Appendices G - Air Quality Technical Report
Espola Road Improvement Project
Appendix G
Air Quality Technical Report
Prepared for:
City of Poway
March 2013
1
ADDENDUM
to the
Air Quality Technical Report
for the
Espola Road Improvement Project
Poway, California
This addendum provides an update to the background air quality information presented in the Air
Quality Technical Report for the Espola Road Improvement Project by Scientific Resources
Associated in 2010, as shown in Tables 1 and 2 of this addendum. Since completion of the Air
Quality Technical Report in 2010, more recent background air quality information has become
available.
Background Air Quality
The San Diego Air Pollution Control District (APCD) operates a network of ambient air
monitoring stations throughout San Diego County. The purpose of the monitoring stations is to
measure ambient concentrations of the pollutants and determine whether the ambient air quality
meets the California Ambient Air Quality Standards (CAAQS) and the National Ambient Air
Quality Standards (NAAQS). The nearest ambient monitoring station to the Project site is the
Escondido station. Because of the location of the monitoring station near East Valley Parkway
in downtown Escondido, where there is substantial traffic congestion, the station sees higher
concentrations of CO than are measured elsewhere in San Diego County and the background
data may provide a highly conservative estimate of background concentrations along Espola
Road. Table 1 presents ambient concentrations of pollutants between 2006 and 2011 as recorded
at the Escondido station.
Table 2 provides a summary of the attainment status for each criteria pollutant within the SDAB
and the number of air quality violations at the monitoring station nearest to the site for the period
over the same period. The eight-hour federal and state O3 standards were exceeded multiple
times. Similarly, the one-hour state O3 standard was exceeded. The Escondido monitoring
station recorded exceedances of the state PM10 and PM2.5 standards; the highest measured values
were recorded during and following the 2007 fire events in San Diego County. The data from
the monitoring station indicate that air quality at the Escondido station is in attainment of all
other federal standards, with the exception of PM10. PM10 is designated as unclassifiable due to
available data supporting neither an attainment nor nonattainment status at the time of
designation.
2
Table 1
AMBIENT BACKGROUND CONCENTRATIONS
(ppm [unless otherwise indicated])
Pollutant Averaging
Time 2006 2007 2008 2009 2010 2011
Most
Stringent
Ambient
Air Quality
Standard
O3 8 hour 0.096 0.077 0.098 0.080 0.084 0.089 0.070
1 hour 0.108 0.094 0.116 0.093 0.105 0.098 0.09
PM101,2 Annual 24.2 µg/m3 26.9 µg/m3 24.7 µg/m3 24.6 µg/m3 21.0 µg/m3 18.8 µg/m3 20 µg/m3
24 hour 52 µg/m3 68 µg/m3 82 µg/m3 73 µg/m3 42 µg/m3 40 µg/m3 50 µg/m3
PM2.51,2 Annual 11.5 µg/m3 13.3 µg/m3 12.3 µg/m3 13.4 µg/m3 12.2 µg/m3 12.2 µg/m3 12 µg/m3
24 hour 40.6 µg/m3 151.0 µg/m3 44.0 µg/m3 78.3 µg/m3 48.4 µg/m3 67.7 µg/m3 35 µg/m3
NO2 Annual 0.017 0.016 0.018 0.016 0.014 0.013 0.030
1 hour 0.071 0.072 0.081 0.073 0.064 0.062 0.100
CO 8 hour 3.61 3.19 2.81 3.24 2.46 2.20 9.0
1 hour 5.7 5.2 4.6 4.4 NA 3.5 20
1Annual value is arithmetic mean; values shown are California measurements
2Highest particulate values measured during and following the 2007 San Diego County fires
Source: www.arb.ca.gov/aqd/aqd.htm (all pollutants except 1-hour CO and annual PM2.5)
www.epa.gov/air/data/monvals.html (1-hour CO, annual PM2.5)
NA = not available
Table 2
ATTAINMENT CLASSIFICATION AND NUMBER OF AIR QUALITY VIOLATIONS
AT THE NEAREST MONITORING STATION
Pollutant Averaging
Time
Attainment Status Number of Air Quality Violations
Federal State 2006 2007 2008 2009 2010 2011
Ozone 8 hour Marginal
Nonattainment Nonattainment 2 (Na),
11 (C)
0 (Na),
5 (C)
13 (N),
23 (C)
1 (N),
9 (C)
3 (N),
5 (C)
2 (N),
2 (C)
1 hour Attainment Nonattainment 3 (C) 0 (C) 9 (C) 0 (C) 2 (C) 1 (C)
PM10
Annual
Arithmetic
Mean
Unclassifiableb Nonattainment 1 (C) 1 (C) 1 (C) 1 (C) 1 (C) 0 (C)
24 hour Unclassifiableb Nonattainment 1 (C) 2 (C) 1 (C) 1 (C) 0 (C) 0 (C)
PM2.5
Annual
Arithmetic
Mean
Attainment Nonattainment 0 (C) 1 (C) 1 (C) 1 (C) 0 (C) 0 (C)
24 hour Attainment Nonattainment 1 (N) 11 (N) 1 (N) 2 (N) 2(N) 3 (N)
NO2 Annual Attainment Attainment 0 0 0 0 0 0
1 hour Attainment Attainment 0 0 0 0 0 0
CO 8 hour Attainment Attainment 0 0 0 0 0 0
1 hour Attainment Attainment 0 0 0 0 0 0
SO2
Annual Attainment Attainment 0 0 0 0 0 0
24 hour Attainment Attainment 0 0 0 0 0 0
3 hour Attainment Attainment 0 0 0 0 0 0
1 hour Attainment Attainment 0 0 0 0 0 0
(N) = NAAQS; (C) = CAAQS
a Number of violations in 2006 and 2007 based on previous NAAQS of 0.08 ppm.
bAt the time of designation, if the available data do not support a designation of attainment or nonattainment, the area is designated as
unclassifiable.
Air Quality Technical Report
for the
Espola Road Improvement Project
Poway, California
Submitted To:
HELIX Environmental Planning, Inc.
7578 El Cajon Blvd., Suite 200
La Mesa, CA 91942
Prepared By:
1328 Kaimalino Lane
San Diego, CA 92109
February 1, 2010
Table of Contents
1.0 Introduction ............................................................................................................ 1
2.0 Existing Conditions ................................................................................................ 2
2.1 Meteorology/Climate ...................................................................................... 2
2.2 Regulatory Setting .......................................................................................... 3
2.3 Background Air Quality ................................................................................ 9
3.0 Impacts .................................................................................................................. 11
3.1 Construction .................................................................................................. 11
3.2 Operational Impacts ..................................................................................... 15
3.3 Mobile Source Air Toxics ............................................................................. 29
4.0 Naturally-Occurring Asbestos ............................................................................ 36
5.0 Global Climate Change ....................................................................................... 37
6.0 Conclusions ........................................................................................................... 40
7.0 References ............................................................................................................. 42
Air Quality Impact Analysis 1 02/01/10
Espola Road Improvement Project
1.0 Introduction
This report presents an assessment of potential air quality impacts associated with the
proposed Espola Road Improvement Project in the City of Poway, California. The
evaluation addresses the potential for air emissions during construction and after full
buildout of the project, including an assessment of the potential for CO “hot spots” to
form due to traffic associated with the proposed project.
The proposed Espola Road Improvement Project involves improvements to Espola Road
to widen the road from two lanes from south of Titan Way to the intersection for Espola
Road and Twin Peaks Road. The project is evaluating four build alternatives. Three of
the four alternatives involve widening the roadway to four lanes. The Proposed Project
involves widening the roadway to three lanes.
This Air Quality Analysis is based on information on traffic provided in the Espola Road
Traffic Analysis (Katz, Okitsu & Associates 2006) that was prepared for the City of
Poway, and addresses traffic projections for 2010 and 2030. The Traffic Analysis
evaluated four separate scenarios:
Existing Conditions (2006)
Year 2010 Conditions – No Project
Year 2010 Project Opening Year
Year 2030 Conditions – No Project
Year 2030 Conditions – With Project
The Air Quality Analysis addresses the four separate scenarios that were evaluated in the
Traffic Analysis.
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Espola Road Improvement Project
2.0 Existing Conditions
2.1 Meteorology/Climate
The proposed project is located within the City of Poway along Espola Road, between
Titan Way and Rattlesnake Creek. The climate of San Diego County is dominated by a
semi-permanent high pressure cell located over the Pacific Ocean. This cell influences
the direction of prevailing winds (westerly to northwesterly) and maintains clear skies for
much of the year. Figure 1 provides a graphic representation of the prevailing winds in
the project vicinity, as measured at Marine Corps Air Station Miramar (the closest
meteorological monitoring station to the site). The high pressure cell also creates two
types of temperature inversions that may act to degrade local air quality.
Subsidence inversions occur during the warmer months as descending air associated with
the Pacific high pressure cell comes into contact with cool marine air. The boundary
between the two layers of air creates a temperature inversion that traps pollutants. The
other type of inversion, a radiation inversion, develops on winter nights when air near the
ground cools by heat radiation and air aloft remains warm. The shallow inversion layer
formed between these two air masses also can trap pollutants. As the pollutants become
more concentrated in the atmosphere, photochemical reactions occur that produce ozone,
commonly known as smog.
