SDC"). The Caltrans SDC
provides the minimum seismic requirementsr highway bridges designed in California."
DEIVS at 3.10-1 (emphasis added); see also DEIR/S Preliminary Geotechnical Report,
Appx. E at 15 ("No Caltrans seismic design criteria for tunnels are currently available.");
Appx.F at 8 (same). As the Wilson Geosciences Report explains, the SDC does not even
mention tunnels. The SDC refers readers to the "20-10 Fault Rupture Memo to

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Designers," authored by Caltrans and updated in2013, but that document does not
address tunnels either. On the contrary, all of its fault rupture references are to
'We
assume these'ostructures" are bridges inasmuch as the State Bridge
"structures."
Engineer prepared the memo.
This error is profound. The DEIR/S makes no attempt to justi$z or explain
why the SDC developed for highway bridges would be effective for tunnels. It simply
states that "to support the environmental documentation, it was agreed that the Caltrans
seismic design criteria for an Ordinary Nonstandard facility will be used as the basis for
seismic design of the Freeway Tunnel." DEIR/S Preliminary Geotechnical Report, Appx.
F at 8. This is afar cry from the substantial evidence required under CEQA to support
environmental determinations. Se Pub. Res. Code $$ 21080(e)(1) ("substantial evidence
includes fact, areasonable assumption predicated upon fact, or expert opinion supported
by fact"), 21082.2(c). As the Wilson Geosciences Report confirms, there is no sound
scientific basis for Caltrans' reliance on design criteria for bridges in analyzing and
developing mitigation for impacts to massive, deeply seated tunnels like those proposed
by the Project.
The agencies must not proceed with the Project until the DEIR/S identifies
seismic design criteria for constructing tunnels. Wilson Geosciences Report. The
DEIR/S should fully describe these standards and explain specifically why their use is
appropriate for the proposed Freeway Tunnel alternatives (both the single- and dual-bore
variations). This explanation should include examples of technical methods for
determining the magnitude of acceptable fault offsets for the specific tunnel design. It
should also speci$' how the design standards, such as use of cross-passages and other
safety measures, would best prevent risks to tunnel users.
The agencies may counter that developing such standards would be timeconsuming, impractical, or infeasible. But that is irrelevant. The unprecedented size and
scope of the Project's Freeway Tunnel alternatives, coupled with their location in a
seismically active area, dernand that Caltrans develop and use design standards
specifically intended for tunnels . See Laurel Heghts, 47 Cal.3d at399 ("We find no
authority that exempts an agency form complying with the law, environmental or
otherwise, merely because the agency's task may be difficult'").

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The DEIR/S's Proposed Mitigation Measures Are Vague and

Unsupported By Substantial Evidence That They Will Be
Effective.

The mitigation proposed in the DEIR/S for the Project's impacts to geology
and soils are inadequate and legally deficient. Most notably, the measures defer
development of crucial plans and studies until after Project approval. For example, the
DEIR/S contemplates, but does not include, the following plans and studies: a
"comprehensive geologic and geotechnical investigation," "design-level
geotechnical/baseline reports," and a "quality assurance/quality control (QA/QC) plan."
DEIR/S at3.10-22. This information must be part of the DEIR/S and be provided to the
public before Project approval, not put off to an unknown future date. See San Joaqun
Raptor Rescue Ctr. v. County of Merced (2007) 149 Cal. App. 4th 645, 670. Deferral is
impermissible where an EIR calls for mitigation measures to be created based on future
studies and/or describes mitigation in general terrns and the agency does not commit
itself to specific performance standards. Calfornia Clean Energy Comm'n v. City of
Woodland (2014) 225 Cal.App.4th 173,195 (agency could not rely on future report on
urban decay with no standards for determining whether mitigation would be required).
The following measures do not commit Caltrans to specific performance
standards and cannot therefore constitute legally adequate mitigation:
a

Mitigation Measure GEO-1 states that during preliminary and final design,
a comprehensive geologic and geotechnical investigation will be conducted
and design level geotechnical/baseline reports will be prepared. This
lneasure defers investigation and preparation of key reports until an
unspecified later date, and it is not clear at which stage of project
construction and design these reports will issue. Furthermore, the design
recommendations that it will purportedly contain for seismic hazards and
for geology related constraints should be identified up front.

Mitigation Measure GEO-2 states that the Resident Engineer will maintain
a quality assurance/quality control (QA/QC) plan during construction and
submit "weekly reports" to Caltrans or Metro during Project construction.
Mitigation Measure GEO-3 states that the Project Engineer will "make
sure" various measures are included in the comprehensive geologic and
geotechnical investigation and the design-level geotechnical/baseline report
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and the project design and specifications. For example, "[a] fault crossing
design will be evaluated to be able to accommodate the expected fault
offset, maintaining the structural integrity of the tunnel lining and
preventing the intrusion of surrounding groundwater into the tunnel. The

design will meet the performance criteria of the operating agency."

However, the measure does not specify what these performance criteria are,
and provides no evidence to conclude that they will be adequate to deal
with the fault offset.

Mitigation Measure GEO-4 states that "If ground ovements exceed

acceptable levels set during design, additional measures will be required.
." However, the document does not state what the "acceptable levels" of
ground movements will be. Moreover, the additional measures that will be
required are not described in adequate detail. The measure also fails to
describe the contents of the "contingency plan of action" that will be
required in the event that ground movements occur above levels that could
.

cause structural damage.

DEIR/S at.3.l0-2I to -24. These measures are not adequate to support the
DEIR/S's conclusion that geological and seismic impacts will be mitigated to a less than
significant level. This deferral of mitigation is especially problematic since Caltrans has
not developed, and the DEIVS does not rely on, seismic design criteria for tunnels.

8.

Caltrans Improperly Substituted a Less Robust Tunnel Design

for the Original Design in Order to Save Costso Without
Explaining If or How the Later Design Will Minimize or Avoid
Impacts.

As originally proposed, the Project's freeway tunnel design called for an

oversized tunnel, or large vault backfilled with crushable materials in the sections of the
tunnel crossed by active faults. DEIR/S Preliminary Geotechnical Report at Ll-9 to -10.
This design was intended to protect tunnel users by reducing tunnel damage at fault
crossings in the case of fault offset. Ultimately, however, Caltrans settled on a different
design that calls for vault sections with steel segmental lining. Caltrans made the change
due to "constructability issues as well as risk, cost, and schedule implications." Id. at 1110. In other words, the subsequent design can be built more cheaply and quickly.
Moreover, the design change was made in reliance on "future design studies," without
any specific analysis of how either design would perform in response to an earthquake.

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DEM

Tunnel Evaluation Report at 2-4 ("Site-specific geotechnical investigations have

yet to be completed at each of the various fault zones; future design studies will require
site-specif,r c datato be obtained in order to refine the design concepts discussed herein.")

In fact, as the Wilson Geosciences Report describes in detail, the change in

design could potentially increase the damage to the tunnel due to an earlhquake. But the
DEIR/S ignores this critical problem, as it fails to address how the proposed tunnel
design option will best protect tunnel users. The DEIR/S should have analyzedthe
design's expected performance under various fault offset and near-source ground motion
scenarios. It also should have explained the cost, risk, and construction time trade-offs
used to justify the final design selected by Caltrans. Without this information, the
DEM cannot assure the public that the chosen design will prevent serious impacts to
tunnel users, and that cost and time considerations were properly balanced with public
safety.

In sum, the DEIVS's analysis of impacts relating to seismic risks does not
meet CEQA and NEPA's minimum standards. As a result, the DEIR/S provides no
evidence that any of the tunnel alternatives would be constructed in a manner that will
ensure public safety.

F.

The DBIR/S's Analysis of and Mitigation for the Project's

Hydrotogical and Groundwater Impacts Are Inadequate.

One of the policy goals of CEQA and NEPA is to identify impacts and
feasible mitigation at the earliest feasible stage before project momentutn decreases an
agency's flexibility . See Sundstrom v. County of Mendociruo (1988) 202 CaLApp3d296,
307; Oro Fno Gold Mning Corp. v. County of El Dorado (1990) 225 CaLApp3d 872,
884-85; see also Cty of Tenakee Springs v. Clough (9th Cir. 1990) 915 F.2d 1308, 1313
("NEPA requires consideration of the potential impact of an action before the action
takes place"). To that end, information regarding the project's impacts must be
"painstakingly ferreted out." Envronmental Plannng and Information Councl of
Western El Dorado County v. County of El Dorado (1982) 13 1 Cal.App.3d 350, 357
(finding an EIR for a general plan amendment inadequate where the document did not

make clear the effect on the physical environment).

As discussed below and in the report prepared by Wilson Geosciences Inc.,

the DEIVS's analysis of the Project's hydrologic and groundwater impacts frorn the
Project's LRT and Freeway Tunnel alternatives is inadequate because it fails to: (a)

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adequately describe the Project setting; (b) identify thresholds of significance; (c)
describe the engineering design features of the tunnel alternatives; (d) support its
conclusions with the necessary facts and analysis; and (e) identi$t mitigation capable
minimizing the tunnel alternatives' significant environmental impacts.

1.

of

The DBIR/S's Failure to Accurately Describe the Projectos

Bxisting Hydrotogical and Groundwater Setting Results in a
Serious Underestimation of the Project's Hydrological Effects.

Knowledge of the regional setting is critical, as it forrrs the baseline for

evaluating a project's environmental effects. In considering impacts to hydrology and
groundwater, the DEM must provide a through description of the site's existing
hydrological characteristics and then comprehensively describe how the Project,
particularly the LRT and Freeway Tunnel alternatives, would affect these conditions.
Here, the DEIVS fails to provide the most basic hydrologic inforrnation about the
groundwater basins and floodplains that the Project would potentially affect.

(a)

Raymond Basin and Main San Gabriel Basins.

As the Wilson Geosciences Report explains, the DEIR/S mentions the Main
San Gabriel and Raymond groundwater basins, but it does not describe the geologic,
hydrological and groundwater characteristics of these basins. The DEIR/S provides no
information on groundwater depth contours, groundwater flow direction, basin thickness
descriptions or contours, groundwater volumes, groundwater interactions between the
Raymond and Main San Gabriel basins, rates of groundwater recharge and withdrawal,
locations of pumping wells, or groundwater quality. Nor does the document provide
sufficient hydrogeologic and geotechnical information to allow for an evaluation of
groundwater flow constraints associated with constructing a tunnel in a seismically active
zoe.
EIRs for projects that have the potential to threaten groundwater - such as
the proposed tunnel alternatives - must describe the site's hydrologic conditions (i.e.,
baseline conditions) before they can adequately analyze impacts and propose rnitigation
measures. Here, the DEIR/S tackles the task in reverse order. First, it provides a cursory
acknowledgment of the Project's groundwater impacts. Then, it proposes that, as
mitigation for the tunnel alternatives, the lead agency would comprehensively investigate
the characteristics of groundwater resources in the areas where tunneling and excavation
would occur; this investigation would establish the baseline for examining the Project

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tunnel alternatives' impacts.

Evaluation Report at 20, 2L

DEIVS at3.9-21 (WQ-3);

see also the DEIR/S's Tunnel

The DEIVS's approach violates CEQA and NEPA. The agency's detailed
investigation as to setting cannot be deferred until after project approval. See Sundstrom,
202 Cal.App.3d at30l; see also Robertson, 490 U.S. at 352 (EIS must discuss mitigation
"in sufficient detail to ensure that environmental consequences have been fairly
evaluated"). Without sufficient groundwater and geologic characterization, the DEIR/S
is unable to estimate whether construction of the tunnel, or an earthquake affecting the
tunnel, would substantially deplete groundwater supplies or affect groundwater quality.
The potential development of a tunnel traversing several alluvial groundwater basins
warrants a comprehensive understanding of the groundwater resources within these
basins. These data are readily available and/or attainable, and we can frnd no plausible
explanation why this fundamental information was not included in the DEIR/S.

(b)

Laguna Regulating Basin and Dorchester Channel.

The DEIR/S also does not provide a sufficient description of the two
floodplains that are located within the study area:Lagttna Regulating Basin and
Dorchester. DEIR/S at 3.8-2. Certain alternatives, including, for example, the dual-bore
tunnel alternative, would require longitudinal encroachments32 within one or both of
these floodplains. Id. at 3.8-5. The DEIR/S provides no description of either basin's
hydrologic system. It includes no information on flood elevations, peak flows to
drainage areas, or the flood frequencies associated with peak flows. Without this
information, there is no context for potential flooding irnpacts that could occur as a result
of construction within the floodplains.

Floodplains are critical, interrelated components of the hydrologic system

that receive and discharge water. Changes to one part of the system will affect others.
Dorchester Channel, in particular, is a rnajor drainage within the study atea. Id. at 3.9-8.
The failure of the DEIVS to accurately portray the site's underlying environmental
conditions contravenes CEQA and NEPA, undercutting the legitimacy of the
environmental impact analysis. Especially because the Federal Highway Administration

3t Anencroachment is defined
floodplain." DEIR/S at 3.8-1

as

"an action within the lirnits of the base

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requires that the practicality of alternatives be evaluated if a project results in a

longitudinal encroachment into a floodplain (Id. at 3.8-1), it is critical that the DEIR/S
accurately describe these existing floodplains and the potential for the Project to encroach
into them.

2.

The DEIR/S Lacks Thresholds of Significance for Determining

the Project's Hydrological and Groundwater Impacts.

As discussed above, one of the first steps in any analysis of an

environmental impact is to select a threshold of significance. As with other impact
sections, the DEIVS contains no thresholds of significance for the Project's hydrological
and groundwater impacts. This flaw leads to a cascade of other failures;without a
threshold, the DEIR/S cannot do its job.
For example, the DEIR/S states that the Project would not substantially
deplete groundwater supplies, would result in no groundwater quality impacts, and would
cause no impacts relating to the placement of structures in floodplains. Id. at 4-65 and 466. But because the DEIR/S does not identify numeric levels for any of these impacts,
there is no way for the public to confirm that these impacts would in fact be less than
significant. Indeed, based on the limited information in the DEIR/S and analysis
prepared by Wilson Geosciences, there is sound evidence that the Project would have
potentially significant impacts on groundwater supplies and groundwater quality, and
would adversely impact the floodplains in the study area.

3.

The DEIR/S Does Not Disclose Groundwater Impacts That

Could Result From Penetrating the Raymond Fault.

(a)

Impacts to Groundwater Supplies.

The DEIVS fails to adequate analyze the Project's impacts on groundwater

supplies. First, as discussed above, the DEIVS omits critical inforrnation regarding the
Project's hydrologic setting. As the Wilson Geosciences Report explains, the Raymond
Fault separates the adjudicated Raymond and the Main San Gabriel Groundwater Basins.
The fault serves as a natural subsurface dam, holding back water in the Raymond Basin
on the north from water in the Main San Gabriel Basin on the south. DEIVS at 3.10-3.
Water levels are 160 feet lower in the Main San Gabriel Basin than immediately across
the Raymond Fault in the Raymond Basin. Perforating this groundwater barrier, either
through tunnel construction or as a result of an earthquake, could create significant

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pathways for groundwater from the Raymond Basin to flow into the Main San Gabriel
Basin. Any perforation of this subsurface dam could have devastating impacts, including
on the City of Pasadena's water supply.

Unfortunately, the DEIR/S does not recognize the relationship between the
two groundwater basins and the subsurface dam, and thus dismisses the potential threat to
groundwater resources that could result frorn perfbrating this barrier. A major pafi of the
problem is that the DEIVS relies on tunnel design features to assert that the tunnel would
not cause a drawdown of local groundwater tables. DEIR/S at 4-66. However, the
DEM provides only a superficial discussion of these Project features, never actually
explaining how they would prevent groundwater inflows. Equally concerning, the
Project would be constructed in a seismically active area, but the DEIVS fails to
determine whether the Project's tunnel alternatives have been adequately engineered to
ensure that a moderate or large earthquake would not impair the Main San Gabriel
Groundwater Basins.
The DEIVS casually asserts that "special care would have to be exercised"
when tunneling through a fault zoe. DEIR/S at 3.10-21. Yet, the DEIVS never
describes the "careful" techniques that would be employed to protect groundwater during
this process; it merely states that Caltrans would use a pressurized-face tunnel boring
machine ("TBM") as well as grout and concrete lining with rubberized gaskets. Id. at
3.10-21;3-24.7; 4-65. Tellingly, the DEIR/S never explains how the TBM, grout and
lining would actually protect groundwater. Thus, contrary to CEQA and NEPA's
requirements, the DEIR/S provides no evidence to support either its finding that
groundwater would be sufficiently controlled, or its conclusion that the impact would be
less than significant (see id. at 3 .9 -16, 3.10-12, 3. I 0- 19, 3 .247, 4-66).

In fact, as the Wilson Geosciences Report demonstrates, there is a high

potential for the proposed SR 710 tunnel to leak excessive amounts of groundwater.
Wilson Geosciences conducted a literature search of tunneling projects and, specifically,
the effectiveness of grout to control groundwater. These studies clearly demonstrate that
tunnels leak. See Wilson Geosciences Report, citing Jacobs Engineering. Grouting can
help, but it does not eliminate leaks through or around a tunnel lining. In a study of the
South Cobb tunnel project constructed in Atlanta, Georgia, Jacobs Engineering
determined that the tunnel would likely leak by 252 gallons per minute ("gpm").
IJnfortunately, even after the most advanced grouting techniques were installed, flow
rates were projected to be reduccd by only 40 percent, i.e., 152 gpm would continue to
leak. Accordingly, roughly 80 million gallons annually, or roughly 245-acre feet per
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year, continued to leak from the South Cobb tunnel despite advanced grouting
techniques.

Although the SR 710 DEIR/S does not identiff the expected flow rates
upon completion of the tunnels, Wilson Geosciences assumed for purposes of their
analysis that the Project could result in the same relative amount of leakage as that from
the South Cobb tunnel. Based on Geosciences' analysis, the Freeway Tunnel alternative
could result in a 5.23 percent reduction in Pasadena Subarea storage each year.33 The
DEIR/S never discloses this potential dewatering of the Pasadena's water basin, in
violation of CEQA and NEPA.
Confusingly, while DEIR/S assures readers that the Project's tunnel
alternatives will be designed to avoid groundwater flows, the docurnent's technical
appendix acknowledges that groundwater inflows infact are expected to occur during
construction unless systernatic ground improvement measures are implemented to treat
the ground prior to excavation . See Tunnel Evaluation Report at 20. Despite this
alarrning fact, the appendix states that the estimates of the maximum potential
groundwater flush flows and sustained flows are not available and will not be developed
until future design phases. Id. at20. As a result, it impossible at this time for the agency
to develop specific criteria, plans, and procedures for effective groundwater control
measures. Id. at2l. The appendix never thus explains how the ground improvement
measures would actually control groundwater inflows.
The DEIVS's practice of deferring these critical analyses until after Project
approval violates CEQA and NEPA. Because the DEIR/S declines to analyze the
Projects' hydrological and geotechnical conditions, the document repeatedly concludes

Wilron Geosciences' conclusion may actually underestimate the

dewatering impact, as it is modeled on a study from seismically inactive environment in
Georgia, not for an earthquake-prone region of California. The Project's tunnel
alternatives would be constructed across multiple active faults. Indeed, there is a 93
percent chance of a magnitude 7 or larger earthquake occurring during the next 30 years
in southern California. See "Magnitude - 6.7 quake certain to hit California within 30
years, USGS says," March I0,2015, attached as Exhibit 32. The DEM fails to analyze

"

the potentially disastrous consequences from a moderate or large earthquake on any

the area faults.

of

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that impacts will be determined as they happen and mitigation will be worked out then.
This strategy is unlawful. An EIR is "an environmental alarm bell" whose purpose it is
to alert the public and its responsible officials to environmental changes bere they have
reached ecological points of no return. Laurel Heghts, 47 Cal.3d at 392; see also City of
Tenakee Sprngs, 915 F.2d at l3l3 ("NEPA requires consideration of the potential impact
of an action before the action takes place"). The DEIR/S's approach strips the document
of its key purpose: to provide forewarning.3a

In sum, the DEIVS lacks any evidentiary support for its conclusion that the
Project, particularly the tunnel alternatives, would not adversely impact groundwater
water supplies in the Rayrnond or San Gabriel groundwater basins under a steady state
scenario, much less in the event of a moderate or large earthquake.

(b)

Impacts to Groundwater Quality.

The DEIR/S's conclusion that impacts to groundwater quality would be less

than significant also does not stand up to scrutiny. The DEIVS does not analyze the
potential for groundwater pathways to transport contaminants in the Raymond Basin
(Pasadena Subarea) groundwater into the Main San Gabriel Basin - either along the
Raymond fault, along the tunnel contact with alluvium or bedrock, or through the tunnel.

As the Wilson Geosciences Report explains, cracked and fractured areas

that could facilitate seepage along the outside of the tunnel could allow contaminated
groundwater to flow from the Raymond Basin into the Main San Gabriel Basin. Potential
contamination of Raymond Basin groundwater could come from sources such as the Jet
Propulsion Laboratory's facilities or from incidents such as chemical or fuels spills along
the freeway. Studies have documented actual and projected movements of contaminants
from JPL (perchlorates) and groundwater flow pathways from north and northwest to
south and southeast, all toward the proposed bored tunnel location beginning at the SR21O/SR-134 interchange. Any current or future groundwater contamination along this

3o

Moreover, the fact that groundwater inflows are expected to occur

appears only the DEIVS's technical appendix keeps the public in the dark as to the true
magnitude of the Project's environmental effects. See Calfornia Oak Found., 133
Cal.App.4th at 1239 (information buried in an appendix is not a substitute for good faith
reasoned analysis in the EIR).

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pathway could end up at the proposed bored tunnel north of the penetration of the
Rayrnond fault.
As with its discussion of groundwater supplies, the DEIR/S relies primarily
on grouting to conclude that the Project's tunnel alternatives would not impact
groundwater quality . Id. at 3.9-17 . However, the DEIR/S does not analyze static effects,
such as vibration or chemical degradation, on the proposed grout. Nor does it consider
the effect that a moderate or iarger earthquake would have in disrupting the posto'irnpermeable" groundwater barrier. Rigorous analyses are needed to
construction
evaluate the potential impacts on groundwater quality resulting from ground movements.

Without any evaluation of the geologic units and fracture patterns in

bedrock, or of the potential deterioration of the "grout seal", the DEIVS fails to supporl
its conclusion that impacts related to groundwater contamination will be less than
significant.

4.

The DEIR/S Does Not Adequately Analyze Impacts to the

Laguna Regulating Basin or the Dorchester Channel.

(a)

Laguna Regulating Basin.

The Freeway Tunnel alternative (dual-bore) would require widening SR

710 along its east side, which is along the western boundary of the Laguna Regulating
Basin.3s Id. at 3.8-5. Widening the freeway to provide access to the south portal of the
dual-bore tunnel would involve a longitudinal encroachment within the floodplain of the
Laguna Basin. Id. at 3.8-6. The longitudinal encroachment, which would be up to 20
feet wide and 700 feet long along the Basin's western boundary, results from the
excavation necessary for the construction a bridge structure . Id. at 3.8-7 .
The DEIR/S asserts that this excavation and other construction activities
would not affect the storage volume or the Laguna Basin. Id. The document further

3s

The Freeway Tunnel alternative single-bore design variation would also

require widening SR 710 with associated irnpacts to the Laguna Regulating Basin. Id. at
3.8-5, -6.

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assefis that while construction of the bridge structure would result in slight modifications
to the floodplain boundary, the base floodplain elevation would not change. Id. at3.8-6;
7. However, because the document provides no information on the basin's existing
storage volume or floodplain elevation, it lacks any evidentiary support for its conclusion

that the Freeway Tunnel would not affect the floodplain's elevation.
The DEIVS also does not describe the extent of the excavation or provide
any details about the engineering of the bridge structure, e.g., the number and size of the
bridge pilings. Nor does it identify the existing floodplain elevations or the elevation of
the floodplain upon completion of the Project. Without this basic information, it is not
possible to determine the Freeway Tunnel alternative's hydrologic impacts on the Basin.

(b)

Dorchester Channel.

The dual-bore Freeway Tunnel design variation requires widening SR 710

along its west side, which is along Dorchester Channel's eastern boundary. DEIVS at
3.8-5, 6. It would also place fill into thc Channel, which would result in narrowing the
floodplain boundary. Id. at 3.8-8. The placement of fill and/or structures in a floodplain
would reduce the capacity of the basin and increase water surface elevation (d.), yetthe
DEIR/S concludes that these modifications would result in no increased flood risk to
adjacent communities. Id. The DEIVS lacks the evidentiary support for this conclusion.
What information that is provided in the DEIVS strongly indicates that the Freeway
Tunnel would in fact adversely impact the capacity of the flood basin, with associated
impacts to adjacent areas.
The DEIVS states that the dual-bore Freeway Tunnel would increase water
surface elevation by two feet, with the maximum increase occurring about 235 feet
upstream of the Hellman Avenue crossing. Id. However, the DEIR/S never explains the
implications associated with this increase in the Basin's water surface elevation; it rnerely
states that there would be no increased flood risk because water would still be contained
within the concrete box. Unfortunately, the DEM ornits the following critical
information: the capacity of the existing concrete box and the design engineering and
capacity of the new box. Furthermore, it provides no analysis of how hydrological flows
would change as a result of the Project, or the effect that these changes would have on
adjacent and downstream areas.

Notwithstanding the DEIR/S's lack of analysis, the document concludes

that the Project - specifically, the dual-bore Freeway Tunnel variation - would minimize

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the longitudinal encroachment within this floodplain. Id. at 3.8-8. The DEIVS further
asserts that other design variations considered for this Alternative were rejected because
they would have required geometric modifications to the horizontal or vertical alignment,
or realignrnent of the freeway mainline. Id. Yet, the DEIR/S includes none of this
information, even in summary form. The docurnent never even bothers to identi$r the
alternative design variations that the lead agencies purportedly considered.

In conclusion, the DEIR/S's failure to analyze or mitigate the Project's

hydrological and groundwater impacts is a clear violation of CEQA and NEPA.
Consequently, Metro and Caltrans may not rely on this EIR/S to approve the proposed
Project.

G.

The DEIR/S Fails to Evaluate the Project's Cumulative Impacts.

Both CEQA and NEPA require an analysis of a project's cumulative

impacts. CEQA def,rnes "cumulative impacts" as "two or more individual effects which,
when considered together, are considerable or which compound or increase other
environmental impacts." CEQA Guidelines $ 15355(a). "fl]ndividual effects may be
changes resulting from a single project or a number of separate projects." Id.
"Cumulative impacts can result from individually minor but collectively significant
projects taking place over a period of time." CEQA Guidelines $ 15355(b). The
cumulative irnpacts concept recognizes that "[t]he full environmental impact of a
proposed . . . action cannot be gauged in a vacuum." Whitman v. Bd. of Supervisors
(1979) 88 Cal. App. 3d 397 , 408. Likewise, NEPA requires analysis of connected and
similar actions that will lead to cumulative impacts. 40 C.F.R. $ 1508.25(a), (c); see also
Florda f4ltdlife Fed'n v. US. Army Corps of Eng'rs (D. Fla. 2005) 401 F.Supp.2d 1298.
NEPA regulations define a "cumulative impact" as "the impact on the environment which
results from the incremental impact of the action when added to other past, present, and
reasonably foreseeable future actions .. . ." 40 C.F.R. $ 1508.7.
Here, the DEIR/S's analysis of cumulative impacts fails to comply with
CEQA's and NEPA's clear requirements. To begin with, while the DEIR/S's cumulative
impact chapter identifies 40 projects (see Table 3.25-l), it essentially disregards the
potential for these projects, together with the SR 710 North Project, to result in
cumulatively significant environmental impacts. For example, the DEIR/S mentions the
Devil's Gate Reservoir Project but fails to analyze the effects of this project together with
the SR 710 North Project.

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The Devils Gate project, located in the City of Pasadena (very near the
northern terminus of the Tunnel Alternatives), involves a comprehensive sediment
removal plan that will restore and maintain flood control capacity at the Devil's Gate
reservoir. See Devil's Gate Reservoir Sediment Removal and Management Project, Final
EIR at ES-1, attached as Exhibit 33. This project will include removal of approximately
2.9 million cubic yards of existing excess sediment frorn the reservoir as well as
additional sediment that accumulates during construction. DEIVS at 3.25-10.
According to the DEM, sediment removal activities at Devil's Gate are expected to
occur over approximately 5 years, beginning in summer 2015. Id. This effort will
require an average of 50 truck trips per hour, with an estimated maximum of 425 truck
round-trips per day during excavation. Devils Gate FEIR at 85. Trucks depositing
sediment from Devil's Gate will travel along many of the freeways that will be impacted
by construction and operation of the SR 710 North Project, including thel-210, I-5, SR
134 and SR

2. Id. at238,240.

Even though construction of the two projects appears to be concurrent and

will impact many if not all of the same freeways, the DEIVS concludes that the SR 710
North Project, together with Devil's Gate, would not contribute to cumulative
transportation impacts.36 DEIR/S 3.25-28. Tellingly, the DEIR/S includes no evidence
to support this remarkable assertion. Moreover, the two projects would also result in
other oumulatively significant impacts, including air quality, climate change and noise
impacts. The DEIR/S should have provided a thorough analysis of these impacts.
The DEIR/S also fails to examine the cumulative impacts of the SR 710
North Project together with I-710 expansion project in Los Angeles County between
Ocean Boulevard and SR 60 ("I-710 South Project"). This ornission is surprising
inasmuch as the DEIR/S admits that the SR 710 North Project will have potential
cumulative impacts on traffc/transportation, hydrology/floodplain and air quality.
DEIR/S at3.25-3. The I-710 South Project includes widening I-710 up to 10 generalpurpose lanes (five lanes in each direction); modernizing and reconf,tguring the I-405, the
SR 91, and a portion of the I-5 interchanges with the I-710; modernizing and
reconfiguring most local arterial interchanges along the I-710; and providing a separated
four-lane freight corridor to be used by conventional or zero-emission trucks. Id, A
3u

The DEIR/S admits that the SR 710 North Project may be constructed
concuffently with the Devils Gate Project. DEIVS at3.25-28.

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RDEIR/SDEIS is being prepared to analyze a revised set of build alternatives for the I710 South Project and will be released for public review and comment in 2015. The
anticipated start of constructi on is 2020. Id.
As the letter submitted by Rossman & Moore on behalf of the City of South
Pasadena explains, there is an intimate connection between the I-710 South Project and
the proposed Project. Indeed, the projects occur along segments of the same freeway,
likely require design coordination, and will apparently be constructed concurrently.
Agencies may not improperly "segment" projects in order to avoid preparing an EIS or
EIR; instead, they must consider related actions in a single document. Thomas v.
Peterson, 7 53 F .2d 7 54, 7 58 (9th Cir. 1985); Laurel Heights, 47 Cal3d. at 37 6-395
(19SS). "Not to require this would permit dividing a project into multiple 'actions,' each
of which individually has an insignificant environmental impact, but which collectively
have a substantial impact." Thomas,753 F.2d at758. The Council on Environmental
o'connected,"
"cumulative,"
Quality's NEPA regulations thus require agencies to consider
and "similar" actions within a single EA or EIS. 40 C.F.R. $ 1508.25 ; Thomas, T 53 F ,2d
at 758-59. Similarly, CEQA regulations require that an EIR describe the entirety of a
project, including reasonably foreseeable future actions that are part of a project, and
must analyze those reasonably foreseeable actions. 14 Cal. Code Regs $ 15378(a). The
SR 710 North DEM must analyzethe impacts from these two projects together "when
the best way to assess adequately the cornbined impacts of similar actions or reasonable
alternatives to such actions is to treat thern in a single irnpact statement." 40 C.F.R. $
1s08.2s(a)(3).
The DEIR/S's cumulative impacts chapter is further flawed in that it does
not mention whole categories of potential cumulative impacts. For example, the DEIVS
never studies the potential for the Project, together with other projects listed in Table
3.25-I, to substantially deplete water supplies. In fact, the cumulative irnpact analysis
never mentions the term "groundwater supplies" at all. It also completely ignores health
risk impacts that would result from the release of mobile and other sources of toxic air
contaminants.

In other instances, the DEIR/S provides curnulative impacts analyses that

are simply nonsensical; as a result, its conclusions that these impacts are less than
significant lack any evidentiary basis. For example, regarding impacts to hydrology and
floodplains, the DEIR/S explains that the Freeway Tunnel alternative would encroach
into the Laguna Regulating and Dorchester flood basins. DEIR/S at3.25-34. It further
acknowledges that other curnulative projects such as thel-710 South Project and the
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Olive Pit Mining and Reclamation Project have the potential to result in"substqntial
effects relating to hydrology and floodplains;' Id. (ernphasis added). The DEIVS then
concludes, illogically, that because there are no feasible design variations for the Proiect,
the proposed Project would not have a cumulative impact on hydrology and floodplains.
It makes no attempt to actually analyze the effect of the other projects together with the
Project, as CEQA and NEPA require.
In regards to water quality and storm water impacts, the DEIVS states, "Of
the 39 projects listed in Table 3.25-1, none have the potential to contribute to an impact
on water quality because they all implement BMPs fbest management practices] and
other avoidance, minimization, andlor mitigation measures." Id. at3.25-36. This
statement defies common sense and is incorrect. If every project that were ever
developed fully mitigated water quality impacts with BMPs, the quality of water in Los
Angeles County would be pristine. Yet, as the DEIR/S explains, groundwater in the area
is impaired with, among other things, VOCs, nitrates, ammonia, copper, lead oil, trash,
coliform bacteria and cyanide and that this pollution is from sources such as residential
and industrial development. Clearly BMPs and other mitigation measures may
incrementally reduce some groundwater pollution, but they are not suffrcient to avoid
groundwater contamination altogether as the DEIR/S asserts.
As regards energy consumption, the DEIR/S explains that California is the
most populous state in the United States, and its total energy demand is second only to
Texas. DEIR/S at 3.25-46. It goes on to state:

Much of the energy consumed in the SCAG region is for

residential, commercial, and transpofiation purposes. Driven
by high demand from California's many motorists, major
airports, and military bases, the transportation sector is the
State's largest energy consumer" More motor vehicles are
registered in California than in any other state, and worker
commute times are among the longest in the country.
Transportation-related activities account for approximately
half of all the petroleum products consumed in California. Id.
Despite the fact that energy consumption is a major problem in California, the DEIWS
illogically states that "the 39 reasonably foreseeable actions have no or limited potential
to result in effects related to energy and, therefore, limited potential to contribute to
cumulative effects related to energy with particular relevance to energy." Id. at 3.25-47 ,

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The DEIR/S then finally adrnits that only one project - the El Monte Walmart - might
have limited potential to result in energy-related effects, but then implies, absent any
evidence, that it would be designed to reduce energy consumption, Id.
The DEIR/S's approach to cumulative transportation irnpacts is particularly
uninformative. First, the DEIR/S explains that for the purpose of this cumulative impacts
analysis, the Project study area includes a total of 156 intersections. DEIVS at 3 .25-26.
Yet, this is the precise study area used to examine Project-specffic impacts. Id. at 3.5-5.
Using the same study area for purposes of Project-specific and cumulative impacts might
be sufficient if the cumulative projects - and their respective transportation impacts - did
not extend outside the study area boundary. But, as discussed above, the study area here
is not even large enough to capture all of the Project-specific transportation impacts. It is
clearly too srnall to capture the Project's cumulative transportation irnpacts.

Perplexingly, many of the transportation projects identified on the DEIR's

curnulative projet list (Table 3.25-1) are actually located outside of this study arca.31
These projects include the following:

Proj

ect#l:

SR 710 south project (partially located outside the study area)

Proj ect #2: The I-5 Corridor Project (Project #2) (erirely outside the study
area)

Project #3: I-5 Improvement Project between SR-1 1 8

outside the study area)

Project #4:I-5 North Improvement Projects between SR-134

(entirely outside the study area)

Project# 5: I-SlWestern Interchange Improvements (entirely outside the

study area)

Project # 7: San Bernardino Freeway (I-10) add one HOV lane from I-605
to SR-57/71 &I-210 (entirely outside the study area)
3t

& SR-170 (entirely

&

SR-170

Co-pure Figure ES-1 (SR 710 North Study Area) and Figure 3.25-1 (SR

710 North Study Cumulative Project).

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Project # 9: the I-110 (Harbor Freeway)/Transitway HOT Lanes Project

(entirely outside the study area)
Project # 20: Wilshire Boulevard Bus Rapid Transit
(entirely outside the study area)

- Phases I & II

Project # 30: Olive Pit Mining and Reclamation Operations and Long Term
Reuse Project (entirely outside the study area).
Certain of these projects are massive; there can be no doubt that their transportation
impacts, together with the Project's, would be cumulatively considerable. The DEIR/S's
failure to evaluate the cumulative effect that these projects, taken together, would have on
the region's transportation network is a fatal flaw.

In fact, the DEIWS fails to analyze the transportation impacts of any of the
projects.
The DEIVS identifies 19 projects it purports to include in the
cumulative
curnulative transportation analysis because "they have the potential to contribute to
substantial changes in traffic conditions."38 DEIR/S at 3 .5-27. Despite having identifred
these 19 projects, the DEIR/S never conducts the required impact analysis. While it
asserts that the effects of these 19 projects were already analyzed in Project-specific
analysis (Id. a|"3.25-28), the DEIVS lacks any evidentiary support for this assertion. We
searched both the Transportation Technical Report and the Transportation Technical
Report Appendix for these projects (Devil's Gate Reservoir Sediment Removal and
Management Project and the Olive Pit Mining and Reclamation Operations and Long
Term Reuse Project) and neither document even mentions them. Thus, there is simply no
evidence to support the DEIR/S's claim that the agencies ever conducted any analysis of
the Proj ect' s cumulative transportation impacts.

The DEIR/S also fails to analyze the Project's cumulative air quality
irnpacts. Here, the DEIVS states that most of the 39 projects listed in Table 3.25-1 have

38

The DEIR/S fails to study the effects of the other 21 projects. This is a
serious omission since the DEIR/S clearly acknowledges that all of the projects identified
in Table 3.25-3 have "some potential to result in traffic irnpact and potential to contribute
to cumulative traffic impacts." Id. at 3.25-27. The failureto analyze these impacts is a
fatal flaw, warranting recirculation.

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the potential to result in air quality irnpacts and that 11 of these have the potential to
result in substantial air quality impacts. Id. at 3.25-43. Of these 1 1, the DEIR/S states
thatT projects would contribute to a permanent air quality impacts in the study area. Id.
at3.25-44 (emphasis added). Yet, the document does not proceed to the next required
step in the cumulative irnpacts analysis: (1) to quantifz the increases in emissions from
these nearby projects, and (2) to analyze how the increases frorr these projects would
affect air quality together withthe Project. The DEIVS's failure to provide any analysis
for the 7 projects that the DEIR/S concedes would contribute to a permanent air quality
impact, is particularly glaring.

Rather than provide the required analysis, the DEIR/S offers various
illogical arguments and conclusory statements that the Project will not contribute to any
cumulative air quality irnpact. For example, while the DEIR/S acknowledges that some
of the other projects could be constructed concurrently with the proposed Project, it
asserts that the Project's construction-related air quality impacts will be reduced because
it must comply with the SCAQMD Rule 403 and Caltrans Specif,rcations. Id. at3.25-44.
The DEIVS misses the point. Even if the Project's individual irnpact were small, the
agency is required to analyze that impact together with air quality irnpacts of other
projects, to determine the extent of the cumulative impacf. Kngs County Farm Bureau,
221 Cal.App.3d at720-21. CEQA Guidelines $ 15355(b) ("Cumulative impacts can
result from individually minor but collectively significant projects taking place over a
period of time.") 3e

Finally, as noted above, the DEIVS fails to provide an adequate analysis of

the Project's cumulative impacts on climate change. Clirnate change, of course, is the
classic example of a cumulative effects problem: emissions from numerous sources
combine to create the most pressing environmental and societal problem of our time.
Kings County Farm Bureau,221 Cal.App.3d at 720 ("Perhaps the best example [of a
cumulative impact] is air pollution, where thousands of relatively srnall sources of
pollution cause serious a serious environmental health problem."). As one appellate court
held, "the greater the existing environmental problems are, the lower the threshold for
treating a project's contribution to cumulative impacts as significant." Communties r
3n

In any event, as the Landrum & Brown Air Quality Report explains, the
DEM does not provide the necessary assurance that the Project's air quality impacts
would be reduced to less-than-significant levels.

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Better Env't v. Cal. Res. Agency (2002) 103 Cal.App.4th 98,120. Here, despite
overwhelming evidence of this environmental threat, the DEIVS neglects even to
measure the significance of the curnulative climate impact.

III.

The DEIR/S's Analysis of Alternatives Is Inadequate.

The DEIVS's analysis of alternatives falls short. Properly developing,

evaluating, and comparing project alternatives is key to the environmental review
process. Under CEQA, the alternatives analysis 'omust contain sufficient detail to help
ensure the integrity of the process of decision-making by precluding stubborn problems
or serious criticism from being swept under the rug." Kings County Farm Bureau,22l
Cal.App.3 d at733 (citing cases). An EIR that does not produce adequate inforrnation
regarding alternatives cannot achieve the EIR's dual purposes of enabling the reviewing
agency to make an informed decision and rnaking the decision-maker's reasoning
accessible to the public. Id. Similarly, the CEQ regulations describe the alternatives
analysis as "the heart of the environmental impact statement." 40 C.F.R. $ 1502.14. The
DEIR/S suffers from an inadequate analysis of the Project alternatives as discussed
below.

A.

The DEIR/S Does Not Provide an Adequate Comparative Analysis of

the Impacts of Each Alternative.

The DEIVS does not contain adequate analysis cornparing the alternatives'
respective environmental impacts. Under CEQA, readers must be able to "evaluate
[alternatives'] comparative merits." Kings County Farm Bureau,22l Cal.App.3d at733
(absence of comparative data in EIR precluded meaningful consideration of alternatives).
Likewise, the CE,Q's regulations provide that an EIS "should present the environmental
impacts of the proposal and the alternatives in comparative forrn, thus sharply defining
the issues and providing a clear basis for choice among options by the decision-maker
and the public." 14 C.F.R. $ 1502.14. A thorough comparison of the Project
alternatives' impacts is therefore crucial to a successful environmental document.
Unfortunately, the DEIR/S fails to provide this information. Instead of supplying an
actual qualitative or quantitative comparison of the impacts of each alternative, the
document merely summarizes, in abbreviated, tabular form, the information provided
elsewhere in the various DEIR/S chapters. ,See DEIVS at 2-87 , Table 2.15.
The DEIR/S's truncated approach is no substitute for the in-depth
discussion comparing each alternative's impacts that the law and common sense require.

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The matrix should provide more detailed descriptions of the alternatives' impacts, and a
rteans for readers to quickly and easily weigh them. (For example, in the matrix, each
cell in a ro\ry could contain a numeric ranking on a scale of 1 to 5 of the extent of that
impact.) Moreover, the document's current approach prevents the public frorn
understanding the effect on the environment of each alternative as a whole in comparison
to each other alternative. The DEIR/S should provide detailed narrative analysis and a
comprehensive discussion comparing the alternatives' impacts in addition to the existing
matrix. Organizing this discussion by irnpact category would be the preferred approach.

An actual comparative analysis of alternatives takes on special significance

here, where the agencies claim they have not identified a preferred alternative. Since at
this stage of the environmental review process any one of the document's alternatives
may be selected, the comparative analysis of the alternatives' impacts should be
particularly thorough.
This defciency is compounded by the fact that the Freeway Tunnel
alternative itself contains distinct variants, including single- and dual-bore tunnel designs
The DEIR/S must describe the comparative impacts of each of these variants in greater
detail throughout the document. For example, for noise and vibration impacts and
impacts to geology and soils, Table 2.15 does not distinguish between the Freeway
Tunnel alternative variants. DEIR/S at 2-96 to -97 ,2- 100 to - 10 I . It simply lumps the
impacts from these design options together, without distinguishing which impacts derive
from the single- or dual-bore variations. This shortcoming must be corrected throughout
the document. At the very least, where impacts will be identical for each of these
variants, the DEIR/S should state as much.

B.

The DEIR/S Fails to Identify an Environmentally Superior Alternative.

The DEIR/S does not specify an environmentally superior alternative, as

required by CEQA. CEQA Guidelines section 15I26.6(e)(2) provides that a lead agency
must identify an environmentally superior alternative among the alternatives considered.
See also Kings County Farm Bureau, 221 Cal.App.3d at 731; Latsonvlle Pilots Ass'n v.
City of Watsonville (2010) 183 Cal.App.4th 1059, 1089 (". . .the purpose of an
alternatives analysis is to allow the decision-maker to determine whether there is an
environmentally superior alternative that will meet most of the project's objectives.").
The DEIVS sirnply ignores this crucial requirement without explanation or justif,rcation.
The DEIR/S's failure to meet this requirement renders the document legally defective.

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This shortcoming is highly problematic. Identiffing an environmentally

superior alternative is a necessary prerequisite for the lead agency to make the findings
required by CEQA. In order to approve a project that would have a significant
environmental impact, an agency must make fndings identifying: (1) the "[s]pecific ...
considerations" that "make infeasible" the environmentally superior alternatives, and (2)
the "specific . . . benefts of the project [which] outweigh" the environmental harm. Pub.
Res. Code, $ $ 2 1002.1(b), 21081; Guidelines $ 15092(b). This requirement is rendered
inoperable if a lead agency is permitted to consider alternatives without identiSzing which
of them is environmentally superior.
The DEIR/S's failure to identiff an environmentally superior alternative is
therefore contrary to the very purpose of the EIR process. The omission undermines the
public's ability to determine which alternative is environmentally superior-and
therefore preferable-thus thwarting its capacity to comment on the Project and its
environmental review in a meaningful way. This task is made especially difficult by the
DEIR/S's failure to provide clear standards by which Caltrans and Metro will choose
between project alternatives, an infirmity described in detail in section I.A. of this letter.

C.

The DEIR/S Failed to Consider a Reasonable Range of Alternatives.

The DEIR/S is defective because it fails to consider a reasonable range of

alternatives, including a community-based multi-modal alternative. CEQA requires that
every EIR analyze areasonable range of potentially feasible alternatives to a proposed
project. See Pub. Res. Code $ 21100(bXa); CEQA Guidelines $ 15126.6(a); Center for
Biological Diversity v. County of San Bernardino (2010) 185 Cal.App. th 866 (EIR for
outdoor composting facility legally deficient for failure to consider alternative that would
significantly reduce air quality impacts). NEPA requires EISs to do the same. See 40
C.F.R. $ 1502.14; Natonal Parks & Conservation Ass'n v. Bureau of Land Management
(9th Cir. 2010) 606 F.3d 1058, 1072 (BLM's EIS for land swap overturned for failure to
analyze a "reasonable range of alternatives."). To be reasonable, the range of alternatives
analyzed in an EIR must provide enough variation from the proposed project "to allow
informed decisionmaking" regarding options that would reduce environmental impacts.
Laurel Heights, 47 CaL3d at 404-05.
The DEIR/S fails to meet CEQA and NEPA's requirements for a
reasonable range of alternatives. Members of the S-Cities Alliance have long encouraged
the lead agencies to consider alternatives that could achieve Project objectives without
the negative environmental impacts described above. Although the agencies hosted over

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90 community meetings and 200 stakeholder "briefings," DEIR/S atES-26, they have
ignored input from the 5-Cities Alliance member cities. For example, none of the
alternatives examined in the DEM includes eliminating either the north or south
freeway stubs, despite wide public support for this approach. Community meetings are
meaningless if, as here, agencies do not act on public input to shape project objectives
and alternatives.

Given the public support for this option, the lead agencies for the Project
should have considered a more innovative, multimodal alternative that combines mass
transit, bikeways, and new parks. As noted previously, the 5-Cities Alliance, in
conjunction with other organizations, has worked to develop a "Beyond the 710"
alternative that presents 21st-century options for connecting people to their destinations.
Exhibit 34 (Media Release for "Beyond the 710"), Exhibit 5 (Nelson Nygaard, 'oNew
Initiative for Mobility and Community"). This alternative uses transit and "great streets"
to sustainably grow communities and improve quality of life in the project area. Id. The
lead agencies must consider this, or a similar multi-modal alternative, to comply with
CEQA and NEPA.

CONCLUSION
The 5-Cities Alliance respectfully requests that Metro and Caltrans deny
the SR 710 North Project for the following reasons. First, the Project itself is flawed and
unnecessary, failing to provide areal solution to the region's needs. Second, the SR 710
North DEIR/S is inadequate under CEQA and NEPA, as the document fails to provide an
accurate, comprehensive analysis of Project impacts, rnitigation and alternatives. Third,
as the DEIR/S makes clear, the Project, particularly the Freeway Tunnel alternative,
would result in numerous significant and unmitigated environmental impacts. The lead
agencies should go back to the drawing board and prepare a different alternative, such as
"Beyond the710," that is both environmentally responsible and sensitive to community
needs. In the event that the agencies continue to pursue the present Project, they will
need to prepare and recirculate a revised DEIVS correcting the problems identified in
this letter.

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Very truly yours,

SHUTE, MIHALY & WEINBERGER LLP

B,d,t-

TJ,*I

Rachel B. Hooper

-/

c(
Laurel L. Impett, AICP, Urban Planner

ccs

La Caftada Flintridge City Council

Glendale City Council
Pasadena City Council
Sierra Madre City Council
South Pasadena City Council

List of
Exhibits:

Exhibit

Nelson Nygaard Report (Transportation)

Exhibit

Landrum & Brown Report (Air Quality and Greenhouse Gas)

Exhib it3

Landrum & Brown Report (Noise)

Exhibit

Wilson Geosciences Inc Report

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Page 89

Exhibit

Nelson Nygaard, "New Initiative for Mobility and Community"

Exhibit

California Deparlment of Transportation, Calfurna's 2040

Transportaton Plan, March 2015

Exhibit

S. Handy and M. Boarnet, California Air Resources Board

(CARB), Polcy Brief n the Impact of Hghway Capacty and
Induced Travel on Passenger Vehicle Use and Greenhouse Gas
Emissions, September, 30, 2014

Exhibit

California Department of Transportation, Smart Mobility Report,

20t0

Exhibit

Metropolitan Transp ortation Authority' s

Respondent's Brief, Cty of South Pasadeno v. Los Angeles Counlt
Metropolitan Transp. Authority, Court of Appeal, Second Appellate
District Case No. B22III8

Exhibit

10

G. Hamby Letter to J. Morales, December

Exhibit

11

Galloway, P., et al., Alaskan I4/ay Viaduct Replacement Program

Expert Revew Panel Updated Report, April 3,2015

Exhibit

12

B. Flyvbjerg, et al., What Causes Cost Overrun in Transport

I nfr a s tr uctur e P r oj e c t s ?, T r ansp ort Reviews, 200 4

Exhibir

13

B. Flyvbjerg,l4/hat You Should Know About Megaprojects and

Why: An Overview, Project Management Journal,2014

Exhibir

14

J. Blumenfeld Letter to M. Miles, September 28,2012

Exhibit

15

South Coast Air Quality Management District (SCAQMD), Air

Quality Signficance Thresholds (March 2015)

L os Angeles County

17

,2003

SHUTE, MIHALY

er--vEtNBERGERLp

Garrett Damrath
July 9, 2015
Page 90

Exhibit

Exhibit

Exhibit

16

T. Chico and J Koizumi, South Coast Air Quality Management

District (SCAQMD), Fnal Localized Significance Threshold
Methology" July 2008

17

R. Bhatia and T. Rivard, Assessment and Mitgotion of Air

Pollutant Health Efficts from Intra-urban Roadways: Gudance
Land Use Planning and Environmental Review, May 6, 2008

18

for

Office of Environmental Health Hazard Assessrnent (OEHHA), Air

Toxcs Hot Spots Program, Risk Assessment Guidelines, Gudance
Manual for Preparaton of Health Rsk Assessmenrs (February
201s)

Exhibit

19

U.S President's Council on Environmental Quality, Revsed Draft

Guidance on the Consideration of Greenhouse Gas Emissions and
the Efficts of Climate Change in NEPA Revews, December 18

20t4
Exhibit 20

G. Tholen , et al., California Air Pollution Control Officers

Association (CAPCO A), CEQA & Clmate Change, January 2008

Exhibit

Bay Area Air Quality Management District (BAAQMD),

Quality Gudelines excerpts, }l4ay 2012

21

Air

E.xhibit22

R. Ewing, et al.,IJrban Land Institute, Growng Cooler: Evdence

on Urban Development and Clmate Change, excerpts

Exhibit

Sightline Institute, Increases in Greenhouse-gas Emissons Front

Hghw ay-w idenng Pr oj e cts, October 2007

23

It and They'll

Exhiblt24

Surface Transportation Policy Project, Build

Exhibit 25

California Department of Transportation, State Smart

Transportaton Intative Asse s sment and Recommendatons,
January 2014

Come

SHUTE, MIHALY
gh--\EINBERCERnp

Garrett Damrath
JuIy 9,2015
Page 91

Exhibit 26

Exhibit2T

California Air Resources Board (CARB), Climate Change Scoping

Plan: A Frameworkfor Change, December 2008
California Air Resources Board (CARB), Frst Update to the
Climate Change Scoping Plan: Bulding on the Framework,May

20t4
Exhibit 28

D. Weikel, Los Angeles Times, California Commute: 4 stretches of

freeways tally most bg rig crashes per mile annually, June 2,2015

Exhibit 29

A. Gropman, 8l.I Bllon and Five Years Later, the 405 Congestion
Relief Project Is a FaL, L.A. Weekly, March 4,2015

Exhibit 30

CE Delft, Trffic Noise Reduction n Europe: Health fficts, social

costs and technical and polcy optons to reduce road and ral
trffic noise, excerpts, August 2007

Exhibit

31

N, Ovenden, et

a1.,

How the weather afficts the scale of urban noise

polluton,20II

Exhibit 32

6.7 quake certan to hit Calrnia within

30 years, U,SG,S says,March 10, 2015

Exhibit

Los Angeles County Flood Control District, Devl's Gate Reservor

Sediment Removal and Management Project Final Environmental
Impact Report, October 2014

33

Exhibir 34

89.3 KPCC, Magnitude

C. King, Beyond the 7I0: Movng Forward, Media Release, May

28,2015

678390.7

SHUTE, MIHALY

(=vetNBERCERu-p

Technical Appendix 1
(Transportation)

to
Attachment A
5-Cities Alliance
Comment Letter

MEMORANDUM
To:

Project Team

From:

Jeff Tumlin

Date:

June 24, 2015

Subject: DRAFT Nelson\Nygaard analysis of SR 710 N Extension Project

PURPOSE OF THIS MEMORANDUM

This memorandum represents a high-level overview of our analysis of the SR 710 North project,
its EIR, and supporting documents. It includes descriptive graphics suitable for public
consumption, as well as a running list of questions to submit to Caltrans and its EIR team.

ANALYSIS AND GRAPHICS

Our analysis of the impacts of the SR 710 North Extension Project, as envisioned as a freeway
tunnel, yielded various key themes and findings. The themes include the following:

The tunnel project increases regional vehicle miles traveled (VMT) and CO2 emissions.

The tunnel benefits only a select few, and only by a small amount.

Regional traffic is not improved as a result of the tunnel; rather, it shifts congestion
around.

The tunnel makes arterial traffic worse along certain streets in Alhambra and Rosemead.

Traffic gets significantly worse on various connecting freeways as a result of the tunnel, in
part by inducing extra driving.

The EIR doesnt allow comprehensive analysis of real solutions to the SGVs
transportation needs, particularly for transit.

More detail on each finding is presented in the following sections.

Increased VMT and CO2 emissions

As shown detailed in the Transportation Technical Report, all the tunnel alternatives result in an
increase in actual and per capita VMT beyond the no-build scenario. 1 Figure 1 compares localized
2035 VMT in the project study area across various project scenarios, including no-build and
various freeway tunnel alternatives. As shown, total VMT increases under all tunnel alternatives,

See Transportation Technical Report, SR 710 North Study, Table 4-8, pg 4-15

116 NEW MONTGOMERY STREET, SUITE 500

SAN FRANCISCO, CA 94105

www.nelsonnygaard.com

415-284-1544

FAX 415-284-1554

Nelson\Nygaard Analysis of SR 710 N Extension Project

Cities of South Pasadena, La Canada Flintridge, Glendale, Pasadena, and Sierra Madre

by as many 460,000 miles per day. Per capital VMT also increases with all freeway tunnel
alternatives.
Figure 1

Study Area VMT: No Build and Freeway Tunnel Alternatives

No Build
(2035)
25,120,000

Daily Study Area VMT per Day

Study Area Population
Study Area per capita VMT per Day
Estimated Increase in Total Daily
VMT Compared to No-Build 2
Increase in per capita Daily VMT
Compared to No-Build

Freeway Tunnel Alt. (2035)

Low
High
25,300,000

25,580,000

1,330,000

1,330,000

1,330,000

18.89

19.02

19.23

180,000

460,000

+1%

+2%

As a general rule of thumb, up to 975 hourly vehicles in each direction of travel can be
accommodated per through lane along a typical roadway. 3 Using this assumption, the increase in
daily VMT caused by the freeway tunnel alternatives would necessitate between approximately 15
and 39 highway or lane miles to accommodate this increase in vehicle miles traveled.
The Southern California Association of Governments 2012-2035 Regional Transportation
Plan/Sustainable Communities Strategy outlines the regions transportation future, including
targets for VMT and greenhouse gas emissions. As detailed in the California Air Resources Board
analysis of the plan, it sets a goal for a 10.8% reduction in per capita VMT across the region, down
from 22.5 miles per day per capita, to 20.3 in 2035. 4 Figure 2 compares 2035 regional per capita
VMT for (1) the approved regional Sustainable Communities Strategy, (2) the no build scenario as
analyzed in the SR 710 N project EIR, and (3) various tunnel options. As shown, all analyzed
scenarios result in higher daily regional VMT, as well as higher per capita VMT. This raises two
concerns: (1) the already stated concern that the freeway tunnel alternatives induce increased
VMT, and (2) that the SR 710 N project EIR is not consistent with the assumptions and targets of
the regional SCS and its full implementation. The latter concern represents a key question to ask
Caltrans and its EIR consultant during the public comment period. While the EIR concludes the
tunnel option is consistent with the RTP, it does so merely because it is included in the RTP as a
future project. Conversely, the EIR fails to adequately analyze the Projects consistency with the
RTP/SCS because it increases VMT and, as a result, GHG emissions.

The EIRs analysis does not state how VMT is calculated, and no details about modeling have been provided, despite
repeated requests. So we have estimated VMT difference as follows:
975 = hourly lane capacity
11700 = lane capacity over 12-hour period (for arguments sake)
180,000 / 11,700 = 15.4
460,000 / 11,700 = 39.3
3 Volumes beyond this saturation point lead to various amounts of congestion and delay.
4 Technical Evaluation of the Greenhouse Gas Emissions Reduction Quantification for the Southern California Association
of Governments SB 375 Sustainable Communities Strategy. California Air Resources Board (May 2012).
http://www.arb.ca.gov/cc/sb375/scag_scs_tech_eval0512.pdf
2

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Nelson\Nygaard Analysis of SR 710 N Extension Project

Cities of South Pasadena, La Canada Flintridge, Glendale, Pasadena, and Sierra Madre

Emissions impacts are of particular concern given new State goals for emissions reductions
instituted by Governor Schwarzenegger and strengthened by Governor Brown, including 40%
reductions over 1990 levels by 2030, and 80% over 1990 levels by 2050. 5 The EIR actually shows
a slight decrease in greenhouse gas emissions in the study area (see tables 4.9 and 4.10 on page 4100) across some tunnel alternatives, but does not reconcile this finding with the large increases
in VMT as a result of the tunnel alternatives.
Figure 2

Horizon Year (2035) Change in VMT (No Build and Freeway Tunnel Alternative)
SCS Target

No Build
(2035)

Freeway Tunnel Alt. (2035)

Low

High

Daily Regional VMT

449,934,000

471,435,000

471,530,000

471,950,000

Population

22,091,000

22,091,000

22,091,000

22,091,000

20.37

21.34

21.34

21.36

Increase in Total VMT Compared to

SCS target

21,501,000

21,596,000

22,016,000

Increase in Total Daily VMT

Compared to No Build

95,000

515,000

Per capita VMT

In sum, the freeway tunnel alternatives unilaterally result in increased VMT, directly
contradicting State and regional efforts to reduce greenhouse gas emissions. These VMT increases
also likely do not take into account true induced demand of the project, since the EIR does not
state the assumptions that were used to calculate induced demand. In other words, as more
freeway lane miles and alternative routes are introduced, driving becomes a more convenient
option. This serves to induce more vehicle trips from people who otherwise would not have
traveled via car or made that trip altogether. Figure 3 includes a stylized infographic covering the
VMT impacts of the freeway tunnel alternatives.

http://www.nytimes.com/2015/04/30/us/california-governor-orders-new-target-for-emissions-cuts.html

Nelson\Nygaard Consulting Associates Inc. | 3

Nelson\Nygaard Analysis of SR 710 N Extension Project

Cities of South Pasadena, La Canada Flintridge, Glendale, Pasadena, and Sierra Madre

Figure 3

Infographic of Tunnel Alternative VMT Impacts

Minimal Benefits
Supporters of the tunnel project often cite its ability to shift long distance cut-through traffic off of
existing arterials in the study area and onto the regional highway network. According to the
Transportation Technical report and as shown in Figure 4, only 13.7% of current peak period
traffic on study area arterials represents cut-through traffic, defined to include motorists driving
between adjacent cities. By providing a new freeway link, the tunnel alternatives reduce this cutthrough share from 13.7% to between 7.3% and 10.6%, which represents a rather small reduction
given the high project costs (~$5.5 billion).
By reducing this cut-through traffic, approximately 7% to 13% of all motorists throughout the
study area will receive a rather small travel time savings of 2.5 minutes or better, mostly those
motorists using the new tunnel itself to travel significant distances. This means that
approximately 87-93% of motorists in the study will get no significant travel time savings, or their
travel time will be worse as a result of the project.

Nelson\Nygaard Consulting Associates Inc. | 4

Nelson\Nygaard Analysis of SR 710 N Extension Project

Cities of South Pasadena, La Canada Flintridge, Glendale, Pasadena, and Sierra Madre

Figure 4

2035 Cut-Through Traffic and Improved Travel Time 6

Freeway Tunnel Alt. (2035)

PM Peak Period Percent CutThrough Traffic Using

Arterials in Study Area
Percent AM and PM Peak
Period trips more than 2.5
minutes faster than No Build

No Build (2035)

Low

High

13.7%

7.3%

10.6%

7.0%

13.0%

Freeway Traffic Doesnt Get Better: It Shifts Around

In analyzing projected 2035 traffic patterns under the No-Build and tunnel alternatives, it is clear
that the overall performance of the freeway network does not improve as a result of the project;
traffic is merely shifted around from various freeway segments (such as I-605 and SR-2) to others
(I-5, I-10, I-210, and I-710). Some of the freeway segments that see increased congestion, such as
I-5, are those that are already operating at stressed levels (LOS F) during peak periods. With all
tunnel options, congestion on most freeways stays about the same. The only significant benefits
are various reductions in congestion on I-605 and SR-2. Figure 5 and Figure 6 map the change in
AM and PM peak period congestion, respectively, comparing the No-Build alternative to the
Dual-Bore tunnel alternative. Figure 7 displays the exact congestion impacts, potential
improvements to alleviate these impacts, and whether or not the improvements are
recommended for implementation.
The traffic analysis for the tunnel project suggests the following effects:

By connecting the 710 to the 210, the tunnel options succeed in shifting a significant
amount of traffic off the 605 and onto the 710 and 210, as well as inducing new northsouth driving. Traffic increases by about 1,350 vehicles in the peak hour on the 710 south
of the 10, and about 2,600 vehicles per hour north of the 10. Traffic on the 210 increases
by about 380 vehicles per hour through La Canada Flintridge, and by about 400 vehicles
per hour through Pasadena.

The significant increase in congestion on the 210 means that many drivers would avoid
using the Glendale Freeway, and instead stay on the 5, exacerbating existing traffic
congestion on the 5.

The project results in significant induced north-south travel demand, adding traffic to
both the 5 and 210 freeways. Where those freeways join, in the bottleneck south of the
Highway 14 split, there would likely be a significant increase in traffic congestion, with an
additional 650 vehicle in the peak hour. While the project would result in significant
increases in congestion in this segment, the EIR does not analyze the impact.

See Transportation Technical Report, SR 710 North Study, Table 4-9, pg 4-18

Nelson\Nygaard Consulting Associates Inc. | 5

Nelson\Nygaard Analysis of SR 710 N Extension Project

Cities of South Pasadena, La Canada Flintridge, Glendale, Pasadena, and Sierra Madre

Figure 5 2035 Change in AM Peak Period Congestion (Build vs. No Build Alternatives)

Nelson\Nygaard Consulting Associates Inc. | 6

Nelson\Nygaard Analysis of SR 710 N Extension Project

Cities of South Pasadena, La Canada Flintridge, Glendale, Pasadena, and Sierra Madre

Figure 6 2035 Change in PM Peak Period Congestion (Build vs. No Build Alternatives)

Nelson\Nygaard Consulting Associates Inc. | 7

Nelson\Nygaard Analysis of SR 710 N Extension Project

Cities of South Pasadena, La Canada Flintridge, Glendale, Pasadena, and Sierra Madre

Figure 7
Freeway
I-10

SR 134

I-210

I-5

I-710

2035 Traffic Impact and Potential Mitigation by Freeway Segment (Build vs. No Build Alternatives)
Freeway Segment

Impact

Potential Mitigation

Recommended for
Implementation?

I-10 westbound between the SB I-605 on-ramp and the Garvey Avenue/Durfee Avenue off-ramp

AM: +90 VPH (LOS F to E)

PM: +170 VPH (LOS F to F)

Active Traffic and Demand Management

SR 134 westbound between the Linda Vista Avenue /San Rafael Avenue on-ramp and the Figueroa/Colorado off-ramp

PM: +580 VPH (LOS E to F)

Add an auxiliary lane between the San Rafael Avenue on-ramp and the Figueroa Street off-ramp

SR 134 westbound between the SB SR 2 on-ramp and the Glendale Avenue off-ramp

PM: +390 VPH (LOS F to F)

Add a lane starting at the Harvey Drive on-ramp and drop it after the Central Avenue off-ramp

SR 134 westbound between the Glendale Avenue on-ramp and the Brand Boulevard/Central Avenue off-ramp

PM: +480 VPH (LOS D to F)

I-210 eastbound between the Polk Street on-ramp and the Hubbard Street off-ramp

AM: +380 VPH (LOS F to F)

I-210 eastbound between the Hubbard Street off-ramp and the Hubbard Street on-ramp

AM: +390 VPH (LOS E to F)

I-210 eastbound between the Hubbard Street on-ramp and the Maclay Avenue off-ramp

AM: +360 VPH (LOS F to F)

I-210 eastbound between the Maclay Avenue off-ramp and the Maclay Avenue on-ramp

AM: +400 VPH (LOS F to F)

I-210 eastbound between the Maclay Avenue on-ramp and the WB SR118 off-ramp

AM: +390 VPH (LOS F to F)

I-210 eastbound between the Pennsylvania Avenue off-ramp and the Pennsylvania Avenue on-ramp

AM: +380 VPH (LOS F to F)

I-210 eastbound between the Pennsylvania Avenue on-ramp and the La Crescenta Avenue on-ramp

AM: +380 VPH (LOS F to F)

I-210 eastbound between the La Crescenta Avenue on-ramp and the Ocean View Boulevard off-ramp

AM: +380 VPH (LOS F to F)

I-210 eastbound between the Lake Avenue on-ramp and the Marengo Avenue off-ramp

AM: +400 VPH (LOS F to F)

Add an auxiliary lane between the Lake Avenue on-ramp and the Marengo Avenue off-ramp, add
one lane to the Lake Avenue on-ramp and the Marengo Avenue off-ramp

I-210 westbound between the EB SR 118 on-ramp and the Maclay Avenue off-ramp

PM: +210 VPH (LOS F to F)

Active Traffic and Demand Management

I-210 westbound between the Maclay Avenue off-ramp and the Maclay Avenue on-ramp

PM: +210 VPH (LOS E to F)

I-210 westbound between the Maclay Avenue on-ramp and the Hubbard off-ramp

PM: +210 VPH (LOS F to F)

I-210 westbound between the Hubbard Street on-ramp and the Polk Street off-ramp

PM: +210 VPH (LOS E to F)

I-5 northbound between the SR 2 NB off-ramp and the SR 2 SB offramp

AM: +250 VPH (LOS F to F)

I-5 northbound between the SR 2 SB off-ramp and the SR 2 on-ramp

AM: +250 VPH (LOS F to F)

I-5 southbound between the Stadium Way off-ramp and the SR 2 on-ramp

AM: +230 VPH (LOS E to F)

I-710 northbound between the Olympic Boulevard on-ramp and the SR 60 off-ramp

PM: +260 VPH (LOS F to F)

Active Traffic and Demand Management

I-710 northbound between the Cesar Chavez Avenue on-ramp and the Ramona Boulevard offramp

AM: +760 VPH (LOS F to F)

Add a lane between the Cesar Chavez Avenue on-ramp and the I-10 off-ramp

I-710 northbound between the Ramona Boulevard off-ramp and the I-10 off-ramp

AM: +830 VPH (LOS F to F)

I-710 northbound between the I-10 off-ramp and the EB I-10 on-ramp

AM: +2,600 VPH (LOS C to E)

PM: +2,700 VPH (LOS B to E)

Add a lane between the I-10 off-ramp and the EB I-10 on-ramp

I-710 southbound between the EB I-10/Ramona Boulevard on-ramp and the Cesar Chavez Avenue offramp

AM: +1,350 VPH (LOS E to F)

PM: +570 VPH (LOS F to F)

Add a lane between the Ramona Boulevard on-ramp to the SR 60 off-ramp

I-710 southbound between the Cesar Chavez Avenue off-ramp and the SR 60 off-ramp

AM: +1,140 VPH (LOS D to F)

PM: +440 VPH (LOS F to F)

I-710 southbound between the SR 60 off-ramp and the Cesar Chavez Avenue on-ramp

PM: +1,070 VPH (LOS E to F)

Add a deceleration lane for the SR 60 off-ramp and add a lane between the SR 60 off-ramp and
the Cesar Chavez Avenue on-ramp

No

I-710 southbound between the Cesar Chavez Avenue on-ramp and the Third Street on-ramp

PM: +960 VPH (LOS F to F)

Add a lane starting at the Cesar Chavez Avenue on-ramp and drop it before the SR 60 on-ramp

No

Nelson\Nygaard Consulting Associates Inc. | 8

Yes
No
No

Add a lane between the Polk Street on-ramp and the Paxton Street off-ramp
No

Add a lane between the Pennsylvania Avenue off-ramp and the Ocean view Boulevard
off-ramp

No

No

Yes

Active Traffic and Demand Management

Yes
Yes
No
No

No

Nelson\Nygaard Analysis of SR 710 N Extension Project

Cities of South Pasadena, La Canada Flintridge, Glendale, Pasadena, and Sierra Madre

Freeway

Freeway Segment

Impact

Potential Mitigation

I-710 southbound between the Third Street off-ramp and the SR 60 on-ramp

PM: +880 VPH (LOS E to F)

Add a lane between the Third Street off-ramp and the SR 60 on-ramp

I-710 southbound between the SR 60 on-ramp and the Whittier Boulevard /Olympic Boulevard off-ramp

AM: +240 VPH (LOS F to F)

PM: +220 VPH (LOS F to F)

Active Traffic and Demand Management

I-710 southbound between the Whittier Boulevard /Olympic Boulevard on-ramp and the SB I-5 on-ramp

AM: +200 VPH (LOS F to F)

Source: Table 7-16 of Transportation Technical Report

Nelson\Nygaard Consulting Associates Inc. | 9

Recommended for
Implementation?
No
Yes

Nelson\Nygaard Analysis of SR 710 N Extension Project

Cities of South Pasadena, La Canada Flintridge, Glendale, Pasadena, and Sierra Madre

This lack of improvement in overall freeway traffic congestion forecast with the proposed project
is consistent with national research and experience throughout the U.S. In work done for the
California Air Resources Board, researchers at the University of California and the University of
Southern California reviewed the research literature on induced travel and concluded:
Thus, the best estimate for the long-run effect of highway capacity on VMT is an
elasticity close to 1.0, implying that in congested metropolitan areas, adding new
capacity to the existing system of limited-access highways is unlikely to reduce
congestion or associated GHG in the long-run. 7
This conclusion is based on review of a thorough review of 20 research papers on induced travel
published between 1997 and 2012. An elasticity of 1.0 between VMT and roadway capacity means
that there is no net reduction in congestion. The bottlenecks are simply shifted from one place to
another. Here are three real-world documented examples of this process of shifting bottlenecks:

In the Chicago area, one particularly bad bottleneck on the Eisenhower Expressway,
referred to as the Hillside Strangler, was improved at a cost of $140 million. According
to many local sources, the congestion at that particular location improved, but the traffic
bottleneck only shifted to adjacent areas. In fact, the commute time from the suburbs to
the Loop, via the Eisenhower and its extension, is one hour - exactly what it was before
the Hillside Strangler was repaired.[Daily Herald, October 3, 2002]

The Boston Globe reported that the $15 billion invested by the state and federal taxpayers
for the Big Dig increased mobility on the expanded roadway. But most travelers who
use the tunnels are still spending time in traffic jams just not in the heart of the city,
where bumper-to-bumper was a way of life on the old elevated artery. The Globe
documented no apparent overall travel time savings; rather, it reported a number of trips
where travel times have increased, including one case where peak period travel time has
doubled from 12 minutes to 25 minutes. .[Boston Globe, November 16, 2008]

The $1.1 billion I-405 Sepulveda Pass Completion Project was completed in 2014 after 5
years of extensive construction delays. LA Weekly reported that the project failed to
reduce congestion: A traffic study by Seattle-based traffic analytics firm Inrix has shown
that auto speeds during the afternoon crawl on the northbound 405 are now the same or
slightly slower the maddening 35-minute tangle between the 10 and the 101 is actually a
minute longer. More worrisome is the morning southbound logjam. Its so bad, post
improvements, that when Caltrans issues its worst bottleneck rankings in August,
unofficial data suggest that the 10-mile stretch of the 405 between the Valley and the
Westside could be the worst freeway segment in California. [LA Weekly, $1.1 Billion and
Five Years Later , the 405 Congestion Project is a Fail, March 4, 2015]

As discussed above, the EIR modeling indicates that the proposed project would similarly move
bottlenecks around rather than truly addressing regional congestion. The travel demand model
relied on in the EIR is incapable of properly analyzing these bottlenecks. All of the roadway
segments listed in Figure 7 above are forecast in the EIR to operate at Level of Service (LOS) F in
2035. This means that the modeled demand is greater than the traffic volume that can travel
across the freeway segments. When demand exceeds supply, accurate analysis as described in the

Handy, Susan and Marlon G. Boarnet. Impact of Highway Capacity and Induced Travel on Passenger Vehicle Use
and Greenhouse Gas Emissions: Policy Brief prepared for California Air Resources Board, September 30, 2014.

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Nelson\Nygaard Analysis of SR 710 N Extension Project

Cities of South Pasadena, La Canada Flintridge, Glendale, Pasadena, and Sierra Madre

Highway Capacity Manual requires that the excess volume spill over into adjacent upstream
segments 8 and be accumulated unless demand drops enough that the bottleneck can clear
Anyone who has driven freeways in the Los Angeles region has experienced such spillback. The
EIR model does not include spillback but instead assumes that all modeled vehicles will get
through the bottleneck.
The importance of this serious model deficiency is demonstrated below using EIR model numbers
for I-710 northbound at I-10 (the primary upstream source of northbound tunnel traffic). Figure 8
shows that excess traffic demand totals 16,412 vehicles for the 13-hour weekday period from 6
a.m. to 7 p.m. in the Dual-Bore tunnel alternative. Although the mid-day traffic period is not
addressed in the EIR, it actually is the most congested of the three peak model periods. There is
an excess of 1304 vehicles per hour compared to 1099 vehicles per hour in the morning peak
period and 1255 vehicles per hour in the afternoon peak period.
Figure 8

2035 Spillback on Northbound I-710 at I-10 Calculated from EIR Model Files for Dua-Bore
Tunnel Alternative)
Capacity 9

Demand (PCE) 10

Spillback

AM peak period 6-9

16,200

19,498

3,298

Mid-day period 9-3

32,400

40,223

7,823

PM peak period 3-7

21,600

26,621

5,021

70,200

86,342

16,142

Total (13 hours)

If the EIR traffic demand forecasts were accurate, traffic would begin spilling back at 7 a.m. and
the queue would get longer and longer during the day. As shown in Figure 9, at 7 p.m. the queue
would reach 3 hours in length. It would take much longer than 3 hours for such a queue to clear
because vehicles would continue to arrive after 7 p.m.

Transportation Research Board, Highway Capacity Manual, p. 25-12, 2010.

Using 1800 vehicles per lane per hour as used in EIR modeling. Actual capacity can only be measured in the field, but
most likely is no more than 2000 vehicles per lane per hour. If capacity was 2000 vehicles per lane per hour, the 13hour spillback would be 8,342 vehicles.
10 PCE is Passenger Car Equivalents. Trucks count more than 1.0 PCE.
8
9

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Nelson\Nygaard Analysis of SR 710 N Extension Project

Cities of South Pasadena, La Canada Flintridge, Glendale, Pasadena, and Sierra Madre

Figure 9

2035 Queue Length behind northbound I-710 at I-10 Calculated from EIR Model Files for DualBore Tunnel Alternative) 11

3.5
3.0

16,142 vehicles in I-710

queue at 7 p.m.

Hours to Clear Queue

2.5
2.0
1.5
1.0
0.5
0.0

6:00
AM

7:00
AM

8:00
AM

9:00 10:00 11:00 12:00 1:00

AM AM AM PM PM

2:00
PM

3:00
PM

4:00
PM

5:00
PM

6:00
PM

7:00
PM

This 3-hour+ queue would never actually happen because travelers would adjust their behavior to
avoid such an extreme bottleneck. Nevertheless, this is a more accurate portrayal of this roadway
section than the pure fantasy that is represented in the EIR model files. In the AM peak period in
the No Build alternative, the northbound section of I-710 at I-10 is modeled as the 280th most
congested freeway segment in the greater Los Angeles region. In the Dual-Bore tunnel alternative,
this section moves up the list 256 places to become the 24th most congested freeway segment in
the region. Nevertheless, the model assumes that the increased travel time on this section is only 1
minute relative to the No Build alternative. The actual delay would be many times that long
even if much of the excess demand never materializes.
Relying on this fantasy model leads to erroneous conclusions including:

11

Greatly underestimating the increased delays where the project would create new
bottlenecks or make existing bottlenecks worse.

Overestimating tunnel volumes because upstream bottlenecks are not accounted for.

Overestimating diversion from arterial roadways because the model assumes more
throughput at freeway bottlenecks than is possible.

Miscalculation of air pollution including greenhouse gas emissions.

Inaccurate estimation of induced travel.

Negative impacts for other Build alternatives vary in degree but not in kind.

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The EIR travel demand model would show benefits from added freeway capacity in any location
because it treats each roadway section as completely independent. The model cannot account for
delays from bottlenecks. Engineers have been playing a very expensive game of whack-a-mole
and losing. Capacity is expanded at one bottleneck which causes other bottlenecks to worsen and
new bottlenecks to appear. Then these other bottlenecks are whacked in succession without any
reduction in regional congestion. An analysis of congestion across U.S. regions shows that
additional freeway capacity actually is positively correlated with increased regional congestion;
i.e. more freeway capacity = more congestion. 12
The EIR estimates for future air pollution and greenhouse gas emissions all are developed on a
roadway segment-by-segment basis that assumes that the forecast volumes and speeds are
accurate. As demonstrated above, the travel demand model is incapable of properly modeling the
extreme roadway bottlenecks forecast for 2040, including bottlenecks that would be made worse
by the proposed tunnel. If the forecast traffic volumes were accurate, as discussed above there
would be a 3+ hour queue for I-710 at I-10 northbound at the end of the afternoon peak travel
period. This would suggest an average delay over a 24-hour period that would be on the order of
an hour rather than the roughly 2 minutes estimated in the model. Alternatively, if the forecast
speeds were accurate, then future traffic volumes must be much lower than forecast. Either way,
the forecast air pollution and greenhouse gas emissions are wrong for all alternatives. Comparing
sets of wrong estimates across the alternatives and drawing conclusions from one number being
slightly higher or lower than another is unwarranted.
Similarly, the travel demand model cannot be trusted to accurately estimate induced travel. The
forecast traffic volumes are wrong on a segment-by-segment basis. Therefore, adding up VMT on
a segment-by-segment basis also results in numbers that are wrong. The DEIR traffic modeling
cannot properly inform the public as to either the intended or unintended consequences of the
proposed tunnel.
Even if the travel demand model could be trusted to accurately estimate induced travel, the time
period analyzed in the EIR is too short. Because project construction is expected to take
approximately five years, and will not begin until after 2015, the EIRs analysis of traffic-related
emissions from the Freeway Tunnel alternatives begins in operational year 2025 (p. 4-100).
However, the EIR analyzes traffic demand only through 2035. This means that it only analyzes
traffic-related impacts from the Freeway Tunnel alternatives during a ten year window. This is
misleading. As outside research cited in our comment letter shows, during this short-term
window congestion may actually be reduced as a result of increased capacity. However, after this
period, the purported efficiency gains, if any, can be expected to dissipate as a result of induced
demand. Therefore, the EIR should have analyzed and forecasted traffic through 2050. Caltrans
may respond that the EMFAC2011 model only forecasts through the year 2035. But this is no
excuse to ignore impacts from 2035 to 2050. Even if Caltrans is unable to provide a quantitative
analysis of traffic from 2035 to 2050, it should still have provided a qualitative analysis. This is
especially true given the current research regarding the long-term (10 + years out) effects of
induced demand from increasing capacity.
The I-710 bottleneck used as an illustration is only one the bottlenecks that the proposed project
either would create or make worse. The EIR modeling does more to highlight the deficiencies of

12 Marshall, Norman L. A Statistical Model of Regional Traffic Congestion in the United States. Submitted for
presentation at the 2016 Annual Meeting of the Transportation Research Board.

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the underlying model than it does to tell us anything about the real world. It certainly is no basis
on which to justify spending billions of dollars.

Arterial traffic congestion gets worse in Alhambra and

Rosemead
As discussed previously, the freeway tunnel alternatives result in reduced cut-through traffic
along some study area arterials. However, the tunnel alternatives also result in increased
congestion in certain areas and decreased intersection performance. Figure 10 and Figure 11
compare AM and PM peak period intersection LOS, respectively, for the No-Build and Dual Bore
alternatives. While performance improves at some intersections (notably along Huntington Drive,
portions of South Fremont Avenue, and portions of East Valley Boulevard), the tunnel options
make arterial congestion generally worse in parts of Alhambra, Rosemead, San Marino, Pasadena,
and South Pasadena, particularly on:

West Valley Boulevard in Rosemead

South Garfield Avenue in Alhambra

Huntington Drive in San Marino

Fair Oaks Avenue and Fremont Avenue in South Pasadena

Rosemead Boulevard in Rosemead

Various intersections in downtown Pasadena

The traffic issues in and around Alhambra seem to be due to the fact that trips to Alhambra from
the north and south would get concentrated at the Valley Boulevard ramps rather than filtering
through the grid as they do now.

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Figure 10

2025 Change in AM Peak Period Level of Service (Build vs. No Build Alternatives)

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Figure 11

2025 Change in PM Peak Period Level of Service (Build vs. No Build Alternatives)

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Arterial traffic congestion gets worse in Pasadena

One of the reasons why expanding freeway capacity is so ineffective at reducing congestion is that
freeway expansion increases congestion on the local street network in the vicinity of on-ramps
and off-ramps. No trip begins or ends on a freeway. Each vehicle shifted to freeways increases
congestion at access points which often are the most congested points in the non-freeway road
network. Figure 12 shows non-freeway roadways in Pasadena where the modeled traffic volume
would increase by 5,000 vehicles per day in 2035 with the Dual-Bore tunnel as compared to the
No Build alternative.
Figure 12

Pasadena Streets with 5,000 or More Additional Vehicles per Day in 2035 with Dual-Bore Tunnel
Alternative

The EIR does not identify these streets or the related intersections as particularly congested in
2035. However, as discussed above, the underlying transportation model is incapable of assigning
traffic volumes accurately because it cannot account for the effects of bottlenecks. Therefore, the
highly detailed intersection level-of-service analyses in the EIR that purport to estimate
intersection delay in 2035 to a tenth of a second are not credible. All that can be hoped from the
model is a general indication of areas where traffic volumes are likely to increase or decrease.
More accuracy than that would require a very different type of model. The increased traffic shown
for local streets in Pasadena are likely impacts of the proposed project. The severity of these
impacts are unknown.

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Arterial traffic congestion gets worse at considerable distance

from proposed tunnel
The traffic impacts of the proposed project extend well beyond its immediate vicinity. Figure 13
illustrates two of these locations.
)Figure 13

2025 Change in PM Peak Period Level of Service (Build vs. No Build Alternatives

Oak Grove
Drive +
12,428
vehicles/day

I210

SR
710
I-10

Mednick
Ave. + 5,651
vehicles/day
North of the proposed project, increased traffic volume and congestion on I-710 would shift traffic
to parallel arterials. As shown in Figure 13, the EIR modeling shows 12,428 more vehicles per day
on Oak Grove Drive in the Dual-Bore alternative than in the No Build alternative. To the south of
the proposed tunnel, the EIR modeling shows an increase of 5,651 vehicles per day on Mednick
Avenue in the Dual-Bore alternative as compared to the No Build alternative. These sorts of shifts
of traffic to arterials could create a need for arterial capacity enhancements extending the
whack-a-mole problem discussed above beyond the freeways to the entire regional roadway
system.

Traffic gets a lot worse on the 210, 710, and the 5

The tunnel projects makes congestion significantly worse on the 210 from 710 to I-5, and worse
on the 710 south of the 10. There are minor improvements on the north end of the 605 and on 210
east of 710. What happens to the 5 when all this new 210 traffic is dumped on it where the 5 and
210 merge? Or on the congested portions of the 710 south of SR 60? These impacts are not
analyzed.

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The EIR doesnt allow real solutions to the SGVs transportation

needs
On page 1-53, the Independent Utility and Logical Termini section describes why, given the
highway-focused study area boundaries, it is not allowable to develop a systematic solution to the
San Gabriel Valleys transportation needs. Because the projects purpose and need statement
focuses only on north-south travel, and because the corridor of focus stretches from the 10/710 to
the 210/134 interchanges, it is not possible to examine comprehensive approaches, particularly
for transit. While downtown Pasadena may be a logical transit destination, there are key transit
destinations south of the 1o that cannot be considered under this constrained purpose and need.
Moreover, east-west options are ignored, even if they would create significant benefit for the
congested arterials intersections of concern.
Even if only a north-south transit option were considered, the logical option would be to build
upon Metros existing plans for BRT on Atlantic, and existing plans to upgrade the 762. This
improved service should connect to Cal State LA and East LA College. It should also be extended
to the Long Beach Blvd Green Line station, with stops in central Lynwood, creating a real transit
network for the underserved 710 corridor. See more detail in our draft Mobility Plan.

Most traffic isnt long distance

According to Table 5-2 of the Transportation Technical Appendices, about 40% of study area
residents work in the study area, and over 90% work in LA County. Similarly, 90% of Study Area
employees live in LA County. About 60% of non-work trips in the Study Area start and end there.
However, construction of the proposed project would funnel long-distance regional traffic
through the study area as illustrated in Figure 14. Higher regional VMT results from a
combination of traveler choosing more distant destinations with the project, and less direct
routing with the project.

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Figure 14

2035 Mid-Day (9 AM 3 PM) Traffic Using the Proposed Project (Dual-Bore Alternative) 13

Figure 14 any link colored red has modeled traffic using the tunnel. As shown, this includes trips
to and from areas well to the northwest where there are more direct routes. The width of the lines
is proportional to the volume of traffic. South of the tunnel, tunnel traffic is dispersed widely. To
the north there is somewhat more concentration. About 20 percent of the traffic is to and from
areas to the north of the I-5/I-210 merge.

13

EIR TransCAD trip table assigned to EIR TransCAD network using TransCAD

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QUESTIONS FOR EIR TEAM

Given our analysis of the project EIR and supporting documents, we have the following questions
to submit to Caltrans and its EIR team:
1.

How do the analyses of the No-Build and Build alternatives incorporate total and per
capita VMT targets in the Southern California Association of Governments 2012-2035
Regional Transportation Plan/Sustainable Communities Strategy? The EIR does not
appear to analyze the Projects consistency with the RTP/SCS, beyond its mere inclusion
in the RTP as a future project. Based on our review, the Project would be inconsistent
with the RTP/SCS because it increases VMT and therefore GHG emissions.

2. The EIRs tunnel build options do not appear to be consistent with the Caltrans Strategic
Management Plan 2015-2020, and particularly the agencys stated goals and performance
metrics. How does the project achieve Caltrans goals and objectives for the state
transportation system, particularly the following:
Strategic Objectives

Performance Measures

Targets

PEOPLE: Improve the quality of

life for all Californians by providing
mobility choice, increasing
accessibility to all modes of
transportation and creating
transportation corridors not only
for conveyance of people, goods,
and services, but also as livable
public spaces.

Percentage increase of non-auto

modes for:
Bicycle
Pedestrian
Transit

PLANET: Reduce environmental

impacts from the transportation
system with emphasis on
supporting a statewide reduction
of greenhouse gas emissions to
achieve 80% below 1990 levels by
2050.

Per capita vehicle miles traveled.

By 2020, achieve 15% reduction

(3% per year) of statewide per
capita VMT relative to 2010 levels
reported by District.

Percent reduction of
transportation system-related air
pollution for:
Greenhouse gas (GHG)
emissions
Criteria pollutant emissions

15% reduction (from 2010

levels) of GHG to achieve
1990 levels by 2020.
85% reduction (from 2000
levels) in diesel particulate
matter emissions statewide by
2020.
80% reduction (from 2010
levels) in NOx emissions in
South Coast Air Basin by
2023.

By 2020, increase non-auto

modes:
Triple bicycle;
Double pedestrian; and
Double transit.
(2010-12 California Household
Travel survey is baseline.)

3. Given our analysis, the tunnel build options seem inconsistent with efforts to implement
AB 32. How does the project help meet the California Air Resources Board 3-8% VMT
reduction goals necessary to implement AB 32?

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4. How is induced demand calculated for the tunnel options? What assumptions were used
in estimating induced demand? It is not possible to verify the accuracy of the EIRs
transportation analysis because the EIR does not include any background assumptions
about induced demand. What little information is provided would indicate that the EIR
has substantially underestimated the Projects transportation impacts because it does not
appear to take into account all of the induced travel that would result from the Projects
increase in capacity. Numerous studies exist showing that adding highway capacity leads
to additional vehicle travel, including a report by the California Air Resources Board. 14
Generally, it has been shown that a one-to-one relationship exists between road capacity
and vehicle travel. In other words, if capacity is increased by 10%, the amount of driving
also increases by 10%.
5.

The tunnel projects increase traffic volumes on both the 5 and 210 freeways. It appears
that these added traffic volumes join where the 5 and 210 freeways merge. Yet, the EIR
does not analyze the congestion impacts of adding significant peak traffic to this key
bottleneck. The EIR must disclose how much congestion and delay is created north of the
5/210 merge, and on the 14 freeway.

6. Figure ES-2 shows the travel times to downtown Pasadena from locations within the
project study area, illustrating the lack of continuous north-south transportation
facilities. Figure ES-2 more readily identifies a lack of east-west transportation facilities,
not north-south. The EIR must explain how this figure supports the need for a northsouth project. Moreover, this figure does not appear to have any relationship to actual
travel time, but rather modeled travel time using a limited number of corridors. What
actual travel time empirically measured?
7.

14

Figure 1-5 purports to show the added travel distance necessary as a result of a missing
freeway segment. Why should we assume, however, that one should be expected to use a
regional freeway to travel between adjacent cities? Similarly, taking the 605 to the 210 to
get from El Monte to Pasadena is only slightly more out of direction than taking the 10 to
an extended 710. Measuring in Google, it is 17 miles by way of the 605 and 210, and 17
miles by way of the 10 and 710. Please explain the policy basis for accommodating travel
between adjacent cities on a regional freeway.

http://www.arb.ca.gov/cc/sb375/policies/hwycapacity/highway_capacity_brief-4-21-14.pdf

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8. Table 1-9 provides an LOS analysis comparing existing to future year no-build scenarios.
The charts assume an ever-increasing amount of auto traffic on streets throughout the
study area. Our records, however, show that traffic levels on area streets have remained
fairly steady over the last 30 years, despite significant ongoing growth and development
in the area. In many cases, traffic counts are lower today than in 1999. Please provide an
explanation of why future trends are expected to differ substantially from past trends.
Why should we expect traffic to grow with population and jobs, when they have not
historically? What is the empirical basis for your traffic projections?
Figure 15

Historic Traffic Counts at Key Area Streets

SR 710 at Del Mar

2012 Traffic Count:

37,398 (Current Year Estimate)

2010 Traffic Count:

44,500 (Average Annual Daily Traffic)

2009 Traffic Count:

39,500 (Average Annual Daily Traffic)

2005 Traffic Count:

48,500 (Average Annual Daily Traffic)

2004 Traffic Count:

48,000 (Average Annual Daily Traffic)

2003 Traffic Count:

51,000 (Average Annual Daily Traffic)

South Fair Oaks Ave at Glenarm

2012 Traffic Count:

30,108 (Current Year Estimate)

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2003 Traffic Count:

27,860 (Average Daily Traffic)

1996 Traffic Count:

34,121 (Average Daily Traffic)

California Blvd at Magnolia

2012 Traffic Count:

21,869 (Current Year Estimate)

2004 Traffic Count:

23,414 (Average Daily Traffic)

2002 Traffic Count:

24,349 (Average Daily Traffic)

2001 Traffic Count:

25,892 (Average Daily Traffic)

1996 Traffic Count:

26,000 (MPSI Estimate

9. Table 1.10 shows a steady increase in regional VMT. Is this increase in VMT consistent
with the SCS? If not, why not?
10. Table 1.11 confirms that, on study area arterials, there is more congestion in the northsouth direction than in the east-west. It also confirms:
-

Both the north-south and east-west arterials are substantially less congested than
parallel freeways. Even at peak, the analysis says that the arterials on average have
twice as much capacity as needed (V/C < 0.5). This means that arterial congestion is
largely a result of bottleneck conditions at specific intersections, not a shortage of
corridors.

East-west V/C is about 10 percentage points less than north-south corridors.

More importantly, the analysis for All Roadways concludes that overall, traffic is
substantially worse in the east-west direction, rather than north-south.

Table 1.11 suggests that the projects Purpose and Need is flawed: the study area faces an
east-west transportation problem, not a north -south one. An east-west transportation
project would likely have a greater congestion relief benefit for the project area cities than
a north-south one. Please explain why the east-west transportation needs of the study
area have been ignored.

11. Table 3-2 of the Transportation Technical Report identifies the differences between
predictions in the study are travel demand model and actual traffic counts. For arterials
in the area, the difference between reality and the model ranges from 9%-26%, with the
model predicting 14%-26% less traffic on arterials in the PM peak than actual
measurements. The percentage difference between reality and model results appears to
significantly exceed any of the potential benefits of the tunnel projects claimed by the

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EIR.

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Technical Appendix 2
(Noise and Vibration)

to
Attachment A
5-Cities Alliance
Comment Letter

Technical Review of Noise and Vibration Impact Analysis For:

STATE ROUTE 710 NORTH

STUDY DEIR/EIS
Prepared For:

THE FIVE CITIES ALLIANCE

GLENDALE, LA CANADA FLINTRIDGE,

PASADENA, SIERRA MADRE AND SOUTH PASADENA
SHUTE, MIHALY & WEINBERGER LLP
396 Hayes Street
San Francisco, CA 94102-4421

Prepared By:

LANDRUM & BROWN

Matthew B. Jones P.E.
19700 Fairchild, Suite 230
Irvine, CA 92612
9493490671

June 30, 2015

Report #554301NV04F

This Page is Blank

SR-710 North Study DEIR/EIS

Noise & Vibration Review and Comment

Landrum & Brown

Page i

TABLE OF CONTENTS
TABLE OF CONTENTS....................................................................... i

LIST OF TABLES ............................................................................. i

ACRONYMS .................................................................................. ii

1.0
Introduction ....................................................................... 1

1.1
Primary Shortcomings of the Noise and Vibration Impact Analysis ............ 2

1.1.1

1.1.2

1.1.3

1.1.4

Construction Noise & Vibration .............................................................. 2

Long-Term Operational Impacts CEQA Significance Determination ............. 5

Obfuscation of Noise Impacts ............................................................... 7

Traffic Modeling Deficiencies ................................................................. 8

2.0
Comments ........................................................................ 11

2.1
Main DEIR/EIS Document ................................................................. 11

2.1.1

2.1.2

2.1.3

2.1.4

2.1.5

Construction Noise ............................................................................ 11

Construction Vibration and Groundborne Noise...................................... 15

Operational Noise ............................................................................. 17

Cumulative Impacts .......................................................................... 24

Noise Study Report ........................................................................... 25

LIST OF TABLES
Table 1
Noise Analysis Receptors1....................................................... 22

SR-710 North Study DEIR/EIS

Noise & Vibration Review and Comment

ACRONYMS
CEQA

California Environmental Quality Act

CNEL

Community Equivalent Noise Level

dB

Decibel

dBA

A-Weighted Decibel

DEIR

Draft Environmental Impact Report

EIS

Environmental Impact Statement

FHWA

Federal Highway Administration

FTA

Federal Transit Administration

LDN

Day-Night Noise Level

Leq(H)

One Hour Equivalent Noise Level

NAC

Noise Abatement Criteria

NADR

Noise Abatement Decision Report

NEPA

National Environmental Protection Act

NSR

Noise Study Report

ROW

Right of Way

TNAP

Traffic Noise Analysis Protocol

TNM

Traffic Noise Model

Landrum & Brown

Page ii

SR-710 North Study DEIR/EIS

Noise & Vibration Review and Comment

Landrum & Brown

Page 1

1.0 Introduction
On behalf of the 5-Cities alliance, we have completed our review of the noise and
vibration impact analysis presented in the SR-710 North Study DEIR/EIS and
related technical documents including the Noise Study Report and the Groundborne
Noise and Vibration Impact Report.
This review was conducted primarily by
Matthew B. Jones P.E. (CV attached).
This report presents our specific comments and identifies shortcomings in the noise
and vibration analysis, including the following key issues and findings.
The DEIR/EIS does not identify significance thresholds for construction or
operation impacts. Had the document adopted typical agency thresholds for
these impacts, it would have concluded that both types of impacts are
significant.
Instead, the DEIR/EIS concludes that all construction and operation noise
and vibration impacts are less than significant, albeit without any threshold
for comparison. We disagree with this conclusion for the reasons detailed
below.
The DEIR/EIS fails to analyze the feasibility of proposed mitigation
measures, such as measures requiring compliance with local noise
ordinances and local prohibitions on nighttime construction noise.
The DEIR/EIS does not clearly identify sensitive receptors (i.e., homes) that
would experience significant operational noise impacts but for which noise
barrier mitigation is not reasonable or feasible. This approach is improper.
Such unmitigated impacts must be disclosed as significant and unavoidable.
The DEIR/EIS fails to analyze interior noise impacts.
Section 1.1 presents detailed discussions of the primary deficiencies with the noise
and vibration impact analysis performed for the DEIS/EIR. The first issue is
analysis of construction related noise and vibration impacts.
Section 1.1.1
discusses issues with the assessment and mitigation of construction noise and
vibration impacts. Section 1.1.2 shows that while the analysis concludes that the
project will not result in any significant long-term transportation noise impacts, the
analysis is incomplete and the conclusion of no significant impact is contradicted by
data presented in the DEIR/EIS.
Section 1.1.3 discusses how the analysis
obfuscates operational noise impacts by not clearly identifying impacted receptors
that do not have feasible and reasonable noise abatement and how it minimizes
impacts by only presenting them in terms of the number of impacted receptors
when a single receptor can represent a number of uses, up to 26 residences in this
case (Receptor BR-344).
Section 1.1.4 discusses how deficiencies in trafficmodeling assumptions affect the noise impact analysis. Section 2.0 presents our
specific comments and provides detailed identification of the flaws in the noise and
vibration impact analysis.

SR-710 North Study DEIR/EIS

Noise & Vibration Review and Comment

Landrum & Brown

Page 2

1.1 Primary Shortcomings of the Noise and Vibration Impact

Analysis
The following subsections discuss the primary shortcomings of the DEIR/EIS.
Specifically, those issues that result in understatement of the potential noise and
vibration impacts, adequacy of mitigation, or non-identification of significant
unavoidable impacts as required by CEQA.
1.1.1 Construction Noise & Vibration
All of the Alternatives will require considerable construction and in some cases this
construction will occur nights and weekends.
Tunnel construction for the Single
Bore Freeway Tunnel Alternative is anticipated to take four to five years to
complete, while the Dual Bore Tunnel is anticipated to take five years to complete.
Construction of the LRT Alternative is anticipated to take six years to complete.
Comment 1) presented in Section 2.1.1 provides an overview of the construction
activities that will be required to implement each Alternative summarized from
Section 2 of the DEIR EIS.
Despite the extensive construction required the Build Alternatives, the construction
noise section of the Noise Study Report consists of two and a half pages of text that
describes potential noise impacts from construction of the project in only general
terms. The construction section of the DEIR/DEIS document distills this down to
just over a page (Page 3.24-11). Much of this general information is repeated in
the one and a half page Construction Noise portion of Section 3.14.3.1 starting on
Page 3.14-7. The majority of this section addresses vibration and groundbourne
noise. Groundbourne noise is noise that is generated inside buildings due to
vibrations transmitted through the ground.
The assessment of airborne
construction noise impacts is non-specific and inadequate.
The CEQA analysis (DEIR/EIS Section 4.2.12 starting on Page 4-69) states,
Measures N-1 and N-2, described in detail in Section 3.14.4, require compliance
with the Caltrans Standard Specifications, the County Code, and the city Municipal
Codes as applicable. Implementation of Measures N-1 and N-2 would reduce
construction noise impacts under the Build Alternatives to a less than significant
level. However, while measure N-2 requires compliance with local Municipal Codes
for the TSM/TDM, LRT, and BRT alternatives, measure N-1, which is applicable to
the Freeway Tunnel Alternatives, only requires compliance with Caltrans Standard
Specification Section 14-8.02 and to equip all internal combustion engines with
mufflers. The specification only requires that equipment used between the hours of
9 pm and 6 am not exceed 86 dBA at a distance at 50 feet it does not require
compliance with local municipal noise ordinances. Note that these are the only two
measures that address airborne construction noise impacts. Measures N-3 through
N-6 address potential vibration and groundbourne noise impacts.
In order to provide decision makers with complete information on the potential
impacts of their decision, the DEIR/EIS must provide a more complete description
of the potential noise impacts arising from construction. The analysis should
provide specific noise level estimates for all noise sensitive receptors in the
immediate vicinity of all construction activities for the build alternatives.

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The CEQA analysis concludes that compliance with local Municipal Code construction
noise requirements would result in construction noise having a less than significant
impact. Local noise ordinances define each communitys threshold for allowable
construction noise.
Therefore, noise exposures greater than the local noise
ordinance limits represent a significant noise impact. We assume that measure N-1
did not include the Municipal Code compliance requirement because Caltrans
construction activities within State ROW are legally exempted from control by local
noise ordinances by state law.
However, this exemption does not apply to
compliance with CEQA and its requirements to fully disclose impacts and mitigate
them to the fullest extent possible.
A simple requirement that construction comply with local Municipal Ordinances is
not sufficient to demonstrate that the project will not result in a significant impact
under CEQA. The analysis must demonstrate that compliance is feasible. For
example, the Pasadena Noise Ordinance prohibits the use of certain pieces of
equipment within 500 feet of residential uses during the nighttime hours. The
analysis must demonstrate that it is feasible to construct the project, the Freeway
Tunnel Alternative in this case, while complying with these restrictions. Similar
demonstrations are needed for all construction activities.
As discussed above, the majority of the avoidance, minimization, and/or abatement
measures presented in Section 3.14.4.1 (Page 3.14-16) of the DEIR/EIS address
vibration and groundbourne noise issues. These impacts are summarized under the
Construction Ground-Borne Noise and Vibration heading of Section 3.14.3.1 starting
on Page 3.14-8 of the DEIR/EIS. This source material from this summary comes
from Section 6 of the Groundborne Noise and Vibration Technical Report.
The analysis concludes that if supply/muck trains are used during the construction
of the tunnels under either the LRT or Freeway Tunnel Alternatives, objectionable
vibration levels could be experienced at sensitive receptors. However, the analysis
shows that the use of a resilient mat system to fasten the tracks will reduce these
vibration levels to less than the FTA impact threshold.
The more disconcerting conclusion of the analysis is that Tunnel Boring Machine
operation may generate vibration levels of up to 77 VdB at residences directly
above the tunnel. The FTA vibration impact threshold for residences and buildings
where people sleep is 72 VdB for frequent events (more than 70 events per day),
75 VdB for occasional events (30-70 events per day), and 80 VdB for infrequent
events (less than 30 events per day). The document states that the machines will
advance 22 feet per day and the 77 VdB vibration levels would probably last no
more than two or three days. Because the boring machine operates at a constant
rate, it will generate a relatively constant vibration level.
This means that
objectionable vibration levels could be experienced continuously, 24-hours per day,
for two or three days at affected homes. This impact is not even addressed in the
CEQA noise section (Section 4.2.12). The section reports that there would not be a
significant impact due to the exposure of persons to or generation of excessive
ground-borne noise levels despite acknowledgement of this impact. The report
tries to minimize the impact because it would last two or three days. However, it
fails to mention that the vibration levels would be nearly continuous for this two to
three day period.

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Avoidance, Minimization, and/or Abatement Measure N-5 (DEIR/EIS Section

3.14.4.1, Page 3.14-17) presents a suite of measures to minimize groundborne
noise and vibration. The measure prohibits the use of pile drivers or other high
vibration equipment during construction of TSM/TDM and BRT alternatives. LRT
construction activities will be required to comply with applicable FTA criteria and
guidelines as well as any applicable local regulations related to groundborne noise
and vibration. The Freeway Tunnel construction activities will be required to
comply with applicable FHWA and Caltrans criteria and guidelines as well as any
applicable local regulations related to groundborne noise and vibration. We are not
aware of any applicable specific local groundbourne noise and vibration regulations
and the requirement to comply with non-existent regulations has no value.
The measure also calls for the Project Engineer to develop specific property line
vibration limits during final design for inclusion in the construction vibration
specifications. Further, regular monitoring will be required to verify compliance
with those limits. As discussed in comment 8) in Section 2.0, these provisions lack
performance standards and sufficient specificity to be a valid mitigation measure
under CEQA.
The final issue with the construction noise and vibration impact assessment in the
DEIR/EIS is that it does not adequately address potential impacts from pile driving.
The DEIR/EIS acknowledges that for the LRT and Freeway Tunnel Alternatives,
excavation and construction of the tunnel portals and underground stations,
including pile driving, where residents are located nearby could result in shortterm ground-borne noise and vibration (Page 3.14-9). The Groundborne Noise
and Vibration Impacts technical report concludes that, Pile driving and other
vibration producing activity at station sites may impact residential receptors within
200 feet of the construction activity (Page 6-2). However, this is all the document
has to say about the issue and it is not discussed in the CEQA analysis. As
discussed above, the CEQA analysis concludes that there would be no significant
groundborne noise and vibration impacts. The document requires a much more
extensive discussion of the potential impacts from pile driving and similar highvibration construction activities including a description of where and when these
activities are expected to occur and what sensitive receptors are potentially
impacted. Moreover, the DEIR/EIS fails to propose mitigation for pile driving
associated with the LRT and Freeway Tunnel alternatives, in contrast to proposed
mitigation prohibiting pile driving under the TSM/TDM and BRT alternatives. As a
result, groundborne noise and vibration impacts remain significant for the LRT and
Freeway Tunnel alternatives.

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1.1.2 Long-Term Operational Impacts CEQA Significance Determination

The CEQA Long-Term Transportation Noise Impacts discussion is presented on the
top half of Page 4-75 of the DEIR/EIS. This analysis of the operational noise
impacts under CEQA is minimal and incorrectly concludes that the project will have
a less than significant long-term noise impact. This conclusion is based on the
assertion that the Build Alternatives would not result in any substantial
(perceptible) increases. The text refers to Tables 4.3 through 4.7 as demonstrating
this.
The first issue with the less than significant long-term noise impact conclusion is
that the document does not define the substantial (perceptible) increase threshold.
The second issue is that Tables 4.3 through 4.7 only examine traffic noise level
changes along numbered highways and ignores arterial roadways. Traffic volumes
and noise levels along arterial roadways will be affected by the project and
significant impacts could occur along these roadways. The analysis presented in
these tables must be extended to assess potential impacts along arterial roadways.
One of the most critical deficiencies of the DEIR/S is that traffic noise level changes
presented in Tables 4.3 through 4.7 are not valid for receptors located along
highway segments that will be modified under the build alternative. The analysis of
impacts under the FHWA/Caltrans criteria shows that sensitive receptors in the
vicinity of the build limits of the Freeway Tunnel Alternatives will be subjected to
substantial noise increases. The document concludes that the sound abatement
constructed to address the FHWA/Caltrans standards will reduce these impacts to
less than significant. However, this ignores those receptors for which sound
abatement was found to not be reasonable or feasible and would not be
implemented. The analysis concludes that there will be no impacts for receptors
outside the Build Alternative limits based on the data shown in Tables 4.3 through
4.7 of the DEIR/EIS (pages 4-76 through 4-82). These tables present the projected
change in CNEL noise level with the Project Alternatives. However, these tables
only include numbered highways (State Routes and Interstates). The project will
also affect traffic volumes along arterial roadways in the project area. Because the
analysis does not include arterial roadways, it is incomplete and the conclusion of
no significant impact is not supported. Traffic noise level changes along arterials
for which the traffic analysis projected traffic volumes must be evaluated to assess
potential substantial increases along arterial roadways for all alternatives.
The analysis cites these same tables to conclude that there will be no substantial
increases, and therefore no significant impacts, located along the Build Alternatives
(i.e., along road segments that will be modified by the project). However, this
ignores the limitations of the data shown in Tables 4.3 through 4.7. The noise level
changes shown in the tables are solely due to anticipated changes in traffic
volumes. The noise level changes presented in the table assume that speeds,
traffic mix, and roadway geometry do not change. At a minimum, roadway
geometry will change within the limits of the Build Alternative improvements and
these tables are not applicable in these areas.
Humans are not able to detect changes of less than 1 dB in a laboratory situation
with direct comparison. When comparing fluctuating noise levels without a direct
comparison, as in a community noise situation, the generally accepted change in

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noise levels that is just noticeable is 3 dB. Three dB is the most typical threshold
for a perceptible increase in a community noise setting. The threshold for a
significant impact is that the project causes a perceptible increase and the resulting
noise level exceeds acceptable levels. The local municipalities have typically defined
65 CNEL as the maximum clearly acceptable noise exposure for residential uses.
Tables 3.14.16 and 3.14.18 show the projected increase in Leq(h) noise levels for
the analysis receptors located within the limits of the Build Alternative
improvements for the Single Bore and Dual Bore Freeway Tunnel Alternatives.
These tables show that many receptors will experience noise level changes greater
than 3 dBA. While the table presents changes in peak hour Leq(H) noise levels,
changes CNEL levels would be similar.
Based on the long-term noise measurements at sites FML-1 through FML-4, CNEL
levels along the freeways are approximately 1 to 3 dB greater than the peak noise
hour noise levels. Therefore, receptors with a Leq(q) of 65 dB or greater would be
exposed to a CNEL noise level greater than 65 dBthe typical outdoor residential
noise level deemed acceptable by the local municipalities. Receptors with a Leq(h)
of 62 dB or greater may be exposed to a CNEL noise level greater than 65 CNEL.
Tables 3.14.33 and 3.14.34 shows that under the Single Bore Freeway Tunnel
Alternative only two noise barriers, FTNB No. 5 and FTNB No. 10, will be reasonable
and feasible assuming no donation of right-of way. Therefore, these are the only
two noise barriers that would be implemented with the project. Table 3.14.16
shows that residential receptors FR-7 through FR-15, FR-17 through FR-22, FR-47
through FR-51, FR-68, FR-69, FR-103, FR-106, FR-108, FR-110, and FR-120 will be
subjected to noise level increases of 3 dB or greater and an Leq(h) noise level
greater than 65 dB even considering the proposed reasonable noise barriers. These
27 receptors represent 310 dwelling units. These dwelling units would be subject
to a perceptible noise increase of 3 dB or greater over existing conditions and an
exterior noise level of 65 CNEL or greater, a typical CEQA significance threshold for
highway noise impacts.
Tables 3.14.32 and 3.14.34 show that under the Dual Bore Freeway Tunnel
Alternative only four noise barriers, FTNB No. 5, FTNB No. 6, FNTB. No 9 and FTNB
No. 10, will be reasonable assuming no donation of right-of way. Table 3.14.18
shows that residential receptors FR-7 through FR-22, FR-24, FR-25, FR-26, FR-28
through FR-36, FR-41, FR-46 through FR-51, FR-53, FR-68, FR-69, FR-75, FR-80,
FR-81, FR-83, FR-88 through FR-100, FR-103 through FR-110, FR-113, and FR-120
will be subjected to noise level increases of 3 dB or greater and an Leq(h) noise
level greater than 65 dBA. These 65 receptors represent 348 dwelling units. These
dwelling units would be subject to a perceptible noise increase of 3 dB or greater
over existing conditions and an exterior noise level of 65 CNEL or greater, a typical
CEQA significance threshold for highway noise impacts.
As discussed above, the document does not clearly state the thresholds used to
determine the significance of traffic noise impacts from the project. However, the
analysis presented above shows that this conclusion is incorrect based on a typical
significance threshold. The report cannot rely on the information shown in Table
4.6 and 4.7 to conclude that significant unavoidable traffic noise impacts would not
occur with the Freeway Tunnel Alternatives.

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A cursory review of Tables 3.14.8 and 3.14.10 did not discover any receptors that
may be subject to noise level increases of 3 dB or greater and future with-project
noise levels greater than 65 CNEL for the TSM/TDM and BRT alternatives. Caltrans
should provide a full analysis to demonstrate this though. Table 3.14.14 shows
that, for the LRT Alternative, all receptors with Ldn noise level increases greater
than 3 dB without mitigation, mitigation that would reduce these increases less
than 3 dB.
1.1.3 Obfuscation of Noise Impacts
The Noise Impact Analysis obfuscates the noise impacts from the project in two
ways. First, it presents impacts in terms of the number of analysis receptors, which
minimizes the impacts because one receptor can represent multiple uses. The
second obfuscation is that the analysis barely mentions receptors where noise
impacts are identified but where noise abatement is infeasible. Tables that purport
to identify all impacted receptors, only identify those receptors that are impacted
and have feasible noise abatement.
The analysis of operational (permanent) impacts in Section 3.14.3.2 on Pages 3.1411 through 3.14-15 discuss traffic noise impacts in terms of the number of
receptors that have been identified as impacted under the FHWA Noise Abatement
Criteria. However, what is not clear is that one receptor can represent more than
one household or other use, up to 26 residences in this case. Therefore, the
number of receptors is not an appropriate measure to characterize the scope of the
potential noise impacts. The document should also show the number of residences
and other uses represented by the impacted receptors.
Tables 3.14-21, 3.14-23, 3.14-26, purport to show Receptor Locations Where the
Applicable Noise Abatement Criteria Would be Approached or Exceeded under the
TSM/TDM, BRT, and Freeway Tunnel alternatives. However, these tables only list
those receptors that were identified as impacted AND for which implementation of a
noise barrier is feasible. Under the TSM/TDM alternative a total of 70 receptors are
identified as impacted (i.e., would approach or exceed the NAC) (DEIR/EIS p. 3.1412). However, the DEIR/EIS proposes noise barriers at only 27 locations. (DEIR/EIS
Table 3.14-21). Nine of the receptors listed in the table are not even impacted
(i.e., Receptors T1/TR-6, T1/TR-10, T1/TR-30, T1/TR-31, T1/TR-32, T1/TR-35,
T2/TR-1, T2/TR-12, and T2/TR-13 are proposed for noise barrier mitigation but is
not listed in Table 3.14-8 as being impacted); thus, only 18 of the 70 impacted
locations would receive noise barrier mitigation. The receptor locations for which
abatement is not feasible are dismissed in a single line in the text, Of the 70
locations, 431 were not considered for abatement . . . (DEIR/EIS Page 3.14-12).
Furthermore, as discussed above, this does not represent the total number of
residences and other sensitive uses impacted, just the number of representative
receptors.
Under the BRT alternative, 129 receptors were identified as impacted, while only 9
are listed in Table 3.14-23. There are 120 receptors, and even more residences,
that are projected to experience traffic noise levels approaching or exceeding the
FHWAs Noise Abatement Criteria for which abatement is not feasible. Again, these
1

This number should be 52.

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receptors are dismissed in a single line of text (last sentence of second paragraph
under BRT Alternative heading on page 3.14-13 of the DEIR/EIS)
The Freeway Tunnel Alternative is confusing due to Table 3.14.26 addressing both
Single Bore and Dual Bore Alternatives. Under the Freeway Tunnel Alternatives, 66
receptors reported as impacted under the Single Bore Alternative and 75 under the
Dual Bore Alternative. Table 3.14.26 lists 68 receptors that would receive noise
barrier mitigation. When errors on Tables 3.14.16 and 3.14.18 are corrected (See
Comment 30) in Section 2.1.5 below), there were actually 70 receptors impacted
under the Single Bore Alternative and 84 receptors under the Dual Bore Alternative.
Barriers were thus not considered for 11 receptors under the Single Bore
Alternative and 15 receptors under the Dual Bore Alternative.
Further, several barriers that were considered for the Freeway Tunnel Alternatives
are not considered reasonable and would not be implemented. Under the Single
Bore Alternative 12 receptors representing 28 residences were identified as
impacted but would not receive noise abatement because it was determined to be
not reasonable or not feasible. For the Dual Bore Alternative this increases to 29
receptors representing 68 residences. These receptors are projected be exposed to
noise levels approaching or exceeding the FHWA Noise Abatement Criteria with the
Freeway Tunnel alternatives.
1.1.4 Traffic Modeling Deficiencies
Traffic noise level predictions are based on traffic volumes estimated by the traffic
engineer for the Project. The review of the traffic study prepared for 5-Cities
Alliance performed by Nelson\Nygaard Consulting Associates Inc. identified two
issues that affect modeled traffic volumes that would also affect traffic noise
impacts due to the project, spillback and induced traffic.
The Nelson/Nygaard traffic study review notes that the traffic modeling did not
adequately account for spillback that would occur when projected traffic volume on
a road segment exceeded its capacity. That is, vehicles are assumed to queue and
wait their turn to pass through such bottlenecks. In reality, this large queue would
not occur and travelers would adjust their behavior to avoid such bottlenecks with
many finding alternative routes on arterial roadways in the project study area. This
results in an under prediction of arterial road traffic volumes. As discussed above,
the noise analysis is deficient for not examining traffic noise level increases on
arterial roadways within the project study area. However, even if this analysis were
performed, the noise level increases would be underestimated due to spillback.
As more freeway lane miles and alternative routes are introduced, driving becomes
a more convenient option. This serves to induce more vehicle trips from people
who otherwise would not have traveled via car or made that trip altogether. That
is, as congestion is decreased, people will decide to make trips that they would not
have previously made because of congestion. The traffic study review notes that
the travel demand model cannot be trusted to accurately estimate this induced
travel. Further, the Nelson/Nygaard review notes, that even if the model accurately
reflected induced travel, the time period analyzed in the EIR is too short. Research
shows roadway projects can result in short-term reductions in congestion due to
the increased capacity. However, over time, the reduced congestion induces more

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trips to the point where the same level of congestion as without the project is
reachedbut with a larger number of vehicles.
The incorrect and incomplete
accounting for induced traffic results in lower traffic volume projections than if the
traffic inducing effects were included in the estimates.
The under prediction of with-project traffic volumes used for the noise analysis
would result in an under prediction of with-project traffic noise levels. Small
differences of noise exposures near significance thresholds can change the
determination of significance and mitigation requirements.

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2.0 Comments
The following present our specific comments on the DEIR/EIS document.

