draft environmental impact report: love's travel stops

DRAFT

ENVIRONMENTAL IMPACT REPORT

for the

LOVE’S TRAVEL STOPS State Route 12 East of Thornton Road

Lodi, CA

San Joaquin County EIR No: 1200065 State Clearinghouse No: SCH 2012052082

September 28, 2012

Prepared for:

SAN JOAQUIN COUNTY Community Development Department

Planning Division 1810 E. Hazelton Ave.

Stockton, CA 95205 (209) 468-3124

DRAFT

ENVIRONMENTAL IMPACT REPORT

for the

LOVE’S TRAVEL STOPS State Route 12 East of Thornton Road

Lodi, CA

San Joaquin County EIR No: 1200065 State Clearinghouse No: SCH 2012052082

September 28, 2012

Prepared for:

COUNTY OF SAN JOAQUIN Community Development Department

Planning Division 1810 E. Hazelton Ave. Stockton, CA 95205

(209) 468-3124

Prepared by:

Kleinfelder 2001 Arch-Airport Road, Suite 100

Stockton, CA 95206

NOTICE OF AVAILABILITY FOR THE DRAFT ENVIRONMENTAL IMPACT REPORT (DEIR)

LOVE’S TRAVEL STOPS

The Draft Environmental Impact Report (DEIR) for the Love’s Travel Stops truck stop is available for public review and comment. The proposed Project involves an application to the San Joaquin County Planning Commission for approval of a Use Permit for a proposed Love's Travel Stops truck stop, to be sited on 11.6 acres located immediately east of North Thornton Road and north of State Route 12 (SR 12) in unincorporated San Joaquin County. The proposed Project would include a fuel dispensing area with 24 fueling positions to dispense gasoline and diesel fuel to passenger vehicles and trucks. The Project would include a 7,700 square foot convenience store with an attached 3,000 square foot fast-food restaurant, and a 1,200 square foot storage building. The Project is consistent with existing San Joaquin County General Plan land use designations and zoning, which allow freeway service commercial development. The site is approximately one-quarter mile east of Interstate 5 (I-5). The Project site is comprised of Assessor’s Parcel Numbers (APNs) 025-190-32, 33 and 34. The proposed project site is not present on any of the lists of sites enumerated under Section 65962.5 of the Government Code including, but not limited to lists of hazardous waste facilities, land designated as hazardous waste property, or hazardous waste disposal sites. The EIR for the proposed Love’s Travel Stops project is limited in scope as a result of litigation. The County previously prepared an initial study/mitigated negative declaration (MND) for the Project, which was adopted by San Joaquin County Planning Commission on May 19, 2011, concurrently with the approval of the requested Use Permit and Site Approval Application for the Project. The Planning Commission’s approval was appealed to the County Board of Supervisors by the adjoining Pilot Flying J Truck Stop; the Board heard and denied the appeal on July 12, 2011. A Notice of Determination was filed on July 14, 2011. The approval was upheld by the Board of Supervisors, but the adequacy of the MND was subsequently challenged in the San Joaquin Superior Court. In resolution of the litigation, on April 9, 2012, the Superior Court issued a writ directing the County to rescind its prior approval of the project and its adoption of the MND and to prepare an EIR for the project limited in scope to the subjects that had been at issue in the litigation: traffic (project-specific and cumulative) and air quality (project-specific and cumulative). As such, this DEIR focuses on traffic, air quality, cumulative impacts (traffic and air quality) and other CEQA requirements (alternatives, growth-inducing effects, irreversible effects and other subjects required by CEQA). The DEIR identified two significant and unavoidable impacts regarding traffic: 1) consistency with LOS standards for freeway ramp junctions; and 2) cumulative impacts for freeway ramp junctions. The DEIR and all documents referenced in the DEIR are available for review by members of the public at 1810 E. Hazelton Avenue, Stockton, CA 95205 between the hours of 8:00 am and 12:00 pm and 1:00 pm and 5:00 pm Mondays through Fridays, excluding holidays. The DEIR and its appendices are also available at the Community Development Department website (www.sjgov.org/commdev) for download and review. Additionally,

copies of this DEIR may be purchased for $20.00 at the Community Development Department. Electronic copies are available for $10.00.The review period begins September 28, 2012 and ends November 13, 2012. No public hearings are scheduled at this time. If you have any comments on the contents of the DEIR, they should be submitted in written form to this office by November 13, 2012. The address is 1810 E. Hazelton Avenue, Stockton, CA 95205. The email address is [email protected]. ****

127410/STO12R0432 ii September 28, 2012 Love’s Travel Stops Environmental Impact Report

TABLE OF CONTENTS

Page 1.0 Introduction

1.1 Love’s Travel Stops Project and Background and EIR Overview 1-1 1.2 EIR Requirements and Processing Under the California Environmental Quality Act 1-2 1.3 Environmental Impact and Issues Terminology 1-4 1.4 EIR Scoping 1-5

2.0 Summary

2.1 Summary of Project Description 2-1 2.2 Areas of Controversy 2-1 2.3 Summary of Impacts and Mitigation Measures 2-2 2.4 Summary of Alternatives 2-2 2.5 Significant and Unavoidable Impacts 2-3

3.0 Project Description 3-1

3.1 Project Overview 3-1 3.2 Project Location 3-1 3.3 Project Objectives 3-1 3.4 Project Background 3-2 3.5 Project Details 3-4 3.6 Permits and Approvals 3-5

4.0 Air Quality 4-1 5.0 Transportation/Circulation 5-1 6.0 Cumulative Impacts 6-1

6.1 Air Quality 6-2 6.2 Transportation 6-4

7.0 Alternatives to the Proposed Project 7-1

7.1 Selection of Alternatives 7-2 7.2 Alternatives Not Considered in Detail 7-4 7.3 Alternatives Considered in Detail 7-6 7.4 Environmentally Superior Alternative 7-13

127410/STO12R0432 iii September 28, 2012 Love’s Travel Stops Environmental Impact Report

8.0 Growth-Inducing Impacts 8-1 9.0 Irreversible Environmental Changes 9-1 10.0 Sources 10-1

10.1 References Cited 10-1 10.2 Websites Consulted 10-3 10.3 Persons Consulted 10-3 10.4 EIR Preparers 10-3

LIST OF TABLES 2-1 Summary of Impacts and Mitigation Measures 2-5

3-1 Permits and Approvals 3-6 4-1 State and National Criteria Air Pollutant Standards, Effects and Sources 4-4 4-2 SJVAPCD Attainment Status with Federal and State Ambient Air Quality Standards 4-5 4-3 Estimated Annual Average Emissions for San Joaquin County and The SJVAB (2008) 4-7 4-4 Summary of Air Pollutant Data Compared to Ambient Air Quality Standards, 2009-2011 4-10 4-5 National and State Ambient Air Quality Standards 4-13 4-6 Project Emissions from Construction Activities 4-24 4-7 Estimated Area and Operational Criteria Pollutant Emissions, Including Idling Emissions 4-28 5-1 Project Trip Generation 5-5 5-2 Sample Site Trip Generation Data 5-6 5-3 Intersection Level of Service Definitions 5-8 5-4 Freeway Ramp Junction Level of Service Definitions 5-8 5-5 Intersection LOS – Existing Conditions 5-15 5-6 Ramp Junction LOS – Existing Conditions 5-15 5-7 Intersection LOS – EPAP Plus Project Conditions 5-17 5-8 Ramp Junction LOS – EPAP Plus Project Conditions 5-19 5-9 Intersection Queuing Evaluation Results 5-22 6-1 Intersection LOS-Cumulative No Project Conditions 6-5 6-2 Ramp Junction LOS-Cumulative No Project Conditions 6-7 6-3 Intersection LOS-Cumulative Plus Project Conditions 6-8 6-4 Ramp Junction LOS-Cumulative Plus Project Conditions 6-12 6-5 Intersection Queuing Evaluation Results 6-14 7-1 Comparison of Alternatives to the Proposed Project Impacts 7-6 7-2 Allowable Land Uses in the C-FS Zone 7-8

127410/STO12R0432 iv September 28, 2012 Love’s Travel Stops Environmental Impact Report

7-3 Estimated Annual Criteria Pollutant Emissions by Alternative (Area Plus Operational) 7-10 LIST OF FIGURES 1-1 Regional Map 1-8 1-2 Street Map 1-9 1-3 USGS 1-10 1-4 Aerial Photo 1-11 1-5 Assessor’s Map 1-12 1-6 2010 General Plan and Zoning Designations 1-13 3-1 Site Plan 3-7 3-2 Existing Land Use 3-8 4-1 Air Basin Map 4-2 4-2 Aerial View of San Joaquin Valley 4-2 5-1 Study Intersections 5-3 5-2 Existing (2012) Peak Hour Traffic Volumes 5-14 5-3 EPAP Plus Project Peak Hour Traffic Volumes 5-18 5-4 STAA Vehicle Site Access 5-27 6-1 Cumulative (2025) Peak Hour Traffic Volumes 6-6 6-2 Cumulative Plus Project Peak Hour Traffic Volumes 6-9 APPENDICES (THE FOLLOWING APPENDICES ARE ON A CD ON THE INSIDE BACK COVER OF THE DRAFT EIR) A. Notice of Preparation

B. Air Quality Information

CalEEMod Output Reports Air Permitting Specialists Report

C. Traffic Study

Kimley-Horn, 2012

127410/STO12R0432 1-1 September 28, 2012 Love’s Travel Stops Environmental Impact Report

1.0 INTRODUCTION

1.1 LOVE’S TRAVEL STOPS PROJECT BACKGROUND AND EIR OVERVIEW

This Environmental Impact Report (EIR) describes the potential environmental effects that would result from the construction and operation of the Love's Travel Stops project (Project) proposed for approval by San Joaquin County. The Project would include 16 pumps and 24 fueling stations to serve 16 gasoline and 8 diesel fueling positions. The Project would also include a 7,700 square-foot convenience store with an attached 3,000 square-foot fast-food restaurant, and a 1,200 square-foot storage building. The Project would require County approval of a Use Permit. The Project would be constructed on approximately 11.68 acres east of Thornton Road, north of State Route 12 (SR 12) in unincorporated northwestern San Joaquin County. Figures 1-1 through 1-5 show the Project location. The Project site is comprised of Assessor’s Parcel Numbers (APNs) 025-190-32, -33 and -34. The site is located on the U.S. Geological Survey’s Terminous 7.5-minute quadrangle map within Section 11, Township 3 North, Range 5 East MDBM (Figures 1-1 through 1-6). The proposed Project would be developed in an unincorporated area of San Joaquin County locally known as Flag City, which encompasses approximately 110 acres one-quarter mile east of Interstate 5 (I-5). Flag City is characterized by commercial freeway service enterprises: truck stops, truck wash and truck services, passenger vehicle fueling stations, fast-food restaurants, and overnight traveler accommodations that include a motel and an RV park. Land use for Flag City is regulated by the San Joaquin County General Plan and Development Title (zoning and development codes) and by several Special Purpose Plans specific to the Flag City area. The Project previously was the subject of an application to the County for approval of a Use Permit and a Site Approval application to modify the sign requirements. The County prepared an Initial Study/Mitigated Negative Declaration (IS/MND) for the Project on April 14, 2011, which was released for public and agency review and circulated to the State Clearinghouse. The 30-day review period commenced April 19, 2011, and ended May 18, 2011. The IS/MND analyzed the impacts of the Project and determined that all impacts of the Project would be less than significant with implementation of identified mitigation measures. No substantive comments were received from public agencies or members of the public during the public review period. On May 19, 2011, the San Joaquin County Planning Commission unanimously approved the requested Use Permit and Site Approval Application and concurrently adopted the Mitigated Negative Declaration for the Project. The Planning Commission’s approval was subsequently appealed by Pilot Travel Centers LLC (Pilot), owner of the existing Pilot Flying J Truck Stop immediately west of


and across Thornton Road from the site. The appeal was heard by the County Board of Supervisors on July 12, 2011. The Board upheld the Planning Commission’s Use Permit approval and adoption of the Mitigated Negative Declaration and denied the appeal. On July 14, 2011, the County filed a Notice of Determination for the Use Permit. On August 10, 2011, Pilot filed a Petition for Writ of Mandate challenging the adequacy of the IS/MND. The Project applicant, facing potentially lengthy litigation filed by an economic competitor, successfully urged the County to jointly request that the Superior Court issue a writ of mandate directing the County to prepare a limited EIR for the Project. In doing so, they requested that the EIR ordered by the court be limited to the two issues for which Pilot claimed the IS/MND was deficient: traffic and air quality. After the issuance of the writ, the applicant requested, and agreed to fund, the preparation of an EIR for the Project. The purpose of this EIR is to analyze and describe the potentially significant environmental impacts of the Project relating to traffic and air quality (project-level and cumulative); to identify, analyze and recommend feasible mitigation measures that would avoid or substantially reduce the Project’s environmental effects; to evaluate reasonable alternatives to the proposed Project; and to meet other applicable requirements of CEQA. Despite the narrow scope of the document ordered by the Superior Court, the County, in the interest of full disclosure to all of its citizens, has prepared a document addressing additional CEQA issues. These include cumulative impacts, growth-inducing impacts, and alternatives to the Project. This EIR is an informational document that does not in itself determine whether the proposed Project will be approved. Instead, the function of the EIR is to inform the local land use planning and decision-making process. The authority for EIR preparation is addressed in Section 1.2 below, along with the relationship of the Project and this document to applicable legal requirements under CEQA.

1.2 EIR REQUIREMENTS AND PROCESSING UNDER THE CALIFORNIA ENVIRONMENTAL QUALITY ACT

This EIR has been prepared in accordance with the requirements of the California Environmental Quality Act (CEQA – Public Resources Code Section 21000 et seq.) and the State CEQA Guidelines (California Code of Regulations, Title 14, Division 6, Chapter 3). CEQA was passed in 1970 to ensure that state and local agencies consider the environmental effects of actions undertaken, funded or regulated by those agencies. The State CEQA Guidelines contain advisory and mandatory requirements for the application of CEQA to development projects. Under CEQA Guidelines Section 15367, San Joaquin County is the Lead Agency for the proposed Project. As defined in the CEQA Guidelines, the “lead agency” is the public agency that carries out a project or that has the greatest responsibility for supervising or approving a project. As the Lead Agency, the County is responsible for the preparation of the Project EIR and would decide whether or not to adopt the document. Under


CEQA Guidelines Section 15381, “responsible agencies” include all public agencies other than the Lead Agency which have discretionary approval over the project. Responsible agencies use information in the EIR to make decisions related to the Project over which they have jurisdiction. Table 3-1 in Chapter 3.0, Project Description, lists potential responsible agencies. An EIR is intended to inform decision-makers and the public about the potentially significant adverse environmental effects of the proposed Project, and to recommend feasible mitigation measures that would reduce or avoid these effects. The EIR includes consideration of cumulative impacts, growth-inducing impacts, irreversible effects and alternatives to the proposed Project. Regulatory agencies and members of the public have the opportunity to comment on the adequacy of the environmental review during a 45-day review period following the publication of the Public Review Draft EIR (Draft EIR). In this case, as explained earlier, this EIR was ordered by the court to be limited to the two sets of issues for which Pilot claimed the IS/MND was deficient: traffic and air quality. Therefore, the County requests that public comments be restricted to the information contained in the DEIR prepared pursuant to the court order. Unlike a CEQA document prepared for a project when it was first approved, this environmental document has a limited scope based on a court order. The limited scope reflects the fact that only one party was unsatisfied with the original MDN for the project, and that party raised issues limited to traffic and air quality. The scope of public comment, then, is appropriately limited here to the issues that the court concluded required further analysis. After the close of the public review period, the County is obligated to provide written responses to any significant environmental issues raised in the comments received, and those comments and responses will be published in a Final EIR. Prior to Project approval, the Final EIR must be considered by County decision-makers who must certify the document and make certain findings related to the mitigation of significant environmental effects before the Project can be reapproved. The Final EIR must also be considered by responsible agencies with discretionary approval authority. This document is the Draft EIR for the Project. This EIR is now being made available for review by agencies and the public. The EIR is accompanied by a Notice of Availability, and/or a Notice of Completion, which specify the beginning and ending dates of the public review period. Any comments or questions regarding this EIR should be submitted to the lead agency at the following address by the date specified in the Notice of Availability and/or Notice of Completion for this Draft EIR.

San Joaquin County Community Development Department

1810 E. Hazelton Avenue Stockton, CA 95205

(209) 468-3154 Attn: Rick Griffin, Senior Planner

Comments may also be sent to the following e-mail address: [email protected].


In accordance with the provisions of CEQA and the CEQA guidelines, a Notice of Preparation (NOP) of this EIR was issued by the County, inviting comments from interested agencies and members of the public on issues the EIR should address. The NOP and the comment letters received in response to the NOP are available summarized in Appendix A of this document. A summary of the three letters submitted in response to the NOP follows: California Department of Transportation (Caltrans) – Recommends that the traffic analysis for the Project be prepared in accordance with the Caltrans Guide for the Preparation of Traffic Impact Studies, dated December 2002 or the latest version. Although the traffic consultant followed the San Joaquin County Traffic Impact Study Guidelines of November 2008 in the preparation of the Project traffic study, the study used the level of service thresholds established in the Caltrans Guide. The traffic consultant also has been in contact with Caltrans regarding this Project. Requests three paper copies of the traffic study and a disk containing complete electronic data files be provided to Caltrans for its review and comment. San Joaquin County Public Works Department – Has no comment at this time. Central Valley Regional Water Quality Control Board – Notes that projects that disturb one or more acres of soil must obtain a Construction General Permit (Construction General Permit Order No. 2009-009-DWQ). The Project will be conditioned to obtain the required permit and to comply with the California Stormwater Quality Association’s Best Management Practices Guidelines for Retail Gasoline Outlets. The letter further provides information related to MS4 and industrial permits, Clean Water Act Section 404 permits, Section 401 Water Quality Certification, and Waste Discharge Requirements permits. None of these listed permits are required for the Project.

1.3 ENVIRONMENTAL IMPACT AND ISSUES TERMINOLOGY

The environmental impact analysis contained in Chapters 4.0 through 7.0 of this document compares the potential impacts of the Project to defined “significance thresholds,” in each issue area and a determination is made as to whether the Project will potentially result in: 1) No Impact, 2) a Less Than Significant Impact, 3) a Less Than Significant Impact With Mitigation Incorporated, or 4) a Significant and Unavoidable Impact.

• A Significant and Unavoidable Impact occurs where the County has determined, based on substantial evidence, that the Project will cause a substantial adverse change to the physical environment (i.e., that the environmental effect will be significant, and there are no feasible mitigation measures available that will reduce the potential effect to a less than significant level.)


• A Less Than Significant Impact is identified when the Project will involve some effect on the resource under consideration, but the County has determined that the Project will not involve a substantial adverse change to the physical environment. In this case, no mitigation measures are proposed or required.

• An environmental effect that is identified as Less Than Significant With Mitigation Incorporated is a Potentially Significant Impact that can be avoided or reduced to a less than significant level with the application of proposed mitigation measures. Where the Project may involve significant environmental effects, the EIR describes potentially feasible mitigation measures for consideration by County decision-makers.

• A determination of No Impact is self-explanatory. In this environmental document, those entities or persons responsible for the Project application and/or its ultimate construction and operation are known as the "owners, developers and/or successors-in-interest." This is abbreviated as the "ODS" in the discussions of environmental effects, mitigation measures, and the related implementation monitoring requirements described in each chapter. Some of the potential environmental effects of the proposed Project have also been considered on a cumulative level in the San Joaquin General Plan and EIR. The San Joaquin General Plan EIR addressed the potential environmental impacts of planned urban growth in the County as a whole, and in the vicinity of the Project site. The General Plan EIR and related documents, cited below, are incorporated into this Draft EIR by reference (CEQA Guidelines Section 15150). The potential environmental effects of existing and planned development of the Project site and vicinity have been considered in other CEQA environmental documents. These include mitigated Negative Declarations for the existing Pilot Flying J facility west of the site across Thornton Road and the approved General Plan amendment and rezoning that designated the proposed project site for the proposed freeway service commercial land use. Copies of these documents, and any other documents that are incorporated by reference in this EIR, are available for review at the offices of the San Joaquin County Community Development Department, 1810 East Hazelton Avenue, Stockton, CA 95205.

Baseline Environmental Consulting. 1992. Final Environmental Impact Report on the San Joaquin County Comprehensive Planning program. May 1992. San Joaquin County Community Development Department. 1998. Initial Study, Pilot Flying J Travel Plaza and Thornton Road Realignment, File No. UP-98-7 and PP-98-3. May 28, 1998. San Joaquin County Community Development Department. 1999. Initial Study, Flying J Travel Plaza and Thornton Road Realignment One-Year Extension, File No. UP-98-7 and PP-98-3. September 13, 1999.


San Joaquin County Community Development Department. 2001. General Plan Amendment and Zone Reclassification, Highway 12 Investors, File No. PA-1000183 and PA-1000184. March 7, 2011. San Joaquin Community Development Department. 2011. Initial Study/Mitigated Negative Declaration, Love’s Travel Stop and Country Store/Arby’s, File No. PA-1000131. April 14, 2011.

1.4 EIR SCOPING

As previously noted, the lead agency prepared and circulated a Notice of Preparation (NOP) for the Project in accordance with the requirements of CEQA Guidelines Section 15082. A copy of the NOP and the comments received are shown in Appendix A. The NOP included a description and location of the Project as well as a list of environmental issues that would be addressed in the EIR. The NOP review period extended from May 31, 2012 to June 29, 2012. As noted above, prior to the initiation of this EIR process, San Joaquin County processed an application for the proposed Project (Application PA-1000131). During this process, the County prepared an IS/MND for the Project and circulated it for public review. The IS/MND was also sent to the State Clearinghouse (#2011042053) for distribution. The San Joaquin Council of Governments and the San Joaquin Valley Air Pollution Control District commented on the proposed Project during the pre-application process. Two public agencies commented on the proposed Project during the public review period for the IS/MND: the County Environmental Health Department and the County Department of Public Works. No other comments were received. The received comments are summarized below by commenting agency.

• San Joaquin Council of Governments – Applicant shall participate in the San Joaquin County Multi-Species Habitat and Open Space Plan (SJMSCP), or provide alternative mitigation in amount and kind equal to that provided in the SJMSCP (This comment was previously incorporated as conditions of approval by the County and will be presented as conditions of approval when the Project is considered for potential re-approval.)

• San Joaquin Valley Air Pollution Control District - Requested more information regarding the identification and quantification of the Project’s emissions in order for the District to assess the Project’s potential impact on air quality.

• County Environmental Health Department – Require written confirmation from Public Works and water providers on sewer and water improvements and capacity. Require three sets of food facility plans for Department review. Hazardous material storage and generation require appropriate permits. Require underground storage installation application for Department review. (These comments were previously incorporated as conditions of approval by the County


and will be presented as conditions of approval when the Project is considered for potential re-approval.)

• County Department of Public Works – Require encroachment permit for work in road right-of-way. Improvement requirements for driveways, signing and striping, and pedestrian facilities (ADA compliance). Frontage improvements along Thornton Road required. Truck parking/loading areas shall be designed to ensure adequate space for operations. Applicant shall provide Caltrans hardware for traffic signal coordination. “No Parking” zone along newly constructed portion of Thornton Road. Access to be provided to on-site well. Traffic Impact Mitigation Fee and Regional Transportation Impact Fee shall be paid. Copy of final site plan to be submitted prior to issuance of building permits. Several other requirements related to storm water drainage and water and sewer services. (These comments were previously incorporated as conditions of approval by the County and will be presented as conditions of approval when the Project is considered for potential re-approval.)

CA

LI

FO

RN

IA

O R E G O N

NE

VA

DA

NORTH

EUREKA

REDDING

MEDFORD

SAN DIEGO

LOS ANGELES

SAN FRANCISCO

SACRAMENTO

CARSON CITY

RENO

ALTURAS

MADERA

SALINASFRESNO

BISHOP

MODESTO

SAN BERNARDINO

BAKERSFIELDSAN LUIS OBISPO

VISALIA

SANTA BARBARA

SANTA CRUZ

BUTTON-WILLOW

LATHROPSTOCKTON

Figure 1-1REGIONAL MAP

Source: INSITE ENVIRONMENTAL, INC.

I - 5

SR 99

US 101

SR 299

U.S. 395

SR 70

I-15

I-40

I-10

SR 80

I 80

SR 580

PROJECT LOCATION

US 101

I-5

I - 5

LAS VEGASPA

CI

FI

C

OC

EA

N

Figure 1-2STREET MAP

PROJECT SITE

SOURCE: KLEINFELDERNORTH

Figure 1-3USGS MAP

PROJECT SITE

SOURCE: TERMINOUS QUADRANGLE, SECTION 11 R5E, T3N

NORTH

Figure 1-4AERIAL PHOTONORTH

SOURCE: GOOGLE EARTH

PROJECT SITE

NORTH

SOURCE: SAN JOAQUIN COUNTY ASSESSORS OFFICE

PROJECT SITE

Figure 1-5ASSESSOR’S MAP

HIGHWAY 12 INVESTORS, LLC ETAL

HIGHWAY 12 INVESTORS, LLC ETAL

PAIGE & KIMBERLY

GILLINBLUE BEACON

INTERNATIONAL INC

SAN JOAQUIN COUNTY

PILOT TRAVEL CENTERS, LLC

SAN JOAQUIN COUNTY

REAL ESTATE ASSOCIATES, LLC

GREENLAW GRUPE JR OPERATING CO.

GREENLAW GRUPE JR OPERATING CO.

LILVAL PROPERTIES LTD PTP ETAL

A/G

A/G

GENERAL PLAN DESIGNATIONS

ZONING DESIGNATIONS

Figure 1-62010 GENERAL PLAN AND ZONING

DESIGNATIONSSOURCE: SAN JOAQUIN COUNTY


2.0 SUMMARY

2.1 SUMMARY OF PROJECT DESCRIPTION

This Environmental Impact Report (EIR) describes the potential environmental effects that would result from San Joaquin County approval of a Use Permit allowing the development of a Love’s Travel Stop on a 11.6-acre site located in the area known as Flag City in unincorporated San Joaquin County. The Project would include a fuel dispensing area with 24 pumps to dispense gasoline and diesel fuel to automobiles and trucks. The Project would include a 7,700 square foot convenience store with an attached 3,000 square foot fast-food restaurant, and a 1,200 square foot storage building. The Project is consistent with the existing Freeway Service (C/FS) General Plan designation and Commercial Freeway Service (C-FS) zoning adopted by San Joaquin County in 2011. The Project site is approximately one-quarter mile east of I-5, immediately east of North Thornton Road, and approximately 280 feet north of SR 12 in San Joaquin County. The location of the site is shown on Figures 1-1 through 1-6.

2.2 AREAS OF CONTROVERSY

The following is a discussion of issues that are likely to be of particular concern to agencies and interested members of the public during the environmental review process. The areas of concern noted below are based on the comments received on the Project, prior to the initiation of this EIR process, when the County prepared an IS/MND for the Project and circulated it for public review. The San Joaquin Council of Governments and the San Joaquin Valley Air Pollution Control District commented on the proposed Project during the pre-application process. Two public agencies commented on the proposed Project during the public review period for the IS/MND: the County Environmental Health Department and the County Department of Public Works. The comments from the Environmental Health Department simply identified the San Joaquin County Development Title requirements it deemed pertinent to the Project. The comments from the Department of Public Works involved a request for a traffic study and confirmation that the Project would be served by County Service Area 31 for storm drainage, street lighting and sewer. Comments from the Council of Governments referred to the Project’s potential for participation in the San Joaquin County Multi-Species Habitat Conservation and Open Space Plan. The comments from the San Joaquin Valley Air Pollution Control District requested more information regarding the identification and quantification of the Project’s emissions in order for the District to assess the Project’s potential impact on air quality. None of these parties expressed substantial concerns that are not addressed in this EIR. Section 1.4 in Chapter 1.0 discusses these comments in detail.


The only party that objected to the IS/MND was Pilot Flying J, the owner of an existing truck stop directly across North Thornton Road from the Project site to the west. Pilot Flying J expressed concerns about the traffic and air quality impacts of the project. As a resolution to litigation filed by Pilot on the IS/MND, an EIR was ordered by the court to be limited to the two issues for which Pilot claimed the IS/MND was deficient: traffic and air quality. As such, the potential areas of public or agency concern with respect to the Project are listed below:

• Air Quality. The operation of the proposed Project would result in additional emissions generated by on-site equipment and idling trucks, and from on- and off-site vehicle trips generated by employees and patrons. These emissions have the potential to increase regional criteria pollutant emissions.

• Transportation. The proposed Project would result in new vehicle trips to and from the site, which has the potential to impact traffic operations at intersections and along roadway segments at freeway ramp junctions within the transportation network serving the Project site.

2.3 SUMMARY OF IMPACTS AND MITIGATION MEASURES

The potentially significant impacts of the proposed project, as well as the mitigation measures proposed to minimize these effects, are listed in Table 2-1 at the end of this chapter. The table also identifies the level to which the proposed mitigation measures would reduce impacts. Significant and unavoidable impacts are those for which the significance remains “significant” or “potentially significant” after all potentially feasible mitigation measures are applied.

2.4 SUMMARY OF ALTERNATIVES

Chapter 7.0 identifies and discusses a range of reasonable alternatives to the proposed Project, including the "no project" alternative. The alternatives addressed in detail include:

No Project Reduced Project Size Alternative Use – Combination Gasoline Station Alternative Use – Retail with Fast-Food Restaurant

The No Project alternative is defined as the development of uses by existing right on the Project site, based on the County’s zoning ordinance. Development of the proposed


Project would not occur. This alternative would involve no action on the part of San Joaquin County or other agencies to approve the uses by existing right. Under this alternative, uses by right include minor utility services, family day care homes, and small group care facilities. Minor utility services would not generate any impacts. Family day care homes are associated with residences, of which none exist in the vicinity. Small group care facilities generate relatively little traffic. This alternative would result in avoidance of potentially significant environmental effects compared to the proposed Project, but does not fulfill any of the objectives of the Project. The No Project alternative is only marginally the environmentally superior alternative. The Reduced Project Size alternative assumes the reduction of the proposed Project by approximately 50%. This means 12 fueling stations instead of the 24 proposed by the Project, and reductions in the convenience store and fast-food restaurant floor space by half. This alternative would reduce most Project impacts to a level that would be less than significant, although mitigation would be required for traffic impacts under Cumulative plus alternative conditions during the PM peak hour at the SR 12/North Thornton Road intersection. However, this alternative would not meet all Project objectives. The Alternative Uses – Combination Gasoline Station alternative assumes the construction and operation of a combined gasoline station and convenience store, which is an allowed use under existing General Plan designations and zoning, subject to site approval by the County. This alternative land use would substantially reduce most Project impacts to a level that would be less than significant, although mitigation would be required for traffic impacts under Cumulative plus alternative conditions during the PM peak hour at the SR 12/ North Thornton Road intersection. However, this alternative would not meet all Project objectives. The Alternative Uses – Retail with Fast-Food Restaurant alternative assumes the construction and operation of a small grocery store with a fast-food restaurant, which is an allowed use under existing General Plan designations and zoning, subject to site approval by the County. This alternative land use would substantially reduce most Project impacts to a level that would be less than significant, although mitigation would be required for traffic impacts under Cumulative plus alternative conditions during the PM peak hour at the SR 12/ North Thornton Road intersection. However, this alternative would not meet all Project objectives. Nevertheless, this alternative is considered the environmentally superior alternative after the No Project alternative, due to less traffic.