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Espola Road Improvement Project
Figure 1. Wind Rose – Marine Corps Air Station Miramar
2.2 Regulatory Setting
Air quality is defined by ambient air concentrations of specific pollutants identified by
the United States Environmental Protection Agency (EPA) to be of concern with respect
to health and welfare of the general public. The EPA is responsible for enforcing the
Federal Clean Air Act (CAA) of 1970 and its 1977 and 1990 Amendments. The CAA
required the EPA to establish National Ambient Air Quality Standards (NAAQS), which
identify concentrations of pollutants in the ambient air below which no adverse effects on
the public health and welfare are anticipated. In response, the EPA established both
primary and secondary standards for several pollutants (called “criteria” pollutants).
“Primary” NAAQS are set to protect public health with an adequate margin of safety, and
“secondary” NAAQS protect against adverse welfare effects (e.g., effects on vegetation,
ecosystems, visibility, manmade materials). The EPA has established NAAQS for ozone
(O3), carbon monoxide (CO), nitrogen dioxide (NO2), fine particulate matter (PM10 and
PM2.5), sulfur dioxide (SO2), and lead.
Air Quality Impact Analysis 4 02/01/10
Espola Road Improvement Project
The CAA allows states to adopt ambient air quality standards and other regulations
provided they are at least as stringent as federal standards. The California Air Resources
Board (ARB) has established the California Ambient Air Quality Standards (CAAQS) for
six criteria pollutants through the California Clean Air Act of 1988, and also has
established CAAQS for additional pollutants, including sulfates, hydrogen sulfide, vinyl
chloride and visibility-reducing particles.
The ARB is the state regulatory agency with authority to enforce regulations to both
achieve and maintain the NAAQS and CAAQS. The ARB is responsible for the
development, adoption, and enforcement of the state’s motor vehicle emissions program,
as well as the adoption of the CAAQS. The ARB also reviews operations and programs
of the local air districts, and requires each air district with jurisdiction over a
nonattainment area to develop its own strategy for achieving the NAAQS and CAAQS.
The local air district has the primary responsibility for the development and
implementation of rules and regulations designed to attain the NAAQS and CAAQS, as
well as the permitting of new or modified sources, development of air quality
management plans, and adoption and enforcement of air pollution regulations. The San
Diego County Air Pollution Control District (APCD) is the local agency responsible for
the administration and enforcement of air quality regulations for San Diego County.
Each of the regulated pollutants and their health effects of concern are discussed below.
The CAAQS and NAAQS for each of these pollutants are shown in Table 1.
Ozone. Ozone is considered a photochemical oxidant, which is a chemical formed when
reactive organic compounds (ROC) and nitrogen oxides, both byproducts of combustion,
react in the presence of ultraviolet light. Ozone is considered a respiratory irritant and
prolonged exposure can reduce lung function, aggravate asthma, and increase
susceptibility to respiratory infections. Children and those with existing respiratory
diseases are at greatest risk from exposure to ozone.
Air Quality Impact Analysis 5 02/01/10
Espola Road Improvement Project
Carbon monoxide. Carbon monoxide is a product of combustion, and the main source
of carbon monoxide in the SDAB is from motor vehicle exhaust. CO is an odorless,
colorless gas. CO affects red blood cells in the body by binding to hemoglobin and
reducing the amount of oxygen that can be carried to the body’s organs and tissues. CO
can cause health effects to those with cardiovascular disease, and also can affect mental
alertness and vision.
Nitrogen dioxide. NO2 is also a by-product of fuel combustion, and is formed both
directly as a product of combustion and in the atmosphere through the reaction of NO
with oxygen. NO2 is a respiratory irritant and may affect those with existing respiratory
illness, such as asthma. NO2 can also increase the risk of contracting respiratory illness.
Particulate matter. Particulate matter, or PM10, refers to particulate matter with an
aerodynamic diameter of 10 microns or less. Fine particulate matter, or PM2.5, refers to
particulate matter with an aerodynamic diameter of 2.5 microns or less. Particulate
matter in this size range has the potential to lodge in the lungs and contribute to
respiratory problems. PM10 and PM2.5 arise from a variety of sources, including road
dust, diesel exhaust, combustion, tire and break wear, construction operations, and
windblown dust. PM10 and PM2.5 can increase susceptibility to respiratory infections and
can aggravate existing respiratory diseases such as asthma and chronic bronchitis. PM2.5
is considered to have the potential to lodge deeper in the lungs.
Sulfur dioxide. SO2 is a colorless, reactive gas that is produced from the burning of
sulfur-containing fuels such as coal and oil, and by other industrial processes. Generally,
the highest concentrations of SO2 are found near large industrial sources. SO2 is a
respiratory irritant that can cause narrowing of the airways, leading to wheezing and
shortness of breath. Long-term exposure to SO2 can cause respiratory illness and
aggravate existing cardiovascular disease.
Air Quality Impact Analysis 6 02/01/10
Espola Road Improvement Project
Table 1
Ambient Air Quality Standards
POLLUTANT AVERAGE
TIME
CALIFORNIA STANDARDS NATIONAL STANDARDS
Concentration Measurement
Method Primary Secondary Measurement
Method
Ozone
(O3)
1 hour 0.09 ppm
(180 g/m3)Ultraviolet
Photometry
-- -- Ethylene
Chemiluminescence8 hour 0.070 ppm
(137 g/m3)
0.075 ppm
(147 g/m3)
0.075 ppm
(147 g/m3)
Carbon
Monoxide
(CO)
8 hours 9.0 ppm
(10 mg/m3)
Non-Dispersive
Infrared
Spectroscopy
(NDIR)
9 ppm
(10 mg/m3)None
Non-Dispersive
Infrared
Spectroscopy
(NDIR) 1 hour 20 ppm
(23 mg/m3)
35 ppm
(40 mg/m3)
Nitrogen
Dioxide
(NO2)
Annual
Average
0.030 ppm
(56 g/m3)Gas Phase
Chemiluminescence
0.053 ppm
(100 g/m3)
0.053 ppm
(100 g/m3) Gas Phase
Chemiluminescence1 hour 0.18 ppm
(338 g/m3)-- --
Sulfur Dioxide
(SO2)
Annual
Average --
Ultraviolet
Fluorescence
0.03 ppm
(80 g/m3)--
Pararosaniline
24 hours 0.04 ppm
(105 g/m3)
0.14 ppm
(365 g/m3)--
3 hours -- -- 0.5 ppm
(1300 g/m3)
1 hour 0.25 ppm
(655 g/m3)-- --
Respirable
Particulate
Matter
(PM10)
24 hours 50 g/m3
Gravimetric or Beta
Attenuation
150 g/m3 150 g/m3 Inertial Separation
and Gravimetric
Analysis
Annual
Arithmetic
Mean
20 g/m3 -- --
Fine
Particulate
Matter
(PM2.5)
Annual
Arithmetic
Mean
12 g/m3 Gravimetric or Beta
Attenuation
15 g/m3 15 g/m3 Inertial Separation
and Gravimetric
Analysis 24 hours -- 35 g/m3 35 g/m3
Sulfates 24 hours 25 g/m3 Ion Chromatography ---- --
Lead
(Pb)
30-day
Average 1.5 g/m3
Atomic Absorption
-- --
Atomic Absorption Calendar
Quarter -- 1.5 g/m3 1.5 g/m3
Hydrogen
Sulfide
(H2S)
1 hour 0.03 ppm
(42 g/m3)
Ultraviolet
Fluorescence -- -- --
Vinyl Chloride 24 hours 0.010 ppm
(26 g/m3) Gas Chromatography-- -- --
Air Quality Impact Analysis 7 02/01/10
Espola Road Improvement Project
Table 1 (cont.)
Ambient Air Quality Standards
Visibility
Reducing
Particles
8 hours
Extinction
coefficient of
0.23 per
kilometer —
visibility of
ten miles or
more due to
particles when
relative
humidity is
less than
70 percent.
Beta Attenuation and
Transmittance
through Filter Tape.
-- -- --
ppm= parts per million
g/m3 = micrograms per cubic meter
mg/m3= milligrams per cubic meter
Source: California Air Resources Board 2008
Lead. Lead in the atmosphere occurs as particulate matter. Lead has historically been
emitted from vehicles combusting leaded gasoline, as well as from industrial sources.
With the phase-out of leaded gasoline, large manufacturing facilities are the sources of
the largest amounts of lead emissions. Lead has the potential to cause gastrointestinal,
central nervous system, kidney, and blood diseases upon prolonged exposure. Lead also
is classified as a probable human carcinogen.
Sulfates. Sulfates are the fully oxidized ionic form of sulfur. In California, emissions of
sulfur compounds occur primarily from the combustion of petroleum-derived fuels (e.g.,
gasoline and diesel fuel) that contain sulfur. This sulfur is oxidized to sulfur dioxide
(SO2) during the combustion process and subsequently converted to sulfate compounds in
the atmosphere. The conversion of SO2 to sulfates takes place comparatively rapidly and
completely in urban areas of California due to regional meteorological features. The
ARB's sulfates standard is designed to prevent aggravation of respiratory symptoms.
