Section 3.3 Air Quality and Global Climate Change 

California High-Speed Rail Authority November 2017 

Fresno to Bakersfield Section Page | 3.3-1 

Draft Supplemental EIR/EIS 

3.3 Air Quality and Global Climate Change 

This section describes the regulatory and environmental setting associated with the air quality 

and global climate change impacts that would result from implementation of the Fresno to 

Bakersfield Section with the Locally Generated Alternative (F-B LGA). Unlike other resource 

areas, this section addresses the impacts for the entire Fresno to Bakersfield Section alignment. 

This is because the types of impacts assessed are more appropriately viewed within the context 

of the San Joaquin Valley Air Basin (SJVAB). Therefore, instead of comparing the F-B LGA to the 

May 2014 Project, this analysis evaluates the full Fresno to Bakersfield Section, with either the 

F-B LGA or the May 2014 Project as a component of the full section. The section also evaluates 

the smaller LGA area for local impacts such as carbon monoxide at intersections and sensitive 

receptors exposed to air toxics. This section also describes avoidance and minimization 

measures and mitigation measures that would reduce these impacts. Emission reduction 

measures identified in the Fresno to Bakersfield Section California High-Speed Train Final Project 

Environmental Impact Report/Environmental Impact Statement (EIR/EIS) (California High-Speed 

Rail Authority [Authority] and Federal Railroad Administration [FRA] 2014) are incorporated as 

described in Section 3.3.7, Mitigation Measures and Avoidance and Minimization Measures. 

This section summarizes detailed information contained in the Fresno to Bakersfield Section Draft 

Supplemental Environmental Impact Report/Environmental Impact Statement Air Quality and 

Global Climate Change Technical Report (Authority and FRA 2017). 

3.3.1 Regulatory Setting 

Federal, state, and local laws, regulations, orders, or plans relevant to air quality and global 

climate change affected by the project are presented below. National Environmental Policy Act 

(NEPA) and California Environmental Quality Act (CEQA) requirements for assessment and 

disclosure of environmental impacts are described in Section 3.1, Introduction. The latest state 

and federal ambient air quality standards are shown in Table 3.3-1, as identified in Table 3.3-1 of 

the Fresno to Bakersfield Section Final EIR/EIS (page 3.3-3). 

Table 3.3-1 Ambient Air Quality Standards 

Pollutant Averaging

Time

California Standardsa Federal Standardsb

Concentrationc Methodd Primaryc,e Secondaryc,f Methodg

Ozoneh

(O3)

1-Hour 0.09 ppm 

(180 μg/m3) Ultraviolet

Photometry

– Same as

Primary 

Standard

Ultraviolet Photometry

8-Hour 0.070 ppm 

(137 μg/m3)

0.070 ppm 

(137 μg/m3)

Respirable

Particulate

Matter

(PM10)

i

24-Hour 50 μg/m3

Gravimetric or Beta 

Attenuation

150 μg/m3

Same as

Primary 

Standard

Inertial Separation and

Gravimetric Analysis

Annual

Arithmetic

Mean

20 μg/m3 –

Fine

Particulate

Matter

(PM2.5)

i

24-Hour – – 35 μg/m3

Same as

Primary 

Standard Inertial Separation and

Annual Gravimetric Analysis

Arithmetic

Mean

12 μg/m3 Gravimetric or Beta 

Attenuation 12.0 μg/m3

15 μg/m3

Carbon

Monoxide

(CO)

1-Hour 20 ppm (23 

mg/m3)

Non-Dispersive

Infrared Photometry

(NDIR)

35 ppm 

(40 mg/m3)

– Non-Dispersive

Infrared Photometry

8 (NDIR) -Hour 9.0 ppm 

(10 mg/m3)

9 ppm 

(10 mg/m3)

–
Section 3.3 Air Quality and Global Climate Change 

November 2017 California High-Speed Rail Authority 

3.3-2 | Page Fresno to Bakersfield Section 

Draft Supplemental EIR/EIS 

Pollutant Averaging California Standardsa Federal Standardsb

Time Concentrationc Methodd Primaryc,e Secondaryc,f Methodg

8-Hour

(Lake 6 ppm (7 mg/m3) – –

Tahoe)

0.18 ppm 100 ppb 1-Hour – Nitrogen (339 μg/m3) (188 μg/m3) Gas Phase Gas Phase Dioxide Annual Same as Chemiluminescence Chemiluminescence 0.030 ppm 0.053 ppm (NO2)j Arithmetic Primary (57 μg/m3) (100 μg/m3) Mean Standard

0.25 ppm 75 ppb 1-Hour – (655 μg/m3) (196 μg/m3)

0.5 ppm 3-Hour – – Ultraviolet (1300 μg/m3) Sulfur Fluorescence; Ultraviolet 0.14 ppm Dioxide Spectrophotometry 0.04 ppm 24-Hour Fluorescence (for certain – (SO2)k (Pararosaniline (105 μg/m3) areas)i Method)

Annual 0.030 ppm

Arithmetic – (for certain –

Mean areas)i

30-Day 1.5 μg/m3 – – Average

1.5 μg/m3

Calendar Lead – (for certain High-Volume Sampler Quarter Atomic Absorption l, m Same as (Pb) areas)l and Atomic Absorption Primary Rolling Standard

3-Month – 0.15 μg/m3

Averagei

Visibility- Beta Attenuation and 

Reducing 8-Hour See footnote n Transmittance 

Particlesn through Filter Tape

Sulfates 24-Hour 25 μg/m3 Ion Chromatography No Federal Standards

Hydrogen 0.03 ppm Ultraviolet 1-Hour Sulfide (42 μg/m3) Fluorescence

Vinyl 0.01 ppm 24-Hour Gas Chromatography Chloridel (26 μg/m3)

Source: California Air Resources Board, 2016a (May 4, 2016) 

Footnotes continue onto next page. 

a California standards for ozone, carbon monoxide (except 8-hour Lake Tahoe), sulfur dioxide (1- and 24-hour), nitrogen dioxide, suspended 

particulate matter (PM10, PM2.5, and visibility-reducing particles) are values that are not to be exceeded. All others are not to be equaled or 

exceeded. California ambient air quality standards are listed in the Table of Standards in Section 70200 of Title 17 of the California Code of 

Regulations. 

b National standards (other than ozone, particulate matter, and those based on annual averages or annual arithmetic mean) are not to be 

exceeded more than once per year. The ozone standard is attained when the fourth-highest 8-hour concentration measured at each site in a 

year, averaged over 3 years, is equal to or less than the standard. For PM10, the 24-hour standard is attained when the expected number of days 

per calendar year with a 24-hour average concentration above 150 μg/m3 is equal to or less than one. For PM2.5, the 24-hour standard is attained 

when 98 percent of the daily concentrations, averaged over three years, are equal to or less than the standard. Contact the USEPA for further 

clarification and current federal policies. 

c Concentration is expressed first in the units in which it was promulgated. Equivalent units given in parentheses are based on a reference 

temperature of 25°C and a reference pressure of 760 torr. Most measurements of air quality are to be corrected to a reference temperature of 

25°C and a reference pressure of 760 torr; ppm in this table refers to ppm by volume, or micromoles of pollutant per mole of gas. 
Section 3.3 Air Quality and Global Climate Change 

California High-Speed Rail Authority November 2017

Fresno to Bakersfield Section Page | 3.3-3 

Draft Supplemental EIR/EIS 

d Any equivalent procedure that can be shown to the satisfaction of the California Air Resources Board to give equivalent results at or near the 

level of the air quality standard may be used. 

e National Primary Standards: The levels of air quality necessary, with an adequate margin of safety to protect the public health. 

f National Secondary Standards: The levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of a 

pollutant. 

g The reference method as described by the USEPA. An “equivalent method” of measurement may be used but must have a “consistent

relationship to the reference method” and must be approved by the USEPA. 

h On October 1, 2015, the national 8-hour ozone primary and secondary standards were lowered from 0.075 ppm to 0.070 ppm. 

I On December 14, 2012, the national annual PM2.5 primary standard was lowered from 15 μg/m3

to 12.0 μg/m3. The existing national 24-hour 

PM2.5 standards (primary and secondary) were retained at 35 μg/m3, as was the annual secondary standard of 15 μg/m3. The existing 24-hour 

PM10 standards (primary and secondary) of 150 μg/m3 also were retained. The form of the annual primary and secondary standards is the annual 

mean, averaged over 3 years. 

j To attain the 1-hour national standard, the 3-year average of the annual 98th percentile of the 1-hour daily maximum concentrations at each site 

must not exceed 100 ppb. Note that the national standards are in units of ppb. California standards are in units of ppm. To directly compare the 

national standards to the California standards, the units can be converted from ppb to ppm. In this case, the national standard of 100 ppb is 

identical to 0.100 ppm. 

k

 On June 2, 2010, a new 1-hour SO2 standard was established and the existing 24-hour and annual primary standards were revoked. To attain the 

1-hour national standard, the 3-year average of the annual 99th percentile of the 1-hour daily maximum concentrations at each site must not 

exceed 75 ppb. The 1971 SO2 national standards (24-hour and annual) remain in effect until 1 year after an area is designated for the 2010 

standard, except that in areas designated nonattainment for the 1971 standards, the 1971 standards remain in effect until implementation plans 

to attain or maintain the 2010 standards are approved. 

Note that the 1-hour national standard is in units of ppb. California standards are in units of ppm. To directly compare the 1-hour national 

standards to the California standard, the units can be converted to ppm. In this case, the national standard of 75 ppb is identical to 0.075 ppm. 

l The California Air Resources Board has identified lead and vinyl chloride as “toxic air contaminants” with no threshold level of exposure for 

adverse health effects determined. These actions allow for the implementation of control measures at levels below the ambient concentrations 

specified for these pollutants. 

m The national standard for lead was revised on October 15, 2008, to a rolling 3-month average. The 1978 lead standard (1.5 μg/m3

 as a quarterly 

average) remains in effect until one year after an area is designated for the 2008 standard, except that in areas designated nonattainment for the 

1978 standard, the 1978 standard remains in effect until implementation plans to attain or maintain the 2008 standard are approved. 

n

 In 1989, the California Air Resources Board converted both the general statewide 10-mile visibility standard and the Lake Tahoe 30-mile visibility 

standard to instrumental equivalents, which are “extinction of 0.23 per kilometer” and “extinction of 0.07 per kilometer” for the statewide and Lake 

Tahoe Air Basin standards, respectively. 

C = degrees Celsius 

μg/m3 = micrograms per cubic meter 

mg/m3 = milligrams per cubic meter 

ppb = parts per billion 

ppm = parts per million 

USEPA = United States Environmental Protection Agency 

3.3.1.1 Federal 

The Federal laws, regulations, and guidance applicable to the F-B LGA listed below are 

discussed in further detail in Section 3.3.2.1 of the Fresno to Bakersfield Section Final EIR/EIS 

(Authority and FRA 2014a). 

 National Ambient Air Quality Standards (NAAQS)

 Clean Air Act (CAA) and Conformity Rule

 Mobile Source Air Toxics

3.3.1.2 State 

The state laws, regulations, and orders applicable to the F-B LGA listed below are discussed in 

further detail in Section 3.3.2.2 of the Fresno to Bakersfield Section Final EIR/EIS (Authority and 

FRA 2014a: pages 3.3-6 through 3.3-8). 

 California Clean Air Act

 Asbestos control measures

 GHG regulations

 Assembly Bill (AB) 1493

 Executive Order (EO) S-3-05

 AB 32

 EO S-01-07

 Sustainable Communities and Climate Protection Act of 2008 (SB 375)

A number of state initiatives related to GHG have been put in place or built upon since the Fresno 

to Bakersfield Section: Air Quality Technical Report was approved that would apply to the F-B 

LGA, including: 
Section 3.3 Air Quality and Global Climate Change 

November 2017 California High-Speed Rail Authority 

3.3-4 | Page Fresno to Bakersfield Section 

Draft Supplemental EIR/EIS 

 Senate Bill (SB) 2X and First Update to the Climate Change Scoping Plan

 EO B-30-15

 SB 32

 Short-Lived Climate Pollutant Reduction Strategy

These regulations are described in more detail below. 

SB 2X (2011) and First Update to the Climate Change Scoping Plan 

In April 2011, Governor Brown signed SB 2X requiring California to generate 33 percent of its 

electricity from renewable energy by 2020. In May 2014, the California Air Resources Board 

(CARB) approved the First Update to the Climate Change Scoping Plan (CARB 2014). This first 

update defines CARB’s climate change priorities for the next five years and sets the groundwork 

to reach post-2020 goals set forth in EO S-3-05. The update highlights California’s progress 

toward meeting the “near-term” 2020 GHG emission reduction goals defined in the original 

Climate Change Scoping Plan (CARB 2008). It also evaluates how to align the state’s longer-term 

GHG reduction strategies with other state policy priorities, like those for water, waste, natural 

resources, clean energy and transportation, and land use (CARB 2014). 

EO B-30-15 and SB 350 (2015) 

In April 2015, Governor Brown issued EO B-30-15, which expanded the goals of EO S-3-05 by 

calling for a new target of 40 percent below 1990 levels by 2030. This EO also directed all state 

agencies with jurisdiction over GHG-emitting sources to implement measures designed to 

achieve the new interim 2030 goal, as well as the pre-existing, long-term 2050 goal identified in 

EO S-3-05 of reducing emissions 80 percent under 1990 levels by 2050. The new emission 

reduction target of 40 percent below 1990 levels by 2030 is intended to make it possible to reach 

the state’s ultimate goal set by EO S-3-05. 

In October 2015, Governor Brown signed into legislation SB 350, which requires retail seller and 

publicly owned utilities to procure 50 percent of their electricity from eligible renewable energy 

resources by 2030, with interim goals of 40 percent by 2024, and 45 percent by 2027. 

Senate Bill 32 

On September 8, 2016 Governor Brown signed into law SB 32, effectively extending California’s 

landmark AB 32 to the year 2030. SB 32 effectively establishes a new greenhouse gas reduction 

goal for statewide emissions of 40 percent below 1990 levels by 2030. This goal is 40 percent 

more stringent than the current AB 32 mandated goal of 1990 levels by 2020. In terms of metric 

tons, this means that statewide, California not only needs to reduce emissions from 441.5 million 

metric tons (MMT) of carbon dioxide equivalents (CO2e) in 2014 to 431 MMT CO2e by 2020, but 

will now need to cut emissions to 258.6 MMT CO2e by 2030. 

Short-Lived Climate Pollutant Reduction Strategy 

SB 605 (Lara, Chapter 523, Statutes of 2014) directed CARB to develop a comprehensive shortlived climate pollutant (SLCP) strategy, in coordination with other state agencies and local air 

quality management and air pollution control districts. Short-lived climate pollutants include three 

main components: black carbon, fluorinated gases, and methane. CARB staff released a 

proposed SLCP Strategy in April 2016. In September 2016, Governor Brown signed SB 1383 

(Lara, Chapter 395, Statutes of 2016) mandating CARB to take certain specific actions with 

regard to the SLCP strategy. SB 1383 identifies specific reduction targets for three SLCPs (i.e., 

black carbon, fluorinated gases, and methane), which the SLCP Strategy, currently being revised 

by CARB, will address. 

3.3.1.3 Regional and Local 

The Fresno to Bakersfield Section is entirely within the San Joaquin Valley Air Pollution Control 

District (SJVAPCD). The SJVAPCD is responsible for implementing air quality regulations, 

including developing plans and control measures for stationary sources of air pollution to meet 

the NAAQS and California Ambient Air Quality Standards (CAAQS); implementing permit 
Section 3.3 Air Quality and Global Climate Change 

California High-Speed Rail Authority November 2017 

Fresno to Bakersfield Section Page | 3.3-5 

Draft Supplemental EIR/EIS 

programs for the construction, modification, and operation of sources of air pollution; and 

enforcing air pollution statutes and regulations governing stationary sources. The following 

regulations and guidance that may be relevant to the project, as administered by the SJVAPCD 

with CARB oversight, were identified and considered for analysis: 

 SJVAPCD Rule 2201: New and Modified Stationary Source Review

 SJVAPCD Rule 2280: Portable Equipment Registration

 SJVAPCD Rule 2303: Mobile Source Emission Reduction Credits

 SJVAPCD Rule 4201 and Rule 4202: Particulate Matter Concentration and Emission Rates

 SJVAPCD Rule 4301: Fuel Burning Equipment

 SJVAPCD Rule 8011: General Requirements–Fugitive Dust Emission Sources

 SJVAPCD Rule 9510: Indirect Source Review

 SJVAPCD CEQA Guidelines

These rules are discussed in further detail in Section 3.3.3.3 of the Fresno to Bakersfield Section 

Final EIR/EIS (Authority and FRA 2014a: pages 3.3-8 through 3.3-10). Rule 2201 was modified in 

2016, and the SJVAPCD CEQA Guidelines were updated in 2015 as follows. 

SJVAPCD Rule 2201 – New and Modified Stationary Source Review 

Rule 2201 applies to new or modified stationary sources and requires that sources not increase 

emissions above the specified thresholds. If the post-project stationary source potential to emit 

equals or exceeds the offset threshold levels, offsets will be required (SJVAPCD 2006). 

Stationary sources at the station (such as natural gas heaters) require permitting by the 

SJVAPCD and would have to comply with best available control technology requirements. 

Stationary sources such as exterior washing, welding, material storage, cleaning solvents, 

abrasive blasting, painting, oil/water separation, and wastewater treatment and combustion would 

require permits. Permits would need to be obtained for equipment associated with these activities 

from the SJVAPCD and would need to comply with best available control technology 

requirements. 

SJVAPCD CEQA Guidelines 

The SJVAPCD prepared the Draft Guidance for Assessing and Mitigating Air Quality Impacts 

(GAMAQI) to assist lead agencies and project applicants in evaluating the potential air quality 

impacts of projects in the San Joaquin Valley Air Basin (SJVAPCD 2015a). The GAMAQI 

provides SJVAPCD-recommended procedures for evaluating potential air quality impacts during 

the CEQA environmental review process. The GAMAQI provides guidance on evaluating shortterm (construction) and long-term (operational) air emissions. The most recent version of the 

GAMAQI was adopted March 2015 and was used in this evaluation and contains guidance on the 

following: 

 Criteria and thresholds for determining whether a project may have a significant adverse air

quality impact under CEQA

 Specific procedures and modeling protocols for quantifying and analyzing air quality impacts

 Methods to mitigate air quality impacts

 Information for use in air quality assessments and environmental documents including air

quality data, regulatory setting, climate, and topography

3.3.2 Pollutants for Analysis 

Three general classes of air pollutants are of concern for this project: criteria pollutants, toxic air 

contaminants (TAC), and GHGs. Criteria pollutants are those for which the United States (U.S.) 

Environmental Protection Agency (USEPA) and the State of California have set ambient air 

quality standards, or that are chemical precursors to compounds for which ambient standards 

have been set. TACs of concern for the proposed project are seven Mobile Source Air Toxics 

(MSAT) identified by the USEPA as having significant contributions from mobile sources: 

acrolein, benzene, 1,3-butadiene, diesel particulate matter and diesel exhaust organic gases, 
Section 3.3 Air Quality and Global Climate Change 

November 2017 California High-Speed Rail Authority 

3.3-6 | Page Fresno to Bakersfield Section 

Draft Supplemental EIR/EIS 

formaldehyde, naphthalene, and polycyclic organic matter. GHGs are gaseous compounds that 

limit the transmission of radiated heat from the earth’s surface to the atmosphere. Section 4.0 of 

the Fresno to Bakersfield Section: Air Quality Technical Report includes additional detailed 

discussion of air quality impacts on human health (see pages 4-1 through 4-7). 

