California High-Speed Rail Authority

Burbank to Los Angeles

Project Section 

Final General Conformity 

Determination 

November 2021 

The environmental review, consultation, and other actions required by 

applicable Federal environmental laws for this project are being or have 

been carried out by the State of California pursuant to 23 U.S.C. 327 and 

a Memorandum of Understanding dated July 23, 2019, and executed by 

the Federal Railroad Administration and the State of California.
California High-Speed Rail System, Burbank to Los Angeles Section

Final General Conformity Determination

Prepared by: 

U.S. Department of Transportation 

Federal Railroad Administration 

This Final General Conformity Determination has been prepared by the Federal Railroad Administration 

(FRA), pursuant to Section 176(c) of the Federal Clean Air Act, 42 U.S.C. 7506(c)(1), and its 

implementing regulations (“General Conformity Rule”). Specifically, this Final General Conformity 

Determination documents FRA’s finding that the California High-Speed Rail System, Burbank to Los 

Angeles Section will comply with the General Conformity Rule, provided that any construction emissions 

exceeding the de minimis levels will be offset though an agreement with the South Coast Air Quality 

Management District (SCAQMD).

Date of Approval Marlys Osterhues 

Chief of Environment and Project Engineering Division

Federal Railroad Administration 

For further information, please contact: 

Andréa E. Martin

Senior Environmental Protection Specialist

U.S. Department of Transportation

Federal Railroad Administration 

Environment & Project Engineering Division

1200 New Jersey Ave., SE

Washington, D.C. 20590

(202) 493-6201 
Table of Contents

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TABLE OF CONTENTS

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

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

1.2 General Conformity Requirements ............................................................... 1-2

2 CALIFORNIA HIGH SPEED RAIL PROJECT......................................................... 2-1

2.1 California High Speed Rail System ..............................................................2-1

2.2 California High Speed Rail System – Burbank to Los Angeles Section ....... 2-1

3 AIR QUALITY CONDITIONS IN THE STUDY AREA ............................................. 3-1

3.1 Meteorology and Climate.............................................................................. 3-1

3.2 Ambient Air Quality in the Study Area .......................................................... 3-1

3.3 Study Area Emissions .................................................................................. 3-5

3.4 Project Study Area Designations.................................................................. 3-5

4 RELATIONSHIP TO NEPA..................................................................................... 4-1

5 AVOIDANCE AND MITIGATION MEASURES TO REDUCE EMISSIONS TO 

BE INCORPORATED IN THE PROJECT............................................................... 5-1

6 REGULATORY PROCEDURES ............................................................................. 6-1

6.1 Use of Latest Planning Assumptions............................................................ 6-1

6.2 Use of Latest Emission Estimation Techniques ........................................... 6-1

6.3 Major Construction-Phase Activities............................................................. 6-2

6.4 Emission Scenarios ......................................................................................6-3

7 APPLICABILITY ANALYSIS ................................................................................... 7-1

7.1 Attainment Status of Project Area ................................................................ 7-1

8 CONSTRUCTION ACTIVITIES CONSIDERED...................................................... 8-1

8.1 Site Preparation............................................................................................ 8-1

8.1.1 Demolition......................................................................................8-1

8.1.2 Land Clearing/Grubbing................................................................. 8-2

8.2 Earthmoving ................................................................................................. 8-2

8.3 Trenching/Tunneling.....................................................................................8-2

8.4 High-Speed Rail Alignment Construction ..................................................... 8-2

8.4.1 Material Hauling............................................................................. 8-2

8.4.2 System Facilities............................................................................ 8-3

8.5 Station Construction ..................................................................................... 8-3

8.6 Roadway Crossing Construction .................................................................. 8-3

8.7 Early Action Project Construction ................................................................. 8-3

9 ESTIMATED EMISSIONS RATES AND COMPARISON TO DE MINIMIS 

THRESHOLDS – BURBANK-LOS ANGELES........................................................ 9-1

10 REGIONAL EFFECTS ..........................................................................................10-1

11 GENERAL CONFORMITY EVALUATION ............................................................11-1

11.1 Conformity Requirements of Project...........................................................11-1

11.2 Compliance with Conformity Requirements ...............................................11-1

11.3 Consistency with Requirements and Milestones in Applicable SIP............11-2

11.3.1 Applicable Requirements from the USEPA..................................11-2

11.3.2 Applicable Requirements from the CARB....................................11-2

11.3.3 Applicable Requirements from SCAQMD....................................11-2

11.3.4 Consistency with Applicable Requirements for the Authority.......11-2
Table of Contents

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12 REPORTING AND PUBLIC COMMENTS............................................................12-1