Effects of sulfate exposure at levels above the standard include a decrease in ventilatory
function, aggravation of asthmatic symptoms, and an increased risk of cardio-pulmonary
disease. Sulfates are particularly effective in degrading visibility, and, due to fact that
they are usually acidic, also can harm ecosystems and damage materials and property.
Air Quality Impact Analysis 8 02/01/10
Espola Road Improvement Project
Hydrogen Sulfide. H2S is a colorless gas with the odor of rotten eggs. It is formed
during bacterial decomposition of sulfur-containing organic substances. Also, it can be
present in sewer gas and some natural gas, and can be emitted as the result of geothermal
energy exploitation. Breathing H2S at levels above the standard will result in exposure to
a very disagreeable odor. In 1984, an ARB committee concluded that the ambient
standard for H2S is adequate to protect public health and to significantly reduce odor
annoyance.
Vinyl Chloride. Vinyl chloride, a chlorinated hydrocarbon, is a colorless gas with a
mild, sweet odor. Most vinyl chloride is used to make polyvinyl chloride (PVC) plastic
and vinyl products. Vinyl chloride has been detected near landfills, sewage plants, and
hazardous waste sites, due to microbial breakdown of chlorinated solvents. Short-term
exposure to high levels of vinyl chloride in air causes central nervous system effects,
such as dizziness, drowsiness, and headaches. Long-term exposure to vinyl chloride
through inhalation and oral exposure causes liver damage. Cancer also is a major
concern; inhalation of vinyl chloride has been shown to increase the risk of
angiosarcoma, a rare form of liver cancer in humans.
Visibility Reducing Particles. Visibility-reducing particles consist of suspended
particulate matter, which is a complex mixture of tiny particles that consists of dry solid
fragments, solid cores with liquid coatings, and small droplets of liquid. These particles
vary greatly in shape, size and chemical composition, and can be made up of many
different materials such as metals, soot, soil, dust, and salt. The Statewide standard is
intended to limit the frequency and severity of visibility impairment due to regional haze.
In the state of California, hydrogen sulfide is only monitored at 13 sites, none of which
are located in San Diego County. Vinyl chloride has been measured at various locations
in the state where elevated levels are anticipated or for toxic air contaminant studies.
Visibility-reducing particles are not monitored separately except in areas, such as the
Lake Tahoe Air Basin, where regional haze may cause an adverse impact to visibility.
Because the project site is not located near any substantial sources of hydrogen sulfide or
Air Quality Impact Analysis 9 02/01/10
Espola Road Improvement Project
vinyl chloride (such as industrial or chemical plants, landfills, sewage plants, or
hazardous waste sites), it is not anticipated that levels of hydrogen sulfide or vinyl
chloride would be above the CAAQS.
In summary, health-based air quality standards have been established by California and
the federal government for the following criteria air pollutants: O3, CO, NO2, particulate
matter with a diameter of 10 microns or less (PM10), PM2.5, SO2, and lead. The CAAQS
are more stringent than the federal standards. California also has established standards
for sulfate, visibility, hydrogen sulfide, and vinyl chloride. Hydrogen sulfide, vinyl
chloride, and visibility-reducing particles currently are not monitored in the Basin
because these contaminants are not assessed as posing a significant air quality problem.
Areas that do not meet the NAAQS or the CAAQS for a particular pollutant are
considered to be “nonattainment areas” for that pollutant. In December 2002, the San
Diego APCD submitted a maintenance plan for the 1-hour NAAQS for O3 and requested
redesignation from a serious O3 nonattainment area to attainment. As of July 28, 2003,
the SDAB was reclassified as an attainment area for the 1-hour NAAQS for O3. On April
15, 2004, the SDAB was classified as a basic nonattainment area for the 8-hour NAAQS
for O3. The SDAB is an attainment area for the NAAQS for all other criteria pollutants.
The SDAB is currently classified as a nonattainment area under the CAAQS for O3 and
PM10.
2.3 Background Air Quality
The APCD operates a network of ambient air monitoring stations throughout San Diego
County. The purpose of the monitoring stations is to measure ambient concentrations of
the pollutants and determine whether the ambient air quality meets the CAAQS and the
NAAQS. The nearest ambient monitoring station to the project site is the Escondido
station. Because the Escondido monitoring station is located in downtown Escondido
where there is substantial traffic congestion, pollutant concentrations may be higher than
at the project site. Table 2 provides a summary of the attainment status for each criteria
pollutant within the SDAB and the number of air quality violations at the monitoring
Air Quality Impact Analysis 10 02/01/10
Espola Road Improvement Project
stations nearest to the site for the period from 2006 through 2008. Ambient
concentrations of pollutants over the last three years are presented in Table 3.
Table 2
Attainment Classification
and Number of Air Quality Violations at the Nearest Monitoring Station
Pollutant Averaging
Time
Attainment StatusNumber of Air Quality Violations
FederalState20062007 2008
Ozone 8 hour Nonattainment Nonattainment 2 (Na),
11 (C)
0 (Na),
5 (C)
13 (N),
23 (C)
1 hour N/A Nonattainment 3 (C)0 (C) 9 (C)
PM10
Annual
Arithmetic
Mean
Attainment Nonattainment 1 (C) 1 (C) 1 (C)
24 hour Attainment Nonattainment 1 (C)2 (C) 1 (C)
PM2.5
Annual
Arithmetic
Mean
Attainment Nonattainment 0 (C) 1 (C) 1 (C)
24 hour Attainment Nonattainment 1 (N)11 (N) 1 (N)
NO2 Annual AttainmentAttainment00 0
1 hour AttainmentAttainment00 0
CO 8 hour MaintenanceAttainment00 0
1 hour MaintenanceAttainment00 0
SO2 Annual AttainmentAttainment00 0
24 hour AttainmentAttainment00 0
3 hour AttainmentAttainment00 0
1 hour AttainmentAttainment00 0
NOTE: (N) = NAAQS; (C) = CAAQS
aNumber of violations in 2006 and 2007 based on previous NAAQS of 0.08 ppm.
Table 3
Ambient Background Concentrations
ppm (unless otherwise indicated)
Pollutant Averaging
Time 2006 2007 2008
Most
Stringent
Ambient Air
Quality
Standard
Monitoring
Station
O3 8 hour 0.0960.0770.0980.070 Escondido
1 hour 0.1080.0940.1160.09 Escondido
PM101,2 Annual 24.2 µg/m3 26.9 µg/m3 24.7 µg/m3 20 µg/m3 Escondido
24 hour 52 µg/m3 68 µg/m3 82 µg/m3 50 µg/m3 Escondido
PM2.51.2 Annual 11.5 µg/m3 13.3 µg/m3 12.3 µg/m3 12 µg/m3 Escondido
24 hour 40.6 µg/m3 151.0 µg/m3 37.3 µg/m3 35 µg/m3 Escondido
NO2 Annual 0.0170.0160.0180.030 Escondido
1 hour 0.0710.0720.0810.18 Escondido
CO 8 hour 3.613.192.819.0 Escondido
1 hour 5.75.24.620 Escondido
1Annual value is arithmetic mean; values shown are California measurements
2Highest particulate values measured during and following the 2007 San Diego County fires
Source: www.arb.ca.gov/aqd/aqd.htm (all pollutants except 1-hour CO and annual PM2.5)
www.epa.gov/air/data/monvals.html (1-hour CO, annual PM2.5)
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The previous 8-hour federal ozone standard of 0.08 ppm was exceeded twice in 2006 at
the Escondido monitoring station during the time period from 2006 – 2008. No
exceedances of the federal standard were recorded in 2007. The new 8-hour federal
ozone standard of 0.075 ppm was exceeded 13 times in 2008. Periodic exceedances of
the state ozone standards were observed. The Escondido monitoring station recorded
exceedances of the state PM10 and PM2.5 standards; the highest measured values were
recorded during the 2007 fire events in San Diego County. The data from the monitoring
station indicate that air quality at the Escondido station is in attainment of all other
federal standards.
Because of the location of the monitoring station near East Valley Parkway in downtown
Escondido, the station sees higher concentrations of CO than are measured elsewhere in
San Diego County and the background data may provide a highly conservative estimate
of background concentrations along Espola Road.
3.0 Impacts
The proposed Espola Road Improvement Project includes both construction and
operation of the roadway. The proposed Espola Road Improvement Project involves
improvements to Espola Road to widen the road from two lanes to either three or four
lanes from south of Titan Way to the intersection of Espola Road and Twin Peaks Road.
3.1 Construction
The emissions of NOx, CO, SOx and PM10 associated with of the Project were evaluated
against the criteria derived from the San Diego APCD’s Rule 20.3. Because no criterion
exists in Rule 20.3 for ROC, the threshold criterion for ROC was obtained from the City
of San Diego Significance Determination Thresholds (City of San Diego 2007). The
significance criteria based on Rule 20.3 are as follows:
250 lbs per day or 40 tons per year of NOx
550 lbs per day or 100 tons per year of CO
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250 lbs per day or 40 tons per year of sulfur oxides (SOx)
100 lbs per day or 15 tons per year of PM10
137 lbs per day or 15 tons per year of ROC
Emissions from the construction phase of the project were estimated through the use of
emission factors from the ARB’s OFFROAD 2007 Model for construction equipment. It
was assumed that heavy construction equipment would be operating at the site for eight
hours per day, six days per week during project construction. Based on the length of road
that would be affected by the project (approximately 1.44 miles) and assuming that the
widening would affect 25 feet on each side of the existing roadway, it was estimated that
approximately 12.1 acres (worst case for a four-lane scenario) would be graded during
the initial construction phase. The construction activities include the following:
1. Grading - 2 months;
2. Pavement construction - 2-3 months;
Table 4 presents estimates of the heavy equipment required for each phase of
construction.
