HomeMy WebLinkAboutFinal EIR
Final
Environmental Impact Report
TEMECULA REGIONAL HOSPITAL
SCH # 2005031017
January 2006
Lead Agency:
City of Temecula
43200 Business Park Drive
Temecula, CA 92589
Contact:
Emery Papp, Senior Planner
Planning Department
Consultant to the City:
P&D Consultants
800 E. Colorado Blvd., Suite 270
Pasadena, CA 91101
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT TEMECULA REGIONAL HOSPITAL
This Final Environmental Impact Report (EIR) for the Temecula Regional Hospital in the City of
Temecula contains comments and responses to comments received on the Draft EIR, which was
circulated for public review from September 28, 2005 to October 28, 2005. The comments and
responses to comments are presented in Section 9.0 – Responses to Comments on the Draft EIR
and Section 9.1 – Responses to Comments on the Draft EIR Received after Close of Public
Comment Period. Revisions and clarifications to the EIR in response to comments and information
received on the Draft EIR are indicated by strikeout (DEIR text removed) or underline (text added to
the Final EIR). Revisions and clarifications are included as Section 10.0 – Errata.
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL
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CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT
i TEMECULA REGIONAL HOSPITAL
Table of Contents
Page
9.0 Responses to Comments on the Draft EIR...............................................................................9-1
9.1 Responses to Comments on the Draft EIR Received after Close of the Public Comment
Period .........................................................................................................................................9-237
10.0 Errata ............................................................................................................................................10-1
Table of Contents
ENVIRONMENTAL IMPACT REPORT ii CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL
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CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT 9-1 TEMECULA REGIONAL HOSPITAL
9.0 Responses to Comments
on the Draft EIR
This section of the Final EIR contains comments and responses to written comments received during
the public review period on the Draft EIR (DEIR) extending from September 28, 2005 through
October 28, 2005. Pursuant to Section 15105(d)(3) and Appendix K of the California
Environmental Quality Act (CEQA) Guidelines the City of Temecula requested a shortened review
period to the Governor’s Office of Planning and Research, State Clearinghouse and Planning Unit.
The following pages contain the State Clearinghouse and Planning Unit letter dated September 26,
2005 that accepted the shortened review period of 30 days and City’s Shortened Review Request
Form with an attached letter to agencies.
Revisions and clarifications to the EIR in response to comments and information received on the
Draft EIR are indicated by strikeout (DEIR text removed) or underline (text added to the Final EIR).
Corrections of typographical errors have been made throughout the document and are not
indicated by strikeout or underline text. Revisions and clarifications are included as Errata pages
within this document.
Each letter has been assigned a number code, and individual comments in each letter have been
coded as well to facilitate responses. For example, the letter from the Riverside Transportation
Commission is identified as letter 1, with comments noted as 1-1, 1-2, etc.
In this document, the City has also provided written responses to comment letters received after the
end of the formal, published 30-day public review period, up through publication of this document
prior to the December 7, 2005 Planning Commission hearing. These comment letters received after
October 28, 2005 are listed below, and responses to these comments follow Letter 7.
Comments Received that Address Environmental Issues
The City received letters from the following organizations and individuals during the public review
period from September 28, 2005 through October 28, 2005:
1. Hideo Sugita, Deputy Executive Director, Riverside County Transportation Commission,
October 4, 2005.
2. Greg Holmes, Unit Chief, Southern California Cleanup Operations Branch, Department of Toxic
Substances Control, October 14, 2005.
3. Stephanie Gordin, Cultural Analyst, Pechanga Band of Luiseño Indians, October 24, 2005.
4. Teresa Tung, Senior Civil Engineer, Riverside County Flood Control and Water Conservation
District. October 26, 2005.
5. Salvador M. Salazar, AICP. Best Best & Krieger LLP. October 26, 2005.
6. Salvador M. Salazar, AICP. Best Best & Krieger LLP. October 28, 2005.
7. Gloria D. Smith, Adams Broadwell Joseph & Cardozo, October 28, 2005.
Responses to Comments on the Draft EIR
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL 9-2
The City received letters from the following organizations and individuals after the close of the
noticed public review period:
8. J.B. “Pete” Olhasso, Santiago Ranchos Property Owners Association Board of Directors,
October 31, 2005.
9. Victoria Mata, Trumark Companies, November 3, 2005.
10. Board of Directors, Los Ranchitos Homeowners Association, November 14, 2005 (received
November 16, 2005).
11. David Oberbeck, via facsimile transmittal on November 14, 2005 (received November 16,
2005).
12. Roger Ziemer, President, Murrieta Temecula Group, November 15, 2005.
13. Linda Betts, via email on November 16, 2005.
14. Jon Silver, President, Covenant Development, via email on November 15, 2005.
15. Gloria D. Smith, Adams Broadwell Joseph & Cardozo, November 16, 2005
16. O.B. Johnson, Chairman of the Board, Murrieta Chamber of Commerce, November 16, 2005.
17. Helen Chichester, November 16, 2005.
18. Don L. Rhodes, November 21, 2005.
Letter 1
1-1
1-2
1-3
1-4
1-5
1-6
1-7
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT 9-11 TEMECULA REGIONAL HOSPITAL
1. Hideo Sugita, Deputy Executive Director, Riverside County Transportation Commission,
October 4, 2005.
Response 1-1
The comment states the Riverside County Transportation Commission’s (RCTC) concern regarding
potential impacts to Highway 79 South and Interstate 15, and RCTC’s support of the traffic
mitigation measures. After project approval, the mitigation measures in the EIR will be implemented
through a Mitigation Monitoring Plan to ensure that all mitigation measures are implemented and
completed. The comment is acknowledged, and no further response is required.
Response 1-2
Emergency vehicles will use either the main entrance on Highway 79 South or the De Portola
driveway, depending upon the direction from which they return from an emergency call. Pre-
emption of traffic signals will not occur.
Response 1-3
As the hospital is a critical facility in the event of an emergency, evacuation of employees is not
anticipated to occur. Persons may instead be taken to the facility should a disaster occur. If the
need to evacuate arises, such would take place in accordance with City emergency response plans,
which provide for multiple evacuation routes and directions depending upon the location and
scope of a disaster.
Response 1-4
According to the project traffic engineer, the MRI facility, Cancer Treatment Center, and Fitness
Center were all included in the trip generation forecast for the project.
Response 1-5
The 1,278 parking spaces that will be provided on surface lots include parking for employees of the
hospital facility. The 1,278 total parking spaces exceed the City’s parking standards, which require
663 parking spaces for the proposed project. The greatest number of additional parking spaces are
those calculated for the hospital portion of the project, for which the Development Code requires
one space per three beds. The parking provided on the site exceeds the standards contained within
the Development Code because applicant, based of experience at other hospitals owned and
operated by Universal Health Services, believes that the City of Temecula code requirements do not
fully account for parking needs within the hospital associated with staff parking, outpatient services,
and other needs within the facility. This is common within most jurisdictions, and hospital facilities
often exceed minimum parking requirements for this reason.1 Providing additional parking guards
against employees parking in surrounding commercial development or residential neighborhoods.
1 Personal Communication, David Prusha, HKS Inc. – Project Architects and Engineers. September 22, 2005.
Responses to Comments on the Draft EIR
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL 9-12
Response 1-6
The applicant has no plans for expansion of the hospital or construction of parking structures.
CEQA guidelines require an EIR to analyze reasonably foreseeable significant effects of a proposed
project. The expansion of the hospital or its facilities is not anticipated in the in future and thus, has
not been analyzed in this EIR. Any future development on this site would be subject to CEQA
review at the time proposed.
Response 1-7
The comment states that there are many other residential and commercial development projects
near the proposed project, and efforts regarding impacts to Highway 79 South and Interstate 15
should be coordinated. The City requires a cumulative analysis of all projects in the vicinity of a
proposed development and analyzes all impacts of all projects through the CEQA process. The
traffic generation from 17 cumulative projects was included in the traffic analysis. No additional
analysis is required.
Letter 2
2-1
2-2
2-3
2-3
Cont.
2-4
2-5
2-6
2-7
2-8
2-9
2-10
2-11
2-12
2-13
2-14
2-15
2-16
2-17
2-18
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT 9-18 TEMECULA REGIONAL HOSPITAL
2. Greg Holmes, Unit Chief, Southern California Cleanup Operations Branch, Department of
Toxic Substances Control, October 14, 2005.
Response 2-1
This comment provides an introduction to the Department of Toxic Substances Control (DTSC)
comments on the Draft EIR. No response is required.
Responses 2-2 through 2-7
As the Initial Study (Appendix A of the Draft EIR) indicated, the project site is not included on a list
of hazardous materials sites compiled pursuant to Government Code Section 65962.5. The
Applicant’s consultant searched DTSC's Hazardous Waste and Substances Site List (Cortese List) for
Riverside County, which confirms that conclusion. A Phase I Environmental Site Assessment was
not required by the City for the application process and is not required under CEQA. Generally,
Phase I reports may be desired by prospective lenders during a property purchase process, but not
as part of a discretionary permit application. This project does not involve any acquisition of
property. Nevertheless, the applicant’s consultant performed the Cortese List search and compiled
other information about the site history. The applicant also provided a prior property owner’s
undated Phase I Environmental Site Assessment prepared by Tumbridge Consulting, Inc. that covers
about 25 acres of the current project site. That Phase I report concludes that no evidence exists
that current or historic use of the site may have resulted in any release of hazardous
waste/substances.
The Tumbridge Consulting Phase I report was completed prior to official identification of the two
known leaking underground fuel tanks (LUFTs) located near, but not on the project site. These two
LUFTs are: a Chevron station located at 31669 Highway 79 and an ARCO gas station at 44239
Margarita Road. However, as stated the DTSC’s comment letter, gas stations are exempt from
“Border Zone of a Contaminated Property.” Remediation of such facilities is the responsibility of
those site owners, and all such remediation must occur in a timely manner and pursuant to state
and federal regulations. In any event, the existence of the off-site LUFTs does not pose a CEQA-
related impact for this Project. Thus, as concluded in the Initial Study, environmental impact will be
less than significant.
Per the project conditions of approval, and consistent with standard City practices and
requirements, the applicant/operator will be required to submit for review and approval by the
Riverside County Department of Environmental Health and Fire Department a Hazardous Material
Inventory Statement and Fire Department Technical Report. Such report will be kept on files, and
should any quantities of hazardous materials used or stored on-site increase or should changes to
operation introduce any additional hazardous material not listed in such reports, the operator will
be required to update such reports.
Response 2-8
The comment is noted. Prior to the demolition of any existing structure, standard procedures to
comply with California environmental regulations, policies, and laws will be implemented.
Responses to Comments on the Draft EIR
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT
9-19 TEMECULA REGIONAL HOSPITAL
Response 2-9
The comment is noted. As noted in the Response to Comments 2-2 through 2-7, no known soils
contamination exists. The project applicant will apply standard procedures to comply with
California environmental regulations, policies, and laws regarding contamination of soils being
excavated, imported, and reused.
Response 2-10
Through the permit issuance process, the City will ensure that the applicant complies with all
applicable local, state, and federal environmental regulations.
Response 2-11 through 2-14
The comments are acknowledged. As stated in Response to Comments 2-2 through 2-7, per the
project conditions of approval and consistent with standard City practices and requirements, the
applicant/operator will be required to submit for review and approval by the Riverside County
Department of Environmental Health and Fire Department a Hazardous Material Inventory
Statement and Fire Department Technical Report. Such report will be kept on files, and should any
quantities of hazardous materials used or stored on-site increase or should changes to operation
introduce any additional hazardous material not listed in such reports, the operator will be required
to update such reports. Moreover, the proposed project will comply with the California Hazardous
Waste Control Law (California Health and Safety Code, Division 20, Chapter 6.5) and the
Hazardous Waste Control Regulations (California Code of Regulations, Title 22, Division 4.5).
Response 2-15
Water quality impacts will be less than significant due to compliance with standard City programs
and practices to implement the City’s NPDES permit. Construction-phase and post-construction
Best Management Practices (BMPs) will be designed and included into plans for submittal to, and
subject to the approval of, the City Engineer prior to issuance of a grading permit. The project
proponent will also provide proof of a mechanism to ensure ongoing long-term maintenance of all
structural post-construction BMPs.
Response 2-16
As indicated in the responses above, no known hazardous soils conditions exist on the property.
The Rancho California Water District is responsible for ensuring acceptable groundwater quality.
Through the permit issuance process, the City will ensure that the applicant complies with all
applicable local, state, and federal environmental regulations.
Response 2-17
Refer to Responses 2-2 through 2-7.
Response 2-18
The comment is noted. This comment provides a closing statement to DTSC’s comments on the
Draft EIR.
Letter 3
3-1
3-2
3-3
3-4
3-6
3-5
3-6
Cont.
3-7
3-7
Cont.
3-8
3-9
3-10
3-12
3-11
3-13
3-12
Cont.
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT 9-25 TEMECULA REGIONAL HOSPITAL
3. Stephanie Gordin, Cultural Analyst, Pechanga Band of Luiseño Indians, October 24, 2005.
Response 3-1
This comment provides an introduction to the Pechanga Band of Luiseño Indians’ (Pechanga Tribe)
comments on the Draft EIR. The comment is a formal request pursuant to Public Resources Code
§21092.2, to the Pechanga Tribe to be noticed throughout the proposed project’s CEQA process.
The Pechanga Tribe has been on the distribution list for throughout the entire CEQA process and
will continue to be notified when mailings occur.
Response 3-2
This comment is acknowledged regarding the additional mitigation measures and conditions of
approval. Both the City of Temecula Planning Commission and City Council will review all project
conditions of approval, including those noted in the Initial Study for the proposed project and
incorporated into the conditions of approval documents. The conditions of approval include the
requirement of a pre-construction agreement/treatment plan with the Pechanga Band of Luiseño
Indians prior to the issuance of grading permits. Consistent with state law, such plan must set forth
and contain the terms and conditions for the treatment of any discoveries of any previously
unknown subsurface Native American cultural resources or human remains that may occur during
grading activities. Additionally, the City has included the following condition of approval for the
project:
A note on the grading plans shall be provided and shall read as follows:
If at any time during excavation/construction of the site, archaeological/cultural resources, or any
artifact or other object which reasonably appears to be evidence of cultural or archaeological
resource is discovered, the property owner shall immediately advise the City of such and the City
shall cause all further excavation or other disturbance of the affected area to immediately cease.
The Director of Planning at his/her sole discretion may require the property to deposit a sum of
money it deems reasonably necessary to allow the City to consult and/or authorize an
independent, fully qualified specialist to inspect the site at no cost to the City, in order to assess
the significance of the find.
Upon determining that the discovery is not an archaeological/cultural resource, the Director of
Planning shall notify the property owner of such determination and shall authorize the resumption
of work. Upon determining that the discovery is an archaeological/cultural resource, the Director
of Planning shall notify the property owner that no further excavation or development may take
place until a mitigation plan or other corrective measures have been approved by the Director of
Planning.
Response 3-3
This comment indicates a concern about the lack of inclusion of cultural resources in the CEQA
evaluation of the proposed project. The Initial Study, contained in the Draft EIR as Appendix A,
evaluated the proposed project’s impact on cultura l r e s o u r c e s . P u r s u a n t t o C E Q A G u i d e l i n e s
Section 15064.5, the proposed project will result in a less than significant impact to archeological
and historical resources. The following two reports, included as references for the Initial Study,
support the conclusion of a less than significant impact on cultural resources. Therefore, no
additional analysis is required per CEQA.
Responses to Comments on the Draft EIR
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL 9-26
1. Historical/Archaeological Resources Survey Report, Temecula Hospital, CRM Tech.,
September 17, 2004.
2. Paleontological Resource Assessment Report, Temecula Hospital Project, CRM Tech.,
September 16, 2004.
As indicated in Response 3-2, the applicant will be required to guard against harm to any previously
unidentified subsurface cultural resources during the project grading process.
Response 3-4
See Response 3-2. The applicant will be required to comply with agreements, as well as Sections
15064.5(d) and (e) of the CEQA Guidelines (California Code of Regulations) addressing the
discovery of human remains during the grading or construction process.
Response 3-5
The comment is acknowledged. Maintaining a good working relationship with the Pechanga Tribe
is important to the City. As noted in Responses 3-1 and 3-2, the Pechanga Tribe is included on the
project notification list, and per project conditions of approval, the Tribe will be consulted by the
project applicant and can be present during ground-disturbing activities.
Response 3-6
The comment is noted. Please refer to Responses 3-2 and 3-3. If the project is approved by the City
Council, conditions of approval will be adopted by the City, and the conditions will be enforceable
measures that the applicant must comply with prior to proceeding with different phases of the
project. Additional mitigation is not necessary per CEQA Guidelines Section 15143 because impact
to cultural resources were identified as less than significant during the Initial Study analysis.
Response 3-7
The comment is acknowledged. Please refer to Responses 3-2 and 3-3. Pursuant to Sections
15064.5(d) and (e) of the CEQA Guidelines and the proposed conditions of approval, if human
remains are identified during the grading or excavation phase, state law and standard reporting
practice will be implemented, and the site must be cleared by the appropriate authorities prior to
the restart of construction activities. The Tribe’s assertion that it constitutes the most likely
descendant of any human remains that may be found is noted.
Response 3-8 through 3-12
The comment is noted. Please refer to Response 3-2. All four conditions of approval cited in the
Initial Study, all of which reflect standard City practices and regulations, will be applied to the
project.
Responses to Comments on the Draft EIR
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT
9-27 TEMECULA REGIONAL HOSPITAL
Response 3-13
N o k n o w n s a c r e d s i t e s w e r e i d e n t i f i e d a s p a r t o f t h e c u l t u r a l r e s o u r c e i n v e s t i g a t i o n s c i t e d i n
Response 3-3. If, as result of grading and construction monitoring activities, any sacred site is
discovered, such activities will cease until appropriate reconnaissance and treatment can be
completed. Consistent with state law (see Public Resources Code Section 21083.2[b]), treatment
could include redesigning of project components to avoid, protect, and respect such cultural
resources.
Letter 4
4-2
4-1
4-3
4-4
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT 9-30 TEMECULA REGIONAL HOSPITAL
4. Teresa Tung, Senior Civil Engineer, Riverside County Flood Control and Water Conservation
District. October 26, 2005.
Response 4-1
This comment provides an introduction to the Riverside County Flood Control and Water
Conservation District’s (District) comments on the Draft EIR. No response is necessary.
Response 4-2
The comment is noted. Per standard City practices and regulations, the Public Works Department
has included conditions of approval for the project that require an encroachment permit from the
District for any work within the District’s right-of-way. An additional condition of approval requires
that a copy of the grading and improvement plans, along with supporting hydrologic and hydraulic
calculations, be submitted to the District for approval prior to the issuance of any permit.
Response 4-3
In response to the comment, under the “Storm Water Drainage and Water Quality” subheading on
page 4-33 of the Final EIR, the first sentence of the first paragraph has been revised to read as
follows:
To ensure that adequate flood control capacity is available to support new development, all
proposed development projects within the City of Temecula are may be reviewed by the
Riverside County Flood Control and Water Conservation District, at the request of the City,
prior to approval by the City of Temecula.
The revision does not affect any of the impact conclusions contained in the EIR. As noted in Response
4-2, conditions of approval require that grading and improvement plans, along with supporting
hydrologic and hydraulic calculations, be submitted to the District for approval prior to the issuance
of any permit.
Response 4-4
As described on page 4-31 of the Draft EIR, currently the eastern watershed on the project site
drains to the drainage channel (the District’s existing Line V Stage 2 Channel). The project applicant
proposes to construct storm drain outlets into the District’s Line V Stage 2 Channel directly east of
the project site. Current flows into the channel are anticipated to increase as a result of the project.
The hydrology and drainage analysis report prepared for the project (November 2004) analyzed the
impact on channel capacity. The report concluded that the slight increase in flows into the channel
will be less than significant; thus, the proposed project will not impact downstream drainage
systems.2
Per standard City practices and regulations, a condition of approval will be applied to the project
requiring that all grading and improvement plans, along with supporting hydrologic and hydraulic
2 Hunter Associates, Ltd. (A TRC Company). Hydrology & Drainage Analysis for Temecula Regional Medical Center.
November 2004.
Responses to Comments on the Draft EIR
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT
9-31 TEMECULA REGIONAL HOSPITAL
calculations, be submitted to the District for approval prior to the issuance of any permit. The
applicant will be required to implement any measures imposed by the District.
The comment suggests that biological resource impacts should be analyzed in relation to the
channel. The project applicant does not propose construction within the channel and thus, no such
analysis has been conducted or is required. If, subsequent to project approval and through the
review of improvement plans, any construction within the channel is required to comply with
District directives or to address any additional requirements that the City Council may impose as a
result of public hearings, then subsequent environmental review will be required per CEQA for any
such activity.
The comment suggests that air quality and water quality impacts should be analyzed in relation to
the channel. Section 4.1, Air Quality of the Draft EIR analyzed air quality impacts associated with
the construction of the proposed project. No additional impact analysis is required for air quality.
Water quality impacts will be less than significant as a result of compliance with standard City
practices and regulations, enforced through conditions of approval, that implement the City’s
NPDES permit. Construction-phase and post-construction BMPs will be designed and included into
plans for submittal to, and subject to the approval of, the City Engineer prior to issuance of a
grading permit. The project proponent will also provide proof of a mechanism to ensure ongoing
long-term maintenance of all structural post-construction BMPs. No additional impact analysis is
required with regard to water quality.
All other impacts related to the District channel are considered less then significant because the
proposed project does not include construction within the channel. Therefore, no additional impact
analysis is required.
Letter 5
5-1
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT 9-34 TEMECULA REGIONAL HOSPITAL
5. Salvador M. Salazar, AICP. Best Best & Krieger LLP. October 26, 2005.
Response 5-1
The comment is noted. Please refer to the letter (Debbie Ubnoske, Director of Planning, City of
Temecula. October 31, 2005.) on the following page as a response to Letter 5.
Letter 6
6-1
6-1
Cont.
6-2
6-3
6-3
Cont.
6-5
6-4
6-6
6-9
6-8
6-7
6-6
Cont.
6-9
Cont.
6-10
6-10
Cont.
6-11
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT 9-42 TEMECULA REGIONAL HOSPITAL
6. Salvador M. Salazar, AICP. Best Best & Krieger LLP. October 28, 2005.
Response 6-1
This comment provides an introduction to the Best Best & Krieger LLP comments on the Draft EIR;
identifies Brad and Nicole Stormon as owners of a single-family residence located at the northeast
corner of De Portola Road and Pio Pico Road, across De Portola Road from the project site; and
provides a summary of the Stormons’ interests in the proposed project. The comment also
describes the Stormons' participation in past public hearings and scoping meetings, concluding that
the Draft EIR fails to analyze several concerns noted by the Stormons, including spill-over traffic
impacts on Pio Pico Road. The comment is acknowledged. Please refer to Responses 6-3, 6-4, and
6-5 concerning analysis of traffic impacts to Pio Pico Road.
Response 6-2
The comment provides suggested mitigation measures for the project to reduce traffic, noise, and
aesthetic impacts, including solid fencing along the Stormons’ property frontage and traffic-calming
devices and signage to reduce potential traffic along Pio Pico Road, noting that these measures
would lessen the significant impacts of the project. The comment also notes that these measures
are supported by past testimony of the Stormons and other neighbors. However, none of these
measures is tied to a specific significant project impact identified in the Draft EIR. The traffic
analysis conducted for the project identified no significant impact to De Portola Road. As noted in
Response 6-5, a traffic analysis of Pio Pico Road was conducted pursuant to the Stormons’
comments. Traffic impacts to Pio Pico Road were found to be less than significant. Traffic noise
and aesthetic impacts of the project were also found to be less than significant in the Draft EIR.
Therefore, neither of these mitigation measures is required.
Responses 6-3 and 6-4
The commentor’s opinions are acknowledged. An analysis of the De Portola Road/Pio Pico Road
intersection was not conducted in the traffic study since only a very small amount of project traffic
is expected to utilize Pio Pico Road to reach the hospital. This is because project traffic would need
to travel out-of-direction to use Pio Pico Road to reach the site. While Pio Pico Road is a viable
short cut to utilize westbound De Portola Road, it is not a timely way to head eastbound on De
Portola Road. However, in response to this concern, an analysis of this intersection was conducted,
assuming all traffic which would otherwise use Margarita Road would instead use Pio Pico Road.
Please refer to Response 6-5 regarding the Pio Pico Road analysis.
Response 6-5
Linscott, Law & Greenspan, Engineers (LLG), conducted an A.M. and P.M. peak-hour traffic count at
the intersection on Thursday November 3, 2005 during a typical workday. Using these counts, LLG
conducted an A.M. and P.M. unsignalized intersection level of service (LOS) analysis for existing,
existing + cumulative project, and the existing + cumulative projects + total project conditions. In
addition, LLG assumed a worst-case scenario, diverting all Margarita Road traffic (15%) to Pio Pico
Road. The resulting analysis shows that the intersection of Pio Pico Road and De Portola Road is
calculated to operate at LOS B conditions under existing conditions and LOS C conditions under
the existing + cumulative projects + total project conditions. The analysis is shown on the following
pages.
Responses to Comments on the Draft EIR
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT
9-49 TEMECULA REGIONAL HOSPITAL
The resulting analysis shows that the intersection of Pio Pico Road and De Portola Road is
calculated to operate at LOS B under existing conditions and LOS C conditions under existing +
cumulative + total project conditions. Since the project does not cause this intersection to operate
at LOS E or LOS F, impact is less than significant, and no mitigation is required. The signage
proposed in the comment as a potential mitigation measure is feasible, but bears no relationship to
any identified significant impact associated with the project. No mitigation measure is required.
Furthermore, since no new significant impact or mitigation measure has been identified,
recirculation of the Draft EIR is not required. (CEQA Guidelines, Section 15088.5 [a][1])
Response 6-6
This comment restates helicopter noise issues, providing an introduction to comment 6-7. This
comment does not address an environmental issue or raise any question regarding the analysis or
conclusions in the EIR. No response is required.
Response 6-7
This comment requests further analysis of potential helicopter operations and noise impacts
associated with the hospital, and proposes a mitigation measure (construction of a block wall on the
southern portion of the Stormons’ property) as a means to minimize the ambient and interior noise
levels caused by helicopter flights.
As stated in the Draft EIR (page 4-58), the project applicant indicates that on average, about one
helicopter flight per month will occur at the hospital. This assertion is based upon Universal Health
Services’ previous experience designing, building, and managing similar facilities. Therefore, the
Draft EIR analyzes a single-event, worst-case, nighttime flight scenario under normal (non-
emergency) operating conditions. Under these conditions, and pursuant to mitigation measure N-3,
helicopter pilots responding to calls for patient transport shall be informed of a preferred approach
and departure heading of 135 degrees southwest. As described on page 4-59 of the Draft EIR, the
60 dB contour associated with this worst-case scenario under normal operating conditions does not
extend to nearby homes, so helicopter flights are not anticipated to increase ambient noise levels by
3 dB or more. Therefore, impacts associated with any single helicopter flight under normal
operating conditions will not be significant, and no additional mitigation is required.
The Draft EIR also considers that up to six helicopter flights per month may occur, pursuant to the
Emergency Medical Services Landing Site permit to be obtained by the applicant from the California
Department of Transportation, Division of Aeronautics. Furthermore, the Draft EIR notes on page 4-
59 that the preferred flight path might change for any given flight, depending upon weather
conditions and wind speeds and direction. As noted on page 4-59 of the Draft EIR, the City of
Temecula does not have any regulations applicable to point-source noise events, such as helicopter
operations. Furthermore, it is conceivable that emergency conditions, such as the need to evacuate
the hospital or respond to a mass casualty event, might necessitate several helicopters to be within
the vicinity of the helipad at any given time. Operation of more than six helicopters per month is
expressly permitted under these conditions by the Caltrans permit, as described in mitigation
measure N-1.
For these reasons, the Draft EIR states that with operation of up to six helicopters per month, nearby
residents could experience short-term exterior and interior noise levels that could be considered
annoying (page 4-59). The Draft EIR concludes that the potential annoyance to residents near the
Responses to Comments on the Draft EIR
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL 9-50
hospital associated with up to six helicopter flights per month constitutes a significant impact. Due
to the unpredictable nature of helicopter flights and uncertainty regarding the frequency of
helicopter operations under normal and emergency conditions, the Draft EIR further concludes that
the impact is significant and unavoidable after mitigation incorporation, and a Statement of
Overriding Considerations is required.
Given that the City has no regulations applicable to point source noise events, additional analysis
requested by the commentor would not change the conclusions reached in the Draft EIR, as no
exterior or interior dB(A) significance threshold applies for point source noise in the City of
Temecula. Furthermore, additional study suggested by the commentor regarding the average
number of helicopter flights at a similar facility would not address emergency conditions, which
would certainly exceed average operating condition s . T h e r e f o r e , n o c h a n g e i n i m p a c t s w o u l d
result. Increased noise levels would remain annoying to nearby property owners, and impact would
remain significant and unavoidable.
While feasible, the proposed mitigation measure bears no relationship to impacts identified for a
single worst-case flight (as the noise contours extend to the southwest and the subject property is
located to the northeast), and bears only a tangential relationship to identified significant impacts
associated with operation of up to six flights per month. Lacking a point-source noise standard, it is
not possible to determine if the proposed block wall would result in a less than significant impact,
and the conclusions stated in the EIR remain unchanged. Furthermore, the noise consultant for the
EIR has indicated that a block wall at the southerly end of the Stormon’s property, approximately
one thousand feet from the proposed helipad, would be ineffective at mitigating noise during take-
off and landing maneuvers of helicopters.
Response 6-8
This comment notes that the City did not analyze the noise that could be generated by the
maximum number of flights arriving at the hospital, and suggests that the Draft EIR be recirculated
due to brief and conclusory treatment of helicopter noise impacts.
As noted in Response 6-7, the City of Temecula has no regulations applicable to point-source noise
events, such as helicopter flights. Furthermore, it is not possible to determine if proposed mitigation
would result in a less than significant impact in the absence of exterior or interior dB(A) significance
thresholds. Therefore, further study of helicopter flight operations and recirculation of the EIR
would not result in any change to impact conclusions or mitigation within the EIR, or the need to
adopt a Statement of Overriding Considerations.
Response 6-9
This comment refers to portions of the Draft EIR addressing aesthetics impacts, asserts that the
aesthetics analysis was dismissed because views are not protected, and opines that conclusions
within the aesthetics section of the Draft EIR are not based on substantial evidence.
Pages 4-5 through 4-13 of the Draft EIR present the analysis of visual character or quality impacts
associated with the proposed hospital. Two photographic renderings were prepared, one
illustrating views from a hillside to the north overlooking the project site (presented in the Draft EIR
as Figures 4-2a and 4-2b), and a second illustrating conditions just north of the intersection of Pio
Pico Road and De Portola Road (presented in the Draft EIR as Figures 4-3a and 4-3b). As noted on
Responses to Comments on the Draft EIR
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT
9-51 TEMECULA REGIONAL HOSPITAL
Page 4-5 of the Draft EIR, the project will be visible from various residential lots north of the project
site. Furthermore, while the project can be seen from the north, views of Palomar Mountain from
areas north of the project site will not be blocked. Furthermore, at the request of the Santiago
Ranchos Property Association, balloons were elevated above the project site on Saturday,
November 12, 2005 to provide residents information regarding the proposed height of the hospital
towers. The renderings and use of balloons to indicate the proposed project’s height are standard
and accepted techniques used to analyze the view shed impacts of a project under CEQA. The
analysis was not dismissed. The Draft EIR and subsequent activities requested by the public have
adequately disclosed the potential view shed impacts of the project.
The Draft EIR presents substantial evidence regarding the potential aesthetic impacts of the
proposed project and describes how project features will reduce impacts (pages 4-5 and 4-12).
However, because the City of Temecula Municipal Code does not contain any view protection
regulations, no significant impact results.
Response 6-10
The comment asserts that mitigation measures A-1 and A-3 defer mitigation of aesthetic impacts.
Pursuant to mitigation measure A-1, the City has included the following condition of approval for
the project:
Final construction plans shall demonstrate that all exterior lighting shall comply with Mount
Palomar Lighting Ordinance 655, be directed down and fully shielded. Lighting onto adjacent
properties shall be limited to the greatest extent possible.
Compliance with this standard project review requirement constitutes compliance with mitigation
measure A-1 and will ensure a less than significant impact. This information clarifies how the City
will implement the mitigation measure (CEQA Guidelines Section 15088.5 [b]). No new measure is
proposed; therefore, recirculation of the Draft EIR is not required.
Pursuant to mitigation measure A-3, the City has included the following conditions of approval for
the project:
A combination of large (no less than 24-inch box) Afghan Pines and California Pepper trees (or
other large screen trees) shall be provided along the northern perimeter of the project to screen
off-site views of the development as approved by the Director of Planning.
A landscaped berm shall be provided along the northern property lines adjacent to the
residentially zoned lots and DePortola, with mature (24” and 36” box) screen trees to screen the
view of the buildings and reduce the amount of glare from the project site, subject to approval
by the Director of Planning. A cross section shall be provided on grading and landscape plans
verifying the buffer area.
Therefore, the amount and conditions under which additional landscaping is required on the
northern boundary of the site have been defined. Compliance with these conditions of approval
constitutes compliance with mitigation measure A-3, and will ensure a less than significant impact.
This information clarifies how the City will implement the mitigation measure (CEQA Guidelines
Section 15088.5 [b]). No new measure is proposed; therefore, recirculation of the Draft EIR is not
required.
Responses to Comments on the Draft EIR
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL 9-52
Response 6-11
This comment reiterates the assertions in the comment letter that the Draft EIR fails to adequately
analyze impacts relative to traffic, noise, and aesthetics; that the Stormons’ suggested mitigation
measures should be incorporated in the Draft EIR; and/or that the Draft EIR should be recirculated.
Please refer to Responses 6-2 through 6-10 which address these issues.
1818-003a
DANIEL L. CARDOZO
RIC RD T. DRURY
THO A. ENSLOW
TANYA A. GULESSERIAN
MA D. JOSEPH
OSH R. MESERVE
SU EESAPATI
GLORIA D. SMITH
FELLOW
KEVIN S. GOLDEN
OF COUNSEL
THOMAS R. ADAMS
ANN BROADWELL
HA
MAS
RC
A
MA P
SACRAMENTO OFFICE
1225 8th STREET, SUITE 550
SACRAMENTO, CA 95814-4810
TEL: (916) 444-6201
FAX: (916) 444-6209
ADAMS BROADWELL JOSEPH & CARDOZO
A PROFESSIONAL CORPORATION
ATTORNEYS AT LAW
601 GATEWAY BOULEVARD, SUITE 1000
SOUTH SAN FRANCISCO, CA 94080-7037
___________
TEL: (650 660
FAX: (650 062
gsmith@adams roadwell.com
) 589-1
) 589-5
b
printed on recycled paper
October 28, 2005
TRANSMITTED VIA EMAIL
AND REGULAR MAIL
Mr. Emery Papp
Planning Department
City of Temecula
43200 Business Park Drive
Temecula CA 92589
Re: Comments on the Draft Environmental Impact Report for the
Temecula Regional Hospital
Dear Mr. Papp:
On behalf of the California Nurses Association (“CNA”), this letter provides
preliminary comments on the City of Temecula’s focused environmental impact
report (“focused EIR”) for the Temecula Regional Hospital project (“Project). As
explained below, the City of Temecula’s (“City”) focused EIR does not comply with
the requirements of the California Environmental Quality Act (“CEQA”).1
Accordingly, the City may not approve the Project or grant any permits for it until
the City prepares and circulates a full EIR that addresses all of the environmental
impacts associated with the proposed Project.
The City’s proposed Project is located within city limits on undeveloped land
near south Highway 79 and Margarita Road. Temecula Creek runs approximately
1000 feet south of the project site. (Focused EIR, at p. 1-1.) The project site consists
of 35.31 acres of vacant land on gently sloping terrain, with a high point between
two watersheds on the western side of the parcel. (Id., at p. 1-2.) The eastern
boundary of the project contains dense riparian vegetation, presumably along
Temecula Creek.
1 Public Resources Code §§ 21000 et seq.
Letter 7
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The proposed Project consists of a 566,160-square-foot medical facility that
will include a two-tower hospital complex with approximately 320 beds. One tower
will be six stories and the other five stories. The hospital will provide in-patient,
out-patient and emergency services. The facility will also include a 10,000-square-
foot cancer center in an adjacent one-story building, and an 8,000 square-foot
fitness rehabilitation center. The Project also includes a 60-foot by 60-foot helipad
and 1,278 parking spaces. (Id., at p. 1-3.)
According to the focused EIR, the Project will have unavoidable and
significant short term, long term and cumulative impacts to air quality. The Project
will also have unavoidable and significant impacts concerning traffic and noise.
The California Nurses Association is one of California’s oldest nonprofit social
welfare institutions. Founded in 1901, today CNA represents over 65,000 members
in more than 165 facilities throughout the state. CNA has represented its members
on nursing and public health issues before municipal, county, and state bodies for
over 100 years. Over 100 members of the CNA provide professional care for
patients in medical facilities in the vicinity of Riverside County and Temecula.
CNA’s comments are made in its representative capacity of over 100 CNA members
and their families who currently reside in Riverside County, on behalf of its
members and their families throughout California, and on behalf of health care
consumers generally who are directly affected in their health and general welfare
by the availability of, access to, and quality and safety of health care services.
CNA members and their families have a direct and substantial interest in
assuring that scarce health care resources are devoted to the provision of safe and
quality care to all persons, and that new health care facilities are developed,
constructed and operated in manner that will serve the public health priority of
universal access and a single standard of safe and quality care.
In addition, like the public at large, CNA members are concerned about
sustainable land use and development in this county. Similarly, CNA members live
in the communities that suffer the impacts of environmentally detrimental and
poorly planned projects. Ill-conceived development, in turn, may jeopardize human
health and safety. This is particularly true here given that underground hazardous
waste occurs in close proximity to the proposed Project, and the fact that the City
seeks to situate a hospital adjacent to an active earthquake fault zone. Likewise,
environmentally detrimental projects may jeopardize future jobs by making it more
difficult and more expensive for business and industry to expand in the region, and
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by making it less desirable for businesses to locate and people to live here. CNA
members breathe the same polluted air that others breathe and suffer the same
health and safety impacts. The CNA therefore has a strong interest in enforcing
environmental laws such as CEQA to protect its members.
We have prepared these comments with the assistance of three technical
experts: Mr. Tom Brohard, Mr. Matt Hagemann, and Dr. Petra Pless. The
comments of each of these experts along with their curriculum vitae are provided
herein as Attachments 1, 2 and 3. Please note that these experts’ comments
supplement the issues addressed below, thus each expert’s comments should be
addressed and responded to separately.
I. INTRODUCTION
CEQA has two basic purposes, neither of which the focused EIR satisfies.
First, CEQA is designed to inform decision makers and the public about the
potential, significant environmental effects of a project. (14 Cal. Code Regs. (“CEQA
Guidelines”) § 15002(a)(1).) The EIR is the “heart” of this requirement. (No Oil,
Inc. v. City of Los Angeles (1974) 13 Cal.3d 68, 84.) The EIR has been described as
“an environmental ‘alarm bell’ whose purpose it is to alert the public and its
responsible officials to environmental changes before they have reached ecological
points of no return.” (County of Inyo v. Yorty (1973) 32 Cal.App.3d 795.)
Second, CEQA directs public agencies to avoid or reduce environmental
damage when possible by requiring alternatives or mitigation measures. (CEQA
Guidelines § 15002(a)(2) and (3).See also Citizens of Goleta Valley v. Board of
Supervisors (1990) 52 Cal.3d 553, 564; Laurel Heights Improvement Ass’n v. Regents
of the University of California (1988) 47 Cal.3d 376, 400.)
The City failed to satisfy these purposes by not issuing a full EIR but instead
circulated a focused EIR addressing only a small portion of the actual impacts
associated with the Project. In fact, a focused EIR, by design, is a final-stage tiering
document, but the City has not conducting any tiering for this Project. In addition,
the City has not complied with CEQA by: failing to provide sufficient information to
conduct project-level environmental review of the Project; failing to accurately
describe the environmental setting and establish an accurate baseline necessary for
an accurate evaluation of environmental impacts; failing to disclose all potentially
significant environmental impacts; failing to describe inconsistencies with the
applicable general plan and zoning ordinance policies and regulations; failing to
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provide adequate mitigation measures to avoid impacts; and failing to analyze
cumulative impacts.
Based on the foregoing, the focused EIR fails to inform the public or decision
makers about the Project’s significant impacts, and fails to avoid or reduce
environmental damage when possible by requiring alternatives or mitigation
measures. The City must correct these shortcomings and recirculate a full EIR for
public review and comment.
II. THE CITY VIOLATED CEQA’S STATUTORY PUBLIC REVIEW
PERIOD
As a preliminary matter, the CNA hereby reserve its right to file
supplemental comments at a later date because the City illegally curtailed its
Project’s public review period from the statutorily required 45 days to 30 days.
Specifically, CEQA expressly provides the public with a 45-day review and comment
period for all draft environmental impact reports submitted to the State
Clearinghouse (No. 2005031017). (CEQA, section 21091.) Here the City
impermissibly curtailed the review time by a full two weeks, which precluded the
CNA from providing full and complete comments on the Project.
It appears that, coincident to the City submitting its focused EIR to the
State Clearinghouse, the City also requested a shortened public review period.2
(Focused EIR, at p. 2-3.) The State Clearinghouse website indicates that it granted
the City’s improper request for shortened time, but does not state the date or
justification of the State’s decision. (www.ceqanet.ca.gov) Appendix K of the CEQA
Guideline describes exceptional and very limited circumstances under which a
lead agency may curtail the public’s review period, and it is clear that the City’s
focused EIR meets none of the below criteria:
Under exceptional circumstances, and when requested in writing by the lead
agency, the State Clearinghouse in the Office of Planning and Research (OPR)
may shorten the usual review periods for proposed negative declarations,
mitigated negative declarations and draft EIRs submitted to the
Clearinghouse. A request must be made by the decision-making body of the
2 Note, that the focused EIR simply declares that the City intended to apply for a curtailed review
period, omitting any justification or indication of final resolution of this issue. (Focused EIR, at p. 2-
1.)
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lead agency, or by a properly authorized representative of the decision-making
body.
A shortened review period may be granted when any of the following
circumstances exist:
(1) The lead agency is operating under an extension of the one-year period for
completion of an EIR and would not otherwise be able to complete the EIR
within the extended period.
(2) The public project applicant is under severe time constraints with regard to
obtaining financing or exercising options which cannot be met without
shortening the review period.
(3) The document is a supplement to a draft EIR or proposed negative
declaration or mitigated negative declaration previously submitted to the
State Clearinghouse.
(4) The health and safety of the community would be at risk unless the project
is approved expeditiously.
(5) The document is a revised draft EIR, or proposed negative declaration or
mitigated negative declaration, where changes in the document are primarily
the result of comments from agencies and the public.
Shortened review cannot be provided to a draft EIR or proposed negative
declaration or mitigated negative declaration which has already begun the
usual review process. Prior to requesting shortened review, the lead agency
should have already issued a notice of preparation and received comments
from applicable State agencies, in the case of an EIR, or consulted with
applicable State agencies, in the case of a proposed negative declaration or
mitigated negative declaration.
(CEQA Guidelines, Appendix K)
According to State Clearinghouse senior planner, Scott Morgan, the City
relied on section (5), above (Telephone communication, Oct. 24, 2005). However,
that provision only allows shortened time when the lead agency has circulated a
revised DEIR, a proposed negative declaration or a mitigated negative declaration,
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October 28, 2005
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none of which applies here. Instead, the City issued a focused EIR, and circulated it
for the first time on September 28, 2005. Thus, Appendix K’s section 5 is
inapplicable, as are all of the other limited exceptions to CEQA’s 45-day rule.
Therefore, the City submitted a wrongful request which the State granted, likely
assuming the City’s request had been made on valid grounds. In any case, the
City’s dubious actions have curtailed the public’s and decision makers’ review of its
CEQA document by a full two weeks.
Because the CNA was illegally denied the full statutory period to review and
comment upon the City’s focused EIR, the CNA hereby reserves the right to
supplement these preliminary comments at a later date.
III. THE DEIR FAILS TO ACCURATELY DESCRIBE THE PROJECT
An accurate, stable and finite project description is the sine qua non of an
informative and legally adequate EIR. (County of Inyo v. City of Los Angeles (1977)
71 Cal.App.3d 185, 192.) Without it, CEQA’s objective of fostering public disclosure
and informed environmental decision-making is stymied. As one analyst has noted:
The adequacy of an EIR’s project description is closely linked to the adequacy
of the EIR’s analysis of the project’s environmental effects. If the description
is inadequate because it fails to discuss the complete project, the
environmental analysis will probably reflect the same mistake. (Kostka and
Zischke, “Practice Under the California Environmental Quality Act,” p. 474
(8/99 update).)
The project description must be accurate and consistent throughout an EIR.
(County of Inyo, 71 Cal.App.3d at 192.) It is impossible for the public to make
informed comments on a project of unknown or ever-changing proportions. “A
curtailed or distorted project description may stultify the objectives of the reporting
process. Only through an accurate view of the project may affected outsiders and
public decision-makers balance the proposal’s benefit against its environmental
costs . . . .” (County of Inyo, 71 Cal.App.3d at 192-193.) In County of Inyo, the lead
agency first defined the project to include only the extraction of groundwater from
Owens Valley for export and use on city-owned land in Inyo and Mono Counties.
Then, the project was defined as “one part of the larger operation of the Los Angeles
Aqueduct System.” And in yet another part of the document, the project included
the entire Los Angeles Aqueduct System. (Id. at 190.) The Court found the
inconsistent project descriptions to be harmful because “the inconsistency confused
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the public and commenting agencies, thus vitiating the usefulness of the process”. . .
“as a vehicle for intelligent public participation. . . . A curtailed, enigmatic or
unstable project description draws a red herring across the path of public input.”
(Id. at 197-198.)
A project is “the whole of an action, which has a potential for resulting in a
physical change in the environment, directly or ultimately”…including “the activity
which is being approved and which may be subject to several discretionary
approvals by governmental agencies.” (CEQA Guidelines § 15378(a), (c); see
McQueen v. Board of Directors (1988) 202 Cal.App.3d 1136, 1143.) In McQueen, the
plaintiff challenged the approval of a project that was improperly described in a
CEQA exemption as simply acquiring surplus federal property for public open
space. (202 Cal.App.3d at pp. 1140, 1144.) The court concluded that this
description impermissibly “divided the project into segments which evade CEQA
review” because the public entity had plans for the interim use and management of
this property that contained polychlorinated biphenyls. (Id. at pp. 1144-1146.) An
accurate description of the property also demonstrated the project was not exempt
from CEQA review. (Id. at p. 1149.)
As discussed below, the focused EIR fails to describe the Project and its
environmental setting accurately and completely. It omits key project features that
have the potential to result in significant impacts. As a result, potentially
significant environmental impacts were not adequately analyzed or addressed by
the focused EIR. Therefore, the focused EIR is fatally deficient under CEQA.
A. The Focused EIR Failed To Accurately Describe The Project
Construction Schedule And Equipment
The focused EIR fails to include a detailed construction schedule with the list
of equipment that will be used, the horsepower of each piece of equipment, the
hours of operation, the type of fuel used, the length and timing of the individual
construction phases, and so forth. Further, the focused EIR contains no information
regarding the expected timing of completion of each of the major project phases as
well as the buildout horizon for the entire Project. This information is typically
provided in an EIR, but was not. Without this information, emissions resulting
from construction cannot be accurately estimated. As discussed below, the focused
EIR uses mostly default assumptions to model construction emissions, which may
considerably underestimate emissions.
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1. The Focused EIR Contains No Grading Plan Or Cut-And-
Fill Analysis
The Initial Study for the Project finds no significant impacts with respect to
geology and soils, relying on a perfunctory geotechnical investigation conducted for
the Project. The Initial Study fails to include this study for public review.
According to the Initial Study, the geotechnical investigation recommends over-
excavation up to 24 inches below existing grade and recompaction for support of
building slabs and pavement. (Appx. A, NOP/Initial Study, p. 16 through 18.) Yet,
neither the focused EIR nor the Initial Study contains a grading plan or any other
information regarding the amount of cut and fill necessary for development of the
site or the projected amount and location of spoils, if any. Review of the focused
EIR’s emissions modeling suggests that only some minor amount of material will
have to be im/exported.3 This suggests that the focused EIR largely relies on
balancing the amount of cut and fill of native soil on site with no additional import
of fill material or export of excess cut material. Yet neither the Initial Study nor
the focused EIR contains any information demonstrating that cut and fill can, in
fact, be balanced on site. This information is typically derived from a grading plan,
which would ordinarily be provided in an EIR, but was not. If cut and fill cannot be
balanced on site, material would have to be imported or exported, which causes
additional emissions.
2. The Focused DEIR Failed To Adequately Describe
Mechanical Equipment
The Project requires a variety of mechanical equipment, including heating
and air conditioning equipment, emergency generators, boilers, and so forth. None
of this equipment is described with any detail in the focused EIR. The focused EIR
provides only the following vague statement: “A truck loading area and facilities
plant will be located at the eastern edge of the hospital, south of the helipad. This
area provides infrastructure needed to support the hospital, such as a loading dock,
cooling tower, generators, transformers, a fuel tank, and a bulk oxygen storage
area.” (Focused EIR, p. 3-4.) Review of the Project site plan indicates three cooling
towers, two emergency generators, two transformers, and a fuel tank located in the
3 URBEMIS2002 modeling assumes 18 vehicle miles traveled (“VMT”) for on-road truck travel
during the grading phase, suggesting a minimal im/export of materials, approximately 2500 cubic
yards based on the program’s default values. This small amount of material is most likely export of
existing pavements, utilities and other deleterious material that has to be removed from the site.
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mechanical yard. (Focused EIR, p. 3-5, Figure 3-2.) The focused EIR’s noise impact
analysis further indicates that the mechanical equipment room, which is proposed
to be located inside the Phase IB hospital building, adjacent to the mechanical yard,
will contain pumps, chillers and boilers. Air conditioning and refrigeration units
and their associated inlet and outlet exhaust systems will be located on the
hospital’s rooftop. (Focused EIR, p. 4-63.)
This limited information, scattered over several chapters of the focused EIR,
is entirely inadequate to determine emissions and resulting environmental impacts
from operation of the mechanical equipment. A complete and accurate project
description must include the fuel, firing rate, and number of boilers; the capacity for
the two emergency generators; the type and efficiency of the proposed pollution
control equipment; the circulating water flow and total dissolved solids (“TDS”)
content of the cooling water; the drift rate of the cooling towers; and the information
required to model these sources, e.g., stack location, height, diameter, exhaust gas
flow rate, temperature, and so forth. Without knowledge of these characteristics, it
is impossible to determine emissions from this equipment and, in fact, they were
not included in the operational emissions estimates for the Project.
Because the City failed to include an adequate project description in its
focused EIR, CEQA requires that it complete and recirculate a full EIR that fully
complies with long-established caselaw on this issue.
IV. THE FOCUSED EIR LACKS SUFFICIENT DETAIL TO ANALYZE
THE PROJECT’S IMPACTS
Rather than issue a full EIR, the City circulated an incomplete CEQA
document it deemed a “focused EIR.” Irrespective of its title, the EIR fails to meet
CEQA requirements because the document only addresses a fraction of the true
environmental impacts associated with the proposed Project. There is no dispute
that CEQA allows agencies to prepare different types of EIRs. Indeed, the different
types of documents serve to promote efficiency and avoid redundancy in the
planning process while still providing the public with full disclosure of the
environmental impacts of a proposed project. The permitted CEQA documents
include: project EIRs; EIRs as part of general plans; master EIRs; program EIRs;
staged EIRs; focused EIRs; subsequent EIRs; and supplemental EIRs. Most of
these EIRs, including a focused EIR, are associated with a process known as
“tiering” by which an agency prepares a series of EIRs or negative declarations,
typically moving from general, regional concerns to more site-specific considerations
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with the preparation of each new document. (CEQA sections 21068.5, 21093, 21094;
CEQA Guidelines sections 15152, 15385.) However, as shown below, the City has
not engaged in any early planning or tiering which would allow it to issue anything
but a full EIR.
A. The City Must Prepare A Full EIR
The most common type of EIR examines the environmental impacts of a
specific development project. Such project EIRs address all of the changes in the
environment that would result from the development project. Project EIRs must
examine all phases of the project including planning, construction, and operation.
(CEQA Guidelines section 15161.) Project EIRs may or may not be part of a tiering
process because they operate as stand alone documents containing all of the
necessary components of a valid CEQA document. On the other hand, a focused
EIR is only appropriate where an agency has prepared a master EIR (“MEIR”) for a
broadly defined planning program. (Remy, Thomas et al., Guide to the California
Environmental Quality Act (CEQA) (10th ed. 1999), p. 275.) In such cases, a
focused EIR may be appropriate for subsequent individual projects expressly
contemplated in the MEIR. (Id.) This allows the lead agency to dispense with
analyses already addressed in the MEIR. (CEQA, sections 21157 et seq.; CEQA
Guidelines, section 15157.) However, importantly, a focused EIR must
incorporate by reference the MEIR on which the lead agency is relying.
(CEQA, sections 21158.)
Here, the City circulated a final-stage tiering document, despite its not
providing any indication of prior tiering associated with the proposed Project. As a
result, the City’s focused EIR is incomplete and omits important impact analyses
that would normally be discussed in a prior finalized document, and then
incorporated by reference into the focused EIR. Specifically the focused EIR failed
to include analyses for: agricultural resources, biological resources, cultural
resources, geology and soil, hazardous materials, mineral resources, population and
housing, public services, recreation, and utilities and service systems. As shown
below, the City’s preparation of a focused EIR for the proposed Project does not
comply with CEQA’s legal requirements because a factual analysis of the Project
shows that the City failed to include significant environmental impacts in its CEQA
document.
In sum, given the procedural and factual background of the City’s Project, it
is clear that the City was required to prepare a full project EIR since the Project is
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not part of a larger CEQA planning process. By this measure alone, it is clear the
City acted improperly by preparing a focused EIR which omits essential impact
analyses for ten CEQA factors without incorporating by reference from an earlier
CEQA document. The City must prepare and circulate for public review a full EIR
that includes analyses for all of the required topics.
B. The Fair Argument Standard Requires The City To Prepare A
Full EIR
Here, the “fair argument” standard determines whether the City is required
to prepare either a full EIR or a focused EIR. (Remy Thomas, at p. 506.) This
standard obtains because CEQA requires the preparation of an EIR whenever it can
be fairly argued on the basis of substantial evidence that a project may have a
significant environmental impact. If an agency is presented with such evidence, it
cannot rely on contrary evidence as a basis for choosing not to prepare an EIR.
(Sierra Club v. County of Sonoma (1992) 6 Cal.App.4th 1307, 1316-17.) In this case,
the City prepared only a partial EIR addressing only a fraction of the significant
impacts associated with the proposed Project. Thus the fair argument standard
applies to those resource areas the City omitted from its CEQA analysis.
More specifically, a full EIR is required (as opposed to a negative declaration
or focused EIR) whenever substantial evidence in the record supports a fair
argument that significant impacts may occur. Even if other substantial evidence
supports the opposite conclusion, the agency nevertheless must prepare a full EIR.
(No Oil, Inc. v. City of Lost Angeles (1974) 13 Ca.3d 68, 75.) The fair argument
standard creates a low threshold for requiring preparation of an EIR. (Citizens
Action to Serve All Students v. Thornley (1990) 222 Cal.App.3d 748, 754.) This
standard is founded upon the principle that, because adopting a negative
declaration has a terminal effect on the environmental review process, an EIR is
necessary to resolve “uncertainty created by conflicting assertions,” and to
“substitute some degree of factual certainty for tentative opinion and speculation.”
(No Oil, Inc. 13 Cal.3d at p. 85.)
This analysis is fully applicable here because, by choosing to ignore ten of the
sixteen environmental factors in the NOP’s Environmental Checklist, the City has
precluded all review of these issues, resulting in the same outcome as if the City
had simply issued a negative declaration for these issues. It is clear from the City’s
environmental documents that the Project will have a significant effect on the
environment in resource areas the City refused to analyze. For example, the City’s
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focused EIR omitted significant analyses covering the existence of hazardous
leaking underground storage tanks within 250 feet of the Project. Therefore,
applying the fair argument standard, there is substantial evidence that the City
should have prepared a full EIR addressing all of the environmental factors
enumerated in the NOP’s Environmental Checklist.
V. THE FOCUSED EIR FAILS TO DISCLOSE OR ANALYZE ALL
POTENTIALLY SIGNIFICANT IMPACTS
Even if using a focused EIR were appropriate in this instance, which it is not,
the document itself is defective and must be revised and recirculated. Under
CEQA, an EIR must disclose all of a project’s potentially significant adverse
environmental impacts. (CEQA section 21100(b)(1).) The City’s focused EIR
patently fails to do so. First, the focused EIR contains only cursory analyses of
impacts associated with aesthetic resources, air quality, hydrology and
groundwater, land use and planning, noise and transportation. Second, the focused
EIR failed to include any analyses whatsoever for: agricultural resources, biological
resources, cultural resources, geology and soil, hazardous materials, mineral
resources, population and housing, public services, recreation, and utilities and
service systems. For nearly all of these issues, the record is incomplete because the
City failed to identify significant impacts associated with these resource areas. The
most glaring deficiencies are as follows:
A. The Focused EIR Fails To Identify Hazardous Waste Sites
Since 2001, Riverside County and the City of Temecula have known that the
Project site and local groundwater is contaminated by hazardous waste due to
leaking underground fuel tanks (“LUFTs”). Yet, the City’s focused EIR fails to
reveal this information, claiming instead that there would be no impacts or less
than significant impacts associated with the proposed Project for geology, soils and
hazardous waste issues. (Focused EIR, at p. 1-8)
But, in reality, the proposed Project is within 250 feet of two gas stations
where leaking underground fuel tanks have been the subject of ongoing assessment
and cleanup activities. First, there is a Chevron station located at 31669 Hwy. 79
which has been listed as an ‘open file’ according to the California EPA “Geotracker”
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web site.4 This website specifies that the site’s groundwater is contaminated with
gasoline-related hazardous materials, including methyl tert-butyl ether (MTBE),
tert-buytl alcohol (TBA) and toluene. There is no evidence that remediation at this
site is close to complete. Nor is there any indication of the size and movement of the
existing contaminant plume.
Second, there is an ARCO gas station at 44239 Margarita Road that is listed
at the Geotracker web site as undergoing assessment and cleanup activities. Here,
as at the Chevron station, there is no evidence that remediation is close to
complete.5 Also, as with the Chevron station, contaminants in groundwater include
gasoline-related compounds. Currently, there is no indication of the size and
movement of the existing contaminant plume.
Significantly, the City is well aware that these facilities pose serious health
risks to workers and patients at the proposed medical facility because the gas
stations are included in the City’s General Plan as “open fuel leak cases” and
specifies:
“any new development that involves contaminated property will necessitate
the clean up and/or remediation of the property in accordance with applicable
federal, State, and local requirements and regulations. No construction will
be permitted to occur at such locations until a no further action or similar
determination is issued by the City’s Fire Department, Department of Toxic
Substances Control, Regional Water Quality Control Board, and/or other
responsible agency.”6
Despite this clear directive, the City is proposing to locate the Project, a
hospital containing a cancer center, in-patient, out-patient, emergency services and
a rehabilitation center, adjacent to two hazardous waste sites that are listed as
open and are actively undergoing assessment and cleanup for hazardous materials.
Inexplicably, the focused EIR completely omits any discussion of these hazardous
waste sites and the status of their cleanup.
4(http://geotracker.swrcb.ca.gov/reports/luft.asp?global_id=T0606599286&assigned_name=MAINSIT
E).
5(http://geotracker.swrcb.ca.gov/reports/luft.asp?global_id=T0606599255&assigned_name=MAINSIT
E).
6http://www.cityoftemecula.org/cityhall/CommDevDivision/Planning/gpupdate/Final%20EIR/5_7%20
Hazards%20and%20Hazardous%20Materials.pdf
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Similarly, the focused EIR does not address the issue of hazardous waste
exposure to hospital patients and employees through groundwater contamination.
Instead, the City asserts that no mitigation measures are required with respect to
these issues. (Focused EIR, at p. 4-35) This, despite the fact that the City
acknowledges it intends to rely on groundwater on an as needed basis, “if surface
waters are reduced.” (Focused EIR, at p. 4-35).