2.5 SIGNIFICANT AND UNAVOIDABLE IMPACTS

This EIR identifies the significant environmental air quality and transportation effects of the proposed Project and the mitigation measures that are proposed to minimize these effects. Proposed mitigation would be effective in reducing project-level and cumulative potentially significant environmental effects to a less than significant level in most cases. The following impacts were identified as significant and unavoidable or potentially so in this EIR:


• Freeway ramp junction operations, EPAP Plus Project conditions

• Freeway ramp junction operations, Cumulative Plus Project conditions

TABLE 2-1

SUMMARY TABLE OF MITIGATION MEASURES

Potential Impact

Significance Before

Mitigation Measures

Mitigation Measures

Significance

After Mitigation Measures

127410/0432STO12R0432 2-5 September 28, 2012 Love’s Travel Stops Environmental Impact Report

4.0

4.1 Consistency with Air Quality Attainment Plans

LS None required

4.2 Impacts of Project Construction on Air Quality

LS None required

4.3 Impacts of Project Operations on Air Quality

S (NOx)/LS

(other criteria

pollutants)

4.3-1 Prior to the issuance of building permits, the ODS shall make application to the SJVAPCD for a permit under Rule 9510 - Indirect Source Rule (ISR). The ODS shall submit an air impact assessment (AIA) providing the quantified NOx and PM emissions associated with Project operations. The ODS shall incorporate mitigation measures identified by SJVAPCD into the Project to reduce the NOx and PM emissions associated with Project operations by at least 33.3% and 50% respectively over a period of ten years. These reduction requirements shall be met through on-site emission reduction measures. If necessary to offset any excess NOx and PM emissions not reduced by on-site measures, the applicant shall pay a monetary Off-Site Fee to SJVAPCD, as calculated under Rule 9510.

LS

4.4 Project Impacts on Carbon Monoxide Hot Spots

LS None required

4.5 Generation of or Exposure to Toxic Air Contaminants

LS None required

TABLE 2-1


Potential Impact

Significance Before

Mitigation Measures

Mitigation Measures

Significance



4.6 Odor Impacts LS None required

5.0 TRANSPORTATION

5.1 Consistency with LOS Standards: Intersections Under EPAP Plus Project Conditions

LS None required

5.2 Consistency with LOS Standards: Freeway Ramp Junctions Under EPAP Plus Project Conditions

SU None feasible

5.3 Consistency with Congestion Management Plan

LS None required

5.4 Potential Hazards: Vehicle Queuing Under EPAP Plus Project Conditions

LS None required

5.5 Potential Hazards: Circulation Impacts of Project Driveways

S 5.5-1 Three of the existing eight parking stalls located along the Burger King frontage on the shared access road shall be removed or realigned to allow for an expanded southernmost driveway and access road. The ODS shall reach an agreement with the owner of the Burger King restaurant regarding these parking stalls prior to their removal or realignment. If an agreement with the owner of the Burger King cannot be reached, the ODS shall modify the design of the southernmost driveway and access road so that the potential for conflict between vehicles entering the Project site and users of the parking stalls will be eliminated. This may be accomplished by extension of the northern edge of the driveway to accommodate the required width, or by other means that are approved by the County Public Works

LS

TABLE 2-1


Potential Impact

Significance Before

Mitigation Measures

Mitigation Measures

Significance



Department.

The expanded driveway shall be delineated to include one large entering lane and one large exiting lane. The total width of this driveway shall not exceed the maximum width specified by the County for commercial driveways. The County Public Works Department shall review and approve the design of the expanded southernmost driveway and access road prior to the issuance of building permits.

5.5-2 The middle site driveway shall have appropriate signage and pavement striping to adequately convey the proposed one-way enter driveway operation to all approaching vehicles. The County Public Works Department shall determine the adequacy of the design and approve the signage and pavement striping for the driveway prior to the issuance of building permits.

5.5-3 The ODS shall coordinate with the County to minimize potential inefficiencies of traffic interactions between the Project site and Pilot Flying J’s two truck driveways. Specifically, clarification of the one-way entering operation at the Pilot Flying J’s southern driveway and of the two-way operation at Pilot’s northern driveway should be considered. The County Public Works Department shall determine the adequacy of the design of and approve the signage and pavement striping for the northernmost driveway for the proposed Project prior to the issuance of building permits.

TABLE 2-1


Potential Impact

Significance Before

Mitigation Measures

Mitigation Measures

Significance



5.5-4 The ODS shall design and construct all improvements associated with the extension of North Thornton Road along and to the northern end of the Project site frontage. The ODS shall coordinate with the County Public Works Department to ensure that the design of improvements meets County road standards.

5.6 Potential Hazards: On-Site Circulation PS 5.6-1 The ODS shall provide on-site pedestrian facilities, such as walkways and striped crosswalks, as required, to enhance pedestrian visibility to on-site motor vehicles, both trucks and passenger cars. The location of pedestrian facilities shall be considered for, but not limited to, the following locations: between the truck fuel dispensers and the store; and the passenger car parking area and the store (across the drive-thru lane).

LS

5.6-2 The ODS shall provide signage and pavement striping to direct and contain vehicles destined for the drive-thru in order to avoid conflicts with the southernmost driveway. The County Public Works Department shall determine the adequacy of and approve the signage and pavement striping prior to installation.

5.6-3 The ODS shall provide on-site signage to restrict the internal connection between the truck and the passenger car areas.

5.7 Potential Hazards: Truck Turning Path Radii

PS 5.7-1 The proposed island south of the northernmost driveway shall be modified so as to allow the off-tracking of STAA trucks, as illustrated in Figure 10 of the Kimley-Horn and Associates traffic impact

LS

TABLE 2-1


Potential Impact

Significance Before

Mitigation Measures

Mitigation Measures

Significance



analysis of the Project (see Appendix C and also Figure 5-4 of this EIR).

5.8 Potential Hazards: Adequacy of On-Site Parking

PS 5.8-1 On-street parking shall be prohibited along the Project site frontage on North Thornton Road. Signage and striping indicating this prohibition shall be installed along this frontage in accordance with County standards. Prior to issuance of any building permits, the ODS shall submit a request, including payment of any fees, to the County Board of Supervisors to establish this “no parking” zone along the Project site frontage.

LS

5.9 Adequacy of Emergency Access LS None required

5.10 Impacts on Public Transportation, Bicycle and Pedestrian Facilities

LS None required

6.0 CUMULATIVE IMPACTS

6.1 Cumulative Impacts to Air Quality CC Implement practices associated with dust control described under Impact 4.2 in Chapter 4.0 and Mitigation Measure 4.3-1 in Chapter 4.0

LCC

6.2 Traffic Impacts Under Cumulative (2025) Plus Project Conditions

C 6.2-1 The ODS shall fund the necessary hardware and wiring to coordinate the traffic signals at the State Route 12/North Thornton Road intersection, the State Route 12/Interstate 5 Northbound Ramp intersection, and the State Route 12/Interstate 5 Southbound Ramp intersection. The traffic signals shall be coordinated such that all intersections during both AM and PM peak hours will attain at least a minimum of LOS C. Traffic signal coordination shall be accomplished in coordination

LC

TABLE 2-1


Potential Impact

Significance Before

Mitigation Measures

Mitigation Measures

Significance



with, and to the satisfaction of, Caltrans. Prior to issuance of the certificate of occupancy, written verification from Caltrans indicating compliance with this mitigation measure shall be provided.

6.3 Freeway Ramp Junction Impacts Under Cumulative (2025) Plus Project Conditions

C/U None feasible

6.4 Vehicle Queuing Under Cumulative (2025) Plus Project Conditions

LC None required

6.5 Other Impacts Under Cumulative (2025) Plus Project Conditions

LC None required

Notes:

S-Significant; PS – Potentially Significant; LS-Less than Significant; None-No Available Mitigation Measures Required; S/U-Significant and Unavoidable;

LC-Less than Cumulatively Considerable, C-Cumulatively Considerable; C/U-Cumulatively Considerable and Unavoidable

127410/STO12R0432 3-1 September 28, 2012 Love’s Travel Stops, Environmental Impact Report

3.0 PROJECT DESCRIPTION

3.1 PROJECT OVERVIEW

The proposed Project involves an application to the San Joaquin County Planning Commission for approval of a Use Permit for a proposed Love's Travel Stops truck stop, to be sited on 11.6 acres located immediately east of North Thornton Road and north of State Route 12 (SR 12) in unincorporated San Joaquin County. The proposed Project would include a fuel dispensing area with 24 fueling positions to dispense gasoline and diesel fuel to passenger vehicles and trucks. The Project would include a 7,700 square foot convenience store with an attached 3,000 square foot fast-food restaurant, and a 1,200 square foot storage building. The Project is consistent with existing San Joaquin County General Plan land use designations and zoning, which allow freeway service commercial development.

3.2 PROJECT LOCATION

As noted above, the Project site is located immediately east of North Thornton Road and approximately 300 feet north of SR 12 in unincorporated northwestern San Joaquin County. The site is approximately one-quarter mile east of Interstate 5 (I-5). The Project site is comprised of Assessor’s Parcel Numbers (APNs) 025-190-32, 33 and 34. The site is shown on the U.S. Geological Survey’s Terminous 7.5-minute quadrangle map, within Township 3 North, Range 5 East, MDBM. Figures 1-1 through 1-5 provide more detail on the Project site location. The Project is in an unincorporated area of San Joaquin County known locally as Flag City. Flag City is a freeway service commercial center that encompasses approximately 110 acres east of I-5. Flag City is characterized by commercial freeway service enterprises that include truck stops, truck wash and truck services, passenger vehicle fueling stations, fast-food restaurants and overnight traveler accommodations that include a motel and an RV park. Agricultural uses are located to the north and east of the Project site. The Project site parcels themselves have no agricultural activities.

3.3 PROJECT OBJECTIVES

The general objective of the proposed Project is to construct a Love’s Travel Stops location to serve existing travelers and truck traffic on SR 12 and I-5 and other potential customers within nearby areas along these major thoroughfares. Specifically, the objectives include:


• To develop a regional travel stop on commercially-designated land within the northern portion of the County that is consistent with County General Plan policy and zoning.

• To create a high-quality travel stop commercial development near Interstate 5, a major transportation corridor.

• To develop a property of sufficient size to accommodate a truck and auto fuel dispensing area, emergency tire repair and replacement services, convenience store, and fast-food restaurant to create a regional travel stop.

• To provide a travel stop facility that maximizes its proximity to Interstate 5 for all buildings and tenants.

• To construct a facility near a major freeway interchange in order to minimize traffic generation on local streets.

• To construct a facility with access to adequate existing or anticipated utility infrastructure to support planned operations.

• To provide a travel stop facility of sufficient size to capture overflow overnight truck parking.

3.4 PROJECT BACKGROUND

The proposed Project site consists of vacant land and approximately 5.1 acres of vineyard within an existing freeway service commercial area known as Flag City. Flag City primarily serves travelers and truck traffic along the I-5 and SR 12 corridor. Land uses in Flag City are served with utilities provided by County Service Area No. 31 (CSA 31); most other public services are provided by the County. All lands within Flag City are designated Commercial Freeway Service (C/FS) by the San Joaquin County General Plan, and are zoned Commercial Freeway Service (C-FS) by the County. Development of Flag City was initiated and approved by the County in the early 1990s. Land use for Flag City is regulated by the San Joaquin County General Plan, the County’s Development Title (zoning and development codes), and by several Special Purpose Plans specific to the Flag City area:

Special Purpose Plan PP-94-0002 - Flag City Comprehensive Site Plan Special Purpose Plan PP-98-0003 - Realignment of Thornton Road/State Route 12 intersection Special Purpose Plan PA-0700226 - Flag City (CSA 31) Design Guidelines


The southern 6.5 acres of the Project site received its current General Plan designation and zoning during the Special Purpose Plan process. A request for approval of a General Plan amendment and zone reclassification of the 5.1-acre northern portion of the site for freeway service commercial use was submitted to the County in 2010. On March 1, 2011, the Board of Supervisors approved General Plan Map Amendment PA-1000183, re-designating the 5.1-acre area from General Agriculture to Freeway Service, and Zone Reclassification No. PA-1000184, rezoning this area from General Agriculture, 40-acre minimum, to Commercial Freeway Service. This approval required annexation of the area into CSA 31. On April 15, 2011, LAFCO approved the annexation. On November 3, 2010, a Lot Line Adjustment and Merger Application No. PA-1000232 was approved by the County’s Community Development Department to merge five parcels and adjust the lot line between the remaining two parcels. As a result, the Project site is one parcel; a remainder parcel located immediately adjacent to the Project site remains in agricultural use. These approvals were followed by an application to the County for approval of a Use Permit (Application 14 No. PA-1000131, “Use Permit”) for the Project. A Site Approval application to modify the sign requirements pursuant to Development Title 9-1710(4)(j) was also submitted. The County prepared an Initial Study/Mitigated Negative Declaration for the Project (IS/MND) on April 14, 2011 (County File No: PA-1000131), which was released for public and agency review and circulated to the State Clearinghouse (State Clearinghouse #2011042053). The 30-day review period extended from April 19, 2011 to May 18, 2011. The IS/MND analyzed the impacts of the Project and determined that all impacts of the Project would be less than significant with implementation of identified mitigation measures. No substantive comments were received from public agencies or members of the public during the public review period. Consequently, the Project was scheduled for public hearing. On May 19, 2011, the San Joaquin County Planning Commission unanimously approved the requested Use Permit and Site Approval Application and concurrently adopted the Mitigated Negative Declaration for the Project. The Planning Commission’s approval was subsequently appealed by Pilot Travel Centers LLC (Pilot), owner of the existing Pilot Flying J Truck Stop immediately west of and across Thornton Road from the site. The appeal was heard by the County Board of Supervisors on July 12, 2011. The Board upheld the Planning Commission’s Use Permit approval and adoption of the Mitigated Negative Declaration and denied the appeal. On July 14, 2011, the County filed a Notice of Determination for the Use Permit. On August 10, 2011, Pilot filed a Petition for Writ of Mandate challenging the adequacy of the IS/MND. The Petition alleged that, in adopting the IS/MND and approving the Project, the County failed to comply with the provisions set forth under CEQA and the California Planning and Zoning Law (Government Code Section 65000 et seq.). The case was briefed for a hearing scheduled for May 4, 2012 in the San Joaquin Superior Court. After receiving Pilot’s opening brief in the litigation, the applicant, facing potentially lengthy litigation filed by an economic competitor, successfully urged the County to jointly request that the Superior Court issue a writ of mandate directing the County to prepare a limited EIR for the Project. In doing so, they requested that the EIR ordered by the court be limited to the two issues for which Pilot claimed the IS/MND was


deficient: traffic and air quality. After the issuance of the writ, the applicant requested, and agreed to fund, the preparation of a limited EIR for the project, analyzing the Project’s project-level and cumulative traffic and air quality impacts, consistent with the requirements of the judgment and writ. This EIR is the result of that decision, made on May 4, 2012 by the San Joaquin County Superior Court.

3.5 PROJECT DETAILS

The proposed Project would construct a Love’s Travel Stops facility on the proposed Project site described above. Figure 3-1 contains the preliminary site plan showing the layout of the proposed uses. The Project’s primary components would include two fuel dispensing area with a total of 16 and 24 fueling positions to dispense gasoline and diesel fuel to passenger vehicles and trucks. The Project would include a 7,700 square-foot convenience store with an attached 3,000 square foot fast-food restaurant, and a 1,200 square-foot storage building. The proposed structures and automobile fueling area would be located on the south portion of the site, truck fueling in the middle portion, and truck parking along the northern and eastern perimeter of the site. The passenger vehicle fueling area and circulation for this area would be physically separated from the truck fueling area and parking stalls by a raised sidewalk that links North Thornton Road to the proposed convenience store and fast food restaurant. Of the 24 fueling positions, 16 pumps would dispense gasoline, and the remaining eight would dispense diesel fuel. Fuel storage for passenger vehicles would be located west of the passenger vehicle fueling area. Passenger vehicle fuel storage tanks are expected to include a 30,000-gallon unleaded tank and a 20,000-gallon split tank for super and auto diesel. Truck fuel storage would be above-ground in an approximately 350 square foot “tank farm” located in the northern portion of the site (Figure 3-1). The diesel tanks are expected to include three 20,000-gallon tanks, one 20,000-gallon biodiesel tank, and one 8,000-gallon tank for diesel exhaust fluid. The Project would also include a 7,700 square-foot convenience store with an attached 3,000 square foot fast-food restaurant. The fast-food restaurant would have a drive-through facility for passenger vehicles. The Project would also include a 1,200 square-foot building for storage, located in the northern portion of the site. The facility would operate 24 hours a day, 365 days per year. The Project is anticipated to employ 35-40 full-time employees. The site lighting would be designed and implemented in compliance with County Development Code Section 9-1015.5, subdivision (g). A landscape architect has been engaged for designing appropriate site landscaping in accordance with County Development Code Chapter 9-1020. Parking for the proposed Project would include 68 passenger vehicle stalls, three of which would be reserved for the handicapped. The Project site would also include 94 truck stalls located along the northern and eastern boundaries of the site. Truck stalls would permit overnight parking.


Access to the site would be via three ingress/egress drives along the east side of North Thornton Road. The southernmost proposed access would be a 25-foot driveway that would allow for a full range of left- and right-turn movements by passenger vehicles accessing the fueling area and convenience store and restaurant. This entrance is located approximately 280 feet north of the North Thornton Road/SR 12 intersection. The second proposed entrance is located approximately 330 feet north of the first and would provide a 130-foot one-way inbound driveway for trucks only entrance; this access would lead directly to the proposed truck fueling stations. The third access would be located approximately 100 feet north of the second driveway and would provide an 80-foot ingress/egress that would permit the full range of left and right turn movements, inbound and outbound, for truck traffic between the Project site and Thornton Road. The proposed driveways would be aligned with the existing Pilot Flying J driveways located along the west side of North Thornton Road. North Thornton Road would be widened to five lane along the Project site frontage, with four through lanes and a center turn lane. Water, sewer, storm drainage and street lighting services for the Project would be provided through CSA 31, which is managed by San Joaquin County. The Project site had been annexed previously annexed into CSA 31, and the Project would connect to existing utility lines in the vicinity by on-site connecting lines, installed in conjunction with Project construction. Central Valley Waste Services would provide solid waste collection services, as it does for San Joaquin County. Police protection services would be provided by the San Joaquin County Sheriff’s Department, and fire protection services would be provided by the Woodbridge Rural Fire District.

3.6 PERMITS AND APPROVALS

This EIR is intended to inform decision-makers and the public about the potentially significant adverse traffic and air quality related environmental effects of the proposed Project, and to recommend feasible mitigation measures that would reduce or avoid these effects. The EIR includes consideration of cumulative impacts, growth-inducing impacts, irreversible effects and alternatives to the proposed Project. The decision-makers for the Project not only include the Lead Agency (the County), but also responsible agencies with discretionary approval authority. A Responsible Agency for the proposed Project would be the San Joaquin Valley Air Pollution Control District. The decisions by these agencies on the Project must consider the information contained in this EIR. CEQA requires that an EIR identify the principal discretionary actions under consideration in the EIR, as well as any other agency permits and approvals that may require consideration under CEQA. Anticipated and potential permits and approvals associated with the Project are identified in Table 3-1 below.


TABLE 3-1

PERMITS AND APPROVALS

Agency Permit/Approval

San Joaquin County Use Permit/Site Approval

Roadway Encroachment Permit, Storm Water Pollution Prevention Commercial Program compliance

Grading permit

San Joaquin Valley Air Pollution Control District Indirect Source Review, Authority to Construct/Permit to Operate (gasoline dispensing station)

San Joaquin Council of Governments San Joaquin County Multi-Species Habitat and Open Space Plan review and compliance (if Project chooses to implement Plan provisions)

Regional Water Quality Control Board, Central Valley Region

General Construction Permit

California Department of Transportation (Caltrans) Approval for changes to existing facilities on SR 12 (traffic signals)

Figure 3-1SITE PLAN

July 2, 2012

NORT

H

SOURCE: KIMLEY-HORN AND ASSOCIATES, INC.

Figure 3-2EXISTING LAND USESNORTH

SOURCE: GOOGLE EARTH

PROJECT SITE

TRUCK LUBE

TRUCK WASH

WELL

TRUCK STOP

TRUCK STOP

FIRE STATION

RV PARK

RESTAURANT

FAST FOOD

FAST FOOD FAST

FOOD

FAST FOOD

FAST FOOD

FAST FOOD

AUTO FUEL

AUTO FUEL MOTEL

MOTELPARK AND RIDE

127410/STO12R012R0432 4-1 September 28, 2012 Love’s Travel Stops Environmental Impact Report

4.0 AIR QUALITY

ENVIRONMENTAL SETTING

This chapter evaluates the potential air quality impacts of the Project. The original Initial Study/Mitigated Negative Declaration prepared by the County for the Project did not identify any significant air quality impacts associated with the Project. However, the Initial Study was challenged, and one of the challenges dealt with the air quality evaluation. This specific challenge was supported by a report from Air Permitting Specialists, an air quality consulting firm. Among other issues, the Air Permitting Specialists report noted the need to analyze emissions from the idling of trucks. Such emissions contain diesel particulate matter (diesel PM), which is classified by the State of California as an air toxin. Among other potential air quality impacts, this chapter evaluates diesel PM emissions from all sources, including truck idling, and assesses the potential health risk of these emissions.

Air Basin

Air quality is a function of pollutant emissions as well as the topographic and climatologic characteristics of the region. The California Air Resources Board (ARB) has divided California into regional air basins according to topographic and air drainage features. The Project site is located in the San Joaquin Valley Air Basin (SJVAB), which encompasses the entire San Joaquin Valley (Figure 4-1). The SJVAB is about 250 miles long and averages 35 miles wide. The basin is defined by the Sierra Nevada foothills to the east, the Coast Ranges to the west, and the Tehachapi mountains to the south (Figure 4-2). The San Joaquin Valley floor is essentially flat with a slight downward gradient to the northwest, opening to the sea at the Carquinez Straits.

Climate

The San Joaquin Valley is characterized by an inland Mediterranean climate typified by warm, dry summers and cooler winters. Summer high temperatures often exceed 100 degrees Fahrenheit (°F), averaging from the low 90s in the northern part of the valley to the high 90s in the south. The daily summer temperature variation can be as much as 30°F. Winters are, for the most part, mild and humid. Average high temperatures during the winter are in the 50s, while the average daily low temperature is about 45°F (City of Stockton, 2007). The Stockton area receives an average of approximately 14 inches of precipitation annually as rain. Precipitation is confined primarily to the winter months, although some precipitation does occur in the fall and spring. Summers are dry. Fog is common during the winter, often between winter storms, when high pressure and light winds allow cold moist air to pool on the valley floor, resulting in strong low-level temperature inversions and very stable air conditions (SJVAPCD, 1998).

STSTOOCC KTKTOONN

FIGURE 4-1 AND FIGURE 4-2

AIR BASIN MAPFigure 4-1

Figure 4-2AERIAL VIEW OF THESAN JOAQUIN VALLEY

SOURCE: SJVAPCD 2002

127410/STO12R012R0432 4-3 September 28, 2012 Love’s Travel Stops Environmental Impact Report

Summer winds in the SJVAB are derived from marine airflow into the basin from the west and north via the Carquinez Strait and the Sacramento-San Joaquin Delta; these air movements, which are the prevailing winds, are to the south and southeast through the Valley to and over the Tehachapi Pass into the Southeast Desert Air Basin. During the winter, regional winds occasionally originate from the southeast. The Stockton area is also subject to diurnal breezes - a sea breeze flows inward during the day and outward at night (SJVAPCD, 1998). The mountains that surround the SJVAB restrict air movement, resulting in generally weak airflow and thereby preventing dispersion of pollutants. Air movement is further restricted vertically by persistent high barometric pressure over the valley and by both summer and winter temperature inversions that generally occur below the elevation of the surrounding mountains. As a result, the SJVAB is susceptible to pollutant accumulation over time (SJVAPCD, 1998).

Air Pollutants and Related Health Concerns

This section identifies and describes the criteria pollutants of potential concern in the SJVAPCD in a human health context, including ozone and its precursors, carbon monoxide, particulate matter (PM10 and PM2.5), and air toxics. A summary of the potential health effects of these constituents is provided in Table 4-1. A summary of the SJVAPCD’s attainment status with respect to each pollutant is shown in Table 4-2. Emissions of carbon dioxide (CO2) are not of direct health concern; however, these emissions are of concern in the global climate change context. Global climate change concerns are addressed in detail in Chapter 10.0 of this EIR, and are not treated further in this chapter.

Ozone

Ozone is a colorless gas with a pungent odor. Ozone causes eye irritation and respiratory function impairment. Most ozone in the atmosphere is formed as a result of the interaction of ultraviolet light, reactive organic gases (ROG), and oxides of nitrogen (NOx). ROG is composed of non-methane hydrocarbons, and NOx is composed of different chemical combinations of nitrogen and oxygen, mainly nitrogen oxide and nitrogen dioxide. A highly reactive molecule, ozone readily combines with many different components of the atmosphere. Consequently, high levels of ozone tend to exist only while high ROG and NOx levels are present to sustain the ozone formation process. Once the precursors have been depleted, ozone levels rapidly decline. Because these reactions occur on a regional scale, ozone is considered a regional pollutant. Studies have indicated that “high ozone concentrations in the Valley were due to varying combinations of local and transported pollutants” (SJVAPCD, 2002b).

127410/STO120432 4-4 September 28, 2012 Love’s Travel Stops Environmental Impact Report

TABLE 4-1

STATE AND NATIONAL CRITERIA AIR POLLUTANT STANDARDS, EFFECTS AND SOURCES

Pollutant Averaging Time

State Standard

National Standard

Pollutant Health and Atmosphere Effects Major Pollutant Sources

Ozone 1 Hour

8 Hour

0.09 ppm

0.07

--

0.08 ppm

High concentrations can directly affect lungs, causing irrigation. May result in coughing, chest tightness, difficult taking deep breathes, worsened asthma symptoms. Long-term exposure may cause damage to lung tissue.

Formed when reactive organic gases and nitrogen oxides react in the presence of sunlight. Major sources include on-road motor vehicles, solvent evaporation, and commercial/industrial mobile equipment.

Carbon Monoxide

1 Hour

8 Hour

8-Hour (Lake Tahoe)

20 ppm (23 mg/m

3)

9.0 ppm (10 mg/m

3)

6 ppm (7 mg/m

3)

35 ppm

9 ppm

Classified as a chemical asphyxiant, carbon monoxide interferes with the transfer of fresh oxygen to the blood and deprives sensitive tissues of oxygen. May result in chest pain in heart patients, headaches, nausea, reduced mental alertness and death at very high levels.

Internal combustion engines, primarily gasoline-powered motor vehicles.

Nitrogen Dioxide

1 Hour

Annual

0.18 ppm

0.03 ppm

100 ppb

53 ppb

Irritating to eyes and respiratory tract and increased response to allergens. Colors atmosphere reddish-brown.

Motor vehicles, petroleum-refining operations, industrial sources, aircraft, ships and railroads.

Sulfur Dioxide

1 Hour

3 Hour

24 Hour

Annual

0.25 ppm

--

0.04 ppm

--

75 ppb

0.14 ppm

0.03 ppm

Irritates upper respiratory tract; injurious to lung tissue. Can yellow the leaves of plants, destructive to marble, iron, and steel. Limits visibility and reduces sunlight.

Fuel combustion, chemical plants, sulfur recovery plants, and metal processing.

Respirable Particulate Matter

(PM 10)

24 Hour

Annual

50 ug/m3

20 ug/m3

150 ug/m3

May irritate eyes and respiratory tract, decreases in lung capacity, cancer and increased mortality. Produces haze and limits visibility. May result in hospitalization for worsened heart diseases, emergency room visits for asthma and premature death.

Dust and fume-producing industrial and agricultural operations, combustion, atmospheric photochemical reactions, and natural activities (e.g. wind-raised dust and ocean sprays).

Fine Particulate Matter

(PM2.5)

24 Hour

Annual

--

12 ug/m3

35 ug/m3

15 ug/m3

Increases respiratory disease, lung damage, cancer, and premature death. Reduces visibility and results in surface soiling.

Fuel combustion in motor vehicles, equipment, and industrial sources; residential and agricultural burning. Also, formed from photochemical reactions of other pollutants, including nitrogen oxides, sulfur oxides, and organics.

Lead 30-Day Avg.

Cal. Qtr.

1.5 ug/m3

--

--

1.5 ug/m3

Disturbs gastrointestinal system, and causes anemia, kidney disease, and neuromuscular and neurological dysfunction.

Present source: lead smelters, batter manufacturing & recycling facilities. Past sources: combustion of leaded gasoline.

Note: ppm = parts per million; ug/m3 = micrograms per cubic meter.

SOURCE: Stockton General Plan 2035; California Air Resource Board; http://www.arb.ca.gov/aqs/aaqs2.p (2012)


TABLE 4-2 SJVAPCD ATTAINMENT STATUS

WITH FEDERAL AND STATE AMBIENT AIR QUALITY STANDARDS

Pollutant

Designation/Classification

Federal Standardsa

State Standardsb

Ozone - One hour No Federal Standardf Nonattainment/Severe

Ozone - Eight hour Nonattainment/Seriouse Nonattainment

PM-10 Attainmentc Nonattainment

PM-2.5 Nonattainmentd Nonattainment

Carbon Monoxide Attainment/Unclassified Attainment/Unclassified

Nitrogen Dioxide Attainment/Unclassified Attainment

Sulfur Dioxide Attainment/Unclassified Attainment

Lead (Particulate) No Designation/Classification Attainment

Hydrogen Sulfide No Federal Standard Unclassified

Sulfates No Federal Standard Attainment

Visibility Reducing Particles

No Federal Standard Unclassified

Vinyl Chloride No Federal Standard Attainment

aSee 40 CFR Part 81

bSee CCR Title 17 Sections 60200-60201

cOn September 25, 2008, EPA redesignated the San Joaquin Valley to attainment for the PM10 National

Ambient Air Quality Standard (NAAQS) and approved the PM10 Maintenance Plan dThe Valley is designated nonattainment for the 1997 PM 2.5 federal standards. EPA designations for the

2006 PM 2.5 standards will be finalized in December 2009. The District has determined, as of the 2004-06 PM 2.5 data, that the Valley has attained the 1997 24-Hour PM 2.5 standard. eOn April 30, 2007 the Governing Board of the San Joaquin Valley Air Pollution Control District voted to

request EPA to reclassify the San Joaquin Valley Air Basin as extreme nonattainment for the federal 8-hour ozone standards. The Califonria Air Resources Board, on June 14, 2007, approved this request. This request must be forwarded to EPA by the California Air Resources Board and would become effective upon EPA final rulemakng after a notice and comment process; it is not yet in effect. fEffective June 15, 2006, the U.S. Environmental Protection Agency (EPA) revoked in the federal 1-hour ozone standard, including associated designations and classifications. However, EPA had previously classified the SJVAB as extreme nonattainment for this standard. Many applicable requirements for extreme 1-hour ozone nonattainment areas continue to apply to the SJVAB.