Fugitive dust emissions were estimated using the URBEMIS2007 emission factor for
construction of 20 lbs per acre per day of construction, assuming the 12.1 acres would be
graded during the initial two months of construction with a maximum of 25% of the site
subject to grading in any single day.
Construction may also include minor amounts of blasting to remove large boulders. The
use of explosives can generate fugitive dust, and minor amounts of CO and other
emissions. Blasting, if required, will be sporadic and will not be expected to generate
significant amounts of emissions.
Air Quality Impact Analysis 13 02/01/10
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Table 4
Construction Equipment
EQUIPMENT NUMBER
Grading Phase
Bulldozers 2
Graders 2
Loaders 2
Backhoes 2
Dump Trucks 2
Water Trucks 2
Pavement Construction
Concrete Trucks/Mixers 4
Steam Rollers 2
Paving Machine 1
Supply Trucks 4
Table 5 provides a summary of the emission estimates for the construction phase of the
proposed project, assuming no measures are implemented to reduce emissions.
Emissions of SOx and lead are anticipated to be negligible, and required no further
evaluation. Attachment A to this Report provides the detailed calculations for
construction emissions.
Project construction emissions would be less than the significance criteria for short-term
emissions. Project construction emissions would also be below the annual significance
criteria for all pollutants. In addition, standard measures to reduce emissions of fugitive
dust would be employed to further reduce emissions of PM10 and PM2.5.
Air Quality Impact Analysis 14 02/01/10
Espola Road Improvement Project
Table 5
Estimated Construction Emissions
Emission Source CO ROC NOx SOx PM10 PM2.5
lbs/day
Grading
Grading Fugitive Dust - - - - 60.50 12.71
Heavy Construction
Equipment 91.99 23.07 193.20 0.18 9.66 8.60
Worker Travel – Vehicle
Emissions 6.09 0.45 0.62 0.01 0.05 0.05
Construction Truck
Emissions 2.61 0.59 6.53 0.01 0.32 0.32
TOTAL 100.69 24.11 200.35 0.2 70.53 21.68
Significance Criteria 550 137 250 250 100 55
Significant? No No No No No No
Paving
Heavy Construction
Exhaust Emissions 17.79 5.79 34.27 0.03 2.92 2.60
Worker Travel – Vehicle
Emissions 6.09 0.45 0.62 0.01 0.05 0.05
Construction Truck
Emissions 2.61 0.59 6.53 0.01 0.32 0.32
TOTAL 26.49 6.83 41.42 0.05 3.29 2.97
Significance Criteria 550 137 250 250 100 55
Significant? No No No No No No
Tons/yr
Grading
Grading Fugitive Dust - - - - 0.12 0.025
Heavy Construction
Equipment 11.50 2.88 24.15 0.02 1.21 1.08
Worker Travel – Vehicle
Emissions 0.76 0.06 0.08 0.0007 0.006 0.006
Construction Truck
Emissions 0.33 0.07 0.82 0.001 0.04 0.04
TOTAL 12.59 3.01 25.05 0.0217 1.376 1.151
Significance Criteria 100 15 40 40 15 10
Significant? No No No No No No
Paving
Heavy Construction
Exhaust Emissions 2.22 0.72 4.28 0.00 0.37 0.33
Worker Travel – Vehicle
Emissions 0.76 0.06 0.08 0.00 0.007 0.006
Construction Truck
Emissions 0.33 0.07 0.82 0.001 0.04 0.04
TOTAL 3.31 0.85 5.18 0.001 0.417 0.376
Significance Criteria 100 15 40 40 15 10
Significant? No No No No No No
Air Quality Impact Analysis 15 02/01/10
Espola Road Improvement Project
Measures to reduce the amount of fugitive dust generated from construction of the
proposed project include the following:
Water exposed surface twice daily
Maintain speeds on unpaved areas at 15 mph (24 km/hr) or less
Apply water to unpaved roads three times daily, or non-toxic soil stabilizers
according to manufacturer’s specifications to all unpaved parking or staging areas or
unpaved road surfaces
Apply non-toxic soil stabilizers according to manufacturers’ specification to all
inactive construction areas (previously graded areas inactive for ten days or more)
Replace ground cover in disturbed areas as quickly as possible
Enclose, cover, water twice daily or apply non-toxic soil binders according to
manufacturers’ specifications, to exposed piles (i.e., gravel, sand, dirt) with 5% or
greater silt content
Suspend all excavating and grading operations when wind speeds (as instantaneous
gusts) exceed 25 mph
Sweep streets at the end of the day if visible soil material is carried on to adjacent
public paved roads
3.2 Operational Impacts
To determine whether the Project will be consistent with local air quality plans and
programs, an affirmative regional conformity determination must be made before a
project may proceed. The purpose of the regional conformity determination is to
demonstrate that the projects included in the conformity determination will not cause or
contribute to a violation of an ambient air quality standard. The SDAB is currently
considered to be a basic nonattainment area for the NAAQS for ozone; therefore the
conformity determination must address regional transportation projects and include the
projects in the assessment conducted for the State Implementation Plan (SIP), which
includes emissions budgets for the air basin and strategies to attain and maintain the
ozone standard.
Air Quality Impact Analysis 16 02/01/10
Espola Road Improvement Project
Because the project does not increase ADT, and serves only to reduce congestion along
Espola Road, the project would not result in increases in air emissions associated with
traffic. The project would therefore not result in operational impacts associated with
emissions above the quantitative significance thresholds.
In addition, all projects except those that are exempt from analysis are subject to a local
CO impact review. This involves an evaluation of the potential for CO “hot spots” to
result due to traffic congestion. CO “hot spots” are typically evaluated when (a) the level
of service (LOS) of an intersection or roadway decreases to a LOS D or worse; and (b)
sensitive receptors such as residences, commercial developments, schools, hospitals, etc.
are located in the vicinity of the affected intersection or roadway segment.
The Protocol provides guidance for determining whether a project would have the
potential to cause or contribute to a violation of an air quality standard on a localized
basis. The Protocol provides for various levels for the regional and local CO analysis to
make the determination of the potential for adverse air quality impacts.
No analysis is required for projects that are exempt from all emissions analyses. These
projects include the following projects:
Safety
Railroad/highway crossing
Hazard elimination program
Safer non-Federal-aid system roads
Shoulder improvements
Increasing sight distance
Safety improvement program
Traffic control devices and operating assistance other than signalization projects
Railroad/highway crossing warning devices
Guardrails, median barriers, crash cushions
Pavement resurfacing and/or rehabilitation
Pavement marking demonstration
Emergency relief (23 U.S.C. 125)
Fencing
Air Quality Impact Analysis 17 02/01/10
Espola Road Improvement Project
Skid treatments
Safety roadside rest areas
Adding medians
Truck climbing lanes outside the urbanized area
Lighting improvements
Widening narrow pavements or reconstructing bridges (no additional travel lanes)
Emergency truck pullovers
Mass Transit
Operating assistance to transit agencies
Purchase of support vehicles
Rehabilitation of transit vehicles
Purchase of office, shop, and operating equipment for existing facilities
Purchase of operating equipment for vehicles (e.g. radios, fareboxes, lifts, etc.)
Construction of renovation of power, signal, and communications systems
Construction of small passenger shelters and information kiosks
Reconstruction or renovation of transit buildings and structures (e.g., rail or bus
buildings, storage and maintenance facilities, stations, terminals, and ancillary
equipment
Rehabilitation or reconstruction of track structures, track and track bed in existing
right-of-way
Purchase of new buses and rail cars to replace existing vehicles or for minor
expansions of the fleet
Construction of new bus or rail storage/maintenance facilities categorically
excluded in 23 CFR Part 771
Air Quality
Continuation of ride-sharing and van-pooling promotion activities at current level
Bicycle and pedestrian facilities
The Espola Road Traffic Analysis (Katz, Okitsu & Associates 2006) evaluated whether
or not there would be a decrease in the level of service at the intersections affected by the
Project. The potential for CO “hot spots” was evaluated based on the results of the
Traffic Analysis. CO “hot spots” are typically evaluated when (a) the level of service
(LOS) of an intersection or roadway decreases to a LOS D or worse; (b) signalization
and/or channelization is added to an intersection; and (c) sensitive receptors such as
residences, commercial developments, schools, hospitals, etc. are located in the vicinity
of the affected intersection or roadway segment. The traffic analysis evaluated whether a
Air Quality Impact Analysis 18 02/01/10
Espola Road Improvement Project
decrease in the level of service (LOS) at intersections and roadway segments in the
Project vicinity would occur during peak a.m. and p.m. periods.