12.1 Availability of Final General Conformity Determination ..............................12-1

13 FINDINGS AND CONCLUSIONS.........................................................................13-1

14 REFERENCES .....................................................................................................14-1

15 PREPARER QUALIFICATIONS ...........................................................................15-1

Tables

Table 1 Planning Documents Relevant to the Resource Study Area ............................ 1-2

Table 2 Ambient Criterial Pollutant Concentration Data at Air Quality Monitoring 

Stations Closest to the Project................................................................................. 3-3

Table 3 Estimated 2019 Annual Average Emissions for the South Coast Air 

Quality Management District (tons/day)................................................................... 3-6

Table 4 Federal and State Attainment Status ................................................................ 7-1

Table 5 Estimated Annual Average Emissions .............................................................. 9-1

Figures

Figure 1 Air Quality Monitoring Stations Closest to the Project .....................................3-2

Appendix 

Appendix A: General Conformity Determination Letter between Authority and South 

Coast Air Quality Management District
Acronyms and Abbreviations

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ACRONYMS AND ABBREVIATIONS

μg/m3 micrograms per cubic meter

AQMP Air Quality Management Plan

Authority California High-Speed Rail Authority

CAA Clean Air Act

CalEEMod California Emissions Estimator Model

CARB California Air Resources Board

CEQA California Environmental Quality Act

C.F.R. Code of Federal Regulations

CO carbon monoxide

EIR Environmental Impact Report

EIS Environmental Impact Statement

EMFAC2014 EMission FACtors 2014

EMMA Environmental Mitigation Management and Assessment

FRA Federal Railroad Administration

HSR high-speed rail

IAMFs impact avoidance and minimization features

max. maximum

mph miles per hour

N/A not available

NAAQS National Ambient Air Quality Standards

NEPA National Environmental Policy Act

NM not monitored

NO2 nitrogen dioxide

NOx nitrogen oxides

NZE near zero-emission

O3 ozone

PM2.5 particulate matter 2.5 microns or less in diameter

PM10 particulate matter 10 microns or less in diameter

ppm parts per million

RECLAIM Regional Clean Air Incentive Market

RSA resource study area

SIP State Implementation Plan

SCAQMD South Coast Air Quality Management District

SO2 sulfur dioxide

SOx sulfur oxides 
Acronyms and Abbreviations

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tpy tons per year

USEPA United States Environmental Protection Agency 

ZE zero emission
Executive Summary

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EXECUTIVE SUMMARY

The California High-Speed Rail (HSR) System, proposed by the California High-Speed Rail 

Authority (Authority), 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 Central Valley, Los Angeles, the Inland Empire, Orange County, and 

San Diego. The Burbank to Los Angeles HSR Section (“ “Project”), which is the focus of this 

General Conformity Determination, is a critical link in Phase 1 of the California HSR System 

connecting the San Francisco Bay Area to the Los Angeles Basin.

1

The General Conformity Rule, as codified in Title 40 Code of Federal Regulations (C.F.R.) 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 Project 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. 

FRA prepared a Draft General Conformity Determination, pursuant to 40 C.F.R. part 93, subpart 

B, which establishes the process for complying with the General Conformity requirements of the 

Clean Air Act. FRA published a notice in the Federal Register on September 20, 2021 advising 

the public of the availability of the Draft Conformity Determination for a 30-day review and 

comment period. The draft Conformity Determination was published at http://www.regulations.

gov, Docket No. FRA-2021-0082. The comment period of the Draft Conformity Determination 

closed on October 20, 2021. FRA received one comment expressing support for the project and 

Draft General Conformity Determination. 

This Final General Conformity Determination documents the FRA’s finding that the Project

complies with the General Conformity Rule, that it conforms to the purposes of the area’s 

approved State Implementation Plan, and that it is consistent with all applicable requirements. 

