California High-Speed Rail Authority

Bakersfield to 

Palmdale Project 

Section 

Draft General 

Conformity 

Determination

March 2021 
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TABLE OF CONTENTS

ACRONYMS AND ABBREVIATIONS.............................................................................. v 

EXECUTIVE SUMMARY...........................................................................................ES-1 

1 INTRODUCTION...................................................................................................1-1

1.1 Regulatory Status of Study Area .................................................................1-1

1.2 General Conformity Requirements ..............................................................1-3

2 DESCRIPTION OF THE FEDERAL ACTION REQUIRING CONFORMITY 

EVALUATION........................................................................................................2-1

3 CALIFORNIA HIGH SPEED RAIL PROJECT........................................................3-1

3.1 California High Speed Rail System..............................................................3-1

3.2 California High Speed Rail System – Bakersfield to Palmdale Section........3-1

4 AIR QUALITY CONDITIONS IN THE STUDY AREA.............................................4-1

4.1 Meteorology and Climate ............................................................................4-1

4.1.1 San Joaquin Valley Air Basin........................................................4-1

4.1.2 Mojave Desert Air Basin ...............................................................4-1

4.2 Ambient Air Quality in the Study Area .........................................................4-1

4.3 Study Area Emissions .................................................................................4-6

4.3.1 San Joaquin Valley Air Pollution Control District ...........................4-6

4.3.2 Eastern Kern County Air Pollution Control District.........................4-7

4.3.3 Antelope Valley Air Quality Monitoring District ..............................4-8

4.4 Action Study Area Designations ..................................................................4-9

5 RELATIONSHIP TO NEPA....................................................................................5-1

6 AVOIDANCE AND MITIGATION MEASURES TO REDUCE EMISSIONS 

TO BE INCORPORATED IN THE ACTION ...........................................................6-1

7 REGULATORY PROCEDURES ............................................................................7-1

7.1 Use of Latest Planning Assumptions...........................................................7-1

7.2 Use of Latest Emission Estimation Techniques...........................................7-1

7.3 Major Construction-Phase Activities............................................................7-2

7.4 Emission Scenarios.....................................................................................7-2

8 APPLICABILITY ANALYSIS..................................................................................8-1

8.1 Attainment Status of Action Area.................................................................8-1

8.1.1 Attainment Status: San Joaquin Valley Air Basin ..........................8-1

8.1.2 Attainment Status: Antelope Valley Air Quality Management 

District ..........................................................................................8-1

8.1.3 Attainment Status: Eastern Kern Air Pollution Control District.......8-1

9 CONSTRUCTION ACTIVITIES CONSIDERED.....................................................9-1

9.1 Site Preparation ..........................................................................................9-2

9.1.1 Demolition.....................................................................................9-2

9.1.2 Land Grubbing..............................................................................9-2

9.2 Earth Moving...............................................................................................9-2

9.3 HSR Alignment Construction.......................................................................9-2

9.3.1 Rail Type and Alignment Alternatives ...........................................9-3

9.3.2 Concrete Batch Plants ..................................................................9-3

9.3.3 Material Hauling............................................................................9-3

9.4 Train Station Construction...........................................................................9-3
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9.5 Maintenance Facilities Construction ........................................................... 9-4

9.6 Roadway Crossing Construction................................................................. 9-4

10 ESTIMATED EMISSIONS RATES AND COMPARISON TO DE MINIMIS 

THRESHOLDS – BAKERSFIELD-PALMDALE ...................................................10-1

10.1 Construction Impacts within the SJVAPCD...............................................10-1

10.2 Construction Impacts within the EKAPCD.................................................10-2

10.3 Construction Impacts within the AVAQMD................................................10-3

11 REGIONAL EFFECTS ........................................................................................11-1

11.1 Construction Impacts within the SJVAPCD...............................................11-1

11.2 Construction Impacts within the EKAPCD.................................................11-1

11.3 Construction Impacts within the AVAQMD................................................11-1

12 GENERAL CONFORMITY EVALUATION...........................................................12-1

12.1 Conformity Requirements of Proposed Action ..........................................12-1

12.2 Compliance with Conformity Requirements ..............................................12-1

12.3 Consistency with Requirements and Milestones in Applicable SIP ........... 12-2

12.3.1 Applicable Requirements from USEPA.......................................12-2

12.3.2 Applicable Requirements from CARB.........................................12-2

12.3.3 Applicable Requirements from SJVAPCD ..................................12-2

12.3.4 Applicable Requirements from EKAPCD....................................12-2

12.3.5 Applicable Requirements from AVAQMD ...................................12-2

12.3.6 Consistency with Applicable Requirements for the Authority ...... 12-3

13 ESTIMATED EMISSION RATES AND COMPARISON TO DE MINIMIS 

THRESHOLDS – CUMULATIVE ANALYSIS.......................................................13-1

14 REPORTING AND PUBLIC COMMENTS...........................................................14-1

14.1 Draft General Conformity Determination...................................................14-1

15 FINDINGS AND CONCLUSIONS .......................................................................15-1

16 REFERENCES ...................................................................................................16-1

17 PREPARER QUALIFICATIONS..........................................................................17-1

Tables

Table 1 Planning Documents Relevant to Action’s Study Area..................................... 1-2

Table 2 Ambient Criterial Pollutant Concentration Data at Air Quality Monitoring 

Stations Closest to the Action................................................................................. 4-4

Table 3 Estimated Annual Average Emissions for the SJVAPCD (tons per day).......... 4-6

Table 4 Estimated Annual Average Emissions for the EKAPCD (tons per day)............ 4-7

Table 5 Estimated Annual Average Emissions for the AVAQMD (tons per day)........... 4-8

Table 6 Federal and State Attainment Status............................................................... 8-2

Table 7 Estimated Annual Average Emissions for the SJVAPCD...............................10-1

Table 8 Estimated Annual Average Emissions for the EKAPCD ................................10-2

Table 9 Estimated Annual Average Emissions for the AVAQMD................................10-4

Table 10 Estimated Annual Average Emissions for the Merced to Fresno Section..... 13-2
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Table 11 Estimated Annual Average Emissions for the Fresno to Bakersfield 

Section .................................................................................................................13-2

Table 12 Estimated Annual Average Emissions for the Merced to Palmdale

Section .................................................................................................................13-3

Figure

Figure 1 Air Quality Monitoring Stations Closest to Action ............................................4-2

Appendix

Appendix A: Draft General Conformity Determination Comments and Responses
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Acronyms and Abbreviations

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ACRONYMS AND ABBREVIATIONS

AIA air impact assessment

AQMD Air Quality Management District

Authority California High-Speed Rail Authority

AVAQMD Antelope Valley Air Quality Management District

CAA Clean Air Act

CalEEMod California Emissions Estimator Model

CARB California Air Resources Board

CCNM César E. Chávez National Monument

CEQA California Environmental Quality Act

C.F.R. Code of Federal Regulations

CO carbon monoxide

EIR Environmental Impact Report

EIS Environmental Impact Statement

EKAPCD Eastern Kern Air Pollution Control District

EMFAC2014 EMission FACtors 2014

EMMA Environmental Mitigation Management and Assessment

FRA Federal Railroad Administration

GAMAQI Guide for Assessing and Mitigating Air Quality Impacts 

GHG greenhouse gas

HP horsepower

HS hydrogen sulfide

HSIPR High-Speed Intercity Passenger Rail

HSR high-speed rail

IAMFs Impact Avoidance and Minimization Features

LMF Light Maintenance Facility

MDAB Mojave Desert Air Basin

MOWF Maintenance-of-Way Facility

Mph miles per hour

MPO metropolitan planning organizations

NAAQS National Ambient Air Quality Standards

O3 ozone

PM2.5 particulate matter less than 2.5 microns in diameter

PM10 particulate matter less than 10 microns in diameter

RoadMod Road Construction Emissions Model

ROD Record of Decision 
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SIP State Implementation Plan

SJVAB San Joaquin Valley Air Basin

SJVAPCD San Joaquin Valley Air Pollution Control District

SOx sulfur oxide

USEPA United States Environmental Protection Agency 

VERA Voluntary Emissions Reduction Agreement 

VHT vehicle hours traveled

VMT vehicle miles traveled
Executive Summary

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EXECUTIVE SUMMARY

The California High-Speed Rail (HSR) System will provide intercity, high-speed service on more 

than 800 miles of guideway throughout California, connecting the major population centers of 

Sacramento, the San Francisco Bay Area, the southern Central Valley, Los Angeles, the Inland 

Empire, Orange County, and San Diego. The Bakersfield to Palmdale HSR Section (“Project” or 

“Action”), which is the focus of this General Conformity Determination, is a critical link connecting 

the Merced to Fresno, and Bakersfield to Palmdale HSR sections to the Palmdale to Los Angeles 

HSR sections.1

The General Conformity Rule, as codified in Title 40 Code of Federal Regulations Part 93, 

Subpart B, establishes the process by which federal agencies determine conformance of 

proposed projects that are federally funded or require federal approval with applicable air quality 

standards. This determination must demonstrate that a Proposed Action would not cause or 

contribute to new violations of air quality standards, exacerbate existing violations, or interfere 

with timely attainment or required interim emissions reductions towards attainment. The California 

High-Speed Rail Authority (Authority), as the Action proponent, is receiving federal grant funds 

through the Federal Railroad Administration’s (FRA) High-Speed Intercity Passenger Rail 

program. The Action may also receive FRA safety approvals. Because of the federal funding and 

potential safety approvals; the Action is subject to the General Conformity Rule; and because 

construction-phase emissions (without mitigation) would exceed General Conformity emission 

thresholds, the Action is not exempt and must demonstrate conformity. 

This draft General Conformity Determination documents FRA’s finding that the Action complies 

with the General Conformity Rule and that it conforms to the purposes of the area’s approved 

State Implementation Plan and is consistent with all applicable requirements. This draft General 

Conformity Determination is being issued for public review and comment concurrent with the 

publication of the Bakersfield to Palmdale Section Final Environmental Impact 

Report/Environmental Impact Statement (EIR/EIS). Copies of the draft General Conformity 

Determination are available in hard copy in the repository locations listed in Chapter 10, Final 

EIR/EIS Distribution, of the Final EIR/EIS. This draft General Conformity Determination is based 

on the Impact Avoidance and Minimization Measures and Mitigation Measures that were 

described in Section 3.3.8 of the EIR/EIS and that will be implemented for the Action. This 

compliance is demonstrated herein as follows:

• The operation of the Action would result in a reduction of regional emissions of all applicable 

air pollutants and would not cause a localized exceedance of an air quality standard; and 

• Whereas emissions generated during the construction of the Action would exceed General 

Conformity thresholds for two pollutants, these emission increases would be offset through a 

Voluntary Emission Reduction Agreement (VERA) with the San Joaquin Valley Air Pollution 

Control District (SJVAPCD), the Air Quality Investment Program in the Antelope Valley Air 

Quality Management District (AVAQMD), and the Emission Banking Certificate Program in 

the Eastern Kern Air Pollution Control District (EKAPCD). 

 

1 As part of its first phase, the California HSR system is currently planned as seven distinct sections from San Francisco in 

the north to Los Angeles and Anaheim in the south.
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Section 1 Introduction

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1 INTRODUCTION

This document is the draft General Conformity Determination for the Bakersfield to Palmdale

Section of the California High-Speed Rail (HSR) System (“Project” or “Federal Action”) and is 

required by the implementing regulations of Section 176 of the Clean Air Act (CAA). Section 

176(c)(1) of the CAA prohibits federal agencies from engaging in, supporting, or providing 

financial assistance for licensing, permitting or approving any activities that do not conform to an 

approved CAA implementation plan. That approved plan may be a federal, state or tribal 

implementation plan.

The CAA defines nonattainment areas as geographic regions that have been designated as not 

meeting one or more of the National Ambient Air Quality Standards (NAAQS). The CAA requires 

that each state prepare a State Implementation Plan (SIP) for each nonattainment area, and a 

maintenance plan be prepared for each former non-attainment area that subsequently 

demonstrated compliance with the standards. The SIP is a state’s plan for how it will meet the 

NAAQS by the deadlines established by the CAA.

The General Conformity Rule is codified in Title 40 Code of Federal Regulations (C.F.R.) Part 93, 

Subpart B, “Determining Conformity of General Federal Actions to State or Federal 

Implementation Plans.” Conformity is defined as “upholding an implementation plan’s purpose of 

eliminating or reducing the severity and number of violations of the NAAQS and achieving 

expeditious attainment of such standards.” 40 C.F.R. Part 93 also establishes the process by 

which federal agencies determine conformance of proposed projects that are federally funded or 

require federal approval. This determination must demonstrate that the Proposed Action would 

not cause or contribute to new violations of air quality standards, exacerbate existing violations, 

or interfere with timely attainment or required interim emissions reductions towards attainment. 

Since the Action is receiving federal funds through grants with the Federal Railroad 

Administration (FRA) and may also receive safety approvals from FRA, it is an action that may be 

subject to the General Conformity Rule.

This draft General Conformity Determination has been issued after the release of the Bakersfield 

to Palmdale Draft Environmental Impact Report/Environmental Impact Statement (EIR/EIS), 

which complies with the National Environmental Policy Act (NEPA) and the California 

Environmental Quality Act (CEQA). Because the analysis used for the EIR/EIS also generated 

the information necessary for the General Conformity Determination, specific analysis may be 

incorporated herein by reference.

1.1 Regulatory Status of Study Area

By way of background, in addition to the regulations covering the General Conformity Rule, on 

November 24, 1993, the U.S. Environmental Protection Agency (EPA) promulgated final 

transportation conformity regulations to address transportation plans, programs, and projects 

developed, funded or approved under title 23 U.S. Code or the Federal Transit Act, 49 U.S. Code

1601 et seq. (40 C.F.R. Part 93 Subpart A). These regulations have been revised several times 

since they were first issued. While the transportation conformity regulations do not apply to this 

Action (see Section 1.2), many of the transportation planning documents developed under those 

regulations are helpful in understanding the regional air quality and planning status of the study 

area.

The Bakersfield to Palmdale Project Section passes through three air quality management 

districts and two air basins: the San Joaquin Valley Air Pollution Control District (SJVAPCD), the 

Eastern Kern Air Pollution Control District (EKAPCD), and the Antelope Valley Air Quality 

Management District (AVAQMD). The SJVAPCD and the San Joaquin Air Basin encompass the 

same area; the EKAPCD and the AVAQMD are both located within the Mojave Desert Air Basin. 

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

nonattainment or maintenance area are developed by the SJVAPCD, EKAPCD, AVAQMD, and 

the California Air Resources Board (CARB), and approved by USEPA. Table 1 lists the planning 

documents relevant to the proposed Action’s study area.
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Table 1 Planning Documents Relevant to Action’s Study Area

Type of Plan Status

San Joaquin Valley Air Pollution Control District

1-Hour Ozone (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.

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

Particulate Matter, 10 microns or 

less in diameter (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

Particulate Matter, 2.5 microns or 

less in diameter (PM2.5) Attainment 

Plan

The 2018 Plan for the 1997, 2006, and 2012 PM2.5 Standard, approved by 

the District Governing Board on November 15, 2018, will bring the San 

Joaquin Valley into attainment of the USEPA’s 1997 annual PM2.5 standard, 

2006 24-hour PM2.5 standard, and 2012 annual PM2.5 standard as 

expeditiously as practicable.4 The plan provides measures designed to 

reduce emissions such that the valley will attain the federal standards as 

soon as possible.