The traffic analysis evaluated LOS at the following roadway segments:
Espola Road between Ezra Lane and Twin Peaks Road
Espola Road between Twin Peaks Road and Durhullen Drive
Espola Road between Durhullen Drive and Del Poniente
Espola Road between Del Poniente and Titan Way
Espola Road between Titan Way and Bounty Way
Twin Peaks Road West of Espola Road
Twin Peaks Road East of Espola Road
The traffic analysis evaluated LOS at the following four intersections:
- Espola Road and Titan Way/Eden Grove
- Espola Road and Del Poniente/High Valley Road
- Espola Road and Durhullen Drive/Golden Sunset
- Espola Road and Twin Peaks Road
Based on the Traffic Study, the LOS for each roadway segment and intersection is
expected to improve to LOS D or better with implementation of the project
improvements.
Table 6 presents a comparison of the LOS for Existing Peak Hour Conditions, Year 2010
Conditions, and Year 2030 Conditions for the roadway segments analyzed in the Traffic
Study.
Air Quality Impact Analysis 19 02/01/10
Espola Road Improvement Project
Table 7 presents a comparison of the LOS for Existing Peak Hour Conditions, Year 2010
Conditions, and Year 2030 Conditions for the roadway segments analyzed in the Traffic
Study.
Table 6
Roadway Segment Level of Service
Intersection Existing
Conditions
2010 2030
No
Project
With
Project
No
Project
With
Project
Espola Road between Ezra Lane and Twin
Peaks Road
E E B F B
Espola Road between Twin Peaks Road and
Durhullen Drive
F F D F D
Espola Road between Durhullen Drive and
Del Poniente
F F C F C
Espola Road between Del Poniente and Titan
Way
F F C F C
Espola Road between Titan Way and Bounty
Way
A A A B A
Twin Peaks Road West of Espola Road B B B B B
Twin Peaks Road East of Espola Roada N/A N/A N/A N/A N/A
aThe City of Poway Transportation Master Plan Element does not classify Twin Peaks Road east of Espola Road.
Source: Katz, Okitsu & Associates, 2006
Table 7
Intersection Level of Service
Intersection Existing
Conditions
2010 2030
No
Project
With
Project
No
Project
With
Project
am Peak Hour
Espola Road and Twin Peaks Road C D D D D
Espola Road and Durhullen Drive/ Golden
Sunset
F F A F B
Espola Road and Del Poniente/High Valley
Road
B B B B B
Espola Road and Titan Way/Eden Grove C C C C C
pm Peak Hour
Espola Road and Twin Peaks Road C C C C C
Espola Road and Durhullen Drive/ Golden
Sunset
E F A F A
Espola Road and Del Poniente/High Valley
Road
B B B B B
Espola Road and Titan Way/Eden Grove B B B B B
Source: Katz, Okitsu & Associates, 2006
Air Quality Impact Analysis 20 02/01/10
Espola Road Improvement Project
As shown in Tables 6 and 7, the project will either improve the LOS in comparison with
the No Project scenario, or the LOS will be unchanged. The Transportation Project-
Level Carbon Monoxide Protocol (hereinafter referred to as the “Protocol”) is applicable
for the assessment of potential impacts of “project alternatives” as identified within the
scope of the EIR required by CEQA. The Protocol is designed to ensure that a
transportation project action conforms to an approved or promulgated air quality
implementation plan and to all applicable state and national ambient air quality standards.
In accordance with the Protocol, an affirmative regional conformity determination must
be made before a project may proceed. An affirmative determination can be made if the
project is included in the Regional Transportation Plan (RTP) for the area, and if the
project has not been altered in design concept or scope from that described in the RTP. In
addition, all projects except those that are exempt from analysis (those projects listed
above) are subject to a local CO impact review.
The following subsections present (1) the analysis that was conducted to determine the
possibility of regional impacts in accordance with the Protocol; and (2) the analysis that
was conducted to determine the possibility of local CO impacts in accordance with the
Protocol. The analyses follow the flow charts, reproduced in Figures 2 and 3 below, from
the Protocol.
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Air Quality Impact Analysis 23 02/01/10
Espola Road Improvement Project
Regional Impacts. The Protocol contains a conformity requirement decision flow chart
for new projects that is designed to assist in the evaluation of the requirements that apply
to the project. The flow chart contained in the Protocol was followed to determine the
level of analysis required for the Espola Road Improvement Project. The steps in the
analysis are as follows:
Step 3.1.1: Is this project exempt from all emissions analyses? No. The
project was determined not to be exempt from all emissions analyses.
Step 3.1.2: Is project exempt from regional emissions analyses? No. The
project was determined not to be exempt from regional emissions analyses.
Step 3.1.3: Is project locally defined as regionally significant? Yes. The
project is defined as a regionally significant project. In accordance with the
definitions contained in 40 CFR Part 93 (the federal conformity rule), a regionally
significant project means a transportation project that is on a facility which serves
regional transportation needs and would normally be included in the modeling of
a metropolitan area’s transportation network, including at a minimum all principal
arterial highways and all fixed guideway transit facilities that offer an alternative
to regional highway travel. Espola Road is a principal arterial roadway in the
North County area of San Diego County.
Step 3.1.4: Is project in a federal attainment area? No. The project is in a
federal nonattainment area for ozone; therefore, further analysis to determine the
potential for regional impacts is required.
Step 3.1.5: Is there a currently conforming RTP and TIP? Yes. The
proposed project is fully funded and is included in the 2030 San Diego Regional
Transportation Plan (RTP): Pathways for the Future (Table A.5-Phased Arterial
Projects – Revenue Constrained Plan, page A-17), 2007 Update. The project is
also included in the SANDAG 2008 Regional Transportation Improvement
Program (page 80). A conformity determination for both the 2030 RTP and the
2008 RTIP was made by USDOT on November 17, 2008 (USDOT 2008). The
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design concept and scope of the proposed project are consistent with the project
description in the 2030 RTP, the 2008 RTIP, and the assumptions in the
SANDAG regional emissions analysis. Therefore, the project would conform to
the SIP and no adverse regional air quality impact would occur as a result of the
project implementation.
Step 3.1.6: Is the project included in the regional emissions analysis
supporting the currently conforming RTP and TIP? Yes. The project as
originally defined was included in the currently conforming RTP and RTIP and
the current conformity analysis.
Step 3.1.7: Has project design concept and/or scope changed significantly
from that in regional analysis? No. The Espola Road Improvement Project as
currently defined has been included in the 2008 RTIP. The RTIP includes
regional modeling and a demonstration of conformity with the SIP based on
traffic and population growth projections for the region. The project is therefore
in a currently conforming RTP and RTIP as designed. Based on inclusion of the
project in the currently conforming RTIP, the project has not changed design
concept and scope from that in the regional analysis.
In accordance with Section 4 of the Protocol, it is necessary to examine local impacts.
The local CO analysis is addressed in the following subsection.
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Espola Road Improvement Project
Local CO Impact Analysis. The Protocol provides guidance for determining whether a
project would have the potential to cause or contribute to a violation of an air quality
standard on a localized basis. The Protocol provides for various levels for the local CO
analysis to make the determination of the potential for adverse air quality impacts.
The Protocol contains a local CO analysis flow chart (reproduced above in Figure 3)
similar to the regional analysis flow chart that is designed to assist in the evaluation of the
requirements for demonstrating that the project will not cause an adverse air quality
impact. The flow chart contained in the Protocol was followed to determine the analysis
required for the Espola Road Improvement Project. The steps in the analysis contained in
the Protocol are as follows:
1. Is the project in a CO nonattainment area? No. The project is located in a
CO attainment area.
2. Was the area redesignated as “attainment” after the 1990 Clean Air Act?
Yes. The local area was redesignated as “attainment” for the California CO
standards after the 1990 Clean Air Act. The local area has always been
considered an attainment area for the federal CO standards.
3. Has continued attainment been verified with the local Air District, if
appropriate? Yes. Continued attainment of the California CO standard has
been verified with the San Diego Air Pollution Control District. Therefore,
according to the flow chart, the next step is to proceed to Level 7 to evaluate
whether the project could have localized CO impacts.
4. Is the project suspected of resulting in higher CO concentrations than
those existing within the region at the time of the attainment
demonstration? No. The project:
Does not significantly increase cold start percentages
Does not significantly increase traffic volumes overall
Improves traffic flow
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Espola Road Improvement Project
Based on this evaluation, as shown in the flow chart, a further local CO impact analysis
or regional conformity determination is not required for the project, and the project would
not cause or contribute to a violation of the air quality standards for CO.
PM2.5 and PM10 Analysis. Emissions of PM2.5 and PM10 are also attributable mainly to
traffic sources. The SDAB is in attainment of the NAAQS for PM2.5. The likelihood for
adverse impacts associated with particulate emissions from project-generated traffic was
evaluated using the Transportation Conformity Guidance for Qualitative Hot-Spot
Analyses in PM2.5 and PM10 Nonattainment and Maintenance Areas (USEPA 2006a).