Groundwater is less than 25 feet below the ground surface at the Project
location, and exposure to the gasoline-related compounds via the water or vapor
pathways is possible during construction and within hospital buildings post-
construction. Therefore, the City must prepare a full EIR to identify potentially
significant impacts of contaminant exposure to construction workers, the hospital
staff and patients as a result of these contaminants. Any pathways of exposure that
would result in risk to human health must be mitigated prior to construction.
B. The Focused EIR Fails To Identify the Location of An Active
Earthquake Fault Zone Near the Project
The City failed to disclose and discuss in its focused EIR the fact that the
Project would be located within 2500 feet of an active earthquake fault zone known
as the Elsinore Fault. This particular fault has generated a magnitude 7.0
earthquake along its southern segment in the late 1800s. The fault zone is
recognized in the Temecula General Plan and designated an Alquist-Priolo
Earthquake Fault Zone. This designation, pursuant to California’s Alquist-Priolo
Earthquake Fault Zoning Act (Alquist-Priolo Act), limits the types of construction
and other activities that can occur within the Elsinore Fault Zone to prevent
damage associated with ground surface rupture. (See Pub. Res. Code section 2621
et. seq.)
Significantly, the purpose of the Alquist-Priolo Act is to prohibit the location
of developments, such as hospitals, across the traces of active faults. (Pub. Res.
Code sections 2621.5, 2621.6) The Act prohibits the City from approving the
proposed Project without completing “a geologic report defining and delineating any
hazard of surface fault rupture.” (Pub. Res. Code section 2623(a)) Moreover,
Project approval must be in accordance with the policies and criteria established by
the State Mining and Geology Board and the findings of the State Geologist. (Id.)
There is no evidence in the focused EIR that the City has conducted such a report in
consultation with the State.
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Additionally, the Alfred E. Alquist Hospital Facilities Seismic Safety Act of
1983 (Hospital Seismic Safety Act) provides further requirements to ensure the
safety of medical facilities sited in earthquake prone areas. (Health and Safety
Code Section 129675 et. seq.) The Legislature passed the Hospital Seismic Safety
Act to require that “hospital buildings . . . shall be designed and constructed to
resist, insofar as practical, the forces generated by earthquakes.” (Health and
Safety § 129680(a).) To accomplish this goal, the Hospital Seismic Safety Act
requires approval of all projects by the Office of Statewide Health and Planning and
Development (“Office”). (Health and Safety § 129770(a).) Approval by the Office
must include an independent review of geological data by an engineering geologist
and independent review of the structural design data by a structural engineer. (Id.)
In addition to independent review by the Office, the Hospital Seismic Safety Act
requires that plans for hospital construction include “an assessment of the nature of
the site and potential earthquake damage, based upon geologic and engineering
investigations and reports by competent personnel of the causes of earthquake
damage.“ (Id.) Prior to construction of any hospital building, discretionary plan
approval by the Office is required. (Health and Safety Code § 129810.) Clearly, the
City has not complied with the Hospital Seismic Safety Act since there is no
evidence in the focused EIR that the City has obtained an approved assessment
from the Office of Statewide Health and Planning and Development.
The City must prepare a full EIR that includes a geologic report consistent
with the State Board for Geology and Mining, and must obtain approval by the
Office of Statewide Health and Planning and Development. In addition, a full EIR
must include measures to mitigate safety impacts as a result of the Project’s
proximity to this particular fault zone. Finally, in accordance with the City’s
General Plan, the full EIR must include a complete geologic investigation by a
State-licensed engineering geologist to ensure that the project will not be
constructed across any traces of the Elsinore Fault. If an active trace fault is found,
a hospital cannot be placed over the trace of the fault, but instead must be set back
from the fault in accordance with the California Public Resources Code.
C. The EIR Fails to Identify the Location of the Project in a
Liquefaction Hazard Zone
Finally, and in connection with seismic impacts the City failed to disclose in
its focused EIR, the Project area is also especially prone to liquefaction in the event
of an earthquake. According to the Temecula General Plan, and as shown in the
following figure, the area underlying the proposed Project has been mapped as a
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“liquefaction hazard zone.”7 As mentioned above, a geologic report in consultation
with the State Mining and Geology Board and incorporating its policies and criteria,
would likely remedy the focused EIR’s deficiencies with respect to the issue of
liquefaction.
7(http://www.cityoftemecula.org/cityhall/CommDevDivision/Planning/gpupdate/Final%20EIR/5_6%20
Geology%20and%20Soils.pdf, p. 5.6-4).
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Nevertheless, because the City failed to comply with State law, and
completely omitted a geologic report and omitted the actual topic of geology and
soils from its CEQA analysis, the public and decision makers are denied the
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opportunity to review this critical issue. An adequate EIR containing a geologic
report, specifically identifying the Project as within a liquefaction zone, is required
to analyze the issue of liquefaction and to identify specific ways in which these
conditions can be mitigated.
D. The Focused EIR Fails to Identify Particulate Matter Ambient
Air Quality Standards
Particulate matter is emitted from two sources, engine exhaust and fugitive
dust. The health impacts of particulate matter depend on its size, and the size
depends on its source. Combustion sources, such as vehicle exhaust, predominantly
emit particulate matter with an aerodynamic diameter of less than or equal to
2.5 micrometers (“PM2.5”), while fugitive dust consists predominantly of particulate
matter less than 10 micrometers (“PM10”).
Historically, health impacts due to particulate matter were regulated
through ambient air quality standards for PM10. However, a substantial amount of
important new research has been published, documenting new health impacts at
much lower concentrations and for different size fractions of particulate matter
than was previously known and reflected in ambient air quality standards. (U.S.
EPA 04/96;8 U.S. EPA 03/01.9)
This new research documents that the inhalation of particulate matter,
particularly the smallest particles, causes a variety of health effects, including
premature mortality, aggravation of respiratory (e.g., cough, shortness of breath,
wheezing, bronchitis, asthma attacks) and cardiovascular disease, declines in lung
function, changes to lung tissues and structure, altered respiratory defense
mechanisms, and cancer, among others. (U.S. EPA 04/96; 61 FR 65638.10) A recent
article linked long-term exposure to combustion-related fine particulate air
8 U.S. Environmental Protection Agency, Air Quality Criteria for Particulate Matter, Report
EPA/600/P-95-001aF through 001cF, April 1996.
9 U.S. Environmental Protection Agency, Air Quality Criteria for Particulate Matter, Second
External Review Draft, March 2001.
10 National Ambient Air Quality Standards for Particulate Matter: Proposed Decision, Federal
Register, v. 61, no. 241, December 13, 1996, pp. 65638-65675.
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pollution to cardiopulmonary and lung cancer mortality.11 Particulate matter is a
non-threshold pollutant, which means that there is some possibility of an adverse
health impact at any concentration. (See American Trucking v. EPA: Unjustified
Revival of the Nondelegation Doctrine, 23-SPG Environs Envtl. L & Pol’y J. 17, 26.)
This new information led the U.S. Environmental Protection Agency (“U.S.
EPA”) and the State of California to propose new ambient air quality standards for
PM2.5. These standards are not subsets of the old PM10 standards, but new
standards for a separate pollutant with distinguishable impacts. The new annual
PM2.5 standard of 12 µg/m3 was adopted by the California Air Resources Board
(“CARB”) on June 20, 2002 and became effective on June 5, 2003, more than two
years before the focused EIR was published. (Voting on the proposed 24-hour-
average PM2.5 standard of 25 µg/m3 has been deferred by CARB.12) At the same
time, California lowered its annual PM10 standard from 30 µg/m2 to 20 µg/m3.
(CARB 09/0513.) The focused EIR also failed to acknowledge this new, lower
standard for PM10. (Focused EIR, at Table 4-1.) Consequently, the focused EIR
failed to accurately characterize the regulatory setting for the Project.
E. The Focused EIR Fails To Analyze PM2.5 Emissions
The focused EIR does not include an analysis of the Project’s impacts on
ambient air quality resulting from PM2.5 emissions. This is a significant and
inexcusable omission because the South Coast Air Basin (“SoCAB”), where the
Project is located, frequently does not meet the federal or State ambient air quality
standards for PM2.5. The focused EIR should be revised to include an analysis of
PM2.5 emissions from Project construction and operation and resulting impacts on
air quality and human health.
11 A.A. Pope et al., Lung Cancer, Cardiopulmonary Mortality, and Long-term Exposure to Fine
Particulate Air Pollution, Journal of the American Medical Association, v. 287, no. 9, pp. 1132-1141.
12 California Air Resources Board (CARB) and Office of Environmental Health Hazard Assessment
(OEHHA), Draft Proposal to Establish a 24-hour Standard for PM2.5, Public Review Draft, March
12, 2002.
13 California Air Resources Board, Review of the Ambient Air Quality Standards for Particulate
Matter and Sulfates, http://www.arb.ca.gov/research/aaqs/std-rs/std-rs.htm, accessed
October 26, 2005.
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F. The Focused EIR Failed To Include A Health Risk Assessment
The focused EIR identifies several sensitive receptors in the vicinity of the
Project, including residential developments surrounding the site; nine primary
schools, two middle schools, and three high schools within two miles of the Project
site; and two parks within two miles of the Project site. (Focused EIR, at p. 4-21.)
Yet the focused EIR contains no health risk assessment analyzing the potential
health risks for these sensitive receptors resulting from Project construction or
operational emissions. Potentially adverse health impacts likely result from toxic
air contaminant emissions, including PM2.5, from diesel combustion engines such
as emissions from operation of the emergency generators and the diesel trucks that
access the loading dock. The focused EIR should be revised to include a health risk
assessment.
G. The Focused EIR Underestimated Construction Emissions
According to the focused EIR, significant impacts will continue after its
implementation of proposed mitigation measures for ROG and NOx. As discussed
below, the focused EIR’s air quality analysis considerably underestimates emissions
from construction activities and thereby fails to adequately disclose impacts on air
quality from Project construction. If these problems are corrected, emissions of CO
and PM10 will likely also exceed applicable significance thresholds.
H. The Focused EIR Employed An Incorrect Construction Period
For Emissions Estimates
The focused EIR indicates that construction of the Project will occur in five
phases as summarized in the Table 1. (Focused EIR, at pp. 3-7 and 3-8.)
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Table 1: Project Construction Phases
Phase Activity Period
IA Ɇ Grading
Ɇ Demolition of existing buildings
Ɇ Construction of 3-story, 60,000-square foot medical office
building
Ɇ Construction of surface parking
10 months
IB Ɇ Construction of 1-story, 162,650-square foot main hospital
structure
Ɇ Construction of 6-story, 122,755-square foot bed tower
Ɇ Construction of associated parking
14 months
II Ɇ Construction of 5-story, 122,755-square foot bed tower
III Ɇ Construction of 4-story, 80,000-square foot medical office
building
Ɇ Construction of hospital connector
IV Ɇ Construction of 1-story, 10,000-square foot cancer center
Ɇ Construction of associated parking
V Ɇ Construction of 8,000 square foot fitness center
Ɇ Construction of jogging trail
12 months
(II-V
concurrent)
Total 36 months
Construction of all phases is projected to last a maximum of 36 months if the
proposed construction phases (IA, IB, and II-V) are conducted subsequently. In
contrast, the focused EIR’s construction emissions estimates were based on a 60-
month construction period, starting in January 2006 and terminating in December
2010. (Focused EIR, at p. 4-24, footnote to Table 4-5, and Appx. B, p. 2.) By
stretching construction emissions over a period of 60 months rather than the actual
proposed 36-month construction period, the focused EIR considerably
underestimates maximum daily emissions and, thus, considerably underestimates
air quality impacts from Project construction. In fact, construction of the Project
could even be shorter than 36 months because nothing in the focused EIR’s
language restricts the developer to the staggered construction phasing. If more
than the specified construction phases would be conducted concurrently, even
greater emissions would occur.
The City relied upon the URBEMIS2002 model in assuming a construction
buildout of 36 months and otherwise accepting all of the focused EIR’s assumptions.
Results are included in Exhibit 1 to Dr. Pless’ comments. Maximum daily ROG
emissions increase considerably from 224 lb/day to 344 lb/day. Therefore, the
focused EIR failed to disclose the magnitude of impacts associated with Project
construction. The focused EIR must be revised to include a construction schedule
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showing the projected start of the various construction phases and their expected
buildout. The focused EIR’s air quality analysis must be corrected accordingly
because, as currently drafted, it employs an incorrect construction period.
I. The Focused EIR Assumes Unacceptable Model Default Values
The focused EIR’s construction emissions estimates largely assume
URBEMIS2002 default values, which may substantially underestimate the Project’s
real emissions. For example, the focused EIR assumes the default factor for average
fugitive dust emissions from grading of 0.11 ton/acre-month. By accepting the
default value for average conditions, the focused EIR fails to evaluate the potential
worst case, as is customary for CEQA analyses. The default factor for worst-case
condition is 0.42 ton/acre-month. Therefore, the focused EIR may have
underestimated potential worst-case conditions during grading of the Project by a
factor of almost four. Further, use of this default value is only suggested when no
other information is available. Typically, for a Project of this size, the amount of
cut/fill would also be known.
Another example is the assumption of 8 hours of construction per day. This
assumption directly conflicts with the focused EIR’s statement that “construction
activity will occur only between 6:30 A.M. and 6:30 P.M., Monday through Friday,
and 7:00 A.M. and 6:30 P.M. on Saturday. (Focused EIR, at p.4-53.) Although the
focused EIR makes this assertion, it should be noted that the document contains no
enforceable restrictions on the hours of construction per day and, thus, construction
may be conducted for more than the assumed 8 hours per day and more than the 12
hours per day claimed in the noise section of the document. This would
considerably increase the potential daily emissions from the Project. The focused
EIR must either contain an enforceable mitigation measure limiting the permissible
hours of construction or it must adjust its emissions estimates accordingly.
J. The Focused EIR Failed to Identify Fugitive Dust Emissions
From Wind Erosion And Trackout
The focused EIR indicates that grading of the entire 35.31-acre site will occur
during Phase IA, exposing those portions of the site which will be developed in later
phases (Phase IB through V), to wind erosion for an extended period of time.
(Focused EIR, at p. 3-7.) The City relied upon the URBEMIS2002 emissions
modeling to estimate Project construction emissions which includes fugitive dust
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associated with grading, but does not account for wind erosion.14 Wind erosion can
be a substantial contributor to fugitive dust from construction sites, particularly in
summer-dry climates such as the SoCAB. Further, the URBEMIS2002 emissions
modeling does not account for mud/dirt trackout from the site. Consequently, the
focused EIR does not disclose the full impact of fugitive dust PM10 emissions from
Project construction. Fugitive dust emissions due to wind erosion and trackout can
be calculated using guidance developed by the U.S. Environmental Protection
Agency (“U.S. EPA”). (AP-42, Sec. 13.2.515; EPA 450/3-88-008.16) The City must
prepare a full EIR to include this analysis.
K. The Focused EIR Failed To Properly Estimate Operational
Emissions
The focused EIR’s air quality impact analysis underestimates operational
emissions from the Project because it omits emission sources, uses inadequate trip
generation rates, and fails to include secondary emissions from electricity
generation. The focused EIR finds total operational NOx emissions of 94.5 lb/day,
only 5.5 lb/day below the SCAQMD’s significance threshold of 100 lb/day. This NOx
significance threshold will likely be exceeded when taking into account the omitted
emission sources, adequate trip generation rates, and secondary emissions from the
Project. Similarly, PM10 emissions, currently estimated at 123 lb/day, may exceed
the SCAQMD’s significance threshold of 150 lb/day. As a result, the focused EIR
fails to disclose and adequately mitigate significant impacts due to operational
emissions of PM10 and NOx. The focused EIR should be revised to address these
issues and be recirculated for public review.
14 The URBEMIS2002 fugitive dust emissions estimates are based on a methodology developed for
the SCAQMD by the Midwest Research Institute (“MRI”). (Software User’s Guide: URBEMIS 2002
for Windows with Enhanced Construction Module, April 2005, p. A-6.) The MRI study specifically
notes that the emission factors for fugitive dust emissions from construction activities do not include
wind erosion or mud/dirt trackout from the site. (MRI, Improvement of Specific Emission Factors,
BACM Project No. 1, Final Report, March 29, 1996, p. 4-1.)
15 Compilation of Air Pollutant Emission Factors, Volume 1: Stationary Point and Area Sources,
Section 13.2.5, Industrial Wind Erosion, January 1995, corrected on April 13, 2001.
16 C. Cowherd, G.E. Muleski, and J.S. Kinsey, Control of Open Fugitive Dust Sources, EPA 450/3-88-
008, U.S. Environmental Protection Agency, Research Triangle Park, NC, September 1988.
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L. The Focused EIR Omitted Important Emission Sources
The focused EIR’s air quality impact analysis is based on emissions
calculated with the URBEMIS2002 model. The model calculates area source
emissions from traffic generated by the Project and emissions from natural gas
usage, hearths, landscaping, consumer products, and architectural coatings and
operational traffic emissions. The model does not include emissions from the
helicopter, the three cooling towers, the two emergency generators, and the boilers.
The Initial Study concluded that “[a]rea source emissions such as heaters, air
condition units and other machines are not considered significant generator [sic] of
emissions.” (NOP/Initial Study, p. 7.) This conclusion is unsupported in the text of
the focused EIR and appears to be speculation. Even if emissions from these
sources were individually small, they may be cumulatively considerable and must
therefore be included in the a full EIR concerning a Project emissions analysis.
The combined emissions from the helicopter, the diesel generators and the
boilers, even if small, may result in exceedance of the NOx significance threshold.
For example, typical NOx emissions for commercial light twin-engine helicopters17
are about 4.0 lb per landing and takeoff (“LTO”), bringing total NOx emissions from
the Project within one pound per day of the significance threshold. (OCS 10/0418,
p. 6-17.)
M. The Focused EIR’s Failed To Identify Emissions From Natural
Gas Usage
The URBEMIS2002 model assigns gas usage rates to different land uses,
e.g., residences, industrial, hotel/motel, and office, to calculate area source
emissions from the use of gas-fired boilers, furnaces, hearths, etc. The model does
not calculate emissions associated with natural gas usage at hospitals. The Project
is intended to operate a number of, presumably natural-gas fired equipment-types,
17 The noise analysis stated that the exact model of helicopter to be used at the hospital has not been
confirmed, but that the Bell 222 has been identified as a model that could potentially be used. The
Bell 222, a frequently used helicopter model for emergency transports, is a commercial light twin-
engine helicopter.
18 R. Billings and D. Wilson, Data Quality Control and Emissions Inventories of OCS Oil and Gas
Production Activities in the Breton Area of the Gulf of Mexico, Final Report, U.S. Department of the
Interior, Minerals Management Service, Gulf of Mexico OCS Region, MMS 2004-071, October 2004.
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including boilers and heating/air conditioning equipment. Emissions from such
equipment, which are likely considerable, are not included in the focused EIR’s area
emissions estimates for Project operations presented in Table 4-6. Because the
focused EIR does not include these types of emissions analyses, the document is
inadequate.
N. The Focused EIR Used Incorrect Target Year Results To
Underestimate Vehicle Emissions
The focused EIR assumes 2010 as the target year for operational traffic
emissions. Construction is assumed to start in January 2006 with a 36 month
construction period. Therefore, the target year for operational emissions should be
2009, not 2010. Because vehicular emissions are assumed to decrease with every
year, the calculated operational emissions for 2010 underestimate actual emissions
at Project buildout, i.e. in 2009.
Relying upon URBEMIS2002 for target year 2009 and otherwise assuming
all of the focused EIR’s assumptions, results are included as Exhibit 1 to Dr. Pless’
comments. Emissions of ROG, NOx, and CO in 2009 are about 10% higher than for
target year 2010. This results in NOx emissions exceeding the SCAQMD’s
quantitative daily significance threshold. This is a significant impact that was not
disclosed in the focused EIR.
O. The Focused EIR Underestimated Traffic Emissions
The City’s URBEMIS2002 air quality analysis uses default trip lengths to
estimate emissions from Project-related traffic. These default trip lengths do not
apply to traffic associated with a regional hospital. Trips associated with a regional
hospital are typically longer and hence traffic emissions attributable to the Project
are higher. In addition, an independent review of the focused EIR’s traffic analysis
found a considerable underestimate of traffic generated by the Project, which is not
reflected in the URBEMIS2002 default assumptions for traffic. (See Brohard
10/0519.) Consequently, emissions associated with Project traffic are also
underestimated. The focused EIR’s emissions estimates for Project traffic must be
modified to reflect the Project’s actual traffic characteristics.
19 Tom Brohard, Brohard and Associates, Letter to Gloria D. Smith, Adams, Broadwell, Joseph &
Cardozo, Re: Review of Traffic Portions of the Temecula Regional Hospital Project Focused
Environmental Impact Report in the City of Temecula, October 26, 2005.
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P. The Focused EIR Failed to Include Secondary Emissions From
Electricity Generation
CEQA requires that an EIR identify direct and indirect significant effects of
the project on the environment. (CEQA Guidelines Section 15126.2(a).) The Project
will require a substantial amount of electricity, which generates so-called indirect or
secondary emissions. The focused EIR mentions that air pollutant emissions will be
generated due to the consumption of electricity and states that these regional
emissions were calculated using emission factors from the SCAQMD’s CEQA Air
Quality Handbook. (Focused EIR, p. 4-24.) Yet the focused EIR fails to account for
these emissions in its presentation of regional emissions associated with the
operational phase of the Project. (Focused EIR, at p. 4-25, Table 4-6.)
A considerable share of the electricity delivered to the SoCAB is generated by
coal-fired power plants, which generate substantial particulate matter and SO2
emissions. The focused EIR should be revised to include emissions from electricity
generation.
Q. The Focused EIR Failed To Identify Increased Ozone
Formation Due To Urban Heat Island Effect
The Project would develop 35.31 acres of largely open grass-covered land.
The focused EIR states that lot coverage will consist of approximately 16 percent
building area, 30 percent parking area, and 33 percent landscape areas.20 (Focused
EIR, at pp. 3-3 and 3-7.) The Project would add several buildings, parking lots,
roads, and roofs, thus increasing the amount of existing blacktop. Black surfaces
absorb about 85% to 95% of the sunlight that falls on them, becoming one of the
hottest surfaces in urban areas. The hot surfaces of pavement and similarly dark
roofs quickly warm the air over urban areas, leading to the creation of summer
urban “heat islands.” On a clear summer afternoon, the air temperature in urban
areas can be 2F to 9 F hotter than the surrounding rural area. The elevated
temperature increases cooling energy demand, accelerates the rate of smog
production, and increases evaporative losses of organic compounds from gasoline
tanks of vehicles parked over the hot surfaces.
20 The Site Plan provided in the Draft EIR suggests a considerably larger percentage of buildings and
parking spaces and lower percentage of landscaped areas. (Draft EIR, p. 3-5, Figure 3-2.)
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Conversion of open, grass-covered land to build-out areas would increase local
ambient temperatures, thereby contributing to the urban heat island effect and
increasing the local formation of ozone. Thus, the urban heat island effect would
exacerbate existing exceedances of the ozone standards in the Project vicinity. The
SoCAB is not in compliance with either federal or State ozone standards. Thus, the
Project would directly contribute to existing exceedances of the federal and State
ozone standards, which is a significant impact. (See Kings County Farm Bureau v.
City of Hanford (1990) 221 Cal.App.3d 692) This is a significant impact that was
not discussed in the focused EIR and is absolutely feasible to mitigate.
R. The EIR Fails to Identify Important Water Quality Issues
The Project site lies within the San Diego Basin, which encompasses
Temecula and the Santa Margarita Hydrologic Unit. (Focused EIR, at p. 4-32.)
Murrieta Creek is a tributary to Temecula Creek and is located downstream of the
Project. Significantly, the focused EIR failed to disclose that a twelve-mile segment
of Murrieta Creek is listed on the State Water Resources Control Board’s 303(d) list
(pursuant to the federal Clean Water Act’s section 303(d)) as an impaired water
body for phosphorous pollution. The San Diego Regional Water Quality Control
Board has listed sources polluting the creek to include urban runoff and storm
sewers, unknown nonpoint sources, and unknown point sources.21 The focused EIR
omits from its hydrology analysis the potential for the Project to add additional
phosphorous pollution into Murrieta Creek, further impairing the creek’s water
quality in violation of the Clean Water Act.
Additionally, an 18-mile portion of the Santa Margarita River, the primary
drainage course within the Planning Area, is also listed as impaired for
phosphorous from the same sources. The focused EIR states that Murrieta Creek is
one of two main tributaries to the Santa Margarita River: “The creeks drain the
inland portion of the Santa Margarita River Basin and join with the Santa
Margarita River at Temecula Canyon.” (Focused EIR, at p. 4-32.) Again, the
focused EIR omits from its hydrology analysis the potential for the Project to add
additional phosphorous pollution into regional water bodies such as the Santa
Margarita River, further impairing its water quality in violation of the Clean Water
Act.
21 (http://www.waterboards.ca.gov/tmdl/docs/2002reg9303dlist.pdf).
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The Regional Board’s total maximum daily load criteria (“TMDL”) classified
Murrieta Creek as “low,” nevertheless, the potential for additional phosphorous
contamination from the Project should be evaluated in the a full DEIR. Urban
runoff typically contains phosphorous as a main pollution component. Since
potential exists for phosphorous contamination to travel downstream into the Santa
Margarita River, further degrading its water quality, it is imperative that
mitigation measures are included as specific best management practices (“BMPs”)
which describe how phosphorous contamination will be prevented from entering
Murrieta Creek.
Furthermore, the focused EIR states that flooding of Murrieta Creek banks
has occurred during times of heavy rain:
“Frequent overtopping of the Murrieta Creek channel by floodwaters in a
number of channel reaches, flood inundation of structures with attendant
damages, and other water-related problems are caused during major
rainstorms, resulting in increased emergency costs, automobile damage, and
traffic disruption. Murrieta Creek has been altered since the late 1800s and
has been channelized for flood control purposes since the 1930s. Restoration
of the natural functions of the creek is planned, including the banks, channel
invert, tributaries and floodplain.” (City of Temecula General Plan, at p. 5.8-
3)
It is important that this flood potential be mitigated prior to development to
protect water quality of Murrieta Creek and its tributaries. Flooding of the
developed site can contribute urban contaminates to the creek, which include but
are not limited to debris, oil, grease, herbicides, and nutrients from fertilizers such
as phosphorous. Water quality omissions of this magnitude in a project level CEQA
document are impermissible, and can only be remedied through circulation of a full
EIR.
S. The EIR Fails to Disclose The Fact That the Project Cannot
Meet NPDES General Permit No. CAS000002 Requirements
Applicants of construction projects disturbing one or more acres of soil are
required to file for coverage under the State Water Resources Control Board
(“SWRCB”), Order No. 99–08–DWQ, National Pollutant Discharge Elimination
System (NPDES) General Permit No. CAS000002 for Discharges of Storm Water
Runoff Associated with Construction Activity (General Permit). The proposed
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Project is thus subject to the NPDES General Permit requirements. In addition,
the General Permit requires the development and implementation of a Storm Water
Pollution Prevention Plan (SWPPP). The SWPPP must contain:
xa site map which shows the construction site perimeter;
xexisting and proposed buildings, lots, roadways, storm water collection
and discharge points;
xgeneral topography both before and after construction;
xdrainage patterns across the project.
In addition, any SWPPP must include BMPs the discharger will implement to
protect storm water runoff.
The focused EIR fails to analyze whether the proposed Project will meet the
NPDES General Permit No. CAS000002 requirements. It likewise omits a
discussion of storm water discharge and the adoption of a SWPPP. Finally the
focused EIR does not include specific mitigation BMPs for both of the above-
described requirements.
With respect to post-construction, the focused EIR omits the discussion of
post-construction stormwater BMPs as required in Sections A of any SWPPP in
accordance with NPDES General Permit. Given post-construction adverse impacts
on water quality associated with the Project’s operation, such as anticipated water
pollution due to increased traffic volumes, typical landscaping upkeep, and
equestrian uses of trails, discussion of post-construction stormwater BMPs is
critical to ascertain the effectiveness of these BMPs to mitigate such operational
impacts and meet applicable water quality attainment objectives.
Finally, the focused EIR omits the inclusion of water quality monitoring
programs as required in Sections B of any SWPPP. This section of an NPDES
permit requires that a SWPPP also include a sampling and analysis strategy, and
sampling schedule for discharges from construction activities that directly impact
water bodies listed on the Regional Water Quality Control Board’s Section 303(d)
impaired water bodies list for sedimentation. Since both Murrieta Creek and Santa
Margarita River are listed on the Regional Board’s 303(d) list as impaired for
phosphorous, a full EIR should be prepared to include a monitoring plan for the
establishment of baseline water quality conditions, prior to construction, to evaluate
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and validate the effectiveness of the BMPs, to measure the effectiveness of the
BMPs and avoid further degradation of the impaired waterways.
T. The EIR Contains an Inadequate Water Supply Assessment
The focused EIR’s water supply and impacts analysis fails to comply with the
requirements of CEQA, California Water Code section 10910, and S.B. 610. In
essence, these legal requirements mandate that a local public water system, here
the Rancho California Water District (RCWD), prepare a Water Supply Assessment
(WSA) for new development proposals. The City attached a WSA to Appendix G of
the focused EIR. However the assessment must be revised as it is insufficient
under SB 610 because it does not comply with the following S.B. 610 requirements:
Groundwater – Basin Description, PWS Pumping, and Sufficiency Analysis
10910. (f) If a water supply for a proposed project includes groundwater, the
following additional information shall be included in the Water Supply
Assessment:
(3) A detailed description and analysis of the amount and location of
groundwater pumped by the public water system, or the city or county if either
is required to comply with this part pursuant to subdivision (b), for the past
five years from any groundwater basin from which the proposed project will be
supplied. The description and analysis shall be based on information that is
reasonably available, including, but not limited to, historic use records.
(4) A detailed description and analysis of the amount and location of
groundwater that is projected to be pumped by the public water system, or the
city or county if either is required to comply with this part pursuant to
subdivision (b) from any basin from which the proposed project will be.
The City admits that additional water supply will come via local groundwater
sources:
“To accommodate future developments such as the Temecula Regional
Hospital, the RCWD intends to meet supply planning issues through a
combination of the following alternatives: (1) Continued practice of managing
groundwater levels through natural and artificial recharge via groundwater
extracted using existing and planned RCWD-owned wells. . . ” (Focused EIR,
at p. 4-34)
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However, the Project’s WSA does not include a “detailed description and
analysis” of the most recent groundwater usage, including source locations and
pumped volumes for the past five years, nor does it provide a detailed description of
projected water usage volumes, as mandated by points (3) and (4), above.
Additionally, according to the WSA regarding groundwater volume: “The
amount of groundwater which can be produced varies due to such factors as rainfall,
recharge area and amount and location of well pumping capacity.” (WSA, at p. 7)
With respect to a drought with decreased surface water flows, the WSA states:
“increased groundwater extractions along with implementation of conservation and
other measures” will make up the difference.
This analysis is wholly inadequate because without calculated projected
groundwater volumes, it is impossible for the City or RCWD to guarantee that
groundwater will be an adequate and reliable source. A full EIR must quantify the
range of variable groundwater volumes, and then evaluate the most conservative
scenario to demonstrate quantitatively that water demand will still be achieved.
Absent such an analysis, the whole WSA and groundwater discussion is inadequate.
Accordingly, the City must prepare a full EIR that includes a proper WSA.
U. The EIR Fails to Identify Important Traffic Impacts
The focused EIR, its Traffic Impact Analysis (TIA), and its Appendix D
provide only a cursory analysis of the actual traffic and circulation impacts that
result from the construction and operation of the City’s hospital project. The City’s
most glaring traffic analysis deficiencies and omissions are enumerated below.
First, flaws in the focused EIR’s traffic analysis stem in part from the City’s
failure to properly calculate the phasing for the Project’s construction. Regarding
Project phasing, the focused EIR states:
“Construction of the proposed project will occur in five phases. Phase IA
consists of site grading, demolition of existing buildings, construction of a 3
story, 60,000 square foot medical office building (MOB #2), and construction
of adequate surface parking to serve the building. Phase IA is anticipated to
last approximately 10 months.
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Phase IB consists of construction of the one story main hospital structure
comprising approximately 162,650 square feet and a 6-story tower of
approximately 122,755 square feet, as well as parking associated with the
structure and tower. Phase IB is anticipated to last approximately 14
months.
Phase II will expand the hospital to its ultimate 320 bed configuration with
the addition of the 5 story bed tower of approximately 122,755 square feet.
Phase III will add a 4 story 80,000 square foot medical office building (MOB
#1) and the hospital connector.
Phase IV consists of construction of a one story, 10,000 square foot cancer
center and associated parking spaces.
Phase V will be construction of the 8,000 square foot fitness center and the
jogging trail.
Construction of Phases II through V is anticipated to occur concurrently and
to last approximately 12 months.”
(Focused EIR, at pp. 3-7 and 3-8)
Such construction phasing, according to the focused EIR, will take 36 months.
Importantly, however, it is likely that a number of months or years will pass
between construction activities associated with each of the three major construction
phases. Thus, the focused EIR does not properly evaluate baseline conditions in
concert with the phasing of construction for the proposed Project. The failure of the
focused EIR to analyze traffic impacts associated with the major construction
phases as well as buildout of the entire Project provides no assurance that
implementation of mitigation measures will be linked to significant traffic impacts
caused by the phased development of the Project.
Next, the focused EIR’s Traffic Impact Analysis and Appendix D contain the
City’s traffic analysis for the proposed Project. Unfortunately, these analyses
include significant errors in the calculation of AM peak hour, PM peak hour, and
daily trips that will be generated by the proposed Project. Use of average trip rates
per hospital bed, together with the omission of all trips associated with the 10,000
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square-foot cancer center and the 8,000 square-foot fitness center, significantly
understates the Project trip generation and the resulting traffic impacts.
Based on these errors in trip calculations, major revisions to the focused EIR
are required to address the significant impacts that the Project will have on traffic.
The focused EIR must use the higher trip forecasts discussed below to properly
identify the Project traffic impacts and develop appropriate mitigation measures.
Until the City conducts a proper traffic analysis, trip forecasts are significantly
below those that should have been calculated for the Project as follows:
1. The Project Will Provide Additional Parking Spaces On
Site
According to the focused EIR, “…the total parking spaces provided will be
1,278 which exceeds the City’s parking standards which requires 663 parking
spaces calculated for the hospital portion of the Project, for which the Development
Code requires one space per 3 beds. The parking provided on the site exceeds the
standards contained in the Development Code because the Code requirements do
not adequately account for parking needs within the hospital associated with staff
parking, outpatient services, and other needs within the facility. This is common in
most jurisdictions, and hospital facilities often exceed minimum parking
requirements for this reason.” (Focused EIR, at p. 3-8 note 2.) Thus, the City’s
constructing nearly double the amount of parking spaces on site over the City
requirements in its Development Code is a strong indication that the Project will
generate more than the average number of vehicle trips, particularly since the site
is not currently served by bus or other public transit.
Likewise, the City’s unrealistically low trip rates enumerated in its focused
EIR do not provide a proper basis for analysis of reasonably foreseeable conditions
associated with the City’s intent to construct nearly double the parking spaces
required by the its own Development Code. In addition, the low trip rates clearly do
not provide an evaluation of the “worst case” condition.
2. The City Relied Upon A Low Trip Rate Per Hospital Bed
Analysis
The focused EIR relied upon a trip rate of 20 daily trips per hospital bed
published by the San Diego Association of Governments (SANDAG) to develop its
forecasts of daily, AM and PM peak hour trips. (Focused EIR, at section 4.6) For
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the initial phase with 170 beds, 3,400 daily trips including 272 trips in the AM peak
hour and 340 trips in the PM peak hour were forecast. For the buildout of 320 beds,
6,400 daily trips including 512 trips in the AM peak hour and 640 trips in the PM
peak hour were forecast. These unreasonably low trip generation forecasts for the
170 bed hospital and the 320 bed hospital were relied upon throughout the focused
EIR.
In addition to trip rates per bed, SANDAG has also published rates of 25
daily trips per 1,000 square feet for hospitals, with 8 percent of the daily trips in the
AM peak hour and 10 percent of the daily trips in the PM peak hour. Applying the
SANDAG trip rate per 1,000 square feet indicates the initial phase of the hospital
building with 285,405 square feet will generate 7,140 daily trips including 570 trips
in the AM peak hour and 710 trips in the PM peak hour. For the buildout of
408,160 square feet, the hospital portion of the proposed project will generate
10,200 daily trips including 820 trips in the AM peak hour and 1,020 trips in the
PM peak hour. With the additional parking provided on site and the absence of
public transit services, the SANDAG trip rates per 1,000 square feet for the hospital
portion of the Project must be used to analyze and mitigate Project traffic impacts.
Without such an analysis, the focused EIR’s traffic impacts are artificially low.
3. All Trips from Cancer Center and Fitness Center Were
Omitted
The focused EIR indicates that the Project will also include a 10,000 square
foot cancer center and an 8,000 square foot fitness center. (Focused EIR, at p. 3-4)
The traffic analysis is also misleading because the focused EIR fails to include the
cancer center and fitness center in trip generation at buildout. (Focused EIR, at
Table 4-22 on p. 4-87) Instead, the focused EIR diminishes the trip generation
numbers forecasted for buildout by only considering trips for a hospital containing
320 beds and 140,000 square feet of medical offices. This analysis is misleading and
inaccurate because all trips associated with the cancer center and the fitness center
were omitted from the focused EIR’s traffic analysis.
A more reasonable calculation, for example, would include employing
SANDAG data showing that, per 1,000 square-feet of hospital space, the 10,000
square-foot cancer center will generate 250 daily trips, including 20 trips in the AM
peak hour and 25 trips in the PM peak hour. Also based on SANDAG data, per
1,000 square feet of hospital space, indicates the 8,000 square-foot fitness center
will generate 200 daily trips including 16 trips in the AM peak hour and 20 trips in
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the PM peak hour. An additional 450 daily trips including, 36 trips in the AM peak
hour and 45 trips in the PM peak hour, from the cancer center and fitness center
alone, is critical to an accurate analysis of Project trip generation forecasts,
distributed to area roadway links and intersections, analyzed, and the resulting
significant traffic impacts mitigated as necessary. Without this type of analysis, the
focused EIR’s traffic analysis is fatally flawed.
4. Additional Phase I Project Trips Will Create Significant
Traffic Impacts
Next, with respect to Phase I construction, the focused EIR incorrectly
forecasts 3,400 daily trips with 272 trips in the AM peak hour and 340 trips in the
PM peak hour for the 170 beds for Phase I. (Focused EIR, at Table 4-21, p 4-81) A
proper analysis of the Phase I hospital component indicates that the 285,405 square
feet in Phase I will generate 7,140 daily trips including 570 trips in the AM peak
hour and 710 trips in the PM peak hour. The 3,740 additional daily trips including
298 additional AM peak hour trips and 370 additional PM peak hour trips that will
be generated by Phase I will significantly impact additional intersections and
segments over and above those identified in the focused EIR. The focused EIR
improperly omits all of these additional trips. These significant Phase I traffic
impacts must be identified and mitigated as necessary to maintain the City’s Level
of Service (LOS) D standard.
5. Additional Buildout Trips Will Create Significant Traffic
Impacts
For buildout, the focused EIR incorrectly forecasts 6,400 daily trips, with 512
trips in the AM peak hour and 640 trips in the PM peak hour for 320 hospital beds.
(Focused EIR, at Table 4-22, p. 4-87) A proper analysis indicates that the 408,160
square feet forecasted for buildout will generate 10,200 daily trips including 820
trips in the AM peak hour and 1,020 trips in the PM peak hour.
Furthermore, 450 daily trips including 36 trips in the AM peak hour and 45
trips in the PM peak hour will be generated by the 10,000 square foot cancer center
and the 8,000 square foot fitness center. The 4,250 additional daily trips including
344 additional AM peak hour trips and 425 additional PM peak hour trips that will
be generated by the Project will significantly impact additional intersections and
segments over and above those identified in the focused EIR. Clearly, the City
greatly underestimated the actual daily trips that will be generated by the Project.
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A full EIR must address these significant traffic impacts for buildout, and must
identify and mitigate these impacts in order to meet the City’s LOS D standard.
As the foregoing illustrates, the focused EIR fails to identify numerous
potentially significant impacts. Unquestionably, substantial evidence exists in the
record for this Project supporting a fair argument that significant Project impacts
may occur. Accordingly, the City must complete and recirculate a full EIR in
compliance with CEQA.
VI. THE CITY’S EIR FAILS TO INCORPORATE EFFECTIVE MEASURES
TO MITIGATE ENVIRONMENTAL IMPACTS TO LESS THAN
SIGNIFICANT
A. The Focused EIR Must Describe Effective Mitigation Measures
for Each Significant Environmental Impact
An EIR must propose and describe mitigation measures sufficient to
minimize the significant adverse environmental impacts identified in the EIR.
(CEQA sections 21002.1(a), 21100(b)(3).) Also, mitigation measures must be
designed to minimize, reduce or avoid an identified environmental impact or to
rectify or compensate for that impact. (CEQA Guidelines section 15370.) Where
several mitigation measures are available to mitigate an impact, each should be
discussed and the basis for selecting a particular measure should be identified. (Id.
at section 15126.4(a)(1)(B).) A lead agency may not make the required CEQA
findings unless the administrative record clearly shows that all uncertainties
regarding the mitigation of significant environmental impacts have been resolved.
The City’s administrative record is clearly deficient with respect to mitigating the
impacts in all of the affected resource areas.
In particular, CEQA requires the lead agency to adopt feasible mitigation
measures that will substantially lessen or avoid the Project’s potentially significant
environmental impacts (CEQA sections 21002, 21081(a)) and describe those
mitigation measures in the EIR. (CEQA section 21100(b)(3); CEQA Guidelines
section 15126.4.) A public agency may not rely on mitigation measures of uncertain
efficacy or feasibility. (Kings County Farm Bureau v. City of Hanford (1990) 221
Cal.App.3d 692, 727 (finding groundwater purchase agreement inadequate
mitigation measure because no record evidence existed that replacement water was
available).) “Feasible” means capable of being accomplished in a successful manner
within a reasonable period of time, taking into account economic, environmental,
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legal, social and technological factors. (CEQA Guidelines section 15364.)
Mitigation measures must be fully enforceable through permit conditions,
agreements or other legally binding instruments. (Id. at section 15126.4(a)(2).)
Here, the focused EIR lacks effective mitigation for the following categories of
impacts: air quality, traffic, parking, and circulation, geologic hazards and water
quality. Additional mitigation measures must be included and a full EIR
recirculated for public review.
1. The Focused EIR Does Not Provide Adequate Mitigation
for Air Quality and Public Health Impacts
The focused EIR improperly defers the development of most of its mitigation
plans into the future without specifying any performance measures, including:
Ɇ Location of the staging area for construction (AQ-1);
Ɇ Transportation Demand Management Plan (AQ-2;
Ɇ Landscape Plan (AQ-4);
Ɇ Watering Program (AQ-6); and
Ɇ Fugitive Dust Control Program (AQ-7).
Further, several of the mitigation measures (e.g., temporary landscaping,
clean fueled vehicles, construction equipment energy efficiency) required by the
focused EIR are worded ambiguously, e.g., “may require,” “when feasible,” or
“reasonably possible,” which renders them unenforceable as a practical matter.
(Focused EIR, at p. 4-26 to 4-29.) The focused EIR must specify specific performance
measures and reasons for rejection of these measures if found not feasible or
appropriate.
By the focused EIR’s own admission of “significant unavoidable impacts” and
as demonstrated in the comments above, impacts from construction and operation of
the Project remain significant after implementation of the focused EIR’s proposed
mitigation measures. Therefore, the City must impose all feasible mitigation to
mitigate these significant impacts, which it did not. The comments below discuss
the specific inadequacies of the focused EIR’s proposed mitigation program and
propose mitigation measures that should be implemented to lessen or eliminate the
significant adverse effects of Project construction and operation.
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a. Additional Feasible Construction Mitigation
The focused EIR finds significant and unavoidable NOx emissions from the
Project. (Focused EIR, at p. 4-29.) As discussed below, construction emissions are
considerably underestimated, likely resulting in significant and unmitigated ROG,
CO, and PM10 emissions beyond what is reported by the focused EIR. Likewise,
there are numerous other relevant and reasonable fugitive dust and diesel exhaust
mitigation measures contained in the CEQA Guidelines and rules for air districts
and other agencies that should also be required for this Project to mitigate its
significant construction impacts.
b. Fugitive Dust Mitigation Measures
Several agencies have conducted relevant and comprehensive studies of
fugitive dust control measures to bring their region into compliance with national
ambient air quality standards on PM10. For example, the South Coast Air Quality
Management District (“SCAQMD”) has sponsored research, passed regulations (e.g.,
Rule 40322), and published guidelines that identify best management practices for
controlling fugitive dusts at construction sites. The Rule 403 Implementation
Handbook23 contains a comprehensive list of such measures, which should be
incorporated into the Project’s Fugitive Dust Control Plan. (See Focused EIR, at p.
4-27, Mitigation Measure AQ-7.) Clark County, Nevada, has also sponsored
research, passed regulations (Rule 94), and published best management practices
for controlling fugitive dust from construction activities.24 Clark County’s
Construction Activities Dust Control Handbook contains a comprehensive list of best
22 South Coast Air Quality Management District, Revised Final Staff Report for Proposed Amended
Rule 403, Fugitive Dust and Proposed Rule 1186, PM10 Emissions from Paved and Unpaved Roads,
and Livestock Operations, February 14, 1997.
23 South Coast Air Quality Management District, Rule 403 Implementation Handbook, January
1999.
24 P.M. Fransioli, PM10 Emissions Control Research Sponsored by Clark County, Nevada,
Proceedings of the Air &Waste Management Association’s 94th Annual Conference & Exhibition,
Orlando, FL, June 24-28, 2001.
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management practices.25 Similarly, Arizona has developed guidance to control
fugitive PM10 emissions.26
Several of the measures included in these agency guidelines are feasible and
therefore should be considered for adoption here under CEQA Guidelines §§15126.4,
15091. Examples of such feasible mitigation measures are listed below:
Ɇ During clearing and grubbing, prewet surface soils where equipment will
be operated; for areas without continuing construction, maintain live
perennial vegetation and desert pavement; stabilize surface soil with dust
palliative unless immediate construction is to continue; and use water or
dust palliative to form crust on soil immediately following
clearing/grubbing. (CCHD)
Ɇ Grade each phase separately, timed to coincide with construction phase or
grade entire project, but apply chemical stabilizers or ground cover to
graded areas where construction phase begins more than 60 days after
grading phase ends. (Rule 403 Handbook)
Ɇ During initial grading, earth moving, or site preparation, projects 5 acres
or greater may be required to construct a paved (or dust palliative treated)
apron, at least 100 ft in length, onto the project site from the adjacent site
if applicable. (BCAQMD)
Ɇ During cut and fill activities, prewater with sprinklers or wobblers to
allow time for penetration; prewater with water trucks or water pulls to
allow time for penetration; dig a test hole to depth of cut to determine if
soils are moist at depth and continue to prewater if not moist to depth of
cut; use water truck/pull to water soils to depth of cut prior to subsequent
cuts; and apply water or dust palliative to form crust on soil following fill
and compaction. (CCHD)
Ɇ For backfilling during earthmoving operations, water backfill material or
apply dust palliative to maintain material moisture or to form crust when
not actively handling; cover or enclose backfill material when not actively
handling; mix backfill soil with water prior to moving; dedicate water
25 Clark County Department of Air Quality Management, Construction Activities Dust Control
Handbook, March 18, 2003.
26 Arizona Department of Environmental Quality, Air Quality Exceptional and Natural Events
Policy PM10 Best Available Control Measures, June 5, 2001.
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truck or large hose to backfilling equipment and apply water as needed;
water to form crust on soil immediately following backfilling; and empty
loader bucket slowly; minimize drop height from loader bucket. (CCHD)27
Ɇ For large tracts of disturbed land, prevent access by fencing, ditches,
vegetation, berms, or other barriers; install perimeter wind barriers 3 to
5 feet high with low porosity; plant perimeter vegetation early; and for
long-term stabilization, stabilize disturbed soil with dust palliative or
vegetation or pave or apply surface rock. (CCHD)
Ɇ Barriers with 50 percent or less porosity located adjacent to roadways to
reduce windblown material leaving a site. (Rule 403 Handbook)
Ɇ In staging areas, limit size of area; apply water to surface soils where
support equipment and vehicles are operated; limit vehicle speeds to
15 mph; and limit ingress and egress points. (CCHD)
Ɇ Following the addition of materials to, or the removal of materials from,
the surface of outdoor storage piles, said piles shall be effectively
stabilized of fugitive dust emissions utilizing sufficient water or chemical
stabilizer/suppressant. (SJVUAPCD, ADEQ)
Ɇ For stockpiles, maintain at optimum moisture content; remove material
from downwind side; avoid steep sides or faces; and stabilize material
following stockpile-related activity. (CCHD)
Ɇ When materials are transported off-site, all material shall be covered,
effectively wetted to limit visible dust emissions, or at least six inches of
freeboard space from the top of the container shall be maintained.
(BAAQMD, SJVUAPCD, Rule 403 Handbook, ADEQ, SLOCAPCD)
Ɇ Where feasible, use bedliners in bottom-dumping haul vehicles. (Rule 403
Handbook)
Ɇ Empty loader bucket slowly and minimize drop height from loader bucket.
(CCHD)
27 The following acronyms are used in this listing of mitigation measures: ADEQ = Arizona
Department of Environmental Quality; BAAQMD = Bay Area Air Quality Management District;
BCAQMD = Butte County Air Quality Management District; CCHD = Clark County (Nevada)
Health District; MBUAPCD = Monterey Bay Unified Air Pollution Control District; SBCAPCD =
Santa Barbara County Air Pollution Control District; SJVUAPCD = San Joaquin Valley Unified Air
Pollution Control District; SLOCAPCD = San Luis Obispo County Air Pollution Control District.
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Ɇ Clean wheels and undercarriage of haul trucks prior to leaving
construction site. (CCHD)
Ɇ Gravel pads must be installed at all access points to prevent tracking of
mud on to public roads. (SBCAPCD)
Ɇ Install and maintain trackout control devices in effective condition at all
access points where paved and unpaved access or travel routes intersect.
(CCHD)
Ɇ All roadways, driveways, sidewalks, etc., to be paved should be completed
as soon as possible. In addition, building pads should be laid as soon as
possible after grading unless seeding or soil binders are used.
(SLOCAPCD)
Ɇ Pave all roads on construction sites. (MBUAPCD)
Ɇ To prevent trackout, pave construction roadways as early as possible;
install gravel pads; install wheel shakers or wheel washers, and limit site
access. (CCHD, SLOCAPCD)
Ɇ While clearing forms, use single stage pours where allowed; use water
spray to clear forms; use sweeping and water spray to clear forms; use
industrial shop vacuum to clear forms; and avoid use of high pressure air
to blow soil and debris from the form. (CCHD)
Ɇ Limit fugitive dust sources to 20 percent opacity. (ADEQ)
Ɇ Require a dust control plan for earthmoving operations. (ADEQ)
Ɇ Prior to land use clearance, the applicant shall include, as a note on a
separate informational sheet to be recorded with map, these dust control
requirements. All requirements shall be shown on grading and building
plans. (SBCAPCD, SLOCAPCD)
Ɇ The contractor or builder shall designate a person or persons to monitor
the dust control program and to order increased watering, as necessary, to
prevent transport of dust offsite. (SBCAPCD, SLOCAPCD)
Ɇ Post a publicly visible sign with the telephone number and person to
contact regarding dust complaints. This person shall respond and take
corrective action within 24 hrs. (BCAQMD, CCHD)
While portions of some of these measures are included in the focused EIR’s
mitigation measures, the above measures are far more protective and should all be
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required in the Project’s Fugitive Dust Control Plan. All of these measures are
feasible and various combinations of them are routinely required elsewhere to
reduce fugitive PM10 emissions. See, for example, the fugitive dust control program
for the Big Dig (Kasprak and Stakutis 200028), for the El Toro Reuse focused EIR,29
and for the Padres Ballpark Final EIR.30
c. Diesel Exhaust Mitigation Measures
There are a number of additional mitigation measures that are routinely
required as CEQA mitigation by air districts and other agencies in California for
construction projects, (e.g., the mitigation programs routinely implemented by the
SMAQMD and California Energy Commission (“CEC”) decisions), including:
Ɇ Limiting the hours of operation of heavy duty equipment and/or the
amount of equipment in use. (BAAQMD 12/99, p. 53);
Ɇ Conversion to cleaner engines;
Ɇ Use of cleaner (reduced sulfur) fuel;
Ɇ Add-on control devices, e.g., particulate traps, catalytic oxidizers;
Ɇ Buffer zone between facility and sensitive receptors;
Ɇ Installation of high pressure injectors on diesel construction equipment;
Ɇ Restricting engine size of construction equipment to the minimum
practical size;
Ɇ Electrification of construction equipment;
28 A. Kasprak and P.A. Stakutis, A Comprehensive Air Quality Control Program for a Large
Roadway Tunnel Project, Proceedings of the Air & Waste Management Association’s 93rd Annual
Conference, June 18-22, 2000.
29 County of Orange, Draft Environmental Impact Report No. 573 for the Civilian Reuse of MCAS El
Toro and the Airport System Master Plan for John Wayne Airport and Proposed Orange County
International Airport, Draft Supplemental Analysis, Volume 1, April 2001, pp. 2-121 to 2-123.
30 City of San Diego, Final Subsequent Environmental Impact Report to the Final Master
Environmental Impact Report for the Centre City Redevelopment Project and Addressing the Centre
City Community Plan and Related Documents for the Proposed Ballpark and Ancillary Development
Projects, and Associated Plan Amendments, V. IV. Responses to Comments, September 13, 1999,
pp. IV-254 to IV-256.
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Ɇ Substitution of gasoline-powered for diesel-powered construction
equipment;
Ɇ Use of alternatively fueled construction equipment, using, e.g.,
compressed natural gas, liquefied natural gas, propane, or biodiesel;
Ɇ Implementation of activity management techniques including
a) development of a comprehensive construction management plan
designed to minimize the number of large construction equipment
operating during any given time period; b) scheduling of construction
truck trips during non-peak hours to reduce peak hour emissions;
c) limitation of the length of construction work-day period; and d) phasing
of construction activities;
Ɇ Installation of catalytic converters on gasoline-powered equipment, if
feasible;
Ɇ Minimization of construction worker trips by requiring carpooling and
by providing for lunch onsite;
Ɇ Lengthening of construction period during smog season (May through
October), so as to minimize the number of vehicles and equipment
operating at the same time;
Ɇ Utilization of new technologies to control ozone precursor emissions as
they become available and feasible;
Ɇ Use electricity from power poles rather than temporary diesel power
generators; and
Ɇ Emission offsets if ROG or NOx emissions exceed 6.0 tons/quarter.
The following discusses the use and feasibility of construction equipment
certified by CARB, post-combustion controls, and the use of PuriNOx, an alternative
diesel formulation.
i. CARB-certified Construction Equipment
Both the U.S. EPA and CARB have established emission limits on new
off-road engines. CARB-certified off-road engines are engines that are 3 years old
or less at the time of use and which comply with these new low emission limits.
This equipment is widely available in the construction fleet. The use of CARB-
certified equipment should be required for this Project.
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For example, the SMAQMD and other agencies require the use of at least
20 percent CARB-certified off-road engines in the mix of construction equipment
operating on-site, or alternatively, setting a NOx, ROG, and/or PM10 emission
reduction goal for the construction fleet. A similar measure has been adopted by
the Texas Natural Resource Conservation Commission (“TNRCC”) for the
Dallas/Fort Worth and Houston-Galveston areas. (Rennie et al. 2001.31) The
Arizona Department of Environmental Quality (“ADEQ”) has also recommended
this measure to address the air quality problems in the Phoenix area. (ADEQ
11/9/00, pp. 19-24.)
ii. Post-combustion Controls
Post-combustion controls, such as oxidation catalysts and particulate filters,
are devices that are installed downstream of the engine on the tailpipe to treat the
exhaust. These devices are now widely used on construction equipment and are
capable of removing over 90% of the PM10, CO, and ROG from engine exhaust,
depending on the fuel and specific engine. The most common and widely used post-
combustion control devices are particulate traps (i.e., soot filters), oxidation
catalysts, and combinations thereof. The many variants of these devices have
recently been identified, evaluated, and comprehensively reviewed by CARB32 and
others.33
The City should avail itself of these devices as most are commonly required
as mitigation for construction emissions, which are similar to Project operations.
The Massachusetts Turnpike Authority (“MTA”) implemented a voluntary program
in the fall of 1998 which resulted in retrofitting 70 pieces of construction equipment
with oxidation catalysts (Kasprak et al. 200134) at the “Big Dig,” the massive, 5-
31 S.G. Rennie, L. Fiffick, D. Huckabay, and B. Ubanwa, Heavy Duty Diesel Engines Retrofit
Programs as a Part of Houston SIP, Proceedings of the Air & Waste Management Association’s 94th
Annual Conference & Exhibition, June 24–28, 2001.
32 California Air Resources Board, Risk Reduction Plan to Reduce Particulate Matter Emissions from
Diesel-Fueled Engines and Vehicles, October 2000; California Air Resources Board, Risk
Management Guidance for the Permitting of New Stationary Diesel-Fueled Engines, October 2000.
33 Manufacturers of Emission Controls Association, Demonstration of Advanced Emission Control
Technologies Enabling Diesel-Powered Heavy-Duty Engines to Achieve Low Emission Levels, Final
Report, June 1999.
34 A. Kasprak, G. Schattanek, and P.K. Wan, Emission Reduction Retrofit Program for Construction
Equipment of the Central Artery/Tunnel Project, Proceedings of the Air & Waste Management
Association’s 94th Annual Conference & Exhibition, June 24-28, 2001. Also see:
www.epa.gov/OMS/retrofit/documents/bigdig_case_01.htm, accessed October 26, 2005.
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year, $10 billion-plus Central Artery/Tunnel Project in Boston’s North End and one
of the largest infrastructure construction projects in the country.
These controls have also been widely required to mitigate construction
emissions in California. The CEC, which follows a CEQA-equivalent process in
licensing of new power plants larger than 50 megawatts (“MW”), has required these
devices on many projects. The Sunrise Power Project was recently constructed
using this equipment.35 No problems were encountered. Several other 500+MW
power plants have been licensed and constructed successfully using these controls,
including High Desert36, Elk Hills37, Pastoria38, Western Midway-Sunset39,
Mountain View,40 and Contra Costa,41 among others. (All of the CEC citing
decisions are posted at www.energy.ca.gov under the name of the individual
facility.)
Post-combustion controls have also been required as conventional CEQA
mitigation in EIRs. The El Toro Reuse focused EIR42, page 2-124, AQ-11k and AQ-
11l, required the use of particulate traps with a minimum 80% PM10 efficiency and
selective catalytic reduction (“SCR”) or comparable technology with a minimum 70%
NOx reduction on all off-road construction equipment. The Stanford University
35 California Energy Commission, Commission Decision, Sunrise Power Project, December 2000,
Condition AQ-C3, p. 120.
36 California Energy Commission, Commission Decision, High Desert Power Project, May 2000,
Condition AQ-3(o), p. 107.
37 California Energy Commission, Commission Decision, Elk Hills Power Project, December 2000,
Condition AQ-C2(3), p. 123.
38 California Energy Commission, Commission Decision, Pastoria Energy Facility, December 2000,
Condition AQ-C3, p. 108.
39 California Energy Commission, Commission Decision, Western Midway Sunset Power Project,
March 2001, Condition AQ-C2, p. 114.
40 California Energy Commission, Commission Decision, Mountain View Power Project, March 2001,
Condition AQ-C2, p. 34.
41 California Energy Commission, Commission Decision, Contra Costa Unit 8 Power Project, May
2001, Condition AQC-2, p. 12.
42 County of Orange, Draft Environmental Impact Report, No. 573 for the Civilian Reuse of MCAS
El Toro and the Airport System Master Plan for John Wayne Airport and Proposed Orange County
International Airport, April 2001.
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General Use Permit Application focused EIR43, page 4.11-10, AQ-1, required a
range of measures to minimize diesel engine exhaust, including catalytic converters
and particulate traps. The City of San Diego in the Padres Ballpark Final EIR44
required the control of 95% of engine exhaust emissions, using, among others,
oxidation catalysts, particulate filters, and “Blue Sky” low-emission engines.