3.3.2.1 Criteria Pollutants 

Criteria pollutants applicable to the F-B LGA are listed below. These pollutants are discussed in 

further detail in Section 3.3.5.1 of the Fresno to Bakersfield Section Final EIR/EIS (Authority and 

FRA 2014a: pages 3.3-10 through 3.3-12). 

 Ozone (O3)

 Particulate matter

 Carbon monoxide

 Nitrogen dioxide

 Lead

 Sulfur dioxide

3.3.2.2 Toxic Air Contaminants 

California law defines a TAC as an air pollutant that “may cause or contribute to an increase in 

mortality or an increase in serious illness, or which may pose a present or potential hazard to 

human health.” The USEPA uses the term “hazardous air pollutant” in a similar sense. These 

TACs are discussed in further detail in Section 3.3.3.2 of the Fresno to Bakersfield Section Final 

EIR/EIS (Authority and FRA 2014a: page 3.3-12). 

3.3.2.3 Greenhouse Gases 

GHGs trap heat in the atmosphere, keeping the earth’s surface warmer than it otherwise would 

be. GHGs are discussed in further detail in Section 3.3.3.3 of the Fresno to Bakersfield Section 

Final EIR/EIS (Authority and FRA 2014a: page 3.3-13). 

3.3.3 Methods for Evaluating Impacts 

The methods for evaluating impacts are intended to satisfy the federal and state requirements, 

including NEPA, CEQA, and general conformity. In accordance with CEQA requirements, an EIR 

must include a description of the existing physical environmental conditions in the vicinity of the 

project. Those conditions, in turn, “will normally constitute the baseline physical conditions by 

which a lead agency determines whether an impact is significant” (CEQA Guidelines Section 

15125[a]). 

For a project such as the HSR project that would not commence operation of HSR service for 

almost 10 years and would not reach full operation for almost 25 years, use of only existing 

conditions as a baseline for air quality impacts would be misleading. It is more likely that existing 

background traffic volumes (and background roadway changes from other programmed traffic 

improvement projects) and vehicle emission factors would change between today and 2020/2035 

than it is that existing conditions would remain unchanged over the next 10 to 25 years. For 

example, RTPs include funded transportation projects programmed to be constructed by 2035. 

To ignore that these projects would be in place before the HSR project reaches maturity (i.e., the 

point/year at which HSR-related traffic emissions reaches its maximum), and to evaluate the HSR 

project’s air quality impacts ignoring that these RTP improvements would change the underlying 

background conditions to which HSR project traffic would be added, would be misleading 

because it would represent a hypothetical comparison. 

Therefore, the air quality analysis for operations uses a dual-baseline approach. That is, the HSR 

project’s air quality impacts are evaluated both against existing conditions and against 

background (i.e., No Project) conditions as they are expected to be in 2035. 

Section 3.3.6 of the Fresno to Bakersfield Final EIR/EIS (Authority and FRA 2014a: pages 3.3-13 

through 3.3-36) provides further detail on the methods used for evaluating potential impacts on air 
Section 3.3 Air Quality and Global Climate Change 

California High-Speed Rail Authority November 2017 

Fresno to Bakersfield Section Page | 3.3-7 

Draft Supplemental EIR/EIS 

quality, including developing study areas, background review, and establishing a reasonable 

baseline for analysis. 

3.3.3.1 Study Areas for Analysis 

Statewide 

A statewide study area was identified to evaluate potential changes in air quality from large-scale, 

non-localized impacts, such as HSR power requirements, changes in air traffic, and project 

conformance with the State Implementation Plan (SIP). 

Regional 

The F-B LGA would potentially affect regional air pollutant concentrations in the SJVAB, which 

contains the F-B LGA. Figure 3.3-1 shows the entire Fresno to Bakersfield alignment as it is 

situated in the SJVAB, which includes all of Fresno, Kings, and Tulare counties, and a portion of 

Kern County. The SJVAB, which is approximately 250 miles long and 35 miles wide, is the 

second-largest air basin in the state. The SJVAB is defined by the mountain ranges of the Sierra 

Nevada to the east (8,000 to 14,000 feet in elevation), the Coast Range to the west (averaging 

3,000 feet in elevation), and the Tehachapi Mountains to the south (6,000 to 8,000 feet in 

elevation). To the north, the valley opens to the sea at the Carquinez Strait, where the 

Sacramento–San Joaquin River Delta empties into San Francisco Bay. 

Local 

Local study areas are areas of potential major air emission activities along the project alignment, 

including areas near large construction activities and major traffic pattern changes. Local study 

areas are generally defined as areas along the alignment, within 1,000 feet of the proposed 

station, the maintenance of infrastructure facility (MOIF) and affected intersections. Analyses 

performed by CARB indicate that providing a separation of 1,000 feet from diesel sources and 

high-traffic areas would substantially reduce diesel particulate matter concentrations, public 

exposure, and asthma symptoms in children (California Environmental Protection Agency 

[Cal-EPA] and CARB 2005). Potential impacts from changes in carbon monoxide (CO), 

particulate matter smaller than or equal to 2.5 microns in diameter (PM2.5), and particulate matter 

smaller than or equal to 10 microns in diameter (PM10) concentrations caused by changes in local 

traffic conditions were evaluated at sensitive land uses located within 1,000 feet of intersections 

operating at level-of-service (LOS) D or worse. 

3.3.3.2 Statewide and Regional Emission Calculations 

The emission burden analysis of a project determines a project’s potential overall impact on air 

quality. The proposed project would affect long-distance, city-to-city vehicular travel along 

freeways and highways throughout the state, as well as long-distance, city-to-city aircraft takeoffs and landings. The project would also affect electrical demand throughout the state. 

On-Road Vehicles 

A summary of the methodology used to conduct the on-road vehicles analysis is described in 

Section 3.3.4.2 of the Fresno to Bakersfield Section Final EIR/EIS (Authority and FRA 2014a: 

page 3.3-16). The LGA analysis utilized the methodology and results that were generated for the

Fresno to Bakersfield Final EIR/EIS. As identified in the Fresno to Bakersfield Section Final 

EIR/EIS, an on-road vehicle emission analysis was conducted using average daily vehicle miles 

traveled (VMT) estimates and associated average daily speed estimates for each affected county. 

Emission factors were estimated by using the CARB emission factor program, EMission FACtors 

2011 (EMFAC2011) for criteria pollutants and GHG emissions. Parameters were set in the 

program for each individual county to reflect conditions within the county, and statewide 

parameters were used to reflect statewide conditions. The analysis was conducted for the future 

No Project Alternative and HSR alternative for the project’s design year, both of which are 2035; 

the existing condition (2015); and the Existing Condition Plus Project (2015). 
Section 3.3 Air Quality and Global Climate Change 

November 2017 California High-Speed Rail Authority 

3.3-8 | Page Fresno to Bakersfield Section 

Draft Supplemental EIR/EIS 

Figure 3.3-1 San Joaquin Valley Air Basin 
Section 3.3 Air Quality and Global Climate Change 

California High-Speed Rail Authority November 2017 

Fresno to Bakersfield Section Page | 3.3-9 

Draft Supplemental EIR/EIS 

To determine the overall pollutant burdens generated by on-road vehicles, the estimated VMT 

were multiplied by the specific pollutant’s emission factors, which were based on speed, vehicle 

mix, and analysis year. 

Airport Emissions 

The methodology used to conduct the airport emissions analysis is described in Section 3.3.4.2 of 

the Fresno to Bakersfield Section Final EIR/EIS (Authority and FRA 2014a: page 3.3-16). As 

identified in the Fresno to Bakersfield Section Final EIR/EIS, the Federal Aviation Administration’s 

(FAA’s) Emission and Dispersion Modeling System (EDMS) Version 5.1.3 (FAA 2009) was used 

to estimate airplane emissions. EDMS estimates emissions generated from a specified number of 

landing and take-off cycles. Along with the emissions from the planes themselves, emissions 

generated from associated ground maintenance requirements are included. Average plane 

emissions were calculated based on the profile of aircraft currently servicing the San Francisco to 

Los Angeles corridor. The number of air trips removed because of the HSR was estimated 

through the travel demand modeling analyses conducted for the project. 

Power Plant Emissions 

Section 3.3.4.2 of the Fresno to Bakersfield Section Final EIR/EIS provides a summary of the 

methodology used to conduct the power plant emissions analysis (Authority and FRA 2014a: 

page 3.3-16). As described in the Fresno to Bakersfield Section Final EIR/EIS, the HSR System, 

including the propulsion of the trains and the operations of the stations and maintenance facilities, 

would be powered by the state’s electricity grid. Because no dedicated generating facilities are 

proposed for this project, no source facilities can be identified. Therefore, emission changes from 

power generation were predicted on a statewide level. In addition, because of the state 

requirement that an increasing fraction (33 percent by 2020) of electricity generated for the state’s 

power portfolio must come from renewable energy sources, the emissions generated for the HSR 

System are expected to be lower in the future as compared to emissions estimated for this 

analysis, which are based on the state’s current power portfolio. In addition, the Authority has 

adopted a goal to purchase the HSR System’s power from renewable energy providers.

3.3.3.3 Local Operational Emission Sources at HSR Station 

Emissions associated with operation of the proposed F-B LGA HSR station would primarily result 

from space heating and facility landscaping, energy consumption for facility lighting, indirect 

emissions associated with water use and solid waste disposal, emergency generator testing, CO 

emissions from vehicle activity at the parking structures and employee and passenger traffic 

(refer to Fresno to Bakersfield Section Final EIR/EIS Section 6.2.3). Emissions from deliveries to 

the HSR stations are considered negligible. 

Emissions of criteria pollutants and GHGs were estimated for operation of the Bakersfield HSR 

station for the design year of 2035. The methodology used to calculate emissions from area and 

stationary sources, indirect electricity, indirect water indirect solid waste, and emergency 

generators are described in Section 3.3.4.3 of the Fresno to Bakersfield Section Final EIR/EIS 

(Authority and FRA 2014a: pages 3.3-16 through 3.3-18). The same methodology was applied to 

calculate these types of emissions for the F-B LGA. 

3.3.3.4 Microscale CO Analysis 

CO hot-spot analyses were conducted to evaluate the potential air quality impacts of the F-B 

LGA-related changes in traffic conditions along heavily traveled roadways, congested 

intersections, primarily due to changes in intersection traffic volumes based on the change of 

location for the proposed train station and parking areas. Methodology for the analysis is 

discussed in Section 3.3.4.4 of the Fresno to Bakersfield Section Final EIR/EIS (Authority and 

FRA 2014a: pages 3.3-18 through 3.3-20). 

CO concentrations were predicted for the existing conditions (2015) and the project’s design year 

(2035). Traffic data for the air quality analysis were derived from traffic counts and other 

information developed as part of an overall traffic analysis for the project. The microscale CO 
Section 3.3 Air Quality and Global Climate Change 

November 2017 California High-Speed Rail Authority 

3.3-10 | Page Fresno to Bakersfield Section 

Draft Supplemental EIR/EIS 

analysis was performed based on data from this analysis for the a.m. and p.m. peak traffic 

periods. These are the periods when maximum traffic volumes occur on local streets and when 

the greatest traffic and air quality effects of the proposed project are expected. 

3.3.3.5 Particulate Matter Hot-Spot Analysis 

Although the HSR portion of the project is subject to the general conformity guidelines and not the 

transportation conformity guidelines, the project vicinity is classified as a nonattainment area for 

PM2.5 and a federal maintenance area for PM10. Therefore, a hot-spot analysis following the 

USEPA’s 2010 Transportation Conformity Guidance for Quantitative Hot-spot Analyses in PM2.5

and PM10 Nonattainment and Maintenance Areas (USEPA 2010) was conducted for the Fresno to 

Bakersfield Section Final EIR/EIS, which included the May 2014 Project, and for the Fresno to 

Bakersfield Section including the F-B LGA. The analysis focused on potential air quality concerns 

under NEPA from project effects on roads and followed the recommended practice in the 

USEPA’s Final Rule regarding the localized or “hot-spot” analysis of PM2.5 and PM10 (40 Code of 

Federal Regulations [C.F.R.] Part 93). Specific methodology related to the particulate matter hotspot analysis is described in Section 3.3.4.5 of the Fresno to Bakersfield Section Final EIR/EIS 

(Authority and FRA 2014a: page 3.3-21). 

3.3.3.6 Mobile Source Air Toxics Analysis 

The methodology for evaluating MSAT is described in Section 3.3.4.6 of the Fresno to Bakersfield 

Section Final EIR/EIS (Authority and FRA 2014a: pages 3.3-21 through 3.3-23). The project has 

low potential for MSAT impacts, because the HSR would use electric multiple unit EMUs trains, 

with the power distributed to each train car via the overhead contact system. Operation of the 

EMUs would not generate combustion emissions; therefore, no toxic emissions would be 

expected from operation of the HSR. Additionally, as with the May 2014 Project, the LGA 

alternative would decrease regional VMT and MSAT emissions compared the existing conditions 

and No Project Alternative, which would reduce the amount of MSATs emitted from highways and 

other roadways in the region. Accordingly, a qualitative analysis was used to provide a basis for 

identifying and comparing the potential differences in MSAT emissions. The qualitative 

assessment is derived, in part, from a study conducted by the Federal Highway Administration 

(FHWA) titled A Methodology for Evaluating Mobile Source Air Toxic Emissions Among 

Transportation Project Alternatives (FHWA 2010). 

3.3.3.7 Asbestos 

Asbestos minerals occur in rocks and soil as the result of natural geologic processes, and are a 

known human carcinogen. Asbestos causes cancers of the lung and the lining of internal organs, 

as well as asbestosis and pleural disease, which inhibit lung function. The USEPA is addressing 

concerns about potential effects of naturally occurring asbestos (NOA) in a number of areas in 

California. The methodology used to determine if NOA would be located within the project vicinity 

was based on a California Department of Conservation, Division of Mines and Geology (CDMG) 

report titled A General Location Guide for Ultramafic Rocks in California Areas More Likely to 

Contain Naturally Occurring Asbestos (CDMG 2000), as described in Section 3.3.4.7 of the 

Fresno to Bakersfield Section Final EIR/EIS (Authority and FRA 2014a: page 3.3-24). 

3.3.3.8 Greenhouse Gas Analysis 

The proposed project would reduce long-distance, city-to-city travel along freeways and highways 

throughout the state, as well as long-distance, city-to-city aircraft take-offs and landings. The 

project would also increase electrical demand throughout the state. These elements would affect 

GHG emissions on both a statewide and regional study area level. The following sections discuss 

the methodology for estimating GHG emissions associated with operation of the project. The 

methodology for estimating GHG emissions associated with construction is included in Section 

3.3.4.10, Construction Phase Analysis, below. 
Section 3.3 Air Quality and Global Climate Change 

California High-Speed Rail Authority November 2017 

Fresno to Bakersfield Section Page | 3.3-11

Draft Supplemental EIR/EIS 

On-Road Vehicles Emissions 

On-road vehicle GHG emissions were estimated using the same methodology as described in 

Section 3.3.3.2, Statewide and Regional Emission Calculations, of this Draft Supplemental 

EIR/EIS. 

Airport Emissions 

Plane emissions were calculated by using the fuel consumption factors and emission factors from 

CARB’s 2000–2009 Greenhouse Gas Emissions Inventory Technical Support Document and the 

accompanying appendix. The emission factors include both landing/take-off and cruise operations 

(formula: plane emission per flight = fuel consumption * emission factor; plane emission = flights 

removed * plane emission per flight). Average plane GHG emissions are calculated based on the 

profile of the aircraft currently servicing the San Francisco to Los Angeles corridor. The number of 

air trips removed due to the HSR project was estimated through the travel demand modeling 

analysis conducted for the project. 

Power Plant Emissions 

The electrical demands due to propulsion of the trains and operation of the station and 

maintenance facilities were calculated as part of the project design. An average GHG emission 

factor of 650 pounds of CO2e for each megawatt-hour required was provided by CARB. This 

factor represents the estimated emission rate for a new electrical load on the system. The GHG 

estimates used in this analysis for the propulsion of the trains include the use of regenerative 

brake power. 

The HSR System will be powered by the state’s electric grid. Because no dedicated generating 

facilities are proposed for this project, no specific source facilities can be identified. GHG 

emission changes from power generation were therefore predicted on a statewide level. In 

addition, because of the state requirement that an increasing fraction (33 percent by 2020 and 50 

percent by 2030) of electricity generated for the state’s power portfolio come from renewable 

energy sources, the emissions generated for the HSR System are expected to be lower in the 

future when compared with the emissions estimated for this analysis, which are based on the 

state’s current power portfolio.

3.3.3.9 MOIF Operations Impact Analysis 

The F-B LGA would include a MOIF, which would include equipment and supplies for maintaining 

the HSR infrastructure such as track, traction power, and signal systems. The proposed MOIF 

would be located in the City of Shafter between Fresno Avenue and Poplar Avenue. The lead 

tracks for the MOIF extend approximately 300 feet past the northern terminus of the F-B LGA and 

south of Fresno Avenue. The facility would include heavy-duty equipment (e.g., cranes, 

backhoes, loaders, and emergency generators) and heavy-duty delivery trucks. Measures would 

be incorporated to minimize atmospheric emissions from these sources, such as the use of 

electric yard trains to move train cars and electric locomotives around the site and the use of 

diesel-retrofits on heavy-duty diesel engines. 

3.3.3.10 Construction Phase Analysis 

Construction phase emissions were quantitatively estimated for the earthwork and major civil 

construction activities in the Fresno to Bakersfield Section Final EIR/EIS. The major construction 

activities would account for the vast majority of earthwork, the largest number of diesel-powered 

off-road construction equipment, and the majority of material to be hauled along public streets 

compared to other minor construction activities of the project. Therefore, the regional emissions 

and localized emissions from these major activities would account for the majority of construction 

emissions that would be generated by the construction of the proposed project. Regional and 

localized emissions from minor construction activities, such as mobilization and demobilization, 

were quantified and would contribute to fewer emissions than the major construction activities 

listed above. The estimated construction emissions from these major as well as minor activities 
Section 3.3 Air Quality and Global Climate Change 

November 2017 California High-Speed Rail Authority 

3.3-12 | Page Fresno to Bakersfield Section 

Draft Supplemental EIR/EIS 

were then used to estimate the regional air quality impacts and localized air quality impacts that 

would occur during the construction phase. 

Methodologies and Assumptions 

Construction emissions for the F-B LGA were calculated based on the construction emission 

estimates in the Fresno to Bakersfield Section Final EIR/EIS, with an adjustment factor applied to 

the number of pieces of equipment to reflect the F-B LGA construction schedule. This approach 

was taken as construction activities would be very similar to those identified in the Fresno to 

Bakersfield Final EIR/EIS, with some changes to account for the specific LGA features. 

Section 3.3.4.10 of the Fresno to Bakersfield Section Final EIR/EIS (Authority and FRA 2014a: 

pages 3.3-29 through 3.3-33) further discusses the methodology and assumptions used to 

analyze construction impacts. 

Project information used for the construction emission estimates and details of the construction 

emission calculations are provided in the F-B LGA: Air Quality Technical Report (Authority and 

FRA 2016). 