2.1 Main DEIR/EIS Document2

2.1.1 Construction Noise
1)

The Construction Noise Analysis is Incomplete. All of the Project

Alternatives would require considerable construction to implement. Further,
the tunneling for the LRT and Freeway Tunnel Alternatives would proceed 24
hours per day for four to five years. While Tunnel Boring Machine would
operate underground, there would be considerable nighttime activities in the
portal areas to remove excavated materials and process muck. The CEQA
Noise Section (DEIR/EIS Page 4-70) estimates that 360,000 truck trips will be
required to haul excavated materials for the Dual Bore Alternative with 360
daily truck trips on a peak day. This equates to 720 truck passes per day, 30
per hour, or one every two minutes on average for an equivalent of 1,000
days.
Construction of the Freeway Tunnel Alternatives involves the extension of St.
John Avenue and widening Pasadena Avenue, demolition of three
overcrossings, replacing two with new overcrossings and one with an at-grade
roadway, as well as the construction of a new bridge over the Laguna
Regulating Basin and a new overpass bridge. The Dual Bore Alternative would
require the widening of Ramona Boulevard undercrossing bridge and the SR
710/I-10 bridge. These alternatives would also construct two Operations and
Maintenance Buildings at the portals. At the south portal, a 50-foot tall tunnel
ventilation structure would be constructed. Ventilation structures would also
need to be constructed near the north portal.
Two options are being
considered, a 50-foot tall structure at the SR 710/SR 134 interchange or four
50-foot tall structures located at the SR 710/Colorado Boulevard interchange.
The LRT Alternative is proposed to be constructed with two boring machines
operating from the southern end of the tunnel.
The Freeway Tunnel
Alternative would utilize a two boring machines operating from the each end of
the tunnel. In addition, the LRT alternative includes the construction of seven
stations. Four of these stations will be underground and require considerable
excavation. Further, the LRT alternative includes the construction of
approximately three miles of aerial track including five bridges over freeways,
seven stations, and a maintenance yard. Overnight construction activities
would be required where the elevated track crosses SR 60, I-710 or other
roadways (DEIR/EIS Page 2-57). Excavation of the first 10 to 15 feet of
underground stations would be primarily conducted in the evening and on
weekends (DEIR/EIS Page 2-59).
Roadway deck installation above the
underground stations could require multiple consecutive weekend full roadway
closures (DEIR/EIS Page 2-59). One would assume that this would involve
noise generating construction activities along with the closures.

Note that these comments also apply to the technical reports where the information has
been reproduced from the technical report.

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The TSM/TDM alternative proposes improvements that will require construction

along eight local streets, 45 intersections, and three other roads, including the
widening of a bridge and construction of new bridge.
Many of these
improvements are included in the other build alternatives as well. The BRT
alternative includes the construction of seventeen BRT stations, widening of
Atlantic Boulevard, Huntington Drive, and Fair Oaks Avenue as well as ramp
modifications at the I-710/SR 60 interchange.
Despite the extensive construction required for the project alternatives the
primary technical document, the Noise Study Report, addresses construction
noise impacts in two and a half pages and the main DEIR/DEIS document
distills this discussion down to a little over one page. Noise impacts from
construction and vibration impacts from normal construction activities and pile
driving are only discussed generally. The only construction activity impact
analysis that specifically address the project are the analysis of vibration and
groundborne noise impacts from the Tunnel Boring Machine and the use of
supply/muck trains during tunnel construction.
The analysis must provide a more detailed discussion of the specific
construction activities and potential impacts for every component of each of
the Build Alternatives. This includes a clear discussion of the types of activities
that will be required and the noise and vibration levels that may be
experienced at nearby sensitive receptors. The identification of the nature and
location of nighttime construction activities is especially critical. As discussed
in Comment 4) below the analysis must also demonstrate that it is feasible for
the construction activities to comply with local noise ordinances.
2)

Construction Noise and Vibration CEQA Significance Thresholds are

Not Clearly Stated. The CEQA Impact Section 4.2.12 of the DEIR/EIS does
not clearly state the thresholds used to determine the significance of the noise
and vibration impacts. The document must clearly state the thresholds used
to determine the significance of impacts to determine if these thresholds are
adequately assessed and to support the finding of no significant impact.
The document recites the Appendix G threshold, which considers whether the
Project would expose persons to noise levels in excess of the local
municipalities noise ordinance. See DEIR/EIS, p. 4-69. However, it does not
appear to analyze compliance with that threshold.
The document is equally confusing regarding the threshold it is applying to
analyze ground-borne noise and vibration impacts from construction. Both
Caltrans and FTA provide guidance on acceptable levels of vibration that
should be used to establish vibration and groundborne noise significance
thresholds, yet the document makes no attempt to describe these acceptable
vibration levels.

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Analysis of CEQA Impacts from Haul Trucks is Incomplete. On Page 470, the analysis of potential haul truck noise impacts concludes that, it is
expected that the noise impacts associated with haul routes for excavation
activities for the LRT and Freeway Tunnel Alternatives would be less than
significant. However, the documents only support for this assertion is the
assertion that the maximum 360 daily truck trips anticipated during tunnel
excavation is a very small percentage of the existing daily volumes on haul
route roadways. Note that 360 trips result in twice the number of truck passes
as the truck departs and then returns from the disposal location.
At 35 mph, 720 daily heavy truck passes generate the same noise as a typical
arterial roadway with a daily traffic volume (ADT) of 36,000 vehicles. If the
projects heavy trucks were added to a roadway with this volume the CNEL
noise level along the road would increase by 3 dB (The noise level change due
to different traffic volumes is equal to 10 times the base ten logarithm of the
ratio of the traffic volumes. Ten times the base ten logarithm of 2 is equal to
3.) As discussed below, an increase of 3 dB is a typical CEQA threshold of
significance for traffic noise impacts, and is appropriate here given that
construction will span approximately five years. Road segments with lower
traffic volumes would experience even greater CNEL increases. At 45 miles
per hour, an ADT of 24,000 on an arterial generates the same noise as the
construction trucks; at 55 miles per hour, this number is reduced to an ADT of
17,500.
In other words, the document fails to support its less than significant
conclusion because it does not present the traffic volumes and speeds, on the
roadways that will be serving haul trucks, along with the traffic noise levels
with and without the trucks and the increase due to the haul trucks. Absolute
noise levels at sensitive receptors must be examined for any road segments if
perceptible increases, greater than between 1 and 3 dB to determine if there
will be any significant impacts.

4)

The CEQA Conclusion of No Significant Construction Noise Impacts is

Incorrect. The CEQA Noise Analysis Discussion states that because measures
N-1 and N-2 described in Section 3.14.4 require compliance with County and
Municipal Codes and construction noise impacts under the build alternative will
be less than significant. While Measure N-2 requires compliance with the local
jurisdictions Noise Ordinance it is only applied to the TSM/TDM, BRT and LRT
alternatives. Measure N-1, applicable to the Freeway Tunnel Alternatives,
contains no such provision. This measure requires compliance with Caltrans
noise limits for equipment used between 9 pm and 6 am and the use of
mufflers, but these measures in no way ensure that the local jurisdictions
noise ordinance is not violated during the construction. Caltrans work within
the right-of-way is legally exempted during construction
While not stated explicitly, the DEIR implies that it is using compliance with the
local municipalitys noise ordinance as the significance threshold for
construction noise impacts. At a minimum, the threshold should require
compliance with local noise ordinances as these local standards reflect each
communitys tolerance for construction noise. However, this is not explicitly

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required for the Freeway Tunnel Alternative and Caltrans is legally exempted
from compliance with local noise ordinance requirements.
Without a
requirement to comply or demonstration that Freeway Tunnel construction
activities would comply with local noise ordinances the document cannot
conclude that construction of the Freeway Tunnel Alternative will not result in
any significant noise impacts. Further, the requirement to comply by itself is
not sufficient to conclude there will be no significant impacts. The analysis
must demonstrate that compliance is feasible. This may not be possible where
nighttime construction is required near sensitive noise receptors.
5)

The CEQA Construction Noise Impact Analysis Fails to Analyze the

Feasibility of Proposed Mitigation Measures. As discussed above, the
simple requirement that construction activities for the TSM/TDM, LRT and BRT
alternatives comply with the local municipalitys noise ordinance is not
sufficient to guarantee that there will be no significant construction noise
impacts if it does not analyze the feasibility of compliance. If nighttime
construction occurs near residential areas, compliance may not be feasible.
For example, Pasadena Municipal Code 9.36.070 (A) reads No person shall
operate any pile driver, power shovel, pneumatic hammer, derrick power hoist,
forklift, cement mixer or any other similar construction equipment within a
residential district or within a radius of 500 feet therefrom at any time other
than as listed below:. Section 9.36.070 (B) reads No person shall perform
any construction or repair work on buildings, structures or projects within a
residential district or within a radius of 500 feet therefrom in such a manner
that a reasonable person of normal sensitiveness residing in the area is caused
discomfort or annoyance at any time other than as listed below:. The
allowable times are 7 am to 7 pm Monday through Friday and 8 am to 5 pm on
Saturday. The only way to comply with the first provision is to not have
nighttime construction with the equipment listed.
The DEIR/DEIS must demonstrate that the anticipated construction activities
can be completed without violation of the applicable noise ordinances in order
to conclude that the requirement to comply with the ordinance is feasible.
Otherwise the document cannot support its conclusion that construction noise
impacts are mitigated to a level of insignificance.

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2.1.2 Construction Vibration and Groundborne Noise

6)

The CEQA Analysis Does Not Identify Significant Construction Vibration

Impacts.
The construction vibration analysis concludes that the Tunnel
Boring Machines used for the LRT and Freeway Tunnel alternatives may
generate vibration levels as high as 77 VdB at homes directly above the tunnel
and these vibration levels could persist for two to three days (First paragraph
of Section 6.2 of the Groundborne Vibration Impacts Technical Report, page 613). The FTA vibration impact threshold for residences and buildings where
people sleep is 72 VdB for frequent events (more than 70 events per day).
While not stated in the Vibration Technical Report or the DEIR/EIS document,
because the Tunnel Boring Machines will operate in a constant manner for 24
hours a day except as they are stopped for maintenance. The vibration levels
generated by the machines will be relatively constant while they are in
operation. That the FTAs threshold for infrequent events (less than 30 events
per day) is 80 VdB shows that vibration tolerance is highly dependent on the
frequency of vibration events. Going from under 30 events to over 70 events
reduces tolerance by 8 dB. Going from 70 events to nearly continuous
vibration is a much greater jump in terms of annoyance.
Despite this obviously significant impact the CEQA analysis, Section 4.2.12 of
the DEIR/EIS, responds to the question of would the project result in
exposure of persons to or generation of excessive ground-borne noise levels,
question b, as Less than significant for the LRT alternative and Less than
significant impact for the Freeway Tunnel alternative while providing no
discussion of this impact below the checklist table.
The following two
comments address the inadequacy of vibration avoidance, minimization,
and/or abatement measure N-5 to mitigate these impacts.

7)

Measure N-5 Does Not Avoid, Minimize, nor Mitigate the Potential
Construction
Vibration
Impact.
Noise
and
vibration
avoidance,
minimization, and/or abatement measure N-5 requires all LRT construction
activities to comply with applicable FTA criteria and guidelines as well as any
applicable local regulations related to groundbourne noise and vibration and
the Freeway Tunnel Alternatives are to comply with FHWA and Caltrans
guidelines as well as any applicable local regulations related to groundbourne
noise and vibration (DEIR/EIS page 3.14-18 and 3.14-19). Without some
description the applicable guidelines and regulations, the actual impact of this
measure to reduce, minimize, and/or avoid impacts are unknown. The only
component of measure N-5 that actually goes towards reducing vibration
levels is the last one that addresses muck/supply trains.
The DEIR/DEIS should provide a description of the applicable FTA, FHWA,
Caltrans, and local jurisdiction regulations related to groundborne noise and
vibration and how these will effectively avoid, minimize or reduce impacts. We
are not aware of any applicable specific local groundbourne noise and vibration
regulations and the requirement to comply with non-existent regulations has

This impact is discussed in the second paragraph under the Potential Effects on all
Sensitive Receptors on Page 3.14-9 of the DEIR/EIS but the potential vibration level is not
disclosed.

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no value. Further, the measure should include specific actions to reduce

vibration levels rather than simply monitor them. As a result of the above
errors, Measure N-5 fails to reduce construction vibration impacts to less than
significant levels.
8)

Measure N-5 is not a Valid CEQA Mitigation Measure for Construction

Vibration Impacts. Noise and vibration avoidance, minimization, and/or
abatement measure N-5 calls for the Project Engineer to develop specific
property line vibration limits during final design for inclusion in the
construction vibration specifications and regular monitoring will be required to
verify compliance with those limits. The deferral of the selection of vibration
limits to the Project Engineer makes this an invalid mitigation measure under
CEQA. There is no reason to not establish acceptable vibration levels at this
time. To be valid, such a mitigation measure must include, a specific action to
be accomplished, performance standards to be met, and methods to meet the
standards presented. For the mitigation measure to result in a no significant
impact finding, the feasibility of meeting the performance standards in all
anticipated conditions must be demonstrated. Otherwise the potential for a
significant unavoidable impact must be acknowledged. To ensure that no
significant impacts would occur, potential mitigation measures should include
compensation for residents to temporarily relocate as the tunnel boring
machines pass under their homes.

9)

The Analysis Does Not Completely Address Potential Construction

Vibration Impacts. The DEIR/EIS acknowledges that for the LRT and
Freeway Tunnel Alternatives, excavation and construction of the tunnel
portals and underground stations, including pile driving, where residents are
located nearby could result in short-term ground-borne noise and vibration
(Page 3.14-9). The Groundborne Noise and Vibration Impacts technical report
concludes that, Pile driving and other vibration producing activity at station
sites may impact residential receptors within 200 feet of the construction
activity (Page 6-2). As with the potential boring vibration impact discussed
above, this impact is not discussed in the CEQA section and the CEQA section
concludes that there would not be a significant impact due to the exposure of
persons to or generation of excessive ground-borne noise levels. The CEQA
analysis must address and propose mitigation for this significant impact.

10) The Analysis does Not Address Potential Impacts from Blasting Section
3.14.3.1 notes that while no blasting is anticipated, it may be evaluated if
higher than expected strength bedrock is discovered in the cut-and-cover
sections or in the excavation of cross passages (page 3.14-9).
The
determination of whether blasting will be performed is to be made after more
detailed geotechnical information becomes available.
This information is
repeated in Section 3.24.14.2 (page 3.24-13). The potential for noise and
vibration impacts from blasting is quite variable and many of the variables that
determine impacts can be adjusted to minimize the potential for impacts. For
example, several small blasts can perform the same work as one large blast
but result in lower maximum vibration levels. The DEIR/EIS should better
indicate where blasting may be used as well as the possibility that it will be
used. A performance standard based mitigation measure should be developed

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to ensure that any blasting would not result in significant noise and/or
vibration impacts. This standard should include planning, notification and
monitoring components as well as clear noise and vibration level limits. The
DEIR/EIS should discuss feasibility of meeting the limits and alternatives if
they cannot be met.
2.1.3 Operational Noise
11) Thresholds of Significance for Long-Term Stationary Impacts under
CEQA are Not Stated Clearly. The discussion of Long-Term Stationary Noise
Impacts starting on Page 4-70 concludes that with the proposed 8-foot high
perimeter wall, noise levels would comply with the Alhambra and Los Angeles
City Noise Ordinances at surrounding noise sensitive uses. The section should
clearly state at the introduction that compliance with the noise ordinance is
being used as the threshold of significance.
12) The Discussion of Long-Term Stationary Impacts is Confusing. The
discussion of Long-Term Stationary Noise Impacts starting on Page 4-70 starts
abruptly with information regarding the City of Alhambra and City of Los
Angeles Noise Ordinances and then the proposed LRT maintenance yard and
noise levels generated by the yard. The purpose of this information is not
clear to the reader until the end of the discussion. A few introductory
sentences are called for to allow the reader to understand the purpose of the
information presented.
13) Thresholds of Significance for Long-Term Transportation Noise
Impacts under CEQA are Not Presented. As with construction noise and
vibration impacts, the DEIR/EIS does not state what threshold of significance
apply to its analysis. The discussion of Long-Term Transportation Noise
Impacts indicate that because the Build Alternatives would not result in any
substantial increases in noise levels that no significant impact would occur.
While substantial increase is not defined, the document appears to define it
as perceptible. For example, the document concludes (albeit incorrectly) that
long-term transportation impacts would be less than significant because the
Build Alternatives would not result in any substantial (perceptible) increases in
noise levels. DEIR/EIS Page 4-75.
We agree that whether the Project causes a perceptible noise increase is the
appropriate qualitative threshold. However, it does not appear to be applied
properly or consistently. To the extent the document relies on the
FHWA/Caltrans Substantial Increase criterion, 12 dB, that level of noise
increase is well above a perceptible increase and is not appropriate for use as
a threshold of significance. Indeed, a 10 dB increase is perceived as a
doubling of noise levels. The FHWA/Caltrans approach/exceed criteria does
not consider the change in noise levels due to the project. Therefore, a project
resulting in a decrease of noise levels at a sensitive receptor would still need to
consider abatement for that receptor if the with project noise level approaches
or exceeds the applicable NAC. The 12 dB substantial increase criterion is
meant as a backstop measure for projects that introduce traffic noise to
receptors with low background noise levels.

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Rather, the appropriate format for a CEQA significance threshold for a

transportation noise source is that the project causes a perceptible increase in
noise and the resulting noise level exceeds an applicable noise standard. This
threshold responds to question XII (a) of the CEQA Guidelines Appendix G,
would the project exposure of persons to or generation of noise levels in
excess of standards established in the local general plan or noise ordinance, or
applicable standards of other agencies? while recognizing that imperceptible
noise level increases would not result in a significant impact.
Perceptible noise increase: A 3 dB change is the most typical threshold for
a perceptible increase in a community noise setting. The just noticeable
difference in noise level perception, the smallest change that can be
perceived by a human, for sound is about 1 dB. In areas where high noise
levels are experienced the 1 dB threshold may be more valid.
Applicable noise standard: In this case the applicable noise standard is
defined by the local municipalities typically in their Noise Element. In
California the typical exterior noise standard applied to residences is 65
CNEL and the typical interior noise standard for residences is 45 CNEL.
Note that the exterior standard is often limited to private outdoor living
areas (enclosed rear yards, patios or balconies, not front yards).
Municipalities define noise standards for other uses as well that would be
applicable to this analysis.
The threshold for a significant impact is that the project causes a perceptible
increase and the resulting noise level exceeds acceptable levels.
The analysis should also analyze cumulative noise impacts. Cumulative noise
impacts occur when perceptible noise increases over existing conditions due to
the project and all other anticipated traffic growth are anticipated and the
resulting noise levels exceed an applicable noise standard. If cumulative
impacts are identified and the project is determined to considerably contribute
to that impact then the project is responsible for mitigating that impact.
14) Analysis of CEQA Long-Term Operational Traffic Noise Impacts is
Incorrect and Fails to Identify Significant Impacts. The first paragraph
of the Long-Term Transportation Noise Impacts analysis on Page 4-75 states
that because the Build Alternatives would not result in any substantial
increases in noise levels in the study area4 compared to the existing noise
levels as shown in Table 4.3, no significant noise impact would occur under
CEQA. The paragraph continues to discuss how noise abatement will further
reduce noise levels and long-term noise impacts are considered less than
significant. The second paragraph states, Since the Build Alternatives would
not result in any substantial (perceptible) increases in noise levels in the study
area outside the limits of the physical improvement, long-term noise impacts
would be less than significant under CEQA, and references Tables 4.3 through
4.7 as demonstrating this.
4

The use of study area here is a misnomer as it does not mean the Project Study Area as
shown in Figure 1-1. The first sentence of the paragraph correctly limits the discussion to
residents in the vicinity of the limits of the Build Alternative Improvements.

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There are several problems with the conclusions stated in these paragraphs:
First, as discussed in comment 13), the DEIR/EIS fails to specify what value
of decibel level increase constitutes a substantial or perceptible increase.
Second, Tables 4.3 through 4.7 only show changes in traffic noise levels
along numbered highways. The Alternatives will also affect traffic volumes
and noise levels along arterial roadways and sensitive receptors (e.g.,
homes) within the study area.
The analysis must assess noise level
changes along arterial roadways to demonstrate that there will not be a
significant impact.
Third, the traffic noise level differences presented in Tables 4.3 through 4.7
only reflect noise level changes due to changes in traffic volumes, they do
not reflect noise level changes that will be caused by physical changes to
the roadway roads and highways constructed and/or modified by the
project. Therefore, the traffic noise level changes presented in these tables
are not valid for receptors located along the build portions of the project
alternatives. As discussed below, the modeling performed to satisfy the
FHWA/Caltrans 23 CFR 772 requirements account for the noise level
changes caused by proposed physical changes for receptors located along
roads and highways constructed and/or modified by the project. Tables
3.14.16 through 3.14.19 show that many receptors, representing dozens
more homes, would experience peak hour noise level changes of 3 dB or
more. These receptors would also experience CNEL noise level increases of
3 dB and many would experience resulting CNEL levels greater than the
standards defined by local municipalities a standard CEQA threshold of
significance. These impacts should have been identified as significant. The
DEIR/Ss conclusion of less-than-significant ignores these substantial noise
level changes at sensitive receptors along the build alternatives.
Finally, the conclusion ignores the noise level changes at sensitive receptors
along the build alternatives that are not eligible for sound abatement under
the Federal Highway Noise Abatement Regulation, 23 CFR 772.
Traffic noise level changes experienced by sensitive receptors (e.g., homes)
along the roads and highways that will be constructed and/or modified by the
project are shown in Tables 3.14.8 and 3.14.9 for the TSM/TDM alternative,
Tables 3.14.11 and 3.14.12 for the BRT alternatives, Tables 3.14.16 and
3.14.17 for the Single Bore Freeway Tunnel Alternative, and Tables 3.14.18
and 3.14.19 for the Dual Bore Freeway Tunnel alternative. The noise levels
presented in these tables are in terms of peak hour Leq(h). However, the
change in CNEL noise levels will be similar to the change in Leq(h) noise levels.
Therefore, the change in Leq(h) noise levels is an appropriate surrogate for
change in CNEL noise levels. The analysis needs to be be extended to calculate
CNEL noise exposures and changes for each of the receptors analyzed in these
tables to accurately determine CEQA impacts along the build alternatives.
The DEIR/EIS seems to conclude that these impacts would be mitigated by
implementation of sound abatement. However, the analysis, once again,
ignores those receptors for which implementation of noise abatement is not

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reasonable or feasible. For purposes of CEQA impact determination, the

analysis should explain that sound mitigation is not feasible or reasonable at
certain
locations
and
reach
a
corresponding
conclusion
of
significant/unavoidable impacts at these locations.
Tables 3.14.16 and 3.14.18 show the projected increase in Leq(h) noise levels
for the sensitive receptors located within the limits of the Build Alternative
improvements for the Single Bore and Dual Bore Freeway Tunnel Alternatives.
These tables show that many receptors will experience perceptible noise level
changes of 3 dBA or greater. Based on the long-term noise measurements at
sites FML-1 through FML-4, CNEL levels along the freeway are approximately 1
to 3 dB greater than the peak noise hour noise level. Therefore, receptors
with a Leq(h) of 65 dBA or greater would be exposed to a CNEL noise level
greater than 65 dBAthe typical outdoor residential noise level deemed
acceptable by the local municipalities. Receptors with a Leq(h) between 62
and 65 dBA or greater may be exposed to a CNEL noise level greater than 65
dBA.
Table 3.14.34 shows that under the Single Bore Freeway Tunnel Alternative
only two noise barriers, FTNB No. 5 and FTNB No. 10, will be reasonable
assuming no donation of right-of way. Table 3.14.16 shows that residential
receptors FR-7 through FR-15, FR-17 through FR-22, FR-47 through FR-51,
FR-68, FR-69, FR-103, FR-106, FR-108, FR-110, and FR-120 will be subjected
to noise level increases of 3 dB or greater (i.e., perceptible noise increase)
and an Leq(h) noise level greater than 65 dB even considering the proposed
reasonable noise barriers. These 27 receptors represent 310 dwelling units.
These dwelling units would therefore be subject to a perceptible noise increase
of 3 dB or greater over existing conditions and an exterior noise level of 65
CNEL or greater, a typical CEQA significance threshold for highway noise
impacts.
Table 3.14.34 further shows that under the Dual Bore Freeway Tunnel
Alternative only four noise barriers, FTNB No. 5, FTNB No. 6, FNTB. No 9 and
FTNB No. 10, will be reasonable assuming no donation of right-of way. Table
3.14.18 shows that residential receptors FR-7 through FR-22, FR-24, FR-25,
FR-26, FR-28 through FR-36, FR-41, FR-46 through FR-51, FR-53, FR-68, FR69, FR-75, FR-80, FR-81, FR-83, FR-88 through FR-100, FR-103 through FR110, FR-113, and FR-120 will be subjected to noise level increases of 3 dB or
greater and an Leq(h) noise level greater than 65 dB. These 65 receptors
represent 348 dwelling units. These dwelling units would be subject to a
perceptible noise increase of 3 dB or greater over existing conditions and an
exterior noise level of 65 CNEL or greater, a typical CEQA significance
threshold for highway noise impacts.
The DEIR/EIS must prepare a proper analysis of long-term transportation
noise impacts as the existing analysis is insufficient and deficient for the
reasons discussed above. In sum, our analysis of the data included in the
document shows that there are significant impacts that are not identified or
mitigated by the document.

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15) The Methodology Used To Determine the Noise Level Increases

Presented in Tables 4.3 Through 4.7 Is Not Documented and Errors
May Result in Unidentified Significant Impacts. The DEIR/EIS only states
that the FHWA Traffic Noise Model was used to assess the increase in noise
level. The specific data used in the model is not presented. The analysis
should take into account changes in traffic volumes, speeds and vehicle mix
(truck percentages). The analysis must also account for noise level changes
caused by physical changes to the roads and highways constructed and/or
modified by the project for receptors in these areas. If all of these factors
were not accounted for in the calculation then it is possible that noise level
increases greater than those shown in Tables 4.3 through 4.7 could occur and
result in unidentified significant impacts.
16) The Operational Noise Analysis Obfuscates Impacts by Not Accurately
Reporting the Number of Sensitive Uses Impacted. The analyses of
operational (permanent) impacts in Section 3.14.3.2 on Pages 3.14-11
through 3.14-15 discuss noise impacts in terms of the number of receptors.
However, as shown in Tables 3.14.8, 3.14.11, 3.14.14, 3.14.16, and 3.14.18
each receptor can represent one or more households. Therefore, there are
many more households with noise exposures projected to approach or exceed
the FHWAs NAC than reported in the document.
Under the TSM/TDM
alternative the 70 impacted receptors represent 178 residential units and 9
commercial uses. Under the BRT alternative the 118 impacted receptors
represent 239 homes and 6 commercial uses. Under the Single Bore Freeway
Tunnel Alternative the 69 impacted receptors represent 150 residential units
and 4 commercial uses. Under the Dual Bore Freeway Tunnel Alternative the
86 impacted receptors represents 184 residences and 9 commercial uses. The
layperson is most likely unaware of the distinction between receptor and
household and the reporting of only of number of receptors impacted misleads
their perception of the scope of the noise impacts. To allow the reader to
accurately understand the noise impacts from the Build Alternatives they must
be presented in terms of uses rather than only receptors.
17) The Operational Noise Analysis Obfuscates Impacts for Which
Abatement is Not Feasible. Tables 3.14-21, 3.14-23, 3.14-26, purport to
show Receptor Locations Where the Applicable Noise Abatement Criteria
Would be Approached or Exceeded under the TSM/TDM, BRT, and Freeway
Tunnel alternatives. However, these tables only list those receptors which
were identified as impacted AND for which abatement through construction of
a noise barrier is feasible. Table 1 presents a summary of the receptors
considered (Number of Modeled Receptors) and the number of receptors
identified as being impacted. The final three columns of the table show the
disposition of those impacts.
The final column presents the number of
receptors for which noise abatement will be provided with the project
(assuming no donation of right of way). This shows that only a small portion
of those receptors identified as being impacted will receive noise abatement
with the project.

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Table 1
Noise Analysis Receptors1
Receptors
Receptors Number of
With No
With No Receptors to
Feasible
Reasonable be Provided
Noise
with Noise
Noise
Abatement Abatement Abatement

Alternative

Number
of
Modeled
Receptors

Total
Impacted2
Receptors

TSM/TDM

227

70

43 (52)

17

BRT

506

129 (118)

120 (109)

Freeway Tunnel
Single Bore3

137

66 (69)

3 (5)

46 (47)

20 (17)

Freeway Tunnel
Dual Bore3

137

75 (86)

3 (12)

44 (45)

28 (29)

1. Note that this table only reports the number of analysis receptors. In many instances one analysis
receptor is representative of multiple dwelling units. Therefore, this table does not present the
number of impacted residences or other land uses.
2. All impacts were due to with-project noise exposures approaching or exceeding the FHWA/Caltrans
NAC. There were no receptors identified to experience increases greater than the FHWA/Caltrans
Substantial Increase criterion (12 dBA over existing conditions).
3. Due to errors in Tables 3.14.8 through 3.14.18 some of the receptor counts presented here and in
the document are incorrect. The numbers in parenthesis is the corrected count when errors in Tables
3.14.8 through 3.14.18 are corrected.

The document discusses the receptors for which noise abatement was
considered but not found reasonable. The number of receptors for which
abatement was considered but not found reasonable is shown in the
Receptors With No Reasonable Noise Abatement heading of Table 1.
However, there are also a considerable number of receptors for which noise
abatement was found to be not feasible. The number of receptors for which
abatement was not determined to be reasonable are show in Table 1 under
the Receptors With No Feasible Noise Abatement heading. These receptors
are simply omitted from Tables 3.14-21, 3.14-23, 3.14-26. The DEIR/EIS
needs to clearly present receptors that have been identified as impacted under
the FHWA criteria for which abatement is not possible. In other words, as
Table 1 demonstrates, the Project will result in numerous significant long-term
noise impacts, most of which will not receive noise barrier mitigation. These
impacts must be disclosed as significant and unavoidable.
18) The Analysis Does Not Address Potential Long-Term Operational
Interior Noise Impacts Under CEQA. The analysis of long-term operational
impacts focuses on exterior noise levels and only addresses interior noise
levels under the FHWA/Caltrans Activity Category C which applies to schools
and churches. The CEQA analysis of impacts only addresses exterior noise
levels and ignores interior noise levels. The appropriate significance threshold
for interior noise impacts is the same as exterior noise impacts. A significant
impact occurs if the project results in a perceptible noise increase and the
resulting noise level exceeds the locally defined interior noise standard. The
State of Californias General Plan Guidelines (Specifically Appendix C: Noise
Element Guidelines) suggest 45 CNEL as an acceptable interior noise standard
and most local municipalities have adopted this standard.

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With closed windows, residential structures achieve between 20 and 25 dB of

outdoor-to-indoor noise reduction. However, adequate ventilation per the
Uniform Building Code must be provided in order to assume windows can
remain closed. When windows are open, the outdoor-to-indoor noise reduction
falls to between 12 and 15 dBA. This means that interior noise levels will
exceed 45 CNEL when windows are open and exterior noise exposures exceed
57 CNEL. Exterior noise exposures greater than 65 CNEL will result in interior
noise levels of greater than 45 CNEL with closed windows.
As discussed in comment 14) above, the CEQA analysis of long-term impacts
incorrectly dismisses those receptors located along the build alternative for
which noise abatement was considered to address the FHWA requirements but
will not be implemented due to infeasibility or unreasonableness. Of these
receptors, those with perceptible noise level increases and exterior exposures
greater than 57 CNEL will be subject to a significant indoor noise impacts
under CEQA in addition to the exterior impacts described in comment 14).
Further, while noise barriers implemented to address the FHWA criteria will
reduce noise levels for ground level exterior and first floor interior observers
to less than perceptible levels, the analysis does not examine second floor
observers, interior or exterior. The effectiveness of a noise barrier is based on
how much it breaks line of sight between an observer and a noise sourcethe
more it breaks the line of sight the greater the noise reduction provided. This
results in ground level observers receiving considerably higher levels of noise
reduction from barriers than second floor observers.
Additional modeling is required to determine the second floor noise exposures
of sensitive receptors behind barriers that will be constructed to comply with
FHWA criteria. These exposures should be used to assess potential impacts
under CEQA by examining the increase in and absolute traffic noise levels for
these receptors.
Mitigation must be considered for all receptors with
discernable increases and unavoidable impacts identified for those without
feasible noise reduction options.
19) Ventilation System Exhaust Noise is not Examined. The Freeway Tunnel
and LRT alternatives include a ventilation system for the proposed tunnel.
There is very little detail provided regarding the ventilation system beyond
general locations of exhaust vents. The ventilation system will utilize fans and
fans generate noise. However, there is no discussion of noise generated by
the ventilation system in the DEIR/EIS. The document must address potential
noise impacts from operation of the ventilation system.
20) The CEQA analysis of vibration impacts (page 4-75) concludes that with the
implementation of Measure N-5, the ground-borne noise effect would be
minimized during the operation of the LRT Alternative. However, measure N5 only addresses construction vibration; it does not address operational
vibration impacts from the LRT Alternative.
21) Table 3.14.14 (Table B.11 of NSR) footnote 1 states that short-term
measurements at sites LM-22 through LM-29 use the DNL level measured at
long-term site LML-2 as the basis to convert the measured Leq noise level to

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LDN. However, the existing noise level shown in the table is not consistent
with this statement for Receptors LR-22 through LR-29. The values shown
are consistent with using FML-1 as the long-term site. The footnote or the
LDN values need to be corrected.
22) The text of the DEIR/EIS states that 129 of 506 receptors would approach or
exceed the NAC under the BRT Alternative. However, the Impact Type Column
of Table 3.14.11 only show 116 receptors as being impacted. Further, there
are three additional receptors that should have been shown as impacted but
were not. We would assume that Table B.3 of the Noise Study Report contains
the same errors. These errors and the subsequent errors in the analysis and
presentation caused by the misidentification of impacted receptors must be
corrected.
23) The text of the DEIR/EIS states that 66 of 137 receptors would approach or
exceed the NAC under the Single Bore Freeway Tunnel Alternative and the
Impact Type Column of Table 3.14.16 shows this number of receptors as being
impacted. However, there are errors in the identification of impacts that when
corrected results in 69 receptors with noise levels that approach or exceed the
NAC. We would assume that Table B.7 of the Noise Study Report contains the
same errors. These errors and the subsequent errors in the analysis and
presentation caused by the misidentification of impacted receptors must be
corrected.
24) The text of the DEIR/EIS states that 75 of 137 receptors would approach or
exceed the NAC under the Dual Bore Freeway Tunnel Alternative and the
Impact Type Column of Table 3.14.18 shows this number of receptors as being
impacted. However, there are errors in the identification of impacts that when
corrected results in 86 receptors with noise levels that approach or exceed the
NAC. We would assume that Table B.9 of the Noise Study Report contains the
same errors. These errors and the subsequent errors in the analysis and
presentation caused by the misidentification of impacted receptors must be
corrected.
25) Page 119 second line under 7.3.4.2 heading. FR-2 should be LR-2.
2.1.4 Cumulative Impacts
26) Cumulative Impact Conclusion is Incorrect. Section 3.25.4.14 includes
the following statement, Additionally, neither the I-10 HOT Lanes, nor the SR
710 North Study Build Alternatives would result in substantial unmitigable
long-term noise impacts. Abatement measures are proposed and none of the
receptors reach a noise level that exceeds 12 A-weighted decibels (dBA).
Therefore, the SR 710 North Study would not contribute to a cumulative noise
impact. As discussed above, the conclusion that the SR 710 North Study
Build Alternatives would not result in substantial unmitigable long-term noise
impacts is incorrect. Further, the statement that none of the receptors are
exposed to noise levels exceeding 12 dBA is obviously errant. There are no
developed areas that experience noise levels this low. To the extent that the
document meant to refer to a 12 dBA increase, such a threshold is not an
appropriate threshold as it represents a more than doubling of the noise level.

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An appropriate threshold is a just perceptible increase which occurs with a 1 to

3 dB noise level increase.
Cumulative traffic noise impacts should be assessed the same as project
impacts.
That is, a cumulative impact occurs if traffic noise levels are
projected to perceptibly increase over existing conditions and the resulting
future noise level exceeds the locally defined acceptable level. The analysis
will then need to consider the projects contribution to the noise level increase
and determine if it is cumulatively considerable. If the projects contribution is
cumulatively considerable then it is responsible for providing mitigation. The
document failed to provide this analysis.
2.1.5 Noise Study Report
27) Noise Model Calibration is not Consistent with Caltrans Guidance.
Caltrans guidance (Technical Noise Supplement Section 4.4.1.6) states that
model calibration should not be attempted when calculated and measured
noise levels agree within 1 dBA and should only be used when the levels agree
within 2 dBA if there is great confidence in the accuracy and
representativeness of the measurements. Differences between 3 and 4 dBA
are routinely calibrated unless the validity of the measurements are in serious
doubt. Differences of 5 dBA or more should be approached with caution.
Tables 6.33 through 6.35 of the NSR present the results of the traffic model
calibration. These tables show the measured and modeled noise levels for the
calibration sites along with the difference, the K-factor. The final column of
the table lists the Representative Modeled Receptors. We assume that the Kfactors shown were applied to the receptors listed. The tables show that there
are a considerable number of receptors with K-factors of less than 1.5 dB.
Per Caltrans guidance, K-Factors of less than 1.5 dB should not be used in the
modeling. The analysis should be revised to not omit the use of K-Factors of
less than 1.5 dB or provide a detailed explanation of why this guidance was
ignored. Making this correction may result in changes to the identification of
noise impacts and barrier considerations.
28) The Analysis of TSM/TDM Impacts Does Not Adequately Discuss
Receptors With No Feasible Abatement. Section 7.1.1 of the NSR states
that 70 receptors would approach or exceed the NAC under the TSM/TDM
alternative. However, the discussion of impacted receptors on pages 88 and
89 lists only 27 receptors as being subjected to noise levels approaching or
exceeding the applicable NAC. The report notes that 43 receptors were not
considered for abatement due to driveway or pedestrian access and it appears
that it is these receptors that are not presented in the discussion. The report
should distinctly and clearly identify ALL impacted receptors (i.e., those with
noise exposures approaching or exceeding the NAC). Otherwise it appears
that the document is attempting to discount significant and unavoidable noise
impacts for which there is no feasible abatement and inappropriately minimize
the identification of impacts. The discussion of whether or not there are
feasible noise abatement measures for the impacted receptors should be
included in Section 7.3.1.

SR-710 North Study DEIR/EIS

Noise & Vibration Review and Comment

Landrum & Brown

Page 26

29) The Analysis of BRT Impacts Does Not Adequately Discuss Receptors
With No Feasible Abatement. Section 7.1.2 of the NSR states that 129
receptors would approach or exceed the NAC under the BRT alternative.
However, the discussion of impacted receptors on pages 90 and 91 lists only 9
receptors as being subjected to noise levels approaching or exceeding the
applicable NAC. The report notes that 120 receptors were not considered for
abatement due to driveway or pedestrian access and it appears that it is these
receptors that are not presented in the discussion. The report should distinctly
and clearly identify ALL impacted receptors (i.e., those with noise exposures
approaching or exceeding the NAC). Otherwise it appears that the document
is attempting to discount significant and unavoidable noise impacts for which
there is no feasible abatement and inappropriately minimize the identification
of impacts.
The discussion of whether or not there are feasible noise
abatement measures for the impacted receptors should be included in Section
7.3.2.
30) The Analysis of Freeway Tunnel Impacts Does Not Adequately Discuss
Receptors With No Feasible Abatement. Section 7.1.3 of the NSR states
that 66 receptors would approach or exceed the NAC under the single-bore
freeway tunnel alternative and 75 receptors would under the dual-bore tunnel
alternative. However, the discussion of impacted receptors on pages 92
through 95 lists only 68 receptors as being subjected to noise levels
approaching or exceeding the applicable NAC. Further, this information is not
consistent with the data shown in Tables B-7 and B-9.
In Table B-7 there are three receptors that show A/E in the Impact Type
column yet the noise level in the With Project column does not approach or
exceed the NAC, specifically, Receptors FR-29, FR-46 and FR-109. There are
seven receptors With Project noise levels approaching or exceeding the NAC
that are not shown as A/E in the Impact Type column. Specifically, FR-38, FR39, FR-54, FR-68, FR-91, FR-114, and FR-133.
In Table B-9 are nine
receptors With Project noise levels approaching or exceeding the NAC that are
not shown as A/E in the Impact Type column. Specifically, FR-50, FR-57, FR68, FR-69, FR-73, FR-81, FR-100, FR-114, and FR-121.
The report does not note that for the Freeway Tunnel Alternatives 8 receptors
were not considered for abatement due to driveway or pedestrian access under
both Single and Dual Bore Alternatives. Note that when the corrections
presented above are made this number jumps to 6 receptors under the single
bore alternative, and 12 receptors under the dual bore alternative. The report
should distinctly and clearly identify ALL impacted receptors (i.e., those with
noise exposures approaching or exceeding the NAC). Otherwise it appears
that the document is attempting to discount significant and unavoidable noise
impacts for which there is no feasible abatement and inappropriately minimize
the identification of impacts. The discussion of whether or not there are
feasible noise abatement measures for the impacted receptors should be
included in Section 7.3.2.
31) The Analysis Obfuscates Impacts by Only Presenting the Number of
Analysis Receptors Impacted Rather Than the Number of Residences

SR-710 North Study DEIR/EIS

Noise & Vibration Review and Comment

Landrum & Brown

Page 27

Represented by the Receptors. The discussion of impacts presented in

Section 7.1 only presents the number of analysis receptors that are identified
as being impacted. In many cases a single receptor is used to represent
multiple dwelling units.
This discussion should clearly present the total
number of dwelling units and other uses that are projected to experience
traffic noise levels approaching or exceeding the NAC.
32) There are errors in Tables B.1, B.7 and B.9 of the NSR. Tables B.1, B.7
and B.9 of the NSR show a number of receptors with noise exposures
approaching or exceeding the NAC for the activity category identified in the
table for the receptor that are erroneously not identified as impacted.
33) It is not clear how the Spec 721.560 Lmax noise levels for construction
equipment are relevant to this project. The NSR should explain why this
information is relevant or remove it. Table 3.14-20 of the DEIR/EIS is more
appropriate. (Interestingly the source of this table in the DEIR/EIS is listed as
the Noise Study Report but it is not the same table.)

Resume

Matthew B. Jones P.E.

Education

Bachelor of Science Engineering Physics, Acoustics Specialization,

University of California, San Diego, Summa Cum Lade

Project Manager

A.A. Liberal Arts with a Certificate in Recording Arts, Golden West

College, Huntington Beach, CA
Professional Registration

Registered Professional Engineer in the State of California

(Electrical #17156)

Overview

Mr. Jones has over 20 years of experience in acoustics, noise, and air
quality. He has prepared noise and air quality technical reports for
hundreds of Environmental Impact Reports (EIRs) and Environmental
Impact Assessments (EISs) as well as specialty studies. Work efforts
include project management, software development, engineering
analysis, report preparation, as well as noise and air quality
monitoring. Mr. Jones is involved in the development of many in-house
computer modeling and data analysis programs and is well versed in
many regulatory and non-regulatory air quality and noise modeling
programs as well as ArcView GIS.

Noise Impact Assessments

Mr. Jones has prepared noise assessments for a wide range of projects
with the majority being residential, commercial, and mixed-use
developments ranging from a few residential units or office buildings,
to large specific plans with thousands of units and hundreds of
thousands of square feet of commercial uses. He has also prepared
assessments for include landfills, water treatment plants, cement batch
plants, schools, parks, truck repair facilities, car washes, and a natural
gas pipeline pump station.
Mr. Jones has prepared traffic noise
assessments for many new highway and highway improvement
projects involving the application of the Federal Highway
Administrations (FHWA) Highway Noise Abatement Regulation. He is
intimately familiar with the FHWA Traffic Noise Model (TNM) in both the
algorithms used and the use of the modeling software. Mr. Jones also
has considerable experience in the measurement and modeling of
aircraft noise levels. He is fluent in the use of the FAAs INM and HNM
models and was part of the beta testing team for the FAAs newest
model the Aviation Environmental Design Tool (AEDT).

Air Quality and Greenhouse Gas

Impact Assessments

Mr. Jones has extensive experience quantifying criteria pollutant and

greenhouse gas emissions from a variety of sources and applying an
assortment of criteria to evaluate the impacts of those emissions. In
addition, he is well versed in dispersion modeling and the prediction of
air pollutant concentrations at sensitive receptors.
This includes
assessing the impacts of toxic air contaminants.
Mr. Jones is
experienced with many air quality models including SCAQMDs
URBEMIS and CalEEMod, EPAs AERMOD, ISCST3, SCREEN3,
CALINE3QHC, and MOBILE, FAAs EDMS and AEDT, CARBs EMFAC and
URBEMIS, and Caltrans CALINE4. He has prepared air quality and
greenhouse gas assessments for a variety of projects and purposes,
primarily CEQA and/or NEPA documents for residential/commercial
developments, landfills and waste management, highways, and
airports. He has considerable experience applying the Federal Clean
Air Acts General and Transportation conformity requirements as well
as specific requirements prescribed by the FAA and FHWA for airport
and highway air quality assessments including involvement in FAAs
Voluntary Airport Low Emissions (VALE) grant program applications.
Mr. Jones has been involved in projects in several states including
Arkansas, Idaho, Louisiana, and Texas, and several California Air
Districts including the Bay Area, South Coast, and San Joaquin.

Resume
Representative
Projects

Matthew B. Jones P.E.

Sonoma, CA
Charles M. Schultz-Sonoma County
Airport
Air
Quality
and
Greenhouse
Gas
assessments for Master Plan Update
proposing
a
variety
of
airport
improvement projects.
Analyzed
impacts
from
toxic
air
contaminants on surrounding area.
Orange County, CA
John Wayne Airport (SNA) Settlement
Agreement Amendment Project
Noise Assessment for EIR to extend
existing agreement between the airport
and the City of Newport Beach and citizen
groups including increases to limits on
passengers and flights.
Analyzed 10 years of operations and noise
data to inform future operation estimates.
Assessed aircraft and traffic noise impacts
for four future scenarios implemented in
three phases.
Orange County, CA
South Orange County Transportation
Infrastructure Improvement Project
Noise Assessment for SEIR/EIS for
extension of SR-241 to connect with I-5 .
Analyzed noise impacts for 14 different
alignments
and
two
existing
road
improvement alternatives.
Measured noise levels at 74 sites and
modeled noise levels for 122 receptors
Orange County, CA
Noise Study Report-Foothill
Transportation Corridor-South
Noise barrier assessment for extension of
SR-241 to connect with I-5.
Considered sound abatement options for
impacted receptors per Caltrans and
FHWA requirements.
Measured noise levels at 18 sites and
modeled noise levels at 144 receptors
Wilmington, CA
Harbor Community Benefit Foundation
School & Residential Sound Insulation
Program
Measured noise levels at 25 locations in
the Wilmington Community to identify and
quantify noise generated by activities
associated with the operation of Port of
Los Angeles.
Generated noise contour maps for Port
related
noise
sources
throughout
community
Developed program to select and prioritize
implementation of Sound Insulation.
Saguache County, CO
Tessera Solar
Prepared critique of project proponent
prepared noise assessment for solar
generating facility for county board.
Provided testimony at public hearing

Project Manager
Los Angeles, CA
I-405 HOV Lane Addition
Air Quality Assessment for addition of
HOV lane to northbound I-405 through
the Sepulveda Pass.
Analyzed potential impacts from Mobile
Source Air Toxics
Prepared Air Quality Conformity Analysis
to
demonstrate
compliance
with
Transpiration Conformity Requirements
of Federal Clean Air Act
Irvine, CA
Planning Area 18/39 General Plan
Amendment & Zone Change
Noise and Air Quality Assessments for
proposed
development
of
6,050
residential units.
Assessed potential impacts from mobile
source air toxics on proposed residences
located near major freeway.
Assessed potential impacts on project
from existing amphitheater and water
park on proposed residences.
Azusa, CA
Azusa Material Recovery Facility &
Transfer Station
Noise, Air Quality and Greenhouse Gas
Assessments for new municipal waste
transfer station with materials recovery.
Assessed potential changes in air
pollutant and GHG emissions due to rerouting of trucks and operation of facility
compared to no-project conditions
Assessed potential traffic noise impacts
due to trucks on area roads and from
facility operation.
Los Angeles CA
Light Rail Inverse Condemnation
Lawsuit
Provided noise and vibration consulting
to defense legal team in inverse
condemnation suit from construction and
operation of a light rail facility.
Reviewed and critiqued information
submitted by plaintiffs experts.
Performed and analyzed noise and
vibration
measurements
for
XX
residences.
Noise and vibration excluded from
lawsuit in summary judgment
Costa Mesa, CA
Pacific Amphitheater Re-Opening
Season
Perform community noise measurements
for re-opening season of Amphitheater
with a history of noise issues that had
been reconfigured.
Noise levels as well as subjective
audibility were recorded and reported to
City staff the day following each event.

Technical Appendix 3
(Geology, Seismic,
Soils and Groundwater)

to
Attachment A
5-Cities Alliance
Comment Letter

WILSON GEOSCIENCES
Engineering and Environmental Geology

MEMORANDUM
DATE: July 8, 2015
TO: Laurel L. Impett, AICP, Urban Planner, Shute, Mihaly & Weinberger LLP
FROM: Kenneth Wilson, Wilson Geosciences Inc. (California Professional Geologist #3175 and
Certified Engineering Geologist #928)
WGI PROJECT #: EG14-12
WGI PROJECT NAME: SR 710 North Study DEIR/S ReviewGeology/Seismic/Soils/
Groundwater
SUBJECT: Review of March 2015 SR 710 North Study DEIR/S

INTRODUCTION
At the request of the 5-Cities Alliance and Shute, Mihaly & Weinberger LLP, Wilson
Geosciences Inc. (WGI) in cooperation with GeoDynamics Inc. (GDI, Ali Abdel-Haq,
Registered Civil Engineer #46989 and Geotechnical Engineer #2308), reviewed selected portions
of the SR 710 North Study DEIR/S and the appendices that relate to geology, seismic, soils, and
the Raymond Basin, San Gabriel Basin and Raymond Fault groundwater barrier issues. This
memorandum provides comments on the following DEIR/S sections:

1. PROJECT DESCRIPTION
2. ALTERNATIVES
3.10. GEOLOGY/SOILS/SEISMIC/TOPOGRAPHY (March 2015)
3.9. WATER QUALITY AND STORM WATER RUNOFF (Raymond Basin
Groundwater Portion (March 2015)
4. CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) EVALUATION,
Sections 4.2.6 (Geology and Soils) and 4.2.9 (Hydrology and Water Quality)

In order to review these portions of the DEIR/S, it was necessary also to review all or parts of
numerous other support documents, including but not limited to the following:
1. DEIR/S Sections 2, 3.8, 3.9, 3.10, 3.12, 3.22, 3.23, 3.24.8, 3.24.9, 3.24.10, 3.24.12, 3.25, 4.1,
4.2.6, 4.2.8, 4.2.9, and corresponding tables, figures, and Appendix A (March 2015; 260 pages)
Preliminary Geotechnical Report, Figures, and Plates (November 2014; 166 pages)
SR 710 Preliminary Geotechnical Appendix C Groundwater Monitor (November 2014;
9 pages)
SR 710 Preliminary Geotechnical Appendix E Fault Rupture Memo (December 2013; 20
pages)
SR 710 Preliminary Geotechnical Appendix G Fault Investigation (February 2014 ;27
pages)

1910 Pinecrest Drive Altadena, California 91001 Telephone 626 791-1589

wilsongeosciencesinc@gmail.com

SR-710 DEIR/S Review-Geology/Seismic/Soils/Groundwater

July 8, 2015
Page 2 of 24

Water Quality Assessment Report (May 2014; 156 pages)

SR 710 Tunnel Evaluation Report (September 2014; 374 pages)
Geologic Hazard Evaluation (November 2014; 130 pages)
2. Alternatives Analysis Report and Appendices A, C, G, J, and T (December 2012; 226 pages)
This review addresses the following deficiencies in the DEIR/S:
1. PROJECT DESCRIPTION/ALTERNATIVES
a. The DEIR/S lacks information, including specific definition and consequences, of the fatal
flaw analysis contained in the geotechnical feasibility study affecting the bored tunnel and LRT
alternatives.
2. GEOLOGY/SOILS/SEISMIC/TOPOGRAPHY (SECTION 3.10)
a. Caltrans has no established tunnel site selection criteria or tunnel design criteria for earthquake
fault rupture; therefore, the DEIR/S does not adequately analyze the risk that active fault tunnel
crossings entail.
b. The DEIR/S does not accurately characterize potential active fault rupture offset for the
Raymond, Eagle Rock, and San Rafael faults at the proposed tunnel crossings thereby
underestimating the Projects risks to public safety.
c. The DEIR/S does not adequately evaluate the bored tunnel design for near-source groundshaking effects from an earthquake on the Raymond fault, or one involving the Raymond, Eagle
Rock, and San Rafael faults together, thereby potentially underestimating ground shaking values.
d. The DEIR/S does not identify significance criteria relating to fault offset and ground shaking,
fails to determine the significance of the Projects impacts, and defers mitigation until after
Project approval.
e. The DEIR/S fails to analyze adequately potential impacts from ground settlement and fails to
mitigate for these effects.
f. Caltrans improperly rejected a safer tunnel design in favor of a less expensive, more quickly
built design, but one with more potential for severe stress to the tunnel.
3. WATER QUALITY AND STORM WATER RUNOFF (SECTION 3.9, RAYMOND BASIN
GROUNDWATER PORTION)
a. The DEIR/S does not describe the Raymond Basin and Pasadena Subarea groundwater
characteristics in sufficient detail to allow an evaluation of groundwater flow in the tunnel area.
It also does not include sufficient geotechnical detail including information relating to bedrock
fracture patterns.
b. The DEIR/S lacks analysis to determine the potential impacts on the Raymond Basin and
Pasadena Subarea groundwater supplies that could result from a penetration of the Raymond
Fault groundwater barrier.
c. The DEIR/S lacks analysis to determine the potential degradation of Main San Gabriel Basin
groundwater quality from penetrating the Raymond fault groundwater barrier

SR-710 DEIR/S Review-Geology/Seismic/Soils/Groundwater

July 8, 2015
Page 3 of 24

These issues render the documents analysis of geology, seismic, soils, and groundwater impacts
severely deficient, and the mitigation measures ineffective and inadequate.
1. PROJECT DESCRIPTION/ALTERNATIVES
The DEIR/S lacks information, including specific definition and consequences, of the fatal
flaw analysis contained in the geotechnical feasibility study affecting the bored tunnel and
LRT alternatives.
DEIR/S Section 1 (pages 1-1 through 1-7) presents a series of alternatives, including a freeway
tunnel alternative that would satisfy the goal of providing transportation improvements to
improve mobility and relieve congestion. In subsection 1.1.2 (page 1-6), the DEIR/S states a
geotechnical feasibility assessment concluded that the tunnel concept was feasible to complete a
freeway, and no fatal flaws1 were identified. The DEIR/S does not indicate whether a similar
geotechnical feasibility assessment was conducted for the LRT alternative.
The DEIR/S also never identifies or defines the phrase fatal flaws, nor does it identify the
particular characteristics that would be considered a fatal flaw. As discussed below, potentially
significant geologic, seismic, geotechnical, and groundwater constraints occur in the study area,
especially near the tunnel alternative alignment.
Did the feasibility assessment evaluate the constraints associated with crossing one or more
active faults capable of generating vertical and horizontal movements across the 60-foot tunnel
excavations? Did the assessment consider penetrating a groundwater barrier between two
currently separate groundwater storage basins, potentially allowing transmission of groundwater
and chemical contaminants between these independently operated basins? Did Caltrans and
Metro ever evaluate the technical and design limitations that were used to eliminate the
individual tunnel alignments from consideration? Was there an alternative that met the following
criteria: (1) sufficient portal2 depth; (2) does not cross an active fault3; (3) meets the minimum
curvature design; and (4) would not potentially join two groundwater basins4? These are
fundamental flaws with the proposed tunnel and LRT alignment, yet these questions remain
unanswered. The DEIR/Ss failure to identify the criteria that Caltrans and Metro used to
identify the proposed tunnel alignment makes it impossible to determine whether other Project
alternatives or tunnel alignment locations would avoid these serious constraints. The DEIR/S
should have disclosed this information and identified the associated alignment. Without this
information, the public has no way of determining whether any tunnel alignment is practical
and/or safe. Unfortunately, it is not possible to verify independently the accuracy of the
geotechnical feasibility assessment since it was not included in the DEIR/S.
At a minimum, the tunnel design alternative must take into account geologic, seismic,
geotechnical, and groundwater constraints. Equally important, the DEIR/S must apprise the
1

Fatal flaw = A condition that would prevent the alternative from meeting the project objectives.
Portal = The beginning (entrance) and ending (exit) points for the tunnel alternative.
3
Active fault = An earthquake fault that has moved (fault offset) within the past approximately 11,000 years.
4
Groundwater basins = Subterranean areas where water naturally collects and is stored for pumping and use.
2

SR-710 DEIR/S Review-Geology/Seismic/Soils/Groundwater

July 8, 2015
Page 4 of 24

public of these constraints and the public safety and environmental implications associated with
building a tunnel along the proposed alignment.
2. GEOLOGY/SEISMIC/SOILS (SECTION 3.10)
Using the established geology and soils thresholds from CEQA (CEQA Guidelines Appendix G),
the DEIR/S states that the Project will be considered to have a significant impact if it:
Expose[s] people or structures to potential substantial adverse effects, including the risk
of loss, injury, or death involving:
i)
Rupture of a known earthquake fault, as delineated on the most recent
Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for
the area or based on other substantial evidence of a known fault. Refer to
Division of Mines and Geology Special Publication 42.
ii)
Strong seismic ground shaking.
The following questions are critical for determining whether the Project would have a significant
impact to geology and soils: 1) have Caltrans and Metro used a vetted, tunnel-specific fault
rupture offset standard in their analysis; 2) did the agencies use a current and sufficiently
conservative methodology to determine the design fault rupture; 3) did they properly consider
whether the added effects of near-source/near-fault ground shaking would amplify fault offset
damage; and 4) will the preferred tunnel design accommodate offset at/near a threshold that
could cause collapse?
To determine properly whether a tunnel project constructed in a seismically active region would
expose people to injury or death and structures to damage, the DEIR/S must undertake the
following steps. First, the DEIR/S must identify thresholds of significance. That is, it should
identify the point at which the projects seismic impacts will be considered significant. Second,
the DEIR/S must identify and describe existing active fault and earthquake conditions
specifically where the crossings are to occur. This should include sympathetic movement5 on
non-active faults and parallel geologic bedding6 between the Raymond and San Rafael faults.
Third, given the known conditions affecting Project construction, the DEIR/S must provide a
detailed description of the Projects fault rupture and near-source7 earthquake ground shaking
effects on the geologic formations that could affect the tunnel, on the construction elements of
the tunnel, and on the users of the tunnel. This information would then allow the agency to
select the appropriate performance standard, and therefore the appropriate tunnel design, for
tunnel construction and operation within the seismically active setting.8
The DEIR/S preparers should have considered this information to accurately identify and analyze
the Projects seismic impacts. If the DEIR/S determines the impacts to be significant (again, a
5

Sympathetic movement = Movement (offset) on secondary/subsidiary fractures or along geologic bedding near
parallel to, but away from, the main fault(s) rupture; this can be caused by earthquake-induced stresses/forces
affecting geologic materials within the interfault mass (e.g., between the Raymond and San Rafael faults).
6
Parallel geologic bedding = In this case geologic bedding parallel to nearby active faults.
7
Near-source = A surface or subsurface location that is near the earthquake fault (source) causing the subject
earthquake and where ground shaking is usually stronger than at more distance locations.
8
Performance standard = A specific criterion or statement (most often quantifiable) to judge the adequacy of a
design or of a study for its intended purpose or use; how you know when you have it right.

SR-710 DEIR/S Review-Geology/Seismic/Soils/Groundwater

July 8, 2015
Page 5 of 24

significance determination can only occur once thresholds of significance are established), it
must then identify feasible design and mitigation measures capable of reducing these impacts to
a level of less than significant. Substantial evidence in the record must support both the analysis
of impacts and the efficacy of mitigation. As explained below, the DEIR/S errs in each of these
steps.
a. Caltrans has no established tunnel site selection criteria or tunnel design criteria for
earthquake fault rupture; therefore, the DEIR/S does not adequately analyze the risk that active
fault tunnel crossings entail.
Fault offset is the combination of the vertical and horizontal ground movement experienced on
opposite sides of an earthquake fault during a large earthquake as viewed from a fixed point on
one side. Fault offsets can cause damage to structures, including tunnels that straddle the fault.
Any appropriate standard for assessing fault offset for a freeway tunnel must establish the
acceptable post-earthquake performance requirements of the freeway tunnel crossing an active
fault.9
Here, Caltrans and Metro did not use a fault offset performance standard related to tunnels when
evaluating the Projects impacts. In purporting to mitigate impacts to geology and soils, the
DEIR/S states The [Freeway tunnel] design will meet the performance criteria of the operating
agency. (page 3.10-23). However, the Preliminary Geotechnical Report (PGR) indicates that
Caltrans has no tunnel fault offset design standard (PGR Appendix E, page 15). Without such a
standard that can be used to evaluate the chosen tunnel design, Caltrans cannot defend its
methodology for applying its fault offset design values to the LRT and Freeway Tunnel
alternatives.
A tunnel fault offset performance standard is necessary to ensure that sufficiently conservative
analytical methods are used to ensure the following: minimal tunnel damage (no collapse); the
ability to reach quickly the faulted/damaged area to rescue tunnel occupants (occupants will be
sufficiently protected, minimal injury and loss of life); the public will have confidence to use the
tunnel system; capability of repairing the four- to eight-lanes of the freeway tunnel in a
reasonable timeframe. The standard should also enable Caltrans to justify a specific
methodology for determining the fault offset amount, e.g., a low displacement value based on
earthquake probabilities or a high value based on actual observations for other similar faults that
have moved in an earthquake. This information could be derived from a study of historic
earthquakes such as the 1971 San Fernando and 1999 Taiwan Chi-Chi earthquakes, or
determinations from paleoseismic investigations on the fault in question (the Raymond fault) or a
similar fault in the area (e.g., the Sierra Madre, Hollywood, or Santa Monica faults). Where a
tunnel crosses a zone of several active or potentially active faults, as the SR 710 tunnel would
here, each fault should be addressed individually and cumulatively. The effects of all faults
moving in the same earthquake should be considered over the length of the zone in question. A
proper fault offset performance standard would also include or take into account the following
components: 1) descriptions of optional freeway tunnel designs that were evaluated considering
9

Tunnel fault offset = When an earthquake fault ruptures near a tunnel, the tunnel structure is shifted on each side of
the fault causing the tunnel walls to no longer be aligned or possibly to collapse.

SR-710 DEIR/S Review-Geology/Seismic/Soils/Groundwater

July 8, 2015
Page 6 of 24

the size and capacity of the specific tunnel alternative, 2) the considerable design requirement
differences between a two-lane tunnel and an eight-lane tunnel that could potentially carry truck
traffic, and 3) an explanation of the various design options that are generally available to
accommodate fault movements of various magnitudes and directions.
The more comprehensive type of analysis is possible for a complex freeway tunnel with
thousands of users at any given time. For the Century City area of its Westside Subway
Extension Project, for example, Metro (2011, page 5 of 13) issued a tunneling safety and fault
investigation report. The report describes the concerns with fault rupture design for a complex
underground station as follows:
In the case of rupture during an earthquake on an active fault, large concentrated fault
offsets are imposed on structures located directly on the fault. Metro underground stations
are sited so that they are not on active faults.
And,
Even with a complex and sophisticated design, unacceptable risks would remain in the
ability to limit damage and protect the public if faulting were to intersect a station.
Applying this fault avoidance strategy to a complex of eight-lane underground freeway system
with thousands of occupants is as reasonable as applying it to a complex underground station
with hundreds of occupants.
In lieu of developing and vetting a design-offset standard for tunnels, Caltrans and Metro used a
standard evidently developed for bridges. When explaining the design criteria used for
earthquake fault rupture, the DEIR/S indicates that Caltrans preferred strategy is the April
2013 Caltrans Seismic Design Criteria (SDC) (DEIR/S, page 3-10.1 and SDC, page 6-2). The
SDC does not mention tunnels; it refers readers to a 20-10 Fault Rupture Memo to Designers
authored by Caltrans and updated in 2013 (SDC, page 6-2). The 20-10 Memo also does not
mention tunnels. All of its fault rupture references are to structures, which are presumably
bridges since the memo was prepared by the State Bridge Engineer.
The DEIR/S cannot rely on the SDC to conclude that impacts related to fault rupture would be
less than significant. The project under consideration is not a bridge. Rather than simply
promising to comply with a vague regulatory standard intended for use with a different type of
structure, the DEIR/S must clearly identify and explain, for each tunnel fault crossing, how the
individual fault offsets were determined. If Caltrans believes that the SDC is the optimal
strategy, it must demonstrate that it is adequate to support the construction of a single and/or
dual-bore tunnel. This explanation must include examples of the suitable technical analytical
methods available to determine the magnitude of the fault offsets that would be acceptable for
the specific tunnel design. It must also demonstrate how the respective designs will best prevent
serious impacts to tunnel users by integrating discussions of cross-passages and other safety
measures for long and deep transportation tunnels. This is necessary to assure the public that the

SR-710 DEIR/S Review-Geology/Seismic/Soils/Groundwater

July 8, 2015
Page 7 of 24

users of the tunnels will have various means of coping with potential accidents caused by
earthquake and non-earthquake forces. It also must address the cumulative effect of the offsets
along the tunnel section bracketed by the Raymond and San Rafael faults, including the
VerdugoEagle Rock fault. Because the DEIR/S does not disclose these effects, and because
Caltrans has no tunnel fault offset standard (PGR Appendix E, page 15), the DEIR/S cannot
conclude that the project would have no significant impacts caused by active faulting.
b. The DEIR/S does not accurately characterize potential active fault rupture offset for the
Raymond, Eagle Rock, and San Rafael faults at the proposed tunnel crossings thereby
underestimating the Projects risks to public safety.
The DEIR/S does not accurately estimate the likely magnitudes of earthquake-related fault
movements associated with the Raymond, Eagle Rock, and San Rafael faults where they cross
the freeway tunnel or LRT alternatives (DEIR/S, p. 3.10-19; PGR, pages 4-12 and 4-13; and
PGR Appendix E, pages 2 and 11). It also presents conflicting explanations of the earthquakerelated fault movements likely to occur.
There are two principal methodologies for estimating the magnitude of fault ruptures. The
DEIR/S selects and applies the older of the two methodologies, which favorably influences the
outcome of its analysis. The most up-to-date and applicable methodology is contained in a study
published in 2008 by Wesnousky. However, the DEIR/S rejects this methodology in favor of an
older methodology published in 1994 by Wells and Coppersmith. The DEIR/S contains no
satisfactory explanation for this decision, except to state that that Currently, there is no
agreement on the validity of one relationship over the others, as all are considered statistically
valid (PGR Appendix E (page 11).
On the contrary, the Wesnousky study is the most recent methodology. The methodology was
presented in 2008, and included a compilation of data obtained from 37 earthquakes, including
sixteen post-1980 earthquakes. Overall, it considered a greater number of earthquakes than the
Wells and Coppersmith methodology. As it turns out, choosing the older methodology generates
lower values for fault rupture offset predictions to be used in tunnel design. For example,
Caltrans and Metro use the average Wells and Coppersmith offset of 0.5 meters over the
maximum Wesnousky offset (2.2 meters). The 2.2 meter offset prediction would result in a
much safer design for users of the freeway tunnel. Since Caltrans has no tunnel fault offset
design standard (PGR Appendix E, page 15), it has no basis to select the average Wells and
Coppersmith (0.5 meter) offset versus the maximum Wesnousky offset (2.2 meters). Whats
more, the 2.2-meter offset prediction is nearly the same as the offset observed in the 1971 San
Fernando earthquake, which was on a very similar fault, and thus appears to be more accurate.
In apparent justification for not selecting and using the Wesnousky method, the PGR states that
the Wesnousky method would result in larger average and maximum displacements than those
estimated using the Wells and Coppersmith (1994) models (PGR Appendix E, page 11). Larger
fault offsets create more damage and risk. While this may be disadvantageous for Caltrans and
Metro because it may require more rigorous design engineering (and therefore may be more

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costly), it is not a sound basis for rejecting the newest available methodology for predicting fault
ruptures.
The U.S. Geological Survey (USGS) has expressed a preference for the Wesnousky
methodology. For instance, the Uniform California Earthquake Rupture Forecast, Version 3
(UCERF3; USGS, 2013) Appendix F highlights the 2008 Wesnousky analyses with respect to
development of improved estimates of average fault displacement as a function of fault/fault
rupture length. This document mentions Wells and Coppersmith in various contexts, mainly to
show how this older method compares with the latest concepts (Figures F5 through F8). Figure
F8 (UCERF3, Appendix F page 13) shows that for normal and reverse faults (the Raymond is a
reverse fault) the average fault offset per event using Wesnousky consistently is greater than
would be predicted by the segment length approach, which is the Wells and Coppersmith
approach.
Absent a technical and scientific reasoning for why the Wells and Coppersmith is superior
which Caltrans has not providedits decision to reject the Wesnousky methodology is
indefensible. Because it relied on an inappropriate methodology, the DEIR/S provides
insufficient evidence to conclude that the tunnel would be constructed in a manner that protects
the publics safety. There is no basis not to select either the Wesnousky B (Power-law) or C
(Log-linear)10 relationship options.
The DEIR/Ss conclusion regarding the problem of displacement magnitude and risk relies on
insufficient study; yet critical design decisions affecting the suitability of the selected route are
also based on it. PGR Appendix G (page 19) admits published data and opinions on the
Raymond fault vary by almost a full order of magnitude for the following: (a) slip rates (from 0.5
to 5 millimeters per year), (b) recurrence intervals (from 1,000 to more than 6,000 years), and (c)
earthquake fault rupture displacement estimates (from 0.5 to more than 5 meters). In its analysis,
Caltrans consistently accepts the published data that minimizes the amount of fault offset they
will consider in their design.
The DEIR/S further understates the public safety risk from the tunnel alternatives because it does
not consider cascading fault rupture scenarios (PGR Appendix E, pages 68). Cascading
scenarios occur when an earthquake causes other earthquakes on faults in related fault systems.
These triggered earthquake events could also cause fault rupture and fault offset on these related
faults.11 A cascading fault rupture would cause larger fault rupture displacements than are
currently suggested for the freeway tunnel design. The most likely of these would occur at the
HollywoodRaymond faults raising the potential earthquake magnitude from a M6.5 to a M6.9.
However, Appendix E dismisses the cascading scenario entirely by indicating, At this time, it
does not seem realistic to design for this scenario event. There is no discussion of a
performance standard for the tunnels, or of what design standard would need to be created to
10

Power-law and log-linear relationships = Mathematical relationships that are not purely linear (e.g., length
compared to length), but involve the use of probability and higher mathematical functions such as logarithms.
11
Triggered earthquake event = An example in southern California would be an earthquake on the Hollywood fault
that triggers earthquakes and fault offsets on the Santa Monica, Raymond, Eagle Rock, and San Rafael faults.

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accommodate this potentially much larger offset, or whether the selected segmental design
would be adequate. Caltrans and Metro cannot determine the likelihood of this event without
performing further study. The DEIR/S may not simply decline to consider cascading scenarios
on this basis.
The Project is similar in some respects to the California High Speed Rail project, a large-scale
transportation infrastructure project for which the tunnel portions cross numerous active faults,
including the Garlock, Ortigalita, Greenville, and Calaveras faults. See the California HighSpeed Rail Project EIR/EIS (Parsons Brinckerhoff Inc. [PBI], 2004. The High-Speed Rail
project is similar to the SR 710 Project because it calls for tunnels carrying passenger railcars
and must be designed to minimize tunnel damage, injury, and death. The California High Speed
Rail project design option for crossing each of these faults is an oversized mined vault12, a design
that Caltrans rejected in the PGR, and consequently in the DEIR/S. PBI states that the California
High Speed Rail design would be for faults with offsets in the 1- to 3-foot range. This range is
similar to the minimum values for the 710 Project where the tunnels would cross the Raymond
fault.
The DEIR/S must develop and use tunnel-specific fault offset standards to justify its
methodology used to determine the design tunnel fault offset13 for this project. This
methodology must be justifiable and based on the best science available. Caltrans may not select
one methodology (e.g., Wells and Coppersmith) over superior methodologiesespecially if the
decision prompts Caltrans to use a less conservative design tunnel fault offsetwithout
substantial justification. It is not sufficient simply to state (PGR Appendix E, page 16) the
Wells and Coppersmith (1994) model is the most widely used model in practice and is
considered appropriate for these preliminary estimates. Without knowing the performance
standard and acceptable consequences of fault rupture, it is impossible to evaluate the selected
design. The larger potential fault offset cannot be adequately addressed with specific design
features as currently proposed (DEIR/S page 4-59). The performance standard and acceptable
consequences of fault rupture are discussed further below.
c. The DEIR/S does not adequately evaluate the bored tunnel design for near-source ground
shaking effects from an earthquake on the Raymond fault, or one involving the Raymond,
Eagle Rock, and San Rafael faults together, thereby potentially underestimating ground
shaking values.
The DEIR/S fails to evaluate the potential impact of the near-source ground shaking hazard on
the tunnel from an earthquake on the Raymond fault or the Raymond, Eagle Rock, and San
Rafael faults together. The intensity of ground shaking generally depends on the distance from
any location to the earthquake epicenter (closer has stronger, more severe shaking) and to the
12

Vault = An extra large mined opening around a conventionally excavated tunnel that is used in theory to absorb
fault offset; for larger predicted offsets it is often filled with crushable materials to absorb more movement.
13
Design tunnel fault offset = This is the magnitude of fault offset (horizontal and vertical) chosen by Caltrans as
the basis for designing the tunnel structure after considering the predicted offset characteristics of the fault or faults
crossing the tunnel at any given location.

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causative earthquake fault (near-source shaking is more severe). As with fault rupture, Caltrans
has produced no seismic design criteria for tunnels (PGR Appendix F, page 8) that account for
ground shaking. Because this hazard is not addressed, there is no evidence that the
recommended design measures, which are intended to accommodate vertical and lateral offset
movements, would be sufficient to protect the tunnel. Very strong near-source ground shaking,
in addition to fault rupture, could potentially severely affect a 50-foot wide zone (the typical
setback zone from a fault trace) or more. Effects could include ground/grout cracking, and local
permanent ground deformation, thereby resulting in further tunnel damage. Caltrans failure to
identify design criteria that would account for the potential hazards associated with near-source
ground shaking undermines the effectiveness of any proposed design measures14.
A tunnel design will affect not only its response to the magnitude of the fault rupture
displacement hazard, but also its response to the intensity of near-source ground shaking at the
location where the tunnel crosses the earthquake fault. Tunnels are underground structures that
are typically confined by the surrounding soil or rock. As such, studies and observations from
recent earthquakes1995 Kobe, Japan; 1999 Chi-Chi, Taiwan; and 2004 Niigata, Japan
indicate that tunnels located within close proximity to a causative fault during a seismic event
suffered severe damage (Corigliano et al. 2011). For example, a survey of tunnel damage due to
the Chi-Chi, Taiwan earthquake indicates that 49 of 57 tunnels surveyed experienced moderate
to severe damage (Wang et al. 2001; Xiaoqing-Lin et al., 2008). Based on a study by XiaoqingLin et al., a tunnel would be expected to suffer severe damage when ground acceleration from
the near earthquake is expected to exceed 0.5g (peak ground acceleration). The Tunnel
Evaluation Report (TER; Appendix H TM-6, pages 5, 29, and 30) also cites the 2008 Wenchuan
earthquake, which caused extensive damage due to a one-meter fault offset and to a tunnel
collapse. The proposed freeway tunnel and LRT alignments cross the Raymond fault (DEIR/S
Section 3.10.2.6, page 3.10-4). The Projects tunnel can be expected to suffer high ground
acceleration that could cause severe damage to the tunnel in the event of an earthquake.
d. The DEIR/S does not identify significance criteria relating to fault offset and ground
shaking, fails to determine the significance of the Projects impacts, and defers mitigation
until after Project approval.
Caltrans and Metro did not establish a fault offset performance measure to judge what offset is
an unacceptable level of displacement damage to the tunnel. Instead, the DEIR/S simply
recognizes that there is the potential for substantial adverse effects due to fault rupture
(DEIR/S page 4-59). This potential is the same for a large Raymond fault earthquake and the
underestimated effects of near-source ground shaking discussed in section 2.c of this report. The
DEIR/S never evaluates the potential for the tunnel to fail partially or completely.
Tunnel accidents, whether caused by fault rupture or not, can be disastrous. As noted above,
observations from the earthquakes in 1995 Kobe, Japan, in 1999 Chi-Chi, Taiwan, and in 2004
14

Design measures = These are the specific factors in the design of a structure (e.g., size of the foundations, amount
of reinforcing, and thickness of concrete) that allow the structure to perform adequately (defined by performance
standards) in an earthquake event.

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Niigata, Japan indicate that tunnels located within close proximity to a causative fault during a
seismic event suffered severe damage (Corigliano et al. 2011). The 0.7-mile long Caldecott
tunnel fire in 1982 illustrates the potential effects on tunnel users from a fire. This was caused
by a gas-tanker truck collision followed by fire and smoke that killed six people died and injured
two. Those involved were apparently unaware of the exit cross-passages and passageways.
Such a tunnel fire could accompany earthquake damage to the SR 710 Project tunnel. The
Gotthard, Switzerland, tunnel fire killed 11 people and injured many more. The Gotthard tunnel
has only two traffic lanes, not the four to eight lanes contemplated here. The SR 710 Project
could expose two to four times the more people to collapse and fire dangers in case of an
accident caused by a seismic event.
Dr. Kenneth Hudnut, a U.S. Geological Survey (USGS Pasadena) Geophysicist, discussed
earthquake issues in relation to the SR 710 tunnels in a presentation in September 2012. He
stated, Tunnels have collapsed, and suffered damage in many earthquakes, so seismic
countermeasure designs is essential for these new tunnels (Hudnut 2012). Dr. Hudnut reviewed
various cases of tunnel damage or even collapse, and pointed out that damage and collapse of
tunnels has occurred even in newly built and very strong tunnels in advanced nations. . . .
(Hudnut 2012). He recommended not building tunnels on or along fault lines, or at least building
on the less active sections of fault lines, and noted that most of the proposed tunnels cross fault
lines at more than one place. Dr. Hudnuts findings regarding the potential for severe damage
from faults due to significant earthquakes are consistent with observations from recent
earthquakes in advanced nations (Corigliano et. al., 2011). For the SR 710 Project, an obvious
solution is to avoid constructing a tunnel across active faults.
The DEIR/Ss lack of significance threshold criteria means that it does not adequately disclose to
the public that significant, non-routine seismic events are possible and could result in significant
property damage, severe injury, or even death. With regard to fault rupture and earthquake
ground shaking, the DEIR/S (PGR Appendix E, pages 11 and 15) concludes, with insufficient
evidentiary support, that cascading earthquake events15 have a low probability of occurrence
and cannot be demonstrated geologically for known active faults connected to the active
Raymond fault. The consequences of such events are much larger magnitude earthquake and
surface fault offset similar to large magnitude events such as occurred in 1995 Kobe, Japan, in
1999 Chi-Chi, Taiwan, and in 2004 Niigata, Japan. For a project such as this, it must be
demonstrated that such events would not adversely impact the public. In essence, the DEIR/S
ignores the potentially catastrophic consequences of these events by focusing on the alleged
improbability of them occurring. As discussed below in the context of impacts to the areas
groundwater basins, large earthquakes are quite common in southern California. The DEIR/S
has no basis to conclude that these larger events are so improbable that they can be dismissed out
of hand.

15

Cascading earthquake events = With cascading events, several faults could rupture together with slip/offset
transferring from one fault to the other; a cascading event would result in a larger magnitude event and much larger
displacements on each of the faults than an event on a single shorter fault.

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The DEIR/S also defers mitigating seismic impacts until after project approval. The DEIR/S
(page 3.10-22) proposes to mitigate the Projects geotechnical/seismic impacts by conducting
future studies and analysis, and preparing geology and geotechnical reports designed to provide
design recommendations for seismic hazards such as fault-induced ground rupture, ground
shaking, co-seismic deformation16, slope instability, seismic settlement, liquefaction, or related
secondary seismic impacts that may be present along the alignment of the selected Build
Alternative project. This is precisely the type of analysis that should have been conducted prior
to the selection of a proposed tunnel alignment. Nor can the DEIR/S rely on a promise to
conduct detailed geotechnical investigation to conclude that impacts associated with these
seismic hazards are less than significant without specifying quantifiable performance measures.
As discussed in 2.a, 2.b, and 2.c above, proposing a freeway tunnel or LRT design for a 0.5meter fault offset and then performing studies that show the design must accommodate 2.2- to 5meters would necessitate design changes after Project approval that would not have been
reviewed in the DEIR/S.
Design changes like the above could have other very significant impacts. For example, changing
the tunnel design from a small vault to a large vault filled with compressible materials (the
original design) would have a dramatically greater effect on groundwater flow along the outside
of the tunnel north of and across the Raymond fault and potentially cause a substantial impact on
the City of Pasadena Subarea groundwater storage. These design changes would substantially
increase by many feet the opening size between the tunnel structure and the surrounding
bedrock, and this space would be filled with a purposefully high permeability crushable material.
Groundwater would much more readily flow through this larger opening and through the highly
permeable material filling it. Given that Caltrans and Metro are considering only one freeway
tunnel alignment, there is no justifiable reason to delay the important studies that would allow a
proper mitigation to be determined now.
Because the DEIR/S calls for deferring the preparation of these plans, and because it fails to
provide details on how these plans will mitigate for the Projects seismic impacts, let alone
provide enforceable measures and performance criteria, there is no assurance that these
significant impacts will be mitigated at all. In order to satisfy CEQAs requirement that an
agency propose feasible, enforceable mitigation that it shows will actually mitigate the projects
impacts, Caltrans must conduct these studies before the DEIR/S can be approved.
e. The DEIR/S fails to analyze adequately potential impacts from ground settlement and fails
to mitigate for these effects.
The DEIR/S states that the proposed excavation would result in the potential for ground
settlement and differential settlement17 immediately above and adjacent to the bored tunnel
16

Co-seismic deformation = A large earthquake does not always rupture the ground surface above buried fault
planes. However, deformation of the ground (e.g., uplift, subsidence, tilting) may occur at certain distances away
from (e.g., to the north of) a lateral-reverse fault such as the Raymond fault.
17
Differential settlement = When the ground surface settles unevenly due to activity beneath the surface such as an
excavation (e.g., a tunnel) or groundwater withdrawal for porous alluvial sediments.

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portion, and the portal and station excavations of the LRT Alternative (pages 3.10-10 and 3.1012). It further states that Open excavation and tunneling in unconsolidated and/or saturated
alluvium have the potential for groundwater inflows and flowing ground conditions at the
heading of the excavation, which could potentially result in settlement of the ground surface if
not properly controlled (page 3.10-12). Despite these acknowledgements, the DEIR/S does not
adequately evaluate the extensive impacts that could result from ground settlement.
According to other studies, such as Dubnewych et al. (2011), Settlement could damage surface
facilities such as existing buildings, streets, utilities, and other improvements, and further that
Uncontrolled and/or excessive groundwater inflow during tunnel construction could result in
loss of ground, which could lead to surface settlements. Groundwater inflow into excavation
areas may require dewatering, which in turn could potentially cause more settlement. Many of
the areas above the SR 710 tunnel alignment are occupied with improvements such as
residences, roads, and businesses. These improvements could be damaged in the event of ground
settlement. With respect to 2009 Shanghai Yangtze River Tunnel the TER (Table 1) indicates
that the Highest recorded settlement occurred near portals with shallow ground cover.
In order to evaluate properly the potential hazards associated with the settlement of overburden
soils and the consequent impact on existing improvements, Caltrans should have: (a) estimated
the anticipated total and differential settlements; (b) identified the tolerance limits of the existing
improvements to such settlements; and (c) studied alluvial deposits and groundwater
characterization in the area. The DEIR/S includes none of this. These studies are necessary at
the outset, to determine whether the proposed excavation and tunneling techniques require
adjustment or augmentation through mitigation. In particular, the studies would evaluate the
specific groundwater conditions within the alluvial deposit portions of the tunnel alignments,
including the densities, porosities, and transmissivities of the materials. Only with such
information, can Caltrans and Metro evaluate the Projects impacts, and identify necessary
design changes and mitigation.
In lieu of these studies, the DEIR/S speculates that use of certain construction techniques may
limit ground settlement: tunneling equipment and procedures as well as portal and station
support methods are capable of controlling ground movements to limit surface settlements and in
turn minimize damage to existing structures (page 3.10-11). The DEIR/S also suggests other
measures, such as chemical or cement grouting, but it does not explain the effectiveness of these
measures. The DEIR/Ss failure to evaluate adequately effective construction techniques makes
it impossible to determine whether sufficient measures will be employed to prevent damage from
ground settlement. Caltrans cannot defer these important studies.
f. Caltrans improperly rejected a safer tunnel design in favor of a less expensive, more quickly
built design, but one with more potential for severe stress to the tunnel.
Generally, large backfilled vaults should perform better than small steel-lined vaults in
earthquakes producing fault offset and high near-source ground motions. As originally proposed,
the freeway tunnel design called for a large vault backfilled with crushable materials in the
sections of the tunnel crossed by active faults (see PGR Section 11.8.1.3, pages 11-9 and 11-10).

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Ultimately, however, Caltrans settled on a smaller, less expensive, and more quickly built design
that employs vault sections utilizing steel segmental lining. This change in tunnel design was
made due to constructability issues as well as risk, cost, and schedule implications (PGR page
11-10). The DEIR/S (pages 2-58, 2-85, and 3-10.21, and the TER (Appendix H TM-6) do not
demonstrate that the newer tunnel vault design will mitigate potential Raymond fault movements
in the range of 5-feet (Appendix H TM-6, page 5). Caltrans made this design change without a
specific analysis of how either design would perform in response to an earthquake and in
reliance on future design studies. On page 2-4, the TER states Sitespecific geotechnical
investigations have yet to be completed at each of the various fault zones; future design studies
will require sitespecific data to be obtained in order to refine the design concepts discussed
herein.
The change in design includes a thicker concrete tunnel lining that could potentially increase the
damage to the tunnel due to an earthquake (Xiaoqing et. al. 2008), not mitigate it. Recent
evaluations of tunnel performance during earthquakes indicate that tunnel sections with thick
lining have a higher damage percentage (Xiaoqing et al. 2008). While thicker lining may be
needed to mitigate potential damage to the tunnel lining from non-earthquake ground pressures,
thicker lining in turn is more susceptible to damage from severe ground shaking (Xiaoqing et al.
2008). Where, as here, steel plate lining is proposed to be used, the agency must undertake
seismic loading18 analyses (in addition to static loading analyses) in order to ensure it is
sufficient to mitigate the fault-offset hazard. Caltrans and Metro did not perform this analysis of
the seismic loading resulting from earthquake ground shaking. This difference in the thickness
of the vault lining becomes critical if further study determines that the assumed fault offset
parameters assumed are far too low and cannot be accommodated by the steel segmental lining
approach. Not accounting for the higher potential offsets could lead to the consequences
described in previous subsections 2.a though 2.e.
The TER (Appendix H TM-6, page 5) states:
When tunnels are subjected to larger offsets (greater than about 5 feet) and the linings are
not designed for offset, major cracking of the lining and collapse of the lining is possible,
if not probable, as illustrated in Figure 5. In addition, significant lengths of lining on either
side of the fault offset zone would probably be heavily cracked and damaged and may
require replacement.
As explained immediately above, with this greater than or less than 5 feet of fault offset serving
as an apparent critical fault offset design threshold, it is even more important that Caltrans
employ the appropriate fault offset determination methodology, i.e., Wesnousky rather than
Wells and Coppersmith. As explained above, the Wesnousky 2.2-meter (over 5-feet) offset
prediction is approximately the same as the offset already observed in the 1971 San Fernando
earthquake along an oblique slip fault (the north side moves up and to the left) very similar to the
Raymond fault.
18

Seismic loading = The force on a structure caused by ground acceleration induced on the structure mass by an
earthquake.

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The DEIR/S must document how the proposed design option will protect tunnel users. This
documentation must include examples of the expected design performance under various fault
offset and near-source ground motion scenarios. In particular, it must consider sympathetic
movement19 on non-active faults and parallel geologic bedding between the Raymond and San
Rafael faults. Rigorous analyses, using finite element/finite difference methods20, are needed to
evaluate the performance of the tunnel under static and seismic loading conditions. Cost, risk,
and construction time trade-offs must be detailed to justify the final design selected by Caltrans
that will prevent serious impacts to tunnel users, and assure the public that the cost and time
considerations are properly balanced with safety.
3. WATER QUALITY AND STORM WATER RUNOFF (SECTION 3.9 RAYMOND
BASIN GROUNDWATER PORTION)
Using the established hydrology and water quality thresholds from CEQA (Appendix G of
CEQA Statute and Guidelines), the project will be considered to have a significant impact if it:
a. Substantially depletes groundwater supplies or interferes substantially with groundwater
recharge such that there would be a net deficit in aquifer volumes or a lowering of the local
groundwater table level (e.g., the production rate of pre-existing nearby wells would drop
to a level which would not support existing land uses or planned uses for which permits
have been granted)?
b. Otherwise substantially degrade water quality?
In order to evaluate the Projects potential impacts relating to groundwater, the DEIR/S must
undertake a series of steps. First, it must identify and describe existing groundwater conditions.
Second, since the Project would be constructed in a seismically active zone, it must provide a
detailed description of the Projects fault rupture and near-source ground shaking impacts on the
geologic formations and on the construction elements of the tunnel. This would allow the
DEIR/S to examine how the construction of a tunnel would impact groundwater resources taking
into account, the tunnels construction in a seismically active setting. Third, if the DEIR/S
determines that the Project would result in potential impacts, the DEIR/S must evaluate the
severity and extent of these impacts. Fourth, the DEIR/S must then identify feasible measures
capable of reducing these impacts. The analysis of impacts and the efficacy of mitigation must
be supported by substantial evidence.

19

Sympathetic movement = Offsets along faults, fractures, or bedrock bedding planes due to strain release along the
main fault or vibratory ground motion that disturbs the state of stress on these other faults (they may be active or
non-active), fractures, and bedding planes causing them to undergo displacement.
20
Finite element/finite difference methods = Computer software (programs) based on complex numerical methods
and mathematical models used for analyzing complex engineering problems utilizing the geometry and properties of
the subject materials to simulate the response of project to loads and seismic ground shaking. Such programs can
simulate the propagation of movement along secondary faults, fractures, or bedding planes due to a movement along
a main fault during an earthquake. This requires a thorough understanding of the physical properties of the
secondary faults, fractures, or bedding planes.

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a. The DEIR/S does not describe the Raymond Basin and Pasadena Subarea groundwater
characteristics in sufficient detail to allow an evaluation of groundwater flow in the tunnel
area. It also does not include sufficient geotechnical detail including information relating to
bedrock fracture patterns.
The San Gabriel Valley includes two groundwater basins: the Raymond Basin and the San
Gabriel Basin (DEIR, p. 3.9-9). The Raymond Fault separates the Raymond and the Main San
Gabriel Groundwater Basins. The Pasadena Subarea is the major portion of the overall basin and
abuts the Raymond Fault where the bored tunnels would be located (RBMB Annual Report
2014, Figure 6). The Fault acts as a natural subsurface dam21 holding back the groundwater in
the Raymond Basin on the north from water in the Main San Gabriel Basin on the south (DEIR/S
p. 3.10-3).
Studies indicate that groundwater from the northwestern and western portions of the basin flow
toward the proposed bored tunnel locations (NASA/JPL 2007). Water levels are 160 feet lower
in the Main San Gabriel Basin than immediately across the Raymond fault in the Raymond
Basin. This suggests that penetration of the Raymond Fault barrier could cause a pathway for
water flow (including possibly along the Eagle Rock and San Rafael faults) to be extended
across the barrier into the Main San Gabriel Basin.
The DEIR/S mentions the Raymond and the San Gabriel Basins, but it does not provide
sufficient context to allow an evaluation of the Projects impact on the groundwater system. The
DEIR/S does not, for example, identify or include groundwater depth contour maps, groundwater
flow maps, basin thickness descriptions or contour maps, basin groundwater volumes, or the
locations of pumping wells. The DEIR/S also does not describe the groundwater interactions
between the Raymond and Main San Gabriel Basins or provide information relating to
groundwater recharge and withdrawal. Nor does the document identify the basins existing
groundwater quality or explain how it could be affected by specific sources of contamination
(e.g., Jet Propulsion Laboratory (JPL)). In addition, the DEIR/S does not provide sufficient
hydrogeologic and geotechnical information to allow for an evaluation of groundwater flow
constraints associated with constructing a tunnel in a seismically active zone. For example, the
DEIR/S does not quantify flow characteristics of the alluvial geologic units and fracture patterns
in the surrounding bedrock. Without these fundamental details relating to groundwater
characterization and geotechnical setting, the DEIR/S consultants are unable to evaluate how
specifically the bored tunnels may affect the groundwater system.
Some of this information is readily available, while other information would require additional
investigation. For example, existing groundwater data from the Raymond Basin Management
21

Natural subsurface dam = Subsurface groundwater basins are separated from one another by natural barriers such
as dense bedrock (e.g., intervening hills or mountains) and active faults, such as the Raymond fault. Active fault
movement can grind bedrock and alluvial deposits into clay-sized particles that form fault gouge parallel to the
fault that may be several feet thick. If natural barrier is not disturbed this gouge can hold back groundwater that
would otherwise tend to flow down gradient (south in this case) in the subsurface trying to seek a stable, continuous
horizontal surface.

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Board are readily available. Groundwater elevations for the proposed bored tunnel penetration
areas could be extrapolated using Department of Water Resources (DWR) well data (GeoTracker
2015) and project borings. To evaluate the risk to groundwater from an earthquake, however,
Caltrans/Metro must conduct a detailed geologic investigation of geologic units and fracture
patterns in bedrock. It must evaluate the groundwater pathways that could be created by
sympathetic movement on non-active faults and parallel geologic bedding between the Raymond
and San Rafael Faults. Borings and monitoring wells should be installed in areas east of the
Arroyo Seco, north of the Raymond Fault, and west of Arroyo Parkway to identify groundwater
elevations and groundwater flow properties in alluvium and fractured bedrock. Finally, pumping
tests would be necessary to estimate groundwater storage in the bedrock and flow rates from the
fracture zones.
The DEIR/S should have included these background investigations in order to document the
specific groundwater conditions of the Pasadena Subarea. Only from the results of these specific
studies can potentially significant impacts to the Raymond and Main San Gabriel Basins be
determined.
b. The DEIR/S lacks analysis to determine the potential impacts on the Raymond Basin and
Pasadena Subarea groundwater supplies that could result from a penetration of the Raymond
Fault groundwater barrier.
Because the Raymond Fault acts as a natural subsurface dam holding back water in the Raymond
Basin on the north from water in the Main San Gabriel Basin on the south, perforating this
groundwater barrier, either as a result of the tunnels construction or because of an earthquake,
could create significant pathways for Raymond Basin groundwater to flow into the Main San
Gabriel Basin. Any failure would potentially deplete groundwater supplies in the Raymond
BasinPasadena Subarea. Water levels within the Raymond Basin are already dropping because
of the drought. With Governor Browns April 2015 mandate to reduce water consumption by 25
percent, pressure on the Raymond Basin Management Board to conserve groundwater will
increase.
The DEIR/S dismisses the potential threat to groundwater resources that could result from
perforating this subsurface groundwater barrier either because of tunnel boring or in the event of
an earthquake. Initially, the DEIR/S should have identified the estimated groundwater inflow
and expected flow rates, and identified the expected treatment volumes from groundwater
discharged at the surface. Neither the DEIR nor the Water Quality Assessment Report (WQAR)
provides any information in this regard. While it may be a difficult to accurately estimate
groundwater inflow into tunnels, this is no excuse for foregoing this critical analysis altogether.
As Katibeh and Aalianvari (2012, page 75) explain, failure to account accurately for
groundwater inflows during tunnel construction can have catastrophic consequences:
During construction, groundwater flows freely into these tunnels through fractures in the rock.
Where the rock is tight and the potentiometric head above the tunnel is low, the inflow will be
small. Where the rock contains large, open fractures or where the head is high, the inflow will be

SR-710 DEIR/S Review-Geology/Seismic/Soils/Groundwater

July 8, 2015
Page 18 of 24

substantial. Where the rock contains large fractures and a high groundwater head, the inflows can
be catastrophic. Katibeh and Aalianvari (2012, page 76) go on to explain that there are several
analytical methods to calculate groundwater discharges into tunnels. Caltrans should have
conducted this investigation and included the results in the DEIR/S. Instead, the DEIR/S appears
to ignore the potential for groundwater inflow altogether. Instead, it merely states, special care
would have to be exercised when tunneling through a fault zone. While the Tunnel Evaluation
Report describes the proposed tunneling process, none of this is brought forward to the DEIR/S
for evaluation. The DEIR/S never describes the tunneling process other than to state that a
pressurized-face tunnel boring machine22 (TBM) would be used and that grout and a concrete
lining with rubberized gaskets would be used to control water inflows (DEIR/S page 3.10-21; 324.7).
The DEIR/S (page 4-66) looks to the use of grouting to suggest that the potential for the Project
(LRT and Tunnel Alternatives) to deplete groundwater supplies or interfere with groundwater
recharge23 is low. The DEIR/S provides no documentation about the effectiveness of grouting
to control groundwater. Other studies on tunneling, however, including those undertaken by
Jacobs Engineering (Bedell et al. 2013), evaluate grouting as a solution for leaking tunnels and
conclude that tunnels leak. Grouting certainly helps but does not eliminate leaks through or
around a tunnel lining. Bedell et al. state (page 460) that:
While it is tempting to say no leakage allowed, the goal of no leakage can be quite
expensive and is probably unattainable. As long as there is a substantial head difference
between the inside of the tunnel and the outside, groundwater will tend to find its way
through even impermeable membranes. The leakage will occur at the joints, seams and
other imperfections. These imperfections are inevitable over the length of a long tunnel.
Jacobs Engineering supports these statements with data from three Atlanta area tunnel projects,
Nancy Creek (16-foot diameter), South Cobb (27-foot diameter), and South River (14-foot
diameter) (Table 1 in Bedell et al. 2013). The 27-foot diameter, 5.5-mile-long South Cobb hard
rock tunnel in Georgia has the most recent data and projections, but all three tunnels have similar
results. The South Cobb tunnel had a target groundwater inflow criterion24 of 252 gallons/minute
(gpm) and after the most advanced modified contact grouting (MCG) was performed, flow rates
were projected to be reduced to 152 gpm, a 40 percent reduction from the criterion. This is a
positive outcome considering the reduction in wastewater treatment costs. However, despite the
annual reduction in water volume loss, a 152-gpm loss remained, indicating that 80 million
gallons (MG; 245 acre-feet) per year were still leaking despite the grout.
22

Tunnel boring machine = A machine used to excavate tunnels with a circular cross-section through soil and
bedrock. This may be in lieu of drilling and blasting or other mining techniques.
23
Groundwater recharge = Precipitation and surface water that enters a groundwater basin to restore the volumes of
water lost through normal uses, pumping, or leakage.
24
Target groundwater inflow criterion = For tunneling, this is the expected amount of water that would enter a
tunnel excavation during tunneling and during operation of the tunnel project. This prediction requires knowledge
of the groundwater system gained through collection of geologic, geotechnical and hydrologic studies, the analysis
of data, and the numerical modeling to define flow paths and flow velocities.

SR-710 DEIR/S Review-Geology/Seismic/Soils/Groundwater

July 8, 2015
Page 19 of 24

The Pasadena Subarea groundwater storage on June 30, 2014 (RBMB Annual Report 2014,
Table 4B) was 24,811.4 acre-feet, of which the City of Pasadena portion was 10,996.1 acre-feet.
Because the DEIR/S makes no projections of target groundwater inflow or expected flow rates
upon completion of the Project, we assumed for purposes of this report that the SR 710 tunnel
could result in the same relative amount of leakage as that from the South Cobb tunnel. While
the comparative lengths and diameters of the SR 710 tunnel sections involved must be
considered in any detailed analysis, a leakage amount of 245 acre-feet (from the single smaller
diameter tunnel, not the larger diameter or twin-bore tunnel under consideration) would represent
approximately a 237 acre-feet of the Pasadena Subarea storage lost in one year. Considering the
proposed Projects tunnels are about 2.2 times larger in circumference/surface area than the
South Cobb tunnel and about 44-percent the length, the Project could generate 475.8 acre-feet
per year leakage (4.33 percent of annual storage) from the City of Pasadena Subarea to the Main
San Gabriel Basin along the dual-bore tunnel. Taking the average groundwater leakage rate for
the Nancy Creek, South River, and South Cobb tunnels combined, and applying that rate to the
proposed Project, the Project could result in a 5.23 percent reduction in Pasadena Subarea
storage each year. Construction of the Project could thus result in a substantial loss of the City
of Pasadenas groundwater. If the grouting safeguard fails, and the DEIR/S provides no
assurance of their effectiveness, dewatering25 of the Pasadena Subarea would occur and
effectively cause a substantial loss of the Citys water. The DEIR/S does not identify this
potential impact on groundwater resources as significant.
Of critical concern though is the fact that the proposed tunnel would be constructed across
multiple active faults. The South Cobb tunnel analysis discussed above is for a steady state,
seismically inactive environment in Georgia, not for an earthquake-prone region of California.
The DEIR/S fails to analyze the potentially disastrous consequences from a moderate or large
earthquake on any of the area faults. The DEIR/S must analyze the consequences from various
scenarios such as a moderate or large earthquake, including sympathetic movement on nonactive faults, fractures, and parallel geologic bedding between the Raymond and San Rafael
faults. What would the condition of this grout seal be after years of degradation,
leaching/dissolution, and ambient vibration or earthquake shaking?
In addition to grouting, the DEIR/S calls for monitoring groundwater levels at selected locations
to prevent groundwater flow. Mitigation measures WQ-2 and WQ-3 (page 3.9-20, 21) mention
construction site dewatering and groundwater levels. Measure WQ-2 refers to compliance with
an NPDES General Permit for Storm Water Discharges, but these permits address the quality of
discharged water not mitigation for the loss of groundwater. WQ-3 mentions monitoring of
groundwater levels, but not in the context of groundwater depletion. Simple monitoring of
groundwater levels at selected locations is not mitigation to prevent the groundwater flow.
Therefore, there is no basis for the DEIR/S to conclude that the project would not detrimentally
impact the groundwater levels in the Pasadena Subarea
The DEIR/S must disclose the severity and extent of the impact, e.g., how much water could the
City of Pasadena potentially lose and the implications associated with this loss. In addition, the
25

Dewatering = Pumping of groundwater from an excavation in order to facilitate underground construction.

SR-710 DEIR/S Review-Geology/Seismic/Soils/Groundwater

July 8, 2015
Page 20 of 24

DEIR/S must discuss whether this drawdown26 of the Citys water would require Caltrans and/or
Metro to obtain permits from the City of Pasadena.
c. The DEIR/S lacks analysis to determine the potential degradation of Main San Gabriel
Basin groundwater quality from penetrating the Raymond fault groundwater barrier.
The DEIR/S (Section 4.2.9) does not analyze the impacts of the potential groundwater pathways
to transport contaminants in the Raymond Basin (Pasadena Subarea) groundwater into the Main
San Gabriel Basineither along the Raymond fault, along the tunnel contact with alluvium or
bedrock, or through the tunnel. Potential contamination of Raymond Basin groundwater could
come from sources such as JPL or from other incidents (e.g., chemical or fuels spills). GSSI
(2009) documents actual and projected movements of contaminants from JPL (perchlorates27)
and groundwater flow pathways from north and northwest to south and southeast, all toward the
proposed bored tunnel location beginning at the SR-210/SR-134 interchange. Any current or
future contamination events along this pathway could end up at the proposed bored tunnel north
of the penetration of the Raymond fault.
As discussed above, the DEIR/S WQAR (page 106) assumes that backfill grouting operations
performed during the construction phase would mitigate potential contaminant migration by
filling gaps between the tunnel lining and the excavated ground around the tunnel. However, the
DEIR/S does not analyze static effects, such as vibration or chemical degradation, on the
proposed grout. Nor does it consider the effect that a moderate or larger earthquake would have
in disrupting the post-construction impermeable groundwater barrier. As discussed above,
rigorous analyses, using finite element/finite difference methods, are needed to evaluate the
extent of the severely impacted areas resulting from fault offset ground movements and nearsource ground shaking. This is necessary to assess the extent of cracked and fractured areas that
could contribute to and facilitate seepage along the outside of the tunnel potentially facilitating
groundwater flow from the Raymond Basin and contamination into the Main San Gabriel Basin.
This includes pathways developed by sympathetic movement on non-active faults, fractures, and
parallel geologic bedding between the Raymond and San Rafael faults.
Without any evaluation of the geologic units and fracture patterns in bedrock, or of the potential
deterioration of the grout seal, the DEIR/S does not demonstrate that impacts related to
groundwater contamination would be less than significant, even considering measures such as
grouting.
4. REFERENCES CITED
14 C.C.R. 15000 et seq. (California Environmental Quality Act Guidelines), Appendix. G.

26

Drawdown = Reduction in the elevation of the groundwater surface in a groundwater basin due to natural or
manmade causes.
27
Perchlorates = A natural and manmade chemical used to produce rocket fuel, fireworks, flares, and explosives,
which can also be found in bleach and some fertilizers. Its adverse health effects can include disruption of hormone
production needed for normal growth and development.

SR-710 DEIR/S Review-Geology/Seismic/Soils/Groundwater

July 8, 2015
Page 21 of 24

Bambridge et al. 2013, Factors of ScalePlanning, Design, and TBM Considerations for Large
Diameter Bored Tunnels, Rapid Excavation Tunneling Conference Proceedings 2013,
pages 614624.
Bedell, A. et al. 2013, Does the End Justify the MeansCost of Grouting and the Benefit to
Owners. Rapid Excavation Tunneling Conference Proceedings 2013, pages 460464.
Caltrans (California Department of Transportation), 2013. Memo to Designers Section 20-10
Fault Rupture, January 2013.
Caltrans, 2013, Seismic Design Criteria, Version 1.7, April 2013.
Caltrans (California Department of Transportation) and Metro (Los Angeles County
Metropolitan Transportation Authority), 2012, Alternatives Analysis Report, SR 710
North Study, Los Angeles County, California, with figures and plates, including
Appendix A, Performance of Unscreened Set of Alternatives; Appendix C, Performance
of Preliminary Set of Alternatives; Appendix J, Performance of Initial Set of
Alternatives; and Appendix T, Geotechnical Study Technical Memorandum, December
2012.
Caltrans and Metro, 2014, Tunnel Evaluation Report SR 710 North Study Los Angeles County,
California. September 5, 2014.
Caltrans and Metro, 2014, Geologic Hazard Evaluation to Support Environmental Studies
Documentation SR 710 North Study Los Angeles County, California.
Caltrans and Metro, 2014, Preliminary Geotechnical Report, SR 710 North Study, Los Angeles
County, California with figures and plates, including Appendix E, Fault Rupture
Evaluation Technical Memorandum; Appendix F, Preliminary Earthquake Acceleration
Response Spectra Technical Memorandum; and Appendix G, Fault Investigation
Technical Memorandum. December 2014.
Caltrans and Metro, 2015, SR 710 North Study, Draft Environmental Impact
Report/Environmental Impact Statement and Draft Section 4(f) De Minimis Findings, 2
vols. Los Angeles County, California 07-LA-710 (SR 710) E.A. 187900 EFIS
0700000191, March 2015.
Corigliano, Mirko, Laura Scandella, Carlo G. Lai, Roberto Paolucci, 2011 Seismic analysis of
deep tunnels in near fault conditions: a case study in Southern Italy Bull Earthquake
Engineering, DOI 10.1007/s10518-011-9249-3, dated February 6, 2011.
Dubnewych, Steve, Steve Klein, Yoga Chandran, 2011, Ramifications of Anticipated
Geotechnical Conditions on The SR-710 Tunnel, 2011 Rapid Excavation and Tunneling
Conference Proceedings, pages 738750.

SR-710 DEIR/S Review-Geology/Seismic/Soils/Groundwater

July 8, 2015
Page 22 of 24

GEOSCIENCE Support Services, Inc. (GSSI), 2009, Technical Memorandum: Perchlorate

Contamination of Groundwater in the Raymond Basin NASA/JPL. March 6, 2009.
Conference Call Action Items 1, 2, and 3, Prepared for the City of Pasadena Water and
Power. June 24, 2009.
GeoTracker, 2015, http://geotracker.waterboards.ca.gov/gama/gamamap.
Hudnut, K. 2012, Presentation Handout at Pasadena Forum, September 2012,
http://www.google.com/url?url=http://www.cityofpasadena.net/WorkArea/DownloadAss
et.aspx%3Fid%3D6442466533&rct=j&frm=1&q=&esrc=s&sa=U&ei=VFh3VZjyNc6ly
ATg6oDACA&ved=0CCAQFjAC&usg=AFQjCNGzwUwnCpad3B3-Hlwdj-pGvUu3_g.
Katibeh, H and Aalianvari, A., 2012, Common Approximations to the Water Inflow into
Tunnels, Drainage Systems, Prof. Muhammad Salik Javaid (Ed.), ISBN: 978-953-510243-4, InTech, http://www.intechopen.com/books/drainage-systems/a-review-on-themethods-of-groundwater-flow-dischargeestimation-into-tunnels
Los Angeles County Metropolitan Transportation Authority (METRO), 2011, CENTURY CITY
AREA TUNNELING SAFETY AND FAULT INVESTIGATIONS Edward J. Cording,
Geoffrey Martin, Harvey Parker, Tunnel Advisory Panel (TAP), dated October 14, 2011.
NASA/JPL, 2007, EPA ID# CA9800013030, Technical Memorandum: Additional Investigation
Results, January 31, 2007.
Parsons Brinckerhoff Inc. (PBI), 2004, Task 1.11: Engineering Criteria Tunneling Issues Report,
California High-Speed Rail Program EIR/EIS, January 2004.
Raymond Basin Management Board, 2014, Watermaster Service in the Raymond Basin, Annual
Report July 1, 2013June 30, 2014. September 2014.
Wang, W. L., T. T. Wang, J. J. Su, C. H. Lin, C. R. Seng, T. H. Huang, (2001), Assessment of
damage in mountain tunnels due to the Taiwan Chi-Chi Earthquake Tunneling and
Underground Space Technology, July 2001, Pages 133-150.
Wesnousky, Steven G., 2008, Displacement and Geometrical Characteristics of Earthquake
Surface Ruptures: Issues and Implications for Seismic-Hazard Analysis and the Process
of Earthquake Rupture Bulletin of the Seismological Society of America, Vol. 98, No.
4, pp. 16091632, August 2008, doi: 10.1785/0120070111.
Xiaoqing-Lin, Fang, Junqi-Zhou Xiaolan-Liu Runzhou (2008), DAMAGE EVALUATION OF
TUNNELS IN EARTHQUAKES The 14th World Conference on Earthquake
Engineering October 12-17, 2008, Beijing, China

SR-710 DEIR/S Review-Geology/Seismic/Soils/Groundwater

July 8, 2015
Page 23 of 24

WILSON GEOSCIENCES INC.

KENNETH WILSON
Principal Engineering Geologist
EDUCATION
University of California at Riverside, B.S. Geological Sciences, 1967
University of California at Riverside, M.S. Geological Sciences, 1972
PROFESSIONAL REGISTRATIONS
Professional Geologist, California, #3175 [Issued 1-08-1974; Expires 2-28-2015]
Certified Engineering Geologist, California, #928 [Issued 1-08-1974; Expires 2-28-2015]
PROFESSIONAL SUMMARY
Kenneth Wilson is responsible for management, technical supervision and performance of engineering geology, geotechnical,
environmental impact, and environmental geology projects, and is a Professional Geologist (#3175) and Certified Engineering
Geologist (#928) in California. He performs and supervises environmental assessments for commercial, industrial and
government projects covering the disciplines of hydrogeology, engineering geology, geology, hydrology, seismicity, tectonics,
faulting, mineral resources, and waste management. Geotechnical studies include fault evaluations, ground failure
assessments, slope stability and foundation materials characterization, liquefaction potential, flooding hazards and site
selection. The emphasis of his work is on defining geologic and geotechnical conditions, and hazards, which may affect the
feasibility and design of any type of development project. Mr. Wilson has over 40 years of technical performance/project
experience in critical facilities studies, radioactive/mixed/hazardous waste management, energy plant site licensing, waste
disposal site development, dams and reservoirs and numerous other engineered structures. Specialized experience is in
engineering geology in support of geotechnical studies, site selection/evaluation, seismic safety, integration of
multidisciplinary technical teams, project management, and EIRs, EAs, and EISs.
PROFESSIONAL EXPERIENCE
Wilson Geosciences Inc., Engineering and Environmental Geology [1989-Present]
Principal Engineering Geologist: Responsible for all management and technical activities for engineering geology,
environmental impact, and environmental geology projects. Performs and supervises environmental assessments for
commercial, industrial and government projects covering the disciplines of hydrogeology, engineering geology, geology,
hydrology, seismicity, tectonics, faulting, mineral resources, and waste management. Geotechnical studies include fault
evaluations, slope stability and foundation materials characterization, liquefaction potential, and site selection.
The Earth Technology Corporation [1974-1989]
Corporate Vice President: Mr. Wilson worked from late-1987 to mid-1989 for the Chairman/CEO and the President/COO
performing the following tasks: assisting in evaluation of several potential acquisitions; management of pre-acquisition
due diligence; evaluation of four new office geographic expansion options; managed preparation of corporate health and
safety program and H/S technical procedures. In 1989 was principal-in-charge for start-up of environmental engineering
and hydrogeology portion of Technical Assistance Contract with DOE/Nevada Operations.
Vice President; Director, Program Management: Mr. Wilson reported to the President of the Western Division (19851987) and was responsible for business development, project execution and strategic planning for market areas related to
radioactive (high, mixed, and low-level) waste management programs, energy and mineral resources, geophysics and
offshore technology. Emphasis was on geosciences, engineering, environmental, and program management disciplines for
site selection, site evaluation/characterization, site remediation and specialized advanced technology considerations in
hydrologic modeling, rock mechanics testing and geophysical exploration.
Vice President, Associate and Senior Manager: Mr. Wilson had numerous challenging technical and management
responsibilities and assignments during the period 1974-1988. There was a wide range of projects for which he had a
technical role, either performance, supervisory, or management in scope. A substantial portion of the time he was
Program Manager for the Missile-X (MX) ICBM, Siting and Characterization Studies in the Western and Midwestern
United States: for United States Air Force, Ballistic Missile Office, and the Southern Region Geologic Project Manager
(SRGPM) in Mississippi, Louisiana, Texas, Georgia, South Carolina, Virginia, Maryland for Office of Nuclear Waste
Isolation (ONWI) and Office of Crystalline Repository Development (OCRD). These projects were national in scope and
involved most geologic, geotechnical, geophysical, environmental, and hydrologic disciplines
Converse Consultants (formerly Converse, Davis and Associates) [1970-1974]
Staff and Project Geologist: Conducted and supervised investigations in southern, central, and northern California,
southern Nevada, and eastern Washington. Groundwater and related studies included permeability, transmissibility, and

KENNETH WILSON
Page 2
storage coefficient studies at Searles Lake, California; earth dam projects at Yucaipa, Littlerock, and Anaheim, California;
groundwater contamination (hydrocarbons) evaluation in the Glendale, California area; wastewater and water treatment
facilities in Solvang, Lompoc, Victorville, Thousand Oaks, and Sylmar, California. Numerous earthquake and fault risk
studies were performed for earth dams and reservoirs, high-and low-rise buildings, hospitals and schools, proposed
nuclear power plant sites, water storage tanks, and large-diameter pipelines. Landslide and other slope failure studies
were performed in rock and soil terrains. Offshore studies planned and conducted include coastal geophysical (seismic
reflection, side scan sonar, fathometer), sampling and scuba investigations near Monterey and Dana Point, California.
PROFESSIONAL ORGANIZATIONS
Member Association of Engineering Geologists, National and Southern California Sections
American Geophysical Union
COURSES, SEMINARS, AND WORKSHOPS

Engineering Geophysics Short Course, Colorado School of Mines, Office of Continuing Education, Golden, Colorado
Fundamentals of Ground-Water Monitoring Well Design, Construction, and Development, Las Vegas, Nevada
New Developments in Earthquake Ground Motion Estimation and Implications for Engineering Design Practice,
Seminar organized by Applied Technology Council and funded by U.S. Geological Survey, Los Angeles, California
Seismic Hazards Analysis, Course sponsored by Association of Engineering Geologists, Los Angeles, California

REPRESENTATIVE EXPERIENCE WITH GENERAL PLAN SAFETY ELEMENTS/TECHNICAL

BACKGROUND REPORTS
Wilson Geosciences Inc. has been responsible for the geology, seismic, and soils [safety element technical background
report and/or EIR section] portions of the following southern California General Plan updates:


Arcadia

Ontario SOI Amendment


Rosemead

Chino


Azusa

Riverside


Claremont

City of Los Angeles Framework


Laguna Hills

San Clemente


Huntington Beach

California City


San Marcos

American Canyon
REPRESENTATIVE TRANSPORTATION AND HIGHWAY/ROADWAY PROJECTS
Vandenburg Air Force Base Road Re-alignment
An initial site assessment was made for the feasibility of a major road re-alignment around a potentially unstable landslide
area, Vandenburg Air Force Base, California. The study involved aerial photo interpretation, field mapping, and
preparation of a report and cost estimate for performing a full geotechnical evaluation to design the roadway. Since the
roadway was the only land route an important radar site it was necessary to accommodate very steep terrain and unfavorable
geology along a major portion of the route. Environmental preservation of biological resources was an important
consideration in planning the drilling and geophysical exploration sites.
Foothill Transportation Corridor (FTC) Geotechnical Investigations: Near Irvine and Mission Viejo, Orange
County, California
Performed evaluations of the engineering geologic and geotechnical conditions, and recency of last fault movement on a
potentially active fault along two several-mile-long sections of the Foothill Transportation Corridor, Orange County,
California. Conducted geologic mapping, drilling, and trenching; logged deep (up to 140 feet) bucket auger borings and
logged backhoe trenches to determine bedrock and soil characteristics, and potential for future fault movement. Analyzed
data, prepared cross-sections, and co-authored a geotechnical reports presenting data, findings, and recommendations. Field
investigations were targeted at specific bridges and interchange structures, as well as along this entire section of the tollway.
Engineering Geology and Geotechnical Investigations for the San Joaquin Transportation Corridor, Orange
County, California
Also provided the supervision and review of geotechnical and engineering geology assessment for the San Joaquin
Transportation Corridor, Orange County, California. Utilized existing geologic data and newly acquired borehole, trench
and laboratory test information to evaluated various alternative routes through the San Joaquin Hills for the freeway
complex. This reconnaissance and feasibility level study was the key input to the project environmental documents and
final route selection. Presented data on maps and in a report, as well as at client/agency briefings.
1910 Pinecrest Drive Altadena, California 91001 Telephone 626 791-1589

KENNETH WILSON
Page 3
Santa Barbara County Regional Transportation Agency, Santa Barbara County, California
Provided a full geologic and seismic evaluation of a large portion of the Santa Barbara County area as a part of their
Regional Transportation Plan EIR. This study identified the potential hazards in the area of proposed transportation
projects, and the potential impacts of these hazards. The text and tabular information was used in the preparation of the EIR
documentation.

1910 Pinecrest Drive Altadena, California 91001 Telephone 626 791-1589

Ali Abdel-Haq, PE, GE

EDUCATION
Advanced Courses in Environmental Engineering, UCLA, 1989-1991
M.S. Engineering (Geotechnical), University of Ohio, 1985-1987
B.S. (Civil Engineering), Nottingham University-England, 1980-1983
Advanced Level in Mathematics, Further Mathematics, & Physics, Swindon CollegeEngland, 1978-1980.
REGISTRATIONS
Geotechnical Engineer, California, GE#2308
Professional Engineer (Civil), California, CE#46989
PROFESSIONAL HISTORY
GeoDynamics, Inc., Thousand Oaks, Principal Engineer, 2005-present
Bing Yen & Associates, Inc., Camarillo, Principal Engineer, 2000-2005
Leighton and Associates, Inc., Westlake Village, Senior Project Engineer, 1999-2000
Gorian & Associates, Inc., Westlake Village, Senior Project Engineer, 1997-1999
Burns & McDonnell, Kansas City, KS, Senior Project Engineer, 1994-1997
Gorian & Associates, Inc., Westlake Village, Senior Project Engineer, 1989-1994
Ensotech, Inc., Sun Valley, Senior Project Engineer, 1987-1989
AFFILIATIONS
American Society of Civil Engineers (ASCE), Member
REPRESENTATIVE
REPRESENTATIVE EXPERIENCE
Mr. Abdel-Haq has over 27 years of professional experience in geotechnical engineering in the State of
California, and 3 years of experience on projects throughout the United States. His project experience
includes field explorations, laboratory testing, engineering analyses, and construction observation of
various types of projects including hillside land development, commercial and industrial buildings,
landslides, theme parks, schools, water tanks, airport facilities, wastewater treatment plants, transmission
and distribution lines, and power generator facilities. Mr. Abdel-Haq has managed multiple projects with
an emphasis on client and project management particularly on meeting project schedules and budgets.
Mr. Abdel-Haq has performed geotechnical engineering reviews for over 14 years for the cities of Simi
Valley, Calabasas, Agoura Hills, Moorpark, Hidden Hills, Pasadena, Rosemead, Camarillo, Palmdale,
Santa Barbara County, and Malibu. He also performed third party reviews of projects for private
consultants. He has also served as a geotechnical engineer on public work projects for municipalities in
Southern California, and other parts of the United States.
Mr. Abdel-Haq performed geotechnical investigations, including an evaluation of the potential for
liquefaction and associated hazards, for projects including large tract home developments where high
liquefaction potential is known to exist, or is suspected. Projects included Simi Village, Tracts 4923,
5164 and 5113 (Simi Valley, California), North Shores at Mandalay Bay, Tract 4424 (Oxnard,
California), Tract 44986 (Santa Clarita, California), Mission Bell Plaza Shopping Center and Tracts 5147
(Moorpark, California). He also performed foundation investigations for a wide variety of projects across
the United States including industrial buildings, Multi-story buildings and parking garages, bridges, water
tanks, transmission and distribution lines and power substations, retaining walls, several rides at Six Flags
Magic Mountain, and Naval Facilities. He has also evaluated foundation settlement due to noise vibration
associated with jet engine test facilities, dynamic foundations for conveyor belts and electric generators,

Ali Abdel-Haq, PE, GE

and the potential impact of adding fill, on large diameter (48 to 60diameters) high-pressure water lines
of the Calleguas Water Company.
Mr. Abdel-Haqs Masters thesis utilized finite element analyses to evaluate induced stresses in culverts
due to different types and thicknesses of backfill materials.