Carbon Monoxide (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

Eastern Kern Air Pollution Control District

2017 Ozone Attainment Plan On July 27, 2017, the EKAPCD adopted the 2017 Ozone Attainment Plan for 

the Eastern Kern County nonattainment area. The Plan demonstrates that 

the air quality improvement was achieved due to successful implementation 

of ozone control strategies contained in the region’s SIP. It also 

demonstrates that significant ozone precursor emission reductions that have 

been impacted in the region are permanent and enforceable. A maintenance 

plan is also included to ensure that the region would not experience 

exceedance. The Plan requests a redesignation in accordance with the 

Federal Clean Air Act.6 
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Type of Plan Status

Antelope Valley Air Quality Management District 

Western Mojave Desert Ozone 

Attainment Plan

The Western Mojave Desert non-attainment area, which includes the 

AVAQMD, was designated non-attainment for the NAAQS for ozone by the 

USEPA on April 15, 2004. The USEPA designated the Western Mojave 

Desert area as non-attainment area for the 8-hour ozone NAAQS. The 

AVAQMD is included in the Western Mojave Desert non-attainment area and 

has adopted state and federal attainment plans for the region within its 

jurisdiction. The 2007 Western Mojave Desert Ozone Attainment Plan 

includes the latest planning assumptions regarding population, vehicle 

activity, and industrial activity and addresses all existing and forecasted 

ozone precursor-producing activities within the Antelope Valley through the 

year 2020. The document includes updates to the necessary information to 

allow general and transportation conformity findings to be made within the 

Antelope Valley.7 

Antelope Valley Ozone Attainment 

Plan

The 2004 Antelope Valley Ozone Attainment Plan includes AVAQMD’s 

review and update of all elements of the Air Quality Management Plan that 

had been previously prepared by the South Coast Air Pollution Control 

District, when that District had jurisdiction of the Antelope Valley. The Plan 

indicates Antelope Valley will also show significant progress toward 

attainment of the CAAQS for the ozone standard. The document also 

includes the latest planning assumptions regarding population, vehicle 

activity, and industrial activity and addresses all existing and forecasted 

ozone precursor- producing activities within the Antelope Valley.8 

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, 2018 5 California Air Resources Board, 2004 6 Eastern Kern Air Pollution Control District, 2017 7 Antelope Valley Air Quality Management District, 2008 8 Antelope Valley Air Quality Management District, 2004

AVAQMD = Antelope Valley Air Quality Management District PM10 = particulate matter smaller than or equal to 10 microns in diameter

CARB = California Air Resources Board PM2.5 = particulate matter smaller than or equal to 2.5 microns in diameter

CO = carbon monoxide SJVAB = San Joaquin Valley Air Basin

EKAPCD = Eastern Kern Air Pollution Control District SJVAPCD = San Joaquin Valley Air Pollution Control District

NAAQS = National Ambient Air Quality Standards USEPA = U.S. Environmental Protection Agency 

O3 = ozone

1.2 General Conformity Requirements

On November 30, 1993, USEPA promulgated final General Conformity regulations at 40 C.F.R.

Part 93 Subpart B for all federal activities except highways and transit programs covered by 

Transportation Conformity. The regulations in Subpart B were subsequently amended in March of 

2010. The Action requires approval by FRA, and because the Action will not be funded or require 

approval(s) under Title 23 U.S. Code or the Federal Transit Act, 49 U.S. Code 1601 et seq., the 

General Conformity requirements are applicable, rather than transportation conformity. In general 

terms, unless a project is exempt under 40 C.F.R. § 93.153(c) or is not on the agency’s 

presumed–to-conform list pursuant to 40 C.F.R. § 93.153(f), a General Conformity Determination 

is required where a federal action in a nonattainment or maintenance area causes an increase in 

the total of direct and indirect emissions of the relevant criteria pollutants and precursor pollutants 

that are equal to or exceed certain de minimis rates.

The General Conformity regulations incorporate a stepwise process, beginning with an 

applicability analysis. According to USEPA’s General Conformity Guidance: Questions and 

Answers (USEPA 1994) (USEPA Guidance), before any approval is given for a federal action to 

go forward, the federal agency must apply the applicability requirements found at 40 C.F.R. § 
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93.153 to the federal action and/or determine on a pollutant-by-pollutant basis, whether a 

determination of General Conformity is required. During the applicability analysis, the federal 

agency determines the following: 

• Whether the action will occur in a nonattainment or maintenance area;

• Whether one or more of the specific exemptions apply to the action;

• Whether the federal agency has included the action on its list of presumed-to-conform 

actions;

• Whether the total direct and indirect emissions are below or above the de minimis levels; 

and/or

• Where a facility has an emissions budget approved by the State or Tribe as part of the SIP or 

TIP, the federal agency determines that the emissions from the proposed action are within 

the budget (USEPA 2010).

The USEPA Guidance states that the applicability analysis can be (but is not required to be) 

completed concurrently with any analysis required under NEPA. The applicability analysis for this 

Action is described in Section 8.0.

If through the applicability analysis process the responsible federal agency determines that the 

General Conformity regulations do not apply to the federal action, no further analysis or 

documentation is required. If, however, the General Conformity regulations do apply to the federal 

action, the responsible federal agency must conduct a conformity evaluation in accordance with 

the criteria and procedures in the implementing regulations; publish a draft determination of 

General Conformity for public review; and then publish the final determination of General 

Conformity.

To make a conformity determination, the federal agency must demonstrate conformity by one or 

more of several prescribed methods. These methods include: 

• Demonstrating that the direct and indirect emissions are specifically identified in the relevant 

implementation plan; 

• Obtaining a written statement from the entity responsible for the implementation plan that the 

total indirect and direct emissions from the action, along with other emissions in the area, will 

not exceed the total implementation plan emission budget; or

• Fully offsetting the total direct and indirect emissions by reducing emissions of the same 

pollutant in the same nonattainment or maintenance area.
Section 2 Description of the Federal Action Requiring Conformity Evaluation

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2 DESCRIPTION OF THE FEDERAL ACTION REQUIRING CONFORMITY 

EVALUATION

In accordance with applicable General Conformity regulations and guidance, when a General 

Conformity Determination is necessary, the FRA conducts a General Conformity evaluation for 

the specific federal action associated with the preferred alternative for a project or program 

(USEPA 1994), and FRA must issue a positive conformity determination before the federal action 

is approved. Each federal agency is responsible for determining conformity of those proposed 

actions over which it has jurisdiction. This draft General Conformity Determination is related only 

to those activities included in the federal action pertaining to the Action, which is the Action’s 

potential approval through a NEPA Record of Decision (ROD). The Action is described further in 

Section 3.0 below.

General Conformity requirements only apply to federal actions proposed in nonattainment areas 

(i.e., areas where one or more NAAQS are not being achieved at the time of the proposed action 

and requiring SIP provisions to demonstrate how attainment will be achieved) and in maintenance 

areas (i.e., areas recently reclassified from nonattainment to attainment and requiring SIP 

provisions to demonstrate how attainment will be maintained). 
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Section 3 California High Speed Rail Project

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3 CALIFORNIA HIGH SPEED RAIL PROJECT

3.1 California High Speed Rail System

The Authority, a state governing board formed in 1996, is responsible for planning, designing, 

constructing, and operating the HSR System. Its mandate is to develop a high-speed rail system 

connecting the state’s major population centers and coordinating with the state’s existing 

transportation network, which includes intercity rail and bus lines, regional commuter rail lines, 

urban rail and bus transit lines, highways, and airports.

The HSR System will provide intercity, high-speed service on more than 800 miles of railroad 

throughout California, connecting the major population centers of Sacramento, the San Francisco 

Bay Area, the southern Central Valley, Los Angeles, the Inland Empire, Orange County, and San 

Diego. It will use state-of-the-art, electrically powered, high-speed, steel-wheel-on-steel-rail 

technology, including contemporary safety, signaling, and automated train-control systems, with 

trains capable of operating up to 220 miles per hour (mph) over a fully grade-separated, 

dedicated guideway alignment.

FRA is responsible for oversight and regulation of railroad safety and is also charged with the 

implementation of the High-Speed Intercity Passenger Rail (HSIPR) financial assistance program. 

As part of the HSIPR Program, FRA is providing partial funding for the environmental analysis 

and documentation required under NEPA, CEQA and other related environmental laws. Pursuant 

to U.S. Code (U.S.C.) Title 23 Section 327, under the NEPA Assignment Memorandum of 

Understanding (MOU) between FRA and the State of California, effective July 23, 2019, the 

Authority is the federal lead agency for environmental reviews for all Authority Phase 1 and 

Phase 2 California HSR System projects. The FRA maintains responsibility to perform Clean Air 

Act Conformity determinations under the NEPA Assignment MOU. The Authority and the FRA 

have agreed to collaborate on the development of conformity determinations. As part of this 

collaboration, the Authority has provided the FRA this draft General Conformity Determination 

and supporting information, as well as the Authority’s proposed approach for achieving general 

conformity. The FRA will make the ultimate general conformity determination. In addition to its 

involvement in the environmental analysis and documentation, FRA is also providing partial 

funding for the final design and construction of the initial construction section of the HSR System, 

which includes activities analyzed in this draft Conformity Determination.

In April 2012, FRA and the Authority published the Final EIR/EIS for the Merced to Fresno 

Section of the HSR System. The Authority certified the EIR and adopted the project in May, while 

the FRA issued its ROD in September 2012. The Merced to Fresno Section is within the San 

Joaquin Valley Air Basin (SJVAB) and a General Conformity Determination was prepared as part 

of the environmental process to comply with the CAA. It is worth noting that the Merced to Fresno 

General Conformity Determination includes the Authority’s commitment to offset all emissions to 

net zero through a Voluntary Emissions Reduction Agreement (VERA) between the Authority and 

the SJVAPCD.

Although the Authority considers the Bakersfield to Palmdale section of the HSR System 

independent of the other HSR System sections for purposes of NEPA and CEQA analysis, 

certain construction activities within the Merced to Fresno Section, as well as within the Fresno to 

Bakersfield and San Jose to Merced Sections, may occur concurrently with Bakersfield to 

Palmdale Section construction activities. Therefore, estimates of these cumulative emissions 

within the SJVAPCD, EKAPCD, and AVAQMD have been presented in Section 13.0 of this 

document. These emissions estimates have been included in this document in the interest of the 

full disclosure of construction emissions that may occur in the SJVAPCD, EKAPCD, and 

AVAQMD from other sections of the HSR Project; each of these sections will undergo separate 

conformity determinations at a later date.

3.2 California High Speed Rail System – Bakersfield to Palmdale Section 

The purpose of the Bakersfield to Palmdale Section of the HSR System is to implement the 

California HSR System between Bakersfield and Palmdale, providing the public with electric-
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powered high-speed rail service that provides predictable and consistent travel times between 

major urban centers and connectivity to airports, mass transit systems, and the highway network 

in the south San Joaquin Valley and Mojave Desert, and to connect the northern and southern 

portions of the HSR System. 

The Bakersfield to Palmdale Section would be approximately 80 miles in length and would 

traverse valley, mountain, and high desert terrain, as well as urban, rural, and agricultural lands. 

From the north, this section would begin at the Bakersfield Station and travel south and southeast 

through the Tehachapi Mountains, then descend into the Antelope Valley where it would

terminate at the Palmdale Station in the south. This section includes a potential Light 

Maintenance Facility (LMF) and a Maintenance-of -Way Facility (MOWF) in the Lancaster area.

The Bakersfield to Palmdale Project Section would include surface, underground, and elevated 

track types with varying profiles. Surface tracks would be built on concrete or ballast material (a 

thick bed of angular rock) placed on compacted soil. To the extent practicable, fill material for the 

rail bed would be obtained from on-site excavations. Underground tracks would be in areas with 

cut slopes and retaining walls or tunnels. Although tunnels are underground and hidden from 

sight, their approaches have deep open excavations and extensive portal facilities necessary for 

maintenance and safety. Elevated tracks would be on retained fill (earth), embankments, or 

structures and would consist of cast-in-place, reinforced-concrete columns supporting the box 

girders and bridge deck. 

The EIR/EIS for the Bakersfield to Palmdale Project Section examines alignment alternatives, 

stations, LMF, and MOWF sites within the general Railway corridor. The following alternatives are 

considered: Alternative 1, Alternative 2, Alternative 3, and Alternative 5. The following stations are 

considered: the Bakersfield Station and the Palmdale Station. The EIR/EIS also considers the 

César E. Chávez National Monument Design Option (CCNM Design Option), which would result 

in only a minimal change in construction emissions due to the additional 124 feet of track required 

for the design, and the Refined CCNM Design Option, which would be anticipated to result in 

slightly higher emissions due to the additional 2,006 feet of track required for the design. Total 

emissions would be 0.028 percent higher with the CCNM Design Option. The Refined CCNM 

option would increase the length of the line by 0.45 percent and would require additional off-haul 

associated with additional earthwork activities. Emission estimates presented in this draft General 

Conformity Determination for each Bakersfield to Palmdale Project Section (B-P) Build Alternative 

would be applicable with or without the CCNM Design Option, due to rounding, and the difference 

would be within the margin of error of the model estimates. Emission estimates for each B-P 

Alternative with the Refined CCNM Design Option are identified in this draft General Conformity 

Determination. 
Section 4 Air Quality Conditions in the Study Area

California High-Speed Rail Authority March 2021

Draft General Conformity Determination Page | 4-1 

4 AIR QUALITY CONDITIONS IN THE STUDY AREA

4.1 Meteorology and Climate

Air quality is affected by both the rate and location of pollutant emissions, and by meteorological 

conditions that influence movement and dispersal of pollutants in the atmosphere. Atmospheric 

conditions, such as wind speed, wind direction, and air temperature gradients, along with local 

topography, provide the link between air pollutant emissions and local air quality levels. Elevation 

and topography can affect localized air quality. 

The Action traverses two air basins. The northern section of the Action is in the SJVAB, which 

encompasses the southern third of California’s Central Valley. The southern section of the Action

is on the western edge of the Mojave Desert Air Basin (MDAB). 

4.1.1 San Joaquin Valley Air Basin

The SJVAB is approximately 250 miles long and is shaped like a narrow bowl. The sides and 

southern boundary of the bowl are bordered by mountain ranges. The valley’s weather conditions 

include frequent temperature inversions; long, hot summers; and stagnant, foggy winters, all of 

which are conducive to the formation and retention of air pollutants (SJVAPCD 2011).

The SJVAB is typically arid in the summer months with cool temperatures and prevalent tule fog 

(i.e., a dense ground fog) in the winter and fall. The average high temperature in the summer 

months is in the mid-90s and the average low in the winter is in the high 40s. January is typically 

the wettest month of the year with an average of about 2 inches of rain. Wind direction is typically 

from the northwest with speeds around 30 mph (Western Regional Climate Center 2011).

4.1.2 Mojave Desert Air Basin

The MDAB is separated from populated valleys and coastal areas to the west by several 

mountain ranges. These valleys and coastal areas are the major source of ozone precursor 

emissions affecting ozone exceedances within the Kern County part of the Mojave Desert. 

Surrounding mountain ranges contain a limited number of passes serving as “transportation 

corridors.” Air quality in Kern County is primarily influenced by the Tehachapi Pass corridor with 

some influence through Soledad Canyon (EKAPCD 2003).

During the summer the MDAB is generally influenced by a Pacific Subtropical High cell that sits 

off the coast, inhibiting cloud formation and encouraging daytime solar heating. Most desert 

moisture arrives from infrequent warm, moist, and unstable air masses from the south. The 

MDAB averages between 3 and 7 inches of precipitation per year (from 16 to 30 days with at 

least 0.01 inch of precipitation). The MDAB is classified as a dry-hot desert climate, with portions 

classified as dry-very hot desert, to indicate at least 3 months have maximum average 

temperatures over 100.4-degrees Fahrenheit (AVAQMD 2011). Predominant surface wind flow 

patterns are southerly and westerly, transporting air pollution from the SJVAB through the 

Tehachapi Mountains and over the San Gabriel and San Bernardino Mountains (CARB 2015).

4.2 Ambient Air Quality in the Study Area

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

stations closest to the B-P Build Alternative alignments are the 43301 Division Street station in 

the City of Lancaster; the 923 Poole Street station in Mojave; and the 5558 California Avenue 

station in Bakersfield. These stations monitor NO2, O3, PM10, PM2.5, and CO. 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 SJVAPCD, the EKAPCD, and the AVAQMD because of existing industrial, 

mobile, and agricultural sources. The four monitoring station locations are shown on Figure 1. 
Section 4 Air Quality Conditions in the Study Area

March 2021 California High-Speed Rail Authority

4-2 | Page Draft General Conformity Determination 

Figure 1 Air Quality Monitoring Stations Closest to Action
Section 4 Air Quality Conditions in the Study Area

California High-Speed Rail Authority March 2021

Draft General Conformity Determination Page | 4-3 

A brief summary of the monitoring data includes the following: 

• Monitored data from 2017 through 2019 do not exceed either the state or federal standards 

for CO. The Mojave and Bakersfield stations were not monitored for CO during 2017 through 

2019; therefore, CO data from the 2000 S Union Avenue, Bakersfield, monitoring site is 

included.

• O3 values for the region exceed the state and national 8-hour O3 standards for all three 

stations for years 2017 through 2019. O3 values for the region also exceed the state 1-hour 

O3 standard for all stations for every year from 2017 through 2019 except in 2019 at the 923 

Poole Street station in Mojave. 