Similarly, the Port of Oakland required the use of new engines or post-combustion
controls on trucks serving its Vision 2000 expansion project. The Port’s air quality
mitigation program is now partially in place and has been very successful in
reducing emissions.45
All of these post-combustion controls are feasible for construction of this
Project. Therefore, a proposed EIR should be prepared requiring the use of post-
combustion controls on off-road equipment specifying target control levels.
iii. PuriNOx
Alternate diesel fuels exist that achieve PM10 and NOx reductions. PuriNOx
is an alternative diesel formulation that was verified by CARB on January 31,
200146 as achieving a 14% reduction in NOx and a 63% reduction in PM10
compared to CARB diesel. It can be used in any direct-injection, heavy-duty
compression ignition engine and is compatible with existing engines and existing
storage, distribution, and vehicle fueling facilities. Operational experience indicates
little or no difference in performance and startup time, no discernable operational
differences, no increased engine noise, and significantly reduced visible smoke.
(Hagstrand 6/0447.)
43 Santa Clara County, Draft Environmental Impact Report, EIR Stanford University Draft
Community Plan and General Use Permit Application, June 23, 2000.
44 City of San Diego, Final Subsequent Environmental Impact Report, Ballpark and Ancillary
Development Projects, and Associated Plan Amendments, September 13, 1999 and Draft Subsequent
EIR, May 12, 1999, , page IV-262, I8.A.89.
45 Port of Oakland, Summary Report #5, Vision 2000 Air Quality Mitigation Program, February
2002.
46 Letter from Dean C. Simeroth, Chief, Criteria Pollutants Branch, to Thomas J. Sheahan, Lubrizol,
Verification of Lubrizol Corp. PuriNOx Fuel, January 31, 2001,
http://www.arb.ca.gov/fuels/diesel/altdiesel/altdiesel.htm, accessed June 18, 2004.
47 Personal communication, Petra Pless/Phyllis Fox with Hep Hepner, Ramos Oil Co., Dixon, CA,
(916-371-3289, ext. 242) and Bill Hagstrand, Lubrizol (440-347-6592), March and June 2004.
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This fuel has been successfully used in heavy-duty off-road and on-road
equipment, including by the Tri-Delta Transit Authority fleet in Contra Costa
County, by the County of Sacramento at the Keifer Landfill and North Transfer
station, in off-road construction equipment at very large residential construction
projects in Sacramento, in truck fleets operated by Pacific Cement in San Francisco
and Ramos Oil in Dixon, in yard hostlers at the Port of Long Beach, in off-road
equipment operated by Hanson Aggregate in San Francisco, and in yard haulers at
the Port of Houston. (Howes 4/0048 and Hagstrand 6/04.) Six yard tractors have
been operating on PuriNOx at the Port of Houston since April 2000. The Texas
Natural Resource Conservation Commission (“TNRCC”) has also approved PuriNOx
fuel for funding under Texas Senate Bill 5.
PuriNOx fuel is available from fuel distributor Chevron Texaco in Los
Angeles and is competitively priced at a surcharge over regular diesel of about
10 cents per gallon.49 It has been required as mitigation for construction exhaust
emission impacts. For example, the NASA Ames Development Plan focused
Environmental Impact Statement,50 page 4.4-34, requires “where reasonable and
feasible, use alternative diesel fuels.” See also construction exhaust mitigation in
the Bickford Ranch Final EIR, page 1-24, requiring 10% to 20% NOx emission
reductions to be achieved by both engine selection and fuel selection. (“Includes the
use of emulsified fuel in non-certified engines…”.)
d. Additional Feasible Operational Mitigation
The focused EIR concludes that after implementation of the proposed
mitigation measures, emissions of CO and ROG from operation of the hospital and
other on-site facilities will remain significant. The focused EIR states that “[e]ven
with measures to encourage trip reduction and energy efficiency, emissions cannot
be mitigated to below a level of significance” and concludes that “[l]ong-term air
quality impacts will be significant and unavoidable.” (Focused EIR, at p. 4-29.)
Yet, the focused EIR imposes a total of only five mitigation measures that address
operational emissions, specifically, AQ-2 incorporation and encouragement of
48 P. Howes, An Evaluation of the Effects of PuriNOxTM on Exhaust Emissions from Yard Haulers at
the Port of Houston, April 2000.
49 Personal communication, Petra Pless with Bill Hagstrand, Lubrizol (440-347-6592), June 21, 2004.
50 NASA Ames Research Center, NASA Ames Development Plan, Draft Programmatic
Environmental Impact Statement, November 2001.
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Transportation Demand Management techniques (“TDM”); AQ-3 incorporation of
energy efficiency standards for buildings; AQ-4 submission of a landscape plan; AQ-
16 enclosure and cover of refuse areas; and AQ-17 promotion of alternative
transportation. (Focused EIR, at pp. 4-26 through 4-28.)
By the focused EIR’s own admission, these mitigation measures are
insufficient to reduce the significant impacts from operational emissions to less
than significance for CO and ROG, resulting in significant unmitigated impacts
from Project operational emissions. (Focused EIR, at p. 4-29.) Further, the focused
EIR considerably underestimates Project operational emissions of PM10 and NOx,
which likely also exceed the SCAQMD’s quantitative daily significance thresholds.
The focused EIR does not contain any discussion why no additional mitigation
measures were considered to reduce the Project’s significant impacts on air quality.
As discussed below, numerous other mitigation measures exist that are routinely
required as CEQA mitigation and should have been required for the Project.
For example, the Initial Study for the Project recommends the following two
mitigation measures for emissions from Project operations that were not
incorporated into the focused EIR:
Ɇ Electrical powered equipment should be utilized in-lieu of gasoline-
powered engines where feasible; and
Ɇ Prior to the issuance of a grading and building permit, the applicant shall
submit verification that a ridesharing program for the construction crew
has been encouraged and will be supported by the contractor via
incentives or other inducements. (NOP/Initial Study, pp. 9-11.)
e. Operational Traffic Mitigation Measures
The following traffic mitigation measures are routinely required elsewhere to
mitigate significant impacts from a project and should be required to mitigate the
Project’s significant NOx, ROG, and PM10 impacts:
Ɇ Encourage carpool/vanpool program;
Ɇ Provide on-site child care or contribute to off-site child care within
walking distance;
Ɇ Provide preferential parking for carpool/vanpool vehicles;
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Ɇ Provide secure, weather-protected bicycle parking for employees;
Ɇ Provide direct safe, direct bicycle access to adjacent bicycle routes;
Ɇ Provide showers and lockers for employees bicycling or walking to work;
Ɇ Short-term bicycle parking for retail customers and other non-commute
trips;
Ɇ Connect bicycle lanes/paths to city-wide network;
Ɇ Design and locate buildings to facilitate transit access, e.g., locate building
entrances near transit stops, eliminate building setbacks, etc.;
Ɇ Construct transit facilities such as bus turnouts/bus bulbs, benches,
shelters, etc.;
Ɇ Provide shuttle service to food service establishments/commercial areas;
Ɇ Provide shuttle service to transit stations/multimodal centers;
Ɇ Implement parking fee for single-occupancy vehicle commuters;
Ɇ Implement parking cash-out program for non-driving employees;
Ɇ Provide direct, safe, attractive pedestrian access from project to transit
stops and adjacent development;
Ɇ Implement compressed work week schedule;
Ɇ Implement home-based telecommuting program;
Ɇ Provide electric vehicle (“EV”) and compressed natural gas (“CNG”)
vehicles in vehicle fleets;
Ɇ Install EV charging facilities;
Ɇ Install CNG fueling facility;
Ɇ Provide preferential parking locations for EVs and CNG vehicles; and
Ɇ Charge reduced or no parking fee for EVs and CNG vehicles;
The Lent Ranch Final EIR,51 for example, requires most of these measures.
The NASA Ames Development Plan focused Environmental Impact Statement
51 City of Elk Grove, Lent Ranch Marketplace, Draft Environmental Impact Report, for example
Table 4.3-21, page 3.0-96, and Table 12-2, October 2000.
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(“EIS”)52 would implement an aggressive transportation demand management
program (“TDM”) to reduce trip generation by at least 22 percent. The Stanford
University focused Community Plan and General Use Permit focused EIR53 adopts
all applicable Bay Area TDMs. The Bickford Ranch Specific Plan Final EIR54
requires that emissions be reduced by 40% by implementing many of these
measures. The Old Greenwood Planned Development focused EIR55 requires,
among others, paying an air quality mitigation fee to offset PM10 emissions from
vehicle exhaust and re-entrained road dust to zero. Therefore, the above-listed
measures should be assumed feasible unless otherwise demonstrated, and used by
this Project to reduce traffic emissions to a less than significant level.
f. Operational Area Mitigation Measures
The City’s General Plan contains the following two operational mitigation
measures that are not required by the focused EIR:
Ɇ Optimize building sites and orientation to take advantage of shading and
windbreak trees and reduce fuel consumption for heating and cooling; and
Ɇ Design buildings to optimize natural lighting, provide for task lighting,
and specific high-efficiency electric lighting. (General Plan, p. AQ-8.)
In addition to the mitigation measures proposed by the focused EIR and
contained in the City’s General Plan, operational area emissions can also be
mitigated by controlling other sources of emissions from the Project, including
exhaust emissions from landscaping equipment, emissions from natural gas
combustion for heating/air-conditioning, increased ozone production from the heat
island effect, and indirect emissions from electricity generation. In addition, the
CEQA Guidelines of other air districts identify numerous other feasible measures
52 NASA Ames Research Center, NASA Ames Development Plan, Draft Programmatic
Environmental Impact Statement, pp. O-11 to O-16, November 2001.
53 Santa Clara County, Draft Environmental Impact Report, Stanford University Draft Community
Plan and General Use Permit Application, Table 4.11-6, June 23, 2000.
54 County of Placer, Bickford Ranch Specific Plan Final Environmental Impact Report, Section 8.3.2
and 8.4, November 13, 2000.
55 City of Truckee, Draft Environmental Impact Report, Old Greenwood Planned Development,
pp. 4.5-10 to 4.5-13, February 2002.
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for commercial/industrial operations. Some of these additional measures, which are
routinely required as mitigation in other EIRs56 include:
Ɇ Use electric lawn and garden equipment for landscaping (BAAQMD);
Ɇ Use electrically or CNG-powered specialty equipment, e.g., utility carts
(BAAQMD);
Ɇ Use propane-powered specialty equipment, e.g., forklifts, utility carts, etc.
(BAAQMD);
Ɇ Increase walls and attic insulation beyond Title 24 requirements
(SLOAPCD57, SCAQMD58);
Ɇ Orient buildings to maximize standard heating and cooling (SLOAPCD)
and include passive solar design, e.g., day-lighting (SCAQMD, SBAPCD59,
BCAQMD60);
Ɇ Plant shade trees in parking lots to reduce evaporative emissions from
parked vehicles (SLOAPCD, SCAQMD, SBAPCD, BCAQMD);
Ɇ Plant shade trees along southern exposures of buildings to reduce summer
cooling needs (SLOAPCD, SCAQMD, SBAPCD);
Ɇ Use energy-efficient and automated controls for air conditioning
(SCAQMD, BCAQMD);
Ɇ Use lighting controls and energy-efficient interior lighting (SLOAPCD,
SCAQMD, SBAPCD, BCAQMD) and built-in energy-efficient appliances
(SLOAPCD);
Ɇ Use double-paned windows (SLOAPCD, SCAQMD);
56 For example: City of Elk Grove, Lent Ranch Marketplace, Draft Environmental Impact Report,
Table 4.3-5, p. 3.0-96, October 2000; County of Placer, Bickford Ranch Specific Plan Final
Environmental Impact Report, pp. 8-20 to 8-22, November 13, 2000; Sacramento County, East
Franklin Specific Plan, Final Environmental Impact Report, Table ES-1; and Appendix D,
February 2000; City of Truckee, Draft Environmental Impact Report, Old Greenwood Planned
Development, pp. 4.5-10 to 4.5-13, February 2002.
57 San Luis Obispo Air Pollution Control District, CEQA Air Quality Handbook, August 1997.
58 South Coast Air Quality Management District, CEQA Air Quality Handbook, April 1993.
59 Santa Barbara Air Pollution Control District, Scope and Content of Air Quality Sections in
Environmental Documents, September 1997.
60 Butte County Air Quality Management District, Indirect Source Review Guidelines, March 1997.
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Ɇ Use energy-efficient low sodium parking lot and street lights (SLOAPCD,
SCAQMD);
Ɇ Use light-colored roof materials (SCAQMD) and paint (SBAPCD) to reflect
heat;
Ɇ Install solar cooling/heating (SBAPCD);
Ɇ Install solar water heater for at least 25% of the building floor area
(BCAQMD);
Ɇ Substitute materials, e.g., use water-based paint (SCAQMD);
Ɇ Modify manufacturing processes, e.g., reduce process stages, closed loop-
systems, materials recycling (SCAQMD);
Ɇ Install resource recovery systems that redirect chemicals to new
production processes (SCAQMD);
Ɇ Use solar or low-emission water heaters (SCAQMD);
Ɇ Use centralized water-heating systems (SCAQMD, VCAPCD61);
Ɇ Use concrete or other non-pollutant materials for parking lots instead of
asphalt (SBAPCD);
Ɇ Pay an air quality mitigation fee;
Ɇ Secure emission offsets;
Ɇ Landscape with drought-resistant species, and use groundcovers rather
than pavement to reduce heat reflection;
Ɇ Provide electric maintenance equipment;
Ɇ Use ozone-destruction catalyst on air condition systems; and
Ɇ Reduce standard paving by 20%.
Further, some air districts recommend that large projects that cannot be fully
mitigated with on-site measures, should implement off-site mitigation measures.
For example:
61 Ventura County Air Pollution Control District, Ventura County Air Quality Management Plan,
Appendix G-94, Guidelines for the Preparation of Air Quality Impact Analyses, October 1989.
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There are a large number of options that can be used to comply with this
measure, ranging from porous block pavement systems to conventional asphalt
pavements using light aggregate, to conventional concrete pavements. Some are
comparable in cost to conventional pavements and have added benefits besides
reducing air quality impacts.
Ɇ Retrofit existing homes and businesses in the project area with approved
energy conservation devices (SLOAPCD);
Ɇ Replace/repower school/transit bus with cleaner vehicles (SLOAPCD);
Ɇ Construct satellite work stations (SLOAPCD);
Ɇ Fund a program to buy and scrap older, high-emission vehicles
(SLOAPCD);
Ɇ Contribute to an off-site TDM fund (VCAPCD);
Ɇ Repair smog-check waived vehicles (SLOAPCD);
Ɇ Introduce electric lawn and garden equipment exchange program
(SLOAPCD); and
Ɇ Retrofit/purchase clean heavy-duty trucks, construction equipment, diesel
locomotives, and marine vessels (SLOAPCD).
g. Mitigation For Urban Heat Island Effect
A number of the above discussed mitigation measures will reduce the urban
heat island effect. The feasibility of two of these measures, reduction of standard
paving by 20% and use of Energy Star roof products, are discussed in the following
comments in more detail.
i. Reduction Of Standard Paving By 20%
The heat island effect can be mitigated by reflecting the sunlight off the
pavement before it heats up through use of lighter-colored, reflective pavement
materials. These materials reduce the urban heat island effect, reducing the
formation of ozone, and reducing evaporative emissions from vehicles that park on
and use the pavement, thus reducing traffic emissions. This can be accomplished by
using grass paving or reflective surfaces on unshaded parking lots, driveways, and
fire lanes to reduce standard paving by 20%. This measure is widely used,
technically feasible, provides air quality benefits, and is economic.
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ii. Use Of Energy Star Roof Products
Most commercial and residential buildings have dark roofs. Dark roofs
absorb 80% to 90% of the incident sunlight, heating the roof and plenum space.
Because the air distribution system is typically installed in the plenum space
between the roof deck and the dropped ceiling over the finished interior space, this
raises the summertime cooling demand. In addition, heating the roof heats the air
that passes over the roof. Thus, the entire region around a dark roof becomes
warmer, increasing the formation of ozone.
As discussed above, dark roofs (and parking lots) quickly warm the air over
urban areas, leading to the creation of summer urban “heat islands.” The
additional air conditioning demand created by this temperature effect is responsible
for 5% to 10% of urban peak electric demand. The increased power demand leads to
higher emissions from power plants. This increase in temperature causes a 10% to
20% increase in urban ozone, and in some cases, generates as much ozone as all on-
road motor vehicles.62 Measures to reverse the heat island effect include reflective
roofs and pavements.
Intercepting the sunlight before it heats a building keeps its surface cooler
and reduces the heat flow into the building. This reduces the demand for air
conditioning. This can be accomplished by using light-colored, reflective roofs. A
light-colored roof can reduce the amount of energy needed for cooling by 20% to
70%, depending on the amount of insulation under the roof and design of the air
ducting system. This is achieved by reflecting most of the energy, rather than
absorbing it. The difference between the roof surface and ambient air temperatures
may be as high as 90F, while for reflective roofs, the difference is only about 18F.
This reduces peak cooling demand, cooling costs, the size of the HVAC system, and
the rating and amount of insulation required in a building, and increases the
lifetime of the roof. This also reduces air pollution by reducing the amount of
external power that must be produced and the amount of ambient ozone that is
formed in the vicinity of the development from the heat island effect.
62 Akbari H, Cool Roofs Save Energy, ASHRAE Transactions, v. 104, Pt. 1, 1998; Taha H, Modeling
the Impacts of Large-Scale Albedo Changes on Ozone Air Quality in the South Coast Air Basin,
Atmospheric Environment, v. 31, no. 11, 1997, pp. 1667-1676.
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Normal asphalt-based roofing products typically have a reflectivity of 10% to
20%. Energy Star-labeled roof products are roofing products certified to achieve at
least 65% reflectivity and to maintain a reflectivity of 50% under normal conditions
for 3 years after installation. The program is sponsored by the U.S. EPA and the
Department of Energy. There are currently over 115 manufacturers enrolled in the
program. Reflective roofing is also recognized as an acceptable design option in the
latest edition of the American Society of Heating, Refrigerating and Air-
Conditioning Engineers (“ASHRAE”) Standards 90.163 and 90.2 on energy-efficient
buildings.
Energy Star roof products are economical to apply and maintain and can be
cheaper than or comparable to conventional roofing products, which cost from $1.50
to $2.50 per square foot installed.64 Cool roofs come in a variety of styles, including
reflective coatings, reflective membranes, or metal roofs made of galvanized or other
coated metal. Coatings have a consistency of thick paint and cost from $0.75 to
$1.50 per square foot installed. Membranes are single-ply, pre-fabricated sheets
applied in a single layer, typically made of PVC (poly vinyl chloride), TPO
(tripolymer olefin), Hypalon, or CPA (copolymer alloy) and cost from $1.50 to $3.00
per square foot. A reflective roof can be installed or applied over almost any type of
roof material, including directly on a plywood deck in place of asphalt.
The performance of reflective roofing materials has been extensively
documented. At a single family residence in Sacramento, increasing the reflectivity
of the roof from 18% to 79% by painting with a white coating reduced the cooling
energy use over the June to October period by 66% and the peak power by 17%. At
a one-story school in Sacramento, increasing the reflectivity of the roof from 8% to
68% by painting with a white coating reduced the cooling energy use over the June
to October period by 34% and peak power by 32%.65 In another Sacramento study,
daily air conditioning savings of 17%, 26%, and 39% were documented in an office,
museum, and hospice with high reflectivity roofs.66
63 American Society of Heating, Refrigerating and Air-Conditioning Engineers, Inc., Energy
Standard for Buildings Except Low-Rise Residential Buildings, Standard 90.1-1999.
64 R.S. Means, Square Foot Costs, 21st Ed., 2000, Division 5, Roofing.
65 H. Akbari, S. Bretz, D. Kurn, and J. Hanford, Peak Power and Cooling Energy Savings of High-
Albedo Roofs, Energy and Buildings, v. 25, 1997, pp. 117-126.
66 E.W. Hildebrandt, W. Bos, and R. Moore, Assessing the Impacts of White Roofs on Building
Energy Loads, ASHRAE Technical Data Bulletin, v. 14, no. 2, 1998.
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At a one-story, 31,700-square footKaiser medical office building in Davis,
increasing the reflectivity of an R-19 flat roof from 24% to 60% reduced summertime
average weekday air conditioning by 18%. At another one-story, 23,800-square foot
Kaiser medical office building in Gilroy, increasing the reflectivity of an R-7 flat roof
from 25% to 65% reduced the summertime average weekday air conditioning by
13%. At a 33,000-square foot drug store in San Jose, increasing the reflectivity of a
foil barrier flat roof from 18% to 28% reduced the summertime average daytime air
condition by 2%.67
Reflective coatings reduced cooling energy costs by 12% to 18% in two other
commercial buildings in California.68 The reflectivity of a conventional unsurfaced
galvanized corrugated metal roof of seven retail stores in a strip mall in Florida was
increased from 29% to 75% with a white coating. This reduced the summer space
cooling energy use by 25%, with a range in savings of 13% to 48%, depending on the
temperature maintained in the shops. Those maintaining the lowest interior
temperatures saved the least on a percentage basis. The cost of the application was
$0.53/ft2 with a payback period of about 9 years.69 In nine Florida homes, daily air
conditioning energy use was reduced by 2% to 43% and peak demand was reduced
by an average of 22%. The amount of energy savings was inversely correlated with
the amount of ceiling insulation and duct system location, with the largest savings
in poorly insulated homes and those with duct systems in the attic space and
smaller savings in well-insulated homes.70 A high-reflective coating on an office
building in Mississippi reduced cooling energy demands by 22%.71 In addition to
field studies, computer simulations of reflective roofs have documented cooling
67 H. Akbari, L. Gartland, and S. Konopacki, Measured Energy Savings of Light-Colored Roofs:
Results from Three California Demonstration Sites, Proceedings of the 1998 ACEEE Summer Study
on Energy Efficiency in Buildings, v. 3, no. 1, 1998.
68 S. Konopacki, H. Akbari, L. Gartland, and L. Rainer, Demonstration of Energy Savings of Cool
Roofs, LBNL Report 40673, 1998.
69 D. Parker, J. Sonne, and J. Sherwin, Demonstration of Cooling Savings of Light Colored Roof
Surfacing in Florida Commercial Buildings: Retail Strip Mall, Florida Solar Energy Center Report
FSEC-CR-964-97, 1997; www.fsec.ucf.edu/Bldg/pubsonline.htm.
70 D.S. Parker and others, Measured and Simulated Performance of Reflective Roofing Systems in
Residential Buildings, ASHRAE Proceedings (Winter Meeting), Atlanta, GA, 1998;
www.fsec.ucf.edu/Bldg/pubsonline.htm.
71 C. Boutwell and Y. Salinas, Building for the Future - Phase I: An Energy Saving Materials
Research Project, Mississippi Power Co., Rohm and Haas Co and the University of Mississippi, 1986.
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energy savings in residential and commercial buildings.72 Cool roofs have been
widely used in California, including on the American Airline airport terminal in San
Jose, on control towers at the Stockton and Palmdale airports, at the 300,000-
square foot Honda distribution warehouse in Stockton, the 200,000-square foot JC
Penny warehouse in Buena Park, and numerous buildings in Silicon Valley.
Thus, this measure would save a substantial amount of money over the life of
the Project and would cost no more than a standard roof. Further, it would reduce
pollution by reducing the generation of power and the formation of ozone from the
heat island effect.
In sum, there are many additional feasible measures that should be
evaluated and required for this Project. The focused EIR should be revised to
include these additional measures and be recirculated for public review.
2. The Focused EIR Does Not Provide Adequate Mitigation
for Significant Traffic Impacts
The City acknowledges that there will be significant traffic impacts
associated with development of Phase I of the proposed project. (Focused EIR, at p.
4-86) For example, the AM peak hour at Highway 79 South/Redhawk
Parkway/Margarita Road is a particular problem. Yet, the City takes no affirmative
steps to mitigate this issue. Instead, the focused EIR states, “Mitigation measures
are required to reduce the level of impact” (Focused EIR, at p. 4-86), but the City
neglected to actually identify real measures to mitigate these traffic impacts. An
adequate EIR requires the City to identify near-term mitigation measures for this
intersection.
Next, the focused EIR points to four primary mitigation measures for project
buildout. (Focused EIR, at pp. 4-93 and 4-94) For two of the four, mitigation will be
achieved by paying fees to Riverside County for impacts at the I-15 Interchange
with Highway 79 South, or by paying the Project’s fair share of the cost of the
improvements at six other intersections. These are hollow and totally inadequate.
72 See, for example: H. Akbari, S. Konopacki, C. Eley, B. Wilcox, M. Van Geem and D. Parket,
Calculations for Reflective Roofs in Support of Standard 90.1, ASHRAE Transactions, v. 104, no. 1,
1998, pp. 984-996; L. Gartland, S. Konopacki, and H. Akbari, Modeling the Effects of Reflective
Roofing, ACEEE 1996 Summer Study on Energy Efficiency in Buildings, v. 4, 1996, pp. 117-124.
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For the other two mitigation measures, the Focused EIR recommends that
Temecula Regional Hospital construct the associated mitigation measures.
All adequate traffic impact mitigation measures must be achieved through
actual implementation of real mitigation measures, not payments or fees. Payment
of fees to Riverside County or payment of the Project’s fair share of improvements to
the City does not guarantee that these mitigation measures will ever be
implemented. Until improvements are actually in place, Project traffic impacts
must be considered as “significant” rather than “less than significant.” Finally, the
focused EIR must include a mitigation-monitoring program that clearly identifies
financing, scheduling, implementation responsibilities, and lead agency monitoring
to achieve actual mitigation of these significant impacts. A full EIR must include
these measures.
B. The Focused EIR Does Not Include All Feasible Mitigation
Measures Before Concluding That The Impacts Are
Unavoidable, Relying Instead Upon A Statement of Overriding
Considerations
A lead agency may not conclude that an impact is significant and unavoidable
without requiring the implementation of all feasible mitigation measures to reduce
the impact to less than significant levels. (CEQA Guidelines sections 15126.4,
15091.) When the agency is unable to provide a specific mitigation measure, CEQA
requires the articulation of performance criteria at the time of project approval.
(Sacramento Old City Association v. City Council of Sacramento (1991) 229
Cal.App.3d 1011, 1028-1029.)
With respect to the focused EIR, CEQA Guidelines specify that a lead agency
must make a “fully informed and publicly disclosed” decision that “specifically
identified expected benefits from the project outweigh the policy of reducing or
avoiding significant environmental impacts of the project.” (CEQA Guidelines
section 15043(b).) An agency must “state in writing the specific reasons to support
its action based on the final EIR and/or other information in the record” and must
include the statement of overriding considerations in the record of the project
approval and refer to it in the notice of determination. (CEQA Guidelines sections
15093(b)(c).) A revised and recirculated EIR must show that the City required all
feasible mitigation measures and full articulation of performance criteria before
issuing a statement of overriding considerations.
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1. The City Failed to Provide Specific and Adequate
Measures To Mitigate Significant Traffic Impacts
The focused EIR fails to adequately discuss potentially significant impacts,
and fails to develop mitigation measures associated with the following topics:
First, the focused EIR must analyze and evaluate impacts associated with
construction including dirt and building material hauling, worker traffic, and
worker parking for each of the three major phases. Measures must be developed
and incorporated into the focused EIR to mitigate construction traffic impacts.
These measures must maintain the City’s LOS D standard as defined on Pages 4-69
and 4-70 of the focused EIR so construction traffic does not degrade the LOS below
the significance threshold used in the focused EIR.
Second, according to the focused EIR, there has been communication between
the Riverside Transit Authority (RTA) and the City indicating that, “…future bus
service is highly likely along SR 79 and that the busses will be stopping at the
proposed hospital. The City has expressed previous support for the concept of a bus
turnout and related amenities along SR 79 to be installed by the project sponsors.”
Providing public transit to the Project presents significant mitigation to project
impacts. Yet, the focused EIR simply fails to address the request for a bus turnout
from RTA. Likewise, the focused EIR fails to quantify the demand for new transit
services that the Project will create, and fails to provide any transit mitigation
measures such as financial contributions to help establish new transit service along
Highway 79 South. A full EIR must include public transit as feasible mitigation to
the Project impacts.
Third, the City fails to fully and adequately address parking impacts. For
example, the focused EIR states, “Approximately 1,278 parking spaces will be
provided on surface lots.” (Focused EIR, at p. 1-4) As previously indicated, the
focused EIR characterizes the proposed parking as being significantly above the
requirements of the City’s Development Code. (Id. at p. 3-8) However, the
document neglected to review and analyze the amount of parking being proposed on
site.
Instructive to this analysis is the publication Parking Generation, 3rd Edition,
published by the Institute of Transportation Engineers (ITE). This authority
contains parking data for various land uses including hospitals and medical office
buildings. For suburban hospitals like the Project, the average peak parking
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demand is identified at 4.72 vehicles per bed. To satisfy this demand, at least 1,510
parking spaces would be needed for the 320 hospital beds in the proposed project.
For medical offices, the average parking supply is identified as 3.9 spaces per 1,000
square feet. To meet this, at least 616 parking spaces would be needed for the
140,000 square feet of medical offices, the 10,000 square foot cancer center, and the
8,000 square foot fitness center in the proposed project. Based on the data
published by ITE, at least 2,126 parking spaces are required to meet the needs of
the Project, significantly higher than the 1,278 parking spaces being proposed.
Clearly, parking proposed for the Project is inadequate. A full EIR must analyze
actual parking needs for the Project.
Finally, with respect to parking, the focused EIR fails to analyze impacts
associated with providing all parking on site as surface parking. Given that the
Project has an overall parking shortage of 850 spaces, and given that over 30
percent of the Project site will be occupied by surface parking, the City must
consider building a parking structure to reduce environmental impacts in other
areas and to avoid impacts to rock outcrops and trees on the site.
C. The Focused EIR Employs An Incorrect Baseline, Thereby
Skewing The Impact Analysis
The environmental setting establishes the baseline physical conditions
against which a lead agency can determine whether an impact is significant.
(CEQA Guidelines § 15125(a).) Under CEQA, an EIR must include a description of
the physical environmental conditions in the vicinity of the project, as they exist at
the time the Notice of Preparation is published, from both a local and regional
perspective.73 (Id.) Knowledge of the regional setting is critical to an assessment of
environmental impacts. (Id. at § 15125(c).)
The importance of having a stable, finite, fixed baseline for purposes of an
environmental analysis was recognized decades ago in the case of County of Inyo v.
City of Los Angeles (1977) 71 Cal.App.3d 185. The recent case of County of Amador
vs. El Dorado County Water Agency (1999) 76 Cal.App. 4th 931 provides a
comprehensive exegesis concerning baseline water condition and held the EIR must
focus on impacts to the existing environment, not hypothetical situations. (Id., 76
Cal.App.4th at 954.) The presentation of baseline information must be sufficiently
73 According to the DEIR, page 5, the Notice of Preparation for this Project was published in
February 2002.
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detailed to make further analysis possible. (Id.) In short, it must provide not only
raw data but also analysis. (Id., 76 Cal.App.4th at 955; See Environmental Planning
& Information Council v. County of El Dorado (1982) 131 Cal.App.3d 350, 355
(holding that an EIR should inventory and address the environment as it actually
existed, not as it was proposed to be under the old General Plan).)
“[T]he impacts of the project must be measured against the ‘real conditions
on the ground.’” (Save Our Peninsula Committee v. Monterey Board of Supervisors
(2001) 87 Cal.App.4th 99, 121.) While the absence of information in an EIR does
not per se constitute a prejudicial abuse of discretion, “a prejudicial abuse of
discretion occurs if the failure to include relevant information precludes informed
decision-making and informed public participation, thereby thwarting the statutory
goals of the EIR process.” (Berkeley Keep Jets Over the Bay Committee v. Board of
Port Commissioners (2001) 91 Cal.App.4th 1344, 1355.) Here, the focused EIR does
not correctly describe the existing physical conditions related to traffic and geologic
setting.
1. Inadequate Description of the Traffic Setting
According to the focused EIR, “Existing peak hour manual intersection
counts were conducted during the traditional weekday AM (7:00 – 9:00) and PM
(4:00 – 6:00) peak hours on March 23, 2004. (Focused EIR, at p. 4-72).
Supplementary counts were obtained in July of 2005 for the traffic study
Addendum.” (Id. at p. 4-76) Also, “The current levels of service for study
intersections and roadway segments were calculated based upon traffic counts and
current intersection and roadway configurations.”
The focused EIR indicates the peak hour traffic counts were made on March
23, 2004, for all intersections. Also, the City then made capacity calculations by
using the traffic volumes from these March 2004 traffic counts. This approach
ignores the significant traffic volume increases that have occurred with the rapid
growth and development within and adjacent to the study area. The values
obtained were then used in the focused EIR to represent baseline conditions at the
time of the Notice of Preparation (NOP).
Page 10 of the Addendum states “Existing Average Daily Traffic (ADT)
volumes and intersection counts were conducted by LLG in July 2005. In addition,
traffic counts were also obtained from the Temecula Medical Center report.
Appendix A contains the existing traffic volumes.” This data indicates that peak
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hour traffic counts were made on July 7, 2005 only for the intersection of Margarita
Road and Dartolo Road, with the March 2004 traffic counts included for the other
two intersections studied in the Addendum. The traffic counts on Thursday, July 7,
2005, were taken during the week with the July 4 Independence Day holiday.
These traffic counts do not properly represent normal weekday conditions with the
national holiday on Monday of that week, with summer vacations, and with schools
closed for the summer months. In short, all of this data grossly underestimates true
traffic capacity.
Next, the City made capacity calculations by directly using the traffic
volumes from the March 2004 traffic counts and the holiday week counts. This
approach ignores the significant traffic volume increases that have occurred with
the rapid growth and development in and adjacent to the study area, and provides
unreliable data for the holiday week. The capacity calculation values in the focused
EIR do not represent baseline conditions at the time of the NOP.
The NOP was released on August 3, 2005. (Focused EIR, at p. 2-2) CEQA
requires evaluation of the existing conditions at the time of the NOP because timely
information is essential to an accurate and complete impact analysis. Traffic counts
made in March, 2004 at the eight intersections in the TIA do not represent baseline
conditions in 2005. Traffic counts at Margarita Road and Dartolo Road taken during
the summer week that included the Independence Day holiday are unreliable. New
traffic counts must be made at all study intersections and all calculations and
subsequent analysis must be redone to properly analyze traffic impacts of the
Temecula Regional Hospital Project.
With one exception, existing traffic volumes counted at study intersections
reflect traffic conditions, as they existed in 2004. (Focused EIR, at p. 4-81) To
account for traffic volumes from other development projects and to include
continuing traffic volume increases year after year due to project construct phasing,
existing volumes are expanded by an annual growth factor ranging from one to
three percent annually. (Id.) To properly evaluate buildout conditions, traffic
studies must include an appropriate annual growth factor plus traffic volume
projections from approved near term land development projects.
The focused EIR states, “To assess opening year and buildout traffic
conditions, two approaches were used. In the November 2004 traffic study, a 4
percent growth factor was added to existing traffic volumes and then 17 cumulative
projects were added.” (Focused EIR, at p. 4-81) The focused EIR’s analysis is
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flawed because the capacity calculations for project buildout failed to include a
growth factor to the March 2004 traffic counts with one exception. (Appendix B)
For the analysis of conditions in the AM peak hour at SR 79 and La Paz Street, a 4
percent growth was included to account for the traffic volume increases from small
developments and annual traffic growth. This 4 percent growth factor does not
appropriately expand the baseline traffic volumes to the buildout horizon year for
the entire Project. In addition, the capacity calculation sheets for the PM peak hour
analysis at SR 79 and La Paz Road and for all of the other intersections do not
include any growth factor in the analysis of buildout conditions for the Project. This
flawed approach does not properly reflect annual traffic volume growth essential to
an accurate buildout baseline for traffic volumes.
The focused EIR neglects to identify the expected timing of completion of each
of the three major Project construction phases, as well as the buildout horizon for
the entire Project. (Focused EIR, at pp. 3-7 and 3-8) Such an analysis provides no
assurance that implementation of mitigation measures will be linked to significant
traffic impacts caused by the phased development of the Project. The following two
significant omissions in the focused EIR bear directly on the traffic analysis,
causing it to be inaccurate and incomplete as follows:
First, to account for traffic volumes from small development projects and to
include continuing traffic volume increases year after year, existing volumes are
expanded by an annual growth factor ranging from one to three percent annually.
Second, to properly evaluate near term conditions, traffic studies must include an
appropriate annual growth factor plus traffic volume projections from approved
near term land development projects.
Instead, according to the focused EIR, “To assess opening year and buildout
traffic conditions, two approaches were used. In the November 2004 traffic study, a
4 percent growth factor was added to existing traffic volumes and then 17
cumulative projects were added.” (Focused EIR, at p. 4-81) However, near term
capacity calculations in Appendix B indicate that a no growth factor was applied to
the March 2004 traffic counts with one exception. For the analysis of near term
conditions in the AM peak hour at SR 79 and La Paz Street, a 4 percent growth was
included to account for annual traffic growth. But, the capacity calculation sheets
for the PM peak hour analysis at SR 79 and La Paz Road and for all of the other
intersections do not include any growth factor in the analysis of near term
conditions for Phase I of the Project. The focused EIR’s flawed approach does not
properly reflect annual traffic volume growth. This information is required for
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accurate near term baseline traffic volumes. A full EIR must be circulated
containing this information.
The focused EIR failed to evaluate the Project traffic impacts at the conclusion of
each Project phase. Accordingly, it is impossible to determine the point in time at
which the multi-phased Project will cause the Level of Service (LOS) at impacted
intersections to deteriorate to an unacceptable level. Project phasing assumptions
in the traffic analysis must match project phasing in the focused EIR so mitigation
measures can be implemented in a timely manner to maintain the City’s LOS D
standard. (Focused EIR, at pp. 4-69 and 4-70) A full EIR must include annual
growth of the 2004 traffic counts for both AM and PM peak hours at all
intersections. The traffic analysis must also disclose significant traffic impacts and
associated mitigation measures at the completion of each of the three major phases
of the Temecula Regional Hospital.
VII. CUMULATIVE IMPACTS ARE SIGNIFICANT AND UNMITIGATED
An EIR must discuss significant “cumulative impacts.” (CEQA Guidelines
section 15130(a).) This requirement flows from CEQA section 21083, which
requires a finding that a project may have a significant effect on the environment if
“the possible effects of a project are individually limited but cumulatively
considerable. . . . ‘Cumulatively considerable’ means that the incremental effects of
an individual project are considerable when viewed in connection with the effects of
past projects, the effects of other current projects, and the effects of probable future
projects.” “Cumulative impacts” are defined as “two or more individual effects
which, when considered together, are considerable or which compound or increase
other environmental impacts.” (CEQA Guidelines section 15355(a).) “[I]ndividual
effects may be changes resulting from a single project or a number of separate
projects.” (CEQA Guidelines section 15355(a).)
“The cumulative impact from several projects is the change in the
environment which results from the incremental impact of the project when added
to other closely related past, present, and reasonably foreseeable probable future
projects. Cumulative impacts can result from individually minor but collectively
significant projects taking place over a period of time.” (Communities for a Better
Environment v. Cal. Resources Agency (2002) 103 Cal.App.4th 98, 117.) A legally
adequate “cumulative impacts analysis” views a particular project over time and in
conjunction with other related past, present, and reasonably foreseeable probable
future projects whose impacts might compound or interrelate with those of the
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project at hand. “Cumulative impacts can result from individually minor but
collectively significant projects taking place over a period of time.” (CEQA
Guidelines section 15355(b).)
As the court recently stated in Communities for a Better Environment v.
California Resources Agency, 103 Cal. App. 4th 98, 114 (2002):
Cumulative impact analysis is necessary because the full environmental impact
of a proposed project cannot be gauged in a vacuum. One of the most important
environmental lessons that has been learned is that environmental damage
often occurs incrementally from a variety of small sources. These sources appear
insignificant when considered individually, but assume threatening dimensions
when considered collectively with other sources with which they interact.
(Citations omitted).
In Kings County Farm Bureau v. City of Hanford, 221 Cal.App.3d at 718, the
court concluded that an EIR inadequately considered an air pollution (ozone)
cumulative impact. The court said: “The []EIR concludes the project’s contributions
to ozone levels in the area would be immeasurable and, therefore, insignificant
because the [cogeneration] plant would emit relatively minor amounts of [ozone]
precursors compared to the total volume of [ozone] precursors emitted in Kings
County. The EIR’s analysis uses the magnitude of the current ozone problem in the
air basin in order to trivialize the project’s impact.” The court concluded: “The
relevant question to be addressed in the EIR is not the relative amount of
precursors emitted by the project when compared with preexisting emissions, but
whether any additional amount of precursor emissions should be considered
significant in light of the serious nature of the ozone problems in this air basin.”74
The Kings County case was recently reaffirmed in CBE v. CRA, 103 Cal.App.4th at
116, where the court rejected cases with a narrower construction of “cumulative
74 Los Angeles Unified v. City of Los Angeles, 58 Cal.App.4th at 1024-1026 found an EIR inadequate
for concluding that a project’s additional increase in noise level of another 2.8 to 3.3 dBA was
insignificant given that the existing noise level of 72 dBA already exceeded the regulatory
recommended maximum of 70 dBA. The court concluded that this “ratio theory” trivialized the
project’s noise impact by focusing on individual inputs rather than their collective significance. The
relevant issue was not the relative amount of traffic noise resulting from the project when compared
to existing traffic noise, but whether any additional amount of traffic noise should be considered
significant given the nature of the existing traffic noise problem.
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impacts.” (See also, Friends of Eel River v. Sonoma County Water Agency, 108 Cal.
App. 4th 859, 869 (2003) (adopting Kings County approach for cumulative impacts
analysis).)
In Friends of Eel River v. Sonoma County Water Agency (2003) 108 Cal. App.
4th 859, the court held that the EIR for a project that would divert water from the
Eel River had to consider the cumulative impacts of the project together with other
past, present and reasonably foreseeable future projects that also divert water from
the same river system. The court held that the EIR even had to disclose and
analyze projects that were merely proposed, but not yet approved. The court stated,
CEQA requires “the Agency to consider ‘past, present, and probable future projects
producing related or cumulative impacts . . . .’ (Guidelines, § 15130, subd. (b)(1)(A).)
The Agency must interpret this requirement in such a way as to ‘afford the fullest
possible protection of the environment.’” (Id. at 867, 869.) The court held that the
failure of the EIR to analyze the impacts of the project together with other proposed
projects rendered the document invalid. “The absence of this analysis makes the
EIR an inadequate informational document.” (Id. at 872.)
The court in Citizens to Preserve the Ojai v. Bd. of Supervisors, 176
Cal.App.3d 421 (1985), held that an EIR prepared to consider the expansion and
modification of an oil refinery was inadequate because it failed to consider the
cumulative air quality impacts of other oil refining and extraction activities
combined with the project. The court held that the EIR’s use of an Air District Air
Emissions Inventory did not constitute an adequate cumulative impacts analysis.
The court ordered the agency to prepare a new EIR analyzing the combined impacts
of the proposed refinery expansion together with the other oil extraction projects.
A. The Focused EIR’s Cumulative Impact Assessment is
Inaccurate and Inconsistent and Not In Accordance With
CEQA
The focused EIR’s cumulative impact analysis is deficient and legally
unsound for several reasons. First, there is no cumulative impacts analyses
whatsoever for ten of the sixteen environmental factors listed in the NOP’s CEQA
Checklist. Given the comments above concerning leaking underground fuel tanks,
seismic hazards, fouling water quality, and traffic problems, it defies credulity that
the Project presents no cumulative impacts for these issues.
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1. The Focused EIR’s Cumulative Impact Analysis For
Hydrology and Water Quality is Inadequate
The focused EIR’s cumulative impact analysis for hydrology and water
quality merely discusses flooding and storm drainage in vague terms that do not
actually require anything of the facility or other present or future projects: “Typical
measures could include covering all outside storage facilities, vegetated swales,
detention basins with filtration systems, and monitoring programs.” (Focused EIR,
at p. 6-2 (emphasis added).) In this regard, the focused EIR merely discusses
measures which would normally address the flooding impact without actually
requiring such measures or conducting an assessment of whether the measures
reduce significant impacts. In other words, the DEIR contains no cumulative
impact analysis at all for this issue. Worse, the cumulative impacts analysis for
hydrology fails to address the cumulative impacts associated with water supply
issues for the proposed Project and other past, present and reasonably foreseeable
future projects in the planning area.
Significantly, with respect to hydrology and water quality, the City’s
cumulative impact analysis fails to mention the issues of cumulative phosphorus
pollution and groundwater contamination. A full EIR must address the cumulative
result of this Project and other area projects’ affect on water quality issues in the
project vicinity.
2. The Focused EIR’s Cumulative Impact Analysis For Land
Use and Planning is Inadequate
With respect to land use and planning, the focused EIR is impermissibly
vague: “The proposed project and cumulative growth will result in changes to
existing land uses. Vacant properties will be developed pursuant to recently
updated Temecula General Plan, leading to intensification of housing, commercial,
and industrial development throughout southern Temecula.” (Focused EIR, at p.
6.3.) Again, the DEIR contains no cumulative impact analysis at all for this issue,
and fails to identify other past present and future projects in the planning area. At
a minimum, the City must identify and describe specific projects in the planning
area in its cumulative impacts analysis.
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3. The Focused EIR’s Cumulative Impact Analysis For
Traffic Is Inadequate
The focused EIR fails to undertake the required evaluation of consistency
with the City’s General Plan policies related to cumulative traffic impacts. The
cumulative traffic analysis fails to evaluate traffic conditions at buildout of the
City’s General Plan. Instead, the focused EIR evaluates conditions at buildout
using the faulty methodology discussed above. While the TIA includes trips from 17
nearby projects in its analysis of eight intersections, the analysis does not include
trips associated with buildout of the City’s entire General Plan or trips associated
with buildout of the surrounding area. (See TIA, at p. 9) While Appendix B
includes trips from 21 nearby projects in its analysis of five intersections, the
cumulative projects data does not include trips associated with buildout of the City’s
entire General Plan or trips associated with buildout of the surrounding area.
Furthermore, the focused EIR fails to properly account for annual growth from
small development projects out to the horizon year of the City’s General Plan.
Accordingly, the focused EIR must analyze traffic conditions at General Plan
buildout without and with Temecula Regional Hospital Project traffic. Absent such
a cumulative analysis, the City’s focused EIR is inaccurate and incomplete.
B. The Focused EIR’s Cumulative Impact Analysis For Air Quality
Is Inadequate
The focused EIR finds significant and unavoidable cumulative impacts. The
focused EIR evaluates impacts “based primarily on 21 related projects identified by
the City of Temecula.” For a description of 17 of these projects, the focused EIR
relies on a 2002 traffic impact analysis for another project, the Apis Plaza. Rather
than providing a summary of these projects in the cumulative impacts analysis
section, the focused EIR refers the reviewer to the traffic impact analysis contained
in Appendix D for further information. Yet Appendix D does not contain any
information beyond the name and proposed uses of these projects and their
projected trip generation; it claims that the Apis Plaza Traffic Impact Analysis is
contained in its Appendix E, but the Initial Study failed to include this document.
Further, the focused EIR claims that four additional projects were
supplemented, yet it fails to supply any information on these projects. (Focused
EIR, p. 6-1 and Appx. D, p. 9.) The focused EIR contains no information for any of
these 21 projects. For example, there is no information on these project’s time
period over which they will be constructed, their expected buildout, or the air
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quality impacts resulting from their construction or operation. In short, the
information provided in the focused EIR is entirely inadequate to assess the
cumulative impacts on air quality resulting from the Project.
In sum, the cumulative impact analysis must include all past, present and
reasonably foreseeable future projects, including proposed projects. Instead, the
focused EIR only discusses other projects in the abstract, not once identifying other
applicable projects subject to an adequate cumulative impacts analysis. CEQA
prohibits the City from viewing the Project in a vacuum. The City must prepare a
full EIR for the Project to fully analyze, disclose to the public and consider
mitigation measures to address the important resources in the region.
VIII. THE FOCUSED EIR MUST DISCLOSE ALL GENERAL PLAN
INCONSISTENCIES
CEQA requires a lead agency to analyze the impacts of a project in reference
to relevant planning documents, including the General Plan. (CEQA Guidelines,
App. G, Evaluation of Environmental Impacts, Item 6.) An EIR must discuss any
inconsistencies that exist between a proposed project and any applicable general
plans and regional plans. (CEQA Guidelines section 15125(d).) This discussion is
mandatory under CEQA. The same analysis must be conducted when a lead agency
elects to use a negative declaration to evaluate the significant environmental
impacts that may be caused by a project. (CEQA Guidelines, App. G.) The purpose
of this requirement is to determine – in the context of a general plan’s policies,
objectives and standards – whether a particular project will have a significant
impact on the environment. A project’s impacts may be significant if they are
greater than those deemed acceptable in a general plan. (Gentry v. City of Murrieta
(1995) 36 Cal.App.4th 1359, 1416.)
Here, there are a number of inconsistencies between the focused EIR and the
General Plan for the City of Temecula. Specifically, as explained by Dr. Pless in her
attached comments, while the General Plan requires the Project’s air quality
impacts to be reduced to the greatest extent feasible, the focused EIR does not
include all feasible mitigation. Dr. Pless provides a list of feasible mitigation for air
quality impacts that are not addressed in the focused EIR.
Second, according to the General Plan, “public and institutional facilities
should be clustered in activity centers to reinforce other uses and benefit from
access to alternative modes of transportation.” City of Temecula General Plan, LU-
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October 26, 2005
Ms. Gloria D. Smith, Attorney at Law
Adams Broadwell Joseph & Cardozo
601 Gateway Boulevard, Suite 1000
South San Francisco, California 94080-7037
SUBJECT: Review of Traffic Portions of the Temecula Regional
Hospital Project Focused Environmental Impact Report in the City
of Temecula
Dear Ms. Smith:
Tom Brohard, PE, has reviewed various documents associated with the
proposed Temecula Regional Hospital in the City of Temecula. These
documents include the September 26, 2005 Focused Environmental Impact
Report (Focused EIR) prepared by P&D Consultants as well as the November
4, 2004 Traffic Impact Analysis (TIA) and the September 22, 2005 Traffic
Impact Analysis Addendum (Addendum) prepared by Linscott Law &
Greenspan Engineers.
My reviews of the Focused EIR, TIA, and Addendum indicate that numerous
transportation and circulation issues associated with the project have not
been properly or adequately addressed. As detailed throughout this report,
the following significant omissions, deficiencies and inadequacies were found:
1) Trip Generation Forecasts for the Project Are Significantly
Underestimated
a) Project Will Provide Additional Parking Spaces On Site
b) Low Trip Rate per Bed Was Used
c) All Trips from Cancer Center and Fitness Center Were Omitted
d) Additional Phase I Project Trips Will Create Significant Traffic
Impacts
e) Additional Buildout Project Trips Will Create Significant Traffic
Impacts
2) Inappropriate Traffic Counts Used to Evaluate Existing Conditions
3) Near Term and Buildout Baseline Analysis Issues
a) Near Term Baseline Traffic Volumes Must Include Annual Growth
b) Buildout Baseline Traffic Volumes Must Include Annual Growth
4) Cumulative Traffic Analysis Is Erroneous
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Temecula Regional Hospital Focused EIR Traffic Comments
October 26, 2005
5) Mitigation Measures Do Not Result in Less Than Significant Impacts
6) Numerous Omissions from the Focused EIR
a) Construction Impacts
b) Transit Impacts
c) Parking Impacts
d) Site Plan Analysis
In summary, the City has not conducted an appropriate traffic and
circulation analysis of the Temecula Regional Hospital Project. Without
further study to address the City’s inadequate analysis of significant traffic
impacts, it is not possible to conclude that the majority of the project’s traffic
impacts have a less than significant effect on the environment with
mitigation.
To rectify the numerous significant deficiencies and inadequacies, the issues
in this report as well as those expressed by others must be carefully studied
and addressed in a revised traffic impact analysis conducted as part of a
thorough project reevaluation in a revised and recirculated EIR.
Education and Experience
Since receiving a Bachelor of Science in Engineering from Duke University in
Durham, North Carolina in 1969, I have gained over 35 years of professional
engineering experience, all of which has occurred in California. I am licensed
as both a Professional Civil Engineer and as a Professional Traffic Engineer
in California. I formed Tom Brohard and Associates in 2000 and now serve
“on call” as Consulting Transportation Engineer for the City of San Fernando
and as the Interim City Traffic Engineer for the City of Indio.
I have extensive experience in traffic engineering and transportation
planning. During my career in both the public and private sectors, I served as
City Traffic Engineer for the Cities of Bellflower, Bell Gardens, Huntington
Beach, Indio, Lawndale, Los Alamitos, Oceanside, Paramount, Rancho Palos
Verdes, Rolling Hills, Rolling Hills Estates, San Fernando, San Marcos,
Santa Ana, and Westlake Village. While serving these communities, I
personally conducted hundreds of investigations of citizen requests for the
installation of various traffic control devices. During these assignments, I
successfully presented hundreds of traffic engineering reports at City Council
and Traffic Commission meetings.
During my career, I have reviewed numerous environmental documents and
traffic studies for various projects. Several recent assignments are
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Temecula Regional Hospital Focused EIR Traffic Comments
October 26, 2005
highlighted in the enclosed resume. During these assignments, I worked
successfully with several law firms and local interest groups in the review of
environmental documents and traffic studies, frequently within very limited
time constraints.
Brief Summary of the Project
According to Page 3-4 of the Focused EIR, “The proposed 566,160 square foot
Temecula Regional Hospital Facility consists of:
An approximately 408,160 square foot, 2-tower hospital complex to
contain approximately 320 beds…
Two medical office buildings, one 4 stories/73 feet high and the second
3 stories/60 feet high, providing approximately 140,000 square feet of
office space.
A 10,000 square foot cancer center housed in a one story building.
An 8,000 square foot fitness rehabilitation center in a one story
building.”
Regarding the project phasing, Pages 3-7 and 3-8 of the Focused EIR state:
“Construction of the proposed project will occur in five phases. Phase IA
consists of site grading, demolition of existing buildings, construction of a 3
story, 60,000 square foot medical office building (MOB #2), and construction
of adequate surface parking to serve the building. Phase IA is anticipated to
last approximately 10 months.
Phase IB consists of construction of the one story main hospital structure
comprising approximately 162,650 square feet and a 6 story tower of
approximately 122,755 square feet, as well as parking associated with the
structure and tower. Phase IB is anticipated to last approximately 14
months.
Phase II will expand the hospital to its ultimate 320 bed configuration with
the addition of the 5 story bed tower of approximately 122,755 square feet.
Phase III will add a 4 story 80,000 square foot medical office building (MOB
#1) and the hospital connector.
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October 26, 2005
Phase IV consists of construction of a one story, 10,000 square foot cancer
center and associated parking spaces.
Phase V will be construction of the 8,000 square foot fitness center and the
jogging trail.
Construction of Phases II through V is anticipated to occur concurrently and
to last approximately 12 months.”
From the above description of the project phasing in the focused EIR,
construction of the proposed project will take 36 months. It is likely that a
number of months or perhaps years will pass between construction activities
associated with each of the three major construction phases. As discussed
throughout this report, the focused EIR, TIA, and Addendum do not properly
evaluate baseline conditions in concert with the phasing of construction for
the proposed project. The failure of the focused EIR to analyze traffic impacts
associated with the major construction phases as well as buildout of the
entire project provides no assurance that implementation of mitigation
measures will be linked to significant traffic impacts caused by the phased
development of the Temecula Regional Hospital.
Traffic Related Issues
Section 4.6 of the focused EIR provides a summary of the environmental
setting, project analysis, traffic impacts and mitigation measures for the
project prepared by Linscott Law & Greenspan Engineers. Based on the
information in the Focused EIR, Traffic Impact Analysis (TIA), and
Addendum, my review indicates the following omissions, deficiencies, and
inadequacies in the traffic analysis for the proposed project:
1) Trip Generation Forecasts for the Project Are Significantly
Underestimated – The TIA and Addendum summarized in the Focused
EIR contain several significant errors in the calculation of AM peak hour,
PM peak hour, and daily trips that will be generated by the proposed
project. Use of average trip rates per hospital bed together with the
omission of all trips associated with the 10,000 square foot cancer center,
and the 8,000 square foot fitness center, significantly understates the
project trip generation and the resulting traffic impacts. As such, major
revisions to the Focused EIR are required to address the significant
impacts that the Temecula Regional Hospital Project will have on traffic.
The Focused EIR must use the higher trip forecasts discussed in the
following comments to properly identify the project traffic impacts and
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Temecula Regional Hospital Focused EIR Traffic Comments
October 26, 2005
develop appropriate mitigation measures. As detailed below, trips forecast
in the Focused EIR are significantly below those that should have been
calculated for the proposed project as follows:
a) Project Will Provide Additional Parking Spaces On Site – According to
Page 3-8 of the Focused EIR, “…the total parking spaces provided will
be 1,278 which exceeds the City’s parking standards which requires
663 parking spaces calculated for the hospital portion of the project, for
which the Development Code requires one space per 3 beds. The
parking provided on the site exceeds the standards contained in the
Development Code because the Code requirements do not adequately
account for parking needs within the hospital associated with staff
parking, outpatient services, and other needs within the facility. This
is common in most jurisdictions, and hospital facilities often exceed
minimum parking requirements for this reason.” Footnote 2 on Page 3-
8 of the Focused EIR attributes the above comments to a personal
communication on September 22, 2005 with Mr. David Prusha, HKS,
Inc., the architects and engineers for the proposed project.
Providing nearly double the amount of parking spaces on site over
what is required in the City’s Development Code is a strong indication
that the proposed project will generate more than the average number
of vehicle trips, particularly since the site is not currently served by
bus or other transit. The unrealistically low trip rates used in the
Focused EIR, TIA, and Addendum do not provide a proper basis for
analysis of reasonably foreseeable conditions associated with providing
nearly double the parking spaces required by the City’s Development
Code, and the low trip rates certainly do not provide an evaluation of
the “worst case” condition.
b) Low Trip Rate Per Bed Was Used – The Focused EIR, TIA, and
Addendum used the trip rate of 20 daily trips per bed published by
SANDAG, the San Diego Association of Governments, in developing
forecasts of daily, AM, and PM peak hour trips. For the initial phase
with 170 beds, 3,400 daily trips including 272 trips in the AM peak
hour and 340 trips in the PM peak hour were forecast. For the buildout
of 320 beds, 6,400 daily trips including 512 trips in the AM peak hour
and 640 trips in the PM peak hour were forecast. These unreasonably
low trip generation forecasts for the 170 bed hospital and the 320 bed
hospital developed in the TIA and Addendum were the used
throughout the Focused EIR for the proposed project.
In addition to trip rates per bed, SANDAG has also published rates of
25 daily trips per 1,000 square feet for hospitals, with 8 percent of the
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October 26, 2005
daily trips in the AM peak hour and 10 percent of the daily trips in the
PM peak hour. Applying the SANDAG trip rate per 1,000 square feet
indicates the initial phase of the hospital building with 285,405 square
feet will generate 7,140 daily trips including 570 trips in the AM peak
hour and 710 trips in the PM peak hour. For the buildout of 408,160
square feet, the hospital portion of the proposed project will generate
10,200 daily trips including 820 trips in the AM peak hour and 1,020
trips in the PM peak hour. With the additional parking provided on
site and the absence of transit service, the SANDAG trip rates per
1,000 square feet for the hospital portion of the project must be used to
analyze and mitigate project traffic impacts.
c) All Trips from Cancer Center and Fitness Center Were Omitted – Page
3-4 of the Focused EIR indicates the proposed project will include a
10,000 square foot cancer center and an 8,000 square foot fitness
center as components of the Temecula Regional Hospital. Table 4-22 on
Page 4-87 of the Focused EIR for the trip generation for buildout of the
proposed project only forecasts trips for a hospital containing 320 beds
and 140,000 square feet of medical offices. From the description of the
project on Page 3-4 of the Focused EIR, all trips associated with the
cancer center and the fitness center have been omitted from the traffic
analysis.