PUBLICATIONS
PUBLICATIONS
Abdel-Haq, A and Hryciw, R. D. (1998). Ground Settlement in Simi Valley Following The Northridge
Earthquake. Journal of Geotechnical and Geoenvironmental Engineering, Vol. 124, No. 180-89.

Technical Appendix 4
(Air Quality)

to
Attachment A
5-Cities Alliance
Comment Letter

Technical Review of Air Quality, Greenhouse Gas,

and Health Risk Assessments for:

STATE ROUTE 710 NORTH

STUDY DEIR/EIS
Prepared For:

THE FIVE CITY ALLIANCE

GLENDALE, LA CANADA FLINTRIDGE,

PASADENA, SIERRA MADRE AND SOUTH PASADENA
SHUTE, MIHALY & WEINBERGER LLP

396 Hayes Street

San Francisco, CA 94102-4421

Prepared By:

LANDRUM & BROWN

Matthew B. Jones P.E.
19700 Fairchild, Suite 230
Irvine, CA 92612
9493490671

July 10, 2015

Report #554301AQ05

This Page is Blank

SR-710 North Study DEIR/EIS

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LIST OF TABLES .............................................................................i

LIST OF FIGURES............................................................................i
ACRONYMS .................................................................................. ii
1.0 Introduction .......................................................................1
2.0 Overview Comments ...........................................................1
2.1 Construction Emissions ...................................................................... 1
2.2 Operational Emissions ........................................................................ 3

3.0 Detailed Accounting of the Shortcomings of the Air Quality,

Greenhouse Gas and Health Risk Assessments ................. 10
3.1 Construction Air Quality Analysis is Incomplete, Finding of No Significant
Impact After Mitigation Unsupported, and Mitigation Inadequate ............
3.2 The Particulate Matter Hotspot Assessment is Not Substantiated ............
3.3 The Methodology Used to Determine Health Risk Impacts Minimizes
Differences Between Alternatives and Underestimates Impacts ..............
3.4 The Conclusion of Health Risk Impact Significance Is Incorrect ..............
3.5 Greenhouse Gas Emission Calculations Do Not Include Those From
Electrical Consumption .....................................................................
3.6 Traffic Modeling Deficiencies .............................................................

10
15
19
19
21
22

Appendix Reference Documents........................................... 23

Los Angeles County Metropolitan Transit Authority Green Construction Policy 23
Environmental Protection Agency Transportation Conformity Guidance for
Quantitative Hot-Spot Analyses in PM2.5 and PM10 Nonattainment &
Maintenance Areas .......................................................................... 23
South Coast Air Quality Management District Finalized Localized Significance
Threshold Methodology .................................................................... 23

LIST OF TABLES
Table 1 Construction Emissions and SCAQMD Regional Significance
Thresholds (lbs./day) ............................................................ 11
Table 2 Approximate Emissions Reductions From Off-road Engine Tier 2
Standards ............................................................................ 12

LIST OF FIGURES
Figure 1 Off-road Equipment Emission Standard Tiers ............................ 12

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ACRONYMS
AAQS

Ambient Air Quality Standards

AQMP

Air Quality Management Plan

CAAQS

California Ambient Air Quality Standards

CARB

California Air Resources Board

CEQA

California Environmental Quality Act

CO

Carbon Monoxide

CO2

Carbon Dioxide

CO2EQ

Carbon Dioxide Equivalent

DEIR

Draft Environmental Impact Report

DPM

Diesel Particulate Matter

EIS

Environmental Impact Statement

FHWA

Federal Highway Administration

FTA

Federal Transit Administration

GHG

Greenhouse Gasses

HDDT

Heavy Duty Diesel Truck

LST

Localized Significance Threshold

MATES IV

Multiple Air Toxics Exposure Assessment IV

MSAT

Mobile Source Air Toxic

NAAQS

National Ambient Air Quality Standards

NEPA

National Environmental Protection Act

N 2O

Nitrogen Dioxide

NOX

Nitrogen Oxides

PM2.5

Particulate Matter with a Diameter of 2.5 microns or less

PM10

Particulate Matter with a Diameter of 10 microns or less

ROG

Reactive Organic Gas

ROW

Right of Way

RTP

Regional Transportation Plan

SCAB

Southern California Air Basin

SCAQMD

South Coast Air Quality Management District

SIP

State Implementation Plan

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1.0 Introduction
The purpose of this report is to present the findings of our review of the air quality,
greenhouse gas, and health risk impact analyses presented in the SR-710 North
Study DEIR/EIS.
We have determined that the DEIR/EIS has significant
deficiencies that should be corrected prior to taking any action on any of the Project
alternatives.
Section 3.0 of this report provides an overview of the flaws in the air quality,
greenhouse gas, and health risk impact analyses. The primary shortcomings of the
analysis include: (1) an incorrect finding of no significant impact and inadequate
mitigation for short-term construction emissions; (2) an inadequate and poorly
documented analysis of particulate hotspots; (3) the use of an oversimplified
methodology to calculate cancer and non-cancer health risks; (4) an incorrect
significance finding for health risk impacts; and (5) an incomplete estimate of
greenhouse gas (GHG) emission increases. Further, the effects of traffic modeling
issues on the air quality analysis are also presented.
Section 2.0 presents a more detailed accounting of the deficiencies identified in
section 3.0. Because section 2.0 is more comprehensive than the points raised in
section 3.0, and because certain of this more comprehensive analysis may raise
slightly different issues than those raised in section 3.0, we respectfully request
that Caltrans prepare responses to each of the comments raised in this entire
report.

2.0 Overview Comments

The following presents an overview of our comments on the DEIR/EIS document.

2.1 Construction Emissions

1)

The construction emissions analysis does not clearly state whether the fugitive
dust calculations assumed the implementation of measures, such as regular
site watering or other dust preventive measures. This assumption should be
clearly stated presented.

2)

The DEIR/EIS does not specify a significance threshold for construction

emissions.
The document should clearly specify the threshold used to
determine whether or not the projects construction impacts would be
significant.

3)

The DEIR/EIS compares the projects operational regional emissions, Table

3.13.10 (p. 3.13-29) with the SCAQMD recommended operational regional
significance thresholds.
The DEIR/EIS concludes that the alternatives
operational emissions are well below these thresholds. However, the DEIR/EIS
makes no mention of the equivalent SCAQMD construction regional significance
thresholds in Table 3.13.4 (p. 3.13-11). Construction emissions are well
above the SCAQMD thresholds. Why does the document cite the SCAQMD
significance thresholds when the comparison is beneficial but ignore them
when they contradict the finding of no significant impact? The constructionrelated emissions from all alternatives exceed the thresholds for one or more
pollutants by as much as 10 times. For the analysis to conclude that there will

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be no significant impact it must demonstrate that construction emission will be

less than the SCAQMD thresholds with implementation of the specified
mitigation.
4)

Although the construction of the Freeway Tunnel Alternatives would generate

approximately twice the NOX and particulate exhaust emissions as the
TSM/TDM, BRT and LRT alternatives, the DEIR/EIS does not provide the most
stringent measures to reduce these emissions.
Avoidance, minimization
and/or mitigation measure AQ-4 would be applied to construction of the
Freeway Tunnel Alternatives while AQ-5 would be applied to the TSM/TDM,
BRT, and LRT alternatives. Measure AQ-5 calls for compliance with the Metro
Green Construction Policy, which would require the use of Tier 4 rated off-road
equipment and on-road haul trucks that are model year 2007 or later.
Compliance with the Metro Green Construction Policy for the Freeway Tunnel
Alternatives would reduce exhaust particulate and NOX emissions by
approximately 90% from the estimate presented in the DEIR/EIS. AQ-4
contains no such restrictions and AQ-2 would only require that Freeway Tunnel
Alternatives to use Tier 3 or better off-road construction equipment with no
restrictions on haul trucks. AQ-4 would reduce only a fraction of the NOX
emissions, those from off-road equipment but not haul trucks, by
approximately 33% and would not reduce particulate emissions. The DEIR/EIS
must justify the use of less stringent measures to mitigate the Freeway Tunnel
alternatives construction impacts.

5)

Avoidance, minimization and/or mitigation measure AQ-4 addresses asphalt

batch plant emissions.
However, the DEIR/EISs construction emissions
calculations do not appear to include any fugitive asphalt emissions. Nor are
these emissions discussed in the DEIR/EIS or its air quality technical
appendices. The Freeway Tunnel Alternatives would likely require asphalt
paving; fugitive ROG emissions from this paving must be included in the
construction emissions calculations.

6)

Avoidance, minimization and/or mitigation measure AQ-1 calls for compliance

with SCAQMD Rule 403. Rule 403 requires all operations to implement the
Best Available Control Practices. These Practices are presented in Table 6.1 of
the Air Quality Assessment Report. The rule contains additional requirements
for large operations which are defined as those involving 50 or more acres or
with a daily throughput of 5,000 cubic yards or greater. The DEIR/EIS does
not provide enough information to determine if any of the Build Alternatives
would be defined as Large Operations under Rule 403. However, the DEIR/EIS
should commit to incorporating the Large Operations Rule 403 requirements
for the LRT and Freeway Tunnel Alternatives to provide the greatest amount of
fugitive dust minimization as possible.

7)

SCAQMD recommends assessing potential localized impacts from construction

activities yet no such analysis was included in the DEIR/EIS. A localized
impact analysis would determine whether or not construction has the potential
to either create any exceedances of the ambient air quality standard (AAQS) or
make worse any existing exceedances of the AAQS. SCAQMD developed its
Localized Significance Threshold Methodology (LST) to make it easier for

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smaller projects, less than five acres, to assess these impacts. Most of the
TDM/TSM, and BRT construction activities and LRT station construction fall into
this category. The LST methodology provides on-site emissions lookup tables
to determine whether the emissions have the potential to create an
exceedance of the AAQS or worsen an existing exceedance. Projects that
include construction activities on sites larger than five acres are required to
demonstrate compliance with SCAQMD standards by conducting dispersion
modeling. These analyses must be undertaken in order for the DEIR/EIS to
assess whether the project will result in a significant impact under CEQA
checklist item III(b).
8)

Section 6 of the DEIR/EISs Air Quality Analysis Report presents two lists of
measures to reduce or minimize construction related emissions. The first list is
described as regulatory measures. However, only the first two measures fit
this description. The second list is described as a list of Caltrans standard
measures. All of the items from both of these lists are mitigation measures
typically applied to construction projects in the South Coast Air Basin.
However, only a few of these measures have been incorporated into the
avoidance, minimization, and/or mitigation measures presented in Section
3.13.4 of the DEIR/EIS. All of the measures presented in Section 6 of the Air
Quality Analysis Report should be required mitigation measures for the
Projects significant construction-related air quality impacts.

9)

The DEIR/EIS does not quantify the estimated emission reduction potential of
each mitigation measure. The DEIR/EIS must provide these estimates to
determine whether these measures would effectively reduce the constructionrelated emissions from each project alternative to a less than significant level.

2.2 Operational Emissions

10) The DEIR/EIS, the Air Quality Analysis Report and the Health Risk Assessment
show that emission concentrations in the future would be less than current
pollutant concentration levels. The DEIR/EIS attributes these reduced pollutant
concentrations to the project. However, this conclusion is unsupported by
evidence. These considerable reductions will occur independent of the project
due to turnover of older vehicles with newer vehicles that comply with
increasingly stringent vehicle emission standards.
While CEQA generally
requires an analysis of a projects environmental impacts against a baseline of
existing conditions, in this instance, such a comparison would not accurately
depict the projects impact on air quality or health risk. A comparison of future
conditions to existing conditions does not provide an independent measure of
the Projects impacts.
Instead, it demonstrates the effects of the
implementation of more stringent vehicle emissions standards in combination
with the project. Because this methodological approach incorrectly mixes the
projects emissions together with future background emission concentrations,
there is no way to isolate the emissions that would be generated by the
Project. The analysis must be revised to include two future scenarios. The
first scenario would identify future concentrations without the project. The
second scenario would identify future concentrations with the project. The
difference in emission concentrations between the two scenarios would show
the effects of the Project.

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11) The DEIR/EIS and Air Quality Analysis Report do not provide any details of the
specific data used in the quantitative particulate hotspot dispersion modeling.
The modeling input parameters, such as traffic volumes and speeds, emission
factors and specific receptor locations must be identified. These modeling
assumptions were provided for the health risk dispersion modeling, so we can
find no logical explanation for not identifying this data for the particulate hot
spot analysis.
12) The Health Risk Assessment technical document provides a reasonable amount
of documentation of the input parameters used for the MSAT dispersion
modeling. This data and the methodology description show that the dispersion
modeling utilized average daily traffic volumes and speeds. However, this
methodological approach is incorrect as it does not properly account for diurnal
variations in traffic characteristicsincreased emissions during peak commute
hours, slightly lower emissions during midday, and considerably lower
emissions overnightand how they interact with the diurnal weather
conditions that affect how pollutants are dispersed. The use of average traffic
characteristics would tend to compress the modeling results. That is, if the
diurnal traffic variation was properly accounted for, some receptors would have
higher concentrations and others would have lower concentrations. These
errors could be amplified because the projects impact is based on the
difference between two modeled scenarios, i.e., conditions with and without
the project. Large differences would occur if diurnal variations in emissions
and dispersion under no project conditions were out of synci.e. the highest
emissions occurring during periods of high dispersion (afternoons/evenings)
and were in synci.e. the highest emissions occurring during periods of low
dispersion (late nights/early mornings)under with project conditions.
Section 5.3.2 of the EPAs Transportation Conformity Guidance for
Quantitative Hot-Spot Analyses in PM2.5 and PM10 Nonattainment and
Maintenance Areas describes the preferred methodology for accounting for
diurnal traffic variation. EPAs methodology separates the diurnal variation
into four periods, AM peak, midday average, PM Peak period, and overnight
average. This method adequately captures diurnal emission variations that are
lost with the use of average daily emission characteristics. The HRA modeling
must be revised with this more accurate methodology to ensure that impacts
are accurately assessed.
13) As discussed in Comment 11, the DEIR/EIS does not disclose the modeling
input data assumptions used in the particulate hotspot analysis. However,
there are indications that the hotspot analysis used the same errant modeling
(i.e., the use of average daily traffic volumes and speeds) as the HRA. If this is
the case, the particulate hotspot analysis must be revised so that with the
more appropriate EPA methodology.
14) The dispersion modeling for the quantitative particulate hotspot and HRA also
err in the use of average speeds to determine emission factors. As discussed
in comments 12 and 13 above, both models appear to have used average daily
speeds to determine the emission factor. In addition, it appears that the
particulate hot spot and HRA model used average bi-directional speed. This

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approach is also incorrect. Speeds and emission factors are not linearly
correlated. For most pollutants, emissions per mile are greatest at low and
high speeds and minimal at medium speeds. For particulate matter, emissions
are at a minimum between 35 and 40 mph, increasing at lower and higher
speeds. PM10 emission factors between 0 and 5 mph are approximately 20%
higher than the mid-speed minimum emission factor and approximately 7%
higher between 65-70 mph. PM10 emission factors are approximately 40%
higher between 0 and 5 mph and approximately 15% higher between 65-70
mph.
Because emission factors and speed are not linearly correlated,
multiplying the average traffic volume with the emission factors based on
average speed does not result in the average emissions. Further, average
speeds would tend towards the minimum emission factor, incorrectly
minimizing emissions.
When the dispersion modeling is revised to properly account for diurnal traffic
variations, emissions should be determined for each travel direction based on
the speed and volume in each direction and then combined for model input.
15) In addition to the fact that the particulate hotspot analysis relied on improper
methodology, the analysis has additional flaws. First, it does not identify the
intended purpose of the particulate analysis, which is to determine whether a
projects increase in particulate pollutants would create or make worse any
exceedances of the ambient air quality standard (AAQS). Specifically, a hot
spot analysis is prepared so that the agency is able to compare air quality
concentrations with the proposed project (the build scenario) to air quality
concentrations without the project (the no-build scenario).
Second the DEIR/EIS does not identify the threshold for determining the
significance of the projects impact. A threshold of significance is generally a
numeric or qualitative level at which impacts are normally less than significant.
Here, the threshold of significance would be a design value that describes a
future air quality concentration in the project area that can be compared to the
AAQS.
Third, the analysis does not appear to have included background
concentrations in the Project area. Background concentrations account for all
other sources of pollution within the project area. A determination of a
projects effect on particulate AAQS must necessarily take into account
background particulate concentrations. The DEIR/EIS displays the results of
the particulate hotspot analysis in Tables 3.13.7 through 3.13.9. These tables
show PM10 and PM2.5 concentrations by Project alternative for the opening year
(2025) and horizon year (2035). The values depicted in these tables appear to
only include pollutant concentrations from the sources, i.e., vehicles on
freeways and arterial streets. The modeled 24 hour PM2.5 concentration shown
in Table 3.13.7 is just more than one tenth of the average of the three most
recent years of measured concentrations at the Main Street Los Angeles
monitoring station presented in Table 3.13.2. The modeled annual PM2.5
concentration is three and a half times lower than the measured and the 24hour PM10 concentration is four times lower.

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Fourth, the DEIR/EIS does not identify pollutant concentrations at each

potentially affected receptor location. Tables 3.13.7 through 3.13.9 appear to
show only the highest modeled concentration for each scenario at one
(unspecified) receptor location. The analysis should have identified particulate
concentrations on a receptor-by-receptor basis. It is necessary to calculate
the design values for all receptors in the build and no-build scenarios to
determine whether there would be violations of the AAQS at each receptor
location.
Fifth, the DEIR/EIS does not even compare the particulate pollutant
concentration at the one receptor location it does identify to the AAQS.
Finally, the DEIR/EIS only addresses Federal PM10 AAQS; it does not address
the State AAQS. The analysis must address all applicable federal and state
AAQS. This analysis is especially important, as the state standard is more
restrictive than the federal standard.
16) The DEIR/EIS does not provide an adequate analysis of the Projects
cumulative air quality impacts. First, in the discussion of CEQA checklist
question III(c) (Page 4-7), the DEIR/EIS concludes that the project
alternatives, in combination with the other cumulative projects would not
contribute to a cumulative temporary air quality impact. The DEIR/EIS errs in
this conclusion. The document asserts that Mitigation Measures AQ-1 through
AQ-4 would reduce the projects construction-related air quality impacts to a
less than significant level. As explained earlier in this report, there is no
evidence to support this conclusion. Consequently, the projects cumulative
impacts would be significant. Second, also in the context of question III(c),
the DEIR/EIS includes a discussion of mobile source air toxics. However, this
CEQA checklist question only addresses criteria air pollutants. The DEIR/EIS
concludes that cumulative air quality impacts related to a net increase of any
criteria pollutant for which the project region is in nonattainment would be less
than significant with construction of the Build Alternative in combination with
these projects.
However, this conclusion regarding criteria pollutants is
derived from a discussion of MSAT and the conclusion does not logically follow
from the argument. The EIR/EIS must evaluate whether the projects increase
in criteria air pollutants, together with criteria air emissions from other
cumulative projects would result in cumulatively significant air quality impacts.
17) The response to checklist question III(d) in the DEIR/EIS (Page 4-7) states
that the Health Risk Assessment shows that the Build Alternatives would not
result in a significant increase or significant cumulative increase in criteria
pollutants that are in non-attainment. However, the Health Risk Assessment
analyzes the impacts of air toxics and in no way addresses criteria pollutants.
The conclusion does not logically follow the argument presented.
18) The response to checklist question III(d) in the DEIR/EIS (Page 4-7) states,
the Build Alternatives would reduce cancerous and non-cancerous chronic and
acute risks in the region. However, this remark is not supported and even
contradicted by the DEIR/EISs Health Risk Assessment. The Health Risk
Analysis shows that the Freeway Build Alternatives will result in cancer risk
increases greater than the significance threshold of 10 in a million. This is

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when the actual impact of the project is measured using the Health Risk
Assessments Scenario 2 which compares future conditions with and without
the project. The Health Risk Assessments Scenario 1 does not provide a
measure of the build alternative impacts as it compares future conditions with
the project to existing conditions without the project. Nearly all of substantial
cancer risk reductions shown under Scenario 1 are due to stricter vehicle
emissions regulations including those enacted as part of the States Diesel Risk
Reduction Program. Scenario 2 compares conditions with and without the
build alternatives with no other changes to the environment and therefore,
accurately reflects the impact of the alternatives.
The analysis shows that a larger area will experience decreases in cancer risk
than will experience increases. Yet, this is not an accurate measure of the
relative overall risk. If all of the increases occur in residential areas and all of
the decreases occur in non-residential areas, then the overall net effect could
be negative (note this is provided as an example we are not arguing that is the
case). As discussed in the HRA section of this report, a burden analysis should
be performed to calculate the change in cancer cases by applying the risk to
census tracts. This analysis is required to demonstrate whether the project
would have a net benefit or impact in terms of cancer cases.
19) The DEIR/EISs HRA concludes that the project will not result in any noncancer health risk impacts based on the difference in the acute and chronic
hazard indices (HIA and HIC) with and without the project. However, this is
not a complete analysis of the projects potential impacts. The hazard indices
are a measure of when adverse non-cancer health effects begin to occur. An
absolute hazard index of less than one indicates that there is no potential for
adverse non-cancer health impacts. A hazard index greater than one indicates
that there may be adverse non-cancer health effects. A hazard index of one is
the threshold between when no adverse effects are anticipated and when
sensitive persons would begin to have adverse health effects. The amount
that a hazard index exceeds one does not provide any additional information
regarding the level of impact.
In addition to determining if the emissions associated with project itself would
result in a hazard index of one, the analysis needs to determine if there are
any areas exposed to hazard indices of less than one without the project that
would be exposed to a hazard index of greater than one with the project.
Under this condition, the project would result in adverse health effects that
would not occur without the project. This would represent a significant impact.
20) The DEIR/EIS evaluated cancer risks using the methodology described in the
2003 Office of Environmental Health Hazard Assessments (OEHHA) Guidance
Manual for Preparation of Health Risk Assessments. In February of 2015, the
OEHHA published revised Guidelines with a new methodology to calculate
cancer risks that accounts for childrens increased sensitivity to toxic air
pollutants. This new methodology multiplies the risk due to exposure between
the start of the third trimester in the womb and the second birthday by 10 and
the risk between the second birthday and the sixteenth birthday by 3. The
new methodology results in considerably higher cancer risk estimates than the

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prior methodology. The Technical Support Document for the Guidelines that
describe the new methodology was adopted by the OEHHA in 2012 after
undergoing public review. The 2012 Technical Support Document incorporated
a decades worth of knowledge since the methodology presented in the 2003
Guidelines used to calculate cancer risks for the DEIR/EIS. Cancer risks need
to be estimated using the revised methodology as using the outdated
methodology likely results in unidentified significant impacts.
21) The greenhouse gas (GHG) emissions presented in the Air Quality Assessment
Report and the DEIR only include those emitted from vehicles within the study
area.
GHG Emissions will also be produced through the generation of
electricity used by the project. For the TDM/TSM and BRT alternatives,
electrical requirements would be expected to be minimal, as would the
anticipated emissions.
The Freeway Tunnel Alternatives would consume
electricity for tunnel lighting and the tunnel ventilation system. This could
result in considerable GHG emission that should be reported in the DEIR/EIS.
The LRT would consume the most electricity of the Build Alternatives and the
non-inclusion of the GHG emissions associated with electricity in the reported
emissions is a significant omission. We estimate that the electricity used for
train propulsion only, not including lighting, ventilation, other electrical usage,
would generate between approximately 23,400 and 61,700 metric tons of
CO2EQ per year. The GHG emission estimates must account for all sources of
GHG emissions directly attributed to the project alternatives to provide a valid
analysis and comparison of alternatives.
22) The DEIR/EIS states that the CT-EMFAC 5.0 emissions model was used to
calculate vehicular CO2 emissions (Page 4-98).
CT-EMFAC is Caltrans
interpretation of CARBs EMFAC2011 emissions model that presents the
EMFAC2011 data in formats that are easier to use for highway air quality
analysis. Appendix E of the Air Quality Assessment includes two sets of CO2
emissions, one that includes the effects of the Pavley I and Low Carbon Fuel
Standards and one that does not.1 The DEIR/EIS, however, only presents
emissions that assume full implementation of the Pavley I and Low Carbon
Fuel Standard. This is misleading for two reasons.
First, full implementation of Pavley and LCFS is speculative. The Low Carbon
Fuel Standard is a mix of command and control regulation and emissions
trading that uses a mix of market based mechanisms to allow providers to
choose how they will reduce emissions while responding to consumer demand.
This results in the actual reduction in tailpipe CO2 emissions from
implementation of the Low Carbon Fuel Standard being uncertain. This also
results in a speculative underestimate of the future CO2 emissions and an over
estimate of the reduction in future CO2 emissions over existing conditions.
Second, the DEIR/EIS skews the analysis and GHG significance conclusion by
excluding Appendix E data regarding emissions without implementation of
Pavley and LCFS. A comparison of CO2 emissions without the Pavley I and Low
1

This is not explained anywhere in the text of the DEIR/EIS, the Air Quality Assessment, or
Appendix E of the Assessment. One must review the Appendix E tables to discover the CO2
emissions without Pavley/LCFS.

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Carbon Fuel Standards shows that future emissions under the freeway tunnel
alternatives are anticipated to increase by approximately 1,110 metric tons per
day in 2020, 1,400 metric tons per day in 2025 and approximately 2,100
metric tons per day in 2035 over existing conditions (the differences among
the freeway tunnel alternatives are slight).2 These increases in GHG emissions
would be significant. However, the data presented in the body of the Air
Quality Assessment and DEIR/EIS includes only emissions assuming full
Pavley/Low Carbon Fuel Standard implementation assumptions in EMFAC2011.
Under these assumptions, the document shows decreases in CO2 emissions of
approximately 1,100 metric tons per day in 2025, approximately 1,400 metric
tons per day in 2025, and approximately 1,100 metric tons per day in 2035
regardless of whether the TSM/TDM, BRT, LRT or Freeway Tunnel alternative is
selected. In other words, these decreases are not attributable to the Project.
Rather, they are a function of a regulatory program, which may or may not
achieve its goal, not of the Project alternatives
23) As discussed above, EMFAC2011 was used as the basis for the vehicular CO 2
emission estimates presented in the DEIR/EIS.
CARBs Mobile Source
Emissions Inventory On-Road Category website (http://www.arb.ca.gov/msei/
categories.htm#onroad_motor_vehicles) recommends the use of the
methodology specified in the Greenhouse Gas Emissions inventory
(http://www.arb.ca.gov/cc/inventory/inventory.htm) to estimate on-road
mobile source GHG emissions. The DEIR/EIS should discuss why it chose to
use a GHG emissions calculation methodology different from what is
recommended by the State air emissions regulating agency. Further, the use
of CARBs recommended methodology would also include estimates of
methane (CH4) and nitrous oxide (N2O), which are important GHGs emitted
from combustion and global warming potentials 25 and 300 times greater than
an equivalent amount of CO2 emissions.
24) The DEIR/EIS does not specify the threshold of significance used to determine
that GHG emissions will not result in a significant impact. The DEIR/EIS must
provide a clear impact threshold for GHG emissions and evaluate the project
alternatives based on this threshold.
25) Section 4.3 of the DEIR/EIS presents operational GHG emissions in terms of
metric tons per day. This information is conventionally presented on an annual
basis and confusion may result by reporting GHG emissions using an a-typical
metric. Operational GHG emissions should be presented on an annual basis.

The DEIR/EIS does not provide these emission totals. They are calculated by subtracting
the existing CO2 emissions from the 2035 CO2 emissions found in the Air Quality
Assessment Report Appendix E tables under the CO2 heading (note the DEIR/EIS presents
the values shown under the CO2 (Pavley I + LCFS) heading), and converting lbs./day to
metric tons/day.

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3.0 Detailed Accounting of the Shortcomings of the Air

Quality, Greenhouse Gas and Health Risk Assessments
The following subsections discuss the primary shortcomings of the DEIR/EIS.
Specifically, those issues that result in understatement of the potential air quality
impacts, adequacy of mitigation, or non-identification of significant unavoidable
impacts as required by CEQA.

3.1 Construction Air Quality Analysis is Incomplete, Finding of No

Significant Impact After Mitigation Unsupported, and Mitigation
Inadequate
Section 3.13.3.1 of the DEIR/EIS (pages 3.13-9 through 3.13-13) discusses
construction air pollutant emissions.
Common construction activities and air
pollutant emissions are discussed along with short discussions of the construction
activities for each alternative. Table 3.13.4 of the DEIR/EIS presents an estimate
of maximum total daily construction emissions. This mirrors the analysis presented
in Section 5.1 of the Air Quality Assessment Report, included as Appendix A of the
DEIR/EIS. The Air Quality Assessment Report presents the detailed equipment
assumptions used to generate the estimate of maximum total daily construction
emissions.3
Section 3.13.3.1 of the DEIR/EIS does not make any statements about whether the
construction emissions would adversely impact the environment. It notes that
because construction is not anticipated to last for more than five years, it is exempt
from the regional and project level conformity analysis of the federal clean air act.
Section 3.13.4 presents five Avoidance, Minimization, and/or Mitigation Measures
that are all applicable to construction.
The analysis of air quality impacts under CEQA is presented in Section 4.2.3 of the
DEIR (Pages 4-5 through 4-9). The discussion for CEQA Checklist Question III(b)
on Page 4-6 states that short-term degradation of air quality may occur due to the
release of particulate emissions generated by excavation, grading, hauling, and
other construction equipment. The last sentence of the paragraph concludes,
Measures AQ 1 through AQ-5 include measures to reduce construction-related air
quality impacts from fugitive dust and construction equipment emissions to less
than significant levels. The document does not specify the emissions thresholds
used to make this determination. The projects construction-related emissions
before mitigation are well above the Regional Significance Thresholds recommended
by the SCAQMD. The DEIR/EIS did not calculate the emission-reduction potential of
the measures.
Table 1 below presents the maximum daily construction emissions for each project
alternative from Table 3.13.4 of the DEIR/EIS along with the SCAQMDs
recommended regional significance thresholds for construction. Emissions greater
3

It appears likely that the DEIR/EIS underestimated the Freeway Tunnel Alternatives
increase in emissions, as it did not include emissions resulting from asphalt concrete plants.
Measure AQ-4 (p. 3.13-42) requires the Project to comply with Section 39-3.06 [Asphalt
Concrete Plan Emissions], which implies that this source of emissions should have been
included in the EIR/EISs estimate of total daily construction emissions.

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than the significance thresholds are shown in bold-italics. This table shows that
reactive organic gasses (ROGs), and CO emissions are above the thresholds for the
LRT and Freeway Tunnel Alternatives. NOX and particulate emissions exceed the
SCAQMD thresholds for all of the Build Alternatives. Particulate emissions are
between 1.3 and 3.4 times greater than the thresholds for the TSM/TDM and BRT
alternatives and between 3.8 and 9.7 times greater under the LRT and Freeway
Tunnel Alternatives.
NOX emissions are shown to be 2.1 times greater than the
threshold for the BRT Alternative, 9.4 times greater for the TSM/TDM Alternative,
22.4 times greater for the LRT alternative and 43.9 and 49.3 times greater for the
two Freeway Tunnel Alternatives.

Table 1
Construction Emissions and SCAQMD Regional Significance
Thresholds (lbs./day)
Alternative

ROGs

CO

NOX

PM10

PM2.5

TSM/TDM

49

548

935

513

130

BRT

12

123

206

327

74

LRT

119

1,335

2,242

720

207

Single Bore Freeway Tunnel

214

2,167

4,337

1,116

330

Dual Bore Freeway Tunnel

237

2,284

4,926

1,460

411

75

550

100

150

55

SCAQMD Significance
Threshold (lbs./day)

The emissions presented in Table 1 (which reflect the maximum construction

emissions included in the DEIR/EISs Table 3.13.4) are comprised of exhaust
emissions from off-road equipment and on-road haul trucks. Particulate emissions
(PM10 and PM2.5) include fugitive dust emissions from material handling as well.
Between 86 and 94 percent of the PM10 emissions and between 61 and 91 percent
of the PM2.5 emissions are due to fugitive dust. The DEIR/EIS includes a mitigation
measure that requires compliance with Caltrans Standard Specifications and Best
Available Control Measures from SCAQMD Rule 403, which requires, among other
things, that fugitive dust emissions be controlled by regular watering (DEIR/EIS, p.
3.13-40). However, the report does not identify any reductions in particulate matter
emissions for this mitigation measure or any of the other mitigation measures.
The Air Quality Assessment Report states (on page 5-2) that the construction
emissions assumed Tier 2 emission standards for all diesel-fueled off-road
equipment.
Off-road diesel engines have been subject to stricter emission
standards over time, referred to as Tiers. These emission limits apply to the engine
on the date it is sold and are based on the horsepower rating of the engines.
Figure 1 shows how these Tiers have been implemented. For each Tier, the years
that each tier was implemented are showncompliance dates were phased based
on engine power. The vertical axis of the chart shows the allowable particulate
emissions under each Tier and the horizontal axis shows the allowable NOX
emissions for each Tier. Table 2 presents the approximate reduction in emissions
compared to Tier 2 standards.

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Figure 1
Off-road Equipment Emission Standard Tiers

Table 2
Approximate Emissions Reductions From Off-road Engine
Tier 2 Standards
Particulate
Matter

NOx

Tier 3

0%

-33%

Tier 4 - Interim

-90%

-33%

Tier 4 - Final

-90%

-93%

To estimate emissions from on-road haul trucks, the DEIR/EIS analysis used
emission factors from EMFAC2011, CARBs on-road vehicle emissions model. The
emission factors represent the average emissions from all heavy trucks operating in
Los Angeles County. As with off-road equipment, heavy-duty diesel trucks (HDDT)
have been subject to stricter emission limits over time.
The most recent
regulations apply to model year 2007 and later HDDT. Model year 2007 and later
trucks emit 95 percent less PM10 and 92 percent less PM2.5 than the composite truck
assumed for the construction emissions calculations. NOX emissions reductions
were phased in between 2007 and 2010 with all trucks with a model year of 2010
or later emitting 96 percent less NOX than the emission calculations.
Section 3.13.4 of the DEIR/EIS (Pages 3.13-40 to 3.13-42) presents five measures
geared toward mitigating the projects construction emissions. However, there are
effectively only four measures because AQ-4 only applies to the Freeway Tunnel
Alternatives and AQ-5 only applies to the TSM/TDM, BRT, and LRT alternatives.
Measure AQ-1 (p. 3.13-41) just calls for compliance with SCAQMD Rule 403, which
calls for implementing fugitive dust measures as specified in SCAQMD Rule 403.
Rule 403 requires implementation of the Best Available Control Measures presented

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in Table 6.1 of the DEIR/EISs Air Quality Assessment Report. Rule 403 places
additional requirements on large operations, those involving more than 50 acres or
with a daily throughput of more than 5,000 cubic yards. The DEIR/EIS (p. 4-70)
indicates that with the Dual Bore Freeway Tunnel Alternative there would be up to
360 daily haul trucks and the air quality calculations indicate that haul trucks have
a 14 cubic yard capacity. This equates to just over 5,000 cubic yards. Therefore, it
would be likely that the Dual Bore Freeway Tunnel Alternative would need to
implement these additional measures. The Single Bore Freeway Tunnel and the LRT
may not.
Measure AQ-2 presents general measures to reduce exhaust emissions. These
include reducing trips, minimizing idling, using solar powered message signs, using
power pole electricity, maintaining engines, prohibiting tampering of engines, using
Tier 3 or better equipment with engine sizes greater than 75 HP, and using EPA
registered particulate traps. Measure AQ-3 requires the contractor to meet EPA
diesel fuel requirements, use alternative fuels where appropriate, and to identify
sensitive receptors in the immediate vicinity of construction and specify means to
minimize impacts to these populations.
Measure AQ-4 only applies to the Freeway Tunnel Alternative and simply requires
adherence to Caltrans Standard Specifications for Construction (Section 14-9.03
and 18 [Dust Control] and Section 39-3.06 [Asphalt Concrete Plant Emissions]).
The specification of asphalt concrete plant emissions is interesting because the
emissions calculations do not appear to include asphalt paving fugitive ROG
emissions. Section 14-9.03 requires the application of water, dust palliative or
both, if ordered and for soil stockpiles to be covered with a soil stabilization
material or temporary cover. Section 18 just provides specifications for the dust
palliative.
Measure AQ-5 only applies to the TSM/TDM, BRT, and LRT Alternatives. This
measure requires contractors to comply with the most current Metro Green
Construction Policy. This policy requires all off-road diesel powered construction
equipment greater than 50 HP to meet the Tier 4 emission standards. In addition,
equipment without a factory equipped diesel particulate filter is to be outfitted with
Best Available Control Technology (BACT) devices certified by CARB. All on-road
heavy-duty diesel trucks with a GVWR of 19,500 pounds or greater shall comply
with the EPA 2007 on-road emissions standards. In addition, the Metro Green
Construction Policy defines fifteen Best Management Practices. Several of these
Best Management Practices are included in Measure AQ-2 of the DEIR/EIS.
There is no justification given in the document for the Metro sponsored project
Alternatives to implement much more extensive, and effective, pollutant emissions
reduction measures than the Caltrans sponsored Freeway Tunnel Alternatives.
Metros construction policy was developed in consultation with the Ports of Los
Angeles and Long Beach and the Los Angeles World Airports based on their
experiences mitigating large construction projects and concludes that the additional
costs for the mitigation were not significant. The effective difference in the
mitigation measures is that the TSM/TDM, BRT and LRT alternatives would require
the use of Tier 4 final off-road equipment and 2007 or later on-road heavy duty
diesel trucks while the Freeway Tunnel Alternatives would require the use of the

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lesser stringent Tier 3 off-road equipment and would not place any restrictions on
on-road haul trucks.
As shown in Table 2 and Figure 1 above, assuming that Metros Green Construction
Policy was used for the TSM/TDM and BRT alternatives, NOX and particulate exhaust
emissions from off-road construction equipment would be reduced by around 93
percent. Because the LRT includes considerably more hauling, there would be a
slightly greater reduction in NOx emissions; hauling-related NOX emissions would be
reduced by 96 percent. Under the Freeway Tunnel Alternatives Mitigation,
particulate exhaust emissions would not be reduced and NOX emissions would be
reduced by less than 33 percent. Assuming the off-road equipment and haul trucks
account for the same amount of NOX emissions, the total NOX emissions would only
be reduced by about 16 percent.
To reduce NOX emissions to below the significance thresholds, mitigation for the
TSM/TDM and BRT alternatives would need to reduce NOX emissions by 89 and 51
percent respectively. It is possible that the Metro Green Construction Policies would
achieve these reductions. The LRT alternative requires a 96 percent reduction in
NOX emissions to be less than the significance threshold. The mitigation would
reduce these emissions by between 93 percent and 96 percent. The Green
Construction Policies would likely not reduce emissions to less than the significance
thresholds, but they would be near the threshold.
The Freeway Tunnel Alternatives would require NOX emissions reductions of 98
percent to be reduced below the SCAQMD Significance Threshold. The DEIR/EISs
proposed mitigation measure for the Freeway Tunnel Alternatives would reduce
NOx emissions by less than 33 percent. The Freeway Tunnel Alternatives should be
required to implement the measures outlined in the Metro Green Construction
Policy.
The Metro Green Construction Policy would reduce particulate exhaust emissions
from construction of the TSM/TDM and BRT alternatives by about 90 percent. LRT
reductions would be somewhat greater as haul truck PM10 emissions would be
reduced by about 95 percent and PM2.5 emissions would be reduced by about 92
percent. The mitigation proposed for the Freeway Tunnel Alternatives would not
result in any reduction in particulate emissions.
If the fugitive dust calculations include reductions from watering, then it is not
possible to reduce particulate emissions to below the SCAQMD thresholds as the
fugitive dust emissions themselves exceed the standard. If watering was accounted
for in the emissions calculations, then mitigated particulate emissions for the BRT
alternative would likely be less than the significance thresholds.
The measures
would likely reduce PM2.5 emissions to less than the threshold for the TDM/TSM
alternative, but PM10 emissions would likely be slightly above the threshold.
Even with 90% reductions in exhaust particulate emissions, it would not be possible
to reduce total particulate emissions to below the significance thresholds for the
LRT and Freeway Tunnel Alternatives. Fugitive dust emissions would need to be
reduced by between 78 and 90 percent. These levels of reduction are not feasible.
The LRT alternative would only need a 64 percent reduction in fugitive dust to

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reduce PM2.5 emissions to less than the standard. This could be achieved with three
times a day watering.
SCAQMD recommends assessing potential localized impacts from construction
activities, yet no such analysis was included in the DEIR/EIS. A localized impact
analysis, or as its often called, a hot-spots analysis, would determine whether or
not construction has the potential to either create any exceedances of the ambient
air quality standards (AAQS) or make worse any existing exceedances of the AAQS.
For small projects, SCAQMD has developed their Localized Significance Threshold
(LST) methodology that provides on-site emissions thresholds for projects of less
than five acres in size. The TDM/TSM alternative and portions of the LRT and BRT
alternatives should have been analyzed under this threshold. For those project
alternatives that are larger than five acres, e.g., the Freeway Tunnel Alternatives,
the DEIR/EIS should have performed dispersion modeling to determine pollutant
concentrations at nearby receptors.
Without this modeling, the DEIR cannot
conclude that construction will not result in a significant localized air quality impact.

3.2 The Particulate Matter Hotspot Assessment is Not Substantiated

The particulate hotspot analysis required by the Clean Air Act (Transportation
Conformity) is done in two steps. A qualitative analysis is performed to determine
if a project is a project of Air Quality Concern (POAQC) in terms of particulate
hotspots. If a project is determined to not be POAQC then no further analysis is
required. This determination is reviewed and approved by Caltrans, FHWA, and
EPA at SCAGs Transportation Conformity Working Group (TCWG). If the project is
a POAQC then a quantitative analysis is performed per guidance published by EPA.
The DEIR/EIS discusses how the TSM/TDM, BRT, and LRT alternatives were
determined to not be projects of Air Quality Concern (POAQC). The Freeway Tunnel
Alternatives were determined to be POAQC and will require quantitative particulate
hotspot analysis.
The DEIR/EIS included something of a quantitative particulate hotspot analysis.
However, the methodology used in this analysis is not well documented. What
information that does exists indicates that the DEIR/EIS preparers did not follow
EPA guidance. The DEIR/EIS does not identify the analytical steps in the analysis
and does not present the results of the analysis in a meaningful way. Because of
these flaws, it is not possible to determine the adequacy or accuracy of the
analysis. The particulate analysis consists of a discussion of the type of emissions
that were considered, a brief description of the dispersion models that were used,
and an overview of the input parameters. Although the results are presented in
Tables 3.13.7 through 3.13-9 of the DEIR/EIS and Tables 5.8 through 5.10 of the
Air Quality Assessment Technical Report, it is not clear what the values in these
tables actually represent. The Air Quality Report provides no clarification. Set forth
below is a detailed description of the flawed analysis.
First, the DEIR/EIS (p. 3.13-20) presents 13 locations that were identified as areas
of air quality concern followed by a discussion of the modeling parameters used to
represent the pollution sources (p. 3.31-21). These modeling parameters include
emission sources such as vehicle exhaust, vehicle fugitive emissions and tunnel
ventilation towers. However, all of the data presented in the discussion of modeling

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parameters are general parameters for each source type. The document does not
provide any specific input parameters such as specific roadways included in the
model and their traffic volumes, speeds and emission factors. Nor did the DEIR/EIS
identify the specific receptor locations.
The DEIR/EIS (p 3.13-22): The forecast average daily traffic data were applied to
appropriate emission factors to estimate emission for each of the segments along
the proposed alignment. Because the document mentions average daily traffic,
we are assuming the particulate hotspot modeling used the same errant
methodology as the Health Risk Assessment (HRA) to calculate daily and longer
average pollutant concentrations. However, the DEIR/EIS or Air Quality Assessment
Report did not include enough data regarding the particulate modeling to confirm
this assumption.
The HRA dispersion modeling and assumed particulate dispersion modeling
methodologies errs in the use of average daily traffic characteristics in the
dispersion modeling. In order to understand the effect of the use of average daily
traffic characteristics on the particulate hot spot analysis, it is important to first
understand details relating to dispersion modeling. Dispersion modeling uses the
location and quantity of pollutant emissions from each source and hourly weather
data to predict pollutant concentrations at specific receptor locations. For this
project, the sources of pollution are roadway segments and the tunnel ventilation
towers. In the model, roadway segments are represented as line segments and
ventilation towers are represented as points. The dispersion model calculates a
Dispersion Factor for each source/receptor pair for each hour of weather data. This
Dispersion Factor relates the amount of pollutants emitted by the source with the
concentration of pollutants at the receptor.
Pollutant concentrations at a receptor are inversely proportional to the Dispersion
Factor. A large Dispersion Factor indicates that the pollutant is spread out more
widely, while a low Dispersion Factor indicates the pollutant is more concentrated.
In low-wind conditions, Dispersion Factors at downwind receptors near the source
are low and increase for receptors further away from the source. Dispersion
Factors for up-wind receptors are higher than downwind receptors. During these
conditions, pollutants are not dispersed but tend to collect just downwind from the
source. As wind speed increases, the Dispersion Factors for receptors near the
source increase and the Factors for downwind receptors further from the source
decrease. Concentrations at close receptors decrease while concentrations at more
distant downwind receptors increase.
If wind blows in one direction with little side-to-side variation then receptors
directly downwind will have low Dispersion Factors and the Factors will increase to
each side. Most of the pollution will be directed towards receptors that are directly
downwind from the source. A more variable wind will increase Dispersion Factors
directly downwind and decrease those for receptors to each side compared to a
constant wind.
Directionally variable winds spread the downwind pollution
concentrations out side to side.
The DEIR/EISs modeling utilized five years of measured hourly weather data. That
is, 43,800 hourly Dispersion Factors were calculated for each source receptor pair.
That data encodes the dominant daily diurnal weather variations in Southern

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California. Calm nights and mornings and increasing on-shore breezes through the
day and evening that calm after sundown. However, it applies these Dispersion
Factors to hourly emission factors that do not account for diurnal traffic variations.
That is, the model assumes that the roadways are generating the same amount of
pollution at 2:00 a.m. as they are during the morning and evening peak commute
hours. In reality, the quantities of emissions during these periods are quite
different. Not only are there fewer vehicles operating during the late night hours,
but also speeds are increased, lowering the emissions per vehicle.
Accurate pollutant concentrations require accurate accounting of diurnal variation in
emissions. The use of average daily conditions would tend to compress the range
of concentrations. Areas where periods of high emission factors correspond with
low Dispersion Factors would have higher concentrations with accurate diurnal
modeling of traffic characteristics, rather than the average used in the DEIR/EIS.
Conversely, areas where periods of low emissions correspond with high Dispersion
Factors would have lower concentrations.
The project will result in changes in traffic patterns, which will result in
redistributing pollutants. Using a methodology that compresses the range of
concentrations results in an underestimation of the Projects effects on particulate
pollutant concentrations. In addition using this errant methodology could result in
compressing the differences between Project alternatives.
Section 5.3.2 of the EPAs Transportation Conformity Guidance for Quantitative
Hot-Spot Analyses in PM2.5 and PM10 Nonattainment and Maintenance Areas
describes the preferred methodology for accounting for diurnal traffic variation that
should have been utilized. This methodology separates the diurnal variation into
four periods, AM peak, midday average, PM Peak period, and overnight average.
This method adequately captures diurnal emission variations that are lost with the
use of average daily emission characteristics.
In addition to minimizing traffic volume variations, the methodology used for the
modeling also minimizes emission factor variations. The HRA dispersion modeling,
and we assume the particulate dispersion modeling, used the average daily speed
to determine emission factors.
Emission factors are speed dependent.
For
particulate matter, emissions are at a minimum between 35 and 40 mph, increasing
at lower and higher speeds. PM10 emission factors between 0 and 5 mph are
approximately 20% higher than the mid speed minimum emission factor and
approximately 7% higher between 65-70 mph.
PM10 emission factor are
approximately 40% higher between 0 and 5 mph and approximately 15% higher
between 65-70 mph.
Because emission factors and speed are not linearly
correlated multiplying the average traffic volume with the emission factor based on
average speed does not result in the average emissions.
An accurate average daily emission calculation world need to use the same
methodology as the regional emissions calculation, dividing the traffic volume into 5
mph speed increments and then multiplying the volume in each speed by the
appropriate emission factor and then summing and averaging. The use of average
speeds during the four modeling periods suggested by the EPAs methodology
would acceptably correct this error. However, this would need to be done for each
travel direction for each link.

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The HRA modeling, and we assume the particulate hotspot modeling, used the
average bi-directional speed to determine the emission factor. Because speed and
emission factors are not linearly related, this results in an incorrect estimate of
emissions. This is especially true for facilities with large directional splits in peak
hour traffic. The average vehicle speed on a facility that is congested in one
direction and free flow in the other would tend towards speeds with the lowest
emissions rates while traffic was traveling at mid-range speeds that generate higher
emission factors. Obviously, the emissions would be underestimated using the
average rate.
The results of the particulate hotspot modeling are also poorly documented. Tables
3.13.7 through 3.13.9 purport to show the Projects highest concentrations from
AERMOD. Although never stated, we assume that the analysis concludes that there
will be no particulate matter hotspot impacts because the with-project
concentrations are shown to be lower than the no build conditions. The CEQA
Analysis (Section 4.2.3) just states that if one of the Freeway Tunnel Alternatives
were selected that quantitative PM modeling would be conducted to demonstrate
that the project would not delay attainment of or cause an exceedance of the PM2.5
or PM10 NAAQS. It does not refer to the quantitative modeling results at all.
Assuming that the tables do depict the highest modeled concentrations, and
because there is no discussion of background concentrations, we assume that these
concentrations do not include background pollutant concentrations. The modeled
concentrations only include emissions from those sources included in the model,
freeways, arterials, and the tunnel ventilation towers. There are many other
pollution sources within and outside the project area that contribute to the overall
pollutant concentrations at the modeled receptors.
Comparing the modeled concentrations to measured levels appears to confirm that
they do not include background concentrations.
The modeled 24 hour PM2.5
concentration shown in Table 3.13.7 is just more than one tenth of the average of
the three most recent years of measured concentrations at the Main Street Los
Angeles monitoring station presented in Table 3.13.2. The modeled annual PM2.5
concentration is three and a half times lower than the measured and the 24-hour
PM10 concentration is four times lower.
The purpose of the particulate hot spot analysis is to determine whether the project
would create or worsen an exceedance of the ambient air quality standards. The
first step to evaluate this impact would be to determine if there are any existing
exceedances of the AAQS. This requires that the DEIR/EIS include the background
concentrations for sources not included in the model. Alternatively, if the EIR/EIS
seeks to demonstrate that concentrations with the project are less than no project
conditions, this analysis must be undertaken for ALL receptors, not just the
receptors with the highest concentration under each alternative. Moreover, the
DEIR/EIS errs further because it only addresses exceedances under the federal
AAQS. Under CEQA, exceedances of the state AAQS must be assessed as well.

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3.3 The Methodology Used to Determine Health Risk Impacts

Minimizes Differences Between Alternatives and
Underestimates Impacts
Our comments regarding the modeling methodology used for the particulate
hotspot analysis above also apply to the Health Risk Assessment (HRA). In fact,
they are more applicable to the HRA because the DEIR/EIS identifies the inputs for
the HRA but does not do so for the particulate analysis.
Specifically, the use of average daily traffic volumes and speeds to characterize the
emissions in the dispersion modeling does not provide accurate results. This flawed
methodology likely understates the Projects health risks. In addition, it tends to
minimize the differences between each of the Project alternatives. In order to
assess the impacts of each alternative, the modeling for the HRA must use EPA
methodology discussed above, i.e., AM peak period, mid-day average, PM peak
period, and overnight average.

3.4 The Conclusion of Health Risk Impact Significance Is Incorrect

The DEIR/EIS (Section 4.2.3; p. 4-8) states the HRA indicated that the project
would result in substantial regional benefits that reduce health risk from exposure
to MSATs in the majority of the study area. Attributing these reductions to the
project is erroneous and misleading. The considerable health risk reductions will
occur independent of the project due to turnover of older vehicles with newer
vehicles that comply with increasingly stringent vehicle emission standards. While
CEQA generally requires an analysis of a projects environmental impacts against a
baseline of existing conditions, in this instance, such a comparison would not
accurately depict the projects impact on air quality or health risk. A comparison of
future conditions to existing conditions does not provide an independent measure of
the Projects impacts. Instead, it demonstrates the effects of the implementation of
more stringent vehicle emissions standards in combination with the project.
Because this methodological approach incorrectly mixes the projects emissions
together with future background emission concentrations, there is no way to isolate
the emissions that would be generated by the Project.
The DEIR/EISs HRA Technical Report provides a more accurate indication of the
Projects health risk. Comparison of opening year conditions presented in Tables 34 through 3-6 and Figures 3-11 through 3-19 of the HRA present accurate
measures of the impacts of the project alternatives. These tables and figures show
that some areas will be exposed to cancer risk increases due to the project and
other will experience decreases. The tables and maps show that both residents and
workers would experience cancer risks greater than 10 in a million with the
Freeway Tunnel Alternatives. This is a significant increase in cancer risk. As
discussed above, these results are based on a modeling methodology that would
tend to minimize differences between projects. Therefore, the impacts of the
project alternatives are likely more extensive than shown.
The HRA Technical Report presents the results of the analysis in terms of cancer
risks. That is the risk of an individual developing cancer. A secondary measure of
impacts is the cancer burden. This is a measure of the total number of persons
that would be expected to contract cancer due to the Projects increased risks. This
is done by multiplying the cancer risk by the number of exposed persons, typically

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by census tract. The average risk for each census tract is determined and then
multiplied by the population. The results show risk increases in some areas and
risk decreases in other areas. A burden analysis would determine whether the
decreases outweighed the increases in terms of the number of persons impacted.
The HRA Technical Report discusses how a burden analysis would be performed if
the project were projected to increase cancer risk by more than 10 in million.
However, it did not perform this analysis because it incorrectly concluded that the
project would not increase the cancer risk by more than this amount. The HRA
shows locations where cancer risk would increase along with locations where they
would decrease.
The burden analysis would show how these increases and
decreases balanced when applied to actual populations. This analysis would be
required to conclude whether the project results in a net benefit or impact.
The DEIR/EISs analysis of non-cancer health effect impacts from the project is
even more problematic. Non-cancer health effects are measured by the acute
hazard index (HIA), and chronic hazard index (HIC). These values are a measure
of the potential for non-cancer health effects to occur. A value of less than one
indicates that no adverse non-cancer health effects are expected to occur. An
index of one indicates that sensitive persons will experience adverse non-cancer
health effects. Indices greater than one indicate that the adverse non-cancer
health effects will be more severe and pervasive but it does not show how much
more severe or pervasive the adverse health effects would be. The hazard indices
do not measure changes in non-cancer health effects but are a threshold at which
adverse health effects begin to occur.
The HRA assesses non-cancer health effects of the project by examining the change
in hazard index with the project over no project conditions. The DEIR/EIS asserts
that if the project increases the index by one, then the impact is significant. Under
this condition the project, by itself, with no other air pollutant emissions, would
result in pollutant concentrations high enough to cause adverse non-cancer health
impacts. The DEIR/EIS shows that this condition does not occur. However, the
DEIR/EIS does not to analyze the impact that can occur when existing conditions
are properly accounted for. This impact occurs when the hazard index at a receptor
is increased from below one without the project, where there is no adverse health
effect, to greater than one with the project and causing an adverse health effect at
the receptor. In this case, the Project results in an impact when considered in
combination with all other existing pollutant emissions. The DEIR/EIS needs to
present the overall hazard index that includes all sources of pollutants for each
alternative to determine the threshold of one is exceeded. If a hazard index
exceeds one then the project creates or makes worse an adverse health impact..

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3.5 Greenhouse Gas Emission Calculations Do Not Include Those

From Electrical Consumption
The greenhouse gas (GHG) emissions presented in the Air Quality Assessment
Report and the DEIR only include those emitted from vehicles within the study area.
GHG Emissions will also be produced through the generation of electricity used by
the project. Emissions of criteria pollutants from electrical generation faculties are
not included in those calculations because any new electrical generation emissions
would come from outside the air basin and would not contribute to air quality levels
within the basin. However, greenhouse gasses are a global issue and the location
of the emissions is not relevant.
GHG emissions from electrical generation are dependent on the provider of the
electricity. One-megawatt hour of electricity generates approximately 0.56 metric
tons of CO2EQ if purchased from Los Angeles Department of Water and Power. If
purchased from Pasadena Department of Water and Power, one megawatt of
electricity generates approximately 0.76 metric tons of CO2EQ. One megawatt of
power purchased from Southern California Edison generates approximately 0.29
metric tons of CO2EQ. These emission factors come from SCAQMDs California
Emissions Estimator Model (CalEEMod).
For the TDM/TSM and BRT alternatives, electrical requirements would be expected
to be minimal, as would the anticipated emissions.
The Freeway Tunnel
Alternatives would consume electricity for tunnel lighting and the tunnel ventilation
system. This could result in considerable GHG emission that should be reported in
the DEIR/EIS. The LRT would consume the most electricity of the Build Alternatives
and the non-inclusion of the GHG emissions associated with electricity in the
reported emissions is a significant omission.
We were not able to find any data regarding the energy consumption of LA Metros
LRT cars. Dallas Area Rapid Transit LRT cars are similar to LA Metros and consume
an average of 288 kilowatt-hours of electricity per car per hour of operation
(https://www.dart.org/newsroom/dartrailfacts.asp). Assuming just two cars per
train and a 20-minute one-way travel time, the 326 daily one-way trains would
generate between 65 and 170 metric tons of CO2EQ per day. This equates to
between approximately 23,400 and 61,700 metric tons of CO2EQ per year. These
are just the emissions for train propulsion and do not include electricity consumed
by other components of the project such as lighting and ventilation. For the LRT
Alternative, increased GHG emissions due to electrical generation are much greater
than the increase due to vehicular travel. The DEIR/EIS shows that the LRT
Alternative is anticipated to reduce vehicular emissions by 20 metric tons per day in
the 2025 opening year and by 2.2 metric tons per day in 2035. However, the GHG
emissions produced by the generation of electricity used to propel the trains will
more than offset these reductions.

SR-710 North Study DEIR/EIS

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3.6 Traffic Modeling Deficiencies

Air pollutant emission predictions are based on traffic volumes and speeds. The
review of the traffic study prepared for 5-Cities Alliance performed by
Nelson\Nygaard Consulting Associates Inc. identified two issues that affect the
DEIR/EISs modeled traffic volumes that would also affect air pollutant impacts due
to the project, spillback and induced traffic.
The Nelson/Nygaard traffic study notes that the traffic modeling did not adequately
account for spillback that would occur when projected traffic volume on a road
segment exceeds capacity. That is, vehicles are assumed to queue and wait their
turn to pass through such bottlenecks. In reality, this large queue would not occur
and travelers would adjust their behavior to avoid such bottlenecks with many
finding alternative routes on arterial roadways in the project study area. This
results in an under prediction of arterial road traffic volumes. If the DEIR/EISs
traffic modeling accounted for spillback, the traffic volume increases along local
roadways could result in localized hot-spot impacts and cancer risk increases could
be more widely dispersed, this traffic would generally travel at lower speeds on the
arterial roadways and result in greater emissions.
A second important issue raised in the Nelson Nygaard report relates to induced
travel. As more freeway lane miles and alternative routes are introduced, driving
becomes a more convenient option. This serves to induce more vehicle trips from
people who otherwise would not have traveled via car or made that trip altogether.
That is, as congestion is decreased, people will decide to make trips that they would
not have previously made because of congestion. The Nelson Nygaard traffic study
notes that the DEIR/EISs travel demand model cannot be trusted to accurately
estimate this induced travel. Further, the Nelson/Nygaard study explains, that
even if the model accurately reflected induced travel, the time period analyzed in
the EIR/EIS is too short. Research shows roadway projects can result in short-term
reductions in congestion due the increased capacity. However, over time, the
reduced congestion induces more trips to the point where the same level of
congestion as without the project is reachedbut with a larger number of vehicles.
Proper accounting for spillback and induced traffic in the traffic model would
increase pollutant emissions estimates in two ways. The increased traffic would
increase congestion and lower speeds resulting in increased emissions per mile
traveled and it would increase the vehicle miles traveled. The VMT increase would
cause a proportional increase in emissions. That is, a one percent increase in VMT
would result in a one percent increase in emissions. The increase due to the
change in speed is more complex and not easily estimated.
The additional induced traffic would also result in increased pollutant concentrations
and cancer risks with the project alternatives compared to no project conditions.

SR-710 North Study DEIR/EIS

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Appendix Reference Documents

Los Angeles County Metropolitan Transit Authority Green
Construction Policy
Environmental Protection Agency Transportation Conformity
Guidance for Quantitative Hot-Spot Analyses in PM2.5 and PM10
Nonattainment & Maintenance Areas
South Coast Air Quality Management District Finalized Localized
Significance Threshold Methodology

Los Angeles County

Metropolitan Transportation Authority

One Gateway Plaza

Los Angeles, CA 90012-2952

43

Metro
EXECUTIVE MANAGEMENT AND AUDIT COMMITTEE
CONSTRUCTION COMMITTEE
JULY 21, 2011

SUBJECT: GREEN CONSTRUCTION POLICY

ACTION: ADOPT GREEN CONSTRUCTION POLICY

RECOMMENDATION
Adopt the Los Angeles County Metropolitan Transportation Authority (LACMTA) Green
Construction Policy for implementation on construction projects conducted on LACMTA
properties and rights-of-way. Phase the implementation of this policy, through a
collaborative process, for implementation by other jurisdictions that receive/program
LACMTA funding (in whole or in part) for construction projects.

ISSUE
Expediting the LACMTAs Measure R Initiative through the America Fast Forward
Program will reduce overall emissions and get people out of their cars and onto transit
sooner. However, the potential to create significant harmful emissions from traffic
congestion and those associated with construction activities and existing non-mitigated
legacy construction equipment usage remains high. This concern is echoed by the US
Environmental Protection Agency (USEPA), the South Coast Air Quality Management
District (SCAQMD), and various non-profit environmental organizations in the last few
months through comment letters to LACMTAs environmental documents, or in public
meetings. Specifically, the USEPA and the SCAQMD have recommended through
those forums that the LACMTA either implement best management practices or require
the use of cleaner on-road and off-road equipment to mitigate particulate matter (PM)
and nitrogen oxide (NO,,) compound emissions.
The development and implementation of a Green Construction Policy was advanced in
a motion sponsored by Director Richard Katz and approved by the LACMTA Board of
Directors on December 9, 2010. An LACMTA Board approved Green Construction
Policy will facilitate agency-wide and uniform implementation of cost-effective solutions
to this recognized air quality issue.

DISCUSSION
Staff presented a Draft Green Construction Policy during the March 2011 and June
2011 Executive Management and Audit Committee meetings. Additional guidance was
given by our Board of Directors during those meetings to ensure the development of a
comprehensive policy, consistent with the intent of Director Katzs December 2010
motion; but more importantly considers issues associated with the implementation of
such a policy outside of the LACMTA jurisdiction. Additional considerations would
include lessons learned from the policies, guidelines, or framework of other jurisdictions
within our region specifically those of the Port of Los Angeles, Port of Long Beach, and
Los Angeles World Airports (LAWA).
Over the course of four months, staff had conducted separate meetings with various
stakeholders that included non-profit environmental organizations, construction
contractors, manufacturers of retrofit equipment; as well as representatives of the South
Coast Air Quality Management District, Port of Los Angeles, Port of Long Beach, and
Los Angeles World Airports. The meetings were designed not only to develop a more
comprehensive LACMTA Green Construction Policy but to gain consensus on language
and provisions that should be included in the policy. Additional meetings were
conducted in June and July to gain input from Metros Technical Advisory Committee,
Metro Streets and Freeways Sub-Committee, Metro Transit Business Advisory Council,
Northern Corridor Cities Meeting, Antelope Valley Air Quality Management District, Los
Angeles County Department of Public Works, and Small Business Outreach meeting to
discuss the policy. After going through this extensive outreach, the Green Construction
Policy included in Attachment A is attached for Board consideration. This policy
includes a commitment for the immediate adoption of the policy on construction projects
conducted on LACMTA properties and rights-of-way. The policy will be phased,
through a collaborative process, for implementation by other jurisdictions that
receive/program LACMTA funding (in whole or in part) for construction projects.
Staffs recommendation to adopt this LACMTA Green Construction Policy is in line with
the clean construction requirements already existing in New York, Illinois (Cook Co.),
and Rhode Island (Providence), among others. Locally, the Port of Los Angeles, Port
of Long Beach, and LAWA have already incorporated clean construction requirements
into their specifications.
From an informal survey of transit agencies nationwide [through the American Public
Transportation Association (APTA)], it appears that only a handful of our peers have
considered clean/green construction equipment requirements. There appears to be no
transit agency at this time that has adopted such a policy. With the adoption of this
policy, we will be the industry leader in the APTA community.

LACMTA Green Construction Policy

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FINANCIAL IMPACT
LAWA and Port of Los Angeles staffs have been implementing clean construction
requirements in their construction activities. Specifically to LAWA, they have indicated
that the cost to implement these requirements in total, including the labor associated
with contractor bid costs, an Independent Third Party Monitor, environmental
management contractor staff, plus the cost for retrofitting the off-road construction
vehicles with diesel emission control systems, is approximately 0.3% of the overall
construction costs on one of their $150 million projects. In LAWA staffs opinion, the
costs to do the same level of effort would conservatively be around 0.5% on a typical
construction project.
The Contractor or equipment owner (in cases where construction equipment is leased)
is responsible for all costs of purchase, installation, and maintenance of retrofit device
or any new construction equipment required by the policy. The Contractor shall also be
responsible for any compliance costs to be incurred by any of their subcontractors.
Finally, no Contractor shall be given a competitive advantage or disadvantage as a
result of the policy. Costs for complying with the policy shall not be considered by
LACMTA in evaluating bids.
As indicated in the policy, the LACMTA will provide information to the Contractor and
their subcontractors in identifying and applying for grants and loans that are available
for the greening of existing construction equipment or purchase of new green
construction equipment.

ALTERNATIVES CONSIDERED
Rejection of the recommended Board action is inconsistent with the intent of the Board
approved motion to develop this policy. Rejection of the staff recommendation is also
inconsistent with the provisions of our Board adopted Environmental Policy that
specifically commits to specific actions in mitigating environmental and human health
impacts, while maintaining sustainable operations.

NEXT STEPS
After the proposed Green Construction Policy is adopted by the LACMTA Board, staff
will incorporate the requirements of this policy in all future procurement contracts. It is
not retroactive. Staff will encourage Contractors that work on existing construction
projects in LACMTA properties or rights-of-way to implement the provisions of this
policy to the greatest extent feasible. Staff will develop a collaborative process to
phase the implementation of this policy in other jurisdictions that receive/program
LACMTA funding (in whole or in part) for construction projects.

LACMTA Green Construction Policy

Page 3

ATTACHMENT

A.

LACMTA Green Construction Policy

Prepared by: Cris B. Liban, Environmental Compliance and Services Department

Manager

LACMTA Green Construction Policy

Page 4

Krishniah N. Murthy
Executive Director, Project Transit Delivery

&,H- 7, 4ir
Arthur T. Leahy
Chief Executive Officer

LACMTA Green Construction Policy

Page 5

ATTACHMENT A
LACMTA GREEN CONSTRUCTION POLICY
POLICY STATEMENT
The Los Angeles County Metropolitan Transportation Authority (LACMTA) will only use
greener, less polluting construction equipment and vehicles; and implement best
practices to meet or exceed air quality emission standards in all construction projects
performed on LACMTA properties and rights-of-way. Phase the implementation of this
policy, through a collaborative process, for implementation by other jurisdictions that
receive/program LACMTA funding (in whole or in part) for construction projects.

PURPOSE
This policy provides requirements for 1) identifying and mitigating air emission impacts
on human health, environment, and climate of on-road and off-road construction
equipment and generators used in our construction and development activities; 2)
implementing appropriate Best Management Practices (BMP) to complement
equipment mitigations; and 3) implementing strategies to ensure compliance with this
policy.
This policy is effective and enforceable immediately upon adoption for all new
construction projects. This policy is not retroactive. However, for all existing
construction projects [i.e., where contracts have already been awarded], LACMTA will
encourage all Contractors to implement the provisions of this policy to the greatest
extent feasible. The intent of this policy is to reduce harmful air emissions (particularly
particulate matter and nitrogen oxides) while minimizing any significant impact to cost
and schedule in any existing construction project. Nothing in this policy shall require a
retrofit that does not meet California OSHA standards.

COMMITMENTS
The LACMTA is an international leader in implementing environmental and
sustainability principles in all of its planning, construction, operations, and procurement
activities. The LACMTA commits to the following construction equipment requirements,
construction BMPs, and implementation strategies for all of its construction projects
performed on LACMTA properties or rights-of-way. The implementation of this policy
will be phased, through a collaborative process, for implementation in other jurisdictions
that receive/program LACMTA funding (in whole or in part) for construction projects.

LACMTA Green Construction Policy

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CONSTRUCTION EQUIPMENT
Through this Green Construction Policy, the LACMTA commits to ensuring that all of
the on-road and off-road equipment used in its construction activities are green and
less-polluting as follows:
Construction Equipment (excluding On-Road Equipment)

1)

Construction equipment shall incorporate, where feasible, emissions-reducing

technology such as hybrid drives and specific fuel economy standards.

2)

Idling shall be restricted to a maximum of 5 minutes, except as provided in the

exceptions to the applicable CARB regulations regarding idling.

3)

Equipment Engine Specifications:

a. Prior to December 31, 2011: All off-road diesel-powered construction
equipment greater than 50 horsepower (hp) shall meet Tier-2 off-road
emission standards at a minimum. In addition, all construction equipment
greater than 50 hp shall be retrofitted with a CARB-verified Level 3 Diesel
Emissions Control Device system (DECS).
b. From January 1, 2012, to December 31, 2014: All off-road dieselpowered construction equipment greater than 50 hp shall meet Tier-3 offroad emission standards at a minimum. In addition, all construction
equipment greater than 50 hp shall be retrofitted with a CARB-verified
Level 3 DECS. Any emissions control device used by the Contractor shall
achieve emissions reductions that are no less than what could be
achieved by a Level 3 diesel emissions control strategy for a similarly
sized engine as defined by CARB regulations.
c. From January 1, 2015 and onwards: All off-road diesel-powered
construction equipment greater than 50 hp shall meet Tier-4 off-road
emission standards at a minimum. In addition, if not already supplied with
a factory-equipped diesel particulate filter, all construction equipment shall
be outfitted with Best Available Control Technology (BACT) devices
certified by CARB. Any emissions control device used by the Contractor
shall achieve emissions reductions that are no less than what could be
achieved by a Level 3 diesel emissions control strategy for a similarly
sized engine as defined by CARB regulations.

On-Road Equipment

1) Trucks or equipment hauling material such as debris or any fill material shall be
fully covered while operating at, to and from the LACMTA construction project.

LACMTA Green Construction Policy

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2) Idling shall be restricted to a maximum of 5 minutes, except as provided in the

regulations
regarding
idling.
applicable
CARB
exceptions
to
the
3) EPA Standards:
a)

Prior to December 31, 2013: All on-road heavy-duty diesel trucks or

equipment with a gross vehicle weight rating (GVWR) of 19,500 pounds or
greater shall meet or exceed the EPA 2007 on-road emission standards
for PM (0.01 g/bhp-hr); or shall be equipped with a CARB verified Level 3
diesel particulate filter.

b) From January 1, 2014 and onwards: All on-road heavy-duty diesel

trucks or equipment with a GVWR of 19,500 pounds or greater shall
comply with EPA 2007 on-road emission standards for PM and NO (0.01
g/bhp-hr and at least 1.2 g/bhp-hr, respectively).
r trrc

Every effort shall be made to utilize grid-based electric power at any construction
site, where feasible. Where access to the power grid is not available, on-site
generators must:
1)

Meet a 0.01 gram per brake-horsepower-hour standard for PM, or

2)

Be equipped with BACT for PM emissions reductions.

Exceptions
These on-road and off-road construction equipment and generator requirements shall
apply unless any of the following circumstances exist and the Contractor provides a
written finding consistent with project contract requirements that:
1) The Contractor intends to meet the requirements of this policy as to a particular
vehicle or piece of equipment by leasing or short-term rental, and the Contractor
has attempted in good faith and due diligence to lease the vehicle or equipment
that would comply with this policy, but that vehicle or equipment is not available
for lease or short-term rental within 200 miles of the project site, and the
Contractor has submitted documentation to LACMTA showing that the
requirements of this Exception provision apply.
2) The Contractor has been awarded funding by SCAQMD or another agency that
would provide some or all of the cost to retrofit, repower, or purchase a piece of
equipment or vehicle, but the funding has not yet been provided due to
circumstances beyond the Contractors control, and the Contractor has
attempted in good faith and due diligence to lease or short-term rent the

LACMTA Green Construction Policy

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equipment or vehicle that would comply with this policy, but that equipment or
vehicle is not available for lease or short-term rental within 200 miles of the
project site, and the Contractor has submitted documentation to LACMTA
showing that the requirements of this Exception provision apply.
3) Contractor has ordered a piece of equipment or vehicle to be used on the
construction project in compliance with this policy at least 60 days before that
equipment or vehicle is needed at the project site, but that equipment or vehicle
has not yet arrived due to circumstances beyond the Contractors control, and
the Contractor has attempted in good faith and due diligence to lease or shortterm rent a piece of equipment or vehicle to meet the requirements of this
policy, but that equipment or vehicle is not available for lease or short-term
rental within 200 miles of the project, and the Contractor has submitted
documentation to LACMTA showing that the requirements of this Exception
provision apply.
4) Construction-related diesel equipment or vehicle will be used on an LACMTA
construction project site for fewer than 10 calendar days per calendar year. The
Contractor shall not consecutively use different equipment or vehicles that
perform the same or a substantially similar function in an attempt to use this
Exception to circumvent the intent of this policy.
In any of the situations described above, the Contractor shall provide the next cleanest
piece of equipment or vehicle as provided by the step down schedules in Table A for
Off-Road Equipment and Table B for On-Road Equipment.
Table A. Off-Road Compliance Step Down S chedule *

CA RB-verified DECS (VDECS)

Engine Standard
Compliance Alternative
N/A**
Tier
4
1
Level
Tier
2
Level
Tier
3
Level
Tier 1
4
Level
Tier
5
Level 1
Tier
6
Uncontrolled
Tier 2
7
Level
Tier
8
Equipment less than Tier 1, Level 2 shall not be permitted.

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Table B On-Road Compliance Step Down S chedule *

Compliance Alternative
1
2
3
4
5
6

Engine Model Year

2010
2007
2004
1998
2004
1998

CA RB- Verified DECS (VDECS)

N/A
N/A**
Level
Level
Uncontrolled
Uncontrolled

Equipment with a model year earlier than Model Year 1998 shall not be permitted.
*How to use Table A and Table B: For example, if Compliance Alternative #3 is required by this policy

but a Contractor cannot obtain an off-road vehicle that meets the Tier 2 engine standard that is equipped
with a Level 3 DECS (Compliance Alternative #3 in Table A) and meets one of the above exceptions, then
the Contractor shall use a vehicle that meets the next compliance alternative (Compliance Alternative #4)
which is a Tier 1 engine standard equipped with a Level 3 DECS. Should the Contractor not be able to
supply a vehicle with a Tier 1 engine equipped with a Level 3 DECS in accordance with Compliance
Alternative #4 and has satisfied the requirements of one of the above exceptions as to the Contractors
ability to obtain a vehicle meeting Compliance Alternative #4, the Contractor shall then supply a vehicle
meeting the next compliance alternative (Compliance Alternative #5), and so on. If the Contractor is
proposing an exemption for on-road equipment, the step down schedule in Table B should be used. A
Contractor must demonstrate that it has satisfied one of the exceptions listed in the selected Compliance
Alternative # before it can use a subsequent Compliance Alternative. The goal is to ensure that the
Contractor has exercised due diligence in supplying the cleanest fleet available.
**Tier 4 or 2007 Model Year equipment not already supplied with a factory-equipped diesel particulate
filter shall be outfitted with Level 3 VDECS.

BEST MANAGEMENT PRACTICES

In addition to equipment requirements, the Best Management Practices (BMP5) listed
below are imposed on all construction projects that performed on LACMTA properties
and rights-of-way.
BMPs shall include, at a minimum:
1)

Use of diesel particulate traps or best available control technology, as feasible;

2)

Maintain equipment according to manufacturers specifications;

3)

Restrict idling of construction equipment and on-road heavy-duty trucks to a

maximum of 5 minutes when not in use, except as provided in the exceptions
to the applicable CARB regulations regarding idling for off-road and on-road
equipment;

LACMTA Green Construction Policy

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4)

Maintain a buffer zone that is a minimum of 1,000 feet between truck traffic and
sensitive receptors, where feasible;

5)

Where applicable and feasible, work with local jurisdictions to improve traffic
flow by signal synchronization;

6)

If feasible and as allowed by local jurisdictions, configure construction parking

to minimize traffic interference;

7)

Enforce truck parking restrictions, where applicable;

8)

Prepare haul routes that conform to local requirements to minimize traversing

through congested streets or near sensitive receptor areas;

9)

Provide dedicated turn lanes for movement of construction trucks and

equipment on- and off-site, as feasible;

1 0) Schedule construction activities that affect traffic flow on the arterial system to
off-peak hours to the extent practicable;
11) Use electric power in lieu of diesel power where available; and
12) Traffic speeds on all unpaved roads to be 15 mph or less.

IMPLEMENTATION
The following shall be incorporated to ensure proper compliance with this policy.
Not/f/cat/on
Contractors of construction activities that are located within 1,000 feet of
sensitive receptors shall notify each of these sites in writing at least 30 days
before construction activities begin. Notification shall include the name of the
project, a description of the location, the acreage of the construction site, the
type and quantity of equipment and vehicles that will be operating at or near the
site, the start date and reasonably anticipated duration of the construction, and
contact information for a LACMTA community liaison who can answer any
questions.
Enforcement
Each solicitation by LACMTA for a construction project contract and each
contract entered into as a result of such solicitation shall include provisions
authorizing enforcement of the requirements of this policy.
Violations of any of the requirements of this policy shall be deemed to be a
material breach of the Contractor agreement, and LACMTA shall have available

LACMTA Green Construction Policy

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all remedies including warnings, fines, requirement to remove equipment,

institution of special assessments, and termination of contract.
LACMTA shall conduct inspection of construction sites and affected off-road and
on-road equipment and generator as well as compliance with air quality rules.
These inspections will be conducted as part of existing LACMTA staff functions
and without advance notice to the Contractor.
Records

Prior to Notice to Proceed (NTP) to commence construction project and to be

verified afterwards consistent with project contract requirements and through
enforcement provisions above, the Contractor shall submit to LACMTA the
following information for all construction equipment to be used in all construction
projects on LACMTA properties or rights-of-way:
1) A certified statement that all construction equipment used conform to the
requirements specified above;
2) A list of all the equipment and vehicles [i.e., for off-road equipment,
include the CARB-issued Equipment Identification Number (EIN)] to be
used;
3) A copy of each Contractors certified EPA rating and applicable paperwork
issued either by CARB, SCAQMD and any other jurisdiction that has
oversight over the equipment; and
4) The name, business address, e-mail address, and phone number for the
individual person responsible for each of the pieces of equipment and
vehicles subject to this policy.
If an unanticipated need for the use of equipment or a vehicle arises after
construction has commenced or after the Contractor has submitted the
information required by the above subsections (1)(4), the Contractor shall
provide such information for the unanticipated equipment or vehicle within 14
days after an identified emergency or when the need arises and prior to the use
of the equipment or vehicle.
Quantification and Reporting of Emission Reductions

No later than 18 months after the date the LACMTA Board of Directors adopts
this policy, and annually thereafter, LACMTA shall develop a summary report
presented to the Board and available on the LACMTA website which shall
include:

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1) A description of the implementation of this policy;

2) Quantification of the resulting PM and NO emission reductions;
3) A list and description of monitoring and enforcement actions;
4) A description of other appropriate measures of progress;
5) A description of the outreach of this policy in other jurisdictions that
receive/program LACMTA funding (in whole or in part) for construction
projects;
6) A description of implementation problems encountered and
opportunities for additional reductions in emissions; and
7) Recommendations for any statutory or policy changes.
Implementation and Compliance Costs

The Contractor or equipment or vehicle owner (in cases where the equipment or
vehicle is leased) is responsible for all costs of purchase, installation, and
maintenance of retrofit devices or any new construction equipment required by
this policy. The Contractor shall also be responsible for any compliance costs to
be incurred by any of their subcontractors.
The LACMTA will provide information to the Contractor and their subcontractors
to aid in the identification of and application for grants and loans that are
available for the retrofit or repower of existing construction equipment or
purchase of new green construction equipment.
No Contractor shall be given a competitive advantage or disadvantage as a
result of this policy. Costs for complying with this policy is a part of the
Contractors bid and will not have any consideration in evaluating bids.
DEFINITIONS
Best Available Control Technology (BACT) is defined as technology, verified by
CARB, for an off-road vehicle that achieves reductions in PM emissions at the
highest applicable classification level for diesel emission control strategies. A
summary of CARB-verified diesel emission control strategies may be found at
http://www.arb.ca.Qov/diesel/verdev/vt/cvt.htm . Where this policy requires BACT,
this requirement can be satisfied by a factory installed equivalent device, such as
a diesel particulate filter.

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Classification Levels are defined as levels of diesel emission control retrofit

technologies, with Level 3 being the highest classification level, and the only
level acceptable for a retrofit under this policy, except as provided for in this
policy:
Level 3 is defined as retrofit technology that reduces diesel PM emissions
by 85 percent or greater or reduces engine emissions to less than or
equal to 0.01 grams diesel PM per brake horsepower-hour;
. Level 2 is defined as retrofit technology that reduces diesel PM emissions
by between 50 and 84 percent;
Level 1 is defined as retrofit technology that reduces diesel PM emissions
by between 25 and 49 percent.

Construction Project is defined as a project that is performed on LACMTA

properties or rights-of-way. If the project is performed in collaboration with
another agency or agencies or parties, including where the other agency or
agencies or parties have the lead responsibility for construction, LACMTA shall
discuss with those agencies or parties the incorporation of the provisions of this
Green Construction policy into all agreements, including Memoranda of
Understanding, between LACMTA and the other agency or agencies or parties.
Until such time, provisions of this policy shall only be used as a guideline in
performing construction projects that receive/program LACMTA funds in whole or
in part.
Sensitive Receptor Site is defined as a site that is within the definition provided in
the CARB Air Quality and Land Use Planning Guidelines (2005)
(www.arb.ca.ciov/ch/landuse.htm) such as schools, daycares, playgrounds, and
hospitals.

LACMTA Green Construction Policy

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Transportation Conformity Guidance for

Quantitative Hot-Spot Analyses in

PM2.5 and PM10 Nonattainment and

Maintenance Areas

Transportation and Climate Division

Office of Transportation and Air Quality
U.S. Environmental Protection Agency

EPA-420-B-13-053
November 2013

Table of Contents
LIST OF EXHIBITS .................................................................................................................................... V

LIST OF APPENDICES ............................................................................................................................ VI

SECTION 1: INTRODUCTION ................................................................................................................. 1

1.1
1.2
1.3
1.4
1.5
1.6
1.7
1.8

PURPOSE OF THIS GUIDANCE.................................................................................................... 1

TIMING OF QUANTITATIVE PM HOT-SPOT ANALYSES ................................................................ 1

DEFINITION OF A HOT-SPOT ANALYSIS ..................................................................................... 2

PROJECTS REQUIRING A PM HOT-SPOT ANALYSIS ..................................................................... 2

OTHER PURPOSES FOR THIS GUIDANCE .................................................................................... 3

ORGANIZATION OF THIS GUIDANCE ......................................................................................... 3

ADDITIONAL INFORMATION ..................................................................................................... 4

GUIDANCE AND EXISTING REQUIREMENTS .............................................................................. 5

SECTION 2: TRANSPORTATION CONFORMITY REQUIREMENTS............................................. 6

2.1
2.2
2.3
2.4
2.4.1
2.4.2
2.4.3
2.5
2.5.1
2.5.2
2.5.3
2.5.4
2.5.5
2.6
2.7
2.8
2.9
2.9.1
2.9.2
2.9.3
2.9.4

INTRODUCTION ........................................................................................................................ 6

OVERVIEW OF STATUTORY AND REGULATORY REQUIREMENTS ............................................... 6

INTERAGENCY CONSULTATION AND PUBLIC PARTICIPATION REQUIREMENTS .......................... 8

HOT-SPOT ANALYSES ARE BUILD/NO-BUILD ANALYSES ........................................................... 9

General ................................................................................................................................... 9

Suggested approach for PM hot-spot analyses ....................................................................... 9

Guidance focuses on refined PM hot-spot analyses ..............................................................11

EMISSIONS CONSIDERED IN PM HOT-SPOT ANALYSES..............................................................13

General requirements ............................................................................................................13

PM emissions from motor vehicle exhaust, brake wear, and tire wear .................................13

PM2.5 emissions from re-entrained road dust.........................................................................13

PM10 emissions from re-entrained road dust .........................................................................13

PM emissions from construction-related activities................................................................14

NAAQS CONSIDERED IN PM HOT-SPOT ANALYSES ...................................................................14

BACKGROUND CONCENTRATIONS...........................................................................................14

APPROPRIATE TIME FRAME AND ANALYSIS YEARS .................................................................15

AGENCY ROLES AND RESPONSIBILITIES ..................................................................................16

Project sponsor......................................................................................................................16

DOT .......................................................................................................................................16

EPA ........................................................................................................................................16

State and local transportation and air agencies ....................................................................16

SECTION 3: OVERVIEW OF A QUANTITATIVE PM HOT-SPOT ANALYSIS .............................18

3.1
3.2
3.3
3.3.1
3.3.2
3.3.3
3.3.4
3.3.5
3.3.6
3.3.7
3.4
3.5
3.6
3.7

INTRODUCTION .......................................................................................................................18

DETERMINE NEED FOR A PM HOT-SPOT ANALYSIS (STEP 1) .....................................................18

DETERMINE APPROACH, MODELS, AND DATA (STEP 2)............................................................18

General ..................................................................................................................................18

Determining the geographic area and emission sources to be covered by the analysis ........20

Deciding the general analysis approach and analysis year(s) ..............................................20

Determining the PM NAAQS to be evaluated ........................................................................21

Deciding on the type of PM emissions to be modeled............................................................22

Determining the models and methods to be used...................................................................22

Obtaining project-specific data .............................................................................................22

ESTIMATE ON-ROAD MOTOR VEHICLE EMISSIONS (STEP 3) .....................................................23

ESTIMATE EMISSIONS FROM ROAD DUST, CONSTRUCTION, AND ADDITIONAL SOURCES

(STEP 4) ..................................................................................................................................23

SELECT AN AIR QUALITY MODEL, DATA INPUTS AND RECEPTORS (STEP 5) ..............................23

DETERMINE BACKGROUND CONCENTRATIONS FROM NEARBY AND OTHER SOURCES

(STEP 6) ..................................................................................................................................24

3.8
3.9
3.10

CALCULATE DESIGN VALUES AND DETERMINE CONFORMITY (STEP 7)....................................24

CONSIDER MITIGATION OR CONTROL MEASURES (STEP 8) ......................................................24

DOCUMENT THE PM HOT-SPOT ANALYSIS (STEP 9)..................................................................25

SECTION 4: ESTIMATING PROJECT-LEVEL PM EMISSIONS USING MOVES ........................26

4.1
4.2
4.2.1
4.2.2
4.3
4.3.1
4.3.2
4.3.3
4.4
4.4.1
4.4.2
4.4.3
4.4.4
4.4.5
4.4.6
4.4.7
4.4.8
4.4.9
4.4.10
4.4.11
4.5
4.5.1
4.5.2
4.5.3
4.5.4
4.5.5
4.5.6
4.5.7
4.5.8
4.5.9
4.6
4.6.1
4.6.2

INTRODUCTION .......................................................................................................................26

CHARACTERIZING A PROJECT IN TERMS OF LINKS ...................................................................28

Highway and intersection projects ........................................................................................29

Transit and other terminal projects .......................................................................................31

DETERMINING THE NUMBER OF MOVES RUNS .........................................................................31

General ..................................................................................................................................31

Projects with typical travel activity data ...............................................................................33

Projects with additional travel activity data..........................................................................34

DEVELOPING BASIC RUN SPECIFICATION INPUTS.....................................................................34

Description ............................................................................................................................35

Scale ......................................................................................................................................35

Time Spans.............................................................................................................................36

Geographic Bounds ...............................................................................................................36

Vehicles/Equipment ...............................................................................................................36

Road Type ..............................................................................................................................37

Pollutants and Processes .......................................................................................................38

Manage Input Data Sets ........................................................................................................39

Strategies ...............................................................................................................................39

Output ....................................................................................................................................40

Advanced Performance Features...........................................................................................40

ENTERING PROJECT DETAILS USING THE PROJECT DATA MANAGER ........................................41

Meteorology...........................................................................................................................42

Age Distribution ....................................................................................................................43

Fuel Supply and Fuel Formulation........................................................................................44

Inspection and Maintenance (I/M) ........................................................................................44

Link Source Type ...................................................................................................................44

Links ......................................................................................................................................45

Describing Vehicle Activity ...................................................................................................45

Deciding on an approach for activity ....................................................................................47

Off-Network ...........................................................................................................................47

GENERATING EMISSION FACTORS FOR USE IN AIR QUALITY MODELING ..................................49

Highway and intersection links..............................................................................................49

Transit and other terminal links ............................................................................................50

SECTION 5: ESTIMATING PROJECT-LEVEL PM EMISSIONS USING EMFAC2011

(IN CALIFORNIA) .....................................................................................................................................51

5.1
5.2
5.2.1
5.2.2
5.3
5.3.1
5.3.2
5.3.3
5.4
5.4.1
5.4.2
5.5
5.5.1
5.5.2
5.5.3

INTRODUCTION .......................................................................................................................51

CHARACTERIZING A PROJECT IN TERMS OF LINKS ...................................................................54

Highway and intersection projects ........................................................................................54

Transit and other terminal projects .......................................................................................55

DETERMINING THE NUMBER OF EMFAC2011 RUNS...............................................................56

General ..................................................................................................................................56

Projects with typical travel activity data ...............................................................................56

Projects with additional travel activity data..........................................................................57

DETERMINING THE MODELING APPROACH ..............................................................................58

Highway and intersection projects ........................................................................................59

Transit and other terminal projects .......................................................................................60

APPLYING THE SIMPLIFIED APPROACH: USING EMFAC2011-PL ...............................................60

Vehicle Category Scheme ......................................................................................................61

Region Type ...........................................................................................................................61

Region....................................................................................................................................62

ii

5.5.4
5.5.5
5.5.6
5.5.7
5.5.8
5.5.9
5.6
5.6.1
5.6.2
5.6.3
5.6.4
5.7
5.7.1
5.7.2
5.7.3
5.7.4
5.8
5.8.1
5.8.2
5.8.3
5.8.4
5.8.5
5.9

Calendar Year........................................................................................................................63

Season....................................................................................................................................63

Vehicle Category ...................................................................................................................64

Fuel Type ...............................................................................................................................64

Speed......................................................................................................................................64

Generating and post-processing EMFAC2011-PL emission factors .....................................64

OVERVIEW OF THE DETAILED APPROACH ...............................................................................65

General ..................................................................................................................................65

Introduction to EMFAC2011 bus types .................................................................................67

Obtaining idling emissions using the detailed approach .......................................................67

Obtaining start emissions using the detailed approach .........................................................68

APPLYING THE DETAILED APPROACH: USING EMFAC2011-LDV ..............................................70

Specifying basic scenario inputs............................................................................................72

Configuring mode and output ................................................................................................74

Editing program constants ....................................................................................................77

Generating EMFAC2011-LDV emission factors ...................................................................80

APPLYING THE DETAILED APPROACH: USING EMFAC2011-HD ................................................84

Obtaining EMFAC2011-HD vehicle running exhaust emission rates ...................................86

Obtaining EMFAC2011-HD vehicle brake and tire wear emission rates .............................89

Obtaining EMFAC2011-HD vehicle idling exhaust emission rates ......................................91

Obtaining EMFAC2011-HD vehicle start exhaust emission rates ........................................92

Diesel retrofits in EMFAC2011 .............................................................................................93

USING THE DETAILED APPROACH FOR PROJECTS CONTAINING BOTH LIGHT -DUTY AND

HEAVY-DUTY VEHICLES ..........................................................................................................93

SECTION 6: ESTIMATING EMISSIONS FROM ROAD DUST, CONSTRUCTION, AND

ADDITIONAL SOURCES .........................................................................................................................95

6.1
6.2
6.3
6.3.1
6.3.2
6.3.3
6.3.4
6.3.5
6.4
6.4.1
6.4.2
6.4.3
6.5
6.6
6.6.1
6.6.2
6.6.3

INTRODUCTION .......................................................................................................................95

OVERVIEW OF DUST METHODS AND REQUIREMENTS ..............................................................95

ESTIMATING RE-ENTRAINED ROAD DUST ................................................................................96

PM2.5 nonattainment and maintenance areas ........................................................................96

PM10 nonattainment and maintenance areas .........................................................................96

Using AP-42 for road dust on paved roads ...........................................................................96

Using AP-42 for road dust on unpaved roads .......................................................................96

Using alternative local approaches for road dust .................................................................97

ESTIMATING TRANSPORTATION-RELATED CONSTRUCTION DUST ............................................97

Determining whether construction dust must be considered .................................................97

Using AP-42 for construction dust ........................................................................................97

Using alternative approaches for construction dust..............................................................97

ADDING DUST EMISSIONS TO MOVES/EMFAC MODELING RESULTS ..........................................98

ESTIMATING ADDITIONAL SOURCES OF EMISSIONS IN THE PROJECT AREA ..............................98

Construction-related vehicles and equipment .......................................................................98

Locomotives ...........................................................................................................................98

Additional emission sources ..................................................................................................98

SECTION 7: SELECTING AN AIR QUALITY MODEL, DATA INPUTS, AND RECEPTORS .....99

7.1
7.2
7.3
7.3.1
7.3.2
7.3.3
7.4
7.4.1
7.4.2
7.4.3

INTRODUCTION .......................................................................................................................99

GENERAL OVERVIEW OF AIR QUALITY MODELING ..................................................................99

SELECTING AN APPROPRIATE AIR QUALITY MODEL...............................................................101

Recommended air quality models ........................................................................................101

How emissions are represented in CAL3QHCR and AERMOD..........................................104

Alternate models ..................................................................................................................104

CHARACTERIZING EMISSION SOURCES ..................................................................................105

Physical characteristics and location ..................................................................................105

Emission rates/emission factors...........................................................................................106

Timing of emissions .............................................................................................................106

iii

7.5
7.5.1
7.5.2
7.5.3
7.5.4
7.5.5
7.6
7.6.1
7.6.2
7.7

INCORPORATING METEOROLOGICAL DATA ...........................................................................106

Finding representative meteorological data........................................................................106

Surface and upper air data ..................................................................................................108

Time duration of meteorological data record......................................................................109

Considering surface characteristics ....................................................................................110

Specifying urban or rural sources .......................................................................................111

PLACING RECEPTORS ............................................................................................................113

Overview ..............................................................................................................................113

General guidance for receptors for all PM NAAQS ............................................................114

RUNNING THE MODEL AND OBTAINING RESULTS ..................................................................115

SECTION 8: DETERMINING BACKGROUND CONCENTRATIONS FROM NEARBY AND

OTHER EMISSION SOURCES ..............................................................................................................116

8.1
8.2
8.3
8.3.1
8.3.2
8.3.3

INTRODUCTION .....................................................................................................................116

NEARBY SOURCES THAT REQUIRE MODELING .......................................................................117

OPTIONS FOR BACKGROUND CONCENTRATIONS ...................................................................118

Using ambient monitoring data to estimate background concentrations ............................119

Adjusting air quality monitoring data to account for future changes in air quality:

using chemical transport models .........................................................................................122

Adjusting air quality monitoring data to account for future changes in air quality:

using an on-road mobile source adjustment factor .............................................................125

SECTION 9: CALCULATING PM DESIGN VALUES AND DETERMINING CONFORMITY...126

9.1
9.2
9.3
9.3.1
9.3.2
9.3.3
9.3.4
9.4
9.4.1
9.4.2
9.5

INTRODUCTION .....................................................................................................................126

USING DESIGN VALUES IN BUILD/NO-BUILD ANALYSES ........................................................127

CALCULATING DESIGN VALUES AND DETERMINING CONFORMITY FOR PM HOT-SPOT

ANALYSES ............................................................................................................................130

General ................................................................................................................................130

Annual PM2.5 NAAQS...........................................................................................................130

24-hour PM2.5 NAAQS .........................................................................................................134

24-hour PM10 NAAQS..........................................................................................................141

DETERMINING APPROPRIATE RECEPTORS FOR COMPARISON TO THE ANNUAL PM2.5 NAAQS ...145

Overview..............................................................................................................................145

2012 PM NAAQS final rule and revised conformity guidance.............................................145

DOCUMENTING CONFORMITY DETERMINATION RESULTS .....................................................148

SECTION 10: MITIGATION AND CONTROL MEASURES ............................................................149

10.1
10.2
10.2.1
10.2.2
10.2.3
10.2.4
10.2.5

INTRODUCTION .....................................................................................................................149

MITIGATION AND CONTROL MEASURES BY CATEGORY .........................................................149

Retrofitting, replacing vehicles/engines, and using cleaner fuels........................................149

Reduced idling programs.....................................................................................................150

Transportation project design revisions ..............................................................................151

Fugitive dust control programs ...........................................................................................151

Addressing other source emissions ......................................................................................152

iv

List of Exhibits
EXHIBIT 3-1. OVERVIEW OF A PM QUANTITATIVE HOT-SPOT ANALYSIS ........................................................... 19

EXHIBIT 4-1. STEPS FOR USING MOVES IN A QUANTITATIVE PM HOT-SPOT ANALYSIS ................................... 27

EXHIBIT 4-2. TYPICAL NUMBER OF MOVES RUNS FOR AN ANALYSIS YEAR .................................................... 32

EXHIBIT 5-1. STEPS FOR USING EMFAC2011 IN A QUANTITATIVE PM HOT-SPOT ANALYSIS ........................... 53

EXHIBIT 5-2. GENERAL DECISION MATRIX FOR USING EMFAC2011 FOR PM HOT-SPOT ANALYSES ............... 59

EXHIBIT 5-3. USING THE SIMPLIFIED APPROACH (EMFAC2011-PL TOOL) FOR A PM HOT-SPOT ANALYSIS .... 62

EXHIBIT 5-4. EMFAC2011-PL GRAPHICAL USER INTERFACE (GUI)................................................................ 63

EXHIBIT 5-5. USING THE DETAILED APPROACH FOR A PM HOT-SPOT ANALYSIS .............................................. 67

EXHIBIT 5-6. BUS TYPES IN EMFAC2011 ......................................................................................................... 68

EXHIBIT 5-7. EMFAC2011-LDV VEHICLE CATEGORIES .................................................................................. 70

EXHIBIT 5-8. USING EMFAC2011-LDV TO OBTAIN EMISSION RATES FOR PM HOT-SPOT ANALYSES ............ 71

EXHIBIT 5-9. SUMMARY OF EMFAC2011-LDV INPUTS NEEDED TO EVALUATE A PROJECT SCENARIO FOR

A PM HOT-SPOT ANALYSIS.......................................................................................................... 72

EXHIBIT 5-10. CHANGING EMFAC2011-LDV DEFAULT SETTINGS FOR TEMPERATURE AND RELATIVE

HUMIDITY .................................................................................................................................. 75

EXHIBIT 5-11. SELECTING POLLUTANT TYPES IN EMFAC2011-LDV FOR PM10 AND PM2.5 ............................. 76

EXHIBIT 5-12. EMFAC2011 PROGRAM CONSTANTS AND MODIFICATION NEEDS FOR PM HOT-SPOT

ANALYSES.................................................................................................................................. 77

EXHIBIT 5-13. EXAMPLE DEFAULT EMFAC2011-LDV VMT BY VEHICLE CLASS DISTRIBUTION

(HEAVY-DUTY VEHICLE VMT HIGHLIGHTED)........................................................................... 78

EXHIBIT 5-14. EXAMPLE ADJUSTED EMFAC2011-LDV VMT BY VEHICLE CLASS DISTRIBUTION

(HEAVY-DUTY VEHICLE VMT HIGHLIGHTED)........................................................................... 79

EXHIBIT 5-15. EXAMPLE EMFAC2011-LDV RUNNING EXHAUST, TIRE WEAR, AND BRAKE WEAR

EMISSION FACTORS IN THE SUMMARY RATES (RTS) OUTPUT FILE ............................................ 81

EXHIBIT 5-16. EMFAC2011-HD VEHICLE CATEGORIES .................................................................................. 84

EXHIBIT 5-17. DATA SOURCES FOR EMFAC2011-HD VEHICLE EMISSION RATES (DETAILED APPROACH) ..... 85

EXHIBIT 5-18. GRAPHICAL USER INTERFACE FOR CARBS EMFAC WEB DATABASE ..................................... 86

EXHIBIT 5-19. OBTAINING RUNNING EMISSIONS (RUNEX) EMISSION RATES FOR EMFAC2011-HD

VEHICLES (DETAILED APPROACH)............................................................................................. 88

EXHIBIT 5-20. PM BRAKE WEAR AND TIRE WEAR (PMBW/PMTW) EMISSION RATES FOR

EMFAC2011-HD VEHICLES (DETAILED APPROACH) ............................................................... 90

EXHIBIT 5-21. OBTAINING IDLING (IDLEX) EMISSION RATES FOR EMFAC2011-HD VEHICLES

(DETAILED APPROACH) ............................................................................................................. 91

EXHIBIT 7-1. OVERVIEW AND DATA FLOW FOR AIR QUALITY MODELING....................................................... 100

EXHIBIT 7-2. SUMMARY OF RECOMMENDED AIR QUALITY MODELS ............................................................... 101

EXHIBIT 7-3. AIR QUALITY MODEL CAPABILITIES FOR METEOROLOGICAL DATA FOR EACH SCENARIO ......... 110

EXHIBIT 9-1. GENERAL PROCESS FOR CALCULATING DESIGN VALUES FOR PM HOT-SPOT ANALYSES ........... 126

EXHIBIT 9-2. GENERAL PROCESS FOR USING DESIGN VALUES IN BUILD/NO-BUILD ANALYSES ...................... 128

EXHIBIT 9-3. DETERMINING CONFORMITY TO THE ANNUAL PM2.5 NAAQS .................................................... 132

EXHIBIT 9-4. DETERMINING CONFORMITY TO THE 24-HOUR PM2.5 NAAQS USING FIRST TIER ANALYSIS ...... 136

EXHIBIT 9-5. RANKING OF 98TH PERCENTILE BACKGROUND CONCENTRATION VALUES .................................. 137

EXHIBIT 9-6. DETERMINING CONFORMITY TO THE 24-HOUR PM2.5 NAAQS USING SECOND TIER ANALYSIS.. 139

EXHIBIT 9-7. RANKING OF 98TH PERCENTILE BACKGROUND CONCENTRATION VALUES .................................. 140

EXHIBIT 9-8. DETERMINING CONFORMITY TO THE 24-HOUR PM10 NAAQS..................................................... 143

List of Appendices
APPENDIX A:
APPENDIX B:
APPENDIX C:
APPENDIX D:
APPENDIX E:

CLEARINGHOUSE OF WEBSITES, GUIDANCE, AND OTHER TECHNICAL RESOURCES FOR PM

HOT-SPOT ANALYSES
EXAMPLES OF PROJECTS OF LOCAL AIR QUALITY CONCERN
HOT-SPOT REQUIREMENTS FOR PM10 AREAS WITH PRE-2006 APPROVED CONFORMITY SIPS
CHARACTERIZING INTERSECTION PROJECTS FOR MOVES
EXAMPLE QUANTITATIVE PM HOT-SPOT ANALYSIS OF A HIGHWAY PROJECT USING MOVES

APPENDIX F:

EXAMPLE QUANTITATIVE PM HOT-SPOT ANALYSIS OF A TRANSIT PROJECT USING MOVES AND

APPENDIX G:
APPENDIX H:
APPENDIX I:
APPENDIX J:
APPENDIX K:

EXAMPLE OF USING EMFAC2011 FOR A HIGHWAY PROJECT

EXAMPLE OF USING EMFAC2011 TO DEVELOP EMISSION FACTORS FOR A TRANSIT PROJECT
ESTIMATING LOCOMOTIVE EMISSIONS
ADDITIONAL REFERENCE INFORMATION ON AIR QUALITY MODELS AND DATA INPUTS
EXAMPLES OF DESIGN VALUE CALCULATIONS FOR PM HOT-SPOT ANALYSES

AND CAL3QHCR
AERMOD

vi

Section 1: Introduction
1.1

PURPOSE OF THIS GUIDANCE

This guidance describes how to complete quantitative hot-spot analyses for certain
highway and transit projects in PM2.5 and PM10 (PM) nonattainment and maintenance
areas. This guidance describes transportation conformity requirements for hot-spot
analyses, and provides technical guidance on estimating project emissions with the
Environmental Protection Agencys (EPAs) MOVES model, Californias EMFAC
model, and other methods. It also outlines how to apply air quality models for PM hotspot analyses and includes additional references and examples. However, the guidance
does not change the specific transportation conformity rule requirements for quantitative
PM hot-spot analyses, such as what projects require these analyses. EPA has coordinated
with the Department of Transportation (DOT) during the development of this guidance.
Transportation conformity is required under Clean Air Act (CAA) section 176(c) (42
U.S.C. 7506(c)) to ensure that federally supported highway and transit project activities
are consistent with (conform to) the purpose of a state air quality implementation plan
(SIP). Conformity to the purpose of the SIP means that transportation activities will not
cause or contribute to new air quality violations, worsen existing violations, or delay
timely attainment of the relevant national ambient air quality standards (NAAQS) or
required interim milestones. EPAs transportation conformity rule (40 CFR 51.390 and
Part 93) establishes the criteria and procedures for determining whether transportation
activities conform to the SIP. Conformity applies to transportation activities in
nonattainment and maintenance areas for transportation-related pollutants, including
PM2.5 and PM10. This guidance is consistent with existing regulations and guidance for
the PM NAAQS, SIP development, and other regulatory programs as applicable. This
guidance does not address carbon monoxide (CO) hot-spot requirements or modeling
procedures.1

1.2

TIMING OF QUANTITATIVE PM HOT-SPOT ANALYSES

On March 10, 2006, EPA published a final rule establishing transportation conformity
requirements for analyzing the local PM air quality impacts of transportation projects (71
FR 12468). The conformity rule requires a qualitative PM hot-spot analysis to be
performed until EPA releases guidance on how to conduct quantitative PM hot-spot
analyses and announces in the Federal Register that such requirements are in effect (40
CFR 93.123(b)).2 EPA also stated in the March 2006 final rule that quantitative PM hot
1

EPA has issued a separate guidance document on how to use MOVES for CO project-level analyses
(including CO hot-spot analyses for conformity purposes). This guidance is available online at:
www.epa.gov/otaq/stateresources/transconf/policy.htm.
2
For more information on qualitative PM hot-spot analyses, see Transportation Conformity Guidance for
Qualitative Hot-spot Analyses in PM2.5 and PM10 Nonattainment and Maintenance Areas, EPA420-B-06
902 (March 2006); available online at: www.epa.gov/otaq/stateresources/transconf/policy.htm. The
qualitative PM hot-spot requirements under 40 CFR 93.123(b)(2) will no longer apply in any PM 2.5 and

spot analyses would not be required until EPA released an appropriate motor vehicle
emissions model for these project-level analyses.3
Quantitative PM hot-spot analyses will be required after the end of the conformity grace
period for applying motor vehicle emissions models for such analyses. See the Federal
Register notice of availability for more information on EPAs approval of MOVES (and
EMFAC in California) for PM hot-spot analyses. The effective date of the Federal
Register notice constitutes the start of the two-year conformity grace period.4 EPA has
issued policy guidance on when these models will be required for PM hot-spot analyses
and other purposes.5

1.3

DEFINITION OF A HOT-SPOT ANALYSIS

A hot-spot analysis is defined in 40 CFR 93.101 as an estimation of likely future

localized pollutant concentrations and a comparison of those concentrations to the
relevant NAAQS. A hot-spot analysis assesses the air quality impacts on a scale smaller
than an entire nonattainment or maintenance area, including, for example, congested
highways or transit terminals. Such an analysis of the area substantially affected by the
project demonstrates that CAA conformity requirements are met for the relevant NAAQS
in the project area. When a hot-spot analysis is required, it is included within a projectlevel conformity determination.

1.4

PROJECTS REQUIRING A PM HOT-SPOT ANALYSIS

PM hot-spot analyses are required for projects of local air quality concern, which include
certain highway and transit projects that involve significant levels of diesel vehicle traffic
and any other project identified in the PM SIP as a localized air quality concern. See
Section 2.2 of the guidance for further information on the specific types of projects where
a PM hot-spot analysis is required. A PM hot-spot analysis is not required for projects
that are not of local air quality concern. This guidance does not alter the types of projects
that require a PM hot-spot analysis.
Note that additional projects may need hot-spot analyses in PM10 nonattainment and
maintenance areas with approved conformity SIPs that are based on the federal PM10 hotspot requirements that existed before the March 2006 final rule.6 EPA strongly
PM10 nonattainment and maintenance areas once the grace period is over and quantitative requirements are

in effect. At that time, the 2006 EPA/FHWA qualitative PM hot-spot guidance will be superseded by

EPAs quantitative PM hot-spot guidance.

3
See EPAs March 2006 final rule (71 FR 12498-12502).

4
EPA posts all Federal Register notices for approving new emissions models on its website:

www.epa.gov/otaq/stateresources/transconf/policy.htm#models.

5
Policy Guidance on the Use of MOVES2010 for State Implementation Plan Development,

Transportation Conformity, and Other Purposes, EPA-420-B-09-046 (December 2009); available online

at: www.epa.gov/otaq/stateresources/transconf/policy.htm#models.

6
A conformity SIP includes a states specific criteria and procedures for certain aspects of the

transportation conformity process (40 CFR 51.390).

encourages states to revise these types of approved conformity SIPs to take advantage of
the streamlining flexibilities provided by the current CAA.7 See Appendix C for further
details on how these types of approved conformity SIPs can affect what projects are
required to have PM hot-spot analyses.

1.5

OTHER PURPOSES FOR THIS GUIDANCE

This guidance addresses how to complete a quantitative PM hot-spot analysis for

transportation conformity purposes. However, certain sections of this technical guidance
may also be applicable when completing analyses of transportation projects for general
conformity determinations and for other purposes. For example, Sections 4 or 5 can be
used to estimate transportation project emissions using MOVES or EMFAC, and Sections
7 and 8 can be used to conduct PM air quality analyses of transportation projects.

1.6

ORGANIZATION OF THIS GUIDANCE

The remainder of this guidance is organized as follows:

Section 2 provides an overview of transportation conformity requirements for PM
hot-spot analyses.
Section 3 describes the general process for conducting PM hot-spot analyses.
Sections 4 and 5 describe how to estimate vehicle emissions from a project using
the latest approved emissions model, either MOVES (for all states other than
California) or EMFAC (for California).
Section 6 discusses how to estimate emissions from road dust, construction dust,
and additional sources, if necessary.
Section 7 describes how to determine the appropriate air quality dispersion model
and select model inputs.
Section 8 covers how to determine background concentrations, including nearby
source emissions in the project area.
Section 9 describes how to calculate the appropriate design values and determine
whether or not the project conforms.
Section 10 describes mitigation and control measures that could be considered, if
necessary.
The following appendices for this guidance may also help state and local agencies
conduct PM hot-spot analyses:
Appendix A is a clearinghouse of information and resources external to this
guidance that may be useful when completing PM hot-spot analyses.
Appendix B gives examples of projects of local air quality concern.

For more information about conformity SIPs, see EPAs Guidance for Developing Transportation
Conformity State Implementation Plans (SIPs), EPA-420-B-09-001 (January 2009); available online at:
www.epa.gov/otaq/stateresources/transconf/policy/420b09001.pdf.

Appendix C discusses what projects need a PM10 hot-spot analysis if a states

approved conformity SIP is based on pre-2006 requirements.
Appendix D demonstrates how to characterize links in an intersection when
running MOVES.
Appendices E and F are abbreviated PM hot-spot analysis examples using
MOVES and air quality models for a highway and transit project, respectively.
Appendices G and H are examples on how to configure and run EMFAC for a
highway and transit project, respectively.
Appendix I describes how to estimate locomotive emissions in the project area.
Appendix J includes details on how to input data and run air quality models for
PM hot-spot analyses, as well as prepare outputs for design value calculations.
Appendix K has examples of how to calculate design values and determine
transportation conformity.

Except where indicated, this guidance applies equally for the annual PM2.5 NAAQS, the
24-hour PM2.5 NAAQS, and the 24-hour PM10 NAAQS. This guidance is written for
current and future PM2.5 and PM10 NAAQS. EPA will re-evaluate the applicability of
this guidance, as needed, if different PM NAAQS are promulgated in the future.

1.7

ADDITIONAL INFORMATION

For specific questions concerning a particular nonattainment or maintenance area, please

contact the transportation conformity staff person responsible for your state at the
appropriate EPA Regional Office. Contact information for EPA Regional Offices can be
found at: www.epa.gov/otaq/stateresources/transconf/contacts.htm.
General questions about this guidance can be directed to Meg Patulski at EPAs Office of
Transportation and Air Quality, patulski.meg@epa.gov, (734) 214-4842.
Technical questions about conformity hot-spot analyses can be directed to conformity
hotspot@epa.gov.

1.8

GUIDANCE AND EXISTING REQUIREMENTS

This guidance does not create any new requirements. The CAA and the regulations
described in this document contain legally binding requirements. This guidance is not a
substitute for those provisions or regulations, nor is it a regulation in itself. Thus, it does
not impose legally binding requirements on EPA, DOT, states, or the regulated
community, and may not apply to a particular situation based upon the circumstances.
EPA retains the discretion to adopt approaches on a case-by-case basis that may differ
from this guidance but still comply with the statute and applicable regulations. This
guidance may be revised periodically without public notice. As noted above, EPAs
Federal Register notice describes the two-year conformity grace period for MOVES and
EMFAC for PM hot-spot analyses, and when the requirements for quantitative PM hotspot analyses in 40 CFR 93.123(b) will take effect.

Section 2: Transportation Conformity Requirements

2.1

INTRODUCTION

This section outlines the transportation conformity requirements for quantitative PM hotspot analyses, including the general statutory and regulatory requirements, specific
analytical requirements, and the different types of agencies involved in developing hotspot analyses.

2.2

OVERVIEW OF STATUTORY AND REGULATORY REQUIREMENTS

CAA section 176(c)(1) is the statutory requirement that must be met by all projects in
nonattainment and maintenance areas that are subject to transportation conformity.
Section 176(c)(1)(B) states that federally-supported transportation projects must not
cause or contribute to any new violation of any standard [NAAQS] in any area; increase
the frequency or severity of any existing violation of any standard in any area; or delay
timely attainment of any standard or any required interim emission reductions or other
milestones in any area.8
Section 93.109(b) of the conformity rule outlines the requirements for project-level
conformity determinations. For example, PM hot-spot analyses must be based on the
latest planning assumptions available at the time the analysis begins (40 CFR 93.110).
Also, the design concept and scope of the project must be consistent with that included in
the conforming transportation plan and transportation improvement program (TIP) or
regional emissions analysis (40 CFR 93.114).
Section 93.123(b)(1) of the conformity rule defines the projects that require a PM2.5 or
PM10 hot-spot analysis as:
(i) New highway projects that have a significant number of diesel vehicles, and
expanded highway projects that have a significant increase in the number of diesel
vehicles;
(ii) Projects affecting intersections that are at Level-of-Service D, E, or F with a
significant number of diesel vehicles, or those that will change to Level-ofService D, E, or F because of increased traffic volumes from a significant number
of diesel vehicles related to the project;

See EPAs March 2006 final rule (71 FR 12469-12490) and March 24, 2010 final rule (75 FR 14274
14285). Both of these final rules address the statutory conformity requirements and explain how the hotspot analyses required by EPAs regulations satisfy those requirements. Issues relating to the statutory
conformity requirements are therefore not addressed in this guidance document. See also Environmental
Defense v. EPA 467 F.3d 1329 (D.C. Cir. 2006) and Environmental Defense vs. EPA, 509 F.3d 553 (D.C.
Cir. 2007).

(iii) New bus and rail terminals and transfer points that have a significant number
of diesel vehicles congregating at a single location;
(iv) Expanded bus and rail terminals and transfer points that significantly increase
the number of diesel vehicles congregating at a single location; and
(v) Projects in or affecting locations, areas, or categories of sites which are
identified in the PM2.5 or PM10 applicable implementation plan or implementation
plan submission, as appropriate, as sites of violation or possible violation.
A PM hot-spot analysis is not required for projects that are not of local air quality
concern. For these projects, state and local project sponsors should document in their
project-level conformity determinations that the requirements of the CAA and 40 CFR
93.116 are met without a hot-spot analysis, since such projects have been found not to be
of local air quality concern under 40 CFR 93.123(b)(1). Note that all other project-level
conformity requirements must continue to be met. See Appendix B for examples of
projects that are most likely to be of local air quality concern, as well as examples of
projects that are not.9
Section 93.123(c) of the conformity rule includes the general requirements for all PM
hot-spot analyses. A PM hot-spot analysis must:
Estimate the total emissions burden of direct PM emissions that may result from
the implementation of the project(s), summed together with future background
concentrations;
Include the entire transportation project, after identifying the major design
features that will significantly impact local concentrations;
Use assumptions that are consistent with those used in regional emissions
analyses for inputs that are needed for both analyses (e.g., temperature, humidity);
Assume the implementation of mitigation or control measures only where written
commitments for such measures have been obtained; and
Consider emissions increases from construction-related activities only if they
occur during the construction phase and last more than five years at any
individual site.
Finally, the interagency consultation process must be used to develop project-level
conformity determinations to meet all applicable conformity requirements for a given
project. In general, when a hot-spot analysis is required, it is done when a project-level
conformity determination is completed. Conformity determinations are typically
developed during the National Environmental Policy Act (NEPA) process, although
conformity requirements are separate from NEPA-related requirements. There can also

See the preamble of the March 2006 final rule for further information regarding how and why EPA
defined projects of local air quality concern (71 FR 12491-12493). EPA also clarified Section
93.123(b)(1)(i) in the January 24, 2008 final rule (73 FR 4435-4436).

be limited cases when conformity requirements apply after the initial NEPA process has
been completed.10

2.3

INTERAGENCY CONSULTATION AND PUBLIC PARTICIPATION

REQUIREMENTS

The interagency consultation process is an important tool for completing project-level

conformity determinations and hot-spot analyses. Interagency consultation must be used
to develop a process to evaluate and choose models and associated methods and
assumptions to be used in PM hot-spot analyses (40 CFR 93.105(c)(1)(i)). For example,
each areas interagency consultation procedures must be used to determine the models
and associated methods and assumptions for:
The geographic area covered by the analysis (see Section 3.3);
The emissions models used in the analysis (see Section 4 for MOVES and
Section 5 for EMFAC);
Whether and how to estimate road and construction dust emissions (see
Section 6);
The nearby sources considered, background data used, and air quality model
chosen, including the background monitors/concentrations selected and any
interpolation methods used (see Sections 7 and 8); and
The appropriateness of receptors to be compared to the annual PM2.5 NAAQS
(see Section 9.4).
State and local agencies have flexibility to decide whether the process outlined in the
interagency consultation procedures should be used for aspects of PM hot-spot analyses
where consultation is not required. The roles and responsibilities of various agencies for
meeting the transportation conformity requirements are addressed in 40 CFR 93.105 or in
a states approved conformity SIP. See Section 2.9 for further information on the
agencies involved in interagency consultation.
This guidance describes when consultation on specific decisions is necessary, but for
many aspects of PM hot-spot analyses, the general requirement for interagency
consultation can be satisfied without consulting separately on each and every specific
decision that arises. In general, as long as the consultation requirements are met,
agencies have discretion as to how they consult on hot-spot analyses. For example, the
interagency consultation process could be used to make decisions on a case-by-case basis
for individual transportation projects for which a PM hot-spot analysis is required. Or,
agencies involved in the consultation process could develop procedures that will apply
for any PM hot-spot analysis and agree that any departures from procedures would be
discussed by involved agencies. For example, interagency consultation is required on the
emissions model used for the analysis, but agencies could agree up front that the latest
EPA-approved version of MOVES will be used for any hot-spot analysis necessary in an
10

Such an example may occur when NEPA is completed prior to an area being designated nonattainment,
but additional federal project approvals are required after conformity requirements apply.

area that is not located in California. As a second example, agencies could agree ahead
of time that, if appropriate, instead of modeling all four quarters of the year for a 24-hour
PM NAAQS, only the quarters that were modeled for the latest SIP demonstration for
that NAAQS need to be modeled in a hot-spot analysis.
The conformity rule also requires agencies completing project-level conformity
determinations to establish a proactive public involvement process that provides
opportunity for public review and comment (40 CFR 93.105(e)). The NEPA public
involvement process is typically used to satisfy this public participation requirement.11 If
a project-level conformity determination that includes a PM hot-spot analysis is
performed after NEPA is completed, a public comment period must still be provided to
support that determination. In these cases, agencies have flexibility to decide what
specific public participation procedures are appropriate, as long as the procedures provide
a meaningful opportunity for public review and comment.