The EPA’s Transportation Conformity Rule (40 CFR 93.123(b)(1)) identified projects for
which PM2.5 and PM10 would be of concern. These projects include the following:
“(i) New or expanded highway projects that have a significant number of
or significant increase in diesel vehicles;
(ii) Projects affecting intersections that are at Level-of-Service D, E, or F
with a significant number of diesel vehicles, or those that will change to
Level-of-Service D, E, or F because of increased traffic volumes from a
significant number of diesel vehicles related to the project;
(iii) New bus and rail terminals and transfer points that have a significant
number of diesel vehicles congregating at a single location;
(iv) Expanded bus and rail terminals and transfer points that significantly
increase the number of diesel vehicles congregating at a single location;
and
(v) Projects in or affecting locations, areas, or categories of sites which are
identified in the PM2.5 or PM10 applicable implementation plan or
implementation plan submission, as appropriate, as sites of violation or
possible violation.”
The Espola Road Project would not be a project of air quality concern for PM2.5 and PM10
emissions because the project would not result in increases in the number of diesel
vehicles utilizing the road, nor is the SDAB in violation of the federal PM2.5 or PM10
standard.
Project Alternatives. As discussed in the introduction, the project is evaluating four
build alternatives. The Proposed Project would involve widening of the roadway to three
lanes. Three of the four alternatives involve widening the roadway to four lanes.
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The four-lane alternatives would result in improvements in traffic LOS from the No
Build conditions that improve LOS at least as much as the three-lane alternative. No
additional traffic would result from the four-lane alternatives. As with the three-lane
project, no CO or particulate impacts would be anticipated for the four-lane alternatives.
3.3 Mobile Source Air Toxics
The following discussion is based on the FHWA Memorandum, Subject:
INFORMATION: Interim Guidance Update on Mobile Source Air Toxic Analysis in
NEPA Documents, dated September 30, 2009 (FHWA 2009), which provides an update
to the Interim Guidance on Air Toxic Analysis in NEPA Documents, dated February 3,
2006 (FHWA 2006a). The purpose of the guidance is to advise when and how to analyze
MSAT in the NEPA process for highways. This guidance is interim, because MSAT
science is still evolving. As the science progresses, FHWA will update the guidance.
The USEPA is the lead Federal Agency for administering the Clean Air Act and has
certain responsibilities regarding the health effects of MSATs. The USEPA regulates
188 air toxics, known as hazardous air pollutants, under the Clean Air Act. The USEPA
has assessed this expansive list in their latest rule on the Control of Hazardous Air
Pollutants from Mobile Sources (Federal Rigister, Vol. 72, No. 37, Page 8430, February
20, 2007) and identified a group of 93 compounds emitted from mobile sources that are
listed in their Integrated Risk Information System (IRIS) (http://cfcpub.epa.gov/
ncea/iris/index.cfm). In addition, USEPA identified seven compounds with significant
contributions from mobile sources that are among the national and regional-scale cancer
risk drivers from their 1999 National Air Toxics Assessment (NATA)
(http://www.epa.gov/ttn/atw/nata1999/). These are acrolein, benzene, 1,3-butadiene,
diesel particulate matter plus diesel exhaust organic gases (diesel PM), formaldehyde,
naphthalene, and polycyclic organic matter. While FHWA considers these the priority
MSATS, the list is subject to change and may be adjusted in consideration of future
USEPA rules.
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The 2007 USEPA rule mentioned above requires controls that will dramatically decrease
MSAT emissions through cleaner fuels and cleaner engines. According to an FHWA
analysis using USEPA’s MOBILE6.2 model, even if vehicle activity (vehicle-miles
travelled, VMT) increases by 145 percent as assumed, a combined reduction of 72
percent in the total annual emission rate for the priority MSATs is projected from 1999 to
2050, as shown in Figure 4.
Air toxics analysis is a continuing area of research. While much work has been done to
assess the overall health risk of air toxics, many questions remain unanswered. In
particular, the tools and techniques for assessing project-specific health outcomes as a
result of lifetime MSAT exposure remain limited. These limitations impede the ability to
evaluate how the potential health risks posed by MSAT exposure should be factored into
project-level decision-making within the context of NEPA.
Nonetheless, air toxics concerns continue to be raised on highway projects during the
NEPA process. Even as the science emerges, the FHWA is expected by the public and
other agencies to address MSAT impacts in environmental documents. The FHWA,
USEPA, the Health Effects Institute, and others have funded and conducted research
studies to try to more clearly define potential risks from MSAT emissions and associated
with highway projects. The FHWA will continue to monitor the developing research in
this emerging field.
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Figure 4 MSAT Emission Trends 1999-2050 for Vehicles Operating on Roadways
Using USEPA’s MOBILE6.2 Model
Note:
(1) Annual emissions of polycyclic organic matter are projected to be 561 tons/yr for 1999, decreasing to 373 tons/yr
for 2050.
(2) Trends for specific locations may be different, depending on locally derived information representing vehicle-miles
travelled, vehicle speeds, vehicle mix, fuels, emission control programs, meteorology, and other factors
Source: U.S. Environmental Protection Agency. MOBILE6.2 Model run 20 August 2009.
Incomplete or Unavailable Information for Project Specific MSAT Impact Analysis
This air quality analysis includes a basic analysis of the likely MSAT emission impacts of
this project. However, available technical tools do not enable us to predict the project-
specific health impacts of the emission changes associated with implementation of the
proposed project. Due to these limitations, the following discussion is included in
accordance with the Code of Federal Regulations, Title 40, Protection of the
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Environment, Section 1502.22(b) (40 CFR § 1502.22(b)) regarding incomplete or
unavailable information:
Information that is Unavailable or Incomplete.
In FHWA's view, information is incomplete or unavailable to credibly predict the project-
specific health impacts due to changes in MSAT emissions associated with a proposed set
of highway alternatives. The outcome of such an assessment, adverse or not, would be
influenced more by the uncertainty introduced into the process through assumption and
speculation rather than any genuine insight into the actual health impacts directly
attributable to MSAT exposure associated with a proposed action.
The U.S. EPA is responsible for protecting the public health and welfare from any known
or anticipated effect of an air pollutant. They are the lead authority for administering the
Clean Air Act and its amendments and have specific statutory obligations with respect to
hazardous air pollutants and MSAT. The U.S. EPA is in the continual process of
assessing human health effects, exposures, and risks posed by air pollutants. They
maintain the Integrated Risk Information System (IRIS), which is "a compilation of
electronic reports on specific substances found in the environment and their potential to
cause human health effects" (U.S. EPA, http://www.epa.gov/ ncea/iris/index.html). Each
report contains assessments of non-cancerous and cancerous effects for individual
compounds and quantitative estimates of risk levels from lifetime oral and inhalation
exposures with uncertainty spanning perhaps an order of magnitude.
Other organizations are also active in the research and analyses of the human health
effects of MSAT, including the Health Effects Institute (HEI). Two HEI studies are
summarized in Appendix D of FHWA's Interim Guidance Update on Mobile source Air
Toxic Analysis in NEPA Documents. Among the adverse health effects linked to MSAT
compounds at high exposures are cancer in humans in occupational settings; cancer in
animals; and irritation to the respiratory tract, including the exacerbation of asthma. Less
obvious is the adverse human health effects of MSAT compounds at current
environmental concentrations (HEI, http://pubs.healtheffects.org/view.php?id=282) or in
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the future as vehicle emissions substantially decrease (HEI, http://pubs.healtheffects.
org/view.php?id=306).
The methodologies for forecasting health impacts include emissions modeling; dispersion
modeling; exposure modeling; and then final determination of health impacts - each step
in the process building on the model predictions obtained in the previous step. All are
encumbered by technical shortcomings or uncertain science that prevents a more
complete differentiation of the MSAT health impacts among a set of project alternatives.
These difficulties are magnified for lifetime (i.e., 70 year) assessments, particularly
because unsupportable assumptions would have to be made regarding changes in travel
patterns and vehicle technology (which affects emissions rates) over that time frame,
since such information is unavailable. The results produced by the U.S. EPA's
MOBILE6.2 model, the California EPA's Emfac2007 model, and the U.S. EPA's
DraftMOVES2009 model in forecasting MSAT emissions are highly inconsistent.
Indications from the development of the MOVES model are that MOBILE6.2
significantly underestimates diesel particulate matter (PM) emissions and significantly
overestimates benzene emissions.
Regarding air dispersion modeling, an extensive evaluation of U.S. EPA's guideline
CAL3QHC model was conducted in an NCHRP study (http://www.epa.gov/
scram001/dispersion_alt.htm#hyroad), which documents poor model performance at ten
sites across the country - three where intensive monitoring was conducted plus an
additional seven with less intensive monitoring. The study indicates a bias of the
CAL3QHC model to overestimate concentrations near highly congested intersections and
underestimate concentrations near uncongested intersections. The consequence of this is
a tendency to overstate the air quality benefits of mitigating congestion at intersections.
Such poor model performance is less difficult to manage for demonstrating compliance
with National Ambient Air Quality Standards for relatively short time frames than it is
for forecasting individual exposure over an entire lifetime, especially given that some
information needed for estimating 70-year lifetime exposure is unavailable. It is
particularly difficult to reliably forecast MSAT exposure near roadways, and to determine
the portion of time that people are actually exposed at a specific location.
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There are considerable uncertainties associated with the existing estimates of toxicity of
the various MSAT, because of factors such as low-dose extrapolation and translation of
occupational exposure data to the general population, a concern expressed by HEI
(http://pubs.healtheffects.org/view.php?id=282 ). As a result, there is no national
consensus on air dose-response values assumed to protect the public health and welfare
for MSAT compounds, and in particular for diesel PM. The U.S. EPA
(http://www.epa.gov/risk/basicinformation.htm#g) and the HEI (http://pubs.healtheffects.
org/getfile.php?u=395) have not established a basis for quantitative risk assessment of
diesel PM in ambient settings.
