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HomeMy WebLinkAbout001E N V I R O N 0 Date: January 14, 2011 MEMORANDUM To: Garth Mann, Statesman Corporation From: Richard Steffel, Lisa Graham Subject: Proposed Air Quality Impact Analysis Scope and Budget for the Pleasant Harbor Master Planned Resort SEPA Review Jefferson County Board of County Commissioners (BoCC) Ordinance No. 01-0128-08 includes a condition (63.cc) that requires Statesman Corporation to "collaborate with the Jefferson County Climate Action Committee (CAC) to calculate greenhouse gas emissions (GHGs) associated with the MPR, and identify techniques to mitigate such emissions through sequestration and/or other acceptable methods." Recent communication with Zoe Ann Lamp, Jefferson County Department of Community Development staff memberto the CAC, indicates that this condition was written before the Washington Department of Ecology issued draft SEPA Guidance for climate change documentation (see e-mail message dated August 5, 2010, attached). Ms. Lamp indicates that GHG emission calculations are required for the MPR, along with a description of methods for reducing the emissions of the MPR. It is no longer necessary 0 for the GHG emissions analysis to be coordinated with the CAC. ENVIRON Corporation is experienced at preparing GHG Emission Analyses in accordance with Ecology's guidelines, as well as more meaningful analyses that will show by calculation effective reductions inherent in several innovative elements of the Pleasant Harbor Master Planned Resort (MPR). ENVIRON proposes to provide SEPA-level analysis of the air quality implications of the proposed Pleasant Harbor Resort in Jefferson County, Washington as described below. • SEPA REVIEW IMPACT ANALYSIS ENVIRON will analyze the potential off-site air quality implications of the proposed development assuming: Off-site Traffic: Typically, congested intersections that are likely to be affected by project traffic are assessed for potential air quality impacts. Based on EPA guidance, only signalized intersections with poor level of service are considered for this type of analysis. Based on correspondence with the Pleasant Harbor MPR traffic consultant, the intersections near the project would not likely reach the level of service that would require `hot spot' analysis (LOS D or worse). Therefore, it is assumed that a SEPA level `hot -spot' analysis will not be required. Instead, a qualitative assessment will be performed of off-site project traffic effects on air quality within the study area. In the event review of the traffic study comparing the projects alternatives indicates an air quality hot -spot analysis is necessary (i.e., that a modeling review will be required), the ENVIRON scope and budget will require modification. 19023 33rd Avenue Suite 310, Lynnwood, VVA98036-4754 www.environcorp.com Tel: 425,412.1800 Fax: 425.412.1840 Garth Mann, Statesman Corporation - 2 - January 14, 2011 • Construction: ENVIRON will provide a qualitative review of potential air quality impacts related to construction and a discussion of commonly used methods to reduce potential emissions and related air quality impacts. For example, dust from short-term construction activities such as excavation, grading, sloping and filling would contribute to ambient concentrations of suspended particulate matter. Construction contractor(s) would have to comply with local air quality regulations requiring that reasonable precautions betaken to minimize fugitive dust emissions. For this project, ENVIRON assumes no air quality dispersion modeling will be necessary for construction emissions under SEPA review. • On-site Mining and Concrete Production: ENVIRON will assess the potential for the proposed on-site mining of sand and gravel and portable concrete batch plant to reduce off-site construction traffic. We assume that no air quality dispersion modeling will be necessary under SEPA review for this element of the proposal. CHP Cogeneration: ENVIRON will calculate the emissions related to the Combined Heat and Power Cogeneration facilities. Air quality permits will likely be required for these facilities, which will limit the potential for off-site impacts. Therefore, ENVIRON will provide a qualitative review of the potential for off-site impacts. We assume that no air quality dispersion modeling will be necessary under SEPA review for this element of the proposal. • ENVIRON assumes that although the Washington State Department of Transportation (WSDOT) will review the SETS, the level of effort required for this analysis would not • trigger the need for an Air Quality Discipline Report to be reviewed and approved by WSDOT. To trigger a WSDOT discipline report, the proposed project would have to in someway alter intersections on U.S. Highway 101 to the point where intersection performance would deteriorate to a poor level of service. ENVIRON is aware that the intersection of Black Point Road/US Highway 101 will likely be modified by the project proponent, but ENVIRON assumes