2.4

HOT-SPOT ANALYSES ARE BUILD/NO-BUILD ANALYSES

2.4.1

General

As noted above, the conformity rule requires that the emissions from the proposed
project, when considered with background concentrations, will not cause or contribute to
any new violation, worsen existing violations, or delay timely attainment of the relevant
NAAQS or required interim milestones. As described in Section 1.3, the hot-spot
analysis examines the area substantially affected by the project (i.e., the project area).
In general, a hot-spot analysis compares the air quality concentrations with the proposed
project (the build scenario) to the air quality concentrations without the project (the nobuild scenario).12 These air quality concentrations are determined by calculating a
design value, a statistic that describes a future air quality concentration in the project
area that can be compared to a particular NAAQS. It is always necessary to complete
emissions and air quality modeling on the build scenario and compare the resulting
design values to the relevant PM NAAQS. However, it will not always be necessary to
conduct emissions and air quality modeling for the no-build scenario, as described further
below.
2.4.2

Suggested approach for PM hot-spot analyses

To avoid unnecessary work, EPA suggests the following approach when completing a
PM hot-spot analysis:

11

Section 93.105(e) of the conformity rule requires agencies to provide opportunity for public

involvement in conformity determinations for projects where otherwise required by law.

12
See 40 CFR 93.116(a). See also November 24, 1993 conformity rule (58 FR 62212-62213). Please note

that a build/no-build analysis for project-level conformity determinations is different than the build/no

build interim emissions test for regional emissions analyses in 40 CFR 93.119.

 First, model the build scenario and account for background concentrations in
accordance with this guidance. If the design values for the build scenario are less
than or equal to the relevant NAAQS, the project meets the conformity rules hotspot requirements and no further modeling is needed (i.e., there is no need to
model the no-build scenario). If this is not the case, the project sponsor could
choose mitigation or control measures, perform additional modeling that includes
these measures, and then determine if the build scenario is less than or equal to
the relevant NAAQS.
If the build scenario results in design values greater than the NAAQS, then the
no-build scenario will also need to be modeled. The no-build scenario will model
the air quality impacts of sources without the proposed project. The modeling
results of the build and no-build scenarios should be combined with background
concentrations as appropriate. If the design values for the build scenario are less
than or equal to the design values for the no-build scenario, then the project meets
the conformity rules hot-spot requirements. If not, then the project does not meet
conformity requirements without further mitigation or control measures. If such
measures are considered, additional modeling will need to be completed and new
design values calculated to ensure that the build scenario is less than or equal to
the no-build scenario.
The project sponsor can decide to use the suggested approach above or a different
approach (e.g., conduct the no-build analysis first, calculate design values at all build and
no-build scenario receptors). The project sponsor can choose to apply mitigation or
control measures at any point in the process.13 This guidance applies to any of the above
approaches for a given PM hot-spot analysis.
In general, assumptions should be consistent between the build and no-build scenarios for
a given analysis year, except for traffic volumes and other project activity changes or
changes in nearby sources that are expected to occur due to the project (e.g., increased
activity at a nearby marine port or intermodal terminal due to a new freight corridor
highway). Project sponsors should document the build/no-build analysis in the projectlevel conformity determination, including the assumptions, methods, and models used for
each analysis year(s).
The conformity rule defines how to determine if new NAAQS violations or increases in
the frequency or severity of existing violations are predicted to occur based on the hotspot analysis. Section 93.101 states:
Cause or contribute to a new violation for a project means:
(1) To cause or contribute to a new violation of a standard in the area
substantially affected by the project or over a region which would

13

If mitigation or control measures are used to demonstrate conformity during the hot-spot analysis, the
conformity determination for the project must include written commitments to implement such measures
(40 CFR 93.125).

10

otherwise not be in violation of the standard during the future period in

question, if the project were not implemented; or
(2) To contribute to a new violation in a manner that would increase the
frequency or severity of a new violation of a standard in such area.
Increase the frequency or severity means to cause a location or region to exceed
a standard more often or to cause a violation at a greater concentration than
previously existed and/or would otherwise exist during the future period in
question, if the project were not implemented.
A build/no-build analysis is typically based on design value comparisons done on a
receptor-by-receptor basis. However, there may be certain cases where a new violation
at one receptor (in the build scenario) is relocated from a different receptor (in the nobuild scenario). As discussed in the preamble to the November 24, 1993 transportation
conformity rule, EPA believes that a seemingly new violation may be considered to be a
relocation and reduction of an existing violation only if it were in the area substantially
affected by the project and if the predicted [future] design value for the new site would
be less than the design value at the old site without the project that is, if there would
be a net air quality benefit (58 FR 62213). Since 1993, EPA has made this interpretation
only in limited cases with CO hot-spot analyses where there is a clear relationship
between a proposed project and a possible relocated violation (e.g., a reduced CO
NAAQS violation is relocated from one corner of an intersection to another due to trafficrelated changes from an expanded intersection). Any potential relocated violations in PM
hot-spot analyses should be determined through an areas interagency consultation
procedures.
2.4.3

Guidance focuses on refined PM hot-spot analyses

Finally, the build/no-build analysis described in this guidance represents a refined PM

hot-spot analysis, rather than a screening analysis. Refined analyses rely on detailed
local information and simulate detailed atmospheric processes to provide more
specialized and accurate estimates, and can be done for both the build and no-build
scenarios. In contrast, screening analyses estimate the maximum likely air quality
impacts from a given source under worst case conditions for the build scenario only.14
EPA believes that, because of the complex nature of PM emissions, the statistical form of
each NAAQS, the need to consider temperature effects throughout the time period
covered by the analysis, and the variability of background concentrations over the course
of a year, quantitative PM hot-spot analyses need to be completed using the refined
analysis procedures described in this guidance.
However, there may be cases where using a screening analysis or components of a
screening analysis could be supported in PM hot-spot analyses, such as:
14

Screening analyses for the 1-hour and 8-hour CO NAAQS have been completed based on peak emissions
and worst case meteorology. The shorter time period covered by these NAAQS, the types of projects
modeled, and other factors make screening analyses appropriate for the CO NAAQS.

11

Where a project can be characterized as a single source (e.g., a transit terminal

that could be characterized as a single area source). Such a case may be a
candidate for a screening analysis using worst case travel activity and
meteorological data and an appropriate screening model.15
Where emissions modeling for a project is completed using worst case travel
activity and a recommended air quality model (see Section 7.3).

Both of these options would be appropriate only for the build scenario and may be most
feasible in areas where monitored PM air quality concentrations are significantly below
the applicable NAAQS. In addition, other flexibilities that can simplify the hot-spot
analysis process are included in later parts of this guidance (e.g., calculating design
values in the build scenario first for the receptor with highest modeled concentrations
only).
EPA notes, however, that this guidance assumes that emissions modeling, air quality
modeling, and representative background concentrations are all necessary as part of a
quantitative PM hot-spot analysis in order to demonstrate conformity requirements. For
example, an approach that would involve comparing only emissions between the build
and no-build scenarios, without completing air quality modeling or considering
representative background concentrations, would not be technically supported.16
Furthermore, EPA believes that the value of using a screening option decreases for a PM
hot-spot analysis if a refined analysis will ultimately be necessary to meet conformity
requirements.
Evaluating and choosing models and associated methods and assumptions used in
screening options must be completed through the process established by each areas
interagency consultation procedures (40 CFR 93.105(c)(1)(i)). Please consult with your
EPA Regional Office, which will coordinate with EPAs Office of Transportation and Air
Quality (OTAQ) and Office of Air Quality Planning and Standards (OAQPS), if a
screening analysis option is being considered for a PM hot-spot analysis.

15

Such as AERSCREEN or AERMOD using meteorological conditions suitable for screening analyses.
Since Section 93.123(b)(1) of the conformity rule requires PM hot-spot analyses for projects with
significant new levels of PM emissions, it is unlikely that every portion of the project area in the build
scenario would involve the same or fewer emissions than that same portion in the no-build scenario. Such
an approach would not consider the variation of emissions and potential NAAQS impacts at different
locations throughout the project area, which is necessary to meet conformity requirements.
16

12

2.5

EMISSIONS CONSIDERED IN PM HOT-SPOT ANALYSES

2.5.1

General requirements

PM hot-spot analyses include only directly emitted PM2.5 or PM10 emissions. PM2.5 and
PM10 precursors are not considered in PM hot-spot analyses, since precursors take time at
the regional level to form into secondary PM.17
2.5.2

PM emissions from motor vehicle exhaust, brake wear, and tire wear

Exhaust, brake wear, and tire wear emissions from on-road vehicles are always be
included in a projects PM2.5 or PM10 hot-spot analysis. See Sections 4 and 5 for how to
quantify these emissions using MOVES (outside California) or EMFAC (within
California).
2.5.3

PM2.5 emissions from re-entrained road dust

Re-entrained road dust must be considered in PM2.5 hot-spot analyses only if EPA or the
state air agency has made a finding that such emissions are a significant contributor to the
PM2.5 air quality problem in a given nonattainment or maintenance area (40 CFR
93.102(b)(3) and 93.119(f)(8)).18
If a PM2.5 area has no adequate or approved SIP budgets for the PM2.5 NAAQS,
re-entrained road dust is not included in a hot-spot analysis unless the EPA
Regional Administrator or state air quality agency determines that re-entrained
road dust is a significant contributor to the PM2.5 nonattainment problem and has
so notified the metropolitan planning organization (MPO) and DOT.
If a PM2.5 area has adequate or approved SIP budgets, re-entrained road dust
would have to be included in a hot-spot analysis only if such budgets include reentrained road dust.
See Section 6 for further information regarding how to estimate re-entrained road dust for
PM2.5 hot-spot analyses, if necessary.
2.5.4

PM10 emissions from re-entrained road dust

Re-entrained road dust must be included in all PM10 hot-spot analyses. Because road
dust is a significant component of PM10 inventories, EPA has historically required road
dust emissions to be included in all conformity analyses of direct PM10 emissions
17
See 40 CFR 93.102(b) for the general requirements for applicable pollutants and precursors in
conformity determinations. Section 93.123(c) provides additional information regarding certain PM
emissions for hot-spot analyses. See also EPAs March 2006 final rule preamble (71 FR 12496-8).
18
See the July 1, 2004 final conformity rule (69 FR 40004).

13

including hot-spot analyses.19 See Section 6 for further information regarding how to
estimate re-entrained road dust for PM10 hot-spot analyses.
2.5.5

PM emissions from construction-related activities

Emissions from construction-related activities are not required to be included in PM hotspot analyses if such emissions are considered temporary as defined in 40 CFR
93.123(c)(5) (i.e., emissions which occur only during the construction phase and last five
years or less at any individual site). Construction emissions would include any direct PM
emissions from construction-related dust and exhaust emissions from construction
vehicles and equipment.
For most projects, construction emissions would not be included in PM2.5 or PM10 hotspot analyses (because, in most cases, the construction phase is less than five years at any
one site).20 However, there may be limited cases where a large project is constructed
over a longer time period, and non-temporary construction emissions must be included
when an analysis year is chosen during project construction. See Section 6 for further
information regarding how to estimate transportation-related construction emissions for
PM hot-spot analyses, if necessary.

2.6

NAAQS CONSIDERED IN PM HOT-SPOT ANALYSES

The CAA and transportation conformity regulations require that conformity be met for all
transportation-related NAAQS for which an area has been designated nonattainment or
maintenance. Therefore, a project-level conformity determination must address all
applicable NAAQS for a given pollutant.21
Accordingly, results from a quantitative hot-spot analysis will need to be compared to all
relevant PM2.5 and PM10 NAAQS in effect for the area undertaking the analysis. For
example, in an area designated nonattainment or maintenance for only the annual PM2.5
NAAQS or only the 24-hour PM2.5 NAAQS, the hot-spot analysis would have to address
only that respective PM2.5 NAAQS. If an area is designated nonattainment or
maintenance for the annual and 24-hour PM2.5 NAAQS, the hot-spot analysis would have
to address both NAAQS for conformity purposes.

2.7

BACKGROUND CONCENTRATIONS

As required by 40 CFR 93.123(c)(1) and discussed in Section 2.2, a PM hot-spot analysis

must be based on the total emissions burden which may result from the implementation
of the project, summed together with future background concentrations. By
19

See the March 2006 final rule (71 FR 12496-98).

EPAs rationale for limiting the consideration of construction emissions to five years can be found in its

January 11, 1993 proposed rule (58 FR 3780).

21
See EPAs March 2006 final rule (71 FR 12468-12511).

20

14

definition, background concentrations do not include emissions from the project itself.
Background concentrations include the emission impacts of all sources that affect
concentrations in the project area other than the project. Section 8 provides further
information on how background concentrations can be determined.

2.8

APPROPRIATE TIME FRAME AND ANALYSIS YEARS

Section 93.116(a) of the conformity rule requires that PM hot-spot analyses consider
either the full time frame of an area's transportation plan or, in an isolated rural
nonattainment or maintenance area, the 20-year regional emissions analysis.22
Conformity requirements are met if the analysis demonstrates that no new or worsened
violations occur in the year(s) of highest expected emissions which includes the
projects emissions in addition to background concentrations.23 Areas should analyze the
year(s) within the transportation plan or regional emissions analysis, as appropriate,
during which:
Peak emissions from the project are expected; and
A new NAAQS violation or worsening of an existing violation would most likely
occur due to the cumulative impacts of the project and background concentrations
in the project area.
If such a demonstration occurs, then no adverse impacts would be expected to occur in
any other years within the time frame of the transportation plan or regional emissions
analysis.24
The following factors (among others) should be considered when selecting the year(s) of
peak emissions:
Changes in vehicle fleets;
Changes in traffic volumes, speeds, and vehicle miles traveled (VMT); and
Expected trends in background concentrations, including any nearby sources that
are affected by the project.
In some cases, selecting only one analysis year, such as the last year of the transportation
plan or the year of project completion, may not be sufficient to satisfy conformity
requirements. For example, if a project is being developed in two stages and the entire
two-stage project is being approved, two analysis years should be modeled: one to
examine the impacts of the first stage of the project and another to examine the impacts

22

Although CAA section 176(c)(7) and 40 CFR 93.106(d) allow the election of changes to the time
horizons for transportation plan and TIP conformity determinations, these changes to do not affect the time
frame and analysis requirements for hot-spot analyses.
23
If such a demonstration can be made, then EPA believes it is reasonable to assume that no adverse
impacts would occur in any other years within the time frame of the transportation plan or regional
emissions analysis.
24
See EPAs July 1, 2004 final conformity rule (69 FR 40056-40058).

15

of the completed project.25 Selecting appropriate analysis year(s) should be considered

through the process established by each areas interagency consultation procedures (40
CFR 93.105(c)(1)(i)).

2.9

AGENCY ROLES AND RESPONSIBILITIES

The typical roles and responsibilities of agencies implementing the PM hot-spot analysis
requirements are described below. Further details are provided throughout later sections
of this guidance.
2.9.1

Project sponsor

The project sponsor is typically the agency responsible for implementing the project (e.g.,
a state department of transportation, regional or local transit operator, or local
government). The project sponsor is the lead agency for developing the PM hot-spot
analysis, meeting interagency consultation and public participation requirements, and
documenting the final hot-spot analysis in the project-level conformity determination.
2.9.2

DOT

DOT is responsible for making project-level conformity determinations. PM hot-spot

analyses and conformity determinations would generally be included in documents
prepared to meet NEPA requirements. It is possible for DOT to make a project-level
conformity determination outside of the NEPA process (for example, if conformity
requirements apply after NEPA has been completed, but additional federal action on the
project is required). DOT is also an active member of the interagency consultation
process for conformity determinations.
2.9.3

EPA

EPA is responsible for promulgating transportation conformity regulations and provides

policy and technical assistance to federal, state, and local conformity implementers. EPA
is an active member of the interagency consultation process for conformity
determinations. In addition, EPA reviews submitted SIPs, and provides policy and
technical support for emissions modeling, air quality modeling, monitoring, and other
issues.
2.9.4

State and local transportation and air agencies

State and local transportation and air quality agencies are part of the interagency
consultation process and assist in modeling of transportation activities, emissions, and air
quality. These agencies are likely to provide data required to perform a PM hot-spot
analysis, although the conformity rule does not specifically define the involvement of
25

See EPAs July 1, 2004 final rule (69 FR 40057).

16

these agencies in project-level conformity determinations. For example, the state or local
air quality agency operates the air quality monitoring network, processes meteorological
data, and uses air quality models for air quality planning purposes (such as SIP
development and modeling applications for other purposes). MPOs often conduct
emissions modeling, maintain regional population forecasts, and estimate future traffic
conditions relevant for project planning. The interagency consultation process can be
used to discuss the role of the state or local air agency, the MPO, and other agencies in
project-level conformity determinations, if such roles are not already defined in an areas
conformity SIP.

17

Section 3: Overview of a Quantitative PM Hot-Spot Analysis

3.1

INTRODUCTION

This section provides a general overview of the process for conducting a quantitative PM
hot-spot analysis. All individual elements or steps presented here are covered in more
depth and with more technical information throughout the remainder of the guidance.
The general steps required to complete a quantitative PM hot-spot analysis are depicted
in Exhibit 3-1 (following page) and summarized in this section.
As previously noted in Section 2.3, the interagency consultation process is an essential
part of developing PM hot-spot analyses. As a number of fundamental aspects of the
analysis need to be determined through consultation, it is recommended that these
discussions take place as early and as often as necessary for the analysis to be completed
on schedule. In addition, early consultation allows potential data sources for the analysis
to be more easily identified.

3.2

DETERMINE NEED FOR A PM HOT-SPOT ANALYSIS (STEP 1)

The conformity rule requires a PM hot-spot analysis only for projects of local air quality
concern. See Section 2.2 regarding how to determine if a project is of local air quality
concern according to the conformity rule.

3.3

DETERMINE APPROACH, MODELS, AND DATA (STEP 2)

3.3.1

General

There are several decisions that need to be made before beginning a PM hot-spot
analysis, including determining the:
Geographic area to be covered by the analysis (the project area) and emission
sources to be modeled;
General approach and analysis year(s) for emissions and air quality modeling;
Applicable PM NAAQS to be evaluated;
Type of PM emissions to be modeled for different sources;
Emissions and air quality models and methods to be used;
Project-specific data to be used; and
Schedule for conducting the analysis and points of consultation.
Further details on these decisions are provided below. Evaluating and choosing models
and associated methods and assumptions must be completed through the process
established by each areas interagency consultation procedures (40 CFR 93.105(c)(1)(i)).

18

Exhibit 3-1. Overview of a PM Quantitative Hot-spot Analysis

19

3.3.2 Determining the geographic area and emission sources to be covered by the
analysis
The geographic area to be covered by a PM hot-spot analysis (the project area) is to be
determined on a case-by-case basis.26 PM hot-spot analyses must examine the air quality
impacts for the relevant PM NAAQS in the area substantially affected by the project (40
CFR 93.123(c)(1)). To meet this and other conformity requirements, it is necessary to
define the project, determine where it is to be located, and ascertain what other emission
sources are located in the project area.27 In addition to emissions from the proposed
highway or transit project,28 there may be nearby sources of emissions that need to be
estimated and included in air quality modeling (e.g., a freight rail terminal that is affected
by the project). There also may be other sources in the project area that are determined to
be insignificant to project emissions (e.g., a service drive or small employee parking lot).
See Sections 4 through 6 for how to estimate emissions from the proposed project, and
Sections 6 through 8 for when and how to include nearby source emissions and other
background concentrations.
Hot-spot analyses must include the entire project (40 CFR 93.123(c)(2)). However, it
may be appropriate in some cases to focus the PM hot-spot analysis only on the locations
of highest air quality concentrations. For large projects, it may be necessary to analyze
multiple locations that are expected to have the highest air quality concentrations and,
consequently, the most likely new or worsened PM NAAQS violations. If conformity is
demonstrated at such locations, then it can be assumed that conformity is met in the entire
project area. For example, if a highway project involves several lane miles with similar
travel activity (and no nearby sources that need to be modeled), the scope of the PM hotspot analysis could involve only the point(s) of highest expected PM concentrations. If
conformity requirements are met at such locations, then it can be assumed that
conformity is met throughout the project area. Such an approach would be preferable to
modeling the entire length of the highway project, which would involve additional time
and resources.
Questions regarding the scope of a given PM hot-spot analysis can be determined through
the interagency consultation process.
3.3.3 Deciding the general analysis approach and analysis year(s)
As stated in Section 2.4, there are several approaches for completing a build/no-build
analysis for a given project. For example, a project sponsor may want to start by
completing the build scenario first to see if a new or worsened PM NAAQS violation is
26

Given the variety of potential projects that may require a PM hot-spot analysis, it is not possible to

provide one definition or set of parameters that can be used in all cases to determine the area covered by the

PM hot-spot analysis.

27
See more in the March 24, 2010 final conformity rule entitled Transportation Conformity Rule PM 2.5

and PM10 amendments, 75 FR 14281; found online at: www.epa.gov/otaq/stateresources/transconf/conf

regs.htm.

28
40 CFR 93.101 defines highway project and transit project for transportation conformity purposes.

20

predicted (if not, then modeling the no-build scenario would be unnecessary). In
contrast, a project sponsor could start with the no-build scenario first if a future PM
NAAQS violation is anticipated in both the build and no-build scenarios (even after
mitigation or control measures are considered).
It is also necessary to select one or more analysis years within the time frame of the
transportation plan or regional emissions analysis when emissions from the project, any
nearby sources, and background are expected to be highest. See Section 2.8 for more
information on selecting analysis year(s).
3.3.4

Determining the PM NAAQS to be evaluated

As stated in Section 2.6, PM hot-spot analyses need to be evaluated only for the NAAQS
for which an area has been designated nonattainment or maintenance. In addition, there
are aspects of modeling that can be affected by whether a NAAQS is an annual or a 24
hour PM NAAQS. It is also important to conduct modeling for those parts of an analysis
year where PM concentrations are expected to be highest. For example, a hot-spot
analysis for the annual PM2.5 NAAQS would involve data and modeling throughout a
given analysis year (i.e., all four quarters of the analysis year).29
A hot-spot analysis for the 24-hour PM2.5 or PM10 NAAQS would also involve data and
modeling throughout an analysis year, except when future NAAQS violations and peak
emissions in the project area are expected to occur in only one quarter of the future
analysis year(s). In such cases, a project sponsor could choose to complete emissions and
air quality modeling for only that quarter, as determined through the interagency
consultation process. For example, if an areas SIP demonstration is based on only one
quarter for a 24-hour PM NAAQS, it may be appropriate to make the same assumption
for hot-spot analyses for that NAAQS. This could be the case in a PM10 nonattainment or
maintenance area that has PM10 NAAQS violations only during the first quarter of the
year (January-March), when PM emissions from other sources, such as wood smoke, are
highest. In such an area, if the highest emissions from the project area are also expected
to occur in this same quarter, then the project sponsor could complete the PM hot-spot
analysis for only that quarter. EPA notes, however, that it may be difficult to determine
whether 24-hour PM2.5 NAAQS violations will occur in only one quarter. State and local
air quality agencies should be consulted regarding when it may be appropriate for a PM
hot-spot analysis for a 24-hour PM NAAQS to cover only one quarter in an analysis year.
These agencies are responsible for monitoring air quality violations and for developing
SIP attainment demonstrations.

29

Calendar quarters in this guidance are defined in the following manner: Q1 (January-March), Q2 (AprilJune), Q3 (July-September), and Q4 (October-December). These quarters are also used by EPA and state
and local agencies to calculate design values for air quality monitoring purposes and for SIP development.

21

3.3.5

Deciding on the type of PM emissions to be modeled

See Section 2.5 for further information on what types of directly emitted PM must be
included in hot-spot analyses and Sections 4 through 6 and Section 8 on when and how to
quantify PM emissions.
3.3.6

Determining the models and methods to be used

The emissions and air quality models and methods used in PM hot-spot analyses must be
evaluated and chosen through the process established by each areas interagency
consultation procedures (40 CFR 93.105(c)(1)(i)). The latest approved emissions
models must be used in PM hot-spot analyses (40 CFR 93.111). See Sections 3.4 through
3.6 and the subsequent sections of the guidance they refer to for specific information
about models and methods that apply.
Note: It is important to select an air quality model to be used in the PM hot-spot analysis
early in the process, since this information is necessary to prepare emissions model
outputs for air quality modeling purposes. See Section 7 for further information on when
AERMOD and CAL3QHCR are recommended air quality models for PM hot-spot
analyses.
3.3.7

Obtaining project-specific data

The conformity rule requires that the latest planning assumptions available at the time
that the analysis begins be used in conformity determinations (40 CFR 93.110). In
addition, the regulation states that hot-spot analysis assumptions must be consistent with
those assumptions used in the regional emissions analysis for any inputs that are required
for both analyses (40 CFR 93.123(c)(3)).
The project sponsor should use project-specific data for both emissions and air quality
modeling whenever possible, though default inputs may be appropriate in some cases.
The use of project-specific versus default data is discussed further in this guidance.
The following are examples of data needed to run MOVES or EMFAC, as described in
Sections 4 and 5:
Traffic data sufficient to characterize each link in the project area;
Starts per hour and number of vehicles idling during each hour for off-network
links/sources;
Vehicle types and age distribution expected in the project area; and
Temperature and humidity data for each month and hour included in the analysis.
Depending on the air quality model to be used, the following are examples of data that
will likely be needed, as described in Sections 7 through 9:
Surface meteorological data from monitors that measure the atmosphere near the
ground;
22

Upper air data describing the vertical temperature profile of the atmosphere;
Land use data describing surface characteristics near the surface meteorological
monitors;
Nearby population data; and
Information necessary for determining locations of air quality modeling receptors.

To complete the PM hot-spot analysis, areas will also need data on background
concentrations in the project area from nearby or other emission sources, as described in
Section 8.

3.4

ESTIMATE ON-ROAD MOTOR VEHICLE EMISSIONS (STEP 3)

There are two approved motor vehicle emissions models available for estimating the
projects exhaust, brake wear, and tire wear emissions. See Section 4 for more on
estimating these PM emissions with EPAs MOVES model. Section 5 describes how to
apply EMFAC for estimating these emissions for projects in California.

3.5

ESTIMATE EMISSIONS FROM ROAD DUST, CONSTRUCTION, AND

ADDITIONAL SOURCES (STEP 4)

Section 2.5 provides more information about when re-entrained road dust and/or
construction emissions are included in PM hot-spot analyses. Section 6 describes
methods for estimating these emissions.
There may be other sources of emissions that also need to be estimated, and included in
air quality modeling. Section 8 provides further information regarding how to account
for these emissions in a PM hot-spot analysis and Appendix I describes how to estimate
locomotive emissions.

3.6

SELECT AN AIR QUALITY MODEL, DATA INPUTS AND RECEPTORS

(STEP 5)

An air quality model estimates PM concentrations at specific points in the project area
known as receptors. Emissions that result from the project (including those from
vehicles, dust, and construction from Steps 3 and 4) as well as any other nearby emission
sources that are affected by the project (e.g., expanded locomotive emissions at a freight
terminal) are included in the selected air quality model, which predicts how emissions are
dispersed based on meteorological and other input data.
There are two air quality modelsAERMOD and CAL3QHCR recommended for use
in PM hot-spot analyses, depending on the project involved. Basic information about

23

these models, including how to select an appropriate model for a particular project and
the data needed to run them, is found in Section 7 and Appendix J.

3.7

DETERMINE BACKGROUND CONCENTRATIONS FROM NEARBY AND

OTHER SOURCES (STEP 6)

The PM hot-spot analysis must also account for background PM concentrations in the
project area. Section 8 provides further information on selecting representative
background concentrations, including when to incorporate nearby sources into air quality
modeling.

3.8

CALCULATE DESIGN VALUES AND DETERMINE CONFORMITY (STEP 7)

In general, the PM concentrations estimated from air quality modeling (from Step 5) are
then combined with background concentrations (from Step 6) at the receptor locations for
both the build and no-build scenarios. The resulting statistic is referred to as a design
value; how it is calculated depends on the form of the NAAQS. If the design value in the
build scenario is less than or equal to the relevant PM NAAQS at appropriate receptors,
then the project meets conformity requirements. In the case where the design value is
greater than the NAAQS in the build scenario, a project could still meet conformity
requirements if the design values in the build scenario were less than or equal to the
design values in the no-build scenario at appropriate receptors. See Sections 2.4 and 9
for further details on build/no-build approaches and implementation.

3.9

CONSIDER MITIGATION OR CONTROL MEASURES (STEP 8)

Where a project does not meet conformity requirements, a project sponsor may consider
mitigation or control measures to reduce emissions in the project area. If such measures
are considered, additional modeling will need to be completed and new design values
calculated to ensure that conformity requirements are met. A project sponsor could
decide to add mitigation or control measures at any time in the process; such measures
must include written commitments for implementation (40 CFR 93.125). See Section 10
for more information on possible measures for consideration.

24

3.10 DOCUMENT THE PM HOT-SPOT ANALYSIS (STEP 9)

The PM hot-spot analysis should include sufficient documentation to support the
conclusion that a proposed project meets conformity rule requirements per 40 CFR
93.116 and 93.123. This documentation should include, at a minimum:
A description of the proposed project, including where the project is located, the
projects scope (e.g., adding an interchange, widening a highway, expanding a
major bus terminal), when the project is expected to be open to traffic, travel
activity projected for the analysis year(s), and what part of 40 CFR 93.123(b)(1)
applies;30
A description of the analysis year(s) examined and the factors considered in
determining the year(s) of peak emissions;
Emissions modeling, including the emissions model used (e.g., MOVES),
modeling inputs and results, and how the project was characterized in terms of
links;
Modeling inputs and results for estimating re-entrained road dust, construction
emissions, and any nearby source emissions (if applicable to a particular PM hotspot analysis);
Air quality modeling data, including the air quality model used, modeling inputs
and results, and description of the receptors employed in the analysis;
A description of the assumptions used to determine background concentrations;
A discussion of any mitigation or control measures that will be implemented, the
methods and assumptions used to quantify their expected effects, and associated
written commitments;
A description of how the interagency consultation and public participation
requirements in 40 CFR 93.105 were met; and
A conclusion for how the proposed project meets 40 CFR 93.116 and 93.123
conformity requirements for the PM2.5 and/or PM10 NAAQS.
Documentation should describe the sources of data used in preparing emissions and air
quality modeling inputs. This documentation should also describe any critical
assumptions that have the potential to affect predicted concentrations. Documentation of
PM hot-spot analyses would be included in the project-level conformity determination.

30

This information could reference the appropriate sections of any NEPA document prepared for the
project.

25

Section 4: Estimating Project-Level PM Emissions Using

MOVES
4.1

INTRODUCTION

This section of the guidance describes how to use MOVES to estimate PM exhaust, brake
wear, and tire wear emissions for PM hot-spot analyses outside of California.31 This
section focuses on determining the appropriate project-level inputs and how MOVES
should be run to provide the necessary information to complete air quality modeling.32
MOVES is a computer model designed by EPA to estimate emissions from cars, trucks,
buses and motorcycles. MOVES replaces MOBILE6.2, EPAs previous emissions
model.33 MOVES is based on an extensive review of in-use vehicle data collected and
analyzed since the release of MOBILE6.2. MOVES estimates PM emissions to account
for speed and temperature variations and models emissions at a high resolution. As a
result, MOVES allows users to incorporate a much wider array of vehicle activity data
for each roadway link, as well as start and extended idle activity in transit or other
terminal projects.
Exhibit 4-1 (following page) shows the necessary steps for applying the MOVES model
for project-level PM hot-spot analyses.
This section presumes users already have a basic understanding of how to run the
MOVES model.34 MOVES includes a default database of meteorology, fleet, activity,
fuel, and control program data for the entire United States. The data included in this
database come from a variety of sources which are not necessarily the most accurate or
up-to-date information available at the local level for a particular project. This section
describes when the use of that default database is appropriate for PM hot-spot analysis, as
well as when available local data must be used (40 CFR 93.110 and 93.123(c)).

31

This guidance is applicable to current and future versions of the MOVES model, unless EPA notes

otherwise when approving the model for conformity purposes.

32
Technical guidance on using MOVES for regional emissions inventories can be found in Technical

Guidance on the Use of MOVES2010 for Emission Inventory Preparation in State Implementation Plans

and Transportation Conformity, EPA-420-B-10-023 (April 2010); available online at:

www.epa.gov/otaq/stateresources/transconf/policy.htm.

33
EPA stated in the preamble to the March 2006 final rule that finalizing the MOVES emissions model was

critical before quantitative PM hot-spot analyses are required, due to the limitations of applying

MOBILE6.2 for PM at the project level. See EPAs March 2006 final rule for further information (71 FR

12498-12502).

34
The MOVES model, user guide, and supporting documentation are available online at:

www.epa.gov/otaq/models/moves/index.htm.

26

Exhibit 4-1. Steps for Using MOVES in a Quantitative PM Hot-spot Analysis

Note: The steps in this exhibit and in the accompanying text describe how to use MOVES at the
project-level for a PM hot-spot analysis.

27

As discussed in Section 2.4, it is suggested that project sponsors conduct emissions and
air quality modeling for the project build scenario first. If the resulting design value does
not exceed the NAAQS, then the project meets the hot-spot analysis requirements of
project-level conformity, and it is not necessary to model the no-build scenario.
Following this approach will allow users to avoid unnecessary emissions and air quality
modeling.
Finally, Section 4 describes how to use MOVES to estimate emissions from a highway or
transit project that requires a PM hot-spot analysis (the project); this section could also
be used to estimate emissions for any other highway and transit facilities in the project
area, when necessary.

4.2

CHARACTERIZING A PROJECT IN TERMS OF LINKS

Prior to entering data into MOVES, the first step is to identify the project type and the
associated emission processes (running, start, brake wear, tire wear, extended idle, and
crankcase) to be modeled. This guidance distinguishes between two types of
transportation projects: (1) highway and intersection projects, and (2) transit or other
terminal projects:
For highway and intersection projects, running exhaust, crankcase, brake wear,
and tire wear emissions are the main focus.
For transit and other terminal projects, start, crankcase, and extended idle
emissions are typically needed; in some cases, these projects will also need to
address cruise, approach and departure running exhaust emissions on affected
links.
The goal of defining a projects links is to accurately capture emissions where they occur.
Within MOVES, a link represents a segment of road or an off-network location where
a certain type of vehicle activity occurs.35 Generally, the links specified for a project
should include segments with similar traffic/activity conditions and characteristics (e.g.,
decelerating vehicles approaching an intersection should be treated as one link). From
the link-specific activity and other inputs, MOVES calculates emissions from every link
of a project for a given time period (or run). In MOVES, running emissions, including
periods of idling at traffic signals, are defined in the Links Importer (see Section 4.5.6),
while starts and extended periods of idling (e.g., truck idling at a freight terminal) are
defined in the Off-Network Importer (see Section 4.5.9). There are no limits to the
number of links that can be defined in MOVES.

35

Off-network in the context of MOVES refers to an area of activity not occurring on a roadway.
Examples of off-network links include parking lots and freight or bus terminals.

28

4.2.1

Highway and intersection projects

General
A PM hot-spot analysis fundamentally depends on the availability of accurate data on
roadway link speed and traffic volumes for build and no-build scenarios.36 Thus, local
traffic data should be used to characterize each link sufficiently. It is recommended that
the user divide a project into separate links to allow sufficient resolution at different
vehicle traffic and activity patterns; characterizing this variability in emissions within the
project area will assist in air quality modeling (see Section 7).
In MOVES, activity on free-flow highway links can be defined by an average speed, link
drive schedule, or operating mode (Op-Mode) distribution (discussed in Section 4.5.7).
For analyses with MOVES, average speed and traffic volume, at a minimum, is needed
for each link. If no other information is available, MOVES uses default assumptions of
vehicle activity patterns (called drive cycles) for average speed and type of roadway to
estimate emissions. Default drive cycles use different combinations of vehicle activity
(acceleration, deceleration, cruise, and/or idle) depending on the speed and road type.
For example, if the link average speed is 30 mph and it is an urban arterial (urban
unrestricted road type), MOVES uses a default drive cycle that includes a high proportion
of acceleration, deceleration, and idle activity as would be expected on an urban arterial
with frequent stops. If the average speed is 60 mph and it is a rural freeway (rural
restricted road type), MOVES uses a default drive cycle that assumes a higher proportion
of cruise activity, smaller proportions of acceleration and deceleration activity, and little
or no idle activity.
Project sponsors should determine average congested speeds by using appropriate
methods based on best practices used for highway analysis. 37 Some resources are
available through FHWAs Travel Model Improvement Program (TMIP).38
Methodologies for computing intersection control delay are provided in the Highway
Capacity Manual 2000.39
As described further in Section 4.5.7, users should take advantage of the full capabilities
of MOVES for estimating emissions on different highway and intersection project links.
36

Project sponsors should document available traffic data sets, their sources, key assumptions, and the
methods used to develop build and no-build scenario inputs for MOVES. Documentation should include
differences between how build and no-build traffic projections are obtained. For projects of local air
quality concern, differences in traffic volumes and other activity changes between the build and no-build
scenarios must be accounted for in the data that is used in the PM hot-spot analysis.
37
As discussed in Section 7, the use of the CAL3QHCR queuing algorithm for intersection idle queues is
not recommended. Rather, idling vehicles should be represented in combination with decelerating,
accelerating, and free-flow traffic on an approach segment of an intersection.
38
See FHWAs TMIP website: http://tmip.fhwa.dot.gov/.
39
Users should consult the most recent version of the Highway Capacity Manual. As of the release of this
guidance, the latest version is the Highway Capacity Manual 2000, which can be obtained from the
Transportation Research Board (see http://144.171.11.107/Main/Public/Blurbs/152169.aspx for details).

29

Although average speeds and travel volumes are typically available for most
transportation projects and may need to be relied upon during the transition to using
MOVES, users can develop and use more precise data through the MOVES Operating
Mode Distribution Importer or Link Drive Schedule Importer, as described further below.
When more detailed data are available to describe the pattern of changes in vehicle
activity (proportion of time in acceleration, deceleration, cruise, or idle activity) over a
length of road, MOVES is capable of calculating these specific emission impacts. EPA
encourages users to consider these options for highway and intersection projects,
especially as MOVES is implemented further into the future, or for more advanced
MOVES applications.
Free-flow Highway Links
The links defined in MOVES should capture the expected physical layout of a project and
representative variations in vehicle activity. A simple example would be a single, one
directional, four-lane highway that could be characterized as just one link. More
sophisticated analyses may break up traffic flow on that single link into multiple links of
varying operating modes or drive cycles that may have different emission factors
depending on the relative acceleration, cruise, or deceleration activity on each segment of
that link. In general, the definition of a link will depend on how much the type of vehicle
activity (acceleration, deceleration, cruise or idle) changes over a length of roadway, the
level of detail of available data, and the modeling approach used with MOVES. For a
highway lane where vehicle behavior is fairly constant, the length of the link could be
longer and the use of detailed activity data will have a smaller impact on results.
Intersection Links
If the project analysis involves intersections, the intersections need to be treated
separately from the free-flow links that connect to those intersections. Although road
segments between intersections may experience free-flow traffic operations, the
approaches and departures from the intersections will likely involve acceleration,
deceleration, and idling activity not present on the free-flow link. For intersection
modeling, the definition of link length will depend on the geometry of the intersection,
how that geometry affects vehicle activity, and the level of detail of available activity
information. Guidance for defining intersection links is given in Appendix D, but the
definition of links used for a particular project will depend of the specific details of that
project and the amount of available activity information.40
Note: For both free-flow highway and intersection links, users may directly enter output
from traffic simulation models in the form of second-by-second individual vehicle
trajectories. These vehicle trajectories for each road segment can be input into MOVES
using the Link Drive Schedule Importer and defined as unique LinkIDs. There are no
limits in MOVES as to how many links can be defined; however, model run times
40

As discussed in Section 7, the use of the CAL3QHCR queuing algorithm for intersection idle queues is
not recommended. Rather, idling vehicles should be represented in combination with decelerating,
accelerating, and free-flow traffic on an approach segment of an intersection.

30

increase as the user defines more links. More information on using vehicle trajectories
from traffic micro-simulation models is found in Appendix D.
4.2.2

Transit and other terminal projects

For off-network sources such as a bus terminal or intermodal freight terminal, the user
should have information on starts per hour and number of vehicles idling during each
hour. This activity will likely vary from hour to hour. Additionally, if there are vehicles
starting, it is necessary to provide an estimate of the duration that vehicles are parked
before starting (soak-time distribution). It is recommended that the user divide such a
project into separate links to appropriately characterize variability in emission density
within the project area (as discussed in Section 7). In this case, each link describes an
area with a certain number of vehicle starts per hour, or a certain number of vehicles
idling during each hour.
Some transit and other terminal projects may have significant running emissions similar
to free-flow highway projects (such as buses and trucks coming to and from an
intermodal terminal). These emissions can be calculated by defining one or more unique
running links as described in Section 4.2.1 and Appendix D (that is, in addition to any
other roadway links associated with the project). These running link emissions can then
be aggregated with the emissions from starts and idling from non-running activity on the
transit or other terminal link outside of the MOVES model to generate the necessary air
quality model inputs.
Long duration idling (classified in MOVES as OpModeID 200) can only be modeled in
MOVES for long-haul combination trucks. Idling for other vehicles and shorter periods
of idling for long-haul combination trucks should be modeled as a project link with an
operating mode distribution that consists only of idle operation (OpMode 1). This can be
specified in the Links table by inputting the vehicle population and specifying an average
speed of 0 mph.
Note: The user may choose to exclude sources such as a separate service drive, separate
small employee parking lot, or other minor sources that are determined to be
insignificant to project emissions.

4.3

DETERMINING THE NUMBER OF MOVES RUNS

4.3.1

General

When MOVES is run at the project scale, it estimates emissions for only the hour
specified by the user. Before running MOVES to calculate emission factors, users should
first determine the number of unique scenarios that can sufficiently describe activity
variation in a project. In most projects, traffic volume, average speed, idling, fleet mix,
and the corresponding emission factors will likely vary from hour to hour, day to day,
and month to month. However, it is unlikely that data are readily available that capture
31

such finite changes. Project sponsors may have activity data collected at a range of
possible temporal resolutions. The conformity rule requires the use of the latest planning
assumptions or data available at the time the conformity analysis begins (40 CFR
93.110).41 Depending on the sophistication of the activity data analysis for a given
project, these data may range from a daily average-hour and peak-hour value to hourly
estimates for all days of the year. EPA encourages the development of sufficient travel
activity data to capture the expected ranges of traffic conditions for the build and no-build
scenarios.
The number of MOVES runs should be based on the best available activity data and the
PM NAAQS involved. One of the advantages to using MOVES is that, for the first time,
PM emission estimates are sensitive to temperature changes through a day and across a
year. Therefore, EPA is recommending the minimum number of MOVES runs that is
necessary for PM hot-spot analysis to capture changes in emission rates due to changes in
ambient conditions.42 Exhibit 4-2 includes EPAs recommendations for PM hot-spot
analyses:
Exhibit 4-2. Typical Number of MOVES Runs for an Analysis Year
Applicable NAAQS

Build Scenario

No-build Scenario43

Annual PM2.5 NAAQS only

16

16

24-hour PM2.5 NAAQS only

16 (4 in certain cases)

16 (4 in certain cases)

24-hour PM10 NAAQS only

16 (4 in certain cases)

16 (4 in certain cases)

Annual and 24-hour PM

NAAQS44

16

16

Hot-spot analyses for the annual PM2.5 NAAQS should include 16 unique MOVES runs
(i.e., four runs for different time periods for each of four calendar quarters). For a typical
build/no-build analysis, a total of 32 runs would be needed (16 for the build scenario and
16 for the no-build scenario). Hot-spot analyses for only the 24-hour PM2.5 or PM10
NAAQS should also be completed with 16 MOVES runs for each scenario, except in
cases where potential PM NAAQS violations are expected to occur in only one quarter of
the calendar year. In such cases, the user may choose to model only that quarter with

41

See EPA and DOT Joint Guidance for the Use of Latest Planning Assumptions in Transportation
Conformity Determinations, EPA-420-B-08-901 (December 2008) for a more detailed discussion of the
latest planning assumptions requirements:
www.epa.gov/otaq/stateresources/transconf/policy/420b08901.pdf.
42
Information on PM emission rate sensitivity to temperature inputs is available in Draft MOVES2009
Highway Vehicle Temperature, Humidity, Air Conditioning, and Inspection and Maintenance
Adjustments at: www.epa.gov/otaq/models/moves/techdocs/420p09003.pdf.
43
There are some cases where the no-build scenario and associated emissions and air quality modeling is
not necessary. See Section 2.4 for further information.
44
Such a situation would include cases where a project is located in a nonattainment/maintenance area for
both the annual PM2.5 NAAQS and either a 24-hour PM2.5 NAAQS or the 24-hour PM10 NAAQS.

32

four MOVES runs for each scenario. See Section 3.3 for more information on when
using fewer MOVES runs is appropriate for the 24-hour PM NAAQS.
The product of the MOVES analysis is a years (or quarters) worth of hour-specific
emission factors for each project link that will be applied to the appropriate air quality
model (discussed in Section 7) and compared to the relevant PM NAAQS (discussed in
Section 9). The following subsections provide further information for determining
MOVES runs for all PM NAAQS, based on the level of available travel activity data.
4.3.2

Projects with typical travel activity data

Traffic forecasts for highway and intersection projects are often completed for annual
average daily traffic volumes, with an allocation factor for a daily peak-hour volume.
This data can be used to conduct an analysis with MOVES that is representative for all
hours of the year. To complete 16 MOVES runs as outlined above, the user should run
MOVES for four months: January, April, July, and October; and four weekday time
periods: morning peak (AM), midday (MD), evening peak (PM), and overnight (ON).45
The AM and PM peak periods should be run with peak-hour traffic activity; MD and ON
periods should be run with average-hour activity. The most reasonable methods in
accordance with good practice should be used to obtain the peak hour allocation factors
and diurnal distribution of traffic; these methods must be determined in accordance with
interagency consultation procedures (40 CFR 93.105(c)(1)(i)).
The results for each of the four hours can then be extrapolated to cover the entire day.
For example, the peak-hour volume can be used to represent activity conditions over a
three-hour morning (AM) and three-hour evening (PM) period. The remaining 18 hours
of the day can be represented by the average-hour volume. These 18 hours would be
divided into a midday (MD) and overnight (ON) scenario.
The following is one suggested approach for an analysis employing the averagehour/peak-hour traffic scenario:
Morning peak (AM) emissions based on traffic data and meteorology occurring
between 6 a.m. and 9 a.m.;
Midday (MD) emissions based on data from 9 a.m. to 4 p.m.;
Evening peak (PM) emissions based on data from 4 p.m. to 7 p.m.; and
Overnight (ON) emissions based on data from 7 p.m. to 6 a.m.
If there are local or project-specific data to suggest that the AM or PM peak traffic
periods will occur in different hours than the default values suggested here, or over a
longer or shorter period of time, that information should be documented and the hours
representing each time period adjusted accordingly. Additionally, users should determine
peak periods for the build and no-build scenarios independently and not assume that each
scenario is identical.
45

If only four MOVES runs are required for a PM hot-spot analysis for a 24-hour PM NAAQS, four runs
would be done for the same weekday time periods, except only for one quarter (i.e., January, April, July, or
October) for each build or no-build scenario.

33

The emission factors for each months runs should be used for the other months within
the quarter. The months suggested for the minimum number of MOVES runs correspond
to the first month of each quarter. For instance, January emissions should be assumed to
represent February and March emissions, April should be used to represent May and June
emissions, and so forth.46
4.3.3

Projects with additional travel activity data

Some project sponsors may have developed traffic or other activity data to show
variations in volume and speed across hours, days, or months. Additionally, if users are
modeling a transit or other terminal project, traffic volumes, starts, and idling estimates
are likely to be readily available for each hour of the day. Under either of these
circumstances, users have the option of applying the methodology described above (using
average-hour and peak-hour as representative for all hours of the year) if it is determined
through the interagency consultation process that using the additional data would not
significantly impact the emissions modeling results. Alternatively, additional MOVES
runs could be generated to produce unique emission factors using these additional activity
data and emission factors for each period of time for which specific activity data are
available.

4.4

DEVELOPING BASIC RUN SPECIFICATION INPUTS

Once the user has defined the project conceptually in terms of links and determined the
number of MOVES runs, the next step in using MOVES for project-level analyses is to
develop a run specification (RunSpec). The RunSpec is a computer file in XML
format that can be edited and executed directly or with the MOVES Graphical User
Interface (GUI). MOVES needs the user to set up a RunSpec to define the place and time
of the analysis as well as the vehicle types, road types, fuel types, and the emissionproducing processes and pollutants that will be included in the analysis.
The headings in this subsection describe each set of input options needed to create the
RunSpec as defined in the Navigation panel of the MOVES GUI. In order to create a
project-level RunSpec, the user would go down the Navigation panel filling in the
appropriate data for each of the items listed. A new panel will open for each item:
Description
Scale
Time Spans
Geographic Bounds
Vehicles/Equipment
Road Type
Pollutants and Processes
Manage Input Data Sets
46

Rather than use the middle month of the first quarter (February), January is used because it is typically
the coldest month of the year and therefore has the highest PM emission rates.

34

Strategies
Output
Advanced Performance Features

Additional information on each panel can be found in the MOVES User Guide available
on EPAs website (www.epa.gov/otaq/models/moves/index.htm). The appropriate
sections of the user guide are referenced when describing the RunSpec creation process
below.
4.4.1 Description
(MOVES User Guide Section 2.2.1)
The Description panel allows the user to enter a description of the RunSpec using up to
5,000 characters of text. Entering a complete description of the RunSpec is important for
users to keep track of their MOVES runs as well as to provide supporting documentation
for the regulatory submission. Users may want to identify the project, the time period
being analyzed, and the purpose of the analysis in this field.
4.4.2 Scale
(MOVES User Guide Section 2.2.2)
The Scale panel in MOVES allows the user to select different scales or domains for the
MOVES analysis. All MOVES runs for project-level analysis must be done using the
Project domain in the Scale panel. Selecting the Project domain is necessary to
allow MOVES to accept detailed activity input at the link level.47
Users can select either Inventory or Emission Rates as output, depending on the air
quality model being used:
When using AERMOD, a grams/hour emission factor is needed. Users should
select Inventory, which produces results for total emissions on each link; this is
equivalent to a grams/hour/link emission factor.
When using CAL3QHCR, the Emission Rates option should be selected to
produce link specific grams/vehicle-mile emission factors.
This guidance explains the steps of post-processing both Inventory and Emission
Rates results to produce the desired emission factors in Section 4.6.

47

Running MOVES using the County or National domains would not allow for detailed link-level
input or output that is needed for PM hot-spot analyses.

35

4.4.3 Time Spans

(MOVES User Guide Section 2.2.3)
The Time Spans panel is used to define the specific time period covered in the MOVES
run. The Time Spans panel allows the user to select the time aggregation level and the
year, month, day, and hour included in the run.
For the project domain, the MOVES model processes one hour, of one day, of one
month, of one year for each run; that is, each MOVES run represents one specific hour.
The user should enter the desired time period in the MOVES Time Span panel for
estimating PM2.5 and/or PM10 emissions for the relevant NAAQS in a given
nonattainment or maintenance area. Time aggregation should be set to hour, which
indicates no pre-aggregation. The day selection should be set to weekday or
weekend, but not both. Most users will be defining activity for a typical weekday. The
year, month, and hour should be set to specifically describe each MOVES run. For
instance, one run might be: 2015, January, 8:00 to 8:59 a.m. (the start and end hours both
set to 8:00 to 8:59 a.m.). The user may choose to build a batch file to automate the
process of running multiple scenarios.48
4.4.4 Geographic Bounds
(MOVES User Guide Section 2.2.4)
The Geographic Bounds panel allows the user to define the specific county that will be
modeled. The MOVES database includes county codes and descriptive information for
all 3,222 counties in the United States. Specifying a county in MOVES determines
certain default information for the analysis. Users should select the specific county
where the project is located. Only a single county (or single custom domain) can be
included in a MOVES run at the project level. If a project spans multiple counties, users
have three options:
1. If the fuel supply and age distribution of vehicles in the fleet are the same for all
of the counties, select the county in which the majority of the project area is
located;
2. If not, separate the project into multiple parts (each of which is in a separate
county) and do a separate MOVES run for each part; or
3. Use the custom domain option to model one unique area that represents all the
project counties.
4.4.5 Vehicles/Equipment
(MOVES User Guide Section 2.2.5)
The Vehicles/Equipment panel is used to specify the vehicle types that are included in the
MOVES run. MOVES allows the user to select from among 13 source use types (the
terminology that MOVES uses to describe vehicle types) and several different fuels.
48

For more information about using batch commands, see Appendix C of the MOVES User Guide,
available online at: www.epa.gov/oms/models/moves/index.htm.

36

Some fuel/source type combinations do not exist (e.g., diesel motorcycles) and therefore
are not included in the MOVES database. PM hot-spot analyses must include all vehicle
types that are expected to operate in the project area. Users should select the appropriate
fuel and vehicle type combinations in the On Road Vehicle Equipment panel to reflect
the full range of vehicles that will operate in the project area. The fuel type Placeholder
Fuel Type should not be selected as it can cause errors.
4.4.6 Road Type
(MOVES User Guide Section 2.2.6)
The Road Type panel is used to define the types of roads that are included in the project.
MOVES defines five different road types:
Rural Restricted Access a rural highway that can be accessed only by an onramp;
Rural Unrestricted Access all other rural roads (arterials, connectors, and local
streets);
Urban Restricted Access an urban highway that can be accessed only by an onramp;
Urban Unrestricted Access all other urban roads (arterials, connectors, and local
streets); and
Off-Network any location where the predominant activity is vehicle starts and
idling (parking lots, truck stops, rest areas, freight or bus terminals).
MOVES uses these road types to determine the default drive cycle on a particular link.
For example, MOVES uses drive cycles for unrestricted access road types that assume
stop-and-go driving, including multiple accelerations, decelerations, and short periods of
idling. For restricted access road types, MOVES uses drive cycles that include a higher
fraction of cruise activity with much less time spent accelerating or idling.
For project-level analyses, the extent upon which MOVES uses these default drive cycles
will depend on how much additional information the user can supply for the link. The
process of choosing default or local drive cycles is described in Sections 4.2 and 4.5.7.
However, even if the user will be supplying detailed, link-specific drive cycle
information or an Op-Mode distribution, road type is a necessary input in the RunSpec
and users should select one or more of the five road types that correspond to the road
types of the links that will be included in the project area. The determination of rural or
urban road types should be based on the Highway Performance Monitoring System
(HPMS) functional classification of the road type.
Additionally, any project that includes a significant number of engine starts or significant
amounts of extended idling for heavy-duty vehicles needs to include the Off-Network
road type to account for emissions from those activities properly. More details on
describing inputs for engine start and idling activity are given in Section 4.5.9.

37

4.4.7 Pollutants and Processes

(MOVES User Guide Section 2.2.7)
The Pollutant and Processes panel is used to select both the types of pollutants and the
emission processes that produce them. For PM2.5 or PM10 emissions, MOVES calculates
emissions for several pollutant species:
Organic Carbon (OC)
Elemental Carbon (EC)
Sulfate Particulate
Brake Wear Particulate
Tire Wear Particulate
In addition, MOVES divides emissions by pollutant process. For a PM hot-spot analysis,
the categories are:
Running Exhaust
Start Exhaust
Extended Idle Exhaust
Crankcase Running Exhaust
Crankcase Start Exhaust
Crankcase Extended Idle Exhaust
Brake Wear
Tire Wear
For a PM2.5 hot-spot analysis, the user should select Primary Exhaust PM2.5 - Total (or
Primary Exhaust PM10 - Total if it is a PM10 hot-spot analysis), which is an aggregate
of each of the pollutant species (OC, EC, and sulfate) for each process. For MOVES to
run, the user would select each individual PM species (i.e., Primary PM2.5 - Organic
Carbon, Primary PM2.5 - Elemental Carbon, Primary PM2.5 - Sulfate Particulate, or
the PM10 equivalents). In addition, if the analysis has road links with running emissions,
users would also select Primary PM2.5 - Brake Wear Particulate and Primary PM2.5
Tire Wear Particulate (or their PM10 equivalents) as brake wear and tire wear are not
included in the exhaust totals.
MOVES does not automatically sum the appropriate processes to create an aggregate
emission factor, although EPA is considering creating one or more MOVES scripts that
would automate the summing of aggregate emissions when completing project-level
analyses.49 Therefore, the user should calculate total PM from the MOVES output table
results for each link using the formulas described below:
For highway links (roads, intersections, ramps, etc.) where output was specified as a
grams/vehicle-mile emission factor (Emission Rates output), the aggregate total PM

49

These scripts would be made available for download on the MOVES website
(www.epa.gov/otaq/models/moves/tools.htm), when available.

38

emission factor (i.e., the sum of all PM emission factors for a link) needs to be calculated
using the formula:
PMaggregate total = (PMtotal running) + (PMtotal crankcase running) + (brake wear) + (tire wear)
For transit and other terminal project activity (starts and extended idle) where output was
selected as grams/hour (Inventory output), the aggregate total PM emission factor (i.e.,
the sum of all PM emission factors for a link) needs to be calculated using the formula:
PMaggregate total = (PMtotal starts) + (PMtotal crankcase starts) + (PMtotal ext. idle) +
(PMtotal crankcase ext. idle)
For transit and other terminal project links that contain starts and extended idling as well
as running emissions, and output was selected as Inventory output (grams/hour/link),
the aggregate total PM emission factor for each link needs to be calculated using the
formula:
PMaggregate total = (PMtotal running) + (PMtotal crankcase running) + (PMtotal starts) +
(PMtotal crankcase starts) + (PMtotal ext. idle) + (PMtotal crankcase ext. idle) +
(brake wear) + (tire wear)
4.4.8 Manage Input Data Sets
(MOVES User Guide Section 2.2.8)
Most analyses will not use the Manage Input Data Sets panel. One possible application is
to specify user-supplied databases to be read by the model during execution of a run.
However, for project-level analysis in MOVES, the Project Data Manager (described
below) serves this same function while providing for the creation of data table templates
and for the review of default data. EPA specifically developed the Project Data Manager
for project analyses and recommends using it, instead of the Manage Input Databases
panel, to create and specify user supplied database tables.
4.4.9 Strategies
(MOVES User Guide Section 2.2.9)
In MOVES, the Strategies panel can be used to model alternative control strategies that
affect the composition of the vehicle fleet. The MOVES model has two alternative
control strategies built into the Strategies panel:
The Alternative Vehicle Fuels and Technologies (AVFT) strategy allows users to
modify the fraction of alternative fuel vehicles in each model year.
The On-Road Retrofit strategy allows the user to enter information about diesel
trucks and buses that have been retrofitted with emission control equipment.
A common use of the AVFT panel would be to change the diesel fractions of the fleet.
Users can modify the default assumptions about diesel, gasoline, and CNG use for each
source type and model year. If local information is available on these fractions, the
39

AVFT should be used to modify the defaults. For instance, users modeling a transit
facility may use the AVFT to specify that the entire fleet of buses uses CNG, or entirely
diesel, rather than a default mix of both fuel types.
Another application of the Strategies panel would be to apply a retrofit program to the
fleet. For example, a bus terminal project might include plans to mitigate emissions by
retrofitting the bus fleet that will operate at that terminal with control equipment that
reduces PM emissions. In that case, the user would specify the details of the retrofit
project using the On-Road Retrofit Strategy panel. The latest guidance on retrofit
programs can be located at the EPAs conformity website:
www.epa.gov/otaq/stateresources/transconf/policy.htm. Strategies that affect vehicle
activity, such as implementing a truck idle reduction plan, should be handled in the OffNetwork Importer and Links Importer.
See Section 10 for further information regarding the inclusion of mitigation and/or
control measures in PM hot-spot analyses.
4.4.10 Output
(MOVES User Guide Section 2.2.10)
Selecting Output in the Navigation panel provides access to two additional panels:
General Output and Output Emissions Detail. Each of these allows the user to specify
aspects of the output data.
Under General Output, users should make sure to choose grams and miles for the
output units in order to provide results for air quality modeling. Also, Distance
Traveled and Population should be selected under the Activity heading to obtain
vehicle volume information for each link in the output.
Output Emissions Detail is used to specify the level of detail desired in the output data.
Emissions by hour and link are the default selections and cannot be changed. Road type
will also be checked if output by Emission Rates was selected. EPA recommends that
users check the box labeled Emission Process. No other boxes should be selected in
order to produce fleet aggregate emission factors for each link.50 Emission rates for each
process can be appropriately summed to calculate aggregate PM emission factors for each
link (as described in Section 4.4.7).
4.4.11 Advanced Performance Features
(MOVES User Guide Section 2.2.11)
Most analyses will not use the Advanced Performance Features panel. This menu item is
used to invoke features of MOVES that improve run time for complex model runs by
50
Users may choose to select output by Source Type if using AERMOD to model a volume source. It may
be appropriate to characterize a volume source with an initial vertical dimension and source release height
that is the emission-weighted average of light-duty and heavy-duty vehicles. See Section J.3.3 of the
Appendix for more information on characterizing volume sources.

40

saving and reusing intermediate results. For specific applications, the user may want to
save data for deriving the intermediate MOVES calculation of an Op-Mode
Distribution from an average speed or link drive schedule. This is discussed further in
the MOVES User Guide, as well as demonstrated in the quantitative PM hot-spot analysis
example of a transit project in Appendix F.

4.5

ENTERING PROJECT DETAILS USING THE PROJECT DATA MANAGER

After completion of all the necessary panels to create the RunSpec, the user would then
create the appropriate input database tables that describe the project in detail. As
described in Section 4.3, a typical PM hot-spot analysis will involve 32 MOVES runs (16
runs for each build and no-build scenario), each run needing individual sets of input
database tables to be created. This is done using the Project Data Manager, which can be
accessed from the Pre-Processing menu item at the top of the MOVES GUI or by
selecting Enter/Edit Data in the Domain Input Database section of the Geographic
Bounds panel.
Since modeling a project involves many MOVES runs, good data management practices
are essential to prevent confusion and errors. For example, the name of the project input
database for each run should reflect the purpose of that run (e.g.,
NoBuildSpringAMPeak_in). A similar naming protocol should be used for the
RunSpec for each run. Also, each tab of the Project Data Manager includes a box for
entering a Description of Imported Data. Modelers should make liberal use of these
descriptions to (1) indicate whether default or local data were used, and (2) indicate the
source and date of any local data, along with the filename of imported spreadsheets.
These descriptions are preserved with the input database so reviewers (or future users of
the same runs) will have the documentation of inputs readily at hand.
The Project Data Manager includes multiple tabs to open importers used to enter projectspecific data. These importers are:
Meteorology
Age Distribution
Fuel Supply
Fuel Formulation
Inspection and Maintenance
Link Source Type
Links
Link Drive Schedule
Operating Mode Distribution
Off-Network
Each of the importers allows the user to create a template file with the necessary data
field names and some key fields populated. The user then edits this template to add
project-specific local data with a spreadsheet application or other tool and imports the
data files into MOVES. In some importers, there is also the option to export default data
41

from the MOVES database in order to review and then use it. Once the user determines
that the default data are accurate and applicable to the particular project, or determines
that the default data need to be changed and makes those changes, the user can then
import that data into MOVES. Details of the mechanics of using the data importers are
provided in the MOVES User Guide. Guidance for the use of these importers in PM hotspot analyses is described below.
4.5.1 Meteorology
(MOVES User Guide Section 2.3.3.4.1)
The Meteorology Data Importer is used to import temperature and humidity data for the
month and hour that are defined in the MOVES run specification. Although temperature
and humidity data can be entered for all hours, only the one hour selected in the run
specification will be used for PM hot-spot analyses. Meteorology inputs for MOVES
should be the same for build and no-build scenarios.
Users should enter data specific to the projects location and time period modeled, as PM
emissions are found to vary significantly depending on temperature. The accuracy of
emission estimates at the project level improves when meteorological data specific to the
modeled location is included. Default temperature and humidity values are available in
MOVES, but are not recommended for use in a PM hot-spot analysis.
Temperatures must be consistent with those used for the projects county in the regional
emissions analysis (40 CFR 93.123(c)(3)) as well as the air quality modeling inputs used
in the hot-spot analysis. Meteorological data may be obtained either from the National
Weather Service (NWS) or as part of a site-specific measurement program. Local
universities, the Federal Aviation Administration (FAA), military stations, and state and
local air agencies may also be sources of such data. The National Oceanic and
Atmospheric Administrations National Climatic Data Center (NCDC; online at
www.ncdc.noaa.gov/oa/ncdc.html) is the worlds largest active archive of weather data
through which years of archived data can be obtained. A data source should be selected
that is representative of local meteorological conditions. Meteorological site selection is
discussed further in Section 7.5.
As discussed in Section 4.3, MOVES will typically be run for multiple time periods and
specific meteorology data that accurately represents these runs is needed to produce
emission estimates for comparison with both the 24-hour and annual PM NAAQS. The
user should employ a minimum of four hours (corresponding to AM peak traffic/PM
peak traffic/MD traffic/ON traffic), for one day (weekday), for January, April, July, and
October. Within each period of day in each quarter, temperatures should be used that
represent the average temperature within that time period. For example, for January AM
peak periods corresponding to 6 a.m. to 9 a.m., the average January temperature based on
the meteorological record for those hours should be used in estimating the average
January AM peak period temperature for MOVES runs. The user may choose to run
additional hours and temperatures beyond the number of traffic periods for which data
exist. For example, within an 11-hour overnight (ON) modeling period, temperature data
42

could be used to differentiate hours with significantly different temperatures, despite

having assumed identical traffic estimates. Humidity estimates should be based on the
same hours and data source as the temperature estimates. See Section 4.3 for further
information on the number of MOVES runs recommended for different project analyses.
4.5.2 Age Distribution
(MOVES User Guide Section 2.3.3.4.3)
The Age Distribution Importer is used to enter data that provides the distribution of
vehicle fractions by age for each calendar year (yearID) and vehicle type
(sourceTypeID). These data are needed for running MOVES at the project level. The
distribution of ageID (the variable for age) fractions must sum to one for each vehicle
type. These inputs should generally be the same for build and no-build scenarios, unless
something about the project would change them (e.g., a bus terminal project that includes
the purchase of new buses in the build scenario).
To build a MOVES-compatible age distribution table, there are three possible options.
1. If available, users should use the latest state or local age distribution assumptions
from their SIP or transportation conformity regional emissions analysis. For the
initial transition from MOBILE6.2 to MOVES, EPA has provided a registration
distribution converter.51 The tool allows users to input a MOBILE6.2 registration
distribution table (10, 10, 5 format) and obtain a MOVES age distribution table.
Over time, users should develop age distribution data consistent with MOVES.
Some users may have local registration distribution tables for all vehicle classes.
However, there may be cases where the user has registration distributions only for
one or more vehicle classes (e.g., LDVs) and therefore relies on MOBILE6.2
defaults for the remaining vehicle classes. In these cases, the user may use
MOVES default distributions available on the EPAs website.
2. If the project is designed to serve a fleet that operates only locally, such as a
drayage yard or bus terminal, the user should provide project-specific fleet age
distribution data. For most captive fleets, an exact age distribution should be
readily available or obtainable. The data should be in a format compatible with
MOVES. This format includes age fractions in 30-year bins rather than the 25
used in MOBILE6.2. Additionally, vehicle categories need to be in terms of the
13 MOVES source types.
3. If no state or local age distribution is available, the MOVES default age
distribution should be used. This can be obtained from the tables available on the
EPA website: www.epa.gov/otaq/models/moves/tools.htm. The user can select
the analysis year(s) and find the corresponding age distribution. These fractions
are national defaults and could be significantly different than the local project age
distribution. Age distribution can have a considerable impact on emission
51

This convertor can be found online at: www.epa.gov/otaq/models/moves/tools.htm.

43

estimates, so the default data should be used only if an alternative state or local
dataset cannot be obtained.
4.5.3 Fuel Supply and Fuel Formulation
(MOVES User Guide Section 2.3.3.4.8 and 2.3.3.4.9)
The user needs to define in MOVES what fuel(s) and fuel mix will be used in the project
area. The Fuel Supply Importer and Fuel Formulation Importer are used to enter the
necessary information describing fuel mix and fuel type for each MOVES run. These
inputs should generally be the same for build and no-build scenarios, unless something
about the project would change them (e.g., a project that includes alternate fuel vehicles
and infrastructure in the build scenario).
Users should review the default fuel formulation and fuel supply data in MOVES and
make changes only if local volumetric fuel property information is available. Otherwise,
EPA recommends that the MOVES default fuel supply and formulation information be
used. The lone exception to this is in the case of Reid Vapor Pressure (RVP), where a
user should change the value to reflect the differences between ethanol and non-ethanol
blended gasoline.
For additional guidance on defining fuel supply and formulation information, consult the
EPA document Technical Guidance on the Use of MOVES2010 for Emission Inventory
Preparation in State Implementation Plans and Transportation Conformity available
online at: www.epa.gov/otaq/stateresources/transconf/policy.htm.
4.5.4 Inspection and Maintenance (I/M)
(MOVES User Guide Section 2.3.3.4.10)
MOVES does not provide a PM emission benefit from an I/M program. If the user
includes an I/M program in the run specification, the selection will have no impact on PM
emissions.
4.5.5 Link Source Type
(MOVES User Guide Section 2.3.3.4.13)
The Link Source Type Importer allows the user to enter the fraction of the link traffic
volume that is represented by each vehicle type (source type). It is not needed if the
project contains only a transit or other terminal (off-network) link. For each LinkID, the
SourceTypeHourFractions must sum to one across all source types.
Additionally, the user needs to ensure that the source types selected in the MOVES
Vehicles/Equipment panel match the source types defined through the Link Source Type
Importer.
There are no defaults that can be exported from the Link Source Type Importer. For any
analysis at the project level, the user needs to provide source type fractions for all
44

vehicles being modeled and for each MOVES run (as vehicle mixes may change from
hour to hour and month to month). There are two options available to populate the Link
Source Type input:
1. For projects that will have an entirely different source type distribution than that
of the regional fleet, the preferred option is for the user to collect project-specific
data. For projects such as bus or freight terminals or maintenance facilities that
contain links that are primarily used by a specific subset of the regional fleet,
users need to develop the fractions of link traffic volume by vehicle type data
specific to the project. This could be based on analysis of similar existing
projects through the interagency consultation process.
2. If the project traffic data suggests that the source type distribution for the project
can be represented by the distribution of the regional fleet for a given road type,
the user can provide a source type distribution consistent with the road type used
in the latest regional emissions analysis. For example, highways tend to have a
higher fraction of truck traffic than arterial roads. Therefore, the highway source
type distribution used in the regional emissions analysis may be appropriate to use
for a highway project.
4.5.6 Links
(MOVES User Guide Section 2.3.3.4.12)
The Links Importer is used to define the individual roadway links. All links being
modeled should have unique IDs. The Links Importer requires information on each
links length (in miles), traffic volume (units of vehicles per hour), average speed (miles
per hour), and road grade (percent). Users should follow guidance given above in
Section 4.2 when determining the number of links and the length of specific links.
Consult Section 7 for information on how these links should be formatted for use in air
quality modeling.
4.5.7 Describing Vehicle Activity
(MOVES User Guide Section 2.3.3.4.14 through Section 2.3.3.4.16)
MOVES determines vehicle emissions based on operating modes, which represent
different types of vehicle activity such as acceleration (at different rates), deceleration,
idle, and cruise that have distinct emission rates. MOVES handles these data in the form
of a distribution of the time vehicles spend in different operating modes. This capability
is central to the use of MOVES for PM hot-spot analyses because it allows for the
analysis of fine distinctions between vehicle behavior and emissions before and after
construction of the project. For example, the full emission benefits of a project designed
to smooth traffic flow can best be realized by taking into account the changes in
acceleration, deceleration, and idle activity that result from the project. There are several
methods that users may employ to calculate an Op-Mode distribution based on the project
design and available traffic information. MOVES currently offers three options that the
user can employ to add link activity data, depending on data availability. These are:
45

1. Provide average speed and road type through the Links input:
Using this approach, MOVES will calculate emissions based on a default drive
cycle for a given speed, grade, and road type. Input of link drive schedules or
operating mode distributions is not needed. For users modeling a free-flow link
with only basic information on average speed and volume on a link, this option
may be appropriate. This approach accounts for some differences in emissions
due to changes in operating modes associated with different average speeds on a
specific road type. However, this approach provides the least resolution when
analyzing the emission impact of a project because the default drive cycles used
by the model may not accurately reflect the specific project. For instance, due to
the range of operating modes associated with intersection projects, a single
average speed would not spatially capture localized idling and acceleration
emissions.
2. Provide a link drive schedule using the Link Drive Schedule Importer:
The Link Drive Schedule Importer allows the user to define the precise speed and
grade as a function of time (seconds) on a particular roadway link. The time
domain is entered in units of seconds, the speed variable is miles-per-hour and the
grade variable in percent grade (vertical distance/lateral distance, 100% grade
equals a 45-degree slope). MOVES builds an Operating Mode Distribution from
the Link Drive Schedule and uses it to calculate link running emissions.
Individual Link Drive Schedules cannot be entered for separate source types. The
Link Drive Schedule therefore represents the tracer path of an average vehicle
on each link. Link drive schedules could be based on observations using methods
such as chase (floating) cars on similar types of links, or on expected vehicle
activity based on an analysis of link geometry. Link drive schedules will only
represent average vehicle activity, not the full range of activity that will occur on
the link. As described in Section 4.2 and Appendix D, users can overcome this
limitation by defining multiple links for the same portion of the project (links that
overlap) with separate source distributions and drive schedules to model
individual vehicle types.
3. Provide a detailed operating mode distribution for the link:
The Operating Mode Distribution Importer allows the user to directly import
operating mode fraction data for source types, hour/day combinations, roadway
links, and pollutant/process combinations that are included in the run
specification. Operating mode distributions may be obtained from:
Op-Mode distribution data from other locations with similar geometric
and operational (traffic) characteristics;52 or
Output from traffic microsimulation models.53
52

For example, chase (or floating) cars, traffic cameras, and radar guns have been used previously to
collect some traffic data for use in intelligent transportation systems and other applications. EPA
encourages the development of validated methods for collecting verifiable vehicle operating mode
distribution data at specific locations representative of different projects covered by this guidance.

46

4.5.8

Deciding on an approach for activity

Users should consider the discussion in Section 4.2 when deciding on the appropriate
activity input. The MOVES model is capable of using complex activity datasets with
high levels of resolution to calculate link-level emissions. EPA encourages the
development of validated methods for collecting verifiable vehicle Op-Mode distribution
data at locations and in traffic conditions representative of different projects covered by
this guidance. However, the user should determine the most robust activity dataset that
can be reasonably collected while still achieving the goal of determining an accurate
assessment of the PM air quality impacts from a given project. The decision to populate
the Links table, Link Drive Schedule, or Op-Mode Distribution should be based on the
data available to the user and should reflect the vehicle activity and behavior on each
link.
Note: If either the average speed or link-drive schedule approach is used, it is not
necessary to input an Op-Mode distribution for on-road link activity.
4.5.9 Off-Network
(MOVES User Guide Section 2.3.3.4.16)
The Off-Network Importer is where the user can provide information about vehicles not
driving on the project links, but still contributing to the projects emissions. Currently,
only one off-network link may be described per run. If more than one off-network link is
associated with the project, another set of 16 MOVES runs would be needed to
characterize each additional off-network location for each build or no-build scenario.
The Off-Network Importer should be used if the project includes an area where highway
vehicles are parked, starting their engines, or in extended idling mode (such as at a truck
stop, parking lot, or passenger or freight intermodal terminal). All such areas within the
project area should be modeled, regardless of whether they are part of the project.
There are no default values available for any of the off-network inputs, so users will need
to populate the Off-Network table with information describing vehicle activity in the offnetwork area being modeled. The necessary fields are vehicle population, start fraction,
and extended idle fraction:
The vehicle population reflects the total number of vehicles parked, starting, or
idling on the off-network area over the course of the hour covered by the MOVES
run.
The start fraction is the fraction of the total vehicle population that starts during
the hour.

53

A traffic microsimulation model can be used to construct link drive schedules or operating mode
distributions if prior validation of the models predictions of speed and acceleration patterns for roadway
links similar to those in the project was conducted. If a user has a microsimulation model that has been
previously demonstrated to adequately predict speed/acceleration patterns for relevant vehicle classes (e.g.,
heavy-duty), and has a procedure for importing data into MOVES, it may be appropriate to use the
microsimulation model, subject to interagency consultation.

47

 The extended idle fraction specifies the fraction of time that the vehicle

population spends in extended idle operation in the hour.54

Extended idle operation applies only to long-haul combination trucks and is defined as
the operation of the truck's propulsion engine when not engaged in gear for a period
greater than 15 consecutive minutes, except when associated with routine stoppages due
to traffic movement or congestion.55 As discussed in Section 4.2.2, shorter periods of
idling for long-haul combination trucks and all idling for other vehicles should be
modeled as a project link with an Op-Mode distribution that consists only of idle
operation (Op-Mode 1). This can be specified in the Links table by inputting the vehicle
population and specifying an average speed of 0 mph.
For vehicle population inputs, the user should be able to rely on existing project
documentation. The user will also need to estimate the number of starts and idle
operation of the facility for other inputs, which will depend on the project involved. For
example, in a bus terminal project, the user could estimate the number of starts and idling
based on expected passenger ridership and proposed operating schedules for the buses
using the terminal. Most buses would be expected to first start early in the morning, prior
to the morning peak period. The buses might operate all day, with little or no start
activity during the midday hours. Idle operation is likely a function of the volume of
buses accessing the terminal each hour and the duration that those buses idle prior to
leaving the terminal. Conversely, an employee parking lot would have little or no idle
activity and may have the opposite trend in start activity. Typically, employees arrive
during the morning peak period and leave during the evening peak period. In this case,
most starts would occur during the evening peak period.
Information on start and idle activity should be specific to the project being modeled.
However, data from similar projects could be adapted for use in a quantitative PM hotspot analysis, when appropriate. For instance, the ratio of starts to vehicles and the
distribution of starts throughout the day for a project being analyzed could be determined
by studying a similar parking lot.
If an off-network link is defined, users need to also define an Op-Mode distribution that
describes the soak-time distribution of vehicles on the link; this will affect the start
emissions. Additionally, any extended idle operation on an off-network link needs to be
described by the Op-Mode distribution with a fraction of 1.0 for Op-Mode 200 (Extended
Idle Mode). Since there is only one possible extended idle mode in MOVES, this
fraction should always be 1.0.
The soak time is the time a vehicle is stationary with the engine turned off, following the
last time it was operated. There are no default soak-time distributions available. Soak
times and soak-time distributions should be specific to the type of project being modeled.
54

Parked fraction is not required as an input and can be left blank.

See Guidance for Quantifying and Using Long Duration Truck Idling Emission Reductions in State

Implementation Plans and Transportation Conformity; available online at

www.epa.gov/smartway/documents/420b04001.pdf.

55

48

This information could either be directly collected or obtained from information collected
for a similar project. For instance, a park-and-ride lot may have vehicles parked for eight
or nine hours prior to starting, while an intermodal freight terminal may have vehicles
parked for only one hour before starting. This information should be defined through the
appropriate distribution of soak-time Op-Modes (OpModes 101-108) in the Op-Mode
Distribution table.
The methods and assumptions used to derive off-network inputs (including starts, idle
activity, and soak-time distributions) should be documented as part of the analysis,
including any adjustments based on data from similar projects.

4.6

GENERATING EMISSION FACTORS FOR USE IN AIR QUALITY

MODELING

The MOVES model provides results as either an emission total (if Inventory output is
selected) or an emission factor (if Emission Rates output is selected). The emission
results are produced for each pollutant and process and are calculated in terms of grams
per link or grams/vehicle-mile per link. Using the equations in Section 4.4.7, the user
will need to sum the appropriate pollutants and processes to derive a link total
grams/vehicle-mile or grams/hour emission factor. These totals will be needed as inputs
into the appropriate air quality model. Instructions on running AERMOD and
CAL3QHCR for quantitative PM hot-spot analyses are in Section 7 and Appendix J.
Note: If MOVES is being run in batch-mode, or if multiple runs are being saved to the
same output database, the user should make sure to separate link emissions in the result
database by MOVESRunID or monthID, dayID, hourID. Aggregating separate
runs will result in incorrect emission rates.
4.6.1 Highway and intersection links
For links characterized as highway or running segments of a project, a
grams/vehicle-mile emission rate is needed for CAL3QHCR; if AERMOD is being used,
a grams/hour emission factor for each roadway link is needed:
CAL3QHCR uses grams/vehicle-mile emission factors and calculates air quality
estimates based on the volume of traffic and length of a given link. All of the
information necessary to generate the necessary inputs is available in the MOVES
MySQL output database. After running MOVES for a particular hour/day/month
scenario, emission results can be located in the user defined MOVES output
database in the table rateperdistance. All links defined in the Project Level
Importer will have results in the column rateperdistance. The units should have
been defined as grams and miles in the MOVES RunSpec (see Section 4.4.10).
As shown in the equations in Section 4.4.7, all relevant pollutants and processes
should be summed together to get a single rateperdistance value. This value
can then be paired with link volume and link length for use in CAL3QHCR for
each link.
49

 AERMOD uses a grams/hour emission factor for each hour of the day (which
should be mapped based on the time periods analyzed with MOVES, as described
in Section 4.3). If Inventory is selected in the Scale panel, MOVES will
produce output in terms of grams/hour/link. The user should then calculate
aggregate PM grams/hour emission factors by summing the appropriate pollutants
and processes as described in Section 4.4.7. Since AERMOD processes emission
factors in terms of grams/hour (or second), no further calculation is necessary.
Section 7 and Appendix J discuss input formats for different AERMOD source
configurations.
4.6.2

Transit and other terminal links

For transit and other terminal projects, or a combination of highway and transit or other
terminal components, AERMOD is recommended (see Section 7). AERMOD uses a
grams/hour emission factor for each hour of the day (which should be mapped based on
the time periods analyzed with MOVES as described in Section 4.3). If Inventory is
selected in the Scale panel, MOVES will produce output in terms of grams/hour/link.
The user should then calculate aggregate PM grams/hour emission factors by summing
the appropriate pollutants and processes as described in Section 4.4.7. Since AERMOD
processes emission factors in terms of grams/hour (or second), no further calculation is
necessary. Section 7 and Appendix J discuss input formats for different AERMOD
source configurations.

50

Section 5: Estimating Project-Level PM Emissions Using

EMFAC2011 (in California)
5.1

INTRODUCTION

This section of the guidance addresses the necessary steps to run EMFAC2011 to
estimate a projects exhaust, brake wear, and tire wear emissions for PM hot-spot
analyses in California.56 The California Air Resources Board (CARB) maintains the
EMission FACtors (EMFAC) model, which is approved by EPA for developing on-road
motor vehicle emission inventories and conformity analyses in California. EMFAC
models on-road mobile source emissions under multiple temporal and spatial scales; it
produces composite emission factors for an average day of a month (January to
December), a season (summer and winter), or an annual average, for specific California
geographic areas by air basin, district, and county as well as the statewide level. EMFAC
can produce PM2.5 and PM10 emission rates for three exhaust emission processes
(running, starting, and idle), tire wear, and brake wear.
EMFAC2011 consists of three modules:
EMFAC2011-LDV, which estimates passenger vehicle emissions;
EMFAC2011-HD, which estimates emissions from diesel trucks and buses over
14,000 pounds; and
EMFAC2011-SG, which integrates the output of EMFAC2011-LDV and
EMFAC2011-HD and provides users with the ability to conduct scenario
assessments for air quality and transportation planning.57
CARB has also made available, through its mobile emissions inventory web site,
EMFAC2011 databases which provide regional population, activity, emissions, and
emission rates at varying levels of detail. EPA approved EMFAC2011 for SIP and
transportation conformity purposes on March 6, 2013 (78 FR 14533). When the grace
period ends on September 6, 2013, EMFAC2011 will become the only approved motor
vehicle emissions model for all new regional emissions analyses and CO, PM10 and PM2.5
hot-spot analyses for transportation conformity determinations across California.
EPA also approved use of the EMFAC2011-PL tool for hot-spot analyses that involve a
simplified approach. EMFAC2011-PL extracts emissions factors for analyses of
projects that are consistent with the default assumptions in EMFAC2011. Section 5.5
describes how to use EMFAC2011-PL for projects covered by the simplified approach,
but some aspects of this guidance may be applicable when an alternate project-level tool
has been approved by EPA.58 Sections 5.6 through 5.9 describe how to apply
56

This guidance is applicable to EMFAC2011 and future versions of the EMFAC model, unless EPA notes
otherwise when approving the model for conformity purposes. This guidance updates the previous
EMFAC2007 guidance contained in the December 2010 version of this document (EPA-420-B-10-040).
57
The current version of EMFAC2011 model, database updates, and supporting documentation can be
downloaded from the CARB website at: www.arb.ca.gov/msei/modeling.htm
58
EPA noted in its March 2013 Federal Register notice that alternate project-level tools could be used if
EPA approves such tools as having similar performance (78 FR 14534).

51

EMFAC2011 using the detailed approach for projects that have project-specific vehicle
age distributions and/or project-specific rest and soak time data (e.g., any project that
includes starts or idling). Sections 5.2 through 5.4 apply to all PM hot-spot analyses.
More details about applying the different approaches to PM hot-spot analyses are
included later in this section.
Many of the processes and procedures contained in this section are based on procedures
described in CARBs project-level handbook for EMFAC201159 and follow the same
general organization, with additional detail and guidance for using EMFAC2011
specifically for quantitative PM hot-spot analyses, as appropriate. In addition, Appendix
G of this EPA guidance contains an example of using EMFAC2011 for a highway
project, and Appendix H contains an example of using EMFAC2011 for a transit project.
As discussed in Section 2.4, it is suggested that project sponsors conduct emissions and
air quality modeling for the project build scenario first. If the design values for the build
scenario are less than or equal to the relevant NAAQS, then the project meets the hot-spot
analysis requirements of project-level conformity and it is not necessary to model the nobuild scenario. Following this approach will allow users to avoid additional emissions
and air quality modeling. Please see Section 2.4 for additional information if the design
values for the build scenario are greater than the relevant NAAQS.
Finally, this section describes how to use EMFAC2011 to estimate emissions from a
highway and transit project that requires a PM hot-spot analysis (the project); this
section could also be used to estimate emissions for any other highway and transit
facilities in the project area, when necessary. The emission factors obtained from the
EMFAC2011 modules and databases can then be used in air quality modeling as
discussed in Section 7 of the guidance.
The general steps to using EMFAC2011 are illustrated in Exhibit 5-1. This section
presumes users already have a basic understanding of how to run EMFAC2011. Note
that there are some aspects of Section 5 that differ from the MOVES guidance discussed
in Section 4, due to the inherent differences between MOVES and EMFAC2011. For
example, using EMFAC2011 may require the use of multiple modules to obtain all the
emission factors for a project, whereas MOVES uses a single GUI. In addition,
EMFAC2011 produces emission rates for a range of average speeds only. In contrast,
MOVES calculates emission rates based on a distribution of operating modes, which
allows the option of more advanced methods of defining link-level activity.
As described in Section 2.3, decisions on how to use EMFAC2011 for a quantitative PM
hot-spot analysis should be considered through the process established by each areas
interagency consultation procedures (40 CFR 93.105(c)(1)(i)). Any technical questions
about EMFAC2011 should be directed to CARB.

59

EMFAC2011 Handbook for Project-level Analyses (CARB, January 2013), available online at:
www.arb.ca.gov/msei/emfac2011-pl-handbook-for-project-level-analyses-final-020713-2.pdf

52

Exhibit 5-1. Steps for Usin

Usingg EMFAC2011 in a Quantitative PM H
Using
Ho
Hot
ot-spot
t
Analysis60

60

The process shown in this exhibit

ex
exhhibit differs in several ways from the decision matrix iin
n CARBs
EMFAC2011 Handbook for Project-level
roject level Analyses in several respects due to the aappplication
plication here to PM
hot-spot analyses. See Section
ection 5.4 for more information.

53

5.2

CHARACTERIZING A PROJECT IN TERMS OF LINKS

Prior to using EMFAC2011, users first need to identify the project type and the
associated emission processes (running, start, brake wear, tire wear, and idle exhaust) to
be modeled. This guidance distinguishes between two types of transportation projects:
(1) highway and intersection projects, and (2) transit or other terminal projects:
For highway and intersection projects, running exhaust, brake wear, and tire wear
emissions are the main focus.
For transit and other terminal projects, start and idle emissions are typically
needed, and in some cases these projects will also need to address cruise,
approach and departure running exhaust emissions on affected links.
The goal of defining a projects links is to accurately capture emissions where they occur.
A link represents a segment of a highway or transit project characterized by a certain type
of vehicle activity. Generally, the links specified for a highway project should include
road segments with similar traffic conditions and characteristics. Links representing
transit or other terminal projects should similarly reflect variation in idle and start
activity, as well as other relevant cruise, approach and departure running exhaust
emissions.
5.2.1

Highway and intersection projects

A PM hot-spot analysis fundamentally depends on the availability of accurate data on

roadway link speed and traffic volumes for build and no-build scenarios.61 Thus, local
traffic data should be used to characterize each link sufficiently. It is recommended that
the user divide a project into separate links to allow sufficient resolution at different
vehicle traffic and activity patterns; characterizing this variability in emissions within the
project area will assist in air quality modeling (see Section 7).
For analyses with EMFAC2011, an average speed and traffic volume is needed for each
link.62 A simple example would be a single, one directional, four-lane highway that
could be characterized as one link with one average speed. If the project analysis
involves intersections, the intersections need to be treated separately from the free-flow
links that connect to those intersections. Although road segments between intersections
may experience free-flow traffic operations, the approaches and departures from the
intersections will involve acceleration, deceleration, and idling activity not present on the
free-flow link. For intersection modeling, the definition of link length will depend on the
61

Project sponsors should document available traffic data sets, their sources, key assumptions, and the
methods used to develop build and no-build scenario inputs for EMFAC. Documentation should include
differences between how build and no-build traffic projections are obtained. For projects of local air
quality concern, differences in traffic volumes and other activity changes between the build and no-build
scenarios must be accounted for in the data that is used in the PM hot-spot analysis.
62
Unlike MOVES, EMFAC2011 does not allow a user to account for more detailed data to describe the
pattern of changes in vehicle activity (proportion of time in acceleration, deceleration, cruise, and idle
activity) over the length of a road.

54

geometry of the intersection, how that geometry affects vehicle activity, and the level of
detail of available activity information.
When using EMFAC2011, project sponsors can use average speeds for highway and
intersection links based on travel time and distance. Travel time should account for the
total delay attributable to traffic signal operation, including the portion of travel when the
light is green and the portion of travel when the light is red. The effect of a red signal
cycle on travel time includes deceleration delay, move-up time in a queue, stopped delay,
and acceleration delay. Each approach link would be modeled as one link to reflect the
higher emissions associated with vehicle idling through lower speeds affected by stopped
delay; each departure link would be modeled as another link to reflect the higher
emissions associated with vehicle acceleration through lower speeds affected by
acceleration delay.
Project sponsors should determine average congested speeds by using appropriate
methods based on best practices used for highway analysis. 63 Some resources are
available through FHWAs Travel Model Improvement Program (TMIP).64
Methodologies for computing intersection control delay are provided in the Highway
Capacity Manual.65
5.2.2

Transit and other terminal projects

For transit and other terminal projects such as a bus terminal or intermodal freight
terminal, the user should have information on starts per hour and number of vehicles
idling during each hour. This activity will likely vary from hour to hour. It is
recommended that the user divide such a project into separate links to characterize
variability in emission density within the project area appropriately (as discussed in
Section 7). In this case, each link describes an area with a certain number of vehicle
starts per hour, or a certain number of vehicles idling during each hour.
Generally, users need to account for the number of vehicle starts and the amount of idle
activity (in hours). Grams/trip rates can be calculated for start exhaust emissions.
Additionally, grams/idle-hour (grams/hour) emission rates can be calculated for both
regular idle and extended idle exhaust emissions. Users need to have data on the number
of vehicle starts per hour and number of vehicles idling during each hour to get the total
project or project area emission factor.
In addition, some transit and other terminal projects may have significant running
emissions similar to free-flow highway projects (such as buses and trucks traveling to and
from an intermodal terminal). These emissions can be calculated by defining one or
63

As discussed in Section 7, the use of the CAL3QHCR queuing algorithm for intersection idle queues is

not recommended. Rather, idling vehicles should be represented in combination with decelerating,

accelerating, and free-flow traffic on an approach segment of an intersection.

64
See FHWAs TMIP website: http://tmip.fhwa.dot.gov/.

65
Users should consult the most recent version of the Highway Capacity Manual. As of the release of this

guidance, the latest version is the Highway Capacity Manual 2010, which can be obtained from the

Transportation Research Board (see www.trb.org/main/blurbs/164718.aspx for details).

55

more unique running links as described in Section 5.2.1 and Appendix G (that is, in
addition to any other roadway links associated with the project). These running link
emissions can then be aggregated with emissions from starts and idling from non-running
activity on the transit or other terminal link outside of the EMFAC2011 model to
generate the necessary air quality model inputs.
Note: The user may choose to exclude sources such as a separate service drive, separate
small employee parking lot, or other minor sources that are determined to be
insignificant to project emissions.

5.3

DETERMINING THE NUMBER OF EMFAC2011 RUNS

5.3.1

General

Before using EMFAC2011 to calculate emission factors, users should first determine the
number of unique scenarios that can sufficiently describe activity variation in a project.
In most projects, traffic volume, average speed, idling, fleet mix, and the corresponding
emission factors will likely vary from hour to hour, day to day, and month to month.
However, it is unlikely that data are readily available to capture such finite changes.
Project sponsors may have activity data collected at a range of possible temporal
resolutions. The conformity rule requires the use of latest planning assumptions or data
available at the time the conformity analysis begins (40 CFR 93.110).66 Depending on
the sophistication of the activity data analysis for a given project, these data may range
from a daily average-hour and peak-hour value to hourly estimates for all days of the
year. EPA encourages the development of sufficient travel activity data to capture the
expected ranges of traffic conditions for the build and no-build scenarios.
5.3.2

Projects with typical travel activity data

Traffic forecasts for highway and intersection projects are often completed for annual
average daily traffic volumes, with an allocation factor for a daily peak-hour volume.
This data can be used to conduct an analysis with EMFAC2011 that is representative for
all hours of the year. The most reasonable methods in accordance with good practice
should be used to obtain the peak-hour allocation factors and diurnal distribution of
traffic and the methods must be determined in accordance with interagency consultation
procedures (40 CFR 93.105(c)(1)(i)).
One option is to represent traffic over four time periods: morning peak (AM), midday
(MD), evening peak (PM), and overnight (ON). For example, the peak-hour volume can
be used to represent activity conditions over a three-hour morning (AM) and three-hour
evening period (PM). The remaining 18 hours of the day can be represented by the
average off-peak hourly volume (AADT minus the total volume assigned to the peak
66

See EPA and DOT Joint Guidance for the Use of Latest Planning Assumptions in Transportation
Conformity Determinations, EPA-420-B-08-901 (December 2008); available online at:
www.epa.gov/otaq/stateresources/transconf/policy/420b08901.pdf.

56

period, divided by the number of off-peak hours). These 18 hours would be divided into
a midday (MD) and overnight (ON) scenario.
The following is one suggested approach for an analysis employing the averagehour/peak-hour traffic scenario:
Morning peak (AM) emissions based on peak hour traffic data, applied to hours
between 6 a.m. and 9 a.m.;
Midday (MD) emissions based on average off-peak hourly traffic data, applied to
hours from 9 a.m. to 4 p.m.;
Evening peak (PM) emissions based on peak hour traffic data, applied to hours
from 4 p.m. to 7 p.m.; and
Overnight (ON) emissions based on average off-peak hourly traffic data, applied
to hours from 7 p.m. to 6 a.m.
If there are local or project-specific data to suggest that the AM or PM peak traffic
periods will occur in different hours than the default values suggested here, or over a
longer or shorter period of time, that information should be documented and the hours
representing each time period adjusted accordingly. Additionally, users should determine
peak periods for the build and no-build scenarios independently and not assume that each
scenario is identical.
The number of EMFAC2011 runs needed to represent changes in fleet mix depends on
what modeling approach is required to complete the analysis (see Section 5.4). In some
cases, only one run will be necessary, with the resulting emissions rates being weighted
and aggregated through post-processing to reflect a particular fleet mix. In other cases,
multiple model runs will be required. This will be described in more detail in Sections
5.5 through 5.9.
Since PM emission rates do not vary with temperature and humidity in EMFAC2011, it is
not necessary to run multiple EMFAC2011 scenarios to capture seasonal variation in
emission rates. An exception to this concerns medium-heavy and heavy-heavy diesel
truck idling rates, which do vary by season to account for load factor changes due to
heating, air conditioning, and accessory use. See Section 5.8.3 for more information
about these idling rates and options for accounting for this variation in a particular
analysis.
5.3.3

Projects with additional travel activity data

Some project sponsors may have developed traffic or other activity data to show
variations in volume and speed across hours, days, or months. Additionally, if users are
modeling a transit or other terminal project, traffic volumes, starts, and idling estimates
are likely to be readily available for each hour of the day. Under either of these
circumstances, users have the option of applying the methodology described above (using
average-hour and peak-hour as representative for all hours of the year) if it is determined
through the interagency consultation process that using the additional data would not
significantly impact the emissions modeling results. Alternatively, additional
57

EMFAC2011 scenarios could be generated to produce a unique emission factor for each
activity scenario (i.e., each period of time for which specific activity data are available).

5.4

DETERMINING THE MODELING APPROACH

EMFAC2011 uses a modular emissions modeling approach that departs from the single
model approach used by EMFAC2007. Because of this, it may now be necessary to use
more than one method or go to more than one source to obtain all the emission rates
needed to complete a particular quantitative PM hot-spot analysis. The following
sections describe where the emission rates can be found for different vehicle types, the
tools available to obtain them, and approaches that can be used to determine which tools
are applicable to a specific analysis.
This guidance describes two general approaches to using EMFAC2011 for quantitative
PM hot-spot analyses: simplified and detailed. Users should follow the general decision
matrix shown in Exhibit 5-2 to determine which approach is appropriate for their
particular analysis. EPA anticipates that the majority of projects that require PM hotspot analyses should be covered by the simplified approach, where emissions factors for
projects are consistent with the default assumptions in EMFAC2011. In contrast, the
detailed approach is appropriate when projects:
Have a vehicle age distribution that differs from EMFAC2011 default parameters
for the county in which the project is located; and/or
Have project-specific rest and soak time data (e.g., any project that includes
vehicle start or idling emissions).67
In the context of the general decision matrix, idling emissions are those project
emissions resulting from dedicated idling activity (e.g., idling at a truck stop or bus or
intermodal terminal); in these cases, the detailed approach is to be used. Any idling that
occurs as part of a regular vehicle drive cycle (e.g., idling while paused at a signal light)
would be captured as part of a projects running emissions and should considered when
calculating link average speed as described in Section 5.2; if this is the only idling
occurring as part of a project, use of the simplified approach would be appropriate.

67

The general decision factors described here (and shown in Exhibits 5-1and 5-2) differ from those
included in CARBs EMFAC2011 Handbook for Project-level Analyses in two respects. First, CARBs
handbook includes a third factor that has to be met to use the simplified approach (Are project-specific
ambient temperature and relative humidity profiles available profiles available and different from EMFAC
defaults?) However, since PM emission rates do not vary based on temperature and relative humidity in
EMFAC2011, this factor is irrelevant for PM hot-spot analyses. Second, CARBs handbook does not
indicate whether the project includes vehicle start and idling emissions as a factor in deciding to use the
detailed approach. While there is some default information on rest and soak times included in
EMFAC2011, for a PM hot-spot conformity analysis the project sponsor is expected to have and use
project-specific soak/idle and start times; therefore any PM hot-spot analysis which includes starts or idle
emissions should use the detailed approach.

58

While the general decision

decision matrix should be used as a guide, the final decision
decision on which
approach is used for a part
par
particular
ticular project should be determined consiste
consistent
consisten
ntt with the
interagency consultation pprocedures.
rocedures.
The remainder of this secti
sec
section
tion
on contains additional guidance for selecting
selecting an approach
based on the type of proje
projecct being analyzed in the PM hot-spot
hot spot analys
analysis
is.. The two
approaches themselves are
are explained in further detail in Section 5.5 (si
(sim
mplified approach)
and Sections 5.6 through 55.9
.9 (detailed approach).
Exhibit 5-2. General Dec
Decision Matrix for Using EMFAC2011 for PM
Decision
PM Hot-spot
Hot
Analyses68

5.4.1

Highway and inte

interrsection
secti projects

The simplified approach ccan

an be used for highway and intersection pro
proje
projects
jects
cts for PM hot
hotspot analyses if the project
project-specific
specific vehicle age distributions do not dif
difffer from the
EMFAC2011 defaults for the county in which the project is located. T
Th
The
he simplified
approach is described furth
further
er in Section 5.5.
For PM hot-spot
spot analyses,
analyses, project sponsors should use the latest state oorr local age
distribution assumptions fr
from their SIP or transportation conformity rregional
from
reegional
gional emissions
analysis, or other project-sspecific
specific age distribution data, if available. If the age
distribution to be used in the
the PM hot-spot
hot spot analysis differs from the EM
EMFAC2011
FAC2011 defaults
for the county in which th
thee project is located, this would necessitate us
usee of the detailed
approach, described
ed furthe
furtherr in Sections 5.6 through 5.9.

68

As previously noted in this se

section,
section,
ction, this matrix differs in several ways from the gen
ge
general
neral
eral decision matrix in
CARBs EMFAC2011 Handbo
Handbook for Project-level
Project level Analyses due to the application here to PM hot
hot-spot
analyses.

59

Start and idle emissions would not normally be part of a highway or intersection project
analysis; however, if they are, the detailed approach should be used.
5.4.2

Transit and other terminal projects

Transit and other terminal projects will be expected to have project-specific rest/soak
times to generate start and idle emissions; for these projects, the detailed approach
described in Sections 5.6 through 5.9 should be used. If the terminal project is designed
to serve a fleet that operates only locally, such as a drayage yard or bus terminal, the
sponsor should provide project-specific fleet age distribution data, which would also
necessitate use of the detailed approach.
There may be limited cases where the simplified approach described in Section 5.5 could
be appropriate when modeling certain vehicle activity associated with a transit or other
terminal project (such as modeling the running emissions associated with a terminal); this
should be decided on a case-by-case basis using the interagency consultation process.
When modeling transit or terminal projects involving bus fleets, care should be taken to
obtain emission rates for the appropriate EMFAC2011 bus type; see Section 5.6.2 for
details.

5.5

APPLYING THE SIMPLIFIED APPROACH: USING EMFAC2011-PL

As noted in Section 5.4, the simplified approach described here may be appropriate for
highway and intersection projects meeting certain criteria. Most transit and terminal
projects would not qualify to use this approach since they will involve project-specific
rest/soak times (except to obtain any running emissions associated with the terminal);
these projects would instead use the detailed approach.
The simplified approach uses EMFAC2011-PL, a project-level assessment tool CARB
has developed to assist in the generation of emission rates for certain project-level
analyses.69 EMFAC2011-PL uses emissions and activity data from EMFAC2011-SG
module inventory files (default inventories of EMFAC2011-LDV and EMFAC2011-HD
modules) and calculates emission factors consistent with the default fleet distributions in
the region in which the project is located. The tool is available for download from
CARBs Mobile Source Emission Inventory website
(www.arb.ca.gov/msei/modeling.htm). The EMFAC2011-PL tool is used only with the
simplified approach as described in this section. The steps for using EMFAC2011-PL for
the simplified approach for a PM hot-spot analysis are shown in Exhibit 5-3.

69

As previously noted, EPA noted in its March 2013 Federal Register notice that alternative project-level
tools could be used if EPA approves such tools as having similar performance (78 FR 14534). This
guidance will cover only the use of EMFAC2011-PL for the simplified approach.

60

The EMFAC2011-PL tool will generate the following emission rates for the vehicle
category type, geographic area, fuels, and timeframe selected, relevant for PM hot-spot
analyses:
Running Exhaust Emissions Rates [RUNEX] in g/mile/vehicle
Idling Exhaust Emissions Rates [IDLEX] in g/hr/vehicle
Starting Exhaust Emissions Rates [STREX] in g/trip/vehicle
PM Brake Wear [PMBW] and PM Tire Wear [PMTW] in g/mile/vehicle
Note that EMFAC2011-PL does not allow one to enter any project-level activity data
with which to associate these emission rates and also does not generate composite rate
that includes brake wear and tire wear. Therefore, in most situations the rates obtained
from EMFAC2011-PL will have to be post-processed in order to calculate the emissions
from the project; see Section 5.5.9 for more details.
EMFAC2011-PL contains a graphical user interface (GUI) to enable the selection of
emission rates relevant for a particular project (see Exhibit 5-4). The following sections
describe the selections available in the GUI and how to use EMFAC2011-PL to obtain
project emission rates.
5.5.1

Vehicle Category Scheme

This selection allows one to select the vehicles categories for which emission rates will
be obtained. Users must select one of the following options:70
EMFAC2011 Vehicle Categories
EMFAC2007 Vehicle Categories
Trucks/Non-Trucks Categories
Trucks 1/Trucks 2/Non-Trucks Categories
Total (Fleet Average)
In many cases, project travel activity data is likely to be in truck/non-truck categories, in
which case selection of the Trucks/Non-Trucks option would be appropriate. If project
data is not available at the vehicle category level, the Total option should be selected.
Users modeling one or more specific vehicle types would choose the appropriate EMFAC
vehicle category options as a later selection (see Section 5.5.6).
5.5.2

Region Type

EMFAC2011-PL offers six geographic scales (State, Air Basin, Air District, MPO,
County, and GAI)71; each corresponds to specific defaults for fleet characteristics. For
PM hot-spot analyses, users will typically select the County region type.

70
More information on the various EMFAC model vehicle categories is available online at:
www.arb.ca.gov/msei/vehicle-categories.xlsx
71
The GAI sub-area option is used in EMFAC2011 to distinguish certain heavy-duty idling rates in specific
parts of the state and is not an appropriate selection here.

61

Exhibit 5-3. Using the Si

Simplified Approach (EMFAC2011
(EMFAC2011-PL
PL tool)
tool) for a PM HotHot
spot Analysis

5.5.3

Region

After County has been sselected

elected for Region Type as recommended in Section 5.5.2, the
county in which the projec
projectt is located should be selected here (e.g., S
Saacramento).
cramento). For
projects which may be loc
located
located
ated in more than one county, options includ
includee selecting the
county in which the major
majority
majority
ity of the project is located, or running EMFA
EMF
EMFAC2011
AC2011-PL
C2011
multiple times to obtain ra
rates
tes for the parts of the project located in eac
each
h county. For these
situations, the interagency
interagency consultation process should be used to deter
determine
determ
mine what
approach may be most app
appropriate.
ropriate.

62

Exhibit 5-4. EMFAC2011-PL Graphical User Interface (GUI)

5.5.4

Calendar Year

EMFAC2011-PL is able to analyze calendar years from 1990 to 2035 but is limited to
one year per run. The calendar year (CalYr) selected here should be that of the project
analysis year. If an analysis year beyond 2035 is needed, select 2035 to represent that
year.
5.5.5

Season

EMFAC2011-PL can estimate emission factors for two seasons (winter and summer) or
an annual average. In general, since there is no seasonal variation in the PM emission
rates generated by EMFAC2011-PL, it will be appropriate to use the annual average. 72

72

The only seasonal variation in PM emission rates in EMFAC2011 is in the medium-heavy and heavyheavy duty diesel truck idling rates (see Section 5.8.3). Since this guidance recommends obtaining all

63

As previously noted, any variations in project fleet mix will be handled through post
processing and will not require additional EMFAC2011-PL runs (see Section 5.5.9); a
single EMFAC2011-PL will therefore be able to generate all the emission rates for a
project eligible to use the simplified approach.
5.5.6

Vehicle Category

The options available in this category depend on the selection previously made for
Vehicle Category Scheme (see Section 5.5.1):
If either the EMFAC2011 vehicle category scheme were selected, the option for
vehicle category will include all the vehicle categories for each model. Output for
all categories can be selected, or only one category if that is the only rate desired.
If the Trucks/Non-Trucks scheme was selected, then the options are to obtain
rates for either both categories or just one.
If the Total (Fleet Average) scheme was selected, the only option is to obtain rates
for All Vehicles Combined.
In most cases, ALL should be selected to ensure all vehicle classes are included in the
output.
5.5.7

Fuel Type

This selection offers the option of selecting emission rates by fuel type (GAS, DSL, TOT,
or ALL). In most cases TOT should be selected, which will ensure all fuel types are
included in resulting composite rate. However, when using EMFAC2011-PL to obtain
emissions for a vehicle category using a single fuel, selecting only the desired fuel type is
recommended. Selecting ALL will give separate output for gas and diesel fuel types,
which would be useful in the event project VMT was available by fuel type.
5.5.8

Speed

EMFAC2011-PL can give emission rates in 14 speed bins (5-70 MPH in 5 MPH
increments). The speed bin selected should be the speed that most closely matches the
average speed for the link for which the EMFAC scenario applies. If the project contains
links with a large range of average speeds, it may be useful to select all speed bins
(ALL) for efficiency.
5.5.9

Generating and post-processing EMFAC2011-PL emission factors

Once all the selections have been made on the EMFAC2011-PL GUI, the user should
select Download to obtain the desired rates. Once the download process is completed,
an Excel file containing the results will appear in the drive where the EMFAC program is
located. Rates for different processes will be on separate tabs within the spreadsheet.
vehicle idling rates using the detailed process (see Section 5.6), annual average is the recommended
selection here when using EMFAC2011-PL.

64

Because the rates for different processes are output into different spreadsheet tabs in this
way, for running emission links, the EFMAC2011-PL results will then have to be postprocessed to add brake wear and tire wear emission rates to the associated running
emission rates to obtain a composite rate suitable for use in air quality modeling. This
post-processing will have to occur outside of EMFAC2011-PL and can be accomplished
using a spreadsheet or similar tool.
As previously mentioned, only one EMFAC2011-PL run is necessary to obtain
emissions rates for a project using the simplified approach. However, if the project fleet
mix differs from the EMFAC2011 default county vehicle mix, those rates will then have
to be weighted and aggregated to reflect the project-specific fleet mix before being used
in air quality modeling. Typically, this would mean weighting the emission rates to
reflect the appropriate truck/non-truck vehicle mix of a project. See Appendix G for an
example of this post-processing for a simplified highway project. An additional example
can be found in Scenario #4 in the Appendices to CARBs EMFAC2011 Handbook for
Project-level Analyses. There may be limited cases in which no post-processing of
EMFAC2011-PL results are needed.

5.6

OVERVIEW OF THE DETAILED APPROACH

5.6.1

General

The detailed approach is to be followed when completing a quantitative PM hot-spot

analysis when (a) the vehicle age distributions for the project differ from EMFAC2011
defaults, and/or (b) the project includes vehicle idling and/or start emissions. As noted in
Section 5.4, most transit and other terminal projects are likely to use the detailed
approach. In addition, any highway or intersection project that has a vehicle age
distribution which differs from the EMFAC2011 default values would also have to use
the detailed approach.
The detailed approach consists of two parts:
The EMFAC2011-LDV procedure, which gives emission rates for light duty
vehicles and some bus types (see Section 5.7); and
The EMFAC2011-HD procedure, which gives emission rates for heavy duty
vehicles and the remaining bus types (see Section 5.8)
Depending on the fleet mix for the project, users may need to use either the
EMFAC2011-LDV procedure, the EMFAC2011-HD procedure, or both procedures in
order to obtain all the emission rates needed for a particular project. Exhibit 5-5 shows
an overview of using the detailed approach for a quantitative PM hot-spot analysis. In
addition, Section 5.9 describes the process for combining emission rates from
EMFAC2011-LDV and EMFAC2011-HD into a link aggregate emission rate suitable for
use in dispersion modeling.

65

Because project analyses necessitating use of the detailed approach cannot use the
EMFAC2011-PL tool (or similar interface) to obtain EMFAC2011 emission rates, this
section of the guidance contains detailed instructions on how obtain data directly from
the various EMFAC2011 modules. In addition, this guidance is geared towards
addressing the most likely situations likely to be part of a PM hot-spot analysis. CARB is
available to help answer questions on how to obtain emission rates for project situations
not covered by this guidance.
The general steps to the EMFAC2011-LDV procedure can be summarized as:
Open EMFAC2011-LDV and determine appropriate inputs to describe the
geographic area, time period, and vehicles for which you need emission rates;
Select Emfac mode to generate area-specific fleet average emission factors;
Change settings for temperature and humidity, to input one appropriate value for
each that represents the project area;
Edit program constants to change distribution of VMT, trips, and vehicle
population (as needed) to reflect the projects fleet mix;
Run EMFAC2011-LDV and obtain the relevant project emissions factors for
running exhaust, tire wear, brake wear, MDT and HDT idling, and gasoline
vehicle start emissions;
If needed, estimate idling emissions for all other vehicle types, based on the
EMFAC emission factor for 5 mph;
If needed, estimate diesel start emissions by multiplying the time between ignition
and driving by the appropriate idle rate;
For a link total emissions factor, add running, tire wear, and brake wear emission
factors together;
Process idling and start emissions to reflect the activity anticipated at the project
when transit and other terminal links are modeled.
Section 5.7 will cover these steps in detail.
The general steps to using the EMFAC2011-HD procedure can be summarized as:
Obtain running exhaust, brake wear, and tire wear emission rates from CARBs
EMFAC website, selecting the relevant geographic area, time period, and vehicle
types;
If needed, obtain idling emission rates from CARBs website, selecting the
relevant geographic area and filtering the spreadsheet for the appropriate calendar
year and vehicle type;
If needed, weight the rates from the individual EMFAC2011-HD vehicle classes
into an aggregate heavy-duty emission rate based on the default VMT mix and the
project-specific age distribution;
If needed, estimate diesel start emissions by multiplying the time between ignition
and driving by the appropriate idle rate;
To calculate the total emissions factors for each link, add running, tire wear, and
brake wear emission factors together;
Process idling and start emissions to reflect the activity anticipated at the project
when transit and other terminal links are modeled.
66

Section 5.8 will cover thes

thesee steps in detail.
The remainder of this secti
section
on discusses two situations which may caus
causee confusion when
applying the detailed appro
approach for a transit or other terminal project: ((1)
approach
(1
1)) where to obtain
emission rates for the bus types included in EMFAC2011, and (2) how to address idling
and start emissions.
Exhibit 5-5. Using the D
Detailed
etailed Approach for a PM Hot-spot
Hot spot Analy
Analysis
sis

5.6.2

Introduction to EM
EMFAC2011
FAC2011 bus types

EMFAC2011 contains em
emission
emission
ission rates for seven different bus types. W
Wh
When
hen using the
detailed approach to model
modell a bus fleet (for a transit or terminal project, for example),
mode
users need to determine the
tth
hee appropriate EMFAC2011 vehicle bus type and make
selections accordingly. E
Ex
xhibit
hibit 55-6
6 contains a list of the bus types, a bbrrief
ief description of
each, and the associated EMFAC2011
EMFAC2011 vehicle category and module (EMFAC2011
(EM
(EMFAC2011-LDV
FAC2011
HD) whic
whichh should be used to obtain the desired rate.
or EMFAC2011-HD)
5.6.3

Obtaining idling eem

missions using the detailed approach

Idling emissions in EMFA

EMFAC2011
C2011 are handled differently depending
depending on the vehicle type
involved. In general:
For EMFAC2011-L
LDV
L
DV vehicle types, in most (but not all) case
cases,
s, it will be
necessary to use the
the appropriate 5 mph running emission rate to obtain an idling
rate see Section 5.7.4 for details.
For EMFAC2011-H
HD vehicle
vehicle types, idling rates have been exp
expllicitly included in
the model. In this case, the appropriate idle rate should be iden
identified
identtified and used in
the analysis see S
Section
ection 5.8.3 for details.

67

Therefore, if idling emissions for a project are required for vehicle types found in both
the EMFAC2011-LDV and EMFAC2011-HD modules, then both methods will need to
be used to extract all the required idling emission rates for that project.
Exhibit 5-6. Bus Types in EMFAC2011
Bus type

Description

EMFAC2011 vehicle category

[Module in which found]

Urban transit buses

Publicly-owned urban transit buses. Either

diesel buses or (more commonly) natural gas
buses certified to diesel standards.

UBUS-DSL
[EMFAC2011-LDV]

Intercity buses
(motor coach)

Heavy buses with a specific body type used

for inter-regional transit. Regulated by the
Truck and Bus rule.

Motor Coach-DSL
[EMFAC2011-HD]

Other diesel buses

Catch-all diesel bus category. Includes rental

car shuttles, school buses sold to a private
entity like a church, etc. Regulated by the
Truck and Bus rule.

OBUS-DSL
[EMFAC2011-HD]

Small transit/
paratransit buses

Lighter, smaller buses used by transit or

paratransit fleet, etc.

UBUS-GAS
[EMFAC2011-LDV]

Other gas buses

Catch-all category for gas buses or shuttles

not owned by a transit fleet or school district.

OBUS-GAS
[EMFAC2011-LDV]

School buses (diesel)

Self-explanatory. Regulated by the Truck

and Bus rule.

SBUS-DSL
[EMFAC2011-HD]

School buses (gas)

Self-explanatory; few in number.

SBUS-GAS
[EMFAC2011-LDV]

5.6.4

Obtaining start emissions using the detailed approach

General
Obtaining start emissions using the detailed approach also depends on the vehicle type
involved. EMFAC2011 does not include explicit start emission rates for any diesel
vehicle types in either the EMFAC2011-LDV or EMFAC2011-HD modules. However,
EMFAC2011 does include start emission rates for gasoline vehicles.
In general, then, when needing to estimate project start emissions:
For gasoline vehicles, obtain the appropriate start emission rate from the
EMFAC2011-LDV module;
For diesel vehicles, estimate the start emissions rate based on the vehicles idling
rate, as described below.
68

Obtaining start emission rates for EMFAC2011 diesel vehicle types

A diesel start can be defined as the period following key-on ignition, an initial warmup period before the vehicle begins driving. The duration of this process will be specific
to the project, but can be simply modeled as a period of idle activity.
To estimate start emissions, users should multiply the length of this period in terms of
hours (e.g., 3 minutes = 0.05 hour) by the appropriate idle rate in grams/hour extracted
from EMFAC2011, to determine a gram/start emission rate for use in air quality
modeling. For instance, to account for a 30 second start-up period, the EMFAC2011 idle
rate (in grams/hour) should be multiplied by .0083 hours to obtain the total grams of
emissions per start. This grams/start rate can then be multiplied by the number of vehicle
starts present in the project in that hour to obtain total start emissions.
More Section 5.6.3 for more information about obtaining idling rates using the detailed
approach.

69

5.7

APPLYING THE DETAILED APPROACH: USING EMFAC2011-LDV

The procedure described here should be used to generate emission rates for any of the
EMFAC2011-LDV vehicle categories listed in Exhibit 5-7 when using the detailed
approach for a PM hot-spot analysis.
Exhibit 5-7. EMFAC2011-LDV Vehicle Categories
EMFAC2011 Vehicle & Technology
LDA DSL
LDA GAS
LDT1 DSL
LDT1 GAS
LDT2- DSL
LDT2 GAS
LHD1 DSL
LHD1 GAS
LHD2 DSL
LHD2 GAS
MCY GAS
MDV DSL
MDV GAS
MH DSL
MH GAS
T6TS GAS
T7IS GAS
SBUS GAS
UBUS DSL
UBUS GAS
OBUS GAS

Description
Passenger Cars
Passenger Cars
Light-Duty Trucks (0-3750 lbs)
Light-Duty Trucks (0-3750 lbs)
Light-Duty Trucks (3751-5750 lbs)
Light-Duty Trucks (3751-5750 lbs)
Light-Heavy-Duty Trucks (8501-10000 lbs)
Light-Heavy-Duty Trucks (8501-10000 lbs)
Light-Heavy-Duty Trucks (10001-14000 lbs)
Light-Heavy-Duty Trucks (10001-14000 lbs)
Motorcycles
Medium-Duty Trucks (5751-8500 lbs)
Medium-Duty Trucks (5751-8500 lbs)
Motor Homes
Motor Homes
Medium-Heavy Duty Gasoline Truck
Heavy-Heavy Duty Gasoline Truck
School Buses
Urban Buses
Urban Buses
Other Buses

Exhibit 5-8 shows the general process for using the EMFAC2011-LDV module to obtain
emission rates for EMFAC2011-LDV vehicle types for PM hot-spot analyses. However,
how EMFAC2011-LDV is to be configured and run depends entirely upon the specific
types of rates required for a particular PM hot-spot analysis. This section will describe
the various EMFAC2011-LDV inputs and show, as an example, how to use
EMFAC2011-LDV to obtain an aggregate light duty emission rate from vehicles types
LDA, LDT1, LDT2, and MCY. In addition, Appendix H contains an example of how to
use EMFAC2011-LDV to generate bus idling rates for a transit terminal for a PM hotspot analysis.