• The PM10 values for the region exceed the national 24-hour PM10 standard for the Lancaster 

and Mojave stations for the year 2019. The state 24-hour PM10 concentrations were 

exceeded at all stations for all years. However, the number of days over the state standard 

was not available. 

• The PM2.5 values for the region exceed the national 24-hour PM2.5 standard for the Lancaster 

station for 2018, the Bakersfield station for 2018, and the Bakersfield station for 2017 through 

2019. 

• SO2 values were not monitored at any of the three stations or the additional station at 2000 S 

Union Avenue in Bakersfield between 2017 and 2019. 

Table 2 lists the three monitoring stations nearest to the Action and ambient criteria pollutant 

concentrations for 2017, 2018, and 2019. 
Section 4 Air Quality Conditions in the Study Area

March 2021 California High-Speed Rail Authority

4-4 | Page Draft General Conformity Determination 

Table 2 Ambient Criterial Pollutant Concentration Data at Air Quality Monitoring Stations Closest to the Action

Air 

Pollutant Standard/Exceedance

43301 Division Street,

Lancaster

923 Poole Street,

Mojave

5558 California Avenue, 

Bakersfield

2017 2018 2019 2017 2018 2019 2017 2018 2019

Carbon 

Monoxide 

(CO)1

Year Coverage NM NM NM NM NM NM NM NM NM

Max. 1-hour Concentration (ppm) 1.3 1.2 1.4 1.8 1.9 1.2 1.8 1.9 1.2

Max. 8-hour Concentration (ppm) 0.9 1.0 0.9 1.2 1.3 1.0 1.2 1.3 1.0

Number of Days>Federal 1-hour Std of >35 

ppm

0 0 0 0 0 0 0 0 0 

Number of Days>Federal 8-hour Std of >9 

ppm

0 0 0 0 0 0 0 0 0 

Number of Days>California 8-hour Std of >9 

ppm

0 0 0 0 0 0 0 0 0 

Ozone (O3) Year Coverage2 98% 96% 91% 99% 99% 99% 99% 100% 98%

Max. 1-hour Concentration (ppm) 0.109 0.125 0.096 0.097 0.111 0.085 0.122 0.107 0.097

Max. 8-hour Concentration (ppm) 0.087 0.105 0.081 0.086 0.095 0.077 0.104 0.098 0.088

Number of Days>Federal 8-hour Std of 

>0.070 ppm

43 48 13 35 53 10 85 60 24

Number of Days>California 1-hour Std of 

>0.09 ppm

10 5 N/A 1 8 0 11 8 N/A

Number of Days>California 8-hour Std of 

>0.07 ppm

43 49 N/A 37 56 N/A 87 34 N/A

Nitrogen 

Dioxide 

(NO2) 

Year Coverage 87% 97% N/A NM NM NM 97% 97% N/A

Max. 1-hour Concentration (ppm) 46.5 47.6 50.0 NM NM NM 66.0 61.5 67.0

Annual Average (ppm) N/A 8 8 NM NM NM 12 12 12

Number of Days>Federal 1-hour Std of >100 

ppm

0 0 0 NM NM NM 97% 97% N/A
Section 4 Air Quality Conditions in the Study Area

California High-Speed Rail Authority March 2021

Draft General Conformity Determination Page | 4-5 

Air 

Pollutant Standard/Exceedance

43301 Division Street,

Lancaster

923 Poole Street,

Mojave

5558 California Avenue, 

Bakersfield

2017 2018 2019 2017 2018 2019 2017 2018 2019

Sulfur 

Dioxide 

(SO2) 

Year Coverage NM NM NM NM NM NM NM NM NM

Max. 24-hour Concentration (ppm) NM NM NM NM NM NM NM NM NM

Annual Average (ppm) NM NM NM NM NM NM NM NM NM

Number of Days>California 24-hour Std of 

>0.04 ppm

NM NM NM NM NM NM NM NM NM

Respirable 

Particulate 

Matter 

(PM10) 

Year Coverage NM NM NM NM NM NM 98% 95% NM

Max. 24-hour Concentration (μg/m3)3 82.4 89.3 165.0 93.4 93.1 248.0 143.6 142.0 116.0

Number of Days>Federal 24-hour Std of 

>150 μg/m3 

0 0 2 0 0 2 0 0 0 

Number of Days>California 24-hour Std of 

>50 μg/m3

NM NM NM 10 19 N/A 16 13 N/A

Annual Average3 (μg/m3) 26.3 25.2 NA 25.3 26.7 N/A 42.6 42.1 N/A

Fine 

Particulate 

Matter 

(PM2.5) 

Year Coverage 97% 99% N/A 95% 94% N/A 94% 93% N/A

Max. 24-hour Concentration (μg/m3) 26.6 40.4 13.6 26.9 39.0 19.8 101.8 95.8 59.1

State Annual Average (μg/m3) 7.3 7.2 N/A NM NM NM 15.9 15.7 N/A

Number of Days>Federal 24-hour Std of >35 

μg/m3 

0 1 0 0 2 0 28 36 N/A

Annual Average3 (μg/m3) 7.2 7.2 6.1 5.5 7.1 6.5 15.6 17.6 11.9

Sources: California Air Resources Board and U.S. Environmental Protection Agency, 2020 1 CO data for the 923 Poole Street, Mojave, and 5558 California Avenue, Bakersfield, monitoring sites are from the 2000 S Union Avenue, Bakersfield, monitoring site. 2 Coverage is for the 8-hour standard. 3 Coverage is for the national standard. 

> = greater than

μg/m3 = micrograms per cubic meter PM2.5 = particulate matter smaller than or equal to 2.5 microns in diameter

N/A = not available ppm = parts per million

NM = not monitored Std = standard

PM10 = particulate matter smaller than or equal to 10 microns in diameter
Section 4 Air Quality Conditions in the Study Area

March 2021 California High-Speed Rail Authority

4-6 | Page Draft General Conformity Determination 

4.3 Study Area Emissions

4.3.1 San Joaquin Valley Air Pollution Control District

CARB maintains an annual emission inventory for select counties and air basins in the state. The 

inventory for the SJVAB comprises of data submitted to CARB by the SJVAPCD plus estimates 

for certain source categories, which are provided by CARB staff. The 2012 inventory data (the 

most recent data provided by the CARB) for the SJVAB is summarized in Table 3. Note that 

Table 3 shows tons per day, while the emissions estimates for the Proposed Action are shown in 

tons per year. 

Table 3 Estimated Annual Average Emissions for the SJVAPCD (tons per day) 

Source Category TOG ROG CO NOX SOX

Particulate 

Matter PM10 PM2.5

Stationary Sources

Fuel Combustion 18.82 3.60 23.76 29.17 4.30 6.0 5.53 5.31

Waste Disposal 457.38 20.98 0.5 0.29 0.12 0.56 0.15 0.11

Cleaning and Surface Coatings 23.34 20.31 0.01 0.0 0.0 0.1 0.1 0.1

Petroleum Production and 

Marketing

130.88 33.59 0.61 0.27 0.14 0.23 0.16 0.15

Total Industrial Processes 16.72 15.68 0.83 6.71 3.36 16.54 8.03 3.16

Total Stationary Sources 647.15 94.16 25.70 36.44 7.92 23.44 13.97 8.82

Stationary Sources Percentage 

of Total

36.7 26.3 2.8 11.2 76.2 4.4 5.0 11.7

Areawide Sources

Solvent Evaporation 53.11 47.59 -- -- -- -- -- --

Miscellaneous Processes 969.01 128.58 186.76 13.25 1.27 488.35 250.24 59.99

Total Areawide Sources 1,022.12 176.16 186.76 13.25 1.27 488.35 250.24 59.99

Areawide Sources Percentage 

of Total

57.9 49.2 20.6 4.0 12.2 92.4 88.9 71.4

Mobile Sources

On-Road Motor Vehicles 53.22 48.51 437.65 177.87 0.67 10.78 10.77 6.73

Other Mobile Sources 41.62 39.02 252.45 97.60 0.53 5.89 6.61 6.09

Total Mobile Sources 94.84 87.53 690.10 275.47 1.20 16.66 17.38 12.81

Mobile Sources Percentage of 

Total

5.4 24.4 76.5 84.7 11.5 3.2 6.2 16.9

Grand Total 1,764.1 357.9 902.6 325.2 10.4 528.5 281.6 75.6

Source: California Air Resources Board, 2015

CO = carbon monoxide ROG = reactive organic gas

NOX = nitrogen oxides SOX = sulfur oxides 

PM2.5 = particulate matter smaller than or equal to 2.5 microns in diameter TOG = total organic gas

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

In the SJVAPCD, mobile source emissions account for over 65 percent of the basin's ROG and 

NOx emission inventory. Area sources account for over 90 percent and over 50 percent of the 

basin’s particulate and total VOC emissions, respectively, and stationary sources account for over 

75 percent of the basin’s sulfur oxide (SOx) emissions. 
Section 4 Air Quality Conditions in the Study Area

California High-Speed Rail Authority March 2021

Draft General Conformity Determination Page | 4-7 

4.3.2 Eastern Kern County Air Pollution Control District

Emission inventory data for the EKAPCD for 2012 (the most recent data the CARB provides) is 

summarized in Table 4. In the EKAPCD, mobile source emissions account for more than 74 

percent of the ROG and 56 percent of the NOx emission inventory. Area sources made up more 

than 64 percent of the particulate emissions, where stationary sources made up 88 percent of 

SOx emissions. Note that Table 4 shows tons per day, whereas the emissions estimates for the 

Proposed Action are shown in tons per year.

Table 4 Estimated Annual Average Emissions for the EKAPCD (tons per day) 

Source Category TOG ROG CO NOX SOX

Particulate 

Matter PM10 PM2.5

Stationary Sources

Fuel Combustion 0.52 0.12 0.56 2.46 0.23 0.40 0.37 0.36

Waste Disposal 7.30 0.05 -- -- 0.00 0.00 0.00 0.00

Cleaning and Surface Coatings 0.85 0.77 -- -- -- 0.00 0.00 0.00

Petroleum Production and 

Marketing

0.20 0.20 -- -- -- -- -- --

Industrial Processes 0.11 0.09 6.79 15.43 2.25 5.69 3.67 1.55

Total Stationary Sources 8.98 1.22 7.35 17.89 2.48 6.09 4.04 1.91

Stationary Sources Percentage 

of Total

44 12 13 50 88 23 25 29

Areawide Sources

Solvent Evaporation 1.14 1.21 -- -- -- -- -- --

Miscellaneous Processes 1.85 0.30 1.37 0.26 0.01 17.09 8.26 1.40

Total Areawide Sources 3.26 1.51 1.37 0.26 0.01 17.09 8.26 1.40

Areawide Sources Percentage 

of Total

16 14 2 1 0 64 52 21

Mobile Sources

On-Road Motor Vehicles 2.59 2.37 23.53 9.70 0.03 0.54 0.54 0.35

Other Mobile Sources 5.71 5.48 24.90 7.85 0.31 3.13 3.06 3.02

Total Mobile Sources 8.30 7.85 48.44 17.55 0.34 3.67 3.06 3.37

Mobile Sources Percentage of 

Total

40 74 85 49 12 14 19 50

Grand Total 20.54 10.59 57.15 35.70 2.83 26.85 15.90 6.68

Source: California Air Resources Board, 2015

CO = carbon dioxide ROG = reactive organic gas

NOX = nitrogen oxides SOX = sulfur oxides 

PM2.5 = particulate matter smaller than or equal to 2.5 microns in diameter TOG = total organic gas

PM10 = particulate matter smaller than or equal to 10 microns in diameter
Section 4 Air Quality Conditions in the Study Area

March 2021 California High-Speed Rail Authority

4-8 | Page Draft General Conformity Determination 

4.3.3 Antelope Valley Air Quality Monitoring District

Emission inventory data for the AVAQMD for 2012 (the most recent data the CARB provides) is 

summarized in Table 5. In the AVAQMD, mobile source emissions account for more than 91 

percent and 69 percent of the CO and NOx emission inventory, respectively. Area sources made 

up more than 55 percent of the particulate emissions, whereas stationary sources made up 45 

percent of particulate emissions. Mobile sources were 64 percent of the SOx emissions. 

Stationary sources made up 43 percent of the area-wide ROG emissions. Note that Table 5

shows tons per day, whereas the emissions estimates for the Proposed Action are shown in tons 

per year.

Table 5 Estimated Annual Average Emissions for the AVAQMD (tons per day) 

Source Category TOG ROG CO NOX SOX

Particulate

Matter PM10 PM2.5

Stationary Sources

Fuel Combustion 0.36 0.17 1.35 5.09 0.02 3.24 1.36 0.57

Waste Disposal 2.88 0.06 0.00 0.00 0.00 0.54 0.16 0.02

Cleaning and Surface Coatings 5.21 3.36 -- -- -- 0.21 0.20 0.19

Petroleum Production and 

Marketing

13.82 3.11 -- -- -- -- -- --

Industrial Processes 0.19 0.11 0.00 0.01 0.00 17.57 8.46 2.00

Total Stationary Sources 22.46 6.82 1.36 5.09 0.03 21.56 10.81 2.79

Stationary Sources 

Percentage of Total

63 43 2 28 21 45 43 49

Areawide Sources

Solvent Evaporation 3.89 3.39 -- -- -- -- -- --

Miscellaneous Processes 3.78 0.74 3.67 0.50 0.02 26.43 13.52 2.28

Total Areawide Sources 7.67 4.13 3.67 0.50 0.02 26.43 13.52 2.28

Areawide Sources Percentage 

of Total

21 26 6 3 14 55 53 40

Mobile Sources

On-Road Motor Vehicles 3.19 2.84 41.25 9.54 0.05 -- 0.65 0.33

Other Mobile Sources 2.36 2.22 11.57 2.84 0.04 0.32 0.31 0.30

Total Mobile Sources 5.54 5.06 52.81 12.37 0.09 0.32 0.97 0.63

Mobile Sources Percentage of 

Total

16 32 91 69 64 1 4 11

Grand Total 35.68 16.01 57.84 17.97 0.14 48.31 24.66 5.70

Source: California Air Resources Board, 2015

CO = carbon dioxide ROG = reactive organic gas

NOX = nitrogen oxides SOX = sulfur oxides

PM2.5 = particulate matter smaller than or equal to 2.5 microns in diameter TOG = total organic gas

PM10 = particulate matter smaller than or equal to 10 microns in diameter
Section 4 Air Quality Conditions in the Study Area

California High-Speed Rail Authority March 2021

Draft General Conformity Determination Page | 4-9 

4.4 Action Study Area Designations

The study area defined in the EIR/EIS for the Action and for this draft General Conformity 

Determination includes the SJVAPCD, EKAPCD, and AVAQMD. Under the federal criteria, the 

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

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

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

for PM10, and the Bakersfield urbanized area is a maintenance area for CO. The SJVAPCD is in 

attainment for the NO2 and SO2 NAAQS. The SJVAPCD is unclassified for the lead NAAQS. The 

EKAPCD is currently designated nonattainment for federal 8-hour O3. The western portion of the 

district is currently designated nonattainment for PM10. The EKAPCD is an attainment/

unclassifiable area for the PM2.5, CO, and lead NAAQS. The EKAPCD is unclassified for the 

federal NO2 and SO2 standards. Under the federal criteria, the AVAQMD is currently designated 

as nonattainment for 8-hour O3. The AVAQMD is an attainment/unclassified area under the 

NAAQS for CO, NO2, SO2, and lead. The AVAQMD is unclassified for the PM10 and PM2.5

NAAQS.
Section 4 Air Quality Conditions in the Study Area

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Section 5 Relationship to NEPA

California High-Speed Rail Authority March 2021

Draft General Conformity Determination Page | 5-1 

5 RELATIONSHIP TO NEPA

The Draft Bakersfield to Palmdale EIR/EIS identifies reasonable foreseeable environmental 

impacts of the Action, both adverse and beneficial, identifies appropriate measures to mitigate 

adverse impacts, and identifies the agencies’ preferred alternative. The EIR/EIS was prepared to 

comply with both NEPA and CEQA. 