the level of service will not degrade to LOS D or worse. If LOS is predicted to degrade to LOS D or worse, a WSDOT-level review would require additional effort and budget. • ENVIRON assumes that the pending potential reclassification of a portion of western Washington that includes the project vicinity to an ozone nonattainment area will have no bearing on this air quality analysis. ENVIRON assumes that no on-site suitability assessment is requested by the client. An on-site suitability assessment would include a review of potential impacts to on-site locations from both on-site and off-site sources, such as traffic -related air quality impacts from a nearby congested highway or potential impacts from on-site mining activities. This level of analysis is not included in this scope of work. GREENHOUSE GAS EMISSIONS ANALYSIS In early 2010, Ecology issued a comprehensive preliminary draft guidance to address projected impacts and potential mitigation measures for project -level review. Ecology issued a significantly modified draft document on greenhouse gas emissions and SEPA in response to comments received on its prior draft in mid-October 2010. This document is no longer called guidance, but rather is a "Working Paper" that will be updated as new information becomes available. The • newest update is now scheduled for sometime in mid-January 2011. Garth Mann, Statesman Corporation - 3 - January 14, 2011 • Currently, the new draft provides guidance on how the existing SEPA checklist (or Environmental Impact Statements prepared under SEPA) can be used to identify and disclose greenhouse gas emissions. Most of the guidance is based on quantitative analysis of GHG emissions during construction and operation of the project, as well emissions associated with potential changes in land use (from forested land to development as one example). Several tools exist to consider these emissions, although not necessarily required as yet. ENVIRON will assess greenhouse gas emissions (GHGs) using tools and methods described in the most recently published Washington Department of Ecology SEPA Working Paper guidance document. The current Working Paper is attached to this scope. As part of this scope, to provide a credible analysis of the benefits of the project, the GHG emissions from a typical similarfacility will be considered and compared to the GHG emissions associated with construction and operation of the proposed Master Planned Resort. Our proposal is based on the following assumptions forthe GHG analysis: • GHG emissions associated with construction and material handling transport using typical methods and tools in Ecology's SEPA Working Paper. • GHG emissions associated with the electric consumption of the building facilities and benefits of on-site power generation will be discussed. • GHG emissions associated with the transport and application of the EarthRenew fertilizer product will be discussed and compared to conventional golf course methods including energy consumption during the application process. • Other proposed sustainable methods will be assessed for GHG emission benefits. DOCUMENTATION • ENVIRON will document the methods and findings of the air quality and greenhouse gas emission assessments in a section suitable for direct inclusion in the Draft SEIS for the project. Technical appendices will be prepared as necessary. ENVIRON will provide one draft of the section for review by the client, SEIS author, and Jefferson County prior to its finalization. ENVIRON assumes that our participation will not be required to respond to comments on the Draft SETS. If this assistance is needed, and if there is remaining budget following completion of the Draft SEIS analysis, we will use this to respond to comments. Major comments orcomments requiring additional analyses (not anticipated at this time) would require a supplemental budget. Our estimated time and expenses budget for the Air Quality analysis is $ . A level -of -effort breakdown by task is provided on the following page. PROFESSIONAL SERVICES AGREEMENT Following review and acceptance of this scope of work and cost estimate, ENVIRON will prepare and submit a Professional Services Agreement to the Statesman Group for signature prior to initiating the Pleasant Harbor Master Planned Resort Air Quality Impact Analysis. cc: Vicki Morris, Vicki Norris Consulting Services • • -Working Paper - The Washington Department of Ecology has prepared this paper to assist in applying the State Environmental Policy Act (SEPA) to proposals that will result in greenhouse gas emissions or that may be vulnerable to the impacts of those emissions: climate change. C:hinate Change through the SEPA teras The State Environmental Policy Act or SEPA became state law in 1971 (RCW 43.21C). By enacting SEPA, lawmakers established a systematic, interdisciplinary approach for evaluating decisions that may impact our environment and ensure that "presently unquantified environmental amenities and values ... be given appropriate consideration along with