70

Exhibit 5-8. Using EMFA

EMFAC2011-LDV
C2011
to Obtain
n Emission Rates ffoorr PM Hot-spot
Hot
Analyses

71

5.7.1

Specifying basic scenario inputs

To generate emission factors in EMFAC2011-LDV for PM hot-spot analyses, users need

to first enter a series of basic inputs using the user interface. Exhibit 5-9 presents a
summary of all basic inputs needed to complete an EMFAC2011-LDV scenario run
(scenario). The EMFAC2011-LDV defaults can be used directly for most basic input
categories; however, some inputs need to be modified to reflect project-specific
information.
Exhibit 5-9. Summary of EMFAC2011-LDV Inputs Needed to Evaluate a Project
Scenario for a PM Hot-spot Analysis
Step

EMFAC Basic Input Category

Geographic Area

1
Calculation Method
2

Calendar Year

Season or Month

Scenario Title

Model Years

Vehicle Classes

I/M Program Schedule

EMFAC Basic Input Data

State
Air Basin
District
County
By Sub-Area
Use Average
Calendar Year
Month
Season
Annual
Default
Modify
All
Modify
All
Modify
Default
Modify

Modification Needed?
Yes

No*
Yes
Yes
Optional
No
Optional**
No

* Defaults to Use Average if County selected. If District selected, By Sub-Area option is

available.

** If a project uses a subset of the default fleet, users should delete unwanted vehicle classes

through the Vehicle Classes user interface.

Geographic area and calculation method

Upon creating a new scenario in EMFAC2011-LDV, users should enter into GUI the
geographic area where the project is located. EMFAC2011-LDV offers four geographic
scales and each corresponds to specific defaults for fleet characteristics. The Area
Type category includes State, Air Basin, District, and County. For PM hot-spot
analyses, users will typically select the County area type. When County is selected, a
list of all the counties in California will be available. Users should select the county
where the project is located.
If the selected county is part of only one air basin, users can continue to the next step to
specify calendar years. However, if the selected county is within multiple air basins,
72

EMFAC2011-LDV will show two options, By Sub-Area and Use Average, as

calculation methods. Users should select By Sub-Area to generate EMFAC2011
emission factors in look-up tables for all sub-areas within the selected county.
For instance, Los Angeles County is located in both the Mojave Desert Air Basin and the
South Coast Air Basin. If the project is located near the Port of Los Angeles and Los
Angeles County with By Sub-Area selected, EMFAC2011-LDV will provide
emission data for both the Mojave Desert Air Basin and the South Coast Air Basin. Only
the look-up tables for the South Coast Air Basin would be used because this is where the
port is located; the Mojave Desert Air Basin data would be ignored.
Calendar year
EMFAC2011-LDV is able to analyze calendar years from 1990 to 2035 and allows
emission rates to be obtained for multiple calendar years in a single run. Users should
select one or more calendar years based on the project scenarios to be analyzed. If an
analysis year beyond 2035 is needed, select 2035 to represent that year.
Season or month
EMFAC2011-LDV can give emission factors for each month, two seasons (winter and
summer), or an annual average. Although VMT and speed are handled external to the
model, the vehicle mix may vary by hour and season and these scenarios should be
modeled explicitly. As discussed in Section 5.3, users should use EMFAC for the
appropriate number of scenarios based on the availability of travel activity data. Users
with typical travel activity data (i.e., average and peak hour data) may run one or two
scenarios (depending whether vehicle mix varies between the peak-hour and averagehour) and will select annual average in the Season or Month selection panel. Users
with additional data that shows variation in fleet mix across seasons or months should
select the appropriate month or season for each run.
Scenario title
EMFAC2011-LDV generates a default scenario title that includes the name of the county,
calculation method, season or month, and calendar year. A replacement scenario title can
be specified, if desired.
Model years
EMFAC2011 includes vehicle model years from 1965 to 2040 and default assumptions
about mileage accumulation that vary by model year. EMFAC2011-LDV will generate
emission factors for 45 model years (ages 1 through 45). Users can change the range of
model years to be included in an EMFAC2011-LDV run through the model interface. If
a project involves a specialized and simple fleet (e.g., buses operating in a bus terminal)
for which the range of model years is well known or reliably estimated, users may

73

consider including only those model years and exclude unrelated vehicle types in an
EMFAC2011-LDV run.
Vehicle classes
Typically, all 21 default vehicle classes should be selected for most projects. The
exception would be a project or link that involves a specialized fleet of limited vehicle
types (e.g., a bus terminal). The EMFAC2011-LDV module assumes vehicle population
and travel activity distributions by vehicle class, depending on the geographic area and
analysis year selected. Editing the default distribution of vehicle classes, and excluding
vehicle classes from the rate calculations will be discussed in Section 5.7.3. If only one
vehicle type is selected, all emission information in the EMFAC2011-LDV output will be
calculated for that one vehicle type.
I/M program schedule
Currently, no PM emission benefit from I/M programs exists in EMFAC2011. Although
EMFAC2011-LDV allows edits for each I/M program, users should not alter the default
settings and parameters associated with I/M programs and their coverage.
5.7.2

Configuring mode and output

EMFAC includes three scenario types or modeling modes: Burden, Emfac, and Calimfac.
For PM hot-spot analyses, users should select the Emfac mode, which generates areaspecific fleet average emission factors for running exhaust, starting and idling emissions.
Once Emfac mode is selected, the following additional settings can be modified:
Temperature and relative humidity
The default settings in the Emfac mode include 15 temperature bins (-20F to 120F) and
11 relative humidity bins (0% to 100% RH) to generate average emission factors.
However, because EMFAC2011 PM emission rates are insensitive to changes in
temperature and humidity, generating emission factors for all default temperature/relative
humidity combinations throughout an analysis year is not necessary. As shown in
Exhibit 5-10, users need to remove the default temperature/relative humidity settings and
input only one value (e.g., 60F, 70% RH) for temperature and relative humidity,
respectively, to perform an Emfac mode run. Selecting one combination of
temperature/relative humidity will reduce computer run time and produce PM emission
factor look-up tables that can be easily used.

74

Exhibit 5-10. Changing EMFAC2011-LDV Default Settings for Temperature and

Relative Humidity

Note: Radio button selection will default to delete even after change has been made.

Speed
The Emfac mode allows users to input up to 24 speed values to populate average
emission factors. The default setting specifies speed bins for 0 mph through 65 mph in 5
mph increments. Emission factors for intermediate speeds can also be generated if
specific speed values are input into the EMFAC2011-LDV module.
Users have several options to calculate appropriate speed-dependent emission factors for
a project. For instance, if a highway link in a build scenario is known to have an average
speed of 32 mph, it can be directly input into the speed list of EMFAC2011-LDV to
produce the associated PM emission factors. Alternatively, if the EMFAC2011-LDV
default settings are used to generate a look-up table for different speed bins, users can
either select the emission factors associated with the closest speed bin (e.g., 30 mph bin,
representing speeds of 27.5 mph to 32.5 mph), or interpolate between the emission
factors for speed bins of 30 mph and 35 mph.
For specific cases for which the average link speed is less than 5 mph, users can either
select the emission factors from the 5 mph speed bin, or extrapolate the desired speed by
75

using the emission factors from the speed bins for 5 mph and 10 mph to create a trend
line to lower speeds.
Output rate file
The Emfac mode can provide emission information in four output formats with different
levels of detail. Users should select Summary Rates (RTS). The Summary Rates
format generates average emission factors by speed for six vehicle groups (aggregated
from the 21 vehicle classes modeled in EMFAC2011-LDV) and an overall average
emission factor for the entire vehicle fleet. Typically, the ALL emission factor
(aggregate) should be used.
Output particulate
As shown in Exhibit 5-11, users have to select either PM10 or PM2.5 in an Emfac mode
run to obtain particulate emission factors. EMFAC2011-LDV must be run twice to
obtain both PM10 and PM2.5 data for those projects that are located in both PM10 and PM2.5
nonattainment/maintenance areas.
Exhibit 5-11. Selecting Pollutant Types in EMFAC2011-LDV for PM10 and PM2.5

76

5.7.3

Editing program constants

Default data in the Emfac mode

The Emfac mode is associated with a range of pre-populated program constants linked to
specific time periods and California geographic areas. Exhibit 5-12 lists the default data
available in the Emfac mode that can be accessed through the Edit Program Constants
in the user interface. For a PM hot-spot analysis, many of the defaults do not need to be
modified. However, users do need to determine which adjustments are needed for the
default distributions of VMT, trips, and vehicle population by vehicle class. The
EMFAC2011-LDV interface has Copy with Headers and Paste Data Only tabs that
are helpful for users to easily export the default data and import the adjusted data.
Exhibit 5-12. EMFAC2011 Program Constants and Modification Needs for PM
Hot-spot Analyses
EMFAC2011-LDV
Program Constants
Exh Tech Fractions
Evap Tech Fractions
Interim I/M
Population
Accrual
Trips
VMT
Speed Fractions
Idle Time

Description
Exhaust control technology fractions
Evaporative control technology factions
Enhanced interim I/M program
Vehicle population by class, fuel type, and age
Odometer accrual rate by class, fuel type, and age
Vehicle trips/starts per day by class, fuel type, and age
Vehicle miles traveled per day by class, fuel type, and age
VMT by speed bin distribution for each vehicle class
Idle times by vehicle class, fuel, and hour of day

Modification
Needed for PM
Analyses?
No
No
No
Yes*
No
Yes*
Yes*
No
No

* Different distributions in VMT, trips, or vehicle population than those reflected by the EMFAC2011

defaults should be updated through the user interface to incorporate project-specific vehicle activity

information.

EMFAC2011-LDV allows users to adjust the calculated fleet-average emission factors by

varying the relative weightings of the 21 vehicle classes. This adjustment is done by
replacing the default numbers for each vehicle class in the EMFAC2011-LDV user
interface, using the VMT option for a highway project, or the Trips or Population
option if analyzing a transit or other terminal project, under the Edit Program Constants
function available via the Emfac mode screen (an example is discussed below).
Note: EMFAC2011-LDV also allows users to modify the fuel characteristics
(gas/diesel/electric) for each vehicle class. For most PM hot-spot analyses for highway
projects with non-captive fleets, users will not need to modify the fuel assumed for the
fleet vehicles. For projects involving captive fleets with known fuel use distributions, the
default fractions should be modified.

77

For the scenario described earlier, where only an aggregate light-duty emission rate is
needed, the heavy-duty classes included in EMFAC2011-LDV should be functionally
zeroed-out by assigning a value of 1 (see Exhibits 5-13 and 5-14).73 The default
VMT for the light duty (non-truck) vehicle classes (PC, T1, T2, and MC) would remain
unchanged unless project-specific VMT is available for these vehicle classes, in which
case these entries should be adjusted to reflect project data. ,.
Exhibit 5-13. Example Default EMFAC2011-LDV VMT by Vehicle Class
Distribution (Heavy-duty Vehicle VMT Highlighted)

73

EMFAC2011-LDV will not accept 0 as a valid input.

78

Exhibit 5-14. Example Adjusted EMFAC2011-LDV VMT by Vehicle Class

Distribution (Heavy-duty Vehicle VMT Highlighted)

Note: The average emission factors provided by EMFAC2011-LDV in the Emfac mode
are VMT-weighted (for running emissions), vehicle trip-weighted (for start emissions), or
vehicle population-weighted (for idle emissions) across different vehicle classes. If a
user runs the model for a county, the weighting reflects county-level VMT, trips (starts),
or vehicle fleet and their absolute values are not relevant at the project level.
For most transit and other terminal projects, users may have detailed information on not
only vehicle mix, but also fuel mix (diesel/gas/electric) and age distribution (model year
distribution). Users should adjust the fuel mix (changed through the By Vehicle and
Fuel tabs of the VMT, Population, and Trips panels) to reflect the known or expected
fuel use (if, for instance, a bus fleet is expected to use entirely diesel fuel). Similarly, if
79

the age distribution (model year distribution) is known for a particular fleet, this should
be entered in place of the EMFAC2011-LDV default values (found in the By
Vehicle/Fuel/Age tab of the Edit Population panel). An example showing the steps
involved in defining a project-specific age distribution for a single vehicle type is shown
in Appendix H.
Note that EMFAC2011-LDVs ability to model alternate fuel options is not uniform
among vehicle classes. If users determine that modification of the fleet in terms of fuel
or age distribution is needed, they should contact CARB for further guidance. However,
for most highway and intersection projects with a non-captive fleet, the EMFAC2011
LDV default fuel mix should be used.
5.7.4

Generating EMFAC2011-LDV emission factors

For each EMFAC2011-LDV run, emission factors will be generated in the Summary
Rates (RTS) file (.rts file) in the form of look-up tables. These tables are organized and
numbered by different emission processes and pollutant types. PM emission factors for
running exhaust, idle exhaust, tire wear, and brake wear are included in Table 1 of the .rts
file; PM start emission factors are included in Table 2 of the .rts file. Exhibit 5-15
(following page) includes example screenshots of EMFAC2011-LDV .rts file output.
Highway and intersection links
For each speed value (greater than 0 mph), EMFAC2011-LDV outputs running exhaust,
tire wear, and brake wear emission factors in grams/vehicle-mile, for six vehicle groups
plus an aggregate emission factor named as All. Note that the .rts output file includes
only six vehicle groups an aggregation of the 21 vehicle classes manipulated during the
input process. In general, assuming users have run the model with VMT-weighted
distributions appropriate for the projects fleet activity (see Section 5.7.2), only the
emission factors from the All column will be needed. The All column includes a
grams/vehicle-mile value that is a VMT-weighted average based on the user-provided
vehicle activity mix. The sum of running exhaust, tire wear, and brake wear grams/mile
PM emission factors for a given speed is the total fleet-average grams/vehicle-mile
emission factor appropriate for modeling highway project links:
Total Link Emission Factor = (EFrunning) + (EFtire wear) + (EFbrake wear)
The total link emission factor (grams/vehicle-mile) can be used in combination with the
link volume and link length as input into CAL3QHCR. If using AERMOD, an emission
rate (in grams/hour) should be calculated for each link. This can be done by multiplying
the total link emission factor (calculated above) by the link hourly volume and link
length. If the project contains heavy-duty vehicle activity, an additional process is
necessary to weight together heavy-duty and light-duty emission rates based on linkspecific heavy-duty/light-duty volumes. See Section 5.9 for additional information.

80

Exhibit 5-15. Example EMFAC2011-LDV Running Exhaust, Tire Wear, and Brake
Wear Emission Factors in the Summary Rates (rts) Output File

Transit and other terminal links

For transit and other terminal projects, such as bus terminals or intermodal freight
terminals, the emissions contribution will be a combination of idling, starting, and/or
running emissions. EMFAC2011-LDV allows users to generate emission factors for both
the bus terminal itself (idling and start emissions) and approaching/departing links
(running emissions) in a single run. To obtain project-specific running exhaust emission
factors, users can modify the VMT associated with the buses at the approaching link by
81

adjusting the values for each of the EMFAC2011-LDV vehicle classes in the user
interface with the method described in Section 5.7.3. In the same EMFAC2011-LDV
run, users can enter project-specific vehicle population to generate the necessary idle
emission factors. Note that since AERMOD will always be used for complex projects
involving both highway/intersections and terminals, the running rates from EMFAC
(grams/veh-mile) should be converted to grams/hour rates.
Other special projects may need additional data manipulation. Project sponsors should
contact CARB or the local air quality management district for further guidance.
Idling Emissions. Idling emission factors for some EMFAC2011-LDV vehicle types (the
MDT and HDT groups) are reported as grams/idle-hour and are available in Table 1 of
the .rts file associated with a speed value of 0 mph. For all other vehicle types (including
passenger cars and urban buses), an idle rate may be calculated based on the reported rate
for 5 mph, also in Table 1 of the .rts file. This rate in grams/vehicle-mile should be
multiplied by 5 miles/hour to obtain a grams/veh-hour rate. This grams/veh-hour idle
rate can then be multiplied by the number of idling vehicles in the area and the resulting
grams/hour rate can be used in air quality modeling.
Note that in many transit projects, buses will not typically idle for the entire hour.
Therefore, the grams/veh-hour rate should be adjusted to include the actually number of
idling buses, as well as the dwell time. For instance, a transit terminal may have a
particular area where 50 buses idle for 6 minutes per hour while they pick-up/drop-off
passengers. The idle rate generated by EMFAC2011-LDV should be multiplied by the
number of idling buses, as well as the fraction of the hour (0.1 hour) when idling is
occurring. The resulting grams/hour rate can be used in air quality modeling.
Start Emissions. Start emissions may be a significant source of PM for many transit or
other terminal projects. EMFAC2011-LDV reports start emissions as grams/trip (or
grams/start) emission factors for gasoline vehicles only. These factors can be combined
with project-specific estimates of vehicle trips (or starts) per hour to calculate grams/hour
emissions. Starting emission factors depend on the vehicle soak time (the soak time is
the time a vehicle is stationary with the engine turned off, following the last time it was
operated). The longer a vehicle is turned off, or soaks, the higher the start emissions
embedded in EMFAC2011-LDV. The output look-up table for start emissions includes
18 time bins (5 minutes to 720 minutes); users need to choose an appropriate time bin
that is representative for the project activity. A particular area of starting activity may
have a soak time distribution (e.g., 10 percent soaking 5 minutes, 40 percent soaking 320
minutes, and 50 percent soaking 720 minutes), the subsequent rates should be
appropriately weighted together to calculate a grams/hour emission rate for use in air
quality modeling.
Since EMFAC2011-LDV does not contain any start rates for any diesel vehicle type in
the module, the approach described in Section 5.6.4 should be used to estimate a start rate
for these vehicles. Note that idling emissions (and therefore start emissions) will vary
between EMFAC2011-LDV vehicle types; care should be taken to ensure rates are
82

matched to the correct vehicle type and that starts for all appropriate vehicle types are
accounted for.
Running Emissions. Finally, users may need to model running exhaust emissions from
cruise, approach, and departure link activity, as well as start and idle emissions at the
project site. For instance, to assess impacts from a proposed bus terminal, users may
need to evaluate the idle emissions from buses at the terminal as well as the bus running
exhaust emissions along the links approaching and departing from the terminal.
Given that the link activity will likely involve a unique vehicle fleet (one with a
disproportionate amount of bus activity), users should modify the default travel activity
in EMFAC-LDV to reflect the bus activity.

83

5.8

APPLYING THE DETAILED APPROACH: USING EMFAC2011-HD

The procedure described here should be used when emission rates are needed for any of
the EMFAC2011-HD vehicle categories listed in Exhibit 5-16.
Exhibit 5-16. EMFAC2011-HD Vehicle Categories
EMFAC2011 Vehicle & Technology
T6 Ag - DSL
T6 CAIRP heavy - DSL
T6 CAIRP smal l - DSL
T6 instate construction heavy - DSL
T6 instate construction smal l - DSL
T6 instate heavy - DSL
T6 instate smal l - DSL
T6 OOS heavy - DSL
T6 OOS smal l - DSL
T6 Public - DSL
T6 utility - DSL
T7 Ag - DSL
T7 CAIRP - DSL
T7 CAIRP construction - DSL
T7 NNOOS - DSL
T7 NOOS - DSL
T7 other port - DSL
T7 POAK - DSL
T7 POLA - DSL
T7 Public - DSL
T7 Single - DSL
T7 single construction - DSL
T7 SWCV - DSL
T7 tractor - DSL
T7 tractor construction - DSL
T7 utility - DSL
PTO - DSL
SBUS - DSL
Motor Coach - DSL
All Other Buses - DSL

Description
Me dium-Heavy Duty Diesel Agriculture Truck
Medium-Heavy Duty Diesel CA International Regi stration Plan Truck
with GVWR>26000 lbs
Me dium-Heavy Duty Diesel CA International Regi stration Plan Truck
with GVWR<=26000 lbs
Me dium-Heavy Duty Diesel instate construction Truck with
GVWR>26000 lbs
Me dium-Heavy Duty Diesel instate construction Truck with
GVWR<=26000 lbs
Me dium-Heavy Duty Diesel instate Truck with GVWR>26000 lbs
Me dium-Heavy Duty Diesel instate Truck with GVWR<=26000 lbs
Me dium-Heavy Duty Diesel Out-of-state Truck with GVWR>26000 lbs
Me dium-Heavy Duty Diesel Out-of-state Truck with GVWR<=26000 lbs
Me dium-Heavy Duty Diesel Publ ic Fleet Truck
Me dium-Heavy Duty Diesel Utility Fleet Truck
Heavy-Heavy Duty Diesel Agri culture Truck
Heavy-Heavy Duty Diesel CA International Re gistration Plan Truck
Heavy-Heavy Duty Diesel CA International Re gistration Plan
Construction Truck
Heavy-Heavy Duty Diesel Non-Neighbori ng Out-of-state Truck
Heavy-Heavy Duty Diesel Neighboring Out-of-state Truck
Heavy-Heavy Duty Diesel Drayage Truck at Other Faciliti es
Heavy-Heavy Duty Diesel Drayage Truck in Bay Area
Heavy-Heavy Duty Diesel Drayage Truck near South Coast
Heavy-Heavy Duty Diesel Public Flee t Truck
Heavy-Heavy Duty Diesel Singl e Unit Truck
Heavy-Heavy Duty Diesel Singl e Unit Construction Truck
Heavy-Heavy Duty Diesel Solid Waste Coll ection Truck
Heavy-Heavy Duty Diesel Tractor Truck
Heavy-Heavy Duty Diesel Tractor Construction Truck
Heavy-Heavy Duty Diesel Utility Flee t Truck
Power Take Off
School Buses
Motor Coach
All Other Buses

84

In order to capture all the emission processes for EMFAC2011-HD vehicle categories
using the detailed approach, users will need to access multiple data sources (described in
Exhibit 5-17, below). This is because the data formats and input requirements are quite
different for different processes:
Running Exhaust Emission Rates (g/mile) change by speed, and therefore, require
speed as an input.
PM Brake Wear and Tire Wear Emissions Rates (g/mile) are assumed to be same
at all speeds (EMFAC2011-HD outputs it at the ALL Combined Speed level).
Idling Exhaust Emission Rates (g/hour) are based on idling time.
Start Exhaust Emission Rates (g/start) can be estimated using EMFAC2011-HD
idling exhaust rates and the procedure described in Section 5.8.4.
All the required rates to calculate these emissions are available on the CARB website.
The specific tools used to generate emission rates for the EMFAC2011-HD vehicle
categories will vary depending on the particular type of emissions selected. Exhibit 5-17
provides a quick reference for data sources for each of the emission processes. However,
users need to follow all the procedures detailed in following sections (5.8.1 through
5.8.4) to obtain complete emission rates for EMFAC2011-HD vehicles.
Exhibit 5-17. Data Sources for EMFAC2011-HD Vehicle Emission Rates (Detailed
Approach)
Emission Process
Running Exhaust
Emission Rates
(RUNEX)

Where to Find

Units

www.arb.ca.gov/emfac
Download by speed for RUNEX

PM Brake Wear
and Tire Wear
(PMBW/PMTW)

www.arb.ca.gov/emfac

Idling Exhaust
Emission Rates
(IDLEX)

http://www.arb.ca.gov/msei/emfac2011_idling_emission_rates.xlsx

Start Exhaust
Emission Rates

Estimate using appropriate idling exhaust rate; see Section 5.8.4.

Download Combined speeds for PMBW and PMTW

g/mile

g/mile

g/hr

g/start

As noted, for some processes it will be necessary to go to CARBs EMFAC web database
(www.arb.ca.gov/emfac). A screenshot of the databases graphical user interface is
shown in Exhibit 5-18. Details on how and when to access the database emission factors
are described further in this section.

85

In addition, the CARB EMFAC2011 Handbook for Project-level Analyses contains

examples in the appendices (see, in particular, Scenario #5B and Scenario #7) that show
using EMFAC2011-HD to obtain emission rates for some illustrative projects. These can
be referenced as a general guide on how to employ EMFAC2011-HD as part of the
detailed approach.
Exhibit 5-18. Graphical User Interface for CARBs EMFAC Web Database

5.8.1

Obtaining EMFAC2011-HD vehicle running exhaust emission rates

The general methodology for generating Running Exhaust Emission Rates (RUNEX) for
EMFAC2011-HD vehicles using the detailed approach is shown in Exhibit 5-19.
The emission rates and default VMT by vehicle class (which can be used when
weighting, per Section 5.9) are available through the EMFAC2011 web database
(www.arb.ca.gov/emfac). Users are required to select the following options:
Data Type: Emission Rates
Region Type: Statewide Average, Air Basin, Air District, MPO, County, SubArea (GAI)
Region (based on Region Type selection)
Calendar Year
Season
Vehicle Category scheme (EMFAC2011 or EMFAC2007)
Vehicle Type (based on Vehicle Category scheme selection)
86

Model Year
Speed
Fuel

See Exhibit 5-19 for additional input guidance. In addition, guidance for using
EMFAC2011-LDV applies to the Region, Region Type, Calendar Year and Season
selections for PM hot-spot analyses; see Section 5.5 for details.

87

Exhibit 5-19. Obtaining Running

Running Emissions (RUNEX) Emission R
Rates
ates for
EMFAC2011-HD
HD Vehicle
Vehicless (Detailed Approach)74

74

Exhibit is the same as in CAR

CARBs
Bs EMFAC2011 Handbook for Project-level
Project level Analy
Analyses for consistency
purposes. Users may find that the checkboxes now may be menu selections.

88

5.8.2

Obtaining EMFAC2011-HD vehicle brake and tire wear emission rates

The general methodology for generating PM Brake Wear (PMBW) and PM Tire Wear
(PMTW) emission rates for EMFAC2011-HD vehicles using the detailed approach is
explained in Exhibit 5-20.
The emission rates are available through the EMFAC2011 web database
(www.arb.ca.gov/emfac). Users are required to select the following options:
Data Type: Emission Rates
Region Type: Statewide Average, Air Basin, Air District, MPO, County, SubArea (GAI)

Region (based on Region Type selection)

Calendar Year

Season

Vehicle Category scheme (EMFAC2011 or EMFAC2007)

Vehicle Type (based on Vehicle Category scheme selection)

Model Year

Speed (select Combined Speeds option)

Fuel

See Exhibit 5-20 for additional input guidance. In addition, guidance for using
EMFAC2011-LDV applies to the Region, Region Type, Calendar Year and Season
selections for PM hot-spot analyses; see Section 5.5 for details.

89

Exhibit 5-20. PM Brake Wear and Tire Wear (PMBW/PMTW) Em

E
Emission
mission
ission Rates for
EMFAC2011-HD
HD Vehicle
Vehicless (Detailed Approach)75

75

Exhibit is the same as in CAR

CARBs
Bs EMFAC2011 Handbook for Project-level
Pr
level Analy
Analyses for consistency
purposes. Users may find that the checkboxes now may be menu selections.

90

5.8.3

Obtaining EMFAC
EMFAC2011-HD
2011 HD vehicle idling exhaust emission ra
rattes

The general methodology for generating Idling Exhau

Exhaust
st Emission Rates
Rates (IDLEX) for
EMFAC2011-HD vehicles
ehicles using the detailed approach is shown in Ex
Exh
hibit
ibit 55-21.
Exhibit 5-21. Obtaining Idling (IDLEX) Emission Rates for EMFA
EMF
EMFAC2011
AC2011-HD
C2011
Vehicles (Detailed Appr
Approoach)
ach)

The emission rates are ava

available
available
ilable in an Excel spreadsheet that can be dow
do
downloaded
wnloaded from the
web at www.arb.ca.gov/m
www.arb.ca.gov/msei/emfac2011_idling_emission_rates.xlsx.
sei/emfac2011_idling_emission_rates.xlsx
provides
provides
ovides idling emission rates for EMFAC201
EMFAC2011
1-HD vehicle
The spreadsheet pr
categories (Diesel Vehicles classes for T6/MHDT, T7/HHDT,
7/HHDT, OBUS,
OBUS, and
SBUS).
Emission rates are in grams/hour
Emission rates are corrected for cleaner fuel, but not for retrofi
retrofitt requirements of
the idling rule.
HD Idling emission
emission rates are available for two geographic areas
area
areas:
s:: (1) the South
Coast Air Basin an
and
d the South Central Coast (Ventura County) Air Basin; and (2)
all other areas.
91

Specific idling emission rates can be selected by selecting select the Filter function
from the Data menu and then selecting the following from the drop-down menus:
By Calendar Year
By Season
By Vehicle Class
By Fuel Type
By Model Year
Idle rates are available for annual, winter, or summer periods. Depending on the season,
assumptions are made about the engine load based on the expected use of heaters, air
conditioners, and other vehicle accessories. The annual average rate should not be used,
as it is a simple composite of both winter and summer rates. Instead, users may either
select the most conservative emission rate (usually winter), or emission rates from
summer (S) and winter (W) can be paired with activity on a seasonal basis. Users may
consult with the Section 7 of the guidance for information on how seasonal variation in
emission rates impacts the air quality modeling procedures.
If project-specific engine loads are known for idling vehicles, CARB has created
supplemental guidance that, off-model, provides MHDDT and HHDDT emission rates
for activity that CARB has termed high idle and low idle.76 Low idle (sometimes
also called curb idle) involves short-term idling with engine speeds of 800 rpm or less
and no accessory loading. High idle is idling over an extended period of time with
engine speeds over 800 rpm, usually involving the use of heaters, air conditioners, or
other vehicle accessories. If the project under evaluation involves either MHDDT or
HHDDT vehicle types and the user has detailed information about the fleet (vehicle
model years and the amount of time spent in low and high idle, in particular), the
information from this supplemental guidance may be used to obtain more specific idle
emission factors for MHDDT and HHDDT than those available in the web-based
spreadsheet.
5.8.4

Obtaining EMFAC2011-HD vehicle start exhaust emission rates

Since EMFAC2011-HD does not contain any start rates for any vehicle type in the
module (they are all diesel vehicles), the approach described in Section 5.6.4 should be
used to estimate a start rate for these vehicle types. Note that idling emissions (and
therefore start emissions) will vary between EMFAC2011-HD vehicle types; care should
be taken to ensure rates are matched to the correct vehicle type and that starts for all
appropriate vehicle types are accounted for.

76

For MHDDT rates, see Table 11-5 of the EMFAC2011 Technical Documentation, available through
CARB online at: www.arb.ca.gov/msei/modeling.htm. For HHDDT rates, see pages 13-15 of the EMFAC
Modeling Change Technical Memo, Revision of Heavy Duty Diesel Truck Emissions Factors and Speed
Correction Factors (original and amendment), October 20, 2006; available at:
www.arb.ca.gov/msei/supportdocs.htm#onroad.

92

5.8.5 Diesel retrofits in EMFAC2011

Regarding diesel engine retrofits, benefits from the retrofits contained in the Truck and
Bus Rule are already included in the appropriate EMFAC2011 emission rates. Only
retrofits not included in EMFAC2011 are potentially eligible for consideration outside of
the model. Any issues regarding the models and associated methods and assumptions for
the inclusion of state control measures in PM hot-spot analyses must be considered
through the process established by each areas interagency consultation procedures (40
CFR 93.105(c)(1)(i)).77

5.9

USING THE DETAILED APPROACH FOR PROJECTS CONTAINING BOTH

LIGHT-DUTY AND HEAVY-DUTY VEHICLES

Individual projects will often have a mix of vehicle types that varies from the regional
average fleet mix. A common practice in California is to define, for emissions purposes,
truck activity as being comprised of all activity associated with what EMFAC identifies
as medium-duty and heavier vehicles. In addition, travel activity data typically identify
trucks in a general sense, without regard to their fuel type. A useful spreadsheet
showing vehicle class mapping between trucks/non-trucks and the EMFAC2007 and
EMFAC2011 vehicle categories can be found on CARBs website:
www.arb.ca.gov/msei/vehicle-categories.xlsx. To obtain a single aggregate link emission
rate for a detailed analysis, users should properly weight together summary rates from
EMFAC2011-LDV and EMFAC2011-HD as described below.
For the light-duty (non-truck) fleet, users will need to adjust the project fleet and fleet
activity (VMT, trips) to reflect the expected project fleet mix for each EMFAC2011-LDV
run. Depending on the project, users should modify some combination of VMT (which
affects running exhaust emission factors), vehicle trips (which affects starting emission
factors), and/or vehicle population (which affects running and idling emission factors).
Typically, users should adjust the EMFAC2011-LDV VMT defaults to zero-out all
non-light-duty vehicle classes (demonstrated in Section 5.7.3.) Running the model will
produce an aggregate light duty-only emission rate for the appropriate light-duty vehicle
classes.
To estimate an aggregate emission rate for heavy-duty (truck) vehicle classes, it is
recommended that ARBs web database be used. As described in Section 5.8, emission
rates and default VMT can be obtained for each heavy-duty vehicle type. For a detailed
analysis where a project-specific age distribution is known, emission rates should be
queried for each heavy-duty vehicle type and vehicle age. A spreadsheet program can be
used to properly weight the heavy-duty vehicle types to correctly account for the project
77
For information about quantifying the benefits of retrofitting diesel vehicles and engines to conformity
determinations, see EPAs website for the most recent guidance on this topic:
www.epa.gov/otaq/stateresources/transconf/policy.htm. Also, see CARBs website at:
www.arb.ca.gov/msprog/onrdiesel/calculators.htm.

93

specific age distribution. If a detailed heavy-duty vehicle mix is not known (i.e., only a
heavy-duty/light-duty split is known), the default VMT reported by the online emission
rate database can be used to properly weight together all heavy-duty vehicle classes into a
single aggregate heavy-duty emission rate. Users can contact ARB if they have questions
or need additional information about this process.
Once aggregate light-duty and heavy-duty emission rates have been calculated for each
link, they should be weighted together based on the link specific light-duty and heavyduty vehicle mix. The resulting emission rate for each link can be used in dispersion
modeling.

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Section 6: Estimating Emissions from Road Dust,

Construction, and Additional Sources
6.1

INTRODUCTION

This section provides guidance on how to estimate re-entrained road dust and
transportation-related construction dust emissions. MOVES and EMFAC do not estimate
emissions of road or construction dust, so this section must be consulted if dust is
required to be included in the PM hot-spot analysis. See Section 2.5 for further
information regarding when dust emissions are required to be included in a PM hot-spot
analysis. This section also includes information on quantifying emissions from
construction vehicles and equipment and additional sources in the project area, when
applicable. The models and associated methods and assumptions used in estimating these
emissions must be evaluated and chosen through the process established by each areas
interagency consultation procedures (40 CFR 93.105(c)(1)(i)).

6.2

OVERVIEW OF DUST METHODS AND REQUIREMENTS

In summary, road or construction dust can be quantified using EPAs AP-42 method or
alternative local methods. AP-42 is EPAs compilation of data and methods for
estimating average emission rates from a variety of activities and sources from various
sectors. Refer to EPAs website (www.epa.gov/ttn/chief/ap42/index.html) to access the
latest version of AP-42 sections and for more information about AP-42 in general. The
sections of AP-42 that address emissions of re-entrained road dust from paved and
unpaved roads and emissions of construction dust are found in AP-42, Chapter 13,
Miscellaneous Sources. The key portions of the chapter include:
Section 13.2: Introduction to Fugitive Dust Sources,
Section 13.2.1: Paved Roads
Section 13.2.2: Unpaved Roads
Section 13.2.3: Heavy Construction Operations (includes road construction)
Users should consult EPAs website to ensure they are using the latest approved version
of AP-42, as the methodology and procedures may change over time.78
In addition to the latest version of AP-42, alternative local methods can be used for
estimating road or construction dust; in some areas, these methods may already exist and
can be considered for use in quantitative PM hot-spot analyses.
This section presumes users already have a basic understanding of how to use AP-42 or
other dust methods.

78

This guidance is applicable to current and future versions of AP-42, unless otherwise noted by EPA in
the future.

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6.3

ESTIMATING RE-ENTRAINED ROAD DUST

6.3.1

PM2.5 nonattainment and maintenance areas

The transportation conformity rule requires a hot-spot analysis in a PM2.5 nonattainment

and maintenance area to include emissions from re-entrained road dust only if emissions
from re-entrained road dust are determined to be a significant contributor to the PM2.5
nonattainment problem. See Section 2.5 for further information.
6.3.2

PM10 nonattainment and maintenance areas

Re-entrained road dust must be included in all PM10 hot-spot analyses. EPA has
historically required road dust emissions to be included in all conformity analyses of
direct PM10 emissions including hot-spot analyses. See Section 2.5 for further
information.
6.3.3

Using AP-42 for road dust on paved roads

Section 13.2.1 of AP-42 provides a method for estimating emissions of re-entrained road
dust from paved roads for situations for which silt loading, mean vehicle weight, and
mean vehicle speeds on paved roads fall within ranges given in AP-42, Section 13.2.1.3
and with reasonably free-flowing traffic (if the project doesnt meet these conditions, see
Section 6.3.5, below). Section 13.2.1 of AP-42 contains predictive emission factor
equations that can be used to estimate an emission factor for road dust. This section can
be downloaded from EPAs website at: www.epa.gov/ttn/chief/ap42/ch13/index.html.
When estimating emissions of re-entrained road dust from paved roads, site-specific silt
loading data must be consistent with the data used for the projects county in the regional
emissions analysis (40 CFR 93.123(c)(3)). In addition, if the project is located in an area
where anti-skid abrasives for snow-ice removal are applied, information about their use
should be included (e.g., the number of times such anti-skid abrasives are applied).
6.3.4

Using AP-42 for road dust on unpaved roads

Section 13.2.2 of AP-42 provides a method for estimating emissions of re-entrained road
dust from unpaved roads. Different equations are provided for vehicles traveling
unpaved surfaces at industrial sites and vehicles traveling on publicly accessible roads.
Most PM hot-spot analyses will involve only vehicles traveling on publicly accessible
roads. When applying an equation that accounts for surface material moisture content,
the percentage of surface material moisture must be consistent with the data used for the
projects county in the regional emissions analysis (40 CFR 93.123(c)(3)).

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6.3.5

Using alternative local approaches for road dust

Some PM areas have historically used locally-developed methods for estimating reentrained road dust emissions that may be more appropriate than the AP-42 methods
given specific local conditions. Other areas may develop alternatives in the future.
Also, an alternative method could be used if the equations in AP-42 do not apply
to a particular project, as they were developed using a particular range of source
conditions. Section 13.2.1 of AP-42 currently states that users should use caution
when applying the 13.2.1 equation outside of the range of variables and operating
conditions specified. In these cases, users are encouraged to consider alternative
methods that can better reflect local conditions.

6.4

ESTIMATING TRANSPORTATION-RELATED CONSTRUCTION DUST

6.4.1

Determining whether construction dust must be considered

Construction-related PM2.5 or PM10 emissions associated with a particular project are

required to be included in hot-spot analyses only if such emissions are not considered
temporary as defined in 40 CFR 93.123(c)(5) (see Section 2.5.5). The following
discussion includes guidance only for construction-related dust emissions; any other
construction emissions (e.g., exhaust emissions from construction equipment) would need
to be calculated separately, as discussed in Section 6.6.
6.4.2

Using AP-42 for construction dust

Section 13.2.3 of AP-42 describes how to estimate emissions of dust from construction of
transportation projects. This section can be downloaded from EPAs website at:
www.epa.gov/ttn/chief/ap42/ch13/index.html. Section 13.2.3 of AP-42 indicates that a
substantial source of construction-related emissions could be from material that is tracked
out from the site and deposited on adjacent paved streets. Therefore, AP-42 states that
persons developing construction site emission estimates need to consider the potential for
increased adjacent emissions from off-site paved roadways; users should refer to the
discussion regarding paved roads in Section 6.3.3.
6.4.3

Using alternative approaches for construction dust

Some PM nonattainment or maintenance areas have historically used alternative methods

for estimating construction dust that may be more appropriate than AP-42, given specific
local conditions. Other areas may develop alternatives in the future.
Also, an alternative method may be more appropriate if the projects conditions such as
surface material silt and moisture content percentages, mean vehicle weight and speed
are not within the ranges of source conditions that were tested in developing the
97

equations. In such cases, users may consider alternative methods that are more
appropriate for local conditions.

6.5

ADDING DUST EMISSIONS TO MOVES/EMFAC MODELING RESULTS

Emission factors for road and construction dust should be added to the emission factors
generated for each link by MOVES or EMFAC (in California). Once this data is
available, the user can move on to Section 7 to develop input files for the appropriate air
quality model.

6.6

ESTIMATING ADDITIONAL SOURCES OF EMISSIONS IN THE PROJECT

AREA

6.6.1 Construction-related vehicles and equipment

In certain cases, emissions resulting from construction vehicles and equipment, including
exhaust emissions as well as dust, must be included in an analysis; refer to Section 2.5.5
for more information on when to include such emissions. State and local air agencies
may have quantified these types of emissions for the development of SIP non-road
mobile source inventories, and related methods should be considered for PM hot-spot
analyses. Evaluating and choosing models and associated methods and assumptions for
quantifying construction-related emissions must be determined through an areas
interagency consultation procedures (40 CFR 93.105(c)(1)(i)).
6.6.2 Locomotives
EPA has developed guidance to quantify locomotive emissions when they are a
component of a transit or freight terminal or otherwise a source in the project area being
modeled. See Appendix I for further general guidance, resources, and examples.
6.6.3 Additional emission sources
When applicable, additional sources need to be estimated and included in air quality
modeling, as described in Section 8.

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Section 7: Selecting an Air Quality Model, Data Inputs, and

Receptors
7.1

INTRODUCTION

This section describes the recommended air quality models, data inputs, and receptor
considerations for PM hot-spot analyses. This guidance is consistent with the conformity
rule and recommendations for air quality modeling in EPAs Guideline on Air Quality
Models (Appendix W to 40 CFR Part 51).
Regardless of the model used, the quality of a models predictions depends on
appropriate input data, proper formatting, model setup, quality assurance, and other
assumptions. As noted in Section 2, air quality modeling for PM hot-spot analyses must
meet the conformity rules general requirements for such analyses (40 CFR 93.123(c))
and rely on the latest planning assumptions available when the conformity analysis
begins (40 CFR 93.110).
This section presumes that users already have a basic understanding of air quality models
and their operation. EPA has also included additional details on air quality modeling in
Appendix J of this guidance. The models in this section, user guides, and supporting
documentation are available through EPAs Support Center for Regulatory Air Models
(SCRAM) website at: www.epa.gov/scram001. Project sponsors conducting PM hot-spot
analyses will need to refer to the latest user guides and available guidance for complete
instructions.

7.2

GENERAL OVERVIEW OF AIR QUALITY MODELING

Air quality models, methods, and assumptions need to be determined for each PM hotspot analysis through the interagency consultation process (40 CFR 93.105(c)(1)(i)).
Exhibit 7-1 (following page) outlines the basic process for conducting air quality
modeling for a given project. This exhibit depicts the flow of information developed for
air quality modeling (as described in this section), the development of background
concentration estimates (see Section 8), and the calculation of design values and
comparison to the NAAQS (see Section 9).

99

Exhibit 7-1. Overview and Data Flow for Air Quality Modeling

100

7.3

SELECTING AN APPROPRIATE AIR QUALITY MODEL

7.3.1

Recommended air quality models

PM hot-spot analyses should be developed consistent with EPAs current recommended

models under Appendix W to 40 CFR Part 51. The purpose of recommending a
particular model is to ensure that the best-performing methods are used in assessing PM
impacts from a particular project and are employed in a consistent fashion.79 Exhibit 7-2
summarizes the recommended air quality models for PM hot-spot analyses for required
projects under 40 CFR 93.123(b)(1).
Exhibit 7-2. Summary of Recommended Air Quality Models
Type of Project

Recommended Model

Highway and intersection projects

AERMOD, CAL3QHCR

Transit, freight, and other terminal projects

AERMOD

Projects that involve both highway/intersections

and terminals, and/or nearby sources*

AERMOD

* Note that nearby sources refers to those sources that (1) are not part of the project but are affected by
the project or (2) are sources in the project area whose emissions are not adequately captured by the
selected background concentrations. See Section 8.2 for more information.

The American Meteorological Society/EPA Regulatory Model (AERMOD) is EPAs

recommended near-field dispersion model for many regulatory applications. EPA
recommended AERMOD in a November 9, 2005 final rule that amended EPAs
Guideline on Air Quality Models after more than ten years of development and peer
review that resulted in substantial improvements and enhancements.80 AERMOD
includes options for modeling emissions from volume, area, and point sources and can
therefore model the impacts of many different source types, including highway and
transit projects. In addition, EPA conducted a study to evaluate AERMOD and other air
quality models in preparation for developing this guidance and the study supported

79

The best performing model is one that best predicts regulatory design values for a particular pollutant.

EPAs Protocol for Determining the Best Performing Model (EPA-454/R-92-025) defines operational

and statistical criteria for this evaluation. According to the document: For a pollutantfor which short-

term ambient standards exist, the statistic of interest involves the network-wide highest concentrationthe

precise time, location, and meteorological condition is of minor concern compared to the magnitude of the

highest concentration actually occurring.

80
The final rule can be found at: www.epa.gov/scram001/guidance/guide/appw_05.pdf. Extensive

documentation is available on EPAs SCRAM website describing the various components of AERMOD,

including user guides, model formulation, and evaluation papers. See:

www.epa.gov/scram001/dispersion_prefrec.htm#aermod.

101

AERMODs use.81 To date, AERMOD has already been used to model air quality near
roadways, other transportation sources, and other ground-level sources for regulatory
applications by EPA and other federal and state agencies.82
CAL3QHCR is an extension of the CAL3QHC model, which is the model recommended
for use in analyzing CO impacts from intersections.83 In addition, CAL3QHCR
incorporates enhancements to process up to a year of meteorological data and emissions
data that vary by day of week and hour of day. It is appropriate to use CAL3QHCR for
PM hot-spot modeling for specified projects; however, its queuing algorithm should not
be used.
Both the AERMOD and CAL3QHCR models (and related documentation) can be
obtained through EPAs SCRAM website. OAQPS maintains the SCRAM website and
maintains, codes, and supports AERMOD on an ongoing basis. Modelers should
regularly check this website to ensure use of the latest regulatory version. CAL3QHCR
is not maintained by EPA and is no longer updated; therefore, technical support for the
model code is not available through OAQPS. However, EPA will provide technical
support for implementing AERMOD and the current version of CAL3QHCR for PM hotspot analyses completed with this guidance.
Appendix J includes important additional information about configuring AERMOD and
CAL3QHCR when using these models to complete PM hot-spot analyses. In the future,
it is possible that other recommended models will become available.
Highway and Intersection Projects
Some projects may consist exclusively of highways and intersections, with little or no
emissions coming from extended idling, non-road engine operations, or modeled nearby
sources (see more below). Both AERMOD and CAL3QHCR are recommended air
quality models for these types of projects.84 When using CAL3QHCR for such highway
and intersection projects, its queuing algorithm should not be used. As discussed in
Sections 4 and 5, as well as in Appendix D, idling vehicle emissions should instead be

81

Hartley, W.S.; Carr, E.L.; Bailey, C.R. (2006). Modeling hotspot transportation-related air quality
impacts using ISC, AERMOD, and HYROAD. Proceedings of Air & Waste Management Association
Specialty Conference on Air Quality Models.
82
For example, EPA used AERMOD to model concentrations of nitrogen dioxide (NO 2) as part of the 2008
Risk and Exposure Assessment for revision of the primary NO2 NAAQS. Also, other agencies have used
AERMOD to model PM and other concentrations from roadways (represented as a series of area sources)
for purposes of NEPA and CAA analyses.
83
CAL3QHC is a CALINE3-based screening model with a traffic model to calculate delays and queues at
signalized intersections; CAL3QHCR is a refined model based on CAL3QHC that requires local
meteorological data. The CAL3QHCRs User Guide (Users Guide to CAL3QHC Version 2.0: A
Modeling Methodology for Predicting Pollutant Concentrations Near Roadway Intersections) can be
found at: www.epa.gov/scram001.
84
Appendix W to 40 CFR Part 51 describes both AERMOD and CAL3QHCR as being appropriate for
modeling line sources. For further background, see Sections 3.0, 4.0, 5.0, and 8.0 of Appendix W, as well
as Appendix A to Appendix W of 40 CFR Part 51.

102

accounted for by properly specifying links for emission analysis and reflecting idling
activity in the activity patterns used for MOVES or EMFAC modeling.
Note: Users should be aware that, to handle quarterly emissions and multiple years of
meteorological data, AERMOD and CAL3QHCR need different numbers of input files
and runs. AERMOD can handle quarterly variations in emissions and multiple years of
meteorological data using a single input file and run. In contrast, CAL3QHCR can
handle only one quarters emissions and one year of meteorological data at a time. See
further information in Section 7.5.3.
Transit and Other Terminal Projects
Other projects may include only transit or freight terminals and transfer points where a
large share of total emissions arise from engine start and idling emissions or from nonroad engine activity. AERMOD is the recommended air quality model for these types of
projects.
Projects that Involve Both Highway/Intersection and Terminal Projects, and/or Nearby
Sources
There may be some projects that are a combination of the highway and intersection and
transit and freight terminal project types. AERMOD is the recommended model for
these projects. As a general recommendation, if AERMOD is used for modeling any
source associated with the project, it should be the only air quality model used for the PM
hot-spot analysis.85 There may be other cases where the project area also includes a
nearby source that is affected by the project, and as a result, needs to be modeled to
account for background concentrations around the project (e.g., locomotives at a nearby
freight terminal or marine port). In these cases, AERMOD should be used for the project
and any such nearby sources. In general, it should be unnecessary to include nearby
sources in air quality modeling if they are not affected by the project (assuming the
impacts of such sources are adequately accounted for in the selected representative
background concentrations). See Section 8.2 for further information on nearby sources.

85

There are several reasons for this recommendation. First, AERMOD is flexible in how different sources
are represented, while CAL3QHCR represents all sources as line sources (see Section 7.3.2). Second,
AERMOD allows a much wider number of receptors and sources to be modeled simultaneously, which is
useful for large projects with different source configurations. Third, AERMODs treatment of dispersion in
the lower atmosphere is based on more current atmospheric science than CAL3QHCR. Furthermore, the
use of a single model, rather than multiple models, is recommended to avoid the need to run the same
meteorological data through different preprocessors (AERMET, MPRM), avoid different receptor networks
for different sources, reduce the number of atmospheric modeling runs required to analyze a project, avoid
the use of different modeling algorithms that perform the same task, and reduce double-counting or other
errors.

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7.3.2

How emissions are represented in CAL3QHCR and AERMOD

Both CAL3QHCR and AERMOD simulate how pollutants disperse in the atmosphere.
To do so, the models classify emission sources within a project as line, volume, area, and
point sources:
Line sources are generally linear emission sources, which can include highways,
intersections, and rail lines. They are directly-specified in the CAL3QHCR input
file using road link coordinates. AERMOD can simulate a highway line source
using a series of adjacent volume or area sources (see the AERMOD User Guide
and the AERMOD Implementation Guide for suggestions).86
Volume sources (used in AERMOD only) are three-dimensional spaces from
which emissions originate. Examples of sources that could be modeled as volume
sources include areas designated for truck or bus queuing or idling (e.g., offnetwork links in MOVES), driveways and pass-throughs in bus terminals, and
locomotive activity at commuter rail or freight rail terminals.87
Area sources (used in AERMOD only) are flat, two-dimensional surfaces from
which emissions arise (e.g., parking lots).
Point source emissions (used in AERMOD only) emanate from a discrete location
in space, such as a bus garage or transit terminal exhaust stack.
Each of these source types may be appropriate for representing different sources in a PM
hot-spot analysis. For example, highways may be modeled as line sources in
CAL3QHCR, but they may also be modeled as a series of adjoining volume or area
sources in AERMOD, as described below. Using another example, an exhaust vent from
a bus garage might be best represented as a point source, area source, or volume source,
depending on its physical characteristics. Project sponsors should consult with the most
recent user guides for air quality models to determine the most appropriate way to
represent a particular source within a model. Appendix J includes additional specific
information for modeling highway and transit projects.
7.3.3

Alternate models

In limited cases, an alternate model for use in a PM hot-spot analysis may be considered.
As stated in Section 3.2 of Appendix W, Selection of the best techniques for each
individual air quality analysis is always encouraged, but the selection should be done in a
consistent manner. This section of Appendix W sets out objective criteria by which
alternate models may be considered.
Analyses of individual projects are not expected to involve the development of new air
quality models. However, should a project sponsor seek to employ a new or alternate
model for a particular transit or highway project, that model must address the criteria set
forth in Section 3.2 of Appendix W. Determining model acceptability in a particular
86

The AERMOD Implementation Guide is updated on a periodic basis. The latest version is posted on the

SCRAM web site at: www.epa.gov/ttn/scram/dispersion_prefrec.htm#aermod.

87
See Appendix I for information on estimating locomotive emissions.

104

application is an EPA Regional Office responsibility involving consultation with EPA

Headquarters, when appropriate.

7.4

CHARACTERIZING EMISSION SOURCES

Characterizing sources is the way in which the transportation projects features and
emissions are represented within an air quality model. In order to determine the
concentrations downwind of a particular emission source, an air quality model needs to
have a description of the sources, including:
Physical characteristics and location;
Emission rates/emission factors; and
Timing of emissions.
There may be several different emission sources within the project area. Sections 4 and 5
describe how a project can be characterized into different links, which will each have
separate emission rates to be used in air quality modeling. Sections 6 and 8.2 outline how
nearby source emissions, when present, can be characterized to account for emissions
throughout the project area. Properly characterizing all of these distinct sources within
the PM hot-spot analysis will help ensure that the locations with the greatest impacts on
PM air quality concentrations are identified.
This section describes the major elements needed to characterize a source properly for
use in an air quality model.
7.4.1

Physical characteristics and location

When modeling an emission source, its physical characteristics and location need to be
described using the relevant models input format, as described in the appropriate user
guide. Sources with the same emission rate but with different physical characteristics
may have different impacts on predicted concentrations.
Refer to Appendix J of this guidance and to the user guides for CAL3QHCR and
AERMOD for specific information about how physical characteristics and location of
sources are included in these models.
In addition, for emissions on or near rooftops, such as those from exhaust stacks on
transit or other terminal projects, building downwash can result in higher concentrations
on the downwind side of nearby buildings than would otherwise be present.88 Consult
Appendix J for guidance on when to include building downwash for these projects when
using AERMOD.

88

Building downwash occurs when air moving over a building mixes to the ground on the downwind side
of the building.

105

7.4.2

Emission rates/emission factors

The magnitude of emissions within a given time period or location is a necessary

component of dispersion modeling. For motor vehicles, MOVES-based emission rates
are required in all areas other than the state of California, where EMFAC-based emission
rates are required, as described in Sections 4 and 5, respectively. For road and
construction dust, emission factors from AP-42 or a local method are required, as
described in Section 6. For nearby sources, the appropriate emission rates should also be
estimated, as described in Sections 6 and 8.2.
CAL3QHCR and AERMOD accept emission rates in different formats. For highways
and intersections, CAL3QHCR needs emissions to be specified in grams/vehicle-mile
traveled (grams/mile).89 AERMOD needs emission rates in grams/hour (or
grams/second). When employing area sources with AERMOD (e.g., parking lots),
emission rates must be specified in grams/second per unit area.
7.4.3

Timing of emissions

The proper description of emissions across time of year, day of week, and hour of day is
critical to the utility of air quality modeling.90 Sections 4 and 5 describe how to account
for different periods of the day in emissions modeling with MOVES and EMFAC. This
approach is then applied to air quality modeling to estimate air quality concentrations
throughout a day and year. As described in Section 3.3.4, air quality modeling for the
annual PM2.5 NAAQS would involve data and modeling for all four quarters of the
analysis year; air quality modeling for the 24-hour PM NAAQS may involve all four
quarters, or one quarter in certain circumstances.
Sections 4 and 5 and Appendix J describe how results from MOVES and EMFAC should
be prepared for use as inputs in both AERMOD and CAL3QHCR.

7.5

INCORPORATING METEOROLOGICAL DATA

7.5.1

Finding representative meteorological data

One of the key factors in producing credible results in a PM hot-spot analysis is the use
of meteorological data that is as representative as possible of the project area.
Meteorological data are necessary for running either AERMOD or CAL3QHCR because
meteorology affects how pollutants will be dispersed in the lower atmosphere. The
following paragraphs provide an overview of the meteorological data needed and sources
of this data. More detailed information can be found in Appendix J and in model user
89

CAL3QHCR uses the hourly volume of vehicles on each road link and the emission factor (in
grams/mile) for the vehicles on each link to calculate time-specific emission rates for use in air quality
modeling. As described in Sections 4 and 5, the idle emission factor inputs in CAL3QHCR should not be
used in a PM hot-spot analysis.
90
The timing of emissions in AERMOD is described in Section 3.3.5 of the AERMOD User Guide.

106

and implementation guides. EPAs SCRAM web site also contains additional
information, including additional guidance, archived meteorological data (which may be
suitable for some analyses), and links to data sources.
Meteorological data is used by air quality dispersion models to characterize the extent of
wind-driven (mechanical) and temperature-driven (convective) mixing in the lower
atmosphere throughout the day.91 For emissions near the ground, as is common in
transportation projects, dispersion is driven more by mechanical mixing, but temperaturedriven mixing can still have a significant impact on air quality. As a sources plume
moves further downwind, temperature-driven mixing becomes increasingly important in
determining concentrations.
Depending on the air quality model to be used, the following types of information are
needed to characterize mechanical and convective mixing:
Surface meteorological data, from surface meteorological monitors that measure
the atmosphere near the ground (typically at a height of 10 meterssee Section
7.5.2);
Upper air data on the vertical temperature profile of the atmosphere (see Section
7.5.2);
Data describing surface characteristics, including the surface roughness, albedo,
and Bowen ratio (see Section 7.5.4); and
Population data to account for the urban heat island effect (see Section 7.5.5).
Project sponsors may want to first consult with their respective state and local air quality
agencies for any representative meteorological data for the project area. In addition,
some state and local air agencies may maintain preprocessed meteorological data suitable
for use in PM hot-spot analyses. Interagency consultation can be used to determine
whether preprocessed meteorological data are available, which could reduce time and
resources for PM hot-spot analyses.
To format meteorological data appropriately and prepare them for use in air quality
models, EPA maintains meteorological processing software on the SCRAM website.92
These programs produce input data files that the air quality models read to produce
calculations of atmospheric dispersion. AERMOD and CAL3QHCR employ different
meteorological preprocessing programs. AERMET is the meteorological preprocessor
for AERMOD. The Meteorological Processor for Regulatory Models (MPRM) program
is the meteorological preprocessor for CAL3QHCR. User guides for both AERMET and
MPRM should be consulted for specific instructions.
The meteorological data used as an input to an air quality model should be selected on the
basis of geographic and climatologic representativeness and how well measurements at
91

Mechanical turbulence arises when winds blow across rough surfaces. When wind blows across areas

with greater surface roughness (roughness length), more mechanical turbulence and mixing is produced.

Temperature-driven mixing is driven by convection (e.g., hot air rising).

92
These programs and their user guides may be downloaded from the SCRAM website at:

www.epa.gov/scram001/metobsdata_procaccprogs.htm.

107

one site represent the likely transport and dispersion conditions in the area around the
project. The representativeness of the data depends on factors such as:
The proximity of the project area to the meteorological monitoring site;
The similarity of the project area to the meteorological monitoring site in surface
characteristics (particularly surface measurements);
The time period of data collection;
Topographic characteristics within and around the project area; and
Year-to-year variations in weather conditions (hence, a sufficient length of
meteorological data should be employed, as discussed in Section 7.5.3 and
Appendix J).
The AERMOD Implementation Guide provides up-to-date information and
recommendations on how to judge the representativeness of meteorological data. 93
Modelers should consult the most recent version of the AERMOD Implementation Guide
for assistance in obtaining and handling meteorological information. Although intended
for users of AERMOD, its recommendations for how to assess the representativeness of
meteorological data apply to analyses employing CAL3QHCR as well.
7.5.2

Surface and upper air data

Surface Data
Air quality models need representative meteorological data from a near-ground surface
weather monitoring station (surface data). Models have minimum needs for surface
observations. For example, when using National Weather Service (NWS) data to
produce meteorological input files for AERMOD, the following surface data
measurements are needed:
Wind vector (speed and direction);
Ambient temperature; and
Opaque sky cover (or, in the absence of opaque sky cover, total sky cover).
Station barometric pressure is recommended, but not needed (AERMET includes a
default value in the absence of such data).
When processing data using MPRM for use in CAL3QHCR, information on stability
category is also needed. MPRM estimates stability internally. Alternatively, when using
NWS data, the calculation needs:
Wind speed and direction;
Ceiling height; and
Cloud cover (opaque or total).
For details, refer to the AERMET or MPRM user guides on the SCRAM website.94

93
94

See www.epa.gov/scram001/dispersion_prefrec.htm#aermod.
See www.epa.gov/scram001/metobsdata_procaccprogs.htm.

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Upper Air Data

Upper air soundings measure gradients of vertical temperature in the atmosphere. The
vertical temperature gradients of the lower atmosphere are used by air quality models to
calculate convective mixing heights. Models need upper air sounding data from a
representative measurement site. For AERMOD, consult the AERMOD Implementation
Guide for specific recommendations. For CAL3QHCR, consult the MPRM user guide.
Obtaining Surface and Upper Air Meteorological Data
Meteorological data that is most representative of the project area should always be
sought. Meteorological data that can be used for air quality modeling are routinely
collected by the NWS. Other organizations, such as the FAA, local universities, military
bases, industrial facilities, and state and local air agencies may also collect such data.
Project sponsors may also choose to collect site-specific data for use in PM hot-spot
analyses, but it is not necessary to do so. If site-specific data are used, it should be
obtained in a manner consistent with EPA guidance on the topic.95
There are several locations where such data can be obtained. The National Oceanic and
Atmospheric Administrations National Climatic Data Center (NCDC) contains many
years of archived surface and upper air data (www.ncdc.noaa.gov) from NWS and other
sources. In addition, EPAs SCRAM web site contains archived surface and upper air
data from several sources, including NWS, as well as internet links to other data sources.
Some states can provide processed meteorological data for use in regulatory air quality
modeling applications. Other local agencies and institutions may also provide
meteorological data, as described above.
7.5.3

Time duration of meteorological data record

PM hot-spot analyses can be based on either off-site or site-specific meteorological data.

When using off-site data, five consecutive years of the most recent representative
meteorological data should be used.96 Meteorological data files that have been
preprocessed by the relevant state or local air agency may be used, when appropriate. If
meteorological data are collected on the project area prior to analysis, at least one year of
site-specific data is needed. Consult Section 8.3.1 of Appendix W for additional
explanation.
AERMOD and CAL3QHCR have different capabilities for modeling meteorological
data, as illustrated in Exhibit 7-3 (following page). The numbers in the exhibit pertain to
each analysis year and build or no-build scenario analyzed.
95

See Section 8.3.3 in Appendix W to 40 CFR Part 51 (Site Specific Data) and the Monitoring
Guidance for Regulatory Modeling Applications (www.epa.gov/scram001/metguidance.htm). Other
meteorological guidance documents are also available through SCRAM, including procedures for
addressing missing data and for quality assuring meteorological measurements.
96
As noted above, meteorological data are available through the NCDC website. Meteorological data are
continuously collected by NWS from sources such as airports. Five years of meteorological data are also
routinely used in other dispersion modeling applications.

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Exhibit 7-3. Air Quality Model Capabilities for Meteorological Data for Each
Scenario
Type of Air
Quality Model
AERMOD
CAL3QHCR

Number of Runs with 5

Years of Off-Site
Meteorological Data
1-5
20

Number of Runs with 1 Year

of Site-Specific
Meteorological Data
1
4

AERMOD can model either five years of representative off-site meteorological data (e.g.,
from NWS) or one year of site-specific data in a single run, since the model handles
different emissions within a year and multiple years of meteorological data with a single
input file. This requires a user to externally join meteorological data files before
preprocessing them with AERMET. Alternatively, AERMOD can be run five times, with
one year of meteorological data processed per run.
CAL3QHCR needs different input files for each quarter that is modeled using MOVES or
EMFAC, since CAL3QHCR does not distinguish between emission changes due to
seasonal differences. If site-specific data are collected, CAL3QHCR needs to be run only
four times, once for each quarter. If off-site data are used (e.g., from NWS), modeling
five years of consecutive meteorological data involves five runs of CAL3QHCR for each
quarter, which results in 20 runs for all four quarters.
7.5.4

Considering surface characteristics

In addition to surface and upper air meteorological data, three surface characteristics for
the site of meteorological monitoring are needed for air quality modeling, depending on
the model used:
The surface roughness length (zo), which indicates how much the surface features
at a given site (e.g., buildings, trees, grass) interrupt a smooth-flowing wind;
Albedo (r), which is the amount of solar radiation reflected by the surface; and
Bowen ratio (Bo), which indicates how much heat the ground imparts to the air,
instead of evaporating moisture at the surface.
AERMOD and AERMET make use of these parameters directly. CAL3QHCR and
MPRM do not need data on surrounding surfaces albedo or Bowen ratio for modeling
ambient PM concentrations, but surface roughness is an input to CAL3QHCR.97 As
described above, surface characteristics are also used to assess a meteorological
monitors representativeness.
The AERMOD Implementation Guide should be consulted for the latest information on
processing land surface data, when using either AERMOD or CAL3QHCR. Although its
recommendations are intended for AERMOD, they also apply to CAL3QHCR with
97

As described in Section 4.2 of its user guide, MPRM makes use of surface roughness in calculating
stability categories.

110

meteorological data processed by MPRM.98 More detailed information about each of

these characteristics is found in Appendix J.
Sources of data that can be used to determine appropriate surface characteristics include
printed topographic and land use/land cover (LULC) maps available from the U. S.
Geological Survey (USGS), aerial photos from web-based services, site visits and/or site
photographs, and digitized databases of LULC data available from USGS. For specific
transportation projects, detailed nearby LULC data may be developed as part of project
design and engineering plans. Furthermore, some MPOs have adopted modeling
techniques that estimate the land use impacts resulting from individual highway and
transit projects.
LULC data may only be available for particular years in the past. As such, planning for
modeling should consider how representative these data are for the year when
meteorological data were collected, as well as the PM hot-spot analysis year(s).
The National Land Cover Database (NLCD) is a set of satellite-based land cover
measurements that are updated periodically.99 As of the writing of this guidance,
versions of the NLCD have been released representing calendar years 1992 and 2001,
with five areas/states (New England, Mississippi, South Dakota, Washington, and
Southern California) being updated to reflect 2006. Consult the AERMOD
Implementation Guide for recommendations for using NLCD data when processing
meteorological data.100
In most situations, the project area should be modeled as having flat terrain. However, in
some situations a project area may include complex terrain, such that sources and
receptors included in the model are found at different heights. See Appendix J for
information on handling complex terrain in air quality modeling.
7.5.5

Specifying urban or rural sources

In addition to surface characteristics, night-time dispersion in urban areas can be greater

than in surrounding rural areas with similar surface characteristics as a result of the
urban heat island effect.101 After sunset, urban areas cool at slower rates than
surrounding rural areas, because buildings in urban areas slow the release of heat.
Furthermore, the urban surface cover has greater capacity for storing thermal energy due
to the presence of buildings and other urban structures. As a result, the vertical motion of
urban air is enhanced through convection, a phenomenon lacking (or reduced) in rural
98
The CAL3QHCR User Guide does not address preprocessing meteorological data, which is necessary for
PM hot-spot analyses. In the absence of such information, project sponsors should rely on the AERMOD
Implementation Guide when using either dispersion model.
99
This database can be accessed at: www.mrlc.gov.
100
The AERSURFACE model, a non-regulatory component of AERMOD, may also be used to generate
information on surface roughness, albedo, and Bowen ratio. As of this writing, AERSURFACE is based on
the 1992 NLCD. The latest version of AERSURFACE may be accessed via SCRAM
(www.epa.gov/scram001/).
101
The MPRM User Guide refers to the urban heat island effect as anthropogenic heat flux.

111

areas. The magnitude of the urban heat island effect is driven by the urban-rural
temperature difference that develops at night.
The implications for highway and transit projects are that the same emissions in a rural
area will undergo less dispersion than the same source in an urban area, all other factors
(e.g., surface characteristics, meteorology) being equal. For the purposes of a hot-spot
analysis, then:
In urban areas, sources should generally be treated as urban.
In isolated rural nonattainment and maintenance areas (as defined by 40 CFR
93.101), sources should be modeled as rural.
Near the edge of urban areas, additional considerations apply that should be
addressed through the interagency consultation process.102
Modeling sources as urban or rural can have a large impact on predicted concentrations.
Both AERMOD and CAL3QHCR can account for the urban/rural differences in
dispersion. When sources are modeled as urban in AERMOD, the urban areas
population is a necessary input.
For projects near or beyond the edge of an urbanized area, there may be situations where
the build and no-build scenarios result in different degrees of urbanization. In these
situations, sources in the build scenario might be treated as urban, while in the no-build
they are treated as rural. Local data on such cases may not be universally available,
although some planning agencies have adopted models that may allow the impacts of
projects on population growth to be described. Given the potentially large impact of
modeling sources as either urban or rural, all available information on population growth
in the greater area around the project should be used when modeling projects near or
beyond the edge of an urbanized area.
When using AERMOD, consult the latest version of the AERMOD Implementation
Guide for additional information, including instructions on what type of population data
should be used in making urban/rural determinations. When using CAL3QHCR, consult
Section 7.2.3 of Appendix W for guidance on determining urban sources. Refer to
Appendix J for additional information on how to handle this data for each model.

102

Since the urban heat island is not a localized effect, but regional in character, Section 7.2.3 of Appendix
W recommends that all sources within an urban complex be modeled as urban.

112

7.6

PLACING RECEPTORS

Note: Section 7.6 has been revised in accordance with EPAs 2012 PM NAAQS final rule
that was published on January 15, 2013 (78 FR 3264).103
7.6.1 Overview
Receptors for conformity purposes are locations in the project area where an air quality
model estimates future PM concentrations. Section 93.123(c)(1) of the conformity rule
requires PM hot-spot analyses to estimate air quality concentrations at appropriate
receptor locations in the area substantially affected by the project. An appropriate
receptor location is a location that is suitable for comparison to the relevant PM
NAAQS, consistent with how the PM NAAQS are established and monitored for air
quality planning purposes.104
The paragraphs below provide general guidance for placing receptors for all PM
NAAQS. Placing receptors should take into account project emissions as well as any
modeled nearby sources. Project sponsors should place receptors in the project area for
the relevant NAAQS consistent with applicable requirements. Evaluating and choosing
the models and associated methods and assumptions for placing receptors must be
completed through the process established by each areas interagency consultation
procedures (40 CFR 93.105(c)(1)(i)). State and local air quality agencies have significant
expertise in air quality planning for the PM NAAQS that may be relevant for PM hotspot analyses.
Receptors can be placed for PM2.5 hot-spot analyses consistent with EPAs general
guidance for any air quality modeling, as described below; there are no longer special
considerations for receptor placement for either the 24-hour or annual PM2.5 NAAQS.105
As a result, EPA has revised Section 7.6 of this guidance document to remove the
previous additional guidance for placing receptors for hot-spot analyses involving either
PM2.5 NAAQS. In addition, EPA has revised Section 9.4 for determining appropriate
receptor locations for the annual PM2.5 NAAQS.106

103

EPA committed to review whether there is a need to issue new or revised transportation conformity
guidance in light of this final rule. (78 FR 3264) EPA is fulfilling this commitment through this guidance
revision. The previous version of Section 7.6 was issued in December 2010, EPA-420-B-10-040.
104
CAA section 176(c)(1)(B) requires that transportation activities do not cause or contribute to new
NAAQS violations, worsen existing NAAQS violations, or delay timely attainment of the NAAQS or
interim milestones in the project area. EPA interprets NAAQS in this provision to mean the specific
NAAQS that has been established through rulemaking.
105
The previous PM2.5 monitoring regulations required that air quality monitors for the 24-hour and annual
PM2.5 NAAQS be placed at population-oriented locations. This requirement was eliminated from the
monitoring regulations under the 2012 PM NAAQS final rule, and as a result, this is no longer a
consideration for placing receptors for hot-spot analyses for either PM2.5 NAAQS.
106
The 2012 PM NAAQS final rule also resulted in receptors for the annual PM2.5 NAAQS needing to
represent area-wide locations, rather than the previous community-wide air quality requirement.

113

7.6.2 General guidance for receptors for all PM NAAQS

Section 7.2.2 of Appendix W to 40 CFR Part 51 provides guidance on the selection of
critical receptor sites for refined analyses, and recommends that receptor sites be placed
in sufficient detail to estimate the highest concentrations and possible violations of a
NAAQS. The selection of receptor sites for all PM NAAQS should be determined on a
case-by-case basis taking into account project-specific factors that may influence areas of
expected high concentrations, such as prevailing wind directions, monitor locations,
topography, and other factors. In designing a receptor network (e.g., the entire coverage
of receptors for the project area), the emphasis should be placed on resolution and
location, not the total number of receptors. Design of the receptor network should also
consider whether any locations within the project area should be excluded from the
modeling based on a location being restricted from public access or where a member of
the public would normally be present only for a very short period of time. Examples
include locations within a fenced property of a business, a median strip of a highway, a
right-of-way on a limited access highway, or an approach to a tunnel.
As described in Appendix W, air quality dispersion models are more reliable for
estimating the magnitude of highest concentrations somewhere within a specified area
and span of time than in predicting concentrations at a specific place and time.
Therefore, receptors should be sited at all locations at which high concentrations may
occur, rather than simply focusing on the expected worst case location.
Receptor spacing in the vicinity of the source should be of sufficient resolution to capture
the concentration gradients around the locations of maximum modeled concentrations.
The majority of emissions from a highway or transit project will occur within several
meters of the ground, and concentrations are likely to be greatest in proximity of nearground sources. As such, receptors should be placed with finer spacing (e.g., 25 meters)
closer to a near-ground source, and with wider spacing (e.g., 100 meters) farther from
such a source. While prevailing wind directions may influence where maximum impacts
are likely to occur, receptors should also be placed in all directions surrounding a project.
It should not be assumed that the location of maximum concentration will always be
located closest to the project itself. For example, if a highway project consists of a new
bypass that branches off an existing highway with significant emissions, maximum
concentrations may be expected at receptors farther from the project, but closer to the
existing highway.
Receptors should be sited as near as five meters from a source (e.g., the edge of a traffic
lane or a source in a terminal), except possibly with projects involving urban street
canyons where receptors may be appropriate within 2-10 meters of a project.107 In
Although this is not a consideration for placing receptors, it is relevant for interpreting design values for the
annual PM2.5 NAAQS for cases involving unique locations, as described further in Section 9.4.
107
See 40 CFR Part 58, Appendix D, Section 4.7.1(c)(1); Appendix E, Section 6.3(b) and Table E-4. The
interagency consultation process should be used to determine when these provisions are relevant for a given
analysis.

114

addition, if AERMOD is used to create a standardized receptor network (e.g., using

AERMODs Cartesian or polar grid functions), receptors may inadvertently be placed
within five meters of a project, and subsequently modeled. Such receptors should not be
used when calculating design values in most cases.
Receptors should be placed to capture the impacts of the project and any nearby source
that needs to be modeled. Receptor placement should be extended out to a sufficient
distance from sources to account for emissions that affect concentrations throughout the
project area, depending on the spatial extent of the project and the impacts of other
modeled sources.
EPA recommends that receptors should be sited to represent concentrations near-ground
level, generally at a height of 1.8 meters above grade or less. Receptors should also be
placed at higher elevations if needed to represent concentrations at several heights along
multi-story buildings, such as apartment or office buildings.
When completing air quality modeling for build and no-build scenarios, receptors should
be placed in the same geographic locations in both scenarios so that direct comparisons
can be made between the design values calculated at each receptor. Receptors are first
determined based on the build scenario, and then placed in the same locations in the nobuild scenario (when this scenario is modeled). See Section 9 for further information
regarding calculating design values in a build/no-build analysis and appropriate receptors.

7.7

RUNNING THE MODEL AND OBTAINING RESULTS

After preparing all model inputs, the air quality model should be run to predict
concentrations. Next, background concentrations need to be determined, as described in
Section 8. Finally, the resulting concentrations at receptors should be combined with
background concentrations from other sources to calculate design values, as described in
Section 9.
Note that, before the results of either AERMOD or CAL3QHCR are ready for use in
calculating design values and determining conformity, the data will have to undergo
some post-processing, depending on how the data was run in the models and the NAAQS
being evaluated. See Appendix J for more details.

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Section 8: Determining Background Concentrations from

Nearby and Other Emission Sources
8.1

INTRODUCTION

This section describes how to determine background concentrations for PM hot-spot

analyses. Section 93.123(c)(1) of the conformity rule states that estimated pollutant
concentrations must be based on the total emissions burden which may result from the
implementation of the project, summed together with future background
concentrations. Background concentrations do not include the emissions from the
project itself.108 Instead, background concentrations for PM hot-spot analyses involve:
Nearby sources: These are individual sources other than the highway or transit
project that contribute to ambient concentrations in the project area. Some nearby
sources may be included in the air quality modeling for PM hot-spot analyses,
while other nearby sources can be reflected in representative background
concentrations. In general, nearby sources would be included in air quality
modeling only when those sources would be affected by the project; and
Other sources: This term is intended to capture the background concentrations in
the project area that are not from the project or any nearby sources that are
modeled.
Further information is provided in Section 8.2 on when to include nearby sources in air
quality modeling and in Section 8.3 on how to include the impact of other sources of
emissions in a future analysis year. It is important to note that nearby sources may only
be present for some PM hot-spot analyses.
This section is consistent with EPAs Guideline on Air Quality Models (Appendix W
to 40 CFR Part 51), which provides the appropriate framework for defining the elements
of background concentrations. Section 8.2.1 of Appendix W states that background
concentrations are an essential part of the total air quality concentration to be considered
in determining source impacts.109 Concentrations are expected to vary throughout a PM
nonattainment or maintenance area, resulting from differences in emission sources,
meteorology, terrain, and other factors. EPA believes that meeting Section 93.123(c)(1)
requirements for PM hot-spot analyses will be different from what has occurred
historically for CO hot-spot analyses, due to the fundamental differences between the
contributors to PM and CO pollution and the projects that are required to have
quantitative PM and CO hot-spot analyses. Additional information is provided in Section
8.3 of this guidance.

108

See Sections 4 through 6 for more information on how to estimate project emissions.

Section 8.2.3 recommends for multi-source areas that two components of background should be

determined: contributions from nearby sources and contributions from other sources.

109

116

Evaluating and choosing the models and associated methods and assumptions for nearby
sources and representative background concentrations must be completed through the
process established by each areas interagency consultation procedures (40 CFR
93.105(c)(1)(i)).
State and local air quality agencies will have the primary expertise on what emission
sources are expected to affect background concentrations, including any nearby sources.
The state or local air agency is likely to have an understanding of the project area and
knowledge about information needed to characterize background concentrations
appropriately, due to experience in developing air quality demonstrations, emission
inventories, and siting air quality monitors for a given NAAQS. The EPA Regional
Office is also a key resource for discussions regarding the air quality monitoring network,
SIP modeling, and other issues.

8.2

NEARBY SOURCES THAT REQUIRE MODELING

Nearby sources are individual sources that contribute PM concentrations to the project
area.110 In general, nearby sources need to be included in air quality modeling only when
those sources would be affected by the project. An example of a project that could affect
nearby sources would be a highway project whose primary purpose is to accommodate
future growth in freight and goods movement; such a project could affect emissions from
related activity at nearby marine ports, rail yards, or intermodal facilities. These types of
nearby sources (that is, those affected by the project) need to be included in air quality
modeling for the PM hot-spot analysis, as described in Section 7, because their emissions
will change between build and no-build scenarios.
EPA anticipates that most PM hot-spot analyses will not involve modeling of nearby
sources that are not affected by the project, such as a stationary source, since these types
of nearby sources would typically be captured in the representative background
concentrations described in Section 8.3.
The following questions can be used by project sponsors, the relevant state or local air
agency, the EPA Regional Office, and other members of the interagency consultation
process to identify any nearby sources that are affected by the project:
Are there any nearby sources in the project area? If no, then the remainder of
Section 8.2 can be skipped.
If yes, then:
o Do these sources emit significant levels of emissions that could affect PM
concentrations in the project area?
o Are emissions from any nearby sources expected to differ between the
build and no-build scenarios as a result of the project?
110

Section 8.2.3 of Appendix W describes nearby sources more generally as: All sources expected to
cause a significant concentration gradient in the vicinity of the source or sources under consideration for
emission limit(s) should be explicitly modeled.

117

EPA notes that there may be limited cases where nearby sources not affected by the
project would also need to be included in the modeling for a PM hot-spot analysis.
However, such cases would only occur when these sources are not captured in
background concentrations for the project area. See Section 8.3 for further information
on the factors used to determine representative background concentrations for these
cases.
For example, if a stationary source is located upwind of the project area, representative
background concentrations should include concentrations from such a source whenever
possible. As stated above, state and local air quality agencies and the EPA Regional
Office are key resources in understanding how to characterize nearby sources in PM hotspot analyses, including those nearby sources not affected by the project.
As discussed in Section 7.3, EPA recommends that AERMOD be used for any PM hotspot analyses that involve nearby sources that need to be modeled. The air quality
modeling for nearby sources that would be affected by the project must include any
reasonably expected changes in operation of the nearby source between the build and nobuild scenarios when both scenarios are necessary to demonstrate conformity. Refer to
Section 7 for more information about using AERMOD, placing receptors, and other
information for air quality modeling.
Specific information on emissions from nearby sources should be obtained. The state and
local air agency should be consulted on characterizing nearby sources. In addition,
emission rates and other parameters of nearby sources should be consistent with any
permits approved by the state or local air agency, when applicable. For unpermitted
sources, emission information should be consistent with information used by air agencies
for developing emission inventories for regulatory purposes. Sections 8.1 and 8.2 of
Appendix W describe the information needed to characterize the emissions of nearby
sources for air quality models. For the 24-hour PM2.5 and PM10 NAAQS, it is also
important to consider Section 8.2.3 of Appendix W, which states that it is appropriate to
model nearby sources only during those times when they, by their nature, operate at the
same time as the primary source(s) being modeled. Finally, estimation of nearby source
impacts may take into account the effectiveness of anticipated control measures in the
SIP if they are already enforceable in the SIP.

8.3

OPTIONS FOR BACKGROUND CONCENTRATIONS

PM hot-spot analyses should also include background concentrations from other

sources as well as any nearby sources that are not included in modeling.111 There are
several options provided below that meet the requirements of Section 93.123(c)(1) of the
conformity rule that involve using representative air quality monitoring data. Whatever
option is selected, the same background concentrations would be used at every receptor
111

Section 8.2.3 of Appendix W defines contributions from other sources as that portion of the
background attributable to all other sources (e.g., natural sources, minor sources and distant major
sources).

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used in the build and no-build scenarios for a PM hot-spot analysis. Additional options
for background concentrations can be considered by the EPA Regional Office, OTAQ,
and OAQPS. See Section 1.7 for contact information.
8.3.1

Using ambient monitoring data to estimate background concentrations

Ambient monitoring data for PM10 and PM2.5 provide an important source of information
to characterize the contributions from sources that affect the background concentrations
in the project area, but are not captured by air quality modeling for the PM hot-spot
analysis. Nonattainment and maintenance areas, and areas that surround them, have
numerous sites for monitoring PM2.5 and PM10 concentrations that may be appropriate for
estimating background concentrations.112 Project sponsors, relevant state or local air
agencies, and the EPA Regional Office should identify the appropriate PM10 and PM2.5
monitoring data, along with information on each monitors site location, purpose,
geographic scale, nearby land uses, and sampling frequency. EPA offers Air Explorer
(based on Google Earth mapping software) as a user-friendly way to identify and
visualize where monitoring sites are in operation and to obtain concentration data and
descriptions of the site (such as the reported scale of spatial representation).113
The evaluation and selection of monitoring data for use in a particular analysis must
follow the process defined in each areas interagency consultation procedures. These
discussions, as well as any maps or statistical techniques used to analyze background
data, should be well-documented and included in the project-level conformity
determination.
Project sponsors should not use monitoring data for which EPA has granted data
exclusion under the Exceptional Events rule (see 40 CFR 50.14).
Using a Single Monitor
Background concentration data should be as representative as possible for the project area
examined by the PM hot-spot analysis.114 In most cases, the simplest approach will be to
use data from the monitor closest to and upwind of the project area. However, all of the
following factors need to be evaluated when considering monitors for use of their data as
representative background concentrations:

112

Monitors in adjacent nonattainment, maintenance, and attainment areas should also be evaluated for use
in establishing background concentrations, which may be appropriate if the air quality situation at those
monitors can be determined to be reasonably similar to the situation in the project area.
113
Available online at: www.epa.gov/airexplorer/monitor_kml.htm.
114
In particular, there should be interagency consultation prior to using any ambient monitoring data set for
PM2.5 that does not meet EPA requirements in Appendix N to 40 CFR Part 50 regarding data completeness,
and any data set that reflects a sampling schedule that has been erratic or has resulted in more frequent
samples in some seasons of a year than others. The guidance in Section 9 of this document assumes that
the normal data completeness requirement (75% of scheduled samples in each calendar quarter of each
year) has been met and that the monitoring data is evenly distributed across the year. Deviation from these
conditions may make the steps given in Section 9 inappropriate.

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 Similar characteristics between the monitor location and project area: Monitors at
locations that are similar to the project area should be preferred for this factor,
whenever possible. If several monitors are available, preference should be given to
the monitor with the most similar characteristics as the project area. Some questions
to be considered include:
o Is the density and mix of emission sources around the monitor location
similar to those around the project site?
o How well does the monitor capture the influence of nearby sources that
are not affected by the project?
o Are there differences in land use or terrain between the two locations that
could influence air quality in different ways?
o Is the monitor probe located at a similar height as the project (e.g., is the
project at grade, but the monitor is on top of a high building)?
o What is the purpose of the monitor and what geographic scale of
representation does the monitor have?
Distance of monitor from the project area: Monitors closer to the project may have
concentrations most similar to the project area. If more than one such monitor is
available, preference may be given to the closest representative monitor for this
factor. There are some cases, however, where consideration of distance alone may
mask the influence of other factors that need to also be considered (e.g., a monitor
upwind of the project location may be preferred to an even closer monitor located
downwind of the project).
Wind patterns between the monitor and the project area: Monitors that are located in
directions that are frequently upwind of a project are more likely to represent a
project areas background concentrations than monitors that are frequently
downwind.115 Preference should be given to upwind monitors for this factor,
whenever appropriate.
The factors considered when selecting a particular monitor to represent background
concentrations should be documented as part of the PM hot-spot analysis.
Interpolating Between Several Monitors
If, during interagency consultation, agencies conclude that no single ambient monitor is
sufficiently representative of the project area, interpolating the data of several monitors
surrounding the project area is also an option. The advantage of interpolation is that no
single monitor is used exclusively in representing air quality for a project area. There
may be projects sited in locations between large emission sources and areas several miles
away with relatively low emissions, suggesting a gradient in concentrations across the
nonattainment or maintenance area. If there are no monitors within or near the project
115

Constructing a wind rose (a graph that depicts the frequency of wind blowing from different
directions) can be a useful tool in examining the frequency of wind blowing from different directions.
EPAs SCRAM website contains two programs for calculating wind statistics and wind roses, WINDROSE
and WRPLOT.

120

area, then background concentrations from other sources may be difficult to estimate.
Interpolation is an approach that allows estimates of background concentrations for a
project to take advantage of monitoring data from multiple monitoring sites. Any
planned interpolation methods must be addressed through the interagency consultation
process.
There are several approaches to interpolation that can be used. One simple method is
weighted averaging, which places greater weight on nearby monitors and uses the inverse
distance between the project site and the monitor to weight each monitor. For example,
suppose monitors A, B, and C surround an unmonitored location, at distances 5, 10, and
15 miles from the site, respectively, the weighting of data from monitor A:

Weight ( A)

1 1 1 1
0.55
5 5 10 15

The weighting for monitor B:

Weight (B)

1 1 1 1
0.27
10 5 10 15

The weighting for monitor C:

Weight(C)

1 1 1 1
0.18
15 5 10 15

If concentrations at A, B, and C are 10.0, 20.0, and 30.0 g/m3, respectively, then the
predicted concentration at the unmonitored site is 16.3 g/m3. In most situations, the
inverse-distance weighted average will provide a reasonable approximation of
background concentrations due to other sources. Another interpolation approach is the
inverse-squared distance weighting that weights monitors based on how close they are to
the project (1/distance squared).
Other, more advanced statistical methods to interpolate monitoring data may also be
used, but these require significant geostatistical expertise.116

116

EPAs MATS (www.epa.gov/ttn/scram/modelingapps_mats.htm) and BenMAP

(www.epa.gov/air/benmap) models incorporate another interpolation-based approach (Voronoi Neighbor
Averaging). Consult those models documentation for further information.

121

8.3.2 Adjusting air quality monitoring data to account for future changes in air quality:
using chemical transport models
Options Using Chemical Transport Models (CTMs)
To account for future emission changes, it may be appropriate in some cases to use future
background concentrations that have been calculated based on modeled outputs from a
CTM. CTMs are photochemistry models that are routinely used in regulatory analyses,
including attainment demonstrations for PM SIPs and EPA regulatory analyses to support
national or regional final rules. 117 In these types of analyses, CTM modeling is
completed for a base and future year, and then these resulting PM concentrations are used
to develop relative response factors (RRFs). These factors are then used to adjust the air
quality monitoring data from the base year of the SIP or EPA final rule modeling. The
end result will be predicted PM concentrations for monitoring locations for a future year
(e.g., the attainment year addressed in the SIP).
Although project sponsors are not expected to operate CTMs, there may be available
information from CTM modeling to support PM hot-spot analyses. There are two CTMbased options that may be available for PM hot-spot analyses:
1. Use existing pre-calculated future year PM concentrations from EPA or state or
local air quality agency modeling. If available, the future year concentrations at a
monitor used in the SIP or EPA rulemaking can be used for a PM hot-spot
analysis, if the monitor is representative of the project area. Typically, projected
annual average and/or 24-hour average PM design values for a future year will be
available for monitoring site locations that are part of such modeling
demonstrations.
2. In some cases, site-specific, post-processed concentrations may not be readily
available from states or EPA. Depending on the nature of the modeling, it may be
possible to obtain CTM outputs that can be used to derive background
concentrations.118 This may be an option if the standard post-processed data
includes only a subset of monitoring sites in the domain or a subset of averaging
times (e.g., annual average results are available, but not 24-hour average results).
Details on the recommended procedures for projecting PM2.5 concentrations using CTMs
are contained in EPAs Guidance on the Use of Models and Other Analyses for
Demonstrating Attainment of Air Quality Goals for Ozone, PM2.5, and Regional

117

Examples of commonly employed CTMs are shown on the SCRAM website at:

www.epa.gov/scram001/photochemicalindex.htm.

118
Many CTM applications are post-processed with EPAs MATS program available at:

www.epa.gov/ttn/scram/modelingapps_mats.htm . MATS produces future year annual and quarterly PM2.5

outputs for both the annual and 24-hour PM2.5 NAAQS. The quarterly concentration information may not

be routinely documented.

122

Haze.119 The location where CTM modeling is completed, the location of the project,
and determining representative monitors are important considerations in using CTMbased options for PM hot-spot analyses. Evaluating and choosing the models and
associated methods and assumptions for using CTM-based options must be determined
through interagency consultation (40 CFR 93.105(c)(1)(i)). The EPA Regional Office
should consult with OTAQ and OAQPS in applying the above options or considering
other options.
Additional Information and Considerations about CTMs
EPAs photochemical modeling guidance recommends using CTM outputs in a relative
sense. Therefore the absolute predictions of a CTM in a future analysis year are not used
to predict future background concentrations directly. Instead, appropriate future year
design values or concentrations are derived from monitoring data that have been adjusted
using the modeled relative change in PM concentrations. RRFs are calculated from the
outputs of current (base) year and future year CTM results. These RRFs reflect the
relative changes in concentrations between current and future years.120 An RRF is
generally calculated as:

RRF

Concentrations in future year, predicted by CTM

Concentrations in base year, predicted by CTM

Future year concentrations are then calculated by multiplying base year monitoring data
by modeled RRFs, as follows:
Base year measured concentration * RRF = Future year concentration
Additionally, when using the CTM-based options, several criteria should be met:
The CTM has demonstrated acceptable performance for the project area using
standard indicators of model performance.121
The results of CTM runs are appropriate for the project and future analysis year(s)
covered by the PM hot-spot analysis (e.g., the CTM modeling includes the project
area and the modeling was completed for the analysis year or a year earlier than
the analysis year).
Any future emission reductions for sources within the CTM modeling
demonstration are based on enforceable commitments in the SIP and/or are
consistent with the conformity rules latest planning assumptions requirements
(40 CFR 93.110).
119

See guidance for further information at: www.epa.gov/scram001/guidance/guide/final-03-pm-rh

guidance.pdf.

120
Future year concentrations of PM2.5 are calculated based on PM2.5 species concentrations that have been

projected using RRFs for individual PM2.5 species.

121
Details on model performance evaluation and examples of model evaluation statistics may be found in

Chapter 18 and Appendix A of the document Guidance on the Use of Models and Other Analyses for

Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5, and Regional Haze, referenced above.

123

EPA or state modeling which includes future emissions reductions from a

proposed rule or hypothetical emissions reductions that are not associated with
enforceable SIP commitments or state or Federal rules should not be used.
Any future emission reductions for sources within the CTM modeling
demonstration should take effect prior to the year(s) for which the PM hot-spot
analysis is conducted.

The PM hot-spot analysis year(s) will often be after a year for which CTM modeling is
performed. In this case, the future background concentration for the analysis year should
be the same year for which CTM modeling was performed. It is not technically justified
to extrapolate background concentrations beyond the year in which data are available for
the CTM modeling. For example, if future background concentrations were estimated
based on CTM modeling for the year 2014, and the PM hot-spot analysis year was 2016,
then the 2014 background estimate could be used for 2016. A project sponsor could not
make a further adjustment based on an extrapolation to the year 2016; such an
extrapolation would not be based on credible modeling or mathematical practices.
Similarly, emissions-based roll-back and roll-forward techniques for adjusting
current air quality monitoring data for future background concentrations are also not
technically supported and would not allow projects sponsors to meet Section 93.123(c)(1)
requirements.
Note that in some cases, CTM adjusted background predictions for a future year may
already incorporate emissions from the projects no-build scenario (e.g., if the monitor
used in the SIP modeling demonstration included emissions from the current project
area). Adding modeled concentrations for the build scenario to this value would be
essentially adding build emissions to the no-build emissions already accounted for in the
background. In these cases, an adjustment may be appropriate only when comparing the
build scenario to the NAAQS. In such cases, to evaluate predicted concentrations in the
build scenario, the difference between modeled concentrations at each receptor in the
build and no-build scenarios should be calculated as:
Difference receptor i Concentration receptor i, build scenario Concentration receptor i, no build scenario

The result the difference between the build and no-build scenarios at each receptor
should be added to background concentrations when calculating design values for the
build scenario. Comparing a build scenario to the no-build scenario to demonstrate
conformity will not involve any similar adjustments, since the same background
concentrations are used in the build and no-build scenarios. Using this approach, only the
changes in receptor concentrations affected by emission changes from the project or
modeled nearby sources used in calculating design values. Evaluating and choosing the
models and associated methods and assumptions for using these adjustments must be
determined through interagency consultation (40 CFR 93.105(c)(1)(i)).

124

8.3.3 Adjusting air quality monitoring data to account for future changes in air quality:
using an on-road mobile source adjustment factor
There may be limited cases in PM10 nonattainment or maintenance areas where it would
be appropriate to adjust representative air quality monitoring data by the factor described
in Section 93.123(c)(2) of the conformity rule. This provision states that the future
background concentration should be estimated by multiplying current background by the
ratio of future to current traffic and the ratio of future to current emission factors. This
method has been a credible option for CO hot-spot analyses. Since CO air quality
problems are primarily due to on-road CO emissions, such a ratio is appropriate for CO
hot-spot analyses.
EPA has determined that this method may also be a credible option when on-road mobile
sources overwhelm overall PM10 SIP inventories. Such a case could occur in a limited
number of PM10 areas where on-road mobile emissions for directly emitted PM10
represent most of the overall directly emitted PM10 emission inventory (e.g., are 75% or
more of the overall inventory).122 Such cases include smaller PM10 areas where paved
and unpaved road dust are the main source of direct PM10 emissions. EPA notes that this
option would increase background concentrations (as compared to options discussed in
Section 8.3.1), in cases where road dust and VMT are expected to increase in the future.
The EPA Regional Office should be consulted on a case-by-case basis if Section
93.123(c)(2) is considered for a PM10 hot-spot analysis.
However, EPA has determined that the method described in Section 93.123(c)(2) is not
required by the conformity rule and is not a technically viable option for estimating
background concentrations in all PM2.5 hot-spot analyses and most PM10 hot-spot
analyses. PM2.5 and PM10 nonattainment problems are typically more complex and result
from many different types of emission sources, including emissions from on-road, nonroad, stationary, and area sources. It would not be appropriate to adjust PM air quality
monitoring data from all source types based on an on-road mobile source adjustment
factor only, as has been done in CO hot-spot analyses. While the conformity rule
requires CO hot-spot analyses for only the largest and most congested intersections in a
given area (40 CFR 93.123(a)(2)), PM hot-spot analyses are required for more complex
highway and transit projects that can also involve nearby sources (40 CFR 93.123(b)(1)).
For all of the above reasons, using the same ratios in most PM hot-spot analyses would
not allow project sponsors to meet Section 93.123(c)(1) requirements.

122

Precursor emissions inventories should not be considered in such a determination, since precursor
emissions are not considered in hot-spot analyses.

125

Section 9: Calculating PM Design Values and Determining

Conformity
9.1

INTRODUCTION

This section describes how to combine all previous steps of a PM hot-spot analysis into a
design value so that a project sponsor can determine if conformity requirements are met.
For conformity purposes, a design value is a statistic that describes a future air quality
concentration in the project area that can be compared to a particular NAAQS.123 In
general, design values are calculated by combining two pieces of data:
Modeled PM concentrations from the project and nearby sources (Sections 7 and
8); and
Monitored background PM concentrations from other sources (Section 8).
Exhibit 9-1 illustrates the conceptual flow of information described in this section, which
is similar for all PM NAAQS.
Exhibit 9-1. General Process for Calculating Design Values for PM Hot-spot
Analyses

123

Design values based on monitoring data are used to determine the air quality status of a given
nonattainment or maintenance area (40 CFR Part 50). Design values are also used for SIP modeling and
other air quality planning purposes.

126

This section describes how to calculate the specific statistical form of design values for
each PM NAAQS and how to apply design values in build/no-build analyses for
conformity purposes. This section also discusses appropriate receptors for the annual
PM2.5 NAAQS.
This guidance is consistent with how design values are calculated for designations and
other air quality planning purposes for each PM NAAQS. EPA is considering whether
spreadsheet tools can be developed to assist state and local agencies in calculating design
values for PM hot-spot analyses. This guidance is written for current and future PM2.5
and PM10 NAAQS. EPA will re-evaluate the applicability of this guidance as needed, if
different PM NAAQS are promulgated in the future.
The interagency consultation process must be used to determine the models, methods,
and assumptions used for PM hot-spot analyses, including those used in calculating
design values and completing build/no-build analyses (40 CFR 93.105(c)(1)(i)). State
and local air quality agencies and EPA have significant expertise in air quality planning
that may be useful resources for the topics covered by this section. Project sponsors
should document the data and other details used for calculating design values for the
build and no-build scenarios for a project-level conformity determination, as well as how
appropriate receptors were determined in cases involving unique locations as described in
Section 9.4.

9.2

USING DESIGN VALUES IN BUILD/NO-BUILD ANALYSES

Design values are a fundamental component of PM hot-spot analyses, as they are the
values compared to the NAAQS and between build and no-build scenarios. In general, a
hot-spot analysis compares air quality concentrations with the proposed project (the build
scenario) to air quality concentrations without the project (the no-build scenario). The
conformity rule requires that the build scenario not cause or contribute to any new
violations of the NAAQS, increase the frequency or severity of existing violations, or
delay timely attainment as compared to the no-build scenario (40 CFR 93.116(a) and
93.123(c)(1)).
Exhibit 9-2 (following page) illustrates the build/no-build analysis approach suggested in
Section 2.4.

127

Exhibit 9-2. General Pr

Pro
ocess
cess for Using Design Values in Build/No-b
build Analyses

In general, project sponsors

sponso
sponsorrs could begin by determining the design valu
value
valuee for only one
receptor in the build scena
scenario:
scenario:
rio: the receptor with the highest modeled aair
ir quality
concentration, as described
described in Section 9.3. If the design value
value for this receptor
receptor is less
than or equal to the relevan
releva
relevant
nt NAAQS, it can be assumed that conform
conformity
conformit
ityy requirements are
met at all receptors in the pproject
roject area, without further analysis. If this is not the case, the
project sponsor could choo
choose
se to add mitig
mitigation
ation or control measures an
and
d then determine if
the new build scenario concentrations
co
con
ncentrations
centrations at the receptor with the highest m
modeled
odeled
concentrations is less than
than or equal to the relevant NAAQS. If this is nnot
ot the case, the
project sponsor would ca
calc
lculate
ulate the design
design values at all receptors in th
thee build scenario
and also model the no-buil
build
buildd scenario. Design values should then be ca
cal
calculated
lculated for the nono
build scenario at all recep
receptors
recepto
tors
rs with design values that exceeded the NAA
NAAQS
NAAQS in the build
scenario. Conformity requ
requirements
irements are met if the design value for eve
everryy appropriate
receptor in the build scena
scenario
scenario
rio is less than or equal to the same receptor in the no-build
no
124
If not, then th
thee project does not meet conformity require
requirem
requirements
ments
ents without
scenario.

124

This would be the receptor aatt the same geographic location in the build and no-bui
build scenarios.

128

further mitigation or control measures to address air quality concentrations at such

receptors, except in certain cases described below.125
A build/no-build analysis is typically based on design value comparisons done on a
receptor-by-receptor basis. However, there may also be cases where a possible new
violation at one receptor (in the build scenario) is relocated from a different receptor (in
the no-build scenario). It would be necessary to calculate the design values for all
receptors in the build and no-build scenarios to determine whether a new violation is
actually a relocated violation. EPA addressed this issue in the preamble to the
November 24, 1993 transportation conformity rule (58 FR 62213), where a new
violation within the same intersection could be considered a relocated violation. Since
1993, EPA has made this interpretation only in limited cases with CO hot-spot analyses
where there is a clear relationship between such changes (e.g., a reduced CO NAAQS
violation is relocated from one corner of an intersection to another due to traffic-related
changes from an expanded intersection). Any potential relocated violations in PM hotspot analyses should be determined through the process established by each areas
interagency consultation procedures.
When completing air quality modeling for build and no-build scenarios, receptors should
be placed in identical locations so that direct comparisons can be made between design
values calculated at receptors under each scenario. Also, design values are compared to
the relevant NAAQS and between build and no-build scenarios after rounding has been
done, which occurs in the final steps of design value calculations.126 Further details on
rounding conventions for different PM NAAQS are included in Section 9.3 below.
Section 9.4 provides further information on determining appropriate receptors for the
annual PM2.5 NAAQS in cases involving unique locations.

125

Additional mitigation or control measures can be considered at any point in the hot-spot analysis
process. When such measures are considered, additional emissions and air quality modeling would need to
be completed and new design values calculated to ensure that conformity requirements are met.
126
For example, conformity requirements would be met at a receptor if the final build design value is no
greater than the final no-build design value, even if the pre-rounding build design value is greater than the
pre-rounding no-build design value.

129

9.3

CALCULATING DESIGN VALUES AND DETERMINING CONFORMITY FOR

PM HOT-SPOT ANALYSES

9.3.1 General
As noted above, this conformity guidance is generally consistent with how design values
are calculated for air quality monitoring and other EPA regulatory programs.127
Further details are included below about how design values should be calculated at
receptors for build/no-build analyses, and examples of each design value calculation can
be found in Appendix K of this guidance. These details and examples are primarily
narrative in nature. EPA has also provided mathematical formulas of design values in
Appendix K, which may be helpful for certain users.
9.3.2 Annual PM2.5 NAAQS
Design Value
The annual PM2.5 design value is currently defined as the average of three consecutive
years annual averages, each estimated using equally-weighted quarterly averages.128
This NAAQS is met when the three-year average concentration is less than or equal to
the annual PM2.5 NAAQS (currently 15.0 g/m3):
Annual PM2.5 design value = ([Y1] average + [Y2] average + [Y3] average) 3
Where:
[Y1] = Average annual PM2.5 concentration for the first year of air quality
monitoring data
[Y2] = Average annual PM2.5 concentration for the second year of air quality
monitoring data
[Y3] = Average annual PM2.5 concentration for the third year of air quality
monitoring data
The annual PM2.5 NAAQS is rounded to the nearest tenth of a g/m3. For example,
15.049 rounds to 15.0, and 15.050 rounds to 15.1.129 These rounding conventions should
be followed when calculating design values for this NAAQS.
127

EPA notes that design value calculations for PM hot-spot analyses involve using air quality modeling
results based on either one year of site-specific measured meteorological data or five years of off-site
measured meteorological data, rather than three years.
128
The design value for the annual PM2.5 NAAQS is defined for air quality monitoring purposes in 40 CFR
Part 50.13.
129
A sufficient number of decimal places (3-4) should be retained during intermediate calculations for
design values, so that there is no possibility of intermediate rounding or truncation affecting the final result.
Rounding to the tenths place should only occur during final design value calculations, pursuant to
Appendix N to 40 CFR Part 50.

130

Necessary Data
This design value calculation assumes the project sponsor already has the following data
in hand:
Air quality modeling results: Average annual concentrations from the project and
any nearby sources should be calculated from the air quality model output files.130
The methodology for post-processing the air quality model output files will vary
depending on what air quality model is used. Refer to Appendix J for details on
preparing air quality model outputs for use in design value calculations.
Air quality monitoring data: 12 quarters of background concentration
measurements (four quarters for each of three consecutive years). See Section 8
for more details on determining representative monitored background
concentrations that meet all applicable monitoring requirements (such as data
completeness).131
Calculating Design Values and Determining Conformity
Exhibit 9-3 (following page) illustrates how a design value is to be calculated and
conformity determined for the annual PM2.5 NAAQS. This exhibit assumes that the
project sponsor would first compare the receptor with the highest average annual
concentration in the build scenario to the NAAQS to determine conformity. If
conformity is not met at this receptor, design values would be calculated at all receptors
in the build scenario. For any receptors with design values above the NAAQS in the
build scenario, the project sponsor would then model the no-build scenario and calculate
design values to determine if conformity requirements are met.
An example of how to calculate design values for the annual PM2.5 NAAQS using this
procedure is included in Appendix K. The steps below can also be described
mathematically using the formulas found in Equation Set 1 in Appendix K.
The steps shown in Exhibit 9-3 are described below. The initial step is to compare the
build scenario to the NAAQS to see if the project conforms:
Step 1. For each receptor, calculate the average annual concentrations with the air
quality modeling results for each quarter and year of meteorological data used. If
using AERMOD, the model does this step for you and provides the average
annual concentrations as output; proceed to Step 2. If using CAL3QHCR, for
each year of meteorological data, first determine the average concentration in
each quarter. Then, within each year of meteorological data, add the average
concentrations of all four quarters and divide by four to calculate the average
annual modeled concentration for each year of meteorological data. Sum the

130

See Section 7.5.3 for further information on the number of years of meteorological data used in air
quality modeling. For most PM hot-spot analyses, five years of meteorological data will be used.
131
The interagency consultation process should be used when situations require incorporation of any CTM
results into design value calculations.

131

modeled average annual concentrations from each year of meteorological data,

and divide by the number of years of meteorological data used.
Step 2. Identify the receptor with the highest modeled average annual
concentration.
Step 3. For each year of background data, first determine the average monitored
concentration in each quarter. Then, within each year of background data, add the
average concentrations of all four quarters and divide by four to calculate the
average annual background concentration for each year of monitoring data. Next,
add the average annual concentrations from each of the consecutive years of
monitoring data and divide by three. This value is the average annual background
concentration based on monitoring data.132
Exhibit 9-3. Determining Conformity to the Annual PM2.5 NAAQS

132
Each year, EPA calculates quarterly average and annual average concentrations for all PM 2.5 monitoring
sites reporting data to EPAs Air Quality System. The results are posted at:
www.epa.gov/airtrends/values.html. Results are in Excel spreadsheet form, in a worksheet with site
listing in the worksheet name.

132

 Step 4. Add the average annual background concentration (from Step 3) to the
average annual modeled concentration at the highest receptor (from Step 2) to
determine the total average annual background concentration at this receptor.
Step 5. Round to the nearest 0.1 g/m3. This result is the annual PM2.5 design
value at the highest receptor in the build scenario.
The project sponsor should then compare the design value from Step 5 to the annual
PM2.5 NAAQS (currently 15.0 g/m3). If the value is less than or equal to the NAAQS,
the project conforms. If the design value is greater than the NAAQS, the project sponsor
should then continue to Step 6:
Step 6. Repeat the calculations described in Step 1 to determine average annual
concentrations for all receptors in the build scenario.
Step 7. Add the average annual modeled concentrations (from Step 6) to the
average annual background concentrations (from Step 3).133 The result will be the
total average annual concentration at each receptor in the build scenario.
Step 8. Round to the nearest 0.1 g/m3. At each receptor, this value is the annual
PM2.5 design value for the build scenario. Identify all receptors that exceed the
annual PM2.5 NAAQS.
Step 9. From the no-build air quality modeling results, calculate the average
annual concentrations at each receptor identified in Step 8.
Step 10. For the no-build scenario, add the average annual modeled
concentrations for the no-build scenario (from Step 9) to the average annual
background concentrations (from Step 3). The result will be the total average
annual concentration for each receptor identified in Step 8 under the no-build
scenario.
Step 11. Round to the nearest 0.1 g/m3. This result is the annual PM2.5 design
value for each receptor identified in Step 8 under the no-build scenario.
For each receptor with a design value that exceeded the NAAQS in the build scenario,
compare the build design value (Step 8) to the no-build design value (Step 11). For the
project to conform, the build design value must be less than or equal to the no-build
design value at each receptor in the build scenario that exceeded the NAAQS (Step 8). If
this is not the case, it may be necessary to determine if any receptors are at unique
locations and are not appropriate for conformity purposes (see Section 9.4).134
If a build scenario design value is greater than the no-build design value at any
appropriate receptor, the sponsor should then consider additional mitigation and control
measures, and revise the PM hot-spot analysis accordingly. Mitigation and control
133

As discussed in Section 8, the same air quality monitoring concentrations would not be expected to
change between the build and no-build scenarios. As a result, the same background concentrations would
be used for every receptor in the build and no-build scenario.
134
Project sponsors could decide to determine if any receptors are at unique locations for this NAAQS at
Step 8, for any receptors where a NAAQS violation is predicted to occur. Also, in certain cases, project
sponsors can also decide to calculate the design values for all receptors in the build and no-build scenarios
and use the interagency consultation process to determine whether a new violation has been relocated
(see Section 9.2).

133

measures could also be considered at any other point in the analysis before the projectlevel conformity determination is made. Refer to Section 10 for a discussion of potential
measures.
9.3.3

24-hour PM2.5 NAAQS

Design Value
The 24-hour PM2.5 design value is currently defined as the average of three consecutive
years 98th percentile concentrations of 24-hour values for each of those years.135 The
NAAQS is met when that three-year average concentration is less than or equal to the
currently applicable 24-hour PM2.5 NAAQS for a given areas nonattainment designation
(currently 35 g/m3 for nonattainment areas for the 2006 PM2.5 NAAQS and 65 g/m3 for
nonattainment areas for the 1997 PM2.5 NAAQS).136
The design value for comparison to any 24-hour PM2.5 NAAQS is rounded to the nearest
1 g/m3 (decimals 0.5 and greater are rounded up to the nearest whole number; decimals
lower than 0.5 are rounded down to the nearest whole number). For example, 35.499
rounds to 35 g/m3, while 35.500 rounds to 36.137 These rounding conventions should be
followed when calculating design values for this NAAQS.
There are two analysis options, or tiers, that are available to project sponsors to estimate a
24-hour PM2.5 design value.138 Project sponsors can start with either the first or second
tier analysis, since either tier is a viable approach for meeting conformity requirements.
There may be cases where a project sponsor may decide to start with a first tier analysis,
which is a conservative but less intensive approach.139 In other cases, project sponsors
may decide to go directly to a second tier analysis. For example, depending on how the
air quality model was run and its data post-processed, the actions needed to identify the
highest modeled 24-hour concentration by quarter for a second tier analysis may not
involve much additional time or effort, in which case the second tier approach may be
135

The design value for the 24-hour PM2.5 NAAQS is defined for air quality monitoring purposes in 40
CFR Part 50.13.
136
There are only two areas where conformity currently applies for both the 1997 and 2006 24-hour PM 2.5
NAAQS. While both 24-hour NAAQS must be considered in these areas, in practice if the more stringent
2006 24-hour PM2.5 NAAQS is met, then the 1997 24-hour PM2.5 NAAQS is met as well.
137
A sufficient number of decimal places (3-4) should be retained during intermediate calculations for
design values, so that there is no possibility of intermediate rounding or truncation affecting the final result.
Rounding should only occur during final design value calculations, pursuant to Appendix N to 40 CFR Part
50.
138
This approach is consistent with EPAs approach for calculating design values for other EPA regulatory
programs. See the EPA March 23, 2010 memorandum from Stephen D. Page at
www.epa.gov/scram001/Official%20Signed%20Modeling%20Proc%20for%20Demo%20Compli%20w%2
0PM2.5.pdf.
139
While less data intensive and therefore possibly quicker to execute, the first tier approach is considered
more conservative as compared to the second tier analysis. The first tier approach assumes that the
estimated highest predicted concentration attributable to the project and nearby sources will occur in the
future on each of the days from which the three-year average 98 th percentile background concentration is
derived (which may not occur).

134

preferred from that start. Under either tier, the contributions from the project, any nearby
sources, and background concentrations from other sources are combined for a given
analysis year, as described further below.
Examples of how to calculate design values for the 24-hour PM2.5 NAAQS using each
tier are included in Appendix K.
Necessary Data
This design value calculation assumes the project sponsor already has the following data
in hand:
Air quality modeling results: The highest 24-hour average concentration from the
project and any nearby sources should be calculated based on the air quality
model output files, depending on what tier of analysis is used:
o In a first tier analysis, the highest 24-hour values from each year of
meteorological data should be averaged together.
o In a second tier analysis, the highest 24-hour values from each quarter and
year of meteorological data should be averaged together per quarter.
Post-processing the air quality model output files will vary depending on what air
quality model is used in the hot-spot analysis. Refer to Appendix J for a
discussion of air quality model output file formats.
Air quality monitoring data: 12 quarters of background concentration
measurements (four quarters for each of three consecutive years). See Section 8
for more details on determining representative monitored background
concentrations that meet all applicable monitoring requirements (such as data
completeness).140
Calculating Design Values and Determining Conformity Using a First Tier Analysis
The first tier consists of directly adding the highest average modeled 24-hour
concentrations to the average 98th percentile 24-hour background concentrations.
Exhibit 9-4 (following page) illustrates how a design value would be calculated under a
first tier analysis for a given receptor. The steps shown in Exhibit 9-4 are described in
detail below, and are also described mathematically using the formulas found in Equation
Set 2 in Appendix K.

140

The interagency consultation process should be used when situations require incorporation of any CTM
results into design value calculations.

135

Exhibit 9-4. Determining Conformity to the 24-hour PM2.5 NAAQS Using First Tier
Analysis

The initial step in a first tier analysis is to compare the build scenario to the NAAQS to
see if the project conforms:
Step 1. From the air quality modeling results from the build scenario, identify the
receptor with the highest average 24-hour concentration. This is done by first
separating the air quality model output into each year of meteorological data.
Second, for each receptor and year of meteorological data, identify the 24-hour
period (midnight-to-midnight) with the highest average concentration throughout
the entire year. Finally, at each receptor, average the highest 24-hour
concentrations from each year of meteorological data across all years. The
receptor with the highest value is used to calculate the 24-hour PM2.5 design
value.
Step 2. Calculate the average 98th percentile 24-hour background concentration
using the 98th percentile 24-hour concentrations of the three most recent years of
air quality monitoring data. To calculate the 98th percentile background
concentrations for each year of monitoring data, first count the number of 24-hour
background measurements in each year. Next, order the highest eight monitoring
values in each year from highest to lowest and rank each value from 1 (highest) to
8 (eighth highest). Consult Exhibit 9-5 (following page) to determine which of
these eight values is the 98th percentile value. Using the results from the three

136

years of monitoring data, calculate the three-year average of the 98th percentile
concentrations.141
Step 3. Add the highest average 24-hour modeled concentration (Step 1) to the
average 98th percentile 24-hour background concentration (Step 2) and round to
the nearest 1 g/m3. The result is the 24-hour PM2.5 design value at the highest
receptor in the build scenario.
Exhibit 9-5. Ranking of 98th Percentile Background Concentration Values142
Number of
Background
Concentration
Values
1-50
51-100
101-150
151-200
201-250
251-300
301-350
351-366

Rank of Value
Corresponding to
98th Percentile
Concentration
1
2
3
4
5
6
7
8

If the design value calculated in Step 3 is less than or equal to the relevant 24-hour PM2.5
NAAQS, then the project conforms. If it is greater than the 24-hour PM2.5 NAAQS,
conformity is not met, and the project sponsor has two options:
Repeat the first tier analysis for the no-build scenario at all receptors that
exceeded the NAAQS in the build scenario. If the calculated design value for the
build scenario is less than or equal to the design value for the no-build scenario at
all of these receptors, then the project conforms;143 or
Conduct a second tier analysis as described below.

141

Assuming a regular monitoring schedule and a resulting data set that meets the completeness
requirements of 40 CFR Part 50 Appendix N, the result of Step 2 will be the design value for the
monitoring site used to estimate the background concentrations. Each year, EPA calculates the 98th
percentile concentration for each of the most recent three years and the average of the three current annual
values for every PM2.5 monitor, based on the data reported to EPAs Air Quality System. Project sponsors
may use the EPA-calculated design values directly instead of executing Step 2, or may compare their result
from Step 2 to the EPA-calculated design value. These design values appear in the worksheet Site
Listing of the latest PM2.5 design value spreadsheet posted at: www.epa.gov/airtrends/values.html.
142
This exhibit is based on a table in Appendix N to 40 CFR Part 50, and ranks the 98 th percentile of
background concentrations pursuant to the total number of air quality monitoring measurements.
143
In certain cases, project sponsors can also decide to calculate the design values for all receptors in the
build and no-build scenarios and use the interagency consultation process to determine whether a new
violation has been relocated (see Section 9.2).

137

Calculating Design Values and Determining Conformity Using a Second Tier Analysis
The second tier involves a greater degree of analysis, in that the highest modeled
concentrations and the 98th percentile background concentrations are not added together
for each receptor directly, as in a first tier analysis. Unlike a first tier analysis, which
uses the average of the highest modeled 24-hour concentration from each year of
meteorological data, a second tier analysis uses the average of the highest modeled 24
hour concentration within each quarter of each year of meteorological data. In other
words, impacts from the project, nearby sources, and other background concentrations are
calculated on a quarterly basis before determining the 98th percentile concentration
resulting from these inputs.
Exhibit 9-6 (following page) and the following steps provide details for calculating a
design value for the 24-hour PM2.5 NAAQS under a second tier analysis. These steps can
also be described mathematically using the formulas found in Equation Set 3 in Appendix
K.
A project sponsor would initially complete these steps for the build scenario; then, if
necessary, repeat the steps for the no-build scenario. Steps 1 and 2 of a second tier
analysis are completed only once for all receptors, since the same background
concentrations would be used for every receptor in either the build or no-build scenario.
Step 1. Count the number of measurements for each year of monitoring data used
for background concentrations for other sources.
Step 2. For each year of monitoring data used, determine the eight highest 24
hour background concentrations for each quarter modeled. For most hot-spot
analyses for the 24-hour PM2.5 NAAQS, modeling would be completed for all
four quarters of each analysis year. This would therefore result in 32 values
(eight concentrations for four quarters) for each year of monitoring data.144, 145
The remaining steps are completed for calculating the 24-hour PM2.5 design value at each
receptor:
Step 3. At each receptor, identify the highest modeled 24-hour concentration in
each quarter, averaged across each year of meteorological data used for air quality
modeling.
Step 4. At each receptor, add the highest modeled concentration in each quarter
(from Step 3) to each of the eight highest 24-hour background concentrations for
the same quarter for each year of monitoring data (from Step 2). At each
receptor, this step will result in eight 24-hour concentrations in each of four
quarters for a total of 32 values for each year of monitoring data.

144

Section 3.3.4 describes how the number of quarters modeled should be determined. In most PM hotspot analyses for the 24-hour PM2.5 NAAQS, all four quarters of the analysis year will be modeled. There
are limited cases where modeling only one quarter would be appropriate.
145
24-hour PM2.5 concentrations for any monitoring site reported to EPAs Air Quality System can be
obtained by using the data download tools available at: www.epa.gov/airexplorer/monitor_kml.htm.