There is also the lack of a national consensus on an acceptable level of risk. The current
context is the process used by the U.S. EPA as provided by the Clean Air Act to
determine whether more stringent controls are required in order to provide an ample
margin of safety to protect public health or to prevent an adverse environmental effect for
industrial sources subject to the maximum achievable control technology standards, such
as benzene emissions from refineries. The decision framework is a two-step process. The
first step requires U.S. EPA to determine a "safe" or "acceptable" level of risk due to
emissions from a source, which is generally no greater than approximately 100 in a
million. Additional factors are considered in the second step, the goal of which is to
maximize the number of people with risks less than 1 in a million due to emissions from
a source. The results of this statutory two-step process do not guarantee that cancer risks
from exposure to air toxics are less than 1 in a million;in some cases, the residual risk
determination could result in maximum individual cancer risks that are as high as
approximately 100 in a million. In a June 2008 decision, the U.S. Court of Appeals for
the District of Columbia Circuit upheld U.S. EPA's approach to addressing risk in its two
step decision framework. Information is incomplete or unavailable to establish that even
the largest of highway projects would result in levels of risk greater than safe or
acceptable.
Because of the limitations in the methodologies for forecasting health impacts described,
any predicted difference in health impacts between alternatives is likely to be much
smaller than the uncertainties associated with predicting the impacts. Consequently, the
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results of such assessments would not be useful to decision makers, who would need to
weigh this information against project benefits, such as reducing traffic congestion,
accident rates, and fatalities plus improved access for emergency response, that are better
suited for quantitative analysis.
Evaluation of Project MSAT Potential
The FHWA has developed a tiered approach for analyzing MSATs in NEPA documents.
Depending on the specific project circumstances, FHWA has identified three levels of
analysis:
No analysis for projects with no potential for meaningful MSAT effects, Category
(1);
Qualitative analysis for projects with low potential MSAT effects, Category (2);
or
Quantitative analysis to differentiate alternatives for projects with higher potential
MSAT effects, Category (3).
Category (1) is limited to projects that:
qualify as a categorical exclusion under 23 CFR 771.117(c);
are exempt under the Clean Air Act conformity rule under 40 CFR §93.126; or
have no meaningful impacts on traffic volumes or vehicle mix.
This project does not meet any of these Category (1) requirements.
The purpose of this project is to reduce current and future delay experienced by drivers
traveling along Espola Road. This project will not result in any meaningful changes in
traffic volumes, vehicle mix, location of the existing facility, or any other factor that
would cause an increase in emissions impacts relative to the no-build alternative. The
Espola Road Widening Project falls under Category 2, Qualitative analysis projects with
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low potential MSAT effects. The types of projects included under Category 2 include
those projects that serve to improve operations of highway, transit or freight without
adding substantial new capacity or without creating a facility that is likely to
meaningfully increase emissions. The Espola Road Widening Project serves to improve
operations of Espola Road. Based on the FHWA guidance, this project will generate
minimal air quality impacts for Clean Air Act criteria pollutants and would not be linked
with any special MSAT concerns. Consequently, this effort is exempt from analysis for
MSATs. Moreover, USEPA regulations for vehicle engines and fuels will cause overall
MSATs to decline significantly over the next 20 years. Even after accounting for a 64
percent increase in VMT, FHWA predicts MSATs will decline in the range of 57 percent
to 87 percent, from 2000 to 2020, based on regulations now in effect. This will both
reduce the background level of MSATs as well as the possibility of even minor MSAT
emissions from this project.
4.0 Naturally-Occurring Asbestos
Exposure and disturbance of rock and soil that contains asbestos can result in the release
of fibers to the air and consequent exposure to the public. Asbestos most commonly
occurs in ultramafic rock that has undergone partial or complete alteration to serpentine
rock (proper rock name serpentinite) and often contains chrysotile asbestos. In addition,
another form of asbestos, tremolite, can be found associated with ultramafic rock,
particularly near faults. Sources of asbestos emissions include: unpaved roads or
driveways surfaced with ultramafic rock, construction activities in ultramafic rock
deposits, or rock quarrying activities where ultramafic rock is present. Based on the map
of naturally-occurring asbestos locations contained in A General Location Guide for
Ultramafic Rocks in California – Areas More Likely to Contain Naturally Occurring
Asbestos (California Department of Conservation, Divisions of Mines and Geology
2000), major ultramafic rock formations are not found in San Diego County. Therefore,
construction and grading would not occur in an area with ultramafic rock that could be a
source of emissions of naturally-occurring asbestos.
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5.0 Global Climate Change
While climate change has been a concern since at least 1988, as evidenced by the
establishment of the United Nations and World Meteorological Organization’s
Intergovernmental Panel on Climate Change (IPCC), the efforts devoted to greenhouse
gas1 (GHG) emissions reduction and climate change research and policy have increased
dramatically in recent years. In 2002, with the passage of Assembly Bill 1493 (AB
1493), California launched an innovative and pro-active approach to dealing with GHG
emissions and climate change at the state level. AB 1493 requires the Air Resources
Board (ARB) to develop and implement regulations to reduce automobile and light truck
GHG emissions; these regulations will apply to automobiles and light trucks beginning
with the 2009 model year.
On June 1, 2005, Governor Arnold Schwarzenegger signed Executive Order S-3-05. The
goal of this Executive Order is to reduce California’s GHG emissions to: 1) 2000 levels
by 2010, 2) 1990 levels by the 2020 and 3) 80% below the 1990 levels by the year 2050.
In 2006, this goal was further reinforced with the passage of Assembly Bill 32 (AB 32),
the Global Warming Solutions Act of 2006. AB 32 sets the same overall GHG emissions
reduction goals while further mandating that ARB create a plan, which includes market
mechanisms, and implement rules to achieve “real, quantifiable, cost-effective reductions
of greenhouse gases.” Executive Order S-20-06 further directs state agencies to begin
implementing AB 32, including the recommendations made by the state’s Climate Action
Team.
With Executive Order S-01-07, Governor Schwarzenegger set forth the low carbon fuel
standard for California. Under this executive order, the carbon intensity of California’s
transportation fuels is to be reduced by at least 10 percent by 2020.
1 Greenhouse gases related to human activity, as identified in AB 32, include: Carbon dioxide, Methane,
Nitrous oxide, Tetrafluoromethane, Hexafluoroethane, Sulfur hexafluoride, HFC-23, HFC-134a*, and
HFC-152a*.
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Climate change and GHG reduction is also a concern at the federal level; at this time, no
legislation or regulations have been enacted specifically addressing GHG emissions
reductions and climate change. However, California, in conjunction with several
environmental organizations and several other states, sued to force the U.S.
Environmental Protection Agency (EPA) to regulate GHGs as a pollutant under the Clean
Air Act (Massachusetts vs. Environmental Protection Agency et al., U.S. Supreme Court
No. 05–1120. Argued November 29, 2006—Decided April 2, 2007). The court ruled that
GHGs do fit within the Clean Air Act’s definition of a pollutant, and that EPA does have
the authority to regulate GHGS. Despite the Supreme Court ruling, there are no
promulgated federal regulations to date limiting greenhouse gas emissions.
According to a recent white paper by the Association of Environmental Professionals
(AEP 2007), “an individual project does not generate enough greenhouse gas emissions
to significantly influence global climate change. Global climate change is a cumulative
impact; a project participates in this potential impact through its incremental contribution
combined with the cumulative increase of all other sources of greenhouse gases.
With its focus on roadways, Caltrans and its parent agency, the Business, Transportation,
and Housing Agency, have taken an active role in addressing GHG emission reduction
and climate change. Recognizing that 98 percent of California’s GHG emissions are
from the burning of fossil fuels and 40 percent of all human made GHG emissions are
from transportation, Caltrans has created and is implementing the Climate Action
Program at Caltrans (Caltrans 2006). Transportation’s contribution to GHG emissions is
dependent on 3 factors: the types of vehicles on the road, the type of fuel the vehicles
use, and the time/distance the vehicles travel.
One of the main strategies to reduce GHG emissions is to make California’s
transportation system more efficient. The highest levels of carbon dioxide from mobile
sources, such as automobiles, occur at stop-and-go speeds (0-25 miles per hour) and
speeds over 55 mph; the most severe emissions occur from 0-25 miles per hour (see
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Figure below). Relieving congestion by enhancing operations and improving travel times
in high congestion travel corridors will lead to an overall reduction in GHG emissions.
The City recognizes the concern that carbon dioxide emissions raise for climate change.
However, accurate modeling of GHG emissions levels, including carbon dioxide at the
project level, at the project level is not currently possible. No federal, state or regional
regulatory agency has provided methodology or criteria for GHG emission and climate
change impact analysis. Therefore, it is not possible to provide a scientific or regulatory
based conclusion regarding whether the project’s contribution to climate change is
cumulatively considerable.