Using SANDAG data per 1,000 square feet indicates the 10,000 square
foot cancer center will generate 250 daily trips including 20 trips in the
AM peak hour and 25 trips in the PM peak hour. Using SANDAG data
per 1,000 square feet indicates the 8,000 square foot fitness center will
generate 200 daily trips including 16 trips in the AM peak hour and 20
trips in the PM peak hour. The additional 450 daily trips including 36
trips in the AM peak hour and 45 trips in the PM peak hour from these
two project components must be added to the project trip generation
forecasts, distributed to area roadway links and intersections,
analyzed, and the resulting significant traffic impacts mitigated as
necessary.
d) Additional Phase I Project Trips Will Create Significant Traffic
Impacts - Table 4-21 on Page 4-81 of the Focused EIR incorrectly
forecasts 3,400 daily trips with 272 trips in the AM peak hour and 340
trips in the PM peak hour for the 170 beds in the hospital in Phase I of
the proposed project. Analyzing the hospital component properly as
discussed above indicates the 285,405 square feet in Phase I will
generate 7,140 daily trips including 570 trips in the AM peak hour and
710 trips in the PM peak hour. The 3,740 additional daily trips
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October 26, 2005
including 298 additional AM peak hour trips and 370 additional PM
peak hour trips that will be generated by Phase I will significantly
impact additional intersections and segments over and above those
identified in the Focused EIR. Each of these significant traffic impacts
for Phase I of the proposed project must be identified and mitigated as
necessary to maintain the City’s Level of Service (LOS) D standard.
e) Additional Buildout Project Trips Will Create Significant Traffic
Impacts - Table 4-22 on Page 4-87 of the Focused EIR incorrectly
forecasts 6,400 daily trips with 512 trips in the AM peak hour and 640
trips in the PM peak hour for 320 beds in the hospital at buildout of
the proposed project. Analyzing the hospital component properly as
discussed above indicates the 408,160 square feet at buildout will
generate 10,200 daily trips including 820 trips in the AM peak hour
and 1,020 trips in the PM peak hour. Furthermore, 450 daily trips
including 36 trips in the AM peak hour and 45 trips in the PM peak
hour will be generated by the 10,000 square foot cancer center and the
8,000 square foot fitness center. The 4,250 additional daily trips
including 344 additional AM peak hour trips and 425 additional PM
peak hour trips that will be generated by the project will significantly
impact additional intersections and segments over and above those
identified in the Focused EIR. Each of these significant traffic impacts
for buildout of the proposed project must be identified and mitigated as
necessary to maintain the City’s LOS D standard.
2) Inappropriate Traffic Counts Used to Evaluate Existing Conditions – Page
4-72 of the Focused EIR states “Existing peak hour manual intersection
counts were conducted during the traditional weekday AM (7:00 – 9:00)
and PM (4:00 – 6:00) peak hours on March 23, 2004. Supplementary
counts were obtained in July of 2005 for the traffic study Addendum.”
Page 4-76 of the Focused EIR states “The current levels of service for
study intersections and roadway segments were calculated based upon
traffic counts and current intersection and roadway configurations.”
Our review of the traffic count sheets in Appendix A of the TIA indicates
the peak hour traffic counts were made on March 23, 2004 for all
intersections included in the TIA. Capacity calculations in Appendix B
were then made by using the traffic volumes from these March 2004
traffic counts. This approach ignores the significant traffic volume
increases that have occurred with the rapid growth and development
within and adjacent to the study area. The values obtained were then
used in the Focused EIR to represent baseline conditions at the time of
the Notice of Preparation (NOP) of the Focused EIR.
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October 26, 2005
Page 10 of the Addendum states “Existing Average Daily Traffic (ADT)
volumes and intersection counts were conducted by LLG in July 2005. In
addition, traffic counts were also obtained from the Temecula Medical
Center report. Appendix A contains the existing traffic volumes.” Our
review of the traffic count sheets in Appendix A of the Addendum
indicates peak hour traffic counts were made on July 7, 2005 only for the
intersection of Margarita Road and Dartolo Road, with the March 2004
traffic counts included for the other two intersections studied in the
Addendum. The traffic counts on Thursday, July 7, 2005 were taken
during the week with the July 4 Independence Day holiday. These traffic
counts do not properly represent normal weekday conditions with the
national holiday on Monday of that week, with summer vacations, and
with schools closed for the summer months.
Capacity calculations in Appendix C of the Addendum were then made by
directly using the traffic volumes from the March 2004 traffic counts and
the holiday week counts. This approach ignores the significant traffic
volume increases that have occurred with the rapid growth and
development in and adjacent to the study area, and provides unreliable
data for the holiday week. The capacity calculation values in the Focused
EIR do not represent baseline conditions at the time of the Notice of
Preparation (NOP) of the Focused EIR.
Page 2-2 of the Focused EIR indicates the Notice of Preparation (NOP)
was released on August 3, 2005. It is my understanding that the
California Environmental Quality Act (CEQA) requires evaluation of the
existing conditions at the time of the NOP. The evaluation of existing
conditions at the time of the NOP is essential to an accurate and complete
impact analysis. Traffic counts made in March 2004 at the eight
intersections in the TIA do not represent baseline conditions in 2005.
Traffic counts at Margarita Road and Dartolo Road taken during the
summer week that included the Independence Day holiday are unreliable.
New traffic counts must be made at all study intersections and all
calculations and subsequent analysis must be redone to properly analyze
traffic impacts of the Temecula Regional Hospital Project.
3) Near Term and Buildout Baseline Analysis Issues - Pages 3-7 and 3-8 of
the Focused EIR provide information regarding the length of construction
of the three phases of the Temecula Regional Hospital. However, the
failure of the Focused EIR to identify the expected timing of completion of
each of these major project phases as well as the buildout horizon for the
entire project provides no assurance that implementation of mitigation
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October 26, 2005
measures will be linked to significant traffic impacts caused by the phased
development of the project. The following two significant omissions in the
Focused EIR bear directly on the traffic analysis, causing it to be
inaccurate and incomplete as follows:
a) Near Term Baseline Traffic Volumes Must Include Annual Growth –
With one exception, existing traffic volumes counted at study
intersections reflect conditions in 2004. According to the Focused EIR,
development of the proposed project will occur in three major phases
over a number of years. To account for traffic volumes from small
development projects and to include continuing traffic volume
increases year after year, existing volumes are expanded by an annual
growth factor ranging from one to three percent annually. To properly
evaluate near term conditions, traffic studies must include an
appropriate annual growth factor plus traffic volume projections from
approved near term land development projects.
Page 4-81 of the Focused EIR states “To assess opening year and
buildout traffic conditions, two approaches were used. In the November
2004 traffic study, a 4 percent growth factor was added to existing
traffic volumes and then 17 cumulative projects were added.” In our
review of the near term capacity calculations in Appendix B of the TIA,
we found no growth factor was applied to the March 2004 traffic counts
with one exception. For the analysis of near term conditions in the AM
peak hour at SR 79 and La Paz Street, a 4 percent growth was
included to account for annual traffic growth. However, the capacity
calculation sheets for the PM peak hour analysis at SR 79 and La Paz
Road and for all of the other intersections do not include any growth
factor in the analysis of near term conditions for Phase I of the project.
The flawed approach used in the TIA and included in the Focused EIR
does not properly reflect annual traffic volume growth that must be
included in the near term baseline traffic volumes.
b) Buildout Baseline Traffic Volumes Must Include Annual Growth –
With one exception, existing traffic volumes counted at study
intersections reflect conditions in 2004. According to the Focused EIR,
development of the proposed project will occur in three major phases
over a number of years. To account for traffic volumes from small
development projects and to include continuing traffic volume
increases year after year, existing volumes are expanded by an annual
growth factor ranging from one to three percent annually. To properly
evaluate buildout conditions, traffic studies must include an
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October 26, 2005
appropriate annual growth factor plus traffic volume projections from
approved near term land development projects.
Page 4-81 of the Focused EIR states “To assess opening year and
buildout traffic conditions, two approaches were used. In the November
2004 traffic study, a 4 percent growth factor was added to existing
traffic volumes and then 17 cumulative projects were added.” In our
review of the capacity calculations for project buildout in Appendix B of
the TIA, we found no growth factor was applied to the March 2004
traffic counts with one exception. For the analysis of conditions in the
AM peak hour at SR 79 and La Paz Street, a 4 percent growth was
included to account for the traffic volume increases from small
developments and annual traffic growth. This 4 percent growth factor
does not appropriately expand the baseline traffic volumes to the
buildout horizon year for the entire project. In addition, the capacity
calculation sheets for the PM peak hour analysis at SR 79 and La Paz
Road and for all of the other intersections do not include any growth
factor in the analysis of buildout conditions for the project. The flawed
approach used in the TIA and included in the Focused EIR does not
properly reflect annual traffic volume growth that must be included in
the buildout baseline traffic volumes.
Without evaluating the project traffic impacts at the conclusion of each
project phase, it is impossible to determine the point in time at which the
multi phased project will cause the Level of Service (LOS) at impacted
intersections to deteriorate to an unacceptable level. Project phasing
assumptions in the traffic analysis must match project phasing in the
Focused EIR so mitigation measures can be implemented in a timely
manner to maintain the City’s LOS D standard as defined on Pages 4-69
and 4-70 of the Focused EIR. The Focused EIR must include annual
growth of the 2004 traffic counts for both AM and PM peak hours at all
intersections. The traffic analysis must also disclose significant traffic
impacts and associated mitigation measures at the completion of each of
the three major phases of the Temecula Regional Hospital.
4) Cumulative Traffic Analysis Is Erroneous – The cumulative traffic
analysis in the Focused EIR fails to evaluate traffic conditions at buildout
of the City’s General Plan. Instead, the Focused EIR, TIA, and Addendum
evaluate conditions at buildout of the proposed project using the faulty
methodology discussed above. While the TIA includes trips from 17 nearby
projects in its analysis of eight intersections, the listing beginning on Page
9 of the TIA does not include trips associated with buildout of the City’s
entire General Plan or trips associated with buildout of the surrounding
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Cont.
Ms. Gloria D. Smith
Temecula Regional Hospital Focused EIR Traffic Comments
October 26, 2005
area. While the Addendum includes trips from 21 nearby projects in its
analysis of five intersections, the cumulative projects data in Appendix B
of the Addendum does not include trips associated with buildout of the
City’s entire General Plan or trips associated with buildout of the
surrounding area. Furthermore, the TIA and the Addendum fail to
properly account for annual growth from small development projects out
to the horizon year of the City’s General Plan. The Focused EIR must
analyze traffic conditions at General Plan buildout without and with
Temecula Regional Hospital project traffic.
5) Mitigation Measures Do Not Result in Less Than Significant Impacts –
Page 4-86 of the Focused EIR indicates there will be significant traffic
impacts associated with development of Phase I of the proposed project in
the AM peak hour at Highway 79 South/Redhawk Parkway/Margarita
Road. While Page 4-86 states “Mitigation measures are required to reduce
the level of impact”, no measures are identified to mitigate these traffic
impacts. Near term mitigation measures for this intersection must be
identified.
Pages 4-93 and 4-94 of the Focused EIR list four primary mitigation
measures for buildout of the proposed project. For two of the mitigation
measures, the Focused EIR indicates mitigation will be achieved by
paying fees to Riverside County for impacts at the I-15 Interchange with
Highway 79 South or by paying the project’s fair share of the cost of the
improvements at six other intersections. For the other two mitigation
measures, the Focused EIR recommends that Temecula Regional Hospital
construct the associated mitigation measures.
Mitigation of project traffic impacts can only be achieved through actual
construction of mitigation measures. Payment of fees to Riverside County
or payment of the project’s fair share of improvements to the City does not
guarantee that these mitigation measures will be built. Until
improvements are actually in place, the traffic impacts of the Temecula
Regional Hospital must be considered as “significant” rather than “less
than significant”. The Focused EIR must include a mitigation monitoring
program that clearly identifies financing, scheduling, implementation
responsibilities, and lead agency monitoring.
6) Numerous Omissions from the Focused EIR – The Focused EIR for the
Temecula Regional Hospital Project fails to analyze potentially significant
impacts or to develop mitigation measures associated with the following
topics:
11
7-111
Cont.
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Ms. Gloria D. Smith
Temecula Regional Hospital Focused EIR Traffic Comments
October 26, 2005
a) Construction Impacts – The Focused EIR must analyze and evaluate
impacts associated with construction including dirt and building
material hauling, worker traffic, and worker parking for each of the
three major phases. Measures must be developed and incorporated into
the Focused EIR to mitigate construction traffic impacts. These
measures must maintain the City’s LOS D standard as defined on
Pages 4-69 and 4-70 of the Focused EIR so construction traffic does not
degrade the LOS below the significance threshold used in the Focused
EIR.
b) Transit Impacts – Correspondence in response to the NOP dated
August 18, 2005 from Riverside Transit Authority (RTA) in Appendix
A of the Focused EIR indicates “…future bus service is highly likely
along SR 79 and that the busses will be stopping at the proposed
hospital. The City of Temecula has expressed previous support for the
concept of a bus turnout and related amenities along SR 79 to be
installed by the project sponsors.”
The Focused EIR fails to address the request for a bus turnout from
RTA. The Focused EIR also fails to quantify the demand for new
transit services that the Temecula Regional Hospital Project will
create and to provide any transit mitigation measures such as
financial contributions to help establish new transit service along
Highway 79 South.
c) Parking Impacts – Page 1-4 of the Focused EIR states “Approximately
1,278 parking spaces will be provided on surface lots.” As previously
indicated, Page 3-8 of the Focused EIR characterizes the proposed
parking as being significantly above the requirements of the City’s
Development Code. However, the Focused EIR fails to review and
analyze the amount of parking being proposed on site.
Parking Generation, 3rd Edition published by the Institute of
Transportation Engineers (ITE) contains parking data for various land
uses including hospitals and medical office buildings. For suburban
hospitals, the average peak parking demand is identified at 4.72
vehicles per bed. To satisfy this demand, at least 1,510 parking spaces
would be needed for the 320 hospital beds in the proposed project. For
medical offices, the average parking supply is identified as 3.9 spaces
per 1,000 square feet. To meet this, at least 616 parking spaces would
be needed for the 140,000 square feet of medical offices, the 10,000
square foot cancer center, and the 8,000 square foot fitness center in
the proposed project. Based on the data published by ITE, at least
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Ms. Gloria D. Smith
Temecula Regional Hospital Focused EIR Traffic Comments
October 26, 2005
2,126 parking spaces are required to meet the needs of the Temecula
Regional Hospital Project, significantly higher than the 1,278 parking
spaces being proposed.
The Focused EIR also fails to analyze impacts associated with
providing all parking on site as surface parking. With the project
having an overall shortage of 850 parking spaces and with over 30
percent of the project site occupied by surface parking, consideration
must be given to construction of a parking structure to reduce
environmental impacts in other areas and to avoid impacts to rock
outcrops and trees on the site.
d) Site Plan Analysis - The Focused EIR fails to analyze the proposed site
plan shown in Figure 3-2 on Page 3-5 of the Focused EIR for the
Temecula Regional Hospital. Important traffic considerations that
must be addressed by the Focused EIR include topics such as the
length of driveway throats to adequately accommodate vehicle queuing
and stacking, sight distance at external and internal intersections, on
site vehicle circulation, patient and visitor drop off and pick up areas,
pedestrian facilities, truck loading areas, and accessibility of parking
spaces.
Without these additional analyses, the Focused EIR fails to address all
reasonably foreseeable adverse construction, transit, parking, and traffic
impacts of the proposed project.
In sum, there are numerous transportation and circulation issues, omissions,
and inadequacies associated with the September 26, 2005 Focused EIR for
Temecula Regional Hospital Project. The items outlined in this letter must be
carefully studied and evaluated before reaching the conclusion that most of
the project traffic impacts can be reduced to insignificance with mitigation.
The Focused EIR, TIA, and Addendum must be revised to respond to our
significant comments as part of the environmental process and recirculated
13
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Tom Brohard and Associates
Tom Brohard, PE
Licenses: 1976 / Professional Engineer / California – Civil, No. 24577
1977 / Professional Engineer / California – Traffic, No. 724
Education: BS / Civil Engineering / Duke University / 1969
Experience: 35 Years
Memberships: Institute of Transportation Engineers - Member
Orange County Traffic Engineers Council - Chair 1979-1980
American Public Works Association - Member
Expertise: Tom is a recognized expert in the field of traffic engineering and
transportation planning. His background also includes responsibility for
leading and managing the delivery of various contract services to
numerous cities in Southern California. Since forming Tom Brohard
and Associates in 2000, Tom has reviewed many traffic impact reports
and environmental documents for various projects across the state.
Tom has extensive experience in providing transportation planning and
traffic engineering services across Southern California. From 1972
through 1978, he conducted all traffic engineering investigations in the
Second Supervisorial District in Los Angeles County. He has served as
City Traffic Engineer/Transportation Manager/Engineer as follows:
o Bellflower.....................................1997 - 1998
o Bell Gardens................................ 1982 - 1995
o Huntington Beach........................ 1998 – 2004
o Indio………………………………... 2005 - present
o Lawndale..................................... 1973 - 1978
o Los Alamitos................................ 1981 - 1982
o Oceanside................................... 1981 - 1982
o Paramount................................... 1982 - 1988
o Rancho Palos Verdes.................. 1973 - 1978
o Rolling Hills.................................. 1973 - 1978, 1985 - 1993
o Rolling Hills Estates..................... 1973 - 1978, 1984 - 1991
o San Fernando…………………….. 2003 - present
o San Marcos................................. 1981
o Santa Ana....................................1978 - 1981
o Westlake Village..........................1983 - 1994
While serving Huntington Beach, Tom oversaw a staff of 20 including
traffic engineers and transportation planners, traffic signal and street
lighting personnel, and the signing, striping, and marking crews. He
secured $3.5 million in grant funding, managed the initial West Orange
County Rail Feasibility Study, and recently oversaw the consultant
selection for the City’s Traffic Model and Circulation Element Update.
Tom Brohard, PE, Page 2
Tom Brohard and Associates
Selected significant accomplishments during the last four years include the following:
Conducted Traffic Impact Analyses for the Sacred Heart Church and School Master
Plan in the City of Palm Desert including presentations to community residents and
testimony at Public Hearings before the City Council (3/2005 to 7/2005)
Prepared preliminary critique of the Draft EIR and traffic study for the Prewett Ranch
Project in the City of Brentwood for Adams Broadwell Joseph & Cardozo (7/2005)
Prepared critique of the Mitigated Negative Declaration and Traffic Impact Analysis
for the Providence Center Specific Plan in the City of Fullerton for Shute, Mihaly, &
Weinberger (6/2005 to 7/2005)
Prepared critique of the traffic and circulation sections of the Draft Subsequent EIR
of the County of Ventura Focused General Plan Update and prepared rebuttal to
responses for Shute, Mihaly, & Weinberger and the Community of Somis (12/2004
to 1/2005; 6/2005)
Prepared response to Initial Study and Notice of Preparation of a Draft EIR for 483
condominiums proposed in three high rise towers in Century City in the City of Los
Angeles for Tract No. 7260 Association (6/2005)
Prepared critique of the traffic and parking impacts identified in the Draft EIR and
Traffic Impact Analysis for the Long Beach Memorial Medical Center Expansion in
the City of Long Beach for Weinberg, Roger & Rosenfeld (2/2005 to 5/2005)
Prepared critique of the Draft EIR and traffic study for the Villages at Fairfield Project
in the City of Fairfield for Adams Broadwell Joseph & Cardozo (4/2005 to 5/2005)
Prepared critique of the traffic, circulation, and parking impacts identified in the
Traffic Impact Analysis for Los Angeles Unified School District Valley High School #5
in the City of San Fernando (4/2005)
Prepared critique of the transportation, circulation, and parking impacts identified in
the Draft EIR and the Final EIR for the Wood Street Project in the City of Oakland for
the East Bay Community Law Center (3/2005)
Conducted City wide engineering and traffic surveys confirming enforceable speed
limits on 31 street segments for the City of San Fernando (1/2005 to 3/2005)
Prepared critiques of the traffic impacts identified in the Draft EIR and in the Revised
Draft EIR for the Central Larkspur Specific Plan in the City of Larkspur and prepared
responses to comments in the Final EIR for Shute, Mihaly, & Weinberger (7/2002 to
8/2002, 12/2003 to 2/2004, and 1/2005 to 3/2005)
Tom Brohard, PE, Page 3
Tom Brohard and Associates
Checked plans for traffic signal installations and modifications as well as signing and
striping revisions for various projects for Engineering Resources of Southern
California and the Cities of Hemet and Palm Springs (12/2003 to 3/2005)
Prepared critique of the Initial Study and traffic study prepared for the Hidden
Canyon (Greenfield) Quarry Use Permit and Reclamation Plan in Monterey County
for Weinberg, Roger & Rosenfeld (2/2005)
Prepared critiques of the traffic impacts identified in the Los Angeles International
Airport Master Plan Draft EIS/EIR for Alternatives A, B, and C and in the Supplement
Draft EIS/EIR for Alternative D, prepared responses to comments in the Final
EIS/EIR, and reviewed Addendum #3 for Shute, Mihaly, & Weinberger and the City
of El Segundo (2/2001 to 7/2001, 7/2003 to 10/2003, 11/2004, and 12/2004)
Prepared critique of the Traffic Study for the 450-460 North Palm Drive Senior
Housing Residential Project in the City of Beverly Hills for Luna & Glushon (11/2004)
Prepared critique of the Draft EIR and traffic study and provided testimony at a
public hearing regarding the West Los Angeles College Facilities Master Plan in Los
Angeles County for Culver Crest Neighborhood Association (10/2004 to 12/2004)
Prepared critique of the Draft EIR and the associated traffic impact analysis as well
as subsequent rebuttal to responses to these comments in the Final EIR for The
Ranch Plan in the County of Orange for the Endangered Habitats League (6/2004 to
7/2004 and 10/2004)
Prepared preliminary critique of the Draft EIR and traffic study for the Chandler
Ranch Specific Plan Project in the City of Paso Robles for Adams Broadwell Joseph
& Cardozo (9/2004)
Prepared critique of the Draft EIR and traffic report associated with the Magnolia
Park Project in the City of Oakley for Adams Broadwell Joseph & Cardozo (9/2004)
Prepared critique of the traffic impacts identified in the Recirculated Draft EIR and
traffic study for the McKean Road Sports Complex in Santa Clara County for Shute,
Mihaly, & Weinberger (9/2004)
Prepared critique of the Environmental Assessment for Robie Ranch Reclamation
Project in Calaveras County for Weinberg, Roger & Rosenfeld (9/2004)
Provided expert assistance to residents in the City of La Mirada during settlement
negotiations regarding litigation involving the Big T Residential Development Project
in the City of Buena Park (6/2004 to 9/2004)
Prepared critique of the traffic impacts identified in the Recirculated Draft EIR and
the associated traffic study for the Lake Jennings Ralph’s Shopping Center in San
Diego County for SOFAR and Shute, Mihaly, & Weinberger (8/2004)
Tom Brohard, PE, Page 4
Tom Brohard and Associates
Reviewed Traffic Impact Study prepared for the San Fernando Corridors Specific
Plan for the City of San Fernando (7/2004 to 8/2004)
Prepared critique of the Negative Declaration for the Brisbane Recycling Project in
the City of Brisbane for Weinberg, Roger & Rosenfeld (6/2004)
Reviewed various alternative alignments for the extension of Lexington Drive from
Cerritos Avenue to Katella Avenue, a proposed secondary highway, for the City of
Los Alamitos; provided expert assistance to the City of Los Alamitos during
settlement negotiations regarding litigation of the proposed Cottonwood Christian
Center Project in the City of Cypress (4/2004 to 6/2004)
Prepared critique of the Draft EIR and the associated traffic impact study for the
Jaxon Enterprises Mine and Reclamation Expansion Project in the County of Merced
for Weinberg, Roger & Rosenfeld (5/2004)
Prepared critique of the Environmental Secondary Study for the Santa Fe Parcel 6
Mixed Use Project in the City of San Diego for Adams Broadwell Joseph & Cardozo
(4/2004 to 5/2004)
Prepared critique of the Draft EIR and the associated traffic impact analysis for the
for the San Mateo Rail Corridor Plan & Bay Meadows Specific Plan Amendment in
the City of San Mateo for Adams Broadwell Joseph & Cardozo (3/2004 to 5/2004)
Reviewed the Edinger Corridor Specific Plan Traffic Analysis for the proposed
redevelopment and intensification of adjacent land uses for the City of Huntington
Beach (12/2003, 4/2004, and 5/2004)
Conducted the Traffic Impact Study of the San Fernando Regional Pool Facility
Project and the associated street improvements for the City of San Fernando
(3/2004 to 4/2004)
Prepared critique of the Initial Study/Mitigated Negative Declaration and the
associated traffic study for the Pixar Headquarters Expansion in the City of
Emeryville for Shute, Mihaly, & Weinberger (3/2004 to 4/2004)
Prepared critique of the Draft EIR and the associated traffic impact analysis for the
Lower Lagoon Valley Specific Plan in the City of Vacaville for Adams Broadwell
Joseph & Cardozo (3/2004 to 4/2004)
Conducted the Traffic Study of Two Parking Alternatives for the City of San Dimas to
provide on street parking to complement potential retail/residential development on
the east side of San Dimas Avenue north of Arrow Highway (12/2003 to 4/2004)
Prepared trip generation calculations for various retail and “Big Box” stores in
conjunction with a March 2004 ballot measure in Contra Costa County for Mark R.
Wolfe & Associates (1/2004 to 2/2004)
Tom Brohard, PE, Page 5
Tom Brohard and Associates
Prepared critique of the Initial Study/Mitigated Negative Declaration and the
associated transportation impact analysis for the S&S Farms and Hancock Property
Residential Development Plan in the City of Brentwood for Adams Broadwell Joseph
& Cardozo (2/2004)
Prepared critiques of the traffic impacts identified in the Mitigated Negative
Declarations as well as subsequent rebuttal to responses to these comments for the
Bayfront Live Work Project in the City of Hercules for Adams Broadwell Joseph &
Cardozo (4/2003, 10/2003, and 2/2004)
Conducted the City Wide Traffic Calming Study of Residential Streets in the City of
San Fernando including development of traffic calming guidelines and specific
recommendations addressing over 70 “Hot Spots” throughout the City including
monthly presentations at Transportation & Safety Commission meetings and a
presentation of the Final Report to the City Council (5/2003 to 1/2004)
Prepared critique of the Initial Study/Mitigated Negative Declaration and the
associated transportation analysis for the Cottonwood Christian Center in the City of
Cypress for the City of Los Alamitos (1/2004)
Prepared critique of the Recirculated Draft EIR and the associated transportation
analysis for the Sand Creek Specific Plan in the City of Antioch for Adams Broadwell
Joseph & Cardozo (1/2004)
Prepared critique of the Initial Study and the associated traffic impact studies for the
West Dublin Transit Village in the City of Dublin for Adams Broadwell Joseph &
Cardozo (11/2003 to 1/2004)
Prepared critiques of the Initial Study and the Recirculated Initial Study/General Plan
Amendment and Rezoning for the Jack Parker Trucking Site in the City of San Pablo
for Adams Broadwell Joseph & Cardozo (9/2003 and 11/2003)
Prepared critique of the traffic impacts identified in the Draft EIR and rebuttal to
responses to comments in the Final EIR for the proposed Wal-Mart in the City of
Fremont for Mark R. Wolfe & Associates (7/2002 to 10/2003)
Prepared critique of the traffic impacts identified in the Draft EIR, rebuttal to
responses in the Final EIR, and testimony at a public hearing regarding the Alpine
Village Shopping Center in San Diego County for Shute, Mihaly, & Weinberger
(6/2002 to 10/2003)
Prepared critique of the traffic impacts identified in the Draft EIR, rebuttal to
responses in the Final EIR, testimony at public hearings, and assistance during
settlement negotiations regarding the 2000 Avenue of the Stars Project in Century
City in the City of Los Angeles for Tract No. 7260 Association (9/2002 to 10/2003)
Tom Brohard, PE, Page 6
Tom Brohard and Associates
Prepared critique of the traffic impacts identified in the Draft EIR for the Glen Loma
Ranch Project in the City of Gilroy for Adams Broadwell Joseph & Cardozo (9/2003)
Prepared critique of the traffic impacts identified in the Initial Study and the Traffic
Impact Analysis for the Ryder Homes Project in the City of Oakley for Adams
Broadwell Joseph & Cardozo (9/2003)
Prepared critique of the traffic impacts identified in the Initial Study and the Traffic
Impact Analysis for the Ravenswood Residential Project in Contra Costa County for
Adams Broadwell Joseph & Cardozo (8/2003 to 9/2003)
Prepared critique of the traffic impacts identified in the Draft Subsequent EIR for the
proposed Boronda Crossing Commercial Project in the City of Salinas for Mark R.
Wolfe & Associates (8/2002 to 9/2003)
Prepared four grant applications to Caltrans for $1,115,000 of Hazard Elimination
Safety funding to modify traffic signals and to upgrade regulatory, warning, and
street name signs in the City of Santa Ana (3/2003 to 8/2003)
Prepared critique of the traffic impacts identified in the Draft EIR and the Traffic
Impact Analysis for the Bluerock Business Center Project in the City of Antioch for
Adams Broadwell Joseph & Cardozo (8/2003)
Prepared critique of the traffic impacts identified in the Draft EIR for the Clark Road
Residential Project in the City of Richmond for Adams Broadwell Joseph & Cardozo
(8/2003)
Prepared critique of the traffic impacts identified in the Initial Study and the Traffic
Impact Analysis for the Sky Ranch Residential Project in the City of Antioch for
Adams Broadwell Joseph & Cardozo (7/2003 to 8/2003)
Prepared critique of the traffic impacts identified in the Draft EIR for the Cal Poly
Student Housing North Project in the City of San Luis Obispo for Adams Broadwell
Joseph & Cardozo (7/2003)
Prepared critique of the traffic impacts identified in the Final EIR for the Lake
Jennings Ralph’s Shopping Center in San Diego County for SOFAR and Shute,
Mihaly, & Weinberger (3/2003 to 7/2003)
Prepared critique of the traffic impacts identified in the Draft EIR for the Cypress
Grove Residential Project in the City of Oakley for Adams Broadwell Joseph &
Cardozo (6/2003)
Prepared critique of the traffic impacts identified in the Draft EIR for the McKean
Road Sports Complex in Santa Clara County for Shute, Mihaly, & Weinberger
(5/2003)
Tom Brohard, PE, Page 7
Tom Brohard and Associates
Prepared grant application to Caltrans for $448,000 of Safe Route to School funding
to upgrade all school signs at 68 public and private schools in the City of Santa Ana
(3/2003 to 5/2003)
Prepared critique of the traffic impacts identified in the Traffic Impact Analysis for the
Blossom Valley Middle School for the Dunbar Lane Task Force in San Diego County
(4/2003 to 5/2003)
Prepared critique of the traffic impacts identified in the Draft EIR and the Traffic
Impact Analysis for the Bettencourt Ranch Aggregate Mining Project in Merced
County for Weinberg, Roger & Rosenfeld (4/2003)
Conducted a complete review of the General Plan Circulation Element for the City of
Huntington Beach including comparisons to the Orange County Transportation
Authority’s Master Plan of Arterial Streets and drafted a Request for Proposal to
update the City’s Circulation Element (8/2002 to 4/2003)
Prepared critique of the traffic impacts identified in the Traffic Impact Analysis for the
proposed Wal-Mart in the City of Gilroy for Mark R. Wolfe & Associates (2/2003 to
3/2003)
Prepared critique of the traffic impacts identified in the Draft EIR for the
Waterfront/Downtown Mixed Use Project in the City of Vallejo for Adams Broadwell
Joseph & Cardozo (2/2003)
Provided expert witness evaluation of the traffic impacts caused by simultaneous
construction of various Alameda Corridor Transportation Authority projects for
Sullivan, Workman, & Dee (12/2002 to 2/2003)
Conducted 12 training sessions in Urban Street Design Fundamentals for the
Engineering Department staff in the City of Torrance (4/2001 to 4/2002 and 10/2002
to 12/2002)
Prepared critique of the traffic impacts identified in the Transportation Impact Study
for the Western Research Campus in the City of Richmond in Contra Costa County
for Adams Broadwell Joseph & Cardozo (11/2002)
Evaluated Conditions of Approval for the proposed intersection of Mulholland
Highway and Hazel Nut Court in Los Angeles County and provided testimony to the
Board of Supervisors for Seminole Springs Mobile Home Park (11/2002)
Reviewed the Traffic Impact Analysis prepared for the Pacific City Project for the
City of Huntington Beach (9/2002)
Prepared critique of the traffic impacts identified in the Draft EIR for North Yorba
Linda Estates in the City of Yorba Linda for Shute, Mihaly, and Weinberger (9/2002)
Tom Brohard, PE, Page 8
Tom Brohard and Associates
Conducted the Hacienda Road Traffic Calming Study and presented the final report
at locally televised meetings of the Traffic Committee and the City Council in the City
of La Habra Heights (10/2001 to 9/2002)
Prepared critique of the traffic impacts identified in Initial Studies with Traffic Impact
Analyses for three residential subdivisions in the City of Pittsburg for Adams
Broadwell Joseph & Cardozo (8/2002)
Conducted the City Wide Traffic Safety Study and presented the final report at
meetings of the Traffic Committee and the City Council in the City of Rolling Hills
Estates (4/2001 to 5/2002)
Prepared critique of the traffic impacts identified in the Draft EIR, rebuttal to
responses, and testimony at a public hearing regarding extensions of Corona and
Valley View Avenues in the City of Norco for C. Robert Ferguson (1/2002 to 4/2002)
Prepared critique of the traffic impacts identified in the Draft Initial Study and
Environmental Assessment, rebuttal to responses, and testimony at public hearings
before the Ventura County Board of Supervisors regarding intersection
improvements proposed by Caltrans at State Route 118/State Route 34 in Ventura
County for the Community of Somis (12/2000 to 10/2001)
SOIL/WATER/AIR PROTECTION ENTERPRISE
201 Wilshire Blvd., Second Floor
Santa Monica, California 90401
Fax: (310) 393-4909
Matt Hagemann
Tel: (949) 887-9013
Email:mhagemann@swape.com
October 26, 2005
Gloria Smith
Adams Broadwell Joseph & Cardozo
651 Gateway Boulevard, Suite 900
South San Francisco, California 94080
Dear Ms. Smith:
We have reviewed the Draft Temecula Regional Hospital Environmental Impact Report,
as prepared on September 26, 2005 for the City of Temecula. We have the following
comments on the proposed project's potential for impacts on water quality. We have also
noted in our review that the DEIR failed to discuss potentially significant issues related to
hazardous waste and the geologic setting, including proximity to the Elsinore Fault and
the potential for liquefaction.
1. The EIR Fails to Identify Hazardous Waste Sites
The proposed hospital is located within 250 feet of two gas stations where leaking
underground fuel tanks are the subject of ongoing assessment and cleanup activities. A
Chevron station at 31669 Hwy. 79 is listed as open at the Cal/EPA “Geotracker” web site
(http://geotracker.swrcb.ca.gov/reports/luft.asp?global_id=T0606599286&assigned_nam
e=MAINSITE). Contaminants in groundwater are gasoline-related, including methyl
tert-butyl ether (MTBE), tert-buytl alcohol, (TBA) and toluene.
An ARCO station at 44239 Margarita Road is listed at the Geotracker web site as
undergoing assessment and cleanup activities
(http://geotracker.swrcb.ca.gov/reports/luft.asp?global_id=T0606599255&assigned_nam
e=MAINSITE). As with the Chevron station, contaminants in groundwater include
gasoline-related compounds.
These gas stations are listed by the City of Temecula in the General Plan as “open fuel
leak cases. In accordance with the City's General Plan:
“any new development that involves contaminated property will necessitate the
clean up and/or remediation of the property in accordance with applicable federal,
State, and local requirements and regulations. No construction will be permitted
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to occur at such locations until a no further action or similar determination is
issued by the City's Fire Department, Department of Toxic Substances Control,
Regional Water Quality Control Board, and/or other responsible agency.”
http://www.cityoftemecula.org/cityhall/CommDevDivision/Planning/gpupdate/Fi
nal%20EIR/5_7%20Hazards%20and%20Hazardous%20Materials.pdf
The project is located adjacent to two sites that are listed as open and are actively
undergoing assessment and cleanup for hazardous materials. The EIR does not
acknowledge these sites and their cleanup status. Groundwater is less than 25 feet below
the ground surface at the project location and exposure to the gasoline-related compounds
via the water or vapor pathways is possible during construction and within buildings pot-
construction. Therefore, a full DEIR should be prepared to identify potentially
significant impacts of contaminant exposure to workers and hospital staff and patients to
these contaminants. Any pathways of exposure that would result in risk to human health
should be mitigated prior to construction.
2. The EIR Fails to Identify the Location of the Project Near an Active
Fault Zone
The EIR does not disclose that the project is located within 2500 feet of the Elsinore
Fault, a fault that has generated a magnitude 7.0 earthquake along its southern segment in
the late 1800s. The Temecula General Plan identifies the Elsinore Fault as an Alquist-
Priolo Earthquake Fault Zone. This designation, pursuant to California’s Alquist-Priolo
Earthquake Fault Zoning Act (Public Resources Code, Section 2621 et. seq.) limits the
types of construction and other activities that can occur within the Elsinore Fault Zone to
prevent damage associated with ground surface rupture.
A DEIR should be prepared to fully disclose the potential significant impacts on the
project from earthquake shaking and fault rupture. In accordance with the General Plan,
the DEIR should include completion of geologic investigation by a State-licensed
engineering geologist is required to demonstrate that the project will not be constructed
across any traces of the Elsinore Fault. If an active fault is found, a structure
for human occupancy cannot be placed over the trace of the fault and must be set back
from the fault in accordance with the California Public Resources Code.
3. The EIR Fails to Identify the Location of the Project in a
Liquefaction Hazard Zone
According to the Temecula General Plan, and as shown in the following figure, the area
underlying the proposed project is especially prone to liquefaction and has been mapped
in a "liquefaction hazard zone"
(http://www.cityoftemecula.org/cityhall/CommDevDivision/Planning/gpupdate/Final%20
EIR/5_6%20Geology%20and%20Soils.pdf, p. 5.6-4).
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The EIR fails to discuss the geologic setting of the project and fails to identify the
project's location within a liquefaction zone. A full DEIR should be prepared to identify
that the area under that proposed hospital is prone to liquefaction and to identify specific
ways in which these conditions can be mitigated.
4. The DEIR fails to Discuss 303(d) Impaired Water Body Listing of
Nearby Waters
Twelve miles of Murrieta Creek are listed on the 303(d) list as an impaired water body
for phosphorous pollution. The San Diego Regional Water Quality Control Board has
listed sources to include urban runoff and storm sewers, unknown nonpoint sources, and
3
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Cont.
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unknown point sources
(http://www.waterboards.ca.gov/tmdl/docs/2002reg9303dlist.pdf). Additionally, 18
miles of the Santa Margarita River, the primary drainage course within the Planning
Area, are also listed as impaired for phosphorous from the same sources. The DEIR
states that Murrieta Creek is one of two main tributaries to the Santa Margarita River:
“The creeks drain the inland portion of the Santa Margarita River Basin and join with the
Santa Margarita River at Temecula Canyon.” (pg. 5.8-3)
Although the Regional Board's TMDL priority is classified as “low” for Murrieta Creek,
the potential for additional phosphorous contamination from the development project
should be evaluated in the a revised DEIR. Urban runoff typically contains phosphorous
as a main pollution component. Since potential exists for phosphorous contamination to
travel downstream into the Santa Margarita River, further degrading its water quality, it is
imperative that mitigation measures as specific BMPs be addressed within the DEIR that
describe how phosphorous contamination will be prevented from entering the Murrieta
Creek.
Furthermore, the DEIR states that flooding of Murrieta Creek banks has occurred during
times of heavy rain:
“Frequent overtopping of the Murrieta Creek channel by floodwaters in a number
of channel reaches, flood inundation of structures with attendant damages, and
other water-related problems are caused during major rainstorms, resulting in
increased emergency costs, automobile damage, and traffic disruption. Murrieta
Creek has been altered since the late 1800s and has been channelized for flood
control purposes since the 1930s. Restoration of the natural functions of the creek
is planned, including the banks, channel invert, tributaries and floodplain.” (pg.
5.8-3)
It is important that this flood potential be mitigated prior to development to protect water
quality of Murrieta Creek and its tributaries. Flooding of the developed site can
contribute urban contaminates to the creek, which include but are not limited to debris,
oil, grease, herbicides, and nutrients from fertilizers such as phosphorous. Mitigation
measures should be evaluated in the DEIR and implemented upon development.
5. Failure Achieve NPDES General Permit No. CAS000002
Requirements
Applicants of construction projects disturbing one or more acres of soil are required to
file for coverage under the State Water Resources Control Board (SWRCB), Order No.
99–08–DWQ, National Pollutant Discharge Elimination System (NPDES) General
Permit No. CAS000002 for Discharges of Storm Water Runoff Associated with
Construction Activity (General Permit). The proposed development is thus subject to the
NPDES permit requirements.
The General Permit also requires the development and implementation of a Storm Water
Pollution Prevention Plan (SWPPP). The SWPPP should contain:
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xa site map which shows the construction site perimeter;
xexisting and proposed buildings, lots, roadways, storm water collection
and discharge points;
xgeneral topography both before and after construction;
xdrainage patterns across the project.
The SWPPP must list Best Management Practices (BMPs) the discharger will use to
protect storm water runoff and the placement of those BMPs. The DEIR fails to meet the
NPDES General Permit No. CAS000002 requirements and does not include a SWPPP,
nor discuss specific mitigation BMPs.
Additionally, the DEIR omits the discussion of post-construction stormwater
management best management practices (BMPs) as required by Sections A of the
SWPPP in accordance with NPDES General Permit. Given post-construction adverse
impacts on water quality associated with the project’s operation, such as anticipated
water pollution due to increased traffic volumes, typical landscaping upkeep, and
equestrian uses of trails, discussion of post-construction stormwater BMPs is critical to
ascertain the effectiveness of these BMPs to mitigate such operational impacts and meet
applicable water quality attainment objectives.
The DEIR omits the inclusion of water quality monitoring programs as required by
Sections B of the SWPPP in accordance with NPDES General Permit. The NPDES
permit requires that a SWPPP also include a sampling and analysis strategy and sampling
schedule for discharges from construction activities that directly impact water bodies
listed on the Regional Water Quality Control Board’s Section 303(d) impaired water
bodies list for sedimentation. Since both Murrieta Creek and Santa Margarita River are
listed on the Regional Board’s 303(d) list as impaired for phosphorous, a revised DEIR
should be prepared to include a monitoring plan for the establishment of baseline water
quality conditions, prior to construction, to evaluate and validate the effectiveness of the
BMPs, to measure the effectiveness of the BMPs and avoid further degradation of the
impaired waterways.
6. The DEIR Contains an Inadequate Water Supply Assessment
The project is subject to the requirements outlined by the California Water Code section
10910, also known as SB 610. This law requires that the public water system, which in
this case is the Rancho California Water District (RCWD), prepare a Water Supply
Assessment (WSA). This assessment is included as Appendix G within the DEIR.
However the assessment is insufficient according to SB 610 and fails to meet the
following requirements as outlined within the bill:
Groundwater – Basin Description, PWS Pumping, and Sufficiency Analysis
10910. (f) If a water supply for a proposed project includes groundwater, the
following additional information shall be included in the Water Supply
Assessment:
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(3) A detailed description and analysis of the amount and location of groundwater
pumped by the public water system, or the city or county if either is required to
comply with this part pursuant to subdivision (b), for the past five years from any
groundwater basin from which the proposed project will be supplied. The
description and analysis shall be based on information that is reasonably
available, including, but not limited to, historic use records.
(4) A detailed description and analysis of the amount and location of groundwater
that is projected to be pumped by the public water system, or the city or county if
either is required to comply with this part pursuant to subdivision (b) from any
basin from which the proposed project will be.
The DEIR explains that additional water supply for the project will be available via local
groundwater sources:
“To accommodate future developments such as the Temecula Regional Hospital,
the RCWD intents to meet supply planning issues through a combination of the
following alternatives: (1) Continued practice of managing groundwater levels
through natural and artificial recharge via groundwater extracted using existing
and planned RCWD-owned wells. . . ” (pg. 4-34)
However, the WSA does not include a “detailed description and analysis" of the most
recent groundwater usage, including source locations and pumped volumes for the past
five years, or provide a detailed description of projected water usage volumes, as
mandated by points (3) and (4).
Additionally, within the WSA (pg. 7) the following is stated regarding groundwater
volume: “The amount of groundwater which can be produced varies due to such factors
as rainfall, recharge area and amount and location of well pumping capacity.” In the
event of a drought with decreased surface water flows the WSA states that “increased
groundwater extractions along with implementation of conservation and other measures”
will makeup the difference. Without calculated projected groundwater volumes there is
no way to guarantee that groundwater can be considered an adequate source. The DEIR
needs to quantify the range of variable groundwater volume and then evaluate the most
conservative scenario to demonstrate quantitatively that water demand will still be
achieved.
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Sincerely,
Matt Hagemann
Lisa Cuellar
7
Comments
on
Air Quality
Draft Environmental Impact Report
TEMECULA REGIONAL HOSPITAL
CITY OF TEMECULA, CALIFORNIA
Prepared by
Petra Pless, D.Env.
Leson & Associates
(415) 492-2131
October 27, 2005
i
Table of Contents
I. THE PROJECT IS INCONSISTENT WITH THE GENERAL PLAN...............2
II. PROJECT DESCRIPTION AND ENVIRONMENTAL SETTING ARE
INADEQUATE ...........................................................................................................3
II.A Project Construction Schedule And Equipment Insufficiently
Described..........................................................................................................3
II.B No Grading Plan Or Cut-And-Fill Analysis ...............................................4
II.C Mechanical Equipment Not Adequately Described..................................4
II.D Insufficient Information To Evaluate Cumulative Impacts......................5
II.E Particulate Matter Ambient Air Quality Standards Not Correctly
Identified ..........................................................................................................6
II.F PM2.5 Emissions Not Analyzed...................................................................7
II.G No Health Risk Assessment Included..........................................................7
III.THE DRAFT EIR IMPROPERLY DEFERS DEVELOPMENT OF
MITIGATION PLANS AND MITIGATION MEASURES ARE NOT
ENFORCEABLE .........................................................................................................8
IV. CONSTRUCTION EMISSIONS ARE UNDERESTIMATED ..........................8
IV.A Incorrect Construction Period Used For Emissions Estimates.................8
IV.B Model Default Values Not Acceptable ......................................................10
IV.C Fugitive Dust Emissions From Wind Erosion And Trackout Not
Included..........................................................................................................10
V. OPERATIONAL EMISSIONS ARE UNDERESTIMATED............................11
V.A Emissions Sources Omitted.........................................................................11
V.B Emissions From Natural Gas Usage Not Included..................................12
V.C Incorrect Target Year Results In Underestimate Of Vehicle
Emissions........................................................................................................12
V.D Traffic Emissions Underestimated .............................................................13
V.E Secondary Emissions From Electricity Generation Not Included.........13
VI. INCREASED OZONE FORMATION DUE TO URBAN HEAT ISLAND
EFFECT IS NOT ANALYZED ...............................................................................14
ii
VII.ADDITIONAL MITIGATION IS FEASIBLE ....................................................14
VII.A Additional Feasible Construction Mitigation...........................................15
VII.A.1 Fugitive Dust Mitigation Measures............................................15
VII.A.2 Diesel Exhaust Mitigation Measures..........................................19
VII.A.2.a CARB-certified Construction Equipment................20
VII.A.2.b Post-combustion Controls..........................................21
VII.A.2.c PuriNOx........................................................................23
VII.B Additional Feasible Operational Mitigation.............................................24
VII.B.1 Operational Traffic Mitigation Measures..................................25
VII.B.2 Operational Area Mitigation Measures.....................................27
VII.B.3 Mitigation For Urban Heat Island Effect...................................29
VII.B.3.a Reduction Of Standard Paving By 20%...................29
VII.B.3.b Use Of Energy Star Roof Products............................30
VIII.CONCLUSION.........................................................................................................33
List of Tables
Table 1: Project Construction Phases...................................................................................9
List of Exhibits
Exhibit 1: URBEMIS2002 Modeling Output for 36-month Construction Period and
Vehicle Emissions Target Year 2009
COMMENTS
The City of Temecula (“City”) as the Lead Agency under the California
Environmental Quality Act (“CEQA”) has prepared a Draft Environmental Impact
Report1 (“Draft EIR”) for the proposed Temecula Regional Hospital (“Project”). The
proposed Project consists of a General Plan amendment, Zone Change,
Development, Plan, Conditional Use Permit (“CUP”), and a Tentative Parcel Map to
allow the development of a proposed regional hospital to serve the City of Temecula
and surrounding area.
The Project includes construction of a 408,160-square foot, 2-tower hospital
complex containing approximately 320 beds, two medical offices totaling
approximately 14,000 square feet, a 10,000-square foot cancer center, an 8,000-square
foot fitness rehabilitation center, and a helipad. Total building area is approximately
566,160 square feet on the 35.51 acre site. Approximately 1,278 parking spaces will
be provided on surface lots. The Project will be constructed in five phases. (Draft EIR
pp. 3-4 through 3-8.)
CEQA has two basic purposes, neither of which this Draft EIR satisfies. First,
CEQA is designed to inform decision makers and the public about the potential,
significant environmental effects of a project before any decisions are made. (14 Cal.
Code Regs. (“CEQA Guidelines”) Section 15002(a)(1).) A Draft EIR is the “heart” of
this requirement. (No Oil, Inc. v. City of Los Angeles (1974) 13 Cal. 3d 68, 84 [118 Cal.
Rptr. 34].) The EIR has been described as “an environmental ‘alarm bell’ whose
purpose it is to alert the public and its responsible officials to environmental changes
before they have reached ecological points of no return.” (County of Inyo v. Yorty
(1973) 32 Cal. App. 3d 795, 810 [108 Cal. Rptr. 377].) To achieve this goal, an EIR
must contain facts and analysis, not merely bare conclusions. (See Citizens of Goleta
Valley v. Board of Supervisors (1990) 52 Cal. 3d 553, 568.)
Second, CEQA directs public agencies to avoid or reduce environmental
damage when possible by requiring alternatives or mitigation measures. (CEQA
Guidelines § 15002(a)(2) and (3). See also Citizens of Goleta Valley v. Board of
Supervisors (1990) 52 Cal. 3d 553, 564 [276 Cal.Rptr. 410, 416]; Laurel Heights
Improvement Ass’n v. Regents of the University of California (1988) 47 Cal. 3d 376, 400
[253 Cal. Rptr. 426, 436]).) CEQA section 21002 requires agencies to adopt feasible
mitigation measures in order to substantially lessen or avoid otherwise significant
1 City of Temecula, Draft Environmental Impact Report, Temecula Regional Hospital,
SCH#2005031017, September 26, 2005.
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adverse environmental impacts of a proposed project. (See Pub.Res.Code §21081(a);
CEQA Guidelines §15370.) To effectuate this requirement, EIRs must set forth
mitigation measures that decision makers can adopt at the findings stage of the
process. (CEQA Guidelines §15126(c).) For each significant effect, the EIR must
identify specific mitigation measures. Where several potential mitigation measures
are available, each should be discussed separately and the reasons for choosing one
over the other should be stated. (CEQA Guidelines §15126(c).) Mitigation measures
should be capable of “avoiding the impact altogether,” “minimizing impacts,”
“rectifying the impact,” or “reducing the impact.” (CEQA Guidelines §15370.) Public
agencies must deny approval of a project with significant adverse effects when
feasible alternatives and mitigation measures can substantially lessen such effects.
(Sierra Club v. Gilroy City Council, 222 Cal. App. 3d 30, 41 (1990).)
The comments below provide an analysis of the Draft EIR’s failure to meet
these requirements of CEQA. The Draft EIR should be revised to address these
issues and be recirculated for public review.
I. THE PROJECT IS INCONSISTENT WITH THE GENERAL PLAN
The Draft EIR finds a number of significant and unavoidable impacts,
necessitating the adoption of a Statement of Overriding Considerations (“SoC”)
should the City certify the Final EIR and approve the proposed Project. (Draft EIR,
p. 1-7.) The City of Temecula’s General Plan requires that “air quality impacts
associated with development projects [be] mitigated to the greatest extent feasible.”
(General Plan, p. AQ-10, Policy 2.4, emphasis added.) Specifically, the General Plan
requires that the City “[a]pprove development that could significantly impact air
quality, either individually or cumulatively, only if it is conditioned with all
reasonable mitigation measures to avoid, minimize, or offset the impact.” (General
Plan2, p. AQ-13, emphasis added.) As discussed in Comment VII, the Draft EIR fails
to incorporate all mitigation measures recommended by the General Plan to reduce
adverse effects on air quality. In addition, as discussed in Comments VII.A and
VII.B, numerous other feasible and reasonable mitigation exist that could reduce the
Project’s significant impacts on air quality. Therefore, the Draft EIR is inconsistent
with the General Plan.
2 City of Temecula, General Plan, adopted April 2005.
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II. PROJECT DESCRIPTION AND ENVIRONMENTAL SETTING ARE
INADEQUATE
An accurate and complete Project description is the heart of an EIR and is
necessary for an intelligent evaluation of the potential environmental impacts of a
project. As explained in the discussion following Section 15124 of the CEQA
Guidelines,3 an EIR must describe the proposed project “in a way that will be
meaningful to the public, to the other reviewing agencies, and to the decision-
makers…” The state court of appeal declared that “[a]n accurate, stable and finite
project description is the sine qua non of an informative and legally adequate EIR.”
(County of Inyo v. City of Los Angeles (1977) 71 Cal. App. 3d 185, 192 [139 Cal. Rptr.
396, 401].) In contrast, “[a] curtailed, enigmatic or unstable project description draws
a red herring across the path of public input.” (Id., at 197–98;see also, CEQA §15124;
City of Santee v. County of San Diego, 263 Cal. Rptr. 340 (1989).) As one analyst has
noted:
The adequacy of an EIR’s project description is closely linked to the adequacy
of the EIR’s analysis of the project’s environmental effects. If the description is
inadequate because it fails to discuss the complete project, the environmental
analysis will probably reflect the same mistake. (Kostka and Zischke,
“Practice Under the California Environmental Quality Act,” p. 474 (8/99
update).)
As discussed in the following comments, the DEIR fails to describe the Project
and its environmental setting accurately and completely. It omits key project
features that have the potential to result in significant impacts. As a result,
potentially significant environmental impacts were not adequately analyzed or
addressed by the Draft EIR. Therefore, the Draft EIR is fatally deficient under
CEQA.
II.A Project Construction Schedule And Equipment Insufficiently Described
The Draft EIR fails to include a detailed construction schedule with the list of
equipment that will be used, the horsepower of each piece of equipment, the hours
of operation, the type of fuel used, the length and timing of the individual
construction phases, and so forth. Further, the Draft EIR contains no information
regarding the expected timing of completion of each of the major project phases as
well as the buildout horizon for the entire Project. This information is typically
provided in an EIR but was not. Without this information, emissions resulting from
3 California Code of Regulations, Title 14, Secs. 15000 et seq. (“CEQA Guidelines”).
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construction cannot be accurately estimated. As discussed in Comment IV.B, the
Draft EIR uses mostly default assumptions to model construction emissions, which
may considerably underestimate emissions.
II.B No Grading Plan Or Cut-And-Fill Analysis
The Initial Study for the Project finds no significant impacts with respect to
geology and soils, relying on a geotechnical investigation conducted for the Project.
The Initial Study fails to include this study for public review. According to the Initial
Study, the geotechnical investigation recommends over-excavation up to 24inches
below existing grade and recompaction for support of building slabs and pavement.
(Appx. A, NOP/Initial Study, p. 16 through 18.) Yet, neither the Draft EIR nor the
Initial Study contains a grading plan or any other information regarding the amount
of cut and fill necessary for development of the site or the projected amount and
location of spoils, if any. Review of the Draft EIR’s emissions modeling suggests that
only some minor amount of material will have to be im/exported4. This suggests
that the Draft EIR largely relies on balancing the amount of cut and fill of native soil
on site with no additional import of fill material or export of excess cut material. Yet
neither the Initial Study nor the Draft EIR contains any information demonstrating
that cut and fill can, in fact, be balanced on site. This information is typically derived
from a grading plan, which would ordinarily be provided in an EIR but was not. If
cut and fill can not be balanced on site, material would have to be imported or
exported, which causes additional emissions.
II.C Mechanical Equipment Not Adequately Described
The Project requires a variety of mechanical equipment including heating and
air conditioning equipment, emergency generators, boilers, and so forth. None of
this equipment is described with any detail in the Draft EIR. Draft EIR provides only
the following vague statement: “A truck loading area and facilities plant will be
located at the eastern edge of the hospital, south of the helipad. This area provides
infrastructure needed to support the hospital, such as a loading dock, cooling tower,
generators, transformers, a fuel tank, and a bulk oxygen storage area.” (Draft EIR,
p. 3-4.) Review of the Project site plan indicates three cooling towers, two emergency
generators, two transformers, and a fuel tank located in the mechanical yard. (Draft
EIR, p. 3-5, Figure 3-2.) The Draft EIR’s noise impact analysis further indicates that
4 URBEMIS2002 modeling assumes 18 vehicle miles traveled (“VMT”) for on-road truck travel during
the grading phase, suggesting a minimal im/export of materials, approximately 2500 cubic yards
based on the program’s default values. This small amount of material is most likely export of existing
pavements, utilities, and other deleterious material that has to be removed from the site.
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the mechanical equipment room, which is proposed to be located inside the Phase IB
hospital building, adjacent to the mechanical yard, will contain pumps, chillers, and
boilers. Air conditioning and refrigeration units and their associated inlet and outlet
exhaust systems will be located on the hospital’s rooftop. (Draft EIR, p. 4-63.)
This limited information, scattered over several chapters of the Draft EIR, is
entirely inadequate to determine emissions and resulting environmental impacts
from operation of the mechanical equipment. A complete and accurate project
description must include the fuel, firing rate, and number of boilers; the capacity for
the two emergency generators; the type and efficiency of the proposed pollution
control equipment; the circulating water flow and total dissolved solids (“TDS”)
content of the cooling water; the drift rate of the cooling towers; and the information
required to model these sources, e.g., stack location, height, diameter, exhaust gas
flow rate, temperature, and so forth. Without knowledge of these characteristics, it is
impossible to determine emissions from this equipment and, in fact, they were not
included in the operational emissions estimates for the Project. (See Comment V.A.)
II.D Insufficient Information To Evaluate Cumulative Impacts
Section 15130(a) of the CEQA Guidelines requires a discussion of cumulative
impacts of a project “… when a project’s incremental effect is cumulatively
considerable.” The Draft EIR finds significant and unavoidable impacts of the
Project on air quality and, thus, also significant and unavoidable cumulative
impacts. The Draft EIR evaluates impacts “based primarily on 21 related projects
identified by the City of Temecula.” For a description of 17 of these projects, the
Draft EIR relies on a 2002 traffic impact analysis for another project, the Apis Plaza.
Rather than providing a summary of these projects in the cumulative impacts
analysis section, the Draft EIR refers the reviewer to the traffic impact analysis
contained in Appendix D for further information. Yet Appendix D does not contain
any information beyond the name and proposed uses of these projects and their
projected trip generation; it claims that the Apis Plaza Traffic Impact Analysis is
contained in its Appendix E, but the Initial Study failed to include this document.
Further, the Draft EIR claims that fouradditional projects were supplemented, yet it
fails to supply any information on these projects. (Draft EIR, p. 6-1 and Appx. D,
p. 9.) The Draft EIR contains no information for any of these 21 projects, for example
the time period over which they will be constructed, their expected buildout, or the
air quality impacts resulting from their construction or operation. In short, the
information provided in the Draft EIR is entirely inadequate to assess the
cumulative impacts on air quality resulting from the Project.
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II.E Particulate Matter Ambient Air Quality Standards Not Correctly Identified
Particulate matter is emitted from two sources, engine exhaust and fugitive
dust. The health impacts of particulate matter depend on its size, and the size
depends on its source. Combustion sources, such as vehicle exhaust, predominantly
emit particulate matter with an aerodynamic diameter of less than or equal to
2.5 micrometers (“PM2.5”), while fugitive dust consists predominantly of particulate
matter less than 10 micrometers (“PM10”).
Historically, health impacts due to particulate matter were regulated through
ambient air quality standards for PM10. However, a substantial amount of
important new research has been published, documenting new health impacts at
much lower concentrations and for different size fractions of particulate matter than
was previously known and reflected in ambient air quality standards. (U.S. EPA
04/96;5 U.S. EPA 03/01.6)
This new research documents that the inhalation of particulate matter,
particularly the smallest particles, causes a variety of health effects, including
premature mortality, aggravation of respiratory (e.g., cough, shortness of breath,
wheezing, bronchitis, asthma attacks) and cardiovascular disease, declines in lung
function, changes to lung tissues and structure, altered respiratory defense
mechanisms, and cancer, among others. (U.S. EPA 04/96; 61 FR 65638.7) A recent
article linked long-term exposure to combustion-related fine particulate air pollution
to cardiopulmonary and lung cancer mortality.8 Particulate matter is a
non-threshold pollutant, which means that there is some possibility of an adverse
health impact at any concentration. (See American Trucking v. EPA: Unjustified
Revival of the Nondelegation Doctrine, 23-SPG Environs Envtl. L & Pol’y J. 17, 26.)