economic and technical considerations" (RCW 43.21C.030(b)). Further, SEPA directs agencies, municipal and public corporations, and counties to "recognize the world-wide and long-range character of • environmental problems..." (RCW 43.21C.030(f)). Climate is one element of the environment that SEPA requires agencies to evaluate before making a decision on a proposal (WAC 197 -11 - In practice, SEPA requires state and local agencies to identify the possible environmental impacts that may result from their decisions. The current SEPA Checklist can be used to identify and disclose sources of greenhouse gas emissions and impacts on the built environment. There is nothing unique about the SEPA process when considering greenhouse gas emissions or when considering how the built environment might be impacted by anticipated climate change resulting from greenhouse gas emissions. Gr-eenhonse Cases Ecology expects that the most common greenhouse gases that would be identified in a project subject to SEPA will be carbon dioxide, methane, and possibly sulphur hexafluoride, commonly • 10/19/10 Draft 1 0 referred to as SF6. Other greenhouse gases included nitrous oxide, hydroflurocarbons (HFC) and perfluorocarbons (PFC). In Washington State, carbon dioxide emissions from the industrial combustion of biomass in the form of fuel wood, woodwaste, wood byproducts and wood residuals are not a greenhouse gas as long as the region's silvicultural sequestration capacity does not decrease. (See RCW 70.235.020(3)). There are other air emissions associated with forestry biomass however that may be part of the SEPA analysis. Addressing Green1hocise Gases tising the SEPA Checklist The environmental checklist (WAC 197-11-960) requires the proponent to identify air emissions associated with the project during construction and when the project is completed as well as any measures proposed to avoid, minimize or mitigate those emissions. Development Proposals. Greenhouse gases are a type of air emission. The questions under the section titled "Air" can be used to help identify emissions that are directly associated with the proposal (as opposed to for example emissions from electricity that is purchased but used as part of the project). The checklist includes other questions that may be useful indentifying potential greenhouse gas emissions, such as the number of people residing or working in the completed project (under "Land and Shoreline Use" in the checklist), vehicle trips per day and other demands on transportation (under "Transportation"), and energy use (under "Energy and Natural Resources"). These may be areas where identifying greenhouse gas emissions might be more relevant for many types of projects. Non -project actions. The Supplemental Sheet asks if the proposal would "be likely to increase... emissions to air." Here, the proponent or lead agency can think about the various sources of greenhouse gas emissions that could be part of the proposal. As is currently recommended in the Supplemental Sheet, because the questions are very general, reading them in conjunction with the list of the elements of the environment will be helpful as it can help proponents and lead agencies think about the various potential sources of emissions. • 10/19/10 Draft 21 Page How Emissions Can be Identified and Assessed King County has drafted a "GHG Emissions Worksheet" that a project proponent may find useful for both identifying source of greenhouse gas emissions and estimating emission levels. The draft worksheet, which is focused on estimating emissions for most types of buildings, provides a rough estimate of lifespan emissions from materials, transportation and energy usage. It can provide project proponents and lead agencies with an easy methodology to estimate likely emissions. As with any SEPA project, if additional analysis is done by the project proponent, it can be appended to the checklist. If a project proponent or lead agency wishes to develop its own assessment tool for greenhouse gas emissions, we have included in our Table of Tools a variety of greenhouse gas protocols that could be used to calculate emissions. The larger calculation methodologies in these protocols include generic emissions factors, calculation methodologies, and simple modeling tools that can be used to calculate emissions without the level of documentation and • rigor necessary for the underlying mandatory or voluntary reporting programs the protocols support. Some of the protocols in the table provide guidance for estimating emissions for existing development. Others are basic modeling tools that use average factors and assumptions to provide estimates of energy demand, construction emissions, and vehicle trips for new projects. Either could be used as part of the SEPA analysis. For development projects, Ecology developed an easy calculator for determining emissions associated with transportation fuels that can be used if an estimate of quantity of fuel that will be consumed by a project is available. For area -wide