Construction Activities 

As identified in the Fresno to Bakersfield Section Final EIR/EIS, criteria pollutant and GHG 

emissions from regional building demolition and construction of the at-grade rail segments, 

elevated rail segments, retained-fill rail segments, traction power substations, industrial buildings 

at the heavy maintenance facility (HMF), and HSR stations, including parking garages and 

platform facilities, were calculated using emission factors from CARB’s OFFROAD 2011 and 

2007 models. For emission rates not available in OFFROAD 2011, rates from OFFROAD 2007 

were conservatively applied. The use of emission rates from the OFFROAD models reflects the 

recommendation of CARB to capture the latest off-road construction assumptions. OFFROAD 

2011 default load factors (the ratio of average equipment horsepower utilized to maximum 

equipment horsepower) and useful life parameters were used for emission estimates. Mobilesource emission burdens from worker vehicle trips and truck trips were calculated using VMT 

estimates and appropriate emission factors from EMFAC2011. Fugitive dust emissions from dirt 

and aggregate handling were calculated using emission factors derived from equations from U.S. 

EPA’s AP-42 (USEPA 2006b). 

Construction exhaust emissions from equipment, fugitive dust emissions from earthmoving 

activities, and emissions from worker vehicle trips, deliveries, and material hauling were calculated 

and compiled in a spreadsheet tool specific to the HSR project for each year of construction. 

The construction of the Fresno to Bakersfield Section, including the F-B LGA, would occur 

between 2014 to 2023. The 2014 start date for the construction air analysis in this section is to 

account for the construction of the entire Fresno to Bakersfield alignment, which began in 2014. 

The construction air analysis includes minor adjustments in quantities due to the F-B LGA 

alternative. The local analysis focuses on just the F-B LGA study area, since portions of the study 

area were not evaluated on a microscale level in the Fresno to Bakersfield Section Final EIR/EIS 

and emission burdens in the previously studied areas are expected to be the same or lower for 

the F-B LGA. 

Section 3.3.4.10 of the Fresno to Bakersfield Section Final EIR/EIS (Authority and FRA 2014a: 

pages 3.3-29 through 3.3-30) further discusses the methodology and assumptions used to 

analyze impacts associated with construction activities. 

Material Hauling 

Emissions from the exhaust of trucks used to haul material (including concrete slabs) to the 

construction site were calculated using the heavy-duty truck emission factors from EMFAC2011 

and anticipated travel distances of haul trucks within the SJVAB. Ballast materials could 

potentially be hauled by rail within the air basin. 

Ballast materials would be potentially transported from locations outside of the SJVAB. For the 

regional emission analysis, emissions from ballast material hauling were calculated using the 
Section 3.3 Air Quality and Global Climate Change 

California High-Speed Rail Authority November 2017 

Fresno to Bakersfield Section Page | 3.3-13

Draft Supplemental EIR/EIS 

distance traveled within the SJVAB. Emissions from ballast material hauling by trucks and 

locomotives outside the SJVAB were also estimated based on the travel distances and 

transportation method (by rail or by truck) from the locations where ballast materials would be 

available. Locomotive emission factors using U.S. EPA guidance were used to estimate the rail 

emissions. Other construction materials would likely be delivered from supply facilities within the 

SJVAB. 

Five potential quarries that provide ballast material were identified. Of these, three quarries, 

including Napa Quarry, Lake Herman Quarry, and San Rafael Rock Quarry, were included in the 

evaluation because of their proximity to the project construction site. These three quarries are all 

within 70 miles of the SJVAB border and would have material available for the project 

construction. The Bangor Rock Quarry Site A was included in the evaluation because it is located 

within 100 miles of the SJVAB border. In addition, this quarry would have material available for 

the project needs in quantities that exceed the material quantities available at the closest 

quarries. The other quarry, Kaiser Eagle Mountain Quarry, which is located 350 miles by rail (250 

miles by road) from the border of the SJVAB, was analyzed because the annual production rate 

at this quarry was sufficient to meet construction material requirements. 

The analysis was based on the assumption that ballast would be transferred either by diesel truck 

from the quarry to rail (if there was no rail head onsite) and then by rail to the border of SJVAB, 

entirely by rail to the border of the SJVAB (if there was a rail head onsite), or by diesel truck from 

the quarry to the border of the SJVAB. Emissions could potentially occur in several air basins and 

air districts outside SJVAB. 

Concrete Batch Plants 

Concrete would also be required for construction of bridges used to support the elevated sections 

of the alignment and for construction of the retaining wall used to support the retained-fill sections 

of the alignment. To provide enough concrete onsite, it is estimated that three batch plants would 

operate in the project area during construction of the alignment sections. Because the locations of 

the concrete batch plants are unknown, emissions were estimated based on the total amount of 

concrete required and emission factors from AP-42 Chapter 11.12–Concrete Batching (USEPA 

2006a). Emissions from on-road truck trips associated with transporting material to and from the 

concrete batch plants were included in material-hauling emissions calculations. 

Localized Impacts From Construction 

The construction of the F-B LGA has the potential to exceed or contribute to exceedances of the 

ambient air quality standards and to cause adverse health impacts on nearby sensitive land uses. 

A detailed air dispersion modeling analysis and a health risk assessment were conducted to 

determine whether these impacts would be significant under CEQA. Specific details of the model 

parameters for the localized impacts analyses can be found in the Fresno to Bakersfield Section: 

Air Quality Technical Report (Authority and FRA 2014). 

The U.S. EPA’s AERMOD (version 12345) atmospheric dispersion model was used to simulate 

physical conditions and predict pollutant concentrations at locations near the fence line of 

construction site types. This allowed for an analysis of impacts at specified distances away from 

the boundaries of these prototypical construction sites. Guidance from U.S. EPA, state, and local 

air agencies was followed in conducting the air dispersion analysis. AERMOD is generally applied 

to estimate impacts from simple point-source emissions from stacks, as well as emissions from 

volume and area sources such as onsite mobile diesel equipment. The model accepts actual 

hourly meteorological observations and directly estimates maximum and average concentrations 

for various time periods. 

A prototypical site layout was analyzed to evaluate each construction work area. Pollutant 

concentrations were estimated near the site boundary and in the surrounding area. The modeled 

concentrations were compared with the applicable NAAQS, CAAQS, and health-related 

guidelines to determine the level of impacts. The analysis used available meteorological data 

from the 5-year period from 2005 through 2009, as compiled by the SJVAPCD. 
Section 3.3 Air Quality and Global Climate Change 

November 2017 California High-Speed Rail Authority 

3.3-14 | Page Fresno to Bakersfield Section 

Draft Supplemental EIR/EIS 

TAC concentrations at the maximally exposed individual (MEI) sensitive receptor locations were 

used to estimate the cancer risks and the overall non-cancer chronic and acute hazard index 

associated with construction emissions, following procedures developed by the California Office 

of Environmental Health Hazard Assessment (OEHHA) (2015). Details of the risk analysis are in 

the Fresno to Bakersfield Section: Air Quality Technical Report (Authority and FRA 2014). Cancer 

risks were compared with the SJVAPCD CEQA threshold of 10 in a million to assess the level of 

impacts. Chronic and acute hazard indices were compared with the SJVAPCD CEQA threshold 

of 1 to assess the level of impacts. 

Section 3.3.4.10 of the Fresno to Bakersfield Section Final EIR/EIS (Authority and FRA 2014a: 

pages 3.3-31 through 3.3-32) further discusses the methodology and assumptions used to 

analyze localized impacts from construction. 

3.3.3.11 Significance Thresholds 

The following values were used to determine whether estimated project impacts are considered 

to be significant. 

Federal 

In the Fresno to Bakersfield Section Final EIR/EIS, analysts applied specified thresholds for each 

resource topic to assess whether the intensity of each impact is negligible, moderate, or 

substantial for the Build Alternatives, and provided a conclusion of whether the impact was 

“significant”. Since the Fresno to Bakersfield Section Final EIR/EIS does not evaluate the May 

2014 Project as a discrete subsection of the Fresno to Bakersfield Project (as it did for example 

for the Allensworth Bypass), it does not provide conclusions using intensity thresholds for the 

May 2014 Project; therefore, intensity thresholds are not used for the F-B LGA. Instead, the 

evaluation of impacts under NEPA in this Draft Supplemental EIR/EIS focuses on a 

comprehensive discussion of the project’s potential impacts in terms of context, intensity, and 

duration and provides agency decision makers and the public with an apples-to-apples 

comparison between the May 2014 Project and the F-B LGA. Per NEPA regulations, regional 

project emissions are compared with the general conformity (GC) de minimis thresholds on a 

calendar-year basis. If the GC de minimis thresholds are exceeded for any calendar year in which 

emissions occur, a GC determination is required. In addition, project emissions may not cause 

new violations or exacerbate an existing violation of NAAQS. Table 3.3-2 presents the de minimis

thresholds applicable to the HSR project. 

State 

The following CEQA criteria are used to determine whether the HSR project would result in a 

significant impact on air quality and global climate change: 

 Conflict with or obstruct implementation of the applicable air quality plan

 Exceed or contribute to an exceedance of any air quality standard or contribute substantially

to an existing or projected air quality violation (see discussion immediately below under

“Local”)

 Result in a cumulatively considerable net increase of any criteria pollutant for which the

project region is nonattainment under an applicable federal or state ambient air quality

standard (including releasing emissions that exceed quantitative thresholds for O3

precursors)

 Expose sensitive receptors to substantial pollutant concentrations

 Create objectionable odors affecting a substantial number of people

 Generate GHG emissions, either directly or indirectly, that may have a significant impact on

the environment

 Conflict with an applicable plan, policy, or regulation adopted for reducing the emissions of

GHG.
Section 3.3 Air Quality and Global Climate Change 

California High-Speed Rail Authority November 2017 

Fresno to Bakersfield Section Page | 3.3-15

Draft Supplemental EIR/EIS 

Table 3.3-2 General Conformity Thresholds 

Pollutant Federal Attainment Status Threshold Values (tpy)1

NO2 Attainment N/A

Ozone precursor (NOX)

2 Nonattainment: Extreme 10

Ozone precursor (VOCs)2 Nonattainment: Extreme 10

CO3 Maintenance 100

SOx Attainment N/A

PM2.5 Nonattainment 100

PM2.5 precursor (SO2)

4 Nonattainment 100

PM10 Maintenance 100

Lead No designation N/A

Sources: SJVAPCD, 2013; USEPA, 2016b 

1

 Thresholds from 40 C.F.R. 51 and 93 (USEPA 2008). 

2

 Ozone reclassifications were made by the USEPA on May 5, 2010. 

3

 Only the urban portions of Fresno County and Kern County are maintenance areas for CO. 

4 SO2 has a GC threshold of 100 tpy. Due to the stringent requirement of using ultra-low-sulfur-content diesel in California, emissions of SO2 

anticipated from the project are expected to be negligible compared to the threshold. 

C.F.R. = Code of Federal Regulations PM2.5 = particulate matter smaller than or equal to 2.5 microns in diameter 

CO = carbon monoxide SJVAPCD = San Joaquin Valley Air Pollution Control District 

GC = general conformity SO2 = sulfur dioxide 

N/A = not applicable SOx = sulfur oxide 

NO2 = nitrogen dioxide tpy = ton(s) per year 

NOX = nitrogen oxides USEPA = U.S. Environmental Protection Agency 

PM10 = particulate matter smaller than or equal to 10 microns in diameter VOC = volatile organic compound 

Quantitative emission thresholds that can be used to evaluate the significance level of impacts 

have been developed by SJVAPCD and are discussed in the following section. 

Local 

The Fresno to Bakersfield Section Final EIR/EIS summarizes the 2012 GAMAQI (SJVAPCD 

2012), which contains the emissions thresholds used to evaluate the significance of a project’s 

emissions with regard to air quality standards. The GAMAQI was last updated in 2015. If a 

project’s emissions are below the significance thresholds for construction and operational phases, 

the impact would be considered less than significant under CEQA and would not lead to a 

violation of an ambient air quality standard or conflict with an air quality plan. If either the 

construction- or operational-phase emissions are greater than these values, impacts for that 

phase would be considered potentially significant unless localized air-dispersion modeling can 

demonstrate that the emissions would not cause or contribute substantially to an existing or 

projected air quality violation of an ambient air quality standard. 

For nitrogen dioxide (NO2) and sulfur dioxide (SO2), the threshold is the ambient air quality 

standard for each respective pollutant. The increase in pollutant concentration associated with the 

project emissions is added to the background concentration to estimate the ambient air pollutant 

concentration for comparison with the threshold. 

Pre-project concentrations of PM10 and PM2.5 in the SJVAB exceed their respective ambient air 

quality standards. Therefore, SJVAPCD recommends comparing the incremental increase in 

PM10 concentrations to the applicable significant impact level (SIL) for PM10. For construction, the 

SJVAPCD-recommended SILs are 10.4 micrograms per cubic meter (μg/m3) for the 24-hour

average concentration and 2.08 μg/m3 for the annual average concentration. SJVAPCD currently

recommends that these SILs be used to evaluate construction PM10 emissions (SJVAPCD 

2015a). For operations, the SJVAPCD-recommended SILs are 5 μg/m3 for the 24-hour average

concentration and 1 μg/m3 for the annual average concentration. These operational SILs are

used to evaluate operational PM10 and PM2.5 emissions. Therefore, an incremental increase that 
Section 3.3 Air Quality and Global Climate Change 

November 2017 California High-Speed Rail Authority 

3.3-16 | Page Fresno to Bakersfield Section 

Draft Supplemental EIR/EIS 

does not exceed these SILs would not be considered to substantially contribute to further 

exceedances of the ambient air quality standards. 

Additionally, per the SJVAPCD GAMAQI, if a project is individually significant, it is also 

considered cumulatively significant under CEQA. Therefore, the thresholds listed in Table 3.3-3 

are also the cumulative significance thresholds for the project. 

Table 3.3-3 SJVAPCD CEQA Construction and Operational Thresholds of Significance 

Pollutant/

Precursor

Construction Emission 

Thresholds (tons/year)

Operational Emissions

for Permitted Equipment 

and Activities (tons/year)

Operational Emissions for 

Nonpermitted Equipment and 

Activities (tons/year)

CO 100 100 100

NOX 10 10 10

ROG 10 10 10

SOx 27 27 27

PM10 15 15 15

PM2.5 15 15 15

Source: SJVAPCD, 2015a

CEQA = California Environmental Quality Act ROG = reactive organic gas 

NOX = nitrogen oxides SJVAPCD = San Joaquin Valley Air Pollution Control District 

PM10 = particulate matter smaller than or equal to 10 microns in diameter tpy = ton(s) per year 

PM2.5 = particulate matter smaller than or equal to 2.5 microns in diameter 

The significance of the impacts of the emissions from construction, operational nonpermitted 

equipment and activities, and operational permitted equipment and activities are evaluated 

separately. The thresholds of significance are on a calendar year basis. For construction 

emissions, the annual emissions are evaluated on a rolling 12-month period. 

3.3.4 Affected Environment 

This section discusses the affected environment related to air quality and global climate change 

in the F-B LGA and May 2014 Project study areas. 

3.3.4.1 Summary of the May 2014 Project Affected Environment 

This section provides a summary of the affected environment of the May 2014 Project using 

information from the Fresno to Bakersfield Section Final EIR/EIS. The May 2014 Project is the 

comparable portion of the Preferred Alternative used to compare impacts to the F-B LGA. The 

affected environment would not differ between the May 2014 Project and F-B LGA. 

The May 2014 Project is located within the SJVAB. Pollutants of concern within the SJVAB 

include both criteria pollutants and toxic air contaminants, including: ozone, CO, suspended 

particulate matter (PM10 and PM2.5), NOx, SO2, TACs, and GHGs. Under the federal criteria, the 

SJVAB is currently designated as nonattainment for the 8-hour O3 standard, the 1997 PM2.5

standard (annual standard of 15 micrograms/cubic meter [μg/m3] and 24-hour standard of 65

μg/m3), and the 2006 24-hour PM2.5 standard (35 μg/m3). The SJVAB is a maintenance area for

PM10; and the Fresno and Bakersfield Urbanized Areas are designated as maintenance areas for 

CO. The SJVAB is in attainment for the NO2 and SO2 standard, and unclassified for lead. 

Under the state criteria, the SJVAB is currently designated as nonattainment for the 1-hour O3

and 8-hour O3, PM10, and PM2.5 standards. The SJVAB is an attainment/unclassified area for the 

state CO standard and an attainment area for the state NO2, SO2, and lead standards. The 

SJVAB is an unclassified area for the state hydrogen sulfide and the visibility-reducing particle 

standards; it is an attainment area for the sulfates and vinyl chloride standards. 

Planning documents for pollutants for which the May 2014 Project study area is classified as a 

federal nonattainment or maintenance area are developed by the SJVAPCD and CARB and 
Section 3.3 Air Quality and Global Climate Change 

California High-Speed Rail Authority November 2017 

Fresno to Bakersfield Section Page | 3.3-17

Draft Supplemental EIR/EIS 

approved by USEPA. The planning documents relevant to the May 2014 Project’s study area 

include: 1-Hour O3 Attainment Plan, 8-Hour O3 Attainment Plan, PM10 Maintenance Plan, PM2.5

Attainment Plan, and CO Maintenance Plan. 

3.3.4.2 Fresno to Bakersfield Locally Generated Alternative 

Local Meteorological Conditions 

The rate and location of pollutant emissions and the meteorological conditions that influence 

movement and dispersal of pollutants in the atmosphere affect air quality. The hills and 

mountains surrounding the San Joaquin Valley restrict air movement through and out of the 

majority of the basin. The valley’s weather conditions include frequent temperature inversions; 

long, hot summers; and stagnant, foggy winters, all of which are conducive to forming and 

retaining air pollutants (SJVAPCD 2011). Meteorological and climate conditions of the SJVAB are 

further described in Section 3.3.5.1 of the Fresno to Bakersfield Section Final EIR/EIS (Authority 

and FRA 2014a: page 3.3-36). 

Local Monitored Air Quality Data 

CARB maintains ambient air monitoring stations for criteria pollutants throughout California. The 

stations closest to the F-B LGA alignment are the 548 Walker Street station in Shafter, the 2000 

S Union Avenue station in Bakersfield, and the 5558 California Avenue station in Bakersfield 

(Figure 3.3-2). These stations monitor NO2, O3, PM10, CO, and PM2.5. The land uses in the region 

range from urban and residential to rural and agricultural, and these stations represent these land 

use types. Air quality standards, primarily for O3 and particulate matter, have been exceeded in 

the SJVAB because of existing industrial, mobile, and agricultural sources. Table 3.3-4 

summarizes the results of ambient monitoring at three stations in the vicinity of the F-B LGA from 

2013 through 2015. A brief summary of the monitoring data includes the following: 

 Monitored data from 2013 through 2015 do not exceed either the state or federal standards

for CO or NO2.

 O3 values for the region exceed the state and national standards for all stations for years

2013 through 2015.

 The PM10 values for the region exceed the state 24-hour PM10 standard for the years 2013

through 2015 at the 5558 California Avenue, Bakersfield site; this station exceeded the

national standard once in 2014. No measurements were recorded at the S Union Avenue

Bakersfield and Shafter sites.

 The 5558 California Avenue, Bakersfield site exceeded the national PM2.5 standard for the

years 2013 through 2015. The S Union Avenue Bakersfield and Shafter sites did not record

PM2.5 during this time.