This new information led the U.S. Environmental Protection Agency (“U.S.
EPA”) and the State of California to propose new ambient air quality standards for
PM2.5. These standards are not subsets of the old PM10 standards, but new
standards for a separate pollutant with distinguishable impacts. The new annual
5 U.S. Environmental Protection Agency, Air Quality Criteria for Particulate Matter, Report
EPA/600/P-95-001aF through 001cF, April 1996.
6 U.S. Environmental Protection Agency, Air Quality Criteria for Particulate Matter, Second External
Review Draft, March 2001.
7 National Ambient Air Quality Standards for Particulate Matter: Proposed Decision, Federal
Register, v. 61, no. 241, December 13, 1996, pp. 65638-65675.
8 A.A. Pope et al., Lung Cancer, Cardiopulmonary Mortality, and Long-term Exposure to Fine
Particulate Air Pollution, Journal of the American Medical Association, v. 287, no. 9, pp.1132-1141.
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PM2.5 standard of 12 µg/m3was adopted by the California Air Resources Board
(“CARB”) on June 20, 2002 and became effective on June 5, 2003, more than two
years before the Draft EIR was published. (Voting on the proposed 24-hour-average
PM2.5 standard of 25 µg/m3 has been deferred by CARB.9) At the same time,
California lowered its annual PM10 standard from 30 µg/m2 to 20 µg/m3. (CARB
09/0510.) The Draft EIR also failed to acknowledge this new, lower standard for
PM10. (Draft EIR, Table 4-1.) Consequently, the Draft EIR failed to accurately
characterize the regulatory setting for the Project.
II.F PM2.5 Emissions Not Analyzed
The Draft EIR does not include an analysis of the Project’s impacts on
ambient air quality resulting from PM2.5 emissions. This is a significant and
inexcusable omission because the South Coast Air Basin (“SoCAB”), where the
Project is located, frequently does not meet the federal or State ambient air quality
standards for PM2.5. The Draft EIR should be revised to include an analysis of
PM2.5 emissions from Project construction and operation and resulting impacts on
air quality and human health.
II.G No Health Risk Assessment Included
The Draft EIR identifies several sensitive receptors in the vicinity of the
Project including residential developments surrounding the site; nine primary
schools, two middle schools, and three high schools within two miles of the Project
site; and two parks within two miles of the Project site. (Draft EIR, p. 4-21.) Yet the
Draft EIR contains no health risk assessment analyzing the potential health risks for
these sensitive receptors resulting from Project construction or operational
emissions. Potentially adverse health impacts likely result from toxic air
contaminant emissions, including PM2.5, from diesel combustion engines such as
emissions from operation of the emergency generators and the diesel trucks that
access the loading dock. The Draft EIR should be revised to include a health risk
assessment.
9 California Air Resources Board (CARB) and Office of Environmental Health Hazard Assessment
(OEHHA), Draft Proposal to Establish a 24-hour Standard for PM2.5, Public Review Draft, March 12,
2002.
10 California Air Resources Board, Review of the Ambient Air Quality Standards for Particulate
Matter and Sulfates, http://www.arb.ca.gov/research/aaqs/std-rs/std-rs.htm, accessed
October 26,2005.
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III.THE DRAFT EIR IMPROPERLY DEFERS DEVELOPMENT OF
MITIGATION PLANS AND MITIGATION MEASURES ARE NOT
ENFORCEABLE
CEQA generally requires that all mitigation measures be adopted
simultaneously with, or prior to, project approval (State CEQA Guidelines Section
15192). An agency may defer preparation of a plan for mitigation only when the
agency commits itself to satisfying specified performance standards that will ensure
the avoidance of any significant effect from implementation of its mitigation
measures. Here, the Draft EIR improperly defers the development of most of its
mitigation plans into the future without specifying any performance measures,
including:
? Location of the staging area for construction (AQ-1);
? Transportation Demand Management Plan (AQ-2;
? Landscape Plan (AQ-4);
? Watering Program (AQ-6); and
? Fugitive Dust Control Program (AQ-7).
Further, several of the mitigation measures (e.g., temporary landscaping,
clean-fueled vehicles, construction equipment energy efficiency) required by the
Draft EIR are worded ambiguously, e.g., “may require,” “when feasible,” or
“reasonably possible,” which renders them unenforceable as a practical matter.
(Draft EIR, p. 4-26 to 4-29.) The Draft EIR must specify specific performance
measures and reasons for rejection of these measures if found not feasible or
appropriate.
IV. CONSTRUCTION EMISSIONS ARE UNDERESTIMATED
The Draft EIR finds significant impacts after implementation of its proposed
mitigation measures for ROG and NOx. As discussed below, the Draft EIR’s air
quality analysis considerably underestimates emissions from construction activities
and thereby fails to adequately disclose impacts on air quality from Project
construction. If these problems are corrected, emissions of CO and PM10 will likely
also exceed applicable significance thresholds.
IV.A Incorrect Construction Period Used For Emissions Estimates
The Draft EIR indicates that construction of the Project will occur in five
phases as summarized in Table 1. (Draft EIR, pp. 3-7 and 3-8.)
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Table 1: Project Construction Phases
Phase Activity Period
IA ? Grading
? Demolition of existing buildings
? Construction of 3-story, 60,000-square foot medical office
building
? Construction of surface parking
10 months
IB ? Construction of 1-story, 162,650-square foot main hospital
structure
? Construction of 6-story,122,755-square foot bed tower
? Construction of associated parking
14 months
II ? Construction of 5-story, 122,755-square foot bed tower
III ? Construction of 4-story, 80,000-square foot medical office
building
? Construction of hospital connector
IV ? Construction of 1-story, 10,000-square foot cancer center
? Construction of associated parking
V ? Construction of 8,000 square foot fitness center
? Construction of jogging trail
12 months
(II-V concurrent)
Total 36 months
Construction of all phases is projected to last a maximum of 36 months if the
proposed construction phases (IA, IB, and II-V) are conducted subsequently. In
contrast, the Draft EIR’s construction emissions estimates were based on a 60-month
construction period, starting in January 2006 and terminating in December 2010.
(Draft EIR, p. 4-24, Footnote to Table 4-5 and Appx. B, p. 2.) By stretching
construction emissions over a period of 60 months rather than the actual proposed
36-month construction period, the Draft EIR considerably underestimates maximum
daily emissions and, thus, considerably underestimates air quality impacts from
Project construction. In fact, construction of the Project could even be shorter than
36 months because nothing in the Draft EIR’s language restricts the Applicant to the
staggered construction phasing. (See Comment II.A.) If more than the specified
construction phases would be conducted concurrently, even greater emissions
would occur.
I ran the URBEMIS2002 model assuming a construction buildout of
36 months and otherwise accepting all of the Draft EIR’s assumptions. Results are
included in Exhibit 1. Maximum daily ROG emissions increase considerably from
224 lb/day to 344 lb/day. Therefore, the Draft EIR failed to disclose the magnitude
of impacts associated with Project construction. The Draft EIR should be revised to
include a construction schedule showing the projected start of the various
construction phases and their expected buildout. The Draft EIR’s air quality analysis
must be corrected accordingly.
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IV.B Model Default Values Not Acceptable
The Draft EIR’s construction emissions estimates largely assume
URBEMIS2002 default values, which may substantially underestimate the Project’s
real emissions. For example, the Draft EIR assumes the default factor for average
fugitive dust emissions from grading of 0.11 ton/acre-month. By accepting the
default value for average conditions, the Draft EIR fails to evaluate the potential
worst case, as is customary for CEQA analyses. The default factor for worst-case
condition is 0.42 ton/acre-month. (URBEMIS 04/0511, p. A-7.) Therefore, the Draft
EIR may have underestimated potential worst-case conditions during grading of the
Project by a factor of almost four. Further, use of this default value is only suggested
when no other information is available the area and duration of grading are known.
Typically, for a Project of this size, the amount of cut/fill would also be known. (See
Comment II.B.)
Another example is the assumption of only 8 hours of construction per day.
This assumption directly conflicts with the Draft EIR’s statement that “construction
activity will occur only between 6:30 A.M. and 6:30 P.M., Monday through Friday
and 7:00 A.M. and 6:30 P.M. on Saturday. (Draft EIR, p.4-53). Although the DEIR
makes this statement, it should be noted that the document contains no enforceable
restrictions on the hours of construction per day and, thus, construction may be
conducted for more than the 8 hours per day assumed in the air quality section and
more than the 12 hours per day claimed in the noise section of the document. An
increase of hours of operation from 8 to 12 hours per day or more would
considerably increase the potential daily emissions from the Project. The Draft EIR
must either contain an enforceable mitigation measure limiting the permissible
hours of construction to the assumed 8 hours per day or it must adjust its emissions
estimates accordingly.
IV.C Fugitive Dust Emissions From Wind Erosion And Trackout Not Included
The Draft EIR indicates that grading of the entire 35.31-acre site will occur
during Phase IA, exposing those portions of the site, which will be developed in
later phases (Phase IB through V) to wind erosion for an extended period of time.
(Draft EIR, p. 3-7.) The URBEMIS2002 emissions modeling used by the Draft EIR to
estimate Project construction emissions includes fugitive dust emissions associated
11 Software User’s Guide: URBEMIS 2002 for Windows with Enhanced Construction Module, April
2005.
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with grading but does not account for wind erosion12, which can be a substantial
contributor to fugitive dust from construction sites, particularly in summer-dry
climates such as the SoCAB. Further, the URBEMIS2002 emissions modeling does
not account for mud/dirt trackout from the site. Consequently, the Draft EIR does
not disclose the full impact of fugitive dust PM10 emissions from Project
construction. Fugitive dust emissions due to wind erosion and trackout can be
calculated using guidance developed by the U.S. Environmental Protection Agency
(“U.S. EPA”). (AP-42, Sec. 13.2.513; EPA 450/3-88-00814.)
V. OPERATIONAL EMISSIONS ARE UNDERESTIMATED
The Draft EIR’s air quality impact analysis considerably underestimates
operational emissions from the Project because it omits emission sources, uses
inadequate trip generation rates, and fails to include secondary emissions from
electricity generation. The Draft EIR finds total operational NOx emissions of
94.5 lb/day, only 5.5lb/day below the SCAQMD’s significance threshold of
100 lb/day. This NOx significance threshold will likely be exceeded when taking
into account the omitted emission sources, adequate trip generation rates, and
secondary emissions from the Project. Similarly, PM10 emissions, currently
estimated at 123 lb/day, may exceed the SCAQMD’s significance threshold of
150 lb/day. As a result, the Draft EIR fails to disclose and adequately mitigate
significant impacts due to operational emissions of PM10 and NOx. The Draft EIR
should be revised to address these issues and be recirculated for public review.
V.A Emissions Sources Omitted
The Draft EIR’s air quality impact analysis is based on emissions calculated
with the URBEMIS2002 model. The model calculates area source emissions from
traffic generated by the Project and emissions from natural gas usage, hearths,
landscaping, consumer products, and architectural coatings and operational traffic
12 The URBEMIS2002 fugitive dust emissions estimates are based on a methodology developed for the
SCAQMD by the Midwest Research Institute (“MRI”). (URBEMIS 04/05, p. A-6.) The MRI study
specifically notes that the emission factors for fugitive dust emissions from construction activities do
not include wind erosion or mud/dirt trackout from the site. (MRI, Improvement of Specific Emission
Factors, BACM Project No.1, Final Report, March 29, 1996, p. 4-1.)
13 Compilation of Air Pollutant Emission Factors, Volume 1: Stationary Point and Area Sources,
Section 13.2.5, Industrial Wind Erosion, January 1995, corrected on April 13, 2001.
14 C. Cowherd, G.E. Muleski, and J.S. Kinsey, Control of Open Fugitive Dust Sources,EPA 450/3-88-
008, U.S. Environmental Protection Agency, Research Triangle Park, NC, September 1988.
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emissions. The model does not include emissions from the helicopter, the three
cooling towers, the two emergency generators, and the boilers.
The Initial Study concludes that “[a]rea source emissions such as heaters, air
condition units and other machines are not considered significant generator [sic] of
emissions.” (NOP/Initial Study, p. 7.) This conclusion is unsupported in the text of
the Draft EIR and appears to be speculation. Even if emissions from these sources
were individually small, they may be cumulatively considerable and must therefore
be included in the Project’s emissions analysis.
The combined emissions from the helicopter, the diesel generators, and the
boilers, even if small, may result in exceedance of the NOx significance threshold.
For example, typical NOx emissions for commercial light twin-engine helicopters15
are about 4.0 lb per landing and takeoff (“LTO”), bringing total NOx emissions from
the Project within one pound per day of the significance threshold. (OCS 10/0416,
p. 6-17.)
V.B Emissions From Natural Gas Usage Not Included
The URBEMIS2002 model assigns gas usage rates to different land uses,
e.g., residences, industrial, hotel/motel, and office, to calculate area source emissions
from the use of gas-fired boilers, furnaces, hearths, etc. The model does not calculate
emissions associated with natural gas usage at hospitals. The Project operates a
number of, presumably natural-gas fired, equipment, including the boilers and
heating/air conditioning equipment. Emissions from this equipment, which are
likely considerable, are not included in the Draft EIR’s area emissions estimates for
Project operations presented in Table 4-6.
V.C Incorrect Target Year Results In Underestimate Of Vehicle Emissions
The Draft EIR assumes 2010 as the target year for operational traffic
emissions. As discussed in Comment IV.A, construction is assumed to start in
January 2006 with a 36 month construction period. Therefore, the target year for
15 The noise analysis stated that the exact model of helicopter to be used at the hospital has not been
confirmed but that the Bell 222 has been identified as a model that could potentially be used. The
Bell 222, a frequently used helicopter model for emergency transports, is a commercial light twin-
engine helicopter.
16 R. Billings and D. Wilson, Data Quality Control and Emissions Inventories of OCS Oil and Gas
Production Activities in the Breton Area of the Gulf of Mexico, Final Report, U.S. Department of the
Interior, Minerals Management Service, Gulf of Mexico OCS Region, MMS 2004-071, October 2004.
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operational emissions should be 2009, not 2010. Because vehicular emissions are
assumed to decrease with every year, the calculated operational emissions for 2010
underestimate actual emissions at Project buildout, i.e. in 2009.
I ran URBEMIS2002 for target year 2009 and otherwise assuming all of the
Draft EIR’s assumptions. Results are included as Exhibit 1. Emissions of ROG, NOx,
and CO in 2009 are about 10% higher than for target year 2010. This results in NOx
emissions exceeding the SCAQMD’s quantitative daily significance threshold. This
is a significant impact that was not disclosed in the Draft EIR.
V.D Traffic Emissions Underestimated
The Draft EIR’s URBEMIS2002 air quality analysis uses default trip lengths to
estimate emissions from Project-related traffic. These default trip lengths do not
apply to traffic associated with a regional hospital. Trips associated with a regional
hospital are typically longer and hence traffic emissions attributable to the Project
are higher. In addition, an independent review of the Draft EIR’s traffic analysis
found a considerable underestimate of traffic generated by the Project, which is not
reflected in the URBEMIS2002 default assumptions for traffic. (See Brohard 10/0517.)
Consequently, emissions associated with Project traffic are also underestimated. The
Draft EIR’s emissions estimates for Project traffic must be modified to reflect the
Project’s actual traffic characteristics.
V.E Secondary Emissions From Electricity Generation Not Included
CEQA requires that an EIR identify direct and indirect significant effects of
the project on the environment. (CEQA Guidelines Section 15126.2(a).) The Project
will require a substantial amount of electricity, which generates so-called indirect or
secondary emissions. The Draft EIR mentions that air pollutant emissions will be
generated due to the consumption of electricity and states that these regional
emissions were calculated using emission factors from the SCAQMD’s CEQA Air
Quality Handbook. (Draft EIR, p. 4-24.) Yet the Draft EIR fails to account for these
emissions in its presentation of regional emissions associated with the operational
phase of the Project. (Draft EIR, p. 4-25, Table 4-6.)
A considerable share of the electricity delivered to the SoCAB is generated by
coal-fired power plants, which generate substantial particulate matter and SO2
17 Tom Brohard, Brohard and Associates, Letter to Gloria Smith, Adams, Broadwell, Joseph &
Cardozo, Re: Review of Traffic Portions of the Temecula Regional Hospital Project Focused
Environmental Impact Report in the City of Temecula, October 26, 2005.
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emissions. The Draft EIR should be revised to include emissions from electricity
generation.
VI. INCREASED OZONE FORMATION DUE TO URBAN HEAT ISLAND
EFFECT IS NOT ANALYZED
The Project would develop 35.31 acres of largely open grass-covered land.
The Draft EIR states that lot coverage will consist of approximately 16 percent
building area, 30 percent parking area, and 33 percent landscape areas.18 (Draft EIR,
pp. 3-3 and 3-7.) The Project would add several buildings, parking lots, roads, and
roofs, thus increasing the amount of existing blacktop. Black surfaces absorb about
85% to 95% of the sunlight that falls on them, becoming one of the hottest surfaces in
urban areas. The hot surfaces of pavement and similarly dark roofs quickly warm
the air over urban areas, leading to the creation of summer urban “heat islands.” On
a clear summer afternoon, the air temperature in urban areas can be 2F to 9 F hotter
than the surrounding rural area. The elevated temperature increases cooling energy
demand, accelerates the rate of smog production, and increases evaporative losses of
organic compounds from gasoline tanks of vehicles parked over the hot surfaces.
Conversion of open, grass-covered land to build-out areas would increase
local ambient temperatures, thereby contributing to the urban heat island effect and
increasing the local formation of ozone. Thus, the urban heat island affect would
exacerbate existing exceedances of the ozone standards in the Project vicinity. The
SoCAB is not in compliance with either federal or State ozone standards. Thus, the
Project would directly contribute to existing exceedances of the federal and State
ozone standards, which is a significant impact.(See Kings County Farm Bureau v. City
of Hanford (1990) 221 Cal.App.3d 692 [270 Cal.Rptr. 650].) This is a significant impact
that was not discussed in the Draft EIR and is feasible to mitigate as discussed in
Comment VII.B.3.
VII.ADDITIONAL MITIGATION IS FEASIBLE
CEQA section 21002 requires agencies to adopt feasible mitigation measures
in order to substantially lessen or avoid otherwise significant adverse environmental
impacts of a proposed project. (See Pub. Res. Code §21081(a); CEQA Guidelines
§15370.) To implement this requirement, an EIR must set forth mitigation measures
that decisionmakers can adopt at the findings stage of the process. (CEQA
Guidelines §15126(c).) For each significant effect, the EIR must identify specific
18 The Site Plan provided in the Draft EIR suggests a considerably larger percentage of buildings and
parking spaces and lower percentage of landscaped areas. (Draft EIR, p. 3-5, Figure 3-2.)
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mitigation measures. Where several potential mitigation measures are available,
each should be discussed separately and the reasons for choosing one over the other
should be stated. (CEQA Guidelines §15126(c).) Mitigation measures should be
capable of “avoiding the impact altogether,” “minimizing impacts,” “rectifying the
impact,” or “reducing the impact.” (CEQA Guidelines §15370.)
By the Draft EIR’s own admission of “significant unavoidable impacts” and
as demonstrated in the comments above, impacts from construction and operation
of the Project remain significant after implementation of the Draft EIR’s proposed
mitigation measures. Therefore, the City must impose all feasible mitigation to
mitigate these significant impacts, which it did not. The comments below discuss the
specific inadequacies of the Draft EIR’s proposed mitigation program and propose
mitigation measures that should be implemented to lessen or eliminate the
significant adverse effects of Project construction and operation.
VII.A Additional Feasible Construction Mitigation
The Draft EIR finds significant and unavoidable NOx emissions from the
Project. (Draft EIR, p. 4-29.) As discussed in Comment IV, construction emissions are
considerably underestimated, likely resulting in significant and unmitigated ROG,
CO, and PM10 emissions beyond what is reported by the Draft EIR. As discussed
below, there are numerous other relevant and reasonable fugitive dust and diesel
exhaust mitigation measures contained in the CEQA guidelines and rules of air
districts and other agencies that should also be required for this Project to mitigate
its significant construction impacts.
VII.A.1 Fugitive Dust Mitigation Measures
Several agencies have conducted comprehensive studies of fugitive dust
control measures to bring their region into compliance with national ambient air
quality standards on PM10. For example, the South Coast Air Quality Management
District (“SCAQMD”) has sponsored research, passed regulations (e.g., Rule 40319),
and published guidelines that identify best management practices for controlling
fugitive dusts at construction sites. The Rule 403 Implementation Handbook20 contains a
comprehensive list of such measures, which should be incorporated into the
Project’s Fugitive Dust Control Plan. (See Draft EIR, p. 4-27, Mitigation Measure
19 South Coast Air Quality Management District, Revised Final Staff Report for Proposed Amended
Rule 403, Fugitive Dust and Proposed Rule 1186, PM10 Emissions from Paved and Unpaved Roads,
and Livestock Operations, February 14, 1997.
20 South Coast Air Quality Management District, Rule 403 Implementation Handbook, January 1999.
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AQ-7.) Clark County, Nevada, has also sponsored research, passed regulations
(Rule 94), and published best management practices for controlling fugitive dust
from construction activities.21 Clark County’s Construction Activities Dust Control
Handbook contains a comprehensive list of best management practices.22 Similarly,
Arizona has developed guidance to control fugitive PM10 emissions.23
Several of the measures included in these agency guidelines are feasible and
therefore should be considered for adoption here under CEQA Guidelines
§§15126.4, 15091. Examples of such feasible mitigation measures are listed below:
? During clearing and grubbing, prewet surface soils where equipment will
be operated; for areas without continuing construction, maintain live
perennial vegetation and desert pavement; stabilize surface soil with dust
palliative unless immediate construction is to continue; and use water or
dust palliative to form crust on soil immediately following
clearing/grubbing. (CCHD)
? Grade each phase separately, timed to coincide with construction phase or
grade entire project, but apply chemical stabilizers or ground cover to
graded areas where construction phase begins more than 60 days after
grading phase ends. (Rule 403 Handbook)
? During initial grading, earth moving, or site preparation, projects 5 acres
or greater may be required to construct a paved (or dust palliative treated)
apron, at least 100 ft in length, onto the project site from the adjacent site if
applicable. (BCAQMD)
? During cut and fill activities, prewater with sprinklers or wobblers to
allow time for penetration; prewater with water trucks or water pulls to
allow time for penetration; dig a test hole to depth of cut to determine if
soils are moist at depth and continue to prewater if not moist to depth of
cut; use water truck/pull to water soils to depth of cut prior to subsequent
cuts; and apply water or dust palliative to form crust on soil following fill
and compaction. (CCHD)
21 P.M. Fransioli, PM10 Emissions Control Research Sponsored by Clark County, Nevada,
Proceedings of the Air &Waste Management Association’s 94th Annual Conference & Exhibition,
Orlando, FL, June 24-28, 2001.
22 Clark County Department of Air Quality Management, Construction Activities Dust Control
Handbook, March 18, 2003.
23 Arizona Department of Environmental Quality, Air Quality Exceptional and Natural Events Policy
PM10 Best Available Control Measures, June 5, 2001.
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? For backfilling during earthmoving operations, water backfill material or
apply dust palliative to maintain material moisture or to form crust when
not actively handling; cover or enclose backfill material when not actively
handling; mix backfill soil with water prior to moving; dedicate water
truck or large hose to backfilling equipment and apply water as needed;
water to form crust on soil immediately following backfilling; and empty
loader bucket slowly; minimize drop height from loader bucket. (CCHD)24
? For large tracts of disturbed land, prevent access by fencing, ditches,
vegetation, berms, or other barriers; install perimeter wind barriers 3 to
5 feet high with low porosity; plant perimeter vegetation early; and for
long-term stabilization, stabilize disturbed soil with dust palliative or
vegetation or pave or apply surface rock. (CCHD)
? Barriers with 50 percent or less porosity located adjacent to roadways to
reduce windblown material leaving a site. (Rule 403 Handbook)
? In staging areas, limit size of area; apply water to surface soils where
support equipment and vehicles are operated; limit vehicle speeds to
15 mph; and limit ingress and egress points. (CCHD)
? Following the addition of materials to, or the removal of materials from,
the surface of outdoor storage piles, said piles shall be effectively
stabilized of fugitive dust emissions utilizing sufficient water or chemical
stabilizer/suppressant. (SJVUAPCD, ADEQ)
? For stockpiles, maintain at optimum moisture content; remove material
from downwind side; avoid steep sides or faces; and stabilize material
following stockpile-related activity. (CCHD)
? When materials are transported off-site, all material shall be covered,
effectively wetted to limit visible dust emissions, or at least six inches of
freeboard space from the top of the container shall be maintained.
(BAAQMD, SJVUAPCD, Rule 403 Handbook, ADEQ, SLOCAPCD)
? Where feasible, use bedliners in bottom-dumping haul vehicles. (Rule 403
Handbook)
? Empty loader bucket slowly and minimize drop height from loader
bucket. (CCHD)
24 The following acronyms are used in this listing of mitigation measures: ADEQ = Arizona
Department of Environmental Quality; BAAQMD = Bay Area Air Quality Management District;
BCAQMD = Butte County Air Quality Management District; CCHD = Clark County (Nevada) Health
District; MBUAPCD = Monterey Bay Unified Air Pollution Control District; SBCAPCD = Santa
Barbara County Air Pollution Control District; SJVUAPCD = San Joaquin Valley Unified Air
Pollution Control District; SLOCAPCD = San Luis Obispo County Air Pollution Control District.
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? Clean wheels and undercarriage of haul trucks prior to leaving
construction site. (CCHD)
? Gravel pads must be installed at all access points to prevent tracking of
mud on to public roads. (SBCAPCD)
? Install and maintain trackout control devices in effective condition at all
access points where paved and unpaved access or travel routes intersect.
(CCHD)
? All roadways, driveways, sidewalks, etc., to be paved should be
completed as soon as possible. In addition, building pads should be laid
as soon as possible after grading unless seeding or soil binders are used.
(SLOCAPCD)
? Pave all roads on construction sites. (MBUAPCD)
? To prevent trackout, pave construction roadways as early as possible;
install gravel pads; install wheel shakers or wheel washers, and limit site
access. (CCHD, SLOCAPCD)
? While clearing forms, use single stage pours where allowed; use water
spray to clear forms; use sweeping and water spray to clear forms; use
industrial shop vacuum to clear forms; and avoid use of high pressure air
to blow soil and debris from the form. (CCHD)
? Limit fugitive dust sources to 20 percent opacity. (ADEQ)
? Require a dust control plan for earthmoving operations. (ADEQ)
? Prior to land use clearance, the applicant shall include, as a note on a
separate informational sheet to be recorded with map, these dust control
requirements. All requirements shall be shown on grading and building
plans. (SBCAPCD, SLOCAPCD)
? The contractor or builder shall designate a person or persons to monitor
the dust control program and to order increased watering, as necessary, to
prevent transport of dust offsite. (SBCAPCD, SLOCAPCD)
? Post a publicly visible sign with the telephone number and person to
contact regarding dust complaints. This person shall respond and take
corrective action within 24 hrs. (BCAQMD, CCHD)
While portions of some of these measures are included in the mitigation
measures imposed by the Draft EIR, the above measures are far more protective and
should all be required in the Project’s Fugitive Dust Control Plan. All of these
measures are feasible and various combinations of them are routinely required
elsewhere to reduce fugitive PM10 emissions. See, for example, the fugitive dust
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control program for the Big Dig (Kasprak and Stakutis 200025), for the El Toro Reuse
Draft EIR 26, and for the Padres Ballpark Final EIR27.
VII.A.2 Diesel Exhaust Mitigation Measures
There are a number of additional mitigation measures that are routinely
required as CEQA mitigation by air districts and other agencies in California for
construction projects, (e.g., the mitigation programs routinely implemented by the
SMAQMD and California Energy Commission (“CEC”) decisions), including:
? Limiting the hours of operation of heavy duty equipment and/or the
amount of equipment in use. (BAAQMD 12/99, p. 53.)
? Conversion to cleaner engines;
? Use of cleaner (reduced sulfur) fuel;
? Add-on control devices, e.g., particulate traps, catalytic oxidizers;
? Buffer zone between facility and sensitive receptors;
? Installation of high pressure injectors on diesel construction equipment;
? Restricting engine size of construction equipment to the minimum
practical size;
? Electrification of construction equipment;
? Substitution of gasoline-powered for diesel-powered construction
equipment;
? Use of alternatively fueled construction equipment, using, e.g.,
compressed natural gas, liquefied natural gas, propane, or biodiesel;
? Implementation of activity management techniques including
a) development of a comprehensive construction management plan
25 A. Kasprak and P.A. Stakutis, A Comprehensive Air Quality Control Program for a Large Roadway
Tunnel Project, Proceedings of the Air & Waste Management Association’s 93rd Annual Conference,
June 18-22, 2000.
26 County of Orange, Draft Environmental Impact Report No. 573 for the Civilian Reuse of MCAS El
Toro and the Airport System Master Plan for John Wayne Airport and Proposed Orange County
International Airport, Draft Supplemental Analysis, Volume 1, April 2001, pp. 2-121 to 2-123.
27 City of San Diego, Final Subsequent Environmental Impact Report to the Final Master
Environmental Impact Report for the Centre City Redevelopment Project and Addressing the Centre
City Community Plan and Related Documents for the Proposed Ballpark and Ancillary Development
Projects, and Associated Plan Amendments, V. IV. Responses to Comments, September 13, 1999,
pp.IV-254 to IV-256.
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designed to minimize the number of large construction equipment
operating during any given time period; b) scheduling of construction
truck trips during non-peak hours to reduce peak hour emissions;
c) limitation of the length of construction work-day period; and
d) phasing of construction activities;
? Installation of catalytic converters on gasoline-powered equipment, if
feasible;
? Minimization of construction worker trips by requiring carpooling and
by providing for lunch onsite;
? Lengthening of construction period during smog season (May through
October), so as to minimize the number of vehicles and equipment
operating at the same time;
? Utilization of new technologies to control ozone precursor emissions as
they become available and feasible;
? Use electricity from power poles rather than temporary diesel power
generators; and
? Emission offsets if ROG or NOx emissions exceed 6.0 tons/quarter.
The following discusses the use and feasibility of construction equipment
certified by CARB, post-combustion controls, and the use of PuriNOx, an alternative
diesel formulation.
VII.A.2.a CARB-certified Construction Equipment
Both the U.S. EPA and CARB have established emission limits on new
off-road engines. CARB-certified off-road engines are engines that are 3 years old or
less at the time of use and which comply with these new low emission limits. This
equipment is widely available in the construction fleet. The use of CARB-certified
equipment should be required for this Project.
For example, the SMAQMD and other agencies require the use of at least
20 percent CARB-certified off-road engines in the mix of construction equipment
operating on-site, or alternatively, setting a NOx, ROG, and/or PM10 emission
reduction goal for the construction fleet. A similar measure has been adopted by the
Texas Natural Resource Conservation Commission (“TNRCC”) for the Dallas/Fort
Worth and Houston-Galveston areas. (Rennie et al. 2001.28) The Arizona Department
28 S.G. Rennie, L. Fiffick, D. Huckabay, and B. Ubanwa, Heavy Duty Diesel Engines Retrofit Programs
as a Part of Houston SIP, Proceedings of the Air & Waste Management Association’s 94th Annual
Conference & Exhibition, June 24–28, 2001.
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of Environmental Quality (“ADEQ”) has also recommended this measure to address
the air quality problems in the Phoenix area. (ADEQ 11/9/00, pp. 19-24.)
VII.A.2.b Post-combustion Controls
Post-combustion controls, such as oxidation catalysts and particulate filters,
are devices that are installed downstream of the engine on the tailpipe to treat the
exhaust. These devices are now widely used on construction equipment and are
capable of removing over 90% of the PM10, CO, and ROG from engine exhaust,
depending on the fuel and specific engine. The most common and widely used post-
combustion control devices are particulate traps (i.e., soot filters), oxidation catalysts,
and combinations thereof. The many variants of these devices have recently been
identified, evaluated, and comprehensively reviewed by CARB29 and others.30
These devices are commonly required as mitigation for construction
emissions, which are similar to Project operations. The Massachusetts Turnpike
Authority (“MTA”) implemented a voluntary program in the fall of 1998 which
resulted in retrofitting 70 pieces of construction equipment with oxidation catalysts
(Kasprak et al. 200131) at the “Big Dig,” the massive, 5-year, $10 billion-plus Central
Artery/Tunnel Project in Boston’s North End and one of the largest infrastructure
construction projects in the country.
These controls have also been widely required to mitigate construction
emissions in California. The CEC, which follows a CEQA-equivalent process in
licensing of new power plants larger than 50 megawatts (“MW”), has required these
devices on many projects. The Sunrise Power Project was recently constructed using
this equipment.32 No problems were encountered. Several other 500+MW power
plants have been licensed and constructed successfully using these controls,
29 California Air Resources Board, Risk Reduction Plan to Reduce Particulate Matter Emissions from
Diesel-Fueled Engines and Vehicles, October 2000; California Air Resources Board, Risk Management
Guidance for the Permitting of New Stationary Diesel-Fueled Engines, October 2000.
30 Manufacturers of Emission Controls Association, Demonstration of Advanced Emission Control
Technologies Enabling Diesel-Powered Heavy-Duty Engines to Achieve Low Emission Levels, Final
Report, June 1999.
31 A. Kasprak, G. Schattanek, and P.K. Wan, Emission Reduction Retrofit Program for Construction
Equipment of the Central Artery/Tunnel Project, Proceedings of the Air & Waste Management
Association’s 94th Annual Conference & Exhibition, June 24-28, 2001. Also see:
www.epa.gov/OMS/retrofit/documents/bigdig_case_01.htm, accessed October 26, 2005.
32 California Energy Commission, Commission Decision, Sunrise Power Project, December 2000,
Condition AQ-C3, p. 120.
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including High Desert33, Elk Hills34, Pastoria35, Western Midway-Sunset36, Mountain
View37, and Contra Costa38, among others. (All of the CEC siting decisions are
posted at www.energy.ca.gov under the name of the individual facility.)
Post-combustion controls have also been required as conventional CEQA
mitigation in EIRs. The El Toro Reuse Draft EIR39, page 2-124, AQ-11k and AQ-11l,
required the use of particulate traps with a minimum 80% PM10 efficiency and
selective catalytic reduction (“SCR”) or comparable technology with a minimum
70% NOx reduction on all off-road construction equipment. The Stanford University
General Use Permit Application Draft EIR40, page 4.11-10, AQ-1, required a range of
measures to minimize diesel engine exhaust, including catalytic converters and
particulate traps. The City of San Diego in the Padres Ballpark Final EIR41 required
the control of 95% of engine exhaust emissions, using, among others, oxidation
catalysts, particulate filters, and “Blue Sky” low-emission engines. Similarly, the Port
of Oakland required the use of new engines or post-combustion controls on trucks
serving its Vision 2000 expansion project. The Port’s air quality mitigation program
is now partially in place and has been very successful in reducing emissions.42
33 California Energy Commission, Commission Decision, High Desert Power Project, May 2000,
Condition AQ-3(o), p. 107.
34 California Energy Commission, Commission Decision, Elk Hills Power Project, December 2000,
Condition AQ-C2(3), p. 123.
35 California Energy Commission, Commission Decision, Pastoria Energy Facility, December 2000,
Condition AQ-C3, p. 108.
36 California Energy Commission, Commission Decision, Western Midway Sunset Power Project,
March 2001, Condition AQ-C2, p. 114.
37 California Energy Commission, Commission Decision, Mountain View Power Project, March 2001,
Condition AQ-C2, p. 34.
38 California Energy Commission, Commission Decision, Contra Costa Unit 8 Power Project, May
2001, Condition AQC-2, p. 12.
39 County of Orange, Draft Environmental Impact Report, No. 573 for the Civilian Reuse of MCAS
El Toro and the Airport System Master Plan for John Wayne Airport and Proposed Orange County
International Airport, April 2001.
40 Santa Clara County, Draft Environmental Impact Report, EIR Stanford University Draft
Community Plan and General Use Permit Application, June 23, 2000.
41 City of San Diego, Final Subsequent Environmental Impact Report, Ballpark and Ancillary
Development Projects, and Associated Plan Amendments, September 13, 1999 and Draft Subsequent
EIR, May 12, 1999, , page IV-262, I8.A.89.
42 Port of Oakland, Summary Report #5, Vision 2000 Air Quality Mitigation Program, February 2002.
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All of these post-combustion controls are feasible for construction of this
Project. Therefore, the Draft EIR should be revised be prepared requiring the use of
post-combustion controls on off-road equipment specifying target control levels.
VII.A.2.c PuriNOx
Alternate diesel fuels exist that achieve PM10 and NOx reductions. PuriNOx
is an alternative diesel formulation that was verified by CARB on January 31, 200143
as achieving a 14% reduction in NOx and a 63% reduction in PM10 compared to
CARB diesel. It can be used in any direct-injection, heavy-duty compression ignition
engine and is compatible with existing engines and existing storage, distribution,
and vehicle fueling facilities. Operational experience indicates little or no difference
in performance and startup time, no discernable operational differences, no
increased engine noise, and significantly reduced visible smoke. (Hagstrand 6/0444.)
This fuel has been successfully used in heavy-duty off-road and on-road
equipment, including by the Tri-Delta Transit Authority fleet in Contra Costa
County, by the County of Sacramento at the Keifer Landfill and North Transfer
station, in off-road construction equipment at very large residential construction
projects in Sacramento, in truck fleets operated by Pacific Cement in San Francisco
and Ramos Oil in Dixon, in yard hostlers at the Port of Long Beach, in off-road
equipment operated by Hanson Aggregate in San Francisco, and in yard haulers at
the Port of Houston. (Howes 4/0045 and Hagstrand 6/04.) Six yard tractors have
been operating on PuriNOx at the Port of Houston since April 2000. The Texas
Natural Resource Conservation Commission (“TNRCC”) has also approved
PuriNOx fuel for funding under Texas Senate Bill 5.
PuriNOx fuel is available from fuel distributor Chevron Texaco in Los
Angeles and is competitively priced at a surcharge over regular diesel of about
10 cents per gallon.46 It has been required as mitigation for construction exhaust
emission impacts. For example, the NASA Ames Development Plan Draft
43 Letter from Dean C. Simeroth, Chief, Criteria Pollutants Branch, to Thomas J. Sheahan, Lubrizol,
Verification of Lubrizol Corp. PuriNOx Fuel, January 31, 2001,
http://www.arb.ca.gov/fuels/diesel/altdiesel/altdiesel.htm, accessed June 18, 2004.
44 Personal communication, Petra Pless/Phyllis Fox with Hep Hepner, Ramos Oil Co., Dixon, CA,
(916-371-3289, ext. 242) and Bill Hagstrand, Lubrizol (440-347-6592), March and June 2004.
45 P. Howes, An Evaluation of the Effects of PuriNOxTM on Exhaust Emissions from Yard Haulers at
the Port of Houston, April 2000.
46 Personal communication, Petra Pless with Bill Hagstrand, Lubrizol (440-347-6592), June 21, 2004.
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Environmental Impact Statement,47 page 4.4-34, requires “where reasonable and
feasible, use alternative diesel fuels. See also construction exhaust mitigation in the
Bickford Ranch Final EIR, page 1-24, requiring 10% to 20% NOx emission
reductions, to be achieved by both engine selection and fuel selection. (“Includes the
use of emulsified fuel in non-certified engines…”.)
VII.B Additional Feasible Operational Mitigation
The Draft EIR concludes that after implementation of the proposed mitigation
measures, emissions of CO and ROG from operation of the hospital and other
on-site facilities will remain significant. The Draft EIR states that “[e]ven with
measures to encourage trip reduction and energy efficiency, emissions cannot be
mitigated to below a level of significance” and concludes that “[l]ong-term air
quality impacts will be significant and unavoidable.” (Draft EIR, p. 4-29.) Yet, the
Draft EIR imposes a total of only five mitigation measures that address operational
emissions, specifically, AQ-2 incorporation and encouragement of Transportation
Demand Management techniques (“TDM”); AQ-3 incorporation of energy efficiency
standards for buildings; AQ-4 submission of a landscape plan; AQ-16 enclosure and
cover of refuse areas; and AQ-17 promotion of alternative transportation. (Draft EIR,
pp. 4-26 through 4-28.)
By the Draft EIR’s own admission, these mitigation measures are insufficient
to reduce the significant impacts from operational emissions to less than significance
for CO and ROG, resulting in significant unmitigated impacts from Project
operational emissions. (Draft EIR, p. 4-29.) Further, as discussed in Comment V, the
Draft EIR considerably underestimates Project operational emissions of PM10 and
NOx, which likely also exceed the SCAQMD’s quantitative daily significance
thresholds. The Draft EIR does not contain any discussion why no additional
mitigation measures were considered to reduce the Project’s significant impacts on
air quality. As discussed below, numerous other mitigation measures exist that are
routinely required as CEQA mitigation and should have been required for the
Project.
For example, the Initial Study for the Project recommends the following two
mitigation measures for emissions from Project operations that were not
incorporated into the Draft EIR:
47 NASA Ames Research Center, NASA Ames Development Plan, Draft Programmatic
Environmental Impact Statement, November 2001.
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? Electrical powered equipment should be utilized in-lieu of gasoline-
powered engines where feasible; and
? Prior to the issuance of a grading and building permit, the applicant shall
submit verification that a ridesharing program for the construction crew
has been encouraged and will be supported by the contractor via
incentives or other inducements. (NOP/Initial Study, pp. 9-11.)
VII.B.1 Operational Traffic Mitigation Measures
The following traffic mitigation measures are routinely required elsewhere to
mitigate significant impacts from a project and should be required to mitigate the
Project’s significant NOx, ROG, and PM10 impacts.
? Encourage carpool/vanpool program;
? Provide on-site shops and services for employees, such as cafeteria,
bank/ATM, dry cleaners, convenience market, etc.;
? Provide on-site child care or contribute to off-site child care within
walking distance;
? Provide preferential parking for carpool/vanpool vehicles;
? Provide secure, weather-protected bicycle parking for employees;
? Provide direct safe, direct bicycle access to adjacent bicycle routes;
? Provide showers and lockers for employees bicycling or walking to work;
? Short-term bicycle parking for retail customers and other non-commute
trips;
? Provide neighborhood-servicing shops and services within ½ mile of
residential areas;
? Connect bicycle lanes/paths to city-wide network;
? Design and locate buildings to facilitate transit access, e.g., locate building
entrances near transit stops, eliminate building setbacks, etc.;
? Construct transit facilities such as bus turnouts/bus bulbs, benches,
shelters, etc.;
? Provide shuttle service to food service establishments/commercial areas;
? Provide shuttle service to transit stations/multimodal centers;
? Implement parking fee for single-occupancy vehicle commuters;
? Implement parking cash-out program for non-driving employees;
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? Provide direct, safe, attractive pedestrian access from project to transit
stops and adjacent development;
? Implement compressed work week schedule;
? Implement home-based telecommuting program;
? Provide electric vehicle (“EV”) and compressed natural gas (“CNG”)
vehicles in vehicle fleets;
? Install EV charging facilities;
? Install CNG fueling facility;
? Provide preferential parking locations for EVs and CNG vehicles; and
? Charge reduced or no parking fee for EVs and CNG vehicles;
The Lent Ranch Final EIR48, for example, requires most of these measures.
The NASA Ames Development Plan Draft Environmental Impact Statement
(“EIS”)49 would implement an aggressive transportation demand management
program (“TDM”) to reduce trip generation by at least 22 percent. The Stanford
University Draft Community Plan and General Use Permit Draft EIR 50 adopts all
applicable Bay Area TDMs. The Bickford Ranch Specific Plan Final EIR51 requires
that emissions be reduced by 40% by implementing many of these measures. The
Old Greenwood Planned Development Draft EIR52 requires, among others, paying
an air quality mitigation fee to offset PM10 emissions from vehicle exhaust and re-
entrained road dust to zero. Therefore, the above-listed measures should be
assumed feasible unless otherwise demonstrated, and used by this Project to reduce
traffic emissions to a less than significant level.
48 City of Elk Grove, Lent Ranch Marketplace, Draft Environmental Impact Report, for example Table
4.3-21, page 3.0-96, and Table 12-2, October 2000.
49 NASA Ames Research Center, NASA Ames Development Plan, Draft Programmatic
Environmental Impact Statement, pp. O-11 to O-16, November 2001.
50 Santa Clara County, Draft Environmental Impact Report, Stanford University Draft Community
Plan and General Use Permit Application, Table 4.11-6, June 23, 2000.
51 County of Placer, Bickford Ranch Specific Plan Final Environmental Impact Report, Section 8.3.2
and 8.4, November 13, 2000.
52 City of Truckee, Draft Environmental Impact Report, Old Greenwood Planned Development,
pp. 4.5-10 to 4.5-13, February 2002.
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VII.B.2 Operational Area Mitigation Measures
The City’s General Plan contains the following two operational mitigation
measures that are not required by the Draft EIR:
? Optimize building sites and orientation to take advantage of shading and
windbreak trees and reduce fuel consumption for heating and cooling;
and
? Design buildings to optimize natural lighting, provide for task lighting,
and specific high-efficiency electric lighting. (General Plan, p. AQ-8.)
In addition to the mitigation measures proposed by the Draft EIR and
contained in the City’s General Plan, operational area emissions can also be
mitigated by controlling other sources of emissions from the Project, including
exhaust emissions from landscaping equipment, emissions from natural gas
combustion for heating/air-conditioning, increased ozone production from the heat
island effect (see Comment VI), and indirect emissions from electricity generation
(see Comment V.E). In addition, the CEQA Guidelines of other air districts identify
numerous other feasible measures for commercial/industrial operations. Some of
these additional measures, which are routinely required as mitigation in other EIRs53
include:
? Use electric lawn and garden equipment for landscaping (BAAQMD);
? Use electrically or CNG-powered specialty equipment, e.g., utility carts
(BAAQMD);
? Use propane-powered specialty equipment, e.g., forklifts, utility carts, etc.
(BAAQMD);
? Increase walls and attic insulation beyond Title 24 requirements
(SLOAPCD54, SCAQMD55);
53 For example: City of Elk Grove, Lent Ranch Marketplace, Draft Environmental Impact Report,
Table 4.3-5, p. 3.0-96, October 2000; County of Placer, Bickford Ranch Specific Plan Final
Environmental Impact Report, pp. 8-20 to 8-22, November 13, 2000; Sacramento County, East
Franklin Specific Plan, Final Environmental Impact Report, Table ES-1; and Appendix D,
February 2000; City of Truckee, Draft Environmental Impact Report, Old Greenwood Planned
Development, pp. 4.5-10 to 4.5-13, February 2002.
54 San Luis Obispo Air Pollution Control District, CEQA Air Quality Handbook, August 1997.
55 South Coast Air Quality Management District, CEQA Air Quality Handbook, April 1993.
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? Orient buildings to maximize standard heating and cooling (SLOAPCD)
and include passive solar design, e.g., day-lighting (SCAQMD, SBAPCD56,
BCAQMD57);
? Plant shade trees in parking lots to reduce evaporative emissions from
parked vehicles (SLOAPCD, SCAQMD, SBAPCD, BCAQMD);
? Plant shade trees along southern exposures of buildings to reduce
summer cooling needs (SLOAPCD, SCAQMD, SBAPCD);
? Use energy-efficient and automated controls for air conditioning
(SCAQMD, BCAQMD);
? Use lighting controls and energy-efficient interior lighting (SLOAPCD,
SCAQMD, SBAPCD, BCAQMD) and built-in energy-efficient appliances
(SLOAPCD);
? Use double-paned windows (SLOAPCD, SCAQMD);
? Use energy-efficient low sodium parking lot and street lights (SLOAPCD,
SCAQMD);
? Use light-colored roof materials (SCAQMD) and paint (SBAPCD) to reflect
heat; (see Comment VII.B.3.b)
? Install solar cooling/heating (SBAPCD);
? Install solar water heater for at least 25% of the building floor area
(BCAQMD);
? Substitute materials, e.g., use water-based paint (SCAQMD);
? Modify manufacturing processes, e.g., reduce process stages, closed loop-
systems, materials recycling (SCAQMD);
? Install resource recovery systems that redirect chemicals to new
production processes (SCAQMD);
? Use solar or low-emission water heaters (SCAQMD);
? Use centralized water-heating systems (SCAQMD, VCAPCD58);
? Use concrete or other non-pollutant materials for parking lots instead of
asphalt (SBAPCD);
56 Santa Barbara Air Pollution Control District, Scope and Content of Air Quality Sections in
Environmental Documents, September 1997.
57 Butte County Air Quality Management District, Indirect Source Review Guidelines, March 1997.
58 Ventura County Air Pollution Control District, Ventura County Air Quality Management Plan,
Appendix G-94, Guidelines for the Preparation of Air Quality Impact Analyses, October 1989.
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? Pay an air quality mitigation fee;
? Secure emission offsets;
? Landscape with drought-resistant species, and use groundcovers rather
than pavement to reduce heat reflection;
? Provide electric maintenance equipment;
? Use ozone-destruction catalyst on air condition systems; and
? Reduce standard paving by 20%.
Further, some air districts recommend that large projects that cannot be fully
mitigated with on-site measures, should implement off-site mitigation measures, for
example:
? Retrofit existing homes and businesses in the project area with approved
energy conservation devices (SLOAPCD);
? Replace/repower school/transit bus with cleaner vehicles (SLOAPCD);
? Construct satellite work stations (SLOAPCD);
? Fund a program to buy and scrap older, high-emission vehicles
(SLOAPCD);
? Contribute to an off-site TDM fund (VCAPCD);
? Repair smog-check waived vehicles (SLOAPCD);
? Introduce electric lawn and garden equipment exchange program
(SLOAPCD); and
? Retrofit/purchase clean heavy-duty trucks, construction equipment,
diesel locomotives, and marine vessels (SLOAPCD).
VII.B.3 Mitigation For Urban Heat Island Effect
A number of the above discussed mitigation measures will reduce the urban
heat island effect. The feasibility of two of these measures, reduction of standard
paving by 20% and use of Energy Star roof products, are discussed in the following
comments in more detail.
VII.B.3.a Reduction Of Standard Paving By 20%
The heat island effect can be mitigated by reflecting the sunlight off the
pavement before it heats up through use of lighter-colored, reflective pavement
materials. These materials reduce the urban heat island effect, reducing the
formation of ozone, and reducing evaporative emissions from vehicles that park on
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and use the pavement, thus reducing traffic emissions. This can be accomplished by
using grass paving or reflective surfaces on unshaded parking lots, driveways, and
fire lanes to reduce standard paving by 20%. This measure is widely used,
technically feasible, provides air quality benefits, and is economic.
There are a large number of options that can be used to comply with this
measure, ranging from porous block pavement systems to conventional asphalt
pavements using light aggregate to conventional concrete pavements. Some are
comparable in cost to conventional pavements and have added benefits besides
reducing air quality impacts.
VII.B.3.b Use Of Energy Star Roof Products
Most commercial and residential buildings have dark roofs. Dark roofs
absorb 80% to 90% of the incident sunlight, heating the roof and plenum space.
Because the air distribution system is typically installed in the plenum space
between the roof deck and the dropped ceiling over the finished interior space, this
raises the summertime cooling demand. In addition, heating the roof heats the air
that passes over the roof. Thus, the entire region around a dark roof becomes
warmer, increasing the formation of ozone.
As discussed above, dark roofs (and parking lots) quickly warm the air over
urban areas, leading to the creation of summer urban “heat islands.” The additional
air conditioning demand created by this temperature effect is responsible for 5% to
10% of urban peak electric demand. The increased power demand leads to higher
emissions from power plants. This increase in temperature causes a 10% to 20%
increase in urban ozone, and in some cases, generates as much ozone as all on-road
motor vehicles.59 Measures to reverse the heat island effect include reflective roofs
and pavements.
Intercepting the sunlight before it heats a building keeps its surface cooler
and reduces the heat flow into the building. This reduces the demand for air
conditioning. This can be accomplished by using light-colored, reflective roofs. A
light-colored roof can reduce the amount of energy needed for cooling by 20% to
70%, depending on the amount of insulation under the roof and design of the air
ducting system. This is achieved by reflecting most of the energy, rather than
absorbing it. The difference between the roof surface and ambient air temperatures
may be as high as 90F, while for reflective roofs, the difference is only about 18F.
59 Akbari H, Cool Roofs Save Energy, ASHRAE Transactions, v. 104, Pt. 1, 1998; Taha H, Modeling the
Impacts of Large-Scale Albedo Changes on Ozone Air Quality in the South Coast Air Basin,
Atmospheric Environment, v. 31, no. 11, 1997, pp. 1667-1676.
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This reduces peak cooling demand, cooling costs, the size of the HVAC system, and
the rating and amount of insulation required in a building, and increases the lifetime
of the roof. This also reduces air pollution by reducing the amount of external power
that must be produced and the amount of ambient ozone that is formed in the
vicinity of the development from the heat island effect.
Normal asphalt-based roofing products typically have a reflectivity of 10% to
20%. Energy Star-labeled roof products are roofing products certified to achieve at
least 65% reflectivity and to maintain a reflectivity of 50% under normal conditions
for 3 years after installation. The program is sponsored by the U.S. EPA and the
Department of Energy. There are currently over 115 manufacturers enrolled in the
program. Reflective roofing is also recognized as an acceptable design option in the
latest edition of the American Society of Heating, Refrigerating and Air-
Conditioning Engineers (“ASHRAE”) Standards 90.160 and 90.2 on energy-efficient
buildings.
Energy Star roof products are economical to apply and maintain and can be
cheaper than or comparable to conventional roofing products, which cost from $1.50
to $2.50 per square foot installed.61 Cool roofs come in a variety of styles, including
reflective coatings, reflective membranes, or metal roofs made of galvanized or other
coated metal. Coatings have a consistency of thick paint and cost from $0.75 to $1.50
per square foot installed. Membranes are single-ply, pre-fabricated sheets applied in
a single layer, typically made of PVC (poly vinyl chloride), TPO (tripolymer olefin),
Hypalon, or CPA (copolymer alloy) and cost from $1.50 to $3.00 per square foot.
A reflective roof can be installed or applied over almost any type of roof material,
including directly on a plywood deck in place of asphalt.
The performance of reflective roofing materials has been extensively
documented. At a single family residence in Sacramento, increasing the reflectivity
of the roof from 18% to 79% by painting with a white coating reduced the cooling
energy use over the June to October period by 66% and the peak power by 17%. At a
one-story school in Sacramento, increasing the reflectivity of the roof from 8% to
68% by painting with a white coating reduced the cooling energy use over the June
to October period by 34% and peak power by 32%.62 In another Sacramento study,
60 American Society of Heating, Refrigerating and Air-Conditioning Engineers, Inc., Energy Standard
for Buildings Except Low-Rise Residential Buildings, Standard 90.1-1999.
61 R.S. Means, Square Foot Costs, 21st Ed., 2000, Division 5, Roofing.
62 H. Akbari, S. Bretz, D. Kurn, and J. Hanford, Peak Power and Cooling Energy Savings of High-
Albedo Roofs, Energy and Buildings, v. 25, 1997, pp. 117-126.
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daily air conditioning savings of 17%, 26%, and 39% were documented in an office,
museum, and hospice with high reflectivity roofs.63
At a one-story, 31,700-square footKaiser medical office building in Davis,
increasing the reflectivity of an R-19 flat roof from 24% to 60% reduced summertime
average weekday air conditioning by 18%. At another one-story, 23,800-square foot
Kaiser medical office building in Gilroy, increasing the reflectivity of an R-7 flat roof
from 25% to 65% reduced the summertime average weekday air conditioning by
13%. At a 33,000-square foot drug store in San Jose, increasing the reflectivity of a
foil barrier flat roof from 18% to 28% reduced the summertime average daytime air
condition by 2%.64
Reflective coatings reduced cooling energy costs by 12% to 18% in two other
commercial buildings in California.65 The reflectivity of a conventional unsurfaced
galvanized corrugated metal roof of seven retail stores in a strip mall in Florida was
increased from 29% to 75% with a white coating. This reduced the summer space
cooling energy use by 25%, with a range in savings of 13% to 48%, depending on the
temperature maintained in the shops. Those maintaining the lowest interior
temperatures saved the least on a percentage basis. The cost of the application was
$0.53/ft2 with a payback period of about 9 years.66 In nine Florida homes, daily air
conditioning energy use was reduced by 2% to 43% and peak demand was reduced
by an average of 22%. The amount of energy savings was inversely correlated with
the amount of ceiling insulation and duct system location, with the largest savings in
poorly insulated homes and those with duct systems in the attic space and smaller
savings in well-insulated homes.67 A high-reflective coating on an office building in
Mississippi reduced cooling energy demands by 22%.68 In addition to field studies,
63 E.W. Hildebrandt, W. Bos, and R. Moore, Assessing the Impacts of White Roofs on Building Energy
Loads, ASHRAE Technical Data Bulletin, v. 14, no. 2, 1998.
64 H. Akbari, L. Gartland, and S. Konopacki, Measured Energy Savings of Light-Colored Roofs:
Results from Three California Demonstration Sites, Proceedings of the 1998 ACEEE Summer Study
on Energy Efficiency in Buildings, v. 3, no. 1, 1998.
65 S. Konopacki, H. Akbari, L. Gartland, and L. Rainer, Demonstration of Energy Savings of Cool
Roofs, LBNL Report 40673, 1998.
66 D. Parker, J. Sonne, and J. Sherwin, Demonstration of Cooling Savings of Light Colored Roof
Surfacing in Florida Commercial Buildings: Retail Strip Mall, Florida Solar Energy Center Report
FSEC-CR-964-97, 1997; www.fsec.ucf.edu/Bldg/pubsonline.htm.
67 D.S. Parker and others, Measured and Simulated Performance of Reflective Roofing Systems in
Residential Buildings, ASHRAE Proceedings (Winter Meeting), Atlanta, GA, 1998;
www.fsec.ucf.edu/Bldg/pubsonline.htm.
68 C. Boutwell and Y. Salinas, Building for the Future - Phase I: An Energy Saving Materials Research
Project, Mississippi Power Co., Rohm and Haas Co and the University of Mississippi, 1986.
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computer simulations of reflective roofs have documented cooling energy savings in
residential and commercial buildings.69 Cool roofs have been widely used in
California, including on the American Airline airport terminal in San Jose, on control
towers at the Stockton and Palmdale airports, at the 300,000-square foot Honda
distribution warehouse in Stockton, the 200,000-square foot JC Penny warehouse in
Buena Park, and numerous buildings in Silicon Valley.
Thus, this measure would save a substantial amount of money over the life of
the Project and would cost no more than a standard roof. Further, it would reduce
pollution by reducing the generation of power and the formation of ozone from the
heat island effect.
In sum, there are many additional feasible measures that should be evaluated
and required for this Project. The Draft EIR should be revised to include these
additional measures and be recirculated for public review.
VIII.CONCLUSION
As detailed in the comments above, the Draft EIR fails to meet the most basic
requirements of CEQA. The Draft EIR fails to comply with the goals of the General
Plan, fails to adequately describe the Project and its environmental setting, and fails
to adequately identify the Project’s regulatory setting. The Draft EIR’s air quality
impact analysis for both the construction and operational phases of the Project are
fatally flawed and considerably underestimate Project emissions. As a result, the
Draft EIR fails to disclose all significant impacts and fails to disclose the full
magnitude of all impacts. The Draft EIR did not require all feasible mitigation to
mitigate these significant impacts from Project construction and mitigation.
Additional feasible mitigation exists and should be required to reduce these
significant impacts. In sum, the Draft EIR is patently inadequate and should be
revised and recirculated for public review.
69 See, for example: H. Akbari, S. Konopacki, C. Eley, B. Wilcox, M. Van Geem and D. Parket,
Calculations for Reflective Roofs in Support of Standard 90.1, ASHRAE Transactions, v. 104, no. 1,
1998, pp. 984-996; L. Gartland, S. Konopacki, and H. Akbari, Modeling the Effects of Reflective
Roofing, ACEEE 1996 Summer Study on Energy Efficiency in Buildings, v. 4, 1996, pp. 117-124.