planning, the Washington Department of Commerce has looked at a variety of tools that estimate transportation demand and the vehicle miles traveled that a project might generate. In addition, Washington State DOT has developed guidance specifically for transportation projects. • 10/19/10 Draft 3 1 P a g e iEnvironmental Impacts associated with Greenhouse Gas Emissioos Once a project's emissions have been assessed, the lead agency is to determine whether the project will result in any probable significant adverse environmental impacts. Greenhouse gas emissions accumulate in the atmosphere, which result in changes to the climate, leading to environmental impacts on the ground. In February 2009, the University of Washington's Climate Impacts Group (CIG) released a study that provides a comprehensive assessment of the environmental impacts of climate change in Washington and the Pacific Northwest. (See the executive summary of the study.) Using global climate models scaled to the Pacific Northwest, CIG projects that even with moderate reductions in the rate of current global greenhouse gas emissions, Washington can expect environmental impacts from climate change resulting in: • Higher temperatures • Changes in precipitation patterns • • Lower water supply in summer months • Elevated stress on certain animal species and habitats • Increased risk to our forests • Reductions in air quality • Adverse impacts to agriculture • Increased risk to coastal areas • Decrease in summer hydropower production • Increase in summer energy demands • Increase in illness and mortality related to heat and worsening air quality The U.S. Global Change Research Program, overseen by the National Oceanic and Atmospheric Administration, has also released a scientific report titled "Global Climate Change Impacts in the United States." This report identified similar impacts for the Pacific Northwest: • 10/19/10 Draft 4 1 P a g e • • Declining springtime snowpack, leading to reduced summer stream flows and strained water supplies. • Increased stresses on salmon and other cold water species due to reduced summer stream flows and warmer water temperatures. • Drought stress and higher ambient temperatures resulting in increased insect outbreaks, wildfire, and changes in species composition. • Rising sea levels leading to increased erosion and loss of land. Significance of the Impacts Whether or not the emissions from a proposal are significant is the hardest question to answer when considering greenhouse gas emissions under SEPA, just as it is for many other impacts considered through SEPA. The current SEPA rules, which include the process for the threshold determination (WAC 197-11-330) and the definition of the terms apply to making this determination for the environmental impacts of greenhouse gases. Mitigating Emissions There are a number of ways project proponents could voluntarily reduce or avoid greenhouse gas emissions and thus mitigate environmental impacts through the design of the project. There are also some state laws that require greenhouse gases to be reduced. If a project includes any of the following strategies, or is (or will be) subject to a requirement to reduce or otherwise offset greenhouse gas emissions, then it may be appropriate to consider a mitigated DNS for the project's GHG emissions (as long as other impacts have also been mitigated to a level of nonsignificance. Certain utilities are required to meet an emissions performance standard for greenhouse gases under RCW 80.80.040 for baseload power. Similarly, certain new fossil -fueled thermal electric generating facilities are required to offset a portion of their CO2 emissions under RCW 80.70.020. Starting in January, 2011, large stationary sources that are new or modified will be required to apply `Best Available Control Technology' to their greenhouse gas emissions under the federal and state Clean Air Act. In addition, both Acts require emissions of nitrous oxide • 10/19/10 Draft 5 1 P a g e . (N2O) be permitted. Local air agencies or the Department of Ecology's Air Quality Program can provide more information on these requirements. Commercial, residential, and industrial facilities can all be designed to exceed the state building code by using available energy efficiency technologies and building methods. Certification systems such as Leadership in Energy and Environmental Design (LEED), Energy Star, and Built Green are all sources for highly energy-efficient building standards. The Washington State University Extension Energy Program is another excellent source of information about energy efficiencies. Local electricity and natural gas utilities are another good source. Combined Heat and Power (CHP) technologies generate electricity as well as useful mechanical or thermal energy. CHP uses the energy twice by recycling waste heat for on-site energy production. These systems are a good match for some industrial and commercial applications. More information and technical assistance can be found at the Northwest Clean Heat and Power Application Center. 