 No SO2 data were collected in the project vicinity.
Section 3.3 Air Quality and Global Climate Change 

November 2017 California High-Speed Rail Authority 

3.3-18 | Page Fresno to Bakersfield Section 

Draft Supplemental EIR/EIS 

Figure 3.3-2 Air Quality Monitoring Stations Closest to Project 
Section 3.3 Air Quality and Global Climate Change 

California High-Speed Rail Authority November 2017 

Fresno to Bakersfield Section Page | 3.3-19

Draft Supplemental EIR/EIS 

Table 3.3-4 Ambient Criterial Pollutant Concentration Data at Air Quality Monitoring Stations Closest to the Project 

Air 

Pollutant

Standard/Exceedance 548 Walker Street, Shafter 2000 S Union Avenue, 

Bakersfield

5558 California Avenue, 

Bakersfield

2013 2014 2015 2013 2014 2015 2013 2014 2015

Carbon 

Monoxide 

(CO)a

Year Coverage N/M N/M N/M N/M N/M N/M N/M N/M N/M

Max. 1-hour Concentration (ppm) N/M N/M N/M 1.8 1.9 1.7 1.8 1.9 1.7

Max. 8-hour Concentration (ppm) N/M N/M N/M 1.2 1.2 1.0 1.2 1.2 1.0

# Days > Federal 1-hour Std. of >35 ppm N/M N/M N/M 0 0 0 0 0 0

# Days > Federal 8-hour Std. of >9 ppm N/M N/M N/M 0 0 0 0 0 0

# Days > California 8-hour Std. of >9 ppm N/M N/M N/M N/M N/M N/M N/M N/M N/M

Ozone (O3) Year Coverageb 54% 99% 95% 81% 94% 94% 98% 81% 99%

Max. 1-hour Concentration (ppm) 0.112 0.100 0.104 0.109 0.108 0.118 0.107 0.102 0.104

Max. 8-hour Concentration (ppm) 0.096 0.087 0.090 0.102 0.095 0.106 0.099* 0.093* 0.097*

# Days > Federal 8-hour Std. of >0.075 ppm 5 11 17 23 32 55 22 20 28

# Days > California 1-hour Std. of >0.09 ppm 1 2 3 6 10 23 3 3 6

# Days > California 8-hour Std. of >0.07 ppm 19 28 34 81 94 94 47 36 54

Nitrogen 

Dioxide 

(NO2)

Year Coverage 98% 100% 97% 96% 99% 89% 75% 42% 97%

Max. 1-hour Concentration (ppm) 58.5 58.7 45.4 65.0 64.0 55.0 55.4 60.9 54.5

Annual Average (ppm) 14 11 9 14 13 12 N/M N/M 11

# Days > California 1-hour Std. of >0.18 ppm 0 0 0 0 0 0 0 0 0

Sulfur 

Dioxide 

(SO2)

Year Coverage N/M N/M N/M N/M N/M N/M N/M N/M N/M

Max. 24-hour Concentration (ppm) N/M N/M N/M N/M N/M N/M N/M N/M N/M

Annual Average (ppm) N/M N/M N/M N/M N/M N/M N/M N/M N/M

# Days > California 24-hour Std. of >0.04 ppm N/M N/M N/M N/M N/M N/M N/M N/M N/M
Section 3.3 Air Quality and Global Climate Change 

November 2017 California High-Speed Rail Authority 

3.3-20 | Page Fresno to Bakersfield Section 

Draft Supplemental EIR/EIS 

Air Standard/Exceedance 548 Walker Street, Shafter 2000 S Union Avenue, 5558 California Avenue, 

Pollutant Bakersfield Bakersfield

2013 2014 2015 2013 2014 2015 2013 2014 2015

Respirable 

Particulate 

Matter 

(PM10)

Year Coverage N/M N/M N/M N/M N/M N/M 46% 58% 99%

Max. 24-hour Concentration (μg/m3) N/M N/M N/M N/M N/M N/M 120.7 430.1 104.7

# Days > Federal 24-hour Std. of >150 μg/m3 N/M N/M N/M N/M N/M N/M 0 1 0

# Days > California 24-hour Std. of >50 μg/m3 N/M N/M N/M N/M N/M N/M 16 69 20

Annual Averagec (μg/m3) N/M N/M N/M N/M N/M N/M 47.0 55.9 44.5

Fine 

Particulate 

Matter 

(PM2.5)

Year Coverage N/M N/M N/M N/M N/M N/M 92% 95% 91%

Max. 24-hour Concentration (μg/m3) N/M N/M N/M N/M N/M N/M 111.7 101.9 107.8

State Annual Average (μg/m3) N/M N/M N/M N/M N/M N/M N/M 18.6 16.6

# Days > Federal 24-hour Std. of >35 μg/m3 N/M N/M N/M N/M N/M N/M 44 37 29

Annual Averagec (μg/m3) N/M N/M N/M N/M N/M N/M 19.9 18.5 16.2

Sources: CARB, 2016b and USEPA, 2016b

a

 Data is from the 2000 S Union Avenue, Bakersfield monitoring site. 

b Coverage is for 8-hour standard. 

c

 Coverage is for national standard. 

> = greater than 

* = Exceeds annual NAAQS

μg/m3 = micrograms per cubic meter 

Max. = maximum 

N/M = not monitored 

N/A = not available 

PM10 = particulate matter smaller than or equal to 10 microns in diameter 

PM2.5 = particulate matter smaller than or equal to 2.5 microns in diameter 

ppm = parts per million 

Std. = standard 

USEPA = U.S. Environmental Protection Agency 
Section 3.3 Air Quality and Global Climate Change 

California High-Speed Rail Authority November 2017 

Fresno to Bakersfield Section Page | 3.3-21

Draft Supplemental EIR/EIS 

Attainment Status of Study Area 

Both the USEPA and CARB designate each county (or portions of counties) within California as 

attainment, maintenance, or nonattainment based on the area’s ability to maintain ambient air 

concentrations below the air quality standards. Areas are designated as attainment if ambient air 

concentrations of a criteria pollutant are below the ambient standards. Areas are designated as 

nonattainment if ambient air concentrations are above the ambient standards. Areas previously 

designated nonattainment that subsequently demonstrated compliance with the standards are 

designated as maintenance. In February 2016, CARB submitted a final recommendation to the 

USEPA with a supporting document indicating that the San Joaquin Valley be designated in 

attainment of the federal one-hour O3 standard. The USEPA is expected to act upon this 

submittal and recommendation within the year. Table 3.3-5 summarizes the current federal 

(under NAAQS) and state (under CAAQS) attainment status for the basin. 

Table 3.3-5 Federal and State Attainment Status 

Pollutants Federal Classification State Classification 

O3 Nonattainment (Extreme) Nonattainment

PM10 Attainment Nonattainment

PM2.5 Nonattainment Nonattainment

CO Attainment/Unclassified Attainment

NO2 Attainment/Unclassified Attainment

SO2 Attainment/Unclassified Attainment

Source: SJVAPCD 2013

CO = carbon monoxide 

NOx = nitrogen oxide 

O3 = ozone 

Pb = lead 

PM10 = particulate matter smaller than or equal to 10 microns in diameter 

PM2.5 = particulate matter smaller than or equal to 2.5 microns in diameter 

SO2 = sulfur dioxide

Air Quality Plans and Programs 

State Implementation Plan 

Planning documents for pollutants for which the study area is classified as a federal 

nonattainment or maintenance area are developed by the SJVAPCD and CARB and approved by 

the USEPA. 

Table 3.3-6 summarizes the latest planning documents relevant to the project’s study area. 

Table 3.3-6 Federal and State Attainment Status 

Title Status

1-Hour O3 Attainment Plan On March 8, 2010, the USEPA approved the San Joaquin Valley’s 2004 Extreme 

Ozone Attainment Plan for the 1-hour O3 standard. However, effective June 15, 

2005, the USEPA revoked the federal 1-hour O3 standard for areas, including 

SJVAB.1. Due to subsequent litigation, the USEPA withdrew its plan approval in 

November 2012, and the SJVAPCD and CARB withdrew this plan from 

consideration. SJVAPCD adopted a revised plan in September 2013 and is currently 

seeking CARB’s approval. 
Section 3.3 Air Quality and Global Climate Change 

November 2017 California High-Speed Rail Authority 

3.3-22 | Page Fresno to Bakersfield Section 

Draft Supplemental EIR/EIS 

Title Status

8-hour O3 Attainment Plan On May 5, 2010, the USEPA reclassified the 8-hour O3 nonattainment status of San 

Joaquin Valley from “serious” to “extreme.” The reclassification requires the state to 

incorporate more stringent requirements, such as lower permitting thresholds and 

implementing reasonably available control technologies at more sources.1 The 2007 

Ozone Plan contained a comprehensive and exhaustive list of regulatory and 

incentive-based measures to reduce emissions of O3 and particulate matter

precursors throughout the San Joaquin Valley. On December 18, 2007, the 

SJVAPCD Governing Board adopted the plan with an amendment to extend the rule 

adoption schedule for organic waste operations. On January 8, 2009, the USEPA 

found that the motor vehicle budgets for the years 2008, 2020, and 2030 from the 

2007 8-hour Ozone Plan were not adequate for transportation conformity purposes.2

PM10 Maintenance Plan On September 25, 2008, the USEPA redesignated the San Joaquin Valley to 

attainment for the PM10 NAAQS and approved the 2007 PM10 Maintenance Plan.3

PM2.5 Attainment Plan The 2015 Plan for the 1997 PM2.5 Standard, approved by the District Governing 

Board on April 16, 2015, will bring the San Joaquin Valley into attainment of the 

USEPA’s 1997 PM2.5 standard as expeditiously as practicable, but no later than 

December 31, 2020.4 The plan provides measures designed to reduce emissions

such that the valley will attain the federal standards as soon as possible. 

CO Maintenance Plan On July 22, 2004, CARB approved an update to the State Implementation Plan that 

shows how 10 areas, including the SJVAB, will maintain the CO standard through 

2018. On November 30, 2005, the USEPA approved and promulgated the 

implementation plans and designation of areas for air quality purposes.5

Sources: 1 San Joaquin Valley Air Pollution Control District (2004) 

2

 San Joaquin Valley Air Pollution Control District (2007a) 

3

 San Joaquin Valley Air Pollution Control District (2007b) 

4

 San Joaquin Valley Air Pollution Control District (2015b) 

5

 California Air Resources Board 2004 

CARB = California Air Resources Board 

CO = carbon monoxide 

NAAQS = National Ambient Air Quality Standards

O3 = ozone

PM10 = particulate matter smaller than or equal to 10 microns in diameter

PM2.5 = particulate matter smaller than or equal to 2.5 microns in diameter 

SJVAB = San Joaquin Valley Air Basin 

SJVAPCD = San Joaquin Valley Air Pollution Control District 

USEPA = U.S. Environmental Protection Agency 

Transportation Plans and Programs 

Regional Transportation Planning Agencies and Metropolitan Planning Organizations within the 

SJVAB and the study area (for the F-B LGA, the Kern Council of Governments) are responsible 

for preparing Regional Transportation Plans (RTP). RTPs address a region’s transportation goals, 

objectives, and policies for the next 20 to 25 years, and identify the actions necessary to achieve 

those goals. Metropolitan Planning Organizations prepare Transportation Improvement 

Programs, which are five-year programs of proposed projects that incrementally develop the RTP 

and contain a listing of proposed transportation projects committed for funding. Transportation 

conformity projects are analyzed for air quality conformity with the State Implementation Plan as 

components of RTPs and Transportation Improvement Programs. 

The RTP/Sustainable Communities Strategy (SCS) establishes a set of regional transportation 

goals, policies, and actions intended to guide development of the planned multimodal 

transportation systems in Kern County. The RTP focuses on new efforts to achieve and maintain 

federal air quality standards and, in doing so, will make significant progress toward state climate 

change goals. The RTP also includes measures to reduce emissions of PM2.5 to achieve 

attainment plan goals. The SCS is intended to reduce GHG emissions from passenger vehicles 

and light-duty trucks by 5 percent per capita by 2020 and 10 percent per capita by 2035, as 
Section 3.3 Air Quality and Global Climate Change 

California High-Speed Rail Authority November 2017 

Fresno to Bakersfield Section Page | 3.3-23

Draft Supplemental EIR/EIS 

compared to 2005. GHG emissions and vehicle trip reduction strategies include, but are not 

limited to, the construction of new transit lines, expanded passenger rail service, increased transit 

service, and a change in transit fares (Kern Council of Governments 2014). CARB accepted the 

Kern COG 2014 RTP/SCS determination that the plan, if implemented, would meet the 2020 and 

2035 regional GHG reduction targets established by CARB (CARB 2015). 

Sensitive Receptors 

Within the localized study area, some locations are considered more sensitive to adverse effects 

from air pollution than others. These locations are termed sensitive receptors, and include 

schools, daycare facilities, elderly care establishments, medical facilities, and other areas that are 

populated with people considered more vulnerable to the effects of poor air quality. Analyses 

performed by CARB indicate that providing a separation of at least 1,000 feet from diesel sources 

and high-traffic areas would substantially reduce the exposure to air contaminants and decrease 

asthma symptoms in children (CARB 2005). Table 3.3-7 shows the sensitive receptors within 

1,000 feet of the F Street Station. 

Table 3.3-7 Distance Between Sensitive Receptors and the F Street Station 

Sensitive Receptors Distance (feet)

Sam Lynn Ball Park 1,000+

Valley Oaks Charter School 575

Westchester Town Homes 250

Single Family Residential on Spruce Street 850

Source: Authority and FRA, 2017 

3.3.5 Environmental Consequences 

As discussed in Section 1.1.3 of this Draft Supplemental EIR/EIS, the May 2014 Project is a 

component of the Preferred Alternative that was identified in the Fresno to Bakersfield Section 

Final EIR/EIS. The May 2014 Project consists of the portion of the BNSF Alternative from Poplar 

Avenue to Hageman Road and the Bakersfield Hybrid from Hageman Road to Oswell Street. This 

section summarizes the analysis of air quality impacts for the Fresno to Bakersfield Section with 

the May 2014 Project as a component and provides the impact analysis relating to air quality for 

the Fresno to Bakersfield Section with the F-B LGA as a component. Section 3.3.5.1 below 

provides an overview of impacts described for the Fresno to Bakersfield Section with the May 

2014 Project included. Section 3.3.5.2 below characterizes impacts that would occur for the 

Fresno to Bakersfield Section including the F-B LGA. 

3.3.5.1 Summary of Analysis for the May 2014 Project 

This section provides a summary of the effects of the May 2014 Project using information from 

the Fresno to Bakersfield Section Final EIR/EIS. 

Construction 

Construction phase emissions were quantitatively estimated for the earthwork and major civil 

construction activities of the following components of the entire Fresno to Bakersfield Section 

including the May 2014 Project: 

 At-grade guideway segments

 Elevated guideway segments

 Retained-fill guideway segments

 Substations

 HMF/maintenance-of-way facility

 HSR stations

 Roadways and roadway overpasses
Section 3.3 Air Quality and Global Climate Change 

November 2017 California High-Speed Rail Authority 

3.3-24 | Page Fresno to Bakersfield Section 

Draft Supplemental EIR/EIS 

These major construction activities would account for the vast majority of earthwork, the largest 

number of diesel-powered off-road construction equipment, and the majority of material to be 

hauled along public streets compared to other minor construction activities of the project. 

Therefore, the regional emissions and localized emissions from these major activities would 

account for the majority of construction emissions that would be generated by the construction of 

the proposed project. Regional and localized emissions from minor construction activities, such 

as mobilization and demobilization, were quantified and would contribute to fewer emissions than 

the major construction activities listed above. The estimated construction emissions from these 

major as well as minor activities were then used to estimate the regional air quality impacts and 

localized air quality impacts that would occur during the construction phase. 

Criteria pollutant and GHG emissions from regional building demolition and construction of the atgrade rail segments, elevated rail segments, retained-fill rail segments, traction power 

substations, industrial buildings at the HMF, and HSR stations, including parking garages and 

platform facilities, were calculated using emission factors from CARB’s OFFROAD 2011 and 

2007 models (CARB 2011). The OFFROAD 2011 model provided the latest emission factors at 

the time for construction off-road equipment, and accounts for lower fleet population and growth 

factors due to the economic recession and updated load factors based on feedback from engine 

manufacturers (CARB 2010). For emission rates not available in OFFROAD 2011, rates from 

OFFROAD2007 were conservatively applied. The use of emission rates from the OFFROAD 

models reflects the recommendation of CARB to capture the latest off-road construction 

assumptions. OFFROAD 2011 default load factors (the ratio of average equipment horsepower 

utilized to maximum equipment horsepower) and useful life parameters were used for emission 

estimates. Mobile-source emission burdens from worker vehicle trips and truck trips were 

calculated using VMT estimates and appropriate emission factors from EMFAC2011. Fugitive 

dust emissions from dirt and aggregate handling were calculated using emission factors derived 

from equations from U.S. EPA’s AP-42 (U.S. EPA 2006b). 

Results of the analysis indicate construction of the May 2014 Project would have the potential to 

cause temporary and significant localized air quality impacts, including exceeding the applicable 

de minimis thresholds for specific criteria pollutants. Implementation of impact avoidance and 

minimization measures and mitigation measures during construction phases could reduce PM10

and PM2.5 emissions by reducing fugitive dust and exhaust from construction and on-road 

vehicles. Mitigation measures could also reduce the quantity of other criteria pollutants (NOX, 

volatile organic compounds [VOC], and CO) and GHG emissions by controlling exhaust 

emissions from construction and on-road vehicles. Finally, funding of emissions offsets for certain 

criteria pollutants would result in further mitigation leading to a “net zero” level of emission for NOx

and VOC. 

Operation 

Operation of the HSR alternatives including the May 2014 Project would provide a net regional air 

quality benefit. Operation of all HSR Build Alternatives, including the May 2014 Project would 

generally reduce regional criteria and GHG pollutant emissions, and would have less than

significant impact under CEQA on air quality. 

Intersections in the study area assessed for the May 2014 Project would not result in violations of 

CO NAAQS. Maximum modeled CO concentrations at intersections near the Fresno, 

Kings/Tulare Regional, and Bakersfield HSR Stations and HMF and parking facilities would be 

below NAAQS and CAAQS. 

The May 2014 Project would provide regional benefits in reducing the area VMT resulting in 

reduced PM10 and PM2.5 emissions associated with regional vehicle travel. For purposes of 

identifying and evaluating potential impacts, a PM hot-spot analysis was prepared for the May 

2014 Project. Based on the analysis conducted for the project, the May 2014 Project would not be 

considered a project of air quality concern, as defined by 40 C.F.R. § 93.123(b)(1), and would not 

likely cause violations of PM10/PM2.5 NAAQS during its operation. Therefore, quantitative PM2.5 

and PM10 hot-spot evaluations are not required. The requirements of 40 C.F.R. § 93.116 are 

therefore met without a quantitative hot-spot analysis. The Preferred Alternative identified in the 
Section 3.3 Air Quality and Global Climate Change 

California High-Speed Rail Authority November 2017 

Fresno to Bakersfield Section Page | 3.3-25

Draft Supplemental EIR/EIS 

Fresno to Bakersfield Section Final EIR/EIS, which included the May 2014 Project, was found to 

not likely cause an adverse impact on air quality for PM10/PM2.5 standards because, based on 

these criteria, it is not a project of air quality concern. 

3.3.5.2 Fresno to Bakersfield Locally Generated Alternative 

Construction Period Impacts 

Impact AQ #1—Regional Air Quality Impacts During Construction 

Construction of the full Fresno to Bakersfield Section, including the F-B LGA, would occur from 

2014 to 2023. The 2014 start date for the construction air analysis in this section is to account for 

the construction of the entire Fresno to Bakersfield alignment, which began in 2014. The total 

unmitigated emissions (i.e., the actual estimated amounts/quantities) for construction of the F-B 

LGA are shown in Table 3.3-8, which include the incorporation of the Avoidance and 

Minimization Measures for dust control. The F-B LGA emissions were compared to the GC de 

minimis emission thresholds on a calendar-year basis; consequently, thresholds can be 

exceeded for any calendar year in which emissions occur. Table 3.3-8 provides a comparison of 

the HSR construction emissions for the F-B LGA over the total construction period for the entire 

Fresno to Bakersfield alignment and differentiates between the F-B LGA and the May 2014 

Project alternatives. Details of emissions from the F-B LGA are presented in Table 3.3-9. 