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Exhibit 1
URBEMIS2002 Modeling Output
for 36-month Construction Period and Vehicle Emissios Target Year 2009
Page: 1
10/27/2005 10:54 AM
URBEMIS 2002 For Windows 8.7.0
File Name: C:\Documents and Settings\Petra Pless\My Documents\PP Environmental Consulting
Project Name: Temecula Regional Hospital
Project Location: South Coast Air Basin (Los Angeles area)
On-Road Motor Vehicle Emissions Based on EMFAC2002 version 2.2
SUMMARY REPORT
(Pounds/Day - Summer)
CONSTRUCTION EMISSION ESTIMATES
PM10 PM10 PM10
*** 2006 *** ROG NOx CO SO2 TOTAL EXHAUST DUST
TOTALS (lbs/day,unmitigated) 41.95 283.34 338.81 0.03 129.68 11.96 117.72
TOTALS (lbs/day, mitigated) 41.95 283.34 338.81 0.03 53.81 11.96 41.85
PM10 PM10 PM10
*** 2007 *** ROG NOx CO SO2 TOTAL EXHAUST DUST
TOTALS (lbs/day,unmitigated) 13.82 89.14 115.14 0.00 3.97 3.72 0.25
TOTALS (lbs/day, mitigated) 13.82 89.14 115.14 0.00 3.97 3.72 0.25
PM10 PM10 PM10
*** 2008 *** ROG NOx CO SO2 TOTAL EXHAUST DUST
TOTALS (lbs/day,unmitigated) 343.64 227.46 295.63 0.01 9.35 8.83 0.52
TOTALS (lbs/day, mitigated) 343.64 227.46 295.63 0.01 9.35 8.83 0.52
AREA SOURCE EMISSION ESTIMATES
ROG NOx CO SO2 PM10
TOTALS (lbs/day,unmitigated) 8.39 3.79 4.43 0.00 0.01
OPERATIONAL (VEHICLE) EMISSION ESTIMATES
ROG NOx CO SO2 PM10
TOTALS (lbs/day,unmitigated) 92.78 103.76 1,245.27 0.86 123.35
SUM OF AREA AND OPERATIONAL EMISSION ESTIMATES
ROG NOx CO SO2 PM10
TOTALS (lbs/day,unmitigated) 101.17 107.56 1,249.70 0.86 123.36
Petra Pless, D.Env.
440 Nova Albion Way
San Rafael, CA 94903
(415) 492-2131 voice
(775) 254–5849 fax
ppless@earthlink.net
Dr. Pless has over 10 years of experience in environmental engineering and science conducting
and managing interdisciplinary environmental research projects and preparing and reviewing
environmental permits and other documents for U.S. and European stakeholder groups. This
broad-based experience includes air quality and air pollution control; water quality, water
supply, and water pollution control; biology; public health and safety; noise studies and
mitigation; National Environmental Policy Act (“NEPA”), California Environmental Quality
Act (“CEQA”), and Clean Air Act (“CAA”) review; industrial ecology and risk assessment; and
use of a wide range of environmental software.
EDUCATION
Doctorate in Environmental Science and Engineering (D.Env.), University of California,
Los Angeles, 2001
M.S. Biology (with focus on botany/ecology/limnology), Technical University of Munich,
Germany, 1991
PROFESSIONAL HISTORY
Leson & Associates (previously Leson Environmental Consulting), Kensington, CA,
Environmental Scientist/Project Manager, 1997–present
University of California Los Angeles, Graduate Research Assistant/Teaching Assistant, 1994–96
ECON Research and Development, Environmental Scientist, Ingelheim, Germany, 1992–93
Biocontrol, Environmental Projects Manager, Ingelheim, Germany, 1991–92
REPRESENTATIVE EXPERIENCE
Air Quality and Pollution Control
Projects include CEQA/NEPA review; attainment and non-attainment new source review
(“NSR”), prevention of significant deterioration (“PSD”) and Title V permitting; control
technology analyses (BACT, LAER, RACT, BARCT, MACT); technology evaluations and cost-
effectiveness analyses; criteria and toxic pollutant emission inventories; emission offsets;
ambient and source monitoring; analysis of emissions estimates and ambient air pollutant
concentration modeling. Some typical projects include:
Petra Pless, D.Env.
— Critically reviewed and prepared technical comments on the air quality, biology, noise,
water quality, and public health and safety sections of CEQA/NEPA documents for
numerous commercial, residential, and industrial projects (e.g., power plants, airports,
residential developments, retail developments, hospitals, refineries, quarries, and mines).
— Critically reviewed and prepared technical comments on the air quality and public health
sections of the Los Angeles Airport Master Plan (Draft, Supplement, and Final
Environmental Impact Statement/Environmental Impact Report) for the City of El Segundo.
Provided technical comments on the Draft and Final General Conformity Determination for
the preferred alternative submitted to the Federal Aviation Administration.
— For several California refineries, evaluated compliance of fired sources with Bay Area Air
Quality Management District (“BAAQMD”) Rule 9-10. This required evaluation and review
of hundreds of source tests to determine if refinery-wide emission caps and compliance
monitoring provisions were being met.
— Critically reviewed and prepared technical comments on Draft Title V permits for several
refineries and other industrial facilities in California.
— Evaluated the public health impacts of locating big-box retail developments in densely
populated areas in California and Hawaii. The impacts of diesel exhaust emissions and
noise on surrounding residential communities were measured and evaluated.
— In conjunction with the permitting of several residential and commercial developments,
conducted studies to determine baseline concentrations of diesel exhaust particulate matter
using an aethalometer.
— For an Indiana steel mill, evaluated technology to control NOx and CO emissions from fired
sources, including electric arc furnaces and reheat furnaces, to establish BACT. This
required a comprehensive review of U.S. and European operating experience. The lowest
emission levels were being achieved by steel mills using selective catalytic reduction
(“SCR”) and selective non-catalytic reduction (“SNCR”) in Sweden and The Netherlands.
— For a California petroleum coke calciner, evaluated technology to control NOx, CO, VOCs,
and PM10 emissions from the kiln and pyroscrubbers to establish BACT and LAER. This
required a review of state and federal clearinghouses, working with regulatory agencies and
pollution control vendors, and obtaining and reviewing permits and emissions data from
other similar facilities. The best-controlled facilities were located in the South Coast Air
Quality Management District (“SCAQMD”).
— For a Kentucky coal-fired power plant, identified the lowest NOx levels that had been
permitted and demonstrated in practice to establish BACT. Reviewed operating experience
of European, Japanese, and U.S. facilities and evaluated continuous emission monitoring
data. The lowest NOx levels had been permitted and achieved in Denmark and in the U.S.
in Texas and New York.
— In support of efforts to lower the CO BACT level for power plant emissions, evaluated the
contribution of CO emissions to tropospheric ozone formation and co-authored report on
same.
— Critically reviewed and prepared technical comments on applications for certification
(“AFCs”) for several natural-gas fired and geothermal power plants in California permitted
2
Petra Pless, D.Env.
by the California Energy Commission (“CEC”). The comments addressed construction and
operational emissions inventories and dispersion modeling, BACT for turbines, etc.
— Critically reviewed and prepared technical comments on draft PSD permits for several
natural-gas fired power plants in California, Indiana, and Oregon. The comments
addressed emission inventories, BACT, case-by-case MACT, compliance monitoring, cost-
effectiveness analyses, and enforceability of permit limits.
— For a California refinery, evaluated technology to control NOx and CO emissions from CO
Boilers to establish RACT/BARCT to comply with BAAQMD Rule 9-10. This required a
review of BACT/RACT/LAER clearinghouses, working with regulatory agencies across the
U.S., and reviewing federal and state regulations and State Implementation Plans (“SIPs”).
The lowest levels were required in a SCAQMD rule and in the Texas SIP.
— In support of several federal lawsuits filed under the Clean Air Act, prepared cost-
effectiveness analyses for SCR and oxidation catalysts for simple cycle gas turbines and
evaluated opacity data.
— Provided comprehensive environmental and regulatory services for an industrial laundry
chain. Facilitated permit process with the SCAQMD. Developed test protocol for VOC
emissions, conducted field tests, and used mass balance methods to estimate emissions.
Reduced disposal costs for solvent-containing waste streams by identifying alternative
disposal options. Performed health risk screening for air toxics emissions. Provided
permitting support with SCAQMD. Renegotiated sewer surcharges with wastewater
treatment plant. Identified new customers for shop-towel recycling services.
— Designed computer model to predict performance of biological air pollution control
(biofilters) as part of a collaborative technology assessment project, co-funded by several
major chemical manufacturers. Experience using a wide range of environmental software,
including air dispersion models, air emission modeling software, database programs, and
geographic information systems (“GIS”).
Water Quality and Pollution Control
Experience in all phases of water quality and pollution control, including surface water and
ground water quality and supply studies, evaluating water and wastewater treatment
technologies, and identifying, evaluating and implementing pollution controls. Some typical
projects include:
— For a homeowner’s association, reviewed a California Coastal Commission staff report on
the replacement of 12,000 linear feet of wooden bulkhead with PVC sheet pile armor.
Researched and evaluated impact of proposed project on lagoon water quality, including
sediment resuspension, potential leaching of additives and sealants, and long-term stability.
Summarized results in technical report.
— For a 500-MW combined-cycle power plant, prepared a study to evaluate the impact of
proposed groundwater pumping on local water quality and supply, including a nearby
stream, springs, and a spring-fed waterfall. The study was docketed with the CEC and
summarized in a journal article.
— Evaluated impacts of on-shore oil drilling activities on large-scale coastal erosion in Nigeria.
3
Petra Pless, D.Env.
— For a 500-MW combined-cycle power plant, identified and evaluated methods to reduce
water use and water quality impacts. These included the use of zero-liquid-discharge
systems and alternative cooling technologies, including dry and parallel wet-dry cooling.
Prepared cost analyses and evaluated impact of options on water resources. This work led
to a settlement in which parallel wet dry cooling and a crystallizer were selected, replacing
100 percent groundwater pumping and wastewater disposal to evaporation ponds.
Applied Ecology, Industrial Ecology and Risk Assessment
Experience in applied ecology, industrial ecology and risk assessment, including human and
ecological risk assessments, life cycle assessment, evaluation and licensing of new chemicals,
and fate and transport studies of contaminants. Experienced in botanical, phytoplankton, and
intertidal species identification and water chemistry analyses. Some typical projects include:
— For the California Coastal Conservancy, San Francisco Estuary Institute, Invasive Spartina
Project, evaluated the potential use of a new aquatic pesticide for eradication of non-native,
invasive cordgrass (Spartina spp.) species in the San Francisco Estuary with respect to water
quality, biological resources, and human health and safety. Assisted staff in preparing an
amendment to the Final EIR.
— Evaluated likelihood that measured organochlorine pesticide concentrations at a U.S. naval
air station are residuals from past applications of these pesticides consistent with
manufacturers’ recommendations. Retained as expert witness in lawsuit.
— Prepared human health risk assessments of air emissions from several industrial and
commercial establishments, including power plants, refineries, and commercial laundries.
— Managed and conducted studies to license new pesticides. This work included the
evaluation of the adequacy and identification of deficiencies in existing physical/chemical
and health effects data sets, initiating and supervising studies to fill data gaps, conducting
environmental fate and transport studies, and QA/QC compliance at subcontractor
laboratories. Prepared licensing applications and coordinated the registration process with
German licensing agencies. This work led to regulatory approval of several pesticide
applications in less than six months.
— Designed and implemented database on physical/chemical properties, environmental fate,
and health impacts of pesticides for a major European pesticide manufacturer.
— Designed and managed toxicological study on potential interference of delta-9-tetrahydro-
cannabinol in food products with U.S. employee drug testing; co-authored peer-reviewed
publication.
— Critically reviewed and prepared technical comments on AFCs for several natural-gas fired
and geothermal power plants and transmission lines in California permitted by the CEC.
The comments addressed avian collisions and electrocution, construction and operational
noise impacts on wildlife, risks from brine ponds, and impacts on endangered species.
— For a 180-MW geothermal power plant, evaluated the impacts of plant construction and
operation on the fragile desert ecosystem in the Salton Sea area. This work included
baseline noise monitoring and assessing the impact of noise, brine handling and disposal,
and air emissions on local biota, public health, and welfare.
4
Petra Pless, D.Env.
— Designed research protocols for a coastal ecological inventory; developed sampling
methodologies, coordinated field sampling, determined species abundance and distribution
in intertidal zone, and analyzed data.
— Designed and conducted limnological study on effects of physical/chemical parameters on
phytoplankton succession; performed water chemistry analyses and identified
phytoplankton species; co-authored two journal articles on results.
— Conducted technical, ecological, and economic assessments of product lines from
agricultural fiber crops for European equipment manufacturer; co-authored proprietary
client reports.
— Developed life cycle assessment methodology for industrial products, including agricultural
fiber crops and mineral fibers; analyzed technical feasibility and markets for thermal
insulation materials from plant fibers and conducted comparative life cycle assessments.
— Conducted and organized underwater surveying and mapping of plant species in several
lakes and rivers in Sweden and Germany as ecological indicators for the health of
limnological ecosystems.
PRO BONO ACTIVITIES
— Management of “SecondAid,” a non-profit organization providing tsunami relief for the
recovery of small family businesses in Sri Lanka. (www.secondaid.org)
— Technical consulting for Lakota Village Fund, a non-profit organization for environmental
improvement and economic development projects for the Pine Ridge Reservation in South
Dakota. (www.lakota-village.de)
PROFESSIONAL AFFILIATIONS
American Chemical Society
American Institute of Chemical Engineers
Association of Environmental Professionals
SELECTED PUBLICATIONS
Fox JP and Pless P, Cost-effectiveness of catalytic oxidation for the control of VOCs and CO
from power generation facilities, to be submitted to Journal of the Air & Waste Management
Association.
Fox JP and Pless P, Fuel and energy penalties associated with catalytic pollution control systems
used in power generation, to be submitted to Power Engineering.
Fox JP, Rose TP, Sawyer TL, and Pless P, Isotope hydrology of a spring-fed waterfall in
fractured volcanic rock, to be submitted to Journal of Hydrology.
Leson G and Pless P, Hemp seeds and hemp oil, in: Grotenhermen F and Russo E (eds),
Cannabis und Cannabinoids, Pharmacology, Toxicology, and Therapeutic Potential, The
Haworth Integrative Healing Press, New York, 2002.
5
Petra Pless, D.Env.
Leson G, Pless P, Grotenhermen F, Kalant H, and ElSohly M, Evaluating the impact of
hemp food consumption on workplace drug tests, Journal of Analytical Toxicology, vol. 25
(11/12), pp. 1–8, 2001.
Pless P, Technical and environmental assessment of thermal insulation materials from fiber
crops, doctoral dissertation in Environmental Science and Engineering, University of
California, Los Angeles, 2001.
Leson G and Pless P, Assessing the impact of THC uptake from hemp oil cosmetics on work-
place drug testing, Report to the Agricultural Research and Development Initiative
(“ARDI”), Morris, MB, 2001.
Leson G and Pless P, Hemp Foods and Oils for Health, Your Guide to Cooking, Nutrition and
Body Care, HempTech, Sebastopol, CA, 1999.
Leson G and Pless P, What variety? Hemp cultivars for Canada, Commercial Hemp, Fall 1998,
pp. 7–8.
Leson G and Pless P, Farming and processing: Technology status, Commercial Hemp, Summer
1998, pp. 5–6.
Center for Waste Reduction Technologies in the American Institute of Chemical Engineers,
Collaborative Biofilter Project, Technical Report, co-author with Leson G of sections
‘Compound Database,’ ‘Design Manual,’ and ‘Literature Database,’ 1998.
Hantke B, Domany I, Fleischer P, Koch M, Pless P, Wiendl M, and Melzer M, Depth profiles of
the kinetics of phosphatase activity in hardwater lakes of different trophic level, Arch.
Hydrobiologia, vol. 135, pp. 451–471, 1996.
Hantke B, Fleischer P, Domany I, Koch M, Pless P, Wiendl M, and Melzer M, P-release from
DOP by phosphatase activity in comparison to P-excretion by zooplankton: studies in
hardwater lakes of different trophic level, Hydrobiologia, vol. 317, pp. 151–162, 1996.
Pless P, Untersuchungen zur Phytoplanktonentwicklung im Herrensee (investigations on
phytoplankton succession in an oligotrophic hardwater lake), Masters Thesis in biology
with focus on botany/ecology/limnology, Technical University of Munich, Germany, 1991.
6
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT 9-202 TEMECULA REGIONAL HOSPITAL
7. Gloria D. Smith, Adams Broadwell Joseph & Cardozo, October 28, 2005.
Response 7-1
This comment provides an introduction to the Adams Broadwell Joseph & Cardozo comments on
the Draft EIR. No response is required.
Response 7-2
The comment provides the commentor’s summary of the proposed project. This comment does
not address an environmental issue or raise any question regarding the analysis or conclusions in
the EIR. No response is required. We note that throughout the letter the commentor merely
expresses narrative argument and unsubstantiated opinion, and does not state facts contrary to the
analysis or conclusions in the EIR. CEQA does not require the City to respond to every narrative
argument and unsubstantiated opinion expressed by the commentor.
Response 7-3
This comment does not address an environmental issue or raise any question regarding the analysis
or conclusions in the EIR. No response is required.
Response 7-4
The comment provides a description of the technical assistance used in the preparation of the
comment letter. All three attachments are included at the end of Letter 7 and are numbered and
responded to below. This comment does not address an environmental issue nor raise any
question regarding the analysis or conclusions in the EIR. No response is required.
Response 7-5
The comment provides a description of the purposes of CEQA. This comment does not address an
environmental issue or raise any question regarding the analysis or conclusions in the EIR. No
response is required.
Response 7-6
As stated on page 2-1 of the Draft EIR, “This EIR meets the content and analysis requirements of a
Project EIR [emphasis added], as defined in Section 15161 of the State CEQA Guidelines. A Project
EIR examines the environmental impacts of a specifi c d e v e l o p m e n t p r o j e c t . T h i s t y p e o f E I R
focuses primarily on the changes in the environment that would result from the development
project. A Project EIR shall examine all phases of the project including planning, construction, and
operation.” Thus, the statement that a Project EIR was not prepared is incorrect. Any reference by
the City to a focused EIR refers to the fact that the Project EIR focuses analysis on those issues
identified in the Initial Study as potentially significant, as permitted by CEQA Guidelines Section
15063(c)(3). The EIR has been revised to delete the use of the term “focused”, so as not to cause
a n y c o n f u s i o n w i t h t h e t e r m “ F o c u s e d E I R ” a s u s e d i n P u b l i c R e s o u r c e C o d e s e c t i o n 2 1 1 5 8 ,
although this Project EIR would qualify as an adequate CEQA document under that section. This
Project EIR was prepared subsequent to the City’s certification of a Program EIR for its General Plan
Update earlier this year. The EIR for the 2005 General Plan Update (GPU) and all supporting
Responses to Comments on the Draft EIR
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT
9-203 TEMECULA REGIONAL HOSPITAL
studies are fully incorporated into the EIR for this hospital project. The GPU contemplated a
regional hospital like this Project.
Therefore, any subsequent references in the subject comment letter to a “focused EIR” are
incorrect. This Project EIR is a “full” EIR in that it fully addresses all applicable areas required by
CEQA.
As required by CEQA Section 15063, the City prepared an Initial Study in March of 2005 to
determine whether the project may have a significant effect on the environment. During this first
level of review, the City determined that all potentially significant impacts could be mitigated and
prepared a draft Mitigated Negative Declaration dated March 4, 2005. The draft Mitigated
Negative Declaration was circulated for public review from March 4, 2005 to April 6, 2005. As a
result of one comment letter received on the draft Mitigated Negative Declaration that raised
questions regarding potentially significant aesthetics, air quality, and traffic impacts, the City
prepared a revised Initial Study and determined that the following issues warranted further analysis
via an EIR: aesthetics, air quality, hydrology and groundwater, land use and planning, noise, and
transportation. Because the prior Initial Study had been circulated for review by public agencies
and the public, with no letters raising any concerns or questions received from any responsible
agencies, the City requested a shortened 30-day review period from the State Clearinghouse. The
State Clearinghouse granted the shortened review period. Thus, the process for ensuring adequate
review of the project and its potential impacts has conformed to CEQA requirements. CEQA does
not define the term “full” EIR as used by the commentor. We presume that by using the term “full”,
the commentor desires analysis of impact areas found as “no significant impact” in the Initial Study.
The City used the Initial Study process, as encouraged and permitted by CEQA, to identify those
issues requiring analysis in the EIR. All other issues are adequately addressed in the Initial Study (see
Appendix A of the Draft EIR.) CEQA does not require that an EIR provide analysis of issues not
identified as significant in the Initial Study. This EIR is procedurally and substantively sufficient, as
explained in the document and supporting studies.
The balance of the comments made in this paragraph are general in nature regarding the adequacy
of the EIR. Each of these general comments is addressed in detail where the detailed comment
arises in the balance of the letter.
Response 7-7
The commentor is incorrect about the proper CEQA procedures followed for this EIR. As noted in
Response 7-6, the subject document is a Project EIR, not a focused EIR. In addition to formal public
hearings before the Planning Commission and City Council, the public and responsible agencies
have had two opportunities to review the potential environmental effects of the project: 1) during
the original Initial Study/draft Mitigated Negative Declaration circulation period of March 4, 2005 to
April 6, 2005 and 2) during the shortened 30-day review period granted by the State Clearinghouse.
The State Clearinghouse, in its letter dated September 26, 2005 granting the shortened review
period, determined that the circumstances presented by the City warranted a 30-day review period
for the Draft EIR.
Responses to Comments on the Draft EIR
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL 9-204
Response 7-8
The commentor is incorrect about the proper CEQA procedures followed for this EIR. See
Responses 7-6 and 7-7. The formal written comment period closed on October 28, 2005. All
persons, organizations, and agencies wishing to comment further on the Draft and Final EIRs may
do so du rin g formal p ublic hearing s before the Planning Commission and City Cou n cil. These
comments and the City’s responses to such oral and written comments will become part of the
project administrative record.
Response 7-9
This comment is a narrative argument, and does not present any facts contrary to the analysis or
conclusions in the EIR. The comment provides several citations regarding the importance of a
consistent project description and states generally, that the EIR does not provide such, nor does the
EIR accurately and completely describe the environmental setting. To the contrary, pages 3-1
through 3-10 of the Draft EIR provide an accurate description of the project and environmental
setting. Each of these general comments is addressed in detail where the detailed comment arises
in the balance of the letter.
Response 7-10
The comment states that the EIR fails to include a detailed construction schedule with the list of
equipment that will be used. The commentor is incorrect. The construction schedule, with a list of
construction equipment and details of the equipment, including horsepower, load factor, and hours
of use per day are included in the Draft EIR as part of the air quality analysis worksheets in
Appendix B. In summary, Appendix B indicates the following schedule:
Phase 1 - Demolition Assumptions
Start Month/Year for Phase 1: Jan '06
Phase 1 Duration: 3 months
Building Volume Total (cubic feet): 54000
Building Volume Daily (cubic feet): 1500
On-Road Truck Travel (VMT): 84
Off-Road Equipment
No. Type Horsepower Load Factor Hours/Day
1 Crushing/Processing Equip 154 0.780 8.0
2 Rubber Tired Dozers 352 0.590 8.0
1 Rubber Tired Loaders 165 0.465 8.0
1 Tractor/Loaders/Backhoes 79 0.465 8.0
Phase 2 - Site Grading Assumptions
Start Month/Year for Phase 2: Apr '06
Phase 2 Duration: 6 months
On-Road Truck Travel (VMT): 18
Responses to Comments on the Draft EIR
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT
9-205 TEMECULA REGIONAL HOSPITAL
Off-Road Equipment
No. Type Horsepower Load Factor Hours/Day
2 Excavators 180 0.580 8.0
1 Graders 174 0.575 8.0
2 Off Highway Tractors 255 0.410 8.0
4 Off Highway Trucks 417 0.490 8.0
2 Other Equipment 190 0.620 8.0
1 Rubber Tired Loaders 165 0.465 8.0
2 Scrapers 313 0.660 8.0
2 Signal Boards 119 0.820 8.0
2 Trenchers 82 0.695 8.0
Phase 3 - Building Construction Assumptions
Start Month/Year for Phase 3: Oct '06
Phase 3 Duration: 51 months
Start Month/Year for Sub Phase Building: Oct '06
Sub Phase Building Duration: 51 months
Off-Road Equipment
No. Type Horsepower Load Factor Hours/Day
1 Concrete/Industrial saws 84 0.730 8.0
2 Cranes 190 0.430 8.0
2 Other Equipment 190 0.620 8.0
1 Rough Terrain Forklifts 94 0.475 8.0
2 Signal Boards 119 0.820 8.0
Start Month/Year for Sub Phase Architectural Coatings: Jul '10
Sub Phase Architectural Coatings Duration: 5.1 months
Start Month/Year for Sub Phase Asphalt: Oct '10
Sub Phase Asphalt Duration: 2.6 months
Acres to be Paved: 13
Off-Road Equipment
No. Type Horsepower Load Factor Hours/Day
1 Off Highway Trucks 417 0.490 8.0
3 Pavers 132 0.590 8.0
5 Paving Equipment 111 0.530 8.0
2 Rollers 114 0.430 8.0
2 Signal Boards 119 0.820 8.0
1 Surfacing Equipment 437 0.490 8.0
The construction schedule included in the Draft EIR was used to analyze the air quality impacts and
to estimate emissions associate with the proposed project. According to the project applicant, the
Responses to Comments on the Draft EIR
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL 9-206
total construction period of 36 months is anticipated to occur over a period of six years. The
anticipated months for construction for each phase of construction indicated in Section 3, Project
Description are correct, but the overall construction period will span approximately six years. No
further detail concerning the construction schedule is necessary for an EIR.
Response 7-11
All of the technical studies referenced in the Initial Study are available for public review at the City
of Temecula Planning Department, including the referenced study. Because potential impacts with
regard to geology and soils were found to be less than significant at the Initial Study level, the cut
and fill analysis in the Draft EIR is included in the Air Quality section. A Conceptual Grading Plan is
available for review at the City of Temecula Planning Department. The City of Temecula typically
provides a copy of a project’s grading plan for review at the Planning Counter, due to the size of
the plans. An actual finalized “grading plan” as submitted prior to construction is not required at
the EIR stage of a project, because it contains detail unnecessary for CEQA review. Furthermore, a
grading plan contains too much detail and is too large to shrink down to an 11 x 17 inch sheet for
inclusion in an Initial Study or EIR. Section 15148 of the CEQA Guidelines indicates that technical
reports may be cited rather than included as part of EIR documentation.
The proposed project is estimated to result in approximately 2,500 cubic yards of export, as the
comment notes. This value was used in the URBEMIS2002 analysis in the proposed project’s air
quality analysis.
Response 7-12
As stated in the Draft EIR, Section 4.5, Noise and the noise technical study (Appendix C of the Draft
EIR), an analysis of the mechanical equipment room noise levels is not currently possible as the
detailed construction design of the room/building is not known and the product details for all the
equipment are not available. However, based on the fact that the room will contain various
mechanical equipment, including pumps, chillers, and boilers, it is anticipated that it could produce
significant impacts at the residential properties unless mitigation is incorporated into the design.
Therefore, the impact is potentially significant. Noise mitigation measure N-1 mitigates for this
potentially significant noise impact. No further analysis is necessary under CEQA.
All other potential impacts associated with the mechanical equipment will be regulated and
mitigated through federal, state, and local laws and policies. Please refer to Response 7-33
regarding air emissions from the mechanical equipment.
Response 7-13
The commentor is incorrect about the CEQA process for this Project. This comment is a narrative
argument, and does not state any facts contrary to the analysis or conclusions in the EIR. Please
refer to Response 7-6 regarding the reasons why the City has prepared this Project EIR examining
the range of potentially significant project effects.
Response 7-14
This comment is a narrative argument, and does not state any facts contrary to the analysis or
conclusions in the EIR. Please refer to Response 7-6 regarding the reasons why the City has
Responses to Comments on the Draft EIR
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT
9-207 TEMECULA REGIONAL HOSPITAL
prepared this Project EIR examining the range of potentially significant project effects. The City of
Temecula used the Initial Study process, as encouraged and permitted by CEQA, to identify those
issues requiring analysis in the EIR. All CEQA issues are adequately addressed either in the text of
the EIR or in the Initial Study, which is part of the EIR (see Appendix A of the Draft EIR).
Response 7-15 through 7-17
These comments are a narrative argument, and do not state any facts contrary to the analysis or
conclusions in the EIR. See Responses 7-6 and 7-14. The City has complied with the requirements
of CEQA regarding preliminary project analysis and review. No responsible agencies raised any
substantial issue of concern during the original Initial Study/draft Mitigated Negative Declaration
review period, and only one public comment letter raised any issues of substance. The City has
prepared an EIR for the project. The so-called “fair argument” standard for EIR preparation only
applies when an agency elects to prepare a negative declaration rather than an EIR. In addition to
certain technical appendices, the following are page citations for the comprehensive environmental
impact analysis found in the Draft EIR: Aesthetics found on pages 4-4 through 4-14, Air Quality
found on pages 4-23 through 4-26, Hydrology and Groundwater found on pages 4-33 through 4-35,
Land Use and Planning found on pages 4-39 through 4-41, Noise found on pages 4-51 through 4-
65, and Transportation found on pages 4-80 through 4-93. It should be noted that the commentor’s
citation to the Remy Thomas publication cites a “Master EIR” section that is not relevant to this
project or the project EIR.
Response 7-18
The City of Temecula acknowledges, as indicated in the comment, that the two known leaking
underground fuel tanks (LUFTs) are located within the proximity of, but not on the project site.
These two LUFTs are: a Chevron station located at 31669 Highway 79 and an ARCO gas station at
44239 Margarita Road. Additionally, a Shell station located at 44260 Redhawk Parkway east of the
Chevron station is known to have a LUFT as well. The City has reviewed publicly available records
for the three LUFTs, including the two identified by the comment. The publicly available records do
not indicate or support the contention that contamination from any of these LUFTs has affected the
subject property at all. Documentation submitted by Shell to the State Regional Water Quality
Control Board indicates that there is no effect on drinking water wells, and that the concentrations
of contaminants near the offsite LUFT locations are actually decreasing.
As part of the public review process for the Initial Study and NOP for the EIR, the State Regional
Water Quality Control Board did not provide any comments and did not state that groundwater
contamination is of concern for this project. Remediation of the LUFTs is the responsibility of the
property owners on which the contamination originates, and all such remediation must occur in a
timely manner and pursuant to state and federal regulations.
In any event, the existence of the off site LUFTs does not pose a CEQA-related impact for this
Project. This Project does not introduce any LUFTs into the environment, nor does it include the
environmental remediation of soil or groundwater, as no such hazards have been identified to exist
on the project site. Thus, as concluded in the Initial Study, environmental impact will be less than
significant.
Responses to Comments on the Draft EIR
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL 9-208
Response 7-19
This comment is a narrative argument and expresses unsubstantiated opinion, and does not state
any facts contrary to the analysis or conclusions in the EIR. The comment references the City’s
General Plan EIR with regard to new development on contaminated property, but ignores the fact
that the project site is not a contaminated property. The comment does not provide any facts that
the nearby LUFTs present any health risks to workers or patients related in any way to the proposed
Project. At the Chevron station (31669 Highway 79), only monitoring is in place, and no
remediation is currently implemented.3 At the Arco station (44239 Margarita Road), both
monitoring and remediation in the form of groundwater extraction and treatment are currently in
place. Moreover, the Arco station has a permit to discharge to surface water.4 Both of these gas
stations have a methyl tert-butyl ether (MTBE) threat classification of B – second highest priority,
meaning that the LUFTs contamination is not affecting the nearby drinking wells. The extent of the
Shell station contamination is currently unknown because extensive monitoring has not occurred.
While the Shell station currently has a MTBE treat classification of A, meaning a potential threat to
drinking wells exists, monitoring and remediation in the form of groundwater extraction and
treatment are in place.5 Documentation submitted by Shell to the State Regional Water Quality
Control Board indicates that there is no effect on drinking water wells, and that the concentrations
of contaminants near the offsite LUFT locations are actually decreasing. The Rancho California
Water District, as required by state and federal law, continuously monitors groundwater conditions
to ensure state and federal drinking water standards are met. As stated in Response 7-18 and in the
City’s General Plan EIR, remediation of contaminated sites is the responsibility of the site owner and
is subject to state and federal regulations.
Response 7-20
This comment does not state any facts contrary to the analysis or conclusions in the EIR. The
proposed project will connect to the municipal water supply via the Rancho California Water
District’s connections. The City’s evaluation did not determine and the commentor has not
provided any factual evidence that the nearby LUFTs present any risks to the municipal water
supply. Even so, leaks from offsite LUFTs do not pose CEQA impacts resulting from this project.
The proposed project will connect to a municipal water system, as noted above in Response 7-19,
RCWD ensures that public water supplies comply with drinking water standards.
The State Regional Water Quality Control Board has been monitoring progress of the remediation
of the Shell station and has not identified contamination extending to the Project site. If, as a result
of its ongoing investigations, documentable evidence arises that a plume extends beneath the
Project site to an extent that would likely cause the need to guard against vapor release during
Project grading operations, the applicant will undertake precautionary actions consisting of
monitoring and installation of any necessary barriers if needed.
3 http://geotracker.swrcb.ca.gov/reports/luft_risk.asp?global_id=T0606599286&assigned_name=MAINSIT. Date accessed:
November 10, 2005.
4 http://geotracker.swrcb.ca.gov/reports/luft.asp?global_id=T0606599255&assigned_name=MAINSIT. Date accessed:
November 10, 2005. 5http://geotracker.swrcb.ca.gov/reports/luft_risk.asp?global_id=T0606597082&assigned_name=MAINSITE. Date accessed:
November 10, 2005.
Responses to Comments on the Draft EIR
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT
9-209 TEMECULA REGIONAL HOSPITAL
The remainder of this comment expresses unsubstantiated opinion, and does not state any facts
contrary to the analysis or conclusions in the EIR. The project does not contemplate any significant
excavation. The commentor has not provided any evidence that the nearby LUFTs present any risks
of contaminant exposure to construction workers, the hospital staff, or patients.
Response 7-21
The comment is incorrect; the Initial Study analyzed seismic and earthquake related issues,
including liquefaction. The Initial Study, Appendix A of the Draft EIR, states that the proposed
project is 1.6 miles from the Temecula segment of the Lake Elsinore Fault. The PSI, Inc.
Geotechnical Exploration Report, Proposed Temecula Hospital (May 14, 2004) referenced in the
Initial Study was prepared for the proposed project. The City of Temecula requires that all
developments comply with the standards of the Uniform Building Code; thus, the proposed project
will be constructed according to the Uniform Building Code’s standards with regard to seismic
hazards for the appropriate groundshaking zone. Furthermore, as a hospital, the project will be
constructed to stringent seismic standards. Specifically, the Project’s design must be reviewed and
approved by the California Office of Statewide Health Planning and Development (OSHPOD) to
assure compliance with the Hospital Seismic Safety Act (Health and Safety Code Sec 129675 et.
seq.).
Response 7-22
A s s t a t e d o n p a g e 3 - 8 o f t h e D r a f t E I R , “ W h ile the overall project must comply with the
requirements of the City Planning Department, the building requirements for the hospital buildings
are under the sole control of the State of California, Office of Statewide Health Planning and
Development. As a result, to the extent required by law all references in the EIR with respect to
building and occupancy permits are intended to apply only to the non-hospital facilities.“
Furthermore, on page 3-9 of the Draft EIR, the City recognizes the fact that the California Office of
Statewide Health Planning and Development will approve the hospital building and occupancy
permits. Compliance with existing regulations addresses any potential impact.
Response 7-23
This comment does not state any facts contrary to the analysis or conclusions in the EIR. In the
Initial Study, seismic and other geology-related impacts are identified as less than significant due to
required compliance with a stringent set of conditions of approval stated at pages 16 and 17 of the
Initial Study. Moreover, the project must comply with the Hospital Seismic Safety Act which
requires that the project design be evaluated and approved for seismic safety by OSHPOD. Thus,
per CEQA Section 15063(c)(3), no further analysis is required in the EIR.
Response 7-24
The comment is incorrect. The PSI, Inc. Geotechnical Exploration Report, Proposed Temecula
Hospital (May 14, 2004) referenced in the Initial Study was prepared for the proposed project and
addressed liquefaction issues. The geotechnical report confirmed that the project site is located in a
mapped liquefaction zone and has a moderate risk potential for soil liquefaction. As required by
the City’s conditions of approval for the proposed project, the geotechnical report provides
recommendations for the structural design to address liquefaction and standard practices of the
Structural Engineers Association of California also will be required by the City. These standard
Responses to Comments on the Draft EIR
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL 9-210
practices to address known conditions are identified in the Initial Study, with the conclusion that
impact will be less than significant. Thus, per CEQA Section 15063(c)(3), no further analysis is
required in the EIR.
Response 7-25
This comment is a narrative argument and expresses unsubstantiated opinion, and does not state
any facts contrary to the analysis or conclusions in the EIR. In the last two sentences, the comment
states that the regulatory setting information for the California PM10 s t a n d a r d i n t h e E I R w a s
inaccurate. The federal standard is Annual Arithmetic Mean (AAM) PM10 > 50 µg/m3 and the state
standard for California is AAM PM10 > 20 µg/m3, which replaced Annual Geometric Mean (AGM)
PM10 > 30 µg/m3 effective July 5, 2003. Table 4-1, Air Pollution Sources, Effects, and Standards, is
hereby revised to correct the inaccuracy regarding the California PM10 standard, as indicated on the
following page.
Response 7-26
The comment letter states that the EIR should be revised to include PM2.5 emissions estimations.
The South Coast Air Quality Management District (SCAQMD) adopted its CEQA Air Quality
Handbook in 1993 to assist other public agencies with the preparation of air quality analyses. The
SCAQMD recommends that the Lead Agency use this Handbook as guidance when preparing air
quality analysis. The SCAQMD last revised the CEQA Air Quality Handbook in November 2001
(Version 3). The Handbook does not include requirements for modeling PM2.5 emissions or list
thresholds to be analyzed within CEQA, nor does the URBEMIS2002 program model PM2.5
emissions. The California Air Resources Board (CARB) does not currently have 24-hour standards
for PM2.5. The nearest air quality monitoring station to Temecula, the Lake Elsinore station, does not
currently monitor for PM2.5, and thus no information is available regarding baseline PM2.5 conditions.
Further, the CARB-approved URBEMIS2002 Model used to model air quality for this project does
not model or otherwise consider PM2.5. Therefore, PM2.5 emissions were not calculated for the
proposed project.
Finally, the comment does not provide any facts indicating that the project will generate PM2.5 in
quantities sufficient to represent a risk to air quality or human health.
Response 7-27
This comment does not state any facts contrary to the analysis or conclusions in the EIR. The
comment letter states that the EIR should be revised to include a health risk assessment. Because
the State of California Air Resources Board (ARB) identified particulate matter from diesel-fueled
engines as a toxic air contaminant, the SCAQMD Governing Board Mobile Source Committee
directed SCAQMD staff to assess the health risks from truck stops and warehouse distribution
centers. Guidance for preparing health risk assessments was prepared by SCAQMD in August
2002, titled Health Risk Assessment Guidance for Analyzing Cancer Risks from Mobile Source Diesel
Idling Emissions for CEQA Air Quality Analysis. According to this guidance, health risk assessments
are recommended for projects with diesel-powered mobile sources, including the following
activities: truck idling and movement (such as, but not limited to, truck stops,
warehouse/distribution centers or transit centers), ship hotelling at ports, and train idling. The
proposed project does not propose major sources of diesel powered mobile sources during project
operations. Therefore, a health risk assessment is not warranted. Furthermore, Table 4-1, the Air
Responses to Comments on the Draft EIR
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT
9-211 TEMECULA REGIONAL HOSPITAL
Pollution Sources, Effects, and Standards, is hereby revised because the primary effects column
describes the potential health risks from criteria air pollutants.
Table 4-1
Air Pollution Sources, Effects, and Standards
Air
Pollutant State Standard
Federal Primary
Standard Sources Primary EffectsPotential Health Risks
Ozone
(O3)
0.09 ppm, 1-hour
average
0.12 ppm, 1-hour
average; 0.08
ppm, 8-hour
average
Atmospheric reaction of
organic gases with nitrogen
oxides in sunlight.
Aggravation of respiratory and
cardiovascular diseases; irritation of eyes;
impairment of cardiopulmonary function;
plant leaf injury.
Carbon
Monoxide
(CO)
9.0 ppm, 8-hour
average; 20 ppm, 1-
hour average
9.0 ppm, 8-hour
average; 35 ppm,
1-hour average
Incomplete combustion of
fuels and other carbon-
containing substances such
as motor vehicle exhaust;
natural events, such as
decomposition of organic
matter.
Reduced tolerance for exercise;
impairment of mental function;
impairment of fetal development;
death at high levels of exposure;
aggravation of some heart diseases
(angina); reduced visibility.
Nitrogen
Oxides
(NOX)
0.25 ppm, 1-hour
average
0.053 ppm, annual
average
Motor vehicle exhaust;
high-temperature stationary
combustion; atmospheric
reactions.
Aggravation of respiratory illness; reduced
visibility; reduced plant growth; formation
of acid rain.
Sulfur
Dioxide
(SO2)
0.25 ppm, 1-hour aver-
age; 0.05 ppm, 24-hour
average with ozone > =
0.10 ppm, 1 hour
average or TSP > = 100
µg/m3, 24-hour average
0.03 ppm, annual
average; 0.14
ppm, 24-hour
average
Combustion of sulfur-
containing fossil fuels;
smelting of sulfur-bearing
metal ores; industrial
processes.
Aggravation of respiratory diseases
(asthma, emphysema); reduced lung
function; irritation of eyes; reduced
visibility; plant injury; deterioration of
metals, textiles, leather, finishes, coatings,
etc.
Respirable
Particulate
Matter
(PM10)
30 20 µg/m3, annual
geometric mean; > 50
µg/m3, 24-hour average
50µg/m3, annual
arithmetic mean;
150 µg/m3, 24-
hour average
Stationary combustion of
solid fuels; construction
activities; industrial
processes; industrial
processes, atmospheric
chemical reactions.
Reduced lung function; aggravation of the
effects of gaseous pollutants; aggravation
of respiratory and cardio-respiratory
diseases; increased coughing and chest
discomfort; soiling; reduced visibility
Fine
Particulate
Matter
(PM 2.5)
No Separate State
Standard
65 µg/m3, 24-hour
average; 15 µg/m3
annual arithmetic
mean
Combustion sources such as
automobiles, trucks, and
stationary sources;
atmospheric chemical
reactions.
Increased mortality; reduced lung
function; aggravation of the effects of
gaseous pollutants; aggravation of
respiratory and cardio-respiratory
diseases; increased coughing and chest
discomfort.
Lead 1.5 µg/m3, 30-day
average
1.5 µg/m3,
calendar quarter
Contaminated soil. Increased body burden; impairment of
blood formation and nerve conduction;
behavioral and hearing problems in
children.
Visibility
Reducing
Particles
Sufficient to reduce
visual range to less
than 10 miles at
relative humidity less
than 70%, 8-hour
average (9am - 5pm)
None Visibility impairment on days when
relative humidity is less than 70 percent.
µg/m3 = micrograms per cubic meter of air; ppm = parts per million parts of air, by volume.
Source: South Coast Air Quality Management District. CEQA Air Quality Handbook. November 2001 (Version 3) update.
Responses to Comments on the Draft EIR
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL 9-212
Response 7-28
This comment expresses unsubstantiated opinion, and does not state any facts contrary to the
analysis or conclusions in the EIR. The comment speculates that the EIR might have underestimated
construction emissions, particularly PM10. The commentor is incorrect. Refer to Responses 7-29
through 7-31 for responses to more specific comments associated with construction emissions.
Response 7-29
The comment is incorrect concerning the construction schedule. See Response 7-10. The
comment expresses unsubstantiated opinion that the estimates in the EIR are not accurate. The
comment further states that the construction time is portrayed differently in Section 3.0, Project
Description, than what was modeled in Section 4.2, Air Quality, of the EIR. Refer to Response 7-10
for a discussion of the construction schedule.
Response 7-30
This comment expresses unsubstantiated opinion that construction emissions estimates “may [be]
substantially underestimate[d]”, and does not state any facts contrary to the analysis or conclusions
in the EIR. The comment letter states that the air quality emissions modeling in the EIR did not
represent worst-case conditions because the modeling used default values. The default values are
estimates for an average project with similar land uses. To estimate fugitive dust emissions,
URBEMIS2002 estimated emissions in the default level by multiplying the default emissions rate by
the maximum acreage disturbed per day, provided in the program as 35.31 acres for the total
project site or 11.77 acres to be disturbed per day. The defaults are programmed into the model to
estimate emissions when all information is not available. Since more detailed information was not
available, the defaults were appropriately used to model air quality emissions to be generated by
the proposed project. Further, the City is not obligated to analyze a speculative worst case
scenario.
URBEMIS2002 estimated eight hours of construction activity per day. Section 4.5, Noise, described
a range in time provided in the City of Temecula Municipal Code (Section 8.32.020) which limits
construction to between the hours of 6:30 A.M. and 6:30 P.M., Monday through Friday, 7:00 A.M.
and 6:30 P.M. on Saturday, and never on Sunday or holidays. The air emissions modeling was
conducted for an eight-hour period within the 6:30 A.M. and 6:30 P.M. time range. The City of
Temecula Municipal Code only exempts construction activity rather than dictates when such
activity will take place. Construction activity is anticipated to result in a maximum of eight hours of
emissions production during each day of grading, which is a standard average for a construction
work day. Moreover, the commentor has not provided any evidence that the model default values
in the URBEMIS2002 Model are incorrect. Therefore, no change to the air quality modeling is
warranted.
Response 7-31
This comment expresses unsubstantiated opinion that wind erosion during construction “can be a
substantial contributor to fugitive dust from construction sites.” This comment does not state any
facts contrary to the analysis or conclusions in the EIR. Specifically, the comment states that the air
Responses to Comments on the Draft EIR
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT
9-213 TEMECULA REGIONAL HOSPITAL
quality model did not estimate emissions resulting from track-out and wind erosion. As stated in the
comment, URBEMIS2002 program does not calculate emissions created by wind erosion or track-
out. Fugitive dust emissions are emitted over large surface areas. Modeling wind-derived emissions
makes their quantification inherently less accurate than actual tests conducted on stacks or other
ducts through which effluents are ejected into the air. Track-out is also a source of air pollution that
is monitored on site only during construction activities, rather than modeled from computer-based
programs and estimated previous to construction activities. Therefore, the EIR did not include
modeling for track-out or wind erosion emissions. However, mitigation measures AQ-4, AQ-6, AQ-
7, and AQ-11 in the EIR minimize emissions resulting from wind erosion or track-out.
Response 7-32
The comment letter suggests that the EIR underestimated operational emissions. The comment
states unsubstantiated opinion that “the NOx significance threshold will likely be exceeded” and
PM10 emissions “may exceed the SCAQMD’s significance threshold”. Refer to Responses 7-33
through 7-38 for responses to more specific comments associated with operational emissions.
Response 7-33
The comment expresses unsubstantiated opinion that NOx emissions “may result in exceedance of
the NOx significance threshold”. This comment does not state any facts contrary to the analysis or
conclusions in the EIR. The comment letter states that the operational emissions estimates omitted
emissions from helicopter use, cooling towers, emergency generators, and boilers. According to the
Software User’s Guide: URBEMIS2002 for Windows with Enhanced Construction Module prepared
by Jones and Stokes (April 2005), fuel combustion emissions from water and space heating is
estimated in the program per SCAQMD CEQA Handbook. Since information regarding the
frequency of helicopter use was not available, it was estimated that the use of a helicopter to
transport patients will most likely be an infrequent use (on average once per month, although the
Caltrans permit allows up to six occurrences per month), and therefore, the EIR does not include an
analysis of emissions from helicopters. Also, the Initial Study stated that heaters, air conditioners,
and other types of similar equipment (i.e. cooling towers, generators, and boilers) would not
generate a substantial amount of emissions; consequently, they were not analyzed in the EIR. Also,
such equipment will be subject to SCAQMD regulation for emissions control. Please refer to
Response 7-37 regarding emissions attributed to use of electricity, such as the cooling towers,
emergency generators, boilers, and the Heating, Ventilating, and Air-Conditioning system.
Response 7-34
The comment letter states that the air quality modeling did not correctly analyze emissions from
natural gas usage. The comment also states that the default values provided in the URBEMIS2002
model do not calculate emissions associated with natural gas usage, specifically for hospital uses.
The URBEMIS2002 program estimated 566,160 square feet of hospital and medical uses. The
hospital land use is described in the Software User’s Guide: URBEMIS2002 for Windows with
Enhanced Construction Module (Jones and Stokes, April 2005) as any “institution where medical or
surgical care is given to non-ambulatory and ambulatory patients and overnight accommodations
are provided”, and medical office uses are described as medical office buildings that “provide
diagnoses and outpatient care.” These uses are a correct interpretation of the uses analyzed in the
EIR. These are also the land uses URBEMIS2002 estimated for natural gas usage.
Responses to Comments on the Draft EIR
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL 9-214
As shown in Table RTC-1 below, natural gas emissions were conducted for the project. All area
source emissions, including natural gas emissions resulting from the proposed project, are shown
individually.
Table RTC-1
Operational Phase Regional Emissions for Area Source Emissions (in pounds per day)
Pollutants (lbs/day)
Emissions Source ROG NOx CO PM10 SO2
Natural Gas 0.27 3.77 3.17 0.00 0.01
Hearth-No summer emissions 0.00 0.00 0.00 0.00 0.00
Landscaping 0.18 0.02 1.26 0.00 0.00
Consumer Products 0.00 -- -- -- --
Architectural Coatings 7.93 -- -- -- --
Total Area Source Emissions 8.39 3.79 4.43 0.00 0.01
Source: P&D Consultants in August 2005 using the URBEMIS2002 emissions inventory model.
Response 7-35
The comment letter states that the air quality analysis used an incorrect target year for operational
emissions. The phasing of the project and the detailed construction schedule provided by the
project applicant shows a completion date of December 2012. However, URBEMIS2002 only
allows construction for up to 60 months, or through to December 2010. Year 2010 was also
inserted into the program as the target year used for operational traffic. Both the target year and
the completion of construction were consistent. Therefore, NOx emissions estimations represented
an accurate construction schedule. Refer to Response 7-10 for a discussion of construction
schedule timing. Additionally, using a 60-month overall construction schedule analyzes a “worst-
case scenario” because air emissions would be more conservative with a shorter construction
schedule. Therefore, if the URBEMIS2002 allowed for a longer time frame for the construction
schedule beyond five years (60 months), then the air emissions would be greater compared to
those calculated in this EIR.
Response 7-36
The comment letter states that the EIR underestimated traffic emissions by using a lower trip
generation rate for a regional hospital use. The air quality modeling relied on defaults inherent in
the URBEMIS2002 program. The trip generation rates used in the air modeling were generalized
trip rates from the Institute of Transportation Engineers (ITE) Trip Generation Rate Manual, Seventh
Edition, 2003 for hospital and medical office uses. Refer to Response 7-48 for a discussion of the
trip rates used in the traffic analysis.
Response 7-37
The comment letter states that the EIR did not fully analyze secondary emissions from electricity
generation. As stated in the EIR, emissions from electricity generation are considered to be regional
in nature. Emissions attributed to use of electricity generated by individual projects are not easily
quantified due to the variety and diverse locations of sources that supply electricity. Electricity
provided to the site via regional suppliers could be generated almost anywhere in California or even
Responses to Comments on the Draft EIR
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT
9-215 TEMECULA REGIONAL HOSPITAL
out of state. Completing an analysis as suggested by the commentor would be purely speculative in
nature. Every power plant in California is required to analyze impacts per CEQA and is subject to
emissions controls applicable to the air basin in which it is located. Therefore, electrical generation
emissions associated with the proposed project were not quantified. No additional analysis is
necessary.6
Response 7-38
The comment letter states that the air quality analysis did not identify increased ozone formation
due to urban heat island effect. The term "heat island" refers to urban air and surface temperatures
that are higher than nearby rural areas (United States Environmental Protection Agency,
http://www.epa.gov/heatisland/about/index.html, accessed November, 2005). Currently the
SCAQMD does not recognize ozone formation due to urban heat island effect as an impact that
requires analysis in a CEQA document. Therefore, no additional analysis is necessary.7 We further
note that the proposed project would not result in exceedances of thresholds for NOx emissions
during the operational phase of the project, and includes mitigation measure AQ-3 to incorporate
energy efficient standards for hospital and medical uses.
Response 7-39
The Project is subject to regulation under the National Pollution Elimination System (NPDES)
General Permit No. CAS000002 for Storm Water Discharges Associated with General Construction
Activity (General Construction Permit) Water Quality Order 99-08-DWQ. The Provisions of the
General Construction Permit require the implementation of Best Management Practices (BMPs) to
control and abate the discharge of pollutants in storm water discharges both during and after
construction, including measures to prevent phosphorous contamination into waterways. The City
Urban Storm Water discharges are regulated through the Municipal Separate Storm Sewer System
permit (Order No. R9-2004-001) (Hereinafter “Municipal Permit”). This permit requires that the City
impose conditions on the project to assure that any water quality impacts are minimized to the
Maximum Extent Possible. Together, these two regulatory schemes will reduce any environmental
impacts from the Project’s storm water discharges to below a level of significance.
Water quality impacts will be less than significant as a result of compliance with standard City
practices and regulations, enforced through conditions of approval that implement the City’s
NPDES permit. Construction-phase and post-construction BMPs will be designed and included into
plans for submittal to, and subject to the approval of, the Director of Public Works prior to issuance
of a grading permit. The project proponent will also provide proof of a mechanism to ensure
ongoing long-term maintenance of all structural post-construction BMPs. No additional impact
analysis is required with regard to water quality.
Response 7-40
This comment does not state any facts contrary to the analysis or conclusions in the EIR. The
comment speculates that flooding “can contribute urban contaminates to the creek.” To the extent
the commentor implies that an analysis of creek-bed contaminants related to offsite flooding is part
6 Koizumi, James. Air Quality Specialist. Pers. Comm. on November 17, 2005. South Coast Air Quality Management
District.
7 Koizumi, James. Air Quality Specialist. Pers. Comm. on November 17, 2005. South Coast Air Quality Management
District.
Responses to Comments on the Draft EIR
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL 9-216
of this project, the commentor is incorrect. As indicated in the Initial Study (Appendix A of the
Draft EIR), the proposed project will result in a less than significant impact with regard to
substantially altering the existing drainage pattern in the area resulting in substantial erosion or
siltation on or off site, or increase the amount of surface runoff that would result in flooding on- or
off-site; and exposing people or structures to a significant risk of loss, injury, or death involving
flooding or inundation. The flooding impacts from the proposed project are less then significant;
therefore, no additional analysis or mitigation is required. For a further discussion of water quality
impacts of the project to surface waters, see Response 7-39.
Response 7-41
The General Construction Storm Water Permit requires that a Storm Water Pollution Prevention
Plan (SWPPP) and a Monitoring and Reporting Plan be prepared prior to the commencement of
“land disturbing activities “. The City will require as a condition of approval that the project
applicant will prepare a SWPPP and file a Notice of Intent to Comply (NOI) with the General
Construction Permit prior to any land disturbing activities.
The Municipal Permit requires the City to require the project applicant to prepare a post
construction storm water management plan. The post construction storm water management plan
addresses post construction storm water impacts and mitigates those impacts to a level below
significance.
The comment misstates the testing requirements of the General Construction Permit. The permit
only requires testing related to 303(d) impaired water bodies when those water bodies are impaired
by silt or sediment. Murrieta Creek and the Santa Margarita River are not impaired by silt or
sediment. The project is conditioned to comply with all appropriate monitoring and reporting
requirements of the General Construction Permit.
Please refer to Response 7-39 regarding compliance with NPDES requirements. The project
proponent, as indicated in the EIR on page 4-31 of the Draft EIR, provided a preliminary hydrology
and drainage analysis identifying that indicated project runoff will drain in two directions. As stated
on page 4-31, “New development projects are required to provide on-site drainage and to pay area
drainage fees per acre of development. Drainage fee revenues are used to support capacity
expansion within the local storm drain system.” Additionally, the project proponent will be required
to submit a final, engineered drainage study, prepared by a registered civil engineer in accordance
with City standards, to identify storm water runoff expected from this site. The study shall identify
all existing or proposed public or private drainage facilities intended to discharge this runoff. The
study will identify any specific improvements required consistent with County Area Drainage Plans
to achieve appropriate storm water control. Fees will be paid per existing requirements. The
submittal of the detailed drainage study will be enforced through the conditions of approval set
forth by the City.
Response 7-42
This comment does not state any facts contrary to the analysis or conclusions in the EIR. The
commentor is fundamentally incorrect about the Water Supply Assessment, which was prepared
and provided by the serving agency, the Rancho California Water District (RCWD). The comment
incorrectly states that the Water Supply Assessment (WSA), Appendix G of the Draft EIR, prepared
by the RCWD fails to comply with the requirements of the California Water Code Section 10910
Responses to Comments on the Draft EIR
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(also known as S.B. 610). Pursuant to Section 10910(g)(b), the City approved the Water District’s
WSA for the Draft EIR. The 2000 Urban Water Management Plan and the 2005 Water Facilities
Master Plan were referenced in the WSA and provide a detailed description of the RCWD’s
groundwater basin from which the proposed project will be supplied. Furthermore, both plans
account for the water demand of the proposed development. As stated on page 6 of the WSA, the
2005 Water Facilities Master Plan estimates a demand of 129,545 acre feet per year for 2025 and
the projected water demand for the proposed project is 42 acre feet per year. The City concludes
that the WSA provided by the RCWD fully complies with California Water Code Section 10910.
The City further acknowledges that the RCWD has relied on groundwater pumping and recharging
for years, and has addressed the SB 610 requirements in that regard. The RCWD has appropriately
determined that the WSA has sufficient water supply for the project. See, RCWD SB610 Water
Supply Assessment in Support of the Temecula Medical Center, City of Temecula, dated August 29,
2005, at EIR Appendix G.
Responses 7-43
This comment expresses unsubstantiated opinion, and does not state any facts contrary to the
analysis or conclusions in the EIR. No response is required.
Response 7-44
This comment expresses unsubstantiated opinion, and does not state any facts contrary to the
analysis or conclusions in the EIR. The baseline condition to which project traffic is added includes
traffic from 17 cumulative projects which will be built over the next several years. The traffic study
assumes the project will be built in two broad phases rather than incrementally (described on page
3-7 of the EIR and indicated on the site plan as five phases). This approach to the analysis allows for
mitigation to be defined and required early on for the second broad phase, which results in a
condition whereby the full impact of project traffic occurs sooner than assuming the project would
be constructed incrementally in five phases. Phase I, consisting of Phases IA and IB described on
page 3-7, consists of related project buildings: the first medical office building and hospital tower.
The second broad phase includes the second hospital tower, the second medical office building,
and the cancer center and rehabilitation facility, all of which are related facilities. Full project
mitigation will be required earlier with this phasing.
Response 7-45
Basing the trip generation for a hospital on the number of beds is the standard of practice in
preparing traffic studies. Beds is listed as an independent variable in the Institute of Transportation
Engineers (ITE) Trip Generation Manual and the SANDAG “San Diego Traffic Generators”
publication (April 2002). Some of the hospitals that were surveyed to determine the trip rate include
many other facilities in addition to the hospital itself, such as fitness centers, cancer centers and
cafeterias. The traffic generated by these other facilities are included in the overall hospital trip rate
since the rate is established by placing road tubes at project driveways and these tubes capture all
traffic even if the destination is not the hospital itself.
In addition, although the ITE trip rate for hospitals is only 11.81 Average Daily Trips (ADT) per bed,
a rate of 20 per bed (based on the SANDAG publication) was utilized to be very conservative. The
SANDAG rate is based on a survey of only one hospital while the ITE rate is based on surveys at 20
hospitals. Therefore, even though the ITE rate (11.81) was considered more credible than the
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SANDAG rate (20.0) based on the larger sample size, the very conservative SANDAG rate was
utilized. The hospital trip generation that was utilized results in 2,620 ADT more ADT than if the ITE
rate was used. The trip generation in the study overstates the amount of traffic the site will generate.
Finally, the Cancer Center and Fitness Center generate only a nominal amount of traffic (less than
500 ADT) due to the day-to-day operations of these facilities. So even if 500 ADT was added, since
the hospital trip generation is already 2,600 ADT overstated, the actual amount of overall traffic
would still be less than the amount analyzed in the traffic study.