0 For proposals that will increase emissions from mobile sources, there are also a number of options. Increased transportation emissions from new residents or customers could be reduced by: • Establishing walking, biking, and public transportation options to the area. • Providing employees with mass transit passes. • Limiting parking spaces or charging for parking. New subdivisions can include pedestrian links to transit stops. A proponent could offer to enhance the use of existing stops by adding transit shelters or appropriate lighting for evening hours. "Complete streets" – designed and operated so that pedestrians, bicyclists, motorists and public transportation users of all ages and abilities are able to safely and comfortably access and travel the street—could be considered. Mixed-use developments well served by transit can substantially reduce greenhouse gas emissions. In addition, lead agencies could 0 10/19/10 Draft 6 1 P a g e consider the transfer of development rights (TDR) to promote denser, mixed-use development to provide easy access to housing, shopping, and work options. Clustering development in some areas and leaving aside a portion of a developed parcel for conservation or continued use as natural resources land can reduce the loss of carbon stored in forested and agricultural ecosystems. Trees can be planted to offset any loss of forested lands. Greenhouse gas offset projects may be considered as a compensatory mitigation measure. These are projects that result in real emission reductions or increased carbon storage that are used to count toward, or "offset," emissions or loss of storage that occur elsewhere. Because offset projects are purchased, they need to meet certain criteria to ensure the purchaser gets what he or she is paying for — reduced emissions or increased carbon storage. If an offset project is considered as a mitigation strategy, the lead agency is encouraged to contact Ecology for assistance in evaluating the project. • In addition to these strategies, mitigation might be part of the: • Site design and location: o Conserve and restore natural areas on-site. o Permanent protection for open space on the project site. o Preserve or replant trees that are removed during development as a means of providing / maintaining carbon storage. • Building design and operation: o Trees and vegetation to shade the buildings and reduce energy requirements for heating and cooling. o Green building practices and materials, including light colored (high -albedo) roofing materials and sustainably harvested wood products. o Orient buildings to takes advantage of natural light. o Energy star equipment and appliances. o On-site renewable energy production. 0 o Water -efficient and low maintenance landscaping. 10/19/10 Draft 7) P a g e • • o Low carbon intensity building materials. o Locally sourced and reused building materials. o Methane destruction. o High -global warming potential gas destruction. o Water recycling or gray water system. • Land use and transportation o Integrate housing, jobs, shopping opportunities, and schools to reduce vehicle miles traveled or support transit. o Low impact development. o Parking incentives and management. o Include infrastructure, such as charging stations, for plug-in Hybrid electric vehicles (PHEVs) and electric vehicles (EVs). o Highly efficient or alternative fueled vehicles. o Video conferencing. • Energy Supply o Energy efficient bulbs and appliances in traffic lights, street lights, and other electrical uses. o Energy efficient equipment. o Correctly sized equipment. • Waste reduction practices o Recycle construction and demolition waste. o Residential and commercial food waste collection and composting. o On-site collection and storage of recycled materials. 11"Pacts on flee Built Environinont A proposal may be affected by climate change, which in turn could create additional environmental impacts or exacerbate impacts that are reasonably expected as a result of climate change. For example, a development project in a coastal area could be impacted as a result of flooding due to sea level rise. That flooding in turn can cause land and water contamination. Ecology believes that assessing a proposal's vulnerability to the impacts of 0 10/19/10 Draft 8 1 P a g e • climate change is appropriate in a SEPA review because SEPA requires consideration of the "built environment" as an element of the environment. (See RCW 43.21C.110(1)(f) and WAC 197-11-444). Useful information on the expected impacts in Washington State as a result of climate change may be found at the University of Washington's Climate Impact Group's website. Also, some local governments have or are preparing their own vulnerability assessments. SEPA Analyses that include Greenhouse Gases Ecology is gathering SEPA analyses that have included greenhouse gas emissions in order to provide additional assistance to project proponents and lead agencies. They can be found on our resources page. • 0 10/19/10 Draft 9 1 11 a g e