Emissions presented include emissions from all construction phases of the HSR and the regional 

roadway realignment. The emission estimates presented in Table 3.3-9 were calculated 

assuming a viaduct structure for the F-B LGA. The structure on retained fill would result in slightly 

different emission estimates, including lower estimates for construction mobilization, demolition, 

road crossings, and demobilization. Emissions would be approximately 1 percent higher for land 

clearing and earth moving. All other construction-phase emissions would remain the same. 

Therefore, construction of the structure on retained fill would result in emissions similar to those 

presented in Table 3.3-8. 

Table 3.3-8 Total F-B HSR Unmitigated Construction Emissions –Total (tons) 

Alternative Emissionsa

VOC CO NOX SO2 PM10b PM2.5b

F-B Section including F-B LGA 101 743 1,796 3 212 99

F-B Section including May 2014 

Project

103 757 1,818 3 218 103

Source: Authority and FRA, 2017

a

 Emissions include HSR project construction as well as roadway projects that are not included in Regional Transportation Plans that would occur 

over a period of years. 

b

 The PM10 and PM2.5 emissions consist of the exhaust and fugitive dust emissions. 

CO = carbon monoxide 

F-B LGA = Fresno to Bakersfield Locally Generated Alternative 

HSR = high-speed rail 

NOX = nitrogen oxides 

PM10 = particulate matter smaller than or equal to 10 microns in diameter 

PM2.5 = particulate matter smaller than or equal to 2.5 microns in diameter 

SO2 = sulfur dioxide 

VOC = volatile organic compound 

As with the May 2014 Project, direct emissions from the construction phase of the F-B LGA would 

exceed the GC applicability thresholds for VOC and NOX in certain calendar years in which 

construction would occur (see Table 3.3-9). 

Purchase of offset emissions through a Voluntary Emission Reduction Agreement (VERA) with 

the SJVAPCD (Mitigation Measure AQ-MM#4) for VOC and NOx would offset and reduce VOC 

and NOX emissions to below the GC applicability thresholds. 
Section 3.3 Air Quality and Global Climate Change 

November 2017 California High-Speed Rail Authority 

3.3-26 | Page Fresno to Bakersfield Section 

Draft Supplemental EIR/EIS 

Table 3.3-9 Programmatic Construction Emissions: F-B LGA (tons/year)a 

Activities VOC CO NOX SO2 PM d 10 PM d 2.5

Total Fresnoe Bakersfielde

SJVAPCD annual CEQA significance thresholdsb 10 100 N/A N/A 10 27 15 15

Annual general conformity de minimis levels applicable to the SJVABc 10 N/A 100 100 10 100 100 100

Year 2014

Emissions (tons/year) 16.33 99.92 59.95 24.71 373.42 0.62 40.16 12.44

Exceeds SJVAPCD CEQA thresholds? Yes No N/A N/A Yes No Yes No

Exceeds GC threshold? Yes N/A No No Yes No No No

Year 2015

Emissions (tons/year) 36.1 284.39 91.77 60.30 610.46 1.16 66.42 29.35

Exceeds SJVAPCD CEQA thresholds? Yes Yes N/A N/A Yes No Yes Yes

Exceeds GC threshold? Yes N/A No No Yes No No No

Year 2016

Emissions (tons/year) 31.71 251.68 75.27 56.47 493.70 0.87 59.34 26.03

Exceeds SJVAPCD CEQA thresholds? Yes Yes N/A N/A Yes No Yes Yes

Exceeds GC threshold? Yes N/A No No Yes No No No

Year 2017

Emissions (tons/year) 8.49 48.86 16.56 15.27 161.23 0.22 15.76 11.8

Exceeds SJVAPCD CEQA thresholds? No No N/A N/A Yes No Yes No

Exceeds GC threshold? No N/A No No Yes No No No

Year 2018

Emissions (tons/year) 3.89 30.27 6.19 3.74 70.89 0.24 14.90 9.43

Exceeds SJVAPCD CEQA thresholds? No No N/A N/A Yes No No No

Exceeds GC threshold? No N/A No No Yes No No No

Year 2019

Emissions (tons/year) 0.42 4.07 6.33 1.70 4.17 0.01 8.63 6.93

Exceeds SJVAPCD CEQA thresholds? No No N/A N/A No No No No

Exceeds GC threshold? No N/A No No No No No No
Section 3.3 Air Quality and Global Climate Change 

California High-Speed Rail Authority November 2017 

Fresno to Bakersfield Section Page | 3.3-27

Draft Supplemental EIR/EIS 

Activities VOC CO NOX SO2 PM d 10 PM d 2.5

Total Fresnoe Bakersfielde

Year 2020

Emissions (tons/year) 0.25 2.50 4.18 1.21 1.95 0.01 2.95 0.14

Exceeds SJVAPCD CEQA thresholds? No No No No No No No No

Exceeds GC threshold? No N/A No No No No No No

Year 2021

Emissions (tons/year) 3.87 19.56 10.11 9.26 79.74 0.14 4.33 2.36

Exceeds SJVAPCD CEQA thresholds? No No No No Yes No No No

Exceeds GC threshold? No N/A No No Yes No No No

Year 2022

Emissions (tons/year) 0.09 1.13 0.54 0.00 0.53 0.00 0.13 0.05

Exceeds SJVAPCD CEQA thresholds? No No No No No No No No

Exceeds GC threshold? No N/A No No No No No No

Year 2023

Emissions (tons/year) 0.03 0.39 0.00 0.00 0.19 0.00 0.08 0.02

Exceeds SJVAPCD CEQA thresholds? No No No No No No No No

Exceeds GC threshold? No N/A No No No No No No

Source: Authority and FRA, 2017

a These construction emissions were established for the F-B LGA, including the entire alignment from Fresno to Bakersfield. 

b

 The SJVAPCD has identified construction emissions significance thresholds for CO, SO2 NOx, ROG, VOC, PM10, and PM2.5 in the 2015 GAMAQI. 

c The GC de minimis thresholds for criteria pollutants are based on the SJVAB federal attainment status. The SJVAB is considered in extreme nonattainment for the ozone NAAQS, is a nonattainment area for PM2.5, and is 

a maintenance area for the CO NAAQS (Fresno and Bakersfield urbanized areas only) and PM10 NAAQS. Although the SJVAB is in attainment for SOx, since SOx is a precursor for PM2.5, the PM2.5 GC de minimis

threshold was used. 

d PM10 and PM2.5 emissions have incorporated the SJVAPCD Regulation VIII requirements and dust control measures. 

e

 The Fresno urbanized area and the Bakersfield metropolitan area are separate CO maintenance areas. CO emissions presented for these areas represent the Fresno and Bakersfield urbanized maintenance areas only. 

CEQA = California Environmental Quality Act 

CO = carbon monoxide 

F-B LGA = Fresno to Bakersfield Locally Generated Alternative 

GAMAQI = Guide for Assessing and Mitigating Air Quality Impacts 

GC = general conformity 

N/A = not applicable 

NOX = nitrogen oxides 

PM10 = particulate matter smaller than or equal to 10 microns in diameter 

PM2.5 = particulate matter smaller than or equal to 2.5 microns in diameter 

ROG = reactive organic gas 

SJVAB = San Joaquin Valley Air Basin 

SJVAPCD = San Joaquin Valley Air Pollution Control District 

SO2 = sulfur dioxide 

VOC = volatile organic compound 
Section 3.3 Air Quality and Global Climate Change 

November 2017 California High-Speed Rail Authority 

3.3-28 | Page Fresno to Bakersfield Section 

Draft Supplemental EIR/EIS 

Construction emissions would exceed the mass emission SJVAPCD CEQA thresholds for VOC, 

CO, NOx, PM10, and PM2.5 in some construction years. Therefore, construction emissions of these 

pollutants may cause significant impacts on air quality under CEQA. There is no mass emission 

CEQA threshold for SO2 from SJVAPCD; however, SO2 emissions are expected to be less than 

significant based on the emission results as shown in Table 3.3-9. 

With onsite mitigation (i.e., AQ MM#1 and #2), VOC, CO, NOx, PM10, and PM2.5 impacts would be 

reduced, but could remain significant under CEQA. As stated in SJVAPCD 2015 GAMAQI 

(SJVAPCD 2015), purchase of offset emissions through a Voluntary Emission Reduction 

Agreement (VERA) with the SJVAPCD (Mitigation Measure AQ-MM#4) for these pollutants would 

reduce impacts to less than significant after mitigation under CEQA. 

Impact AQ #2—Compliance with Air Quality Plans 

As with the May 2014 Project, emissions from construction of the F-B LGA would be temporary. 

However, based on the amount of construction to be completed, construction activities would 

involve heavy-duty construction equipment and would have the potential to cause adverse air 

quality impacts. 

As with the Fresno to Bakersfield Section including the May 2014 Project and as shown in Table 

3.3-9, VOC, CO and NOX emissions associated with the Fresno to Bakersfield Section including 

the F-B LGA would exceed the GC applicability thresholds, while PM10 and PM2.5 emissions 

would be below the GC applicability thresholds. Emissions above the mass emission thresholds 

set by the SJVAPCD would have the potential to conflict with or obstruct implementation of the 

SJVAPCD’s air quality plans, which have been prepared to attain federal and state ambient air 

quality standards. VOC, CO, NOx, PM10, and PM2.5 emissions would exceed the mass emission 

SJVAPCD thresholds and impede the implementation of the respective air quality plans, including 

plans prepared to attain federal ambient air quality standards. 

As with the May 2014 Project, VOC, NOx, PM10, and PM2.5 emissions associated with the F-B 

LGA would be greater than applicable mass emission CEQA significance thresholds, which would 

impede or obstruct implementation of the 8-hour SJVAPCD 2007 Ozone Plan, or the 2013 Plan 

for the Revoked 1-hour Ozone Standard the 2007 PM10 Maintenance Plan, and the 2015 PM2.5

Plan. Therefore, this impact would be significant under CEQA for VOC, NOx, PM10, and PM2.5

emissions. 

With on-site mitigation (i.e., AQ MM#1 and #2), VOC, CO, NOx, PM10, and PM2.5 impacts would 

be reduced but could remain significant under CEQA. As stated in the SJVAPCD 2015 GAMAQI 

(SJVAPCD 2015a), purchase of offset emissions through a VERA with the SJVAPCD (Mitigation 

Measure AQ-MM#4) for these pollutants would reduce impacts to less than significant after 

mitigation under CEQA. 

Impact AQ # 3—Material-Hauling Emissions Outside of SJVAB 

Construction emissions included in the regional impacts analysis (Impact AQ #1) considered 

emissions within the SJVAB. As with the May 2014 Project, the HSR track bed under the F-B 

LGA would be constructed using ballast, subballast, and concrete slabs. Subballast and concrete 

slabs would be available within the SJVAB; however, the ballast could potentially be transported 

from areas outside the SJVAB. As described in Section 3.3.6.3 of the Fresno to Bakersfield 

Section Final EIR/EIS (Authority and FRA 2014a: page 3.3-52), emissions associated with 

transportation of ballast materials from outside the SJVAB to the border of the air basin were 

evaluated for five hauling scenarios from five quarries. 

The emission results demonstrated that worst-case emissions would be above the GC thresholds 

for NOx (25.18 tons per year of NOx) in the South Coast Air Basin for four of the five scenarios 

analyzed; in the Salton Sea Air Basin (35.76 tons per year of NOx) for one of the five scenarios 

analyzed; and in the Mojave Desert Air Basin (27.20 tons per year of NOx) for one of the five 

scenarios analyzed. The emissions of NOx in the other air basins (Sacramento Valley Air Basin 

and San Francisco Bay Area Air Basin) would be below the GC thresholds for all scenarios. The 
Section 3.3 Air Quality and Global Climate Change 

California High-Speed Rail Authority November 2017 

Fresno to Bakersfield Section Page | 3.3-29

Draft Supplemental EIR/EIS 

emissions for all other pollutants would be below the GC thresholds for all scenarios in all air 

basins. 

As with the May 2014 Project, emissions associated with material hauling would exceed the 

CEQA thresholds for NOx for all scenarios in multiple air quality management districts (AQMD) or 

air pollution control districts. All other pollutants for these scenarios would be below the CEQA 

thresholds. 

Under CEQA, the material-hauling emissions outside the SJVAB could exceed the South Coast 

AQMD (which includes both the South Coast Air Basin and Salton Sea Air Basin) CEQA NOx

thresholds in all five scenarios, and could exceed the Bay Area AQMD’s CEQA NOx thresholds 

for two of the scenarios. The material-hauling emissions could also exceed the Mojave Desert 

AQMD NOx CEQA threshold for two of the scenarios. 

Therefore, NOx emissions could have a significant impact in the South Coast AQMD Bay Area 

AQMD, and Mojave Desert AQMD. Material-hauling emissions would be below the CEQA 

thresholds for all other air districts and pollutants, and would have insignificant impacts. Mitigation 

measures to reduce the material-hauling emission impacts are discussed in Section 3.3.7, 

Mitigation Measures and Avoidance and Minimization Measures (AQ-MM#2 and AQ-MM#5). With 

mitigation, impacts in these other air basins would be reduced to less than significant under 

CEQA. 

Detailed analysis for the material-hauling emissions for all build options is presented in the 

Fresno to Bakersfield Section: Air Quality Technical Report (Authority and FRA 2014a). The 

analysis of hauling emissions is representative of the entire Fresno to Bakersfield Section 

including the May 2014 Project and the Fresno to Bakersfield Section including the F-B LGA 

because the estimated quantities of material that would be hauled would be similar for the two 

alternatives. 

Impact AQ #4—Greenhouse Gas Emissions During Construction 

As discussed in the Fresno to Bakersfield Section: Air Quality Technical Report (Authority and 

FRA 2014a), to conservatively estimate the amortized GHG emissions, the HSR project life is 

conservatively assumed to be only 25 years (although the actual project life would be much 

longer). The amortized GHG construction emissions for the F-B LGA would be 8,963 metric tons 

of CO2e per year, as shown in Table 3.3-10. GHG emissions associated with construction and 

operation of the F-B LGA would be similar to those estimated for the May 2014 Project. As shown 

in Table 3.3-10 below, similar to the May 2014 Project, the F-B LGA construction GHG emissions 

would be offset in less than 12 months of the HSR operations because of car and plane trips 

removed in the Fresno to Bakersfield area. Additional emission reductions would be achieved 

statewide due to removed car and plane trips. 

The HSR project’s GHG emissions conform with AB 32 and SB 32. The scoping plan for AB 32 

includes the implementation of the HSR project as a GHG reduction measure, estimating a 2020 

reduction of 1 MMT of CO2e emissions (CARB 2008). Although the current schedule for 

commencement of operation would not result in GHG emission reductions until approximately 

2029, the HSR is still considered to be in conformance with AB 32 because the implementation of 

HSR is specifically highlighted as a GHG reduction measure in the scoping plan for AB 32. SB 32 

effectively establishes a new greenhouse gas reduction goal for statewide emissions of 40 

percent below 1990 levels by 2030. If train operations commence in 2029, then operation of HSR 

would contribute to the SB 32 goal of GHG emissions 40 percent below 1990 levels by 2030 and 

the EO S-3-05 goal of GHG emissions 80 percent under 1990 levels by 2050, and therefore 

implementation of the HSR would be considered to be in conformance with SB 32 and EO S-3-

05. Therefore, construction GHG emissions associated with F-B LGA would be less than

significant under CEQA. 
Section 3.3 Air Quality and Global Climate Change 

November 2017 California High-Speed Rail Authority 

3.3-30 | Page Fresno to Bakersfield Section 

Draft Supplemental EIR/EIS 

Table 3.3-10 F-B LGA CO2e Unmitigated Construction Emissions (metric tons/year)a,b,c

Year F-B LGA May 2014 Project

2014 51,141 51,661

2015 74,838 75,421

2016 51,017 51,561

2017 16,766 16,782

2018 18,509 18,509

2019 498 498

2020 271 271

2021 10,876 10,876

2022 111 111

2023 38 38

Total 224,065 225,728

Amortized GHG Emissions (averaged over 25 years)

CO2e per year 8,963 9,029

Payback of GHG Emissions (months) d

Payback Period 7 or 12 months 7 or 12 months

Source: Authority and FRA, 2017 

a

 Emissions represent GHG emissions associated with construction activities within the SJVAB. Emission factors for CO2 do not account for 

improvements to technology. Project life is assumed to be 25 years. 

b According to the USEPA, on average, CO2 emissions are 95-99% of the total greenhouse gas emissions from a passenger vehicle, after 

accounting for the global warming potential of all GHGs (USEPA 2014). The remaining 1 to 5% is CH4, N2O, and HFC emissions Therefore, to 

account for the CH4, N2O, and HFC emissions, the CO2 emissions were conservatively increased by 5% to calculate the CO2e emissions. It was 

assumed that this approach for passenger vehicles was applicable to construction emissions sources. 

c Construction emissions are lower from 2019 to 2020 and 2022 to 2023 because it was assumed that hauling would not occur during these 

periods. 

d Payback periods were estimated by dividing the GHG emissions during construction years by the annual GHG emission reduction during project 

operation. See Tables 3.3-17 and 3.3-18 of the Fresno to Bakersfield Section: Air Quality Technical Report (California High-Speed Rail Authority 

and Federal Railroad Administration 2014) for operational GHG emissions reduction data. 

CH4 = methane 

CO2 = carbon dioxide 

CO2e = carbon dioxide equivalent 

F-B LGA = Fresno to Bakersfield Locally Generated Alternative 

GHG = greenhouse gas 

HFCs = hydrofluorocarbons 

HSR = high-speed rail 

N2O = nitrous oxide 

RTP = regional transportation plan 

SJVAB = San Joaquin Valley Air Basin 

USEPA = U.S. Environmental Protection Agency 

Local Impacts 

Impact AQ #5—Asbestos and Lead-Based Paint Exposure During Construction 

The demolition of asbestos-containing materials is subject to the limitations of the National 

Emissions Standards for Hazardous Air Pollutants regulations and would require an asbestos 

inspection. Although it is unknown at this time whether any of the buildings that will be 

demolished contains asbestos, the SJVAPCD’s Compliance Division would be consulted before 

demolition of any structures begins. As described in Section 3.10, Hazardous Materials and 

Wastes, the project would include strict compliance with existing asbestos regulations as part of 

project design. 

Compliance with existing asbestos regulations would prevent asbestos from being a significant 

impact under CEQA (SJVAPCD 2015a). Therefore, the localized impacts from asbestos and 
Section 3.3 Air Quality and Global Climate Change 

California High-Speed Rail Authority November 2017 

Fresno to Bakersfield Section Page | 3.3-31

Draft Supplemental EIR/EIS 

lead-based paint exposure would be less than significant under CEQA. Kern County is 

designated by the CDMG as an area likely to contain NOA. However, the specific locations of the 

counties where project construction would occur are in areas designated not likely to contain 

NOA (CDMG 2000). Therefore, NOA would not likely be disturbed during construction. 

Buildings in the study area might be contaminated with residual lead, which was used as a 

pigment and drying agent in oil-based paint until the Lead-Based Paint Poisoning Prevention Act 

of 1971 prohibited such use. If encountered during structure demolitions and relocations, leadbased paint and asbestos will be handled and disposed of in accordance with applicable 

standards. Section 3.10, Hazardous Materials and Wastes, discusses potential issues concerning 

lead-based paint during project construction. 