The General Conformity regulations establish certain procedural requirements that must be 

followed when preparing a General Conformity evaluation and are similar but not identical to 

those for conducting an air quality impact analysis under NEPA regulations. NEPA requires that 

the air quality impacts of the proposed Action’s implementation be analyzed and disclosed. For 

purposes of NEPA, the air quality impacts of the Action were determined by identifying the 

Action’s associated incremental emissions and air pollutant concentrations and comparing them, 

respectively, to emissions thresholds and state and national ambient air quality standards. The air 

quality impacts of the Action under future Build conditions were also compared in the EIR/EIS to 

the future No-Build conditions for NEPA purposes (they were also compared to existing 

conditions). The General Conformity Determination process and general findings are discussed in 

Sections 3.3.2.1, 3.3.4.5, 3.3.6.3, 3.3.7.1, and 3.3.9.2 of the EIR/EIS.

In order to appropriately identify and offset, where necessary, the emissions resulting from the 

Bakersfield to Palmdale section of the HSR system, the FRA is issuing this draft General 

Conformity Determination. The Authority shall enter into agreements with the SJVAPCD (VERA), 

EKAPCD (Emission Banking Certificate Program), and the AVAQMD (Air Quality Investment 

Program) to offset emissions, as necessary, resulting from the Bakersfield to Palmdale Section as 

described in Section 12.2.
Section 5 Relationship to NEPA

March 2021 California High-Speed Rail Authority

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Section 6 Avoidance and Mitigation Measures to Reduce Emissions

to be Incorporated in the Action

California High-Speed Rail Authority March 2021

Draft General Conformity Determination Page | 6-1 

6 AVOIDANCE AND MITIGATION MEASURES TO REDUCE EMISSIONS

TO BE INCORPORATED IN THE ACTION

In order to reduce impacts on the environment, the construction of the Action will include impact 

avoidance and minimization features and mitigation measures that will be implemented as part of 

the Action to minimize, avoid, and mitigate air quality impacts. These Impact Avoidance and 

Minimization Features (IAMF) and mitigation measures will be included components of the Action. 

The IAMFs and mitigation measures required by the ROD will be included in the Mitigation 

Monitoring and Enforcement Program that will be issued concurrently with the Authority’s ROD 

and that would be enforceable commitments undertaken by the Authority. Construction of the 

Action is anticipated to occur through a design/build contract. The Authority will include all of the 

IAMFs and required mitigation measures in the construction contract, which will create a binding 

and enforceable contractual commitment to implement these design features and mitigation 

measures.

The Authority will be responsible for implementing and overseeing a mitigation monitoring 

program to ensure that the contractor meets all air quality IAMFs and mitigation measures.

• AQ-IAMF#1: Fugitive Dust Emissions—During construction, the Contractor shall employ 

the following measures to minimize and control fugitive dust emissions. The Contractor shall 

prepare a fugitive dust control plan for each distinct construction segment. At a minimum, the 

plan shall describe how each measure would be employed and identify an individual 

responsible for ensuring implementation. At a minimum, the plan shall address the following 

components unless alternative measures are approved by the applicable air quality 

management district.

− Cover all vehicle loads transported on public roads to limit visible dust emissions, and 

maintain at least 6 inches of freeboard space from the top of the container or truck bed.

− Clean all trucks and equipment before exiting the construction site using an appropriate 

cleaning station that does not allow runoff to leave the site or mud to be carried on tires 

off the site.

− Water exposed surfaces and unpaved roads at a minimum three times daily with 

adequate volume to result in wetting of the top 1 inch of soil but avoiding overland flow. 

Rain events may result in adequate wetting of top 1 inch of soil thereby alleviating the 

need to manually apply water.

− Limit vehicle travel speed on unpaved roads to 15 miles per hour (mph).

− Suspend any dust-generating activities when average wind speed exceeds 25 mph.

− Stabilize all disturbed areas, including storage piles that are not being used on a daily 

basis for construction purposes, by using water, a chemical stabilizer/suppressant, hydro 

mulch or by covering with a tarp or other suitable cover or vegetative ground cover, to 

control fugitive dust emissions effectively. In areas adjacent to organic farms, the 

Authority would use non-chemical means of dust suppression.

− Stabilize all on-site unpaved roads and off-site unpaved access roads, using water or a 

chemical stabilizer/suppressant, to effectively control fugitive dust emissions. In areas 

adjacent to organic farms, the Authority would use non-chemical means of dust 

suppression.

− Carry out watering or presoaking for all land clearing, grubbing, scraping, excavation, 

land leveling, grading, cut and fill, and demolition activities. 

− For buildings up to 6 stories in height, wet all exterior surfaces of buildings during 

demolition.

− Limit or expeditiously remove the accumulation of mud or dirt from adjacent public streets 

at a minimum of once daily, using a vacuum type sweeper. 
Section 6 Avoidance and Mitigation Measures to Reduce Emissions

to be Incorporated in the Action

March 2021 California High-Speed Rail Authority

6-2 | Page Draft General Conformity Determination 

− After the addition of materials to or the removal of materials from surface or outdoor 

storage piles, apply sufficient water or a chemical stabilizer/suppressant.

• AQ-IAMF#2: Selection of Coatings—During construction, the Contractor shall use:

− Low-volatile organic compound (VOC) paint that contains less than 10 percent of VOC 

contents (VOC, 10%).

− Super-compliant or Clean Air paint that has a lower VOC content than that required by 

San Joaquin Valley Unified Air Pollution Control District Rule 4601, Eastern Kern Air 

Pollution Control District Rule 410, and Antelope Valley Air Quality Management District 

Rule 1113, when available. If not available, the Contractor shall document the lack of 

availability; recommend alternative measure(s) to comply with by San Joaquin Valley 

Unified Air Pollution Control District Rule 4601, Eastern Kern Air Pollution Control District 

Rule 410, and Antelope Valley Air Quality Management District Rule 1113; or disclose 

absence of measure(s) for full compliance and obtain concurrence from the Authority.

• AQ-IAMF#3: Renewable Diesel—During construction, the Contractor would use renewable 

diesel fuel to minimize and control exhaust emissions from all heavy-duty diesel-fueled 

construction diesel equipment and on-road diesel trucks. Renewable diesel must meet the 

most recent ASTM D975 specification for Ultra Low Sulfur Diesel and have a carbon intensity 

no greater than 50% of diesel with the lowest carbon intensity among petroleum fuels sold in 

California. The Contractor would provide the Authority with monthly and annual reports, 

through the Environmental Mitigation Management and Application (EMMA) system, of 

renewable diesel purchase records and equipment and vehicle fuel consumption. Exemptions 

to use traditional diesel can be made where renewable diesel is not available from suppliers 

within 200 miles of the project site. The construction contract must identify the quantity of 

traditional diesel purchased and fully document the availability and price of renewable diesel 

to meet project demand.

• AQ-IAMF#4: Reduce Criteria Exhaust Emissions from Construction Equipment—Prior 

to issuance of construction contracts, the Authority would incorporate the following 

construction equipment exhaust emissions requirements into the contract specifications:

1. All heavy-duty off-road construction diesel equipment used during the construction phase 

would meet Tier 4 engine requirements. 

2. A copy of each unit's certified tier specification and any required CARB or air pollution 

control district operating permit would be made available to the Authority at the time of 

mobilization of each piece of equipment. 

3. The contractor would keep a written record (supported by equipment-hour meters where 

available) of equipment usage during project construction for each piece of equipment. 

4. The contractor would provide the Authority with monthly reports of equipment operating 

hours (through the Environmental Mitigation Management and Assessment [EMMA] 

system) and annual reports documenting compliance.

• AQ-IAMF#5: Reduce Criteria Exhaust Emissions from ON-Road Construction 

Equipment—Prior to issuance of construction contracts, the Authority would incorporate the 

following material-hauling truck fleet mix requirements into the contract specifications:

1. All on-road trucks used to haul construction materials, including fill, ballast, rail ties, and 

steel, would consist of a 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 the CARB's 

EMFAC 2014 database.

2. The contractor would provide documentation to the Authority of efforts to secure such a 

fleet mix. 
Section 6 Avoidance and Mitigation Measures to Reduce Emissions

to be Incorporated in the Action

California High-Speed Rail Authority March 2021

Draft General Conformity Determination Page | 6-3 

3. The contractor would keep a written record of equipment usage during project 

construction for each piece of equipment and provide the Authority with monthly reports 

of VMT (through EMMA) and annual reports documenting compliance.

• AQ-IAMF#6: Reduce the Potential Impact of Concrete Batch Plants—Prior to 

construction of any concrete batch plant, the contractor would provide the Authority with a 

technical memorandum documenting consistency with the Authority’s concrete batch plant 

siting criteria and utilization of typical control measures. Concrete batch plants would be sited 

at least 1,000 feet from sensitive receptors, including places such as daycare centers, 

hospitals, senior care facilities, residences, parks, and other areas where people may 

congregate. The concrete batch plant would implement 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 USEPA AP-42 controlled emission factors for concrete 

batch plants. The contractor would provide to the Authority documentation that each batch 

plant meets this standard during operation.

• AQ-MM#1: Offset Project Construction Emissions through Off-Site Emission Reduction 

Programs—The Authority and SJVAPCD have entered into a contractual agreement to 

mitigate (by offsetting) to net zero the project’s actual emissions from construction equipment 

and vehicle exhaust emissions of volatile organic compound (VOC), NOX, particulate matter 

(PM10), and PM2.5. The agreement will provide funds for the SJVAPCD’s Emission Reduction 

Incentive Program [1] (SJVAPCD 2011) to fund grants for projects that achieve emission 

reductions, with preference given to highly affected communities, thus offsetting project-related 

impacts on air quality. To lower overall cost, funding for the VERA program to cover estimated 

construction emissions for any funded construction phase will be provided at the beginning of the 

construction phase. At a minimum, mitigation/offsets will occur in the year of impact, or as 

otherwise permitted by 40 Code of Federal Regulations (C.F.R.) Part 93 Section 93.163.

The Authority shall also enter into an agreement with the Antelope Valley Air Quality 

Management District (AVAQMD) and Eastern Kern Air Pollution Control District (EKAPCD) to 

mitigate (by offsetting) to net zero the project’s actual emissions from construction equipment 

and vehicle exhaust emissions of VOC, NOX, PM10 and PM2.5. In the AVAQMD, the Authority 

shall participate in the Air Quality Investment Program, which funds stationary- and mobilesource emission reduction strategies. In the EKAPCD, the Authority shall provide an 

application for the Emission Banking Certificate Program.
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 to be Incorporated in the Action

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7 REGULATORY PROCEDURES

The General Conformity regulations establish certain procedural requirements that must be 

followed when preparing a General Conformity evaluation. This section addresses the major 

applicable procedural issues and specifies how these requirements are met for the evaluation of 

the Federal Action. The procedures required for the General Conformity evaluation are similar but 

not identical to those for conducting an air quality impact analysis pursuant to NEPA regulations. 

It is anticipated, however, that the Final General Conformity Determination will be published 

concurrent with the Authority’s ROD for the Federal Action. This draft General Conformity 

Determination is being released for public and agency review pursuant to 40 C.F.R. § 93.156.

The Authority identified the appropriate emission estimation techniques and planning 

assumptions in close consultation with the state entities charged with regulating air pollution in 

the SJVAB and MDAB. 

7.1 Use of Latest Planning Assumptions 

The General Conformity regulations require the use of the latest planning assumptions for the 

area encompassing the Federal Action, derived from the estimates of population, employment, 

travel, and congestion most recently approved by the area’s metropolitan planning organization 

(MPO) (40 C.F.R. § 93.159(a)).

The traffic data used in the air quality analysis (see EIR/EIS, Section 3.2) are consistent with the 

most recent estimates made by the MPOs for traffic volume growth rates, including forecast 

changes in vehicle miles traveled (VMT) and vehicle hours traveled (VHT). The Authority 

developed these estimates based on the MPO’s traffic assignment models using the baseline and 

future population, employment, and travel and congestion information available at the time the 

analysis was prepared. These assumptions are consistent with those in the current conformity 

determinations for the region’s Transportation Plan and TIP. 

7.2 Use of Latest Emission Estimation Techniques

The General Conformity regulations require the use of the latest and most accurate emission 

estimation techniques available, unless such techniques are inappropriate (40 C.F.R. § 

93.159(b)). Operational phase vehicular emission factors were estimated by using the CARB 

emission factor program, EMission FACtors 2014 (EMFAC2014). Parameters were set in 

EMFAC2014 for each individual county to reflect conditions within each county, and statewide 

parameters were used to reflect statewide conditions. Operational phase aircraft emissions were 

estimated using the Federal Aviation Administration’s Aviation Environmental Design Tool. In 

addition, electrical demands caused by propulsion of the trains, and of the trains at terminal 

stations and in storage depots and maintenance facilities were estimated using average emission 

factors for each kilowatt-hour required from CARB statewide emission inventories of electrical 

and cogeneration facilities data along with USEPA eGRID2012 (released October 20, 2015) 

electrical generation data. The energy estimates used for the propulsion of the HSR system 

include the use of regenerative braking power. Operation of the Bakersfield to Palmdale Project 

Section HSR stations and the LMF and co-located MOWF were determined using the California 

Emissions Estimator Model (CalEEMod). 

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

elevated rail segments, retained-fill rail segments, electrical substations, train stations, 

LMF/MOWF, and roadways and roadway overpasses were calculated using emission factors 

from CalEEMod. CalEEMod uses emission factors from the OFFROAD 2011 model. The 

OFFROAD 2011 model provides the latest emission factors for off-road construction equipment 

and accounts for lower fleet population and growth factors as a result of the economic recession 

and updated load factors based on feedback from engine manufacturers. The use of emission 

rates from the OFFROAD models reflects the recommendation of CARB to capture the latest offroad construction assumptions. OFFROAD 2011 default load factors (the ratio of average 

equipment horsepower utilized to maximum equipment horsepower) and useful life parameters 
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March 2021 California High-Speed Rail Authority

7-2 | Page Draft General Conformity Determination 

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

truck trips were also calculated using CalEEMod. 

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 CalEEMod for each year of construction. 

Action-specific data, including construction equipment lists and the construction schedule, were 

used for construction associated with the alignment/guideway. Action-specific data were not 

available for the nonlinear construction associated with the stations and LMF/MOWF buildings. 

Therefore, the CalEEMod default settings were used in these instances only. 

Mobile-source emission burdens from worker trips and truck trips were estimated using 

CalEEMod.

7.3 Major Construction-Phase Activities

Action-specific data, including construction equipment lists and the construction schedule, were 

used for construction associated with the alignment/guideway. Calculations were performed for 

each year of construction. 

Major activities were grouped into the following categories (described in more detail in Section 9.0 

of this report): 

• Mobilization 

• Site preparation including demolition, land clearing, and grubbing 

• Earthmoving 

• Roadway crossings 

• Elevated structures 

• Track laying – elevated, at-grade, and retained fill 

• Traction power supply station 

• Switching station 

• Paralleling station 

• LMF/MOWF

• Bakersfield Station 

• Palmdale Station

• Hauling emissions, including truck and rail 

• Demobilization 

7.4 Emission Scenarios 

The General Conformity regulations require that the evaluation reflect certain emission scenarios 

(40 C.F.R. §93.159(d)). Specifically, these scenarios generally include the evaluation of the direct 

and indirect emissions from a proposed Action for the following years: (1) for nonattainment 

areas, the attainment year specified in the SIP or if the SIP does not specify an attainment year, 

the latest attainment year possible under the CAA, and for maintenance areas, the farthest year 

for which emissions are projected in the approved maintenance plan; (2) the year during which 

the total of direct and indirect emissions for the Federal Action are projected to be the greatest on 

an annual basis; and (3) any year for which the applicable SIP specifies an emissions budget. 

Both the operational and construction phases of the Action have to be analyzed, and the following 

applies to the proposed Action. 

Emissions generated during the operational phase of the HSR would meet the emission 

requirements for the years associated with Items 1 and 3 because the emissions generated 

during the operational phase of the proposed Action would be less than those emitted in the NoBuild scenario. In addition, microscale analyses conducted for the EIR/EIS demonstrate that the 

operational phase of the HSR would not cause or exacerbate a violation of the NAAQS for all 

applicable pollutants. The microscale CO modeling results for 2016 and 2040 are presented in 

the Bakersfield to Palmdale Project Section Draft Air Quality and Global Climate Change 
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Draft General Conformity Determination Page | 7-3 

Technical Report (Authority 2018b). Bakersfield Station data are included in the Fresno to 

Bakersfield Section Final EIR/EIS (Authority and FRA 2014) and technical reports. 