The Final General Conformity Determination is available at http://www.regulations.gov, Docket 

No. FRA-2021-0082, and on FRA’s website at https://railroads.dot.gov/environment/

environmental-reviews/clean-air-act-california-general-conformity-determinations. This Final 

General Conformity Determination is based on the impact avoidance and minimization features 

and mitigation measures described in Section 3.3.4.3 and Section 3.3.7, respectively, of the 

Burbank to Los Angeles Section Final Environmental Impact Report/Environmental Impact 

Statement (Authority 2021) and that will be implemented for the Project. This compliance is 

demonstrated as follows:

• The operation of the Project 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 Project would exceed the 

General Conformity annual de minimis level, the Authority is committing to purchase the 

necessary offsets to bring all criteria pollutant emissions below the General Conformity de 

minimis levels. To implement this commitment, the Authority has executed an agreement with 

SCAQMD providing that after receipt of construction funding, but prior to the start of 

construction, the Authority and SCAQMD will enter into an agreement to ensure all 

construction emissions exceeding the de minimis levels will be offset through contributions to 

emissions reduction programs. The agreement will specify the applicable emissions 

reduction programs, which will be funded by the Authority, and administered by SCAQMD.

 

1

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

the north to Los Angeles and Anaheim in the south. 
Executive Summary

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Section 1 Introduction

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1 INTRODUCTION

This Final General Conformity Determination for the Burbank to Los Angeles Section of the 

California High-Speed Rail (HSR) System (“project” or “Project) was prepared consistent with 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 

failing to meet 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 that 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 conformity. This determination must demonstrate that the 

Project 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. Because the Project 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.

FRA prepared this Final General Conformity Determination after the release of the Burbank to 

Los Angeles Final Environmental Impact Report/Environmental Impact Statement (FEIR/FEIS), 

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 (USEPA) promulgated final 

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. Although the transportation conformity regulations do not apply to this Project

(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 

resource study area (RSA). 

The RSA for the Burbank to Los Angeles Project Section is the South Coast Air Basin. Planning 

documents for pollutants for which the RSA is classified as federal nonattainment or maintenance 

are developed by the South Coast Air Quality Management District (SCAQMD) and California Air 

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

documents relevant to the Project’s RSA. 
Section 1 Introduction

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Table 1 Planning Documents Relevant to the Resource Study Area

Type of Plan Status

SCAQMD 2016 Air Quality 

Management Plan

Approved by the SCAQMD Board of Directors in March 2017, the 2016 

AQMP demonstrates attainment for the 8-hour ozone NAAQS established in 

2008, the annual PM2.5 NAAQS established in 2012, and the 24-hour PM2.5

NAAQS established in 2006. In addition, the 2016 AQMP includes revisions 

to the attainment demonstrations for the 1997 8-hour ozone NAAQS and the 

1979 1-hour ozone NAAQS. The 2016 AQMP was submitted to USEPA on 

April 27, 2017, but no clean air determination has been made to date.

SCAQMD 2012 Air Quality 

Management Plan

Approved by the SCAQMD Board of Directors in February 2013, the 2012 

AQMP was submitted to demonstrate attainment for the 24-hour PM2.5

NAAQS established in 2006. On September 30, 2015, the USEPA proposed 

to approve elements of the South Coast 2012 PM2.5 Plan and 2015 

Supplement, which addressed Clean Air Act requirements for the 2006 

PM2.5 NAAQS, and proposed to reclassify the area as a 'Serious' 

nonattainment area for the 2006 PM2.5 standard. The USEPA provided a 30-

day public comment period from the date of publication in the Federal 

Register. On March 15, 2016, the USEPA approved in part and disapproved 

in part those portions of the SCAQMD’s 2012 Air Quality Management Plan 

(2012 PM2.5 Plan) that address attainment of the 2006 24-hour PM2.5

standards and the 2015 Supplement to the 2012 PM2.5 Plan. To correct 

these deficiencies, the state was required to submit to the USEPA a 

demonstration that the NOx RECLAIM program, either as adopted in 2010 or 

as subsequently amended, ensures emissions reductions equivalent, in the 

aggregate, to the reductions anticipated from the direct application of 

reasonably available control technology on covered sources.

2010 South Coast Air Basin 

Request for PM10 Redesignation 

Request and Maintenance Plan

On April 28, 2010, the CARB submitted Request for PM10 Redesignation 

and Maintenance Plan to the USEPA. On June 12, 2013, the USEPA's 

Regional Administrator signed a final rule to approve the South Coast PM10

Redesignation Request and Maintenance Plan. The plan was developed 

and adopted by SCAQMD, and showed how the area would maintain the 

PM10 standard for at least the next 10 years.