The Authority requires its Design Build contractors to prepare Health and Safety Plans for their 

projects. The Tutor Perini, Zachry, Parsons Joint Venture submitted a Health and Safety Plan in 

February 2014. The Plan includes Best Management Practices required to minimize human 

exposure to asbestos-containing materials. The contracts for Fresno to Bakersfield Section 

Construction Packages 2, 3, and 4 have the same requirements for a Health and Safety Plan. 

The Health and Safety Plans are referenced and discussed in Section 3.10, Hazardous Materials 

and Wastes, and Section 3.11, Safety and Security, of this Draft Supplemental EIR/EIS. 

Impact AQ #6—Localized Air Quality Impacts During Guideway/Alignment Construction 

Construction emissions have the potential to cause elevated criteria pollutant concentrations. 

These elevated concentrations may cause or contribute to exceedances of the NAAQS and 

CAAQS, which are established concentrations of criteria pollutants that provide public health 

protection. Sensitive receptors (such as schools, residences, and health-care facilities) are 

located near the construction areas in Bakersfield. During construction, sensitive receptors would 

be exposed to increased concentrations of TACs, such as diesel particulate matter, which may 

present cancer risks. According to the California Office of Environmental Health Hazard 

Assessment (OEHHA) guidance, cancer risk is defined as the predicted risk of cancer (unitless) 

over a lifetime based on a long-term (70-year) continuous exposure, and is usually expressed as 

chances per million persons exposed (OEHHA 2015). 

The construction emissions associated with the guideway/alignment construction includes several 

different phases such as mobilization, demolition, earth moving, land clearing, track construction 

at grade and elevated structures. These emissions were modeled for the May 2014 Project using 

USEPA’s AERMOD atmospheric dispersion model to predict pollutant concentrations at locations 

near the construction of the guideway/alignment. Meteorological data from the Fresno County 

Airport was used since the SJVAPCD Air Dispersion Modeling Guidance indicates that this 

station has the most conservative wind speeds for the air district (SJVAPCD 2007c). Since it is 

not practical to model the entire 114-mile HSR segment, a 2-mile section of track was modeled as 

this was determined to be an appropriate segment length to represent a reasonable work area, 

and emissions from further away are unlikely to have any appreciable impact to local sensitive 

receptors. The increase in pollutant concentration associated with the project emissions is added 

to the background concentration to estimate the ambient air pollutant concentration for 

comparison to the applicable NAAQS and CAAQS. The modeled diesel particulate matter (DPM) 

concentrations were used to determine the exposure dose and associated health impact following 

OEHHA guidance for health risk assessments. Specific details of the air dispersion modeling and 

health risk assessment are found in Appendix H of the Fresno to Bakersfield Section: Air Quality 

Technical Report. 

The modeling for the May 2014 Project informs the conclusions about construction activities 

associated with the F-B LGA because construction air emissions are largely a function of 

alignment length. The Fresno to Bakersfield Section Final EIR/EIS included calculations of the 

emissions for the 114 miles associated with the May 2014 Project. The construction air quality 

emission values referenced in Table 3.3-9 represent emission calculations for the entire 114-milelong Fresno to Bakersfield Section with the F-B LGA. Emissions presented include emissions 

from all construction phases of the HSR and the regional roadway realignment. 
Section 3.3 Air Quality and Global Climate Change 

November 2017 California High-Speed Rail Authority 

3.3-32 | Page Fresno to Bakersfield Section 

Draft Supplemental EIR/EIS 

According to the construction localized impact air dispersion modeling conducted for the May 

2014 Project, construction activities along the guideway/alignment would not exceed the 

applicable NAAQS and CAAQS or substantially contribute to further exacerbation of exceedances 

of PM10 and PM2.5 standards. The health risk assessment concludes that the incremental 

increase in cancer risk associated with the diesel particulate matter emissions from construction 

equipment exhaust would not exceed the applicable threshold of 10 in 1 million. 

As shown in Table 3.3-9, mass emission generation associated with the F-B LGA would be 

similar to the emissions evaluated for the May 2014 Project. Therefore, emissions associated with 

the F-B LGA would also not be expected to exceed NAAQS or CAAQS or substantially contribute 

to further exacerbation of exceedances of PM10 and PM2.5 standards due to similar site 

meteorology of the two alignments. Emissions associated with the F-B LGA would be expected to 

be lower than those estimated for the May 2014 Project, as shown in Table 3.3-8. Therefore, 

implementation of the F-B LGA would also not cause or contribute to exceedances of the NAAQS 

and CAAQS. 

Since the construction activities associated with the guideway/alignment would occur near the 

sensitive receptors for short periods of time, and air dispersion modeling and health risk 

assessments estimate that concentration levels and health risks would be below applicable 

thresholds, the localized air quality impacts would be less than significant under CEQA 

Impact AQ #7—Localized Air Quality Impacts to Schools and Other Sensitive Receptors 

During Station Construction 

Station construction would take place over a period of four years, and sensitive receptors at 

schools, residences, and health-care facilities near the station construction areas could potentially 

be exposed to health impacts from elevated concentrations of criteria pollutants and cancer risks 

associated with TACs. There are several sensitive receptors located near the proposed F-B LGA 

station, including residences, schools, and parks. The NAAQS and CAAQS are established 

concentrations of criteria pollutants that provide public health protection. According to the OEHHA 

guidance, cancer risk is defined as the predicted risk of cancer (unitless) over a lifetime based on 

a long-term (70-year) continuous exposure, and is usually expressed as chances per million 

persons exposed (OEHHA 2015). As documented in the Fresno to Bakersfield Section Final 

EIR/EIS, the construction emissions associated with HSR station construction were modeled for 

the Bakersfield Station using local meteorological data sets (Bakersfield Airport). These 

emissions were modeled using USEPA’s AERMOD atmospheric dispersion model to predict 

pollutant concentrations at locations near the construction of the station. The modeled work area 

for each station was based on the approximate station footprint. The analysis used station 

footprints for the station alternatives associated with the BNSF Alternative (Bakersfield StationNorth Alternative). These footprints were assumed to be representative of the other station 

alternatives in terms of size and distance to sensitive receptors, and are also representative of 

the F Street Station under the F-B LGA. The increase in pollutant concentration associated with 

the project emissions is added to the background concentration to estimate the ambient air 

pollutant concentration for comparison to the applicable NAAQS and CAAQS. The modeled DPM 

concentrations were used to determine the exposure dose and associated health impact following 

OEHHA guidance for health risk assessments. Specific details of the air dispersion modeling and 

health risk assessment are found in Appendix H of the Fresno to Bakersfield Section: Air Quality 

Technical Report. 

The long-term (cancer risk) impacts from TAC emissions associated with station construction 

would be less than significant under CEQA because the proposed F-B construction would not 

exceed the applicable threshold of 10 in a million. Exposure to TAC emissions associated with 

station construction would not result in substantial short-term (acute) impacts. 

Impact AQ #8–Localized Air Quality Impacts from Concrete Batch Plants 

Construction of the project would require the use of concrete batch plants at various locations 

along the construction route. The precise locations of the concrete batch plants are unknown at 

this time. As with the May 2014 Project, the concrete batch plants associated with construction of 
Section 3.3 Air Quality and Global Climate Change 

California High-Speed Rail Authority November 2017 

Fresno to Bakersfield Section Page | 3.3-33

Draft Supplemental EIR/EIS 

the F-B LGA are estimated to generate 7 tons per year of particulate emissions for the at-grade 

and elevated alignments for each Fresno to Bakersfield Section alternative. It is anticipated that 

the same number and distribution of concrete batch plans is needed for the Fresno to Bakersfield 

Section regardless of whether the May 2014 Project or the F-B LGA would be implemented. The 

concrete generated would include concrete for the elevated structures (elevated rail) and 

retaining wall (retained-fill rail). The concrete batch plants would be located along the alignment. 

According to Cal-EPA and CARB’s Air Quality and Land Use Handbook: A Community Health 

Perspective (Cal-EPA and CARB 2005), emission impacts at receptors would be greatly reduced 

by locating a facility 1,000 feet from sensitive receptors. The air dispersion modeling and health 

risk analysis for fugitive dust emissions and their associated TAC constituents indicated that 

excess cancer risks and noncancer health impacts would not exceed the applicable thresholds, 

but emissions may contribute to further exacerbation of exceedances of PM10 and PM2.5

standards. After mitigation, emissions would not substantially contribute to further exceedances of 

PM10 and PM2.5 standards (AQ-MM#3). 

Based on the air dispersion modeling conducted for the concrete batch plants associated with the 

HSR project, the localized air quality impacts from concrete batch plants would be significant 

under CEQA to sensitive receptors within 1,000 feet of the batch plant. Mitigation measure AQMM# 3 would reduce the localized air impact to sensitive receptors to a less than significant level 

by ensuring concrete batch plants are sited at least 1,000 feet from sensitive receptors. AQMM#3 would also require the utilization of typical control measures to reduce fugitive dust, which 

would reduce the PM10 and PM2.5 concentrations as they relate to the NAAQS and CAAQS, to a 

less than significant level under CEQA. 

Impact AQ #9—Localized Air Quality Impacts from MOIF 

Construction Air emissions associated with construction of the MOIF would be small relative to 

the quantity of emissions from construction of the alignment/guideway. Emissions from MOIF 

construction would be located in one area. TACs, mostly DPM exhaust from construction 

equipment, and criteria pollutants would be emitted during construction of the MOIF. 

Impacts of construction of the MOIF would be localized; therefore, potential exposure to DPM 

was evaluated for areas adjacent to the construction site. The majority of the construction 

emissions would be DPM from diesel construction equipment used for mass site grading, building 

construction, and the HMF guideway construction. The main health risk concerns of DPM are 

cancer and chronic risks. Cancer risk from exposure to carcinogens is typically evaluated based 

on a long-term (70-year) continuous exposure, and chronic risks are also typically evaluated for 

long-term exposure. The period of construction for the MOIF would be approximately 20 months. 

This short period and level of exposure is not expected to increase the cancer risk to sensitive 

receptors in the vicinity of the MOIF construction area. The concentration increase of criteria air 

pollutants associated with construction of the MOIF would not exceed the applicable thresholds. 

The incremental increase in cancer risk associated with the DPM emissions from construction 

equipment would be less than the applicable threshold of 10 in a million. 

Under CEQA, the local impact of the MOIF construction would be less than significant because 

sensitive receptors are not expected to be exposed to long-term DPM emissions during MOIF 

construction that would cause significant cancer or non-cancer health risks. 

Project Operation Impacts 

Common Air Quality Impacts 

Common benefits to regional air quality would come from a reduction in VMT and airplane 

emissions, which would reduce criteria pollutants, MSAT, and GHG emissions. 

Additionally, the project would have the common benefit of meeting a GHG reduction measure 

identified in the AB 32 scoping plan. Common air quality impacts that are applicable to the May 

2014 Project and the F-B LGA are discussed on page 3.3-57 of the Fresno to Bakersfield Section 

Final EIR/EIS. 
Section 3.3 Air Quality and Global Climate Change 

November 2017 California High-Speed Rail Authority 

3.3-34 | Page Fresno to Bakersfield Section 

Draft Supplemental EIR/EIS 

Statewide and Regional Impacts

As discussed in Section 3.3.3, in compliance with CEQA, the HSR project’s air quality impacts 

are evaluated both against existing conditions and against background (i.e., No Project) 

conditions as they are expected to be in 2035. Table 3.3-11 summarizes statewide emission 

changes for the HSR Build Alternatives in 2035 compared to the No Project Alternative. 

Implementation of the HSR project with either the May 2014 Project or the F-B LGA would affect 

long-distance, city-to-city travel along freeways and highways throughout the state, as well as 

aircraft takeoffs and landings. Both full alignment alternatives would also affect electrical demand 

throughout the state. The VMT estimates used in the operational analysis presented in Table 

3.3-11 were based on the statewide multimodal analysis conducted for the statewide HSR 

System. The analysis was conducted for the entire section from Fresno to Bakersfield and is 

representative of all alignment alternatives, including the May 2014 Project and the F-B LGA, as 

all alternatives would be expected to have similar regional effects with regard to changes in VMT 

patterns, flight patterns, and power use estimates. 

Table 3.3-11 Summary of Estimated 2035 Emission Burden Changes (Project versus No 

Project 2035) (tons/year) 

Project Element VOC CO NOx SO2 PM10 PM2.5

Roadways -420 to -280 -10,295.42 to -6,864 -958 to -638 -54 to -36 -586 to -391 -245 to -163

Planes -124 to -83 -1,677 to -1,124 -1,324 to -887 -159 to -106 -24 to -16 -24 to -16

Energy (power 

plants)

61 to 40 616 to 411 468 to 312 52 to 35 88 to 59 81 to 54

Total -483 to -323 -11,356 to -7,576 -1,814 to -1,214 -160 to -107 -522 to -348 -188 to -125

Source: Authority and FRA, 2017 

Totals may not add up exactly due to rounding. 

Operational emissions reflect refined energy usage estimates for the HSR System, which resulted in lower energy requirements and also reflected 

updated speed correlations between the No Build and Build 50% scenarios. 

CO = carbon monoxide 

HSR = high-speed rail 

NOx = nitrogen oxide 

PM10 = particulate matter smaller than or equal to 10 microns in diameter 

PM2.5 = particulate matter smaller than or equal to 2.5 microns in diameter 

SO2 = sulfur dioxide 

VOC = volatile organic compound 

Implementation of the HSR project is predicted to have a beneficial effect on (i.e., reduce) 

statewide emissions of applicable pollutants. Implementation of the HSR project would be 

expected to have similar changes in VMT and intrastate air travel, as well as similar increases in 

electrical demand (required to power the HSR System) with the F-B LGA alternative or the May 

2014 Project alternative. Therefore, implementation of the HSR project with either the F-B LGA or 

the May 2014 Project would have a beneficial effect on (i.e., reduce) statewide emissions of all 

applicable pollutants, as compared to the no project conditions. 

In the Existing Plus Project scenario versus Existing Conditions scenario, the project is also 

predicted to have a beneficial effect on (i.e., reduce) statewide emissions of all applicable 

pollutants, compared to the existing conditions scenario (Table 3.3-12). Details of the Existing 

Condition Plus Project analysis are presented in the Fresno to Bakersfield Section: Air Quality 

Technical Report (Authority and FRA 2014). 
Section 3.3 Air Quality and Global Climate Change 

California High-Speed Rail Authority November 2017 

Fresno to Bakersfield Section Page | 3.3-35

Draft Supplemental EIR/EIS 

Table 3.3-12 Summary of Estimated 2009 Statewide Emission Burden Changes (Existing 

Plus Project versus Existing Conditions – 2009) (tons/year) 

Project Element VOC CO NOx SO2 PM10 PM2.5

Roadways -1,458 to -970 -31,267 to -20,813 -3,444 to -2,292 -39 to -26 -444 to -296 -195 to -130

Planes -72 to -48 -973 to -652 -768 to -514 -92 to -62 -14 to -9 -14 to -9

Energy (power 

plants)

61 to 40 616 to 411 468 to 312 52 to 35 88 to 59 81 to 54

Total -1,469 to -978 -31,624 to -21,053 -3,744 to -2,495 -79 to -53 -370 to -246 -127 to -85

Source: Authority and FRA, 2017 

Totals may not add up exactly due to rounding. 

Operational emissions reflect refined energy usage estimates for the HSR System, which resulted in lower energy requirements and also reflected 

updated speed correlations between the No Build and Build 50% scenarios. 

CO = carbon monoxide 

HSR = high-speed rail 

NOx = nitrogen oxide 

PM10 = particulate matter smaller than or equal to 10 microns in diameter 

PM2.5 = particulate matter smaller than or equal to 2.5 microns in diameter 

SO2 = sulfur dioxide 

VOC = volatile organic compound 

Impact AQ #10—Regional Criteria Pollutant Emissions 

A summary of the total emission changes due to HSR System operation is included in Table 

3.3-13. The F-B LGA would result in similar estimates in terms of ridership, regional vehicle 

travel, aircraft, and power plants, and direct project operational emissions from HSR stations, 

maintenance facilities, and train movements. As noted above, the VMT, aircraft, and power plant 

demands were estimated based on a statewide assessment of the HSR System. VMT estimates, 

aircraft takeoff and landing estimates, and the electrical demand associated with the Fresno to 

Bakersfield Section of the statewide analysis are applicable to both the May 2014 Project and the 

F-B LGA, as the F-B Project would have the same operational emission estimates under the May 

2014 Project and the F-B LGA as ridership would be the same for both options. Therefore, 

operational emissions estimates would be similar to those identified in the Fresno to Bakersfield 

Section: Air Quality Technical Report (Authority and FRA 2014a). The total emission changes are 

shown in Table 3.3-13. Emission results indicate the project would result in a net regional 

decrease in emissions of criteria pollutants. These decreases would be beneficial to the SJVAB 

and help the basin meet its attainment goals for O3 and particulates (PM10 and PM2.5). 

Table 3.3-13 Summary of Regional Changes in Operational Emissions in (Project versus 

No Project 2035) (tons/year) 

Activities VOC CO NOx SO2 PM10 PM2.5

Indirect Emissions

Changes in VMT emissions -100.9 to

-67.28

-2,539.9 to -

1,693.02

-243.4 to 

-162.21

-13.7 to -

9.14

-149.7 to -

99.81

-62.1 to

-41.40

Changes in airport emissions -2.3 to 

-1.5

-31 to -21 -24 to -16 -2.9 to -1.9 -0.44 to 

-0.29

-0.43 to 

-0.29

Changes in power plant emissions 8.5 to 5.7 86.3 to 57.6 65.5 to 

43.7

7.3 to 4.9 12.4 to 8.3 11.4 to 8.0

Direct Emissions

Station operation 2.2 144 15.2 0.8 10.7 4.5

HMF/MOIF onsite emissionsd 0.56 9.0 3.5 0.47 0.13 0.12
Section 3.3 Air Quality and Global Climate Change 

November 2017 California High-Speed Rail Authority 

3.3-36 | Page Fresno to Bakersfield Section 

Draft Supplemental EIR/EIS 

Activities VOC CO NOx SO2 PM10 PM2.5

HMF/MOIF offsite mobile source 

emissionsd

0.24 12 1.8 0.07 1.02 0.44

Maintenance-of-way facility offsite 

emissions

0.06 4 0.4 0.02 0.30 0.13

HSR operations (fugitive dust) N/A N/A N/A N/A 29 4.3

Totala-92 to-60 -2,315 to -

1,486

-181 to -

114

-7.9 to -4.8 -97 to -51 -42 to -24

SJVAPCD significance thresholds 10 N/A 10 N/A 15 15

Exceeds SJVAPCD CEQA 

thresholds?b

No N/A No N/A No No

GC thresholdsc 10 100 10 100 100 100

Exceeds GC thresholds? No No No No No No

Source: Authority and FRA, 2017 

a The total includes the indirect and direct emissions. 

b The SJVAPCD has significance thresholds for NOx and VOC. The district currently does not have thresholds for CO or PM2.5. Section 3.3.11 of 

the Fresno to Bakersfield EIR/EIS summarizes the CEQA significance for these pollutants. 

c The GC thresholds for criteria pollutants are based on the SJVAB federal attainment status. The SJVAB is considered an extreme nonattainment 

area for the O3 NAAQS, is a nonattainment area for PM2.5, and is a maintenance area for the CO NAAQS (Fresno and Bakersfield urbanized 

areas only) and PM10 NAAQS. 

d

 The LGA Alternative does not include construction of an HMF facility. 