• Emissions generated during HSR’s construction phase, which would include the year with the 

greatest amount of total direct and indirect emissions, may be subject to General Conformity 

regulations because regional emissions would increase and, as such, have the potential to 

cause or exacerbate an exceedance of an NAAQS. Therefore, analyses were conducted to 

estimate the amounts of emissions that would be generated during the construction phase 

(for comparison with the General Conformity applicability rates) and the potential impacts of 

these emissions on local air quality levels. Emissions generated at the construction sites 

(e.g., tailpipe emissions from the on-site heavy-duty diesel equipment and fugitive dust 

emissions generated by vehicles traveling within the construction sites) and on the area’s 

roadways by vehicles traveling to and from these sites (by vehicles transporting materials and 

the workers traveling to and from work) were considered.

• Air quality dispersion modeling would be required for this conformity analysis to estimate the 

Action’s localized impacts on PM2.5 and CO concentrations if the annual emissions of the 

pollutants generated during construction were to exceed the General Conformity de minimis

thresholds.

Annual emissions were estimated for each year of the proposed Action’s construction period. 

These emissions, which are the maximum values for the Action, are described in more detail in 

Section 10.0 of this report.
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Section 8 Applicability Analysis

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Draft General Conformity Determination Page | 8-1 

8 APPLICABILITY ANALYSIS

The first step in a General Conformity evaluation is an analysis of whether the requirements apply 

to a proposed federal action in a nonattainment or a maintenance area. Unless exempted by the 

regulations or otherwise presumed to conform, a federal (non-Transportation) action requires a 

General Conformity Determination for each pollutant where the total of direct and indirect 

emissions caused by the federal action would equal or exceed an annual de minimis emission 

rate.

8.1 Attainment Status of Action Area

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

attainment, maintenance, or nonattainment based on the area's ability to meet ambient air quality 

standards. Regions are designated as attainment for a criteria pollutant when the concentration of 

that pollutant is below the ambient air standard. If a criteria pollutant concentration is above the 

ambient air standard, the area is in nonattainment for that pollutant. Areas previously designated 

as nonattainment that subsequently demonstrated compliance with the ambient air quality 

standards are designated as a maintenance area. Table 6 summarizes the federal (under 

NAAQS) and state (under CAAQS) attainment status for each of the air basins for which the 

Action would be located. 

8.1.1 Attainment Status: San Joaquin Valley Air Basin

Under the federal criteria, the SJVAPCD is currently designated as nonattainment for 8-hour O3, 

the 1997 annual PM2.5 standard (annual standard of 15 micrograms per cubic meter [μg/m3]) and 

24-hour standard (65 μg/m3), and the 2006 24-hour PM2.5 standard (35 μg/m3). The SJVAPCD is 

a maintenance area for PM10, and the Bakersfield urbanized area is a maintenance area for CO. 

The SJVAPCD is in attainment for the NO2 and SO2 NAAQS. The SJVAB is unclassified for the 

lead NAAQS.

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

8-hour O3, PM10, and PM2.5. The SJVAPCD is an attainment/unclassified area for the state CO 

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

unclassified area for the state hydrogen sulfide standard and visibility-reducing particle standard, 

and is classified as an attainment area for sulfates and vinyl chloride (SJVAPCD 2013a). 

8.1.2 Attainment Status: Antelope Valley Air Quality Management District

Under the federal criteria, the AVAQMD is currently designated as nonattainment for 8-hour O3. 

The AVAQMD is an attainment/unclassified area under the NAAQS for CO, NO2, SO2, and lead. 

The AVAQMD is unclassified for the PM10 and PM2.5 NAAQS.

Under the state criteria, the AVAQMD is currently designated as nonattainment for O3 (classified 

as extreme nonattainment) and PM10. The AVAQMD is an attainment/unclassified area for state 

PM2.5, CO, NO2, SO2, and lead standards. The AVAQMD is an unclassified area for the state 

hydrogen sulfide standard, visibility-reducing particle standard, and particulate sulfate standard 

(AVAQMD 2014). 

8.1.3 Attainment Status: Eastern Kern Air Pollution Control District

The EKAPCD is currently designated nonattainment for federal 8-hour O3. The western portion of 

the district is currently designated nonattainment for PM10. The EKAPCD is an attainment/

unclassifiable area for the PM2.5, CO, and lead NAAQS. The EKAPCD is unclassified for the 

federal NO2 and SO2 standards.

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

8-hour O3, and PM10. The EKAPCD is in attainment for the state NO2, SO2, and lead standards, 

and is an unclassified area for the PM2.5 and CO state standards (EKAPCD 2012).
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Table 6 Federal and State Attainment Status 

Pollutants Federal Classification State Classification 

San Joaquin Valley Air Pollution Control District

O3: 1-Hour No Federal Standard Nonattainment (Severe)

O3: 8-Hour Nonattainment (Extreme) Nonattainment

PM10 Attainment/Maintenance Nonattainment

PM2.5 Nonattainment Nonattainment

CO Urban portion of Fresno County and Kern County: 

Maintenance 

Remaining basin: Attainment

Attainment/Unclassified

NO2 Attainment/Unclassified Attainment

SO2 Attainment/Unclassified Attainment

Lead No Designation/Classification Attainment 

Antelope Valley Air Quality Management District

O3: 1-Hour No Federal Standard Nonattainment (Extreme)

O3: 8-Hour Nonattainment (Severe) Nonattainment (Extreme)

PM10 Attainment/Unclassified Nonattainment

PM2.5 Attainment/Unclassified Unclassified

CO Attainment Attainment

NO2 Attainment/Unclassified Attainment/Unclassified

SO2 Attainment/Unclassified Attainment/Unclassified

Lead Attainment Attainment

Eastern Kern Air Pollution Control District

O3: 1-Hour No Federal Standard Moderate Nonattainment 

O3: 8-Hour Nonattainment Nonattainment

PM10 Attainment/Unclassified (EKAPCD)

Nonattainment (Kern River/Cummings Valleys), 

Attainment Maintenance (Indian Wells Valley)

Nonattainment

PM2.5 Attainment/Unclassified Unclassified

CO Attainment/Unclassified Unclassified 

NO2 Unclassified Attainment

SO2 Unclassified Attainment

Lead Attainment/Unclassified Attainment

Sources: U.S. Environmental Protection Agency, 2013; San Joaquin Valley Air Pollution Control District, 2013a; Antelope Valley Air Quality 

Management District, 2016; Eastern Kern Air Pollution Control District, 2012c

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

EKAPCD = Eastern Kern Air Pollution Control District PM10 = particulate matter smaller than or equal to 10 microns in diameter

NOX = nitrogen oxides SO2 = sulfur dioxide

O3 = ozone
Section 9 Construction Activities Considered

California High-Speed Rail Authority March 2021

Draft General Conformity Determination Page | 9-1 

9 CONSTRUCTION ACTIVITIES CONSIDERED 

As shown in Section 3.3.6.3 of the EIR/EIS, the results of the regional analyses conducted for the 

proposed Action demonstrate that emissions generated during the operational phase would be 

less than those emitted in the No-Build and existing conditions scenarios and that the microscale 

analyses demonstrate that the Action would not cause or exacerbate a violation of the NAAQS for 

these pollutants. As such, no further analysis of the operational period emissions is necessary for 

this General Conformity determination. Section 9.0 will focus on the emissions generated from 

the construction period emissions for the Bakersfield to Palmdale Project.

The analysis conducted for the EIR/EIS to estimate potential air quality impacts caused by on-site 

(e.g., demolition activities, construction equipment operations, and truck movements) and off-site 

(e.g., motor vehicle traffic effects due to truck trips) construction-phase activities included the 

following:

• Estimation of emissions generated by the construction activities (e.g., deconstruction, 

concrete and steel construction), including fugitive dust emissions and emissions released 

from diesel-powered equipment and trucks based on the hours of operation of each piece of 

equipment;

• Identification of heavily traveled truck routes to estimate the cumulative effects of on-site 

construction activity emissions and off-site traffic emissions;

• An on-site dispersion modeling analysis of the major construction areas;

• An off-site dispersion modeling analysis of the roadway intersections/interchanges adjacent 

to the construction areas using traffic data that include construction-related vehicles and 

background traffic; and

• A comparison of the on-site and off-site modeling results to the applicable NAAQS for the 

applicable pollutants.

Emission rates for these activities were estimated based on the following:

• The number of hours per day and duration of each construction activity;

• The number and type of construction equipment to be used;

• Horsepower (HP) and utilization rates (hours per day) for each piece of equipment;

• The quantities of construction/demolition material produced and removed from each site; and

• The number of truck trips needed to remove construction/demolition material, and to bring the 

supply materials to each site.

The following is a discussion of the major activities considered, the timing of these activities, and 

the procedures used to estimate emission rates. 

A full description of construction analysis methodology can be found in Section 6.9 of the 

Bakersfield to Palmdale Section Air Quality and Global Climate Change Technical Report for this 

Action (Authority 2018b).

Construction activities associated with proposed Action would result in criteria pollutant and 

greenhouse gas (GHG) emissions. Construction emissions for the proposed Action are quantified 

and analyzed in Section 3.3.6.3 of the EIR/EIS. The analysis assumed that project construction 

would occur from 2018 to 2026. The construction schedule has since been revised. See Section 

2.8 in Chapter 2 of the EIR/EIS for additional details on the revised construction schedule. 

Although the schedule has been updated, the analysis is still valid as the equipment quantities 

and annual emission rates would remain unchanged. While separate projects for purposes of 

planning the HSR system, construction of the Bakersfield to Palmdale Section would overlap with 

the construction period for the Merced to Fresno Project Section and Fresno to Bakersfield 

Project Section, thereby adding to the cumulative air quality impacts within the SJVAB. In 

addition, construction of the Bakersfield to Palmdale Project Section would overlap with the 
Section 9 Construction Activities Considered

March 2021 California High-Speed Rail Authority

9-2 | Page Draft General Conformity Determination 

construction period for the Palmdale to Burbank Project Section, thereby adding to the cumulative 

air quality impacts within the MDAB. The cumulative emissions that could result from potential 

concurrent construction activities are presented in Section 13 of the General Conformity Report.

9.1 Site Preparation

9.1.1 Demolition

This analysis assumed that demolition of existing structures along the HSR alignment and near 

HSR stations would take place from December 2020 through August 2021. Demolition emissions 

were calculated with CalEEMod using the project-specific equipment list. In addition to the fugitive 

dust emissions resulting from the destruction of existing buildings, emissions were estimated for 

worker trips, construction equipment exhaust, and truck-hauling exhaust. 

9.1.2 Land Grubbing

Land grubbing refers to the site preparation activities for HSR alignment construction. Emissions 

from land grubbing were estimated using the OFFROAD 2011 emission factors as well as a sitespecific equipment list. This analysis assumed that land grubbing would take place at four staging 

areas from December 2020 to August 2021. Fugitive dust from land-grubbing activities includes 

that from worker trips, construction equipment exhaust, and truck-hauling exhaust.

9.2 Earth Moving

The earthmoving activities include grading, trenching, and cut/fill activities for the HSR alignment 

construction. This analysis assumed that earthmoving would occur at four locations from March 

2018 to October 2020. The emissions associated with the earthmoving activities were estimated 

using CalEEMod with OFFROAD 2011 emission factors, in conjunction with the site-specific 

equipment list. Fugitive dust from land-grubbing activities includes that from worker trips, 

construction equipment exhaust, and truck-hauling exhaust.

The construction area used in CalEEMod was the total area to be cleared based on the length of 

the alignment. Although the track widths vary along the alignment, it was conservatively assumed 

that a width of 120 feet would be graded along the entire length of the alignment. This width 

accounts for the widest portion of the alignment (four tracks wide) plus a buffer on each side.

Earthwork is the disturbance of soil or earth by any means, including excavation (including 

subsurface), tunneling, drilling, infilling, stockpiling, dumping of soil or sand, and construction/

reconstruction of any track, embankment, or drainage channel. Earthwork would be performed in 

such a manner as to achieve a balanced condition where the quantity of soil or earthen materials 

removed through excavation would be roughly equal to the quantity of material being placed in 

embankments. The adjustment of the ratio of excavation to embankment to achieve this balance 

would be performed by variations in cut-slope ratios, embankment widths, and embankment 

slope ratios during construction as existing ground conditions are revealed. It is intended that cut 

material and tunnel spoils would be stored and processed on-site and used as fill materials if 

deemed suitable by the site geotechnical engineer. It is not anticipated that any excavated 

materials would need to be exported to off-site locations for the B-P Build Alternatives. 

9.3 HSR Alignment Construction

This analysis assumed that the HSR alignment construction would occur from 2020 to 2026, and 

includes the following construction phases and operation of a concrete batch plant: 

• Constructing structures for the elevated rail

• Laying elevated rail and at-grade rail

• Constructing the retaining wall for the retained-fill rail

• Laying retained-fill rail
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California High-Speed Rail Authority March 2021

Draft General Conformity Determination Page | 9-3 

9.3.1 Rail Type and Alignment Alternatives

The four B-P Build Alternatives differ in total length, location, width, and percentage of at-grade/

elevated/retained fill. Table 3.3-5 of the EIR/EIS summarizes the total length of at-grade rail, 

elevated rail, and retained-fill rail for each B-P Build Alternative. The CCNM Design Option would 

add 124 feet to the length of each B-P Build Alternative and the Refined CCNM Design Option 

would add 2,006 feet to the length of each B-P Build Alternative. Due to rounding, the total length 

in miles would not change with the CCNM Design Option. Emissions from construction of the 

track were determined using CalEEMod. Equipment counts, horsepower, hours of operation, and 

load factors used in CalEEMod are included in the Bakersfield to Palmdale Project Section Air 

Quality and Global Climate Change Technical Report (Authority 2018b). 

9.3.2 Concrete Batch Plants

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

of the HSR alignment, for construction of the station platform, and for construction of the retaining 

wall used to support the retained-fill sections of the alignment. To provide enough concrete 

on-site, it is estimated that batch plants would operate in the Action vicinity (i.e., within 0.5 mile) 

during construction of the Action. Because the locations of the concrete batch plants are 

unknown, fugitive dust emissions associated with the plants were estimated based on the total 

amount of concrete required and on emission factors from Chapter 11.12 of AP-42 (USEPA 

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

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

9.3.3 Material Hauling

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

construction site were calculated using heavy-duty truck emission factors from EMFAC2014 and 

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

potentially be hauled by rail within the air basins. Locomotive emission factors from Emission 

Factors for Locomotives (USEPA 2009b) and the travel distance by rail to the Action site were 

used to estimate rail emissions. 

Based on active permitted quarry locations, ballast materials are expected to be available within 

the SJVAB and MDAB (California Department of Conservation 2016). Therefore, for the regional 

emission analysis, emissions from ballast materials-hauling were calculated using the distance 

traveled within the Action air districts. Emissions from ballast materials hauling by trucks and 

locomotives outside the Action air districts were estimated based on the travel distances and 

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

available. Rail emission factors using the USEPA guidance (USEPA 2009b) were used to 

estimate the locomotive emissions. Construction materials would likely be delivered from supply 

facilities within the SJVAB and the MDAB.

9.4 Train Station Construction

Emissions from HSR station construction would be the result of mass site grading, building 

construction, and architectural coatings. Where applicable, emissions resulting from worker trips, 

vendor trips, and construction equipment exhaust were included. Paving activities associated with

surface parking lots were included. For the purposes of this analysis, it was assumed that 

construction of the Palmdale Station would begin in 20182 and be completed by 2021. CalEEMod 

was used to estimate emissions from construction phases of the Palmdale Station. 

 

2

 This schedule is presented for analysis purposes only; the resulting data remains valid because the equipment 

quantities and annual emission rates would remain unchanged.
Section 9 Construction Activities Considered

March 2021 California High-Speed Rail Authority

9-4 | Page Draft General Conformity Determination 

9.5 Maintenance Facilities Construction

Emissions associated with construction of the LMF and MOWF are expected as a result of mass 

site grading, asphalt paving, building construction, and architectural coatings. These activities 

would occur during maintenance activities.

Fugitive dust from construction of the maintenance-of-way facility includes that from worker trips, 

construction equipment exhaust, and truck-hauling exhaust. Emissions from track construction 

were estimated using CalEEMod.