138

Exhibit 9-6. Determining Conformity to the 24-hour PM2.5 NAAQS Using Second
Tier Analysis

139

 Step 5. For each receptor and year of monitoring data, order the 32 values from
Step 4 from highest to lowest and rank each value from 1 (highest concentration)
to 32 (lowest concentration).
Step 6. Based on the number of background concentration values you have (from
Step 1), use Exhibit 9-7 to determine which value in the column (from Step 5)
represents the 98th percentile concentration for each receptor. For example, if you
have 180 background concentration values in a year, Exhibit 9-7 shows that the
4th highest value would represent the 98th percentile. Take the value at each
receptor that has this rank.
Exhibit 9-7. Ranking of 98th Percentile Background Concentration Values146
Number of
Background
Concentration
Values
1-50
51-100
101-150
151-200
201-250
251-300
301-350
351-366

Rank of Value
Corresponding to
98th Percentile
Concentration
1
2
3
4
5
6
7
8

Step 7. Repeat Step 6 for each of the three years of background monitoring data.
The result will be three 24-hour 98th percentile concentrations at each receptor,
one for each year of monitoring data.
Step 8. At each receptor, calculate the average of the three 24-hour 98th percentile
concentrations determined in Step 7.
Step 9. Round the average concentrations from Step 8 to the nearest 1 g/m3. At
each receptor, this value is the 24-hour PM2.5 design value for the build scenario.
Compare the design values to the relevant 24-hour PM2.5 NAAQS. If the design values at
all receptors are less than or equal to the NAAQS, then the project conforms. If this is
not the case, proceed to Step 10:
Step 10. Using modeling results for the no-build scenario, repeat Steps 3 through
9 for all receptors with a design value that exceeded the PM2.5 NAAQS in the
build scenario. The result will be a 24-hour PM2.5 design value at such receptors
for the no-build scenario.

146

This exhibit is based on a table in Appendix N to 40 CFR Part 50, and ranks the 98 th percentile of
background concentrations pursuant to the number of air quality monitoring measurements.

140

Compare the build design values (from Step 9) to the no-build design values (from Step
10), identifying which value is higher at each receptor. For the project to conform, the
build design values must be less than or equal to the no-build design value for all of the
receptors that exceeded the NAAQS in the build scenario.147
If the build scenario design value is greater than the no-build design value at any
appropriate receptor, the project sponsor should then consider additional mitigation and
control measures, and revise the PM hot-spot analysis accordingly. Mitigation and
control measures could also be considered at any other point in the analysis before the
project-level conformity determination is made. Refer to Section 10 for a discussion of
potential measures.
9.3.4

24-hour PM10 NAAQS

Design Value
Compliance with the 24-hour PM10 NAAQS is based on the expected number of 24-hour
exceedances of a particular level (currently 150 g/m3), averaged over three consecutive
years.148 Currently, the NAAQS is met when the expected number of exceedances is less
than or equal to 1.0.149
The 24-hour PM10 NAAQS design value is rounded to the nearest 10 g/m3. For
example, 155.511 rounds to 160, and 154.999 rounds to 150.150 These rounding
conventions should be followed when calculating design values for this NAAQS.
The contributions from the project, any nearby sources, and background concentrations
from other sources are combined for a given analysis year, as described further below.
Examples of how to calculate design values for the 24-hour PM10 NAAQS are included in
Appendix K.

147

In certain cases, project sponsors can also decide to calculate the design values for all receptors in the
build and no-build scenarios and use the interagency consultation process to determine whether a new
violation has been relocated (see Section 9.2).
148
The 24-hour PM10 NAAQS and supporting technical documentation can be found in 40 CFR Part 50.6.
149
The term expected means that the actual number of observed exceedances is adjusted upwards when
observations are missing for some days, to reflect the air quality statistically expected for those days. The
design value for the 24-hour PM10 NAAQS is the next highest observed (monitored or modeled)
concentration after the concentrations that could be above 150 g/m3 without causing the expected number
of exceedances to be greater than 1.0.
150
A sufficient number of decimal places (3-4) in modeling results should be retained during intermediate
calculations for design values, so that there is no possibility of intermediate rounding or truncation
affecting the final result. Rounding to the nearest 10 ug/m3 should only occur during final design value
calculations, pursuant to Appendix K to 40 CFR Part 50. Monitoring values typically are reported with
only one decimal place.

141

Necessary Data
This design value calculation assumes the project sponsor already has the following data
in hand:
Air quality modeling results: In most PM hot-spot analyses, five years of
meteorological data will be used to complete air quality modeling for the project
and any nearby sources.151 In this case, the sixth-highest 24-hour modeled
concentration should be calculated for each receptor.152 Note that AERMOD can
be configured to give you these values directly. CAL3QHCR output needs to be
post-processed to obtain the sixth-highest value from five years of meteorological
data. See more details below and refer to Appendix J for a discussion of air
quality model output file formats.
Air quality monitoring data: 12 quarters of background concentration
measurements (four quarters for each of three consecutive years). See Section 8
for more details on determining representative monitored background
concentrations that meet all applicable monitoring requirements (such as data
completeness).153
Calculating Design Values and Determining Conformity
The 24-hour PM10 design value is calculated at each receptor by directly adding the sixthhighest modeled 24-hour concentrations (if using five years of meteorological data) to the
highest 24-hour background concentration (from three years of monitoring data).
Exhibit 9-8 (following page) illustrates how a design value would be calculated. The
steps shown in Exhibit 9-8 are described in detail below and are also described
mathematically using the formulas found in Equation Set 4 in Appendix K.
The initial step is to compare the build scenario to the NAAQS to see if the project
conforms:
Step 1. From the air quality modeling results for the build scenario, identify the
sixth-highest 24-hour concentration for each receptor (across five years of
meteorological data, in most cases). When using AERMOD, the model can be
configured to produce these values.154 When using CAL3QHCR, output needs to
be post-processed to obtain the sixth-highest values from five years of
meteorological data.
Step 2. Identify the receptor with the highest sixth-highest 24-hour concentration.
That is, compare the sixth-highest modeled concentrations (i.e., the concentrations
151

Section 7.5.3 of this guidance provides further information on the number of years of meteorological
data used in air quality modeling.
152
See description in Section 7.2.1.1 of Appendix W. Users with one year of site-specific meteorological
data should select the 2nd highest 24-hour PM10 concentration. If using less than one year of meteorological
data (such as one quarter), users should select the highest 24-hour concentration.
153
The interagency consultation process should be used when situations require incorporation of any CTM
results into design value calculations.
154
For example, users could employ the RECTABLE keyword in the AERMOD output pathway. See
Appendix J to this guidance for further information.

142

at Rank 6) across receptors and identify the receptor with the highest value at
Rank 6.
Step 3. Identify the highest 24-hour background concentration from the three
most recent years of air quality monitoring data.155
Step 4. For the receptor identified in Step 2, add the sixth-highest 24-hour
modeled concentration to the highest 24-hour background concentration (from
Step 3).
Step 5. Round to the nearest 10 g/m3. The result is the highest 24-hour PM10
design value in the build scenario.
Exhibit 9-8. Determining Conformity to the 24-hour PM10 NAAQS

155

24-hour PM10 concentrations for any monitoring site reported to EPAs Air Quality System can be
obtained by using the data download tools available at: www.epa.gov/airexplorer/monitor_kml.htm.

143

The project sponsor should then compare the design value from Step 5 to the 24-hour
PM10 NAAQS (currently 150 g/m3). If the design value calculated in Step 5 is less than
or equal to the NAAQS, the project conforms. If the design value is greater than the
NAAQS, the project sponsor should then continue to Step 6:
Step 6. For each receptor in the build scenario, add the sixth-highest 24-hour
modeled concentration (from Step 1) to the highest 24-hour background
concentration from the three most recent years of air quality monitoring data
(from Step 3).
Step 7. Round to the nearest 10 g/m3. At each receptor, this value is the 24
hour PM10 design value for the build scenario. Identify all receptors that exceed
the 24-hour PM10 NAAQS.
Step 8. From the no-build air quality modeling results, identify the sixth-highest
24-hour concentration for each receptor identified in Step 7.
Step 9. Add the sixth-highest 24-hour modeled concentration in the no-build
scenario (from Step 8) to the highest 24-hour background concentration from the
three most recent years of air quality monitoring data (from Step 3).
Step 10. Round to the nearest 10 g/m3. The result is the 24-hour PM10 design
value under the no-build scenario for each receptor identified in Step 7.
For each receptor with a design value that exceeded the NAAQS in the build scenario,
compare the build design value (from Step 7) to the no-build design value (from Step 10).
For the project to conform, the build design value must be less than or equal to the nobuild design value at each receptor in the build scenario that exceeded the NAAQS (Step
7).156
If the build scenario design value is greater than the no-build design value at any
appropriate receptor, the project sponsor should then consider additional mitigation and
control measures, and revise the PM hot-spot analysis accordingly. Mitigation and
control measures could also be considered at any other point in the analysis before the
project-level conformity determination is made. Refer to Section 10 for a discussion of
potential measures.
More advanced methods of calculating a PM10 design value, such as combining modeled
and monitored concentrations on a quarterly basis, may be considered on a case-by-case
basis by the EPA Regional Office, OTAQ, and OAQPS. Any alternative methods for
calculating PM10 design values must be evaluated and chosen through the process
established by each areas interagency consultation procedures (40 CFR 93.105(c)(1)(i)).

156

In certain cases, project sponsors can also decide to calculate the design values for all receptors in the
build and no-build scenarios and use the interagency consultation process to determine whether a new
violation has been relocated (see Section 9.2).

144

9.4

DETERMINING APPROPRIATE RECEPTORS FOR COMPARISON TO THE

ANNUAL PM2.5 NAAQS

Note: Section 9.4 has been revised in accordance with EPAs 2012 PM NAAQS final
rule that was published on January 15, 2013 (78 FR 3264).157
9.4.1 Overview
When hot-spot analyses are done for the annual PM2.5 NAAQS, there is an additional step
that may be necessary in certain cases to determine whether a receptor is appropriate to
compare to this NAAQS. In the March 2006 final rule, EPA stated that PM2.5 hot-spot
analyses would be consistent with how the PM2.5 NAAQS are developed, monitored, and
implemented (71 FR 12471). Receptors cannot be used for PM2.5 hot-spot analyses if
they are at locations that would not be appropriate for air quality monitoring purposes for
the NAAQS. An appropriate receptor location under Section 93.123(c)(1) of the
conformity rule is a location that is suitable for comparison to the relevant NAAQS,
consistent with how the PM NAAQS are established and monitored for air quality
planning purposes.158
As a result of EPAs 2012 PM NAAQS final rule, in the majority of hot-spot analyses for
the annual PM2.5 NAAQS, project sponsors will not need to determine whether air quality
modeling receptor locations are appropriate for conformity purposes, because all
locations will generally be considered appropriate. However, there may be cases in which
the analysis area includes receptors that are not representative of area-wide air quality
because they are at unique locations, pursuant to the PM NAAQS final rule including
Section 58.1, Section 58.30(a) and Section 4.7.1 of Appendix D to 40 CFR Part 58. In
these cases, further consideration may be needed after air quality modeling is completed
to determine whether any of the modeled receptors are not appropriate for comparison to
the annual PM2.5 NAAQS, as discussed further below. If conformity requirements are
met at all receptors, it is unnecessary to determine whether receptors are appropriate for
comparison to the annual PM2.5 NAAQS; in such a case, project sponsors can conclude
that conformity requirements are met at all appropriate receptors.
9.4.2 2012 PM NAAQS final rule and revised conformity guidance
The paragraphs below describe the relevant regulatory provisions and revised guidance
for calculating design values and determining conformity for the annual PM2.5 NAAQS,
through the steps described in Section 9.3.2.

157

EPA committed to review whether there is a need to issue new or revised transportation conformity
guidance in light of this final rule. (78 FR 3264) EPA is fulfilling this commitment through this guidance
revision. The previous version of Section 9.4 was issued in December 2010, EPA-420-B-10-040.
158
See CAA Section 176(c)(1)(B). EPA interprets NAAQS in this provision to mean the specific
NAAQS that has been established through rulemaking.

145

Overview of 2012 PM NAAQS Final Rule

In the 2012 PM NAAQS final rule, EPA revised the form of the annual PM2.5 NAAQS to
protect the public health of populations living near important sources of PM2.5, including
the large populations that live near major roadways. (78 FR 3127)159 This final rule also
included revisions to the PM2.5 monitoring regulations which are covered in more detail
below.
The annual PM2.5 NAAQS is to be monitored at area-wide locations, which is defined
under 40 CFR 58.1:
Area-wide means all monitors sited at neighborhood, urban, and regional
scales, as well as those monitors sited at either micro- or middle-scale that
are representative of many such locations in the same CBSA.160
In order to be consistent with the revised annual PM2.5 NAAQS, an appropriate receptor
for hot-spot analyses for this NAAQS must also represent area-wide air quality.
EPA also added a near-road component to the PM2.5 monitoring network to provide
characterization of concentrations in near-road environments including for comparison to
the NAAQS. (78 FR 3238). In establishing this new requirement, EPA has made a
determination to protect all area-wide locations, including those locations with
populations living near major roads that are representative of many such locations
throughout an area. (78 FR 3240)
In the final rule, EPA also clarified what monitoring sites are eligible for comparison to
the annual PM2.5 NAAQS, and what unique locations may not be appropriate for
comparison to the annual PM2.5 NAAQS. Section 58.30(a) of the monitoring regulations
states:
PM2.5 measurement data from all eligible monitors that are representative
of area-wide air quality are comparable to the annual PM2.5 NAAQS.
Consistent with appendix D to this part, section 4.7.1, when micro- or
middle-scale PM2.5 monitoring sites collectively identify a larger region of
localized high ambient PM2.5 concentrations, such sites would be
considered representative of an area-wide location and, therefore, eligible
for comparison to the annual PM2.5 NAAQS. PM2.5 measurement data
from monitors that are not representative of area-wide air quality but
rather of relatively unique micro-scale, or localized hotspot, or unique
middle-scale impact sites are not eligible for comparison to the annual
PM2.5 NAAQS. PM2.5 measurement data from these monitors are eligible
for comparison to the 24-hour PM2.5 NAAQS. For example, if a micro- or
middle-scale PM2.5 monitoring site is adjacent to a unique dominating
159

See 78 FR 3124-7 for more on the form of the annual PM2.5 NAAQS.

This requirement does not have to be satisfied for monitoring the 24-hour PM2.5 NAAQS or the 24-hour

PM10 NAAQS.

160

146

local PM2.5 source, then the PM2.5 measurement data from such a site
would only be eligible for comparison to the 24-hour PM2.5 NAAQS. 161
EPA finalized generally what was proposed for Section 58.30(a), recognizing that there
are cases where near-road environments can be considered a unique location...Examples
of such locations that are considered unique and should therefore not be considered
applicable to the annual PM2.5 NAAQS are explained later in section VIII.B.3.b.i. (78
FR 3237) In this part of the preamble, EPA stated:
We do recognize, however, the possibility that some near-road
monitoring stations may be representative of relatively unique locations
versus the more representative area-wide situation mentioned above. This
could occur because an air agency made a siting decision based on NO2
criteria that resulted in the characterization of a microscale environment
that is not considered area-wide for PM2.5; for example, due to proximity
to a unique source like a tunnel entrance, nearby major point source, or
other relatively unique microscale hot spot. In these types of scenarios, air
agencies would identify the site as a unique monitor comparable only to
the 24-hour PM2.5 NAAQS per the language in section 58.30. (78 FR
3241)
See 78 FR 3234-41 of the preamble to the PM NAAQS final rule for further information
on the above revisions to the PM2.5 monitoring regulations.
Revised Conformity Guidance
Section 9.3.2 includes an approach for conducting build/no-build analyses for the annual
PM2.5 NAAQS, in which the appropriateness of receptors is determined only in cases
where a design value in the build scenario is higher than the NAAQS and the design
value in the no-build scenario. As noted above, if conformity requirements are met at all
receptors, it is unnecessary to determine whether receptors are not appropriate for
comparison to the annual PM2.5 NAAQS; in such a case, project sponsors can conclude
that conformity requirements are met at all appropriate receptors. Also as noted above,
the majority of hot-spot analyses for the annual PM2.5 NAAQS will meet Section
93.123(c)(1) of the conformity rule without specifically determining whether air quality
modeling receptor locations are appropriate for conformity purposes, because all
locations will generally be considered appropriate under the revised annual PM2.5
NAAQS and monitoring regulations. However, for those cases involving unique
locations e.g., a tunnel entrance, a nearby major point source, or other relatively unique
microscale hot-spot further consideration for appropriate receptors would be needed
after air quality modeling is completed for the annual PM2.5 NAAQS.162
161

See Section 4.7.1(b) and Section 4.7.1(c) of Appendix D to 40 CFR Part 58 for further background on

middle and microscale locations.

162
As discussed in Section 7.6, receptors can be placed prior to air quality modeling for all PM NAAQS.

Furthermore, the appropriateness of receptor locations for the 24-hour PM2.5 NAAQS (and 24-hour PM10

NAAQS) can be determined prior to air quality modeling.

147

Consistent with 40 CFR 58.30(a) of the PM2.5 monitoring regulations, the air quality
modeling results for the PM hot-spot analysis will provide critical information for
determining whether there is a large region of high PM2.5 concentrations, especially if
high concentrations are predicted in a large number of adjacent receptors. In order to
determine if a larger region of localized high ambient PM2.5 concentrations is present in
a given PM hot-spot analysis, it is critical to know which receptors have concentrations
above the NAAQS. If a significant number of similar adjacent receptors have high
concentrations representing a large portion of the project area, such receptors may
represent area-wide air quality, and not represent unique locations. Such an assessment
cannot be done qualitatively prior to air quality modeling.
Evaluating and choosing the models and associated methods and assumptions, including
appropriate receptor locations for the annual PM2.5 NAAQS, must be completed through
the process established by each areas interagency consultation procedures (40 CFR
93.105(c)(1)(i)). State and local air quality agencies and EPA have significant expertise
in air quality planning and monitoring purposes and may be useful resources in
determining appropriate receptor locations for the annual PM2.5 NAAQS.

9.5

DOCUMENTING CONFORMITY DETERMINATION RESULTS

Once a PM hot-spot analysis is completed, details need to be documented in the

conformity determination. See Section 3.10 for more information on properly
documenting a PM hot-spot analysis, including modeling data, assumptions, and results.

148

Section 10: Mitigation and Control Measures

10.1 INTRODUCTION
This section describes mitigation and control measures that could be considered by
project sponsors to reduce emissions and any predicted new or worsened PM NAAQS
violations. These measures can be applied to the transportation project itself or other PM
sources in the project area. Written commitments for mitigation or control measures
must be obtained from the project sponsor and/or operator, or other emission sources
owner and/or operator, as appropriate, prior to making a project-level conformity
determination (40 CFR 93.123(c)(4) and 93.125(a)). If measures are selected, additional
emissions and air quality modeling will need to be completed and new design values
calculated to ensure that conformity requirements are met.
The following information provides more details on potential measures for PM hot-spot
analyses; others may be possible. Evaluating and choosing any models and associated
methods and assumptions for any measures that are relied upon in the PM hot-spot
analysis must be completed through the process established by each areas interagency
consultation procedures (40 CFR 93.105(c)(1)(i)). The models, methods, and
assumptions used to quantify reductions should be documented in the final project-level
conformity determination.
General categories of mitigation and control measures that could be considered include:
Retrofitting, replacing vehicles/engines, and using cleaner fuels;
Reducing idling;
Redesigning the transportation project itself;
Controlling fugitive dust; and
Controlling other sources of emissions.
More information is provided for each of these categories below.

10.2 MITIGATION AND CONTROL MEASURES BY CATEGORY

10.2.1 Retrofitting, replacing vehicles/engines, and using cleaner fuels
The installation of retrofit devices on older, higher emitting vehicles is one way to
reduce emissions. Retrofit devices such as Diesel Particulate Filters (DPFs) or
Diesel Oxidation Catalysts (DOCs) can be installed on diesel truck or bus fleets,
and off-road construction equipment when applicable to lower emissions cost
effectively.163

163

It would be appropriate to replace or retrofit construction equipment in those cases where construction
emissions are included in the analysis (i.e., when construction emissions are not considered temporary).

149

 Replacing older engines with newer, cleaner engines, including engines powered
by compressed natural gas (CNG), liquefied natural gas (LNG), biodiesel, or
electricity is another way to reduce emissions from existing diesel truck or bus
fleets. Many engines can also benefit from being rebuilt, repaired, upgraded to a
more recent standard, and properly maintained. The emission reduction
calculations should take into account whether retired vehicles or engines are
permanently scrapped.
The accelerated retirement or replacement of older heavy-duty diesel vehicles
with cleaner vehicles is another way to reduce emissions. A replacement program
could apply to buses, trucks, or construction equipment.164 In some areas, local
regulations to ban older trucks at specific port facilities have encouraged early
replacement of vehicles. Such an option would need to be discussed with the
local government with implementing authority.
o For additional information about quantifying the benefits of retrofitting
and replacing diesel vehicles and engines for conformity determinations,
see EPAs website for the most recent guidance on this topic:
www.epa.gov/otaq/stateresources/transconf/policy.htm.
o Also see EPAs National Clean Diesel Campaign website, which includes
information about retrofitting vehicles, including lists of EPA-verified
retrofit technologies and certified technologies; clean fuels; grants; case
studies; toolkits; and partnership programs: www.epa.gov/otaq/diesel/.
10.2.2 Reduced idling programs
Anti-idling programs for diesel trucks or buses may be relevant for projects where
significant numbers of diesel vehicles are congregating for extended periods of
time (e.g., restrictions on long duration truck idling, truck stop electrification, or
time limits on bus idling at a terminal).
o For additional information about quantifying the benefits of anti-idling
programs for conformity determinations, see EPAs website for the most
recent guidance on this topic:
www.epa.gov/otaq/stateresources/transconf/policy.htm.
o A list of EPA-verified anti-idle technologies for trucks can be found at:
www.epa.gov/otaq/smartway/transport/what-smartway/verified
technologies.htm.
164

The Federal Transit Administration (FTA) has minimum service life requirements for transit vehicles
purchased with FTA funds. If a transit agency disposes of a vehicle earlier than its full useful service life,
it will incur a payback penalty. Please refer to Chapter IV of FTA Circular 5010.1D for the establishment
and calculation of a vehicle's useful service life. In addition, Appendix D of the circular address the useful
life calculation and disposition of vehicles acquired with FTA funds:
www.fta.dot.gov/documents/C_5010_1D_Finalpub.pdf.

150

10.2.3 Transportation project design revisions

For transit and other terminals, project sponsors could consider redesigning the
project to reduce the number of diesel vehicles congregating at any one location.
Terminal operators can also take steps to improve gate operations to reduce
vehicle idling inside and outside the facility. Fewer diesel vehicles congregating
could reduce localized PM2.5 or PM10 emissions for transit and other terminal
projects.
o A list of strategies to reduce emissions from trucks operating at marine
and rail terminals are available at:
www.epa.gov/otaq/smartway/transport/partner-resources/resources
publications.htm.
It may be possible in some cases to route existing or projected traffic away from
populated areas to an industrial setting (e.g., truck only lanes). Project sponsors
should take into account any changes in travel activity, including additional VMT,
that would result from rerouting this traffic. Note that this option may also
change the air quality modeling receptors that are examined in the PM hot-spot
analysis.
Finally, project sponsors could consider additional modes for travel and goods
movement. An example would be transporting freight by cleaner rail instead of
by highway (e.g., putting port freight on electric trains instead of transporting it
by truck).
10.2.4 Fugitive dust control programs
Fugitive dust control programs will primarily be applicable in PM10 hot-spot analyses,
since all PM10 nonattainment and maintenance areas must include these emissions in such
analyses. However, there may be PM2.5 nonattainment and maintenance areas that also
could take advantage of these measures if re-entrained road dust or construction dust is
required for a PM2.5 hot-spot analysis. See Section 2.5 for further background.
A project sponsor could commit to cover any open trucks used in construction of
the project if construction emissions are included in an analysis year. Some states
have laws requiring that open truck containers be covered to reduce dispersion of
material. Laws may differ in terms of requirements, e.g., some require covering
at all times, some require covering in limited circumstances, and some restrict
spillage.
A project sponsor could employ or obtain a commitment from another local
agency to implement a street cleaning program. There is a variety of equipment
available for this purpose and such programs could include vacuuming or flushing
techniques. There have been circumstances where municipalities have
implemented street sweeping programs for air quality purposes.
151

 Another option to reduce dust could be a site-watering program, which may be

relevant during the construction phase of a project, if construction emissions are
included in the PM hot-spot analysis.
Project sponsors may consider street and shoulder paving and runoff and erosion
control in the project area, which can reduce significant quantities of dust.
It may also be possible to reduce the use of sand in snow and ice control
programs, to apply additional chemical treatments, or to use harder material (that
is less likely to grind into finer particles).
10.2.5 Addressing other source emissions
Note: Controlling emissions from other sources may sufficiently reduce background
concentrations in the PM hot-spot analysis.
Reducing emissions from school buses may be relevant where such emissions are
part of background concentrations. Information about retrofitting, replacing, and
reducing idling of school buses can be found on EPAs website at:
www.epa.gov/otaq/schoolbus/index.htm.
Reducing emissions from ships, cargo handling equipment and other vehicles at
ports may change the result of the PM hot-spot analysis. Options such as
retrofitting, repowering, or replacing engines or vehicles, use of cleaner fuels, or
cold ironing (that allows ships to plug in to shore-side power units) could be
relevant where these sources significantly influence background concentrations in
the project area. More information about reducing emissions at ports can be
found on EPAs website at: www.epa.gov/otaq/diesel/ports/index.htm and
www.epa.gov/otaq/smartway/transport/partner-resources/resources
publications.htm.
Adopting locomotive anti-idling policies or other measures. For additional
information, see the following EPA resources:
o Guidance for Quantifying and Using Long Duration Switch Yard
Locomotive Idling Emission Reductions in State Implementation Plans,
EPA420-B-04-09-037 (October 2009) available at:
www.epa.gov/otaq/diesel/documents/420b09037.pdf.
o EPA-verified anti-idle technologies for locomotives can be found at:
www.epa.gov/otaq/smartway/transport/what-smartway/verified
technologies.htm.
Remanufacturing existing locomotives to meet more stringent standards at a rate
faster than the historical average, or using only Tier 3 and/or Tier 4 locomotives
at a proposed terminal (once such locomotives become available).

152

 Reducing emissions from a stationary source might also change the result of the
PM hot-spot analysis. Reductions could come from adding a control technology
to a stationary source or adopting policies to reduce peak emissions at such a
source. EPA and the state and/or local air quality agency could provide input on
the feasibility and implementation of such a measure, as well as any necessary
commitments to such measures from operators.

153

Transportation Conformity Guidance for

Quantitative Hot-Spot Analyses in

PM2.5 and PM10 Nonattainment and

Maintenance Areas

Appendices A-K

Transportation and Climate Division

Office of Transportation and Air Quality
U.S. Environmental Protection Agency

EPA-420-B-13-053
November 2013

APPENDIX A: CLEARINGHOUSE OF WEBSITES, GUIDANCE, AND OTHER TECHNICAL

RESOURCES FOR PM HOT-SPOT ANALYSES ......................................................... A-1

APPENDIX B: EXAMPLES OF PROJECTS OF LOCAL AIR QUALITY CONCERN .........................B-1

APPENDIX C: HOT-SPOT REQUIREMENTS FOR PM10 AREAS WITH PRE-2006 APPROVED

CONFORMITY SIPS .......................................................................................................C-1

APPENDIX D: CHARACTERIZING INTERSECTION PROJECTS FOR MOVES ............................. D-1

APPENDIX E: EXAMPLE QUANTITATIVE PM HOT-SPOT ANALYSIS OF A HIGHWAY

PROJECT USING MOVES AND CAL3QHCR ..............................................................E-1

APPENDIX F: EXAMPLE QUANTITATIVE PM HOT-SPOT ANALYSIS OF A TRANSIT

PROJECT USING MOVES AND AERMOD .................................................................. F-1

APPENDIX G: EXAMPLE OF USING EMFAC2011 FOR A HIGHWAY PROJECT .......................... G-1

APPENDIX H: EXAMPLE OF USING EMFAC2011 TO DEVELOP EMISSION FACTORS FOR A

TRANSIT PROJECT ....................................................................................................... H-1

APPENDIX I: ESTIMATING LOCOMOTIVE EMISSIONS .................................................................. I-1

APPENDIX J: ADDITIONAL REFERENCE INFORMATION ON AIR QUALITY MODELS AND

DATA INPUTS .................................................................................................................J-1

APPENDIX K: EXAMPLES OF DESIGN VALUE CALCULATIONS FOR PM HOT-SPOT

ANALYSES..................................................................................................................... K-1

Appendix A:
Clearinghouse of Websites, Guidance, and Other Technical
Resources for PM Hot-spot Analyses
A.1

INTRODUCTION

This appendix is a centralized compilation of documents and websites referenced in the

guidance, along with additional technical resources that may be of use when completing
quantitative PM hot-spot analyses. Refer to the appropriate sections of the guidance for
complete discussions on how to use these resources in the context of completing a
quantitative PM hot-spot analysis. The references listed are current as of this writing;
readers are reminded the check for the latest versions when using them for a particular
PM hot-spot analysis.

A.2

TRANSPORTATION CONFORMITY AND CONTROL MEASURE GUIDANCE

The EPA hosts an extensive library of transportation conformity guidance online at:
www.epa.gov/otaq/stateresources/transconf/policy.htm (unless otherwise noted). The
following specific guidance documents, in particular, may be useful references when
implementing PM hot-spot analyses:
Policy Guidance on the Use of MOVES2010 for SIP Development and
Transportation Conformity, and Other Purposes, EPA-420-B-09-046 (December
2009). This document describes how and when to use the MOVES2010
emissions model for SIP development, transportation conformity determinations,
and other purposes.
EPA Releases MOVES2010 Mobile Source Emissions Model: Questions and
Answers, EPA-420-F-09-073 (December 2009).
EPA Releases MOVES2010a Mobile Source Emissions Model Update:

Questions and Answers, EPA-420-F-10-050 (August 2010).

Technical Guidance on the Use of MOVES2010 for Emission Inventory Prepara

tion in State Implementation Plans and Transportation Conformity, EPA-420-B
10-023 (December 2009). This document provides guidance on appropriate input
assumptions and sources of data for the use of MOVES2010 in SIP submissions
and regional emissions analyses for transportation conformity purposes.
EPA and FHWA, Transportation Conformity Guidance for Qualitative Hot-spot
Analyses in PM2.5 and PM10 Nonattainment and Maintenance Areas, EPA-420
B-06-902 (March 2006).

A-1

 EPA and FHWA, Guidance for the Use of Latest Planning Assumptions in
Transportation Conformity Determinations, EPA-420-B-08-901 (December
2008).
Guidance for Developing Transportation Conformity State Implementation
Plans, EPA-420-B-09-001 (January 2009).
EPA-verified anti-idle technologies (including technologies that pertain to trucks)
can be found at: www.epa.gov/otaq/smartway/transport/what-smartway/verified
technologies.htm#idle.
For additional information about quantifying the benefits of retrofitting and
replacing diesel vehicles and engines for conformity determinations, see EPAs
website for the most recent guidance on this topic:
www.epa.gov/otaq/stateresources/transconf/policy.htm.
For additional information about quantifying and using long duration truck idling
benefits for conformity determinations, see EPAs website for the most recent
guidance on this topic: www.epa.gov/otaq/stateresources/transconf/policy.htm.
FHWAs transportation conformity site has additional conformity information, including
examples of qualitative PM hot-spot analyses. Available at:
www.fhwa.dot.gov/environment/air_quality/conformity/practices/.

A.3

MOVES MODEL TECHNICAL INFORMATION AND USER GUIDES

MOVES, any future versions of the model, the latest user guides, and technical
information can be found at www.epa.gov/otaq/models/moves/index.htm, including the
following:
User Guide for MOVES2010a. This guide provides detailed instructions for
setting up and running MOVES2010a. Available at
www.epa.gov/otaq/models/moves/index.htm.
Policy documents and Federal Register announcements related to the MOVES model can
be found on the EPAs website at:
www.epa.gov/otaq/stateresources/transconf/policy.htm#models.
Guidance on using the MOVES model at the project level, as well as illustrative
examples of using MOVES for quantitative PM hot-spot analyses, can be found in
Section 4 of the guidance and in Appendices D, E and F.

A-2

A.4 EMFAC2007 MODEL TECHNICAL INFORMATION, USER GUIDES, AND

OTHER GUIDANCE

EMFAC2007, its user guides, and any future versions of the model can be downloaded
from the California Air Resources Board website at:
www.arb.ca.gov/msei/onroad/latest_version.htm.
Policy documents and Federal Register announcements related to the EMFAC model can
be found on the EPAs website at:
www.epa.gov/otaq/stateresources/transconf/policy.htm#models.
Supporting documentation for EMFAC, including the technical memorandum Revision
of Heavy Heavy-Duty Diesel Truck Emission Factors and Speed Correction Factors
cited in Section 5 of this guidance, can be found at
www.arb.ca.gov/msei/supportdocs.htm#onroad.
Instructions on using the EMFAC model at the project level, as well as examples of using
EMFAC for quantitative PM hot-spot analyses, can be found in Section 5 of the guidance
and in Appendices G and H.

A.5 DUST EMISSIONS METHODS AND GUIDANCE

Information on calculating emissions from paved roads, unpaved roads, and construction
activities can be found in AP-42, Chapter 13 (Miscellaneous Sources). AP-42 is EPAs
compilation of data and methods for estimating average emission rates from a variety of
activities and sources from various sectors. Refer to EPAs website to access the latest
versions of AP-42 sections and for more information about AP-42 in general:
www.epa.gov/ttn/chief/ap42/index.html.
Guidance on calculating dust emissions for PM hot-spot analyses can be found in Section
6 of the guidance.

A.6 LOCOMOTIVE EMISSIONS GUIDANCE

The following guidance documents, unless otherwise noted, can be found on or through
the EPAs locomotive emissions website at: www.epa.gov/otaq/locomotives.htm:
Procedure for Emission Inventory Preparation - Volume IV: Mobile Sources,
Chapter 6. Available online at: www.epa.gov/OMS/invntory/r92009.pdf. Note
that the emissions factors listed in Volume IV have been superseded by the April
2009 publication listed below for locomotives certified to meet EPA standards.

A-3

 Emission Factors for Locomotives, EPA-420-F-09-025 (April 2009). Available

online at: www.epa.gov/otaq/regs/nonroad/locomotv/420f08014.htm.
Control of Emissions from Idling Locomotives, EPA-420-F-08-014 (March
2008).
Guidance for Quantifying and Using Long Duration Switch Yard Locomotive
Idling Emission Reductions in State Implementation Plans, EPA-420-B-04-002
(January 2004). Available online at:
www.epa.gov/otaq/smartway/documents/420b04002.pdf.
EPA-verified anti-idle technologies (including technologies that pertain to
locomotives) can be found at: www.epa.gov/otaq/smartway/transport/what
smartway/verified-technologies.htm#idle.
Guidance on calculating locomotive emissions for PM hot-spot analyses can be found in
Section 6 of the guidance and in Appendix I.

A.7 AIR QUALITY DISPERSION MODEL TECHNICAL INFORMATION AND

USER GUIDES

The latest version of Guideline on Air Quality Models (Appendix W to 40 CFR Part
51) (dated 2005 as of this writing) can be found on EPAs SCRAM website at:
www.epa.gov/scram001/guidance_permit.htm.
Both AERMOD and CAL3QHCR models and related documentation can be obtained
through EPAs Support Center for Regulatory Air Models (SCRAM) web site at:
www.epa.gov/scram001. In particular, the following guidance may be useful when
running these models:
AERMOD Implementation Guide
AERMOD User Guide (Users Guide for the AMS/EPA Regulatory Model
AERMOD)
CAL3QHCR User Guide (Users Guide to CAL3QHC Version 2.0: A Modeling
Methodology for Predicting Pollutant Concentrations Near Roadway
Intersections)
MPRM User Guide
AERMET User Guide

A-4

Information on locating and considering air quality monitoring sites can be found in 40
CFR Part 58 (Ambient Air Quality Surveillance), particularly in Appendices D and E to
that part.
Guidance on selecting and using an air quality model for quantitative PM hot-spot
analyses can be found in Sections 7 and 8 of the guidance and in Appendix J. Illustrative
examples of using an air quality model for a PM hot-spot analysis can be found in
Appendices E and F.

A.8

TRANSPORTATION DATA AND MODELING CONSIDERATIONS

The following is a number of technical resources on transportation data and modeling

which may help implementers determine the quality of their inputs and the sensitivity of
various data.
A.8.1 Transportation model improvement
The FHWA Travel Model Improvement Program (TMIP) provides a wide range of
services and tools to help planning agencies improve their travel analysis techniques.
Available online at: http://tmip.fhwa.dot.gov/.
A.8.2 Speed
Evaluating Speed Differences between Passenger Vehicles and Heavy Trucks for
Transportation-Related Emissions Modeling. Available online at:
www.ctre.iastate.edu/reports/truck_speed.pdf.
A.8.3 Project level planning
NCHRP 255: Highway Traffic Data for Urbanized Area Project Planning and Design.
Available online at:
http://tmip.fhwa.dot.gov/sites/tmip.fhwa.dot.gov/files/NCHRP_255.pdf.
A.8.4 Traffic analysis
Traffic Analysis Toolbox website: http://ops.fhwa.dot.gov/trafficanalysistools/.
Traffic Analysis Toolbox Volume I: Traffic Analysis Tools Primer. Federal Highway
Administration, FHWA-HRT-04-038 (June 2004). Available online at:
http://ops.fhwa.dot.gov/trafficanalysistools/tat_vol1/vol1_primer.pdf.
The Highway Capacity Manual Application Guidebook. Transportation Research Board,
Washington, D.C., 2003. Available online at: http://hcmguide.com/.

A-5

The Highway Capacity Manual 2000. Transportation Research Board, Washington,

D.C., 2000. Not available online; purchase information available at:
http://144.171.11.107/Main/Public/Blurbs/Highway_Capacity_Manual_2000_152169.asp
x. As of this writing, the 2000 edition is most current; the most recent version of the
manual, and the associated guidebook, should be consulted when completing PM hotspot analyses.

A-6

Appendix B:

Examples of Projects of Local Air Quality Concern

B.1

INTRODUCTION

This appendix gives additional guidance on what types of projects may be projects of
local air quality concern requiring a quantitative PM hot-spot analysis under 40 CFR
93.123(b)(1). However, as noted elsewhere in this guidance, PM10 nonattainment and
maintenance areas with approved conformity SIPs that include PM10 hot-spot provisions
from previous rulemakings must continue to follow those approved conformity SIP
provisions until the SIP is revised; see Appendix C for more information.

B.2

EXAMPLES OF PROJECTS THAT REQUIRE PM HOT-SPOT ANALYSES

EPA noted in the March 2006 final rule that the examples below are considered to be the
most likely projects that would be covered by 40 CFR 93.123(b)(1) and require a PM2.5
or PM10 hot-spot analysis (71 FR 12491).1
Some examples of projects of local air quality concern that would be covered by 40 CFR
93.123(b)(1)(i) and (ii) are:
A project on a new highway or expressway that serves a significant volume of
diesel truck traffic, such as facilities with greater than 125,000 annual average
daily traffic (AADT) and 8% or more of such AADT is diesel truck traffic;
New exit ramps and other highway facility improvements to connect a highway or
expressway to a major freight, bus, or intermodal terminal;
Expansion of an existing highway or other facility that affects a congested

intersection (operated at Level-of-Service D, E, or F) that has a significant

increase in the number of diesel trucks; and,

Similar highway projects that involve a significant increase in the number of

diesel transit busses and/or diesel trucks.
Some examples of projects of local air quality concern that would be covered by 40 CFR
93.123(b)(1)(iii) and (iv) are:
A major new bus or intermodal terminal that is considered to be a regionally
significant project under 40 CFR 93.1012; and,
1

EPA also clarified 93.123(b)(1)(i) in the January 24, 2008 final rule (73 FR 4435-4436).
40 CFR 93.101 defines a regionally significant project as a transportation project (other than an
exempt project) that is on a facility which serves regional transportation needs (such as access to and from
the area outside of the region, major activity centers in the region, major planned developments such as
new retail malls, sports complexes, etc., or transportation terminals as well as most terminals themselves)
and would normally be included in the modeling of a metropolitan areas transportation network, including
at a minimum all principal arterial highways and all fixed guideway transit facilities that offer an
alternative to regional highway travel.
2

B-1

 An existing bus or intermodal terminal that has a large vehicle fleet where the
number of diesel buses increases by 50% or more, as measured by bus arrivals.
A project of local air quality concern covered under 40 CFR 93.123(b)(1)(v) could be any
of the above listed project examples.

B.3 EXAMPLES OF PROJECTS THAT DO NOT REQUIRE PM HOT-SPOT

ANALYSES

The March 2006 final rule also provided examples of projects that would not be covered
by 40 CFR 93.123(b)(1) and would not require a PM2.5 or PM10 hot-spot analysis (71 FR
12491).
The following are examples of projects that are not a local air quality concern under 40
CFR 93.123(b)(1)(i) and (ii):
Any new or expanded highway project that primarily services gasoline vehicle
traffic (i.e., does not involve a significant number or increase in the number of
diesel vehicles), including such projects involving congested intersections
operating at Level-of-Service D, E, or F;
An intersection channelization project or interchange configuration project that
involves either turn lanes or slots, or lanes or movements that are physically
separated. These kinds of projects improve freeway operations by smoothing
traffic flow and vehicle speeds by improving weave and merge operations, which
would not be expected to create or worsen PM NAAQS violations; and,
Intersection channelization projects, traffic circles or roundabouts, intersection
signalization projects at individual intersections, and interchange reconfiguration
projects that are designed to improve traffic flow and vehicle speeds, and do not
involve any increases in idling. Thus, they would be expected to have a neutral or
positive influence on PM emissions.
Examples of projects that are not a local air quality concern under 40 CFR
93.123(b)(1)(iii) and (iv) would be:
A new or expanded bus terminal that is serviced by non-diesel vehicles (e.g.,
compressed natural gas) or hybrid-electric vehicles; and,
A 50% increase in daily arrivals at a small terminal (e.g., a facility with 10 buses
in the peak hour).

B-2

Appendix C:

Hot-Spot Requirements for PM10 Areas with Pre-2006

Approved Conformity SIPs

C.1

INTRODUCTION

This appendix describes what projects require a quantitative PM10 hot-spot analysis in
those limited cases where a states approved conformity SIP is based on pre-2006
conformity requirements.1 The March 10, 2006 final hot-spot rule defined the current
federal conformity requirements for what projects require a PM hot-spot analysis (i.e.,
only certain highway and transit projects that involve significant levels of diesel vehicle
traffic or any other project identified in the PM SIP as a local air quality concern).2
However, there are some PM10 nonattainment and maintenance areas where PM10 hotspot analyses are required for different types of projects, as described further below.
This appendix will be relevant for only a limited number of PM10 nonattainment and
maintenance areas with pre-2006 approved conformity SIPs. This appendix is not
relevant for any PM2.5 nonattainment or maintenance areas, since the current federal
PM2.5 hot-spot requirements apply in all such areas. Project sponsors can use the
interagency consultation process to verify applicable requirements before beginning a
quantitative PM10 hot-spot analysis.

C.2

PM10 AREAS WHERE THE PRE-2006 HOT-SPOT REQUIREMENTS APPLY

Prior to the March 2006 final rule, the federal conformity rule required some type of hotspot analysis for all non-exempt federally funded or approved projects in PM10
nonattainment and maintenance areas. These pre-2006 requirements are in effect for
those states with an approved conformity SIP that includes the pre-2006 hot-spot
requirements.
In PM10 areas with approved conformity SIPs that include the pre-2006 hot-spot
requirements, a quantitative PM10 hot-spot analysis is required for the following types of
projects:
Projects which are located at sites at which PM10 NAAQS violations have
been verified by monitoring;
Projects which are located at sites which have vehicle and roadway emission
and dispersion characteristics that are essentially identical to those of sites

A conformity SIP includes a states specific criteria and procedures for certain aspects of the

transportation conformity process (40 CFR 51.390).

2
See Section 2.2 and Appendix B of this guidance and the preamble of the March 2006 final rule (71 FR

12491-12493).

C-1

with verified violations (including sites near one at which a violation has been
monitored); and
New or expanded bus and rail terminals and transfer points which increase the
number of diesel vehicles congregating at a single location.

This guidance should be used to complete any quantitative PM10 hot-spot analyses.
In addition, a qualitative PM10 hot-spot analysis is required in the pre-2006 hot-spot
requirements for all other non-exempt federally funded or approved projects. For such
analyses, consult the 2006 EPA-FHWA qualitative hot-spot guidance.3
These pre-2006 hot-spot requirements continue to apply in PM10 areas with approved
conformity SIPs that include them until the state acts to change the conformity SIP. The
conformity rule at 40 CFR 51.390 states that conformity requirements in approved
conformity SIPs remain enforceable until the state submits a revision to its [conformity
SIP] to specifically remove them and that revision is approved by EPA.

C.3

REVISING A CONFORMITY SIP

EPA strongly encourages affected states to revise pre-2006 provisions and take advantage
of the streamlining flexibilities provided by the current Clean Air Act. EPAs January
2008 final conformity rule significantly streamlined the requirements for conformity SIPs
in 40 CFR 51.390. 4 As a result, conformity SIPs are now required to include only three
provisions (consultation procedures and procedures regarding written commitments)
rather than all of the provisions of the federal conformity rule.
EPA recommends that states with pre-2006 PM10 hot-spot requirements in their
conformity SIPs act to revise them to reduce the number of projects where a hot-spot
analysis is required. In affected PM10 areas, the current conformity rules PM10 hot-spot
requirements at 40 CFR 93.123(b)(1) and (2) will be effective only when a state either:
Withdraws the existing provisions from its approved conformity SIP and EPA
approves this SIP revision, or
Revises its approved conformity SIP consistent with the requirements found at 40
CFR 93.123(b) and EPA approves this SIP revision.

Transportation Conformity Guidance for Qualitative Hot-spot Analyses in PM2.5 and PM10

Nonattainment and Maintenance Areas, EPA420-B-06-902, found on EPAs website at:

www.epa.gov/otaq/stateresources/transconf/policy/420b06902.pdf.

4
Transportation Conformity Rule Amendments to Implement Provisions Contained in the 2005 Safe,

Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users (SAFETEA-LU); Final

Rule, 73 FR 4420.

C-2

Affected states should contact their EPA Regional Office to proceed with one of these
two options. For more information about conformity SIPs, see EPAs Guidance for
Developing Transportation Conformity State Implementation Plans (SIPs), EPA-420-B
09-001 (January 2009); available online at:
www.epa.gov/otaq/stateresources/transconf/policy/420b09001.pdf.

C-3

Appendix D:
Characterizing Intersection Projects for MOVES
D.1

INTRODUCTION

This appendix expands upon the discussion in Section 4.2 on how best to characterize
links when modeling an intersection project using MOVES. The MOVES emissions
model allows users to represent intersection traffic activity with a higher degree of
sophistication compared to previous models. This appendix provides several options to
describe vehicle activity to take advantage of the capabilities MOVES offers to complete
more accurate PM hot-spot analyses of intersection projects. MOVES is the approved
emissions model for PM hot-spot analyses in areas outside of California.
Exhibit D-1 is an example of a simple signalized intersection showing the links
developed by a project sponsor to represent the two general categories of vehicle activity
expected to take place at this intersection (approaching the intersection and departing the
intersection).
Exhibit D-1. Example of Approach and Departure Links for a Simple Intersection

D-1

When modeling an intersection, each approach link or departure link can be modeled as
one or more links in MOVES depending on the option chosen to enter traffic activity.
This guidance suggests three possible options for characterizing activity on each
approach and departure link (such as those shown in Exhibit D-1):
Option 1: Using average speeds
Option 2: Using link drive schedules
Option 3: Using Op-Mode distributions
While Option 1 may need to be relied upon more during the initial transition to using
MOVES, as more detailed data are available to describe vehicle activity, users are
encouraged to consider using the Options 2 and 3 to take full advantage of the
capabilities of MOVES.
Once a decision has been made on how to characterize links, users should continue to
develop the remaining MOVES inputs as discussed in Section 4 of the guidance.

D.2

OPTION 1: USING AVERAGE SPEEDS

The first option is for the user to estimate the average speeds for each link in the
intersection based on travel time and distance. Travel time should account for the total
delay attributable to traffic signal operation, including the portion of travel when the light
is green and the portion of travel when the light is red. The effect of a traffic signal cycle
on travel time includes deceleration delay, move-up time in a queue, stopped delay, and
acceleration delay. Using the intersection example given in Exhibit D-1, each approach
link would be modeled as one link to reflect the higher emissions associated with vehicle
idling through lower speeds affected by stopped delay; each departure link would be
modeled as one link to reflect the higher emissions associated with vehicle acceleration
through lower speeds affected by acceleration delay.
Project sponsors can determine congested speeds by using appropriate methods based on
best practices for highway analyses. Some resources are available through FHWAs
Travel Model Improvement Program (TMIP).1 Methodologies for computing
intersection control delay are provided in the Highway Capacity Manual.2 All
assumptions, methods, and data underlying the estimation of average speeds and delay
should be documented as part of the PM hot-spot analysis.

See FHWAs TMIP website: http://tmip.fhwa.dot.gov/.

Users should consult the most recent version of the Highway Capacity Manual. As of the release of this

guidance, the latest version is the Highway Capacity Manual 2000, which can be obtained from the

Transportation Research Board (see http://144.171.11.107/Main/Public/Blurbs/152169.aspx for details).

D-2

D.3

OPTION 2: USING LINK DRIVE SCHEDULES

A more refined approach is to enter vehicle activity into MOVES as a series of link drive
schedules to represent individual segments of cruise, deceleration, idle, and acceleration
of a congested intersection. A link drive schedule defines a speed trajectory to represent
the entire vehicle fleet via second-by-second changes in speed and highway grade.
Unique link drive schedules can be defined to describe types of vehicle activity that have
distinct emission rates, including cruise, deceleration, idle, and acceleration.
Exhibit D-2 illustrates why using this more refined approach can result in a more detailed
emissions analysis. This exhibit shows the simple trajectory of a single vehicle
approaching an intersection during the red signal phase of a traffic light cycle. This
trajectory is characterized by several distinct phases (a steady cruise speed, decelerating
to a stop for the red light, idling during the red signal phase, and accelerating when the
light turns green). In contrast, the trajectory of a single vehicle approaching an
intersection during the green signal phase of a traffic light cycle is characterized by a
more or less steady cruise speed through the intersection.
Exhibit D-2. Example Single Vehicle Speed Trajectory Through a Signalized
Intersection
50
45
40
Green Light

Speed (mph)

35
30
25

Red Light

20
Decelerate

Cruise

Idle

Accelerate

Cruise

15
10
5
0
-100

-80

-60

-40

-20

20

40

60

80

100

Distance (m)

For the example intersection in Exhibit D-1, link drive schedules representing the
different operating modes of vehicle activity on the approach and departure links can be
determined. For approach links, the length of a vehicle queue is dependent on the
number of vehicles subject to stopping at a red signal. Vehicles approaching a red traffic

D-3

signal decelerate over a distance extending from the intersection stop line back to the
stopping distance required for the last vehicle in the queue. The average stopping
distance can be calculated from the average deceleration rate and the average cruise
speed. Similarly, for the departure links, vehicles departing a queue when the light turns
green accelerate over a distance extending from the end of the vehicle queue to the
distance required for the first vehicle to reach the cruise speed, given the rate of
acceleration and cruise speed. Exhibit D-3 provides an illustration of how the different
vehicle operating modes may be apportioned spatially near this signalized intersection.
Exhibit D-3. Example Segments of Vehicle Activity Near a Signalized Intersection

There are other considerations with numerous vehicles stopping and starting at an
intersection over many signal cycles during an hour. For instance, heavy trucks
decelerate and accelerate at slower rates than passenger cars. Drivers tend not to
decelerate at a constant rate, but through a combination of coasting and light and heavy
braking. Acceleration rates are initially higher when starting from a complete stop at an
intersection, becoming progressively lower to make a smooth transition to cruise speed.
In the case of an uncongested intersection, the rates of vehicles approaching and
departing the intersection are in equilibrium. Some vehicles may slow, and then speed up
to join the dissipating queue without having to come to a full stop. Once the queue
clears, approaching vehicles during the remainder of the green phase of the cycle will
cruise through the intersection virtually unimpeded.
In the case of a congested intersection, the rate of vehicles approaching the intersection is
greater than the rate of departure, with the result that no vehicle can travel through
without stopping; vehicles approaching the traffic signal, whether it is red or green, will
have to come to a full stop and idle for one or more cycles before departing the
intersection. The latest Highway Capacity Manual is a good source of information for

D-4

vehicle operation through signalized intersections. All assumptions, methods, and data
underlying the development of link drive schedules should be documented as part of the
PM hot-spot analysis.
The MOVES emission factors for each segment of vehicle activity obtained via
individual link drive schedules are readily transferable to either AERMOD or
CAL3QHCR, as discussed further in Section 7 of the guidance. There will most likely be
a need to divide the cruise and the acceleration segments to account for differences in
approach and departure traffic volumes.
Note: For both free-flow highway and intersection links, users may directly enter output
from traffic simulation models in the form of second-by-second individual vehicle
trajectories. These vehicle trajectories for each road segment can be input into MOVES
using the Link Drive Schedule Importer and defined as unique LinkIDs. There are no
limits in MOVES as to how many links can be defined; however, model run times
increase as the user defines more links. A representative sampling of vehicles can be
used to model higher volume segments by adjusting the resulting sum of emissions to
account for the higher traffic volume. For example, if a sampling of 5,000 vehicles
(5,000 links) was used to represent the driving patterns of 150,000 vehicles, then the sum
of emissions would be adjusted by a factor of 30 to account for the higher traffic volume
(i.e., 150,000 vehicles/5,000 vehicles). Since the vehicle trajectories include idling,
acceleration, deceleration, and cruise, separate roadway links do not have to be
explicitly defined to show changes in driving patterns. The sum of emissions from each
vehicle trajectory (LinkID) represents the total emission contribution of a given road
segment.

D.4

OPTION 3: USING OP-MODE DISTRIBUTIONS

A third option is for a user to generate representative Op-Mode distributions for approach
and departure links by calculating the fraction of fleet travel times spent in each mode of
operation. For any given signalized intersection, vehicles are cruising, decelerating,
idling, and accelerating. Op-Mode distributions can be calculated from the ratios of
individual mode travel times to total travel times on approach links and departure links.
This type of information could be obtained from Op-Mode distribution data from (1)
existing intersections with similar geometric and operational (traffic) characteristics, or
(2) output from traffic simulation models for the proposed project or similar projects.
Acceleration and deceleration assumptions, methods, and data underlying the activity-to
Op-Mode calculations should be documented as part of the PM hot-spot analysis.
The following methodology describes a series of equations to assist in calculating vehicle
travel times on approach and departure links. Note that a single approach and single
departure link should be defined to characterize vehicles approaching, idling at, and
departing an intersection (e.g., there is no need for an idling link, as vehicle idling is
captured as part of the approach link).

D-5

D.4.1 Approach links

When modeling each approach link, the fraction of fleet travel times in seconds (s) in
each mode of operation should be determined based on the fraction of time spent
cruising, decelerating, accelerating, and idling:
Total Fleet Travel Time (s) = Cruise Time + Decel Time + Accel Time +
Idle Time
The cruise travel time can be represented by the number of vehicles cruising multiplied
by the length of approach divided by the average cruise speed:
Cruise Time (s) = Number of Cruising Vehicles * (Length of Approach (mi)
Average Cruise Speed (mi/hr)) * 3600 s/hr
The deceleration travel time can be represented by the number of vehicles decelerating
multiplied by the average cruise speed divided by the average deceleration rate:
Decel Time (s) = Number of Decelerating Vehicles * (Average Cruise Speed
(mi/hr) Average Decel Rate (mi/hr/s))
The acceleration travel time occurring on an approach link can be similarly represented.
However, to avoid double-counting acceleration activity that occurs on the departure link,
users should multiply the acceleration time by the proportion of acceleration that occurs
on the approach link (Accel Length Fraction on Approach):
Accel Time (s) = Number of Accelerating Vehicles * (Average Cruise Speed
(mi/hr) Average Accel Rate (mi/hr/s)) * Accel Length Fraction on
Approach
The idle travel time can be represented by the number of vehicles idling multiplied by the
average stopped delay (average time spent stopped at an intersection):
Idle Time (s) = Number of Idling Vehicles * Average Stopped Delay (s)
Control delay (total delay caused by an intersection) may be used in lieu of average
stopped delay, but control delay includes decelerating and accelerating travel times,
which should be subtracted out (leaving only idle time).
After calculating the fraction of time spent in each mode of approach activity, users
should select the appropriate MOVES Op-Mode corresponding to each particular type of
activity (see Section 4.5.7 for more information). The operating modes in MOVES
typifying approach links include:
Cruise/acceleration (OpModeID 11-16, 22-25, 27-30, 33, 35, 37-40);

Low and moderate speed coasting (OpModeID 11, 21);

Braking (OpModeID 0, 501);

D-6

Idling (OpModeID 1); and

Tire wear (OpModeID 400-416).

The relative fleet travel time fractions can be allocated to the appropriate Op-Modes in
MOVES. The resulting single Op-Mode distribution accounts for relative times spent in
the different driving modes (cruise, deceleration, acceleration, and idle) for the approach
link. A simple example of deriving Op-Mode distributions for a link using this
methodology is demonstrated in Step 3 of Appendix F for a bus terminal facility.
D.4.2 Departure links
When modeling each departure link, the fraction of fleet travel times spent in each mode
of operation should be determined based on the fraction of time spent cruising and
accelerating:
Total Fleet Travel Time (s) = Cruise Time + Accel Time
The cruise travel time can be represented by the number of vehicles cruising multiplied
by the travel distance divided by the average cruise speed:
Cruise Time (s) = Number of Cruising Vehicles * (Length of Departure (mi)
Average Cruise Speed (mi/hr)) * 3600 s/hr
The acceleration travel time occurring during the departure link can be represented by the
number of vehicles accelerating multiplied by the average cruise speed divided by the
average acceleration rate. However, to avoid double-counting acceleration activity that
occurs on the approach link, users should multiply the resulting acceleration time by the
proportion of acceleration that occurs on the departure link (Accel Length Fraction on
Departure):
Accel Time (s) = Number of Accelerating Vehicles * (Average Cruise Speed
(mi/hr) Average Accel Rate (mi/hr/s)) * Accel Length Fraction on
Departure
After calculating fraction of time spent in each mode of departure activity, users should
select the appropriate MOVES Op-Mode corresponding to each particular type of activity
(see Section 4.5.7 for more information). The operating modes typifying departure links
include:
Cruise/acceleration (OpModeID 11-16, 22-25, 27-30, 33, 35, 37-40); and
Tire wear (OpModeID 401-416).
The relative fleet travel time fractions can be allocated to the appropriate Op-Modes. The
resulting single Op-Mode distribution accounts for relative times spent in the different
driving modes (cruise and acceleration) for the departure link.

D-7

Appendix E:
Example Quantitative PM Hot-spot Analysis of a Highway
Project using MOVES and CAL3QHCR
E.1

INTRODUCTION

The purpose of this appendix is to demonstrate the procedures for completing a hot-spot
analysis using MOVES and CAL3QHCR following the basic steps described in Section
3. Readers should reference the appropriate sections in the guidance as needed for more
detail on how to complete each step of the analysis. This example is limited to showing
the build scenario; in practice, project sponsors may also have to analyze the no-build
scenario. While this example calculates emission rates using MOVES, EMFAC users
may find the air quality modeling described in this appendix helpful.
Note: The following example of a quantitative PM hot-spot analysis is highly simplified
and intended only to demonstrate the basic procedures described in the guidance. This
example uses default data in places where the use of project-specific data in a real-world
situation would be expected. In addition, actual PM hot-spot analyses could be
significantly more complex and are likely to require more documentation of data and
decisions. In this example, the interagency consultation process is used as needed for
evaluating and choosing models, methods, and assumptions, according to the
requirements of 40 CFR 93.105(c)(1)(i).

E.2

PROJECT DESCRIPTION AND CONTEXT

The proposed project is the construction of a highway interchange connecting a four-lane

principle arterial with a six-lane freeway through on-and-off ramps (see Exhibit E-1).
The project is being built to allow truck access to local businesses. The project is located
in an area that was designated nonattainment for the 2006 24-hour PM2.5 NAAQS and
1997 annual PM2.5 NAAQS.
The following is some additional pertinent data about the project:
The project is located in a medium-sized city (within one county) in a state other
than California.
The project is expected to take less than a year to complete and has an estimated
completion date of 2013. The year of peak emissions is expected to be 2015,
when considering the projects emissions and background concentrations.
In 2015, the average annual daily traffic (AADT) at this location is expected to
exceed 125,000 vehicles and greater than eight percent of the traffic will be
heavy-duty diesel trucks.
The area surrounding the proposed project is primarily residential, with no nearby
sources that need to be included in air quality modeling.

E-1

 The state does not have an adequate or approved SIP budget for either PM2.5
NAAQS, and neither the EPA nor the state air agency has made a finding that
road dust is a significant contributor to the PM2.5 nonattainment problem.
Exhibit E-1. Simple Diagram of the Proposed Highway Project

E.3

DETERMINE NEED FOR PM HOT-SPOT ANALYSIS (STEP 1)

The proposed project is determined to be of local air quality concern under the
conformity rule because it is a new freeway project with a significant number of diesel
vehicles (see 40 CFR 93.123(b)(1)(i) and Sections 2.2 and Appendix B of the guidance).
Therefore, a quantitative PM hot-spot analysis is required.

E-2

E.4

DETERMINE APPROACH, MODELS, AND DATA (STEP 2)

E.4.1 Determining geographic area and emission sources to be covered by the analysis
First, the interagency consultation process is used to ensure that the project area is
defined so that the analysis includes the entire project, as required by 40 CFR
93.123(c)(2). As previously noted, it is also determined that, in this case, there are no
nearby emission sources to be included in air quality modeling (see Section 3.3.2).
E.4.2 Deciding the general analysis approach and analysis year(s)
Second, the project sponsor determines that the preferred approach in this case is to
model the build scenario first, completing a no-build scenario only if necessary.
In addition, it is determined that the year of peak emissions (within the timeframe of the
current transportation plan) is mostly likely to be 2015. Therefore, 2015 is selected as the
year of the analysis, and the analysis considers traffic data from 2015 (see Section 3.3.3).
E.4.3 Determining the PM NAAQS to be evaluated
Because the area has been designated nonattainment for both the 2006 24-hour PM2.5
NAAQS and 1997 annual PM2.5 NAAQS, the results of the analysis will have to be
compared to both NAAQS (see Section 3.3.4). All four quarters are included in the
analysis in order to estimate a years worth of emissions for both NAAQS.
E.4.4 Deciding on the type of PM emissions to be modeled
Next, the following directly-emitted PM2.5 emissions are determined to be relevant for
estimating the emissions in the analysis (see Section 2.5):
Vehicle exhaust1
Brake wear
Tire wear
E.4.5 Determining the models and methods to be used
Since this project is located outside of California, MOVES is used for emissions
modeling. In addition, it is determined that, since this is a highway project with no
nearby sources that need to be included in the air quality modeling, either AERMOD or
CAL3QHCR could be used for air quality modeling (see Section 3.3.6). In this case,
CAL3QHCR is selected. Making the decision on what air quality model to use at this
stage is important so that the appropriate data are collected, among other reasons (see
next step).

Represented in MOVES as PMtotal running and PMtotal crankcase running.

E-3

E.4.6 Obtaining project-specific data

Finally, the project sponsor compiles the data required to use MOVES, including project
traffic data, vehicle types and age, and temperature and humidity data for the months and
hours to be modeled (specifics on the data collected are described in the following steps).
In addition, information necessary to use CAL3QHCR to model air quality is gathered,
including meteorological data and information on representative air quality monitors.
The sponsor also ensures the latest planning assumptions are used and that data used for
the analysis are consistent with that used in the latest regional emissions analysis, as
required by the conformity rule (see Section 3.3.7).

E.5

ESTIMATE ON-ROAD MOTOR VEHICLE EMISSIONS (STEP 3)

Having completed the analysis preparations described above, the project sponsor then
follows the instructions provided in Section 4 of the guidance to use MOVES to estimate
the projects on-road emissions:
E.5.1 Characterizing the project in terms of links
As described in Section 4.2 of the guidance, links are defined based on the expected
emission rate variability across the project. Generally, a highway project like the one
proposed in this example can be broken into four unique activity modes:
Freeway driving at 55 mph;
Arterial cruise at 45 mph;
Acceleration away from intersections to a cruising speed of 45/55 mph; and
Cruise, deceleration, and idle/cruise (depending on light timing) at intersections.
Following the guidance given in Section 4.2, 20 links are defined for MOVES and
CAL3QHCR modeling, each representing unique geographic and activity parameters (see
Exhibits E-2 and E-3). Each LinkID is defined with the necessary information for air
quality modeling: link length, link width, link volume, as well as link start and end points
(x1, y1, x2, y2 coordinates).
Decisions on how to best define links are based on an analysis of vehicle activity and
patterns within the project area. AADT is calculated from a travel demand model for
passenger cars, passenger trucks, intercity buses, short haul trucks, and long haul trucks.
From these values, both an average-hour and peak-hour volume is calculated. The
average and peak-hour vehicle counts for each part of the project are shown in Exhibit E
3.

E-4

Exhibit E-2. Diagram of Proposed Highway Project Showing Links

Based on the conditions in the project area, for this analysis peak traffic is assumed to be
representative of morning rush hour (AM: 6 a.m. to 9 a.m.) and evening rush hour (PM: 4
p.m. to 7 p.m.), while average hour traffic represents all other hours: midday (MD: 9 a.m.
to 4 p.m.), and overnight (ON: 7 p.m. to 6 a.m.) Identical traffic volume and speed
profiles are assumed for all quarters of the year. Quarters are defined as described in
Section 3.3.4 of the guidance: Q1 (January-March), Q2 (April-June), Q3 (JulySeptember), and Q4 (October-December).

E-5

Exhibit E-3. Peak-Hour and Average-Hour Traffic Counts for Each Project Link
Freeway

Peak Hour Count

Average Hour Count

Fraction of Total

Passenger Cars

2260

452

0.45

Passenger Trucks

1760

352

0.35

Intercity Buses

36

0.01

Short Haul Trucks (gas)

60

12

0.01

944

189

5060

1012

0.19
1.00

Long Haul Trucks (diesel)

Total
Exit Ramps

Peak Hour Count

Average Hour Count

Fraction of Total

Passenger Cars

124

25

0.22

Passenger Trucks

124

25

0.22

0.01

Intercity Buses
Short Haul Trucks (gas)

12

0.02

Long Haul Trucks (diesel)

300

60

Total

568

114

0.53
1.00

Entrance Ramps

Peak Hour Count

Average Hour Count

Fraction of Total

Passenger Cars

176

35

Passenger Trucks

148

30

0.24

0.00

Intercity Buses
Short Haul Trucks (gas)

0.29

16

0.03

Long Haul Trucks (diesel)

276

55

Total

616

123

0.45
1.00

Arterial Road

Peak Hour Count

Average Hour Count

Fraction of Total

Passenger Cars

124

25

0.22

Passenger Trucks

116

23

0.20

12

0.02

0.00
0.56
1.00

Intercity Buses
Short Haul Trucks (gas)
Long Haul Trucks (diesel)

316

63

Total

568

114

A significant amount of traffic using the project is expected to be diesel trucks. While
the freeway contains approximately 19% diesel truck traffic, traffic modeling for the onand off-ramps connecting the freeway to the arterial road suggests approximately half of
vehicles are long-haul diesel trucks.
The average speeds on the freeway, arterial, and on/off-ramps are anticipated to be
identical in the analysis year for both peak and average hours and assumed to
approximately reflect the speed limit (55 mph, 45 mph, and 45 mph, respectively).
Traffic flow through the two intersections north and south of the freeway is controlled by
a signalized light with a 60% idle time for vehicles exiting the freeway and 40% idle time
for traffic entering the freeway from the arterial road or traveling north and south on the

E-6

arterial road passing over the freeway. The total project emissions, therefore, are
determined to be a function of:
Vehicles traveling east and west on the freeway at a relatively constant 55 mph;
Exiting vehicles decelerating to a stop at either the north or south signalized
intersection (or continuing through if the light is green);
Vehicles accelerating away from the signalized intersections north and south, as
well as accelerating to a 55 mph cruise speed on the on-ramps;
Idling activity at both intersections during the red phase of the traffic light; and
Vehicles traveling between the north and south intersections at a constant 45 mph.
As there is no new parking associated with the project (e.g., parking lots), there are no
start emissions to be considered. Additionally, there are no trucks parked or hoteling in
extended idle mode anywhere in the project area, so extended idle emissions do not need
to be calculated.
E.5.2 Deciding how to handle link activity
As discussed in Section 4.2 of the guidance, MOVES offers several options for users to
apply activity information to each LinkID. For illustrative purposes, based on the
available information for the project (in this case, average speed, link average and peak
volume, and red-light idle time) several methods of deriving Op-Mode distributions are
employed in this example, as described below.
The links parameter table in Exhibit E-4 shows the various methods that activity is
entered into MOVES for each link. The column MOVES activity input describes how
the Op-Mode distribution is calculated for each particular link:
Freeway links (links 1 and 4) are defined through a 55 mph average speed input,
from which MOVES calculated an Op-Mode distribution (as described in
Appendix D.2).
Arterial cruise links (links 12 and 18) and links approaching an intersection queue
(links 2, 5, 9 and 15) are defined through a link-drive schedule with a constant
speed of 45 mph; indicating vehicles are cruising at 45 mph, with no acceleration
or deceleration (as described in Appendix D.3).
Links representing vehicles accelerating away from intersections (links 7, 8, 11,
14, 17, 20) are given adjusted average speeds calculated from guidance in the
Highway Capacity Manual 2000, based on the link cruise speed (45 mph or 55
mph), red-light timing, and expected volume to capacity ratios. The adjusted
average speeds (16.6 mph or 30.3 mph) are entered into MOVES, which
calculates an Op-Mode distribution to reflect the lower average speed and
subsequent higher emissions (as described in Appendix D.2).
Queue links (links 3, 6, 10, 13, 16, and 19) are given an Op-Mode distribution that
represents vehicles decelerating and idling (red light) as well as cruising through
(green light) (as described in Appendix D.4).
Step 1. First, an Op-Mode distribution is calculated for the link average speed
(45 mph).

E-7

Step 2. Because this does not adequately account for idling at the intersection,
the Op-Mode fractions are re-allocated to add in idling. For instance, after
consulting the Highway Capacity Manual 2000, for this project scenario the
red light timing corresponds to approximately 40% idle time. A fraction of
0.4 for Op-Mode 1 is therefore added to the Op-Mode distribution
calculated from the 45 mph average speed in Step 1. The resulting Op-Mode
distribution represents all activity on a queuing intersection link.
The length of the queue links are estimated as a function of the length of three trucks, one
car, and one passenger truck with two meters in between each car and five meters in
between each truck.
Departure links on the arterial road are assumed to have a link length of 125 meters
(estimated to be the approximate distance that vehicles accelerate to a 45 mph cruising
speed). The departure links from the intersection to the on-ramp are assumed to have a
link length of 200 meters (estimated to be the approximate distance that vehicles
accelerate to a 55 mph cruising speed).
Exhibit E-4. Link Parameters (Peak Traffic)

E-8

E.5.3 Determining the number of MOVES runs

Following the guidance given in Section 4.3, it is determined that 16 MOVES runs
should be completed to produce emission factors that show variation across four hourly
periods (12 a.m., 6 a.m., 12 p.m., and 6 p.m., corresponding to overnight, morning,
midday, and evening traffic scenarios, respectively) and four quarterly periods
(represented by the months of January, April, July, and October; see Section 3.3).
MOVES will calculate values for all project links for the time period specified in each
run. The 16 emission factors produced for each link are calculated as grams/vehicle
mile, which will then be paired with corresponding traffic volumes (peak or average
hour, depending on the hour) and used in CAL3QHCR.
E.5.4 Developing basic run specification inputs
When configuring MOVES for the analysis, the project sponsor follows Section 4.4 of
the guidance, including, but not limited to, the following:
From the Scale panel, selecting the Project domain; in addition, choosing output
in Emission Rates, so that emission factors will be in grams/vehicle-mile as
needed for CAL3QHCR (see Section 4.4.2).
From the Time Spans panel, the appropriate year, month, day, and hour for each
run is selected (see Section 4.4.3).
From the Geographic Bounds panel, the custom domain is selected (see Section
4.4.4).
From the Vehicles/Equipment panel, appropriate Source Types are selected (see
Section 4.4.5).
From the Road Types panel, Urban Restricted and Urban Unrestricted road types
are selected (see Section 4.4.6).
From the Pollutants and Processes panel, the appropriate pollutant/processes are
selected according to Section 4.4.7 of the guidance for highway links.
In the Output panel, an output database is specified with grams and miles selected
as units (see Section 4.4.10).
E.5.5 Entering project details using the Project Data Manager
Meteorology
As described previously, it is determined that MOVES should be run 16 times to reflect
the following scenarios: 12 a.m., 6 a.m., 12 p.m., and 6 p.m. (corresponding to overnight,
morning, midday, and evening traffic scenarios, respectfully) for the months of January,
April, July, and October. Temperature and humidity data from a representative
meteorological monitoring station are obtained and confirmed to be consistent with data
used in the regional emissions analysis from the currently conforming transportation plan
and TIP (see Section 4.5.1). Average values for each hour and month combination are
used for each of the 16 MOVES runs. As an example, temperature and humidity values
for 12 a.m. January are shown in Exhibit E-5.

E-9

Exhibit E-5. Temperature and Humidity Input (January 12 a.m.)

Age Distribution
Section 4.5.2 of the guidance specifies that default data should be used only if an
alternative local dataset cannot be obtained and the regional conformity analysis relies on
national defaults. However, for the sake of simplicity only, in this example the national
default age distribution for 2015 is used for all vehicles and all runs (see Exhibit E-6).
Exhibit E-6. Age Distribution Table (Partial)

E-10

Fuel Supply and Fuel Formulation

In this example, it is determined appropriate to use the default fuel supply and
formulation (see Exhibits E-7 and E-8). The default fuel supply and formulation are
imported for each respective quarter (January, April, July, and October) and used for the
corresponding MOVES runs.
Exhibit E-7. Fuel Supply Table

Exhibit E-8. Fuel Formulation Table

E-11

Inspection and Maintenance (I/M)

As there is no PM emissions benefit in MOVES for I/M programs, this menu item is
skipped (see Section 4.5.4).
Link Source Type
The distribution of vehicle types on each link is defined in the Link Source Type table
(Exhibit E-9) following the guidance in Section 4.5.5. The fractions are derived from the
vehicle count estimates in Exhibit E-3.
Exhibit E-9. Link Source Type Table

Links
The Links input table shown in Exhibit E-10 is used to define each individual project link
in MOVES. Road Types 4 and 5 indicate Urban Restricted (freeway) and Urban
Unrestricted (arterial) road types, respectively; these correspond to the two road types
represented in this example. The average speed is entered for all links, but only used to
calculate Op-Mode distributions for links 1, 4, 7, 8, 11, 14, 17, and 20 (other links are
explicitly defined with a link-drive schedule or Op-Mode distribution). Link length and
link volume is entered for each link; however, since the Emission Rates option is
selected in the Scale panel, MOVES will produce grams/vehicle-mile. The volume and
link length will become relevant when running the air quality model later in this analysis.

E-12

Exhibit E-10. Links Input (AM Period)

The remaining links are defined with an Op-Mode distribution (Exhibit E-11) calculated
separately, as discussed earlier. Operating modes used in this analysis vary by both link
and source type, but not by hour or day.
Exhibit E-11. Operating Mode Distribution Table (Partial)

E-13

Off-Network
As it was determined that there are no off-network links (such as parking lots or truck
stops) that would have to be considered using the Off-Network Importer, there is no need
to use this option in this example.
E.5.6 Generating emission factors for use in air quality modeling
After generating the run specification and entering the required information into the
Project Data Manager as described above, MOVES is run 16 times, once for each unique
hour/month combination. Upon completion of each run, the MOVES output is located in
the MySQL output database table rateperdistance and sorted by Month, Hour, LinkID,
ProcessID, and PollutantID. An aggregate PM2.5 emission factor is then calculated by the
project sponsor for each Month, Hour, and LinkID combination using the following
equation and the guidance given in Section 4.4.7 of the guidance:2
PMaggregate total = (PMtotal running) + (PMtotal crankcase running) + (brake wear) + (tire wear)
The 16 resulting grams/vehicle-mile emission factors (Exhibit E-12) for each link are
then ready to be used as input into the CAL3QHCR dispersion model to predict future
PM2.5 concentrations.

EPA is considering creating one or more MOVES scripts that would automate the summing of aggregate
emissions when completing project-level analyses. These scripts would be made available for download on
the MOVES website (www.epa.gov/otaq/models/moves/tools.htm), when available.

E-14

Exhibit E-12. Grams/Vehicle-Mile Emission Factors Calculated from MOVES

Output by Link, Quarter, and Hour

E-15

E.6 ESTIMATE EMISSIONS FROM ROAD DUST, CONSTRUCTION,

ADDITIONAL SOURCES (STEP 4)

AND

E.6.1 Estimating re-entrained road dust

In this case, this area does not have any adequate or approved SIP budgets for either
PM2.5 NAAQS, and neither the EPA nor the state air agency have made a finding that
road dust emissions are a significant contributor to the air quality problem for either
PM2.5 NAAQS. Therefore, PM2.5 emissions from road dust do not need to be considered
in this analysis (see Sections 2.5.3 and 6.2).
E.6.2 Estimating transportation-related construction dust
The construction of this project will not occur during the analysis year. Therefore,
emissions from construction dust are not included in this analysis (see Sections 2.5.5 and
6.4).
E.6.3 Estimating additional sources of emissions in the project area
It is determined that the project area in the analysis year does not include locomotives or
other nearby emission sources that have to be considered in the air quality modeling (see
Section 6.6).

E.7 SELECT AN AIR QUALITY MODEL, DATA INPUTS, AND RECEPTORS

(STEP 5)
E.7.1 Characterizing emission sources
As discussed previously, the CAL3QHCR model is selected to estimate PM2.5
concentrations for this analysis (see Section 7.3). Each link is defined in CAL3QHCR
with coordinates and dimensions matching the project parameters (shown in Exhibit E-4).
The necessary inputs for link length, traffic volume, and corresponding link emission
factor are also added using the CAL3QHCR Tier II approach. Each MOVES emission
factor (12 a.m., 6 a.m., 12 p.m., and 6 p.m.) and traffic volume (average or peak) for each
link is applied to multiple hours of the day, as follows:
Morning peak (AM) emissions based on traffic data and meteorology occurring
between 6 a.m. and 9 a.m.;
Midday (MD) emissions based on data from 9 a.m. to 4 p.m.;
Evening peak (PM) emissions based on data from 4 p.m. to 7 p.m.;
Overnight (ON) emissions based on data from 7 p.m. to 6 a.m.
In addition, these factors are applied to each of the four quarters being modeled.

E-16

CAL3QHCR scenarios are built to model traffic conditions for all 24 hours of a weekday
in each quarter (partial elements of the CAL3QHCR input file can be found in Exhibits
E-13a and 13b, as file requires one to scroll down the screen): in all, four separate
scenarios.
Exhibit E-13a. CAL3QHCR Quarter 1, 6 a.m. Input File (Partial)

E-17

Exhibit E-13b. CAL3QHCR Quarter 1, 6 a.m. Input File (Partial)

Section 7.5 of the guidance recommends that users run the air quality model for five
years of meteorological data when site-specific meteorology data is not available. Since
CAL3QHCR can only process one year of meteorological data for each run, each
quarterly scenario is run for five years of meteorological data for a total of 20 runs.3

As explained in Section 7, AERMOD allows five years of meteorological data to be modeled in a single
run (see Section 7.5.3)

E-18

E.7.2 Incorporating meteorological data

A representative set of meteorology data, as well as an appropriate surface roughness, are
selected (see Section 7.5). The recommended five years of meteorological data are
obtained from a local airport for calendar years 1998-2002. A surface roughness of 175
cm is selected for the site, consistent with the recommendations made in the Section 7.
E.7.3 Placing receptors
Using the guidance given in Section 7.6, receptors are placed at appropriate locations
within the area substantially affected by the project (Exhibit E-14).4 Note that this grid is
shown for illustrative purposes only; placement, location, and spacing of actual receptors
should follow the guidance in Section 7.6. Receptor heights are set at 1.8 meters.
Additionally, a background concentration of 0 is input into the model. Representative
background concentrations are added later (see Step 7).
CAL3QHCR is then run with five years of meteorological data (1998 through 2002) and
output is produced for all receptors for each of the five years of meteorological data.
Exhibit E-14. Receptor Locations for Air Quality Modeling

The number and arrangement of receptors used in this example are simplified for ease of explanation.

E-19

E.8 DETERMINE BACKGROUND CONCENTRATIONS FROM NEARBY AND

OTHER EMISSION SOURCES (STEP 6)
Through the interagency consultation process, a nearby upwind PM2.5 monitor that has
been collecting ambient data for both the annual and 24-hour PM2.5 NAAQS is
determined to be representative of the background air quality at the project location. The
most recent data set is used (in this case, calendar year 2008 through 2010) and average
24-hour PM2.5 values are taken in a four-day/three-day measurement interval. As
previously noted, no nearby sources needing to be included in the air quality model are
identified.
Note: This is a highly simplified situation for illustrative purposes; refer to Section 8 of
the guidance for additional considerations for how to most accurately reflect background
concentrations in a real-world scenario.

E-20

E.9

CALCULATE DESIGN VALUES AND DETERMINE CONFORMITY (STEP 7)

With both CAL3QHCR outputs and background concentrations now available, the
project sponsor can calculate the design values. For illustrative purposes, calculations for
a single receptor with the highest modeled concentrations for the build scenario are
shown in this example.5 In this step, the guidance from Sections 9.3.2 and 9.3.3 are used
to calculate design values from the modeled results and the background concentrations
for comparison with the annual and 24-hour PM2.5 NAAQS.
E.9.1 Determining conformity to the annual PM2.5 NAAQS
First, average background concentrations are determined for each year of monitored data
(shown in Exhibit E-15).
Exhibit E-15. Annual Average Background Concentration for Each Year
Monitoring
Year
2008
2009
2010

Annual Average
Background
Concentration
13.348
12.785
13.927

The three-year average background concentration is then calculated (see Exhibit E-16).
Exhibit E-16. Calculation of Annual Design Value (At Highest Receptor)
Annual Average
Background
Concentration
(Three-year
Average)
13.353

Annual Average
Modeled
Concentration
(Five-year
Average)
1.580

Sum of
Background +
Project

Annual Design Value

14.933

14.9

In an actual PM hot-spot analysis, design values would be calculated at additional receptors as described
in Section 9.3.

E-21

To determine the annual PM2.5 design value, the annual average background
concentration is added to the five-year annual average modeled concentration (at the
receptor with the highest annual average concentration from the CAL3QHCR output).
This calculation is shown in Exhibit E-16. The sum (project + background) results in a
design value of 14.9 g/m3. This value at the highest receptor is less than the 1997
annual PM2.5 NAAQS of 15.0 g/m3. It can be assumed that all other receptors with
lower modeled concentrations will also have design values less than this NAAQS. In this
example it is unnecessary to determine appropriate receptors in the build scenario (per
Section 9.4 of the guidance) or develop a no-build scenario for the annual PM2.5 NAAQS,
since the build scenario demonstrates that the hot-spot analysis requirements in the
transportation conformity rule are met at all receptors.
E.9.2

Determining conformity to the 24-Hour PM2.5 NAAQS

The next step is to calculate a design value to compare with the 2006 24-hour PM2.5
NAAQS through a Second Tier analysis as described in Section 9.3.3. For ease of
explanation, this process has been divided into individual steps, consistent with the
guidance.
Step 7.1
The number of background measurements is counted for each year of monitored data
(2008 to 2010). Based on a 4-day/3-day measurement interval, the dataset has 104 values
per year.
Step 7.2
For each year of monitored concentrations, the eight highest daily background
concentrations for each quarter are determined, resulting in 32 values (4 quarters; 8
concentrations/quarter) for each year of data (shown in Exhibit E-17).
Step 7.3
Identify the highest-predicted modeled concentration resulting from the project in each
quarter, averaged across each year of meteorological data used for air quality modeling.
For illustrative purposes, the highest average concentration across five years of
meteorological data for a single receptor in each quarter is shown in Exhibit E-18. Note
that, in a real-world situation, this process would be repeated for all receptors in the build
scenario.

E-22

Exhibit E-17. Highest Daily Background Concentrations for Each Quarter and
Each Year

Rank
1
2
3
4
5
6
7
8

Q1
20.574
20.152
19.743
19.346
18.961
18.588
18.226
17.874

Rank
1
2
3
4
5
6
7
8

Q1
20.195
19.784
19.386
19.000
18.625
18.262
17.910
17.568

Rank
1
2
3
4
5
6
7
8

Q1
21.137
20.698
20.272
19.860
19.459
19.071
18.694
18.329

2008
Q2
21.262
20.823
20.398
19.985
19.584
19.196
18.819
18.454
2009
Q2
20.867
20.440
20.026
19.624
19.235
18.857
18.490
18.135
2010
Q2
21.847
21.390
20.948
20.519
20.102
19.698
19.307
18.927

Q3
22.354
22.042
21.735
21.434
21.140
20.851
20.568
20.291

Q4
20.434
20.016
19.611
19.218
18.837
18.467
18.109
17.761

Q3
21.932
21.628
21.329
21.037
20.750
20.469
20.194
19.924

Q4
20.058
19.651
19.257
18.875
18.504
18.145
17.796
17.457

Q3
22.980
22.655
22.336
22.023
21.717
21.417
21.123
20.834

Q4
20.990
20.556
20.135
19.726
19.330
18.945
18.572
18.211

Exhibit E-18. Five-year Average 24-hour Modeled Concentrations for Each Quarter
(At Example Receptor)

Five Year Average

Maximum
Concentration (At
Example Receptor)

Q1

Q2

Q3

Q4

10.42

10.62

10.74

10.61

E-23

Step 7.4
The highest modeled concentration in each quarter (from Step 7.3) is added to each of the
eight highest monitored concentrations for the same quarter for each year of monitoring
data (from Step 7.2). As shown in Exhibit E-19, this step results in eight concentrations
in each of four quarters for a total of 32 values for each year of monitoring data. As
mentioned, this example analysis shows only a single receptors values, but project
sponsors may need to calculate design values at all receptors in the build scenario (see
Section 9.3 of the guidance).
Exhibit E-19. Sum of Background and Modeled Concentrations at Example
Receptor for Each Quarter

Rank
1
2
3
4
5
6
7
8

Q1
31.084
30.662
30.253
29.856
29.471
29.098
28.736
28.384

Rank
1
2
3
4
5
6
7
8

Q1
30.705
30.294
29.896
29.510
29.135
28.772
28.420
28.078

Rank
1
2
3
4
5
6
7
8

Q1
31.647
31.208
30.782
30.370
29.969
29.581
29.204
28.839

2008
Q2
31.902
31.463
31.038
30.625
30.224
29.836
29.459
29.094
2009
Q2
31.507
31.080
30.666
30.264
29.875
29.497
29.130
28.775
2010
Q2
32.487
32.030
31.588
31.159
30.742
30.338
29.947
29.567

Q3
32.994
32.682
32.375
32.074
31.780
31.491
31.208
30.931

Q4
31.074
30.656
30.251
29.858
29.477
29.107
28.749
28.401

Q3
32.572
32.268
31.969
31.677
31.390
31.109
30.834
30.564

Q4
30.698
30.291
29.897
29.515
29.144
28.785
28.436
28.097

Q3
33.620
33.295
32.976
32.663
32.357
32.057
31.763
31.474

Q4
31.630
31.196
30.775
30.366
29.970
29.585
29.212
28.851

E-24

Step 7.5
As shown in Exhibit E-20, for each year of monitoring data, the 32 values from Step 7.4
are ordered together in a column and assigned a yearly rank for each value, from 1
(highest concentration) to 32 (lowest concentration).
Exhibit E-20. Ranking Sum of Background and Modeled Concentrations at
Example Receptor for Each Year of Background Data
Rank
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32

2008
32.994
32.682
32.375
32.074
31.902
31.780
31.491
31.463
31.208
31.084
31.074
31.038
30.931
30.662
30.656
30.625
30.253
30.251
30.224
29.858
29.856
29.836
29.477
29.471
29.459
29.107
29.098
29.094
28.749
28.736
28.401
28.384

2009
32.572
32.268
31.969
31.677
31.507
31.390
31.109
31.080
30.834
30.705
30.698
30.666
30.564
30.294
30.291
30.264
29.897
29.896
29.875
29.515
29.510
29.497
29.144
29.135
29.130
28.785
28.775
28.772
28.436
28.420
28.097
28.078

2010
33.620
33.295
32.976
32.663
32.487
32.357
32.057
32.030
31.763
31.647
31.630
31.588
31.474
31.208
31.196
31.159
30.782
30.775
30.742
30.370
30.366
30.338
29.970
29.969
29.947
29.585
29.581
29.567
29.212
29.204
28.851
28.839

E-25

Step 7.6
For each year of monitoring data, the value with a rank that corresponds to the projected
98th percentile concentration is determined. As discussed in Section 9, an analysis
employing 101-150 background values for each year (as noted in Step 7.1, this analysis
uses 104 values per year) uses the 3rd highest rank to represent a 98th percentile. The 3rd
highest concentration (highlighted in Exhibit E-20) is referred to as the projected 98th
percentile concentration.
Step 7.7
Steps 7.1 through 7.6 are repeated to calculate a projected 98th percentile concentration at
each receptor based on each year of monitoring data and modeled concentrations.
Step 7.8
For the example receptor, the average of the three projected 98th percentile concentrations
(see Step 7.6) is calculated.
Step 7.9
The resulting value of 32.440 g/m3 is then rounded to the nearest whole g/m3, resulting
in a design value at the example receptor of 32 g/m3. At each receptor this process
should be repeated. In the case of this analysis, the example receptor is the receptor with
the highest design value in the build scenario.
Step 7.10
The design values calculated at each receptor are compared to the NAAQS. In the case
of this example, the highest 24-hour design value (32 g/m3) is less than the 2006 24
hour PM2.5 NAAQS of 35 g/m3. Since this is the design value at the highest receptor, it
can be assumed that the conformity requirements are met at all receptors in the build
scenario. Therefore, it is unnecessary for the project sponsor to calculate design values
for the no-build scenario for the 24-hour NAAQS.

E.10 CONSIDER MITIGATION AND CONTROL MEASURES (STEP 8)

In this case, the project is determined to conform. In situations when this is not the case,
it may be necessary to consider additional mitigation or control measures. If measures
are considered, additional air quality modeling would need to be completed and new
design values calculated to ensure that conformity requirements are met. See Section 10
for more information, including some specific measures that might be considered.

E.11 DOCUMENT THE PM HOT-SPOT ANALYSIS (STEP 9)

The final step is to properly document the PM hot-spot analysis in the conformity
determination (see Section 3.10).

E-26

Appendix F:
Example Quantitative PM Hot-spot Analysis of a Transit
Project using MOVES and AERMOD
F.1

INTRODUCTION

The purpose of this appendix is to demonstrate the procedures for completing a hot-spot
analysis using MOVES and AERMOD following the basic steps described in Section 3.
Readers should reference the appropriate sections in the guidance as needed for more
detail on how to complete each step of the analysis. This example is limited to showing
the build scenario; in practice, project sponsors may have to also analyze the no-build
scenario. While this example calculates emission rates using MOVES, EMFAC users
may find the air quality modeling described in this appendix helpful.
Note: The following example of a quantitative PM hot-spot analysis is highly simplified
and intended only to demonstrate the basic procedures described in the guidance. This
example uses default data in places where the use of project-specific data in a real-world
situation would be expected. In addition, actual PM hot-spot analyses could be
significantly more complex and are likely to require more documentation of data and
decisions. In this example, the interagency consultation process is used as needed for
evaluating and choosing models, methods, and assumptions, according to the
requirements of 40 CFR 93.105(c)(1)(i).

F.2

PROJECT DESCRIPTION AND CONTEXT

The proposed project is a new regionally significant bus terminal that would be created
by taking a downtown street segment one block in length and reserving it for bus use
only. It would be an open-air facility containing six sawtooth lanes where buses enter
to load and unload passengers. The terminal is designed to handle about 575 diesel buses
per day with up to 48 buses in the peak hour. The project is located in an area designated
nonattainment for the 2006 24-hour PM2.5 NAAQS and 1997 annual PM2.5 NAAQS.
The following is some additional pertinent data about the project:
The proposed project is located in a medium-size city (within one county) in a
state other than California.
The project is expected to take less than a year to complete and has an estimated
completion date of 2013. The year of peak emissions is expected to be 2015,
when considering the projects emissions and background concentrations.
The area surrounding the proposed project is primarily commercial, with no
nearby sources of PM2.5 that need to be modeled. This assumption is made to
simplify the example. In most cases, transit projects include parking lots with
emissions that would be considered in a PM hot-spot analysis.

F-1

 The state does not have an adequate or approved SIP budget for either PM2.5
NAAQS, and neither the EPA nor the state air quality agency has made a finding
that road dust is a significant contributor to the PM2.5 nonattainment problem.

F.3

DETERMINE NEED FOR PM HOT-SPOT ANALYSIS (STEP 1)

The proposed project is determined to be of local air quality concern under the
conformity rule because it is a new bus terminal that has a significant number of diesel
vehicles congregating at a single location (see 40 CFR 93.123(b)(1)(iii) and Section 2.2
and Appendix B of the guidance). Therefore, a quantitative PM hot-spot analysis is
required.

F.4

DETERMINE APPROACH, MODELS, AND DATA (STEP 2)

F.4.1 Determining geographic area and emission sources to be covered by the analysis
First, the interagency consultation process is used to ensure that the project area is
defined so that the analysis includes the entire project, as required by 40 CFR
93.123(c)(2). As previously noted, it is also determined that, in this case, there are no
nearby emission sources to be modeled (see Section 3.3.2).
F.4.2 Deciding the general analysis approach and analysis year(s)
The project sponsor then determines that the preferred approach in this case is to model
the build scenario first, completing a no-build scenario only if necessary.
The year of peak emissions (within the timeframe of the current transportation plan) is
determined to be 2015. Therefore, 2015 is selected as the year of the analysis, and the
analysis will consider traffic data from 2015 (see Section 3.3.3).
F.4.3 Determining the PM NAAQS to be evaluated
Because the area has been designated nonattainment for both the 2006 24-hour PM2.5
NAAQS and 1997 annual PM2.5 NAAQS, the results of the analysis will be compared to
both NAAQS (see Section 3.3.4). All four quarters are included in the analysis in order
to estimate a years worth of emissions for both NAAQS.

F-2

F.4.4 Deciding on the type of PM emissions to be modeled

Next, the following directly-emitted PM emissions are determined to be relevant for
estimating the emissions in the analysis (see Section 2.5):
Vehicle exhaust1
Brake wear
Tire wear
F.4.5 Determining the models and methods to be used
Since this project will be located outside of California, MOVES is used for emissions
modeling. In addition, it is determined that, since this is a terminal project, the
appropriate air quality model to use would be AERMOD (see Section 3.3.6). Making the
decision on what air quality model to use at this stage is important so that the appropriate
data are collected, among other reasons (see next step).
F.4.6 Obtaining project-specific data
Finally, having selected a model and a general modeling approach, the project sponsor
compiles the data required to use MOVES, including project traffic data, vehicle types
and age, and temperature and humidity data for the months and hours to be modeled
(specifics on the data collected are described in the following steps). In addition,
information required to use AERMOD to model air quality is gathered, including
meteorological data and information on representative air quality monitors. The sponsor
ensures the latest planning assumptions are used and that data used for the analysis are
consistent with that used in the latest regional emissions analysis, as required by the
conformity rule (see Section 3.3.7).

F.5

ESTIMATE ON-ROAD MOTOR VEHICLE EMISSIONS (STEP 3)

Having completed the analysis preparations described above, the project sponsor then
follows the instructions provided in Section 4 of the guidance to use MOVES to estimate
the on-road emissions from this terminal project:
F.5.1 Characterizing the project in terms of links
Using the guidance described in Section 4.2, a series of links are defined in order to
accurately capture the activity at the proposed terminal. As shown in Exhibit F-1, two
one-way running links north and south of the facility (Link 1 and Link 2) are defined
to describe buses entering and exiting the terminal. A third running/idle link (shown as
Link 3 to the north of the facility), is used to describe vehicles idling at the signalized

Represented in MOVES as PMtotal running, PMtotal crankcase running, PMtotal ext. idle, and PMtotal crankcase ext. idle.

F-3

light before exiting the facility. Links 4 through 9 represented bus bays where buses
drop-off and pick-up passengers; these are referred to as the terminal links.2
Exhibit F-1. Diagram of Proposed Bus Terminal Showing Links

The running links have the following dimensions:

Link 1: 200 feet long by 24 feet wide
Link 2: 160 feet long by 24 feet wide
Link 3: 40 feet long by 24 feet wide
Additionally, the dimensions of the six terminal links (Links 4 through 9) are 60 feet long
by 12 feet wide. These links are oriented diagonally from southwest to northeast. The
queue link (Link 3) is defined with a length of 40 feet, based on the average length of a
transit bus.
After identifying and defining the links, traffic conditions are estimated for the project in
the analysis year of 2015. The terminal was presumed to be in operation all hours of the
year. Based on expected terminal operations, the anticipated future traffic volumes are
available for each hour of an average weekday (see Exhibit F-2). To simplify the
analysis, the sponsor conservatively assumes weekday traffic for all days of the year,
even though the operating plan calls for reduced service on weekends.3 Identical traffic
volume and activity profiles are assumed for all quarters of the year. Quarters are defined
for this analysis as described in Section 3.3.4 of the guidance: Q1 (January-March), Q2
(April-June), Q3 (July-September), and Q4 (October-December).

The project area in this example is not realistic and has been simplified for demonstration purposes.

Analyses of transit facilities will likely include inbound and outbound links beyond what is described in

this simplified example, as well as the surrounding area.

3
This decision is made to save time and effort, as it would result in the need for fewer modeling runs.

More accurate results would be obtained by treating weekends differently and modeling them using the

actual estimated Saturday and Sunday traffic.

F-4

Exhibit F-2. Average Weekday Bus Trips through Transit Terminal for Each Hour
Hour
12am - 1am
1am - 2am
2am - 3am
3am - 4am
4am - 5am
5am - 6am
6am - 7am
7am - 8am
8am - 9am
9am - 10am
10am - 11am
11am - 12pm
12pm - 1pm
1pm - 2pm
2pm - 3pm
3pm - 4pm
4pm - 5pm
5pm - 6pm
6pm - 7pm
7pm - 8pm
8pm - 9pm
9pm - 10pm
10pm - 11pm
11pm - 12am

Bus Trips
7
6
6
6
7
9
27
48
39
29
26
28
30
31
31
39
44
42
26
21
22
17
13
10

F.5.2 Deciding on how to handle link activity

As discussed in Section 4.2 of the guidance, MOVES offers several options for users to
apply activity information to each LinkID. For illustrative purposes, based on the
available information for the project (average speed, hourly bus volume, idle time, and
fraction of vehicles encountering a red light) several methods of deriving Op-Mode
distributions are employed in this example, as described below.
Links 1 and 2 represent buses driving at an average of 5 mph through the
terminal, entering and exiting the bus bays. An average speed of 5 mph is entered
into the MOVES links input, which calculates an Op-Mode distribution to
reflect the MOVES default 5 mph driving pattern.
The queue link (Link 3) is given an Op-Mode distribution that represents buses
decelerating, idling, and accelerating (red light) as well as cruising through (green
light). First, an Op-Mode distribution is calculated for the link average speed (5
mph). Because this does not adequately account for idling at the intersection, the
Op-Mode fractions are re-allocated to add in 50% idling (determined after
consulting the Highway Capacity Manual 2000 to approximate idle time in an
under-capacity scenario) reflecting 50% of buses encountering a red light. A
F-5

fraction of 0.5 for Op-Mode 1 is added to the re-allocated 5 mph average speed
Op-Mode distribution. The resulting Op-Mode distribution represents all activity
on a queuing intersection link.
The bus bays (Links 4 through 9) are represented by a single link (modeled in
MOVES as LinkID 4) and activity is defined in the Links table by an average
speed of 0, representing exclusively idle activity.
F.5.3 Determining the number of MOVES runs
Following the guidance given in Section 4.3, it is determined that 16 MOVES runs
should be completed to produce emission factors that show variation across four hourly
periods (12 a.m., 6 a.m., 12 p.m., and 6 p.m., corresponding to overnight, morning,
midday, and evening traffic scenarios, respectively) and four quarterly periods
(represented by the months of January, April, July, and October; see Section 3.3).
MOVES would calculate values for all project links for the time period specified in each
run. Although traffic data is available for 24 hours, the emission factors produced from
the 16 scenarios would be post-processed into grams/vehicle-hour and further converted
to grams/hour emission factors that vary based on the hour-specific vehicle count. This
methodology avoids running 24 hourly scenarios for four quarters (96 runs). Grams/hour
emissions rates are required to use AERMOD.
F.5.4 Developing basic run specification inputs
When configuring MOVES for the analysis, the project sponsor follows Section 4.4 of
the guidance, including, but not limited to, the following:
From the Scale menu, selecting the Project domain; in addition, choosing
output in Inventory so that total emission results are produced for each link,
which is equivalent to a grams/hour/link emission factor needed by AERMOD
(see Section 4.4.2).
From the Time Spans panel, the appropriate year, month, day, and hour for each
run is selected (see Section 4.4.3).
From the Geographic Bounds panel, the custom domain is selected (see Section
4.4.4).
From the Vehicles/Equipment panel, Diesel Transit Buses are selected (see
Section 4.4.5).
From the Road Types panel, the Urban Unrestricted road type is selected (see
Section 4.4.6).
From the Pollutants and Processes panel, appropriate pollutant/processes are
selected according to Section 4.4.7 of the guidance for highway links.
In the Output panel, an output database is specified with grams and miles selected
as units (see Section 4.4.10).

F-6

F.5.5 Entering project details using the Project Data Manager

Meteorology
As described previously, it is determined that MOVES should be run 16 times to reflect
the following scenarios: 12 a.m., 6 a.m., 12 p.m., and 6 p.m. (corresponding to overnight,
morning, midday, and evening traffic scenarios, respectively) for the months of January,
April, July, and October. Temperature and humidity data from a representative
meteorological monitoring station are obtained and confirmed to be consistent with data
used in the regional emissions analysis from the currently conforming transportation plan
and TIP (see Section 4.5.1). Average values for each hour and month combination are
used for each of the 16 MOVES runs. As an example, temperature and humidity values
for 12 a.m. January are shown in Exhibit F-3.
Exhibit F-3. Temperature and Humidity Input (January 6 a.m.)

F-7

Age Distribution
Section 4.5.2 of the guidance specifies that default data should be used only if an
alternative local dataset cannot be obtained and the regional conformity analysis relies on
national defaults. However, for the sake of simplicity only, in this example the national
default age distribution for 2015 is used for all vehicles and all runs (see Exhibit F-4). As
discussed in the guidance, transit agencies should be able to provide a fleet-specific age
distribution, and the use of fleet-specific data is always recommended (and would be
expected in a real-world scenario) because emission factors vary significantly depending
on the age of the fleet.
Exhibit F-4. Age Distribution Table (Partial)

F-8

Fuel Supply and Fuel Formulation

An appropriate fuel supply and formulation is selected to match the project areas diesel
use. In MOVES, diesel fuel formulation is constant across all quarters, so one fuel
supply/fuel formulation combination is used for all MOVES runs. Also, it is known that
all transit buses would use the same diesel fuel, so a fraction of 1 is entered for fuel
20011 (ultra-low-sulfur diesel fuel) in the Fuel Supply Table. In the case of this example,
the default fuel supply/formulation matches the actual fuel supply/formulation, so it is
therefore appropriate to use the default in the analysis (see Exhibits F-5 and F-6).
Exhibit F-5. Fuel Supply Table

Exhibit F-6. Fuel Formulation Table

F-9

Inspection and Maintenance (I/M)

As there is no PM emissions benefit in MOVES for I/M programs, this menu item is
skipped (see Section 4.5.4).
Link Source Type
The distribution of vehicle types on each link is defined in the Link Source Type table
following the guidance in Section 4.5.5. Given that the project will be a dedicated transit
bus terminal this analysis assumes only transit buses are operating on all links.
Therefore, a fraction of 1 is entered for Source Type 42 (Transit Buses) for each LinkID
indicating 100% of vehicles using the project are transit buses (see Exhibit F-7).
Exhibit F-7. Link Source Type Table

F-10

Links
The Links table (see Exhibit F-8) is populated with parameters for the four defined links
of the bus terminal: three running links (Links 1-3) and one idle link (representing the
terminal links). The link length is entered in terms of miles for each link. The road type
for the four links is classified as 5 (Urban Unrestricted). The entrance and exit links
(Links 1 and 2) are given an average speed of 5 mph. The queue link (Link 3) is given an
average speed of 2.5 mph, representing 50% of the vehicle operating hours in idling
mode and 50% operating hours traveling at 5 mph. Although MOVES is capable of
calculating emissions from an average speed (as is done for Links 1 and 2), the specific
activity on Link 3 is directly entered with an Op-Mode distribution. LinkID 4 is given a
link average speed of 0 mph, which indicates entirely idle operation. Link volume
(which represents the number of buses per hour) is entered for each link; however, since
the goal of the analysis is to produce an estimate in grams/vehicle-hour, the volume (i.e.,
the number of vehicles) will be divided out during post-processing. Also, because link
volume is arbitrary, the Links table shown in Exhibit F-8 can be used for all 16 MOVES
runs.
Exhibit F-8. Links Table

Describing Vehicle Activity

MOVES can capture details about vehicle activity in a number of ways. In this case, it is
decided to use average speeds for Links 1, 2, and 4 and a detailed Op-Mode distribution
for Link 3 (see Section 4.5.7).
Op-Mode distributions for Links 1 and 2 are calculated within MOVES based on a 5 mph
average speed. The MOVES model calculates a default Op-Mode distribution based on
average speed and road type (for these links, 5 mph on road type 5). Link 3 is given a
unique Op-Mode distribution to better simulate the queuing and idling that occurs prior to
buses exiting the facility at a traffic signal. The sponsor estimates that 50% of buses

F-11

would idle at a red light before exiting the facility, so the idling operation (OpMode ID 1)
is assumed to be 0.5 for Link 3. The remaining 50% is re-allocated based on the default 5
mph Op-Mode distribution calculated for Links 1 and 2 (which includes acceleration,
deceleration, and cruise operating modes). This process requires an additional MOVES
run to extract the default 5 mph Op-Mode distribution from the MOVES execution
database. By selecting save data for the Operating Mode Distribution Generator
(Running OMDG) under the MOVES Advanced Performance Features panel, the OpMode distributions generated for 5 mph on an urban unrestricted road type are saved in
the MOVES execution database in the MySQL table opmodedistribution. The OpMode distribution used in the analysis for Link 3 is partially shown in Exhibit F-9.
Exhibit F-9. Link 3 (Queue Link) Op-Mode Distribution Input Table (Partial)

F-12

Off-Network
As it is assumed that there are no off-network links (such as parking lots or truck stops)
that would have to be considered using the Off-Network Importer (bus idling at the
terminal is captured by the terminal links), there is no need to use this option in this
example. As noted earlier, this assumption is made to simplify the example. Most transit
projects would include rider parking lots and should include these emissions in a PM hotspot analysis.
F.5.6 Generating emission factors for use in air quality modeling
After generating the run specification and entering the required information into the
Project Data Manager as described above, MOVES is run 17 times: 16 runs (four hours
of the day for four quarters of the year) plus an initial run to generate the Op-Mode
distribution for 5 mph as discussed earlier. Upon completion of each run, the MOVES
output is located in the MySQL output database table movesoutput and sorted by
Month, Hour, LinkID, ProcessID, and PollutantID. An aggregate PM2.5 emission factor
is then calculated by the project sponsor for each Month, Hour, and LinkID combination
using the following equation and the guidance given in Section 4.4.7 of the guidance:4
PMaggregate total = (PMtotal running) + (PMtotal crankcase running) + (brake wear) + (tire wear)
For each link, the total emissions are divided by the number of vehicles on each link (as
reported in the movesactivityoutput table ActivitytypeID = 6) to produce a
grams/vehicle-hour value. This value is then multiplied by the number of buses on each
link, for each of the 24 hours where data are available (see Exhibit F-2).
The emission factor (grams/vehicle-hour) for LinkID 4 (links 4 through 9) is converted
into grams per vehicle-minute, and then multiplied by the total idle time for each unique
hour. For instance, the hour from 5 p.m. to 6 p.m. has a volume of 42 buses per hour (7
buses per bus bay). If each bus is expected to idle for 60 seconds each hour, the total idle
time for each bus bay for that hour would be 7 minutes per hour. If MOVES calculated a
PM emission factor of 2.0 grams per vehicle-minute, the emission factor for each bus bay
link under this scenario would be 14.0 grams/hour.
To account for temperature changes throughout the day, emission factors are evenly
paired with corresponding traffic volumes (six hours per period):
6 a.m. results traffic data from 3 a.m. to 9 a.m.
12 p.m. results traffic data from 9 a.m. to 3 p.m.
6 p.m. results traffic data from 3 p.m. to 9 p.m.
12 p.m. results traffic data from 9 p.m. to 3 a.m.
The emission factor results for each quarter are similarly paired with traffic volumes.
4

EPA is considering creating one or more MOVES scripts that would automate the summing of aggregate
emissions when completing project-level analyses. These scripts would be made available for download on
the MOVES website (www.epa.gov/otaq/models/moves/tools.htm), when available.

F-13

The 96 resulting grams/hour emission factors (24 hours each for four quarters) for each
link are then ready to be used as an input to the AERMOD dispersion model to predict
PM2.5 concentrations.

F.6

ESTIMATE EMISSIONS FROM ROAD DUST, CONSTRUCTION AND

OTHER ADDITIONAL SOURCES (STEP 4)

F.6.1 Estimating re-entrained road dust

In this case, this area does not have any adequate or approved SIP budgets for either
PM2.5 NAAQS, and neither the EPA nor the state air agency has made a finding that road
dust emissions are a significant contributor to the air quality problem for either PM2.5
NAAQS. Therefore, PM2.5 emissions from road dust do not need to be considered in this
analysis (see Sections 2.5.3 and 6.2).
F.6.2 Estimating transportation-related construction dust
The construction of this project will not occur during the analysis year. Therefore,
emissions from construction dust are not included in this analysis (see Sections 2.5.5 and
6.4).
F.6.3 Estimating additional sources of emissions in the project area
Through interagency consultation, it is determined that the project area in the analysis
year does not include locomotives or other nearby emissions sources that would have to
be included in the air quality modeling (see Section 6.6).

F.7 SELECT AN AIR QUALITY MODEL, DATA INPUTS, AND RECEPTORS

(STEP 5)
F.7.1 Characterizing emission sources
Because this is a transit terminal project, EPAs AERMOD model is determined to be the
appropriate dispersion model to use for this analysis (see Section 7.3). AERMOD is run
to estimate PM2.5 concentrations in and around the bus terminal project. Each link is
represented in AERMOD as an Area Source with dimensions matching the project
description (see Exhibit F-1). The emission release height is set to three meters, the
approximate exhaust height of most transit buses.
Emission factors generated from the MOVES runs are added to the AERMOD input file
(see Exhibit F-10). For this analysis, emissions vary significantly from hour to hour due
to fluctuating bus volumes as well as from daily and quarterly temperature effects.
Adjustment factors (EMISFACT) are used to model these hourly and quarterly variations
F-14

in emission factors. Refer to Appendix J for additional detail on using hour-by-hour

emission differences in an AERMOD input file.
Exhibit F-10. AERMOD Input File (Partial) with Seasonal (Quarterly) and Hourly
Adjustment Factors (Circled)

F.7.2 Incorporating meteorological data

A representative set of meteorology data, as well as an appropriate surface roughness are
selected (see Section 7.5). The recommended five years of meteorological data is
obtained from a local airport for calendar years 1998-2002. The appropriate surface
roughness is set at 1 meter, consistent with the recommendations made in the AERMOD
Implementation Guide.

F-15

F.7.3 Placing receptors

Using the guidance given in Section 7.6, receptors are placed at appropriate locations
within the area substantially affected by the project (see Exhibit F-11). 5 It is determined
in this instance to locate receptors around the perimeter of the project in increments of
five meters as well as within the passenger loading areas adjacent to the bus bays.
Receptor heights are set at 1.8 meters. A background concentration of 0 is input into
the model. Representative background concentrations are added at a later step (see Step
7).
AERMOD is run using five years of meteorological data and output produced for all
receptors for each of the five years of meteorological data.
Exhibit F-11. Area Source and Receptor Locations for Air Quality Modeling

The number and arrangement of receptors used in this example are simplified for ease of explanation;
real-world projects could expect to see more receptors and include the surrounding area.

F-16

F.8 DETERMINE BACKGROUND CONCENTRATIONS FROM NEARBY AND

OTHER EMISSION SOURCES (STEP 6)
Through the interagency consultation process, a nearby upwind PM2.5 monitor that has
been collecting ambient data for both the annual and 24-hour PM2.5 NAAQS is
determined to be representative of the background air quality at the project location (see
Exhibit F-12). The most recent data set is used (in this case, calendar year 2008 through
2010) and average 24-hour PM2.5 values are provided in a four-day/three-day
measurement interval. As previously noted, no nearby sources requiring modeling are
identified.
Note: This is a highly simplified situation for illustrative purposes; refer to Section 8 of
the guidance for additional considerations for how to most accurately reflect background
concentrations in a real-world scenario.
Exhibit F-12. PM2.5 Monitor Data from a Representative Nearby Site (Partial)

F-17

F.9

CALCULATE DESIGN VALUES AND DETERMINE CONFORMITY (STEP 7)

With both MOVES outputs and background concentrations now available, the project
sponsor can calculate the design values. For illustrative purposes, calculations for a
single receptor with the highest modeled concentrations for the build scenario are shown
in this example. 6 In Step 7, the guidance from Sections 9.3.2 and 9.3.3 are used to
calculate design values from the modeled results and the background concentrations for
comparison with the annual and 24-hour PM2.5 NAAQS.
F.9.1 Determining conformity to the annual PM2.5 NAAQS
First, average background concentrations are determined for each year of monitored data
(shown in Exhibit F-13). The three-year average background concentration is then
calculated (see Exhibit F-14).
Exhibit F-13. Annual Average Background Concentration for Each Year

Monitoring
Year
2008
2009
2010
Annual
Average

Annual Average
Background
Concentration
13.348
12.785
13.927
13.353

Exhibit F-14. Calculation of Annual Design Value (At Highest Receptor)

Annual Average
Background
Concentration
(Three-year
Average)
13.353

Annual Average
Modeled
Concentration
(Five-year
Average)
1.423

Sum of
Background +
Project

Annual Design Value

14.776

14.8

In an actual PM hot-spot analysis, design values would be calculated at additional receptors as described
in Section 9.3.

F-18

To determine the annual PM2.5 design value, the annual average background
concentration is added to the five-year annual average modeled concentration (at the
receptor with the highest annual average concentration from the AERMOD output). This
calculation is shown in Exhibit F-14. The sum (project + background) results in a design
value of 14.8 g/m3. This value at the highest receptor is less than the 1997 annual PM2.5
NAAQS of 15.0 g/m3. It can be assumed that all other receptors with lower modeled
concentrations will also have design values less than the 1997 annual PM2.5 NAAQS. In
this example it is unnecessary to determine appropriate receptors in the build scenario or
develop a no-build scenario for the annual PM2.5 NAAQS, since the build scenario
demonstrates that the hot-spot analysis requirements in the transportation conformity rule
are met at all receptors.
F.9.2

Determining conformity to the 24-Hour PM2.5 NAAQS

The next step is to calculate a design value to compare with the 2006 24-hour PM2.5
NAAQS through a Second Tier analysis as described in Section 9.3.3. For ease of
explanation, this process has been divided into individual steps, consistent with the
guidance.
Step 7.1
The number of background measurements is counted for each year of monitored data
(2008 to 2010). Based on a 4-day/3-day measurement interval, the dataset has 104 values
per year.
Step 7.2
For each year of monitored concentrations, the eight highest daily background
concentrations for each quarter are determined, resulting in 32 values (4 quarters; 8
concentrations/quarter) for each year of data (shown in Exhibit F-15).
Step 7.3
Identify the highest modeled 24-hour concentration in each quarter, averaged across each
year of meteorological data. For illustrative purposes, the highest average concentration
across five years of meteorological data for a single receptor in each quarter is shown in
Exhibit F-16. Note that, in a real-world situation, this process would be repeated for all
receptors in the build scenario.

F-19

Exhibit F-15. Highest Daily Background Concentrations for Each Quarter and
Each Year

Rank
1
2
3
4
5
6
7

Q1
20.574
20.152
19.743
19.346
18.961
18.588
18.226

17.874

Rank
1
2
3
4
5
6
7

Q1
20.195
19.784
19.386
19.000
18.625
18.262
17.910

17.568

Rank
1
2
3
4
5
6
7
8

2008
Q2
21.262
20.823
20.398
19.985
19.584
19.196
18.819
18.454
2009
Q2
20.867
20.440
20.026
19.624
19.235
18.857
18.490

Q3
22.354
22.042
21.735
21.434
21.140
20.851
20.568

Q4
20.434
20.016
19.611
19.218
18.837
18.467
18.109

20.291

17.761

Q3
21.932
21.628
21.329
21.037
20.750
20.469
20.194

Q4
20.058
19.651
19.257
18.875
18.504
18.145
17.796

19.924

17.457

Q1
21.137
20.698
20.272
19.860
19.459
19.071
18.694

18.135
2010
Q2
21.847
21.390
20.948
20.519
20.102
19.698
19.307

Q3
22.980
22.655
22.336
22.023
21.717
21.417
21.123

Q4
20.990
20.556
20.135
19.726
19.330
18.945
18.572

18.329

18.927

20.834

18.211

Exhibit F-16. Five-year Average of Highest Modeled Concentrations for Each

Quarter (At Example Receptor)

Five Year Average

Maximum
Concentration (At
Example Receptor)

Q1

Q2

Q3

Q4

6.51

6.64

6.71

6.63

F-20

Step 7.4
The highest modeled concentration in each quarter (from Step 7.3) is added to each of the
eight highest monitored concentrations for the same quarter for each year of monitoring
data (from Step 7.2). As shown in Exhibit F-17, this step results in eight concentrations
in each of four quarters for a total of 32 values for each year of monitoring data. As
mentioned, this example analysis shows only a single receptors values, but project
sponsors should calculate design values at all receptors in the build scenario.
Exhibit F-17. Sum of Background and Modeled Concentrations at Example
Receptor for Each Quarter

1
2
3
4
5
6
7
8

Q1
27.088
26.667
26.258
25.861
25.476
25.102
24.740
24.389

1
2
3
4
5
6
7
8

Q1
26.709
26.298
25.900
25.514
25.140
24.776
24.424
24.082

1
2
3
4
5
6
7
8

Q1
27.651
27.212
26.787
26.374
25.974
25.585
25.209
24.843

2008
Q2
27.901
27.462
27.037
26.624
26.224
25.835
25.459
25.093
2009
Q2
27.506
27.079
26.665
26.264
25.874
25.496
25.130
24.774
2010
Q2
28.486
28.030
27.587
27.158
26.742
26.338
25.946
25.566

Q3
29.063
28.750
28.443
28.143
27.848
27.560
27.277
27.000

Q4
26.948
26.530
26.125
25.732
25.351
24.982
24.623
24.275

Q3
28.641
28.336
28.038
27.745
27.459
27.178
26.903
26.633

Q4
26.572
26.166
25.772
25.389
25.019
24.659
24.310
23.971

Q3
29.689
29.363
29.044
28.732
28.426
28.125
27.831
27.543

Q4
27.505
27.070
26.649
26.240
25.844
25.460
25.087
24.725

F-21

Step 7.5
As shown in Exhibit F-18, for each year of monitoring data, the 32 values from Step 7.4
are ordered together in a column and assigned a yearly rank for each value, from 1
(highest concentration) to 32 (lowest concentration).
Exhibit F-18. Ranking Sum of Background and Modeled Concentrations at
Example Receptor for Each Year of Background Data
Rank
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32

2008
29.063
28.750
28.443
28.143
27.901
27.848
27.560
27.462
27.277
27.088
27.037
27.000
26.948
26.667
26.624
26.530
26.258
26.224
26.125
25.861
25.835
25.732
25.476
25.459
25.351
25.102
25.093
24.982
24.740
24.623
24.389
24.275

2009
28.641
28.336
28.038
27.745
27.506
27.459
27.178
27.079
26.903
26.709
26.665
26.633
26.572
26.298
26.264
26.166
25.900
25.874
25.772
25.514
25.496
25.389
25.140
25.130
25.019
24.776
24.774
24.659
24.424
24.310
24.082
23.971

2010
29.689
29.363
29.044
28.732
28.486
28.426
28.125
28.030
27.831
27.651
27.587
27.543
27.505
27.212
27.158
27.070
26.787
26.742
26.649
26.374
26.338
26.240
25.974
25.946
25.844
25.585
25.566
25.460
25.209
25.087
24.843
24.725

F-22

Step 7.6
For each year of monitoring data, the value with a rank that corresponds to the projected
98th percentile concentration is determined. As discussed in Section 9, an analysis
employing 101-150 background values for each year (as noted in Step 7.1, this analysis
uses 104 values per year) uses the 3rd highest rank to represent a 98th percentile. The 3rd
highest concentration (highlighted in Exhibit F-18) is referred to as the projected 98th
percentile concentration.
Step 7.7
Steps 7.1 through 7.6 are repeated to calculate a projected 98th percentile concentration at
each receptor based on each year of monitoring data and modeled concentrations.
Step 7.8
For the example receptor, the average of the three projected 98th percentile concentrations
(highlighted in Exhibit F-18) is calculated.
Step 7.9
The resulting value of 28.508 g/m3 is then rounded to the nearest whole g/m3 resulting
in a design value at the example receptor of 29 g/m3. At each receptor this process
should be repeated. However, in the case of this analysis, the example receptor is the
receptor with the highest design value in the build scenario.
Step 7.10
The design values calculated at each receptor are compared to the NAAQS. In the case
of this example, the highest 24-hour design value (29 g/m3) is less than the 2006 24
hour PM2.5 NAAQS of 35 g/m3. Since this is the design value at the highest receptor, it
can be assumed that the conformity requirements are met at all receptors in the build
scenario. Therefore, it is unnecessary for the project sponsor to calculate design values
for the no-build scenario for the 24-hour PM2.5 NAAQS.