Source: SJVAPCD, 2008

Suspended Particulate Matter

Health concerns associated with suspended particulate matter focus on those particles small enough to reach the lungs when inhaled. Few particles larger than 10 microns in diameter reach the lungs. Consequently, both the federal and state air quality standards for particulate matter apply to particulate matter 10 microns or less in diameter (PM10).


Particulate matter is known to bypass the body’s defense mechanisms and becomes deeply embedded in the lung, and also can disrupt cellular processes. Research has demonstrated a strong linkage between elevated particulate levels and premature deaths, hospital admissions, emergency room visits, and asthma attacks. Particle pollution may significantly reduce lung function growth in children. The state PM10 standards are 50 micrograms per cubic meter (ug/m3) as a 24-hour average and 20 ug/m3 as an annual geometric mean. The federal PM10 standard is 150 ug/ m3 as a 24-hour average. PM10 conditions in San Joaquin County are a result of a mix of rural and urban sources, including agricultural activities, industrial emissions, dust suspended by vehicle traffic, and secondary aerosols formed by reactions in the atmosphere. As noted in Table 4-2, PM10 standards are regularly exceeded within the SJVAB, which is considered “non-attainment” for this pollutant. A federal standard for particulate matter less than 2.5 microns in diameter (PM2.5) was issued in July 1997 by the EPA. PM2.5 is sometimes referred to as "fine particulate matter". The PM2.5 standard has been set at a concentration of 15 ug/m3 annually and 35 ug/m3 daily. Table 4-3 shows the 2004 Emissions Inventory for San Joaquin County by source. The vast majority of particulate matter (85% of PM10) is generated from miscellaneous processes, which are made up primarily of agriculture, road dust, fugitive dust from other sources, and waste disposal, among others. Of these sources, agriculture accounts for 38% of PM10 emissions, while road dust accounts for an additional 27%. About 10% of the PM10 generated by miscellaneous processes is fugitive windblown dust from other sources.

Carbon Monoxide

Carbon monoxide (CO) is an odorless, colorless, gas. CO causes a number of health problems including fatigue, headache, confusion, and dizziness. Since CO binds strongly to hemoglobin and reduces the blood’s capacity for carrying oxygen to the heart, brain and other parts of the body. High concentrations of CO can cause heart difficulties for people with chronic diseases. It can impair mental abilities and in some cases can result in death (Table 4-1). The incomplete combustion of petroleum fuels in on-road vehicles is a major cause of CO. CO is also produced during the winter from wood stoves and fireplaces that are not burning efficiently. CO tends to dissipate rapidly into the atmosphere, but increased CO levels may occur in the winter when temperature inversions trap pollutants near the ground and concentrate the CO.


TABLE 4-3 ESTIMATED ANNUAL AVERAGE EMISSIONS FOR SAN JOAQUIN COUNTY

AND THE SJVAB (2008)

Emissions (tons/day)

ROG NOx CO PM10 PM2.5 Source Category SJC

1 AB

2 SJC AB SJC AB SJC AB SJC AB

Fuel Combustion

0.5 11.1 6.7 57.9 4.1 36.3 0.5 6.9 0.4 6.7

Waste Disposal

0.1 2.6 0.1 0.2 0.1 0.5 0.0 0.1 0.0 0.1

Cleaning and Surface Coatings

2.3 15.3 0.0 0.0 0.0 0.0 0.1 0.1 0.1 0.1

Petroleum Production and Marketing

1.4 36.1 0.0 0.4 0.0 1.1 0.0 0.2 0.0 0.1

Industrial Processes

3.4 18.6 3.8 21.4 0.7 4.0 2.1 17.8 1.1 10.4

Total Stationary Sources

7.5 83.7 10.6 80.0 4.9 41.8 2.6 25.1 1.6 17.5

Solvent Evaporation

7.8 58.9 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Miscellaneous Processes

7.3 90.6 1.7 17.9 22.0 268.4 26.4 250.9 6.5 67.7

Total Area-Wide Sources

15.1 149.5 1.7 17.9 22.0 268.4 26.4 250.9 6.5 67.7

On-Road Vehicles

12.3 79.2 40.3 330.0 116.8 705.6 1.9 14.6 1.5 11.8

Other Mobile 12.1 56.9 38.4 138.2 79 336.5 2.0 9.1 1.8 8.3

Total Mobile Sources

24.4 136.1 78.7 468.2 195.7 1042.1 3.9 23.7 3.3 20.2

Subtotal w/o Natural Sources

47.0 369.2 91.0 566.1 222.7 1352.2 32.9 299.7 11.3 105.3

Natural Sources

8.2 235.2 0.0 10.6 0.2 347.5 0.0 35.2 0.0 29.8

1 San Joaquin County

2 Air Basin

Totals may not be exact due to rounding.

Source: ARB Almanac Emission Projection Data, 2008


However, since CO is somewhat soluble in water, normal winter conditions of rainfall and fog can suppress CO concentrations

Toxic Air Contaminants

California Health and Safety Code Section 39655 defines toxic air contaminants (TACs), or “air toxics,” as “air pollutant(s) which may cause or contribute to an increase in mortality or in serious illness, or which may pose a present or potential hazard to human health.” Examples of toxic air contaminants include benzene, which is found in gasoline; perchlorethlyene, which is emitted from some dry cleaning facilities; and methylene chloride, which is used as a solvent and paint stripper by a number of industries. Other listed air toxics include dioxin, asbestos, toluene, and metals such as cadmium, mercury, chromium, and lead compounds. The State’s Air Toxics Inventory (2008) includes more than 250 substances. TACs cause or may cause cancer or other serious health effects, such as chronic eye, lung or skin irritation, reproductive effects or birth defects, neurological and reproductive disorders, or adverse environmental and ecological effects. The top five air toxics emitted in San Joaquin County include (California Air Resources Board, 2009):

Diesel PM 993 tons/year Formaldehyde 565 tons/year Acetaldehyde 258 tons/year Benzene 227 tons/year Perchloroethylene 117 tons/year

The risk of exposure to air toxic pollution varies by community and location within the community. Communities are exposed to the ambient concentration of air toxics in the region or subregion, which is the result of all air toxic emissions, including diesel PM. Localized areas within the community may be subject to increased exposure based on location near to major diesel PM emitters, such as freeways or rail yards, or near industrial sources of air toxics (ARB, 2005). In its April 2005 Air Quality and Land Use Handbook, the ARB established preliminary risk-based advisory recommendations for siting of new sensitive land uses near major air pollution sources. Of the potential pollution sources considered in the Handbook, which included distribution centers, rail yards, ports, refineries, chrome platers and dry cleaners, only “freeways” are located in the Project vicinity. The Handbook noted that health risks are higher within 1,000 feet of freeways and that the highest non-cancer health risks were seen within about 300 feet of the freeway; pollutant levels were shown to drop off substantially more than 500 feet from the freeway. Among the recommendations of the Handbook was “Avoid siting new sensitive land uses within 500 feet of a freeway, urban roads with 100,000 vehicles/day, or rural roads with 50,000 vehicles/day.” The ARB has developed a diesel PM Risk Reduction Plan composed of new programs and standards, which is being implemented. The Risk Reduction Plan includes


establishment of new emission standards for new diesel engines, retrofit programs for existing engines, programs that facilitate conversion to reduced-emission diesel equipment, and limitations on sulfur content in fuel, among others. Over time, the ARB projects that the Risk Reduction Plan will generate overall reductions of 85% in diesel PM by 2020, with additional reductions expected in the longer term. These reductions, in turn, will result in reductions of associated cancer risks. Major stationary (i.e. industrial) sources of air toxics are required to prepare risk assessments for the review and approval of the local air district. Cancer risks that exceed 10 per million persons, or non-carcinogenic TACs that generate a Hazard Index greater than 1, are defined by the State as “significant.”

Existing Air Quality

Criteria Air Pollutants

Existing air quality is monitored regularly by the SJVAPCD and reported to the ARB. The nearest monitoring station to the Project site is the Stockton-Hazelton monitoring station, approximately 13 miles to the southeast. Air pollutant concentration data from the Stockton-Hazelton monitoring station for the three most recent years data are available (2009-2011), as well as the extent to which ambient air quality standards were exceeded, are summarized in Table 4-4. Table 4-4 indicates that the State one-hour ozone standards of 0.09 ppm have been exceeded twice at the Hazelton station in 2009 and 2010, but not at all in 2011. Likewise, both the State and federal maximum eight-hour-average ozone standards were exceeded in Stockton in 2009 and 2010, but not in 2011. The SJVAB is classified as nonattainment for the State one-hour ozone standard, as well as both the State and federal eight-hour standards (see Table 4-2). Carbon monoxide monitoring in Stockton shows that carbon monoxide levels are consistently below both the State and federal eight-hour standards. San Joaquin County is classified Unclassified/Attainment for both federal and state standards for carbon monoxide. The SJVAB as a whole regularly violates the PM10 standards. Table 4-4 shows that, in Stockton, the 24-hour average federal PM10 standard of 150 ug/m3 has not been exceeded in all three years. However, exceedence of the much-lower California PM10 standard of 50 ug/m3 occurred between one and four times in that time period. Monitoring at the Hazelton station indicates that the federal 24-hour PM2.5 standard of 35 ug/m3 was exceeded from three to eleven times from 2009 to 2011; there is no 24-hour state standard for this pollutant.


TABLE 4-4 SUMMARY OF AIR POLLUTANT DATA COMPARED TO

AMBIENT AIR QUALITY STANDARDS, 2009-2011

Pollutant

2009 2010 2011

StkH SJVAB StkH SJVAB StkH SJVAB Ozone Highest 1-hour (ppm) Days>0.09 ppm (Cal)

0.116 2

0.135 82

0.120 2

0.140 59

0.089 0

0.134 76

Highest 8-hour (ppm) Days>0.08 ppm (Fed) Days>0.07 ppm (Cal)

0.096 2 4

0.110 98

122

0.095 2 3

0.114 93

115

0.068 0 0

0.105 109 131

CO Highest 8-hour (Fed-ppm) Days>=9.5 ppm (Fed) Days>=9.0 ppm (Cal)

2.29 0 0

2.41 0 0

1.60 0 0

2.03 0 0

2.13 0 0

2.71 0 0

PM10

Daily Average Highest Value (Fed-ug/m

3)

Days>150 ug/m3 (Fed)

Highest Value (Cal-ug/m3)

Days>50 ug/m3 (Cal)

58.7 0

58.8 3

423.8 1

139.5 31

54.3 0

55.4 1

235.6 1

238.0 67

66.1 0

70.1 4

151.8 0

154.0 113

Annual Average

Cal (ug/m3)

>20 ug/m3 (Cal)

31 Yes

56 Yes

31 Yes

56 Yes

24 Yes

47 Yes

PM2.5

Daily Average

Highest Value (Fed-ug/m3)

Measured Days>35 ug/m3 (Fed)

48.4 5

195.5 66

41.0 3

107.8 46

60.0 11

80.3 58

Annual Average

Fed >15 ug/m

3? (Fed)

Cal >12 ug/m

3? (Cal)

11.3 No

13.4 No

22.5 Yes 21.2 Yes

10.9 No N/A N/A

17.9 Yes 17.2 Yes

11.3 No N/A N/A

20.4 Yes 18.1 Yes

Notes: StkH = Stockton-Hazelton SJVAB = San Joaquin Valley Air Basin ppm = parts per million ug/m

3 = micrograms per cubic meter N/A – data not available

Source: ARB -- Aerometric Data Analysis and Management System (ADAM) http://www.arb.ca.gov/adam/cgi-bin/db2www/adamtop4b.d2w/start, Accessed July 6, 2012.


The SJVAPCD maintains an inventory of criteria air pollutant emissions within the SJVAB and within San Joaquin County. The most recent inventory is summarized in Table 4-3. ROG emissions are produced primarily by stationary and area-wide sources, and mobile sources produce the majority of NOx emissions. Mobile sources are the primary source of carbon monoxide emissions in the SJVAB, but area sources produce over 80% of PM10 emissions in the basin.

Air Toxics

The ARB monitors ambient levels of various air toxic compounds at selected locations throughout California, including Stockton. These monitoring data have been compiled into on-line statewide cancer risk maps for the 2001 and 2010 years; the mapped data is expressed in terms of inhalation cancer risk per million persons. The risk maps are considered by ARB to be a “gauge of relative risk” rather than “an absolute risk determination.” As the data set and its representation on the maps are being updated, ARB indicates the maps should be considered a “working draft.” The ARB maps (ARB, 2004), the most recent maps available, indicate that the 2001 inhalation cancer risk in the Project vicinity is in the range of 100-250 cancers/million persons. Statewide, the range extends from 0-50 to more than 1,500 cancers/million. In 2001, the mapped cancer risk in downtown Stockton was mapped at 250-500. Inhalation cancer risks in highly-urbanized areas of the state, including San Francisco and Oakland, exceeded 1,000 cancers/million in 2001. Projected cancer risks for the Project area in 2010 would remain in the 100-250 range, although regionally substantial reductions in risk are projected. Cancer risks in the large cities would remain above 1,000 cancers/million but would be reduced in geographic extent.

Odors

Odors are non-health-related air quality concerns that are within the purview of the local air district. Odors are managed by the SJVAPCD primarily on a complaint basis. Odor sources located more than a mile from potential receivers are usually considered less than significant (SJVAPCD, 2002). No identifiable odor sources were identified in the vicinity of the Project site during the preparation of the EIR. The SJVAPCD was contacted about odor complaints during the preparation of the EIR. SJVAPCD records indicated three complaints related to odors in the Project vicinity were received from 2006 to the present. One concerned a fuel dispensing pump at the nearby Flying J truck stop that did not shut off; this complaint was investigated and not confirmed. Another complaint filed in 2006 alleged dust from a construction site was being blown into a recreational vehicle park. An investigation did not confirm the fugitive dust emissions. The third complaint, filed in 2011, alleged smoke and an acrid smell, and noted the presence of a road paving operation in the area. It was determined by SJVAPCD that no odors or smoke emanated from this operation; the source of the smoke may have been fires in Contra Costa County to the west (Christie, 2012).


Existing Local Air Pollution Sources

Existing air pollution sources associated with land uses on the Project site and vicinity include agriculture, an intermittent non-point source of particulate matter and off-road equipment exhaust emissions. Existing vineyard lands involve seasonal weed control and other operations, which are also a source of particulate matter. Agriculture contributes criteria pollutants to the local and regional airshed. There is no known major industry located in or in the vicinity of the Project site. The Project vicinity includes an existing Pilot Flying J truck stop. This facility includes fuel dispensing pumps, which are a potential source of air toxic emissions. The truck stop also receives visiting trucks, which emit diesel PM. These sources are similar to the potential sources of air pollutant emissions from the proposed Project. The Environmental Impacts section of this chapter discusses potential air pollutant emissions associated with the Project in detail. The SJVAPCD was consulted with respect to the potential location of major air toxics sources in the Project vicinity. In addition, ARB’s Community Health Air Pollution Information System (CHAPIS) was checked for the potential presence of air toxics sources in the Project vicinity. CHAPIS online maps identify locations of criteria pollutant and air toxics sources. No such sources were located within a mile of the Project site. The nearest known major source of air toxic emissions would be the Interstate 5 (I-5) freeway, which is located approximately one-quarter mile west of the Project site. The freeway is an existing source of diesel PM emissions from vehicle traffic. State Route 12, located south of the Project site, is another source of diesel PM emissions, mainly from truck traffic. The Flying J Truck Stop is a facility that many diesel trucks visit, and where truck engines are left idling. Therefore, this facility is another potential source of air toxic emissions. In addition, the Flying J Truck Stop contains gasoline and diesel fuel dispensing pumps. Fuel dispensing stations are air toxic sources, and emissions from these stations are subject to permitting controls under the jurisdiction of the SJVAPCD. There are other gasoline stations in the Project vicinity, including the Arco station to the southeast and the Shell station to the south.

REGULATORY FRAMEWORK

The federal and state governments are responsible for the overall regulation of air quality and for the establishment of air quality standards. Air quality standards have been established with the principal goal of protecting public health with a margin of safety. These standards generally are expressed in terms of parts per million (ppm) or micrograms per cubic meter (ug/m3). Air quality standards are established for what are termed “criteria” pollutants, which are identified below. A summary of existing federal and state air quality standards is shown in Table 4-5.


TABLE 4-5 NATIONAL AND STATE AMBIENT AIR QUALITY STANDARDS

Pollutant Averaging Time California Standards

Federal Standards

Primary

Secondary

Ozone (O3) 1 Hour

0.09 ppm (180 ug/m

3)

-- --

8 Hour 0.07 ppm

(137 ug/m3)

0.075 ppm (147 ug/m

3)

Same as Primary Standard

Respirable Particulate Matter (PM10)

24 Hour 50 ug/m3 150 ug/m

3


Annual Arithmetic Mean

20 ug/m3 -- --

Fine Particulate Matter (PM2.5)

24 Hour -- 35 ug/m3



12 ug/m3 15 ug/m

3


Carbon Monoxide (CO)

1 Hour 20.0 ppm

(23 mg/m3)

35.0 ppm (40 mg/m

3)

--

8 Hour 9.0 ppm

(10 mg/m3)

9.0 ppm (10 mg/m

3)

--

Nitrogen Dioxide (NO2) 1 Hour

0.18 ppm (339 ug/m

3)

100 ppb (188 ug/m

3)

--


0.03 ppm (57 ug/m

3)

53 ppb (100 ug/m

3)


Sulfur Dioxide (SO2)

1 Hour 0.25 ppm

(655 ug/m3)

75 ppb (196 ug/m

3)

--

3 Hour -- -- 0.5 ppm

(1,300 ug/m3)

24 Hour 0.04 ppm

(105 ug/m3)

0.14 ppm (for certain areas)

1 --


-- 0.03 ppm

(for certain areas)1 --

Lead

30 Day Average 1.5 ug/m3 -- --

Calendar Quarter -- 1.5 ug/m

3

(for certain areas)2


Rolling 3-Month Average

-- 0.15 ug/m3


Sulfates 24 Hour 25 ug/m3

No National Standards

Hydrogen Sulfide 1 Hour 0.03 ppm (42 ug/m

3)

Vinyl Chloride

24 Hour 0.01 ppm (26 ug/m

3)

Visibility Reducing Particles

8 Hour

Extinction coefficient of 0.23 per kilometer – visibility of ten miles or more (0.07-30 miles or more at Lake Tahoe) due to particles when relative humidity is <70%.

Notes: ppm – parts per million; ppb – parts per billion; mg/m3 – milligrams per cubic meter; ug/m3 – micrograms per cubic meter 1 In 2010, a new 1-hour SO2 standard was established. The 24-hour and annual standards remain in effect until one year after an area is designated for the 2010 standard. 2 In 2008, the national standard for lead was revised to a rolling 3-month average. The quarterly average standard remains in effect until one year after an area is designated for the 2008 standard. Source: California Air Resources Board, 2012


Federal Standards and Regulations

Federal air quality regulation stems from the federal Clean Air Act (CAA), as amended. The federal CAA required the U.S. Environmental Protection Agency (EPA) to establish the air quality standards for criteria pollutants, known as the National Ambient Air Quality Standards (NAAQS), as shown in Table 4-5. The CAA establishes six criteria pollutants: ozone, carbon monoxide, particulate matter, nitrogen dioxide and sulfur dioxide. The primary standards are based on EPA medical research and specific concentration thresholds derived therefrom. Secondary standards are intended to protect the public welfare from effects such as visibility reduction, soiling, nuisance, and other forms of damage. Regions of the County are classified with respect to their attainment or nonattainment of these standards. The federal CAA requires the states to submit a state implementation plan (SIP) for nonattainment areas. The SIPs are reviewed and approved by the EPA, subject to a determination of their adequacy in demonstrating how the federal standards will be achieved. The corresponding attainment/nonattainment designations for the SJVAB are presented later in this section.

State Standards and Regulations

The California Clean Air Act (CCAA) provides the planning framework for California air quality. The CCAA establishes the State’s own set of ambient air quality standards for criteria pollutants, known as the California Ambient Air Quality Standards (CAAQS). The CAAQS are generally more stringent than the corresponding NAAQS; in addition, the CAAQS cover other pollutants besides the six criteria pollutants of the federal CAA. Responsibility for implementation of the CCAA requirements, and for preparation of the State Implementation Plan under the CAA, rests with the ARB; the local air pollution or air quality management districts are responsible for preparation of the Air Quality Attainment Plan (AQAP), which are input to the SIP. No particular schedule is established for achieving attainment with the CAAQS. However, the CCAA imposes increasingly severe requirements based on the degree of nonattainment. Nonattainment is classified into the following categories: Moderate, Serious, Severe and Extreme.

Truck and Bus Rule In 2008, ARB adopted a new regulation to reduce emissions of diesel PM, NOx and other pollutants from in-use diesel trucks and buses that operate in California. This regulation is known as the Truck and Bus Rule (Title 13, California Code of Regulations Section 2025). The regulation applies to trucks and buses with a gross vehicle weight rating greater than 14,000 pounds, with some exemptions. Under the Truck and Bus Rule, starting in 2015, all affected vehicles with a gross vehicle weight rating of 26,000 pounds or less must be equipped with a 2010 model year emission equivalent engine, in accordance with a specified schedule. As defined in the


Truck and Bus Rule, the 2010 model year emission equivalent engine means emissions from:

• An engine certified to the 2004 through 2006 model year heavy-duty diesel engine emissions standard that is equipped with the highest level VDECS and reduces NOx emissions by at least 85 percent; or

• An engine that was built to the 2004 engine emission standard and was not used

in any manufacturer’s averaging, banking, or trading program that is equipped with the highest level VDECS and reduces NOx exhaust emissions by at least 85 percent; or

• An engine certified to the 2007 model year heavy-duty diesel engine emissions

standard that meets PM BACT and reduces NOx exhaust emissions by more than 70 percent; or

• An engine certified to the 2010 model year or newer heavy-duty diesel engine

emissions standard that meets PM BACT; or

• A heavy-duty engine certified to 0.2 grams per brake horsepower-hour (g/bhp-hr) or less NOx emissions level and 0.01 g/bhp-hr or less PM emissions level; or

• An off-road engine certified to the Tier 4 Final engine emissions standard.

The Verified Diesel Emission Control Strategy (VDECS) is an emissions control strategy, designed primarily for the reduction of diesel PM emissions, which has been verified pursuant to ARB’s Verification Procedure, Warranty and In-Use Compliance Requirements for In-Use Strategies to Control Emissions from Diesel Engines (Title 13, California Code of Regulations Sections 2700-2710). VDECS can be verified to achieve Level 1 diesel PM reductions (25 percent), Level 2 diesel PM reductions (50 percent), or Level 3 diesel PM reductions (85 percent). VDECS may also be verified to achieve NOx reductions. Starting in 2012, affected vehicles with a gross vehicle weight rating greater than 26,000 pounds must be equipped with a 2010 model year emission equivalent engine, and also meet particulate matter Best Available Control Technology (PM BACT) standards, according to a specified schedule. As defined in the Truck and Bus Rule, PM BACT means the technology employed on the highest level VDECS for PM or an engine that is equipped with an original equipment manufacturer diesel particulate filter and certified to meet the 0.01 g/bhp-hr certification standard. School buses must comply with PM BACT in accordance with a separate compliance schedule from other affected vehicles. Truck Idling Regulations In 2004, ARB adopted an idling airborne toxic control measure (ATCM) which consists of new engine and in-use truck requirements, and emission performance requirements for technologies used as alternatives to idling the truck's main engine (Title 13, California


Code of Regulations Section 2485). In 2005, ARB approved a regulatory measure extending the ATCM to new and in-use diesel trucks with sleeper berths, beginning in 2008. These regulations apply to diesel-fueled trucks with a gross vehicle weight rating greater than 10,000 pounds. The ARB regulations require that operators shall not idle for more than five minutes when stopped within California. The new engine requirements require 2008 and newer model year heavy-duty diesel engines to be equipped with a non-programmable engine shutdown system that automatically shuts down the engine after five minutes of idling or optionally meet a stringent oxides of nitrogen idling emission standard. The in-use truck requirements require operators of both in-state and out-of-state registered sleeper berth equipped trucks to manually shut down their engine when idling more than five minutes at any location within California. Emission producing alternative technologies such as diesel-fueled auxiliary power systems (APS) and fuel-fired heaters are also required to meet emission performance requirements that ensure emissions are not exceeding the emissions of a truck engine operating at idle. Specifically, the regulation requires diesel APSs installed on trucks with 2007 and newer engines to control PM emissions by either routing the APS exhaust through the PM trap of the truck engine or by retrofitting the diesel APS with a verified level 3 PM control device that reduces PM emissions by at least 85 percent. Fuel-fired heaters installed on trucks with 2007 and newer engines are also required to meet the Ultra Low Emission Vehicle requirements specified in ARB’s Low Emission Vehicle (LEV) regulations. These requirements are effective beginning in 2008. For trucks equipped with 2006 and older engines, any California or federally certified diesel-fueled APS or fuel-fired heater may be used. The idling restrictions do not apply to trucks that are equipped with a primary diesel engine meeting the optional NOx idling emission standard. As set forth in Title 13, California Code of Regulations Section 1956.8(a)(6)(C), the optional NOx idling emission standard for heavy-duty diesel engines is 30 grams per hour. The engine must have a label meeting requirements pursuant to Section 35.B.4 of the “California Exhaust Emissions Standards and Test Procedures for 2004 and Subsequent Model Heavy-Duty Diesel Engines and Vehicles,” as incorporated by reference in Title 13, California Code of Regulations Section 1956.8(b). In any case, idling is prohibited within 100 feet of a residential area. Most of the trucks manufactured since 2008 meet this idling standard. Trucks older than 2008, as well as operators of newer trucks that choose to do so, must deploy idling reduction technologies that can heat/cool/power the truck cab without running the main engine (Mike Tunnell, pers. comm.).

Air Toxics

Air toxics are "toxic air contaminants" (TACs), which are defined by California Health and Safety Code Section 39655 as “air pollutant(s) which may cause or contribute to an increase in mortality or in serious illness, or which may pose a present or potential hazard to human health.” State TACs also include federally listed air toxics.


The State’s Air Toxics Inventory (2008) includes more than 250 substances considered TACs. They include such substances as volatile organic compounds (VOCs), chlorinated hydrocarbons, asbestos, dioxin, toluene, gasoline engine exhaust, particulate matter emitted by diesel engines, and metals such as cadmium, mercury, chromium, and lead compounds, among many others. Other examples include benzene, which is found in gasoline; perchlorethlyene, which is emitted from some dry cleaning facilities; and methylene chloride, which is used as a solvent and paint stripper by a number of industries. The State regulates TACs primarily through the Tanner Air Toxics Act (AB 1807) and the Air Toxics Hot Spots Information and Assessment Act of 1987 (AB 2588). Under these programs, the State is responsible for an inventory of TACs, for analysis of exposure and risk and for planning to reduce risk. Like other federal and state air quality requirements, the various elements of the state air toxics program are implemented by the local air districts. The ARB has published an Air Quality and Land Use Handbook that addresses air toxics risk, with advisory siting recommendations for air-pollutant-sensitive land uses. The scope of this handbook includes a range of major potential TAC sources, including freeways, distribution centers, rail yards, ports, refineries, chrome plating facilities, certain dry cleaners and gas stations.

San Joaquin Valley Air Pollution Control District

The San Joaquin Valley Air Pollution Control District (SJVAPCD) is responsible for air quality management in San Joaquin County as well as the other seven counties that make up the District. The District’s responsibilities include air quality standard attainment planning, regulation of emissions from non-transportation sources, and mitigation of emissions from on-road sources. Local air districts, including the SJVAPCD, are charged to reduce pollutant concentrations for which the district is nonattainment by 5% per year. The local air district is also required to prepare an AQAP if the district exceeds the state air quality standards for ozone, carbon monoxide, nitrogen dioxide or sulfur dioxide; no AQAP is required for particulate nonattainment. The local AQAP is required to address locally generated air pollutant emissions. “Upwind” air districts are required to establish control programs that address pollutant transport to downwind districts. The SJVAPCD has adopted an AQAP only for ozone nonattainment, which describes the actions the District will take to work toward ozone attainment. Among these provisions is the District’s adopted Indirect Source Rule (SJVAPCD Rule 9510), which requires reductions in air pollutant emissions associated with land development, either directly or through payment of a fee that is used to implement other ozone precursor reductions. Rule 9510 is described in more detail below.


The SJVAPCD has adopted required attainment plans for ozone and PM2.5 and maintenance plans for attainment pollutants. The status of SJVAPCD attainment planning is summarized below.

Ozone. In 2010, EPA approved the 2004 Extreme Ozone Demonstration Plan for attainment of the federal one-hour ozone standard. In 2007, ARB approved the 2007 Ozone Plan for attainment of the State eight-hour ozone standard.

Particulate Matter (PM10). The SJVAPCD is in attainment of the federal standards for PM10. A PM10 Maintenance Plan was approved by EPA in 2008. Particulate Matter (PM2.5). In 2008, the SJVAPCD adopted the 2008 PM2.5 Plan for attainment of the federal PM2.5 standard in effect at that time. In response to a subsequent change to the federal PM2.5 standard, the SJVAPCD is currently developing a PM2.5 Plan that is due for submittal to EPA by December 14, 2012. Carbon Monoxide. The SJVAPCD is in attainment for carbon monoxide. In 1998, EPA approved the Carbon Monoxide Maintenance Plan for the State of California. Amendments to this plan were approved by ARB in 2004.

SJVAPCD has adopted several regulations that are directly applicable to land development. These include regulations that limit dust generation, installation of wood-burning appliances, hydrocarbon emissions from paving activities, and volatile organic emissions from architectural coatings. These regulations are summarized below.

Regulation VIII (Fugitive Dust PM10 Prohibitions) Includes Rules 8011-8081 which are designed to reduce PM10 emissions (predominantly dust) generated by construction and demolition activities, among other potential sources. Rule 8021 applies specifically to construction, demolition and earthmoving. The rules that make up Regulation VIII require compliance with the District’s 20% opacity standard. Based on the size of the Project, a Dust Control Plan must be submitted to the SJVAPCD in advance of construction. Rule 2201 (New and Modified Stationary Source Review Rule) New stationary sources and modifications of existing stationary sources that may emit criteria pollutants must obtain an Authority to Construct and Permit to Operate the proposed facility. Emissions that exceed impact thresholds must include emission controls and may require additional mitigation. Rule 4101 (Visible Emissions) Rule 4101 prohibits emissions of visible air contaminants to the atmosphere and applies to any source operation that emits or may emit air contaminants. Rule 4102 (Nuisance) Rule 4102 dictates that if a source operation emits or may emit air contaminants or other materials such that the emissions create a public nuisance, the owner/operator may be subject to SJVAPCD enforcement action.