9.6 Roadway Crossing Construction

The B-P Build Alternatives would include the relocation and expansion of freeway segments, local 

roads, and overpasses, as well as reconstruction of several intersections. Fugitive dust and 

exhaust emissions from these construction activities were estimated using the Sacramento 

Metropolitan Air Quality Management District’s Road Construction Emissions Model. Roadway 

demolition emissions are included in the CalEEMod analysis using the Action-specific equipment 

list. 

For purposes of this analysis, it was assumed that roadway Action construction would begin in 

January 20203 and be completed by June 2022 (a total of 28 months), and that each type of 

roadway Action would be constructed independently at staggered intervals during the 28-month 

period. 

Based on Action-specific data, a simplified construction schedule was used to estimate 

construction emissions. The representative Action roadway length for each scenario was 

estimated by averaging all anticipated Action roadway lengths within that designated scenario.

 

3 This schedule is presented for analysis purposes only; the resulting data remains valid because the equipment quantities 

and annual emission rates would remain unchanged.
Section 10 Estimated Emissions Rates and Comparison to De Minimis

Thresholds – Bakersfield-Palmdale

California High-Speed Rail Authority March 2021

Draft General Conformity Determination Page | 10-1 

10 ESTIMATED EMISSIONS RATES AND COMPARISON TO DE MINIMIS

THRESHOLDS – BAKERSFIELD-PALMDALE

Construction activities associated with the HSR alternatives would result in criteria pollutant 

emissions. Construction emissions for the four Bakersfield to Palmdale alternatives are quantified 

and analyzed in this section. 

10.1 Construction Impacts within the SJVAPCD

Total annual estimated emissions generated within the SJVAPCD during the proposed Action’s 

construction period, as presented in the HSR EIR/EIS, are provided in Table 7. As shown in the

table, direct emissions from the construction phase of the Bakersfield to Palmdale Project Section 

within the SJVAPCD would exceed the GC applicability thresholds for VOC and NOx in certain 

calendar years in which construction would take place. The maximum estimated annual values of 

each pollutant, by non-attainment or maintenance area, and the percentage of the 2012 

estimated emission rates in the SJVAPCD (see Table 3) for the Bakersfield to Palmdale

construction are as follows:

• NOx: 177 tons per year (tpy)(0.15%)

• VOCs: 17 tpy (0.01%)

• PM2.5: 9 tpy (0.03%)

• PM10: 15 tpy (0.02%)

• CO: 90 tpy (0.03%)

Table 7 Estimated Annual Average Emissions for the SJVAPCD

Pollutants 

Emissions (Tons/Year) 

Conformity 

Applicability 

Thresholds 

2018 2019 2020 2021 2022 (tons/year) 

2022 

with 

Refined 

CCNM

Option 2023 

2023 

with 

Refined 

CCNM

Option 2024 2025 2026 

Alternative 1

NOx 55* 2 104* 156* 133* 142* 107* 110* 51* 25* 15* 10 

VOCs 5 1 11* 16* 14* 14* 11* 11* 7 4 2 10 

PM2.5 3 1 5 8 7 7 6 6 3 2 1 100

PM10 4 1 7 13 12 12 11 11 6 2 1 100 

CO1 7 1 25 69 68 68 60 60 12 5 3 100

Alternative 2

NOx 0 0 134* 151* 121* 136* 76* 78* 31* 15* 15* 10 

VOCs 0 0 13* 15* 13* 13* 8 8 4 2 2 10

PM2.5 0 0 6 8 8 8 5 5 2 1 1 100 

PM10 0 0 10 15 13 13 10 10 6 1 1 100

CO1 0 0 29 86 83 84 48 48 7 3 3 100 

Alternative 3 

NOx 0 0 145* 168* 151* 160* 84* 87* 51* 15* 15* 10

VOCs 0 0 15* 17* 16* 16* 9 9 7 2 2 10 

PM2.5 0 0 6 9 8 8 4 4 3 1 1 100

PM10 0 0 8 11 11 11 6 6 4 1 1 100 

CO1 0 0 31 90 89 89 22 22 12 3 3 100
Section 10 Estimated Emissions Rates and Comparison to De Minimis

Thresholds – Bakersfield-Palmdale

March 2021 California High-Speed Rail Authority

10-2 | Page Draft General Conformity Determination 

Pollutants 

Emissions (Tons/Year)

Conformity 

Applicability 

Thresholds 

2018 2019 2020 2021 2022 (tons/year) 

2022 

with 

Refined 

CCNM

Option 2023 

2023 

with 

Refined 

CCNM

Option 2024 2025 2026 

Alternative 5 

NOx 0 0 155* 177* 161* 170* 128* 131* 50* 32* 13* 10

VOCs 0 0 15* 17* 16* 16* 13* 13* 6 5 2 10 

PM2.5 0 0 7 9 8 8 7 7 3 2 1 100

PM10 0 0 10 11 11 11 9 9 4 2 1 100

CO1 0 0 42 90 90 90 85 85 12 7 3 100 

Source: California High-Speed Rail Authority, 2020

Values marked with an asterisk (*) exceed applicability thresholds

1 Bakersfield urbanized maintenance area only 2 The emissions presented in this table reflect the impact of the Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule, per the California Air 

Resource Board’s “EMFAC Off-Model Adjustment Factors to Account for the SAFE Vehicles Rule Part One” issued on November 20, 2019. 

https://ww3.arb.ca.gov/msei/emfac_off_model_adjustment_factors_final_draft.pdf. 

CCNM = César E. Chávez National Monument

CO = carbon monoxide

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

VOC = volatile organic compound

10.2 Construction Impacts within the EKAPCD

Total annual estimated emissions generated within the EKAPCD during the proposed Action’s 

construction period, as presented in the HSR EIR/EIS, are provided in Table 8. As shown in the 

table, construction emissions for Bakersfield to Palmdale Project Section within the EKAPCD 

would exceed the GC applicability thresholds for NOx in some construction years. The maximum 

estimated annual values of each pollutant, by non-attainment or maintenance area, and the 

percentage of the 2012 estimated emission rates in the EKAPCD (see Table 4) for the 

Bakersfield to Palmdale construction are as follows:

• NOx: 279 tpy (2.14%)

• VOCs: 27 tpy (0.70%)

• PM2.5: 14 tpy (0.57%)

• PM10: 22 tpy (0.38%)

• CO: 540 tpy (2.591%)

Table 8 Estimated Annual Average Emissions for the EKAPCD 

Pollutants

Emissions (Tons/Year)

Conformity 

Applicability 

Thresholds 

2018 2019 2020 2021 2022 (tons/year)

2022 

with 

Refined 

CCNM

Option 2023

2022 

with 

Refined 

CCNM

Option 2024 2025 2026

Alternative 1

NOx 33 60* 172* 207* 177* 213* 121* 131* 56* 32 20 50

VOCs 3 6 17 20 18 18 15 16 7 5 3 50

PM2.5 2 3 8 11 10 10 9 9 3 2 1 N/A

PM10 4 5 13 18 16 16 15 15 7 2 1 70
Section 10 Estimated Emissions Rates and Comparison to De Minimis

Thresholds – Bakersfield-Palmdale

California High-Speed Rail Authority March 2021

Draft General Conformity Determination Page | 10-3 

Pollutants

Emissions (Tons/Year)

Conformity 

Applicability 

Thresholds 

2018 2019 2020 2021 2022 (tons/year)

2022 

with 

Refined 

CCNM

Option 2023

2022 

with 

Refined 

CCNM

Option 2024 2025 2026

CO 18 35 161 392 381 384 346 346 155 29 17 N/A

Alternative 2

NOx 0 0 152* 254* 185* 222* 114* 124* 33 20 20 50

VOCs 0 0 15 25 19 19 12 12 4 2 2 50

PM2.5 0 0 7 13 10 10 7 7 3 1 1 N/A

PM10 0 0 14 22 18 18 14 14 7 1 1 70

CO 0 0 149 521 486 489 287 288 33 16 16 N/A

Alternative 3

NOx 0 0 184* 277* 233* 269* 132* 142* 57* 20 20 50

VOCs 0 0 17 27 24 24 13 13 7 3 2 50

PM2.5 0 0 7 13 12 12 7 7 3 1 1 N/A

PM10 0 0 10 17 16 16 10 10 5 1 1 70

CO 0 0 161 534 521 524 137 138 57 17 17 N/A

Alternative 5

NOx 0 0 187* 279* 232* 268* 183* 193* 54* 41 17 50

VOCs 0 0 18 27 24 24 19 19 7 6 2 50

PM2.5 0 0 9 14 12 12 10 10 3 3 1 N/A

PM10 0 0 12 18 15 15 12 12 4 3 1 70

CO 0 0 127 540 522 525 491 492 54 37 14 N/A

Source: California High-Speed Rail Authority, 2020

Values marked with an asterisk (*) exceed applicability thresholds 1 The emissions presented in this table reflect the impact of the Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule, per the California Air 

Resource Board’s “EMFAC Off-Model Adjustment Factors to Account for the SAFE Vehicles Rule Part One” issued on November 20, 2019. 

https://ww3.arb.ca.gov/msei/emfac_off_model_adjustment_factors_final_draft.pdf. 

CCNM = César E. Chávez National Monument

CO = carbon monoxide

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

VOC = volatile organic compound

10.3 Construction Impacts within the AVAQMD

Total annual estimated emissions generated within the AVAQMD during the proposed Action’s 

construction period, as presented in the HSR EIR/EIS, are provided in Table 9. As shown in the 

table, emissions from the construction phase of the Bakersfield to Palmdale Project Section within 

the AVAQMD would exceed the GC applicability thresholds for NOx in certain construction years. 

The maximum estimated annual values of each pollutant, by non-attainment or maintenance 

area, and the percent of the 2012 estimated emission rates in the AVAQMD (see Table 5) for the 

Bakersfield to Palmdale construction are as follows:

• NOx: 177 tpy (2.70%)

• VOCs: 17 tpy (0.29%)

• PM2.5: 9 tpy (0.43%)

• PM10: 11 tpy (0.12%)

• CO: 380 tpy (1.80%)
Section 10 Estimated Emissions Rates and Comparison to De Minimis

Thresholds – Bakersfield-Palmdale

March 2021 California High-Speed Rail Authority

10-4 | Page Draft General Conformity Determination 

Table 9 Estimated Annual Average Emissions for the AVAQMD 

Pollutants

Emissions (Tons/Year) Conformity

Applicability 

Thresholds 

2018 2019 2020 2021 2022 2023 2024 2025 2026 (tons/year)

Alternative 1

NOx 0 12 69* 72* 63* 50* 17 12 10 25

VOCs 0 2 7 7 6 5 2 2 1 25

PM2.5 0 1 3 3 3 3 1 2 1 N/A

PM10 0 1 5 5 4 4 2 2 1 N/A

CO 0 7 68 175 169 150 17 11 8 N/A

Alternative 2

NOx 0 0 95* 132* 122* 81* 56* 38* 10 25

VOCs 0 0 9 12 12 9 7 5 1 25

PM2.5 0 0 4 6 6 4 3 2 1 N/A

PM10 0 0 6 8 7 5 4 3 1 N/A

CO 0 0 96 132 122 81 56 38 10 N/A

Alternative 3

NOx 0 0 46* 84* 88* 35* 17 10 10 25

VOCs 0 0 3 8 9 3 2 1 1 25

PM2.5 0 0 2 4 5 1 1 1 1 N/A

PM10 0 0 3 6 6 2 1 1 1 N/A

CO 0 0 53 232 239 39 17 8 8 N/A

Alternative 5

NOx 0 0 155* 177* 161* 128* 50* 32* 13 25

VOCs 0 0 16 17 16 13 6 5 2 25

PM2.5 0 0 7 9 8 7 3 1 1 N/A

PM10 0 0 10 11 11 9 4 1 1 N/A

CO 0 0 177 380 378 357 50 29 11 N/A

Source: California High-Speed Rail Authority, 2020

Values marked with an asterisk (*) exceed applicability thresholds 1 The emissions presented in this table reflect the impact of the Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule, per the California Air 

Resource Board’s “EMFAC Off-Model Adjustment Factors to Account for the SAFE Vehicles Rule Part One” issued on November 20, 2019. 

https://ww3.arb.ca.gov/msei/emfac_off_model_adjustment_factors_final_draft.pdf. 

CCNM = César E. Chávez National Monument

CO = carbon monoxide

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

VOC = volatile organic compound
Section 11 Regional Effects

California High-Speed Rail Authority March 2021

Draft General Conformity Determination Page | 11-1 

11 REGIONAL EFFECTS

As shown in Section 3.3-6.3 of the EIR/EIS, the total regional emissions for all of the applicable 

pollutants are lower during the operations phase of the Action than under No-Build conditions 

(and will therefore not exceed the de minimis emission thresholds). As such, only emissions 

generated during the construction phase were compared to the conformity threshold levels to 

determine conformity compliance. Based on the results shown in Table 7, Table 8, and Table 9, 

regional construction-phase emissions, compared to the General Conformity applicability rates, 

are summarized below. 

11.1 Construction Impacts within the SJVAPCD

• Annual estimated VOC emissions are greater than the applicability rate of 10 tons per year in 

years 2020 through 2023 for Alternative 1, Alternative 2, and Alternative 5 and in years 2020 

through 2022 for Alternative 3. 

• Annual estimated CO emissions are less than the applicability rate of 100 tons per year in all 

years for all Action Alternatives. 

• Annual estimated NOx emissions are greater than the applicability rate of 10 tons per year in 

years 2018 and 2020 through 2026 for Alternative 1, and 2020 through 2026 for Alternative 2, 

Alternative 3, and Alternative 5. 

• Annual estimated PM10 emissions are less than the applicability rate of 100 tons per year in 

all years for all Action Alternatives. 

• Annual estimated PM2.5 emissions are less than the applicability rate of 10 tons per year in all 

years for all Action Alternatives. 

• There are no applicable thresholds for SO2 annual emissions.

11.2 Construction Impacts within the EKAPCD

• Annual estimated VOC emissions are less than the applicability rate of 50 tons per year in all 

years for all Action Alternatives. 

• Annual estimated NOx emissions are greater than the applicability rate of 50 tons per year in 

years 2019 through 2025 for Alternative 1 and in years 2020 through 2024 for Alternative 2, 

Alternative 3, and Alternative 5. 

• Annual estimated PM10 emissions are less than the applicability rate of 70 tons per year in all 

years for all Action Alternatives. 

• There are no applicable thresholds for CO, SO2, and PM2.5 annual emissions.

11.3 Construction Impacts within the AVAQMD

• Annual estimated VOC emissions are less than the applicability rate of 25 tons per year in all 

years for all Action Alternatives. 

• Annual estimated NOx emissions are greater than the applicability rate of 25 tons per year in 

years 2020 through 2023 for Alternative 1 and Alternative 3 and in years 2020 through 2025 

for Alternative 2 and Alternative 5. 

• There are no applicable thresholds for CO, SO2, PM10, and PM2.5 annual emissions.

As such, a General Conformity Determination is required for this Action for VOC, and NOx for the 

years during construction where the emissions would exceed the de minimis thresholds and do 

not meet any of the exceptions cited in 40 C.F.R. § 93.154(c). This draft Conformity 

Determination identified the Authority’s commitment to reduce VOC and NOx emissions through 

emissions offsets using a VERA with the SJVAPCD, the Air Quality Investment Program with the 

AVAQMD, and the Emission Banking Certificate Program in the EKAPCD, explained in Section 

12.2 below.
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Draft General Conformity Determination Page | 12-1 

12 GENERAL CONFORMITY EVALUATION

For federal actions subject to a General Conformity evaluation, the regulations delineate several 

ways an agency can demonstrate conformity (40 C.F.R. § 93.158). This section summarizes the 

findings that were used to make the determination for the Action. 

12.1 Conformity Requirements of Proposed Action

Based on the results shown in Table 7, Table 8, and Table 9, conformity determinations are 

required for construction-phase emissions for: 

• VOC—Because annual estimated emissions are greater than the applicability rate of 10 tons 

per year in years 2020 through 2023 for Alternative 1, Alternative 2, and Alternative 5 and in 

years 2020 through 2022 for Alternative 3 in the SJVAPCD

• NOx—Because annual estimated emissions are greater than the applicability rate of 10 tons 

per year in years 2018 and 2020 through 2026 for Alternative 1, and 2020 through 2026 for 

Alternative 2, Alternative 3, and Alternative 5 in the SJVAPCD; greater than the applicability 

rate of 50 tons per year in years 2019 through 2025 for Alternative 1 and in years 2020 

through 2024 for Alternative 2, Alternative 3, and Alternative 5 in the EKAPCD; and greater 

than the applicability rate of 25 tons per year in years 2020 through 2023 for Alternative 1 and 

Alternative 3 and in years 2020 through 2025 for Alternative 2 and Alternative 5 in the 

AVAQMD

12.2 Compliance with Conformity Requirements

To support this General Conformity Determination, the FRA demonstrates herein that the VOC 

and NOx emissions caused by the construction of the proposed Action will not result in an 

increase in regional VOC and NOx emissions. This will be achieved by offsetting the VOC and 

NOx emissions generated by construction of the HSR in a manner consistent with the General 

Conformity regulations. 