2005 South Coast Air Basin 

Request for CO Maintenance Plan 

and Redesignation Request

On February 24, 2006, the CARB transmitted the Redesignation Request 

and Maintenance Plan (including the CO budgets) to the USEPA for 

approval. In addition, on August 11, 2006, the CARB provided information to 

the USEPA that demonstrates the Smog Check program satisfies federal 

I&M requirements for CO and provides emission reductions necessary for 

continued improvement in CO air quality. On April 24, 2007, USEPA’s 

Regional Administrator signed a final rule to approve the South Coast 

Maintenance Plan and Redesignation Request for Carbon Monoxide.

Sources: South Coast Air Quality Management District, 2006, 2011, 2013, 2017

CAA = Clean Air Act PM2.5 = particulate matter smaller than or equal to 2.5 microns in diameter

CARB = California Air Resources Board RECLAIM = Regional Clean Air Incentive Market

CO = carbon monoxide SCAQMD = South Coast Air Quality Management District

I&M = inspection and maintenance SIP = State Implementation Plan

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

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

1.2 General Conformity Requirements

On November 30, 1993, the 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. Because the Project will not be funded or require approval(s) under Title 23 U.S.
Section 1 Introduction

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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.

During the applicability analysis, the federal agency determines: 

• 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 

transportation improvement plan, the federal agency determines that the emissions from the 

Project 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 

Project is described in Section 7. If after the applicability analysis, the Federal agency concludes 

it should conduct a conformity determination, it may 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 1 Introduction

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Section 2 California High Speed Rail Project

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2 CALIFORNIA HIGH SPEED RAIL PROJECT

2.1 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 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 over a fully grade-separated, dedicated guideway 

alignment.

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

implementation of the High-Speed Intercity Passenger Rail financial assistance program. As part

of the High-Speed Intercity Passenger Rail 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 Title 23 Section 327, under the NEPA Assignment 

Memorandum of Understanding between the 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 performs Clean Air Act Conformity 

determinations and other federal approvals retained by the FRA under the NEPA Assignment 

Memorandum of Understanding. 

2.2 California High Speed Rail System – Burbank to Los Angeles Section 

The Burbank to Los Angeles Project Section of the California HSR System is approximately 

14 miles long, crossing the cities of Burbank, Glendale, and Los Angeles on an existing railroad 

corridor. HSR for this project section would be within a narrow and constrained urban 

environment, crossing major streets and highways and, in some portions, adjacent to the Los 

Angeles River. The Los Angeles County Metropolitan Transportation Authority owns the railroad

right-of-way, the Southern California Regional Rail Authority owns the track and operates the 

Metrolink commuter rail service, the National Railroad Passenger Corporation (Amtrak) provides 

intercity passenger service, and the Union Pacific Railroad holds track access rights and operates 

freight trains.

The Burbank to Los Angeles Project Section includes new and upgraded track, maintenance 

facilities, grade separations, drainage improvements, communications towers, security fencing, 

passenger train stations, and other necessary facilities to introduce HSR service into the Los 

Angeles-San Diego-San Luis Obispo corridor from near Hollywood Burbank Airport to Los 

Angeles Union Station. In portions of the alignment, new and upgraded tracks would allow other

passenger trains to share tracks with the HSR system. HSR stations would be located near 

Hollywood Burbank Airport and at Los Angeles Union Station. The alignment would be entirely 

grade-separated at crossings, meaning that roads, railroads, and other transport facilities would 

be at different heights so the HSR system would not interrupt or interface with other modes of 

transport, including vehicle, bicycle, and pedestrian.

For most of the project section, the HSR alignment would be within the existing railroad right-ofway, which is typically 70 to 100 feet wide. The HSR alignment includes northbound and 

southbound electrified tracks for high-speed trains. The right-of-way would be fenced to prohibit 

pedestrian and public or unauthorized vehicle access. 