Rule 4103 (Open Burning) Rule 4103 prohibits the burning of agricultural material when the land is converting from agriculture to non-agricultural (i.e. urban) purposes. Rule 4601 (Architectural Coatings) Rule 4601 limits emissions of volatile organic compounds from architectural coatings by specifying storage, clean up and labeling requirements. Rule 4641 (Cutback, Slow Cure, and Emulsified Asphalt, Paving and Maintenance Operations) Rule 4641 applies to the manufacture and application of the specified asphalt types for paving and maintenance operations. Rule 9510 (Indirect Source Review) Rule 9510, also known as the Indirect Source Rule (ISR), took effect March 1, 2006. The purpose of Rule 9510 is to reduce emissions of NOx and PM10 from new development in San Joaquin County, including both construction and operational emissions. This rule requires specific percentage reductions in estimated project emissions for both construction and operation, or the payment of off-site mitigation fees if the required reductions cannot be met on the project site. The rule applies to development projects that include:

• 50 residential units, • 2,000 square feet (SF) of commercial space, • 25,000 SF of industrial space, • 20,000 SF of medical office space, • 39,000 SF of general office space, • 9,000 SF of educational space, 10,000 SF of government space, • 20,000 SF of recreational space, or • 9,000 SF of uncategorized space.

Based on the above criteria, the Project would be subject to Rule 9510. The ISR Rule (Rule 9510) and the Administrative ISR Fee Rule (Rule 3180) are the result of state requirements outlined in the California Health and Safety Code, Section 40604 and the State Implementation Plan (SIP). The SJVAPCD’s SIP commitments are contained in the District’s 2003 PM10 Plan and Extreme Ozone Attainment Demonstration Plan (Plans), which identify the need to reduce PM10 and NOx in order to reach the ambient air-pollution standards on schedule. The Plans identify growth and reductions in multiple source categories. The Plans quantify the reduction from current SJVAPCD rules and proposed rules, as well as state and federal regulations, and then model future emissions to determine if the SJVAPCD may reach attainment for applicable pollutants. The ISR rule looks to reduce the growth in NOx and PM10 emissions associated with the construction and operation of new development projects in the San Joaquin Valley. The rule requirement is to reduce construction NOx and PM10 emissions by 20% and 45%, respectively, as well as reducing operational NOx and PM10 emissions by 33.3% and 50%, respectively, when compared to unmitigated


projects. A project’s emissions can be reduced by incorporating SJVAPCD approved mitigation measures. These include, but are not limited to, the following: • Bicycle lanes throughout the project • Proximity to existing or planned bus stops • Proximity to existing or planned local retail • Eliminate woodstoves and fireplaces from the project • Cleaner fleet construction vehicles • Energy efficiency beyond Title 24 requirements Under Rule 9510, an Off-Site Emission Reduction Fee (Off-Site Fee) shall be paid by the applicant to the SJVAPCD for any emission reductions required by the rule that are not achieved through on-site emission reduction measures. Any necessary Off-Site Fee for a project is calculated based on information contained in the SJVAPCD’s Off-site Emissions Estimator Worksheet and Fee Estimator Worksheet. The Off-site Emissions Estimator Worksheet uses the project’s total tons of NOx and PM10 as calculated using California Emissions Estimator Model (CalEEMod) and compares the unmitigated emissions against the mitigated emissions, determining whether the reduction in emissions is sufficient to satisfy the rule. If the reduction is not sufficient, the required off-site emission reductions are calculated using the District’s off-site emission reduction equations set forth in Rule 9510, section 7.0. Fee Estimator is an Excel worksheet used to calculate the total dollar amount of off-site fees that must be paid to the District in order to cover the District’s cost of obtaining the required off-site emission reductions, and therefore fulfill the rule requirement. This fee amount is derived by multiplying the total tons of off-site reductions by the applicable rate. As of 2008, the applicable rates are as follows:

Cost of NOx Reductions ($/ton) $9,350.00 Cost of PM10 Reductions ($/ton) $9,011.00

The monies collected from the Off-Site Fee are used by the SJVAPCD to reduce emissions in the San Joaquin Valley on behalf of the project, with the goal of offsetting the emissions increase from the project by decreasing emissions elsewhere. More specifically, the fees received by the SJVAPCD are used in the SJVAPCD’s existing Emission Reduction Incentive Program (ERIP) to fund emission reduction projects.

The SJVAPCD regulates the construction and improvement of facilities with potential air toxic emissions, including gas stations. Toxic substances in gasoline include benzene, toluene and naphthalene, among others. Rules applicable to gas stations include:

Rule 4621 Gasoline Transfer into Stationary Storage Containers, Delivery Vessels and Bulk Plants Rule 4621 prohibits the transfer of gasoline from a delivery vessel into a stationary storage container unless the container is equipped with an ARB-certified


permanent submerged fill pipe and ARB certified pressure-vacuum relief valve, and utilizes an ARB-certified Phase I vapor recovery system. Rule 4622 Transfer of Gasoline into Vehicle Fuel Tanks Rule 4622 prohibits the transfer of gasoline from a stationary storage container into a motor vehicle fuel tank with a capacity greater than 5 gallons, unless the gasoline dispensing unit used to transfer the gasoline is equipped with and has in operation an ARB-certified Phase II vapor recovery system.

Gas station applications are reviewed under Rule 2201 - New and Modified Stationary Source Review for compliance with SJVAPCD rules, including the above. SJVAPCD review of these applications includes consideration of proposed vapor recovery equipment and whether the controlled VOC emissions require offsets or trigger public notice requirements.

San Joaquin County

San Joaquin County has no direct responsibility for air quality standards or regulation. However, the County may indirectly influence air quality through land use planning and other decision-making. Development projects must be consistent with the goals and policies of the San Joaquin County General Plan, including those related to air quality. Air quality is addressed by the County General Plan in the following policy statements in the Resources Element:

• San Joaquin County shall meet and maintain all State and national standards for air quality.

• Motor vehicle emissions shall be minimized through land use and transportation strategies, as well as by promotion of alternative fuels.

• Projects shall be designed to minimize concentrations of carbon monoxide (hot spots).

• Air quality hazards from pesticides shall be minimized.

• The elimination of chlorofluorocarbons shall be supported. The County is currently in the process of updating its General Plan. It is expected that the updated General Plan will include new or revised policies related to air quality. At this time, no draft General Plan has yet been released for public review.

ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES

The following impact analysis is based largely on the on the methodology defined in the SJVAPCD’s Guide for Assessing and Mitigating Air Quality Impacts (GAMAQI). The


analysis includes consideration of both project construction and long-term operation effects on criteria pollutants and air toxics. Please refer to Chapter 6.0, Cumulative Impacts, for an analysis of air quality impacts under Cumulative conditions.

Significance Thresholds

Based on criteria derived from Appendix G of the CEQA Guidelines, a project may have a significant effect on air quality if it would:

• Conflict with or obstruct implementation of an applicable Air Quality Attainment Plan.

• Violate any air quality standard, or contribute substantially to an existing or

projected air quality violation.

• Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard, including releasing emissions which exceed quantitative thresholds for ozone precursors.

• Expose sensitive receptors to substantial pollutant concentrations.

• Create objectionable odors affecting a substantial number of people.

GAMAQI defines certain thresholds of significance for the assessment of air quality impacts. Based on GAMAQI, the proposed Project will be considered to have a significant impact on ozone precursor emissions if it would generate more than 10 tons per year of either ROG or NOx. Based on input from SJVAPCD staff, the Project will be considered to have a significant effect on particulate matter emissions if it would generate more than 15 tons per year. The Project’s impact on carbon monoxide emissions would be considered significant if the Project would:

• Degrade operation of an intersection to level of service (LOS) E or F, or substantially worsen an intersection already operating at LOS F, and

• The Transportation Project-Level Carbon Monoxide Protocol, or CALINE4 modeling, indicate that CO standards would be exceeded adjacent to an impacted intersection.

Based on GAMAQI, air toxics exposure effects are considered significant if they would result in:

• Lifetime cancer risk for sensitive land uses (including residential) exceeding 10 in one million.


• Ground-level concentrations of non-carcinogenic toxic air contaminants that would result in a Hazard Index greater than one (1).

If the Project would be located in an area of substantial odor complaints, or would result in a sensitive odor receptor being located within a mile of an undesirable odor generator, the impact on odors may be considered significant.

Impact 4.1 – Consistency with Air Quality Attainment Plans The Project site is within the jurisdiction of the SJVAPCD. As discussed in the Environmental Setting section, several Air Quality Attainment Plans apply to the SJVAPCD. These include the 2004 Extreme Ozone Demonstration Plan and the 2007 Ozone Plan. The 2008 PM2.5 Plan is another adopted AQAP, but this plan is currently being updated in response to a change to the federal PM2.5 standard. The SJVAPCD is also subject to the PM10 Maintenance Plan and the Carbon Monoxide Maintenance Plan. The primary strategy to implement the reduction objectives of these AQAPs is the approval of rules and regulations for stationary sources of emissions, along with incentive programs to encourage mobile sources to use cleaner burning engines. The Project would comply with all SJVAPCD rules and regulations. The primary mobile sources would be vehicle traffic, the emissions from which are regulated by ARB. ARB has already implemented regulations designed to reduce emissions from mobile sources, especially trucks, as described in the Regulatory Framework. Therefore, it is expected that the Project would be in compliance with the objectives of the applicable AQAPs. Impacts would be less than significant.

Level of Significance: Less than significant Mitigation Measures: None required

Impact 4.2 - Impacts of Project Construction on Air Quality

Approval of the Project would result in new construction activity. Construction activities would generate emissions of ozone precursors and particulate matter from heavy equipment operations, as well as particulate matter emissions generated by land clearing, earth moving, and wind erosion. As noted in GAMAQI, construction activities such as grading, excavation and travel on unpaved surfaces can generate substantial amounts of dust, and can lead to elevated concentrations of PM10. These potential emissions were quantified using the computer modeling program called the California Emissions Estimator Model (CalEEMod). Beginning July 1, 2012, the SJVAPCD requires the use of CalEEMod in CEQA evaluations of air quality impacts. CalEEMod bases its calculations on land uses, as did the URBEMIS program previously approved for use. Unlike URBEMIS, CalEEMod also calculates emissions generated by electricity use, water and wastewater demand, and solid waste generation.


For this analysis, the latest version of CalEEMod available at the time of EIR preparation was used (Version 2011.1.1). The CalEEMod run assumed that construction activities would occur within one calendar year. The evaluation included five types of construction activity: site preparation, grading, building construction, paving and coating. Default construction equipment assumptions were used in this estimate, as specific information on construction equipment to be used in Project construction is not available. CalEEMod construction equipment default information is based on a survey of construction sites grouped by construction phase and lot acreage that was performed by the South Coast Air Quality Management District. The CalEEMod run also assumed no application of regulations or other measures that would mitigate construction emissions. In actuality, Project construction would comply with SJVAPCD regulations that would reduce specific emissions, such as Regulation VIII (Fugitive Dust Rule), Rule 4101 (Visible Emissions), Rule 4601 (Architectural Coatings). Table 4-6 shows the results of the CalEEMod run for Project construction emissions. Appendix B of this EIR presents the CalEEMod run in detail. PM2.5 emissions, which are a subset of PM10 emissions, are presented separately.

TABLE 4-6 PROJECT EMISSIONS FROM CONSTRUCTION ACTIVITIES

Emissions (tons per construction period)

ROG NOx CO SO2 PM10 Dust

PM10 Exhaust PM2.5

Construction emissions 0.22 1.25 0.74 0.00 0.00 0.09 0.09

SJVAPCD Thresholds (tons/year) 10 10 -- -- 15* 15* --

Exceeds threshold? No No -- -- No No --

Construction emissions after ISR compliance

N/A 1.00 N/A N/A N/A 0.05 N/A

Construction period assumed to be within one calendar year.

* Threshold applies to total PM10 emissions

Source: CalEEMod (see Appendix B of EIR)

Although Project construction emissions do not have significance thresholds established in GAMAQI, total construction emissions were compared with the GAMAQI significance thresholds for Project operations. As indicated by Table 4-6, Project construction emissions would not exceed operational significance thresholds. According to GAMAQI, the SJVAPCD has determined that implementation and enforcement of dust control measures specified in SJVAPCD Regulation VIII - Fugitive PM10 Prohibitions would reduce construction dust impacts to a less than significant level. SJVAPCD Regulation VIII includes Rules 8011-8081, which require implementation of dust control measures to limit Visible Dust Emissions (VDE) as defined to 20% opacity or less during all phases of construction. During construction, the contractor would implement the following dust control practices identified in Tables 6-2 and 6-3 of the Guide for Assessing and Mitigating Air Quality Impacts (SJVAPCD, 2002):


a. All disturbed areas, including storage piles, which are not being actively utilized for construction purposes, shall be effectively stabilized of dust emissions using water, chemical stabilizer/suppressant, or vegetative ground cover.

b. All on-site unpaved roads and off-site unpaved access roads shall be

effectively stabilized of dust emissions using water or chemical stabilizer/suppressant.

c. All land clearing, grubbing, scraping, excavation, land leveling, grading, cut

and fill, and demolition activities shall be effectively controlled of fugitive dust emissions utilizing application of water or by presoaking.

d. When materials are transported off-site, all material shall be covered,

effectively wetted to limit visible dust emissions, or at least six inches of freeboard space from the top of the container shall be maintained.

e. All operations shall limit or expeditiously remove the accumulation of mud

or dirt from adjacent public streets at least once every 24 hours when operations are occurring. The use of dry rotary brushes is expressly prohibited except where preceded or accompanied by sufficient wetting to limit the visible dust emissions. Use of blower devices is expressly forbidden.

f. Following the addition of materials to, or the removal of materials from, the

surface of outdoor storage piles, said piles shall be effectively stabilized of fugitive dust emissions utilizing sufficient water or chemical stabilizer/suppressant.

g. Within urban areas, trackout shall be immediately removed when it extends

50 or more feet from the site and at the end of each workday. h. Limit traffic speeds on unpaved roads to 15 mph; and i. Install sandbags or other erosion control measures to prevent silt runoff to

public roadways from sites with a slope greater than one percent. For projects subject to SJVAPCD Rule 9510, the Indirect Source Rule (ISR), NOx and PM exhaust emissions from construction equipment greater than 50 horsepower require mitigation. The ISR requires a 20% reduction in NOx emissions and a 45% reduction in particulate emissions from construction equipment exhaust. Since the Project meets the criteria for the application of the Indirect Source Rule, it would be required to obtain this permit, as summarized below. Table 4-6 shows NOx and PM exhaust construction emissions with ISR compliance. Prior to the issuance of building permits, the ODS would submit an application to the SJVAPCD for a permit under Rule 9510 - Indirect Source Rule (ISR). The ODS would submit an air impact assessment (AIA) providing the quantified NOx and PM emissions


associated with Project construction. The ODS also would incorporate permit conditions identified by SJVAPCD into the Project to reduce the NOx and PM emissions associated with Project construction by at least 20% and 45% respectively from the statewide average, as estimated by ARB for NOx and PM emissions associated with construction equipment greater than 50 horsepower. These reduction requirements shall be met through any combination of on-site emission reduction measures or off-site fees.

• An applicant may reduce construction emissions on-site by using less polluting

construction equipment, which can be achieved by utilizing add-on controls, cleaner fuels, or newer lower emitting equipment.

• Additional strategies for reducing construction emissions may include, but are not limited to:

� providing commercial electric power to the Project site in adequate capacity to avoid or minimize the use of portable electric generators and the equipment;

� substitution of electric-powered equipment for diesel engine–driven equipment; and

� limiting the hours of operation of heavy duty equipment and/or the amount of equipment in use at any one time.

The requirements listed above can be met through any combination of on-site emission reduction measures or off-site fees. As discussed in the Regulatory Framework section, the ISR rule provides a method of calculating fee payments for measures to offset any NOX and PM10 emission reductions that would not be achieved by selection of construction equipment and fuels. If necessary, to offset any excess NOx and PM emissions not reduced by on-site measures, the applicant shall pay a monetary sum to SJVAPCD as calculated under Rule 9510. Overall Project construction emissions would be less than significant. The Project commitments described above, which comply with SJVAPCD rules, would further reduce this impact.

Level of Significance: Less than significant Mitigation Measures: None required.


Impact 4.3 - Impacts of Project Operations on Air Quality

Project Operations Upon completion of Project construction, the operations of the proposed land uses would result in additional emissions of criteria pollutants. These emissions would result from emissions generated by on-site equipment, heating and air conditioning appliances, and other (area sources), and from vehicle travel generated by these land uses (operational sources). Both sources of emissions are associated with proposed Project activities, and therefore are included in this analysis. These emissions include ROG and NOx, which combine in the presence of sunlight to form ozone. Because of this ROG and NOx are called “ozone precursors.” As a result of the SJVAB’s ozone nonattainment status, the GAMAQI includes a specific analysis scheme for ozone precursors. GAMAQI describes a three-tier approach, based on the size of the project, for determining the appropriate level of analysis for assessing a project's generation of ozone precursor emissions. The Small Project Analysis Level, which is the first tier, includes projects that are so small that quantification of ozone precursor emissions is not required. For the tier that includes the largest projects (e.g., general plan updates, large specific plans, and large general plan amendments), GAMAQI recommends use of travel demand models and the Direct Travel Impact Model. The proposed Project has been addressed within the middle tier, which includes most development projects. GAMAQI recommends use of the URBEMIS model for calculating mobile source emissions for the middle tier. However, as of July 1, 2012, SJVAPCD requires the use of CalEEMod, and this program is used for this analysis. The foundation of the impact analysis is the quantification of criteria pollutant emissions, including ozone precursors. For this analysis, CalEEMod (Version 2011.1.1) was used to provide an estimate of Project emissions. CalEEMod generates pollutant emission estimates for both area and operational sources, using project-specific information on land use and trip generation. Trip figures from the Kimley-Horn and Associates traffic analysis were used as the basis for the CalEEMod runs (see Chapter 5.0, Transportation). The CalEEMod run used the total number of new trips that would pass through the site driveways (4,532) that were estimated by the traffic analysis, discounting internal trips. The CalEEMod model was run for full buildout of the Project, which is assumed to start operations in the year 2014. The results of the CalEEMod run are presented in Table 4-7 below, with detailed information available in Appendix B of this EIR. As indicated in Table 4-7, unmitigated emissions associated with the Project (excluding truck idling) would not exceed the respective GAMAQI significance thresholds for ROG, NOx and PM10; but would exceed NOx with truck idling. The estimated emissions in Table 4-7 would be reduced by Project design features and compliance with State and SJVAPCD rules and regulations. In 2011, the California Green Building Code, or CALGREEN, became mandatory in all local jurisdictions. Several provisions in CALGREEN require the adoption of energy efficiency and water conservation measures. Such measures are also expected to reduce air pollutant


emissions from indirect sources. The actual reductions from these CALGREEN measures are not quantified in this analysis, but are mentioned here to indicate that the estimated emissions associated with project operation are likely to be less than indicated in Table 4-7.

TABLE 4-7 ESTIMATED AREA AND OPERATIONAL CRITERIA POLLUTANT EMISSIONS,

INCLUDING IDLING EMISSIONS

Emissions (tons per year)

ROG NOx PM10 PM2.5 CO SO2

Area Sources 0.03 0.00 0.00 0.00 0.00 0.00

Operational Sources 2.83 8.76 1.74 0.28 22.35 0.02

Subtotal 2.86 8.76 1.74 0.28 22.35 0.02

SJVAPCD thresholds 10 10 15 -- -- --

Exceeds thresholds? No No No -- -- --

Truck Idling 0.30 4.10 0.13 0.12 1.61 0.00

Total 3.16 12.86 1.87 0.40 23.96 0.02

Exceeds thresholds? No Yes No No No No

ISR reduction target N/A 5.84 0.87 N/A N/A N/A

Total with ISR Reduction 3.16 9.94 2.74 0.40 23.96 0.02 1 Excludes internal trips. Source: CalEEMod, EMFAC 2011 (see Appendix B of EIR)

SJVAPCD Rule 4601 requires the use of coatings containing low levels of volatile organic compounds (VOCs), which contribution to ROG emissions, for interior and exterior surfaces of commercial land uses. AB 939 requires local jurisdictions to recycle at least 50% of its solid waste stream. This is implemented at the local level with recycling programs that are part of solid waste collection services. These measures described above affect mainly emissions from area sources, which constitute a very small amount of the overall Project emissions. There are few reductions available for operational source emissions, since most of these emissions are from motor vehicles diverted from nearby I-5 and State Route 12 (SR 12). However, mobile source emission reductions can be achieved through the implementation of State regulations related to diesel engines and to truck idling. The following subsection discusses truck idling emissions. As indicated in the Environmental Setting section, the Project would be subject to the Indirect Source Rule. The ISR would require NOx and PM reductions by 33.3% and 50% reductions, respectively, from the unmitigated levels associated with the Project. These reductions may be accomplished by the Project applicant’s incorporation of mitigation measures into the Project; or by payment of the required ISR fee for any required reductions that have not been accomplished through project mitigation commitments. Currently, the ISR fees are $9,350 per ton of NOx and $9,011 per ton of


PM; for operational emissions; this fee must be paid for ten years of emissions. The SJVAPCD and the project applicants would process the application and accomplish the actual ISR calculations. The substantial reductions in NOx and PM emissions accomplished by the application of the ISR probably represent the best achievable mitigation for indirect sources. Mitigation presented below would require the Project to apply for an ISR permit. Table 4-7 above indicates the NOx and PM10 reductions that would be required under the ISR, and total emissions with ISR reductions. When the NOx operational emissions required under ISR are added to the NOx truck idling emissions, the total NOx emissions would be below the significance threshold. However, it also should be noted that most of the vehicle trips to and from the Project site are existing trips on I-5 and SR 12 that are diverted to the Project site. As shown in Table 5-1 in Chapter 5.0, Transportation, approximately 75% of the “new” Project trips are diverted linked trips, which may be considered to generate “travel NOx.” Travel NOx is not “new,” as trucks and other vehicles will either keep going on I-5 or stop at the existing truck stop, so travel will not change. That is, the new truck stop does not generate new NOx. If the diverted trips were removed, the total NOx from Project operations would be 2.19 tons per year, and total NOx emissions would be 6.29 tons per year which would be below the NOx significance threshold. As shown in Table 4-7, the Project would also result in emissions of carbon monoxide and sulfur dioxide, associated primarily with vehicle travel. The SJVAB is in attainment of both the state and federal standards for these pollutants. The Project would not result in any exceedence of the applicable standards or require additional air quality planning or enforcement. The Project would not involve a significant air quality effect with respect to regional emissions of these pollutants. An analysis of the potential for carbon monoxide hot spot impacts is provided in the discussion under Impact 4.1 below.

Truck Idling Emissions Emissions from idling trucks associated with the Project were also calculated. Emissions associated with Project operations would also include emissions from idling trucks. Kleinfelder prepared an analysis that estimated the amount of emissions idling trucks would generate. Appendix B contains a memorandum outlining the analysis, including the assumptions used. Table 4-7 shows the results of the idling emissions analysis. For purposes of this analysis, it was assumed that when a HHDDT travels through the truck stop, the vehicle would idle 5 minutes upon arriving and another 5 minutes upon leaving. Trucks remaining at the truck stop were assumed to idle another 5 minutes if the engine does not meet the 5-minute exemption for 2008 and newer models or another 8 hours if the engine does meet the exemption. Furthermore, the idling emissions estimate conservatively assumes that all 94 spaces are continually occupied and that the spaces cycle through 3 times in a day. The addition of the idling emissions indicates that NOx emissions would be above the significance threshold, while all other emissions would remain below their thresholds. Therefore, without mitigation, Project operations would result in potentially significant


impacts related to ozone due to NOx emissions, and would contribute to adverse health effects associated with ozone. While the actual contribution of Project-related emissions on regional pollutant levels cannot be quantified, medical research has identified quantifiable relationships between specific increases in ozone levels that exceed federal standards. Gent et al. (2003) linked a 50 parts per billion (ppb) 1-hour ozone level increase with a quantifiable increase of wheeze (35%) and chest tightness (47%) in children using (asthma) rescue medication; increased ozone levels resulted in shortness of breath and increased use of rescue medication. Pope et al. (2002) found that 10 microgram/cubic meter increases in PM2.5 were associated with 4%, 5% and 8% increases in “all-cause,” cardiopulmonary and lung cancer mortality; coarse particles were not linked with mortality. Kunzli et al. (2004) found a quantifiable linkage between PM 2.5 levels and arterial thickness, a measure of atherosclerosis. When operational emissions are considered together with truck idling emissions, the SJVAPCD NOx threshold would be exceeded. However, as noted in the State Standards and Regulations, California has a regulation limiting the idling time for trucks. Older trucks must use idling reduction technologies, which would be below the NOx significance threshold. Given these requirements, there are no other feasible mitigation measures that can be implemented to reduce emissions from idling trucks. Also, as noted in the Project Operations section above, the Project would be required to comply with ISR requirements for NOx reduction. With application of the NOx reduction standards specified in the ISR, Project emissions would be below the NOx significance threshold. Mitigation presented below would require the Project to comply with ISR requirements, thereby reducing NOx impacts to levels that would be less than significant.

Level of Significance: Significant (NOx), less than significant (other criteria pollutants) Mitigation Measures: 4.3-1. Prior to the issuance of building permits, the ODS shall make application to

the SJVAPCD for a permit under Rule 9510 - Indirect Source Rule (ISR). The ODS shall submit an air impact assessment (AIA) providing the quantified NOx and PM emissions associated with Project operations. The ODS shall incorporate mitigation measures identified by SJVAPCD into the Project to reduce the NOx and PM emissions associated with Project operations by at least 33.3% and 50% respectively over a period of ten years. These reduction requirements shall be met through on-site emission reduction measures. If necessary to offset any excess NOx and PM emissions not reduced by on-site measures, the applicant shall pay a monetary Off-Site Fee to SJVAPCD, as calculated under Rule 9510.

Significance After Mitigation: Less than significant. Implementation of ISR requirements would reduce the amount of NOx and PM emissions generated by Project operations below SJVAPCD significance thresholds.


Implementation: The ODS will be responsible for compliance with the ISR, including implementation of any mitigation measures and/or payment of fees. Monitoring: The SJVAPCD will be responsible for ensuring that the Project complies with the provisions of the ISR.

Impact 4.4 - Project Impacts on Carbon Monoxide Hot Spots

Potential carbon monoxide (CO) impacts are based on the traffic impact analysis prepared by Kimley-Horn and Associates, available in Appendix B of this EIR and discussed in Chapter 5.0, Transportation. The analysis considered whether Project impacts on the level of service (LOS) at three intersections considered in the traffic impact analysis would exceed the GAMAQI’s screening threshold for potentially significant Project contributions to CO concentration impact. According to GAMAQI, if a project would cause the predicted level of service at an intersection to degrade to LOS E or F, or substantially worsens traffic at intersections already predicted to function at these levels, then the project may have a potentially significant impact on CO emissions. GAMAQI significance thresholds indicate that intersections that operate at LOS E or F may involve significant concentrations of carbon monoxide, and the presence of such concentrations at intersections where sensitive receptors exist would constitute a significant environmental effect. There are three intersections; SR 12/I-5 Southbound Ramp, SR 12/I-5 Northbound Ramp, and SR 12/North Thornton Road, where a potential for CO hot spot impacts was considered for Existing Plus Approved Projects (EPAP) Plus Proposed Project conditions. Impact evaluation of the three intersections was based on traffic data described in Chapter 5.0, Transportation. Under EPAP Plus Project conditions, all three intersections would operate at LOS C or better (see Table 5-7 in Chapter 5.0). Therefore, the intersections do not meet the GAMAQI criteria for potentially significant CO impacts. Project CO impacts are considered less than significant.

Level of Significance: Less than significant Mitigation Measures: None required.

Impact 4.5 - Generation of or Exposure to Toxic Air Contaminants

The proposed Project would involve land uses that may generate substantial amounts of TACs, primarily from fuel dispensing operations and emissions from truck traffic. The SJVAPCD was contacted during the preparation of the EIR to determine whether major known air toxic sources exist in the Project vicinity. In addition, the ARB’s CHAPIS mapping system was consulted, with negative results. There are no known substantial point sources of TACs located on or in the vicinity of the Project site.