The offsets are anticipated to be accomplished through a VERA between the Authority and the 

SJVAPCD, the Air Quality Investment Program with the AVAQMD, and the Emission Banking 

Certificate Program in the EKAPCD. The requirements for the VERA, the Air Quality Investment 

Program, and the Emission Banking Certificate Program would be implemented as part of the 

Action as described in the mitigation measure from the EIR/EIS:

AQ-MM#1: Offset Project Construction Emissions through Off-Site Emission Reduction 

Programs

In 2014, the Authority and the San Joaquin Air Pollution Control District (SJVAPCD) entered into 

a contractual agreement through a Memorandum of Understanding and a Voluntary Emission 

Reduction Agreement (VERA). The VERA mitigates (by offsetting) to net zero the project’s actual 

emissions from construction equipment and vehicle exhaust emissions of volatile organic 

compound (VOC), NOX, particulate matter (PM10), and PM2.5. The agreement will provide funds 

for the SJVAPCD’s Emission Reduction Incentive Program (SJVAPCD 2011) to fund grants for 

projects that achieve emission reductions, with preference given to highly affected communities, 

thus offsetting project-related impacts on air quality. To lower overall cost, funding for the VERA 

program to cover estimated construction emissions for any funded construction phase will be 

provided at the beginning of the construction phase. At a minimum, mitigation/offsets will occur in 

the year of impact, or as otherwise permitted by 40 Code of Federal Regulations (C.F.R.) Part 93 

Section 93.163.

The Authority shall also enter into an agreement with the Antelope Valley Air Quality 

Management District (AVAQMD) and Eastern Kern Air Pollution Control District (EKAPCD) to 

mitigate (by offsetting) to net zero the project’s actual emissions from construction equipment and 

vehicle exhaust emissions of VOC, NOX, PM10 and PM2.5. In the AVAQMD, the Authority shall 

participate in the Air Quality Investment Program, which funds stationary- and mobile-source 
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12-2 | Page Draft General Conformity Determination 

emission reduction strategies. In the EKAPCD, the Authority shall provide an application for the 

Emission Banking Certificate Program.

12.3 Consistency with Requirements and Milestones in Applicable SIP

The general conformity regulations state that notwithstanding the other requirements of the rule, a 

federal action may not be determined to conform unless the total of direct and indirect emissions 

from the federal action is in compliance or consistent with all relevant requirements and 

milestones in the applicable SIP (40 C.F.R. § 93.158(c)). This includes but is not limited to such 

issues as reasonable further progress schedules, assumptions specified in the attainment or 

maintenance demonstration, prohibitions, numerical emission limits, and work practice standards. 

This section briefly addresses how the construction emissions for the Action were assessed for 

SIP consistency for this evaluation.

12.3.1 Applicable Requirements from USEPA

The USEPA has already promulgated requirements to support the goals of the Clean Air Act with 

respect to the NAAQS. Typically, these requirements take the form of rules regulating emissions 

from significant new sources, including emission standards for major stationary point sources and 

classes of mobile sources as well as permitting requirements for new major stationary point 

sources. Since states have the primary responsibility for implementation and enforcement of 

requirements under the Clean Air Act and can impose stricter limitations than the USEPA, the 

USEPA requirements often serve as guidance to the states in formulating their air quality 

management strategies.

12.3.2 Applicable Requirements from CARB

In California, to support the attainment and maintenance of the NAAQS, CARB is primarily 

responsible for regulating emissions from mobile sources. In fact, the USEPA has delegated 

authority to the CARB to establish emission standards for on-road and some non-road vehicles 

separate from the USEPA vehicle emission standards, although the CARB is preempted by the 

Clean Air Act from regulating emissions from many non-road mobile sources, including marine 

craft. Emission standards for preempted equipment can only be set by the USEPA.

12.3.3 Applicable Requirements from SJVAPCD

To support the attainment and maintenance of the NAAQS in the SJVAB, the SJVAPCD is 

primarily responsible for regulating emissions from stationary sources. As noted above, 

SJVAPCD develops and updates its Air Quality Management Plan (AQMP) regularly to support 

the California SIP. While the AQMP contains rules and regulations geared to attain and maintain 

the NAAQS, these rules and regulations also have the much more difficult goal of attaining and 

maintaining the California ambient air quality standards.

12.3.4 Applicable Requirements from EKAPCD

On July 27, 2017, the EKAPCD adopted the 2017 Ozone Attainment Plan for the East Kern 

County nonattainment area. The Plan demonstrates that the air quality improvement was 

achieved due to successful implementation of ozone control strategies contained in the region’s 

SIP. It also demonstrates that significant ozone precursor emission reductions that have been 

impacted in the region are permanent and enforceable. A maintenance plan is also included to 

ensure that the region would not experience exceedance. The Plan requests a redesignation in 

accordance with the Federal Clean Air Act (EKAPCD 2017). 

12.3.5 Applicable Requirements from AVAQMD

Under CEQA, the AVAQMD is a commenting agency on air quality within its jurisdiction. The 

CEQA and Federal Conformity Guidelines, released in 2011, are intended to assist persons 

preparing environmental analysis or review documents for any project within the jurisdiction of the 

District by providing background information and guidance on the preferred analysis approach. 

The guidelines include annual and daily GHG emission thresholds of significance for projectgenerated GHGs and criteria pollutants within the jurisdiction of the AVAQMD (AVAQMD 2011). 
Section 12 General Conformity Evaluation

California High-Speed Rail Authority March 2021

Draft General Conformity Determination Page | 12-3 

12.3.6 Consistency with Applicable Requirements for the Authority

The Authority already complies with, and will continue to comply with, a myriad of rules and 

regulations implemented and enforced by federal, state, regional, and local agencies to protect 

and enhance ambient air quality in the SJVAB and MDAB. 

In particular, due to the long persistence of challenges to attain the ambient air quality standards 

in the SJVAB and MDAB, the rules and regulations promulgated by CARB and SJVAPCD are 

among the most stringent in the U.S.

The Authority will continue to comply with all existing applicable air quality regulatory 

requirements for activities over which it has direct control and will meet in a timely manner all 

regulatory requirements that become applicable in the future.

These are appropriate USEPA, CARB, and SJVAPCD rules that are standard practice and BMPs 

for construction in the SJVAPCD and include control of emissions, exhaust---such as:

• 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-Action stationary source has the potential to emit equal

emissions or exceed the offset threshold levels, offsets will be required (SJVAPCD 2006). 

Stationary sources at the station (such as natural gas heaters) would need to be permitted 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 Rule 2280, Portable Equipment Registration requires portable equipment used at 

project sites for less than 6 consecutive months must be registered with SJVAPCD. The 

district will issue the registrations 30 days after the receipt of the application (SJVAPCD 

1996).

• SJVAPCD Rule 2303, Mobile Source Emission Reduction Credits: The Action may qualify for 

SJVAPCD vehicle emission reduction credits if it meets the specific requirements of Rule 

2303 for any of the following categories (SJVAPCD 1994):

− Zero-Emission Transit Buses

− Zero-Emission Vehicles.

− Retrofit Passenger Cars, Light-Duty Trucks, and Medium-Duty Vehicles.

− Retrofit Heavy-Duty Vehicles

• SJVAPCD Rule 4201 and Rule 4202, Particulate Matter Concentration and Emission Rates 

apply to operations that emit or may emit dust, fumes, or total suspended particulate matter. 

Particulate emissions from the Action must be less than the specified emissions limit 

(SJVAPCD 1992a, 1992b).

• SJVAPCD Rule 4301, Fuel Burning Equipment limits the emissions from fuel-burning 

equipment whose primary purpose is to produce heat or power by indirect heat transfer. The 

Action will comply with the emission limits (SJVAPCD 1992c).

• Fugitive dust regulations are applicable to outdoor fugitive dust sources. Operations, 

including construction operations, must control fugitive dust emissions in accordance with 

SJVAPCD Regulation VIII (SJVAPCD 2004). According to Rule 8011, the SJVAPCD requires 

the implementation of control measures for fugitive dust emission sources. The Action would 

also implement the mandatory control measures listed on pages 77 and 78 of the Guide for 

Assessing and Mitigating Air Quality Impacts (GAMAQI) (SJVAPCD 2015) to reduce fugitive 

dust emissions. These measures are not considered mitigation measures because they are 

required by the regulation.
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Many of the control measures required by the SJVAPCD are the same or similar to the 

control measures listed in the Statewide Program EIR/EIS. The SJVAPCD Rule 8011 

requirements are listed below:

− All disturbed areas, including storage piles, which are not being actively used for 

construction purposes, will be effectively stabilized for dust emissions using water or a 

chemical stabilizer/suppressant, or covered with a tarp or other suitable cover or 

vegetative ground cover.

− All onsite unpaved roads and offsite unpaved access roads will be effectively stabilized 

for dust emissions using water or a chemical stabilizer/suppressant.

− All land clearing, grubbing, scraping, excavation, land leveling, grading, cut and fill, and 

demolition activities will be effectively controlled of fugitive dust emissions by utilizing an 

application of water or by presoaking.

− With the demolition of buildings up to six stories in height, all exterior surfaces of the 

building will be wetted during demolition.

− All materials transported offsite will be covered or effectively wetted to limit visible dust 

emissions, and at least six inches of freeboard space from the top of the container will be 

maintained.

− All operations will limit or expeditiously remove the accumulation of mud or dirt from 

adjacent public streets at the end of each workday. The use of dry rotary brushes is 

expressly prohibited except where preceded or accompanied by sufficient wetting to limit 

the visible dust emissions. Use of blower devices is expressly forbidden.

− Following the addition of materials to, or the removal of materials from, the surface of 

outdoor storage piles, piles will be effectively stabilized of fugitive dust emissions utilizing 

sufficient water or a chemical stabilizer/suppressant. 

− Within urban areas, trackout will be immediately removed when it extends 50 or more 

feet from the site and at the end of each workday. 

− Any site with 150 or more vehicle trips per day will prevent carryout and trackout.

For projects in which construction related activities would disturb equal to or greater than one 

acre of surface area, the District recommends a demonstration of receipt of a District 

approved Dust Control Plan or Construction Notification form, before issuance of the first 

grading permit, be made a condition of approval.

• SJVAPCD Rule 9510, Indirect Source Review: In December 2005, the SJVAPCD adopted 

the Indirect Source Rule (Rule 9510) to meet the SJVAPCD’s emission reduction 

commitments in the PM10 and Ozone Attainment Plans (SJVAPCD 2005). Indirect Source 

Review regulation applies to any transportation project in which construction emissions equal 

or exceed two tons of NOx or PM10 per year. Construction of the HSR alignment (specifically, 

onsite off-road construction exhaust emissions) would be subject to Indirect Source Review. 

Accordingly, the Authority would have to submit an Air Impact Assessment (AIA) application 

to the SJVAPCD with commitments to reduce construction exhaust NOx and PM10 emissions 

by 20 percent and 45 percent, respectively. Operation of the HSR would be exempt under 

Sections 4.1 and 4.2 of Rule 9510.

• SJVAPCD CEQA Guidelines: The SJVAPCD prepared the GAMAQI to assist lead agencies 

and project applicants in evaluating the potential air quality impacts of projects in the SJVAB 

(SJVAPCD 2015). The GAMAQI provides SJVAPCD-recommended procedures for 

evaluating potential air quality impacts during the CEQA environmental review process. The 

GAMAQI provides guidance on evaluating short-term (construction) and long-term 

(operational) air emissions (Appendix F). The most recent version of the GAMAQI was 

adopted March 2015 and was used in this evaluation and contains guidance on the following:
Section 12 General Conformity Evaluation

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

air quality impact. 

− 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 that will be 

updated more frequently, such as air quality data, regulatory setting, climate, and 

topography.

• EKAPCD Rule 402, Fugitive Dust: The purpose of Rule 402 is to prevent, reduce, and 

mitigate ambient concentrations of anthropogenic fugitive dust emissions to an amount 

sufficient to attain and maintain the NAAQS and CAAQS. Controlling fugitive dust when 

visible emissions are detected may not prevent all PM10 emissions, but will substantially 

reduce ambient concentrations (EKAPCD 2014).

• EKAPCD CEQA Guidelines: The EKAPCD adopted the Guidelines for Implementation of the 

California Environmental Quality Act of 1970, As Amended, in 1996 (EKAPCD 2012b). The 

guidelines include thresholds for criteria air pollutants and guidance on implementation of 

mitigation measures. 

• AVAQMD Rule 403, Fugitive Dust: The provisions of this rule include actions to prevent, 

reduce or mitigate fugitive dust particulate matter entrained in the ambient air as a result of 

man-made sources. The rule limits actions that would result in a source of dust that causes 

20 percent opacity or greater during an observation of three minutes or more in any one hour. 

It also limits PM10 concentrations to under 50 micrograms per cubic meter.

• AVAQMD Rule 109, Recordkeeping for VOC Emissions: The provisions of this rule shall 

apply to an owner or operator of a stationary source within the District conducting operations, 

which include the use of adhesives, coatings, solvents, and/or graphic arts materials, when 

records are required to determine a District rule's applicability or source's exemption from a 

rule, rule compliance, or specifically as a Permit to Operate or Permit to Construct condition 

(AVAQMD 2010).
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Section 13 Estimated Emission Rates and Comparison to De Minimis 

Thresholds – Cumulative Analysis

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13 ESTIMATED EMISSION RATES AND COMPARISON TO DE MINIMIS 

THRESHOLDS – CUMULATIVE ANALYSIS

The study area for cumulative air quality impacts is the SJVAB and the MDAB. While separate 

projects for purposes of planning the HSR System, construction of the Bakersfield to Palmdale

Section would overlap with the construction period for the Merced to Fresno Section and Fresno 

to Bakersfield Section, thereby adding to the cumulative air quality impacts within the SJVAB. In 

addition, construction of the Bakersfield to Palmdale Section would overlap with the construction 

period for the Palmdale to Burbank Section, thereby adding to the cumulative air quality impacts 

within the MDAB. 

For purposes of full disclosure of the potential impacts, the cumulative emissions that could result 

from potential concurrent construction activities are presented here. As the analysis 

demonstrates, even where concurrent construction will take place, there would be no new 

pollutants exceeding the de minimis thresholds. In addition, construction period emissions would

be offset as a result of the VERA between the Authority and the SJVAPCD, the Air Quality 

Investment Program with the AVAQMD, and the Emission Banking Certificate Program in the 

EKAPCD. 

The total annual estimated emissions generated within the SJVAB during construction of the 

Merced to Fresno Section are provided in Table 10 and the total annual estimated emissions 

generated within the SJVAB during construction of the Merced to Fresno Section are provided in 

Table 11. The total annual estimated emissions generated within the SJVAB during the 

construction of the combined Merced to Palmdale sections (Merced to Fresno, Fresno to 

Bakersfield, plus Bakersfield to Palmdale) are provided in Table 12. As shown in this table, the 

combined annual construction emissions of the three sections would exceed the thresholds for 

NOx in the years 2014 through 2026, VOCs in the years 2014 through 2023, and PM10 in the year 

2015. 

These values are the peak on-site emissions during each analysis year plus maximum annual offsite emissions. The maximum estimated annual values of each pollutant, by non-attainment or 

maintenance area, and the percent of the 2012 estimated emission rates in the SJVAB (see 

Table 3) for the combined (Merced to Palmdale) construction are as follows: 

• NOx: 928 tpy (0.78%)

• VOCs: 54 tpy (0.04%)

• PM2.5: 42 tpy (0.15%)

• PM10: 84 tpy (0.08%)

• CO: 99 tpy (0.03%)

For the Merced to Fresno segment of the HSR system, construction emission rates were 

estimated in the EIR/EIS for each of the six alternatives/options previously under consideration 

for the Merced to Fresno Section. However, only those values associated with the Preferred 

Alternative are included in this Conformity Determination. These values represent the Preferred 

Alternative with the Avenue 21 wye option, because that option has the highest estimated 

emissions. If the Avenue 24 wye option is selected, the estimated emission rates will be lower 

than those presented in this determination.