Response 7-46
This comment expresses argument and unsubstantiated opinion, and does not state any facts
contrary to the analysis or conclusions in the EIR. No response is required
Response 7-47
The comment incorrectly correlates parking supply to trip generation. As explained in the Draft EIR
on page 3-8, hospitals facilities typically exceed minimum parking requirements. Visitors to hospital
facilities tend to remain at the facility longer than typical commercial or professional uses like retail
establishments. No credit was taken for staff using public transit to reach the facilities. The
comment letter provides no evidence that the City parking code for hospitals does not account for
staff. City code requirements include parking for all types of users of a parking facility.
The second paragraph of this comment expresses argument and unsubstantiated opinion, and does
not state any facts contrary to the analysis or conclusions in the EIR.
Response 7-48
The comment reflects misconceptions about trip generation rates for hospitals as it relates to
number of beds and square footage. As California hospital service providers continue to remodel
and build facilities to accommodate future service demands, there are four trends affecting the
relationship among space, beds, and traffic.
Space, Beds and Privacy
Hospitals built in the 1950s, ‘60s and ‘70s were primarily built for double occupancy rooms. In
addition, many also had “wards” or rooms that would hold six of more beds. Wards were often
used for peak demand days or to isolate a potentially contagious disease.
Double occupancy rooms were accepted by the market and considered to be the norm by most
insurance providers. Yet any patient would tell you that a single occupancy room provided the
privacy that families preferred. In 1980s, hospital architecture nation-wide began to respond to this
market preference. Today, single occupancy rooms are the design of choice for all new hospitals.
The double occupancy room is a rare exception.
The space implication of this trend is increased square footage per bed. In addition to increasing
circulation space on a per bed basis, each room requires a bathroom. Whereas a double-occupancy
room shared a bathroom between two patients, single-occupancy rooms dedicate a bathroom to
each patient.
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Space, Beds and Infection Control
Providing a separate bathroom for each patient is also an important improvement in infection
control. A separate bathroom eliminates any potential for infection transmission between patients
using the same bathroom.
Space, Beds, Acuity, and Equipment
During the last 20 years of health care reform in America, the managed care system has successfully
worked to decrease both the number of days a patient would stay in a hospital and the kinds of
cases that might warrant an over-night stay. An increasing number of low-acuity cases have been
transitioned out of the hospital environment and into an outpatient clinic environment.
The result is that today’s hospital bed serves a much sicker patient. A high-acuity patient needs more
support technology at the bedside. The list of additional equipment begins with a respiratory
monitor with pumps, IV poles, specialty medical gas support, and other mobile equipment rolled in
on a case-by-case basis. The space implication of this trend is increased square footage per bed.
Space, Beds, and Staffing
According to the project applicant, for over 20 years there has been a decline in nursing staff in
America. The response to this skilled labor shortage has included:
Steps to increase the desirability of nursing as a career, including increasing salaries, benefits
and tuition support;
Redesigning the job of the Registered Nurse to shift certain lower skilled tasks to lower
skilled employees; and
Replacing manual tasks with automated processes in order to reduce labor demands per
bed, examples include more automated records, charts and billing systems.
Between the economics of health care reimbursements and the shortage of nursing staff, the end
result is that staffing levels do not increase simply because square footage increases.
An increase in square footage is not the correct indicator to use to evaluate an increase in ADT for
the reasons stated above. The correct indicator to use is the increase in the number of beds. In
addition, please see Response 7-45/7-46 for a discussion regarding the use of a trip rate of 20 ADT
per bed as opposed to the ITE rate of 11.81 ADT per bed.
Response 7-49
Please refer to Response 7-45.
Response 7-50
The best indicator of traffic generation for a hospital is the number of beds. Please refer to
Responses 7-45 and 7-48.
Response 7-51
This comment is similar to 7-50 except that it discusses project build out, not Phase I. Please refer
to Response 7-50.
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Response 7-52
The comment provides the commentor’s definition of CEQA mitigation measures. This comment
does not address an environmental issue or raise any question regarding the analysis or conclusions
in the EIR. No response is required.
Response 7-53
This comment expresses argument and unsubstantiated opinion, and does not state any facts
contrary to the analysis or conclusions in the EIR. As stated in CEQA guideline 15126.4 (a) (2),
“mitigation measures must be fully enforceable through permit conditions, agreements, or other
legally binding instruments.” All of the mitigation measures contained in the EIR are fully
enforceable and will require future legal action or compliance and proof will be shown in the
Mitigation Monitoring and Reporting Program (MMRP). Mitigation measures are not required for
water quality, geology and soils, or parking, as determined in the Initial Study and Draft EIR. Also,
the project permittee will be required to comply with all existing and applicable federal, state, and
City of Temecula laws and regulations enforced through the project conditions of approval. The
unavoidable significant impacts are addressed in the proposed Statement of Overriding
Considerations.
Response 7-54
The commentor is incorrect. The comment letter suggests that the EIR did not provide adequate
and feasible mitigation measures to reduce air quality and public health impacts. These mitigation
measures referenced in the comment as measures AQ-1, AQ-2, AQ-4, AQ-6, and AQ-7 in Section
4.2, Air Quality require that the project developer provide, for example, a detailed construction
traffic plan and watering plan. These plans typically are prepared once a project concept is
approved and detailed project plans are prepared. Typical performance measures include
compliance with SCAQMD regulations for dust control and City standards for construction traffic
management. These plans when reviewed and approved by the City and other responsible
agencies, and when implemented will reduce environmental impact. Completion of these plans will
be reviewed by the City, with coordination with other jurisdictions and compliance with SCAQMD
Rule 403 required. Additionally, compliance with these measures and the completion of the plans
must be verified in the Mitigation Monitoring and Reporting Program (MMRP), per CEQA
requirements. As stated in CEQA Guidelines Section 15126.4(a)(2), “mitigation measures must be
fully enforceable through permit conditions, agreements, or other legally binding instruments.” The
above-referenced mitigation measures are fully enforceable and will require future legal action or
compliance and proof will be shown in the MMRP. Therefore, the mitigation measures listed in the
comment are adequate to mitigation air quality impacts, as stated in the measures.
Response 7-55
The mitigation measures do provide further guidance for standards of compliance. For example,
AQ-5 indicates “Construction equipment should be selected and deployed considering the lowest
emission factors and highest energy efficiency reasonably possible.” The City, in consultation with
SCAQMD, will monitor construction activity to ensure compliance with air quality mitigation
measures.
Response 7-56
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This comment speculates on the feasibility of additional mitigation measures to reduce air quality
impacts. This comment expresses argument and unsubstantiated opinion, and does not state any
facts contrary to the analysis or conclusions in the EIR. The more specific comments are addressed
below. The City notes in general that mitigation measures have been applied to the project
consistent with SCAQMD requirements and standards. SCAQMD is the agency responsible for
providing direction for the best means to achieve air quality improvements within the South Coast
Air Basin.
Response 7-57
The comment letter states that additional feasible construction mitigation is needed to address
significant and unavoidable NOx emissions resulting from the project. Refer to Responses 7-58
through 7-59 for responses to more specific comments associated with construction emissions. The
comment expresses unsubstantiated opinion that mitigation measures applied by other air quality
agencies in different locations for different projects should be applied to mitigate speculative air
quality impacts of this project. The City disagrees. The mitigation measures recommended for this
project are reasonable and adequate.
Response 7-58
The comment expresses unsubstantiated opinion that mitigation measures applied by a variety of
other air quality agencies in different jurisdictions for different projects should be applied to mitigate
air quality impacts of this project. The City disagrees. The mitigation measures recommended for
this project are reasonable and adequate and mitigate PM10 impacts to less than significant levels.
Specifically, the comment suggests the use of construction mitigation measures to mitigate fugitive
dust emissions deemed feasible by SCAQMD and other air quality districts. The project developer
will be required to comply with the SCAQMD Rule 403 by preparing a Fugitive Dust Control Plan,
per project mitigation measure AQ-7 and Rule 403 in the Fugitive Dust Implementation Handbook.
The comment lists other potential mitigation measures approved by other air districts. However,
other districts, including the Bay Area Air Quality Management District and Clark County Heath
District, for example, manage air emissions from different areas of the United States. These districts
manage areas that have different air quality conditions and thereby require a different set of
measures. The project’s Fugitive Dust Control Plan will require measures approved by SCAQMD
for construction projects within the South Coast Air Basin (SCAB). Because the impacts are already
mitigated to less than significant levels, there is no need to add further mitigation measures.
Response 7-59
Like with Comment 7-58, the comment expresses unsubstantiated opinion that mitigation measures
applied by a variety of other air quality agencies in different jurisdictions for different projects should
be applied to mitigate air quality impacts of this project, specifically diesel exhaust. The City
disagrees. The mitigation measures recommended for this project are reasonable and adequate. As
stated in Response 7-58, these districts manage areas that have different air quality conditions and
thereby require a different set of measures. Additionally, project measure AQ-5 requires the use of
cleaner fuels and processes that utilize energy efficiency. No additional mitigation measures are
warranted. Mitigation measures AQ-2 and AQ-5 have been hereby revised to the following to
include additional examples for reducing vehicle trips during construction and operations and
include PuriNOx fuel use as a suggested alternative clean-fuel for the applicant to use:
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AQ-2 The applicant/permittee shall incorporate and encourage Transportation Demand
Management (TDM) techniques for reducing vehicle trips during construction, as
well as during the daily operations of the hospital facility. TDM techniques shall
include but not be limited to the following: encouraging car and vanpooling,
providing preferential parking for car and vanpooling, installing electric vehicle (EV)
charging stations, providing preferential parking for EVs and compressed natural gas
vehicles, and offering flex hours and/or flex schedules during the on-going operation
of the facility. Written proof of such program shall be submitted to and approved by
the Planning Director prior to the issuance of a grading permit for construction
activities and prior to the issuance of a Certificate of Occupancy for the operation of
the medical offices.
AQ-5 Prior to the issuance of a grading permit and during the duration of construction
activities, the applicant/permittee shall verify in writing (to the Planning Department)
that all earth-moving and large equipment are properly tuned and maintained to
reduce emissions. In addition, alternative clean-fueled vehicles, such as PuriNOx
fuel or a similar type of fuel, shall be used where feasible. Construction equipment
should be selected and deployed considering the lowest emission factors and
highest energy efficiency reasonably possible.
Response 7-60
Like with Comments 7-58 and 7-59, the comment expresses unsubstantiated opinion that mitigation
measures applied by a variety of other air quality agencies in different jurisdictions for different
projects should be applied to mitigate air quality impacts of this project. The City disagrees. The
mitigation measures recommended for this project are reasonable and adequate. The comment
letter recommends the use of California Air Resources Board (CARB)-certified off-road engines that
are three years old or less. The SCAQMD has not yet required all construction projects within the
SCAB to use a certain percentage of newer vehicles. Additionally, project measure AQ-5
recommends the use of clean-fueled vehicles, which may include the use of newer engines that are
less than three years old or less. Please refer to Response 7-59 for the augmented mitigation
measures, AQ-2 and AQ-5. No additional mitigation measures are necessary.
Response 7-61
Like with Comments 7-58, 7-59 and 7-60, the comment expresses unsubstantiated opinion that
mitigation measures applied by a variety of other air quality agencies in different jurisdictions for
different projects should be applied to mitigate air quality impacts of this project. The City
disagrees. The mitigation measures recommended for this project are reasonable and adequate.
The comment presents unsubstantiated opinion about the effectiveness of alternative post-
combustion controls and argues that these speculative alternatives should be required for the
project. The SCAQMD is responsible for monitoring air quality and planning, implementing, and
enforcing programs designed to attain and maintain state and federal ambient air quality standards
in the district. The air quality analysis and mitigation measures in this EIR are consistent with the
SCAQMD recommendations, rules, and policies. The comment specifically suggests the use of
particulate traps and oxidation catalysts, among other controls. The use of zero volatile organic
compounds (VOC) paints will reduce ROG emissions by 95 percent (see mitigation measure AQ-14
and http://www.aqmd.gov/prdas/brochures/Super-Compliant_AIM.pdf from SCAQMD). However,
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NOx emissions will exceed SCAQMD thresholds for construction emissions. Therefore, a statement
of overriding considerations will be prepared for the project.
Response 7-62
Like with Comments 7-58, 7-59, 7-60 and 7-61, the comment expresses unsubstantiated opinion
that mitigation measures applied by a variety of other air quality agencies in different jurisdictions
for different projects should be applied to mitigate air quality impacts of this project. The City
disagrees. The mitigation measures recommended for this project are reasonable and adequate.
The comment offers unsubstantiated opinion that PM10 and NOx emissions could be reduced for
this project with the requirement of PuriNOx fuel use. The SCAQMD has not yet required all
construction projects within the SCAB to use PuriNOx fuels. Please refer to Response 7-59 for the
augmented mitigation measures, AQ-2 and AQ-5. No additional mitigation measures are necessary.
Response 7-63
The comment expresses unsubstantiated opinion and argument that additional mitigation measures
should be required for the operation of the project, and that that the Project operating emissions of
NOx and PM10s are “considerably underestimate[d]”. The City disagrees. The mitigation measures
recommended for this project are reasonable and adequate. The commentor has not provided any
facts about this project to indicate that additional mitigation measures are necessary or would be
effective. The comment also suggests the incorporation of mitigation measures listed in the
project’s Initial Study. In the Initial Study, the use of electric-powered equipment and encouraging
construction employee ride-sharing are mentioned. With regard to electric-powered equipment,
mitigation measure AQ-5 includes this requirement: “In addition, alternative clean-fueled vehicles
shall be used where feasible.” With regard to reducing construction traffic, mitigation measure AQ-
2 states in part: “The applicant/permittee shall incorporate and encourage Transportation Demand
Management (TDM) techniques for reducing vehicle trips during construction, as well as during the
daily operations of the hospital facility.” No additional mitigation is necessary.
Response 7-64
The comment expresses unsubstantiated opinion that additional mitigation measures should be
required for the operation of the project, and that that the Project operating emissions of NOx and
PM10s are “considerably underestimate[d]”. The City disagrees. The mitigation measures
recommended for this project are reasonable and adequate. The comment offers unsubstantiated
opinion that a shopping list of other operational traffic mitigation measures should be implemented
but fails to offer any facts or analysis to explain why. The project includes mitigation measures AQ-
1, AQ-2, and AQ-17 to reduce traffic-related air pollutant emissions. These measures would require
coordination with the Riverside Transit Authority, the incorporation of Transportation Demand
Management techniques, and the promotion of alternative transportation with the goal of reducing
transportation-related air quality emissions. No additional operational traffic mitigation measures
are required because the measures identified in the EIR mitigate impacts to less than significant
levels.
Response 7-65
The comment expresses unsubstantiated opinion that mitigation measures applied by a variety of
other agencies in different jurisdictions for different projects should be applied to mitigate impacts
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of this project. The City disagrees. The mitigation measures recommended for this project are
reasonable and adequate. The comment offers unsubstantiated opinion that a shopping list of
additional operational area mitigation measures be included for the proposed project. According to
the EIR, area source emissions would not result in exceedances of the SCAQMD thresholds for
criteria pollutants. As stated in CEQA Guidelines Section 15126.4(a)(3), “mitigation measures are
not required for effects which are not found to be significant.” Therefore, area source mitigation
measures are not required for the proposed project.
Response 7-66
The comment states that mitigation for “urban heat island effect” should be included in the project.
The City disagrees. The mitigation measures recommended for this project are reasonable and
adequate. The comment expresses unsubstantiated opinion that such an effect would or could
occur. Refer to Responses 7-67 and 7-68 for a discussion of potential mitigation for urban heat
island effect.
Response 7-67
This comment is a narrative argument, and does not present any facts contrary to the analysis or
conclusions in the EIR. The comment expresses unsubstantiated opinion that the project would
create an “urban heat island effect”, suggesting that additional mitigation is needed. The City
disagrees. The mitigation measures recommended for this project are reasonable and adequate.
The comment appears to suggest that the project require 20 percent less paving to reduce the
impacts resulting from urban heat island effect. Extensive landscaping required in the parking areas
per City Municipal Code standards will reduce heat effects associated with parking lot paving to less
than significant levels.
Response 7-68
This comment is a lengthy narrative discussion about Energy Star roof products for different
projects, and does not present any facts contrary to the analysis or conclusions in the EIR for this
Project. To the extent that the comment recommends the use of Energy Star roof products to
reduce the impacts resulting from urban heat island effect, the comment is noted. Project measure
AQ-3 recommends the use of energy-efficient building standards, which may include the use of
Energy Star roof products. The goal of this measure is to reduce energy needs, including cooling
needs, resulting from heat caused by paved areas and roofs. Please refer to Response 7-38 for
additional discussion about urban heat island effect.
Response 7-69
The comment expresses argument and unsubstantiated opinion that the mitigation measures
proposed by the City are “hollow and totally inadequate” The City disagrees. The payment of “fair
share” traffic fees is an adequate mitigation if the traffic impacts are cumulative in nature. The
impacts to the I-15/Highway 79 South interchange and the other intersections along Highway 79
South were correctly termed to be cumulative since the intersections either already operate below
City standards or were also impacted by many other cumulative projects. Since the impacts are
cumulative, the payment of fees is an adequate mitigation. Please also note that the project
applicant, in addition to paying fees, will be required to make physical improvements to directly
address project needs and impacts. Further, constitutional limits on exactions necessitate fee
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programs rather than requiring full improvements from projects with only limited impacts on a given
facility.
Response 7-70
This comment is a narrative argument, and does not present any facts contrary to the analysis or
conclusions in the EIR. The Statement of Overriding Considerations will be included in record of
project approval. Recirculation is not a prerequisite to adoption of a Statement of Overriding
Considerations.
Cumulative traffic impacts at intersections already experiencing poor operating conditions (the I-
15/Highway 79 South interchange) will be significant and unavoidable. As part of its long-range
planning, the City has identified all feasible measures in the City of Temecula General Plan to
address anticipated conditions at this location, including use of alternative transit modes over the
long term. To encourage transit use, the following additional mitigation measure will be required:
T-5. Prior to the issuance of grading permits, the City will consult with the Riverside Transit Agency
(RTA) regarding RTA’s possible interest in establishing a bus turn-out or similar transit
accommodation at the project site. The applicant/permittee will be required to incorporate
any such plans and facilities into revised site plans and other plans prepared for the project,
and shall further be required to fund a fair-share apportion of the facilities requested by RTA.
Such facilities must be in place prior to the issuance of occupancy permits for Phase I of the
project.
Even with this additional measure, project cumulative traffic impacts will remain significant and
unavoidable since the possible trip reduction effects associated with this measure cannot be
assessed. Per CEQA, the City will adopt a Statement of Overriding Considerations with regard to
cumulative traffic impacts.
Response 7-71
This comment expresses unsubstantiated opinion, and does not present any facts contrary to the
analysis or conclusions in the EIR. URBEMIS2002 estimates emissions resulting from construction
equipment and duration of use. The program does not estimate the amount of trips to be
generated during the construction phase. As the comment indicates, the program generates an
average daily trip amount for the project during the operational phase only. Additionally, the
URBEMIS2002 model includes assumptions regarding worker commutes, but the program does not
allow for input of worker trips plus the amount of construction vehicles to be used per day as a
combined amount. It is all inherent in the program with the goal of estimating construction
emissions, rather than determining construction daily trips. The construction traffic amounts are
much less than the day-to-day traffic generation forecast which the mitigation measures are based
upon. Therefore, the construction impacts would not be in excess of the impacts already identified.
Response 7-72
The traffic study conservatively assumes that transit is not utilized to access the site. Providing a bus
turnout on Highway 79 South could help reduce trips, but facilitating use of transit does not provide
sufficient mitigation to avoid project impacts. See Response 7-70.
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Response 7-73
This comment expresses unsubstantiated opinion, and does not present any facts contrary to the
analysis or conclusions in the EIR. The project parking study indicates that the project forecasted
demand based on standards contained in the City of Temecula Municipal Code; thus, it is accurate
to term the parking impacts not significant.
Response 7-74
This comment and does not present any facts contrary to the analysis or conclusions in the EIR. The
proper reference document for identifying minimum parking standards is the City of Temecula
Municipal Code, as this is the relevant regulatory document. As concluded in the Initial Study
(Appendix A of the EIR), parking provided for the project exceeds the Municipal Code requirement
and no significant environmental impacts will result.
Response 7-75
This comment expresses unsubstantiated opinion, and does not present any facts contrary to the
analysis or conclusions in the EIR. There is no parking deficiency, as demonstrated by the EIR
analysis (Draft EIR, page 3-8). There is no need to construct a parking structure for this project.
Response 7-76
This comment expresses unsubstantiated opinion, and does not present any facts contrary to the
analysis or conclusions in the EIR. The comment describes the commentor’s view of the CEQA
requirement for identifying baseline conditions accurately and fully, and incorrectly asserts generally
that the Draft EIR does not do so with regard to traffic and geologic setting. The EIR provides an
adequate baseline for traffic setting. The traffic environmental setting is found on pages 4-70
through 4-79 of the Draft EIR. Geologic impacts were found to be less than significant during the
Initial Study analysis; therefore, the geologic setting is not necessary to include in the EIR. Detailed
responses are provided below in response to the more specific comments in this regard.
Response 7-77
This comment expresses unsubstantiated opinion, and does not present any facts contrary to the
analysis or conclusions in the EIR. The baseline condition used in the traffic analysis was developed
by adding traffic associated with 17 cumulative projects (identified as new projects after March
2004) to the March 2004 traffic counts (Draft EIR, pages 4-72 and 4-81). Supplemental counts for
intersections in the immediate project vicinity were taken in July of 2005, with the intersection of
Pio Pico/DePortola counted in November of 2005.
Response 7-78
The study area includes the analysis of over 20 intersections and street segments (Draft EIR, pages
4-73 and 4-77 through 4-79). Only one intersection was counted on July 7, 2005 since this
intersection was added to the analysis later in the process (Draft EIR, page 4-72). This date is three
days after July 4th, and despite the EIR analysis, the commentor has not provided any evidence that
indicate that traffic is significantly less on July 7th as compared to other times of the year. Even if
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baseline traffic at this intersection was increased by 20%, the conclusions of the traffic study would
not change.
Response 7-79
The comment is incorrect. Traffic counts from 17 cumulative projects were added to the existing
counts to form the baseline condition to which project traffic was added (Draft EIR, page 4-81).
Response 7-80
This comment expresses unsubstantiated opinion, and does not present any facts contrary to the
analysis or conclusions in the EIR. The City first circulated a draft Mitigated Negative Declaration
for public review in March of 2005. The original traffic study (dated November 2004) was prepared
for this study effort and time frame. Subsequently, with the decision to prepare an EIR, the City
directed the project traffic engineer to conduct a supplemental analysis. As noted on page 4-67 of
the EIR: “Also, updated traffic counts were obtained at selected locations for focused analysis of the
changed conditions, and the background future traffic growth was adjusted to account for
cumulative projects and time that had passed since preparation of the November 4, 2004 study.”
Thus, the traffic analysis in the project EIR adequately represents baseline conditions at the time the
Notice of Preparation was released and the Draft EIR prepared. No additional counts, calculations
or analysis are necessary.
Response 7-81
This comment does not present any facts contrary to the analysis or conclusions in the EIR. The EIR
assumption that 17 cumulative projects are all completed prior to the subject project results in a
very conservative baseline analysis. Adding a growth factor in addition to the cumulative projects
makes the analysis more conservative. A 4% growth factor was included for this project, resulting in
an even more conservative baseline analysis (Draft EIR, page 4-81).
Response 7-82
The comment is incorrect. The background without project (baseline) condition to which project
traffic was added included a 4% growth factor in addition to traffic from 17 cumulative projects.
This baseline condition provides a very conservative approach to assessing project impacts.
Response 7-83
Mitigation measures are not linked to years since the timing of construction can never be assured.
Instead, the mitigation is correctly linked to the number of hospital beds and the square footage of
the medical office, meaning the direct impact created by project components. A two-phased
analysis was conducted in the EIR to provide an analysis that reflects accelerated impacts, which a
multi-phase analysis would not do. This is because once the first phase of development is
exceeded, all mitigation measures will need to be implemented.
Response 7-84
Responses to Comments on the Draft EIR
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL 9-228
The traffic study prepared in November of 2004 assumed the near-term construction of 17
cumulative projects, some of which may never be built or will not be built for a very long time.
Information for four additional cumulative projects, which have begun processing since the start of
the proposed project cumulative impact analysis was completed, were obtained from City of
Temecula staff and included in the Draft EIR analysis. Additionally, traffic counts from two
additional intersections were analyzed and included in the September 22, 2005 Traffic Impact
Analysis Addendum that was include as Appendix D of the Draft EIR. The Draft EIR provides a
comprehensive analysis of annual traffic volume growth. Also, please see Response #7-82 regarding
the 4% growth factor. No additional traffic analysis is required.
Response 7-85
Once the first phase of development is exceeded, all mitigation measures will need to be
implemented. Please refer to Responses 7-77 through 7-84.
Response 7-86
This comment is a lengthy narrative expressing the commentor’s generalized interpretation of
CEQA requirements, but does not state any facts contrary to the analysis or conclusions in the EIR.
To the extent the comment implies that the project EIR cumulative impact analysis is flawed, it does
so by citing examples regarding how cumulative impact analysis might be performed for different
projects. The cumulative impact analysis for this project is adequate (Section 6 of the Draft EIR).
No specific comment is made as to how the subject project cumulative impact analysis fails.
Specific responses to specific comments are presented below.
Response 7-87
The comment states that no cumulative impact analysis was conducted for ten of the CEQA
checklist environmental issues. As provided for in CEQA Guidelines Section 15130(a)(1), “An EIR
should not discuss impacts which do not result in part from the project evaluated in the EIR.” The
EIR extensively examines those issues identified in the Initial Study as potentially significant (Section
4 of the Draft EIR). For those areas determined in the Initial Study to be either less than significant
or of no potential impact, the project is not considered to result in impacts of concern (Draft EIR,
pages 1-7 and 1-8). Thus, the cumulative impact analysis, as allowed by CEQA, properly does not
consider these issue areas.
Response 7-88
Existing plans have been prepared to address regional, cumulative storm water runoff impacts, and
requirements imposed on all projects in the vicinity adequately address storm water and water
quality concerns. Specifically, the Riverside County Flood Control and Water Conservation District
has prepared master drainage plans to address cumulative drainage concerns, and all projects must
provide drainage improvements consistent with such plans and/or pay Area Drainage Plan fees.
This comprehensive approach to storm water management avoids cumulative impact.
With regard to cumulative water quality issues, the EIR states:
Impacts related to runoff and siltation will be controlled on a project-by-project basis by
adherence to requirements of the National Pollution Discharge Elimination System (NPDES).
Responses to Comments on the Draft EIR
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT
9-229 TEMECULA REGIONAL HOSPITAL
Typical measures to implement the NPDES program could include covering all outside storage
facilities, vegetated swales, detention basins with filtration systems, and monitoring programs.
The NPDES system has been put in place to address cumulative, regional impacts. Continued
implementation of the NPDES permitting requirements will reduce cumulative impacts to a
less than significant level. (Draft EIR, p. 6-2)
As discussed in the EIR, the NPDES system adequately addresses cumulative water quality impacts.
Moreover, the project is also subject to the City’s storm water ordinances, which have been
developed to assure compliance with the San Diego Regional Water Quality Control Board
Municipal Permit. The purpose of the Municipal Permit. is to ensure that new development in the
City does not cause or contribute to the exceedance of a water quality objective.
Concerning water supply, the project was reviewed by the Rancho California Water District. The
District has issued a WSA in which it concludes that the District has adequate supplies of potable
water to supply the project and all reasonably foreseeable future projects (Draft EIR, pages 4-33
through 4-35).
Finally, the comment reiterates the commentor's unsubstantiated opinion related to offsite LUFTs or
LUSTs. The comment speculates that offsite LUFTs may have a cumulative environmental impact
on the project. Any groundwater contamination posed by the offsite LUFTs are not part of or
related to this project. Such contamination is not a direct or indirect significant impact posed by
this project, so a cumulative impact analysis is not appropriate.
Response 7-89
This comment expresses unsubstantiated opinion, and does not present any facts contrary to the
analysis or conclusions in the EIR. A list of projects in the vicinity is included in the traffic study in
Appendix D. As discussed on page 6-3 of the EIR: “All other proposed projects must either be
consistent with the General Plan, which has been formulated to achieve compatible land use
patterns, or deemed to be acceptable by the Planning Commission and/or City Council in actions to
approve projects.” Because these cumulative projects do not propose wholesale changes to the
General Plan, no cumulative land use impact will result.
Response 7-90
This comment expresses unsubstantiated opinion, and does not present any facts contrary to the
analysis or conclusions in the EIR. The City’s accepted approach to traffic impact analyses – and
one used by jurisdictions throughout California – is to assess project impacts at the time a proposed
project is completed, not in the distant General Plan build-out future. This approach provides a
better picture of project impacts, as to analyze the longer time frame would dilute the impact of the
project (with a larger volume of future background traffic).
Response 7-91
As noted in Response 7-82, a 4% growth factor was added to the background traffic volumes to
account for the time elapsed since counts were conducted. The EIR’s cumulative impact analysis
f o r A i r Q u a l i t y i s a d e q u a t e ( D r a f t E I R , p a g e 6 - 2 ) . T h e f o u r a d d i t i o n a l p r o j e c t s i n c l u d e d i n t h e
cumulative traffic analysis include the: 1. Butterfield Ranch Shopping Center, 2. Butterfield Ranch
Responses to Comments on the Draft EIR
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL 9-230
Self Storage, 3. Creekside Plaza, and 4. Silver Oaks Senior Condos (Appendix D of the Draft EIR).
Additionally, the Apis Plaza Traffic Study is included in this Final EIR as an Appendix, and, although
not attached to the Initial Study, it was available to the public throughout the public review period.
Response 7-92
This comment is a narrative expressing the commentor’s interpretation of CEQA requirements, but
does not state any facts contrary to the analysis or conclusions in the EIR. No response is required.
Response 7-93
The EIR adequately addresses consistency with the General Plan to the extent necessary for CEQA.
See EIR pages 4-37 to 4-42. The EIR fully addresses all impacts determined by the Initial Study to be
potentially significant. Air Quality impacts are addressed in the EIR at pages 4-17 to 4-29, and are
reduced to the greatest extent feasible by mitigation measures AQ-1 through AQ-17. Refer to
Responses 7-58 through 7-68 for more discussion on the air quality mitigation measures.
Response 7-94
This comment expresses unsubstantiated opinion, and does not present any facts contrary to the
analysis or conclusions in the EIR. The comment refers to language for Public/Institutional Facilities
land use designation in the City’s General Plan. The project is not a public institutional facility.
Under the Professional Office (PO) designation, which applies to the project site, medical office
buildings are permitted uses and hospitals are conditionally permitted uses. The EIR fully addresses
all impacts determined by the Initial Study to be potentially significant for the project.
As part of its long-range planning, the City has identified all feasible measures in the City of
Temecula General Plan to address anticipated conditions at this location, including use of
alternative transit modes over the long term. To encourage transit use, the following additional
mitigation measure will be required:
T-5. Prior to the issuance of grading permits, the City will consult with the Riverside Transit Agency
(RTA) regarding RTA’s possible interest in establishing a bus turn-out or similar transit
accommodation at the project site. The applicant/permittee will be required to incorporate
any such plans and facilities into revised site plans and other plans prepared for the project,
and shall further be required to fund a fair-share apportion of the facilities requested by RTA.
Such facilities must be in place prior to the issuance of occupancy permits for Phase I of the
project.
The proposed project is not inconsistent with the City’s General Plan; no further environmental
analysis is required.
Response 7-95
The project proponent will be required to comply with the RTA letter dated July 21, 2004 that was
included in the Draft EIR in Appendix A. Compliance will be enforced by a condition of approval
from the City. The letter recommends improvements for a bus turnout and shelter on Highway 79
South that would serve the hospitals transit needs. Compliance with this condition of approval,
mitigation measure T-5, and Title 8, Chapter 8.08, Section 8.08.070 D (Trip Reduction Plan Option)
of the Municipal Code, will ensure the proposed project is consistent with the General Plan and
Responses to Comments on the Draft EIR
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT
9-231 TEMECULA REGIONAL HOSPITAL
City’s Municipal Code mandating trip reduction measures for new developments. No further
environmental analysis is required.
Response 7-96
This comment expresses argument and unsubstantiated opinion. This comment provides a closing
statement to Adams Broadwell Joseph & Cardozo comments on the Draft EIR. The Project EIR is
adequate for the project. No significant revisions are necessary; and recirculation is unwarranted.
Response 7-97, 7-99, and 7-100
The comments provide an introduction to Tom Brohard’s letter (Exhibit 1 to Letter 7), including a
summary of Mr. Brohard’s analysis, a project summary, and Mr. Brohard’s education and
experience. No response is necessary for these comments.
Response 7-98
The comment provides a summary of Mr. Brohard’s comments, regarding traffic analysis in the Draft
EIR. All of the comments are addressed in the previous responses. Please refer to Responses 7-47
through 7-51, Responses 7-77 through 7-85, Response 7-90, and Responses 7-71 through 7-74,
regarding Mr. Brohard’s list summary of comments.
Response 7-101
This comment expresses unsubstantiated opinion, and does not present any facts contrary to the
analysis or conclusions in the EIR. See Response 7-83.
Response 7-102
This comment does not present any facts contrary to the analysis or conclusions in the EIR. See
Response 7-45.
Response 7-103
This comment does not present any facts contrary to the analysis or conclusions in the EIR. See
Responses 7-47 and 7-48.
Response 7-104
See Responses 7-45 and 7-46.
Response 7-105
See Response 7-50.
Response 7-106
See Response 7-51.
Responses to Comments on the Draft EIR
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL 9-232
Response 7-107
See Responses 7-77, 7-78, 7-79, and 7-80.
Response 7-108
See Response 7-83.
Response 7-109
See Response 7-84.
Response 7-110
See Responses 7-81, 7-82, 7-83,7-84, and 7-85.
Response 7-111
A traffic study has already been completed, and reviewed by the City, which addresses the build out
of the City General Plan. It is not the responsibility of individual development projects to evaluate
traffic conditions at build out of the City’s General Plan. Examining impacts at the time a project is
to be completed provides a more conservative analysis, as General Plan buildout traffic volumes
would further dilute the contributions made by the project.
Response 7-112
See Response 7-69.
Response 7-113
See Response 7-71.
Response 7-114
See Response 7-72.
Response 7-115
See Responses 7-73, 7-74, and 7-75.
Response 7-116
An analysis of the site plan was conducted which resulted in mitigation number T-1 and several
changes to the site plan. Meetings were held with City staff to specifically discuss the access and on-
site circulation. The current site plan provides for the anticipated queues and meets City sight
distance standards. The on-site circulation was reviewed extensively with the project architects who
specialize in hospital campus development.
Response 7-117
Responses to Comments on the Draft EIR
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT
9-233 TEMECULA REGIONAL HOSPITAL
The comment is noted. This comment provides a closing statement to Mr. Brohard’s comments on
the Draft EIR.
Response 7-118
This comment does not present any facts contrary to the analysis or conclusions in the EIR. See
Responses 2-2, 2-7, 2-16, 7-17 through 7-20. There are no “open fuel leak” cases on the project
site. An EIR has been prepared for the project.
Response 7-119
See Responses 7-21 through 7-24
Response 7-120
See response 7-24
Response 7-121
This comment does not present any facts contrary to the analysis or conclusions in the EIR. See
Responses 2-15, 4-4, 7-39, 7-40, 7-41, and 7-88.
Response 7-122
This comment does not present any facts contrary to the analysis or conclusions in the EIR. See
Responses 2-15, 4-4, 7-39, 7-41, 7-42 and 7-88
Response 7-123
This comment does not present any facts contrary to the analysis or conclusions in the EIR. See
Responses 2-16, 7-20, 7-42, 7-88.
Response 7-124
This comment is a narrative expressing the commentor’s interpretation of CEQA requirements, but
does not state any facts contrary to the analysis or conclusions in the EIR. Refer to Responses 7-5
and 7-6 for a discussion of CEQA requirements.
Response 7-125
This comment expresses unsubstantiated opinion, and does not present any facts contrary to the
analysis or conclusions in the EIR. Mitigation measures for the project are adequate. Refer to
Responses 6-9, 7-19, 7-70, 7-89, 7-93, 7-94, 7-95 and 7-111 for a discussion of General Plan
consistency.
Response 7-126
Responses to Comments on the Draft EIR
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL 9-234
This comment expresses unsubstantiated opinion, and does not present any facts contrary to the
analysis or conclusions in the EIR. Refer to Response 7-9 and 7-10 for a discussion of the project
description and environmental setting.
Response 7-127
The comment is incorrect. Refer to Response 7-10 for a discussion of the project construction
schedule.
Response 7-128
Refer to Response 7-11 for a discussion of a grading plan or cut-and-fill analysis.
Response 7-129
This comment expresses unsubstantiated opinion, and does not present any facts contrary to the
a n a l y s i s o r c o n c l u s i o n s i n t h e E I R . R e f e r t o Response 7-12 for a discussion of mechanical
equipment.
Response 7-130
This comment does not present any facts contrary to the analysis or conclusions in the EIR. Refer to
Response 7-91 for an evaluation of cumulative impacts.
Response 7-131
This comment is a narrative argument and expresses unsubstantiated opinion, and does not state
any facts contrary to the analysis or conclusions in the EIR. Refer to Response 7-25 for a discussion
of ambient air quality standards.
Response 7-132
Refer to Response 7-26 for a discussion of PM2.5 emissions.
Response 7-133
Refer to Response 7-27 for a discussion of heath risk assessments. No health risk assessments are
necessary for this project.
Response 7-134
This comment expresses unsubstantiated opinion, and does not present any facts contrary to the
analysis or conclusions in the EIR. The project does not “improperly” defer mitigation. Refer to
Responses 7-54 and 7-55 for a discussion of feasibility of mitigation measures.
Response 7-135
Refer to Response 7-28 for a discussion of construction emissions.
Responses to Comments on the Draft EIR
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT
9-235 TEMECULA REGIONAL HOSPITAL
Response 7-136
Refer to Response 7-29 for a discussion of the construction schedule.
Response 7-137
Refer to Response 7-30 for a discussion of model default values.
Response 7-138
Refer to Response 7-31 for an evaluation of fugitive dust emissions from track-out and wind erosion.
Response 7-139
Refer to Response 7-32 for a discussion of operational emissions.
Response 7-140
Refer to Response 7-33 for a discussion of operational emissions sources.
Response 7-141
Refer to Response 7-34 for an evaluation of natural gas emissions.
Response 7-142
Refer to Response 7-35 for a discussion of target year results during operations.
Response 7-143
Refer to Response 7-36 for a discussion of traffic emissions.
Response 7-144
Refer to Response 7-37 for a discussion of secondary emissions from electricity.
Response 7-145
Refer to Response 7-38 for a discussion of so-called urban heat island effect.
Response 7-146
Refer to Responses 7-54 and 7-56 for a discussion of additional feasible mitigation measures.
Response 7-147
Refer to Response 7-57 for a discussion of construction emissions.
Responses to Comments on the Draft EIR
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL 9-236
Response 7-148
Refer to Response 7-58 for a discussion of fugitive dust mitigation measures.
Response 7-149
Refer to Response 7-59 for a discussion of diesel exhaust mitigation measures.
Response 7-150
Refer to Response 7-60 for a discussion of construction equipment.
Response 7-151
Refer to Response 7-61 for a discussion of post-construction controls.
Response 7-152
Refer to Response 7-62 for a discussion of PuriNOx fuel.
Response 7-153
Refer to Responses 7-63 and 7-64 for a discussion of additional feasible operational mitigation.
Response 7-154
Refer to Response 7-65 for a discussion of operational area mitigation measures.
Response 7-155
Refer to Responses 7-66, 7-67, and 7-68 for a discussion of mitigation for urban heat island effect.
Response 7-156
Refer to Response 7-96 for an overall conclusion of comments.
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT 9-237 TEMECULA REGIONAL HOSPITAL
9.1 Responses to Comments
on the Draft EIR Received after
Close of Public Comment Period
This section of the Final EIR contains comments and responses to written comments received after
the close of the public review period on the Draft EIR (DEIR) on October 28, 2005 through
publication of this document prior to the December 7, 2005 Planning Commission hearing.
Pursuant to Section 15105(d)(3) and Appendix K of the California Environmental Quality Act
(CEQA) Guidelines the City of Temecula requested a shortened review period to the Governor’s
Office of Planning and Research, State Clearinghouse and Planning Unit.
Revisions and clarifications to the EIR in response to comments and information received on the
Draft EIR are indicated by strikeout (DEIR text removed) or underline (text added to the Final EIR).
Corrections of typographical errors have been made throughout the document and are not
indicated by strikeout or underline text. Revisions and clarifications are included as Errata pages
within this document.
Each letter has been assigned a number code, and individual comments in each letter have been
coded as well to facilitate responses. The coding system continues using the format established in
Section 9.0 of the Final EIR.
Comments Received that Address Environmental Issues
The City received letters from the following organizations and individuals after the close of the
noticed public review period:
8. J.B. “Pete” Olhasso, Santiago Ranchos Property Owners Association Board of Directors,
October 31, 2005.
9. Victoria Mata, Trumark Companies, November 3, 2005.
10. Board of Directors, Los Ranchitos Homeowners Association, November 14, 2005 (received
November 16, 2005).
11. David Oberbeck, via facsimile transmittal on November 14, 2005 (received November 16,
2005).
12. Roger Ziemer, President, Murrieta Temecula Group, November 15, 2005.
13. Linda Betts, via email on November 16, 2005.
14. Jon Silver, President, Covenant Development, via email on November 15, 2005.
15. Gloria D. Smith, Adams Broadwell Joseph & Cardozo, November 16, 2005
16. O.B. Johnson, Chairman of the Board, Murrieta Chamber of Commerce, November 16, 2005.
17. Helen Chichester, November 16, 2005.
18. Don L. Rhodes, November 21, 2005.
Letter 8
8-1
Responses to Comments on the Draft EIR Received After Close of Public Comment Period
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT 9-239 TEMECULA REGIONAL HOSPITAL
8. J.B. “Pete” Olhasso, Santiago Ranchos Property Owners Association Board of Directors,
Ocober 31, 2005.
Response 8-1
This written comment was received after the close of the noticed comment period. A common and
accepted method of analysis for aesthetics impacts in a CEQA document are visual simulations. The
analysis provided in Section 4.1, Aesthetics, of the Draft EIR provides two visual simulations that
show the proposed project in the built environment. The City of Temecula accepts this method of
analysis to demonstrate aesthetics impacts of the proposed project. Additionally, the applicant did
not “reject” a request to float balloons on the site to demonstrate the proposed building height as
suggested by the comment. To the contrary, in order to demonstrate the proposed maximum
hospital tower height on the site and to allow people to visually experience that height, the project
applicant floated tethered balloons on the project site on November 12, 2005.
Letter 9
9-1
9-2
9-2
Cont.
9-3
9-4
9-6
9-5
9-6
Cont.
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT 9-243 TEMECULA REGIONAL HOSPITAL
9. Victoria Mata, Trumark Companies, November 3, 2005.
Response 9-1
This written comment was received after the close of the noticed comment period. This comment
provides an introduction to the Trumark Companies comments on the Draft EIR. No response is
required. Specific responses are provided below to address specific comments in the body of the
letter.
Response 9-2
The application for the referenced senior housing development was submitted to the City of
Temecula approximately one year after the City accepted the application for the proposed hospital
project as complete, after circulation of a proposed Mitigated Negative Declaration in March of
2005, and after the initial public hearing scheduled for the hospital in April of 2005. The proposed
hospital project has not changed since the application was released for public review and comment.
The Trumark Companies has not previously presented any letter or public comment regarding the
subject hospital project until this letter.
Features of the hospital project have been known and available for public review for some time.
The Draft EIR for the subject project was nearly complete at the time Trumark first submitted its
application to the City on August 9, 2005. As such, it becomes incumbent upon any person or
entity (i.e. Trumark) submitting a development application subsequent to the hospital application
and its public review period to assess that subsequent project’s relationship to the earlier and
reasonably foreseeable project (i.e. the hospital).
The aesthetics analysis beginning on page 4-3 of the EIR recognizes the adjacent referenced
property as zoned Professional Office (PO) and Planned Development Overlay (PDO), and
analyzes potential impact based on these zones and the uses generally permitted; the proposed
senior housing development requires a conditional use permit. As noted on page 4-5 of the EIR, the
project will provide for buildings to be centered on the site and will include extensive perimeter
landscaping. These project features will avoid adverse aesthetic impacts relative to surrounding
development. Also, the three mitigation measures stated on page 4-15 will avoid potential light and
glare impacts on adjacent uses, including Trumark’s proposed project.
Response 9-3
This comment does not state any facts contrary to the analysis or conclusions in the EIR. The
comment does not indicate as to how the air quality analysis is deficient, other than suggesting a
need to examine truck emissions, emissions from the generators, and helicopter operations. The air
quality analysis beginning on page 4-17 of the EIR fully analyzes short-term (construction related)
and long-term (operational) impacts of the project. Truck operations are analyzed as part of the
mobile source emissions. Generator equipment is regulated separately by the SCAQMD and must
comply with strict point-source emissions regulations. Helicopter activities are anticipated to be
infrequent (average of one operation per month, with no more than six); helicopters are regulated
by federal, not local, air pollution control agencies. The EIR includes 17 mitigation measures to
reduce project construction and operational air pollutant emissions. The EIR fully discloses the
potential air quality impacts and incorporates feasible mitigation. Nonetheless, the air quality
Responses to Comments on the Draft EIR Received After Close of Public Comment Period
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL 9-244
analysis concludes that short-term and long-term impacts will be significant and unavoidable,
requiring adoption of a Statement of Overriding Considerations (see Draft EIR, page 4-29).
Response 9-4
See Response 9-2. The proposed hospital project and site plan were public information and the
DEIR preparation was underway many months prior to when the Trumark Companies submitted its
application. Since the Trumark Companies’ project application was submitted many months
following that of the proposed hospital project, it is incumbent upon that applicant (Trumark) to
consider known land uses and land use applications deemed by the City to be complete, and to
examine how such known and proposed or reasonably foreseeable uses may affect that subsequent
land use application.
The land use analysis in the EIR (pages 4-38 and 4-39) recognizes the adjacent referenced property
as zoned for commercial and office uses, and the EIR analyzes potential impact based on this zone
and the uses generally permitted; the proposed senior housing development requires a conditional
use permit. On page 4-41 of the Draft EIR, the analysis concludes that the proposed hospital
project is consistent with existing and planned surrounding land uses, and that the site design
respects surrounding uses. The EIR concludes that impact will be less than significant.
Response 9-5
See Response 9-2. The proposed hospital project and site plan was public information and the
DEIR preparation was underway many months prior to when the Trumark Companies submitted its
application. Since the Trumark Companies’ project application was submitted many months
following that of the proposed hospital project, it is incumbent upon that applicant (Trumark) to
consider known land uses and land use applications deemed by the City to be complete, to
consider all planned activities associated with such uses, and to examine how such known and
proposed or reasonably foreseeable uses may affect that subsequent land use application.
Project noise impacts were assessed based upon the Professional Office zone on the adjacent
property and the office and commercial uses generally permitted; the proposed senior housing
development requires a conditional use permit. The EIR concludes that noise from on-site activity
will not exceed City noise/land use compatibility standards (page 4-65). Restrictions will be placed
on loading dock operations (see mitigation measure N-4 on page 4-65). While noise associated
with mechanical equipment also is not anticipated to exceed these standards, mitigation measure N-
1 on page 4-66 is included to ensure compliance over the long term. Helicopter noise associated
with a maximum possible six events is concluded to be significant and unavoidable due to the
annoyance factor (EIR page 4-66).
Response 9-6
This comment provides a closing statement to the Trumark Companies’ comments on the Draft EIR
and presents no further specific comment on the Draft EIR. No further response is required.
Letter 10
10-1
10-1
Cont.
10-2
10-3
10-4
10-5
10-6
10-7
10-8
10-9
10-10
10-10
Cont.
10-11
10-12
10-13
10-14
10-15
10-15
Cont.
10-16
10-17
10-17
Cont.
10-18
10-19
10-20
10-20
Cont.
10-21
10-22
10-22
Cont.
10-23
10-24
10-25
10-26
10-27
10-28
10-29
10-29
Cont.
10-30
10-31
10-32
10-33
10-33
Cont.
10-34
10-35
10-36
10-37
10-37
Cont.
10-38
10-39
10-40
10-41
10-41
Cont.
10-42
10-43
10-44
10-44
Cont.
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT 9-261 TEMECULA REGIONAL HOSPITAL
10. Board of Directors, Los Ranchitos Homeowners Association, November 14, 2005.
Response 10-1
This written comment was received after the close of the noticed comment period. This comment
provides an introduction to the Los Ranchitos Homeowners Association comments on the Draft EIR.
No response is required.
Response 10-2
This comment does not state any facts contrary to the analysis or conclusions in the EIR. As stated
on page 3-1 and pages 3-3 through 3-8 of the Draft EIR, the proposed project analyzed in the Draft
EIR is the construction and operation of a 408,160-square-foot hospital, a helipad, two medical
offices totaling approximately 140,000 square feet, a 10,000-square-foot cancer center, and an
8,000-square-foot fitness rehabilitation center. The hospital includes an emergency room. As noted
in the comment, the hospital will of necessity operate around the clock. However, night-time
operations will be limited primarily to those associated with the emergency room.
Response 10-3
The comment is incorrect. The indirect or secondary effects associated with long-term operation of
the hospital complex are assessed in the Draft EIR in the Air Quality, Hydrology and Groundwater,
Noise, and Transportation sections. With regard to operational aspects of the hospital, shift changes
have been addressed as part of the traffic analysis, which assumes peak-hour impacts based upon
typical operating characteristics (e.g., shift changes) at a hospital. The applicant estimates that
between 1,000 and 1,200 persons will be employed on the site. The traffic analysis takes
employees into account in trip generation totals and peaks.
Response 10-4
Universal Health Services (UHS), the project applicant, currently operates two hospitals in the
region: Inland Valley Medical Center and Rancho Springs. Both of these facilities have emergency
rooms that currently operate beyond capacity. There are approximately 110 ambulance trips per
month to the two existing hospitals combined. With the emergency room at the proposed
Temecula Regional Hospital, those ambulance trips will be distributed among all three facilities.
Based on current ambulance service to the two existing facilities, UHS projects that approximately
one to two ambulance trips could arrive at the proposed Temecula hospital daily. While the
preferred route will be via Highway 79 South (east or west), some trips could originate from the
north via Margarita Road.
As a matter of practice, the ambulance drivers use sirens only when necessary to clear traffic. UHS
generally does not allow sirens to be used once an ambulance arrives on the hospital grounds.
Sirens generally would not be used during night-time hours when traffic volumes are minimal. Siren
noise is part of the current noise environment. Thus, siren noise is not considered a significant
impact.
Responses to Comments on the Draft EIR Received After Close of Public Comment Period
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL 9-262
Response 10-5
This comment does not state any facts contrary to t h e a n a l y s i s o r c o n c l u s i o n s i n t h e E I R . A s
indicated in the Initial Study (Appendix A of the Draft EIR), the proposed project will result in a less
than significant impact with regard to the routine transport, use, or disposal of hazardous materials
or waste. Per the project conditions of approval, and consistent with standard City practices and
requirements, the applicant/operator will be required to submit for review and approval by the
Riverside County Department of Environmental Health and Fire Department a Hazardous Material
Inventory Statement and Fire Department Technical Report. Such report will be kept on file with
these agencies, and should any quantities of hazardous materials used or stored on site increase or
should changes to operations introduce any additional hazardous material not listed in such reports,
the operator will be required to update such reports. All other potential impacts associated with the
hazardous materials will be regulated and mitigated through federal, state, and local laws and
policies. No incinerator is proposed as part of this project. No additional analysis is required.
Response 10-6
In response to the comment, under the “Scope of the Environmental Analysis” subheading on page
2-2 of the Final EIR, the bullet points under the second sentence of the first paragraph have been
revised to read as follows:
The Initial Study concluded that adoption and implementation of the proposed General Plan
might have a significant effect on the environment with respect to the following:
Aesthetics
Air Quality
Land Use and Planning
Hydrology and Water Quality
Noise
Transportation
The revision does not affect any of the facts, analyses, or impact conclusions contained in the EIR.
The City of Temecula used the Initial Study process, as encouraged and permitted by CEQA, to
identify those issues requiring analysis in the EIR. All CEQA issues are adequately addressed either
in the text of the EIR or in the Initial Study, which is part of the EIR (see Appendix A of the Draft
EIR).
Please refer to response 10-5 for a discussion of hazardous materials. Development of the hospital
is consistent with adopted General Plan and zoning designations for surrounding sites, is consistent
with General Plan policies to expand medical and other high-technology employment opportunities,
and would not induce further growth in these sectors beyond that anticipated by the City’s General
Plan. The proposed hospital is responding to medical care needs associated with past and current
growth, and is not a mechanism to spur additional growth within the City and region. No further
analysis is required.
Response 10-7
The first two bullet points on page 3-1 of the Draft EIR are correct. As stated in the first bullet point,
the General Plan Amendment is a request to eliminate the Z2 overlay area from the General Plan,
which currently limits the height of buildings along Highway 79 South to two stories. The medical
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office buildings would be allowed to be developed as three- and four-story buildings with removal
of the Z2 overlay.
Response 10-8
The comment is incorrect. The comment asserts that the “lack of an adequate project description”
results in a failure to analyze land use compatibility issues. The Draft EIR of pages 3-1 through 3-10
provides an accurate and thorough description of the project and environmental setting.
Furthermore, on page 4-41 the Draft EIR provides an analysis of the proposed project’s
compatibility with surrounding land uses, including residential properties and horse-keeping
properties. The analysis concludes that impact will be less than significant because of project design
features and the nature of surrounding uses.
Response 10-9
The comment incorrectly states that there is no rationale for the height of the proposed buildings.
The project is proposed to include two bed towers of 5 and 6 stories. On pages 1-29, 2-2, 4-13,
and 5-2, the Draft EIR references discussion in Appendix F regarding a technical explanation for the
necessary project design. In Appendix F is a description of the functional reasons for the proposed
tower heights and an explanation as to why a reduced building height alternative was rejected.
Response 10-10
The comment suggests opposition to a secondary project access to De Portola Road. The traffic
analysis conducted for the project identified no significant impact to De Portola Road with the
proposed restricted driveway (i.e., no permitted exiting left turns). The roadway will continue to
experience operating conditions consistent with the City’s LOS D standard. Also, the General Plan
Circulation Element designates De Portola Road as a Modified Secondary Arterial. This
classification consists of a four-lane undivided roadway with a cross section of 70 feet within 88 feet
of right-of-way, which allows for a trail alongside the roadway.
Alternative 4: Access from Dartolo Road on pages 5-11 through 5-14 of the Draft EIR provides an
analysis of a secondary access east of the project site via and extension of Dartolo Road in lieu of
the proposed driveway connection to De Portola Road. The analysis concluded that traffic and
biological resource impacts of Alternative 4 could be greater than those associated with the
proposed project. Therefore, secondary access via De Portola Road is the preferred access
compared to Dartolo Road. No further analysis is required.
Response 10-11
This comment does not state any facts contrary to the analysis or conclusions in the EIR. The City
concludes that the Project Description contained in Section 2 of the Draft EIR adequately describes
the proposed project for evaluation and review of all environmental impacts addressed in the Draft
EIR. Per CEQA Guidelines section 15124, the project description contained in the Draft EIR meets
all of the requirements to adequately describe the project.
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Response 10-12
This comment does not state any facts contrary to the analysis or conclusions in the EIR. As stated
in the Initial Study, project wastewater and solid waste impacts will be less than significant. Also,
the project permittee will be required to comply with all existing and applicable federal, state, and
City of Temecula laws and regulations enforced through the project conditions of approval.
Response 10-13
Goals and policies related to visual or aesthetics are presented on pages 4-37 and 4-38 of the Draft
EIR in the Land Use and Planning section.
Response 10-14
As stated on page 4-4, “The General Plan does not identify any view corridors or areas of special
visual significance in the project vicinity.” This statement is correct from the standpoint of the
General Plan. The project site is a vacant, fallow piece of land covered with non-native grasses and
weeds. The project site is not designated as open space, and General Plan policy anticipates
development on this site. Further, the City’s General Plan contains no policies establishing the
project vicinity as an aesthetically important sensitive area.
Response 10-15
The Draft EIR on pages 4-5 through 4-13 presents the analysis of visual character and quality
impacts associated with the proposed hospital project. Two photographic renderings were
prepared, one illustrating views from a hillside to the north overlooking the project site (presented in
the Draft EIR as Figures 4-2a and 4-2b), and a second illustrating conditions just north of the
intersection of Pio Pico Road and De Portola Road (presented in the Draft EIR as Figures 4-3a and 4-
3b). As noted on Page 4-5 of the Draft EIR, the project will be visible from various residential lots
north of the project site. While the project site can be seen from the north, distant views of
Palomar Mountain from areas north of the project site will not be blocked. At the request of the
Santiago Ranchos Property Association, the project applicant floated tethered balloons on the
project site on Saturday, November 12, 2005 to provide residents information regarding the
proposed height of the hospital towers. The renderings and use of balloons to indicate the
proposed project’s height are standard and accepted techniques used to analyze the aesthetic
impacts of a project pursuant to CEQA. The analysis was not dismissed. The Draft EIR and
subsequent activities requested by the public have adequately disclosed the potential aesthetic and
viewshed impacts of the project. Nonetheless, the last sentence on page 4-5 of the Draft EIR is
revised as follows:
However, because the views are considered private, are not considered to be of public benefit, and
are not protected by any City regulation or policy, impact will be less than significant.
The Draft EIR presents substantial evidence regarding the potential aesthetic impacts of the
proposed project and describes how project features will reduce impacts (pages 4-5 and 4-12). No
significant impact will result.
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Response 10-16
Building design will feature the use of earth-toned stucco and terra cotta tile roof. As seen in Figure
4-2b on page 4-9 of the Draft EIR, the proposed building colors will match the surrounding
commercial development. While the proposed buildings will be noticeably taller than the
surrounding uses, the aesthetic impact from the proposed project remains less than significant, as
analyzed in the EIR and restated in Response 10-15.
Response 10-17
This comment expresses unsubstantiated opinion, and does not state any facts contrary to the
analysis or conclusions in the EIR. As discussed on pages 4-13 and 4-14, all outdoor lighting must
comply with Ordinance 655 to avoid impact to Palomar Observatory. See Response 6-10 for a full
discussion of lighting impacts and mitigation. Pursuant to mitigation measure A-1, the City has
included the following condition of approval for the project:
Final construction plans shall demonstrate that all exterior lighting shall comply with Mount
Palomar Lighting Ordinance 655, be directed down and fully shielded. Lighting onto adjacent
properties shall be limited to the greatest extent possible.
Compliance with this standard project review requirement constitutes compliance with mitigation
measure A-1 and will ensure a less than significant impact. This information clarifies how the City
will implement the mitigation measure (CEQA Guidelines Section 15088.5 [b]). No new measure is
proposed; therefore, recirculation of the Draft EIR is not required.
Response 10-18
The comment is incorrect. The last sentence on page 4-18 states that the air quality conditions are
not reflected by the closest air quality monitoring stations due to the stations’ distances from the
project site.
Response 10-19
Air Quality impacts are addressed beginning at EIR page 4-17. The project will comply with all
federal, state, and local regulations related to air quality and air emissions. The applicant, Universal
Health Services (UHS), has indicated that their other hospital projects in the South Coast Air Basin
operated by UHS do not emit toxic air pollutants; thus, SCAQMD would not require the proposed
project to obtain a permit for toxic air pollutants. As shown in Table 4-6 (page 4-25 of the Draft
EIR), regional emissions from the operation of the proposed project are estimated to produce air
pollutant emissions above the SCAQMD significanc e t h r e s h o l d s f o r C O a n d R O G . A s s u c h ,
regional emissions associated with the operational phase of the project will result in a significant air
quality impact related to ROG and CO. See EIR pages 4-26 through 4-29 for discussion of
mitigation measures.
Response 10-20
This comment does not state any facts contrary to the analysis or conclusions in the EIR. The EIR
analysis utilized the URBEMIS2002 air modeling program, which is an accepted model. The
URBEMIS2002 summary report and analysis were made available for public review at the same time
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ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
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as the Draft EIR, and are incorporated as part of the EIR. Please refer to Response 7-10 regarding
the statement of assumptions for construction emissions, as reported in Appendix B.