Fuel Dispensing Operations Emissions from fuel dispensing facilities would be subject to SJVAPCD regulations, specifically Rules 2201, 4621 and 4622 mentioned in the Environmental Setting above. These regulations would essentially prohibit operations unless the business can demonstrate that risks to vulnerable off-site sensitive receptors are below significance criteria. This restriction would apply whether those receptors were located within or outside of the Project site. Potential cancer risks associated with the proposed fuel dispensing station were estimated based on the methodology and tables shown in the Gasoline Service Station Industry-wide Risk Assessment Guidelines by the California Air Pollution Control Officers Association (CAPCOA). Based on tables in Appendix E of the CAPCOA document, at a distance of 1,000 meters (the maximum distance listed) from the center of the gas dispensing facility, cancer risk associated with this facility would be 0.15 cancers per million per 1,000,000 gallons of gasoline dispensed annually. This figure assumes the use of a rural dispersion coefficient, which produces a higher cancer risk value than an urban dispersion coefficient. This figure also assumes the installation of Phase I and Phase II vapor recovery systems and vent valves, as would be required for the Project under SJVAPCD Rules 4621 and 4622. Vapor recovery systems recover the gasoline vapors generated while fueling vehicles in a service station. There are no residences, schools, hospitals, care homes or other land uses in the Flag City area that are considered sensitive to prolonged exposure to air toxics. The nearest such potential receptors are residences located more than 4,000 feet to the southeast from the Project site, which is greater than the 1,000-meter (approximately 3,280 feet) limit in the CAPCOA tables. The estimated annual throughput for the Project is not available; however, a few sources indicate that high-volume stations, such as truck stops, dispense approximately 1,000,000 gallons per month, or 12,000,000 gallons annually (Maslowski, 2008). When the 0.15 cancers per million factor cited above is multiplied by 12, the resultant cancer risk to sensitive receptors is 1.8 cancers per million, which is below the GAMAQI significance threshold of 10 cancers per million. This above estimated cancer risk is considered a conservative estimate, as it uses a higher dispersion coefficient and a high throughput rate. It is likely that the proposed Project would dispense fuel at a lower rate than 1,000,000 gallons monthly. Nevertheless, this “worst case” scenario indicates that the fuel dispensing station by itself would not have a significant health risk effect on potential sensitive land uses in the vicinity. It should be noted that the cancer risk is based on a lifetime exposure (continuously, 24 hours per day, 365 days per year for 70 years), which is very unlikely to occur in reality; therefore, employees and visitors at other commercial establishments in the Project vicinity would not be exposed to a substantial cancer risk. Diesel Particulate Emissions from Truck Traffic Construction emissions of diesel PM, a state-designated air toxic generated primarily from construction equipment and vehicles, are shown as PM10 Exhaust in Table 4-6. There is no known significance threshold for construction-related diesel particulate


matter. However, construction activities are a temporary and short-term activity, and potentially significant health effects associated with diesel particulate emissions are the result of long-term exposure, as previously described. Long-term exposure would not occur with construction emissions. As a result, Project construction is considered to have a less than significant air quality effect related to diesel particulate emissions. In addition, diesel PM construction emissions fall under SJVAPVD Rule 9510, the Indirect Source Rule. The rule requires a reduction of 45% of PM10 exhaust emissions (see Table 4-6). Implementation of the Indirect Source Rule would reduce PM10 exhaust emissions, which include diesel particulate matter. Therefore, diesel PM emissions from construction emissions are not considered a significant health risk, as prolonged exposure is required for a significant health risk to occur. Project operations are expected to generate diesel particulate emissions, mainly from trucks entering and exiting the Project site. Of particular concern are diesel particulate emissions resulting from the idling of truck engines. These emissions are not captured in the CalEEMod runs for operational emissions. For emissions from idling trucks, Kleinfelder developed an estimate using the EMFAC2011 computer model. EMFAC2011, developed by ARB, includes the latest data on California’s car and truck fleets and travel activity. Travel activity data includes vehicle miles traveled, trips, and distributions of vehicle miles traveled by speed and time period. EMFAC2011 has a modular model structure to accommodate more detailed information about the truck and bus fleet. One of its modules, called EMFAC-HD, is the basis for emissions estimates for diesel trucks and buses with a gross vehicle weight rating greater than 14,000 pounds operating in California. This model is based upon the Statewide Truck and Bus Rule emissions inventory that was developed between 2007 and 2010 and approved by ARB in December 2010. The EMFAC2011 run for the Project assumed that all 94 truck stalls would be occupied by trucks staying overnight for an eight-hour period, with emissions occurring in accordance with the ARB’s idling rules. The results of the EMFAC2011 run are available in Appendix A of this document. They indicate that idling trucks on the Project site would generate 0.025 tons of diesel PM emissions per year. Although no significance thresholds have been established for diesel PM emissions, it should be noted that the estimated diesel PM emissions are substantially below the SJVAPCD threshold for PM10 emissions (15 tons per year). A commenter on the previous Initial Study for the Project submitted a health risk assessment conducted by Air Permitting Specialists related to exhaust from diesel trucks. The assessment calculated a Facility Prioritization Score based on the Air Toxics Hot Spots Information and Assessment Act, with a model provided by SJVAPCD. Based on guidelines from the California Air Pollution Control Officers Association (CAPCOA), the Facility Prioritization Score assists districts in ranking air toxics emitting facilities for purposes of risk assessment into high, intermediate, and low priority categories. As previously noted, diesel PM is considered an air toxic. A Facility Prioritization Score above 10 is considered a High priority, indicative of potentially significant impacts to public health. A score below 1 is considered a Low priority indicates minimal impacts to public health. Scores in between are considered Medium priority and require further evaluation.


The Air Permitting Specialists assessment concluded that the Project would generate a Medium priority score or higher within 500 meters (1,640 feet) of the Project site. However, as previously noted, there are no residences or any other sensitive land uses within 1,000 meters of the Project site. The assessment concluded that it was unlikely that emissions of any toxic air pollutants would lead to excess public health risks (Air Permitting Specialists, 2011). Therefore, diesel particulate emissions, both from idling trucks and from fuel dispensing operations, would not have a significant impact on public health. The conclusions of the Air Permitting Specialists study were confirmed by Kleinfelder’s separate analysis of potential health risk associated with Project diesel emissions. This analysis is available in Appendix B of this document. The Kleinfelder analysis used the CAPCOA screening formula to calculate a Risk Score that indicates the potential cancer risk from emissions of potentially carcinogenic compounds. For persons exposed continuously for 70 years to the emissions being evaluated, a Risk Score of 10 or more indicates a potential cancer risk greater than a 10 x 10-6 threshold, which is the State’s Proposition 65 threshold. The Risk Score does not mean that the facility will expose persons to risks as large as indicated by the Score, but that a more refined analysis is required. For diesel exhaust emissions of 0.025 tons per year, as estimated for the Project, the Risk Score for receptors within 100 meters of the source that are continuously exposed for 70 years is 25.5. However, that score is based on continuous 70-year exposure; also, as previously noted, there are no residences within 100 meters of the proposed truck stop. The only persons located that close to the proposed project are workers or the occasional visitor. For workers, CAPCOA and other agencies have published a worker adjustment factor of 0.15 to account for the fact that workers do not work 24 hours per day and do not work for 70 years. When the worker adjustment factor is applied to the score, the Risk Score decreases to 3.8, which is less than the significance threshold of 10. Based on this analysis and the Air Permitting Specialists study, diesel PM emissions from the Project would not present a significant health risk.


Impact 4.6 - Odor Impacts

No significant odor sources or sources of odor complaints were identified in the Project vicinity, based on information provided by SJVAPCD. Three odor complaints were received from 2006 to the present; none of these complaints were confirmed. The proposed Project may result in the development of new odor sources of concern, primarily truck traffic and odors from fuel dispensing facilities. However, as noted above that have been no confirmed odor complaints from existing land uses, which include a truck stop similar to the proposed Project. Activities at the proposed fast-food restaurant may result in food service-related odors, but these would not be considered adverse odor effects.


Land uses sensitive to odor generation include residences, schools, hospitals and care homes. No such land uses are located in the vicinity of the Project site; therefore, no land uses sensitive to odors would be affected by the Project. Odors may be generated from Project construction, mainly exhaust from construction equipment. However, construction time would be limited, and odors from construction activities would cease once work is completed. Overall, odor impacts are considered less than significant.



5.0 TRANSPORTATION

INTRODUCTION

This chapter assesses the potential transportation impacts associated with the proposed Project, including roadway traffic, transit, and bicycle and pedestrian systems. Information in this chapter is based on an updated traffic impact analysis prepared by Kimley-Horn and Associates in June 2012, shown in Appendix B of this EIR. The following text is primarily excerpted from that analysis. Kimley-Horn and Associates originally prepared an analysis of Project traffic impacts for and under contract to the San Joaquin County Department of Public Works in January 2011, with funding provided by the project applicant. The results of this analysis were noted in the Initial Study for the Project adopted by the County in May 2011. The traffic study was reviewed and approved by the Department of Public Works. Following adoption of the Initial Study, the County received memoranda critiquing the Kimley-Horn analysis from Wood Rodgers, an engineering and planning consulting firm. In the first memorandum, Wood Rodgers expressed concerns about the trip generation rates used in the analysis, along with assumptions regarding internalized and diverted-link trips, project truck trips, trip distribution, and facilities analyzed. After a response by Kimley-Horn, Wood Rodgers sent a second memorandum continuing to question the assumptions used in the traffic study. With the decision to prepare an EIR for the Project, Kimley-Horn updated its original analysis, using 2012 baseline/existing traffic data and providing more detailed explanation of the analysis methodologies.

Transportation Analysis Scenarios

The Kimley-Horn analysis was prepared in accordance with the Traffic Impact Study Guidelines (2008) set forth by the San Joaquin County Public Works Department. The Kimley-Horn analysis considered the following five scenarios:

Existing (2012) conditions Existing Plus Approved Projects (EPAP) conditions Existing Plus Approved Projects Plus Proposed Project conditions Cumulative (2025) conditions Cumulative (2025) Plus Proposed Project conditions

The first three scenarios are described in this chapter. The remaining two scenarios are described in Chapter 6.0, Cumulative Impacts. The Existing Plus Approved Projects (EPAP) condition is defined as a near-term background condition that includes existing traffic levels, with adjustments for the anticipated addition of future traffic associated with buildout of approved land use development projects in the vicinity of a project. The Kimley-Horn analysis stated that


the County provided a list of pending/approved projects in the proposed Project vicinity as of May 2012. However, after review, it was determined that, while responsible for adding traffic to the overall regional transportation network, these projects are not anticipated to generate trips at a level that have a measurable effect on the study facilities for this Project. As a result, the turn movement volumes and levels of service for this scenario are identical to those previously presented for Existing (2012) conditions.

Analysis Area Facilities

The traffic-related effects of the proposed Project were assessed by analyzing existing and future traffic operations at intersections that would serve Project-related travel. Figure 5-1 shows the three intersections selected for impact analysis. The intersections subject to analysis under the five traffic analysis scenarios are listed by number below:

1. State Route (SR) 12 at Interstate 5 (I-5) Southbound Ramp 2. SR 12 at I-5 Northbound Ramp 3. SR 12 at North Thornton Road/Star Street

These intersections were considered to have the most potential to be affected by traffic generated by the Project. In response to a comment by Wood Rodgers, Kimley-Horn stated that its study intentionally did not route Project-associated traffic south of SR-12 along Star Street. Such suggested routing would equate to fewer trips making the critical eastbound SR-12 left-turn to North Thornton Road and the southbound North Thornton Road right-turn to SR-12 movements. Therefore, the trip distribution scheme is considered to be more conservative. Furthermore, given the density and variety of commercial uses along North Thornton Road (currently and with the Project), Kimley-Horn considered it unclear why this particular circulation (north/south across SR-12) would be advantageous to the users (Kimley-Horn, 2011). In addition to these intersections, the Kimley-Horn analysis evaluated impacts on the following freeway ramp junctions, located at the I-5/SR 12 freeway interchange in the vicinity of the Project site:

1. I‐5 Northbound diverge to SR 12 2. I‐5 Northbound merge from SR 12 3. I‐5 Southbound diverge to SR 12 4. I‐5 Southbound merge from SR 12

The Kimley-Horn analysis stated that the project study facilities were selected based on the fact that the majority of the project trips are expected to have already been on the road network or were rerouted from either SR-12 or Interstate 5. Therefore, a relevantly low percentage of the project trips are anticipated to be “new” to the surrounding road network. Caltrans specifies 50 peak-hour trips as one of the “starting point” criteria for assessing impacts to State facilities. The number of “new” project trips on state facilities outside of those selected for study is anticipated to be significantly less than Caltrans’ 50 trip threshold. Therefore, study of other state facilities is not warranted by Caltrans guidelines.

September 12, 2012

Figure 5-1PROJECT LOCATION AND

STUDY INTERSECTIONS


NORTH


Analysis Methodology

The traffic analysis, available in Appendix B, provides detailed information on the methodologies used in evaluating the traffic impacts of the Project. The following summarizes the methodologies used in this analysis. The number of trips anticipated to be generated by the Project was estimated using data included in Trip Generation, 8th Edition, and Trip Generation Handbook, 2nd Edition, both published by the Institute of Transportation Engineers. It should be noted that the San Joaquin County Traffic Impact Study Guidelines recommends the use of Trip Generation, 8th Edition for traffic projections. Adjustments were made to account for the interaction between Project land uses, as well as for trips that are already on the adjacent roadways (I-5 and SR-12) anticipated to be served by the Project site uses. According to the ITE Trip Generation Handbook, Second Edition, “a multi-use development is typically a single real-estate project that consists of two or more ITE land use classifications between which trips can be made without using the off-site road system. Because of the nature of these land uses, the trip-making characteristics are interrelated, and some trips are made among the on-site uses. This capture of trips internal to the site has the net effect of reducing vehicle trip generation between the overall development site and the external street system.” Because there is a potential for interaction among the Project land uses (gas station patrons visiting the fast-food restaurant or vice versa) it was deemed appropriate to apply an “internal trip reduction” to account for the interaction between proposed land uses. As noted in Table 5-1, daily, AM peak-hour, and PM peak-hour internal trip reductions were applied per the methodology provided in the Trip Generation Handbook. Furthermore, according to the Trip Generation Handbook, “Diverted linked trips are trips that are attracted from the traffic volume on roadways within the vicinity of the generator but require a diversion from that roadway to another roadway to gain access to the site…” As such, these trips are not considered new to the surrounding roadway network, rather they are re-routed (a.k.a. “diverted”) from their original route in and out of the project site. For this study, 75 percent of the project trips were conservatively assumed to be vehicles (truck and passenger cars) that are already on the adjacent I-5 and SR-12 routes. As required by ITE, these trips were manually and thoroughly re-routed through the study intersections to appropriately account for their diversion and effect on traffic operations. According to the Trip Generation Handbook, 2nd Edition, in cases where the “validity of ITE Trip Generation data for local use is questioned by traffic professionals or local officials, the analyst may need to collect local data and either validate the national data or establish a local rate.” In response to a comment from Wood Rodgers challenging the use of ITE trip generation data, and in an effort to validate the use of the ITE data for the proposed Project, the updated Kimley-Horn analysis collected local data for three existing Love’s Travel Stops located in California. Each of these sites was selected for its on-site uses, the presence of a fast‐food restaurant with a drive‐through window, and its proximity to adjacent freeway facilities.


Table 5-1 shows the estimated Project trip generation. The ITE Land use codes were selected based on the proposed land uses that most closely resemble the ITE Land Use description. The traffic analysis in Appendix C describes the ITE land use trip generation rates used.

TABLE 5-1 PROJECT TRIP GENERATION

Land Use Size

Total Daily Trips

AM Peak Hour4

PM Peak Hour4

Total Trips

IN OUT Total Trips

IN OUT % Trips % Trips % Trips % Trips

Fast-Food Restaurant w/ Drive-Thru

3 ksf 1,490 148 51% 75 49% 73 102 52% 53 49% 49

Gas Station w/ Convenience Market

24 pumps 3,908 244 50% 122 50% 122 321 50% 161 50% 161

Subtotal New Trips 5,398 392 197 195 423 214 209

Internal Trip Reduction (Daily, AM, PM)

1 16%, 22%,10% -866 -86 -43 -43 -42 -21 -21

Total New Trips @ Site Driveways2 4,532 306 154 152 381 192 189

Diverted Linked Trip Reduction3

75% -3,399 -230 -116 -114 -286 -144 -141

Net New External Trips 1,133 77 39 38 95 48 47

ksf – thousand square feet 1 Per Trip Generation Handbook, 2nd Edition, ITE.

2 These values represent the number of trips utilized to access the proposed Project at the study facilities.

3 Assumed trip reduction to account for the existing I-5 and SR 12 traffic accessing Project site uses.

4 Table shows AM and PM peak hour of adjacent street traffic.

Source: Trip Generation, 8th Edition, ITE.

Table 5-2 summarizes the sample site trip generation data that was collected. Table 5-2 shows average morning (AM) and evening (PM) peak‐hour trips per thousand square feet (ksf) of 31 and 39 respectively, and 11 and 14 trips per fuel pump during the AM and PM peak‐hours respectively. As shown in Table 5-2, the ITE data demonstrates AM and PM peak‐hour trips per ksf of 29 and 36 respectively, and 13 and 16 trips per fuel pump during the AM and PM peak‐hours respectively. Based on the comparison of ITE and local trip generation data shown in Table 5-2, the Kimley-Horn analysis concluded that the use of ITE data is appropriate, and is actually more conservative on a trips-per-fuel pump basis. As shown in Table 5-1, the Project is estimated to generate 1,133 new daily trips, with 77 new trips occurring during the AM peak hour, and 95 new trips occurring during the PM peak hour. When trips diverted from existing I-5 and SR 12 traffic are added, the total new daily trips associated with the Project is 4,532, with 306 new trips occurring during the AM peak hour, and 381 new trips occurring during the PM peak hour.


TABLE 5-2 SAMPLE SITE TRIP GENERATION DATA

Sample Site Size

AM Peak Hour PM Peak Hour

Total Trips

IN OUT Total Trips

IN OUT

Auto Truck Auto Truck Auto Truck Auto Truck

Love’s Travel Stop – Ripon (w/ Drive-thru)

336 138 47 123 28 409 150 60 137 62

55% In 45% Out 51% In 49% Out

7.85 ksf 43 trips per ksf 52 trips per ksf

23 pumps 15 trips per pump 18 trips per pump

Love’s Travel Stop – Lost Hills (w/ Drive-thru)

159 31 46 26 56 223 60 56 59 48

48% In 52% Out 52% In 48% Out



Love’s Travel Stop – Coachella (w/ Drive-thru)

207 45 60 38 64 259 62 66 58 73

51% In 49% Out 49% In 51% Out



Average of Love’s Travel Stop Sites

234 71 51 62 49 297 91 61 85 61

51% In 49% Out 51% In 49% Out



Proposed Project (per ITE Trip Generation, 8

th

Edition

306 381

50% In 50% Out 50% In 50% Out



ksf – thousand square feet Source: Driveway Vehicle Classification Counts, Kimley-Horn and Associates, May 9, 2012.

It is important to note that a conservative “heavy vehicle” percentage of 15% was incorporated in the Kimley-Horn analysis for all movements at all intersections – both with and without the Project – to account for the significant proportion of existing and projected truck traffic at most of the analysis facilities. According to the California Department of Transportation (Caltrans), SR 12 experiences 13.9% trucks for the segment west of 1-5 and 15.3% for the segment east of I-5, resulting in a conservative average of 15% in the vicinity of the Project site (Caltrans Traffic and Vehicle Data Systems Unit, http://www.dot.ca.gov/hq/traffops/saferesr/trafdata/). Furthermore, due to the recognized higher proportion of trucks accessing the existing Flying J site and the proposed Project site via the SR 12/North Thornton Road intersection, Kimley-Horn performed manual counts on December 28, 2010 to determine the appropriate heavy vehicle percentage for the eastbound left-turn and southbound right-turn at this intersection. Based on this field data, a 30% heavy vehicle proportion was utilized for these two movements.


Although the Project would add more truck and passenger vehicle traffic to the critical movements at the SR 12/North Thornton Road intersection, it was determined that the ratio of trucks to all vehicles is not anticipated to increase with the addition of the Project. That is, the observed heavy vehicle percentages documented for SR 12 and as counted for the SR 12/North Thornton Road intersection are anticipated to remain virtually the same with the addition of the proposed Project. When compared with the existing Pilot Flying J truck stop, across North Thornton Road from the Project site, the Pilot Flying J is approximately 1/3 larger than the proposed Project operations. This size difference includes the number of truck gas pumps and the number of truck parking stalls. Additionally, the Project’s proposed fast‐food restaurant with drive‐through further supports a level of passenger cars resulting in a comparable truck percentage with the addition of the Project, when compared to the sit‐down restaurant at the Pilot Flying J. It should be noted that the use of a heavy vehicle percentage within traffic analysis software (Synchro Version 7, Trafficware Ltd.) has the identical effect as a passenger car equivalent. As such, no other adjustments are required to accurately reflect the truck traffic associated with the proposed project or the surrounding land uses. The distribution of Project traffic was developed based on Project area roadway volumes, general knowledge of Project area traffic patterns, and engineering judgment. The Project trip distribution percentages are illustrated in Figure 4 of the traffic analysis (Appendix B). The resulting AM and PM peak-hour traffic volumes attributed to the proposed Project at the intersections studied in the analysis are illustrated in Figure 5 of the traffic analysis (Appendix B). The analysis of traffic operations at intersections is typically based on the Level of Service (LOS). LOS is a qualitative measure used to describe operational conditions, represented by letter designations from A to F, with A representing the best conditions (minimal delay) and F representing the worst (heavy delay). Intersection LOS for this analysis was determined using methods defined in the Highway Capacity Manual 2000 and appropriate traffic analysis software. The Highway Capacity Manual 2000 includes procedures for analyzing two-way stop-controlled, all-way stop-controlled, and signalized intersections. The two-way procedure defines LOS as a function of average control delay for each minor street approach movement. Conversely, the all-way and signalized intersection procedures define LOS as a function of average control delay for the intersection as a whole. Table 5-3 below presents definitions for LOS at intersections, as defined in the Highway Capacity Manual 2000.


TABLE 5-3

INTERSECTION LEVEL OF SERVICE DEFINITIONS

Level of Service

Signalized Intersection- Control Delay per Vehicle

(seconds/vehicle)

Unsignalized Intersection- Average Control Delay

(seconds/vehicle)

A ≤10 ≤10

B >10-20 >10-15

C >20-35 >15-25

D >35-55 >25-35

E >55-80 >35-50

F >80 >50

Source: Highway Capacity Manual 2000.

The determination of freeway ramp junction (merge and diverge) LOS is based on the density of vehicles within the corresponding merge or diverge influence area. Density, as it relates to freeway ramp junction LOS, is defined as the number of passenger cars per mile per lane. The Highway Capacity Manual 2000 establishes the influence area as 1,500 feet in advance of diverge points, and 1,500 feet extending past merge points. Table 5-4 presents freeway ramp junction LOS definitions.

TABLE 5-4

FREEWAY RAMP JUNCTION LEVEL OF SERVICE DEFINITIONS

Level of Service

Density (passenger cars/mile/lane)

A ≤10

B >10-20

C >20-28

D >28-35

E >35

F Demand exceeds capacity

Source: Highway Capacity Manual 2000.

The Kimley-Horn analysis states that Caltrans has identified LOS C as the appropriate threshold for its facilities, which include State Routes and interstate freeways. In its Traffic Impact Study Guidelines, the County notes that the County General Plan has set a minimum LOS D for freeways and State highways. However, the County Guidelines also state that Caltrans has set a minimum LOS C for State facilities in rural areas.


REGULATORY FRAMEWORK

San Joaquin County General Plan

The current County General Plan, adopted in 1990, contains a Transportation section in its Community Development Element that sets forth policies related to transportation and circulation. General Plan Policies relevant to this EIR analysis include the following:

Transportation Coordination with Land Use Policy 1. The transportation system shall support the attainment of desired land

use patterns. Roadways Policy 8. The San Joaquin Council of Governments (SJCOG) may establish Levels

of Service (LOS) for freeways in San Joaquin County through the update and amendment of the Congestion Management Plan (CMP). The LOS standards in the CMP shall become the standard for individual freeways in San Joaquin County. On Minor Arterials and roadways of higher classification, the County shall maintain an LOS no lower than “D” at all intersections and the following on the throughway:

(a) On State highways, LOS D. (b) Within a city’s sphere of influence, LOS D, or LOS C when the city

plans for that level of service or better. (c) On Mountain House gateways, as defined in the Master Plan,

LOS D. (d) On other roads, LOS C.

Policy 9. The Level of Service for a roadway shall be based on the average weekly

peak-hour volume.

San Joaquin County Regional Congestion Management Plan

In 2007, the San Joaquin Council of Governments (SJCOG) adopted the most recent version of its Regional Congestion Management Plan (RCMP). The original plan was developed in response to the California Congestion Management Plan, which was approved statewide by voters in 1990 and became operative in 1992. The objective of the California Congestion Management Plan and local plans was to have new land uses developed in tandem with the necessary transportation capacity. The Plan was designed to coordinate land use, air quality and transportation planning to reduce potential congestion from traffic generated by development.


The California Congestion Management Plan required that every urbanized county in California designate a Congestion Management Agency (CMA). SJCOG is the CMA for San Joaquin County. In addition, San Joaquin County’s Measure K, approved by County voters in 2006, committed SJCOG to implement a Regional Congestion Management Plan by January 1, 2008. The 2007 RCMP contains the following elements:

1. A description of the regional transportation system, including roadways, transit systems, pedestrian facilities and bicycle facilities, that is to be monitored and targeted for land use, demand management and infrastructure programs in a biennial Capital Improvement Program. By State law, all State Highways and principal arterials must be included in a congestion management plan. Therefore, SR 12 is included in the RCMP. North Thornton Road is not included.

2. An on‐going performance measurement program for all modes of transportation

in the county. 3. Evaluation criteria section that establishes firm goals for all modes of

transportation to achieve, not just motor vehicle transportation. The plan also introduced a new “tiered” approach to vehicular congestion that mandates the use of alternative transportation programs as congestion becomes noticeable, but before there is a known system “deficiency.”

4. A Land Use Impact Analysis Program that allows a detailed evaluation of all

proposed development projects in the county that may produce more than 125 vehicle trips in a peak hour.

5. New procedures for addressing “deficient” roadway segments in San Joaquin

County involving a coordinated approach that includes local jurisdictions, land owners and developers, Caltrans, and SJCOG at a point well in advance of a deficiency. A Deficiency Plan is to be prepared when a LOS standard established on the Regional Congestion Management Plan network is exceeded, after calculating required exclusions. Based on a draft Regional Deficiency Plan (see below), neither I-5 nor SR 12 are considered deficient in the Project vicinity.

6. A suite of innovative demand management, pricing, land use, and infrastructure

strategies that are at the forefront of programs to reduce single occupancy vehicle travel.

7. A Capital Improvement Program that provides a framework for the funding and

implementation of projects that maintain or improve the transportation performance standards of the RCMP.

8. Conformity requirements to ensure that the County and cities are conforming to

the RCMP.


In accordance with the RCMP, SJCOG is preparing a Regional Deficiency Plan to address roadway segments considered deficient by RCMP criteria. In addition, a Travel Demand Management Plan is being prepared by SJCOG to establish an institutional and planning framework between SJCOG and its member agencies to more effectively address demand management and facility-based demand management strategies for the purpose of relieving peak period congestion on RCMP-designated roadways.

San Joaquin County Traffic Impact Study Guidelines The purpose of the San Joaquin County Traffic Impact Study Guidelines, adopted in November 2008, is to establish general procedures and requirements for the preparation of traffic impact studies associated with development within San Joaquin County. The County Guidelines provide guidance on the traffic study area, growth assumptions and traffic forecasting, traffic counts, traffic projections, and mitigation measures to be discussed. The County Guidelines reiterate the acceptable LOS for County roads, as found in the County General Plan. All County roadways shall operate at LOS C or better (except in a City sphere of influence where the City has adopted LOS D); intersections shall operate at an overall LOS D or better on minor arterials and roadways of higher classification; and LOS C on all other roads. All freeways and State highways shall operate at LOS D.

California Department of Transportation Guidelines Caltrans adopted its Guide for the Preparation of Traffic Impact Studies in December 2002. The format is similar to the San Joaquin County Traffic Impact Study Guidelines, except that the Caltrans guidelines focus on impact on State highways. It also provides methodologies for evaluating impacts on facilities such as freeway sections, weaving areas, ramp junctions, signalized and unsignalized intersections, transit capacity, and pedestrians and bicycles. As with the County Guidelines, the Caltrans guidelines establish acceptable LOS at traffic facilities. Caltrans endeavors to maintain a target LOS at the transition between LOS “C” and LOS “D” on State highway facilities. However, Caltrans acknowledges that this may not always be feasible and recommends that the lead agency consult with Caltrans to determine the appropriate target LOS. As previously noted, the County Guidelines state that Caltrans has set a minimum LOS C for State facilities in rural areas.


ENVIRONMENTAL SETTING

Existing Roadways

The following are descriptions of the primary roadways in the Project vicinity: Interstate 5 (I-5) is a north-south freeway located west of the Project site. Generally, I-5 serves the Central Valley, connecting the major population centers of Northern and Southern California. Locally, I-5 provides connection between the communities of Lodi, Stockton and Sacramento. Access to I-5 from the Project site is provided by SR 12. Within the Project vicinity, I-5 has three travel lanes in each direction. As of 2011, the average annual daily traffic (AADT) on I-5 south of the SR 12 interchange was 77,000, and 53,000 north of the interchange (California Department of Transportation, 2011). State Route 12 (SR 12) is an east-west State highway that provides a link between SR 99 and I-5 in the vicinity of Lodi. In the immediate vicinity of the Project site, SR 12 has two travel lanes in each direction, and had an AADT of 15,000 on the segment between I-5 and North Thornton Road (California Department of Transportation, 2011). North Thornton Road is a minor two-lane roadway that parallels I-5 on the east, and is adjacent to the Project site. It provides local access between Stockton to the south and smaller communities to the north. In the immediate vicinity of SR 12, North Thornton Road serves numerous commercial businesses, and has a wider cross-section to accommodate the traffic associated with these land uses. North Thornton Road has a five-lane cross section at the south end of the Project site that decreases to four lanes as it goes north (three travel lanes and a center turn lane). It provides access to the existing Pilot Flying J Truck Stop and other freeway-related businesses. At the intersection of North Thornton Road and SR 12, Star Street forms the southern leg. Star Street is a minor roadway serving motels and other freeway-related businesses in the Flag City area south of SR 12.

Public Transportation

The San Joaquin Regional Transit District (SJRTD) is the primary provider of public transportation service in San Joaquin County and its incorporated cities. SJRTD provides fixed-route, flexible fixed-route, and dial-a-ride services. However, the Project vicinity currently is not served by SJRTD. Route 165 travels along I-5 from Stockton to Sacramento, passing by the Project vicinity. However, Route 165 is a commuter line, and there are no scheduled stops for this route in the Project area. The Lodi Grape Line provides transit services in the City of Lodi to the east. However, no bus service is provided by the Lodi Grape Line to the Project vicinity.


A park-and-ride facility is located south of SR 12, near the intersection with the south leg of Thornton Road. This facility, sponsored by Caltrans, has 41 regular and two handicapped parking spaces. However, no bus routes stop at this park-and-ride facility.

Bicycle and Pedestrian Systems

The generally level terrain and mild weather make bicycling and walking viable forms of transportation in much of San Joaquin County. According to Caltrans guidelines, bicycle facilities are generally divided into three categories:

Class I Bikeway (Bike Path). A completely separate facility designated for the exclusive use of bicycles and pedestrians with vehicle and pedestrian cross-flow minimized.

Class II Bikeway (Bike Lane). A striped lane designated for the use of bicycles on a street or highway. Vehicle parking and vehicle/pedestrian cross-flow are permitted at designated locations. Class III Bikeway (Bike Route). A route designated by signs or pavement markings for bicyclists within the vehicular travel lane (i.e., shared use) of a roadway.

The Draft Background Report for the San Joaquin County General Plan Update indicates that there are no formally designated bicycle facilities in the Project vicinity. However, the County does plan to install a Class III bike route along SR 12 through the Project area (Mintier Harnish, 2009). Sidewalks have been constructed along both sides of North Thornton Road along the Project site frontage, down to the intersection with SR 12. Some sidewalks also have been installed in front of businesses along Star Street, south of the SR 12 intersection.

Existing (2012) Traffic Conditions

Existing Intersection Operating Conditions

Kimley-Horn assessed existing operating conditions at each of the three analysis intersections as of May 2012. Counts of existing traffic turn movement volumes used in this traffic impact analysis were collected on May 9, 2012. Table 5-5 shows the peak hour operating conditions for the analysis intersections. Figure 5-2 provides a graphic illustration of Existing conditions.

September 12, 2012

Figure 5-2EXISTING (2010) PEAK HOUR

TRAFFIC VOLUMES

NORTH



TABLE 5-5

INTERSECTION LOS – EXISTING CONDITIONS


Intersections Intersection

Control Delay

(seconds) LOS Delay

(seconds) LOS

SR 12 @ I-5 Southbound Ramp Signal 5.5 A 5.3 A

SR 12 @ I-5 Northbound Ramp Signal 15.5 B 15.3 B

SR 12 @ North Thornton Road/Star Street Signal 23.1 C 24.3 C

Note: Signal - Signalized light control. Source: Kimley-Horn and Associates, 2012

Existing Ramp Junction Operating Conditions

Kimley-Horn assessed ramp junction LOS, based on I-5 mainline traffic volume data from Caltrans. Table 5-6 shows the peak hour operating conditions for the analysis ramp junctions. As noted above, Caltrans standards require all state facilities to operate at LOS C or better. Based on this standard, three of the ramp junctions operate at an unacceptable LOS D during certain peak hours. In all other cases, the ramp junctions operate at an acceptable LOS C or better.