Portions of the San Jose to Merced and Sacramento to Merced sections of the HSR would also 

be constructed within the SJVAB. It is possible that the schedule for construction of these 

sections could overlap with construction of the Merced to Fresno, Fresno to Bakersfield, and 

Bakersfield to Palmdale sections, contributing to the cumulative annual emissions totals of HSR

construction in the SJVAB. Portions of the Palmdale to Burbank sections of the HSR would also 

be constructed within the MDAB. It is possible that the schedule for construction of this section 

could overlap with construction of the Bakersfield to Palmdale Section, contributing to the 

cumulative annual emissions totals of HSR construction in the MDAB. 
Section 13 Estimated Emission Rates and Comparison to De Minimis 

Thresholds – Cumulative Analysis

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Table 10 Estimated Annual Average Emissions for the Merced to Fresno Section

Emissions (Tons/Year) Conformity 

Applicability 

Thresholds 

2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 (tons/year)

NOx 169* 110* 115* 32* 13* 49* 15* 7 4 0 0 0 10

VOCs 15* 11* 8 2 2 11* 2 1 5 0 0 0 10

PM2.5 8 6 4 2 1 3 1 0 2 0 0 0 100

PM10 13 9 6 4 1 6 2 1 9 0 0 0 100

CO1 29 22 11 4 2 5 4 1 1 0 0 0 100

Source: California High-Speed Rail Authority, 2014

Values marked with an asterisk (*) exceed applicability thresholds

1 Fresno urbanized maintenance area only

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

NOx = nitrogen oxide VOC = volatile organic compound

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

Table 11 Estimated Annual Average Emissions for the Fresno to Bakersfield Section

Emissions (Tons/Year) Conformity 

Applicability 

Thresholds 

2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 (tons/year)

NOx 622* 818* 549* 161* 71* 4 2 80* 1 0 0 0 10

VOCs 24* 43* 34* 9 4 0 0 4 0 0 0 0 10

PM2.51 20 36 29 12 10 7 0 2 0 0 0 0 100

PM10 51 75* 62 16 15 9 3 4 0 0 0 0 100

CO: Fresno1 31 75 66 12 4 1 1 9 0 0 0 0 100

CO: 

Bakersfield1 30 65 58 15 4 1 2 9 0 0 0 0 100

Source: California High-Speed Rail Authority, 2014

Values marked with an asterisk (*) exceed applicability thresholds

1 Fresno and Bakersfield urbanized maintenance areas only

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

NOx = nitrogen oxide VOC = volatile organic compound

PM10 = particulate matter smaller than or equal to 10 microns in diameter
Section 13 Estimated Emission Rates and Comparison to De Minimis 

Thresholds – Cumulative Analysis

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Table 12 Estimated Annual Average Emissions for the Merced to Palmdale Section

Emissions (Tons/Year) Conformity 

Applicability 

Thresholds 

2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 (tons/year)

NOx 791* 928* 664* 193* 139* 113* 204* 366* 274* 193* 57* 41* 20* 10

VOCs 39* 54* 42* 11* 11* 17* 20* 32* 29* 19* 7 6 2 10

PM2.5 28 42 33 14 14 13 10 16 14 10 3 3 1 100

PM10 64 84* 68 20 20 20 19 27 27 15 7 3 1 100

CO: 

Fresno1 60 97 78 16 6 6 5 10 1 0 0 0 0 100

CO: 

Bakersfield1 30 65 58 15 11 2 44 99 90 85 12 7 3 100

Sources: California High-Speed Rail Authority, 2014, 2020

Values marked with an asterisk (*) exceed applicability thresholds

1 Fresno and Bakersfield urbanized maintenance areas only

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

NOx = nitrogen oxide VOC = volatile organic compound

PM10 = particulate matter smaller than or equal to 10 microns in diameter
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Thresholds – Cumulative Analysis

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Section 14 Reporting and Public Comments

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14 REPORTING AND PUBLIC COMMENTS

To support a decision concerning the Federal Action, the FRA is issuing this draft General 

Conformity Determination for public and agency review for a 30-day period as required by 40 

C.F.R §§93.155 and 93.156. In developing the analysis underlying this general conformity 

determination, the Authority has consulted with the SJVAPCD, EKAPCD, and AVAQMD on a 

variety of technical and modeling issues. The Authority has also consulted with USEPA and 

CARB on the overall approach to general conformity.

14.1 Draft General Conformity Determination

FRA will provide copies of this draft General Conformity Determination to the appropriate regional 

offices of USEPA, CARB, SJVAPCD, EKAPCD, and AVAQMD for a 30-day review. The FRA also 

placed a notice in a daily newspaper of general circulation announcing the availability of the draft 

General Conformity Determination and requesting written public comments during a 30-day 

period. A copy of this draft General Conformity Determination will be made available on FRA’s 

website for public review.
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Section 15 Findings and Conclusions

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15 FINDINGS AND CONCLUSIONS

As part of the environmental review of the proposed Action, FRA conducted a General Conformity 

evaluation pursuant to 40 C.F.R. Part 93 Subpart B. The General Conformity regulations apply at 

this time to this Federal Action because the Action is located in an area that is designated as an 

extreme nonattainment area for the 8-hour ozone standard, nonattainment for PM2.5, and a 

(partial) maintenance area for PM10 and CO. The FRA conducted the General Conformity 

evaluation following all regulatory criteria and procedures and in coordination with USEPA, 

SJVPCD, EKAPCD, AVAQMD, and CARB. As a result of this review, the FRA concluded, based 

on the fact that Action-generated emissions will either be fully offset (for construction phase) or 

less than zero (for operational phase), that the proposed Action’s emissions can be 

accommodated in the SIP for the SJVAB. FRA has determined that the proposed Action as 

designed will conform to the approved SIP, based on:

• A commitment from the Authority that construction-phase NOx and VOC emissions will be 

offset consistent with the applicable federal regulations through a VERA with the SJVAPCD, 

the Air Quality Investment Program in the AVAQMD, and the Emission Banking Certificate 

Program in the EKAPCD. 

• The SJVAPCD, EKAPCD, and AVAQMD will seek and implement the necessary emission 

reduction measures, using Authority funds. 

• The SJVAPCD, EKAPCD, and AVAQMD will serve in the role of administrator of the 

emissions reduction projects and verifier of the successful mitigation effort. 

Therefore, FRA herewith concludes that the proposed Action, as designed, conforms to the 

purpose of the approved SIP and is consistent with all applicable requirements.
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Section 16 References

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16 REFERENCES

Antelope Valley Air Quality Management District (AVAQMD). 2004. 2004 Ozone Attainment Plan.

April 20, 2004.

———. 2008. Western Mojave Desert Ozone Attainment Plan. www.arb.ca.gov/planning/sip/

planarea/mojavesedsip.htm (accessed May 14, 2015).

———. 2010. AVAQMD Rule 109 – Recordkeeping for VOC Emissions. April 20, 2010. 

www.avaqmd.ca.gov/Modules/ShowDocument.aspx?documentid=906 (accessed June 4, 

2015).

———. 2011. CEQA and Federal Conformity Guidelines. www.avaqmd.ca.gov/Modules/

ShowDocument.aspx?documentid=2908 (accessed April 2015).

———. 2014. Attainment Status: AVAQMD Designations and Classifications. 

www.avaqmd.ca.gov/index.aspx?page=289 (accessed May 2015).

California Air Resources Board (CARB). 2004. California State Implementation Plan (SIP): 2004 

Revisions to the Carbon Monoxide Maintenance Plan. July 2004.

———. 2015. California Air Basins. www.arb.ca.gov/knowzone/basin/basin.swf (accessed May 

14, 2015).

———. 2020. iADAM: Air Quality Data Statistics Top 4 Summary. Website: 

https://www.arb.ca.gov/adam/topfour/topfour1.php (accessed January 2020).

California High-Speed Rail Authority (Authority). 2018a. Burbank to Los Angeles Project Section: 

Air Quality and Global Climate Change Technical Report. January 2018.

———. 2018b. Bakersfield to Palmdale Project Section Draft Air Quality and Global Climate 

Change Technical Report. 

California High-Speed Rail Authority and Federal Railroad Administration (Authority and FRA). 

2014. Fresno to Bakersfield Section Final Environmental Impact Report/Environmental 

Impact Statement.

Eastern Kern Air Pollution Control District (EKAPCD). 2012a. Attainment Status. July 31. 

www.kernair.org/Documents/EKAPCD%20Attainment%20Info%207-31-12.pdf (accessed 

May 14, 2015).

———. 2012b. Guidelines for Implementation of the California Environmental Quality Act (CEQA) 

of 1970, As Amended. Amended July 8, 2012. www.kernair.org/Documents/CEQA/

CEQA_Guidelines%20&%20Charts.pdf (accessed October 2016). 

———. 2014. Rule 402 Fugitive Dust. September 10, 2014. www.kernair.org/Documents/Rules/

Rules%20Sept%202014/402%20Fugitive%20Dust%20Staff%20Report%209-10-14.pdf

(accessed June 4, 2014).

———. 2017. 2017 Ozone Attainment Plan For 2008 Federal 75 ppb 8-Hour Ozone Standard. 

July 27. www.kernair.org/Documents/Announcements/Attainment/2017%20Ozone%

20Plan_EKAPCD_Adopted_7-27-17.pdf (accessed June 2019). 

Federal Railroad Administration and State of California, 2019. Memorandum of Understanding 

between the Federal Railroad Administration and the State of California Acting Through 

Its California State Transportation Agency and Its California High-Speed Rail Authority, 

for the State of California’s Participation in the Surface Transportation Project Delivery 

Program Pursuant to 23 U.S.C. 327. July 23.

San Joaquin Valley Air Pollution Control District (SJVAPCD). 1992a. Rule 4201 Particulate Matter 

Concentration. Amended December 17, 1992.

———. 1992b. Rule 4202 Particulate Matter – Emission Rate. Amended December 17, 1992. 

———. 1992c. Rule 4301 Fuel Burning Equipment. Amended December 17, 1992. 
Section 16 References

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———. 1994. Rule 2303 Mobile Source Emission Reduction Credits. Adopted May 19, 1994. 

———. 1996. Rule 2280 Portable Equipment Registration. Amended May 16, 1996. 

———. 2004. 2004 Extreme Ozone Attainment Demonstration Plan: San Joaquin Valley Air 

Basin Plan Demonstrating Attainment of Federal 1-hour Ozone Standards. October 2004. 

www.valleyair.org/Air_Quality_Plans/AQ_Final_Adopted_Ozone2004.htm (accessed 

May 14, 2015).

———. 2005. Rule 95410 Indirect Source Review. Adopted December 15, 2005. 

———. 2006. Rule 2201 New and Modified Stationary Source Review Rule. Amended 

September 21, 2006.

———. 2007a. 2007 Ozone Plan. April 2007. www.valleyair.org/Air_Quality_Plans/AQ_Final_

Adopted_Ozone2007.htm (accessed May 14, 2015).

———. 2007b. PM10 Maintenance Plan and Request for Redesignation. September 30, 2007

———. 2009. District Policy-Addressing GHG Emission Impacts for Stationary Source Projects 

Under CEQA When Serving as the Lead Agency. www.valleyair.org/Programs/CCAP/12-

17-09/2%20CCAP%20-%20FINAL%20District%20Policy%20CEQA%20GHG%20-

%20Dec%2017%202009.pdf (accessed April 2015).

———. 2011. Frequently Asked Questions. www.valleyair.org/General_info/Frequently_

Asked_Questions.htm#About%20The%20Air%20Pollution%20Problem (accessed 

May 24, 2011).

———. 2013a. Ambient Air Quality Standards & Valley Attainment Status. www.valleyair.org/

aqinfo/attainment.htm (accessed May 14, 2015).

———. 2015. Guidance for Assessing and Mitigating Air Quality Impacts. March 19, 2015. 

www.valleyair.org/transportation/GAMAQI_3-19-15.pdf (accessed June 9, 2015). 

———. 2018. 2018 Plan for the 1997, 2006, and 2012 PM2.5 Standards. November 15, 2018. 

http://valleyair.org/pmplans/documents/2018/pm-plan-adopted/2018-Plan-for-the-1997-

2006-and-2012-PM2.5-Standards.pdf (accessed June 2019). 

U.S. Environmental Protection Agency (USEPA).1994. General Conformity Guidance: Questions 

and Answers. July 13, 1994. Accessible at: https://www.epa.gov/sites/production/

files/2016-03/documents/gcgqa_940713.pdf (accessed April 4, 2017).

———. 2006. Emission Factors & AP 42. https://www3.epa.gov/ttnchie1/ap42/ (accessed July 

2016). 

———. 2009. Emission Factors for Locomotives. April 2009. https://www3.epa.gov/nonroad/

locomotv/420f09025.pdf (accessed July 2016). 

———. 2010. Federal Register, Vol. 74, No. 209, Friday, October 30, 2009, 40 C.F.R. Parts 86, 

87, 89 et al. Mandatory Reporting of Greenhouse Gases; Final Rule. 

https://www.gpo.gov/fdsys/pkg/FR-2009-10-30/pdf/E9-23315.pdf (accessed July 2016). 

———. 2020. Outdoor Air Quality Data Monitor Values Report. Website: https://www.epa.gov/

outdoor-air-quality-data/monitor-values-report (accessed January 2020).

Western Regional Climate Center. 2011. Historical Climate Information, Bakersfield, California, 

Normals, Means, and Extremes. www.wrcc.dri.edu/summary/lcd.html (accessed May 14, 

2015).
Section 17 Preparer Qualifications

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17 PREPARER QUALIFICATIONS

Amy Fischer, Senior Air Quality Scientist, Ms. Fischer has a B.S. in Environmental Policy 

Analysis from the University of Nevada, Reno. With 20 years of experience, Amy Fischer serves 

as a senior air quality and greenhouse gas emissions specialist qualified to conduct analyses for 

a variety of infrastructure projects. Ms. Fischer is the technical lead on air quality and climate 

change impact analyses documents and oversees the research, and preparation of technical 

reports. She is skilled in air quality assessment models including: The California Emissions 

Estimator Model (CalEEMod), Emission Factor models (EMFAC/OFFROAD), Road Construction 

Estimator Model (RoadMod) and Line Dispersion Models (CALINE). 

Tin Cheung, Senior Air Quality Scientist, Mr. Cheung graduated with a bachelor’s degree in 

Environmental Studies and Geography from the University of California at Santa Barbara. He is a 

Senior Air Quality Scientist with 23 years of experience in the preparation of air quality and noise 

studies. He has worked on a multitude of small and large projects and is extremely proficient in 

quantitative computer models which include USEPA’s AERMOD air pollutant dispersion model, 

the California Emissions Estimator Model (CalEEMod), CARB’s EMFAC emission factor model,

SMAQMD’s Road Construction Emissions Model, Caline4 roadway air pollutant dispersion model 

and numerous other air quality and noise models.

Matthew Long, MESc, MPP, Senior Environmental Scientist, prepared the greenhouse gas 

analyses for this project. Matthew holds a Master’s Degree in Environmental Science from the 

Yale School of Forestry and Environmental Studies and a Master’s Degree in Public Policy from 

the Luskin School of Public Affairs at UCLA. He also has over 9 years of professional consulting 

experience providing CEQA/NEPA analysis for large infrastructure projects, including electrical 

transmission projects, flood control projects, and commercial-scale renewable energy 

development projects. Recently, Mr. Long provided management support and revised the 

Geology and Soils and Noise analyses for the BLM’s LUPA and Final EIS for the Desert 

Renewable Energy Conservation Plan.

Cara Carlucci, Planner, Ms. Carlucci holds a B.S. in City & Regional Planning with a minor in 

Real Property Development from California Polytechnic State University, San Luis Obispo. At 

LSA, she provides planning and technical assistance to project managers on a variety of planning 

and environmental documents including environmental assessments, initial studies, and environmental impact reports. She has contributed to the CEQA air quality analysis for residential, 

commercial, and infrastructure projects, as well as stand-alone air quality impact studies.
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Appendix A Draft General Conformity Determination Comments and Responses

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APPENDIX A: DRAFT GENERAL CONFORMITY DETERMINATION

COMMENTS AND RESPONSES 
Appendix A Draft General Conformity Determination Comments and Responses 

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