Caltrans continues to be actively involved on the Governor’s Climate Action Team as
ARB works to implement AB 1493 and AB 32. Caltrans is also supporting efforts to
Source: Center for Clean Air Policy— http://www.ccap.org/Presentations/Winkelman%20TRB%202004%20(1-13-04).pdf
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improve the energy efficiency of the transportation sector by increasing vehicle fuel
economy in new cars, light and heavy-duty trucks. However it is important to note that
the control of the fuel economy standards is held by the United States Environmental
Protection Agency and ARB. Lastly, the use of alternative fuels is also being considered;
Caltrans is participating in funding for alternative fuel research at the University of
California Davis.
To the extent that it is applicable or feasible for the project, the following measures can
also help to reduce the GHG emissions and potential climate change impacts from all
projects, including Espola Road:
1. Landscaping—reduces surface warming and through photosynthesis decreases
CO2.
2. Portland cement—use of lighter color surfaces such as Portland cement helps
to reduce the albedo effect and cool the surface; in addition, Caltrans has been
a leader in the effort to add fly ash to Portland cement mixes. Adding fly ash
reduces the GHG emissions associated with cement production—it also can
make the pavement stronger.
3. Use of energy efficient lighting, such as LED traffic signals.
4. Idling restrictions for trucks and equipment.
6.0 Conclusions
Based on the analysis of emissions associated with both project construction and
operation, considering the project development alternatives, the project and alternatives
would not cause a significant impact on the ambient air quality. The purpose of the
project is to alleviate congestion along Espola Road. Under future (2010 and 2030)
conditions without the project, all roadway segments between Twin Peaks road and Titan
Way would operate at LOS F. These roadway segments improve to LOS D or C with the
project. The Traffic Study also indicated that the intersection of Espola Road with
Durhullen/Golden Sunset would operate at LOS F in 2010 and 2030 during both the am
and pm peak hours. With the three-lane improvements to Espola Road, this intersection
would operate at LOS A in 2010 and LOS A/B in 2030. Under the four-lane alternative,
traffic congestion would be equal to or better than the with the three-lane improvements.
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The three-lane alternative was chosen as the project in response to neighborhood requests
to minimize biological impacts and reduce the right-of-way take. The analysis therefore,
that did not indicate the potential for CO “hot spots” associated with traffic congestion at
intersections that would be affected by the proposed project. Furthermore, the project
would not be anticipated to result in an exceedance of the PM10 standard.
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7.0 References
Association of Environmental Professionals. 2007. Recommendations by the Association
of Environmental Professionals (AEP) on How to Analyze Greenhouse Gas
Emissions and Global Climate Change in CEQA Documents. June.
California Air Resources Board. 1998. Final Carbon Monoxide Redesignation and
Maintenance Plan for Ten Federal Planning Areas.
California Department of Transportation. 2006. Climate Action Program at Caltrans.
December.
California Department of Transportation. 2008. Standard Environmental Reference.
Federal Highway Administration. 2006. Interim Guidance on Air Toxic Analysis in
NEPA Documents. February 3.
Federal Highway Administration. 2009. FHWA Memorandum, Subject:
INFORMATION: Interim Guidance Update on Mobile Source Air Toxic
Analysis in NEPA Documents. September 30.
KOA Corporation. 2006. Espola Road Widening Traffic Analysis. August.
San Diego Association of Governments. 2006. Final Regional Transportation
Improvement Program. July.
San Diego Association of Governments. 2007. 2030 Regional Transportation Plan:
Pathways for the Future, 2007 Update. Final. November.
University of California Davis. 1998. Transportation Project-Level Carbon Monoxide
Protocol.
Appendix A
Construction Emissions Calculations
Table A-1
Construction Heavy Equipment Emissions
Espola Road Widening Project
Grading Phase
Equipment Fuel HP Load No of Hrs Per Days in Emissions, lbs/day Emission, tons (total)
Factor CO VOC NOX SOX PM10 PM2.5 Equip Day Service CO VOC NOX SOX PM10 PM2.5 CO VOC NOX SOX PM10 PM2.5
Dozers Diesel 357 59 4.25 0.83 7.51 0.006 0.32 0.28 2 8 250 31.58 6.17 55.80 0.04 2.38 2.12 3.95 0.77 6.97 0.01 0.30 0.26
Graders Diesel 174 57.5 3.43 0.9 7.02 0.006 0.397 0.35 2 8 250 12.11 3.18 24.77 0.02 1.40 1.25 1.51 0.40 3.10 0.00 0.18 0.16
Rubber Tired Loaders Diesel 164 54 3.41 0.89 6.97 0.006 0.392 0.35 2 8 250 10.65 2.78 21.77 0.02 1.22 1.09 1.33 0.35 2.72 0.00 0.15 0.14
Backhoes Diesel 108 55 4.07 1.19 7.16 0.007 0.654 0.58 2 8 250 8.53 2.49 15.00 0.01 1.37 1.22 1.07 0.31 1.88 0.00 0.17 0.15
Dump Trucks Diesel 479 57 1.82 0.57 5.55 0.006 0.205 0.18 2 8 250 17.53 5.49 53.45 0.06 1.97 1.76 2.19 0.69 6.68 0.01 0.25 0.22
Water Trucks Diesel 189 50 3.48 0.89 6.72 0.006 0.395 0.35 2 8 250 11.60 2.97 22.40 0.02 1.32 1.17 1.45 0.37 2.80 0.00 0.16 0.15
91.99 23.07 193.20 0.18 9.66 8.60 11.50 2.88 24.15 0.02 1.21 1.08
Paving
Equipment Fuel HP Load No of Hrs Per Days in Emissions, lbs/day Emission, tons (total)
Factor CO VOC NOX SOX PM10 PM2.5 Equip Day Service CO VOC NOX SOX PM10 PM2.5 CO VOC NOX SOX PM10 PM2.5
Cement/Mortar Mix Diesel 10 56 3.54 0.78 5.05 0.009 0.334 0.30 4 8 250 1.40 0.31 2.00 0.00 0.13 0.12 0.17 0.04 0.25 0.00 0.02 0.01
Pavers Diesel 100 59 4.40 1.5 8.75 0.007 0.759 0.68 2 10 250 11.45 3.90 22.76 0.02 1.97 1.76 1.43 0.49 2.85 0.00 0.25 0.22
Roller Compactor Diesel 95 57.5 4.11 1.31 7.9 0.007 0.678 0.60 1 10 250 4.95 1.58 9.51 0.01 0.82 0.73 0.62 0.20 1.19 0.00 0.10 0.09
17.79 5.79 34.27 0.03 2.92 2.60 2.22 0.72 4.28 0.00 0.37 0.33
Emission Factors (g/bhp-hr)
Emission Factors (g/bhp-hr)
A-1
Table A-2
Construction Worker Commute Emissions
Espola Road Widening Project
Construction Worker Estimates and Emission Calculations
VOCs PM10 Emissions, lbs/day Total Days Emissions, tons/year
No. of
Workers Speed VMT
Running
Exhaust
Tire
Wear
Per
Constructi
on Phase (mph)
(mi/vehicle-
day)
Running
Exhaust
(g/mi)
Start-Up
(g/start)a
Running
Exhaust
(g/mi)
Start-Up
(g/start)a (g/mi)
Running
Exhaust
(g/mi)
Start-Up
(g/start)a
Start-Up
(g/start)a (g/mi)CO NOx VOCs SOx PM10 CO NOx VOCs SOx PM10
Grading/Paving Light-duty truck, catalyst 15 35 40 3.976 12.582 0.438 0.581 0.195 1.048 0.249 0.032 0.062 0.066 0.004 0.002 0.013 0.014 0.008 0.013 6.09 0.62 0.45 0.01 0.05 250 0.761442 0.077226 0.05671 0.000678 0.005738
Assume startup after 8 hours
Assume 45 minutes run time total
2008 Emission Factors from EMFAC2007, average temp 60F
Construction Phase Vehicle Class
CO NOX SOx
Brake
Wear
(g/mi)
Diurnal
Evaporati
ve (g/hr)
Running
Exhaust
(g/mi)
Start-Up
(g/start)a Hot-Soak
(g/trip)
Resting
Loss
(g/hr)
Running
Evaporati
ve (g/mi)
A-2
Table A-3
Construction Truck Emissions
Espola Road Widening Project
No. of
Trucks Speed VMT CO NOX VOCs SOx
Per
Construc
tion
Phase (mph)
(mi/vehicl
e-day)
Running
Exhaust
(g/mi)
Running
Exhaust
(g/mi)
Running
Exhaust
(g/mi)
Running
Exhaust
(g/mi)
Running
Exhaust
(g/mi)
Tire Wear
(g/mi)
Brake
Wear
(g/mi)CO NOx VOCs SOx PM10 CO NOx VOCs SOx PM10
Paving
Supply
Trucks 4 25 40 7.403 18.512 1.672 0.02 0.844 0.036 0.028 2.61 6.53 0.59 0.01 0.32 250 0.326 0.816 0.074 0.001 0.040
Assume 40 miles round
trip travel distance
Emission factors from
2008 EMFAC2007, 25
mph, Heavy Duty Diesel
truck (HHD)
Emissions, lbs/day Emissions, tons/year
DaysConstruction Phase
Vehicle
Class
PM10
A-3
Appendix B
2008 RTIP Listing