F.10 CONSIDER MITIGATION AND CONTROL MEASURES (STEP 8)

In this case, the project is determined to conform. In situations when this is not the case,
it may be necessary to consider additional mitigation or control measures. If measures
are considered, additional air quality modeling would need to be completed and new
design values calculated to ensure that conformity requirements are met. See Section 10
for more information, including some specific measures that might be considered.

F.11 DOCUMENT THE PM HOT-SPOT ANALYSIS (STEP 9)

The final step is to properly document the PM hot-spot analysis in the conformity
determination (see Section 3.10).

F-23

Appendix G:
Example of Using EMFAC2011 for a Highway Project

G.1

INTRODUCTION

The purpose of this appendix is to demonstrate the procedures described in Section 5 of

the guidance on using EMFAC2011 to generate emission factors for air quality modeling.
The following example, based on a hypothetical, simplified highway project, illustrates
the modeling steps required for users to run the EMFAC2011-PL tool to develop projectspecific PM running exhaust emission factors using the simplified approach described
in Section 5.5 of the guidance.
As discussed in the guidance, application of the simplified approach and use of the
EMFAC2011-PL tool is only appropriate when the project-specific fleet age distribution
does not differ from the EMFAC2011 defaults and the project does not include start or
idling emissions. See Appendix H for an example of using the detailed approach to
modify a default age distribution.
Users will be able to generate running emission factors (in grams/vehicle-mile) in a
single EMFAC2011-PL run; multiple links and calendar years can also be handled within
one run. This example does not include the subsequent air quality modeling; refer to
Appendix E for an example of how to run an air quality model for a highway project for
PM hot-spot analyses.

G.2

PROJECT CHARACTERISTICS

The hypothetical highway project is located in Sacramento County, California. For

illustrative purposes, the project is characterized by a single link with an average link
travel speed for all traffic equal to 65 mph.1 Project-specific age distributions do not
differ from the EMFAC2011 defaults, so a simplified modeling approach using the
EMFAC2011-PL tool will be used to develop a link-specific PM2.5 emission rate.
The projects first full year of operation is assumed to be the year 2013. Through the
interagency consultation process, it is determined that 2015 should be the analysis year
(based on the projects emissions and background concentrations). The build scenario
2015 traffic data for this highway project shows that 25% of the total project VMT is
from trucks and 75% from non-trucks. This truck/non-truck fleet mix will be used to
post-process the EMFAC-PL output.
1

These are simplified data to illustrate the use of EMFAC2011; this example does not, for instance,
separate data by peak vs. off-peak periods, divide the project into separate links, or consider additional
analysis years, all of which would likely be required for an actual project.

G-1

G.3

DESCRIBING THE SCENARIO USING THE EMFAC2011-PL TOOL

Based on the project characteristics, it is first necessary to describe the modeling scenario
in the EMFAC2011-PL interface (see Exhibits G-1 and G-2).
Exhibit G-1. Basic Inputs in EMFAC2011-PL for the Hypothetical Highway Project
Step

Input Category

Input Data

Note

Vehicle Category
Scheme

Truck / Non-Truck
Categories

Provides rates for truck/non-truck

categories

Region type

County

Per Section 5.5.2 of the guidance

Region

Sacramento

Select from drop-down list

CalYr

2015

Select from drop-down list

Season

Annual

Select from drop-down list

Vehicle Category

ALL

Provides rates for HD and LD

Fuel Type

TOT

Does not generate separate rates for

gasoline and diesel

Speed

65 MPH

Select from drop-down list

G-2

Exhibit G-2. EMFAC2011-PL GUI Showing Selections Made for the Hypothetical
Highway Project

G-3

G.4 CALCULATING A LINK-SPECIFIC EMISSION RATE FROM

EMFAC2011-PL OUTPUT
After running EMFAC2011-PL, an output Excel file (Exhibit G-3) is produced in the
EMFAC2011-PL folder. From this file, emission rates are appropriately processed to
calculate a single link emission rate appropriate for dispersion modeling. This process is
described below.
Exhibit G-3. EMFAC2011-PL Output File

The next step is to extract the relevant emission rates for post-processing in a separate
Excel worksheet. For running emissions, the Total PM2.5 emission factor (EF) is
calculated as the sum of the running exhaust EF (Exhibit G-4), the brake wear EF, and
the tire wear EF (Exhibit G-5).

Exhibit G-4. Running Exhaust Rates

Exhibit G-5. Brake Wear and Tire Wear Rates

G-4

These rates are then summed separately for Trucks and Non-Truck categories (shown in
Exhibit G-6).
Exhibit G-6. Calculation of Truck and Non-Truck Total PM2.5 EF
Running
Exhaust EF

Tire wear EF

Break wear EF

Total PM2.5 EF

Non-trucks

0.0022297

0.0020026

0.0166726

0.020905

Trucks

0.0229593

0.0025758

0.0206886

0.046224

From the calculated Total PM2.5 EF, the truck and non-truck rates are then weighted
together based on the relative VMT for each vehicle type. In this example, trucks
account for 25% of VMT while non-trucks account for 75% of VMT. Exhibit G-7
demonstrates how the EFs are weighted to calculate a single link emission rate.
Exhibit G-7. Calculation of Total PM2.5 Link Emission Rate
Total
Emission
Rate

VMT adjustment

Weighted
Emission Rate

Non-trucks

0.020905

0.75

0.0156788

Trucks

0.046224

0.25

0.011556
0.027235

This completes the use of the EMFAC2011-PL tool to determine emissions factors for
this project using the simplified approach. The total running link emission factor of
0.027235 grams per vehicle-mile can be now be used in combination with link length and
link volume as inputs into the selected air quality model, as discussed in Section 7 of the
guidance.

G-5

Appendix H:
Example of Using EMFAC2011 to Develop Emission Factors
for a Transit Project
H.1

INTRODUCTION

The purpose of this appendix is to illustrate the modeling steps required for users to
develop PM idling emission factors for a hypothetical bus terminal project using
EMFAC2011. It also shows how to generate emission factors from EMFAC2011 for a
project that involves a limited selection of vehicle classes (e.g., urban buses) and an age
distribution that differs from the EMFAC2011 defaults.1 Because the project age
distribution differs from the EMFAC2011 defaults, use of the simplified approach and
EMFAC2011-PL tool is not appropriate. Instead, the detailed approach described in
Section 5.6 of the guidance will be used.
This example uses the Emfac mode in EMFAC2011-LDV to generate grams per
vehicle-hour (g/veh-hr) emission factors stored in the Summary Rate output file (.rts
file) suitable for use in the AERMOD air quality model. This example does not include
the subsequent air quality modeling; refer to Appendix F for an example of how to run
AERMOD for a transit project for PM hot-spot analyses.
The assessment of a bus terminal or other non-highway project can involve modeling two
different categories of emissions: (1) the idle and/or start emissions at the project site, and
(2) the running exhaust emissions on the links approaching and departing the project site.
As discussed in Section 5.7.4, EMFAC2011-LVD allows users to generate emission
factors for all of these in a single run. This appendix walks through the steps to model
idle emissions for this hypothetical project. Users will be able to generate idle emission
factors in a single EMFAC2011-LDV model run; multiple calendar years can also be
handled within one model run. As described in the main body of this section, each run
will be specific to either PM10 or PM2.5; however, this example is applicable to both.
This example is intended to help project sponsors understand how to create representative
idle emission factors based on the best available information supplied by EMFAC2011,
thus providing an example of how users may have to adapt the information in
EMFAC2011 to their individual project circumstances.
To estimate idle emissions at a terminal project, the main task will involve modifying the
default vehicle populations and VMT distribution, by vehicle, fuel, and age distribution
embedded in EMFAC2011 to reflect the project-specific bus fleet.

This is a highly simplified example showing how to employ EMFAC2011 to calculate idle emission
factors for use in air quality modeling. An actual project would be expected to be significantly more
complex.

H-1

H.2

PROJECT CHARACTERISTICS

A PM10 hot-spot analysis is conducted for a planned bus terminal project in Sacramento
County, California. The projects first full year of operation is assumed to be the year
2013. Through the interagency consultation process, it is determined that 2015 should be
the analysis year (based on the projects emissions and background concentrations). The
PM analysis is focused on idle emissions from buses operated in the terminal.
Additionally, all buses in this example operate using diesel fuel and are ten years old (age
10).
It is determined that the appropriate EMFAC2011 vehicle category for the urban transit
buses included in the project is UBUS-DSL, which is a type found in the
EMFAC2011-LDV module (see Section 5.6.2 of the guidance). Therefore, we will be
applying the EMFAC2011-LDV procedure described in Section 5.7 of the guidance.

H.3

PREPARING EMFAC2011 BASIC INPUTS

Based on the project characteristics, basic inputs and default settings in EMFAC2011
LDV are first specified (see Exhibit H-1). These basic inputs are similar to those
specified for highway projects. To generate idle emission factors for urban transit buses
(UBUS-DSL) from EMFAC2011-LDV, a speed bin of 5 mph must be selected in the
EMFAC2011-LDV interface.
Exhibit H-1. Basic Inputs in EMFAC2011-LDV for the Hypothetical Highway
Project
Step
1

Input Category
Geographic Area
Calculation Method

Input Data

Note

County Sacramento
Use Average

Select from drop-down list

Default (not visible in the
EMFAC2011-LDV user interface)
Select from drop-down list
Select from drop-down list
Define default title in the
EMFAC2011-LDV user interface
Include all model years
Include all vehicle classes
Include all pre-defined I/M program
parameters
Delete all default temperature bins
and input 60
Delete all default relative humidity
bins and input 70
Include speed bin of 5 mph
Select from EMFAC2011-LDV user
interface
Select from EMFAC2011-LDV user
interface

2
3
4

Calendar Years
Season or Month
Scenario Title

2015
Annual
Use default

5
6
7

Model Years
Vehicle Classes
I/M Program Schedule

Use default
Use default
Use default

Temperature

Relative Humidity

70%RH

10
11

Speed
Emfac Rate Files

Use default
Summary Rates (RTS)

12

Output Particulate

PM10

60F

H-2

H.4 EDITING EMFAC2011-LDV DEFAULT VMT AND POPULATION TO

REFLECT PROJECT-SPECIFIC BUS FLEET
To generate idle emission factors that reflect the bus terminal project data, vehicle
population and VMT by vehicle class must be modified in the EMFAC2011-LDV user
interface. The EMFAC2011 module has data limitations regarding idle emissions:
among the available vehicle classes in EMFAC2011-LDV, idle emission factors are
available only for the LHDT1, LHDT2, MHDT, HHDT, School Buses, and Other Buses
vehicle types. Although EMFAC2011-LDV does not explicitly provide idle emission
factors for the UBUS-DSL class (the class most typically associated with urban transit
buses), as described in Section 5.7.4 of the guidance, the 5 mph emission factors may be
used to represent transit buses by multiplying the rate (grams/vehicle-mile) by 5 miles per
hour, resulting in a grams/veh-hour rate.
Since the fuel use and age distribution of the bus fleet are known, it is necessary to edit
the EMFAC2011-LDV program constants (defaults) to reflect this information. First,
VMT By Vehicle and Fuel will be edited to reflect entirely diesel Urban Bus operation
by changing gasoline Urban Bus VMT to 1 (because 0 will cause an error). Next,
Population By Vehicle and Fuel will be edited to reflect entirely diesel Urban Bus
operation by changing the number of gasoline Urban Buses to 1. Finally, the
Population By Vehicle/Fuel/Age will be edited to reflect the known Urban Bus age
distribution by preserving the number of Urban Buses age 10, and changing the number
of buses of all other ages to 0 (note this must be done by exporting the default age
distribution to Excel, as explained in Exhibit H-4).
As shown in Figure H-2, VMT is edited to reflect only diesel operation by Urban Buses.
For this example bus terminal, a very low value (1) is entered into the interface for
gasoline Urban Buses to represent the project-specific fuel data.

H-3

Exhibit H-2. Changing EMFAC2011-LDV Default VMT to Reflect Project-Specific

Fuel Use

Default EMFAC2011-LDV data before modification

H-4

Modified EMFAC2011-LDV data

H-5

Next, in Exhibit H-3 the default EMFAC2011-LDV vehicle population is similarly edited
to reflect an entirely diesel-fueled bus fleet.
Exhibit H-3. Changing EMFAC2011-LDV Default Population to Reflect ProjectSpecific Fuel Use

Default EMFAC2011-LDV data before modification

H-6

Modified EMFAC2011-LDV data

Finally, in Exhibit H-4, it is necessary to export the default age distribution for
modification in Excel. The Urban Bus type has a default age distribution that does not
match the project. To change the default, zeros (0) are entered for all ages except
Age10 to reflect a fleet that is entirely 10 year-old buses. The table is copied and
pasted back into the EMFAC2011-LDV module.

H-7

Exhibit H-4. Changing EMFAC2011-LDV Default Age Distribution to Reflect

Project-Specific Bus Roster

H-8

Default EMFAC2011-LDV age distribution before modification

Modified age distribution

H-9

Modified EMFAC2011-LDV data

H-10

H.6

PROCESSING IDLE EMISSION FACTORS

Urban Buses (UBUS) is the vehicle class best representing transit buses in this
hypothetical bus terminal project. After the EMFAC2011-LDV run is completed, the
project-specific idle exhaust emission factors are presented in Table 1 of the output
Summary Rates file (.rts file) as shown in Exhibit H-5.
Exhibit H-5. EMFAC2011-LDV Output

As discussed, the Urban Bus type does not have an explicit idle emission rate. Therefore,
the 5 mph emission rate will be used to represent idle operation. As highlighted in
Exhibit H-5, the PM10 5 mph exhaust emission factor for the Urban Buses is 0.106
grams/veh-mile. In order to produce a grams/veh-hour emission factor for use in
AERMOD, this emission factor (0.106 grams/vehicle-mile) is multiplied by 5 miles per
hour. The resulting rate is 0.53 grams/veh-hour. Note that buses typically do not idle for
the entire hour, so this rate should be applied to the actual number of bus idle-hours (i.e.,
[grams/vehicle-hour] x [idling time of each vehicle in fraction of an hour] x [number of
vehicles]) expected in the project area to produce an updated grams/hour rate.
This completes the use of EMFAC2011-LDV for determining idle emission factors for
this project. The grams/hour idle rate can now be input into AERMOD as discussed in
Section 7 of the guidance.

H-11

Appendix I:
Estimating Locomotive Emissions
I.1

INTRODUCTION

This appendix describes how to quantify locomotive emissions when they are a
component of a transit or freight terminal or otherwise a source in the project area being
modeled. Note that state or local air quality agencies may have experience modeling
locomotive emissions and therefore could be of assistance when quantifying these
emissions for a PM hot-spot analysis.
Generally speaking, locomotive emissions can be estimated in the following manner:
1. Determine where in the project area locomotive emissions should be estimated.
2. Determine when to analyze emissions.
3. Describe the locomotive activity within the project area, including:
The locomotives present in the project area (the locomotive roster); and
The percentage of time each locomotive spends in various throttle settings
(the duty cycle).
4. Calculate locomotive emissions using either:

Horsepower rating and load factors, or

Fuel consumption data.1

The estimated locomotive emission rates that result from this process would then be used
for air quality modeling. The interagency consultation process must be used to evaluate
and choose the model and associated method and assumptions used for quantifying
locomotive emissions for PM hot-spot analyses (40 CFR 93.105(c)(1)(i)).

I.2

DETERMINING WHERE IN THE PROJECT AREA LOCOMOTIVE

EMISSIONS SHOULD BE ESTIMATED

Under certain circumstances, it is appropriate to model different locations within the

project area as separate sources to characterize differences in locomotive type and/or
activity appropriately. This step is analogous to dividing a highway project into links (as
described in Sections 4.2 and 5.2 of the guidance) and improves the accuracy of
emissions modeling and subsequent air quality modeling. For example, in an intermodal
terminal, emissions from a mainline track (which will have a large percentage of higher
1

These are the two methods described in this appendix; others may be possible. See Appendix I.5 for
details.

I-1

speed operations with little idling) should be estimated separately from the associated
passenger or freight terminal (which would be expected to experience low speed
operations and significant idling).
The following activities are among those typically undertaken by locomotives and are
candidates for being modeled as separate sources if they occur at different locations
within the project area:
Idling within the project area;
Trains arriving into, or departing from, the project area (e.g., terminal arrival and
departure operations);
Testing, idling, and service movements in maintenance areas or sheds;
Switching operations;
Movement of trains passing through, but not stopping in, the project area.
The project area may also be divided into separate sources if it includes several different
locomotive rosters (see Appendix I.4.1, below)

I.3

DETERMINING WHEN TO ANALYZE EMISSIONS

The number of hours and days that have to be analyzed depends on the range of activity
expected to occur within the project area. For rail projects where activity varies from
hour to hour, day to day, and possibly month to month, it is recommended that, at a
minimum, project sponsors calculate emissions based on 24 hours of activity for both a
typical weekday and weekend day and for four representative quarters of the analysis
year when comparing emissions to all PM2.5 NAAQS.2 For projects in areas that violate
only the 24-hour PM10 or PM2.5 NAAQS, the project sponsor may choose to model only
one quarter, in appropriate cases. See Section 3.3.4 of the guidance for further
information.
These resulting emission rates should be applied to AERMOD and used to calculate
design values to compare with the applicable PM NAAQS as described in Sections 7
through 9 of the guidance.

I.4

DESCRIBING THE LOCOMOTIVE ROSTERS AND DUTY CYCLES

Before calculating locomotive emission rates, it is necessary to know what locomotives

are present in the locations being analyzed in the project area (see Appendix I.2, above)
and what activities these locomotives are undertaking at these locations. This data will
impact how emissions are calculated.
2

If there is no difference in activity between weekday and weekend activity, it may not be necessary to
examine weekend day activity separately. Similarly, if there is no difference in activity between quarters,
emission rates can be determined for one quarter, which can then be used to represent every quarter of the
analysis year.

I-2

I.4.1

Locomotive rosters

Because emissions can vary significantly depending on a locomotives make, model,

engine, and year of engine manufacture (or re-manufacture), it is important to know what
locomotives are expected to be operating within the project area. Project sponsors should
develop a locomotive roster (i.e., a list of each locomotives make, model, engine, and
year) for the locomotives that will be operating within the specific project area being
analyzed. The more detailed the locomotive roster, the more accurate the estimated
emissions will be.
In some cases, it will be necessary to develop more than one locomotive roster to reflect
the operations in the project area accurately (for example, switcher locomotives may be
confined to one portion of a facility and therefore may be represented by their own
roster). In these situations, users should model areas with different rosters as separate
sources to account for the variability in emissions (see Appendix I.2).
I.4.2

Locomotive duty cycles

Diesel locomotive engine power is controlled by notched throttles; idling, braking, and
moving the locomotive is conducted by placing the throttle in one of several available
notch settings.3 A locomotives duty cycle is a description of how much time, on
average, the locomotive spends in each notch setting when operating. Project sponsors
should use the latest locally-generated or project-specific duty cycles whenever possible;
this information may be available from local railway authorities or the state or local air
agency.4 The default duty cycles for line-haul and switch locomotives, found in Tables 1
and 2 of 40 CFR 1033.530 (EPAs regulations on controlling emissions from
locomotives), should be used only if they adequately represent the locomotives that will
be present in the project area and no local or project-specific duty cycles are available.

I.5

CALCULATING LOCOMOTIVE EMISSIONS

Once a projects locomotive rosters and respective duty cycles have been determined,
locomotive emissions can then be calculated for each part of the project area using either
(1) horsepower rating and load factors, or (2) fuel consumption data. These two methods
are summarized below. Unless otherwise determined through consultation, only one
method should be used for a given project.

A diesel locomotive typically has eight notch settings for movement (run notches), in addition to one or
more idle or dynamic brake notch settings. Dynamic braking is when the locomotive engine, rather than
the brake, is used to control speed.
4
The state or local air agency may have previously developed locally-appropriate duty cycles for emissions
inventory purposes.

I-3

I.5.1

Finding emission factors

Regardless of method chosen, locomotive emissions factors will be needed for the
analysis. Locomotive emission factors depend on the type of engine, the power rating of
the locomotive (engine horsepower), and the year of engine manufacture (or re
manufacture). Default PM10 emission factors for line-haul and switch locomotives can be
obtained from Tables 1 and 2 of EPAs Emission Factors for Locomotives, EPA-420
F-09-025 (April 2009).5 These PM10 emission factors are in grams/horsepower-hour and
can easily be converted to PM2.5 emission factors. However, these are simply default
values; locomotive-specific data may be available from manufacturers and should be
used whenever possible. In addition, see Appendix I.5.4 for other variables that must be
considered when determining the appropriate locomotive emission factors.
Note that the default locomotive emission factors promulgated by EPA may change over
time as new information becomes available. The April 2009 guidance cited above
contains the latest emission factors as of this writing. Project sponsors should consult the
EPAs website at: www.epa.gov/otaq/locomotives.htm for the latest locomotive default
emission factors and related guidance.
I.5.2

Calculating emissions using horsepower rating and load factors

One way locomotive emissions can be calculated is to use PM2.5 or PM10 locomotive
emission factors, the horsepower rating of the engines found on the locomotive roster,
and engine load factors (which are calculated from the duty cycle).
Calculating Engine Load Factors
The horsepower of the locomotive engines, including the horsepower used in each notch
setting, should be available from the rail operator or locomotive manufacturer.
Locomotive duty cycle data (see Appendix I.4.2) can then be used to determine how
much time each locomotive spends in each notch setting, including braking and idling.
An engines load factor is the percent of maximum available horsepower it uses over
the course of its duty cycle. In other words, a load factor is the weighted average power
used by the locomotive divided by the engines maximum rated power.6 Load factors can
be calculated by summing the actual horsepower-hours of work generated by the engine
in a given period of time and dividing it by the engines maximum horsepower and the
hours during which the engine was being used, with the result expressed as a percentage.
For example, if a 4000 hp engine spends one hour at full power (generating 4000 hp-hrs)
and one hour at 50 percent power (generating 2000 hp-hrs), its load factor would be 75
5

Table 1 of EPAs April 2009 document includes default emission factors for higher power cycles
representative of general line-haul operation; Table 2 includes emission factors for lower power cycles used
for switching operations. The April 2009 document also includes information on how to convert PM 10
emission factors for PM2.5 purposes. Note that Table 6 (PM10 Emission Factors) should not be used for PM
hot-spot analyses, since these factors are national fleet averages rather than emission factors for any
specific project.
6
Weighted average power in this case is the average power used by the locomotive weighted by the time
spent in each notch, as explained further below.

I-4

percent (6000 hp-hrs 4000 hp 2 hrs). Note that, in this example, it would be
equivalent to calculate the load factor using the percent power values instead: ((100% * 1
hr) + (50% * 1 hr) 2 hrs = 75%). To simplify emission factor calculations, it is
recommended that locomotive activity be generalized into the operational categories of
moving and idling, with separate load factors calculated for each.
An engines load factor is calculated by completing the following steps:
Step 1. Determine the number of notch settings the engine being analyzed has and the
horsepower used by the engine in each notch setting.7 Alternatively, as described above,
the percent of maximum power available in each notch could instead be used.
Step 2. Identify the percentage of time the locomotive being analyzed spends in each
notch setting based on its duty cycle (see Appendix I.4.2).
Step 3. To make emission rate calculations easier, it is useful to calculate two separate
load factors for an engine: one for when the locomotive is idling and one for when it is
moving.8 Therefore, the percentage of time the locomotive spends in each notch (from
Step 2) needs to be adjusted so that all idling and all moving notches are considered
separately. For example, if a locomotive has just one idle notch setting, it spends 100%
of its idling time in that setting, even if it only idles during part of its duty cycle. While
calculating the time spent idling will usually be simple, for the non-idle (moving) notch
settings some additional adjustment to the locomotives duty cycle percentages will be
required to determine the time spent in each moving notch as a fraction of total time spent
moving, disregarding any time spent idling.
For example, say a locomotive spends 30% of its time idling and 70% of its time moving
over the course of its duty cycle and that 15% of this total time (idling and moving
together) is spent in notch 2. When calculating the moving load factor, this percentage
needs to be adjusted to determine what fraction of just the 70% of time spent moving is
spent in notch 2. In this example, 15% of the total duty cycle spent in notch 2 would
equal 21.4% (15% * 100% 70%) of the locomotives time when it is not at idle; that is,
whenever it is moving, this locomotive spends 21.4% of its time in notch 2. This
calculation is repeated for each moving notch setting. The result will be the fraction of
time spent in each notch when considering idle and moving modes of operation
separately.
Step 4. The next step is to calculate what fraction of maximum available horsepower is
being used based on the time spent in each notch setting as was calculated in Step 3. This
is determined by summing the product of the percentage of time spent in each notch
(calculated in Step 3) by the horsepower generated by the engine at that notch setting
(determined in Step 1). For example, if the locomotive with a rated engine power of
7

For locomotives that are equipped with multiple dynamic braking notches and/or multiple idle notches, it

may be necessary to assume a single dynamic braking notch and a single idle notch, depending on what

information is available about the particular engine.

8
In this case, moving refers to all non-idle notch settings: that is, dynamic braking and all run notches.

I-5

3000 hp spends 21.4% of its moving time in notch 2 and 78.6% of its moving time in
notch 6, and is known to generate 500 hp while in notch 2 and 2000 hp while in notch 6,
then its weighted average power would be 1679 hp (107 hp (500 hp * 0.214) + 1572 hp
(2000 hp * 0.786) = 1679 hp).
Step 5. The final step is to determine the load factors. This is done by dividing the
weighted average horsepower (calculated in Step 4) by the maximum engine horsepower.
For idling, this should be relatively simple. For example, if there is one idle notch setting
and it is known that a 4000 hp engine uses 20 hp when in its idle notch, then its idle load
factor will be 0.5% (20 hp 4000 hp). To determine the load factor for all power
notches, the weighted horsepower calculated in Step 4 should be divided by the total
engine horsepower. For example, if the same 4000 hp engine is determined to use an
average of 1800 hp while in motion (as determined by adjusting the horsepower by the
time spent in each moving notch setting in Step 4), then the moving load factor would
be 45% (1800 hp 4000 hp).
The resulting idling and moving load factors represent the average amount of the total
engine horsepower the locomotive is using when idling and moving, respectfully. These
load factors can then be used to modify PM emission factors and generate emission rates
as described below.
Generating Emission Rates Based on Load Factors
As noted above, EPAs Emission Factors for Locomotives provides emission factors in
grams/brake horsepower-hour. This will also likely be the case with any specific
emission factors obtained from manufacturers specifications. These units can be
converted into grams/second (g/s) emission rates by using the load factor on the engines
and the time spent in each operating mode, as described below.
The first step is to adjust the PM emission factors to reflect how the engine will actually
be operating.9 This is done by multiplying the appropriate PM emission factor by the
idling and moving load factors calculated for that particular engine.10 Next, to determine
the emission rate, this adjusted emission factor is further multiplied by the amount of
time the locomotive spends idling and moving while in the project area.11
For example, if the PM emission factor known to be 0.18 g/bhp-hr, the engine being
analyzed has an idling load factor of 0.5%, and the locomotive is anticipated to idle 24
minutes per hour in the project area, then the resulting emission rate would be 0.035
grams/hour (0.18 g/bhp-hr * 0.5% * 0.4 hours).

Because combustion characteristics of an engine vary by throttle notch position, it is appropriate to adjust

the emission factor to reflect the average horsepower actually being used by the engine.

10
Project sponsors are reminded to check www.epa.gov/otaq/locomotives.htm to ensure the latest default

emission factors for idle and moving emissions are being used.

11
Note that this may or may not match up with the idle and moving time as described by the duty cycle

used to calculate the load factors, depending on how project-specific that duty cycle is.

I-6

Emission rates need to be converted into g/s for use by AERMOD, as described further in
Sections 7 through 9 of the guidance. These calculations should be repeated until the
entire locomotive roster is represented in each part of the project area being analyzed.
Appendix I.7 provides an example of calculating g/s locomotive emission rates using this
methodology.
I.5.3

Calculating emissions using fuel consumption data

Another method to calculate locomotive emissions involves using fuel consumption data.
Chapter 6.3 of EPAs Procedure for Emission Inventory Preparation -- Volume IV:
Mobile Sources (reference information provided in Appendix I.6, below) is a useful
reference and should be consulted when using this method.
Note that, for this method, it may be useful to scale down data already available to the
project sponsor. For example, if rail car miles/fuel consumption is known for trains
operating in situations identical to those being estimated in the project area, this data can
be used to estimate fuel consumption rates for a defined track length within the project
area.
Calculating Average Fuel Consumption
Locomotive fuel consumption is specific to a particular locomotive engine and the
throttle (notch) setting it is using. Data on the fuel consumption of various engines at
different notch settings can often be obtained from the locomotive or engine
manufacturers specifications. When only partial data is available (e.g., only data for the
lowest and highest notch settings are known), interpolation combined with best available
engineering judgment can be used to determine fuel consumption at the intermediate
notch settings.
A locomotives average fuel consumption can be calculated by determining how long
each locomotive is expected to spend in each notch setting based on its duty cycle (see
Appendix I.4.2). This data can be aggregated to generate an average fuel consumption
rate for each locomotive type. See Chapter 6.3 of Volume IV for details on how to
generate this data based on a specific locomotive roster and duty cycle.
Once the average fuel consumption rates have been determined, they should be
multiplied by the appropriate emission factors to determine a composite average hourly
emission rate for each engine in the roster. Since the objective is to determine an average
fuel consumption rate for the entire locomotive roster, this calculation should be repeated
for each engine on the roster at each location analyzed.
If several individual sources will be modeled at different sections of the project area as
described in Appendix I.2, train schedule data should be consulted to determine the hours
of operation of each locomotive within each section of the project area. Hourly emission
rates per locomotive should then be multiplied by the number of hours the locomotive is

I-7

operating, for each hour of the day in each section of the project area to provide average
hourly emission rates for each section of the project. These should then be converted to
grams/second for use in AERMOD, as described further in Sections 7 through 9 of the
guidance.
Examples of calculating locomotive emissions using this method can be found in Chapter
6 of Volume IV.
I.5.4

Factors influencing locomotive emissions and emission factors

The following considerations will influence locomotive emissions regardless of the

method used and should be examined when determining how to characterize locomotives
for emissions modeling or when choosing the appropriate emission factors:
Project sponsors should be aware of the emission reductions that would result
from remanufacturing existing locomotives (or replacing existing locomotives
with new locomotives) that meet EPAs Tier 3 or Tier 4 emission standards when
they become available. The requirements that apply to existing and new
locomotives were addressed in EPAs 2008 rulemaking entitled Control of
Emissions of Air Pollution from Locomotive Engines and Marine CompressionIgnition Engines Less Than 30 liters Per Cylinder (73 FR 37095). Beginning in
2012 all locomotives will be required to use ultra-low sulfur diesel fuel (69 FR
38958). Additionally, when existing locomotives are remanufactured, certified
remanufacture systems will have to be installed to reduce emissions. Beginning
in 2011, new locomotives must meet tighter Tier 3 emission standards. Finally,
beginning in 2015 even more stringent Tier 4 emission standards for new
locomotives will begin to be phased in.
For locomotives manufactured before 2005, a given locomotive may be in one of
three possible configurations, depending on when it was last remanufactured: (1)
uncertified; (2) certified to the standards in 40 CFR Part 92; or (3) certified to the
standards in 40 CFR Part 1033. Each of these configurations should be treated as
a separate locomotive type when conducting a PM hot-spot analysis.
Emissions from locomotives certified to meet Family Emission Limits (FELs)
may differ from the emission standard identified on the engines Emission
Control Information label. Rail operators will know if their locomotives
participate in this program. Any locomotives in the project area participating in
this program should be identified so that the actual emissions from the particular
locomotives being analyzed are considered in the analysis, rather than the family
emissions level listed on their FEL labels.

I-8

I.6

AVAILABLE RESOURCES

These resources and websites should be checked prior to beginning any PM hot-spot
analysis to ensure that the latest data (such as emission factors) are being used:
Emission Factors for Locomotives, EPA-420-F-09-025 (April 2009). Available
online at: www.epa.gov/otaq/locomotives.htm.
Chapter 6 of Procedure for Emission Inventory Preparation - Volume IV: Mobile
Sources. Available online at: www.epa.gov/OMS/invntory/r92009.pdf. Note
that, as of this writing, the emission factors listed in Volume IV have been
superseded by the April 2009 publication listed above for locomotives certified to
meet current EPA standards.12
Control of Emissions from Idling Locomotives, EPA-420-F-08-014, March
2008. Available online at:
www.epa.gov/otaq/regs/nonroad/locomotv/420f08014.htm.
See Section 10 of the guidance for additional information regarding potential
locomotive emission control measures.

I.7

EXAMPLE OF CALCULATING LOCOMOTIVE EMISSION RATES USING

HORSEPOWER RATING AND LOAD FACTOR ESTIMATES

The following example demonstrates how to estimate locomotive emissions using the
engine horsepower rating/load factor method described in Appendix I.5.2.
The hypothetical proposed project in this example includes the construction of an
intermodal terminal in an area that is designated as nonattainment for both the 1997
annual PM2.5 NAAQS and the 2006 24-hour PM2.5 NAAQS. The terminal in this
example is to be completed and operational in 2013. The hot-spot analysis is performed
for 2015, because it is determined through interagency consultation that this will be the
year of peak emissions, when considering the projects emissions and the other emissions
in the project area.
In this example, the operational schedule anticipates that 32 locomotives will be in the
project area over a 24-hour period, with 16 locomotives in the project area during the
peak hour. Based on the schedule, it is further determined that while in the project area
each train will spend 540 seconds idling and 76 seconds moving.

12

Although the emission factors have been superseded, the remainder of the Volume IV guidance remains
in effect.

I-9

The locomotive PM2.5 emissions are calculated based on horsepower rating and load
factors.
I.7.1

Calculate idle and moving load factors

As described in I.5.2, the project sponsor uses a series of steps to calculate load factors.
These steps are described below and the results from each step are shown in table form in
Exhibit I-1.
Step 1: The project sponsor first needs some information about the locomotives expected
to be operating at the terminal in the analysis year.
For each locomotive, the horsepower used by the locomotive in each notch setting as well
as under dynamic braking and at idle must be determined. For the purpose of this
example it is assumed that all of the locomotives that will serve this terminal are very
similar: all use the same horsepower under each of operating conditions, and all have
only one idle and dynamic braking notch setting. The horsepower generated at each
notch setting is obtained from the engine specifications (see second column of Exhibit I
1). In this case, the rated engine horsepower is 4000 hp (generated at notch 8).
Step 2: The next step is to determine the average amount of time that the locomotives
spend in each notch and expressing the results as a percentage of the locomotives total
operating time. In this example, it is determined that, based on their duty cycle, the
locomotives that will service this terminal spend 38% of their time idling and 62% of
their time in motion in one of the eight run notch settings or under dynamic braking. The
percentage of time spent in each notch is shown in the third column of Exhibit I-1.
Step 3: To make emission factor calculations easier, it is decided to calculate separate
idling and moving load factors. The next step, then, is for the project sponsor to calculate
the actual percentage of time that the locomotives spend in each notch, treating idling and
moving time separately. This is done by excluding the time spent idling and
recalculating the percentage of time spent in the other notches (i.e., dynamic braking and
each of the eight notch settings) so that the total time spent in non-idle notches adds to
100%. The results are shown in the fourth column of Exhibit I-1.
Step 4: The next step is to calculate the weighted average horsepower for this engine
using the horsepower generated in each notch and the percentage of time spent in each
notch as adjusted in Step 3. For locomotives that are idling, this is simply the horsepower
used at idle. For the other notches, the actual horsepower for each notch is determined by
multiplying the horsepower generated in a given notch (determined in Step 1) by the
actual percentage of time that the locomotive is in that notch, as adjusted (calculated in
Step 3). The results are shown in the fifth column of Exhibit I-1.
Step 5: The final step in this part of the analysis is to determine the idle and moving load
factors. The idle load factor is just the horsepower generated at idle divided by the
maximum engine horsepower, with the result expressed as a percentage. To determine

I-10

the moving load factor, the weighted average horsepower for all non-idle notches
(calculated in Step 4) is divided by the maximum engine horsepower, with the result
expressed as a percentage. The final column of Exhibit I-1 shows the results of these
calculations, with the idling and moving load factors highlighted.
Exhibit I-1. Calculating Locomotive Load Factors

Notch
Setting

14

38.0%

100.0%

14.0

136

12.5%

20.2%

27.5

224
484
984
1149
1766
2518
3373
4,000

6.5%
6.5%
5.2%
4.4%
3.8%
3.9%
3.0%
16.2%
62.0%

10.5%
10.5%
8.4%
7.1%
6.1%
6.3%
4.8%
26.1%
100.0%

23.5
50.8
82.7
81.6
107.8
158.6
161.9
1,044.0
1,752.4

Step 1:
Horsepower
(hp)
used in
notch

Idling load factor:

Idle
Moving load factor:
Dynamic
Brake
1
2
3
4
5
6
7
8
Total

I.7.2

Step 2:
Average %
time spent
in notch

Step 3:
Reweighted
time spent in
each notch
(adjusted so
that non-idle
notches add to
100%)

Step 4:
TimeStep 5:
weighted
Load
hp used,
factors
based on
(idle and
time
moving)
spent in
notch

0.4%

43.8%

Using the load factors to calculate idle and moving emission rates

Now that the idle and moving load factors have been determined, the gram/second (g/s)
emission rates can be calculated for the idling and moving locomotives.
First, the project sponsor would determine how many locomotives are projected to be
idling and how many are projected to be in motion during the peak hour of operation and
over a 24-hour period. As previously noted, it is anticipated that 32 locomotives will be
in the project area over a 24-hour period, with 16 locomotives in the project area during
the peak hour. It was further determined that, while in the project area, each train will
spend 540 seconds idling and 76 seconds moving.
For the purpose of this example, it has been assumed that each locomotive idles for the
same amount of time and is in motion for the same amount of time. Note that, in this
case, the number of locomotives considered moving will be double the actual number

I-11

of locomotives present in order to account for the fact that each locomotive moves twice
through the project area (as it arrives and departs the terminal).
Next, the project sponsor would determine the PM2.5 emission factor to be used in this
analysis for 2015. These emission factors can be determined from the EPA guidance
titled Emission Factors for Locomotives.
Table 1 of Emission Factors for Locomotives presents PM10 emission factors in terms
of grams/brake horsepower-hour (g/bhp-hr) for line haul locomotives that are typically
used by commuter railroads. Emission factors are presented for uncontrolled
locomotives, locomotives manufactured to meet Tier 0 through Tier 4 emission
standards, and locomotives remanufactured to meet more stringent emission standards.
Its important to determine the composition of the fleet of locomotives that will use the
terminal in the year that is being analyzed so that the emission factors in Table 1 can be
used in the calculations. This information would be available from the railway operator.
In this example, we are assuming that all of the locomotives meet the Tier 2 emission
standard. However, an actual PM hot-spot analysis would likely have a fleet of
locomotives that meets a combination of these emission standards. The calculations
shown below would have to be repeated for each different standard that applies to the
locomotives in the fleet.
The final step in these calculations is to use the information shown in Exhibit I-1 and the
other project data collected to calculate the PM2.5 emission rates for idling and moving
locomotives during both the peak hour and over a 24-hour basis.13
Calculating Peak Hour Idling Emissions
The following calculation would be used to determine the idling emission rate during the
peak hour of operation:14
PM2.5 Emission Rate = (16 trains/hr) * (1 hr/3,600 s) * (540 s/train) * (4,000 hp) *
(0.004) * (0.18 g/bhp-hr) * (1 hr/3,600 s) * (0.97)
PM2.5 Emission Rate = 0.0019 g/s
Where:
Trains per hour = 16 (number of trains present in peak hour)
Idle time per train = 540 s (from anticipated schedule)
Locomotive horsepower = 4,000 hp (from engine specifications)
Idle load factor = 0.004 (0.4%, calculated in Exhibit I-1)

13

Peak hour emission rates will not be necessary for all analyses; however, for certain projects that involve
very detailed air quality modeling analyses, peak hour emission rates may be necessary to more accurately
reflect the contribution of locomotive emissions to air quality concentrations in the project area.
14
Note that, for the calculations shown here, any units expressed in hours or days need to be converted to
seconds since a g/s emission rate is required for AERMOD.

I-12

Tier 2 Locomotive Emission Factor = 0.18 g/bhp-hr (from Emission

Factors for Locomotives)
Ratio of PM2.5 to PM10 = 0.97 (from Emission Factors for Locomotives)

Calculating 24-hour Moving Emissions

Similarly, the following equation would be used to calculate the moving emission rate for
the 24-hour period:
PM2.5 Emission Rate = (64 trains/day) * (76 s/train) * (1 day/86,400 s) * (4,000 hp) *
(0.438) * (0.18 g/bhp-hr) * (1hr/3,600 s) * (0.97)
PM2.5 Emission Rate = 0.0048 g/s
Where:
Trains per day = 64 (double the actual number of trains present over 24
hours to account for each train moving twice through the project area)
Moving time per train = 76 s (from anticipated schedule)
Locomotive horsepower = 4,000 hp (from engine specifications)
Moving load factor = 0.438 (43.8%, calculated in Exhibit I-1)
Tier 2 Locomotive Emission Factor = 0.18 g/bhp-hr (from Emission
Factors for Locomotives)
Ratio of PM2.5 to PM10 = 0.97 (from Emission Factors for Locomotives)
A summary of the variables used in the above equations and the resulting emission rates
can be found in Exhibit I-2, below.
Exhibit I-2. PM2.5 Locomotive Emission Rates

Operational
Mode

Idle
Moving

Number of
Locomotives

Peak
hour
16
32

24
hours
32
64

Time/
Train

PM2.5
Emission
Factor

Calculated
Peak Hour
Emission Rate

Calculated
24-hour
Emission
Rate

(s)

(g/bhp-hr)

(g/s)

(g/s)

540 0.18
76 0.18

0.0019
0.057

0.00016
0.0048

These peak and 24-hour emission rates can now be used in air quality modeling for the
project area, as described in Sections 7 through 9 of the guidance.
Note that, since this area is designated as nonattainment for both the 1997 annual PM2.5
NAAQS and the 2006 24-hour PM2.5 NAAQS, the results of the analysis will be
compared to both NAAQS (see Section 3.3.4 of the guidance). Since the area is in
nonattainment of the annual PM2.5 NAAQS, all four quarters will need to be included in

I-13

the analysis to estimate a years worth of emissions. If there is no change in locomotive

activity across quarters, the emission rates calculated here could be used for each quarter
of the year (see Appendix I.3).

I-14

Appendix J:
Additional Reference Information on Air Quality Models and
Data Inputs
J.1

INTRODUCTION

This appendix supplements Section 7s discussion of air quality models. Specifically,

this appendix describes how to configure AERMOD and CAL3QHCR for PM hot-spot
analysis modeling, as well as additional information on handling the data required to run
the models for these analyses. This appendix is not intended to replace the user guides
for air quality models, but discuss specific model inputs, keywords, and formats for PM
hot-spot modeling. This appendix is organized so that it references the appropriate
discussions in Section 7 of the guidance.

J.2

SELECTING AN APPROPRIATE AIR QUALITY MODEL

The following discussion supplements Section 7.3 of the guidance and describes how to
appropriately configure AERMOD and CAL3QHCR when completing a PM hot-spot
analysis. Users should also refer to the model user guides, as appropriate.
J.2.1

Using AERMOD for PM hot-spot analyses

There are no specific commands unique to transportation projects that are necessary when
using AERMOD. By default, AERMOD produces output for particulate matter in units
of micrograms per cubic meter of air (g/m3). All source types in AERMOD require that
emissions are specified in terms of emissions per unit time, although AREA-type sources
also require specification of emissions per unit time per unit area. AERMOD has no
specific traffic queuing mechanisms. Emissions output from MOVES, EMFAC, AP-42,
and other types of methods should be formatted as described in the AERMOD User
Guide.1
J.2.2

Using CAL3QHCR for PM hot-spot analyses

CAL3QHCR is an extension of the CAL3QHC model that allows the processing of a full
year of hourly meteorological data, the varying of traffic-related inputs by hour of the
week, and calculation of long-term average concentrations. It also will display the five
highest concentration days for the time period being modeled. Emissions output from
MOVES, EMFAC, AP-42, and other emission methods should be formatted as described

Extensive documentation is available describing the various components of AERMOD, including user
guides, model formulation, and evaluation papers. See EPAs SCRAM website for AERMOD
documentation: www.epa.gov/scram001/dispersion_prefrec.htm#aermod.

J-1

in the CAL3QHCR User Guide.2 In addition, the following guidance is provided when
using CAL3QHCR for a PM hot-spot analysis:
Specifying the Right Pollutant
When using CAL3QHCR for PM hot-spot analyses, the MODE keyword must be used to
specify analyses for PM so that concentrations are described in micrograms per cubic
meter of air (g/m3) rather than parts per million (ppm).
Entering Emission Rates
MOVES emission rates for individual roadway links are based on the Op-Mode
distribution associated with each link and are able to include emissions resulting from
idling. MOVES-based emission factors that incorporate relevant idling time and other
delays should be entered in CAL3QHCR using the EFL keyword. Therefore, within
CAL3QHCR, the IDLFAC keywords emission rates should be set to zero, because the
effects of idling are already included within running emissions. (Note that if a non-zero
emission rate is used in CAL3QHCR, the model will treat idling emission rates separately
from running emission rates.) The same recommendation applies when using emission
rates calculated by EMFAC.
Assigning Speeds
Although the user guide for CAL3QHCR specifies that the non-queuing links should be
assigned speeds in the absence of delay caused by traffic signals, the user should use
speeds that reflect delay when using CAL3QHCR for a hot-spot analysis. Since MOVES
emission factors already include the effects of delay (i.e., Op-Mode distributions that are
user-specified or internally calculated include the effects of delay), the speeds used in
CAL3QHCR links will already reflect the relevant delay on the link over the appropriate
averaging time. The same recommendation applies when using EMFAC.
Using the Queuing Algorithm
When applying CAL3QHCR for the analysis of highway and intersection projects, its
queuing algorithm should not be used.3 This includes the CAL3QHCR keywords
NLANE, CAVG, RAVG, YFAC, IV, and IDLFAC. As discussed in Sections 4 and 5,
idling vehicle emissions should instead be accounted for by properly specifying links for
emission analysis and reflecting idling activity in the activity patterns used for MOVES
or EMFAC modeling.

The CAL3QHCR user guide and other model documentation can be found on EPAs SCRAM website:

www.epa.gov/scram001/dispersion_prefrec.htm#cal3qhc.

3
CAL3QHCRs algorithm for estimating the length of vehicle queues associated with intersections is based

on the 1985 Highway Capacity Manual, which is no longer current. Furthermore, a number of other

techniques are now available that can be used to estimate vehicle queuing around intersections.

J-2

J.3

CHARACTERIZING EMISSION SOURCES

The following discussion supplements Section 7.4 of the guidance and describes in more
detail how to characterize sources in CAL3QHCR and AERMOD, including the physical
characteristics, location, and timing of sources. This discussion assumes the user is
familiar with handling data in these models, including the use of specific keywords. For
additional information, refer to the CAL3QHCR and AERMOD user guides.
J.3.1

Physical characteristics and locations of sources in CAL3QHCR

CAL3QHCR characterizes highway and intersection projects as line sources. The

geometry and operational patterns of each roadway link are described using the following
variables, which in general may be obtained from engineering diagrams and design plans
of the project:4
The coordinates (X, Y) of the endpoints of each link;5
The width of the highway mixing zone (see below);
The type of link (at grade, fill, bridge, or depressed);
The height of the roadway relative to the surrounding ground (not to exceed 10
meters);6 and
The hourly flow of traffic (vehicles per hour).
CAL3QHCR treats the area over each roadway link as a mixing zone that accounts for
the area of turbulent air around the roadway resulting from vehicle-induced turbulence.
The width of the mixing zone is an input to the model. Users should specify the width of
a link in CAL3QHCR as the width of the traveled way (traffic lanes, not including
shoulders) plus three meters on either side. Users should treat divided highways as two
separate links. See Section 7.6 of the guidance for more information on placing
receptors.
J.3.2

Timing of emissions in CAL3QHCR

The CAL3QHCR User Guide describes two methods for accepting time-varying
emissions and traffic data; these are labeled the Tier I and Tier II approaches.7
4

Traffic engineering plans and diagrams may include information such as the number, width, and
configuration of lanes, turning channels, intersection dimensions, and ramp curvature, as well as
operational estimates such as locations of weave and merge sections and other descriptions of roadway
geometry that may be useful for specifying sources.
5
In CAL3QHCR, the Y-axis is aligned due north.
6
The CALINE3 dispersion algorithm in CAL3QHCR is sensitive to the height of the road. In particular,
the model treats bridges and above-grade fill roadways differently. It also handles below-grade roadways
with height of less than zero (0) meters as cut sections. Information on the topological features of the
project site is needed to make such a determination. Note that in the unusual circumstance that a roadway
is more than ten meters below grade, CALINE3 has not been evaluated, so CAL3QHCR is not
recommended for application. In this case, the relevant EPA Regional Office should be consulted for
determination of the most appropriate model.
7
This nomenclature is unrelated to EPAs motor vehicle emission standards and the design value
calculation options described in Section 9 of this guidance.

J-3

Project-level PM hot-spot modeling should use the Tier II method, which can
accommodate different hourly emission patterns for each day of the week. Most
emissions data will not be so detailed, but the Tier II approach can accommodate
emissions data similar to that described in Sections 4 and 5 of the guidance. The
CAL3QHCR Tier I approach should not be used, as it employs only one hour of
emissions and traffic data and therefore cannot accommodate the emissions data required
in a PM hot-spot analysis.
Through the IPATRY keyword, CAL3QHCR allows up to seven 24-hour profiles
representing hour-specific emission, traffic, and signalization (ETS) data for each day of
the week. Depending on the number of MOVES runs, the emission factors should be
mapped to the appropriate hours of the day. For example, peak traffic emissions data for
each day would be mapped to the CAL3QHCR entry hours corresponding to the relevant
times of day (in this case, the morning and afternoon peak traffic periods). If there are
more MOVES runs than the minimum specified in the Section 4, they should be modeled
and linked to the correct days and hours using IPATRY.
As described in Section 7 of the guidance, the number of CAL3QHCR runs required for a
given PM hot-spot analysis will vary based on the amount of meteorological data
available.
J.3.3

Physical characteristics and locations of sources in AERMOD

The following discussion gives guidance on how to best characterize a source.

AERMOD includes different commands (keywords) for volume, area, and point sources.
Modeling Volume Sources
Many different sources in a project undergoing a PM hot-spot analysis might be modeled
as volume sources. Examples include areas designated for truck or bus queuing or idling
(e.g., off-network links in MOVES), driveways and pass-throughs in transit or freight
terminals, and locomotive emissions.8 AERMOD can also approximate a highway line
source using a series of adjacent volume sources (see the AERMOD User Guide for
suggestions). Certain nearby sources that have been selected to be modeled may also be
appropriately treated as a volume source (see Section 8 of the guidance for more
information on considering background concentrations from other sources).
Volume source parameters are entered using the source parameter (SRCPARAM)
keyword in the AERMOD input file. This requires the user to provide the following
information:
The emission rate (mass per unit time, such as g/s);
The initial lateral dispersion coefficient determined from the initial lateral
dimension (width) of the volume;

See Section 6 and Appendix I for information regarding calculating locomotive emissions.

J-4

The initial vertical dispersion coefficient determined from the initial vertical
dimension (height) of the volume; and
The source release height of the volume source center, (i.e., meters above the
ground).

Within AERMOD, the volume source algorithms are applicable to line sources with some
initial plume depth (e.g., highways, rail lines).9 There are three inputs needed to
characterize the initial size of a roadway plume:
1. Initial lateral dispersion coefficient (yo, Syinit). First, estimate the initial lateral
dimension (or width) of the volume source. One of the following options can be
used:
a) The average vehicle width plus 6 meters, when modeling a single lane of
traffic;

b) The road width multiplied by 2; or

c) A set width, such as 10 meters per lane of traffic.

To specify the initial lateral dispersion coefficient (yo), referred to as Syinit in

AERMOD, the AERMOD User Guide recommends dividing the initial width by 2.15.
This is to ensure that the overlapping distributions from adjacent volume sources
simulate a line source of emissions.
2. Initial vertical dispersion coefficient (zo, Szinit). First, estimate the initial vertical
dimension (height) of the plume for volume sources. A typical approach is to assume
it is about 1.7 times the average vehicle height, to account for the effects of vehicleinduced turbulence. For light-duty vehicles, this is about 2.6 meters, using an average
vehicle height of 1.53 meters or 5 feet. For heavy-duty vehicles, this is about 6.8
meters, using an average vehicle height of 4.0 meters. Since most road links will
consist of a combination of light-duty and heavy-duty traffic, the initial vertical
dimension should be a combination of their respective values. There are two options
available to estimate initial vertical dimension:
a) Estimate the initial vertical dimension using an emissions-weighted average.
For example, if light-duty and heavy-duty vehicles contribute 40% and 60%
of the emissions of a given volume source, respectively, the initial vertical
dimension would be (0.4 * 2.6) + (0.6 * 6.8) = 5.1 meters.
b) Alternatively, the initial vertical dimension may be estimated using a traffic
volume weighted approach based on light-duty and heavy-duty vehicle
fractions.
The AERMOD User Guide recommends that the initial vertical dispersion coefficient
(zo), termed Szinit in AERMOD, be estimated for a surface-based volume source by
dividing the initial vertical dimension by 2.15. For typical light-duty vehicles, this
9

The vehicle-induced turbulence around roadways with moving traffic suggests that prior to transport
downwind, a roadway plume has an initial size; that is, the emissions from the tailpipe are stirred because
the vehicle is moving and therefore the plume begins from a three-dimensional volume, rather than from
a point source (the tailpipe).

J-5

corresponds to a Szinit (zo) of 1.2 meters. For typical heavy-duty vehicles, the initial
value of Szinit (zo) is 3.2 meters.
3. Source release height. The source release height (Relhgt in AERMOD), which is
the height at which wind effectively begins to affect the plume, may be estimated
from the midpoint of the initial vertical dimension. For moving light-duty vehicles,
this is about 1.3 meters. For moving heavy-duty vehicles, it is 3.4 meters. Since
most road links will consist of a combination of light-duty and heavy-duty traffic, the
source release height should be a combination of their respective values. There are
two options available to estimate source release height:
a) Estimate using an emissions-weighted average. For a 40% light-duty and
60% heavy-duty emissions share, the source release height would be (0.4 *
1.3) + (0.6 * 3.4) = 2.6 meters.
b) Alternatively, the source release height may be estimated using a traffic
volume weighted approach based on light-duty and heavy-duty VMT.
Another way of dealing with Syinit, Szinit, and/or Relhgt parameters that change as a
result of different fractions of light-duty and heavy-duty vehicles is to create two
overlapping versions of each roadway source, corresponding to either light-duty and
heavy-duty traffic. These two sources could be superimposed in space, but have
emission rates and Syinit, Szinit, and Relhgt parameters that are specific to light-duty or
heavy-duty traffic.
Also, AERMOD (version dated 09292) allows Syinit, Szinit, and Relhgt to change by
hour of the day, which may be considered if the fraction of heavy-duty vehicles is
expected to significantly change throughout a day. Users should consult the latest
information on AERMOD when starting a PM hot-spot analysis.
Groups of idling vehicles may also be modeled as one or more volume sources. In those
cases, the initial dimensions of the source, dispersion coefficients, and release heights
should be calculated assuming that the vehicles themselves are inducing no turbulence.
When using adjacent volume sources to represent emissions from a source such as a
roadway, a sufficient number of volume sources should be employed to represent a
consistent density of emissions for a single link in a MOVES or EMFAC analysis. In
addition, when the source-receptor spacing in AERMOD is shorter than the distance
between adjacent volume sources, AERMOD may produce aberrant results. In the
present version of the model, receptors within a volume source in AERMOD are assigned
concentrations of zero. When volume sources are used and publicly-accessible locations
are closer to a source than the distance between adjacent volume sources, it is
recommended that smaller volume sources be used with shorter spacing between them.
For example, for such a segment along a highway segment, individual lanes might be
modeled discretely, rather than using a single volume source for all lanes. This will
reduce the spacing between volume sources and increase the quality of results closest to a
source. Receptors near area and point sources are not affected by this concern.

J-6

Consult the AERMOD User Guide and AERMOD Implementation Guide for details in
applying AERMOD to roadway sources.
Modeling Area Sources
AERMOD can represent rectangular, polygon-shaped, and circular area sources using the
AREA, AREAPOLY, or AREACIRC keywords. Sources that may be modeled as area
sources may include areas within which emissions occur relatively evenly, such as a
single link modeled using MOVES or EMFAC.10 Evenly-distributed ground-level
sources might also be modeled as area sources.
AERMOD requires the following information when modeling an area source:
The emission rate per unit area (mass per unit area per unit time);
The release height above the ground;
The length of the north-south side of the area;
The length of the east-west side of the area (if the area is not a square);
The orientation of the rectangular area in degrees relative to north; and
The initial height (vertical dimension) of the area source plume.
In using a series of area sources to represent emissions of a roadway, the release height
and initial vertical dimension of the plume should be calculated as described above for
volume sources.
Modeling Point Sources
It may be appropriate to model some emission sources as fixed point sources, such as
exhaust fans or stacks on a bus garage or terminal building. If a source is modeled with
the POINT keyword in AERMOD, the model requires:
The emission rate (mass per unit time);
The release height above the ground;
The exhaust gas exit temperature;
The stack gas exit velocity; and,
The stack inside diameter in meters.
These parameters can often be estimated using the plans and engineering diagrams for
ventilation systems.
For projects with emissions on or near rooftops, such as bus terminals or garages,
building downwash should also be modeled for the relevant sources. The potential for
building downwash should also be addressed for nearby sources whose emissions are on
or near rooftops in the project area. Building downwash occurs when air moving over a
10

At present, the area sources in AERMOD do not include AERMODs plume meander approach.
Consult the latest version of the AERMOD Implementation Guide for the most current information on
when volume sources or area sources are most appropriate.

J-7

building mixes to the ground on the downwind side of the building. AERMOD
includes algorithms to model the effects of building downwash on plumes from nearby or
adjacent point sources. Consult the AERMOD User Guide for additional detail on how
to enter building information.
J.3.4

Placement and sizing of sources within AERMOD

There are several general considerations with regard to placing and sizing sources within
AERMOD.
First, volume, area, and point sources should be placed in the locations where emissions
are most likely to occur. For example: if buses enter and exit a bus terminal from a single
driveway, the driveway should be modeled using one or more discrete volume or area
sources in the location of that driveway, rather than spreading the emissions from that
driveway across the entire terminal yard.
Second, for emissions from the sides or tops of buildings (as may be found from a bus
garage exhaust fan), it may be necessary to use the BPIPPRIME utility in AERMOD to
appropriately capture the characteristics of these emissions (such as downwash).
Third, the initial dimensions and other parameters of each source should be as realistic as
is feasible. Chapter 3 of the AERMOD User Guide includes recommendations for how
to appropriately characterize the shape of area and volume sources.
Finally, if nearby sources are to be included in air quality modeling (see discussion in
Section 8 of the guidance), a combination of all these source types may be needed to
appropriately represent their emissions within AERMOD. For instance, evenlydistributed ground-level sources might also be modeled as area sources, while a nearby
power plant stack might be modeled as a point source.
J.3.5

Timing of emissions in AERMOD

Within AERMOD, emissions that vary across a year should be described with the
EMISFACT keyword (see Section 3.3.5 of the AERMOD User Guide). The number of
quarters that need to be analyzed may vary based on a particular PM hot-spot analysis.
See Section 2.5 of the guidance for more information on when PM emissions need to be
evaluated, and Sections 4 and 5 of the guidance on determining the number of MOVES
and EMFAC runs.
The Qflag parameter under EMISFACT may be used with a secondary keyword to
describe different patterns of emission variations throughout a year. Note that AERMOD
defines seasons in the following manner: winter (December, January, February), spring
(March, April, May), summer (June, July, August), and fall (September, October,
November). Emission data obtained from MOVES or EMFAC should be appropriately
matched with the relevant time periods in AERMOD. For example, if four MOVES or
EMFAC runs are completed (one for each quarter of a year), there are emission estimates

J-8

corresponding to four months of the year (January, April, July, October) and peak and
average periods within each day. In such a circumstance, January runs should be used to
represent all AERMOD winter months (December, January, February), April runs for all
spring months (March, April, May), July runs for all summer months (June, July,
August), and October for all fall months (September, October, November).
If separate weekend emission rates are available, season-specific weekday runs should be
used for the Monday-Friday entries; weekend runs would be assigned to the Saturday and
Sunday entries. The peak/average runs for each day should be mapped to the AERMOD
entry hours corresponding to the relevant time of day from the traffic analysis. Qflag can
be used to represent emission rates that vary by season, hour of day, and day of the week.
Consult the AERMOD User Guide for details.

J.4

INCORPORATING METEOROLOGICAL DATA

This discussion supplements Section 7.5 of the guidance and describes in more detail
how to handle meteorological data in AERMOD and CAL3QHCR. Section 7.2.3 of
Appendix W to 40 CFR Part 51 provides the basis for determining the urban/rural status
of a source. Consult the AERMOD Implementation Guide for instructions on what type
of population data should be used in making urban/rural determinations.
J.4.1

Specifying urban or rural sources in AERMOD

As described in Section 7 of the guidance, AERMOD employs nearby population as a

surrogate for the magnitude of differential urban-rural heating (i.e., the urban heat island
effect). When modeling urban sources in AERMOD, users should use the URBANOPT
keyword to enter this data.
When considering urban roughness lengths, users should consult the AERMOD
Implementation Guide. Any application of AERMOD that utilizes a value other than 1
meter for the urban roughness length should be considered a non-regulatory application
and would require appropriate documentation and justification as an alternate model (see
Section 7.3.3 of the guidance).
For urban applications using representative National Weather Service (NWS)
meteorological data, consult the AERMOD Implementation Guide. For urban
applications using NWS data, the URBANOPT keyword should be selected, regardless of
whether the NWS site is located in a nearby rural or urban setting. When using sitespecific meteorological data in urban applications, consult the AERMOD Implementation
Guide.

J-9

J.4.2

Specifying urban or rural sources in CAL3QHCR

CAL3QHCR requires that users specify the run as being rural or urban using the RU
keyword.11 Users should make the appropriate entry depending if the source is
considered urban or rural as described in Section 7.5.5 of the guidance.

J.5

MODELING COMPLEX TERRAIN

This discussion supplements Section 7.5 of the guidance and describes in more detail
how to address complex terrain in AERMOD and CAL3QHCR. In most situations, the
project area should be modeled as having flat terrain. Additional detail on how this
should be accomplished in each model is found below. However, in some situations a
project area may include complex terrain, such that sources and receptors included in the
model are found at different heights.
J.5.1

AERMOD

This guidance reflects the AERMOD Implementation Guide as of March 19, 2009.
Analysts should consult the most recent AERMOD Implementation Guide for the latest
guidance on modeling complex terrain.
For most highway and transit projects, the analyst should apply the non-DFAULT option
in AERMOD and assume flat, level terrain. In the AERMOD input file, the FLAT option
should be used in the MODELOPT keyword. This recommendation is made to avoid
underestimating concentrations in two circumstances likely to occur with the lowelevation, non-buoyant emissions from transportation projects. First, in DFAULT mode,
AERMOD will tend to underestimate concentrations from low-level, non-buoyant
sources where there is up-sloping terrain with downwind receptors uphill since the
DFAULT downwind horizontal plume will pass below the actual receptor elevation.
Second, in DFAULT mode, AERMOD will tend to underestimate concentrations when a
plume is terrain-following. Therefore, the FLAT option should be selected in most cases.
There may be some cases where significant concentrations result from nearby elevated
sources. In these cases, interagency consultation should be used on a case-by-case basis
to determine whether to include terrain effects and use the DFAULT option. In those
cases, AERMAP should be used to prepare input files for AERMOD; consult the
AERMOD and AERMAP user guides and the latest AERMOD Implementation Guide
for information on obtaining and processing relevant terrain data.

11

Specifying urban modeling with the RU keyword converts stability classes E and F to D.

J-10

J.5.2 CAL3QHCR
CAL3QHCR does not handle complex terrain. No action is therefore required.

J.6

RUNNING THE MODEL AND OBTAINING RESULTS

This discussion supplements Section 7.7 of the guidance and describes in more detail
how to handle data outputs in AERMOD and CAL3QHCR. AERMOD and CAL3QHCR
produce different output file formats, which must be post-processed in different ways to
enable calculation of design values as described in Section 9.3 of the guidance. This
guidance is applicable regardless of how many quarters are being modeled.
J.6.1

AERMOD output

AERMOD requires that users specify the type and format of output files in the main input
file for each run. See Section 3.7 of the AERMOD User Guide for details on the various
output options. Output options should be specified to enable the relevant design value
calculations required in Section 9.3. Note that many users will have multiple years of
meteorological data, so multiple output files may be required (unless the meteorological
files have been joined prior to running AERMOD).
For the annual PM2.5 design value calculations described in Section 9.3.2, averaging
times should be specified that allow calculation of the annual average concentrations at
each receptor. For example, when using five years of meteorological data, the PERIOD
averaging time could be specified using the CO AVERTIME keyword.
For the 24-hour PM2.5 design value calculations described in Section 9.3.3, the
DAYTABLE option provides output files with 24-hour concentrations at each receptor
for each day processed. Users should flag the quarter and year for each day listed in the
DAYTABLE that AERMOD generates. Note users should also specify a 24-hour
averaging time with the CO AVERTIME command as well.
Another option for calculating 24-hour PM2.5 design values is with a POSTFILE, a file of
results at each receptor for each day processed. By specifying a POSTFILE with a 24
hour averaging time, a user can generate a file of daily concentrations for each day of
meteorological data. When using this option, users should specify a POSTFILE with a
24-hour averaging time to generate the outputs needed to calculate design values and flag
the quarter and year for each day listed in the POSTFILE that AERMOD generates. Note
that POSTFILE output files can be very large.
For the 24-hour PM10 calculations described in Section 9.3.4, the RECTABLE keyword
may be used to obtain the six highest 24-hour concentrations over the entire modeling
period. A RECTABLE is a file summarizing the highest concentrations at each receptor
over an averaging period (e.g., 24 hours) across a modeling period (e.g., 5 years).

J-11

EPA is actively working towards a post-processing tool for AERMOD that will provide
the appropriate modeling metrics that may then be combined with background
concentrations for comparisons to the PM NAAQS. EPA will announce these new
options as they become available on EPAs SCRAM website at:
www.epa.gov/scram001/.
J.6.2

CAL3QHCR output

For each year of meteorological data and quarterly emission inputs, CAL3QHCR reports
the five highest 24-hour concentrations and the quarterly average concentrations in its
output file.
For calculating annual PM2.5 design values using CAL3QHCR output, some post
processing is required. CAL3QHCRs output file refers to certain data under the display:
THE HIGHEST ANNUAL AVERAGE CONCENTRATIONS. If four quarters of
emission data are separately run in CAL3QHCR, each quarters outputs listed under
THE HIGHEST ANNUAL AVERAGE CONCENTRATIONS are actually quarterlyaverage concentrations. As described in Section 7, per year of meteorological data,
CAL3QHCR should be run for as many quarters as analyzed using MOVES and
EMFAC, as CAL3QHCR accepts only a single quarters emission factors per input file.
Calculating 24-hour PM2.5 design values under a first or second tier analysis is described
in Section 9.3.3. To get annual average modeled concentrations for a first tier analysis
(Step 1), the highest 24-hour concentrations in each quarter and year of meteorological
data should be identified. Within each year of meteorological data, the highest 24-hour
concentration at each receptor should be identified. For a first tier analysis, at each
receptor, the highest concentrations from each year of meteorological data should be
averaged together. Under a second tier analysis, at each receptor, the highest modeled
concentration in each quarter, from each year of meteorological data, should be averaged
together. These average highest 24-hour concentrations in each quarter, across multiple
years of meteorological data, are used in second tier PM2.5 design value calculations.
In calculating 24-hour PM10 design values, it is necessary to estimate the sixth-highest
concentration in each year if using five years of meteorological data. For each period of
meteorological data, CAL3QHCR outputs the five highest 24-hour concentrations. To
estimate the sixth-highest concentration at a receptor, the five highest 24-hour
concentrations from each quarter and year of meteorological data should be arrayed
together and ranked. From all quarters and years of meteorological data, the sixthhighest concentration should be identified. This concentration, at each receptor, is used
in calculations of the PM10 design value described in Section 9.3.4.

J-12

Appendix K:
Examples of Design Value Calculations for PM Hot-spot
Analyses
K.1

INTRODUCTION

This appendix supplements Section 9s discussion of calculating and applying design

values for PM hot-spot analyses. While this guidance can apply to any PM NAAQS, this
appendix provides examples of how to calculate design values for the PM NAAQS in
effect at the time the guidance was issued (the 1997 annual PM2.5 NAAQS, the 2006 and
1997 24-hour PM2.5 NAAQS, and the 1987 24-hour PM10 NAAQS). The design values
in this appendix are calculated using the steps described in Section 9.3. Readers should
reference the appropriate sections of the guidance as needed for more detail on how to
complete each step of these analyses.
These illustrative example calculations demonstrate the basic procedures described in the
guidance and therefore are simplified in the number of receptors considered and other
details that would occur in an actual PM hot-spot analysis. Where users would have to
repeat steps for additional receptors, it is noted. These examples are organized according
to the build/no-build analysis steps that are described in Sections 2 and 9 of this guidance.
The final part of this appendix provides mathematical formulas that describe the design
value calculations discussed in Section 9 and this appendix.

K.2

PROJECT DESCRIPTION AND CONTEXT FOR ALL EXAMPLES

For the following examples, a PM hot-spot analysis is being done for an expansion of an
existing highway with a significant increase in the number of diesel vehicles (40 CFR
93.123(b)(1)(i)). The highway expansion will serve an expanded freight terminal. The
traffic at the terminal will increase as a result of the expanded highway projects increase
in truck traffic, and therefore the freight terminal is projected to have higher emissions
under the build scenario than under the no-build scenario. The freight terminal is not part
of the project; however, it is a nearby source that will be included in the air quality
modeling, as described further below.
The air quality monitor selected to represent background concentrations from other
sources is a Federal Equivalent Method (FEM) monitor that is 300 meters upwind of the
project. The monitor is on a 1-in-3 day sampling schedule. In this example, the three
most recent years of monitoring data are from 2008, 2009, and 2010. Since 2008 is a
leap year (366 days), for this example, there are 122 monitored values in that year and
121 values for both 2009 and 2010 (365 days each).1
1

Note that the number of air quality monitoring measurements may vary by year. For example, with 1-in
3 measurements, there could be 122 or 121 measurements in a year with 365 days. Or, there may be fewer

K-1

However, through interagency consultation, it is determined that the freight terminals

emissions are not already captured by this air quality monitor. AERMOD has been
selected as the air quality model to estimate PM concentrations produced by the project
(the highway expansion) and the nearby source (the freight terminal).2 There are five
years of representative off-site meteorological data being used in this analysis.
As discussed in Section 2.4, a project sponsor could consider mitigation and control
measures at any point in the process. However, since the purpose of these examples is to
show the design value calculations, in this appendix such measures are not considered
until after the calculations are done.

K.3

EXAMPLE:

K.3.1

General

ANNUAL PM2.5 NAAQS

This example illustrates the approach to calculating design values for comparison to the
annual PM2.5 NAAQS, as described in Section 9.3.2. The annual PM2.5 design value is
the average of three consecutive years annual averages. The design value for
comparison is rounded to the nearest tenth of a g/m3 (nearest 0.1 g/m3). For example,
15.049 rounds to 15.0, and 15.050 rounds to 15.1.3
Each years annual average concentrations include contributions from the project, any
nearby sources modeled, and background concentrations. For air quality monitoring
purposes, the annual PM2.5 NAAQS is met when the three-year average concentration is
less than or equal to the current annual PM2.5 NAAQS (i.e., 15.0 g/m3):
Annual PM2.5 design value = ([Y1] average + [Y2] average + [Y3] average) 3
Where:
[Y1] = Average annual PM2.5 concentration for the first year of air quality
monitoring data
[Y2] = Average annual PM2.5 concentration for the second year of air quality
monitoring data
[Y3] = Average annual PM2.5 concentration for the third year of air quality
monitoring data

actual monitored values if sampling was not conducted on some scheduled days or the measured value was
invalidated due to quality assurance concerns. The actual number of samples with valid data should be
used.
2
EPA notes that CAL3QHCR could not be used in this particular PM hot-spot analysis, since air quality
modeling included the project and a nearby source. See Section 7.3 of the guidance for further information.
3
A sufficient number of decimal places (3-4) should be retained during intermediate calculations for design
values, so that there is no possibility of intermediate rounding or truncation affecting the final result.
Rounding to the tenths place should only occur during final design value calculations, pursuant to
Appendix N to 40 CFR Part 50.

K-2

For this example, the project described in Appendix K.2 is located in an annual PM2.5
NAAQS nonattainment area. This example illustrates how an annual PM2.5 design value
could be calculated at the same receptor in the build and no-build scenarios, based on air
quality modeling results and air quality monitoring data. In an actual PM hot-spot
analysis, design values would be calculated at additional receptors, as described further in
Section 9.3.2.
K.3.2 Build scenario
For the build scenario, the PM2.5 impacts from the project and from the nearby source are
estimated with AERMOD at all receptors.4
Steps 1-2. Because AERMOD is used for this project, Step 1 is skipped. The receptor
with the highest average annual concentration, using five years of meteorological data, is
identified directly from the AERMOD output. This receptors average annual
concentration is 3.603 g/m3.
Step 3. Based on the three years of measurements at the background air quality monitor,
the average monitored background concentrations in each quarter is determined. Then,
for each year of background data, the four quarters are averaged to get an average annual
background concentration (last column of Exhibit K-1). These three average annual
background concentrations are averaged, and the resulting value is 11.582 g/m3, as
shown in Exhibit K-1:
Exhibit K-1. Background Concentrations
Background
Concentrations
2008
2009
2010
3-year average:

Q1

Q2

Q3

Q4

13.013
14.214
11.890

17.037
14.872
16.752

8.795
7.912
9.421

8.145
7.639
9.287

Average
Annual
11.748
11.159
11.838
11.582

Step 4. The 3-year average annual background concentration (from Step 3) is added to
the average annual modeled concentration from the project and nearby source (from Step
2):
11.582 + 3.603 = 15.185
Step 5. Rounding to the nearest 0.1 g/m3 produces a design value of 15.2 g/m3.

As noted above, there is a single nearby source that is projected to have higher emissions under the build
scenario than the no-build scenario as a result of the project and its impacts are not expected to be captured
by the monitor chosen to provide background concentrations. Therefore, emissions from the project and
this nearby source are both included in the AERMOD output.

K-3

In this example, the concentration at the highest receptor is estimated to exceed the
current annual PM2.5 NAAQS of 15.0 g/m3.
Steps 6-8: Since the design value in Step 5 is greater than the NAAQS, design value
calculations are then completed for all receptors in the build scenario, and receptors with
design values above the NAAQS are identified. After this is done, the no-build scenario
is modeled for comparison.
K.3.3

No-build scenario

The no-build scenario (i.e., the existing highway and freight terminal without the
proposed highway and freight terminal expansion), is modeled at all of the receptors in
the build scenario, but design values are only calculated in the no-build scenario at
receptors where the design value for the build scenario is above the annual PM2.5 NAAQS
(from Steps 6-8 above).
Step 9. For this example, the receptor with the highest average annual concentration in
the build scenario is used to illustrate the no-build scenario design value calculation. The
average annual concentration modeled at this receptor in the no-build scenario is 3.521
g/m3.
Step 10. The background concentrations from the representative monitor are unchanged
from the build scenario, so the average annual modeled concentration of 3.521 is added to
the 3-year average annual background concentrations of 11.528 g/m3 from Step 3:
11.582 + 3.521 = 15.103
Step 11. Rounding to the nearest 0.1 g/m3 produces a design value of 15.1 g/m3.
In this example, the design value at the receptor in the build scenario (15.2 g/m3) is
greater than the design value at the same receptor in the no-build scenario (15.1 g/m3).5
In an actual PM hot-spot analysis, design values would also be compared between build
and no-build scenarios at all receptors in the build scenario that exceeded the annual
PM2.5 NAAQS. The interagency consultation process would then be used to discuss next
steps, e.g., appropriateness of receptors. Refer to Sections 9.2 and 9.4 for additional
details.
If it is determined that conformity requirements are not met at all appropriate receptors,
the project sponsor should then consider additional mitigation or control measures, as
discussed in Section 10. After measures are selected, a new build scenario that includes
the controls should be modeled and new design values calculated. Design values for the
no-build scenario shown above would not need to be recalculated since the no-build
scenario would not change.
5

Values are compared after rounding. As long as the build design value is no greater than the no-build
design value after rounding, the project would meet conformity requirements at a given receptor, even if
the pre-rounding build design value is greater than the pre-rounding no-build design value.

K-4

K.4

EXAMPLE: 24-HOUR PM2.5 NAAQS

K.4.1 General
This example illustrates the two-tiered approach to calculating design values for
comparison with the 24-hour PM2.5 NAAQS, as described in Section 9.3.3. The 24-hour
design value is the average of three consecutive years 98th percentile PM2.5 concentration
of 24-hour values for each of those years. For air quality monitoring purposes, the
NAAQS is met when that three-year average concentration is less than or equal to the
currently applicable 24-hour PM2.5 NAAQS for a given areas nonattainment designation
(35 g/m3 for nonattainment areas for the 2006 PM2.5 NAAQS and 65 g/m3 for
nonattainment areas for the 1997 PM2.5 NAAQS).6 The design value for comparison to
any 24-hour PM2.5 NAAQS is rounded to the nearest 1 g/m3 (i.e., decimals 0.5 and
greater are rounded up to the nearest whole number, and any decimal lower than 0.5 is
rounded down to the nearest whole number). For example, 35.499 rounds to 35 g/m3,
while 35.500 rounds to 36.7
For this example, the project described in Appendix K.2 is located in a nonattainment
area for the 2006 24-hour PM2.5 NAAQS. This example presents first tier and second tier
build scenario results for a single receptor to illustrate how the calculations should be
made based on air quality modeling results and air quality monitoring data. It also shows
second tier no-build scenario results for this same receptor. In an actual PM hot-spot
analysis, design values would be calculated at additional receptors, as described further in
Section 9.3.3.
As explained in Section 9.3.3, project sponsors can start with either a first or second tier
analysis. This example begins with a first tier analysis. However, it would also be
acceptable to begin with the second tier analysis and skip the first tier altogether.
K.4.2 Build scenario
PM2.5 contributions from the project and the nearby source are estimated together with
AERMOD in each of four quarters using meteorological data from five consecutive
years, using a 24-hour averaging time. As discussed in Appendix K.2 above, the one
nearby source (the freight terminal) was included in air quality modeling.

There are only two PM2.5 areas where conformity currently applies for both the 1997 and 2006 24-hour
NAAQS. While both 24-hour NAAQS must be considered in these areas, in practice if the more stringent
2006 24-hour PM2.5 NAAQS is met, then the 1997 24-hour PM2.5 NAAQS is met as well.
7
A sufficient number of decimal places (3-4) should be retained during intermediate calculations for design
values, so that there is no possibility of intermediate rounding or truncation affecting the final result.
Rounding should only occur during final design value calculations, pursuant to Appendix N to 40 CFR Part
50.

K-5

First Tier Analysis

Under a first tier analysis, the average highest modeled 24-hour concentrations at a given
receptor are added to the average 98th percentile 24-hour background concentrations,
regardless of the quarter in which they occur. The average highest modeled 24-hour
concentrations are produced by AERMOD, using five years of meteorological data in one
run.
Step 1. The receptor with the highest average modeled 24-hour concentration is
identified. This was obtained directly from the AERMOD output.8 For this example, the
data from this receptor is shown in Exhibit K-2. Exhibit K-2 shows the highest 24-hour
concentration for each year of meteorological data used, regardless of the quarter in
which they were modeled. The average concentration of these outcomes, 6.710 g/m3
(highlighted in Exhibit K-2), is the highest, compared to the averages at all of the other
receptors.
Exhibit K-2. Modeled PM2.5 Concentrations from Project and Nearby Source

Year
Met Year 1
Met Year 2
Met Year 3
Met Year 4
Met Year 5
Average

Highest PM2.5
Concentration
6.413
5.846
6.671
7.951
6.667
6.710

Step 2. The average 98th percentile 24-hour background concentration for a first tier
analysis is calculated using the 98th percentile 24-hour concentrations of the three most
recent years of monitoring data from the representative air quality monitor selected (see
Appendix K.2). Since the background monitor is on a 1-in-3 day sampling schedule, it
made either 122 or 121 measurements per year during 2008 - 2010. According to Exhibit
9-5, with this number of monitored values per year, the 98th percentile is the third highest
concentration. Exhibit K-3 depicts the top eight monitored concentrations (in g/m3) of
the monitor throughout the years employed for estimating background concentrations.

If CAL3QHCR were being used, some additional processing of model output would be needed. Refer to
Section 9.3.3.

K-6

Exhibit K-3. Top Eight Monitored Concentrations in Years 2008 2010

Rank
1
2
3
4
5
6
7
8

2008
34.123
31.749
31.443
30.809
30.219
30.134
30.099
28.481

2009
33.537
32.405
31.126
30.819
30.487
29.998
29.872
28.937

2010
35.417
31.579
31.173
31.095
30.425
30.329
30.193
28.751

The third-ranked concentration of each year (highlighted in Exhibit K-3) is the 98th
percentile value. These are averaged:
(31.443 + 31.126 + 31.173) 3 = 31.247 g/m3.
Step 3. Then, the highest average 24-hour modeled concentration for this receptor (from
Step 1) is added to the average 98th percentile 24-hour background concentration (from
Step 2):
6.710 + 31.247 = 37.957 g/m3.
Rounding to the nearest whole number results in a 24-hour PM2.5 design value of 38
g/m3.
Because this concentration is greater than the 2006 24-hour PM2.5 NAAQS (35 g/m3),
this first tier analysis does not demonstrate that conformity is met. As described in
Section 9.3.3, the project sponsor has two options:
Repeat the first tier analysis for the no-build scenario at all receptors that
exceeded the NAAQS in the build scenario. If the calculated design value for the
build scenario is less than or equal to the design value for the no-build scenario at
all of these receptors, then the project conforms;9 or
Conduct a second tier analysis.
In this example, the next step chosen is to conduct a second tier analysis.
Second Tier Analysis
In a second tier analysis, the highest modeled concentrations are not added to the 98th
percentile background concentrations on a yearly basis. Instead, a second tier analysis
uses the average of the highest modeled 24-hour concentration within each quarter of
each year of meteorological data. Impacts from the project, nearby sources, and other
background concentrations are calculated on a quarterly basis before determining the 98th
9

In certain cases, project sponsors can also decide to calculate the design values for all receptors in the
build and no-build scenarios and use the interagency consultation process to determine whether a new
violation has been relocated (see Section 9.2).

K-7

percentile concentration resulting from these inputs. The steps presented below follow
the steps described in Section 9.3.3.
Step 1. The first step is to count the number of measurements for each year of
monitoring data used for background concentrations. As described in Appendix K.2 and
in Step 2 of the first tier analysis above, there are 122 monitored values during 2008, 121
values during 2009, and 121 values during 2010.
Step 2. For each year of monitoring data, the eight highest 24-hour background
concentrations in each quarter are determined. The eight highest concentrations in each
quarter of 2008, 2009, and 2010 are shown in Exhibit K-4.
Exhibit K-4. Eight Highest 24-hour Background Concentrations By Quarter for
Each Year

Year

2008

2009

2010

Rank of
Background
Concentration
1
2
3
4
5
6
7
8
1
2
3
4
5
6
7
8
1
2
3
4
5
6
7
8

Q1

Q2

Q3

Q4

27.611
25.974
25.760
25.493
25.099
24.902
24.780
23.287
26.962
24.820
24.330
23.768
23.685
23.287
23.226
22.698
27.493
24.637
24.637
24.392
24.050
23.413
22.453
22.061

31.749
30.219
30.134
28.368
27.319
25.788
25.564
24.794
32.405
30.487
28.937
27.035
25.880
25.867
25.254
24.268
31.579
31.173
30.193
27.994
25.439
24.253
23.006
21.790

34.123
31.443
30.809
28.481
27.372
25.748
25.288
24.631
33.537
30.819
29.998
29.872
25.596
25.148
24.744
24.267
35.417
31.095
30.329
28.751
26.084
24.890
24.749
22.538

30.099
28.096
26.990
25.649
25.526
25.509
25.207
24.525
31.126
28.553
25.920
25.856
25.565
24.746
24.147
23.142
30.425
26.927
26.263
25.684
25.170
24.254
23.425
22.891

K-8

Step 3. The highest modeled 24-hour concentrations in each quarter are identified at each
receptor. Exhibit K-5 presents the highest 24-hour concentrations within each quarter at
one receptor (for each of the five years of meteorological data used in air quality
modeling) as well as the average of these quarterly concentrations. This step would be
repeated for each receptor in an actual PM hot-spot analysis.
Exhibit K-5. Highest Modeled 24-hour Concentrations Within Each Quarter (Build
Scenario)

Met Year 1
Met Year 2
Met Year 3
Met Year 4
Met Year 5
Average

Q1
6.413
3.229
6.671
7.095
6.664
6.014

Q2
3.332
3.481
3.330
3.584
4.193
3.584

Q3
6.201
5.846
5.696
7.722
4.916
6.076

Q4
6.193
4.521
6.554
7.951
6.667
6.377

The average highest concentrations on a quarterly basis (i.e., the values highlighted in
Exhibit K-5) constitute the contributions of the project and nearby source to the projected
24-hour PM2.5 design value, and are used in subsequent calculations.
Step 4. For each receptor, the highest modeled 24-hour concentration in each quarter
(from Step 3) is added to each of the eight highest monitored concentrations for the same
quarter for each year of monitoring data (from Step 2). To obtain this result, the average
highest modeled concentration for each quarter, found in the last row of Exhibit K-5, is
added to each of the eight highest background concentrations in each quarter in Exhibit
K-4. The results are shown in Exhibit K-6.

K-9

Exhibit K-6. Sum of Modeled and Monitored Concentrations (Build Scenario)

Year

2008

2009

2010

Rank of
Background
Concentration
1
2
3
4
5
6
7
8
1
2
3
4
5
6
7
8
1
2
3
4
5
6
7
8

Q1

Q2

Q3

Q4

33.625
31.989
31.774
31.507
31.113
30.916
30.794
29.301
32.976
30.835
30.344
29.782
29.700
29.301
29.240
28.712
33.507
30.651
30.651
30.406
30.064
29.428
28.468
28.075

35.333
33.803
33.718
31.952
30.903
29.372
29.148
28.378
35.989
34.071
32.521
30.619
29.464
29.451
28.838
27.852
35.163
34.757
33.777
31.578
29.022
27.837
26.590
25.374

40.200
37.520
36.886
34.557
33.448
31.824
31.365
30.707
39.613
36.895
36.074
35.948
31.672
31.225
30.820
30.343
41.493
37.172
36.405
34.827
32.160
30.966
30.825
28.614

36.476
34.474
33.368
32.026
31.903
31.886
31.584
30.902
37.503
34.931
32.297
32.233
31.942
31.124
30.524
29.520
36.802
33.304
32.640
32.062
31.547
30.631
29.803
29.269

Step 5. The 32 values from each year in Exhibit K-6 are then ranked from highest to
lowest, regardless of the quarter from which each value comes. This step is shown in
Exhibit K-7. Note that only the top eight values are shown for each year instead of the
entire set of 32. Exhibit K-7 also displays the quarter from which each concentration
comes and the values rank within its quarter.

K-10

Exhibit K-7. Eight Highest Concentrations in Each Year, Ranked from Highest to
Lowest (Build Scenario)
Year

2008

2009

2010

g/m3
40.200
37.520
36.886
36.476
35.333
34.557
34.474
33.803
39.613
37.503
36.895
36.074
35.989
35.948
34.931
34.071
41.493
37.172
36.802
36.405
35.163
34.827
34.757
33.777

Yearly
Rank
1
2
3
4
5
6
7
8
1
2
3
4
5
6
7
8
1
2
3
4
5
6
7
8

Quarter
Q3
Q3
Q3
Q4
Q2
Q3
Q4
Q2
Q3
Q4
Q3
Q3
Q2
Q3
Q4
Q2
Q3
Q3
Q4
Q3
Q2
Q3
Q2
Q2

Quarterly
Rank
1
2
3
1
1
4
2
2
1
1
2
3
1
4
2
2
1
2
1
3
1
4
2
3

Steps 6-7. The value that represents the 98th percentile 24-hour concentration is
determined, based on the number of background concentration values there are. As
described in Step 1, there are 122 monitored values for the year 2008 and 121 values for
both 2009 and 2010. According to Exhibit 9-7 in Section 9.3.3, for a year with 101-150
samples per year, the 98th percentile is the 3rd highest concentration for that year.
Therefore, for this example, the 3rd highest 24-hour concentration of each year,
highlighted in Exhibit K-7, represents the 98th percentile value for that year.
Step 8. At each receptor, the average of the three 24-hour 98th percentile concentrations
is calculated. For the receptor in this example, the average is:
(36.886 + 36.895 + 36.802) 3 = 36.861

K-11

Step 9. The average for the receptor in this example from Step 8 (36.861 g/m3) is then
rounded to the nearest whole number (37 g/m3) and compared to the 2006 24-hour
PM2.5 NAAQS (35 g/m3).
The design value at the receptor in this example is higher than the relevant 24-hour PM2.5
NAAQS. In an actual PM2.5 hot-spot analysis, the design value calculations need to be
repeated for all receptors, and compared to the NAAQS. Since one (and possibly more)
receptors have design values greater than the 24-hour PM2.5 NAAQS, the project will
only conform if the design value in the build scenario is less than or equal to the design
value in the no-build scenario for all receptors that exceeded the NAAQS in the build
scenario. Therefore, the no-build scenario needs to be modeled for comparison, as
described further below. Because the build scenario was modeled with a second tier
analysis, the no-build scenario must also be modeled with a second tier analysis.
K.4.3 No-build scenario
The no-build scenario is described in Section 9.3.3 as Step 10:
Step 10. Using modeling results for the no-build scenario, repeat Steps 3 through
9 for all receptors with a design value that exceeded the PM2.5 NAAQS in the
build scenario. The result will be a 24-hour PM2.5 design value at such receptors
for the no-build scenario.
For this part of the example, air quality modeling is completed for the no-build scenario
for the same receptor as the build scenario. Steps 1 and 2 for the build scenario do not
need to be repeated, since the background concentrations in the no-build scenario are
identical to those in the build scenario. Exhibit K-4, which shows the eight highest
monitored concentrations in each quarter over three years, therefore can also be used for
the no-build scenario.
Step 3. For the same receptor examined above in the build scenario, the highest modeled
24-hour concentrations for the no-build scenario are calculated for each quarter, using
each year of meteorological data used for air quality modeling. Exhibit K-8 provides
these concentrations, as well as the quarterly averages (highlighted).
Exhibit K-8. Highest Modeled 24-hour Concentrations Within Each Quarter (NoBuild Scenario)

Met Year 1
Met Year 2
Met Year 3
Met Year 4
Met Year 5
Average

Q1
6.757
3.402
7.029
7.476
7.022
6.337

Q2
3.383
3.535
3.381
3.639
4.258
3.639

Q3
6.725
6.340
6.177
8.374
5.331
6.589

Q4
6.269
4.577
6.635
8.048
6.748
6.455

K-12

Step 4. The highest modeled 24-hour concentration in each quarter (i.e., the values in the
last row of Exhibit K-8) are added to each of the eight highest concentrations for the
same quarter for each year of monitoring data (found in Exhibit K-4), and the resulting
values are shown in Exhibit K-9.
Exhibit K-9. Sum of Modeled and Monitored Concentrations (No-Build Scenario)

Year

2008

2009

2010

Rank of
Background
Concentration
1
2
3
4
5
6
7
8
1
2
3
4
5
6
7
8
1
2
3
4
5
6
7
8

Q1

Q2

Q3

Q4

33.948
32.312
32.097
31.830
31.436
31.239
31.117
29.624
33.299
31.158
30.667
30.105
30.023
29.624
29.563
29.035
33.830
30.974
30.974
30.729
30.387
29.751
28.791
28.398

35.389
33.858
33.774
32.007
30.959
29.428
29.204
28.433
36.044
34.126
32.576
30.674
29.520
29.506
28.894
27.907
35.218
34.812
33.832
31.633
29.078
27.893
26.645
25.429

40.713
38.033
37.399
35.070
33.961
32.337
31.878
31.220
40.127
37.408
36.587
36.461
32.185
31.738
31.333
30.856
42.007
37.685
36.918
35.340
32.674
31.479
31.338
29.127

36.555
34.552
33.446
32.104
31.981
31.964
31.662
30.980
37.581
35.009
32.375
32.311
32.020
31.202
30.602
29.598
36.880
33.382
32.719
32.140
31.625
30.709
29.881
29.347

Step 5. The 32 values from each year in Exhibit K-9 are ranked from highest to lowest,
regardless of the quarter from which each value comes. This step is shown in Exhibit K
10. Note that only the top eight values are shown for each year instead of the entire set of
32.

K-13

Exhibit K-10. Eight Highest Concentrations in Each Year, Ranked from Highest to
Lowest (No-Build Scenario)
Year

2008

2009

2010

g/m3
40.713
38.033
37.399
36.555
35.389
35.070
34.552
33.961
40.127
37.581
37.408
36.587
36.461
36.044
35.009
34.126
42.007
37.685
36.918
36.880
35.340
35.218
34.812
33.832

Yearly
Rank
1
2
3
4
5
6
7
8
1
2
3
4
5
6
7
8
1
2
3
4
5
6
7
8

Quarter
Q3
Q3
Q3
Q4
Q2
Q3
Q4
Q3
Q3
Q4
Q3
Q3
Q3
Q2
Q4
Q2
Q3
Q1
Q1
Q4
Q4
Q1
Q4
Q4

Quarterly
Rank
1
2
3
1
1
4
2
5
1
1
2
3
4
1
2
2
7
3
2
8
6
1
2
3

Steps 6-7. Based on the number of background measurements available per year in this
example (122 for 2008 and 121 for both 2009 and 2010, as discussed in the analysis of
the build scenario), Exhibit 9-7 in Section 9.3.3 indicates that the 3 rd highest 24-hour
concentration in each year represents the 98th percentile concentration for that year. The
third highest concentrations are highlighted in Exhibit K-10.
Step 8. For this receptor, the average of the Rank 3 concentrations in 2008, 2009, and
2010 is calculated:
(37.399 + 37.408 + 36.918) 3 = 37.242
Step 9. The average for the receptor in this example from Step 8 (37.242 g/m3) is
rounded to the nearest whole g/m3 (37 g/m3).

K-14

In this example, the design value at this receptor for both the build and no-build scenarios
is 37 g/m3, which is greater than the 2006 24-hour NAAQS (35 mg/m3). However, the
build scenarios design value is equal to the design value in the no-build scenario. 10 For
the project to conform, the build design values must be less than or equal to the no-build
value for all the receptors that exceeded the NAAQS in the build scenario. Assuming
that this is the case at all other receptors, the proposed project in this example would
therefore demonstrate conformity.

K.5

EXAMPLE: 24-HOUR PM10

NAAQS

K.5.1 General
This example illustrates calculating design values for comparison with the 24-hour PM10
NAAQS, as described in Section 9.3.4. The 24-hour PM10 design value is based on the
expected number of 24-hour exceedances of 150 g/m3, averaged over three consecutive
years. For air quality monitoring purposes, the NAAQS is met when the number of
exceedances is less than or equal to 1.0. The 24-hour PM10 design value is rounded to the
nearest 10 g/m3. For example, 155.511 rounds to 160, and 154.999 rounds to 150.11
The 24-hour PM10 design value is calculated at each air quality modeling receptor by
directly adding the sixth-highest modeled 24-hour concentration (if using five years of
meteorological data) to the highest 24-hour background concentration (from three years
of monitored data).
For this example, the project described in Appendix K.2 is located in a nonattainment
area for the 24-hour PM10 NAAQS. This example presents build scenario results for a
single receptor to illustrate how the calculations should be made based on air quality
modeling results and air quality monitoring data.

10

Values are compared after rounding. As long as the build design value is no greater than the no-build
design value after rounding, the project would meet conformity requirements at a given receptor, even if
the pre-rounding build design value is greater than the pre-rounding no-build design value.
11
A sufficient number of decimal places (3-4) in modeling results should be retained during intermediate
calculations for design values, so that there is no possibility of intermediate rounding or truncation
affecting the final result. Rounding to the nearest 10 ug/m3 should only occur during final design value
calculations, pursuant to Appendix K to 40 CFR Part 50. Monitoring values typically are reported with
only one decimal place.

K-15

K.5.2 Build Scenario

Step 1. From the air quality modeling results from the build scenario, the sixth-highest
24-hour concentration is identified at each receptor. These sixth-highest concentrations
are the sixth highest that are modeled at each receptor, regardless of year of
meteorological data used.12 AERMOD was configured to produce these values.
Step 2. The sixth-highest modeled concentrations (i.e., the concentrations at Rank 6) are
compared across receptors, and the receptor with the highest value at Rank 6 is identified.
For this example, the highest sixth-highest 24-hour concentration at any receptor is
15.218 g/m3. (That is, at all other receptors, the sixth-highest concentration is less than
15.218 g/m3.) Exhibit K-11 shows the six highest 24-hour concentrations at this
receptor.
Exhibit K-11. Receptor with the Highest Sixth-Highest 24-Hour Concentration
(Build Scenario)
Rank
1
2
3
4
5
6

Highest 24-Hour
Concentrations
17.012
16.709
15.880
15.491
15.400
15.218

Step 3. The highest 24-hour background concentration from the three most recent years
of monitoring data (2008, 2009, and 2010) is identified. In this example, the highest 24
hour background concentration from these three years is 86.251 g/m3.
Step 4. The sixth-highest 24-hour modeled concentration of 15.218 g/m3 from the
highest receptor (from Step 2) is added to the highest 24-hour background concentration
of 86.251 g/m3 (from Step 3):
15.218 + 86.251 = 101.469
Step 5. This sum is rounded to the nearest 10 g/m3, which results in a design value of
100 g/m3.
This result is then compared to the 24-hour PM10 NAAQS. In this case, the concentration
calculated at all receptors is less than the 24-hour PM10 NAAQS of 150 g/m3, therefore
12
The six highest concentrations could occur anytime during the five years of meteorological data. They
may be clustered in one or two years, or they may be spread out over several, or even all five, years of the
meteorological data.

K-16

the analysis shows that the project conforms. However, if the design value for this
receptor had been greater than 150 g/m3, the remainder of the steps in Section 9.3.4
would be completed. That is, build scenario design values for each receptor would be
calculated (Steps 6-7 in Section 9.3.4) and, for all those that exceed the NAAQS, the nobuild design values would also be calculated (Steps 8-10 in Section 9.3.4). The build and
no-build design values would then be compared.13

K.6

MATHEMATICAL FORMULAS FOR DESIGN VALUE CALCULATIONS

K.6.1 Introduction
This part of the appendix includes mathematical formulas to represent the calculations
described narratively in Section 9.3. This information is intended to supplement Section
9, which may be helpful for certain users.
Appendix K.6 relies on conventions of mathematical and logical notation that are
described after the formulas are presented. Several symbols are used that may be useful
to review prior to reading the individual formulas.
Notation symbols

x - a single bar over variable x represents a single arithmetic mean of that

variable
x - double bars over variable x represents an average of averages
x - a hat over variable x represents the arithmetic of multiple high
concentration values from different years, either from monitoring data or from
modeling results

Logical symbols

x - an upside down A before variable x means for all values of x

x - an before variable x means in x
x y - means for all x in y

The following information present equations for calculating design values for the PM2.5
annual NAAQS, 24-hour PM2.5 NAAQS, and 24-hour PM10 NAAQS. The equations are
organized into the sets that are referenced in Section 9.3.

13

Values are compared after rounding. As long as the build design value is no greater than the no-build
design value after rounding, the project would meet conformity requirements at a given receptor, even if
the pre-rounding build design value is greater than the pre-rounding no-build design value.

K-17

K.6.2 Equation Set 1: Annual PM2.5 design value

Formulas
ci
bi
p i
3

bim
m 1 3

bi

bim

j 1

pi

k 1

bijm
4

pik
l
4

pijk

j 1

When using CAL3QHCR, pik

Definitions

bi = average of three consecutive years average annual background concentrations at

receptor i
bim = quarterly-weighted average annual background concentrations at receptor i during
monitoring year m
bijm = quarterly average background concentration at receptor i, during quarter j in

monitoring year m
ci = annual PM2.5 design value at receptor i
i = receptor
j = quarter
k = year of meteorological data
l = length in years of meteorological data record
m = year of background monitoring data
pik = average modeled quarterly average concentrations at receptor i for meteorological
year k. When using AERMOD, it is presumed that AERMODs input file is used
to specify this averaging time. When using CAL3QHCR with a single quarter of
meteorological data, pik must be calculated using each pijk for each quarter of
meteorological year k.
pijk = quarterly average concentration at receptor i for quarter j, in meteorological data
year k. This variable is the product of CAL3QHCR when run with a single
quarter of meteorological data. pik can be calculated directly using AERMOD
without explicitly calculating pijk .

K-18

K.6.3 Equation Set 2: 24-Hour PM2.5 design value (First Tier Analysis)
Formulas
ci bi p i
bim bijm m

bimrm
bi
3
m1
l max [max ( p )]
k
jk
ijk
(when using CAL3QHCR), which compresses to:

p i
l

k 1
l
max k ( pik )
(when using AERMOD with maximum concentration by year)
p i
l
k 1
3

Definitions
bi = the average of 98th percentile 24-hour concentrations from three consecutive years of
monitoring data
=
daily
24-hour background concentration at receptor i, during quarter j in monitoring
bijm
year m
bim bijm m = All 24-hour background concentration measurements in year m
bimrm = The 24-hour period within year m whose concentration rank among all 24-hour
measurements in year m is rm (this represents the 98th percentile of 24-hour
background concentrations within one year.)
ci = 24-hour PM2.5 design value at receptor i
i = receptor
j = quarter
k = year of meteorological data
l = length in years of meteorological data record
m = year of background monitoring data
maxk = maximum predicted 24-hour concentration within meteorological year k
max jk = maximum predicted 24-hour concentration within quarter j within
meteorological year k
p i = average of highest predicted concentrations from each year modeled with the l years
from which meteorological data are used (5 years for off-site data, 1 year for
on-site data)
pijk = modeled daily 24-hour concentration at receptor i, in quarter j and meteorological

year k
pik = modeled daily 24-hour concentration at receptor i, in meteorological year k
rm = concentration rank of bim corresponding to 98th percentile of all bim in year m, based
on number of background concentration measurements per year (nm). rm is given
by the following table:
K-19

nm
1-50
51-100
101-150
151-200
201-250
251-300
301-350
351-366

rm
1
2
3
4
5
6
7
8

K-20

K.6.4 Equation Set 3: 24-Hour PM2.5 design value (Second Tier Analysis)
Formulas
3

ci
m1

cimrm
3

cim cijm m
cijm bijm p ij , for the eight (8) highest bijm in quarter j in monitoring year m
l max ( p )
jk
ijk
p ij

k 1

Definitions
bijm = daily 24-hour background concentration at receptor i, during quarter j in monitoring
year m
ci = 24-hour PM2.5 design value at receptor i
cijm = The set of all sums of modeled concentrations ( p ij ) with background

concentrations from quarter j and monitoring year m, using the eight highest
background concentrations ( bijm ) for the corresponding receptor, quarter, and
monitoring year.
cim cijm m = the set of all cimj corresponding to monitoring year m
cimrm = predicted 98th percentile total concentration from the project, nearby sources, and
background measurements from year m. Given by the value of cim whose
concentration rank in year m is rm, using background measurements from year m.
i = receptor
j = quarter
k = year of meteorological data
l = length in years of meteorological data record
m = year of background monitoring data
max jk = maximum predicted 24-hour concentration within quarter j within

meteorological year k
pijk = Predicted daily 24-hour concentration at receptor i, during quarter j, based on data
from meteorological year k
p ij = Average highest 24-hour modeled concentration ( pijk ) using l years of
meteorological data

rm = concentration rank of cim corresponding to 98th percentile of all cim in year m, based
on number of background concentration measurements per year (nm). rm is given
by the following table:
K-21

nm
1-50
51-100
101-150
151-200
201-250
251-300
301-350
351-366

rm
1
2
3
4
5
6
7
8

K-22

K.6.5 Equation Set 5: 24-Hour PM10 design value

Formulas
~
c~i bi ~
pi
~
bi = max in (bin )
3

bin bim

m1

~
p i p il rl

pil pik

k 1

Definitions

c~i = 24-hour PM10 design value

~
bi = maximum monitored 24-hour PM10 background concentration at within bin
bim = the set of all monitored 24-hour PM10 background concentrations at receptor i
within monitoring year m
bin = the set of all bim within monitoring years n
i = receptor
k = year of meteorological data
l = length in years of meteorological data record.
maxin = the maximum monitored 24-hour background concentration at receptor i within
monitoring years n
n = the set of all years of monitoring data, m = {1,2,3}
~
p i p il rl = modeled 24-hour PM10 concentration with concentration rank of rl among all

concentrations modeled using l years of meteorological data

pil = set of all modeled 24-hour concentrations at receptor i across l years of
meteorological data
(for example, rl = 6 when using 5 years of meteorological data)
rl = l + 1
z

= the set (finite union) of all ca with integer values of a = {1,,z}

a1

K-23

SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

Final
Localized Significance Threshold Methodology

June 2003
Revised July 2008

Executive Officer
Barry R. Wallerstein, D. Env.
Deputy Executive Officer
Planning, Rule Development and Area Sources
Elaine Chang, DrPH
Planning and Rules Manager
Jill Whynot

Authors:
Tom Chico
James Koizumi

Program Supervisor
Air Quality Specialist

Technical Assistance:
Robert Wu
Air Quality Specialist
Reviewed by:

Steve Smith, Ph.D.

Jeri Voge

Program Supervisor
Senior Deputy District Counsel

SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

GOVERNING BOARD
CHAIRMAN:

WILLIAM A. BURKE, Ed.D.

Speaker of the Assembly Appointee

VICE CHAIRMAN:

S. ROY WILSON, Ed.D.

Supervisor, Fourth District
Riverside County Representative

MEMBERS:
FRED AGUIAR
Supervisor, Fourth District
San Bernardino County Representative
MICHAEL D. ANTONOVICH
Supervisor, Fifth District
Los Angeles County Representative
JANE W. CARNEY
Senate Rules Committee Appointee
WILLIAM CRAYCRAFT
Councilmember, City of Mission Viejo
Cities Representative, Orange County
BEATRICE J.S. LAPISTO-KIRTLEY
Councilmember, City of Bradbury
Cities Representative, Los Angeles County, Eastern Region
RONALD O. LOVERIDGE
Mayor, City of Riverside
Cities Representative, Riverside County
LEONARD PAULITZ
Mayor Pro Tem, City of Montclair
Cities Representative, San Bernardino County
JAMES SILVA
Supervisor, Second District
Orange County Representative
CYNTHIA VERDUGO-PERALTA
Governor's Appointee
VACANT
Councilmember, City of Los Angeles
Cities Representative, Los Angeles County, Western Region
EXECUTIVE OFFICER:
BARRY R. WALLERSTEIN, D.Env

Acknowledgements
The following members of the Localized Significance Threshold Working Group and
interested parties provided valuable input and their assistance was greatly appreciated.
Name
Ms. Detrich Allen
represented by Ms. Renee
Brandt
Dr. Hsiaoching Chen
Mr. Bill Piazza
Mr. Randy Scott
Name
Mr. Mark Hagmann*
Mr. Bill LaMar*
Mr. Michael Lewis*
Mr. Clayton Miller
Mr. Jeb Stuart*
Ms. Carla Walecka*
Mr. Lee Wallace*
Mr. Rick Zbur
Name
Mr. Bahram Fazeli

Agency Representatives
City of Los Angeles, Environmental Affairs
Department
Los Angeles County Regional Planning
Los Angeles Unified School District
County of San Bernardino Planning Department
Industry Representatives
PCR Services Corporation
California Small Business Alliance
Construction Industry Air Quality Coalition
Construction Industry Air Quality Coalition
Construction Industry Air Quality Coalition
Realtors Committee on Air Quality
Sempra Energy Utilities
Latham & Watkins
Environmental/Community Representatives
Communities for a Better Environment

* Interested party, non-Working Group Member attendee

PREFACE
In accordance with Governing Board direction, SCAQMD staff has developed this methodology
to assist lead agencies in analyzing localized air quality impacts from proposed project. This
methodology is guidance and is VOLUNTARY. Localized significance threshold (LST) lookup tables for one, two and five acre proposed projects emitting carbon monoxide (CO), oxides of
nitrogen (NOx), particulate matter less than 2.5 microns in aerodynamic diameter (PM2.5) or
particulate matter less than 10 microns in aerodynamic diameter (PM10) were prepared for easy
reference according to source receptor area. SCAQMD recommends that lead agencies perform
project-specific modeling for larger projects in determining localized air quality impacts.
The LST methodology was developed to be used as a tool to assist lead agencies to analyze
localized impacts associated with project-specific level proposed projects.
The LST
methodology and associated mass rates are not designed to evaluate localized impacts from
mobile sources traveling over the roadways. Further, LSTs are applicable to projects at the
project-specific level and are not applicable regional projects such as General Plans. The LST
methodology and associated mass rate look-up tables will be included as an update to the
SCAQMD CEQA Air Quality Handbook upon Governing Boards approval.
Subsequent to the adoption of the Final Significance Threshold Methodology, SCAQMD
Governing Board adopted significant thresholds for PM2.5; the California Air Resources Board
(ARB) revised the 1-hour nitrogen dioxide (NO2) Ambient Air Quality Standard (AAQS) from
0.25 ppm to 0.18 ppm, and established a new annual average standard of 0.03 ppm. The Final
Significance Threshold Methodology was revised in July of 2008 to include the PM2.5
significant threshold methodology and update the LST Mass Rate Look-up Tables for the 1-hour
NO2 AAQS.

Table of Contents

TABLE OF CONTENTS
Chapter 1 Introduction ..................................................................................................
Legal Authority........................................................................................................
Background ..............................................................................................................
Basic Approach........................................................................................................

1-1
1-2
1-3
1-4

Chapter 2 Methodology..................................................................................................
Model .......................................................................................................................
Source Treatment .....................................................................................................
Receptor Grid...........................................................................................................
Meteorology.............................................................................................................
Background CO and NO2 Air Quality .....................................................................
PM2.5 and PM10 Air Quality..................................................................................
NO2-to-NOx Ratio...................................................................................................
Deriving Localized Significance Thresholds...........................................................

2-1
2-1
2-2
2-2
2-2
2-5
2-7
2-8
2-9

Chapter 3 Screening Tables and Their Use...................................................................

Estimate Emissions ..................................................................................................
Determine the Source/Receptor Area of the Proposed Construction/
Operational Activity.................................................................................................
Estimate the Receptor Distance ...............................................................................
Mitigation Measures ................................................................................................
Limitations of the Screening Tables ........................................................................
Example Project .......................................................................................................
Sample Calculations.................................................................................................

3-1
3-2
3-2
3-2
3-3
3-3
3-4
3-5

Chapter 4 Conclusion ..................................................................................................... 4-1

Chapter 5 References...................................................................................................... 5-1
APPENDIX A PEAK BACKGROUND CONCENTRATIONS FOR THE 1999-2001
PERIOD
APPENDIX B DIFFERENCES BETWEEN THE MOST STRINGENT AMBIENT
AIR QUALITY STANDARD AND AMBIENT CONCENTRATIONS
FOR EACH SRA FOR THE 1999-2001 PERIOD
APPENDIX C LOCALIZED SIGNIFICANCE THRESHOLD SCREENING
TABLES
LIST OF TABLES
Table 2-1: Number and Dimensions of Volume Sources .......................................
Table 2-2: 1981 Meteorological Data for Dispersion Modeling.............................
Table 2-3: SCAQMD Stations Measuring CO or NO2 ...........................................
Table 2-4: NO2-to-NOX Ratio as a Function of Downwind Distance ...................
Table 3-1: Typical Projects .....................................................................................
Table 3-2: Typical Projects Where Screening Tables May Not Apply ..................
i

2-3
2-6
2-7
2-9
3-3
3-43

Table of Contents

LIST OF FIGURES
Figure 2-1: Volume and Area Sources ...................................................................
Figure 2-2: Comparison of Vertical Concentration Profiles...................................
Figure 2-3: 1981 District Meteorological Sites ......................................................
Figure 2-4: Source/Receptor Areas in the District..................................................
Figure 2-5: NO2-to-NOx Ratio as a Function of Downwind Distance ...................

ii

2-3
2-4
2-4
2-5
2-8

List of Abbreviations and Acronyms

LIST OF ABBREVIATIONS AND ACRONYMS

Abbreviation/Acronym
AAQS
AQMD
Avg
Basin
CAAQS
CAIL
Cb
Cu
CARB
CEQA
DRI
DRYDPLT
EJ
EPA
FY
Handbook
hr
ID
ISC3
lb
m
MET
mg
NO
NOCALM
NO2
NOx
OEHHA
PM
PM10
pphm
ppm
SIP
SRA
U
URBAN
UTM
VOC
g

Description
Ambient Air Quality Standard
South Coast Air Quality Management district
Average
South Coast Air Basin
Ambient Air Quality Standard Concentration
Acceptable Impact Level Concentration
Background Concentration
Peak Predicted Concentration Estimated by ISC3
California Air Resources Board
California Environmental Quality Act
Desert Research Institute
Dry Plume Depletion
Environmental Justice
United States Environmental Protection Agency
Financial Year
SCAQMD Air Quality CEQA Handbook
Hour
Identification
Industrial Source Complex, version 3
Pound
Meter
Meteorological Correction Factors
Milligram
Nitric Oxide
No Calm Wind Processing
Nitrogen Dioxide
Oxides of Nitrogen
Office of Environmental Health Hazard Assessment
Particulate Matter
Particulate of Less Than 10 Microns in Aerodynamic Diameter
Parts per Hundred Million
Parts per Million
State Implementation Plan
Source Receptor Area
Unit Emission Rate
Urban Dispersion Parameters
Universal Transverse Mercator
Volatile Organic Compound
Microgram

iii

Chapter 1 Introduction

CHAPTER 1
INTRODUCTION
In 1993, the South Coast Air Quality Management District (SCAQMD) Governing Board
adopted the CEQA Air Quality Handbook (Handbook). This Handbook contains
guidance for other public agencies when preparing an air quality analysis for California
Environmental Quality Act (CEQA) or National Environmental Policy Act (NEPA)
analyses. In addition to providing guidance for analyzing air quality impacts, the
Handbook also contains indicators of significance recommended for use by other public
agencies. The most widely used of the significance thresholds in the Handbook are the
mass daily significance thresholds for construction and operation, which indicate that a
project has significant adverse regional effects on air quality.
More recently as part of the SCAQMDs environmental justice program, attention has
focused on localized effects of air quality. In accordance with Governing Board
direction, staff has developed localized significance threshold (LST) methodology and
mass rate look-up tables by source receptor area (SRA) that can be used by public
agencies to determine whether or not a project may generate significant adverse localized
air quality impacts. LSTs represent the maximum emissions from a project that will not
cause or contribute to an exceedance of the most stringent applicable federal or state
ambient air quality standard, and are developed based on the ambient concentrations of
that pollutant for each source receptor area.
Use of LSTs by local government is VOLUNTARY. The staff proposal recommends
using the LST mass rate look-up tables only for projects that are less than or equal to five
acres. It should be noted that lead agencies are not precluded from performing projectspecific modeling if they prefer more precise results. It is recommended that lead
agencies perform project-specific air quality modeling for larger projects. LSTs are
applicable at the project-specific level and generally are not applicable to regional
projects such as local General Plans unless specific projects are identified in the General
Plans.
The use of LSTs is VOLUNTARY, to be implemented at the discretion of local agencies.
LSTs would only apply to projects that trigger a CEQA review. Therefore, projects that
are statutorily or categorically exempt under CEQA would not be subject to LST
analyses. Exemptions include infill projects that meet the H&S Code provisions or
projects identified by lead agencies as ministerial. The methodology and screening tables
are included as an appendix to this Handbook.
Staff has developed implementation tools to assist in evaluation of projects. Guidance
information, such as typical scenarios and sample calculations are included as an
appendix to this Handbook. The sample calculations and scenarios include estimations of
both regional and localized impacts for ease of use. If the lead agencies decide to follow
the LST methodology and determine that the proposed projects might exceed LSTs,
please consult Chapter 11 of the CEQA Handbook (1993) for applicable mitigation

Final Localized Significance Threshold Methodology 1-1

June 2003, Revised July 2008

Chapter 1 Introduction

measures. SCAQMD staff is available to assist lead agencies or project proponents in

addressing implementation issues.
The LST mass rate look-up tables provided in Appendix C allow a user to readily
determine if the daily emissions for proposed construction or operational activities could
result in significant localized air quality impacts. If the calculated emissions for the
proposed construction or operational activities are below the LST emission levels found
on the LST mass rate look-up tables and no potentially significant impacts are found to
be associated with other environmental issues, then the proposed construction or
operation activity is not significant for air quality. Proposed projects whose calculated
emission budgets for the proposed construction or operational activities are above the
LST emission levels found in the LST mass rate look-up tables should not assume that
the project would necessarily generate adverse impacts. Detailed air dispersion modeling
may demonstrate that pollutant concentrations are below localized significant levels. The
lead agency may choose to describe project emissions above those presented in the LST
mass rate look-up tables as significant or perform detailed air dispersion modeling or
perform localized air quality impact analysis according to their own significance criteria.
The LST mass rate look-up tables are applicable to the following pollutants only: oxides
of nitrogen (NOX), carbon monoxide (CO), particulate matter less than 2.5 microns in
aerodynamic diameter (PM2.5) and particulate matter less than 10 microns in
aerodynamic diameter (PM10). LSTs are derived based on the location of the activity
(i.e., the source/receptor area); the emission rates of NOX, CO, PM2.5 and PM10; and the
distance to the nearest exposed individual. The location of the activity and the distance to
the nearest exposed individual can be determined by maps, aerial and site photos, or site
visits. The NOx, CO, PM2.5 and PM10 emission factors and/or rates are the same
emission factors/rates identified in the Handbook, AP-42, EMFAC, Offroad, etc.
This document explains the methodology, specifically pollutant dispersion modeling used
to develop the LST mass rate look-up tables and how one uses the procedures to
determine the significance or insignificance of project activities for air quality. This
document will become part of the revised Handbook.
LEGAL AUTHORITY
CEQA Guidelines 15022(a) states that a public agency shall adopt objectives, criteria,
and specific procedures consistent with CEQA and these [State] Guidelines for
administering its responsibilities under CEQA. CEQA Guidelines 15022(d) states
further, In adopting procedures to implement CEQA, a public agency may adopt the
State CEQA Guidelines through incorporation by reference. The agency may then adopt
only those specific procedures or provisions described in subsection [15022] (a) which
are necessary to tailor the general provisions of the guidelines to the specific operations
of the agency. At the December 11, 1998 Public Hearing the SCAQMDs Governing
Board formally incorporated by reference the State CEQA Guidelines as the
implementing guidelines for the SCAQMDs CEQA program. Adopting LSTs would be
consistent with CEQA Guidelines 15022 provision to tailor a public agencys

Final Localized Significance Threshold Methodology 1-2

June 2003, Revised July 2008

Chapter 1 Introduction

implementing guidelines by adopting criteria relative to the specific operations of the

SCAQMD.
Specifically with regard to thresholds of significance, CEQA Guidelines 15064.7(a)
states, "Each public agency is encouraged to develop and publish thresholds of
significance that the agency uses in the determination of the significance of
environmental effects. Subsection (b) of the same section states further, Thresholds of
significance to be adopted for general use as part of the lead agencys environmental
review process must be adopted by ordinance, resolution, rule or regulation, and
developed through a public review process and be supported by substantial evidence.
The methodology for developing LSTs and the resulting LST mass rate look-up tables
developed by the SCAQMD have undergone a public review process as part of
stakeholder working group meetings that are open to the public. This methodology
document provides the substantial evidence relative to the methodology for developing
LSTs. After completion of the public process, the LST methodologies will be heard by
the SCAQMDs Governing Board at a public meeting, where they will be considered for
adoption by resolution, consistent with CEQA Guidelines 15064.7(b).
This
methodology and associated LSTs are recommendations only and not mandatory
requirements. The methodology and LSTs may be used at the discretion of the local lead
agency.
BACKGROUND
At the October 10, 1997 Board Meeting, the SCAQMD Governing Board adopted the
Guiding Principles and Workplan to Implement Environmental Justice Initiatives.
Environmental Justice (EJ) Initiative #4 CEQA Commenting, directed the SCAQMD to
reconstruct its CEQA commenting function, called intergovernmental review. As
specified in the Workplan, EJ Initiative #4 included updating the CEQA Handbook by
creating and working with a stakeholders review group.
Consistent with EJ Initiative #4 staff began the formal Handbook revision process by
creating a Handbook revision working group of stakeholders comprised of local
government planners; representatives of local councils of government; environmental
groups; the building and construction industries; and other interested individuals. In
1998, the SCAQMD started a series of Handbook revision working group meetings. One
of the issues identified by the stakeholders was a request to address localized air quality
impacts. With respect to criteria pollutants, the existing Handbook only discussed
localized impacts as part of focused CO "hotspots" analyses prepared for mobile sources.
Assessing localized air quality impacts requires using complex dispersion models.
Therefore, to address the issue of localized significance, yet be sensitive to the fact that
other public agencies might not have the expertise or adequate financial resources to
perform complex dispersion modeling, in addition to the methodology itself, SCAQMD
staff began developing a proposal to establish localized significance thresholds in a form
similar to the regional significance thresholds, that is, based on the amount of pounds of
emission per day generated by a proposed project that would cause or contribute to
localized air quality impacts.