TABLE 5-6 RAMP JUNCTION LOS – EXISTING CONDITIONS


Locctions Total

Volume Density

(pc/mi/ln) LOS Total

Volume Density

(pc/mi/ln) LOS

I-5 NB Merge from SR 12 247 16.6 B 299 25.3 C

I-5 SB Merge from SR 12 329/181* 29.8 D 300/374* 20.5 C

I-5 NB Diverge from SR 12 580 23.3 C 615 31.5 D

I-5 SB Diverge from SR 12 246 30.6 D 235 21.1 C

Notes: Bold indicates substandard as defined by Caltrans. pc/mi/ln – passenger cars per mile per lane NB – northbound, SB – southbound * I-5 SB Merge results presented in eastbound-to-southbound/westbound-to-southbound format. Source: Kimley-Horn and Associates, 2012

Existing Plus Approved Projects (EPAP) Conditions

A list of project area pending/approved projects was provided to Kimley-Horn by the County. A list of the pending/approved projects shown by the County is provided in Appendix C of the traffic analysis. After review, it was determined that these projects’ trip generation, while responsible for adding traffic to the overall regional transportation network, are not anticipated to have a measurable effect on the study facilities for this


project. As a result, the turn movement volumes and LOS for this scenario are identical to those presented for Existing (2012) conditions. The Existing (2012) conditions description presented above would also apply to the EPAP conditions.

ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES

Significance Thresholds

Based on criteria derived from Appendix G to the CEQA Guidelines, a project would have a significant effect related to transportation if it would:

• Conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit, non-motorized travel and relevant components of the circulation system. Relevant components would include, but are not limited to, intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit.

• Conflict with an applicable congestion management program, including but not limited to level of service standards, travel demand measures or other standards established by the congestion management agency for designated roads or highways.

• Result in a change in air traffic patterns, including either an increase in traffic levels or a change in location that results in substantial safety risks. The Project site is within 2.07 miles of the Kingdon Airport. Given this distance and the use of Kingdon Airport by small aircraft only, the Project is unlikely to have an impact on airport operations or air traffic patterns. Therefore, this issue will not be analyzed in this EIR.

• Substantially increase hazards due to a design feature (for example, sharp curves or dangerous intersections) or incompatible uses (for example, farm equipment).

• Result in inadequate emergency access.

• Conflict with adopted policies, plans or programs regarding public transit, bicycle or pedestrian facilities, or otherwise decrease the performance or safety of such facilities.

In addition to these Appendix G thresholds, an additional threshold has been established for impacts related to vehicle queuing. Queuing involves the “lining up” of vehicles in turn lanes prior to a traffic signal permitting the specific turn. Vehicle queues that exceed the available capacity of a turn lane can lead to obstruction of vehicles in other


lanes, thereby creating a safety hazard (see fourth bullet in list of Appendix G guidelines above). Therefore, the following significance threshold is established for the Project:

• Generate vehicle queue lengths that exceed available vehicle storage lengths of turn lanes.

According to the San Joaquin County Traffic Impact Study Guidelines, which incorporated LOS standards from the San Joaquin County General Plan, all County roadways shall operate at LOS C or better, except in a City sphere of influence where the City has adopted LOS D. Intersections shall operate at an overall LOS D or better on minor arterials and roadways of higher classification; and LOS C on all other roads. All freeways and State highways shall operate at LOS D. Per Caltrans, all state facilities shall operate at LOS C in rural areas and LOS D in urban areas. For the Project, traffic impacts are considered significant if the LOS at affected facilities degrades to LOS D or worse. Traffic impacts analyzed in this chapter are for EPAP Plus Proposed Project conditions. Please refer to Chapter 6.0, Cumulative Impacts, for an analysis of traffic impacts under Cumulative conditions.

Impact 5.1 – Consistency with LOS Standards: Intersections Under EPAP Plus Project Conditions

Peak-hour traffic associated with the proposed Project was added to the Existing (2012) traffic volumes previously noted. LOS at the study facilities was determined by the same methodology. Table 5-7 shows the AM peak hour and PM peak hour LOS at each analysis intersection under EPAP Plus Proposed Project conditions, with a comparison to Existing (2012) conditions (see Table 5-5).

TABLE 5-7 INTERSECTION LOS – EPAP PLUS PROJECT CONDITIONS



Control Delay

(seconds) LOS Delay

(seconds) LOS

SR 12 @ I-5 Southbound Ramp Signal Exist 5.5 A 5.3 A

EPAP+P 6.0 A 6.0 A

SR 12 @ I-5 Northbound Ramp Signal Exist 15.5 B 15.3 B

EPAP+P 15.6 B 16.8 B

SR 12 @ North Thornton Road/Star Street

Signal Exist 23.1 C 24.3 C

EPAP+P 33.2 C 31.2 C

Notes: Signal - Signalized light control. Exist – Existing (2012) conditions; EPAP+P – Existing plus approved projects plus proposed Project conditions Bold indicates unacceptable LOS, as defined by Caltrans. Source: Kimley-Horn and Associates, 2012

September 12, 2012

Figure 5-3EPAP PLUS PROJECT

PEAK HOUR TRAFFIC VOLUMES

NORTH



The worksheets presenting the calculation of LOS are included in an appendix to the traffic analysis, (Appendix B). Figure 5-3 illustrates the EPAP Plus Proposed Project conditions. As indicated in Table 5-7, while the delay times would increase from Existing conditions, the study intersections would operate at an acceptable LOS under all peak hour conditions. In fact, the LOS would remain unchanged at all intersections from Existing conditions. Since LOS would remain at acceptable levels, the Project would have less than significant traffic impacts under EPAP Plus Project conditions.


Impact 5.2 - Consistency with LOS Standards: Freeway Ramp Junctions Under EPAP Plus Project Conditions

Table 5-8 presents the AM peak hour and PM peak hour LOS at each analysis ramp junction under EPAP Plus Project conditions, with a comparison to Existing (2012) conditions (see Table 5-6). As shown in Table 5-8, three of the ramp junctions operate at an unacceptable LOS D during certain peak hours. In all other cases, the ramp junctions operate at an acceptable LOS C or better, according to Caltrans standards.

TABLE 5-8 RAMP JUNCTION LOS – EPAP PLUS PROJECT CONDITIONS


Locations Total

Volume Density


Volume Density

(pc/mi/ln) LOS

I-5 NB Merge from SR 12 Exist 247 16.6 B 299 25.3 C

EPAP+P 297 16.8 B 361 25.6 C

I-5 SB Merge from SR 12 Exist 329/181* 29.8 D 300/374* 20.5 C

EPAP+P 394/173* 30.2 D 380/365* 21.0 C

I-5 NB Diverge from SR 12 Exist 580 23.3 C 615 31.5 D

EPAP+P 638 23.6 C 687 31.7 D

I-5 SB Diverge from SR 12 Exist 246 30.6 D 235 21.1 C

EPAP+P 297 30.8 D 298 21.3 C

Notes: Bold indicates unacceptable LOS as defined by Caltrans. Exist – Existing (2012) conditions; EPAP+P – Existing plus approved projects plus proposed Project conditions pc/mi/ln – passenger cars per mile per lane NB – northbound, SB – southbound * I-5 SB Merge results presented in eastbound-to-southbound/westbound-to-southbound format. Source: Kimley-Horn and Associates, 2012


It should be noted that the freeway ramp junctions would continue to operate at the same LOS as under Existing conditions. The three freeway ramp junctions that were operating at unacceptable LOS under Existing conditions are the same ones that operate at the same unacceptable LOS under EPAP Plus Project conditions. However, with the addition of Project traffic, the volumes and densities at all ramp junctions increased, including those with unacceptable LOS under Existing conditions. The Kimley-Horn analysis (Appendix B) states that the addition of the proposed Project does not cause a ramp junction facility which operates at acceptable levels without the proposed project, to operate at substandard levels with the Project. Furthermore, due to heavy mainline I‐5 volumes, each facility, with the exception of the I‐5 Northbound Merge from SR‐12, experiences LOS D without the Project during either the AM or PM peak hour, and the addition of the Project contributes ramp volumes to the conditions. Due to the heavy mainline volumes, it can be concluded that the addition of the proposed Project would have a nominal effect on the operation of the subject ramp junction facilities. In a response to the first memorandum prepared by Wood Rodgers, Kimley-Horn stated that Caltrans reviewed a draft of the original traffic analysis and had no comment on this identified impact, and concurred with a study on a different project in which the same conclusion was drawn (Kimley-Horn, 2011). The Project would increase traffic density by at most only 0.5 passenger cars per mile per lane from existing conditions, and by at most 0.4 passenger cars per mile per lane on the ramp junctions that would experience LOS D. Nevertheless, since Project traffic would increase the density at ramp junctions that already experience unacceptable LOS, this impact is considered significant. Although widening the subject ramps to include an additional lane would alleviate the substandard operating conditions, both without and with the Project, it is uncertain that these types of interchange modifications would be implemented, since no transportation plan currently includes such improvements. Therefore, the County considers such mitigation to be infeasible, and this impact is considered significant and unavoidable. It is worth noting that, as indicated by the Highway Capacity Manual, Transportation Research Board, 2004, “Capacity and other traffic analyses focus on the peak hour of traffic volume, because it represents the most critical period for operations and has the highest capacity requirements. The peak-hour volume, however, is not a constant value from day to day or from season to season.” Due to the logical inconsistency in peak-hour traffic volumes from day-to-day, month-to-month, and year-to-year, the documented results which are marginally above (worse than) the acceptable level of service threshold could very easily operate acceptably with data collected at a different time. Furthermore, the statistically insignificant addition of less than 0.5 passenger cars per mile per lane would not be anticipated to result in a noticeable effect to the facility operations.

Level of Significance: Significant and unavoidable Mitigation Measures: None feasible


Impact 5.3 – Consistency with Congestion Management Plan

As described in the Regulatory Framework section, SJCOG has adopted a Regional Congestion Management Plan designed to alleviate potential traffic congestion on roadways that are part of the RCMP network. SR 12 is one of the RCMP-designated roadways. A 2010 report for the Regional Deficiency Plan indicates that SR 12 has no deficiencies, based on RCMP criteria.

The same report did not identify I-5 in the Project vicinity as a deficient facility. Since most of the traffic to the Project site would be diverted from existing traffic on both I-5 and SR 12, the Project is not expected to contribute to a deficiency on roadways that are part of SJCOG’s RCMP network.


Impact 5.4 – Potential Hazards: Vehicle Queuing Under EPAP Plus Project Conditions

As previously noted, queuing involves the “lining up” of vehicles in turn lanes prior to a traffic signal permitting the specific turn. Vehicle queues that exceed the available capacity of a turn lane can lead to obstruction of vehicles in other lanes, thereby creating a safety hazard. Therefore, a project that generates queue lengths that exceed available vehicle storage lengths of turn lanes would have a significant impact. Vehicle queuing for exclusive turn lanes was evaluated at the analysis intersections. The 95th percentile queuing (a length that is the maximum of 95% of vehicle queue lengths expected at any given time) was compared against available vehicle storage lengths to determine if the queues are anticipated to exceed their available storage and adversely affect adjacent through travel lanes. Table 5-9 shows the results of this analysis for Existing and EPAP Plus Project conditions. As shown, none of the 95% queue values exceed the available storage at the specified turn lanes under either Existing or EPAP Plus Project conditions. Therefore, it is unlikely that anticipated queues at these turn lanes would obstruct adjacent lanes, even with Project implementation, and impacts related to vehicle queuing are considered less than significant.



TABLE 5-9 INTERSECTION QUEUING EVALUATION RESULTS

Intersections Movement/ Approach


Available Storage (ft)

95% Queue (ft)

Available Storage (ft)

95% Queue (ft)

SR 12 @ I-5 Southbound Ramp SB Left

Existing 850 62 850 71

EPAP Plus Project 850 88 850 105

SR 12 @ I-5 Northbound Ramp NB Right

Existing 460 109 460 157


EB T-turn

Existing 590* 66 590* 87

EPAP Plus Project 590* 87 590* 128

SR 12 @ North Thornton Road SB Left

Existing 250 39 250 44


EB Left

Existing 420 75 420 97


Notes: SB – southbound, NB – northbound, EB – eastbound * Intersection approach with available storage length equal to segment length. Source: Kimley-Horn and Associates, 2012

Impact 5.5 – Potential Hazards: Circulation Impacts of Project Driveways

As indicated by the site plan (Figure 3-1), the Project proposes to use three driveways on North Thornton Road to serve all uses within the Project site. The installation of these driveways would affect circulation in the Project vicinity, which in turn may have impacts on traffic flow and safety. The southernmost Project site driveway was assumed in the traffic impact analysis to serve virtually all passenger car traffic associated with the Project. Passenger cars visiting the gas station, convenience store and fast-food restaurant are expected to use this driveway, as there is minimal opportunity to access this portion of the site from the northern truck servicing area. This driveway shares and expands access with the existing roadway serving the Burger King restaurant to the south.


Due to the volume of traffic anticipated to use this driveway, the Kimley-Horn analysis recommends that the eight existing parking stalls along this access road be removed to improve traffic operations entering and exiting the area. Considering that the predominant movements at this driveway are to and from the south, the analysis recommends that the expanded driveway should be delineated to include one large entering lane and one large exiting lane to improve the ease of traffic entering from northbound North Thornton Road. After review of the recommendations, the County indicated that the potential conflict resulting in this impact can be lessened with removal of only three of these parking spaces. However, as the parking stalls recommended for removal are located on an off-site parcel with different ownership, these recommendations would require the consent of the adjacent parcel owner to implement. If the parcel owner does not agree to these recommendations, then the driveway’s northern edge would need to be extended north within the project site footprint. Refer to Mitigation Measure 5.5-1 below for additional detail. Existing operations at the adjacent Pilot Flying J truck stop were observed as a means by which to anticipate operations at the driveways of the proposed Project. Unlike the Pilot Flying J site, the proposed Project appears to clearly delineate one driveway as one-way (entering). Considering the proposed one-way operation of the middle site driveway, appropriate signage and pavement striping should be provided to adequately convey driveway operations to all approaching vehicles. The traffic analysis states that expanding the driveway island to the south could be beneficial, to further emphasize the one-way entering operations and thereby discouraging exiting movements. These recommendations are incorporated in the mitigation measures presented below. The northernmost site driveway is proposed to be two-way access. This proposed driveway would be opposite an existing driveway that was observed to operate with two-way traffic as well. The combination of two-way traffic at opposite driveways has the potential to result in delays, as the conflicting movements complete their access maneuvers. Regardless of the operation of the driveways, conflicts are anticipated along North Thornton Road, as entering and exiting truck traffic uses the single center turn lane. Further complicating this interaction is that virtually all traffic from both sites (the proposed Project and the Pilot Flying J) is anticipated to originate from and be destined for the south. Extending the existing North Thornton Road five-lane cross section to the north along the Project site frontage will promote the separation of truck and passenger car traffic at the site driveways. This five lane section is shown on the project site plan, although a specific description on how this improvement would be financed is not provided. Mitigation presented below would provide a mechanism for implementing this improvement. Given the anticipated circulation issues associated with the proposed driveways for the Project site, impacts are considered significant. Mitigation measures presented would clarify turn routes for vehicles and reduce the potential conflicts in vehicle turn movements identified above, thereby reducing potential accidents. Impacts after mitigation would be less than significant.

Level of Significance: Significant


Mitigation Measures: 5.5-1. Three of the existing eight parking stalls located along the Burger King

frontage on the shared access road shall be removed or realigned to allow for an expanded southernmost driveway and access road. The ODS shall reach an agreement with the owner of the Burger King restaurant regarding these parking stalls prior to their removal or realignment. If an agreement with the owner of the Burger King cannot be reached, the ODS shall modify the design of the southernmost driveway and access road so that the potential for conflict between vehicles entering the Project site and users of the parking stalls will be eliminated. This may be accomplished by extension of the northern edge of the driveway to accommodate the required width, or by other means that are approved by the County Public Works Department.

The expanded driveway shall be delineated to include one large entering lane and one large exiting lane. The total width of this driveway shall not exceed the maximum width specified by the County for commercial driveways. The County Public Works Department shall review and approve the design of the expanded southernmost driveway and access road prior to the issuance of building permits.

5.5-2. The middle site driveway shall have appropriate signage and pavement

striping to adequately convey the proposed one-way enter driveway operation to all approaching vehicles. The County Public Works Department shall determine the adequacy of the design and approve the signage and pavement striping for the driveway prior to the issuance of building permits.

5.5-3. The ODS shall coordinate with the County to minimize potential

inefficiencies of traffic interactions between the Project site and Pilot Flying J’s two truck driveways. Specifically, clarification of the one-way entering operation at the Pilot Flying J’s southern driveway and of the two-way operation at Pilot’s northern driveway should be considered. The County Public Works Department shall determine the adequacy of the design of and approve the signage and pavement striping for the northernmost driveway for the proposed Project prior to the issuance of building permits.

5.5-4. The ODS shall design and construct all improvements associated with the

extension of North Thornton Road along and to the northern end of the Project site frontage. The ODS shall coordinate with the County Public Works Department to ensure that the design of improvements meets County road standards.

Significance After Mitigation: Less than significant. Implementation of the mitigation measures would improve safety and reduce delays in vehicle access. The measures provide design criteria related to road and driveway improvements associated with North Thornton Road and the southernmost driveway; and signage


placement and pavement striping that will provide clear direction for vehicles entering and exiting the project area. Implementation: The ODS will be responsible for construction of roadway improvements and installation of signage and pavement striping in the project area. The ODS will also coordinate with the owners of the Burger King restaurant regarding improvements to the shared driveway and inform the owners of the Pilot Flying J truck stop of signage and striping improvements to their respective driveways.

Monitoring: The County Public Works Department will be responsible for ensuring that improvements are designed and constructed in accordance with County specifications, including the widening of North Thornton Road.

Impact 5.6 – Potential Hazards: On-Site Circulation

The proposed mix of on-site uses has potential impacts on Project site access and on-site circulation. Minimal pedestrian activity is anticipated between the on-site uses, and specifically between the truck and the passenger car areas. Nevertheless, pedestrian movement within the Project site is a potential concern, given the layout of the Project site and the vehicle movements. Mitigation measures presented below would reduce the potential hazards associated with pedestrian movements, reducing potential impacts to a level that is less than significant. The Kimley-Horn analysis indicates that the vehicle entrance to the drive-through lane could potentially conflict with the southernmost on-site driveway when excessive queues occur. It recommends that adequate pavement striping and signage should be provided, both to contain vehicles destined for the drive-through and to discourage drive-through vehicles from blocking on-site parking and/or the site driveway. This recommendation is incorporated in the mitigation measures presented below. The analysis also recommends that, in general, the on-site trucks using the truck fueling area should be discouraged and restricted from accessing the other, more passenger car dominant areas of the Project site. The analysis observed that the fueling truck for the passenger car area will be provided with an internal connection between the truck and passenger car areas. The analysis recommends that this connection should be downplayed and potentially restricted to limit the interaction of trucks and passenger cars. This recommendation is also incorporated in the mitigation measures presented below. This measure would reduce potential conflicts between truck and passenger car traffic, thereby reducing potential accidents.

Level of Significance: Potentially significant Mitigation Measures: 5.6-1. The ODS shall provide on-site pedestrian facilities, such as walkways and

striped crosswalks, as required, to enhance pedestrian visibility to on-site motor vehicles, both trucks and passenger cars. The location of pedestrian


facilities shall be considered for, but not limited to, the following locations: between the truck fuel dispensers and the store; and the passenger car parking area and the store (across the drive-thru lane).

5.6-2. The ODS shall provide signage and pavement striping to direct and contain

vehicles destined for the drive-thru in order to avoid conflicts with the southernmost driveway. The County Public Works Department shall determine the adequacy of and approve the signage and pavement striping prior to installation.

5.6-3. The ODS shall provide on-site signage to restrict the internal connection

between the truck and the passenger car areas. Significance After Mitigation: Less than significant. The mitigation measures would reduce pedestrian, passenger car and truck traffic conflicts, thereby reducing potential accidents. Signage and pedestrian striping will provide on-site controls that will enhance pedestrian safety and reduce potential impacts to less than significant levels. Implementation: The ODS will be responsible for design and installation of the required signage and pavement striping. Monitoring: The County Public Works Department will be responsible for ensuring that improvements are designed and constructed in accordance with County specifications.

Impact 5.7 – Potential Hazards:Truck Turning Path Radii

The Project application does not indicate whether the Project would accommodate Surface Transportation Assistance Act (STAA) vehicle use. STAA vehicles are large vehicles that have relatively large turning radii, and require roadway design features that accommodate the large turning radii. Nonetheless, the Kimley-Horn analysis considered the two northernmost driveways of the proposed Project for access by STAA design vehicles. As illustrated in Figure 5-4, the standard STAA design vehicle template has been considered at the two northernmost driveways. The evaluation assumed that the five-lane North Thornton Road cross-section would be extended to the northern boundary of the Project site.

July 2, 2012

Figure 5-4STAA VEHICLE SITE ACCESS

TURN TEMPLATES

NORTHSOURCE: KIMLEY-HORN AND ASSOCIATES, INC.


Based on the STAA design templates, minor curb and/or sidewalk modifications would be required to accommodate the wide turns of the STAA design vehicle. The mitigation measure below would require these modifications, which would mainly focus on the proposed island south of the northernmost proposed driveway. This mitigation would allow for safe turning by STAA design vehicles, thereby reducing this impact to a less-than-significant level.

Level of Significance: Potentially significant Mitigation Measures: 5.7-1. The proposed island south of the northernmost driveway shall be modified

so as to allow the off-tracking of STAA trucks, as illustrated in Figure 10 of the Kimley-Horn and Associates traffic impact analysis of the Project (see Appendix C of this EIR).

Significance After Mitigation: Less than significant. The mitigation measure would require modification of the proposed traffic island which would allow for STAA design vehicles to access the two northernmost driveways of the project site. Implementation: The ODS will be responsible for required truck turning movements improvement design and construction. Monitoring: The County Public Works Department will be responsible for review and approval of circulation-related improvements in conjunction with County review of site improvement plans.

Impact 5.8 – Potential Hazards: Adequacy of On-Site Parking

The Environmental Checklist in Appendix G of the CEQA Guidelines – the basis for Initial Studies - no longer has a question related to the adequacy of parking as a potential environmental impact. However, the Kimley-Horn analysis discussed this issue, as inadequate on-site parking could lead to off-site, on-street parking, which presents safety, operational and aesthetic concerns. Based on information from the Project applicant and counts of parking spaces contained in Figure 3-1, the Project would provide 162 parking spaces – 68 for passenger cars and 94 for trucks. The traffic analysis stated that, according to the County’s development standards, the proposed Project provides an adequate on-site parking supply. The analysis compared the proposed Project to three existing Love’s sites in California – Tehachapi, Tulare and Coachella. The conclusion was that the proposed Project appears to more appropriately park both passenger cars and trucks when compared to the existing sites. Therefore, it appears that the Project would provide adequate parking, thereby avoiding demand for on-street parking. However, the traffic analysis acknowledged that demand in excess of the truck parking supply may be more routinely experienced, in particular at night. This could mean that


trucks would park on the street, mainly on North Thornton Road, where permitted. This would have adverse circulation impacts, particularly concerning the safety of vehicles entering and exiting the Project site as line of sight would be restricted. The traffic analysis recommended that on-street parking be prohibited along the Project frontage, with appropriate signage and striping indicating this prohibition. The mitigation measure below would implement this recommendation, which would ensure that adequate line of sight is available for entering and exiting vehicles, thereby reduce potential safety impacts to a level that is less than significant. The County’s parking standards require that Truck parking/loading areas be designated on-site to ensure adequate space is provided to accommodate delivery occurrences (e.g., bulk gas and food delivery). Plans and specifications submitted to the County will include such designations, in accordance with County standards.

Level of Significance: Potentially significant

Mitigation Measures:

5.8-1. On-street parking shall be prohibited along the Project site frontage on North Thornton Road. Signage and striping indicating this prohibition shall be installed along this frontage in accordance with County standards. Prior to issuance of any building permits, the ODS shall submit a request, including payment of any fees, to the County Board of Supervisors to establish this “no parking” zone along the Project site frontage.

Significance After Mitigation: Less than significant. The mitigation would prohibit trucks from parking on North Thornton Road, thereby removing the potential safety hazard posed by trucks parked on the road. Implementation: The ODS will be responsible for the installation of the signage and striping. Monitoring: The County Public Works Department will be responsible for ensuring that the signage and striping are installed in accordance with County standards.

Impact 5.9 – Adequacy of Emergency Access

The Project is located on a site adjacent to North Thornton Road, north of SR 12. As previously described in the Environmental Setting, North Thornton Road has mostly three travel lanes and a center turn lane along the Project site frontage. There is sufficient existing lane availability for emergency vehicles to reach the Project site from North Thornton Road. As described in Chapter 3.0, Project Description, on-site access to the Project site would be via three ingress/egress driveways along the east side of North Thornton Road. The southernmost proposed access would be a 25-foot driveway that would allow for a full range of left- and right-turn movements by passenger vehicles. The second proposed entrance would provide a 130-foot one-way driveway for trucks only. The third access


would provide an 80-foot ingress/egress that would permit the full range of left and right turn movements for truck traffic. All three access points would provide adequate width for emergency vehicles. Therefore, the Project would provide adequate on-site access for emergency vehicles. Emergency access impacts would be less than significant. It should be noted that the driveways analyzed in this EIR were based upon the site plan for the Project. Kimley-Horn notes that the 130-foot driveway presented in the site plan can be reduced in width, provided it can still accommodate the truck turns (Sean Papadakis, pers.comm.).


Impact 5.10 - Impacts on Public Transportation, Bicycle and Pedestrian Facilities

As noted in the Environmental Setting section, the Project site and vicinity are not served by public transportation. While the Project would provide an employment activity in an area with other employment activities, the proposed land use would be a freeway-oriented service. Most freeway-oriented businesses employ relatively small numbers of people, compared with regional shopping centers and industrial activities. In addition, most of the customers of such businesses would be travelers on the freeway, rather than local residents. Therefore, freeway-oriented businesses would not generate the number of local residents and employees to make public transportation service feasible. The Project is not expected to increase demand for public transportation services. As discussed in the Environmental Setting section, there are existing sidewalk facilities along both sides of North Thornton Road by the Project site. Crosswalks at the SR 12/North Thornton Road intersection connect these sidewalks to others south of the intersection along Star Street. Given the freeway-oriented business that is proposed, the Project is not expected to generate an increased number of pedestrians that would require new or expanded facilities. As noted in the Environmental Setting section, the County plans to establish a bike route along SR 12 in the future. This bike route would provide access to the Project site and vicinity .Because of the proposed freeway-oriented land use, however, the Project is not expected to generate an increase in the number of people using bicycles. Also, given the distance the Project site is from likely sources of employees, such as Lodi and Stockton, the Project is unlikely to generate significant bicycle commuter traffic. Therefore, impacts on public transportation, bicycle, and pedestrian facilities would be less than significant.


127410/STO12R0423 6-1 September 28, 2012 Love’s Travel Stops Environmental Impact Report`

6.0 CUMULATIVE IMPACTS

A cumulative impact is an environmental effect that may result from the combination of two or more environmental effects associated with the proposed project, or from the combination of one or more project environmental effects with related environmental effects caused by other closely related projects. Cumulative impacts may also result when a project’s environmental effects compound or increase other environmental impacts. Cumulative impacts can result from individually minor, but collectively significant, projects taking place over a period of time (CEQA Guidelines Section 15355). CEQA Guidelines Section 15130 provides that an EIR must discuss the cumulative environmental impacts of a project “when the project's incremental effect is cumulatively considerable.” CEQA Guidelines Section 15065(a)(3) states that “cumulatively considerable” effects occur when the incremental effects of an individual project are significant when viewed in connection with the effects of other closely related projects, including past projects, current projects and probable future projects. The goal of such an exercise is twofold: first, to determine whether the overall long-term impacts of all such projects would be cumulatively significant; and second, to determine whether the Project itself would cause a “cumulatively considerable” (and thus significant) incremental contribution to any such cumulatively significant impacts (See CEQA Guidelines Section 15130[a]-[b], Section 15355[b], Section 15064[h], Section15065[c]; Communities for a Better Environment v. California Resources Agency [2002] 103 Cal.App.4th 98, 120). In other words, the required analysis intends to first create a broad context in which to assess the project’s incremental contribution to anticipated cumulative impacts, viewed on a geographic scale well beyond the project site itself, and then to determine whether the project’s incremental contribution to any significant cumulative impacts from all projects is itself significant (i.e., “cumulatively considerable” in CEQA parlance). Pursuant to CEQA Guidelines Section 15130, “(t)he discussion of cumulative impacts shall reflect the severity of the impacts and their likelihood of occurrence, but the discussion need not provide as great detail as is provided for the effects attributable to the project alone. The discussion should be guided by the standards of practicality and reasonableness, and should focus on the cumulative impacts to which the identified other projects contribute rather than the attributes of other projects which do not contribute to the cumulative impact.” If the project does not involve a "cumulatively considerable" contribution to a significant cumulative effect, the project’s effect need not be considered significant, and discussion in the EIR can be limited to the basis for that conclusion. Projects that do involve cumulatively considerable contributions may involve significant cumulative impacts. Mitigation measures are to be developed to reduce the project’s contribution to cumulative effects to a level that is less than cumulatively considerable (i.e., less than significant), or otherwise to the degree it is feasible to do so.


The analysis of cumulative impacts is to be based on either 1) a list of past, present, and probable future projects producing related or cumulative impacts, or 2) on a summary of projections contained in an adopted general plan or related planning document, or in a prior certified environmental document which described or evaluated regional or area-wide conditions contributing to the cumulative impact. Where significant cumulative impacts are identified, the EIR must examine reasonable, feasible options for mitigating or avoiding the project's contribution to a less than considerable level. The State CEQA Guidelines acknowledge that, in some cases, the only feasible mitigation may involve the adoption of ordinances or regulations. When using a project list, the cumulative impact analysis should account for the nature of each environmental resource as well as the location of the project and its type. This reflects the fact that the context for cumulative impacts varies from one environmental discipline to another. For example, cumulative ozone impacts are reasonably considered in the context of an air basin; to contrast, cumulative hydrologic impacts would be meaningfully addressed at a watershed level, and aesthetic impacts would ordinarily be addressed on only a local level. The potential cumulative impacts of the proposed Project have been examined pursuant to the direction provided by the CEQA Guidelines. The potential cumulative impacts of the Project are addressed primarily using the “summary of projections” method; i.e., through review of the Project in the context of the County’s General Plan 2010, adopted in 1992. As previously noted in Chapter 5.0, Transportation, the County identified projects that are active or pending in the Project vicinity; however, their impacts related to traffic were determined to be negligible. Since air quality impacts are closely related to traffic, impacts of these projects on air quality are likewise considered negligible. Under the County General Plan, the Project site is designated for Commercial Freeway Service development. This chapter considers the potential cumulative effects of the proposed Project under General Plan 2010 buildout conditions. Potential impacts are considered in detail in two issue areas: air quality and transportation. The following analysis determines for each environmental discipline 1) the geographic context for the analysis, 2) whether a potentially significant cumulative impact could occur, 3) whether the Project would make a cumulatively considerable contribution to a significant cumulative impact, or make significant an impact that was otherwise less than significant, and 4) whether a cumulatively considerable contribution, if it occurs, can feasibly be reduced to a less than cumulatively considerable level through the application of mitigation.