CEQA = California Environmental Quality Act 

CO = carbon monoxide 

GC = general conformity 

HMF = heavy maintenance facility 

HSR = high-speed rail 

NOx = nitrogen oxide(s) 

PM10 = particulate matter smaller than or equal to 10 microns in diameter 

PM2.5 = particulate matter smaller than or equal to 2.5 microns in diameter 

SJVAPCD = San Joaquin Valley Air Pollution Control District 

SO2 = sulfur dioxide 

VMT = vehicle mile(s) traveled 

VOC = volatile organic compound 

The Fresno to Bakersfield Section of the HSR project would result in a net benefit to regional air 

quality from operation of the HSR System under CEQA, because of the reduction of emissions in 

the region. 

Impact AQ #11—Greenhouse Gas Analysis During Operation 

Guidance for the analysis of GHG emissions is provided at the state, regional, and local levels. 

This guidance provides a comprehensive and complementary approach for the analysis of the 

potential effects of GHG emissions. Due to the global nature of GHG emissions and the nature of 

the electrical grid system, GHGs are examined on a statewide level. However, regional and local 

guidance will be considered as a component of the overall statewide goal to reduce GHG 

emissions. 

According to the SJVAPCD’s guidance document on evaluating GHG emissions, for projects to 

have a less than significant impact on an individual and cumulative basis under CEQA, the 

project must comply with an approved Climate Change Action Plan, demonstrate that it would not 

impede the state from meeting the statewide 2020 GHG emissions target, adopt the SJVAPCD’s 

Best Performance Standards for stationary sources (SJVAPCD 2009). As the F-B LGA is not a 

stationary source and there is no appropriate Climate Change Action Plan under which to 

evaluate the project, the F-B LGA would have a less than significant impact related to GHG 

emissions if the construction and operation of the F-B LGA would not impede the state from 

meeting statewide GHG emissions targets established by AB 32, SB 2, and EO B-30-15. 
Section 3.3 Air Quality and Global Climate Change 

California High-Speed Rail Authority November 2017 

Fresno to Bakersfield Section Page | 3.3-37

Draft Supplemental EIR/EIS 

The HSR project, which is included in the AB 32 Scoping Plan as Measure #T-9, would help the 

state meet the GHG emissions reduction goals established by AB 32, SB 32, and EO B-30-15 

(CARB 2008). 

Table 3.3-13 of the Fresno to Bakersfield Section Final EIR/EIS (Authority and FRA 2014a: page 

3.3-65) summarizes the changes to statewide GHG emissions (expressed in terms of CO2e) that 

would result from the project compared to 2035 no project conditions. As shown therein, the 

project would result in a net statewide GHG reduction of at least 1.7 or 2.5 MMT CO2e per year 

(based on HST ticket prices of 83 percent or 50 percent of airfare, respectively) per year 

compared to the 2035 no project condition. Table 3.3-13 of the Fresno to Bakersfield Section 

Final EIR/EIS (Authority and FRA 2014a: page 3.3-65) summarizes the changes to statewide 

GHG emissions that would result from the project compared to existing no project conditions. As 

shown therein, the project would result in a net statewide GHG reduction of 1.6 or 2.4 MMT CO2e 

per year (based on HST ticket prices of 83 percent or 50 percent of airfare, respectively) 

compared to existing no project conditions. 

Overall, the project’s operation would have a net beneficial impact on statewide GHG emissions. 

Operation of the Fresno to Bakersfield Section with the F-B LGA would result in similar estimates 

in terms of ridership, regional vehicle travel, aircraft, and power plants, and direct project 

operational emissions from HSR stations, maintenance facilities, and train movements as 

operation of the Section with the May 2014 Project. Therefore, operational GHG emissions 

estimates would be similar to those identified in the Fresno to Bakersfield Section: Air Quality 

Technical Report (Authority and FRA 2014a) and would have a net beneficial impact on statewide 

GHG emissions. Therefore, the HSR project would help the state meet the GHG emissions 

reduction goals established by AB 32, SB 32, and EO B-30-15. 

As a result, under CEQA operational air quality impacts would be beneficial because of the 

reduction in GHG emissions in the state. 

Impact AQ #12—Localized Air Quality Impacts During Train Operations 

As discussed in Section 3.3.4.6 of the Fresno to Bakersfield Section Final EIR/EIS (Authority and 

FRA 2014a: page 3.3-69 through 3.3-70), the HSR project would use EMU trains, with the power 

distributed through the overhead contact system. Direct emissions from combustion of fossil fuels 

and associated emissions from HSR trains would not occur. However, trains traveling at high 

velocities, such as those associated with the proposed HSR, create sideways turbulence and rear 

wake, which resuspend particulates from the surface surrounding the track, resulting in fugitive 

dust emissions. Using a friction velocity of 0.19 meter/second (m/s) for disturbed desert soil that 

could lead to resuspended soils, a HSR passing at 220 mph could resuspend soil particles out to 

approximately 10 feet from the train (Watson et al.1996). Therefore, all resuspended soil particles 

would remain within the HSR corridor and sensitive receptors would not be exposed to 

resuspended particulates. Impacts identified for the F-B Section of the HSR Project would be 

similar with implementation of the F-B LGA. There are no applicable fugitive dust thresholds, 

however, based on the analysis, for the F-B LGA as with the May 2014 Project, with 

implementation of the HSR Project, fugitive dust emissions due to HSR travel are not expected to 

result in substantial dust that would cause health concerns in the project vicinity. Under CEQA, 

since fugitive dust would be significantly reduced beyond the right-of-way, fugitive dust would not 

expose sensitive receptors to substantial pollutant concentrations, therefore, the health concern 

impacts from dust would be less than significant under CEQA. 

A detailed analysis of wind-induced fugitive dust emissions due to HSR travel is discussed in 

Appendix 3.3-A of the Fresno to Bakersfield Section Final EIR/EIS, Potential Impact from Induced 

Winds. 

Impact AQ #13—Localized Mobile Source Air Toxics Analysis 

As described in Section 3.3.4.6 of the Fresno to Bakersfield Section Final EIR/EIS (Authority and 

FRA 2014a: pages 3.3-70 through 3.3-71), in accordance with the FHWA’s Interim Guidance 

Update on Air Toxic Analysis in NEPA Documents (FHWA 2012), a qualitative assessment was 

derived for the project following a study conducted by FHWA entitled A Methodology for 
Section 3.3 Air Quality and Global Climate Change 

November 2017 California High-Speed Rail Authority 

3.3-38 | Page Fresno to Bakersfield Section 

Draft Supplemental EIR/EIS 

Evaluating Mobile Source Air Toxic Emissions Among Transportation Project Alternatives (FHWA 

2010). It provided the basis for identifying and comparing the potential differences in MSAT 

emissions, if any, among the May 2014 Project and the F-B LGA. 

Based on the analysis conducted in the Fresno to Bakersfield Section with the May 2014 Project 

included, there would be no difference in MSAT emissions between the May 2014 Project and the 

F-B LGA, because the regional change in vehicle emissions would be the same. The MSAT 

analysis concluded that MSAT emissions in the study area are likely to be lower in the future with 

the HSR project, including the F-B LGA and would result in a decrease in regional MSAT 

emissions compared with the No Project Alternative. Therefore, implementation of the F-B LGA 

would also not result in impacts related to regional MSAT impacts. 

Since the MSAT emissions would not increase, the MSAT impact under the F-B LGA would be 

less than significant under CEQA. 

Impact AQ #14—Microscale CO Impact Analysis 

A CO hot-spot analysis was performed for intersections that could potentially cause a localized 

CO hot-spot and for parking structures associated with implementation of the proposed F-B LGA. 

The modeled CO concentrations were combined with CO background concentrations and 

compared with the air quality standards. CO concentrations for the May 2014 Project stations are 

included in Section 3.3.6.3 of the Fresno to Bakersfield Section Final EIR/EIS (Authority and FRA 

2014a: pages 3.3-71 through 3.3-79). 

The project would not worsen traffic conditions at intersections along the alignment because the 

alignment and roadways would be grade-separated. Therefore, the CO analysis did not consider 

intersections along the alignment; instead, the analysis focused on locations near the stations 

that would experience a change in roadway structure or traffic conditions. 

The Fresno to Bakersfield Section Final EIR/EIS indicated that intersections in the project vicinity 

would not cause violations of CO NAAQS at affected intersections. The report indicated that the 

localized CO emissions from existing plus project and future plus project would not be expected 

to cause a violation of ambient air quality standards. 

To evaluate the impacts of the F-B LGA, a CO hot-spot analysis was conducted at affected 

intersections in the vicinity of the proposed F-B LGA and parking structures. The changes were 

evaluated by modeling CO concentrations at intersections in the vicinity of the proposed F-B 

LGA. The model results, as shown in Table 3.3-14, indicate that CO levels would remain below 

the CAAQS and NAAQS for all study intersections. 

Since the modeled CO concentrations would be below the CAAQS for the proposed F-B LGA, 

these impacts would be less than significant under CEQA. 

Impact AQ #15—Localized PM10/PM2.5 Hot-Spot Impact Analysis 

The F-B LGA would have similar particulate matter impacts as those identified for the May 2014 

Project. The project-related particulate matter hot-spot analysis is discussed in Section 3.3.6.3 of 

the Fresno to Bakersfield Section Final EIR/EIS (Authority and FRA 2014a: pages 3.3-79 through 

3.3-80). 

As with the May 2014 Project, the F-B LGA would not be considered a project of air quality 

concern, as defined by 40 C.F.R. 93.123(b)(1), and would not likely cause violations of 

PM10/PM2.5 NAAQS during its operation. Therefore, quantitative PM2.5 and PM10 hot-spot 

evaluations are not required. The requirements of 40 C.F.R. § 93.116 are therefore met without a 

quantitative hot-spot analysis. The HSR project would not likely cause an adverse impact on air 

quality for PM10/PM2.5 standards because, based on these criteria, it is not a project of air quality 

concern. 
Section 3.3 Air Quality and Global Climate Change 

California High-Speed Rail Authority November 2017 

Fresno to Bakersfield Section Page | 3.3-39

Draft Supplemental EIR/EIS 

Table 3.3-14 Maximum Modeled CO Concentrations at Intersections near the F-B LGA Station 

Intersection Existing Conditions1 Existing Plus Project1 2035 No Project/No Action1 2035 Project1

Max 1-Hour CO Max 8-Hour CO

Concentration Concentration 

(ppm) (ppm)2

Max 1-Hour CO Max 8-Hour CO

Concentration Concentration 

(ppm) (ppm)2

Max 1-Hour CO Max 8-Hour CO

Concentration Concentration 

(ppm) (ppm)2

Max 1-Hour CO

Concentration 

(ppm)

Max 8-Hour CO

Concentration 

(ppm)2

F-B LGAa

SR 99 SB Ramps/Olive Drive 3.8 2.5 3.9 2.6 4.2 2.7 4.2 2.8

State Road/SR

Ramps 

99 NB 3.2 2.1 3.2 2.1 2.9 1.9 2.9 1.9

State Road/Olive Drive 3.4 2.3 3.5 2.3 3.5 2.3 3.5 2.3

F Street/SR 204 3.5 2.3 2.9 1.8 4.3 2.9 3.3 2.2

F Street/30th Street 2.4 1.6 2.6 1.7 3.1 2.0 3.5 2.3

F Street/24th Street 3.3 2.2 3.4 2.3 3.9 2.6 3.9 2.6

F Street/23rd23rd Street 3.3 2.2 3.4 2.3 3.8 2.5 3.8 2.5

Chester Avenue/34th Street 2.7 1.8 2.7 1.8 2.8 1.8 2.8 1.8

Chester Avenue/32nd Street 1.9 1.2 2.6 1.7 2.8 1.8 2.7 1.8

Jewett Avenue/34th Street 2.3 1.5 2.3 1.5 2.4 1.6 2.5 1.6

San Dimas Street/34th Street 2.4 1.6 2.4 1.6 2.5 1.6 2.5 1.6

Union Avenue/19th Street 2.8 1.8 2.8 1.8 3.0 2.0 3.1 2.0

Union Avenue/SR

Ramps

58 WB 3.0 2.0 3.0 2.0 3.2 2.1 3.2 2.1

Source: Authority and FRA, 2017 

1 Concentrations include a predicted 1-hour background concentration of 1.9 ppm and an 8-hour background concentration of 1.2 ppm, representing the second-highest measured CO concentrations in 2012–2014. 

2 A persistence factor of 0.7 was used to estimate the 8-hour CO concentrations based on the generalized persistence factor for urban locations in the CO Protocol (California Department of Transportation 1997). 

CO = carbon monoxide 

Max = maximum 

NB = northbound 

ppm = part(s) per million 

SB = southbound 

SR = state route 

WB = westbound 
Section 3.3 Air Quality and Global Climate Change 

November 2017 California High-Speed Rail Authority 

3.3-40 | Page Fresno to Bakersfield Section 

Draft Supplemental EIR/EIS 

As with the May 2014 Project, as discussed in Section 3.3.6.3 of the Fresno to Bakersfield 

Section Final EIR/EIS (Authority and FRA 2014a: pages 3.3-79 through 3.3-80), implementation 

of the F-B LGA is unlikely to cause any localized adverse impact on air quality for the PM10/PM2.5 

NAAQS. Therefore, the PM10 hot-spot impact on air quality would be less than significant under 

CEQA. 

Impact AQ#16—Localized Air Quality Impacts to Sensitive Receptors Including Schools 

Localized air impacts in relation to sensitive receptors were discussed in Section 3.3.6.3 of the 

Fresno to Bakersfield Section Final EIR/EIS (Authority and FRA 2014a: page 3.3-82). As with the 

May 2014 Project, implementation of the F-B LGA would result in a reduction in annual MSAT 

emissions impacts to sensitive receptors at schools around the station (see Table 3.3-7) by 83 

percent from 2010 to 2050 due to current regulatory requirements. Emergency generators would 

be located at the station and would also be screened during the permitting phase with the 

SJVAPCD to ensure that sensitive receptors, including schools, are not exposed to 

concentrations of TACs exceeding significance thresholds. 

Therefore, as with the May 2014 Project, exposure of sensitive receptors including schools under 

the proposed F-B LGA would have a less than significant impact under CEQA. 

Impact AQ #17—Odor Impacts from Operations 

As with the May 2014 Project, odors associated with train operations, including those associated 

with the MOIF, under the F-B LGA are not anticipated. Odors associated with general operations 

are discussed in Section 3.3.6.3 of the Fresno to Bakersfield Section Final EIR/EIS (Authority and 

FRA 2014a: page 3.3-83). The project would likely not create objectionable odors. Therefore, a 

less than significant impact would occur under CEQA. 

Impact AQ #18—Compliance with Air Quality Plans 

As with the May 2014 Project, during operation of the F-B LGA, the project would reduce VMT in 

the region, which would reduce regional O3 precursor pollutant emissions Compliance with air 

quality plans would be similar among the alternatives as described in Section 3.3.6.3 of the 

Fresno to Bakersfield Section Final EIR/EIS. Implementation of the F-B LGA would not result in 

emissions that would exceed the VOC, NOX, PM10, and PM2.5 thresholds of the SJVAPCD, and 

therefore would not conflict with or impede the implementation of the respective air quality plans 

for the attainment of federal air quality standards. As shown in Table 3.3-13, the F-B LGA would 

also result in VOC, NOX, PM10, and PM2.5 emissions that would be less than applicable 

significance thresholds, and therefore would not impede implementation of the 8-Hour SJVAPCD 

2007 Ozone Plan, the 2004 Extreme Ozone 1-Hour Attainment Demonstration Plan, the 2007 

PM10 Maintenance Plan, the 2008 PM2.5 Plan, the 2012 PM2.5 Plan, and the 2015 Plan for the 

1997 PM2.5 Standard. Therefore, this impact would be less than significant under CEQA. 

3.3.6 Compliance with Conformity Rules 

Projects requiring approval or funding from federal agencies that are in areas designated as 

nonattainment or maintenance for the NAAQS are subject to the USEPA’s Conformity Rule. The 

two types of federal conformity are general conformity, which applies to the HSR project due to 

Federal Railroad Administration (FRA) funding, and transportation conformity, which does not 

apply at this time but could apply to future actions related to the project’s minor expansions or 

realignments of local roadways. 

3.3.6.1 General Conformity 

To determine whether projects are subject to the GC determination requirements, the USEPA has 

established GC threshold values (in tons per calendar year) for each of the criteria pollutants for 

each type of federally designated nonattainment and maintenance area. If the emissions 

generated by construction or operation of a project (on an area-wide basis) are less than these 

threshold values, the GC rule is not applicable, and no additional analyses are required. If the 

emissions are greater than these values, compliance with the GC rule must be demonstrated. 
Section 3.3 Air Quality and Global Climate Change 

California High-Speed Rail Authority November 2017 

Fresno to Bakersfield Section Page | 3.3-41

Draft Supplemental EIR/EIS 

GC requirements apply only to federally designated maintenance and nonattainment areas. The 

HSR project study area is in an area federally designated as extreme nonattainment for the 8-

hour O3 standard, nonattainment for PM2.5, and maintenance for PM10 and CO. The applicable

threshold values for this area, according to 40 C.F.R. 93, are 10 tons per year for VOCs, 10 tons 

per year for NOX, and 100 tons per year for PM2.5, PM10, CO, and SO2 (Table 3.3-2). 

Regional emissions for the applicable pollutants would be the same under the operational phase 

of the F-B LGA and the May 2014 project. Therefore, since the May 2014 project identified that 

the pollutants would be lower than for the No Project Alternative (see Table 3.3-13), only 

emissions generated during the construction phase need to be evaluated to determine whether 

the GC Rule is applicable. The FRA found the Fresno to Bakersfield Section of the HSR System 

with the May 2014 Project to be in conformance on June 27, 2014, and issued a conformity 

determination per its requirements. Construction of the Fresno to Bakersfield Section with the F-B 

LGA instead of the May 2014 Project, would also exceed the conformity thresholds for certain 

pollutants, however emissions would be slightly lower than those estimated for the May 2014 

Project and would be offset by Voluntary Emission Reduction Agreement (VERA). A VERA 

agreement with the SJVAPCD would be implemented to offset construction emissions. 

The project will commit to reducing construction emissions for NOx and VOC exceedance years 

to net zero through the VERA program. 

A VERA is a mitigation measure by which the project proponent (the Authority, in this case, in 

partnership with the FRA) will provide pound-for-pound offsets of emissions that exceed GC 

thresholds through a process that develops, funds, and implements emissions reduction projects, 

with the SJVAPCD serving as administrator of the emissions-reduction projects and verifier of the 

successful mitigation effort. 

To implement a VERA, the project proponent and the SJVAPCD will enter into a contractual 

agreement in which the proponent agrees to mitigate the project’s emissions (NOX and VOCs, in 

this case, in the years of exceedance) by providing funds for the SJVAPCD’s Emission Reduction 

Incentive Program to fund grants for projects that achieve emission reductions, thus offsetting 

project impacts on air quality. The SJVAPCD is obligated under the VERA to seek and implement 

such reductions using the project proponent’s funds. The types of projects that have been used in 

the past to achieve such reductions include electrification of stationary internal combustion 

engines (such as agricultural irrigations pumps); replacing old trucks with new, cleaner, more 

efficient trucks; and a host of other emissions-reducing projects. 

In implementing a VERA, the SJVAPCD verifies the actual emission reductions that have been 

achieved as a result of completed grant contracts, monitors the emission reduction projects, and 

ensures the enforceability of achieved reductions. The initial agreement is generally based on the 

projected maximum emissions that exceed thresholds as calculated by an SJVAPCD-approved 

Air Quality Impact Assessment and/or the project’s Supplemental EIR/EIS. The agreement then 

requires the proponent to deposit funds sufficient to offset those maximum emissions 

exceedances. However, because the goal is to mitigate actual emissions, the SJVAPCD has 

designed adequate flexibility into these agreements such that the final mitigation is based on 

actual emissions related to the project, actual equipment used, hours of operation, and so on, 

which the proponent tracks and reports to the SJVAPCD during construction. After the project is 

mitigated, the SJVAPCD certifies to the lead agency that the mitigation is completed. Thus, a 

VERA provides the lead agency with an enforceable mitigation measure that will result in 

emissions exceedances being fully offset. 