Final Localized Significance Threshold Methodology 1-3

June 2003, Revised July 2008

Chapter 1 Introduction

After developing the methodology for deriving LSTs, staff presented the concept,
methodologies, and a retrospective study on the use of LSTs at Governing Board Mobile
Source Committee meetings. In the fourth quarter of 2001, staff presented the LST
proposal to the Mobile Source Committee. Because of concerns and issues raised by
committee members, the Mobile Source Committee recommended that staff seek
approval from the Governing Board before proceeding with further development of the
LSTs. On February 1, 2002, the Governing Board directed staff to continue developing
LSTs and report back to the Board for consideration and possible incorporation into a
revised Handbook.
On September 13, 2002, the Governing Board approved the implementation of the
Environmental Justice Program Enhancements for FY 2002-03. In connection with
approving the Environmental Justice Program Enhancement for FY 2002-03, the Board
directed staff to implement 23 enhancements to the original Environmental Justice
Program divided into three categories. Category I: Further-Reduced Health Risk,
Enhancement I-4 included a proposal to continue to develop localized significance
thresholds for subregions of the air district, as another indicator of CEQA significance.
Enhancement I-4 also directed staff to continue developing localized significance
thresholds through a stakeholder working group. Staff has since met with the stakeholder
working group two times and, with input from the stakeholder working group, developed
a proposal to implement Enhancement I-4.
BASIC APPROACH
An air quality analysis typically separates a projects emissions into construction and
operational activity emissions because these two activities are typically sequential.
Relative to the staff proposal, the emissions of concern from construction activities are
NOx, CO and PM2.5 combustion emissions from construction equipment1 and fugitive
PM 2.5 and PM10 dust from construction site preparation activities. The primary
emissions from operational activities include, but are not limited to NOx and CO
combustion emissions from stationary sources and/or on-site mobile equipment. Some
operational activities may also include fugitive PM2.5 and PM10 dust generating
activities such as aggregate operations or earthmoving activities at landfills. Off-site
mobile emissions from the project should NOT be included in the emissions compared to
the LSTs.
LSTs are derived using one of three methodologies depending upon the attainment status
of the pollutant. For attainment type pollutants, nitrogen dioxide (NO2) and CO2, the
1

Construction equipment also emits PM10, but for simplicity these emissions should be combined with the
fugitive PM10 dust when using the LST procedures provided below.
2
Although the district was not designated as in attainment with the CO ambient air quality standards when
the LSTs were developed, it was treated as an attainment pollutant since CO concentrations hadnot
exceeded any CO ambient air quality standards for the two years prior to the adoption of the LSTs.
Therefore, for developing LSTs, the attainment pollutant approach is applicable. The district was
redesignated as in attainment for CO in 2002. The district was designated in NO2 attainment by the State in
2003, and NO2 concentration had been below the State AAQS for three years prior. The district has been
designated as in NO2 attainment for the federal standard since 1995. In 2007, the State AAQS standards

Final Localized Significance Threshold Methodology 1-4

June 2003, Revised July 2008

Chapter 1 Introduction

mass rate LSTs are derived using an air quality dispersion model to back-calculate the
emissions per day that would cause or contribute to a violation of any short-term AAQS
for a particular SRA. The most stringent of the federal and state standards for NO2 is the
1-hour state standard of 18 parts per hundred million (pphm); and for CO it is the 1-hour
and 8-hour state standards of nine parts per million (ppm) and 20 ppm, respectively.
LSTs are developed based upon the size or total area of the emissions source, the ambient
air quality3 in each source receptor area (SRA) in which the emission source is located,
and the distance to the sensitive receptor. LSTs for NO2 and CO are derived by adding
the incremental emission impacts from the project activity to the peak background NO2
and CO concentrations and comparing the total concentration to the most stringent
ambient air quality standards. Background criteria pollutant concentrations are
represented by the highest measured pollutant concentration in the last three years at the
air quality monitoring station nearest to the proposed project site.
Construction PM 2.5 and PM10 LSTs are developed using a dispersion model to backcalculate the emissions necessary to exceed a concentration equivalent to 50 micrograms
per cubic meter (g/m3) averaged over five hours, which is the control requirement in
Rule 403. The equivalent concentration for developing PM 2.5 and PM10 LSTs is
10.4 g/m3, which is a 24-hour average.
Operational PM 2.5 and PM10 LSTs are derived using an air quality dispersion model to
back-calculate the emissions necessary to make an existing violation in the specific SRA
worse, using the allowable change in concentration thresholds in Table A-2 in Rule 1303.
For PM 2.5 and PM10 the allowable change in concentration thresholds is 2.5 g/m3.
These levels represent measurable impacts taking into account modeling sensitivity.
The staff proposal recommends using the LST mass rate look-up tables only for projects
that are less than or equal to five acres. It should be noted that lead agencies are not
precluded from performing project-specific modeling if they prefer more precise results.
It is recommended that lead agencies perform project-specific air quality modeling for
larger projects. Lead agencies have the discretion to identify appropriate thresholds and
analysis methodologies.
If mitigation measures are needed, please refer to Chapter 11 of the Handbook. Lead
agencies may use mitigation measures beyond those identified in the Handbook and
District staff is available for technical consultation.

were lowered to 0.18 ppm for the NO2 1-hour standard and 0.030 ppm was established as the NO2 annual
average standard. Since the standards have become affective, the NO2 concentrations have been below the
new 1-hour standard. However, there was a single location (SRA 10 Pomona/Walnut Valley) that
exceeded the NO2 annual average standard in 2007 (0.0318 ppm). The LSTs were developed based on
short-term standards (less than 24 hour concentration standards). Since all NO2 concentrations in the
district are less than the new one-hour standard, NOx is still treated as an attainment pollutant.
3
Ambient air quality information is based on the pollutant concentrations measured at the SCAQMDs
monitoring stations in or near the specified SRA.

Final Localized Significance Threshold Methodology 1-5

June 2003, Revised July 2008

Chapter 1 Introduction

The concepts inherent in the above staff recommendations are generally consistent with
the modeling requirement in SCAQMD Rule 1303(b)(1), which states that the Executive
Officer shall deny a Permit to Construct for any new or modified source with an emission
increase unless, The applicant substantiates with modeling that the new facility or
modification will not cause a violation, or make significantly worse an existing
violation of any AAQS at any receptor in the district. It should be noted that there are
some modeling assumptions used to derive mass rate LSTs that are unique for this
purpose and not intended for Regulation XIII permitting applications. Therefore, the
modeling methodology described in this document should not be used to comply with
Rule 1303 modeling requirements. The actual methodology used to derive the mass rate
LSTs is described in more detail in Chapter 2.

Final Localized Significance Threshold Methodology 1-6

June 2003, Revised July 2008

CHAPTER 2
METHODOLOGY
This chapter describes the technical approach used to derive the mass rate LSTs. The models
used to derive the mass rate LSTs are briefly described, including adjustments to the outputs,
which attempt to incorporate more realistic parameters into the modeling results.
MODEL
Two distinct modeling approaches were used to develop the mass rate LSTs for the gaseous
pollutants (i.e., NO2 and CO) and particulate matter (i.e., PM10). A U.S. Environmental
Protection Agency (EPA)-approved dispersion model was used for NO2, CO, and PM 2.5. For
PM10, a combination of a U.S. EPA-approved dispersion model and an empirical equation,
developed by Desert Research Institute (DRI)4 were used to describe concentration changes as a
function of downwind distance.
NO2, CO and PM2.5
Version 3 of the U.S. EPA approved air quality model called Industrial Source Complex (i.e.,
ISC3) was used to develop the mass rate LSTs discussed here for NO2, CO, and PM2.5. The
short-term version of the model was applied using hourly meteorological data from numerous
sites in the district. Important model options employed include: urban dispersion parameters
(i.e., URBAN) and no calm wind processing (i.e., NOCALM). All other model options assumed
the model default values.
PM10
For PM10, the short-term version of ISC3 was used to estimate PM10 concentrations at 25
meters from the boundary of the construction area, 1,000 meters from the boundary of the
construction area, and beyond. Since fugitive dust consists of a significant fraction of large
particles greater than 10 microns, plume depletion due to dry removal mechanisms was assumed
(i.e., DRYDPLT). The fugitive PM10 emissions are separated into the three particle sizes of less
than one micron (m), 1.0 to 2.5 m, and 2.5 to 10 m in aerodynamic diameter, which have the
assumed weight fractions of 7.87, 12.92, and 79.22 percent, respectively. The particle density
for all three size bins is 2.3 grams per cubic centimeter.
For downwind distances from the boundary of the construction area to 100 meters, the following
equation was used to describe the change in PM10 concentration versus downwind distance:
Cx = 0.9403 Co e -0.0462 x

Eq. 1

Where: Cx is the predicted PM10 concentration at x meters from the fence line;
Co is the PM10 concentration at the fence line as estimated by ISC3;
e is the natural logarithm; and
x is the distance in meters from the fence line.
4

Desert Research Institute, 1996.

Final Localized Significance Threshold Methodology

2-1

June 2003, Revised July 2008

Equation 1 was developed from the 1996 DRI study of fugitive dust control measures for
unpaved roads. Concentrations are linearly interpolated between the two approaches for
downwind distances from 100 to 500 meters.
SOURCE TREATMENT
Mass rate LSTs for construction and operational activities for one-, two-, and five-acre sites have
been developed. Exhaust emissions from construction equipment are treated as a set of side-byside elevated volume sources. These volume sources are illustrated in Figure 2-1. The number
and dimensions of the volume sources for each analyzed acreage are shown in Table 2-1. The
release height is assumed to be five meters. This represents the mid-range of the expected plume
rise from frequently used construction equipment during daytime atmospheric conditions. All
construction exhaust emissions are assumed to take place over the eight-hour period between
8 a.m. to 4 p.m. Mass rate LSTs may be used for operational sources with parameters similar to
the construction parameters presented above.
Fugitive dust emissions are treated as a ground-based square area source with the dimension of
the acreage analyzed. For example, the one-acre construction site is 63.6 meters on a side and
the five-acre construction site is 142.2 meters on a side. An initial vertical dimension of one
meter is assumed to represent the initial vertical spread of the emissions. Based on this
assumption, the initial vertical dimension resulted in a vertical concentration profile that closely
matched the vertical profile observed by DRI (1996), as shown in Figure 2-2. As with the
construction equipment, all the fugitive dust emissions are assumed to be emitted over the eighthour period, 8 a.m. to 4 p.m. Area sources are illustrated in Figure 2-1.
RECEPTOR GRID
A radial receptor grid is used to determine impacts. The grid is centered on the source and is
built in ten degree increments at the following downwind distances from the hypothetical
proposed project boundary: 25, 50, 100, 200, and 500 meters. Flat terrain is assumed, since
emissions sources from construction activities are primarily ground-based. All receptors are
placed within the breathing zone at two meters above ground level. Figure 2-1 illustrates the
relationship between the source and receptors.
METEOROLOGY
For modeling purposes, the SCAQMD uses 1981 meteorological data (i.e., hourly winds,
temperature, atmospheric stability, and mixing heights) from 35 sites in the district, as shown in
Figure 2-3 and listed in Table 2-2. The 1981 meteorological data are used because this data set
represents the most complete and comprehensive data set currently compiled. These data are
available at the SCAQMDs web site (www.aqmd.gov/metdata) and is in a format that can be
directly read by ISC3. Using this meteorological data set, LSTs are developed for each of the
37 source receptor areas (SRAs) within the SCAQMDs jurisdiction (see Figure 2-4). LSTs
were not developed for SRA 14, because it is outside of the SCAQMDs jurisdiction. Sitespecific meteorological data may also be used the concurrence from the District staff. A projects
located close to the boundaries of another SRA may use the LSTs for that SRA if the monitored
concentrations better represent the ambient air quality surrounding that project..

Final Localized Significance Threshold Methodology

2-2

June 2003, Revised July 2008

NOx and CO
Adjacent Volume Sources
Project site represented
by elevated volume
sources

Receptor
two meter height

Five meter release

height with a 1.4
meter initial vertical
dimension

Distance from project

boundary to receptor

Receptor grid

PM10
Area Source

Project site
represented by
elevated area sources
Surface release with
a one meter initial
vertical dimension

Receptor
two meter height

Distance from project

boundary to receptor

Receptor grid

Figure 2-1. Volume and Area Sources

Table 2-1. Number and Dimensions of Volume Sources

Area
1 acre
2 acres
5 acres

Number of volume sources

36
81
49

Final Localized Significance Threshold Methodology

Dimensions of volume source

10 by 10 meters
10 by 10 meters
20 by 20 meters

2-3

June 2003, Revised July 2008

1.2

Normalized Concentration

0.8

0.6

0.4

0.2

0
0

Height Above Ground (m)

Initial vertical dimension of 1 meter

DRI observation

Figure 2-2. Comparison of Vertical Concentration Profiles

NEWHALL

LA CANADA
RESEDA
BURBANK
CANOGA PARK

AZUSA
UPLAND

PASADENA
WEST LOS ANGELES
POMONA
LOS ANGELES
PICO RIVERA
WALNUT
VERNON
MALIBU
HAWTHORNE
WHITTIER
KING HARBOR LYNWOOD
SCAQMD
AIR MONITORING NETWORK
SOUTH COAST
AIR BASIN (SCAB)
COUNTY LINES
AIR MON ITOR ING
STATION

REDLANDS
FONTANA

RIVERSIDE

LA HABRA
NORCO
SANTA ANA CANYON

LONG BEACH
ANAHEIM

LOS ALAMITOS
COSTA MESA
EL TORO

25

0
M I L ES
1981 VERSION
Federal Standard

Figure 2-3. 1981 District Meteorological Sites

Final Localized Significance Threshold Methodology

2-4

June 2003, Revised July 2008

Figure 2-4. Source/Receptor Areas in the District

BACKGROUND CO AND NO2 AIR QUALITY
To determine whether or not construction activities create significant adverse localized air
quality impacts, the emissions contribution from the project is added to ambient concentrations
and the total is then compared to the most stringent applicable state and/or federal ambient air
quality standards for CO and NO2. In order to be able to make this determination, it is necessary
to know the background concentrations in the vicinity of the proposed project site. The modeled
incremental impacts from project activities are added to the background values to estimate the
peak impacts downwind of the activities. The LST concentrations are derived by ensuring that
the total concentrations (i.e., background plus project contribution) are just less than the most
stringent applicable state and federal ambient air quality standards. The methodology for
identifying the background concentrations is outlined in the following paragraphs.
Table 2-3 lists the SCAQMD air quality monitoring stations that measure CO or NO2 in the
district. At the time of LST adoption, a database of annual concentrations was assembled for the
period 1999 to 2001. Peak one-hour CO and NO2, and peak eight-hour CO concentrations for
the three-year period were identified.
The observed peak one-hour CO, one-hour NO2, and eight-hour CO concentrations for the
three-year period are given in Appendix A for each available station. The peak concentrations
for each year and for the three-year period as a whole are provided. The difference between the
peak concentrations and the relevant state and federal standards determines the allowable mass
emissions for the construction activities that would not result in significant adverse localized air
quality impacts.

Final Localized Significance Threshold Methodology

2-5

June 2003, Revised July 2008

Table 2-2. 1981 Meteorological Data for Dispersion Modeling

Station ID
Surface

Upper air

53071
54097
54144
51100
51067
53112
53126
52075
53128
54149
54146
53012
51108
53099
51117
52118
53101
53127
52130
52104
51115
54167
54145
51122
53134
54109
54161
51107
54139
53137
54147
52132
54106
52158
53114

91919
99999
99999
99999
99999
91919
91919
91919
91919
99999
99999
91919
99999
91919
99999
91919
91919
91919
91919
91919
99999
99999
99999
99999
91919
99999
99999
99999
99999
91919
99999
91919
99999
91919
91919

UTM (kilometer)
Site Name
Anaheim
Azusa
Banning
Burbank
Canoga Park
Compton
Costa Mesa
Downtown Los Angeles
El Toro
Fontana
Indio
King Harbor
La Canada
La Habra
Lancaster
Lennox
Long Beach
Los Alamitos
Lynwood
Malibu
Newhall
Norco
Palm Springs
Pasadena
Pico Rivera
Pomona
Redlands
Reseda
Riverside
Santa Ana Canyon
Upland
Vernon
Walnut
West Los Angeles
Whittier

Easting

Northing

415.0
414.9
510.5
379.5
352.9
385.5
413.8
386.9
436.0
455.4
572.3
371.2
388.2
412.0
396.0
373.0
390.0
404.5
388.0
344.0
355.5
446.8
542.5
396.0
402.3
430.8
486.2
359.0
464.8
431.0
440.0
387.4
420.0
372.3
405.3

3742.5
3777.4
3754.5
3783.0
3786.0
3750.3
3724.2
3770.1
3720.9
3773.9
3731.0
3744.4
3786.1
3754.0
3839.5
3755.0
3743.0
3739.8
3754.0
3766.9
3805.5
3749.0
3742.5
3778.5
3764.1
3769.6
3769.4
3785.0
3758.6
3748.4
3773.1
3762.5
3761.7
3768.6
3754.0

UTM = Universal Transverse Mercator

Final Localized Significance Threshold Methodology

2-6

June 2003, Revised July 2008

Table 2-3. SCAQMD Stations Measuring CO or NO2

Pollutant measured
Station
Central LA
Northwest Coastal LA County
Southwest Coastal LA County
South Coastal LA County
West San Fernando Valley
East San Fernando Valley
West San Gabriel Valley
East San Gabriel Valley 1
East San Gabriel Valley 2
Pomona/Walnut Valley
South San Gabriel Valley
South Central LA County 1
South Central LA County 2
Santa Clarita Valley
North Orange County
Central Orange County
North Coastal Orange County
Saddleback Valley 1
Saddleback Valley 2
Norco/Corona
Metropolitan Riverside County 1
Metropolitan Riverside County 2
Perris Valley
Lake Elsinore
Banning Airport
Coachella Valley 1
Coachella Valley 2
Northwest San Bernardino Valley
Southwest San Bernardino Valley
Central San Bernardino Valley 1
Central San Bernardino Valley 2
East San Bernardino Valley
Central San Bernardino Mountains
East San Bernardino Mountains

CO

NO2

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X

X
X

X
X
X
X

X
X
X
X
X

X
X

PM2.5 AND PM10 AIR QUALITY

PM2.5 and PM10 impacts are treated differently than CO and NO2, since, as mentioned earlier,
nearly the entire district exceeds the state or federal PM2.5 and PM10 standards. Therefore, the
incremental PM2.5 and PM10 impacts from construction are derived based on the change in
concentration threshold of 10.4 g/m3 (24-hour average), which is comparable to the

Final Localized Significance Threshold Methodology

2-7

June 2003, Revised July 2008

requirement in paragraph (d)(4) in SCAQMD Rule 403, which prohibits fugitive dust
concentrations beyond a projects boundary that exceed 50 g/m3 (averaged over five hours) (see
footnote #3). PM2.5 and PM10 impacts from operational activities are derived based on the
allowable change in concentration threshold of 2.5 g/m3 in Table A-2 of Rule 1303 (see
footnote #4). Because the entire district is nonattainment for PM2.5 and PM10, determining
background PM2.5 and PM10 concentrations is unnecessary. However, meteorological
conditions in the source receptor areas will ultimately affect the PM2.5 and PM10 LSTs.
NO2-TO-NOX RATIO
Combustion processes occurring from equipment yield NOX emissions. The two principal NOX
species are nitric oxide (NO) and nitrogen dioxide (NO2), with the vast majority (95 percent) of
the NOX emissions being comprised of NO. Adverse health effects are associated with NO2, not
NO. NO is converted to NO2 by several processes, the two most important of these are (1) the
reaction of NO with ozone and (2) the photochemical reaction of NO with hydrocarbon radical
species. Destruction of NO2 occurs with its photodissociation into NO and molecular oxygen.
NOX emissions are simulated in the air quality dispersion model and the NO2 conversion rate is
treated by an NO2-to-NOX ratio, which is a function of downwind distance. Initially, it is
assumed that only five percent of the emitted NOX is NO2. At 500 meters downwind, 100
percent conversion of NO-to-NO2 is assumed. The assumed NO2-to-NOX ratios between those
distances are presented in Figure 2-5. The NO2 conversion rates are adapted from work by
Arellano et al.5.

Ratio

0.8
0.6
0.4
0.2
0
0

1000

2000

3000

4000

5000

Downwind Distance (m)

Figure 2-5. NO2-to-NOX Ratio as a Function of Downwind Distance

Arellano, J.V., A.M. Talmon, and P.J.H. Builtjes, 1990.

Final Localized Significance Threshold Methodology

2-8

June 2003, Revised July 2008

Table 2-4. NO2-to-NOX Ratio as a Function of Downwind Distance

Downwind Distance (m)
20
50
70
100
200
500
1000
2000
3000
4000
5000

NO2/NOx Ratio
0.053
0.059
0.064
0.074
0.114
0.258
0.467
0.75
0.9
0.978
1

DERIVING LOCALIZED SIGNIFICANCE THRESHOLDS

Localized Significance Thresholds by Concentration
LSTs by concentrations were used to develop mass rate LSTs. Project proponents, who choose
to perform project specific air quality dispersion modeling, should use LST concentrations to
determine adverse air quality impacts. Project proponents can either follow the procedures
presented below to develop LSTs by concentration or use the tables in Appendix B, and
Rules 403 and 1301.
Gaseous Pollutants (NOx and CO)
To derive the LST concentrations it is necessary to know the concentration of the most stringent
ambient air quality standard and the ambient concentration for the pollutant under consideration
in a specified SRA. The difference between the ambient air quality standard and the peak
ambient concentration in the SRA produces a concentration that is then converted into mass
emissions. The mass emissions result is the maximum amount of emissions a project can emit,
when added to ambient concentrations, without causing or contributing to an exceedance of the
most stringent applicable ambient air quality standard (i.e., background + project contribution).
The resulting mass emissions amount is the LST for the pollutant under consideration for the
specified SRA. The LST concentrations for NOx and CO, which are the differences in
concentration between the most stringent ambient air quality standard and the peak ambient
concentrations for each SRA are shown in Appendix B. The project contribution emissions level
is derived using the following equation:
CPC = CAAQS Cb

Eq. 2

Where: CPC is the project contribution emission levels in micrograms per cubic meter;
Cb is the background concentration measured at the closest air quality monitoring station
in micrograms per cubic meter; and
CAAQS is the limiting state or federal standards in micrograms per cubic meter.
Final Localized Significance Threshold Methodology

2-9

June 2003, Revised July 2008

Particulate Matter
The LST concentrations for particulate matter are the concentration thresholds presented in
Rules 403 and 1301. The Rule 403 threshold of 10.4 microns per cubic meter applies to
construction activities, and may apply to operational activities at aggregate handling facilities.
The Rule 1301 threshold of 2.5 microns per cubic meter applies to nonaggregate handling
operational activities.
Localized Significance Thresholds by Mass Rate
LSTs represent the maximum emissions from a project that will not cause or contribute to an
exceedance of the most stringent applicable federal or state ambient air quality standard, and are
developed based on the ambient concentrations of that pollutant for each source receptor area.
The mass rate LSTs are estimated using an air dispersion model.
Air Dispersion Modeling
A unit emission rate is the single unit of mass over time or emissions rate (e.g., one gram per
second, one kilogram per second, one pound per hour, one ton per year, etc.). Unit emission
rates are typically developed over established AAQS averaging times or daily operating hours
(i.e., one-hour, eight-hour, 24-hour, etc.). Unit emissions rates are used to normalize the
resulting concentration produced by a dispersion model for ease of calculation. Therefore, ISC3
modeling was performed assuming a one pound per day emission rate over the eight-hour
construction period of 8 a.m. to 4 p.m. The units of the results are in grams per cubic meter, per
pound per day ([ g/m3]/[lb/day]). ISC3 provides peak predicted concentrations at the downwind
distances for the receptor for one-hour, eight-hour, and 24-hour averaging periods.
Calculating Localized Significance Thresholds
Gaseous Pollutants (NOx and CO)
Multiplying the unit emission rate of one-pound per day by the ratio of the project contribution
level to the peak predicted concentration using ISC3 yields the mass rate LST in pounds per day.
Emax = U x (CPC)/Cu)

Eq. 3

Where: Emax is the daily mass rate LST emissions in pounds per eight-hour day;
U is the unit emission rate of one-pound per eight-hour day (one-lb/day);
CPC is the acceptable impact levels in micrograms per cubic meter; and
Cu is the peak predicted concentration in micrograms per cubic meter estimated by ISC3
for a unit emission rate of one-pound per day.
The daily mass rate LSTs in pounds per day are the emission rates that with the background
concentration would equal but not exceed the most stringent AAQS. These allowable maximum

Final Localized Significance Threshold Methodology 2-10

June 2003, Revised July 2008

daily emissions are presented in the mass rate Localized Significance Threshold Screening
Tables in Appendix C.
Particulate Matter
The predicted PM2.5 or PM10 concentration at a given distance in meters from the fence line is
estimated from Equation 1 using the PM2.5 or PM10 concentration at the fence line estimated by
ISC3 for sources with combined unit emission rate of one-pound per day. Equation 4 estimates
the daily mass rate LST emission in pounds per day from the predicted PM2.5 or PM10
concentration at a given distance from the fence line.
Emax = (Crule)/Cx

Eq. 4

Where: Emax is the daily mass rate LST emissions in pounds per eight-hour day;
Crule is the concentration threshold presented in Rule 403 (construction) or 1301
(operation); and
Cx is the predicted PM2.5 or PM10 concentration at x meters from the fence line in
micrograms per cubic meter for a unit emission rate of one-pound per day. (see Eq. 1);
The concentration threshold is taken from either Rule 403 (10.4 microns per cubic meter) for
construction activities or from Rule 1301 (2.5 microns per cubic meter) for operational activities.
These allowable maximum daily PM2.5 or PM10 emissions are presented in the mass rate
Localized Significance Threshold Screening Tables in Appendix C.

Final Localized Significance Threshold Methodology 2-11

June 2003, Revised July 2008

Chapter 3 Screening Tables and Their Use

CHAPTER 3
SCREENING TABLES AND THEIR USE
The LST lookup tables provided in Appendix C allow a user to readily determine if the
daily emissions for proposed construction or operational activities could result in
significant localized air quality impacts. If the calculated emissions for the proposed
construction or operational activities are below the LST emission levels found on the
LST lookup tables, then the proposed construction or operation activity is not significant.
Proposed projects whose calculated emission budgets for the proposed construction or
operational activities are above the LST emission levels found in the LST lookup tables
should not assume that the project would necessarily generate adverse impacts. Detailed
emission calculations and/or air dispersion modeling may demonstrate that pollutant
concentrations are below localized significant levels.
The CO, NOX, PM2.5 and PM10 LST lookup tables for each source receptor area are
provided in Appendix C for the 37 source receptor/areas. The CO and NOx LST lookup
tables can be utilized for both construction and operational activities. There are two sets
of PM2.5 and PM10 LST lookup tables: one for construction emissions and one for
operational emissions. The operational emission PM2.5 and PM10 LST lookup tables
were developed based on the allowable change in concentration threshold of 2.5 g/m3 in
Table A-2 of Rule 1303. It is recommended that operational emissions associated with
fugitive dust area sources (e.g., landfills, aggregate material operations) use the PM10
LST lookup tables for operational activities. A lead agency can contact the SCAQMD
staff (ceqa_admin@aqmd.gov) if there are any questions regarding which is the
appropriate PM10 LST lookup tables for area source operational activities.
The tables are first organized by pollutant and then by source/receptor area. Within the
tables, the distance to the nearest receptor is required to properly choose the correct
allowable emission rate. The estimated maximum daily construction and operational
emissions are compared to the allowable emissions to determine significance. If the
projected emission budgets are less than the allowable emissions then significant local
impacts are not expected.
Therefore, the information needed to use the LST lookup tables is as follows:

Maximum daily emissions of CO, NOX, PM2.5 and PM10 in pounds per day (lb/day)

Distance from the boundary of the proposed project site to the nearest off-site
receptor

Geographic location of the construction site in terms of district source/receptor area

This information directs the user to the correct table and table cell. Additional guidance
in each of these three areas is given below:

Final Localized Significance Threshold Methodology 3-1

June 2003, Revised July 2008

Chapter 3 Screening Tables and Their Use

ESTIMATE EMISSIONS
The first step in the process is to estimate the maximum daily emissions of CO, NOX,
PM2.5 and PM10. The emissions include only on-site activities and the emission rate
must be expressed in pounds per day. The PM2.5 and PM10 emissions should include
both fugitive dust and exhaust from the stationary/mobile equipment on-site. The
emission rates can be estimated based on project specific equipment categories and
proposed controls.
DETERMINE THE SOURCE/RECEPTOR AREA OF THE PROPOSED
CONSTRUCTION/OPERATIONAL ACTIVITY
On the SCAQMD website is a utility that provides the district source/receptor area for a
given street address (www.aqmd.gov). The user is advised to follow the instructions on
the use of this utility.
ESTIMATE THE RECEPTOR DISTANCE
Receptor locations are off-site locations where persons may be exposed to the emissions
from project activities. Receptor locations include residential, commercial and industrial
land use areas; and any other areas where persons can be situated for an hour or longer at
a time. These other areas include parks, bus stops, and side walks but would not include
the tops of buildings, roadways, or permanent bodies of water such as, oceans or lakes.6
For the purposes of a CEQA analysis, the SCAQMD considers a sensitive receptor to be
to be a receptor such as residence, hospital, convalescent facility were it is possible that
an individual could remain for 24 hours. Commercial and industrial facilities are not
included in the definition of sensitive receptor because employees do not typically remain
onsite for a full 24 hours, but are present for shorter periods of time, such as eight hours.
Therefore, applying a 24-hour standard for PM10 is appropriate not only because the
averaging period for the state standard is 24 hours, but because, according to the
SCAQMDs definition, the sensitive receptor would be present at the location for the full
24 hours.
Since a sensitive receptor is considered to be present onsite for 24 hours, LSTs based on
shorter averaging times, such as the one-hour NO2 or the one-hour and eight-hour CO
ambient air quality standards, would also apply. However, LSTs based on shorter
averaging periods, such as the NO2 and CO LSTs, could also be applied to receptors such
as industrial or commercial facilities since it is reasonable to assume that a worker at
these sites could be present for periods of one to eight hours. This assumption is
consistent with the CO hotspots modeling protocol, which requires modeling at receptors
that may also include commercial and industrial sites. It is for this reason that the
Methodology paper included commercial and industrial sites when discussing receptor
locations as opposed to sensitive receptors.

SCAQMD, Risk Assessment Procedures for Rules 1401 and 212, Version 6.0, 2000. p 8.

Final Localized Significance Threshold Methodology 3-2

June 2003, Revised July 2008

Chapter 3 Screening Tables and Their Use

The receptor distance is measured from the boundary of the proposed project site to the
nearest receptor location. Care should be taken when estimating these distances since
allowable emissions increase rapidly with increasing downwind distance. It is acceptable
to linearly interpolate to estimate the allowable emissions between the downwind
distances given in the tables.
The closest receptor distance on the mass rate LST look-up tables is 25 meters. It is
possible that a project may have receptors closer than 25 meters. Projects with
boundaries located closer than 25 meters to the nearest receptor should use the LSTs for
receptors located at 25 meters.
MITIGATION MEASURES
If project emissions exceed the mass rates presented in the LST look-up tables or
allowable air quality impacts based on modeling, CEQA requires lead agencies to
implement feasible mitigation measures, if available, to reduce adverse air quality
impacts. Lead agencies may use the mitigation measures presented in Chapter 11 and its
appendix in the Handbook (1993), other sources, or develop their own mitigation
measures. The CEQA Handbook can be accessed on line at www.aqmd.gov/eg/I4/I4.htm. AQMD staff is available for consultation on mitigation measures to provide
updates or new information, if available, on a project-by-project basis.
LIMITATIONS OF THE SCREENING TABLES
The LST lookup tables were developed to assist lead agencies with a simple tool for
evaluating the impacts from small typical projects. Table 3-1 includes a list of typical
projects. Large industrial projects, such as installation of turbines at power plants are
beyond the scope of these LST lookup tables. LSTs are applicable at the project-specific
level and generally are not applicable to regional projects such as local General Plans
unless specific projects are identified in the General Plans. Regional analyses are more
applicable to the scope of General Plans. Table 3-2 includes typical projects where the
LST lookup tables may not apply.

Final Localized Significance Threshold Methodology 3-3

June 2003, Revised July 2008

Chapter 3 Screening Tables and Their Use

Table 3-1. Typical Projects

Apartments
Banks
City Parks
Condo/Townhouses
Convenience Market
Day-Care Center
Discount Clubs
Discount Stores
Electronics Store
Hardware/Paint Store
Home Improvement Store
Hospital
Hotels/Motels
Industrial Building
Libraries
Manufacturing

Medical Office Building

Mobil Home Park
Nursing Home
Office Buildings
Pharmacy/Drug Store
Places of Worship
Racquet/Health Clubs
Regional Shopping Center
Residential Planned Unit Development (PUD)
Restaurants
Retirement Community
Schools (Elementary, Junior High /Middle, High)
Single Family Housing
Strip Mall
Supermarket
University/College

Table 3-2. Typical Projects Where Screening Tables May Not Apply

Project Sites Larger than 5 acres

Projects that require more than one shift

Projects at RECLAIM facilities

Project sites where emissions are

distinctly non-uniform across site

Projects at Title V facilities

Operational sources where fumigation or

building downwash is anticipated

Large Combustion Sources

General Plans

The LST lookup tables are limited to projects with the following parameters:
Five acres or smaller in size
Limited to eight-hours of operation per day
Limited to operations during the day
It is assumed emission sources are distributed evenly across proposed site
Proposed projects that exceed the above limitations should complete a site specific
localized significance analysis.

Final Localized Significance Threshold Methodology 3-4

June 2003, Revised July 2008

Chapter 3 Screening Tables and Their Use

SAMPLE CALCULATIONS
Based on stakeholder comments to ease concerns on potential resource impacts due to
necessary quantification of emissions, a separate technical document was prepared to
illustrate how construction emissions can be calculated for LST impact analysis. The
sample calculations can be used by lead agencies for simlar projects if the projects fall
within the general parameters assumed for the sample projects. A copy of this report can
be found at www.aqmd.gov/eg/I-4/I4.htm. Additional scenarios can be added upon
request for general use and AQMD staff is also available to provide technical assistance
to lead agency staff.

Final Localized Significance Threshold Methodology 3-5

June 2003, Revised July 2008

Chapter 4 Conclusion

CHAPTER 4
CONCLUSION
Environmental justice initiatives and revision of the Handbook have focused attention on
localized adverse effects of proposed projects on air quality. In order to address potential
localized impacts this proposal attempts to establish the thresholds reflecting existing air
quality. The cleaner the air is in a local area, the greater emissions increment it can
afford without causing or contributing to an exceedance of the most stringent ambient air
quality standard. If the existing air quality is not yet in compliance with the air quality
standards, all areas are subject to generally equivalent LSTs
Historically assessing localized air quality impacts required using complex dispersion
models. Therefore, to address the issue of localized significance, yet be sensitive to the
fact that other public agencies might not have the expertise or adequate financial
resources to perform dispersion modeling, in addition to the methodology itself,
SCAQMD staff developed localized significant threshold similar to the regional
significance thresholds, that is, based on the amount of pounds of emissions per day
generated by a proposed project that would cause or contribute to adverse localized air
quality impacts. These projects are assumed to be less than five acres in size. Emissions
were assumed to be uniformly distributed across a flat proposed project site over an
eight-hour workday. Receptors distances are measured in meters from the proposed
project boundary. The same emissions estimated for regional significant thresholds
should be compared to allowable emissions presented the LST lookup tables for the
source/receptor area closest to the proposed project.
Screening procedures are by design conservative, that is, the predicted impacts tend to
overestimate the actual impacts. If the predicted impacts are acceptable using the LST
approach presented here, then a more detailed evaluation is not necessary. However, if
the predicted impacts are significant, then the project proponent may wish to perform a
more detailed emission and/or modeling analysis before concluding that the impacts are
significant. Project proponents are not required to use this LST procedure; and may
complete site specific modeling instead.

Final Localized Significance Threshold Methodology

4-1

June 2003, Revised July 2008

Chapter 5 Reference

CHAPTER 5
REFERENCES

Arellano, J.V., A.M. Talmon, and P.J.H. Builtjes, A Chemically Reactive Plume Model
for the NO-NO2-O3 System, Atmospheric Environment 24A, 2237-2246
Desert Research Institute, Final Effectiveness Demonstration of Fugitive Dust Control
Methods for Public Unpaved Roads and Unpaved Shoulders on Paved Roads,
DRI Document No. 685-5200.1F1, prepared for CARB CRPAQS, December 31,
1996.
SCAQMD, CEQA Air Quality Handbook, April 1993.
SCAQMD, Risk Assessment Procedures for Rules 1401 and 212, Version 6.0, August 18,
2002.
USEPA, Users Guide for the Industrial Source Complex (ISC3) Dispersion Models,
Volume I and II, EPA-454/B-95-003, September, 1995.

Final Localized Significance Threshold Methodology

5-1

June 2003, Revised July 2008

APPENDIX A

PEAK BACKGROUND CONCENTRATIONS

FOR THE 19992001 PERIOD

The peak concentrations in this appendix were the most recent concentrations available at
the time the LSTs were developed. The CEQA practitioner should refer to the peak
concentrations in the most recent three-year period.

Appendix A

Table A-1
Peak Background Concentrations for the 1999-2001 Perioda
Source/
Receptor
Area
1

Pollutant

Averaging
Time

Units

1999
Conc.

2000
Conc.

2001
Conc.

Max
Conc.

Central LA

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.21
7.00
6.30

0.16
7.00
6.00

0.14
6.00
4.57

0.21
7.00
6.30

Northwest Coastal LA County

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.13
6.00
3.80

0.16
6.00
4.30

0.11
4.00
3.00

0.16
6.00
4.30

Southwest Coastal LA County

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.13
10.00
8.40

0.13
9.00
7.00

0.11
7.00
5.14

0.13
10.00
8.40

South Coastal LA County

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.15
7.00
5.40

0.14
10.00
5.80

0.13
6.00
4.71

0.15
10.00
5.80

West San Fernando Valley

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.12
9.00
7.60

0.11
11.00
9.80

0.09
7.00
6.00

0.12
11.00
9.80

East San Fernando Valley

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.18
9.00
9.00

0.17
8.00
6.10

0.25
6.00
4.88

0.25
9.00
9.00

Air Quality Site

a) The peak concentrations in this appendix were the most recent concentrations available at the time the LSTs were developed. The CEQA practitioner should
refer to the peak concentrations in the most recent three-year period.

Final Localized Significance Threshold Methodology

A-1

June 2003, Revised July 2008

Appendix A

Table A-1 (Continued)

Peak Background Concentrations for the 2000-2002 Perioda
Source/
Receptor
Area
1

Pollutant

Averaging
Time

Units

2000
Conc.

2001
Conc.

2002
Conc.

Max
Conc.

Central LA

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.16
7.00
6.00

0.14
6.00
4.57

0.14
5.00
4.00

0.16
7.00
6.00

Northwest Coastal LA County

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.16
6.00
4.30

0.11
4.00
3.00

0.11
4.00
2.70

0.16
6.00
4.30

Southwest Coastal LA County

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.13
9.00
7.00

0.11
7.00
5.14

0.10
7.00
6.10

0.13
9.00
7.00

South Coastal LA County

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.14
10.00
5.80

0.13
6.00
4.71

0.13
6.00
4.60

0.14
10.00
5.80

West San Fernando Valley

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.11
11.00
9.80

0.09
7.00
6.00

0.09
6.00
4.80

0.11
11.00
9.80

East San Fernando Valley

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.17
8.00
6.10

0.25
6.00
4.88

0.26
6.00
4.60

0.26
8.00
6.10

Air Quality Site

a) The peak concentrations in this appendix were the most recent concentrations available at the time the LSTs were developed. The CEQA practitioner should
refer to the peak concentrations in the most recent three-year period.

Final Localized Significance Threshold Methodology

A-2

June 2003, Revised July 2008

Appendix A

Table A-1 (Continued)

Peak Background Concentrations for the 2000-2002 Perioda
Source/
Receptor
Area
8

Pollutant

Averaging
Time

Units

2000
Conc.

2001
Conc.

2002
Conc.

Max
Conc.

West San Gabriel Valley

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.17
9.00
7.40

0.15
7.00
5.00

0.15
6.00
4.00

0.17
9.00
7.40

East San Gabriel Valley 1

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.15
5.00
4.90

0.12
3.00
2.88

0.12
4.00
2.40

0.15
5.00
4.90

East San Gabriel Valley 2

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.13
4.00
3.10

0.12
3.00
2.50

0.10
5.00
2.30

0.13
5.00
3.10

10

Pomona/Walnut Valley

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.14
7.00
4.90

0.13
5.00
3.43

0.11
6.00
3.30

0.14
7.00
4.90

11

South San Gabriel Valley

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.14
7.00
5.30

0.14
6.00
4.00

0.12
5.00
4.00

0.14
7.00
5.30

12

South Central LA County 1

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.14
13.00
10.00

0.15
12.00
7.71

0.14
16.00
10.10

0.15
16.00
10.10

Air Quality Site

a) The peak concentrations in this appendix were the most recent concentrations available at the time the LSTs were developed. The CEQA practitioner should
refer to the peak concentrations in the most recent three-year period.

Final Localized Significance Threshold Methodology

A-3

June 2003, Revised July 2008

Appendix A

Table A-1 (Continued)

Peak Background Concentrations for the 2000-2002 Perioda
Source/
Receptor
Area
12

Pollutant

Averaging
Time

Units

2000
Conc.

2001
Conc.

2002
Conc.

Max
Conc.

South Central LA County 2

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.11
13.00
9.50

----

----

0.11
13.00
9.50

13

Santa Clarita Valley

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.10
6.00
4.90

0.10
6.00
3.14

0.10
3.00
1.90

0.10
6.00
4.90

16

North Orange County

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.12
14.00
6.10

0.13
11.00
4.71

0.12
10.00
4.40

0.13
14.00
6.10

17

Central Orange County

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.13
8.00
6.80

0.12
8.00
4.71

0.10
7.00
5.40

0.13
8.00
6.80

18

North Coastal Orange County

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.11
8.00
6.30

0.08
6.00
4.57

0.11
5.00
4.30

0.11
8.00
6.30

19

Saddleback Valley 1

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

-5.00
2.30

----

----

0.00
5.00
2.30

Air Quality Site

a) The peak concentrations in this appendix were the most recent concentrations available at the time the LSTs were developed. The CEQA practitioner should
refer to the peak concentrations in the most recent three-year period.

Final Localized Significance Threshold Methodology

A-4

June 2003, Revised July 2008

Appendix A

Table A-1 (Continued)

Peak Background Concentrations for the 2000-2002 Perioda
Source/
Receptor
Area
19

Pollutant

Averaging
Time

Units

2000
Conc.

2001
Conc.

2002
Conc.

Max
Conc.

Saddleback Valley 2

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

-4.00
3.30

-3.00
2.38

-3.00
3.60

0.00
4.00
3.60

22

Norco/Corona

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

----

----

----

0.00
8.00
4.30

23

Metropolitan Riverside County 1

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.10
5.00
4.30

0.15
5.00
3.43

0.10
8.00
3.00

0.15
8.00
4.30

23

Metropolitan Riverside County 2

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

-9.00
4.30

-6.00
4.50

-7.00
3.90

0.00
8.00
4.50

24

Perris Valley

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

----

----

----

0.00
8.00
4.50

25

Lake Elsinore

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.08
4.00
2.00

0.09
2.00
2.00

0.07
3.00
2.00

0.09
4.00
2.00

Air Quality Site

a) The peak concentrations in this appendix were the most recent concentrations available at the time the LSTs were developed. The CEQA practitioner should
refer to the peak concentrations in the most recent three-year period.

Final Localized Significance Threshold Methodology

A-5

June 2003, Revised July 2008

Appendix A

Table A-1 (Continued)

Peak Background Concentrations for the 2000-2002 Perioda
Source/
Receptor
Area
29

Air Quality Site

Pollutant

Averaging
Time

Units

2000
Conc.

2001
Conc.

2002
Conc.

Max
Conc.

Banning Airport

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.21
---

0.24
---

0.15
---

0.24
3.00
0.00

30

Coachella Valley 1**

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.07
3.00
1.60

0.08
2.00
1.50

0.10
2.00
1.20

0.10
3.00
1.60

30

Coachella Valley 2**

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.06
3.00
2.10

0.00
---

----

0.06
3.00
2.10

32

Northwest San Bernardino Valley

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.15
4.00
2.60

0.13
3.00
1.75

0.12
4.00
1.60

0.15
4.00
2.60

33

Southwest San Bernardino Valley

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

----

----

----

0.00
4.00
2.60

34

Central San Bernardino Valley 1

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.12
---

0.13
---

0.12
---

0.13
4.00
2.60

a) The peak concentrations in this appendix were the most recent concentrations available at the time the LSTs were developed. The CEQA practitioner should
refer to the peak concentrations in the most recent three-year period.

Final Localized Significance Threshold Methodology

A-6

June 2003, Revised July 2008

Appendix A

Table A-1 (Concluded)

Peak Background Concentrations for the 2000-2002 Perioda
Source/
Receptor
Area
34

Pollutant

Averaging
Time

Units

2000
Conc.

2001
Conc.

2002
Conc.

Max
Conc.

Central San Bernardino Valley 2

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

0.10
5.00
4.30

0.11
4.00
3.25

0.11
5.00
3.30

0.11
5.00
4.30

35

East San Bernardino Valley

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

----

----

----

0.00
5.00
4.30

37

Central San Bernardino Mountains

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

----

----

----

0.00
5.00
4.30

38

East San Bernardino Mountains

NOx
CO
CO

1-hr
1-hr
8-hr

ppm
ppm
pphm

----

----

----

0.00
5.00
4.30

Air Quality Site

a) The peak concentrations in this appendix were the most recent concentrations available at the time the LSTs were developed. The CEQA practitioner should
refer to the peak concentrations in the most recent three-year period.

Final Localized Significance Threshold Methodology

A-7

June 2003, Revised July 2008

APPENDIX B

DIFFERENCES BETWEEN THE MOST STRINGENT

AMBIENT AIR QUALITY STANDARD AND AMBIENT
CONCENTRATIONS FOR EACH SRA FOR THE
19992001 PERIOD

The peak concentrations in this appendix were the most recent concentrations available at the
time the LSTs were developed. The CEQA practitioner should refer to the peak concentrations
in the most recent three-year period.
The current NO2 State AAQS is 0.18 ppm as of March 20, 2008. Table B-1 was prepared when
the NO2 State AAQS was 0.025.

Appendix B

Table B-1
Difference in Concentration for the 2000-2002 Period
Source/
Receptor
Area
1

Pollutant

Averaging
Time

AAQSa
(ppm)

Observedb
(ppm)

Difference
(ppm)

Difference
(ug/m3)

Central LA

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0.16
7
6

0.09
13
3

170
14,950
3,444

Northwest Coastal LA County

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0.16
6
4.3

0.09
14
4.7

170
16,100
5,396

Southwest Coastal LA County

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0.13
9
7

0.12
11
2

226
12,650
2,296

South Coastal LA County

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0.14
10
5.8

0.11
10
3.2

207
11,500
3,674

West San Fernando Valley

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0.11
11
9.8

0.14
9
0.45

264
10,350
517

East San Fernando Valley

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0.26
8
6.1

0.01
12
2.9

19
13,800
3,329

Air Quality Site

a) The current NO2 State AAQS is 0.18 ppm as of March 20, 2008. Table B-1 was prepared when the NO2 State AAQS was 0.25 ppm.
b) The peak concentrations in this appendix were the most recent concentrations available at the time the LSTs were developed. The CEQA practitioner should
refer to the peak concentrations in the most recent three-year period.

Final Localized Significance Threshold Methodology

B-1

June 2003, Revised July 2008

Appendix B

Table B-1 (Continued)

Difference in Concentration for the 2000-2002 Period

Source/
Receptor
Area
8

Pollutant

Averaging
Time

AAQSa
(ppm)

Observedb
(ppm)

Difference
(ppm)

Difference
(ug/m3)

West San Gabriel Valley

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0.17
9
7.4

0.08
11
1.6

151
12,650
1,837

East San Gabriel Valley 1

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0.15
5
4.9

0.1
15
4.1

189
17,250
4,707

East San Gabriel Valley 2

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0.13
5
3.1

0.12
15
5.9

226
17,250
6,773

10

Pomona/Walnut Valley

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0.14
7
4.9

0.11
13
4.1

207
14,950
4,707

11

South San Gabriel Valley

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0.14
7
5.3

0.11
13
3.7

207
14,950
4,248

12

South Central LA County 1

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0.15
16
10.1

0.1
4
0.45

189
4,600
517

Air Quality Site

a) The current NO2 State AAQS is 0.18 ppm as of March 20, 2008. Table B-1 was prepared when the NO2 State AAQS was 0.25 ppm.
b) The peak concentrations in this appendix were the most recent concentrations available at the time the LSTs were developed. The CEQA practitioner should
refer to the peak concentrations in the most recent three-year period.
Final Localized Significance Threshold Methodology

B-2

June 2003, Revised July 2008

Appendix B

Table B-1 (Continued)

Difference in Concentration for the 2000-2002 Period

Source/
Receptor
Area
12

Pollutant

Averaging
Time

AAQSa
(ppm)

Observedb
(ppm)

Difference
(ppm)

Difference
(ug/m3)

South Central LA County 2

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0.11
13
9.5

0.14
7
0.45

264
8,050
517

13

Santa Clarita Valley

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0.1
6
4.9

0.15
14
4.1

283
16,100
4,707

16

North Orange County

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0.13
14
6.1

0.12
6
2.9

226
6,900
3,329

17

Central Orange County

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0.13
8
6.8

0.12
12
2.2

226
13,800
2,526

18

North Coastal Orange County

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0.11
8
6.3

0.14
12
2.7

264
13,800
3,100

19

Saddleback Valley 1

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0
5
2.3

-15
6.7

264
17,250
7,692

Air Quality Site

a) The current NO2 State AAQS is 0.18 ppm as of March 20, 2008. Table B-1 was prepared when the NO2 State AAQS was 0.25 ppm.
b) The peak concentrations in this appendix were the most recent concentrations available at the time the LSTs were developed. The CEQA practitioner should
refer to the peak concentrations in the most recent three-year period.
Final Localized Significance Threshold Methodology

B-3

June 2003, Revised July 2008

Appendix B

Table B-1 (Continued)

Difference in Concentration for the 2000-2002 Period

Source/
Receptor
Area
19

Pollutant

Averaging
Time

AAQSa
(ppm)

Observedb
(ppm)

Difference
(ppm)

Difference
(ug/m3)

Saddleback Valley 2

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0
4
3.6

-16
5.4

264
18,400
6,199

22

Norco/Corona

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0
8
4.3

-12
4.7

189
13,800
5,396

23

Metropolitan Riverside County 1

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0.15
8
4.3

0.1
12
4.7

189
13,800
5,396

23

Metropolitan Riverside County 2

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0
8
4.5

-12
4.5

189
13,800
5,166

24

Perris Valley

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0
8
4.5

-12
4.5

189
13,800
5,166

25

Lake Elsinore

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0.09
4
2

0.16
16
7

302
18,400
8,036

Air Quality Site

a) The current NO2 State AAQS is 0.18 ppm as of March 20, 2008. Table B-1 was prepared when the NO2 State AAQS was 0.25 ppm.
b) The peak concentrations in this appendix were the most recent concentrations available at the time the LSTs were developed. The CEQA practitioner should
refer to the peak concentrations in the most recent three-year period.
Final Localized Significance Threshold Methodology

B-4

June 2003, Revised July 2008

Appendix B

Table B-1 (Continued)

Difference in Concentration for the 2000-2002 Period

Source/
Receptor
Area
29

Air Quality Site

Pollutant

Averaging
Time

AAQSa
(ppm)

Observedb
(ppm)

Difference
(ppm)

Difference
(ug/m3)

Banning Airport

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0.24
3
0

0.01
17
9

19
19,550
10,332

30

Coachella Valley 1**

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0.1
3
1.6

0.15
17
7.4

283
19,550
8,495

30

Coachella Valley 2**

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0.06
3
2.1

0.19
17
6.9

358
19,550
7,921

32

Northwest San Bernardino Valley

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0.15
4
2.6

0.1
16
6.4

189
18,400
7,347

33

Southwest San Bernardino Valley

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0
4
2.6

-16
6.4

189
18,400
7,347

34

Central San Bernardino Valley 1

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0.13
4
2.6

0.12
16
6.4

226
18,400
7,347

a) The current NO2 State AAQS is 0.18 ppm as of March 20, 2008. Table B-1 was prepared when the NO2 State AAQS was 0.25 ppm.
b) The peak concentrations in this appendix were the most recent concentrations available at the time the LSTs were developed. The CEQA practitioner should
refer to the peak concentrations in the most recent three-year period.
Final Localized Significance Threshold Methodology

B-5

June 2003, Revised July 2008

Appendix B

Table B-1 (Concluded)

Difference in Concentration for the 2000-2002 Period

Source/
Receptor
Area
34

Pollutant

Averaging
Time

AAQSa
(ppm)

Observedb
(ppm)

Difference
(ppm)

Difference
(ug/m3)

Central San Bernardino Valley 2

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0.11
5
4.3

0.14
15
4.7

264
17,250
5,396

35

East San Bernardino Valley

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0
5
4.3

-15
4.7

264
17,250
5,396

37

Central San Bernardino Mountains

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0
5
4.3

-15
4.7

264
17,250
5,396

38

East San Bernardino Mountains

NO2
CO
CO

1-hr
1-hr
8-hr

0.25
20
9

0
5
4.3

-15
4.7

264
17,250
5,396

Air Quality Site

a) The current NO2 State AAQS is 0.18 ppm as of March 20, 2008. Table B-1 was prepared when the NO2 State AAQS was 0.25 ppm.
b) The peak concentrations in this appendix were the most recent concentrations available at the time the LSTs were developed. The CEQA practitioner should
refer to the peak concentrations in the most recent three-year period.

Final Localized Significance Threshold Methodology

B-6

June 2003, Revised July 2008

APPENDIX C

LOCALIZED SIGNIFICANCE THRESHOLD

TABLES

The LST mass rate look-up tables are updated annually with the most recent air quality
monitoring data. The latest version of the tables can be downloaded from the SCAQMD
website at http://www.aqmd.gov/ceqa/handbook/LST/LST.html. Original hard copies of
the mass rate LST look-up tables can be obtained through the SCAQMD Public
Information Center at the Diamond Bar headquarters or by calling (909) 396-2039.

Attachment B
Staff Comments

Attachment B
The City of Pasadena provides the following comments on the SR 710 North Study Draft EIR/EIS:
Section

Paragraph

Comment

2. Project
Alternatives

2.2.3.4 Freeway
Tunnel
Alternative

On p. 2-69, the last sentence of the first full paragraph reads, To limit redundant
analysis, only the single-bore or dual-bore variation with the best performance and
fewest impacts was evaluated. Why was only the option with the fewest impacts
evaluated? CEQA requires that the worst-case scenario be considered.

2.2.3.4 Freeway
Tunnel
Alternative

This alternative includes an extension of St. John Ave. from Del Mar Blvd. to
California Blvd. However, no plans are provided for this improvement. What is the
footprint of this improvement and what is the existing condition of the land it would
impact?

2.2.3.4 Freeway
Tunnel
Alternative

This alternative includes the widening of Pasadena Ave to include a new late from
the proposed northbound I-710 off-ramp at Pasadena Ave. to Colorado Blvd.
However, no plans are provided for this improvement. What is the footprint of this
improvement and what is the existing condition of the land it would impact?

2.2.3.4 Freeway
Tunnel
Alternative

This alternative includes portal building with operations and maintenance centers
(OMC) at each end of the tunnel, including at the Del Mar Blvd. portal in Pasadena.
No details whatsoever are provided for this proposed facility. From the limited
information provided, it is not possible to discern the location, layout, height,
elevation, mass, bulk, color, or materials of the structure or of any outdoor
equipment yards or other facilities. Without such details, it is not possible to
consider the OMCs impacts on noise, traffic, air quality, aesthetics, or other
environmental conditions. Without such details, the City of Pasadena is deprived
of a meaningful opportunity to comment on potentially substantial adverse
environmental effects of the project and the document fails to meet the basic
disclosure requirements of CEQA.

2.2.3.4 Freeway
Tunnel
Alternative

On p. 2-72, the DEIR/DEIS notes that an electrical substation would be required to

power the boring machine during construction and for permanent power. This
page further notes that the location of the substation would be coordinated with
the Los Angeles and Pasadena Departments of Water and Power. Again, without
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any details provided about a substation, it is not possible to discern its potential
environmental impacts and the document fails to meet the basic disclosure
requirements of CEQA.

2.2.3.4 Freeway
Tunnel
Alternative

The location of construction staging areas is not provided. Would any construction
staging occur within or adjacent to the City of Pasadena? If so, what localized air
quality, noise, and traffic impacts would occur?

2.2.3.4 Freeway
Tunnel
Alternative

No details regarding the excavation and processing of earth. How many cubic
yards of earth would be excavated and hauled offsite? Where would temporary
stockpiles be located? Would any crushing or process of earth materials occur
within or adjacent to the City of Pasadena that could create air quality and noise
impacts?

3.1 Land Use

Table 3.1.3

The DEIR/DEIS states that all of the Alternatives are consistent with each identified
Pasadena General Plan Land Use and Mobility Policy. Given that many of these
policies emphasize non-auto transportation modes (transit, pedestrian, and
bicycle), it is difficult to understand how the TSM/TDM and Freeway Tunnel
Alternatives would be consistent with the intent of the alternative mode policies.
These policies emphasize the expansion of the current alternative mode network
as well as the improvement of the existing facilities in order to better facilitate their
use. While the TSM/TDM and Freeway Tunnel Alternatives would include some of
these enhancements, their primary purpose is to encourage automobile travel,
rather than to encourage transit, pedestrian, and bicycle use. While each
alternative may meet the letter of the stated policies, the TSM/TDM and Freeway
Tunnel Alternatives do not meet the intent.

3.2 Growth

3.2.3
Environmental
Consequences

The DEIR/DEIS states that the Freeway Tunnel Alternative would not increase
growth pressures and therefore would not result in growth-related effects. The City
of Pasadena disagrees with conclusion.
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The Freeway Tunnel Alternative would reduce travel times between Pasadena and
points south, thus, increasing the attractiveness to commute to or from Pasadena.
By providing no local access interchanges between Alhambra and Pasadena,
growth pressures are further concentrated near these portal locations. In
Pasadena, the largest growth pressures resulting from this alternative would be
expected near the local access intersections that are closest to the portal.
Minimally, the Freeway Tunnel Alternative is anticipated to increase growth
pressures and cause related environmental impacts near the following local access
interchanges: SR 134 at Orange Grove Boulevard, I-210 at Fair Oaks/Marengo,
and I-210 at Mountain/Seco.

3.3
Community
Impacts

3.3.1.3
Environmental
Consequences

In regards to the Freeway Tunnel Alternative, the DEIR/DEIS states that:

Maranatha High School and Sequoyah School are Community Facilities

that Could Experience Short-Term Air Quality, Noise, and Traffic/Access
Effects

Maranatha High School is a Community Facility which Could Experience

Long-Term Noise Effects.

It is unclear why the Sequoyah School would not experience long-term noise
impacts.
Regardless, the DEIR/DEIS fails to describe how such effects would impact the
operations, community cohesion (e.g., pedestrian access, etc.), or community
resources that these facilities provide. The DEIR/DEIS incorrectly states that none
of these schools [including Maranatha and Sequoyah] engage in noise-sensitive
outdoor activities on a routine basis. Maranatha has an outdoor athletic stadium
(football, soccer, and baseball) and an outdoor amphitheater. In addition
Maranathas approved Master Plan identifies outdoor sports courts and an outdoor
pool. Similarly, Sequoyah School has outdoor play areas and outdoor performing
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arts facilities and operations (plays, band concerts, ceremonies, etc.). How would
short- and long-term air quality and noise effects impact these outdoor facilities?
Presumably, noise impacts would disrupt outdoor programming and air pollutants
could cause respiratory and other health related impacts. Such impacts must be
disclosed, evaluated, and mitigated.
In addition, community cohesion and access effects are a concern for these
schools. Formally and informally, student pedestrians travel to Singer Park, Del
Mar Station, Old Pasadena, and other community resources. How would the
project affect such pedestrian activity? Again, such impacts must be disclosed,
evaluated, and mitigated.

3.6 Visual/
Aesthetics

3.6.3.2
Permanent
Impacts

The analysis of visual/aesthetic impacts is limited to 30 view locations and noise

barriers. The analysis fails to analyze numerous locations and proposed facilities,
which in the City of Pasadena include but are not limited to the north portal
operations and maintenance building/facility, the storm water treatment system
near the north portal, the electrical substation (location not provided), and the SR
710/Colorado Boulevard interchange option for the ventilation structure. Each of
these features could significantly impact views, aesthetic character, and aesthetic
quality.

3.6.3.2
Permanent
Impacts

The impacts on the visual quality and character of Old Pasadena are not analyzed.
For example, the Freeway Tunnel Alternative proposes six, 50-feet tall, ventilation
structures on the Colorado Street Bridge over SR 710. Figure 3.6-33 depicts this
ventilation facility with three stacks on either side of Colorado Boulevard, which
appear to be designed in a contemporary style and constructed of brick and/or
concrete with flumed openings clad or painted in multiple colors. These stacks
would be in stark contrast to the aesthetic character of the Old Pasadena Historic
District, which lies immediate to the east. The adjacent segment of Colorado
Boulevard (within the Historic District) consists of one- and two-story buildings of
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varying historic architecture that form a downtown commercial district with
continual ground-floor storefronts along a zero-setback blockface. The proposed
stacks are out of context with this aesthetic character and quality in terms of mass,
scale, height, style, and materials. In addition, the stacks conflict with the rhythm,
feel, and visual experience of Old Pasadena. These are significant impacts on the
visual quality and character of Old Pasadena.
As previously noted, the lack of details for this and other proposed facilities (e.g.,
operation and maintenance building/facility) preclude meaningful comment or
consideration of their impacts on the visual quality and character of surrounding
portions of Pasadena.

3.6.3.2
Permanent
Impacts

The DEIR/DEIS does not consider the impacts of the proposed operations and
maintenance building/facility on views, visual character, visual quality, or
light/glare. Given the type of facility, it could likely have significant aesthetic
impacts. However, the location of the facility is not identified, nor are any physical
details of the facility. Thus, it is not possible to comment on its aesthetic impacts.

3.6.4.1 Measures
for Long-Term
Visual Impacts

Measure V-1 Vividness improperly defers mitigation to a future stage. The

measure neither specifies where mitigation will be implemented nor specifies what
conditions would require mitigation. Furthermore, no performance standard or
enforcement mechanism is provided to ensure that impacts are actually mitigated
to a less than significant level.

3.6.4.1 Measures
for Long-Term
Visual Impacts

Measure V-2 Intactness improperly defers mitigation to a future stage. The

measure neither specifies where mitigation will be implemented nor specifies what
conditions would require mitigation. Furthermore, no performance standard or
enforcement mechanism is provided to ensure that impacts are actually mitigated
to a less than significant level.

3.6.4.1 Measures
for Long-Term
Visual Impacts

Measure V-3 Unity improperly defers mitigation to a future stage. The measure
neither specifies where mitigation will be implemented nor specifies what
conditions would require mitigation. Furthermore, no performance standard or
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enforcement mechanism is provided to ensure that impacts are actually mitigated
to a less than significant level.

3.7 Cultural
Resources

3.6.4.1 Measures
for Long-Term
Visual Impacts

It is unclear why Measure V-5 Built Structures applies only to the LRT Alternative.
The Freeway Tunnel Alternative includes structures in the form of ventilation
stacks, maintenance buildings/facilities, electrical substations, etc. Such built
structures clearly have the potential to significantly impact the visual/aesthetic
environment.

3.6.4.2 Measure
for Short-Term
Visual Impacts
during
Construction

Measure V-7 Short-Term Visual Effects improperly defers analysis. Specifically,

this measures states, During final design, Metro (TSM/TDM, BRT, and LRT
Alternatives) and Caltrans (Freeway Tunnel Alternative) will identify land uses
adjacent to construction areas that may be sensitive to views of construction,
staging, and materials storage areas. Identification of areas that may be
sensitive to views cannot be deferred until a later stage.

Table 3.6.1

Table 3.6.1 inexplicably concludes that the six, 50-feet tall ventilation structures
proposed on Colorado Boulevard would improve the visual quality of the area. The
City of Pasadena strongly disagrees with this conclusion. Table 3.6.1 rates the
existing visual quality as 3.5, which is between moderately low and moderate. It
appears that this scoring does not consider the very high visual power,
memorability, visual integrity, visual coherence, and compositional harmony
created by Old Pasadena.
The EIR should include maps that identify the locations of historic resources
evaluated along with precise descriptions of the work proposed in proximity to each
cultural resource. The EIR does not clearly state whether any buildings in
proximity to any of the alternatives will be demolished or altered to accommodate
the improvements.
On p. 3.7-23 and 3.7-87, the property at 270 S. Orange Grove Blvd. is listed as
being in the City of South Pasadena, but it is actually in the City of Pasadena. Due
to lack of specificity of proposed improvements in this area, it is unclear whether
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other historic resources, such as the Ambassador West Cultural Landscape
Historic District and the Ambassador Auditorium, would be affected by these
alternatives.
On p. 3.7-44, the installation of a Case A BRT station adjacent to a contributing
building in the Old Pasadena Historic District is mentioned; however, there is no
description of what this entails to allow the reader to ascertain how this new facility
may affect views of the adjacent historic resource.
The BRT alternative does not evaluate impacts to the City-designated historic sign
at 592 S. Fair Oaks Avenue (Montys Steakhouse), which is in close proximity to
the existing sidewalk.
Although the BRT alternative shows mixed-flow traffic areas associated with this
alternative on Del Mar Boulevard, Hill Avenue, Colorado Boulevard and Lake
Avenue, it is unclear whether there will be construction of improvements in these
locations. At a minimum, it appears that new stations will be established at five
intersections along this route, the extent of which is unknown. There are historic
resources along Colorado Boulevard between Hill and Lake Avenues, including
one that is within public right-of-way adjacent to property at 1304 E. Colorado
Boulevard (Foothill Blvd. Milestone).
P. 3.7-79 contains a brief description of the Ambassador West Cultural Landscape
Historic District, which inaccurately describes the contributing features of the
district. The district was identified as part of a study of Historic Designed Gardens
and comprises seven historic gardens, all of which collectively exemplify the NonResidential Modern Garden Property Type identified in the study. The
Ambassador Auditorium and Hall of Administration buildings were separately
evaluated in an EIR for the Ambassador West Project in 2006 with status codes of
3S and 6L, respectively. The Student Center Building was evaluated in 2014 in a
Mitigated Negative Declaration for amendments to the Maranatha High School
Master Plan with a status code of 5S2.
On p. 3.7-80, there is an evaluation of the impacts of the Freeway Tunnel
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Alternative on the Norton Simon Museum; however, there is no explanation of the
improvements that are proposed in the vicinity of this building. There are other
historic resources near this building and the improvement areas shown on p. 2-61
that could be affected by the project, depending on the extent of improvements
proposed, including, the West Colorado Street Historic Auto Row Historic District
(eligible for NR, but not listed) and the John S. Hartwell House at 423 Lincoln
Avenue (listed in the NR)
The impacts of the proposed ventilation structures on historic resources are not
analyzed. The Freeway Tunnel Alternative proposes six, 50-feet tall, ventilation
structures on the Colorado Street Bridge over SR 710 in the vicinity of three
historic districtsthe Old Pasadena Historic District (National Register), the West
Colorado Street Historic Auto Row Historic District at the northwest corner of
Colorado and St. John (eligible for listing on the National Register), and the
Ambassador West Cultural Landscape Historic District at the southwest corner of
Green John (eligible for listing on the National Register). The proposed ventilation
structures have the potential to significantly impact these historic districts due to
changes in their setting, character, context, and integrity.
For example, Figure 3.6-33 depicts the ventilation facility with three stacks on
either side of Colorado Boulevard, which appear to be designed in a contemporary
style and constructed of brick and/or concrete with flumed openings clad or painted
in multiple colors. These stacks would be in stark contrast to the setting and feeling
of the Old Pasadena Historic District, which lies immediate to the east. The
adjacent segment of Colorado Boulevard (within the Historic District) consists of
one- and two-story buildings of varying historic architecture that form a downtown
commercial district with continual ground-floor storefronts along a zero-setback
blockface. The proposed stacks are out of context with this setting and feeling in
terms of use, mass, scale, height, style, and materials. In addition, the stacks
conflict with the rhythm, feel, and experience of Old Pasadena.
As previously noted, the lack of details for this and other proposed facilities (e.g.,
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operation and maintenance building/facility) preclude meaningful comment or
consideration of their impacts on Pasadenas historic districts.

3.13 Air
Quality

3.14 Noise &

Vibration

3.13.3.1
Temporary
Impacts

The Air Quality analysis does not compare the projects construction emission to
the South Coast Air Quality Management Districts regional significance thresholds.
Based on the daily pollutant volumes shown in Table 3.13.4, all build alternatives
would exceed these thresholds.

3.13.3.1
Temporary
Impacts

The Air Quality analysis does not evaluate the projects construction emission in
accordance with the South Coast Air Quality Management Districts Localized
Significance Threshold (LST) Methodology. Given the substantial daily pollutant
volumes shown in table 3.13.4, it is assumed that emissions would exceed the LST
screening thresholds at numerous locations.

3.13.3.1
Temporary
Impacts

The Air Quality analysis does not evaluate the localized impacts of haul truck and
other construction equipment activity at the north portal location (loading, idling,
equipment congregation, etc.). What impacts would such activity have on sensitive
receptors in Pasadena?

3.13.3.2
Permanent
Impacts

The Air Quality analysis does not evaluate the localized impacts of the proposed
north portal operations and maintenance building/facility. Given the volume of
equipment that may be staged at this site, localized pollutant
volumes/concentrations (including diesel particulate matter) may be significant.

3.14.3.1
Permanent
Impacts

The Noise and Vibration analysis indicates that pile driving may be required and
blasting may occur in the cut-and-cover segments. Such activity could cause
significant noise and vibration impacts to Pasadenas structures, residents, and
businesses. The Pasadena Noise Restrictions Ordinance (Pasadena Municipal
Code Section 9.36), Section 9.36.080 - Construction equipment states, It is
unlawful for any person to operate any powered construction equipment if the
operation of such equipment emits noise at a level in excess of 85 dBA when
measured within a radius of 100 feet from such equipment. Pile driving and
blasting normally generate noise levels in excess of 85 dBA at a distance of 100
feet. Noise levels in excess of this standard are normally considered significant
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impacts pursuant to CEQA in Pasadena.

3.24
Construction
Impacts

3.14.3.1
Permanent
Impacts

The Noise analysis does not evaluate the impacts of the proposed operations and
maintenance building/facility at the north portal. Given the potential for equipment
to be operated and staged at this site, noise impacts may be significant.

3.14.3.2
Temporary
Impacts

The Noise analysis does not evaluate the impacts of haul truck and other
construction equipment activity at the north portal location (loading, idling,
equipment congregation, etc.). What impacts would such activity have on sensitive
receptors in Pasadena?

3.24.3
Community
Impacts

The DEIR/DEIS does not consider the impacts that construction would have on the
operations or pedestrian access to Maranatha High School or Sequoyah School.
Both of these schools have outdoor facilities and programming. Maranatha has an
outdoor athletic stadium (football, soccer, and baseball) and an outdoor
amphitheater. In addition Maranathas approved Master Plan identifies outdoor
sports courts and an outdoor pool. Similarly, Sequoyah School has outdoor play
areas and outdoor performing arts facilities and operations (plays, band concerts,
ceremonies, etc.). How would construction phase air quality and noise effects
impact these outdoor facilities? Presumably, noise impacts would disrupt outdoor
programming and air pollutants could cause respiratory and other health related
impacts. Such impacts must be disclosed, evaluated, and mitigated.
In addition, community cohesion and access effects during construction are a
concern for these schools. Formally and informally, student pedestrians travel to
Singer Park, Del Mar Station, Old Pasadena, and other community resources. How
would the project affect such pedestrian activity? Such impacts must be disclosed,
evaluated, and mitigated.

3.24.7 Cultural
Resources

There is potential for the conclusion described in this section to change based on
responses to comments provided in Section 3.7.

3.24.13 Air

See the comments provided above in regards to Section 3.13.3.1 Air Quality,
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Quality

Temporary Impacts.

3.24.14 Noise

See the comments provided above in regards to Section 3.14.3.2 Noise and
Vibration, Temporary Impacts.

4.2.1 Aesthetics,
part I(a)

The analysis of Scenic Vistas correctly states that views of the San Gabriel
Mountains exist in the study area, but fails to analyze the impacts on these views
from placing 50-feet tall ventilation stacks. For example, the option for placing the
ventilation stacks on Colorado Boulevard would notably obstruct north-facing views
of the San Gabriel Mountains from pedestrians and motorists.

4.2.1 Aesthetics,
part I(c)

The analysis of Visual Character and Quality states that the Freeway Tunnel
alternative would only result in visual impacts where tunnel entrances and exits are
visible. This analysis fails to consider the visual impacts of the ventilation stacks,
operations and maintenance buildings/facilities, storm water treatment systems,
electrical substations, and other above ground facilities. As previously noted, the
impacts of these facilities on visual character and quality are potentially significant
and require evaluation and mitigation.

4.2.1 Aesthetics,
part I(d)

The analysis of Light and Glare does not consider the impacts of the proposed
operations and maintenance building/facility. As previously noted, given the type
of facility, it could likely cause significant light and glare impacts.

4.2.3 Air Quality,

parts III(b) and
III(c)

The Air Quality analysis does not compare the projects construction emission to
the South Coast Air Quality Management Districts regional significance thresholds.
Based on the daily pollutant volumes shown in table 3.13.4, all build alternatives
would exceed these thresholds.

4.2.3 Air Quality,

parts III(b) and
III(c)

The Air Quality analysis does not evaluate the projects construction emission in
accordance with the South Coast Air Quality Management Districts Localized
Significance Threshold (LST) Methodology. Given the substantial daily pollutant
volumes shown in table 3.13.4, it is assumed that emissions would exceed the LST
screening thresholds at numerous locations.

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4.2.3 Air Quality,

part III(c)

Part III(c) states that Measures AQ-1 through AQ-4 would reduce constructionrelated air quality impacts from fugitive dust emissions and construction equipment
emissions of the Build Alternatives to less than significant levels. It is not clear
how this determination was made, as no analysis of impacts after mitigation is
provided in the DEIR/DEIS.

4.2.3 Air Quality,

part III(d)

The Air Quality analysis does not evaluate the localized impacts of the proposed
north portal operations and maintenance building/facility. Given the volume of
equipment that may be staged at this site, localized pollutant
volumes/concentrations (including diesel particulate matter) may be significant.

4.2.5 Cultural
Resources

There is potential for the conclusion described in this section to change based on
responses to comments provided in Section 3.7.

4.2.7 Greenhouse Section simply refers reader to Section 4.3 Climate Change.
Gas Emissions
4.2.12 Noise,
parts XII(a),
XII(c), and XII(d)

The discussion of Long-Term Stationary Noise Impacts considers the noise

ordinances of the Cities of Alhambra and Los Angeles. Why is the Pasadena
Noise Restrictions Ordinance (Pasadena Municipal Code Section 9.36) not
considered? Section 9.36.050 of the Pasadena Municipal Code General noise
sources states it is unlawful for any person to create, cause, more or continue to
make or permit to be made or continued any noise or sound which exceeds the
ambient noise level at the property line of any property by more than 5 decibels.
Similarly, Section 9.36.090 Machinery, equipment, fans and air conditioning
states that except for emergency workit is unlawful for any person to operate
any machinery, equipment, pump, fan, air conditioning apparatus or similar
mechanical device in any manner so as to create any noise which would cause the
noise level at the property line of any property to exceed the ambient noise level by
more than 5 decibels. Section 9.36.040 defines ambient noise and provides
adjustments for steady audible tones, repeated impulsive noise, and noise
occurring for limited time periods. Proposed permanent facilities in Pasadena
(e.g., ventilation stacks, operation and maintenance facilities, electrical substation,
Page 12 of 19

Attachment B

Section

Paragraph

Comment
etc.) should be evaluated against the Pasadena Noise Restrictions Ordinance.

4.2.12 Noise,
parts XII(a),
XII(c), and XII(d)

While the discussion of Long-Term Stationary Noise Impacts includes an analysis

of the LRT Maintenance Yard/Shop proposed along Valley Boulevard, it does not
consider the operations and maintenance facility that would be developed at the
north portal in the Freeway Tunnel Alternative. Such an analysis must be
provided, as noise levels from an operation and maintenance facility have the
potential to exceed the standards in
Pasadena Noise Restrictions Ordinance and/or otherwise cause significant noise
impacts.

4.3 Climate
Change

4.3.3 Project
Operational
Emissions

It is unclear how the BRT and LRT Alternatives would result in more greenhouse
gas emissions than the Freeway Tunnel Alternatives. The DEIR/DEIS needs to
explain this counterintuitive conclusion. The intent of the BRT and LRT
Alternatives is to reduce the number of vehicle trips, whereas the Freeway Tunnel
Alternatives would increase the attractiveness of automobile travel.

SR 710
Health Risk
Assessment
Vol I

Scenario 1: No
Build and Build
Alternatives vs.
Existing Condition

Scenario 1: The assumptions that over a 7-year period emission levels will remain
constant after 2035 is not realistic, but should be an underestimate. Considering
the changes in the automotive market, including ride-sharing and electric vehicles.
(p. 44 of 108)
The authors repeatedly quote the excess risk that is acceptable according to the
SCAQMD. According to SCAQMD this risk is, Maximum Incremental Cancer Risk
10 in 1 million Cancer Burden; > 0.5 excess cancer cases (in areas 1 in 1
million); or Chronic & Acute Hazard Index 1.0 (project increment). The latter, is
defined by the California Air Resources Board as the potential non-cancer health
impacts resulting from a one-hour exposure to toxic substances. An acute hazard
index is calculated by dividing the one-hour concentration of a toxic pollutant by the
acute reference exposure level for that pollutant.

2.3.2.2 Source
Parameters

In-car filtration systems, when using the re-circulation mode may attenuate
additional risks1,2 In a review of tunnel filtration, in this case electrostatic
Page 13 of 19

Attachment B

Section

Paragraph

Comment

(Tunnel
Ventilation
Towers)

precipitators, systems, a group from France in 2010 found that the estimates put
forth by the 710 group may be an overestimate. The chart below shows that for the
most damaging particles, the smallest <2.5 micrometers, the efficiency could be as
low as 54%, not 80% purported by the 710 authors. This could be the authors
taking into account that this project would happen more recently so filters will have
naturally increased in efficiency and that this project would select only the most
efficient filters on the market. There are alternatives like bag filters and biofiltration
but I do not believe it was noted in this report which was selected for their
assumptions. This is the description available for their assumptions of air filtration
efficacy, the tunnel ventilation tower emissions for the north and south tunnel
portals were modeled as point sources. The exhaust flow rate of the ventilation
tower varies depending on the tunnel design. Exhaust flow rates vary depending
on whether the tunnel is the single-bore or dual-bore design. (p. 52)

Filtration systems may reduce exposure to surface exposure; however, what is the
effectiveness for those stuck in traffic while in the tunnel. Did the authors account
for the additional exposure that commuters may experience on an annual/lifetime
basis?
Researches from Los Angeles looked at heavy metal and air pollution exposure to
compare and contrast Light rail versus freeway exposure and the results were
slightly different than presented in this study, This study represents the integration
Page 14 of 19

Attachment B

Section

Paragraph

Comment
of the results from five commute environments in Los Angeles. Personal PM
exposures are discussed for the: (1) METRO gold line, a ground-level light-rail
route, (2) METRO red line, a subway line, (3) the 110, a high volume freeway with
low heavy-duty vehicle (HDV) fraction, (4) the 710, a major corridor for HDVs from
the Port of Los Angeles, and (5) Wilshire/Sunset Boulevards, major surface streets.
Chemical analysis including total and water-soluble metals and trace elements,
elemental and organic carbon (EC/OC), and polycyclic aromatic hydrocarbons
(PAHs) was performed. The focus of this study is to compare the composition and
estimated lung cancer risk of PM2.5 (dp < 2.5 m) for the five differential commute
environments. Metals associated with stainless steel, notably Fe, Cr, and Mn, were
elevated for the red line (subway), most likely from abrasion processes between
the rail and brakes; elements associated with tire and brake wear and oil additives
(Ca, Ti, Sn, Sb, and Pb) were elevated on roadways. Elemental concentrations on
the gold line (light-rail) were the lowest. For water-solubility, metals observed on
the red line (subway) were the least soluble. PAHs are primarily derived from
vehicular emissions. Overall, the 710 exhibited high levels of PAHs (3.0 ng m3),
most likely due to its high volume of HDVs, while the red and gold lines exhibited
low PAH concentrations (0.6 and 0.8 ng m3 for red and gold lines, respectively).
Lastly, lung cancer risk due to inhalation of PAHs was calculated based on a
commuter lifetime (45 years for 2 hours per workday). Results showed that lung
cancer risk for the 710 is 3.8 and 4.5 times higher than the light-rail (gold line) and
subway (red line), respectively. With low levels of both metal and PAH pollutants,
our results indicate that commuting on the light-rail (gold line) may have potential
health benefits when compared to driving on freeways and busy roadways.

2.2.2.2 Annual
Average
Emissions &
2.4.2.2 Noncancer Chronic
and Acute Risks

on p. 47 the authors noted traffic growth and cleaner vehicles in future years will
reduce overall air pollution. And that they are not able to forecast traffic
patternsfrom years 2031 to 2081. This seems like because the automotive
industry is making such great strides in reducing emission levels, it is therefore
acceptable for the local jurisdictions to open a freeway to relieve future stresses.
This could be counterproductive to the strides being made elsewhere. Wouldnt it
be more beneficial if this is looked as an opportunity to build on these approaches?
Page 15 of 19

Attachment B

Section

Paragraph

Comment
(This is mentioned again on p. 55 due to improved fuel efficiency , newer
emission-control technology.)
IF the auto-industry is moving towards self-driving cars, or aut0-sharing programs
this will likely lead to an increase in cost to consumers. For those who cant afford
these cars this could be a burden of cost to become insured. This could become an
important social justice issue. Would it not be more important for us to identify
options now that will be more cost- and environmentally-effective? What alternative
would be better?

3.1.2
Consistency
with State,
Regional, and
Local Plans

2.4.1.2 Exposure
Assumptions &
2.5 Conservative
Nature and
Uncertainties of
Health Risk
Assessment
(OEHHA has
provided a
discussion of risk
uncertainty, which
is reiterated here
(OEHHA, 2003))

p. 54 adjusted 9-yr. What is it adjusted for? They do not explain what methods
they use for adjusting (e.g. partial rates, regression, etc.) or what they are adjusting
for.
p. 57 interaction effects not taken into account. What the authors mean to say is
they did not look at the effect modification of risk due to other risk factors within
populations For example, it is known that children and seniors are at increased
risk for pulmonary effects of air pollution, the elderly a population they did not take
into account in this report.

3.1.2.1 Local
Plans

On page 3.1-12, the DEIR mentions the 1998 West Gateway Specific Plan. On
October 27, 2014, the City of Pasadena City Council approved a zoning change
within the Specific Plan area to create a neighborhood park site and adjacent 9-unit
SFDD residential development. Desiderio Park as it will be known is a 3.8-acre
neighborhood park site that will feature passive recreational activities and natural
landscape. Construction of this park is anticipated to occur in 2016-2017.
Page 16 of 19

Attachment B

Section

Paragraph

Comment

3.1.3 Parks
and
Recreation
Facilities, and
Section 4(f)
and 6(f)
Resources

TABLE 3.1.4:
Parks, Recreation
Resources, and
Bikeways within
0.5 Mile of the
Build Alternatives
by Jurisdiction

Table 3.1.4 should be revised to add the following locations to the list of Pasadena
parks:
Desiderio Neighborhood Park. This 3.8 acre neighborhood park will feature
passive recreational activities and natural landscape. Construction of this park is
anticipated to occur in 2016-2017.
Arlington Gardens, 275 Arlington Drive. This 2.6 acre public garden provides
walking trails, amphitheater, arbors, and native and ornamental plantings
representing various plant communities.

3.4 Utilities/
Emergency
Services

3.4.1.1

3.4 Utilities/
Emergency
Services

3.4.8

3.12
Hazardous
Waste/
Materials

3.12.3.1

Pasadena Community Garden, 721 Pasadena Ave. This 0.7 acre community
garden provides food gardening opportunities to the local community.
The Fire Department understands the need for the relocation of several utilities.
Also understanding that there will be constant delays in 8 locations, and detours in
11 locations in Pasadena within the vicinity of the North Tunnel Portal (Old Town
Area). This will surely affect the responses of Emergency Personnel. The Fire
Department recommends proper notification on a timely basis to stay updated with
accessible pathways for emergency personnel to respond. The same notifications
would be recommended for any water supplies being shut off or moved during
construction as to provide for additional equipment dispatched for water supply if an
emergency should call for it.
The Fire Department understands the need for relocation and moving of
underground utilities. With proper notifications of where the utilities will be under
construction and the Fire Departments best access route to these areas. The Fire
Department has the trained personnel at Fire Station 32 on the USAR Team staffed
every day for any time of confined space rescue.
The Fire Department understands there will be several sites with the potential of
Hazardous Waste during the alternative build options. They will be monitored
during actual construction. With Mutual Aid agreements we have Hazardous
Materials Teams in Burbank and Glendale staffed at all times.
Page 17 of 19

Attachment B

Section
3.24.4
Utilities/
Emergency
Services
4- CEQAHazards/
Hazardous
Materials
4 CEQA
Public
Services
General
Comments

Paragraph
3.24.4

Comment
The Fire Department understands there will be delays along with lane restrictions,
and ramp/road closures during the build. With proper notifications staffing can be
adjusted if needed to relieve extended response times.

4.2.8

The Fire Department understands there will little to no impact during the
construction.

4.2.14

The Fire Department understands the report will show little to no impact in the
regards of public access in public services, recreation and transportation.

Distance

General
Comments

Entrance/ Exits

Fire Department has the following concerns, with the multiple levels of the tunnel,
what would the weight restrictions be? Will there be ample room for ALL Fire
Department apparatus including our Class A Commercial Vehicle (USAR) to not
only fit, but be able to cross-over to a different tunnel or be able to access from a
lower level to an upper level?
If the freeway will not permit HAZMAT vehicles at all, will there be a toll or
checkpoint to actually keep this hazard out? Also keeping in mind that one of the
deadliest tunnel fires (Mont Blanc) was from a truck carrying butter and flour which
once ignited, basically became an oil based fire equivalent to over 3,000 gallons of
gasoline burning which we believe would generate more than a 100 MW Fire (the
listed rating of the deluge system) Not only a checkpoint but in the Mont Blanc
Tunnel entrance they now have FLIR technology to screen Large Trucks of
possible heat and fire inside the truck to prevent it from entering the tunnel in the
event it has an issue.

General

Natural Elements

At 6.3 Miles in length even at 60 mph would take a vehicle over 6 minutes which is
more than enough time for a fire to or near 100MW. A detection system would
greatly prevent a possible truck developing a fire to even enter the tunnel. Also a
stop gate with Toll would greatly prevent any accidental HAZMAT from passing
through.
The Tunnel runs directly through the active Raymond Fault, with no overhead
Page 18 of 19

Attachment B

Section
Comments

Paragraph

General
Comments

Fire Protection
System

General
Comments

Security Risk

General
Comments

Fire Department
Staffing

General
Comments

Operations in
Tunnel (911)

Comment
access points in the event of a collapse inside the tunnel the Fire Department will
likely not be able to get special apparatus within a reasonable range to help make a
technical rescue.
The Fire Department would like there to be a dedicated water tank for the
Standpipe and the Deluge System separately for BOTH tunnels in case there is a
fire or issue in both tunnels at the same time. Each tunnel should be treated
separately and have its own 60 minute dedicated water supply in case there was
failure of the water main in either tunnel.
Being a one of a kind tunnel not only in the US or world, but in a heavily populated
area of Los Angeles there becomes a severe security threat including New Years
where there is over 1 million people within the Pasadena Old Town vicinity.
This will impact the Fire Department greatly. Resources are already over-worked in
that area/district. Another Station with added resources and staffing would definitely
be recommended/needed for a necessary response time.
Also would need to assess specialty apparatus or staffing resources for best
access within the tunnels.
Multiple Agencies from North and South will automatically be dispatched together
on every call. Some southern end agencies use different radio frequencies
including CHP or LACO Sheriffs. The Current EIR lists only one radio frequency will
be installed in this tunnel This needs to have 3, (UHF, VHF, 800 MHZ) in order to
run Major Emergencies with multiple agencies.

Page 19 of 19

Attachment D
Beyond the 710:
Moving Forward
&
New Initiative for
Mobility and Community
Report

Attachment E
Analysis of Costs and
Benefits
& Technical Exhibits
Exhibit 1: Nelson\Nygaard CBA Report
Review
Exhibit 2: The Maxima Groups Comments

SHUTE, MIHALY
U-\EINBERCERr-r-p
396 HAYES STREET, SAN FRANCISCO, CA 94102

CATHERINE C. ENGBERC

T: (a1s) ss2-7272 F: (a1s) 552-s816

Attorney

www.smwlaw.com

ngb erg@s mwlaw.co m

August 3,2015
Via E-Mail and FedEx
Garrett Damrath
Chief Environmental Planner
California Department of Transportation

District 7
100 South Main Street, MS-I6A
Los Angeles, California 90012
garrett. damrath@dot. ca. gov
Re:

Philip A. Washington
Chief Executive Officer
Los Angeles County Metropolitan
Transportation Agency
One Gateway Plaza
Los Angeles, California 90012-2952
washin gtonp@metro. net

Route 710 North S

Analysis of Costs and Benefits

Dear Mr. Damrath and Mr. Washington:

These comments are submitted on behalf of Connected Cities and Communities
regarding the Analysis of Costs and Benehts ("CBA") for the State Route 710 North
Study Alternatives ("Project"). Our firm previously submitted comments on the adequacy
of the Draft Environmental Impact Report/Statement ("DEIR/S") for the Project. Our
comments, dated July 9, 2015, identif,red numerous flaws in the DEIR/S's analysis and
mitigation of a host of environmental impacts resulting from the Project, particularly its
freeway tunnel alternatives.

The CBA, unfortunately, perpetuates these effors. The CBA concludes that the
freeway tunnel alternatives, particularly the single bore alternative, would have the
greatest benefits relative to its costs. However, the CBA, like the DEIVS, assumes that
the freeway tunnel alternatives will relieve traffic congestion, when in fact the opposite is
true. Similarly, it understates the true environmental costs of the Project-particularly
with respect to air pollution and greenhouse gas emissions-by considering emissions
from vehicles for only 20 years of the 100-year life of the freeway tunnels. Conveniently,
the CBA does consider the 100-year life of the tunnel when it considers Project benefits,
and allocates a generous $769 million (single bore) and $1.39 billion (double bore)
"residual value" to these alternatives. Moreover, contrary to accepted cost-benefit
evaluation methodology, the CBA assigns roughly $1 billion in employment benefits.

amrath, C al i fornia D ep artment of Transp ortation

Philip A. Washington, Los Angeles Metropolitan Transportation Authority
August 3,2015
Page 2
G

arrett

Inclusion of these o'benefits" is all the more questionable because there is no guarantee
that workers will come from the study area. In addition, the DEIVS does not identiff
employment opportunities as a Project objective; consequently, the CBA errs by
including it as a Project benef,rt.
The following table summarizes the CBA's calculations of net present value
("NPV" for each alternative, and identifies just a few of the many analytical flaws
reflected in the NPV estimates. Obviously the single bore freeway tunnel will no longer
rise to the top once the CBA is revised to include accurate assumptions and methodology.

Alternative

TSNI/TDM
Freeway Tunnel
Single Bore
Freeway Tunnel
Double Bore

BRT
LRT

Analytical Flaws

CBA's
estimation of
NPV ($Nr
343
1,477 to 1,590

overstates travel time benef,rt

-37 to 506

overstates residual value ($769

$1.39 B [double bore])

fails to justiff inclusion of "employment

benefits" ($S08 M fsingle bore]; $1.38 B
fdouble bore])

369
-870

M [single bore];

understates air pollution and GHG costs

overstates residual value

fails to justiff inclusion of "employment

benefits" ($714M)

For the reasons detailed in this letter, and the reports prepared by Nelson\Nygaard
and the Maxima Group (attached as Exhibits I and 2),fhe CBA is deeply flawed and
misleading. We urge LA Metro and Caltrans to correct the CBA's analysis consistent
with accepted cost/benefit analysis methodology and common sense. Of critical
importance, the revised CBA must clearly document each of its assumptions for
calculating each of the alternatives costs and benefits. The current CBA provides no

SHUTE, MIHALY

(r-utetN

B E RG E R Lrp

arrett Damrath, C alifornia D epartment o f Transp ortati on

Philip A. Washington, Los Angeles Metropolitan Transportation Authority
G

August 3,2015
Page 3

detail regarding assumptions or methodology and therefore the public and decisionmakers are often forced to guess as to how the document reaches its conclusions.

I.

Under Both NEPA and CEQA' the Agencies May Not Rely on the CBA to
Select a Preferred Alternative or Approve the Project.

The CBA states that it was prepared at the direction of Metro's Board of Directors,
but that it is not a requirement of the National Environmental Policy Act ("NEPA") or the
California Environmental Quality Act ("CEQA"). This assertion does not excuse the
agencies from preparing an accurate analysis of the Project's costs and benefits. NEPA
prohibits agencies from relying on cost-benefit analyses that, like this one, contain
misleading assumptions and inflated economic benefits. See Hughes Rver Watershed
Conservancy v. Glickman (4th Cir. 1996) 81 F.3d 437,446-47 (agency's reliance on a
study that contained faulty economic analysis violated NEPA because it failed to
"ensur[e] that members of the public ha[d] accurate information to enable them to
evaluate the Project" and "impaired fair consideration of the Project's adverse
environmental effects" ); see also Hgh Country Conservaton Advocates v. United States
Forest Serv,, 52 F . Supp. 3d ll7 4,1 191 (D. Colo. 2014) (fact that cost benefit analysis is
not required under NEPA does not permit agency to rely on quantified economic benefits
while ignoring project costs related to greenhouse gas emissions).

Nor may the agencies rely on the CBA to support any findings or statement of
overriding considerations under CEQA. Agencies' statements of overriding
considerations must be supported by substantial evidence in the record. CEQA
Guidelines, 14 CCR $ 15093(c). "The statement's putposes are undermined if . . . it
misleads the reader about the relative magnitude of the impacts and benefits the agency
has considered." Woodward Park Homeowners Ass'n, Inc. v. Cty of Fresno (2007) 150
Cal.App.4th 683, 718 (statement of overriding considerations invalid where it "applied a
thumb to the scale" and its assesslnent of the economic costs and benefits of the project
was not supported by substantial evidence).

NEPA and CEQA thus require the agencies to correct the CBA's flawed analysis
prior to identifring a Preferred Alternative or adopting findings in support of any
statement of overriding considerations.

||.

The CBA Grossly Overstates Benefits Associated with Travel Time Savings.

The CBA concludes that the freeway tunnel alternatives will outperform the other
alternatives with respect to travel time savings by an entire order of magnitude. It assigns,

SHUTE, MIHALY

(r=VEINBERGERu-p

arrett D amrath, C ali fornia D ep artment o f Transp ortation

Philip A. Washington, Los Angeles Metropolitan Transportation Authority
G

August 3,2015
Page 4

for example, a "benef,it" of approximately 52.5 billion for travel time savings associated
with the single bore freeway tunnel alternative, compared to approximately $500 million
for the TSI\4/TDM alternative. See CBA, Exh. 3-5.
The freeway tunnel alternatives' "beneflts" are based on deficient DEIR/S
analyses, including deeply flawed travel demand modeling. These flaws are fully
described in our July 9, 2015 letter, Exhibit 1 (Nelson\NygaardReport), as well as in
Nelson\Nygaard's CBA Report Review. Once corrected, the CBA's calculation of net
present value of the freeway alternatives would likely be significantly reduced.

Key flaws of the DEIR/S, the travel demand model and the CBA's travel time
savings analysis include:
a

The travel demand model and the resulting CBA analysis fail to account for
induced traff,rc that would result from the freeway tunnel alternatives. Over
the short-term, congestion may actually be reduced as a result of the
freeway tunnel alternatives' increased capacity. However, because the
DEIR/S only analyzedtraffic-related impacts for a ten year period (between
2025 and2035),the purported efficiency gains, if any, would be expected
to dissipate as a result of induced demand. Had the DEIR/S evaluated the
Project's impact on traffic conditions through 2050, the alleged travel time
savings, if any, would be greatly diminished.

Rather than alleviating trafFrc, the freeway tunnel alternatives would simply
cause bottlenecks to shift between locations. The CBA, like the traffic
model, fails to recognize this phenomenon. As an example, in the a.m. peak
period under the No Build alternative, the northbound section of I-710 at I10 is modeled as the 280th most congested freeway segment in the greater
Los Angeles region. In the dual-bore freeway tunnel alternative, this
segment moves up the list 256 places to become the 24th most congested
freeway segment in the region.

The CBA's sensitivity analysis for "value of time" reveals a bias in favor of
the freeway tunnel users, and against transit users. Rather than using a
factor of $13.25 for both auto and transit users, the sensitivity analysis uses
a factor of 522.57 for auto and $6.35 for transit. Such figures suggest a
value judgment that drivers are more valuable, without any evidence. In

SHUTE, MIHALY

(r-utuNBERCERu-p

Garrett D amrath, C al i fornia D ep artment o f Transp ortati on

Philip A. Washington, Los Angeles Metropolitan Transportation Authority
August 3,2015
Page 5

fact, many transit users choose transit so that they may work and
communicate during their commute, in ways that drivers cannot.
The calculation of travel time savings commences at "opening day" (2020
or 2025) and includes 20 years of forecasted travel time savings. However,
the CBA does not appear to discount these numbers for the minimum five
to six years of travel time losses due to traffic delays/detours during tunnel
construction.

III.

The CBA Understates Costs Associated With

Gas Emissions.

Air Pollution and Greenhouse

The CBA assigns a $5-40 million "disbenefit," i.e., cost, associated with increased
air pollution resulting the freeway tunnel alternatives. The TSIWTDM, BRT and LRT
alternatives, on the other hand, would not worsen the region's air quality and are
therefore assigned a benefit of $10-$30 million.
The CBA's monetization of costs associated with air pollution resulting from the
freeway tunnel alternatives is grossly understated, for the following reasons:
o

The CBA ignores the sharp increase in particulate emissions that would
occur during the minimum five to six years of tunnel construction. The
CBA should monetize these construction-related impacts.

The DEIVS concludes that the freeway tunnel alternatives would result in
a substantial regional beneft for public health. Yet, in direct contrast to
this f,rnding, the DEIVS's technical appendix discloses that the freeway
tunnel alternatives would cause localized cancer increase due to added
vehicle emissions. In fact, the technical appendix determines that the
increased cancer risk at certain locations would be a staggering 149 in I
million, compared to the South Coast Air Quality Management District's
10-in-1 million cancer risk significance threshold. Given the DEIR/S's
effoneous and highly misleading finding regarding the tunnel alternatives'
alleged health benefts, it is likely that the CBA assumed these same
benefts. A CBA that accurately reflected the f,rndings in the DEIR/S's
technical appendices would have taken into account the economic burden
of cancer such as health care expenditures and productivity loss. The CBA
should be revised to include an accurate monetization of these health
impacts.

SHUTE, MIHALY
(r-u,tetNBERGERu_p

Garrett D amrath, C aliforni a D ep artment o f Transp ortation

Philip A. Washington, Los Angeles Metropolitan Transportation Authority
August 3,2015
Page 6

IV.

As explained in The Maxima's Group report, the CBA fails to consider or

monetize the adverse health effects associated with venting concentrated
vehicle emissions from the freeway tunnels into near-roadway
communities. These adverse health effects include increased rates of
asthma, ear-nose-throat infections, heart attack and stroke.

The CBA ignores and fails to monetize the long term increase in
greenhouse gas emissions that will result over the 1O0-year life of the
tunnel alternatives. See High Country Conserv. Advocates,52F. Supp.3d at
1191 (agency's failure to consider economic costs of greenhouse gas
emissions violates NEPA).

The CBA Includes Residual Benefits White Ignoring Residual Costs.

The CBA's analysis generally includes 20 years of projected costs and benefits.
However, it skews the analysis heavily toward the tunnel alternatives by assigning a 100year "residual benefit" to these alternative. The CBA's approach is flawed, for several
reasons:

V.

The CBA's approach runs contrary to Caltrans cost-benefit evaluation

methodology, which includes no guidance for assigning a "residual value."

The CBA fails to include commensurate "residual costs" associated with

the freeway tunnel alternatives' increased air pollution, greenhouse gas
emissions and traffic congestion.

The CBA's inclusion of residual value inflates the tunnel alternatives'

purported benefits and misleads the public, in violation of NEPA. ,Se
Glickman, Sl F.3d af 446-47.

The CBA Fails to Justify Inclusion of Purported Employment Benefits.

The CBA tips the scales in favor of the tunnel alternatives by assigning roughly $1
billion in employment benefts to these alternatives. This purported "benefit" has no
place in the CBA or in the agencies' consideration of the Project, for the following
reasons:
a

The CBA's approach runs contrary to Caltrans cost-benefit evaluation

methodology.

SHUTE, MIHALY
C1.--\EINBERGERilp

Garrett D amrath, C aliforni a D ep artm ent o f Transp ortati on

Philip A. Washington, Los Angeles Metropolitan Transportation Authority
August 3,2015
PageT

VI.

The DEIR/S does not identiff increased employment of construction and

maintenance workers as a Project Objective.

Employment earnings would not defray project costs because it is likely

that alarge portion of those earnings would be accumulated outside the
study area.

Although this is not disclosed in the CBA, discussion with one of the
consultants involved in its preparation revealed that the estimate ofjobs
created is simply based upon an assumed creation metric of x number of
jobs per construction dollar. This approach incorrectly inflates the number
ofjobs attributed to the tunnel alternatives since the tunnel boring machines
should cost a minimum of $80 million;the use of two TBMs is planned for
single bore tunnel construction, and four for the dual bore tunnels. Since
no TBM manufacturer is located in California, let alone the United States,
the number ofjobs attributed to such alternatives is significantly inflated.

Conclusion

In conclusion, the CBA's errors are not flyspeck;they undermine the document's
entire analysis. LA Metro and Caltrans must revise the CBA to correct its flawed analysis
prior to identiring a preferred Project alternative.
Very truly yours,
SHUTE, MIHALY & WEINBERGER LLP

Catherine C. Engberg
Rachel B. Hooper
Laurel L. Impett, AICP

List of Exhibits

Exhibit

1:

Nelson\Nygaard CBA Report Review (July 16,2015)

Exhibit 2:TheMaxima Group's Comments on Metro's 710 Alternatives Cost Benef,rt

Analysis (July 23, 2015)
SHUTE, MIHALY

e}-\EINBERGERLp

Exhbit

MEMORANDUM
To:

Proiect Teom

From:

Poul Moore

Dote:

July I 6,2015

Subiect: Nelson\Nygoord GBA Report Review

Following is Nelson\Nygaard's initial review of the "Analysis of Costs and Benefits for the State
Route 7ro North Study Alternatives" (CBA) developed by Metro, released on June Lg, 2ot1.

Method of Presentation of Benefits

The CBA states that benefits "are typically examined independent of their relationship to costs."
This is false. No one responsible for a budget would contend that magnitude of cost is irrelevant.
By choosing to present the "results" in terms of net present value rather than a ratio ofbenefit to
cost, the report favors bigness. This is an incomplete picture of the effectiveness of spending
limited fiscal resources - in the case of the freeway tunnels, resources that are not available. As
presented in the report, the order of preference (ranked by net present value in millions) is:

Single Bore Freeway

$r"sgo

Dual Bore Freeway'

$506

BRT

$sog

TSMfTDM

tT

$344

-$so

If, however, the alternatives were presented in terms of the ratio of benefit to cost, the results
would be quite different:

TSM/TDM
Single Bore Freeway
BRT
DualBore Freeway
LRT

2.3
1.8

L.I
1.1

0.6

The TSM/TDM alternative (even as poor designed as it is in the DEIR) clear provides more
public benefit per dollar spent. It stands to reason that the best way to create more net present
value would be to ramp up the TSM/TDM spending to the same level as the single bore tunnel
spending. If as much money were spent on TSM/TDM as is projected for the single bore freeway
and the same 2.3 ratio held, the TSM/TDM alternative would provide $z,693,ooo,ooo of benefit
- over $r billion more than the single bore tunnel. This seems like a sound strategy to explore.

BRT Alternative Costs

The bulk of cost for the BRT alternative appears to be operating and maintenance (O&M) cost and
TSM/TDM supplemental enhancements. However, the information provided raises some
questions:

TSM/TDM

TSM/TDM. Both freeway alternatives

and the LRT include about $So million. The BRT alternative, however, includes $roz million near equal to the construction cost of the BRT itself. There may be two possible explanations:
Each of the build alternatives includes some elements of

1.

Enhanced support for the core bus service - For more detail, the document refers the
reader to the SR 7to North Srudy - BRT Operating Plan (CHzM Hill. March gr, zot4).
That document has a section entitled TSM Alternative (Bus Components), which
presumably documents what these TSM/TDM components are intended to be. That
section says "These enhancements relate primari to frequency of service. By providing
higher frequency seryice throughout the study area, local bus transit becomes an
increasinglyviable alternative to private automobile travel while reducing travel times
and enhancing mobility significantly for existing transit users." If the cost of substantially
increasing bus service throughout the study area is being assigned to the BRT as a cost,
then Metro should confirm that the resulting ridership increases that would be expected
have been calculated in the alternative's benefits. If not, these costs should be removed

from the anasis.

2.

Simplistic application of a rule of thumb - The CBA, on page 2-T has a short paragraph
that suggests "TSM/TDM Alternative costs were determined for each intersection,local
street, and hook ramp location based on a value of $zo,ooo per intersection and per ITS
location, and $S3,ooo per lane mile." If the methodolog'used for this analysis was
simply apply these linear costs to the BRT alternative (which is twice as long as the LRT
alternative) without any modeling of the attendant benefits, this cost should be
subtracted.

O&M Cost
The CBA covers the cost of operating BRT as the most substantial element of the overall cost of
this alternative. The report indicates that these costs amount to a fully allocated cost rate of
$tg+.Zo per revenue service hour. This is a reasonable number consistent with Metro's reporting
and is inclusive of all O&M costs. The CBA indicates that these hour costs add up to $28 million
annually (Table z-3), however the SR 7to North Study - BRT Operating Plan indicates these
costs are only $5 million for the more expensive of the two BRT alternatives based on the service
plan outlined (Table r). It is not clear why the number shown in the CBA is so much higher.

If these costs were, in fact, adjusted downward, it is likely that the BRT alternative would
approach a ratio of benefit to cost very similar to the 2.3 achieved by the TSM/TDM alternative.
In any event, it would only take a minor downward cost adjustment to cause the BRT to perform
better than the single bore tunnel.

Value of Time
Pages z-r and z-z go into some detail about why and how the Cal - B/C model was chosen as the
tool for this analysis. However, the sensitivity analysis includes a note that a "different value of
time(VOT) featuring different VOTs for auto and transit users was applied - 8zz.S7 for auto and
$6.9S for transit (zor4 prices) - instead of the Cal-B/C assumptions ($13.25 for both auto and
transit)." The document does not explain the logic for this analysis, nor why it has any relevance.
This is concerning as it seems to suggest a value judgment that the time of one group of modal
users is more valuable than another. Even if a narrow analysis of the current incomes of regional
drivers verses transit riders illustrated this type of disparity, factoring decision-making processes
to favor those who are current more affluent is a path to hard-wiring poverty. The region and its
transportation agencies are all committed to equitable transportation options, so it is important
that project selection processes be structure to support these goals. Including an analysis that
suggests otherwise, could inappropriate influence readers of the report. The basis for and
relevance of this element of the sensitivity analysis should be explained more fully and Metro
should consider removing this analysis altogether.

Rather, the opposite relationship could be argued. Time spent on transit is less "lost" time than
that spent driving, since transit riders can work or communicate in ways that car drivers cannot.
This is, in fact, why many riders choose transit over driving. The CBA fails to account for this

real.
Accountine for Tolls
The CBA report indicates that tolls were not included as a CBA benefit (or disbenefit) because
they are considered "transfer benefits." Presumably this means that since the tolls paid by users
will help to defray the cost of the tunnel they would be present on both sides of a cost/benefit
equation (or ratio) and therefore need not be accounted. This is a fallacious conclusion for
multiple reasons but specifica because there is no guarantee that the tolls collected over the zo
year period of CBA analysis will cover the full private contribution to tunnel construction. It is
inaccurate to ignore the disbenefit of all of the tolls collected past the 20 year analysis period
while assigning a residual value of the constructed tunnel as a benefit. In simple terms (with no
adjustments made to present dollars) here is how the math would change:

Assumption Set

t (Similar

to CBAAnaIgsis)

a.
b.
c.

Tunnel Cost: $3 Billion

Time Benefit: 4oo Million Person Hours @ gr3/hr = gsBillion
Residual Value: g75o Billion
Ratio of Benefits to Costs: ((b+c)/a) = 1.9
Assumption Set z (More accurate Methodology)

a.
b.
c.
d.

Tunnel Cost: ($3 Billion minus $r.6 B Toll Revenue after Debt Service) = $r.4 Billion
Time Benefit: 4oo Million Person Hours @ gr3/hr = g5Billion
Residual Value: gZSo Billion
Tolls Collected = (610 Million Trips x $+) = $2.+ Billion

Ratio of Benefits to Costs: ((b+c)/(a+d)) = r.s

As stated, the above is a simplistic demonstration meant to illustrate that omitting the tolls from
the analysis results in four primary problems:

1.

Looking at ratios built of numerous factors means that presence of tolls (or
toll-related borrowing) in the numerator and denominator does not necessari cancel.

z.

Any toll money that is intended to fund construction does not exist at the
time of tunnel construction and so must be borrowed, with interest.

3.

Incompatible time cycles - The CBA only analyzed a zo year period for costs and benefits,
then gave the residual value of the tunnel life cycle back as a benefit. This would onlybe
valid if all tolls were collected and done in the zo year window, which they likely won't be.
The above analysis quantifies this zo years of tolling and only gives that level of relief to
the tunnel cost.

4.

Tolls affect behavior - Tolls are not simply a "transfer benefit." The tolls are responsible
for much of the travel time benefit. As stated on page ES-3 of the DEIR "the travel time
savings do not factor in the cost of tolls, which in the single-bore variations function to
keep the tunnel operating at a higher speed." To account for the benefit of time savings
while ignoring the cost is counter to the point of a benefit/cost analysis.

Basic Math

Cost of Money

The CBA should be re-run accounting for toll revenues (and the cost of servicing the debt) and
associated travel behavior changes to better understand their effects on costs and benefits.

Flawed Modeling Results

The analysis substantially overestimates travel time savings. This is problematic since page 2-1o
states that travel time "often produces the majority of the benefits" of a CBA. An error on this
element is significant. The analysis of travel time savings are flawed in several ways:

1.

As has been documented elsewhere, the travel anasis performed for the DEIR (and used
for the CBA) did not account for the proven dSmamic of induced travel.

2.

The description of methodology on page e-to refers to calculation of traffic growth over
2o-years at r% compounded annua. Not only does this seem odd, given the availabil
of a travel demand model that reports vehicle delays, but the assumption flys in the face
of available data which suggest traffic volumes have been fair steady over the past 30
years.

3.

The methodology suggests that trave-l time was only calculated for highway users. In
particular, it makes no sense to evaluate a transit alternative and not account for the
travel time of actual transit riders. It is not appropriate to ignore, for example, all of the
current local bus riders, pedestrians and cyclists whose travel time may be improved by
the BRT, LRT or TSM/TDM alternatives. The fact that these travelers do not current
drive in a car should not negate the benefits that they will accrue from improved transit
service.

4.

The DEIR ignores significant delays that would result from construction of the dual bore
tunnel. The DEIR model does not include spillback (traffic backups, common in Los
Angeles, that spill over into upstream segments and accumuate), but instead assumes
that all cars will get through the bottleneck. The EIR model numbers for I-7ro
northbound at I-ro (the primary upstream source of northbound tunnel traffic) indicates

that traffic would begin spilling back aT7 a.m. and the queue would get longer and longer
during the day. If this were accounted for, that segment would move from the z8oth
most congested freeway segment in the greater Los Angeles region (as reported by the
DEIR) to become the z4ttt. To fail to account for this massive degradation is unacceptable.

Other Fiscal Questions

Assumptions about long term employment (which the CBA estimated based upon European
research) and residual value (which like much of the CBA assessment appears to favor megainfrastructure) are not addressed in this memo and will be left to an economic analyst.

Exhbit

THE MAXIMA GROUP LLC

Reol Eslole ond Business Solulions

23 Jvly 2015

To:

Project Teom

From:

Potricio Flynn

Subject: lnitiol Comments on Metro's Zl0 Alternotves Cost Benefit Anolysis (CBA)
I hove reod the Metro 7,l0 Alternotives Cost Benefit Anolysis (CBA) doted June 19,2015
ond offer the following preliminory comments obout the finonciol ond economic
ospects of the onolysis ond the report.

sed

it

is

for
The net present volue opprooch to evoluoting projects hos three key ottributes:
NPV considers both cosh flows ond liming
NPV uses oll the cosh flows of the project
NPV discounts the cosh flows properly
The chollenge with public infrostructure projects is to occurotely copture oll of o
project's cosh flows; determine on oppropriote period of time for the onolysis;
ossign o discount rote thot reflects project risk; ond determine o residuol volue
thot coplures future benefits beyond the onolysis period.
2.

me sel
lude ih
vestment nc{c ^c^^ in*ar'l uilh tha fi rnnal nl*arn olive
ln oddition to the significont differences in the initiol copitol cost ossocioted with
the tunnel ond the TSM/TDM ond BRT olternotives, eoch project hos o differenl
requirement for periodic copitol investmeni lo keep the infrostructure in working
order. This coptures costs obove ond beyond regulor operolions ond
mointenonce, ond includes replocement of roodwoys, equipment, ond other
costly copitol items.
nnni*nl

rain

The CBA discusses copitol replocement costs in Section 2.2.2.2where it stotes

thot "Reconstruction of povemenl os ossumed to cosl $i,2s0,000 per lone mile
ond toke ploce every twenty yeors with trucks present ond every thiriy yeors for
the freewoy olternotive withoui trucks." Given the twenty yeor onolysis period, it
seems os lhough the significont required copitol reinvesiment ossocioled with
the tunnel olternotives will not be fully reflecled in the onnuol cosh flows.
Poge

I of3

3.

4.

The employment benefit is directly correloted to copitol cost, skewing the

benefits to the most costly olternotives.
Employment benefits ore directly correloted to copitol expenditures. The
dispority in copitol costs insures thot the higher cost projects will generote more
jobs thon lower cost olternoiives.
lu

useful life, fovoring the higher cost olternotives.

The residuol volue colculolion in the CBA seems io refer to the remoining useful
life of the project rother thon the estimqted volue of future benefits. Residuol

volue is better estimoted by copitolizing the net operoting income (expected

future revenues or benefits less operoting costs) to opproximote the volue of
project benefits beyond the onolyticol period. This copitolized volue is
decreosed by the copitol costs required for on-going operotions. Even if the
copitol reinvestmeni is not reflected in the onolysis period (see comment 1), it
con ond should be included in the determinotion of residuolvolue.
The CBA discusses residuol volue with respect to the tunnel olternotives, but does
not provide much detoil for the olternotives. The tunnel residuol volue is
esiimoted be the remoining useful life of the osset, ond nol the volue of the
future benefits it will provide less the copitol reinvestment required to keep it
operotionql in the future. This is inconsistent with the principols of net present
volue onolysis.

Furthermore, the significonl differences in cost for the ronge of projecis ossures
thot the tunnel olternotives with their huge initiol copiiol costs will hove residuol
volues thot overwhelm the lower cosl olternotives.

5.

The discount rote used does not reflect the differentiol in risk ossocioled with lhe
vorious options.
The CBA ossumes lhot oll projecis will be discounted of lhe some rote (four
percent). This is conceptuolly incorrect ond inconsistenl wilh the view of copitol
morkets.
The discount role is correloted To the riskiness of the project: the higher the risk,
the higher the discount rote. li is cleor thol o TSM/TDM projeci, for exomple, is
significontly less risky in both construction ond operotion thon o tunnel. Assuming
thot benefils from both projects would be volued of the some discount rote is
incorrect ond skews the onolysis to fovor the more risky tunnel olternotives.

Copitol morkets ossume o discount rote for the project thot looks of The
weighted overoge cosl of copitol. Very lorge infrosiructure projects typicolly
hove privote sector investmenl ond porticipotion. The required return on privole
copitol is often 20 percent or more. This higher return requirement reflects both
the riskiness of the project ond meons thot the weighted overoge cost of copitol
is significontly higher thon lower cosls olternotives thot ore publicly funded.
Poge 2 of 3

Using the some discount roie for oll of the olternotives in the CBA ignores lhe
significont risk ossocioted with construction ond operotions of the tunnel
olternotives ond overstotes their net present volue.
6

mt

too

venting. The methodology for estimoting the emissions-reloted costs ond

benefits of the proposed olternotives seems very simplistic, relying on the Col B/C
model to estimote the difference in emissions between the vorious olternotives
bosed on chonges in VMT. This opprooch does not occount for lhe
concentrotion in emissions likely to result from the venting plon for ihe tunnel
oliernotives. These vents hove the potentiol to concentrote chemicol pollution,
diesel micro-porticles, ond broke ond tire porticles of the tunnelventing sites.
Numerous studies hove identified the public heolth costs ossocioted with oir
pollution. The USC Environmentol Heolth Centers of the Keck School of Medicine
hove been prominent in the reseorch of the heolth ospects of neor-roodwoy oir
pollution. Studies cleorly show the higher risk of osthmo; eor, nose ond throot
infections; heort ottock; ond stroke in locotions impocted by concentroted truck
ond oulo troffic. A July 2015 study by the Environmentol Heolth Centers detoils
the impoct of neor-roodwoy pollution on coronory heori heolth.
The sociol ond economic costs ossocioted with chronic heolth conditions, while
chollenging to estimote, ore reol ond significont. This includes direct costs such
os hospitolizotion ond long-term treotment os well os indirect costs such os lost
lime of work, obsenteeism of work/school, ond loss of productivity. The Col B/C
estimote of emissions impocts does not oddress public heolth considerotions

given the venting plon for the proposed tunnel olternotives.

The misopplicotion of the NPV opprooch ond the use of incorrect ossumptions,
the incomplete onolysis of long-term costs such os the public heolth impocl of
vented emissions, olong with ihe issues roised in the Nelson Nygoord memo
doted June 23, 2015 cost significont doubt on the integrity of the ZIO Exlension
cBA ond suggesf there should be o different opprooch lo the economic
comporison of project olternotives. The rotio of benefils to cosls, os discussed in
the Nelson Nygoord memo, is o better indicotion of the relotive merits of lhe
olternotive projects.

Poge 3 of 3