6.1 AIR QUALITY

Cumulative impacts on air resources may be assessed at both a regional and local level. The Project would involve contributions to potential air quality impacts at the regional (San Joaquin Valley Air Basin) level, and at the local (immediate Project vicinity) level. This analysis considers both levels.


Impact 6.1 – Cumulative Impacts to Air Quality

Construction Existing air quality conditions at both the regional and local levels are described in Chapter 4.0, as are the potential impacts of the Project. At the local level, construction activities would contribute to existing particulate matter (PM) nonattainment in the Air Basin, which would be considered a significant cumulative impact, even though project-level contributions are less than significant and short-term in nature; in others words, PM emissions would cease with completion of project grading. It should also be noted, implementation of project-level practices associated with dust control, described under Impact 4.2 in Chapter 4.0, would further reduce potential localized impacts associated with dust generation from levels already considered less than significant. With the implementation of dust control practices, construction emissions would have a less than cumulatively considerable impact. Operations Project operations, including truck idling, would not exceed the defined significance thresholds by the regional agency (SJVAPCD), which means that Project operations would not have a cumulatively considerable effect at the Air Basin level, except for NOx. As determined in Chapter 4.0, the Project would generate NOx emissions at levels that would exceed the SJVAPCD significance threshold when emissions from regular operations and truck idling are added together. However, Mitigation Measure 4.3-1, described in Chapter 4.0, would require the Project to comply with ISR requirements. With implementation of Mitigation Measure 4.3-1, NOx emissions would be below the SJVAPCD significance threshold and Project operational emissions would be less than cumulatively considerable. As described in the Environmental Setting section of Chapter 4.0, ARB also has adopted rules and regulations designed to reduce NOx emissions from truck operations and idling. Implementation of these rules regulations would occur during a time period of approximately ten years. When these rules and regulations are fully implemented, NOx emissions would be substantially reduced. Therefore, truck traffic associated with the Project and other cumulative activities within the Air Basin would contribute fewer NOx emissions from operations and idling. As discussed under Impact 4.3 in Chapter 4.0, NOx emissions are not substantially higher than the SJVAPCD significance threshold when diverted trips are excluded. With implementation of these ARB rules and regulations, Project operational emissions, which are expected to have a less than cumulatively considerable impact related to NOx emissions and emissions of other criteria pollutants, would be further reduced. Air Toxics – Diesel PM The Project would contribute emissions of diesel particulate matter, which is classified as an air toxic. Given the existence of a truck stop adjacent to the Project site, diesel particulate emissions from both sites would have a cumulative effect. However, there are no residences or other sensitive land uses in the Project vicinity. Furthermore, as


with NOx emissions, ARB has adopted rules and regulations designed to reduce diesel PM emissions from truck operations and idling during a time period of approximately ten years, beginning January 1, 2012. When these rules and regulations are fully implemented, diesel PM emissions would be substantially reduced, as would the health risk posed by these emissions. Therefore, the Project is considered to have a less than cumulatively considerable impact on diesel PM or other air toxics emissions.

Contribution to Significant Cumulative Impacts: Cumulatively considerable for PM and NOx. Mitigation Measures: Implement practices associated with dust control described under Impact 4.2 in Chapter 4.0 and Mitigation Measure 4.3-1 in Chapter 4.0. Significance After Mitigation: Less than cumulatively considerable. As discussed in Chapter 4.0, Air Quality, implementing the practices associated with dust control would reduce project-level construction dust (PM) emission levels. Mitigation Measure 4.3-1 would implement the Indirect Source Rule (ISR), which would reduce NOx emissions. These measures would reduce Project emissions to levels below the GAMAQI significance thresholds, making Project impacts less than cumulatively considerable. Although the Project would contribute NOx and PM emissions to an existing nonattainment status in the San Joaquin Valley Air Basin, with implementation of mitigation measures identified in Chapter 4.0, the contribution of the Project by itself would not be cumulatively considerable. In addition, all other projects within the Air Basin would be subject to the same dust control conditions and many would be subject to the ISR. Given this and the Project’s less than cumulatively considerable impact with mitigation based on the GAMAQI significance thresholds, the Project’s contribution to cumulative air quality impacts in the Air Basin would be less than cumulatively considerable.

6.2 TRANSPORTATION

Cumulative transportation impacts, primarily vehicular traffic, are addressed within the area potentially impacted by a proposed project, typically within a certain radius from the project site. This is also the case with respect to the potential traffic impacts of the project, which are addressed in detail in Chapter 5.0. The potential cumulative traffic impacts of the Project were considered by Kimley-Horn and Associates in their traffic study for the Project, available in Appendix C of this EIR. Potential cumulative impacts of the Project were considered for two scenarios:

• Cumulative (2025) No Proposed Project.

• Cumulative (2025) Plus Proposed Project.

The Cumulative (2025) condition is a long-term background condition that is assumed to occur in the year 2025, as required by the County’s Traffic Impact Study Guidelines. For the Kimley-Horn analysis, cumulative year traffic volumes were obtained from the


regional traffic model maintained by the San Joaquin Council of Governments (SJCOG). It was determined that the current version of the SJCOG travel demand model is based on Year 2035 cumulative conditions. As a result, Year 2010 and 2035 peak hour model volumes were used to develop an annual growth rate that in turn was used to develop Year 2025 conditions for use in the cumulative scenarios analyzed in this EIR. The methodology used to determine the significance of Project impacts under cumulative conditions is the same as that described in Chapter 5.0. The significance thresholds listed in Chapter 5.0 apply to cumulative conditions.

Cumulative (2025) No Project Traffic Conditions

Cumulative No Project Intersection Operating Conditions

The Kimley-Horn analysis assessed Cumulative No Project operating conditions at each of the three analysis intersections. Figure 6-1 illustrates Cumulative (2025) No Project conditions. Table 6-1 shows the peak-hour operating conditions for the intersections.

TABLE 6-1 INTERSECTION LOS – CUMULATIVE NO PROJECT CONDITIONS



Control Delay

(seconds) LOS Delay

(seconds) LOS

SR 12 @ I-5 Southbound Ramp Signal 6.0 A 5.3 A

SR 12 @ I-5 Northbound Ramp Signal 16.0 B 14.0 B

SR 12 @ North Thornton Road/Star Street Signal 22.3 C 27.2 C

Note: Signal - Signalized light control. Source: Kimley-Horn and Associates, 2012

As indicated in Table 6-1, the analysis intersections operate from LOS A to LOS C during the peak hours. All intersections operate at or above the minimum LOS C standard established by Caltrans for its facilities. It was noted in a comment by Wood Rodgers on the original traffic analysis that the SR 12 delay under Cumulative No Project conditions was less than the delay under Existing conditions. In response, Kimley-Horn noted that, consistent with standard traffic study methodologies, existing year conditions are modeled using actual signal timings in place at the time of the study. Future year conditions are commonly modeled using “optimized” timings to more appropriately reflect the inevitable signal retiming by the controlling jurisdiction (Kimley-Horn, 2011).

September 12, 2012

Figure 6-1CUMULATIVE (2025) PEAK-HOUR

TRAFFIC VOLUMES

NORTH



The Kimley-Horn analysis also conducted an analysis without future-year optimization; however, potential impacts and mitigation were similar to those identified with the optimization model. Caltrans, in its prior review and comments, agreed with the approach using optimization. Secondly, traffic signals operating in an actuated-uncoordinated fashion, such as the study intersections, are anticipated to accommodate increasing or modified traffic patterns efficiently due to their ability to reassign green-time as needed to serve the demand. In addition, average delay is calculated based on a weighted average of individual movements at an intersection. Therefore, in some instances it is possible to increase the volume of a major movement that operates at a relatively low delay and have the average delay per vehicle at the intersection decrease. This result is simply a function of the mathematical calculation used to determine delay (Kimley-Horn, 2011). The updated analysis indicates delay under some peak hour Cumulative No Project conditions was less than under Existing conditions, while delay was greater under other peak hour conditions.

Cumulative No Project Ramp Junction Operating Conditions

Kimley-Horn assessed the peak-hour operating conditions for the analysis freeway ramp junctions. Table 6-2 shows the peak-hour operating conditions for the ramp junctions. As previously noted in Chapter 5.0, according to the County’s Traffic Impact Study Guidelines, per Caltrans, all state facilities shall operate at LOS C in rural areas. Based on this standard, three of the ramp junctions operate at an unacceptable LOS during certain peak hours. In all other cases, the ramp junctions operate at an acceptable LOS C or better.

TABLE 6-2 RAMP JUNCTION LOS – CUMULATIVE NO PROJECT CONDITIONS


Loctions Total

Volume Density


Volume Density

(pc/mi/ln) LOS

I-5 NB Merge from SR 12 279 16.7 B 339 26.4 C

I-5 SB Merge from SR 12 390/181* 30.9 D 311/512* 20.4 C

I-5 NB Diverge from SR 12 718 24.3 C 647 32.3 D

I-5 SB Diverge from SR 12 297 31.5 D 270 21.1 C

Notes: Bold indicates substandard as defined by Caltrans. pc/mi/ln – passenger cars per mile per lane NB – northbound, SB – southbound * I-5 SB Merge results presented in eastbound-to-southbound/westbound-to-southbound format. Source: Kimley-Horn and Associates, 2012


Impact 6.2 - Traffic Impacts Under Cumulative (2025) Plus Project Conditions

Peak-hour traffic associated with the proposed Project was added to the Cumulative (2025) traffic volumes previously noted. LOS at the study facilities was determined by this methodology. Table 6-3 shows the AM peak hour and PM peak hour LOS at each analysis intersection under Cumulative Plus Project conditions, with a comparison to Cumulative (2025) conditions (see Table 6-1). The worksheets presenting the calculation of LOS are included in an appendix to the traffic analysis, available to reviewers upon request. Figure 6-2 illustrates Cumulative (2025) Plus Project peak-hour traffic volumes. As indicated in Table 6-3, the study intersections operate at an acceptable LOS under most peak-hour conditions with Project traffic. However, the SR 12/North Thornton Road intersection operates at an unacceptable LOS D during the AM peak hour, and at LOS F during the PM peak hour. This is a degradation from LOS C under Cumulative No Project conditions during both peak hours. This degradation of LOS at the SR 12/North Thornton Road intersection to an unacceptable condition is considered a cumulatively considerable impact.

TABLE 6-3 INTERSECTION LOS – CUMULATIVE PLUS PROJECT CONDITIONS



Control Delay

(seconds) LOS Delay

(seconds) LOS

SR 12 @ I-5 Southbound Ramp Signal Cumul 6.0 A 5.3 A

Cumul+P 6.5 A 6.2 A

SR 12 @ I-5 Northbound Ramp Signal Cumul 16.0 B 14.0 B

Cumul+P 15.5 B 15.1 B

SR 12 @ North Thornton Road/Star Street

Signal

Cumul 22.3 C 27.2 C

Cumul+P 39.8 D 92.4 F

Cumul+P (mit) 29.3 C 27.6 C

Notes: Signal - Signalized light control. Cumul – Cumulative (2025) conditions; Cumul+P – Cumulative plus proposed Project conditions; Cumul+P (mit) – Cumulative plus proposed Project conditions with proposed mitigation (Mitigation Measure 6.2-1) Bold indicates substandard as defined by Caltrans. Source: Kimley-Horn and Associates, 2012

As indicated in Table 6-3, at the SR 12/I-5 Northbound Ramp intersection, delay time under Cumulative Plus Project conditions actually decreased from Cumulative No Project conditions during the AM peak hour. Traffic signals operating in an actuated-uncoordinated fashion such as the study intersections are anticipated to accommodate increasing or modified traffic patterns efficiently, due to their ability to reassign green-time as needed to serve the demand.

September 12, 2012

Figure 6-2CUMULATIVE (2025) PLUS PROJECT

PEAK-HOUR TRAFFIC VOLUMES

NORTH



In addition, average delay is calculated based on a weighted average of individual movements at an intersection. Therefore, in some instances, it is possible to increase the volume of a major movement that operates at a relatively low delay and have the average delay per vehicle at the intersection decrease. This result is a function of the mathematical calculation used to determine delay. This also explains the substantial increase in delay time experienced at the SR 12/North Thornton Road intersection during the PM peak hour under Cumulative Plus Project conditions. Given the mix of volumes and signal timing parameters, and the heavy proportion of trucks, this intersection is more sensitive during this analysis scenario than in others. The Kimley-Horn analysis proposed as mitigation for this impact signal coordination for the three intersections and re-allocation of the green times at these intersections. This mitigation is presented below. This measure would reduce the delay times experienced at these intersections, which would lead to an improved LOS (see Table 5-3 in Chapter 5.0, Transportation). Kimley-Horn notes that the use of interconnection and improved synchronization between traffic signals is widely considered to be an effective strategy to improving traffic conditions. Such mitigation measures are commonly found within traffic impact studies and have been routinely approved by Caltrans and local jurisdictions as Transportation System Management measures. Table 6-3 shows the results of implementing the proposed mitigation measure:as indicated, implementation would have the SR 12/North Thornton Road intersection operating at acceptable LOS C during both AM and PM peak hours. Kimley-Horn notes that the County has clarified through the Project’s conditions of approval that satisfaction of the mitigation condition will require Caltrans approval. Furthermore, as previously noted in Chapter 5.0, Caltrans reviewed the original Project documentation and did not object to the proposed mitigation measure of signal interconnection and signal coordination (Kimley-Horn, 2011). With the mitigation described below, Project impacts on the SR 12/North Thornton Road intersection would be less than cumulatively considerable.

Level of Significance: Cumulatively considerable Mitigation Measures: 6.2-1. The ODS shall fund the necessary hardware and wiring to coordinate the

traffic signals at the State Route 12/North Thornton Road intersection, the State Route 12/Interstate 5 Northbound Ramp intersection, and the State Route 12/Interstate 5 Southbound Ramp intersection. The traffic signals shall be coordinated such that all intersections during both AM and PM peak hours will attain at least a minimum of LOS C. Traffic signal coordination shall be accomplished in coordination with, and to the satisfaction of, Caltrans. Prior to issuance of the certificate of occupancy, written verification from Caltrans indicating compliance with this mitigation measure shall be provided.


Significance After Mitigation: Less than cumulatively considerable. The SR 12/North Thornton Road intersection would operate at LOS C at both AM and PM peak hours, which is an acceptable LOS by County and Caltrans standards. Implementation: The ODS will be responsible for payment of costs for required physical improvements, and for obtaining written verification from Caltrans. Monitoring: The County Public Works Department will be responsible for ensuring that costs are paid, and that improvements are designed and constructed to the satisfaction of Caltrans.

Impact 6.3 - Freeway Ramp Junction Impacts Under Cumulative (2025) Plus Project Conditions

Table 6-4 presents the AM peak hour and PM peak hour LOS at each analysis ramp junction under Cumulative Plus Project conditions. As shown in Table 6-4, three of the four freeway ramp junctions would operate at an unacceptable LOS D during specific peak hours. This is the same situation as Cumulative No Project conditions, except that volumes and densities increased with the addition of the Project. LOS under all other peak hour conditions would be at an acceptable LOS C or better. It should be noted that the freeway ramp junctions would continue to operate at the same LOS as under Cumulative No Project conditions. The three freeway ramp junctions that were operating at unacceptable LOS under Cumulative No Project conditions are the same ones that operate at the same unacceptable LOS under Cumulative Plus Project conditions. However, with the addition of Project traffic, the volumes and densities at all ramp junctions increased, including those with unacceptable LOS under Cumulative No Project conditions.

The Kimley-Horn analysis states that the addition of the proposed Project does not cause a ramp junction facility, which operates at acceptable levels without the proposed project, to operate at substandard levels with the Project. Furthermore, due to heavy mainline I‐5 volumes, each facility experiencing LOS D with the project would do so without the project, and the addition of the Project would contribute ramp volumes to such conditions. Due to the heavy mainline volumes, it can be concluded that the addition of the proposed Project would have a nominal effect on the operation of the subject ramp junction facilities.

In a response to a memo by Wood Rodgers, Kimley-Horn stated that Caltrans reviewed a draft of its traffic analysis and had no comment on this impact, and concurred with a study on a different project in which the same conclusion was drawn (Kimley-Horn, 2011). The Project would increase traffic density by at most only 0.5 passenger cars per mile per lane from Existing conditions, and by at most 0.4 passenger cars per mile per lane on the ramp junctions that would experience LOS D. Nevertheless, since Project traffic would increase the density at ramp junctions that already experience unacceptable LOS, this impact is considered cumulatively considerable. Widening the subject ramps to include an additional lane would alleviate the substandard operating conditions, both without and with the Project. Due to the uncertainty of these


interchange modifications being implemented, and since no transportation plan has currently included such improvements, the County considers such mitigation to be infeasible and the impact is considered cumulatively considerable and unavoidable.

TABLE 6-4 RAMP JUNCTION LOS – CUMULATIVE PLUS PROJECT CONDITIONS


Locations Total

Volume Density


Volume Density

(pc/mi/ln) LOS

I-5 NB Merge from SR 12 Cumul 279 16.7 B 339 26.4 C

Cumul+P 329 16.9 B 401 26.6 B

I-5 SB Merge from SR 12 Cumul 390/181* 30.9 D 311/512* 20.4 C

Cumul+P 455/173* 31.2 D 391/503* 20.8 C

I-5 NB Diverge from SR 12 Cumul 718 24.3 C 647 32.3 D

Cumul+P 776 24.5 C 719 32.6 D

I-5 SB Diverge from SR 12 Cumul 297 31.5 D 270 21.1 C

Cumul+P 348 31.6 D 333 21.4 C

Notes: Bold indicates substandard as defined by Caltrans. Cumul – Cumulative (2025) conditions; Cumul+P – Cumulative plus proposed Project conditions pc/mi/ln – passenger cars per mile per lane NB – northbound, SB – southbound * I-5 SB Merge results presented in eastbound-to-southbound/westbound-to-southbound format. Source: Kimley-Horn and Associates, 2011

It is worth noting that, as indicated by the Highway Capacity Manual, Transportation Research Board, 2004, “Capacity and other traffic analyses focus on the peak hour of traffic volume, because it represents the most critical period for operations and has the highest capacity requirements. The peak-hour volume, however, is not a constant value from day to day or from season to season.” Due to the logical inconsistency in peak-hour traffic volumes from day-to-day, month to-month, and year-to-year, the documented results, which are marginally above (worse than) the acceptable level of service threshold, could very easily operate acceptably with data collected at a different time. Furthermore, the statistically insignificant addition of less than 0.5 passenger cars per mile per lane would not be anticipated to result in a noticeable effect to the facility operations.

Level of Significance: Cumulatively Considerable and Unavoidable Mitigation Measures: None feasible


Impact 6.4 - Vehicle Queuing Under Cumulative (2025) Plus Project Conditions

Impact 5.3, discussed in Chapter 5.0, described vehicle queuing and the methodology for analyzing queuing impacts. Table 6-5 (on the following page) shows the results of this analysis for Cumulative No Project and Cumulative Plus Project conditions. For the SR 12/North Thornton Road intersection, Cumulative Plus Project conditions include both unmitigated and mitigated (implementation of Mitigation Measure 6.2-1) scenarios. As shown in Table 6-5, none of the 95% queue values exceed the available storage at the specified turn lanes under either Cumulative or Cumulative Plus Project conditions, with and without Mitigation Measure 6.2-1 implemented. Based on these results, queues at any of the approaches would not obstruct vehicles in other lanes at any time. This impact would be less than cumulatively considerable.

Contribution to Significant Cumulative Impacts: Less than cumulatively considerable Mitigation Measures: None required

Impact 6.5 – Other Impacts Under Cumulative (2025) Plus Project Conditions Chapter 5.0 discussed potential impacts related to vehicle parking, on-site circulation and access, truck turning, and alternative transportation modes. All other traffic impacts identified by the traffic study as a potential result of the Project are specific to the Project site and adjacent parcels, and would not contribute to a cumulative impact; therefore, these impacts would not be cumulatively considerable. As previously noted in Chapter 5.0, the County provided a list of pending/approved projects in the proposed Project vicinity, but it was determined that these projects would not generate trips at a level that would have a measurable effect on the study facilities for this Project. Also, as noted in Chapter 5.0, the Project would have no significant impact on alternative transportation facilities such as sidewalks and bus stops. Thus, the Project would not have a cumulatively considerable impact on these other transportation issues.

Contribution to Significant Cumulative Impacts: Less than cumulatively considerable Mitigation Measures: None required


TABLE 6-5 INTERSECTION QUEUING EVALUATION RESULTS


Intersections Movement/ Approach

Available Storage

(ft) 95%

Queue (ft) Available

Storage (ft)

95% Queue

(ft)

SR 12 @ I-5 Southbound Ramp SB Left

Cumulative 850 81 850 80

Cumulative Plus Project 850 110 850 113

SR 12 @ I-5 Northbound Ramp NB Right



EB T-turn

Cumulative 590* 55 590* 84

Cumulative Plus Project 590* 70 590* 101

SR 12 @ North Thornton Road SB Left



Cumulative Plus Project (Mitigated)

250 59 250 51

EB Left



Cumulative Plus Project (Mitigated)

420 175 420 293

Note: SB – southbound, NB – northbound, EB – eastbound * Intersection approach with available storage length equal to segment length. Source: Kimley-Horn and Associates, 2011


7.0 ALTERNATIVES TO THE PROPOSED PROJECT

CEQA Guidelines Section 15126.6(a) of the State CEQA Guidelines requires that an EIR describe and analyze the relative environmental effects of alternatives to the proposed project and evaluate their comparative merits. The EIR must consider a range of reasonable alternatives that can feasibly attain most of the basic objectives of the project, while avoiding or substantially lessening one or more of the significant effects of the project. A reasonable alternative should be considered even if it would impede to some degree the attainment of the project objectives, or would be more costly. The environmentally superior alternative must be identified among the alternatives considered. The alternatives analysis must identify the potential alternatives and include sufficient information about each one to allow meaningful evaluation, analysis, and comparison with the proposed project. The discussion must focus on feasible alternatives that can avoid or substantially reduce the significant effects of the project. If an alternative is not feasible, or does not provide an opportunity to avoid or substantially reduce environmental effects, the alternative need not be analyzed in detail. In such cases, the reasons for limiting the analysis should be identified. Factors in determining the feasibility of an alternative may include site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and whether the applicant can reasonably acquire, control or otherwise have access to the alternative site (CEQA Guidelines Section 15126.6(f)(1)). Similarly, if an alternative would cause one or more significant effects, in addition to those that would be caused by the project, the significant effects of the alternative shall still be discussed, but in less detail than the analysis of the project. CEQA Guidelines Section 15126.6(e) states that the alternatives analysis must include evaluation of the "no project" alternative. "No project" is defined as no action with respect to the proposed project and continuation of existing circumstances without approval of the project. As a result, the “no project” alternative may also consider what could reasonably occur on or near the project site if existing development trends continue, to the degree that current plans, zoning, infrastructure and services permit. The following sections describe the alternatives selection process, identify the alternatives considered but that were not subjected to detailed analysis, and identify and analyze the alternatives to the proposed Project that were analyzed in detail. The alternatives considered in this chapter include:

Alternatives Not Addressed In Detail Alternative Locations for the Project


Alternatives Addressed in Detail No Project Alternative Reduced Project Size Alternative Use – Combination Gasoline Station Alternative Use – Retail with Fast-Food Restaurant

7.1 SELECTION OF ALTERNATIVES

Alternatives to the proposed Project were selected for evaluation in this EIR based on the criteria set forth in the CEQA Guidelines (Section 15126.6). These criteria included: 1) ability of the alternative to meet most of the basic objectives of the Project, 2) feasibility of the alternative, and 3) ability of the alternative to avoid or substantially reduce one or more of the significant environmental effects of the Project. These criteria are discussed in more detail below.

Ability of the Alternative to Meet Most Project Objectives

Potential alternatives to the Project were evaluated against the Project objectives, listed in Section 3.3 of this EIR. Briefly summarized, the main Project objective is to construct a Love’s Travel Stops to serve existing travelers on SR 12, I-5 and within the Project vicinity. The services the Project would provide include fuel dispensing for trucks and passenger cars, food, and convenience retail. More specific Project objectives include:

• To develop a regional travel stop on commercially-designated land within the northern County consistent with County General Plan policy and zoning;

• To create a high-quality travel stop commercial development near Interstate 5, a major transportation corridor;

• To develop a property of sufficient size to accommodate a truck and auto fuel dispensing area, emergency tire repair and replacement services, convenience store, and fast-food restaurant to create a regional travel stop;

• To provide a travel stop facility that maximizes its proximity to Interstate 5 for all buildings and tenants;

• To construct a facility near a major freeway interchange in order to minimize traffic generation on local streets;

• To construct a facility with access to adequate existing or anticipated utility infrastructure to support planned operations; and

• To provide a travel stop facility of sufficient size to capture overflow overnight truck parking.


The footprint of the proposed Project, which meets the Project objectives, is approximately 11.6 acres. Given the proposed services the Project intends to provide, the size of the Project site is considered appropriate. However, this chapter considers alternative uses for the Project site, some of which would require less acreage than the proposed Project.

Range and Feasibility of the Alternatives

Alternatives to the Project were evaluated with respect to the “rule of reason.” As defined in CEQA Guidelines Section 15126.6(f), the “rule of reason” requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant effects of the Project. The range of feasible alternatives shall be selected and discussed in a manner to foster meaningful public participation and informed decision making. Alternatives also were evaluated based on general feasibility criteria suggested by the CEQA Guidelines. These criteria include site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site, including consideration of whether or not the site is already owned by the applicant. The analyses in Sections 7.2 and 7.3 employ these criteria as applicable.

Ability of the Alternative to Avoid or Substantially Reduce Significant Effects

The evaluation of alternatives considers whether the alternative has the potential to avoid or substantially reduce any of the significant effects of the Project, as identified in Chapters 4.0 through 6.0 of this EIR. The potential environmental effects of the Project are summarized in Chapter 2.0, Summary of this EIR, and are briefly summarized below:

Air Quality. The Project would involve short-term construction dust emissions. Construction dust would be reduced to less than significant by conforming to existing construction dust control regulations of the San Joaquin Valley APCD; these requirements are applicable to the entire San Joaquin Valley Air Basin. The Project would generate NOx emissions that exceed the NOx significance threshold, but mitigation would reduce emissions below this threshold. It also would generate diesel particulate emissions in the course of Project operations and truck idling, but will not result in a significant impact. Transportation. The Project would involve increased traffic on roads and intersections serving the Project area, mainly along SR 12 and Thornton Road. On-site access and circulation impacts were identified, along with off-site parking impacts. Most transportation impacts were less than significant or could be reduced to less than significant with mitigation. However, ramp junction impacts were considered significant and unavoidable.


Cumulative Impacts. Cumulative air quality impacts were determined to be less than cumulatively considerable, after implementation of mitigation. Cumulative transportation impacts would involve increased traffic on roads and intersections serving the Project area, mainly along SR 12 and Thornton Road. Proposed mitigation measures would involve coordinating existing traffic signals along SR 12, and these measures would reduce traffic impacts at intersections to less than cumulatively considerable. However, ramp junction impacts were considered cumulatively considerable and unavoidable.

In light of the fact that this EIR was ordered by the court to be limited to the two issues for which Pilot claimed the IS/MND was deficient: traffic and air quality, it has been determined that the only relevant potential environmental effects of the Project for purposes of the alternatives analysis would be air quality and transportation.

7.2 ALTERNATIVES NOT CONSIDERED IN DETAIL

The following alternatives were not addressed in detail, as they did not meet the criteria for detailed analysis defined above. That is, the following alternatives 1) would not meet most of the objectives of the Project, 2) were infeasible, or 3) did not have the ability to avoid or substantially reduce the significant environmental effects of the Project. The “no project” alternative is not among the following alternatives, as CEQA requires that this alternative be addressed in detail.

Alternative Locations for the Project

CEQA Guidelines Section 15126.6(f)(2) indicates that alternative locations for the proposed Project should be considered if any of the significant effects of the Project would be avoided or substantially lessened at an alternative location. Only locations that have the potential to avoid or substantially reduce any of the significant effects of the Project need be considered for inclusion in the EIR. As discussed above, these effects would include air quality and transportation. As with all potential alternatives, Project location alternatives must be reasonable, feasible and able to meet most of the basic objectives of the Project. The analysis also considers the fact that the proposed Project site is currently owned by the Project applicant.

Unincorporated County Locations The analysis of potential alternative County locations takes into consideration the provisions of the San Joaquin County General Plan and Zoning Code, which have defined appropriate locations for uses such as the proposed Project. The San Joaquin County Zoning Code has a Freeway Service Commercial (C-FS) zoning district that allows land uses such as the proposed Project, subject to issuance of a use permit. The proposed Project site is zoned C-FS, as is the area to the south and west of the project site. The San Joaquin County Zoning Map indicates that no other undeveloped areas in the unincorporated County are zoned C-FS. The IL (Limited Industrial) and IG (General Industrial) zones also allow truck stops with a use permit. The County has designated few parcels with such zoning along the two main transportation corridors going through the County – I-5 and SR 99. Only two such


zoned areas were identified on the County Zoning Map. An IG zone is located adjacent to and east of I-5 between the City of Lathrop and the community of French Camp. The other is an IG zone located adjacent to and east of SR 99, between SR 26 and SR 88 east of Stockton. The French Camp parcels closest to the freeway interchanges are occupied. There appear to be two vacant parcels in this IG zone. However, they are a considerable distance from the nearest I-5 interchanges, and are accessible only by a two-lane road that would likely require substantial improvements to accommodate anticipated truck traffic. Given the distance from the freeway interchanges and the existing access limitations, transportation impacts would likely be worse than those for the proposed Project, with a consequent adverse impact on air quality. Most of the area east of the City of Stockton is occupied by existing land uses. There appears to be one vacant site of adequate size to accommodate a land use similar to the proposed Project. However, access to this site is cut off by a diversion canal and by railroad tracks, and there is no convenient access from the freeway. Only two-lane roads have access to this area, and truck traffic on such roads would lead to worse transportation and air quality impacts than the proposed Project. In addition, the Project applicant already has a Love’s Travel Stop located along SR 99 in the City of Ripon, approximately 17 miles south of this location. The placement of a similar truck stop in relatively close proximity on the same highway may be considered economically infeasible. In both locations, the Project applicant would be required to purchase the parcels with adequate size, which may not be feasible. Infrastructure upgrades would likely be required at both locations, adding to the potential economic infeasibility. Therefore, there do not appear to be feasible alternative sites within the unincorporated County for the Project.