According to the SJVAPCD, since 2005 the SJVAPCD has entered into 29 VERAs with project 

proponents and achieved total emissions reductions of 1,700 tons of NOX, 200 tons of VOC, and 

120 tons of PM10 reductions (SJVAPCD 2016). It is the SJVAPCD’s experience that 

implementation of a VERA is a feasible mitigation measure that effectively achieves actual 

emission reductions and mitigates the project to a net-zero air quality impact.

The Authority has negotiated a VERA with the SJVAPCD for all construction package contracts. 

Additional VERAs will be negotiated for future construction packages. Final approval and 
Section 3.3 Air Quality and Global Climate Change 

November 2017 California High-Speed Rail Authority 

3.3-42 | Page Fresno to Bakersfield Section 

Draft Supplemental EIR/EIS 

execution of the VERA by the Authority and the SJVAPCD was given concurrently with the final 

approval of the GC determination. The SJVAPCD has stated that it is certain there are enough 

emission-reduction projects within its air basin to fully offset the project’s NOX and VOC 

exceedances. 

Since the modifications to the Fresno to Bakersfield Section associated with F-B LGA result in 

slightly lower construction emissions compared to those from the Fresno to Bakersfield Section 

with the May 2014 Project, the final GC determination is still valid and no reevaluation of the 

Fresno to Bakersfield Section for the F-B LGA is required. 

As with the Fresno to Bakersfield Section with the May 2014 Project alignment, the offsets will be 

accomplished through a VERA among the Authority the project proponent, and the SJVAPCD. 

The requirement for the VERA would be imposed on the project through implementation of 

Measure AQ-MM#4. 

3.3.6.2 Transportation Conformity 

Transportation conformity is an analytical process required for all federally funded highway and 

transit transportation projects, but it does not apply to this project. Under the 1990 CAA 

Amendments, the U.S. Department of Transportation cannot fund, authorize, or approve federal 

highway and transit actions that are not first found to conform to the State Implementation Plan 

for achieving the goals of the CAA requirements. Transportation conformity with the CAA takes 

place at both the regional level and the project level. 

As discussed in Section 3.3.7.2 of the Fresno to Bakersfield Section Final EIR/EIS (page 3.3-85), 

the Fresno to Bakersfield Section of the HSR project, including the F-B LGA, is not subject to the 

transportation conformity rule. However, if the project requires future actions that meet the 

definition of a project element subject to transportation conformity, additional determinations and 

associated analysis will be completed as may be required. 

3.3.7 Impact Avoidance and Minimization Measures 

The Authority and FRA have considered avoidance and minimization measures. Measures 

considered to be part of the project are summarized in Section 3.3.8 of the Fresno to Bakersfield 

Section Final EIR/EIS (Authority and FRA 2014a: pages 3.3-85 and 3.3-86). The applicable list is 

provided in Technical Appendix 2-G, Mitigation Monitoring and Enforcement Plan. Technical 

Appendix 2-H describes how implementation of these measures reduces adverse effects on air 

quality. The following Avoidance and Minimization Measures would be applicable to the May 

2014 Project as well as the F-B LGA: 

 AQ-AM #1 Truck Equipment: Covering and washing of trucks and construction equipment

to reduce fugitive dust.

 AQ-AM #2 Fugitive Dust Emissions: Best management practices implemented to reduce

fugitive dust emissions.

 AQ-AM #3 Trackouts: Implementation of entrance/exit trackouts that result in vibration and

removal of dirt and dust on trucks and construction equipment so as to not track out onto

public roadways.

 AQ-AM #4 Material Selection: Low or super-compliant VOC (clean air) paints, coatings, and

industrial coatings that meet the regulatory limits in South Coast Air Quality Management

District Rule 1113 will be used.

3.3.8 Mitigation Measures 

3.3.8.1 Mitigation Measures identified in the Fresno to Bakersfield Section 

Final EIR/EIS 

Operation of the HSR project would, in general, improve air quality because of the reduction in 

regional emissions. Construction of the project, however, would temporarily increase regional 

emissions and possibly cause or exacerbate an exceedance of an air quality standard. As such, 
Section 3.3 Air Quality and Global Climate Change 

California High-Speed Rail Authority November 2017 

Fresno to Bakersfield Section Page | 3.3-43

Draft Supplemental EIR/EIS 

mitigation measures designed to minimize potential air quality impacts focus on the construction 

phase of the project. These mitigation measures would go beyond the control measures listed in 

the Fresno to Bakersfield Section Mitigation Monitoring and Enforcement Plan (Authority and FRA 

2014b) and the controls required by the SJVAPCD rules. The mitigation measures would be the 

same regardless of whether the project is compared to the existing conditions as baseline or to 

the no project conditions as baseline. None of these mitigation measures will result in adverse 

secondary effects. The mitigation measures identified in Table 3.3-15 would be applicable to the 

May 2014 Project and the F-B LGA. 

Table 3.3-15 Mitigation Measures Applicable to the F-B LGA 

Mitigation 

Measure

Description

AQ-MM#1 This mitigation measure will apply to heavy-duty construction equipment used during the 

construction phase. All off-road construction diesel equipment will use the cleanest reasonably 

available equipment (including newer equipment and/or tailpipe retrofits), but in no case less 

clean than the average fleet mix for the current calendar year, as set forth in California Air 

Resources Board’s (CARB) OFFROAD 2011 database, and no less than a 40 percent reduction 

compared to a Tier 2 engine standard for nitrogen oxides (NOX) emissions. The contractor will 

document efforts undertaken to locate newer equipment (such as, in order of priority, Tier 4, 

Tier 3, or Tier 2 equipment) and/or tailpipe retrofit equivalents. The contractor will provide 

documentation of such efforts, including correspondence with at least two construction 

equipment rental companies. A copy of each unit’s certified tier specification and any required 

CARB or San Joaquin Valley Air Pollution Control District (SJVAPCD) operating permit will be 

made available at the time of mobilization of each piece of equipment. The contractor will keep 

a written record (supported by equipment-hour meters, where available) of equipment usage 

during project construction for each piece of equipment.

AQ-MM#2 This mitigation measure applies to all on-road trucks used to haul construction materials, 

including fill, ballast, rail ties, and steel. Material-hauling trucks will consist of an average fleet 

mix of equipment model year 2010 or newer, but no less than the average fleet mix for the 

current calendar year as set forth in CARB’s Emission Factors Model 2011 database. The 

contractor will provide documentation of efforts to secure such a fleet mix. The contractor will 

keep a written record of equipment usage during project construction for each piece of 

equipment.

AQ-MM#3 Concrete batch plants would be sited at least 1,000 feet from sensitive receptors, including 

daycare centers, hospitals, senior care facilities, residences, parks, and other areas where 

people may congregate. The concrete batch plant will utilize typical control measures to reduce 

fugitive dust, such as water sprays, enclosures, hoods, curtains, shrouds, movable and 

telescoping chutes, central dust collection systems and other suitable technology, to reduce 

emissions to be equivalent to the U.S. Environmental Protection Agency (USEPA) AP-42 

controlled emission factors for concrete batch plants.

AQ-MM#4 The California High-Speed Rail Authority (Authority) and SJVAPCD will enter into a contractual 

agreement to mitigate the project’s emissions (by offsetting) to net zero the project’s actual 

emissions from construction equipment and vehicle exhaust emissions of volatile organic

compounds (VOC), NOX, particulate matter smaller than or equal to 10 microns in diameter 

(PM10), and particulate matter smaller than or equal to 2.5 microns in diameter (PM2.5). The 

agreement will provide funds for the SJVAPCD’s Emission Reduction Incentive Programa

(SJVAPCD 2011) to fund grants for projects that achieve emission reductions, with preference 

given to highly impacted communities, thus offsetting project impacts on air quality. Projects 

funded in the past include electrification of stationary internal combustion engines (such as 

agricultural irrigation pumps); replacement of old heavy-duty trucks with new, cleaner, more 

efficient heavy-duty trucks; and replacement of old farm tractors. The project will commit to 

reducing construction emissions for NOX and VOC through the Voluntary Emission Reduction 

Agreement (VERA) program. To lower overall cost, funding for the VERA program to cover 
Section 3.3 Air Quality and Global Climate Change 

November 2017 California High-Speed Rail Authority 

3.3-44 | Page Fresno to Bakersfield Section 

Draft Supplemental EIR/EIS 

Mitigation 

Measure

Description

estimated construction emissions for any funded construction phase will be provided at the 

beginning of the construction phase, if feasible. At a minimum, funding shall be provided so that 

mitigation/offsets will occur in the year of impact, or as otherwise permitted by 40 C.F.R. Part 93 

Section 93.163.

AQ-MM#5 This mitigation measure will apply if ballast material is hauled from quarries outside the San 

Joaquin Valley Air Basin (SJVAB) and the hauling activities result in the exceedance of 

applicable annual General Conformity (GC) threshold(s) or local air basin California 

Environmental Quality Act (CEQA) threshold(s) for NOX. To determine whether an exceedance 

will occur based on actual hauling activities, the Authority shall at the beginning of each 

calendar year, or as soon as practicable thereafter, (1) obtain the most up-to-date information 

based on actual or projected contractor-specific information about hauling in the Mojave Desert 

Air Quality Management District (AQMD), South Coast AQMD, and Bay Area AQMD; and (2) 

calculate the expected NOX emissions from hauling activities in those districts using the same 

methodology used in this F-B LGA Draft Supplemental Environmental Impact 

Report/Environmental Impact Statement (EIR/EIS). The analysis methodology shall specify the 

location, the year in which the emissions would be released, and the quantity of emissions. If, 

based on that calculation, exceedance of the applicable NOX threshold(s) is anticipated to occur 

in that next calendar year, the Authority will secure from the appropriate air district(s) or other 

appropriate source the production or generation of a sufficient quantity of NOX offsets for that 

calendar year necessary to achieve conformity (in the case of exceedance of GC thresholds) 

and/or to offset NOX emissions below the applicable CEQA threshold(s). At a minimum, 

mitigation/offsets will occur in the year of impact, or as otherwise permitted by Code of Federal 

Regulations (C.F.R.) Title 40, Part 93, Section 93.163.

The Mojave Desert AQMD’s emission bank has 3,274 tons of NOX credits (Mojave Desert 

AQMD 2016); therefore, there should be enough NOX credits to offset approximately 6 tons per 

year from this project in the Mojave Desert Air Basin. The exact number of NOX credits in the 

South Coast AQMD RECLAIM program is unknown, but 810.5 tons of NOX credits were traded 

in 2015 and 43.3 tons of NOX credits were traded in 2012 (South Coast AQMD 2016). 

Therefore, there should be enough available NOX credits in the program to offset approximately 

75 tons of NOX per year from this project in the South Coast AQMD.

In the Bay Area AQMD, any material emissions above the district’s significance threshold will 

be mitigated through an off-site emission mitigation program to achieve emission reduction due 

to material hauling in the Bay Area AQMD. Potential off-site mitigation programs include the 

Bay Area AQMD’s Carl Moyer Memorial Air Quality Standards Attainment Program (CMP) or 

other air district emission reduction incentive programs. Depending on the final location 

selected to obtain ballast material, this would amount to a maximum of 3 tons per year of NOX

credits.

AQ-MM#6 This mitigation measure will apply to heavy maintenance facility(HMF)b

/maintenance of 

infrastructure facility (MOIF) operation for all site options to ensure that the nearest sensitive 

receptor has a health risk less than the applicable threshold of 10 in 1 million cancer risk and a 

hazard index of 1, with final decisions on the range of mitigation measures to achieve emission

reductions to meet this standard to be selected before the issuance of the Authority to construct 

permit for the HMF/MOIF. These measures may include the following options:

• Use of electric or hybrid trucks to serve the facility.

• Use of an electric or clean switcher locomotive to minimize the emissions from HMF

operation.

• When advertising for a train set vendor, a preference for the use of highly polished external

manufactured aluminum for train sets will be stated in the proposal.

• Adjustment of the facility operation and orientation to move emission activities to areas

where impacts on the surrounding sensitive areas are lessened, thus reducing localized

impacts on surrounding sensitive receptors.
Section 3.3 Air Quality and Global Climate Change 

California High-Speed Rail Authority November 2017 

Fresno to Bakersfield Section Page | 3.3-45

Draft Supplemental EIR/EIS 

Mitigation 

Measure

Description

• A minimum buffer distance of 1,300 feet from sensitive receptors for diesel vehicles,

limitations on idling of diesel vehicles at the facility, or preparation of a detailed health risk

assessment that shows cancer risk to be less than 10 in 1 million when the site design is

refined.

F-B LGA = Fresno to Bakersfield Locally Generated Alternative 

a San Joaquin Valley Air Pollution Control District, “Grants and Incentives,” Website: www.valleyair.org/Grants. 

b It should be noted that the F-B LGA does not include the development of a heavy maintenance facility site. 

Mitigation Measure AQ-MM#1 addresses criteria exhaust emissions from construction equipment. 

The methodologies used to reduce emissions may result in increased fuel or energy consumption 

associated with emissions control equipment. The change in fuel consumption would likely be 

small on a per-equipment basis; however, given the number of equipment pieces and the 

construction duration, the total fuel consumption would result in a moderate increase in volume, 

but still a small percentage of the total volume. If aftermarket control devices are used, such as 

diesel particulate filters, additional waste would be generated associated with the disposal of 

spent filters. These additional increases would be small in comparison to the scope of the project. 

Therefore, the impacts of mitigation would be less than significant under CEQA. 

Implementation of Mitigation Measure AQ-MM#2 would have no impacts. 

Mitigation Measure AQ-MM#3 would reduce potential impacts from concrete batch plants. The 

control measures utilized at the batch plant may increase water usage and energy consumption 

and may generate additional waste from consumables used by the control devices. These 

impacts would be minor in comparison to the project operations as a whole. Therefore, the 

impacts of mitigation would be less than significant under CEQA. 

With AQ-MM#1 and AQ-MM#2, regional construction phase emissions of NOX, VOCs, PM10, and 

PM2.5 for certain years could still be greater than applicable thresholds. As such, construction 

phase emissions would be offset per AQ-MM#4. 

Mitigation Measure AQ-MM#4 would require offset project construction emissions through an 

SJVAPCD VERA agreement. The methodologies used to reduce emissions may result in 

increased fuel or energy consumption associated with emissions control equipment. However, it 

is also possible that fuel and energy consumption may decrease. The change in fuel consumption 

would likely be small on a per-equipment basis. If aftermarket control devices are used, such as 

diesel particulate filters, additional waste would be generated associated with disposal of spent 

filters. In comparison to the scope of the project, these additional increases would be small. 

Therefore, the impacts of mitigation would be less than significant under CEQA. 

Mitigation Measure AQ-MM#5 would require the purchase of offset and off-site emission 

mitigation for emissions associated with hauling ballast material. This mitigation measure would 

have no impacts. 

Mitigation Measure AQ-MM#6 is an operational phase measure that would be implemented to 

reduce emissions from heavy maintenance facility/maintenance of infrastructure facility 

(HMF/MOIF) operations. The methodologies used to reduce emissions may result in increased 

fuel or energy consumption associated with emissions control equipment. However, it is also 

possible that fuel and energy consumption may decrease. The change in fuel consumption would 

likely be small on a per-equipment basis. Consumables used by the emissions control equipment 

could result in additional waste that would be generated from disposal of spent consumables. 

Some emissions control equipment may require water, which may result in increased water 

consumption and may increase the amount of water that needs treatment. This increase in water 

consumption and water treatment will be incorporated into the design assumptions and therefore 

will be addressed, resulting in a small impact. Some emissions control equipment may require 

additional hazardous chemicals to be used and stored on-site. However, any hazardous 

chemicals would be subject to applicable hazard control plans and therefore are unlikely to be a 
Section 3.3 Air Quality and Global Climate Change 

November 2017 California High-Speed Rail Authority 

3.3-46 | Page Fresno to Bakersfield Section 

Draft Supplemental EIR/EIS 

significant concern compared to material that may already be used at the facility. These additional 

increases would be small in comparison to the scope of the project. Therefore, the impacts of 

mitigation would be less than significant under CEQA. PM10, PM2.5, CO, and SO2 emissions 

would be below the GC threshold with the application of mitigation measures and control 

measures for all years. 

Material hauling outside the SJVAB would have impacts of substantial intensity in the South 

Coast Air Basin, Mojave Desert Air Basin, and Salton Sea Air Basin.1

 Mitigation Measures AQMM#2 and AQ-MM#5 would be implemented to reduce NOX impacts in these air basins. 

Similar to the May 2014 Project, the F-B LGA would result in NOX emissions that would exceed 

the SJVAPCD CEQA significance thresholds for most of the construction phase, while VOC, 

PM10, and PM2.5 emissions would exceed the SJVAPCD CEQA significance thresholds for some 

of the construction phase. Therefore, the project may violate an air quality standard and/or 

contribute substantially to an existing or projected air quality violation for NOX, VOC, PM10, and 

PM2.5. As such, the project has the potential to result in a significant impact under CEQA. Air 

dispersion modeling showed that the incremental increase in PM10 and PM2.5 concentrations is 

less than the applicable threshold to exacerbate the existing exceedances of the ambient air 

quality standards and would be considered less than significant after mitigation of the concrete 

batch plant (AQ-MM#3). These emissions would only last through the project construction period 

and would be offset through the VERA program (AQ-MM#4). The project would result in reduction 

in VOC, NOX, PM10, and PM2.5 emissions throughout the operational phase. After mitigation, 

these impacts would be less than significant under CEQA. 

There is no SO2 threshold from the SJVAPCD CEQA guidance. However, using air dispersion 

modeling for construction work areas, SO2 impacts were shown to be less than the ambient air 

quality standards and would be less than significant. No CO hot-spots are expected to occur 

during project construction, as demonstrated by the absence of exceedances of ambient air 

quality standards for CO at the construction work areas modeled. CO impacts are expected to be 

less than significant under CEQA. 

Material hauling in the South Coast AQMD Bay Area AQMD, and Mojave Desert AQMD would 

have significant impacts under CEQA for NOX. Mitigation Measure AQ-MM#5 would be 

implemented to reduce NOX emissions in these regions (as described in Section 3.3.9 of the 

Fresno to Bakersfield Section Final EIR/EIS, Mitigation Measures; Authority and FRA 2014a: 

pages 3.3-86 through 3.3-92). The CEQA impacts after reducing on-road truck exhaust, 

purchasing NOX offsets, and implementing off-site mitigation programs would reduce the material 

hauling emissions to less than significant. 

The localized air quality impacts near construction work areas were evaluated through an 

ambient air quality analysis and a health risk assessment. After mitigation, the localized impacts 

would be below the applicable significance thresholds. Therefore, the localized impacts due to 

construction would be less than significant after mitigation under CEQA. 

3.3.8.2 Mitigation Measures Specific to the F-B LGA 

There are no additional measures specific to the F-B LGA. All measures identified in the May 

2014 Project would be applicable to the F-B LGA, and would reduce all impacts to a less than 

significant level under CEQA. 

1

 Both the South Coast and Salton Sea air basins are under the jurisdiction of the South Coast AQMD. Therefore, NOX

credits would be purchased from the South Coast AQMD RECLAIM program.