Response 10-21
This comment expresses unsubstantiated opinion, and does not state any facts contrary to the
analysis or conclusions in the EIR. The EIR air quality analysis identifies the end state of intersection
conditions since the project requires these improvements over the long term. The analysis correctly
concludes that because intersections will continue to operate at LOS D, SCAQMD methodology
does not require CO hot spot analysis. Also, as stated on page 4-25 of the EIR, CO concentrations
in the area fall far below air quality impact thresholds.
Response 10-22
Please refer to Response 10-5 and 10-19 regarding hazardous materials, waste, or air emissions
during operations of the proposed hospital. As stated in Response 10-5, no incinerator is proposed
as part of this project and the project will result in a less than significant impact with regard to the
routine transport, use, or disposal of hazardous materials or waste. Hazardous materials impacts
will be regulated and mitigated through federal, state, and local laws and policies. At the local level
the Riverside County Department of Environmental Health and Fire Department will regulate the
transport, use and disposal of hazardous materials associated with the proposed project. A health
risk assessment of the fate and transport of hazardous materials is not required for the project and
no additional analysis is required.
Response 10-23
This comment expresses unsubstantiated opinion, and does not state any facts contrary to the
analysis or conclusions in the EIR. Please refer to Response 10-12.
Response 10-24
This comment does not state any facts contrary to the analysis or conclusions in the EIR. Please
refer to Responses 7-39 and 7-41 for a discussion of water quality impacts.
Response 10-25
In response to the comment, under the “Rancho California Water District Urban Water
Management Plan” subheading on page 4-34 of the Final EIR, the third sentence of the second
paragraph has been revised to read as follows:
The Master Plan projected demands for the project site are based on use of the site as 30 acres
of Business Park/Industrial (1500 gallons per day per acre) and 6 acres of Estate Residential
(0.75 acre-feet per acre), resulting in a total of 55 acre-feet for the project area.
The revision does not affect any of the facts, analyses or impact conclusions contained in the EIR.
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Response 10-26
This comment expresses unsubstantiated opinion, and does not state any facts contrary to the
analysis or conclusions in the EIR. The conclusion on page 4-35 is summarized from the Water
Supply Assessment (WSA), which was prepared and provided by the serving agency, the Rancho
California Water District (RCWD). As stated on page 6 of the WSA, the 2005 Water Facilities
Master Plan estimates a demand of 129,545 acre feet per year for 2025 and the projected water
demand for the proposed project is 42 acre feet per year. The City concludes that the WSA
provided by the RCWD fully complies with California Water Code Section 10910. The RCWD has
appropriately determined that the District has sufficient water supply for the project. See RCWD
SB610 Water Supply Assessment in Support of the Temecula Medical Center, City of Temecula, dated
August 29, 2005, at EIR Appendix G.
Response 10-27
As stated on page 4-37 of the Draft EIR, to address habitat conservation plans that apply to the
project site, a comprehensive biological resource survey and focused surveys for the Burrowing
Owl were conducted, pursuant to the Multi-Species Habitat Conservation Plan (MSHCP) guidelines.
The surveys concluded that no protected species or habitats and no Burrowing Owls occur on the
project site (see Appendix E of this EIR).
U.S. Army Corps of Engineers and California Department of Fish and Game jurisdiction may apply
under Alternative 4, Access from Dartolo Road (page 5-14 of the Draft EIR) and Alternative 5,
Access from De Portola Road and Dartolo Road (page 5-19 of the Draft EIR). Because this is
evaluated as a project alternative, rather than as the proposed project, no additional surveys or
mitigation are required per CEQA at this time. No further analysis is required.
Response 10-28
This comment expresses unsubstantiated opinion, and does not state any facts contrary to the
analysis or conclusions in the EIR. The proposed project is consistent with Policy 5.2, which
supports Goal 5 of the Land Use Element in the City’s General Plan. As written in the General Plan:
Goals are broad statements of community desires, purpose or direction. Policies serve as guides
to the City Council, Planning Commission, other City commissions and boards, and City staff in
reviewing development proposals and making other decisions that affect the future growth and
development of Temecula.
General Plan goals are written as broad statements describing the cumulative outcome of
implementing individual policies. The Draft EIR presents substantial evidence regarding the
potential aesthetic impacts of the proposed project and describes how project features will reduce
impacts (pages 4-5 and 4-12). However, because the City of Temecula Municipal Code does not
contain any view protection regulations, no significant impact results.
Pursuant to mitigation measure A-3, the City has included the following conditions of approval for
the project:
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A combination of large (no less than 24-inch box) Afghan Pines and California Pepper trees (or
other large screen trees) shall be provided along the northern perimeter of the project to screen
off-site views of the development as approved by the Director of Planning.
A landscaped berm shall be provided along the northern property lines adjacent to the
residentially zoned lots and DePortola, with mature (24” and 36” box) screen trees to screen the
view of the buildings and reduce the amount of glare from the project site, subject to approval
by the Director of Planning. A cross section shall be provided on grading and landscape plans
verifying the buffer area.
Therefore, the amount and conditions under which additional landscaping is required on the
northern boundary of the site have been defined. Compliance with these conditions of approval
constitutes compliance with mitigation measure A-3, and will ensure a less than significant impact.
This information clarifies how the City will implement the mitigation measure (CEQA Guidelines
Section 15088.5 [b]).
Response 10-29
This comment does not state any facts contrary to the analysis or conclusions in the EIR. Please
refer to Responses 10-3 regarding operations and number of employees. Growth inducing impacts
are discussed on page 6-4 and 6-5 of the Draft EIR. As stated on page 6-5, the proposed project is
not anticipated to induce population or jobs growth beyond that which is already planned for and
anticipated by adopted land use policies. As stated on Pages 6-4 and 6-5 of the Draft EIR, the
additional commercial, professional and medical-office support development that may result from
development of the hospital is consistent with adopted General Plan and zoning designations for
surrounding sites, is consistent with General Plan policies to expand medical and other high-
technology employment opportunities, and would not induce further growth in these sectors
beyond that anticipated by the City’s General Plan. The proposed hospital is responding to medical
care needs associated with past and current growth, and is not a mechanism to spur additional
growth within the City and region. No further analysis is required.
Response 10-30
This comment expresses unsubstantiated opinion, and does not state any facts contrary to the
analysis or conclusions in the EIR. Please refer to Response 10-8. As described in Section 4.4 Land
Use and Planning of the Draft EIR, the proposed project upon amendment of the General Plan as
proposed by the project is considered to be consistent with the City’s General Plan, which was
found to be consistent with all Southern California Association of Governments (SCAG) Regional
Transportation Plan, and Regional Comprehensive Plan and Guide, and Growth Visioning policies
within the General Plan EIR (General Plan EIR at 5.9-14 through 5.9-23). No further analysis is
required.
Response 10-31
This comment expresses unsubstantiated opinion, and does not state any facts contrary to the
analysis or conclusions in the EIR. Section 4.5, Noise, described a range in time provided in the City
of Temecula Municipal Code (Section 8.32.020) which limits construction to between the hours of
6:30 A.M. and 6:30 P.M., Monday through Friday, 7:00 A.M. and 6:30 P.M. on Saturday, and never on
Sunday or holidays. No “pile drivers” are anticipated. As stated in the EIR, the primary source of
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vibration noise will be large bulldozers, which for this project is below the noise impact criteria. See
EIR page 4-55. No additional analysis is required.
Response 10-32
This comment expresses unsubstantiated opinion, and does not state any facts contrary to the
analysis or conclusions in the EIR. Please refer to Response 6-7 regarding the noise analysis and a
noise threshold. The commentors opinion regarding the appropriate threshold for ambient noise
levels is noted. However, as noted on page 4-51 of the Draft EIR, a significant impact will occur
only if project traffic increases the CNEL at any existing noise-sensitive receptor by an audible
amount of 3dB or more. This is a commonly accepted threshold of significance for ambient noise
because the average human cannot distinguish between sounds that are only 1 dB louder or quieter
than each other. No further analysis is required.
Responses 10-33 and 10-34
This comment expresses unsubstantiated opinion, and does not state any facts contrary to the
analysis or conclusions in the EIR. Please refer to Responses 6-7 and 6-8 regarding the helicopter
noise analysis and Response 10-4 regarding siren noise. The commentor’s opinions regarding the
impact of helicopter noise on horses is acknowledged. However, CEQA does not require the
unique analysis of impacts of noise on horses or other domestic animals. CEQA noise thresholds
are designed to analyze the impact of noise on persons, particularly persons at sensitive receptors.
No further analysis is required.
Response 10-35
This comment expresses unsubstantiated opinion, and does not state any facts contrary to the
analysis or conclusions in the EIR. Please refer to Responses 6-7 and 6-8 regarding the helicopter
noise analysis. There is no plan to “expand” or designate the hospital as a “trauma center” as
suggested by the comment.
Response 10-36
As stated in CEQA guideline 15126.4 (a) (2), “mitigation measures must be fully enforceable
through permit conditions, agreements, or other legally binding instruments.” All of the mitigation
measures contained in the EIR are fully enforceable and will require future legal action or
compliance and proof will be shown in the Mitigation Monitoring and Reporting Program (MMRP).
Therefore, truck deliveries will be limited to daytime hours and no nighttime standard is necessary.
The applicant is aware of the mitigation requirement.
Response 10-37
This comment expresses unsubstantiated opinion, and does not state any facts contrary to the
analysis or conclusions in the EIR. Please refer to Response 6-7 regarding the noise analysis and a
noise threshold.
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ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
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Response 10-38
Pursuant to mitigation measure N-3, the City has included the following condition of approval for
the project:
The flight path for all helicopter traffic arriving and departing the project site shall be limited to
the Highway 79 South corridor and commercial areas, unless it is determined unsafe due to
weather conditions. Flights over residential areas shall be avoided to the greatest extent possible.
If the project is approved by the City Council, conditions of approval will be adopted by the City,
and the conditions will be enforceable measures that the applicant must comply with prior to
proceeding with different phases of the project.
Response 10-39
The roadway link analysis for traffic volumes for Margarita Road between De Portola Road and
Highway 79 South were analyzed during project buildout as shown in Table 4-24b on page 4-92 of
the Draft EIR.
The segment of Margarita Road between De Portola Road and Highway 79 South is a short
segment on which the flow and operations are directly dictated by the operations of three
signalized intersections along this section of Margarita Road (at De Portola Road, Dartolo Road, and
Highway 79 South). An intersection analysis is a better predictor of actual arterial operations than a
link analysis. These three intersections are all fully analyzed in the Draft EIR and therefore a link
analysis of Margarita Road is not necessary. No further analysis is required.
Response 10-40
Please refer to Response 7-69.
Response 10-41
This comment expresses unsubstantiated opinion, and does not state any facts contrary to the
analysis or conclusions in the EIR. As identified in public testimony at the November 16 Planning
Commission public hearing, the applicant completed a thorough search of sites located within
Temecula, including sites within the immediate I-15 corridor, to identify sites that meet appropriate
size and access criteria. Only the proposed project site meets the applicant’s needs in terms of size
and access. No further analysis of alternative sites is required.
Response 10-42
This comment expresses unsubstantiated opinion, and does not state any facts contrary to the
analysis or conclusions in the EIR. Please refer to Responses 10-8 and 10-10.
Response 10-43
The comment is incorrect, expresses unsubstantiated opinion, and does not state any facts contrary
to the analysis or conclusions in the EIR. As stated on Page 6-4 of the Draft EIR, the proposed
project is located within an area of Temecula that is fully served by urban infrastructure systems.
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Please refer to Response 10-29, for a discussion of growth inducing impacts. No further analysis is
required.
Response 10-44
This comment provides a closing statement to the Los Ranchitos Homeowners Association
comments on the Draft EIR. No new comments are included in this closing statement. No
response is required.
Letter 11
11-1
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11. David Oberbeck, via facsimile transmittal on November 14, 2005.
Response 11-1
This written comment was received after the close of the noticed comment period. The comment
expresses opposition to the proposed project due to noise and traffic congestion and the proposed
location. This comment expresses unsubstantiated opinion, and does not state any facts contrary to
the analysis or conclusions in the EIR. The EIR analysis concludes that project traffic impacts will be
less than significant with mitigation, and that except for helicopter noise impacts, noise issues will
either be less than significant or can be addressed through mitigation. No further response is
required.
Letter 12
12-1
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12. Roger Ziemer, President, Murrieta Temecula Group, November 15, 2005.
Response 12-1
This written comment was received after the close of the noticed comment period. The comment is
noted. The Murrieta Temecula Group notes its support of the proposed hospital and emphasizes
the need for additional hospital facilities in the area. This comment does not address an
environmental issue or raise any question regarding the analysis or conclusions in the EIR. No
response is required.
Letter 13
13-1
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13. Linda Betts, via email on November 16, 2005.
Response 13-1
This written comment was received after the close of the noticed comment period. The comment
asserts opposition to the proposed De Portola Road access and building height. As stated on page
3-7 of the Draft EIR, the proposed De Portola Road driveway at the northeast corner of the project
site will serve as secondary access, with turning movements restricted to in and out right turns and
in only left turns. Left turns from the site onto De Portola Road will not be permitted. The traffic
analysis conducted for the project identified no significant impact to De Portola Road. Also, as
noted in Response 10-10, the City’s General Plan Circulation Element designates De Portola Road
as a four-lane roadway, with the ultimate cross section to include horse trails consistent with the
character of the area. Any future widening of De Portola Road will take into account traffic safety
issues.
The Draft EIR at pages 4-5 through 4-13, presents the analysis of visual character and quality impacts
associated with the proposed hospital. Two photographic renderings are presented, one illustrating
views from a hillside to the north overlooking the project site (presented in the Draft EIR as Figures
4-2a and 4-2b), and a second illustrating conditions just north of the intersection of Pio Pico Road
and De Portola Road (presented in the Draft EIR as Figures 4-3a and 4-3b). As noted on page 4-5 of
the Draft EIR, the project will be visible from several residential lots north of the project site.
However, while the project can be seen from the north, views of Palomar Mountain from areas
north of the project site will not be blocked.
At the request of the Santiago Ranchos Property Association, the applicant placed tethered balloons
on the project site on Saturday, November 12, 2005 to provide residents information regarding the
proposed height of the hospital towers. The renderings and use of balloons to indicate the
proposed project’s height are standard and accepted techniques used to analyze the aesthetic
impacts of a project under CEQA.
The Draft EIR presents substantial evidence regarding the potential aesthetic impacts of the
proposed project and describes how project features will reduce impacts to less than significant
(pages 4-5 and 4-12 of the Draft EIR). The comment is acknowledged, and no further CEQA
analysis is required.
Letter 14
14-1
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14. Jon Silver, President, Covenant Development, via email on November 15, 2005.
Response 14-1
This written comment was received after the close of the noticed comment period. The comment is
acknowledged. The comment states that Covenant Development supports the proposed hospital.
This comment does not address an environmental issue or raise any question regarding the analysis
or conclusions in the EIR. No response is required.
Letter 15
15-1
15-2
15-3
15-3
Cont.
15-4
15-4
Cont.
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15. Gloria D. Smith, Adams Broadwell Joseph & Cardozo, November 16, 2005
Response 15-1
This written comment was received after the close of the noticed comment period. This comment
provides an introduction to the Adams Broadwell Joseph & Cardozo comments on the Draft EIR.
No response is required. This letter represents a second comment letter from the same party,
reiterating and expanding upon some of the comments made in the October 28, 2005 letter (see
Response to Comment to Letter #7).
Response 15-2
The comment provides an introduction to supplemental comments, from SWAPE, consultants to
Adams Broadwell Joseph & Cardozo, on the leaking underground fuel tanks (LUFTs). The City
acknowledges the LUFTs in the vicinity of the project site. Refer to Responses 2-2 through 2-7 and
Response 7-18.
Response 15-3
Please refer to Responses 7-18 and 7-19.
Response 15-4
Please refer to Response 7-18, 7-19, and 7-20.
Letter 16
16-1
Responses to Comments on the Draft EIR Received After Close of Public Comment Period
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT
9-295 TEMECULA REGIONAL HOSPITAL
16. O.B. Johnson, Chairman of the Board, Murrieta Chamber of Commerce, November 16, 2005.
Response 16-1
This written comment was received after the close of the noticed comment period. The comment is
acknowledged. The comment states that the Murrieta Chamber of Commerce supports the
proposed hospital, and highlights the importance of additional hospital facilities in the area. This
comment does not address an environmental issue or raise any question regarding the analysis or
conclusions in the EIR. No response is required.
Letter 17
17-1
17-1
Cont.
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT 9-298 TEMECULA REGIONAL HOSPITAL
17. Helen Chichester, November 16, 2005.
Response 17-1
This written comment was received after the close of the noticed comment period. . The comment
states opposition to the proposed project location, size, and impact on the Los Ranchitos
neighborhood. Please refer to Responses 11-1 and 13-1. This comment expresses unsubstantiated
opinion, and does not state any facts contrary to the analysis or conclusions in the EIR. No further
response is required.
Letter 18
18-1
Responses to Comments on the Draft EIR Received After Close of Public Comment Period
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL 9-300
18. Don L. Rhodes, November 21, 2005.
Response 18-1
This written comment was received after the close of the noticed comment period. The comment
asserts opposition to the proposed De Portola Road access and supports access from Dartolo Road.
As stated on page 3-7 of the Draft EIR, the De Portola Road driveway at the northeast corner of the
project site will serve as secondary access, with turning movements restricted to in and out right
turns and in only left turns. Left turns from the site onto De Portola Road will not be permitted. The
traffic analysis conducted for the project identified no significant impact to De Portola Road.
Alternative 4: Access from Dartolo Road on pages 5-11 through 5-14 of the Draft EIR presents an
analysis of a secondary access from the east of the project site via Dartolo Road in lieu of the
proposed driveway connection to De Portola Road. The analysis concluded that traffic and
biological resource impacts of Alternative 4 could be greater than those associated with the
proposed project. Therefore, secondary access via De Portola Road is the preferred access
compared to Dartolo Road. No further analysis is required.
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT 10-1 TEMECULA REGIONAL HOSPITAL
10.0 Errata
In September 2005, the City of Temecula published the Draft Environmental Impact Report (Draft
EIR) for the Temecula Regional Hospital. Since publication of the Draft EIR, but prior to its
certification by the Temecula City Council, in response to written comments received both during
and after the formal public review period for the Draft EIR, the City has determined it appropriate to
make revisions to the Draft EIR that are non-substantive in nature. The City Council of the City of
Temecula has elected to use written documents referenced as errata as the means by which
information received prior to certification of an Environmental Impact Report (EIR) is memorialized.
Each erratum is intended to clarify, amplify, or make insignificant modifications to the EIR. The term
errata does not and should not be interpreted to mean that significant error or mistake is present in
the EIR.
The City has reviewed the EIR recirculation requirements set forth in 14 California Code of
Regulations, Section 15088.5 and has determined that the following changes, clarifications, and/or
amplifications do not constitute “significant new information,” as such phrase is used in the State
CEQA Guidelines, because the EIR prepared for this project is neither changed in any manner that
deprives the public of a meaningful opportunity to comment upon a substantial adverse
environmental effect arising from the project, nor is the City declining to implement either a feasible
mitigation measure or impact avoidance measure.
In this errata, revisions and clarifications to the EIR in response to comments and information
received on the Draft EIR are indicated by strikeout (DEIR text removed) or underline (text added to
the Final EIR), and as presented herein, are considered wholly part of the Final EIR. Entire pages
with errata are included on the following pages and explained below.
Errata pages summary:
• Pages 1-5, 1-34, 2-1, 2-2, 2-3, and 3-9 have been revised to delete the word “Focused.”
• Pages 1-9, 1-10, 1-12, and 1-13, air quality mitigation measures have been revised and
clarified.
• Page 1-20 transportation mitigation measure, T-5, has been included to encourage the use
of transit.
• Page 2-2 has been revised to include air quality and land use and planning to the bulleted
list, under the Scope of Environmental Analysis subheading.
• Page 4-5 has been revised to delete part of the last sentence of the page.
• Page 4-19, Table 4-1, Air Pollution Sources, Effects, and Standards, has been revised to
correct the inaccuracy regarding the California PM10 standard.
• Pages 4-26, 4-27 and 4-28, air quality mitigation measures have been revised and clarified.
• Page 4-33, under the “Storm Water Drainage and Water Quality” subheading, the first
sentence of the first paragraph has been revised and clarified.
• Page 4-34, under the “Rancho California Water District Urban Water Management Plan”
subheading the third sentence of the second paragraph has been clarified.
• Page 4-94 transportation mitigation measure, T-5, has been included to encourage the use
of transit.
Errata
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL 10-2
• Pages 8-1 through 8-3 have been revised to include references from the response to
comment sections, 9.0 and 9.1, and the references from the Initial Study that were
incorporated by reference into the EIR.
Executive Summary
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT 1-5 TEMECULA REGIONAL HOSPITAL
comment period for the proposed Mitigated Negative Declaration was March 8, 2005 through April
6, 2005. At a public hearing held on April 20, 2005, the City heard public input and testimony and
determined that an Focused EIR analyzing potential aesthetics, air quality, hydrology and
groundwater, land use and planning, noise, and transportation impacts should be prepared for this
project. Comments received from the U.S. Fish and Wildlife Service on the proposed Mitigated
Negative Declaration have been addressed through analysis of project alternatives in this Focused
EIR. The scope of the project has not changed.
Required Actions
While the overall project must comply with the requirements of the City Planning Department, the
building requirements for the hospital buildings are under the sole control of the State of California,
Office of Statewide Health Planning and Development. As a result, to the extent required by law all
references in the EIR with respect to building and occupancy permits are intended to apply only to
the non-hospital facilities.
The project is anticipated to require the following public actions and approvals.
Agency Action
City of Temecula City Council
Approval of General Plan Amendment to eliminate the
Z2 overlay shown in the General Plan, an amendment
to the Official Zoning Map to change the zoning from
Planned Development Overlay (PDO) 8 and
Professional Office to PDO-9, and the incorporation of
PDO-9 into the Temecula Municipal Code with will
allow building height up to 115 feet for 30% of roof
areas for hospitals
Approval of a Development Plan and Conditional Use
Permit to provide for the development of the project
site with the proposed uses, structures, parking,
landscaping, and other components, and to establish
development standards and conditions of use for the
project
Approval of other actions related to the implementation
of the above actions and mitigation of environmental
effects
Medical Office Building and fitness center building and
occupancy permits
Adoption of the Focused EIR
Hospital building and occupancy permits
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V
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CITY OF TEMECULA
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P
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1
2
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s
Level of Impact after Mitigation
AQ
-
1
1
.
A
l
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a
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V
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h
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e
C
o
d
e
2
3
1
1
4
.
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a
t
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a
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o
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t
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V
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C
o
d
e
23
1
1
4
,
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ec
t
i
o
n
s
2
3
1
1
4
(
b
)
(
2
)
(
F
)
,
(
b
)
(
F
)
,
(e
)
(
2
)
a
n
d
(
e
)
(
4
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a
s
a
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.
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s
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h
a
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s
u
f
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em
i
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o
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t
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i
n
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d
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t
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l
s
,
sh
a
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p
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d
w
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w
a
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r
,
w
h
i
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h
s
h
a
l
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p
r
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r
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y
m
a
n
a
g
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d
s
o
as
t
o
p
r
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v
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n
t
r
u
n
o
f
f
,
t
o
r
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d
u
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e
/
el
i
m
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n
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t
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h
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c
o
n
s
t
r
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c
t
i
o
n
a
r
e
a
.
AQ
-
1
2
.
D
u
r
i
n
g
t
h
e
c
o
u
r
s
e
o
f
t
h
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p
r
oj
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c
t
g
r
a
d
i
n
g
a
n
d
c
o
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s
t
r
u
c
t
i
o
n
,
t
h
e
ap
p
l
i
c
a
n
t
/
p
e
r
m
i
t
t
e
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s
h
a
l
l
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n
s
u
r
e
th
e
s
w
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e
p
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n
g
o
f
a
d
j
a
c
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n
t
s
t
r
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t
s
an
d
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d
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o
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v
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n
t
t
h
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p
l
a
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m
e
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t
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c
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m
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l
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t
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o
f
d
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th
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a
d
w
a
y
.
S
w
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p
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f
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a
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n
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a
s
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r
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t
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o
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o
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n
g
a
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d
/
o
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c
o
n
s
t
r
u
c
t
i
o
n
.
AQ
-
1
3
.
D
u
r
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n
g
p
e
r
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o
d
s
o
f
h
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h
w
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s
(
i
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.
,
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s
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ff
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c
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g
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p
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d
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p
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,
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r
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d
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2
0
m
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av
e
r
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r
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a
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r
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g
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n
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d
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s
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nu
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s
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o
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r
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f
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n
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n
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r
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r
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t
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o
n
.
AQ
-
1
4
.
T
h
e
a
p
p
l
i
c
a
n
t
/
p
e
r
m
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t
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s
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al
l
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s
e
z
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r
o
V
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l
a
t
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l
e
O
r
g
a
n
i
c
Co
m
p
o
u
n
d
s
(
V
O
C
)
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o
n
t
e
n
t
a
r
c
h
i
t
ec
t
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r
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l
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o
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t
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n
g
s
d
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r
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n
g
t
h
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co
n
s
t
r
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c
t
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o
n
a
n
d
r
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p
a
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n
t
i
n
g
o
f
t
h
e
p
r
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j
e
c
t
t
o
t
h
e
m
a
x
i
m
u
m
ex
t
e
n
t
f
e
a
s
i
b
l
e
.
T
h
i
s
m
e
a
s
u
r
e
w
i
l
l
r
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d
u
c
e
V
O
C
(
R
O
G
)
e
m
i
s
s
i
o
n
s
by
9
5
p
e
r
c
e
n
t
o
v
e
r
c
o
n
v
e
n
t
i
o
n
ar
c
h
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t
e
c
t
u
r
a
l
c
o
a
t
i
n
g
s
.
T
h
e
fo
l
l
o
w
i
n
g
w
e
b
s
i
t
e
s p
r
o
v
i
d
e
s l
i
s
t
s
o
f
m
a
n
u
f
a
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t
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r
e
r
s
o
f
z
e
r
o
V
O
C
co
n
t
e
n
t
c
o
a
t
i
n
g
s
:
Ta
b
l
e
1
-
1
Su
m
m
a
r
y
o
f
E
n
v
i
r
o
n
m
e
n
t
a
l
I
m
p
a
c
t
s
a
n
d
M
i
t
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g
a
t
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o
n
M
e
a
s
u
r
e
s
CIT
Y
O
F
T
E
M
E
C
U
L
A
ENVIRONMENTAL IMPACT REPORT
1 -13
GENERAL PLAN UPDATE
Po
t
e
n
t
i
a
l
E
n
v
i
r
o
n
m
e
n
t
a
l
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m
p
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c
t
M
i
t
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g
a
t
i
o
n
M
e
a
s
u
r
e
s
Level of Impact after Mitigation
h
t
t
p
:
/
/
w
w
w
.
a
q
m
d
.
g
o
v
/
p
r
d
a
s
/
b
r
o
c
h
u
r
e
s
/
S
u
p
e
r
-
Co
m
p
l
i
a
n
t
_
A
I
M
.
p
d
f
ht
t
p
:
/
/
w
w
w
.
d
e
l
t
a
-in
s
t
i
t
u
t
e
.
o
r
g
/
p
u
b
l
i
c
a
t
i
o
n
s
/
p
a
i
n
t
s
.
p
d
f
AQ
-
1
5
.
T
h
e
p
r
o
j
e
c
t
s
i
t
e
s
h
a
l
l
b
e
w
a
t
e
re
d
d
o
w
n
n
o
l
e
s
s
t
h
a
n
3
t
i
m
e
s
(
n
o
t
in
c
l
u
d
i
n
g
t
h
e
m
o
r
n
i
n
g
a
n
d
e
v
e
n
i
n
g
w
a
t
e
r
d
o
w
n
)
d
u
r
i
n
g
co
n
s
t
r
u
c
t
i
o
n
a
n
d
/
o
r
g
r
a
d
i
n
g
ac
t
i
v
i
t
i
e
s
t
o
r
e
d
u
c
e
d
u
s
t
.
Op
e
r
a
t
i
o
n
s
AQ
-
1
6
.
A
l
l
r
e
f
u
s
e
a
r
e
a
s
s
h
a
l
l
b
e
co
m
p
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e
t
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l
y
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n
c
l
o
s
e
d
a
n
d
i
n
c
l
u
d
e
a
co
v
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r
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d
r
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o
f
s
u
b
j
e
c
t
t
o
t
h
e
a
p
p
r
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v
a
l
o
f
t
h
e
P
l
a
n
n
i
n
g
D
i
r
e
c
t
o
r
.
Re
f
u
s
e
a
r
e
a
s
s
h
a
l
l
b
e
m
a
i
n
t
a
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e
d
w
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t
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n
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n
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n
c
l
o
s
e
d
s
t
r
u
c
t
u
r
e
an
d
c
o
v
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r
e
d
a
t
a
l
l
t
i
m
e
s
,
e
x
c
e
p
t
du
r
i
n
g
p
i
c
k
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u
p
t
i
m
e
s
f
o
r
o
f
f
-
s
i
t
e
re
m
o
v
a
l
.
AQ
-
1
7
.
T
h
e
a
p
p
l
i
c
a
n
t
/
p
e
r
m
i
t
t
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e
s
h
a
l
l
pr
o
v
i
d
e
a
c
l
e
a
r
p
a
t
h
o
f
t
r
a
v
e
l
f
o
r
pe
d
e
s
t
r
i
a
n
s
,
i
n
c
l
u
d
i
n
g
d
i
r
e
c
t
i
o
n
a
l
si
g
n
s
t
o
/
f
r
o
m
t
h
e
p
u
b
l
i
c
s
t
r
e
e
t
s
(D
e
P
o
r
t
o
l
a
R
o
a
d
a
n
d
H
i
g
h
w
a
y
7
9
So
u
t
h
)
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o
p
r
o
m
o
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e
a
l
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e
r
n
a
t
i
v
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tr
a
n
s
p
o
r
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a
t
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o
n
.
No
i
s
e
–
H
e
l
i
c
o
p
t
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r
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l
i
g
h
t
s
Th
e
6
5
d
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o
m
m
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n
i
t
y
N
o
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q
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y
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e
v
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l
(C
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c
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o
c
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Hi
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Executive Summary
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL 1-34
hour (2,209 inbound and 1,489 outbound). Some vehicle trips would be confined to the area,
while others would travel outside the project area to surrounding counties and urban centers and
affect the regional transportation system. Adverse impacts to the circulation network would occur if
roadway improvements and trip reduction measures and programs are not implemented. The
mitigation discussion in Section 4.6, Transportation, identifies some of the regional roadway
improvements that will be pursued to accommodate anticipated future traffic volumes. Also, other
roadway system enhancements will be pursued over the long term to implement the recently
updated General Plan Circulation Element.
In accordance with City of Temecula regulations, each development project will be assessed its fair
share for identified roadway improvements. Payment of the City's traffic impact fees will allow the
City to fund signalization, roadway widening, and other transportation programs and improvements
necessary to maintain acceptable levels of service at local intersections.
Increases in traffic generated by new development are generally anticipated to be mitigated to less
than significant levels through payment of fair share fees and citywide and project-level roadway
improvements. The proposed project will not result in any cumulative impacts to intersections, but
the following roadway links will continue to operate over capacity:
Highway 79 South west of Pechanga Parkway
Highway 79 South west of Margarita Road
Margarita Road: De Portola Road to Dartolo Road
Margarita Road: Dartolo Road to Highway 79 South
Cumulative impacts to these roadway links at project build-out will be significant and unavoidable.
Furthermore, some intersections near I-15 will continue to experience LOS E and F conditions into
the future. Cumulative impacts, as noted in the General Plan EIR, will be significant and
unavoidable.
Areas of Controversy and Issues to be Resolved
Through the Notice of Preparation process for the project, the concerns shown in Table 1-2 were
raised. Additionally, at a scoping session, held on April 20, 2005 where the City received public
input and testimony, the City determined that a Focused EIR analyzing potential impacts identified
in the attached NOP should be prepared for this project in response to resident and concerns
regarding transportation, aesthetic, and noise impacts of the proposed project, and agency
concerns regarding potential biological impacts associated with the extension of Dartolo Road, as
described in Alternatives 4 and 5 of this EIR.
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT 2-1 TEMECULA REGIONAL HOSPITAL
2.0 Introduction
Purposes of the Environmental Impact Report
This Draft Environmental Impact Report (EIR) has been prepared pursuant to the California
Environmental Quality Act (CEQA) and the CEQA Guidelines to analyze the potential
environmental impacts associated with the construction and long-term operation of the proposed
Temecula Regional Hospital, also referred herein as “the project.”
According to the Guidelines for the Implementation of the California Environmental Quality Act
(CEQA Guidelines, California Code of Regulations, Section 15000 et seq.), an “EIR is an
informational document which will inform public agency decision makers and the public generally
of the significant environmental effects of a project on the environment, identify possible ways to
minimize the significant effects, and describe alternatives to the project” Accordingly, this EIR is an
information document to be used by decision makers, public agencies, and the general public. It is
not a policy document of the City of Temecula. The document provides information regarding the
potential environmental impacts related to the construction and long-term operation of the project.
The EIR will be used by the City of Temecula in assessing impacts of the proposed project. If the
project is approved, feasible mitigation measures identified in the Final EIR will be applied to the
project during project implementation.
Legal Requirements
This EIR has been prepared in accordance with the California Environmental Quality Act of 1970
(Public Resources Code, Section 21000 et seq.) and the Guidelines for Implementation of the
California Environmental Quality Act (CEQA Guidelines) published by the Public Resources Agency
of the State of California (California Code of Regulations, Title 14, Section 15000 et seq.), and in
accordance with the City of Temecula’s CEQA Guidelines. The City of Temecula is the lead agency
for this EIR, as defined in Section 21067 of CEQA.
This EIR meets the content and analysis requirements of a Project EIR, as defined in Section 15161
of the State CEQA Guidelines. A Project EIR examines the environmental impacts of a specific
development project. This type of EIR focuses primarily on the changes in the environment that
would result from the development project. A Project EIR shall examine all phases of the project
including planning, construction, and operation.
Prior to preparing this EIR, the City of Temecula previously circulated an Initial Study (SCH #
2005031017) for this project with the intent of preparing a Mitigated Negative Declaration. The
comment period for the proposed Mitigated Negative Declaration was March 8, 2005 through April
6, 2005. At a public hearing held on April 20, 2005, the City heard public input and testimony and
determined that an Focused EIR analyzing potential aesthetics, air quality, hydrology and
groundwater, land use and planning, noise, and transportation impacts should be prepared for this
project. Comments received from the U.S. Fish and Wildlife Service on the proposed Mitigated
Introduction
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL 2-2
Negative Declaration have been addressed through analysis of project alternatives in this Focused
EIR. The scope of the project has not changed.
This EIR was prepared by environmental planning consultants under the direction of City staff. All
information, analysis, and conclusions contained in this document reflect the independent review
and judgment of the City.
Scope of the Project
The project analyzed in this EIR is the development of a regional hospital serving the Temecula area.
The Development Plan and Conditional Use Permit is a request to construct approximately 565,260
square feet of hospital, medical office, cancer center and a fitness rehabilitation center space on
35.31 acres. The Tentative Parcel Map (Map 32468) is a request to consolidate eight (8) lots into
one (1) parcel.
Scope of the Environmental Analysis
Pursuant to CEQA and the CEQA Guidelines, an Initial Study was prepared for this project. The
Initial Study concluded that adoption and implementation of the proposed General Plan might have
a significant effect on the environment with respect to the following:
Aesthetics
Air Quality
Land Use and Planning
Hydrology and Water Quality
Noise
Transportation
Appendix A contains the Initial Study and NOP for the project. Appendix B contains water supply
assessment. Appendix C contains the noise study. Appendix D contains the Traffic Study.
Appendix E contains a Burrowing Owl Survey Report. Appendix F contains a letter from the project
architect regarding project configuration. Appendix G contains a water supply assessment prepared
for the project by the Rancho California Water District. All other reference documents cited in the
EIR are on file with the City of Temecula Planning Department, 43200 Business Center Drive,
Temecula, CA 92589.
Background
A Notice of Preparation (NOP) for this EIR was issued by the City on August 3, 2005 in accordance
with the requirements of the California Code of Regulations, Title 14, Sections 15082(a), 15103, and
15375. The NOP indicated that an EIR was being prepared and invited comments on the project
from public agencies and the general public. Comment letters were received from the following
agencies (listed in the order received):
Native American Heritage Commission
Riverside Transit Agency
Riverside County Flood Control and
Water Conservation District
Introduction
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT 2-3 TEMECULA REGIONAL HOSPITAL
Pechanga Band of Luiseño Indians
Written comments received during the 30-day public review period for the NOP are included in
Appendix A of this EIR.
City staff has worked directly with the applicant, the surrounding property owners and
representatives of the Los Ranchitos and Santiago Estates Home Owners Associations to identify
key issues of concern. In addition, a City Council Subcommittee was formed to meet to discuss the
project. The City Council subcommittee formally met with the applicant and staff on September 27,
2004 and October 11, 2004. Staff met with the Santiago Estates Home Owners Association on
December 6, 2004, and held a community meeting on December 8, 2004. The community
meeting notice was mailed to the surrounding home owners within 600 feet from the project site
and approximately 45 residents and landowners were in attendance. At a public hearing held on
April 20, 2005 to consider the Draft Mitigated Negative Declaration, the City heard public input and
testimony and determined that an Focused EIR analyzing potential aesthetics, air quality, hydrology
and groundwater, land use and planning, noise, and transportation impacts should be prepared for
this project.
Public Review and Comment
This Draft EIR is available for public inspection at the City of Temecula Planning Department,
located at the 43200 Business Park Drive in Temecula. The Draft EIR is also available to the public
at the Temecula Library, located at 41000 County Center Drive, Temecula. Organizations and
individuals are invited to comment on the Draft EIR. Where possible, respondents are asked to
provide additional information which they feel is not contained in the Draft EIR, or to indicate where
information may be found.
Section 15105(d)(3) and Appendix K of the California Environmental Quality Act (CEQA) Guidelines
outline procedures whereby a lead agency may request a shortened 30-day public review period.
The City of Temecula intends to apply for a 30-day public review period for this Draft EIR, pursuant
to these provisions. Following the public review period for the Draft EIR, all comments and the
City’s responses to those comments will be incorporated within the Final EIR prior to certification of
the Final EIR by the City.
Contact Person
The primary contact person regarding information presented in this EIR is Emery Papp, Senior
Planner. Mr. Papp may be reached at (951) 694-6400, or via email at
emery.papp@cityoftemecula.org.
Project Description
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT
3-9 TEMECULA REGIONAL HOSPITAL
Agency Action
California Office of Statewide Health
Planning and Development
City of Temecula Fire Department
City of Temecula Police Department
City of Temecula Public Works
City of Temecula Departments and
Divisions overseeing construction
related development
U.S. Fish and Wildlife Service
California Department of Fish and
Game
California Department of
Transportation, Aeronautics Division
Riverside County Airport Land Use
Commission
Pechanga Band of Luiseno Indians
Approval of a Development Plan and Conditional Use
Permit to provide for the development of the project
site with the proposed uses, structures, parking,
landscaping, and other components, and to establish
development standards and conditions of use for the
project
Approval of other actions related to the implementation
of the above actions and mitigation of environmental
effects
Medical Office Building and fitness center building and
occupancy permits
Adoption of the Focused EIR
Hospital building and occupancy permits
Review and approval of fire flow, fire lanes, and fire
suppression systems
Review of security plans and systems
Approval of Mitigation Plan
Approval of street improvement plans, sewer plans,
grading plan, and water and drainage system plans
Approval of Water Quality Management Plan
Review and approval of building, electrical, plumbing,
mechanical, and sign plans and permits
Review and approval of encroachment permits
Review and approval of street trees
Approval of Burrowing Owl report/surveys
Approval of special use helipad (Heliport Site Approval
Permit)
Review of helipad
Cultural report approval and pre-excavation agreement
Aesthetics
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT 4-5 TEMECULA REGIONAL HOSPITAL
Visual Character or Quality
The residential areas north of the project site offer distant views to the south of the Palomar
Mountains, with closer views overlooking the vacant project site and developed areas surrounding
the site (see photograph in Figure 4-2a). At closer locations, the site appears as a vacant property
with introduced landscaping and native vegetation (see photo in Figure 4-3a). The view along
Highway 79 South consists of a developed and developing arterial roadway corridor, with low- and
moderate-rise structures and well-landscaped frontage areas.
The proposed project will include:
A 60,000-square-foot, 3-story medical office building (60 feet high)
An 80,000-square-foot 4-story medical office building (73 feet high)
A 408,160-square-foot hospital structure, including towers of 5 and 6 stories (up to 106 feet
high)
A 10,000-square-foot, single-story cancer center
An 8,000-square-foot, single-story fitness rehabilitation center.
The structures will be located toward the center of the site, surrounded by surface parking lots with
extensive landscaping. Per Development Code regulations, all setback areas will be landscaped as
well.
To identify potential view/aesthetic impacts from locations in the project vicinity, photographs were
taken from locations within the residential neighborhood overlooking the site and adjacent to the
site on Pio Pico Road. Figure 4-1 shows the two locations from where photographs were taken for
this aesthetics analysis. The proposed project was digitally modeled onto the photographs based on
renderings provided by the project architect.
The proposed project will be visible from various residential lots north of the project site, as
illustrated in the photograph in Figure 4-2b. However, the views are considered private, are not
considered to be of public benefit, and are not protected by any City regulation or policy. While
the hospital/medical complex will be apparently taller than surrounding development, it will appear
as infill development. As seen in Figure 4-2a, while the project site can seen from residential areas
to the north, particularly in comparison from the existing view, views of Palomar Mountain will not
be blocked by the proposed project. The elevation of De Portola Road and adjacent residences to
the north is greater than the elevation of the pad areas of the project site. Therefore, the building
height will appear slightly lower than the actual height from the residences to the north.
To soften views and blend the development with surrounding urbanization, the preliminary
landscape plan proposes numerous evergreen trees such as Afghan Pine, Coast Live Oaks, and Silk
Trees along the perimeter of the site between the residences and the hospital, which will buffer the
visual appearance of the buildings and mask the development of the site (refer to the photograph in
Figure 4-3b). Incorporation of these project features will help to reduce viewshed impacts. The
proposed height of the hospital towers will continue to obstruct views from nearby locations.
However, because the views are considered private, are not considered to be of public benefit, and
are not protected by any City regulation or policy, impact will be less than significant.
Air Quality
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT 4-19 TEMECULA REGIONAL HOSPITAL
Table 4-1
Air Pollution Sources, Effects, and Standards
Air
Pollutant State Standard
Federal Primary
Standard Sources Primary Effects
Ozone
(O3)
0.09 ppm, 1-hour
average
0.12 ppm, 1-hour
average; 0.08
ppm, 8-hour
average
Atmospheric reaction of
organic gases with nitrogen
oxides in sunlight.
Aggravation of respiratory and
cardiovascular diseases; irritation of eyes;
impairment of cardiopulmonary function;
plant leaf injury.
Carbon
Monoxide
(CO)
9.0 ppm, 8-hour
average; 20 ppm, 1-
hour average
9.0 ppm, 8-hour
average; 35 ppm,
1-hour average
Incomplete combustion of
fuels and other carbon-
containing substances such
as motor vehicle exhaust;
natural events, such as
decomposition of organic
matter.
Reduced tolerance for exercise;
impairment of mental function;
impairment of fetal development;
death at high levels of exposure;
aggravation of some heart diseases
(angina); reduced visibility.
Nitrogen
Oxides
(NOX)
0.25 ppm, 1-hour
average
0.053 ppm, annual
average
Motor vehicle exhaust;
high-temperature stationary
combustion; atmospheric
reactions.
Aggravation of respiratory illness; reduced
visibility; reduced plant growth; formation
of acid rain.
Sulfur
Dioxide
(SO2)
0.25 ppm, 1-hour aver-
age; 0.05 ppm, 24-hour
average with ozone > =
0.10 ppm, 1 hour
average or TSP > = 100
µg/m3, 24-hour average
0.03 ppm, annual
average; 0.14
ppm, 24-hour
average
Combustion of sulfur-
containing fossil fuels;
smelting of sulfur-bearing
metal ores; industrial
processes.
Aggravation of respiratory diseases
(asthma, emphysema); reduced lung
function; irritation of eyes; reduced
visibility; plant injury; deterioration of
metals, textiles, leather, finishes, coatings,
etc.
Respirable
Particulate
Matter
(PM10)
30 20 µg/m3, annual
geometric mean; > 50
µg/m3, 24-hour average
50µg/m3, annual
arithmetic mean;
150 µg/m3, 24-
hour average
Stationary combustion of
solid fuels; construction
activities; industrial
processes; industrial
processes, atmospheric
chemical reactions.
Reduced lung function; aggravation of the
effects of gaseous pollutants; aggravation
of respiratory and cardio-respiratory
diseases; increased coughing and chest
discomfort; soiling; reduced visibility
Fine
Particulate
Matter
(PM 2.5)
No Separate State
Standard
65 µg/m3, 24-hour
average; 15 µg/m3
annual arithmetic
mean
Combustion sources such as
automobiles, trucks, and
stationary sources;
atmospheric chemical
reactions.
Increased mortality; reduced lung
function; aggravation of the effects of
gaseous pollutants; aggravation of
respiratory and cardio-respiratory
diseases; increased coughing and chest
discomfort.
Lead 1.5 µg/m3, 30-day
average
1.5 µg/m3,
calendar quarter
Contaminated soil. Increased body burden; impairment of
blood formation and nerve conduction;
behavioral and hearing problems in
children.
Visibility
Reducing
Particles
Sufficient to reduce
visual range to less
than 10 miles at
relative humidity less
than 70%, 8-hour
average (9am - 5pm)
None Visibility impairment on days when
relative humidity is less than 70 percent.
µg/m3 = micrograms per cubic meter of air; ppm = parts per million parts of air, by volume.
Source: South Coast Air Quality Management District. CEQA Air Quality Handbook. November 2001 (Version 3) update.
Air Quality
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL 4-26
area, whereas a commercial development constructed pursuant to current land use regulations
could yield up to 769,059 square feet based on an assumed Floor Area Ratio of 0.5. More to the
point, the proposed uses would generate 65% fewer vehicle trips than the commercial uses on the
site assumed in the General Plan (see discussion of Alternative 2 in Section 5.0 of this EIR). Finally,
Policy 1.8 in the Land Use Element states:
Policy 1.8 Encourage future development of a community hospital and related services, as well
as a community college, major college or university.
Therefore, the proposed project is consistent with goals and policies within the General Plan.
Because the proposed project is consistent with the City of Temecula General Plan Land Use and
Open Space/Conservation Elements, it is assumed to be consistent with the AQMP and the
development’s assumptions are included in the modeling for the AQMP.
Mitigation Measures
The following mitigation measures will reduce emissions to less than significant levels for all
pollutants except NOx:
Pre-grading
AQ-1. The applicant/permittee shall coordinate with the Riverside Transit Agency (RTA) for a final
location, design, and type of staging area (or turn-out) appropriate for the project site.
Written authorization and final approved design plans shall be submitted to the City of
Temecula Planning Department.
AQ-2. The applicant/permittee shall incorporate and encourage Transportation Demand
Management (TDM) techniques for reducing vehicle trips during construction, as well as
during the daily operations of the hospital facility. TDM techniques shall include but not be
limited to the following: encouraging car and vanpooling ,providing preferential parking for
car and vanpooling, installing electric vehicle (EV) charging stations, providing preferential
parking for EVs and compressed natural gas vehicles, and offering flex hours and/or flex
schedules during the on-going operation of the facility. Written proof of such program shall
be submitted to and approved by the Planning Director prior to the issuance of a grading
permit for construction activities and prior to the issuance of a Certificate of Occupancy for
the operation of the medical offices.
AQ-3. The applicant/permittee shall incorporate energy efficiency standards appropriate for
medical facilities and professional office buildings, as defined by State of California
regulations.
AQ-4. The applicant/permittee shall submit a final landscape plan for the project site incorporating
native drought-resistant vegetation and mature trees (15 gallon, 24-inch box and 36-inch
box). If more than 100 days elapses from the time grading is complete and beginning of
construction, the City of Temecula may require temporary landscaping to reduce the
amount of dust and to prevent dust and erosion, with such temporary landscaping to be
installed at the applicant/permittee’s expense.
Air Quality
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT 4-27 TEMECULA REGIONAL HOSPITAL
AQ-5. Prior to the issuance of a grading permit and during the duration of construction activities,
the applicant/permittee shall verify in writing (to the Planning Department) that all earth-
moving and large equipment are properly tuned and maintained to reduce emissions. In
addition, alternative clean-fueled vehicles, such as PuriNOx fuel or a similar type of fuel, shall
be used where feasible. Construction equipment should be selected and deployed
considering the lowest emission factors and highest energy efficiency reasonably possible.
AQ-6. Prior to the issuance of a grading permit, a watering program shall be submitted to the City
of Temecula Public Works Department for approval. Said program shall include control of
wind-blown dust on site and on adjacent access roadways. The City Public Works Director
reserves the right to modify this requirement as necessary based upon the circumstances
that present themselves during the project construction.
AQ-7. The applicant/permittee shall prepare and submit a comprehensive Fugitive Dust Control
Plan to the City of Temecula, including compliance with SCAQMD Rule 402 – Nuisance
and Rule 403 – Fugitive Dust. The Fugitive Dust Control Plan shall include applicable best
available control measures included in Table 1 and Table 2 of Rule 403 during grading and
construction such as the following examples listed below:
Soil stabilization methods such as water and environmentally safe dust control
materials shall be periodically applied to portions of the construction site inactive
for over four days.
Establish a vegetative ground cover within 21 days after active operations have
ceased.
Apply chemical stabilizers within five working days of grading completion.
Water all roads used for vehicular traffic at least twice per daily, at least once in
the morning and at least once in the afternoon.
Restrict vehicle speeds to 15 miles per hour.
Apply water or chemical stabilizers to at least 80 percent of the surface area of
open storage piles on a daily basis when there is evidence of wind driven
fugitive dust or install temporary coverings.
Cover haul vehicles prior to exiting the site.
Direct construction traffic over established haul routes.
The Fugitive Dust Control Plan shall be reviewed and approved by the SCAQMD prior to
the commencement of grading and excavation operations. Compliance with The Fugitive
Dust Control Plan shall be subject to periodic site monitoring by the City
Grading and Construction
AQ-8. During the course of the project grading and construction, the applicant/permittee shall post
signs on the site limiting construction-related traffic and all general traffic to 15 miles per
hour or less.
AQ-9. The applicant/permittee shall establish construction equipment and supply staging areas
located at least 500 feet from the nearest property line of a residentially improved parcel.
Air Quality
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL 4-28
AQ-10. The applicant/permittee shall properly maintain all waste-related enclosures and facilities
and comply with the state emission controls to ensure against project site related odors
during construction and subsequent use.
AQ-11. All trucks exporting and/or importing fill to/from the project site shall use tarpaulins to fully
cover the load in compliance with State Vehicle Code 23114. Material transported in trucks
off site (to and/or from the site) shall comply with State Vehicle Code 23114, with special
attention to Sections 23114(b) (2) (F), (b) (F), (e) (2) and (e) (4) as amended. Material
transported on-site shall be sufficiently watered or secured to prevent fugitive dust
emissions. Lower portions of the trucks, including the wheels, shall be sprayed with water,
which shall be properly managed so as to prevent runoff, to reduce/eliminate soil from the
trucks before they leave the construction area.
AQ-12. During the course of the project grading and construction, the applicant/permittee shall
ensure the sweeping of adjacent streets and roads to prevent the placement or
accumulation of dirt in the roadway. Sweeping of adjacent streets and roads shall be done
as necessary, but not less than once per day, at the end of each day of grading and/or
construction.
AQ-13. During periods of high winds (i.e., wind speed sufficient to cause fugitive dust to impact
adjacent properties, generally wind speeds exceeding 20 miles per hour, averaged over an
hour), the applicant/permittee shall curtail all clearing, grading, earth moving and excavation
operations as directed by the City Engineer, to the degree necessary to prevent fugitive dust
created by on-site activities and operations from being a nuisance or hazard, either off-site
or on-site, or as determined by the City Engineer at his sole discretion.
AQ-14. The applicant/permittee shall use zero Volatile Organic Compounds (VOC) content
architectural coatings during the construction and repainting of the project to the maximum
extent feasible. This measure will reduce VOC (ROG) emissions by 95 percent over
convention architectural coatings. The following websites provides lists of manufacturers of
zero VOC content coatings:
http://www.aqmd.gov/prdas/brochures/Super-Compliant_AIM.pdfhttp://
http://www.aqmd.gov/prdas/brochures/Super-Compliant_AIM.pdf
http://www.delta-institute.org/publications/paints.pdf
AQ-15. The project site shall be watered down no less than 3 times (not including the morning and
evening water down) during construction and/or grading activities to reduce dust.
Operations
AQ-16. All refuse areas shall be completely enclosed and include a covered roof subject to the
approval of the Planning Director. Refuse areas shall be maintained within an enclosed
structure and covered at all times, except during pick-up times for off-site removal.
Hydrology and Water Quality
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT
4-33 TEMECULA REGIONAL HOSPITAL
Thresholds Used to Determine Level of Impact
Impacts of the proposed project to hydrology and water quality will be significant and adverse if it
will:
Create or contribute runoff water which would exceed the capacity of existing or planned storm
water drainage systems or provide substantial additional sources of polluted runoff
Otherwise substantially degrade water quality
Environmental Impact
Storm Water Drainage and Water Quality
To ensure that adequate flood control capacity is available to support new development, all
proposed development projects within the City of Temecula are may be reviewed by the Riverside
County Flood Control and Water Conservation District, at the request of the City, prior to approval
by the City of Temecula. New development projects are required to provide on-site drainage and
to pay area drainage fees per acre of development. Drainage fee revenues are used to support
capacity expansion within the local storm drain system.5 S t a t e o f C a l i f o r n i a W a t e r R e s o u r c e s
Control Board requires all development projects to prepare a Storm Water Pollution Prevention
Plan to mitigate water quality impacts during storm events that occur during construction. Through
the MS4 Permit, Temecula is required to ensure that these projects comply with the Storm Water
Pollution Prevention Plan. In addition, all commercial development proposals where the land area
represented by the proposed map or permit is 100,000 square feet or more must prepare a Water
Quality Management Plan, outlining how the project will minimize water quality impacts during
project operation.6 Compliance with these existing regulations will ensure a less than significant
impact on storm water drainage and water quality.
California Water Code Sections 10910-10915
In compliance with California Water Code Section 10910-10915, all future development projects
pursuant to the proposed General Plan that meet criteria specified in the law are required to
determine whether projected water supplies available during normal, single-dry, and multiple-dry
water years will be sufficient to satisfy demands of the proposed project, in addition to existing and
planned future uses. No major development project will be permitted to proceed unless required
determinations can be made. Compliance with existing regulations will minimize the potential for
impact. Water Code section 10910 applies to the project because the proposed hospital and
medical office building complex meets the criteria established in California Water Code section
10912 (a)(1) in square feet and potential employment.
5 Riverside County Flood Control District. “Area Drainage Fees.”
http://www.floodcontrol.co.riverside.ca.us/Downloads/Area_Drainage_Plain_Summary.pdf.
6 Riverside County Storm Water Clean Water Protection Program. Riverside County Water Quality Management Plan for
Urban Runoff, Santa Ana River Region and Santa Margarita Region. September 17, 2004.
Hydrology and Water Quality
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL 4-34
The Rancho California Water District (RCWD) owns, operates, and maintains the public water
system within which the proposed project will be located. RCWD will be the water purveyor to the
project. RCWD has prepared a water supply assessment for the proposed project, which is
included as Appendix G to this EIR. Findings and conclusions of the water supply assessment are
summarized in the following paragraphs.
Rancho California Water District Urban Water Management Plan
The development area of the proposed Temecula Regional Hospital was identified in RCWD’s 2000
Urban Water Management Plan, RCWD’s 1997 Water Facilities Master Plan, and RCWD’s recently
adopted 2005 Master Plan Update. The 2005 Water Facilities Master Plan shows an estimated
demand of 129,545 acre-feet per year for 2025. The projected water demand for the Temecula
Regional Hospital is approximately 42 acre-feet per year. This projection includes an allowance of
28 acre-feet for the hospital, 12 acre-feet for the medical office buildings, 1.2 acre-feet for the fitness
center, and 0.8 acre-feet for the proposed cancer center7. This demand has been anticipated and
included in the adopted Urban Water Management Plan and Water Facilities Master Plan for
RCWD.
According to RCWD’s Water Facilities Master Plan and 2000 Urban Water Management Plan,
RCWD has an existing and planned combined well, imported, and recycled water production
capacity of approximately 150,000 acre-feet. The ultimate annual water demand of the RCWD is
estimated to be 129,545 acre-feet, while the existing demand for 2004 was approximately 85,000
acre-feet. Based on the projected water demands for the Temecula Regional Hospital and future
demands projected for the project service area, this project demand is less than the Water Facilities
Master Plan projected demands based on land use for the project location. The Master Plan
projected demands for the project site are based on use of the site as 30 acres of Business
Park/Industrial (1500 gallons per day per acre) and 6 acres of Estate Residential (0.75 acre-feet per
acre), resulting in a total of 55 acre-feet for the project area. Therefore, the 42 acre-feet demand
estimated for the project has been provided for and can be met with existing supply capacities.
To accommodate future developments such as the Temecula Regional Hospital, the Rancho
California Water District intends to meet supply planning issues through a combination of the
following alternatives:
1. Continued practice of managing groundwater levels through natural and artificial
recharge via groundwater extracted using existing and planned RCWD-owned wells.
2. Annual water purchase of direct imported and replenishment water via Metropolitan
Water District of Southern California and from Vail Lake.
3. Orderly implementation of recycled water system use expansion as proposed to be
available.
4. Conservation measures.
Due to RCWD’s access to local groundwater sources, the availability of local groundwater sources,
and the ability to purchase imported water and store it within the basin, short-term drought
7 HKS Inc./CCRD Partners – Project Architects and Engineers.
Transportation
ENVIRONMENTAL IMPACT REPORT CITY OF TEMECULA
TEMECULA REGIONAL HOSPITAL 4-94
Southbound: 2 left-turn lanes
1 shared through/right lane (20 feet wide)
T-2. The project applicant/permittee will pay Riverside County Transportation Uniform
Mitigation Fees (TUMF) to mitigate cumulative impacts to the Highway 79 South
intersection at I-15.
T-3. The project applicant/permittee will contribute a fair share toward the provision of the
following roadway improvements to address the project’s contribution toward cumulative
impacts:
Intersection Required Improvements
Highway 79 South/I-15 Southbound Ramps Additional southbound left-turn lane
Highway 79 South/I-15 Northbound Ramps Additional eastbound through lane, plus convert westbound right lane to
free right turn
Highway 79 South/La Paz Road Widen southbound movement to dual left turn lanes and one shared
through/right lane
Highway 79 South/Pechanga Parkway Additional northbound left-turn lane, plus eastbound and northbound free
right-turn lanes
Highway 79 South/Project Driveway/Country Glen
Way
Signalize and provide dual eastbound left-turn lanes and dual southbound
left-turn lanes with a shared through/right-turn lane. Provide a dedicated
right-turn lane for westbound approach.
Highway 79 South/Redhawk Parkway/Margarita
Road
Provide southbound and eastbound dual left and right-turn traffic signal
overlaps.
T-4. Improvements on the project site shall include a driveway onto De Portola Road developed
to the specifications of the Public Works Director.
T-5. Prior to the issuance of grading permits, the City will consult with the Riverside Transit Agency
(RTA) regarding RTA’s possible interest in establishing a bus turn-out or similar transit
accommodation at the project site. The applicant/permittee will be required to incorporate
any such plans and facilities into revised site plans and other plans prepared for the project,
and shall further be required to fund a fair-share apportion of the facilities requested by RTA.
Such facilities must be in place prior to the issuance of occupancy permits for Phase I of the
project.
Level of Impact after Mitigation
Phase I with Improvements
For Phase I development, the key study area intersections and roadway links were reanalyzed with
lane configuration improvements outlined above.
CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT 8-1 TEMECULA REGIONAL HOSPITAL
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CITY OF TEMECULA ENVIRONMENTAL IMPACT REPORT 8-3 TEMECULA REGIONAL HOSPITAL
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