Locations Within Incorporated Cities The alternative analysis considered alternative sites located within incorporated areas of the County. The analysis considered alternative locations within incorporated areas along I-5; as discussed in the evaluation of County locations above, the location of the Project along SR 99 may be economically infeasible. Segments of SR 4 and SR 120 are freeways that go through mostly incorporated areas. However, the freeway portions of these highways are connectors between I-5 and SR 99, and properties along these segments either are already developed or have been designated for uses other than those that would allow truck stops. There are two incorporated cities along I-5 in San Joaquin County: Lathrop and Stockton. The analysis looked at the zoning ordinances for the two cities to determine the zone in which truck stops would be an allowable land use. A review of the Lathrop Zoning Ordinance indicates that truck stop uses are allowed only in the Commercial Service (CS) and Limited Industrial (IL) zones. Trucking terminals are allowed by right in the CS zone, which such use in the IL zone is allowed with a conditional use permit. An area adjacent to and east of I-5 south of Roth Road has been designated within the IL zone. However, an aerial survey indicates that the parcels within this area have already been developed. No parcels are available for


potential truck stop development. There are no other parcels in Lathrop adjacent to I-5 that are zoned such that a potential truck stop can be developed. The analysis of potential sites in Stockton focused on the area along I-5 south of the junction with SR 4, as areas to the north are already developed. Truck stops are allowed in the Industrial Light (IL), Industrial General (IG) and Port (PT) zones. The PT zone allows such use by right, while the two industrial zones allow it with a permit. Two areas that have appropriately zoned land near I-5 are at the Charter Way interchange and the French Camp Road interchange. The Charter Way interchange has IL-zoned land to the northwest, while the French Camp Road interchange has IG-zoned land to the northeast. Most of the Charter Way land zoned IL has already been developed. The one vacant parcel that appears available for a truck stop is accessible only by a two-lane road that would require freeway traffic to navigate a complex intersection near the interchange. Traffic impacts in this area would likely be worse than with the proposed Project, along with associated air quality impacts. Likewise, most of the French Camp Road land that is zoned IG has been developed, and most available parcels are too small for the proposed Project use. There is one large area of vacant adjacent to the Honda building; however, this area is part of the parcel on which the Honda building is located. Given the lack of available properties, it would not be feasible to locate the proposed Project in the vicinity of the French Camp interchange. As with the County locations, the Project applicant would be required to purchase the parcels with adequate size, which may not be feasible, and is not feasible in the French Camp case. Infrastructure upgrades would likely be required at both locations, adding to the potential economic infeasibility. Therefore, there do not appear to be feasible alternative sites within the incorporated cities along I-5 that would meet the Project objectives.

7.3 ALTERNATIVES CONSIDERED IN DETAIL

The alternatives to the proposed Project that have been considered in detail are addressed in this section. Table 7-1 summarizes the overall analysis.

TABLE 7-1 COMPARISON OF ALTERNATIVES TO THE PROPOSED PROJECT IMPACTS

Issue Area Proposed Project Alt 1: No Project

Alt 2: Reduced Project Size

Alt 3: Gasoline Station

Alt 4: Retail

Ozone precursor (NOx) emissions

Significant, but can be mitigated

Avoided Partial reduction

Partial reduction

Partial reduction

Traffic generation and impacts

Significant, but can be mitigated

Avoided Partial reduction

Partial reduction

Partial reduction


Alternative 1: No Project Alternative

As previously noted an alternatives analysis must include evaluation of a No Project alternative. CEQA Guidelines Section 15126.6(e)(1)(B) further defines the No Project alternative as the circumstance under which the proposed project does not proceed. If disapproval of the project under consideration would result in predictable action by others, such as the proposal of some other project, this “no project” consequence should be discussed. In certain instances, the No Project alternative means “no build,” wherein the existing environmental setting is maintained. However, where failure to proceed with the project will not result in preservation of existing environmental conditions, the analysis should identify the practical result of the project’s non-approval and not create and analyze a set of artificial assumptions that would be required to preserve the existing physical environment. Under the No Project alternative, development of the proposed truck stop would not occur. In the short term, it is anticipated that the proposed Project site would remain vacant. In the long term, it is anticipated that the site would be developed for other uses permitted under the San Joaquin County Zoning Ordinance could be developed on the site. For the purposes of this analysis, potential alternative uses are assumed to be those that could be developed under the existing County zoning designation by right; that is, uses that could be developed without a review process similar to the proposed Project. Alternative uses that would require a General Plan amendment and/or rezoning are not considered reasonable, in light of the commercial land use designations and zoning that prevail in the Project vicinity. The Project site is zoned C-FS, Commercial-Freeway Services. The range of potential alternative uses that could be developed in the C-FS zone is defined by Table 9-405.2, contained in Title 9 of the San Joaquin County Code (Development Title). Some land uses are allowed “by right,” meaning no formal approvals are required. Other uses require special approval, such as a Site Approval, a Special Purpose Plan and a Use Permit. Table 7-2 lists the land uses allowed on a permanent basis in the C-FS, along with any special approvals required. The C-FS also allows various temporary land uses, most of which are allowed by right or with an Improvement Plan. The proposed Project – a truck stop – is an allowable land use in the C-FS zone with a Use Permit. Most of the land uses listed in Table 7-2 are not subject to detailed consideration in this section, because these uses would require a review process similar to that for the proposed Project. Based on Table 7-2 above, there are three land uses allowed by right in the C-FS zone: minor utility services, family day care home, and small group care. These three land uses and their potential impacts are discussed below: Minor Utility Services. Minor utility services, as defined by County Code Section 9-115.580, are utility services that are necessary support principal development involving only minor structures. Typical uses include electrical distribution lines, utility poles and pole transformers. Such structures would not be expected to generate impacts associated with more typical freeway commercial development, particularly traffic and attendant air quality impacts. Therefore, this land use is not analyzed further in this EIR.


TABLE 7-2

ALLOWABLE LAND USES IN THE C-FS ZONE

Land Use Permitted Use

Small Group Care P

Family Day Care Homes P

Automotive Sales and Services - Automotive Rentals S

Automotive Sales and Services - Cleaning S

Automotive Sales and Services - Parking S

Communication Services - Type I PI

Communication Services - Type II S

Crop Production P

Eating Establishments - Convenience S

Eating Establishments - Full Service S

Equipment Sales and Repair - Leisure S

Gasoline Sales - Service and Combination S

Liquor Sales - On Premises S

Lodging Services - Bed and Breakfast S

Lodging Services - Motel S

Petroleum and Gas Extraction U

Produce Sales - Small Agricultural Store S

Produce Sales - Large Agricultural Store U

Public Services - Administrative PI

Public Services - Essential S

Recreation - Campgrounds U

Recreation - Parks S

Recycling Services - Consumer PI

Retail Sales and Services - Primary S

Truck Sales and Services - Cleaning U

Truck Sales and Services - Stops U

Truck Sales and Services - Sales U

Utility Services - Minor P

Utility Services - Major S

Notes: P – Permitted use; PI – Permitted use with Improvement Plan; S – Use permitted subject to Site Approval; U – Use permitted subject to Use Permit

Source: San Joaquin County Code, Title 9, Table 9-405.2.

Family Day Care Home. As defined in County Code Section 9-115.380(a), a “family day care home” is a facility that provides care for 14 or fewer children. It does not include uses requiring overnight care, and is typically located near existing residences. Since


there are no residences on the Project site or in the vicinity, this land use is not analyzed further in this EIR. Small Group Care. County Code Section 9-115.115(a) defines a “small group care” facility as a facility authorized, certified, or licensed by the State of California to provide nonmedical care and supervision to adults or to dependent and neglected children, in which the number of residents are six or fewer. For this analysis, it is assumed that no other development would occur on the Project site other than the small group care facility, which would have the maximum six occupants. ITE’s Trip Generation does not have a rate specifically for small group care facilities. A review of ITE trip generation rates indicated that two land uses are the closest to small group care facilities. One is assisted living facilities, with a trip generation rate of 2.74 trips per bed per day. For this analysis, it is assumed that there is one bed for each occupant of the care facility, with the maximum six occupants allowed by the zoning ordinance. The other trip generation rate available, for congregate care facilities, is 2.02 trips per dwelling unit per day. Assuming one dwelling unit per occupant with the maximum six occupants, the resultant trip generation would be less than that for the assisted living facility. Therefore, the assisted living facility rate, which generates the larger number of trips, is used to provide a conservative analysis. Based on the assisted living facility trip generation factor of 2.74 trips per bed per day, a small group care facility would generate 16.44 vehicle trips per day, which is approximately 99.7% less than the total trips that would be generated by the proposed Project. The total number of AM and PM peak hour trips would likewise be reduced by approximately 99.7%, as would new trips at site driveways and net new external trips. Given that new trips generated by the small group care facility would increase traffic in the area by only 0.03%, it would have essentially no impact on the intersections and ramp junctions analyzed in the Project traffic study. The small group care facility would also have virtually no impact on air pollutant emissions. However, this alternative is in conflict with all the Project objectives, which are based on the construction and operation of a truck stop serving regional travelers.

Alternative 2: Reduced Project Size

This alternative considers potential changes in the Project uses related to its size. The Reduced Project Size alternative is defined as development of a truck stop that is half the size of the proposed Project. Specifically, the alternative proposes a truck stop with 12 available fuel dispensing pumps – four for trucks and eight for passenger cars. The convenience store would be reduced in size to 3,850 square feet, and the attached fast-food restaurant would be 1,500 square feet. The maintenance building and the storage building would also be reduced by half. This alternative would result in an approximately 50% reduction in trips generated by land use activities associated with the Project. Based on figures in the Kimley-Horn traffic analysis, this would mean half of the 4,532 new trips used to evaluate air quality impacts of the proposed Project, or 2,266 trips (see Table 1 of traffic analysis in Appendix B of this EIR). The total number of AM and PM peak hour trips would likewise


be reduced by approximately 50%, as would new trips at site driveways and net new external trips. Although precise quantification is not available, it is expected that intersections operating at LOS D with the proposed Project under cumulative conditions would likely operate at a minimally acceptable LOS C under this alternative, due to reduced traffic generation. As indicated in the Project traffic analysis, however, LOS D and LOS F occurred under cumulative conditions with the proposed Project at the SR 12/North Thornton Road intersection during AM and PM peak hours, respectively. For the proposed Project, a mitigation measure requiring signal coordination at the three intersections studied in the traffic analysis was recommended. This same mitigation would apply under this alternative. Freeway ramp junctions would continue to operate at LOS D under both existing and cumulative conditions under this alternative and this alternative would contribute traffic to these unacceptable LOS. As any contribution of traffic to the ramp junctions operating at LOS D would be a significant impact, and because no feasible mitigation is available, as is the case for the proposed Project, the ramp junction impacts for this alternative would be significant and unavoidable under both existing and cumulative conditions. As such, though traffic generation may be reduced under this alternative, impacts under this alternative would be similar to the proposed Project. This alternative, by reducing the amount of traffic, would reduce the amounts of air pollutant emissions that would be generated by the Project, particularly NOx emissions. In addition, diesel particulate matter emissions would be reduced, along with health risks associated with these emissions. Table 7-3 provides an estimate of the total emissions generated by this alternative, with a line indicating the emissions contributed by idling trucks. The CalEEMod results for each of the alternative presented in this chapter are available in Appendix A of this EIR. As shown in Table 7-3, ROG, NOx and PM10 emissions under this alternative would be below the SJVAPCD significance thresholds.

TABLE 7-3 ESTIMATED ANNUAL CRITERIA POLLUTANT EMISSIONS

BY ALTERNATIVE (AREA PLUS OPERATIONAL)

Emissions (tons per year)

ROG NOx PM10 PM2.5 CO SO2 Diesel PM

Alternative 2: Reduced Size

1.75 6.96 0.99 0.17 13.33 0.01 0.014

Alt. 2 Idling Emissions 0.15 2.05 0.01 0.01 0.80 0.00 0.003

Alternative 3: Combo Gasoline Station

1.09 3.26 0.58 0.10 8.36 0.01 0.08

Alternative 4: Retail w/ Fast Food

1.72 5.51 1.37 0.20 13.85 0.01 0.09

Note: No mitigation measures were incorporated in the emission calculations. Source: CalEEMod, EMFAC 2011 (see Appendix B of this EIR)

Although project trips are reduced under this alternative, thus reducing the intensity of impacts associated with the proposed Project, this alternative is in conflict with the Project objectives, which call for a larger facility to be able to serve regional travelers.


Alternative 3: Alternative Use – Combination Gasoline Station

A combination gasoline station, as defined in Section 9-115.455 of the County Code, typically includes a convenience market that sells gasoline. As noted in Table 7-2, this land use is a permitted use subject to Site Approval by the County. For the purposes of this analysis, the alternative land use is a gas station with a convenience market. The gas station would have 12 fuel dispensing pumps. This station would serve passenger cars and lighter trucks. No heavy-duty trucks would be served. In addition, there would be no fast-food restaurant attached to this gas station. The Combination Gas Station is a permitted use in the C-FS zone, with Site Approval. The Kimley-Horn traffic analysis calculated vehicle trips for a gas station with convenience market, based on a trip generation figure provided by Trip Generation, 8

th

Edition, published by the Institute of Transportation Engineers. This alternative land use would generate approximately 1,954 trips, which is approximately 57% less than the 4,532 trips used to evaluate air quality impacts of the proposed Project. Given the reduced vehicle trips, impacts on the intersections and freeway ramp junctions would be reduced. As with the Reduced Project Size alternative, it is expected that intersections operating at LOS D with the proposed Project under cumulative conditions would likely operate at a minimally acceptable LOS C under this alternative. As indicated in the Project traffic analysis, however, LOS D and LOS F occurred under cumulative conditions with the proposed Project at the SR 12/North Thornton Road intersection during AM and PM peak hours, respectively. For the proposed Project, a mitigation measure requiring signal coordination at the three intersections studied in the traffic analysis was recommended. This same mitigation would apply under this alternative. Freeway ramp junctions would continue to operate at LOS D under both existing and cumulative conditions under this alternative and this alternative would contribute traffic to these unacceptable LOS. As any contribution of traffic to the ramp junctions operating at LOS D would be a significant impact, and because no feasible mitigation is available, as is the case for the proposed Project, the ramp junction impacts for this alternative would be significant and unavoidable under both existing and cumulative conditions. The potential elimination of heavy-duty truck traffic, however, may have a more positive effect on this issue. As such, though traffic generation may be reduced under this alternative, impacts under this alternative would be similar to the proposed Project. Reduction in traffic volumes would also reduce the amounts of air pollutant emissions that would be generated, particularly NOx emissions. Table 7-3 provides an estimate of the emissions generated by this alternative. As shown in Table 7-3, ROG, NOx and PM10 emissions under this alternative would be below the SJVAPCD significance thresholds. In addition, diesel particulate matter emissions would be reduced, thereby reducing the potential health risks associated with these emissions. The Combination Gasoline Station alternative would meet some of the Project objectives, as they related to providing freeway commercial services. However, it would not meet Project objectives related to providing services for trucks and providing a fast-food restaurant.


Alternative 4: Alternative Use – Retail with Fast-Food Restaurant As defined in County Code Section 9-115.555, “primary retail” includes retail establishments that provide a limited number of frequently or recurrently needed personal items or services for residents in an immediate neighborhood. These establishments shall be of appropriate size and scale to meet the above criteria. As noted in Table 7-2, this land use is a permitted use subject to Site Approval by the County. Typical uses include small grocery stores, barber shops, beauty parlors, and self-service laundromats. For this analysis, a small grocery store and a fast-food restaurant are assumed as an alternative land use. The grocery store would be the same size as the convenience market of the proposed Project – approximately 7,700 square feet. The fast-food restaurant would be the same size as that in the proposed Project – 3,000 square feet. No fuel dispensing services would be provided. The proposed retail and restaurant used are permitted in the C-FS zone, with both uses requiring Site Approval by the County. For the evaluation of traffic impacts, a trip generation figure for a supermarket, provided by Trip Generation, 8th Edition, was used (102.24 per 1,000 square feet). The trips for the fast-food restaurant are the same as calculated by the Kimley-Horn traffic analysis (1,490 trips). Based on these figures, this alternative land use would generate approximately 2,276 trips, which is approximately 50% less than the 4,532 trips used to evaluate air quality impacts of the proposed Project. Given the reduced vehicle trips, impacts on the intersections and freeway ramp junctions would be reduced. As with the Combination Gasoline Station alternative, it is expected that intersections operating at LOS D with the proposed Project under cumulative conditions would likely operate at a minimally acceptable LOS C under this alternative. As indicated in the Project traffic analysis, however, LOS D and LOS F occurred under cumulative conditions with the proposed Project at the SR 12/North Thornton Road intersection during AM and PM peak hours, respectively. For the proposed Project, a mitigation measure requiring signal coordination at the three intersections studied in the traffic analysis was recommended. This same mitigation would apply under this alternative. Freeway ramp junctions would continue to operate at LOS D under both existing and cumulative conditions under this alternative and this alternative would contribute traffic to these unacceptable LOS. As any contribution of traffic to the ramp junctions operating at LOS D would be a significant impact, and because no feasible mitigation is available, as is the case for the proposed Project, the ramp junction impacts for this alternative would be significant and unavoidable under both existing and cumulative conditions. The potential elimination of heavy-duty truck traffic may have a more positive effect on this issue. As such, though traffic generation may be reduced under this alternative, impacts under this alternative would be similar to the proposed Project. Reduction in traffic volumes would also reduce the amounts of air pollutant emissions that would be generated, particularly NOx emissions. As shown in Table 7-3, ROG, NOx and PM10 emissions under this alternative would be below the SJVAPCD significance thresholds. In addition, as with Alternative 3, diesel particulate matter


emissions would be reduced, as shown in Table 7-3. This would reduce the potential health risks associated with these emissions. The Retail with Fast-Food Restaurant alternative would meet some of the Project objectives, as they related to providing freeway commercial services. However, it would not meet Project objectives related to providing services for trucks, particularly fuel dispensing services.

7.4 ENVIRONMENTALLY SUPERIOR ALTERNATIVE

The No Project alternative would involve the least environmental effects of the alternatives considered in detail. The reduction in environmental impact associated with this alternative would be limited, as most of the potentially significant environmental effects of the Project would not occur or would be reduced to a less than significant level with proposed mitigation measures. In the event that the No Project alternative is considered the environmentally superior alternative, CEQA Guidelines Section 15126(d)(3) require the identification of an environmentally superior “build alternative.” The Combination Gasoline Station alternative would result in a reduction in environmental effects associated with air quality and traffic impacts as compared to the proposed Project. This alternative would generate the least traffic among all the alternatives considered in detail and is considered the environmentally superior alternative. The reduction in environmental impacts associated with this alternative would be limited, as most of the potentially significant environmental effects of the Project would be reduced to less than significant with proposed mitigation measures. However, as with the proposed Project, the ramp junction impacts for this alternative would be significant and unavoidable under both existing and cumulative conditions.


8.0 GROWTH-INDUCING IMPACTS

CEQA Guidelines Section 15126.2(d) requires that an EIR discuss the ways in which a project could foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment. Projects that could induce growth include those which involve the extension of new development into previously-undeveloped areas, projects which extend new infrastructure or remove physical or economic obstacles to population growth, or projects which encourage and facilitate other activities that could significantly affect the environment, either individually or cumulatively. The CEQA Guidelines note that it must not be assumed that growth in any area is necessarily beneficial, detrimental, or of little significance to the environment. Growth can be induced in a variety of ways. For example, some new development may create demands for other types of development; a large new industrial facility that creates numerous new jobs may increase or accelerate demands for housing. In an area of relative housing shortage, this effect could be growth-inducing in that new housing would need to be developed to meet the Project-related demand; however, the same Project in a labor surplus area may have no growth-inducing effect at all. Development of significant new amenities may also spur development of other land uses nearby. An example of this phenomenon would be the development of major new shopping or entertainment facilities that spur development of new residential areas or other related development in the vicinity. Growth can also be induced by removing obstacles to development or by reducing development costs. Growth inducement can result from development of new infrastructure (e.g., a new sewage treatment facility or potable water system) or the extension of street or utility infrastructure or other facilities to or near previously-unserved areas, stimulating development of these areas. However, the extension of new infrastructure, in conjunction with proposed development that would be served by the new facilities, may not have a distinguishable growth-inducing effect outside of its contribution to the overall development proposal. Growth may also be induced by a variety of government actions that permit, or that may promote, additional development. Such actions may include a general plan amendment or re-zoning that favors additional development, issuance of permits or approvals that establish new precedents for land development, and changes in policy that have the same result. Growth inducement itself is not an environmental effect but may lead to environmental effects. These environmental effects may include increased demand on other community and public services and infrastructure, increased traffic and noise, degradation of air or water quality, degradation or loss of plant or animal habitats, or conversion of agricultural and open space land to urban uses.


The Project involves a request for County approval of a Use Permit for the proposed commercial development. The requested action, if taken by the County, would be inherently economically growth-inducing, in that the purpose of the approval is to facilitate development of the proposed truck stop. The Project site is, however, already designated for freeway service commercial development by the San Joaquin County General Plan, pursuant to the General Plan amendment and zone reclassification for the site approved in early 2011. The Project site is also within CSA 31, which was established to provide utility service to the Flag City area, inclusive of the Project site. No additional general plan amendment or zone reclassification is needed to permit the Project. In this context, the Project would not be considered growth-inducing. The Project involves undeveloped land, including 5.1 acres of agricultural land, located adjacent to North Thornton Road within CSA 31 and Flag City. The development of the Project site for freeway service commercial uses is anticipated by its existing general plan designation and zoning. The site is bordered by existing commercial development or land planned for commercial development to the north, west and south. The site is adjacent to existing development; therefore, the Project would not involve “leap-frog” development. In this respect, the Project would not be considered growth-inducing. Lands to the east of the Project site are presently in agricultural use, and the potential for future development of these lands would be influenced to a minor degree by County action with respect to the Project. However, this agricultural area is designated and zoned for agricultural use and is not within the services boundary of any public utility entity. As a result, the Project would have a negligible growth-inducing effect on the adjoining agricultural lands to the east. Based on San Joaquin County growth policies, development of these lands would need to be preceded by several County legislative actions, including a change in the CSA 31 service boundary, an amendment of the County General Plan and zoning as well as subsequent development entitlements. All of these actions would need to be preceded by environmental review under CEQA. There are no development proposals currently being processed for this area. As a result, the Project would have a negligible growth-inducing effect on the adjoining agricultural lands to the east of the Project site. The Project would not involve the extension of any new urban infrastructure into the Project area. Streets, potable water, sewer, and storm drainage infrastructure adequate to serve the Project are already in place. With respect to the extension of utility services, the Project would not involve any growth-inducing effect. The Project would involve the development of approximately 11.68 acres of commercial development, providing vehicle fueling facilities and a limited range of retail commercial space. These facilities would be attractive primarily to travelers on I-5 and SR 12 but would not involve any substantial amenity influence on development of nearby lands. In addition, the Project would provide construction job opportunities; however, these jobs would not last beyond Project completion. The number of new permanent jobs resulting from Project operations would be too small to induce any new housing construction in the area. The Project would involve a negligible growth-inducing influence in this context.


9.0 IRREVERSIBLE ENVIRONMENTAL CHANGES

CEQA Guidelines Section 15126.2(c) requires that an EIR address any significant irreversible environmental changes that would result from implementation of a proposed project. Significant irreversible environmental changes could include conversion or use of substantial amounts of nonrenewable resources during the construction or operation of the project, or the commitment of resources to other uses, or to their permanent non-use. Resources that may be considered subject to irreversible change may include materials, land, energy or a project site’s state of development or non-development. Consumption, use or commitment of resources is considered irreversible when it is likely that future generations will be committed to similar uses. Irreversible damage can also result from environmental accidents associated with the project. CEQA suggests that irretrievable commitments of resources be evaluated to assure that such current consumption is justified. The proposed Project would involve an irreversible commitment of materials and energy consumption to the construction of the proposed commercial area. Construction materials would include sand and gravel, concrete, asphalt, plastics and metals, as well as various renewable materials such as glass. Energy use would occur as a result of operation of equipment used during construction. The construction materials would not be used in highly significant or unusual quantities, and they would be obtained from existing commercial sources. The Project would lead to relatively minor significant irreversible environmental changes. The Project would involve the conversion of approximately 5.1 acres of agricultural land from its present agricultural use to commercial use. The Project would entail an irreversible commitment of the 11.68-acre Project site as a whole to development; development and increases in the assessed value of the site would likely prohibit any return to agricultural or open space uses. Commitment of the Project site to commercial use would involve a small but irreversible loss of open space and its associated biological resource values. The Project would involve a small but irreversible reduction in groundwater recharge and associated increases in runoff during rainfall events. Groundwater recharge losses are not considered significant, and potential increases in runoff would be accommodated by the CSA 31 storm water drainage system. The Project would involve an irreversible commitment of energy resources to Project operation – greater than is currently committed to the Project site. However, the Project would be required to comply with regulations that are designed to promote energy conservation and efficiency, such as CALGREEN and Title 24 standards. The Project would not involve wasteful or inefficient use of energy. There are no other changes associated with the Project, or resources impacted by the Project, which are considered irreversible.


10.0 SOURCES

10.1 REFERENCES CITED

Baseline Environmental Consulting. 1992. Final Environmental Impact Report on the

San Joaquin County Comprehensive Planning program. May 1992. California Air Pollution Control Officers Association (CAPCOA). 1997. CAPCOA Air

Toxics “Hot Spots Program, Gasoline Service Station Industrywide Risk Assessment Guidelines. November 1997.

California Air Resources Board (CARB). Community Health Air Pollution Information

System (CHAPIS) California Air Resources Board. 2000. California Air Resources Board. Risk Reduction

Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles. October 2000.

California Air Resources Board. 2005. Air Quality and Land Use Handbook: A

Community Health Perspective. April 2005. California Air Resources Board. 2006. 2006 California Toxics Inventory.

http://www.arb.ca.gov/ei/cti.xls. California Department of Finance. 2011. Report E-5 – City/County Population and

Housing Estimates. January 1, 2011. California Department of Transportation. 2011. Annual Average Daily Traffic on the

California State Highway System. Flag City Design Guidelines (PA-0700226). Special Purpose Plan. July, 2007. Gent, Janneane F. et al. 2003. “Association of Low-Level Ozone and Fine Particles

With Respiratory Symptoms In Children With Asthma.” Journal of the American Medical Association, October 8, 2003.

Kimley-Horn and Associates. 2011. Traffic Impact Analysis – Love’s Travel Stop and

Country Store/Arby’s (PA-10-131), Flag City, California. Final, January 31, 2011. Kimley-Horn and Associates. 2012. Traffic Impact Analysis Update – Love’s Travel

Stop and Country Store/Arby’s, Flag City, California. August 9, 2012. Maslovski, Andy. 2008. “Gasoline/Diesel Fuel Transport.” Well Servicing Magazine,

July 2008.


Mintier Harnish Planning Consultants. 2009. San Joaquin County General Plan,

Background Report, Public Review Draft. July 2, 2009. Omni-Means. 2011. Memorandum Re: Flag City Love’s Traffic Study Peer Review.

June 13, 2011. San Joaquin Council of Governments. 2007. Final Report – Park-and-Ride Lot Master

Plan. San Joaquin County Public Works Department – Mapping 1999. San Joaquin County Community Development Department. 1998. Initial Study, Pilot

Flying J Travel Plaza and Thornton Road Realignment, File No. UP-98-7 and PP-98-3. May 28, 1998.

San Joaquin County Community Development Department. 1999. Initial Study, Flying J

Travel Plaza and Thornton Road Realignment One-Year Extension, File No. UP-98-7 and PP-98-3. September 13, 1999.

San Joaquin County Community Development Department. 2001. General Plan

Amendment and Zone Reclassification, Highway 12 Investors, File No. PA-1000183 and PA-1000184. March 7, 2011.

San Joaquin Local Agency Formation Commission. 2007. Policies and Procedures.

September 21, 2007. San Joaquin Local Agency Formation Commission. 2009. Service Review and Sphere

of Influence Update for Sanitary Sewer Services in San Joaquin County. May 15, 2009.

San Joaquin Local Agency Formation Commission. 2011. Executive Officer’s Report –

Thornton Road Annexation to County Service Area 31-Flag City and County Service Area No. 31-Zone W and Amendment to the Sphere of Influence (LAFC 32-10). April 15, 2011.

San Joaquin Regional Transit District (SJRTD). 2009. Short Range Transit Plan Fiscal

Year 2009-2013, Public Draft. San Joaquin Valley Unified Air Pollution Control District (SJVAPCD). 2002. Guide for

Assessing and Mitigating Air Quality Impacts. Adopted August 20, 1998, revised January 10, 2002.

San Joaquin Valley Unified Air Pollution Control District. 2002b. Guide for Assessing

and Mitigating Air Quality Impacts Technical Document: Information for Preparing Air Quality Sections in EIRs. Adopted August 20, 1998, revised January 10, 2002.


San Joaquin Valley Unified Air Pollution Control District. 2006. 2006 Annual Report on the District’s Air Toxics Program.

U.S. Geological Survey. 7.5 minute Terminous and Thornton South Quadrangle Maps. Wood Rodgers, Inc. 2011. 1010“Love’s Travel Stop & Country Store/Arby’s, Flag City,

San Joaquin County, Technical Peer Review of Traffic Impact Analysis.” Memorandum from Ravi Narayanan, P.E., T.E.to Tom Terpstra, July 6, 2011.

10.2 WEBSITES CONSULTED

California Air Resources Board. http://www.arb.ca.gov/toxics/cti/hlthrisk/cncrinhl/rskmapvwtrend.htm

http://www.arb.ca.gov/html/aqe&m.htm http://www.arb.ca.gov/cc/factsheets/cc_newfs.pdf

California Department of Transportation.

http://www.dot.ca.gov/hq/traffops/saferesr/trafdata/index.htm http://www.flagcityrvresort.com/travel.html San Joaquin Council of Governments.

http://www.sjcog.org/Programs%20&%20Projects/Habitat_files/Habitat-Main-page.htm

10.3 PERSONS CONSULTED

Shuffield, Rick. Director of Real Estate & Development. Love’s Travel Stops/Country Store

Conklin, Chris. Vice President, Grupe Commercial Company Keyser, Dan. Senior Vice President, Grupe Commercial Company Weir, Matt, PE, TE, PTDE. Kimley-Horn Associates Inc.

10.4 EIR PREPARERS

Charlie Simpson, Senior Principal Professional, Kleinfelder Trevor Smith, Senior Professional, Kleinfelder Terry Farmer, Project Professional, Kleinfelder


Amy Gartin, Staff Professional II, Kleinfelder Victoria Jordan, Assistant Project Manager, Kleinfelder Russ Erbes, Senior Principal Air Quality Specialist, Kleinfelder Chuck Cleeves, Program Manager, Kleinfelder Estee Lafrenz, Project Professional, Kleinfelder

draft environmental impact report: love's travel stops

Documents

Transcript of draft environmental impact report: love's travel stops