The project footprint (the area required to build, operate, and maintain HSR service) is based on 

the following elements of design: station areas, hydrology, track, roadway, structures, systems, 

and utilities.
Section 2 California High Speed Rail Project

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The Burbank to Los Angeles Project Section includes a combination of at-grade, below-grade, 

and retained-fill track, depending on corridor and design constraints. The at-grade and retainedfill portions of the alignment would be designed with structural flexibility to accommodate shared 

operations with other passenger rail operators. Throughout most of the project section (between 

Alameda Avenue and State Route 110), two new electrified tracks would be placed along the 

west side of the existing railroad right-of-way and would be useable for HSR and other passenger 

rail operators. The existing non-electrified tracks would be realigned closer to the east side of the 

existing right-of-way, for a total of four tracks; these realigned, non-electrified tracks would be 

usable for freight and other passenger rail operators, but not for HSR. 

Throughout most of the Burbank to Los Angeles Project Section, the electrified track centerline 

and the non-electrified track centerline would have a minimum separation of 23.5 feet, and the 

northbound and southbound electrified tracks would have a separation of 16.5 feet, following the 

Authority and FRA’s Technical Memorandum 1.1.21 Typical Cross Sections for 15% Design

(2013). 

However, in several areas of the corridor, the right-of-way is less than 100 feet wide, a threshold 

that constrains the design. As a result, reduced track separations were used in these constrained 

areas in order to stay within the existing right-of-way to the greatest extent possible and thus 

minimize property impacts. The reduced separations between the electrified and non-electrified 

track centerlines would be a minimum of 16.5 feet, and between the two electrified track 

centerlines would be 15 feet. 
Section 3 Air Quality Conditions in the Study Area

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3 AIR QUALITY CONDITIONS IN THE STUDY AREA

3.1 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 South Coast Air Basin covers 6,745 square miles and includes all of Orange County, Los 

Angeles County except for the Antelope Valley, the non-desert portion of western San Bernardino 

County, and the western and Coachella Valley portions of Riverside County.

Low average wind speeds, together with a persistent temperature inversion, limit the vertical 

dispersion of air pollutants throughout the South Coast Air Basin. Strong, dry, north or 

northeasterly winds, known as Santa Ana winds, occur during the fall and winter months, 

dispersing air contaminants. The Santa Ana conditions tend to last for several days at a time. 

The combination of stagnant wind conditions and low inversions produces the greatest pollutant 

concentrations. On days of no inversion or high wind speeds, ambient air pollutant concentrations are 

the lowest. During periods of low inversions and low wind speeds, air pollutants generated in 

urbanized areas are transported into Riverside and San Bernardino Counties. In the winter, the 

greatest pollution problems are carbon monoxide (CO) and nitrogen oxides (NOX) because of 

extremely low inversions and air stagnation during the night and early morning hours. In the summer, 

the longer daylight hours and the brighter sunshine combine to cause a reaction between 

hydrocarbons and NOX to form photochemical smog.

The annual average temperature varies little throughout the South Coast Air Basin, ranging from 

the low- to middle-60s degrees Fahrenheit. With a more pronounced oceanic influence, coastal 

areas show less variability in annual minimum and maximum temperatures than inland areas. 

Much of the annual rainfall in the South Coast Air Basin occurs between November and April. 

Summer rainfall is minimal and is generally limited to scattered thundershowers in coastal regions 

and slightly heavier showers in the eastern portion of the South Coast Air Basin and along the 

coastal side of the mountains. Average monthly rainfall during that period varies from 3.80 inches 

in February to 0.01 inch or less between June and July, with an annual total of 16.35 inches. 

Patterns in monthly and yearly rainfall totals are unpredictable due to fluctuations in the weather.

The South Coast Air Basin intermittently experiences a temperature inversion (increasing 

temperature with increasing altitude) because of the Pacific High. This inversion limits the vertical 

dispersion of air contaminants, holding them relatively near the ground. As the sun warms the 

ground and the lower air layer, the temperature of the lower air layer approaches the temperature of 

the base of the inversion (upper) layer until the inversion layer finally breaks, allowing vertical mixing 

with the lower layer. This phenomenon is observed in mid-afternoon to late afternoon on hot 

summer days when the smog appears to clear up suddenly. Winter inversions frequently break by 

midmorning.

3.2 Ambient Air Quality in the Study Area

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

stations nearest to the local RSA are the 1630 N Main Street station in the city of Los Angeles 

and the 752 Wilson Avenue station in the city of Pasadena. Monitoring data from these stations 

are shown in Table 2. The stations monitor CO, ozone (O3), nitrogen dioxide (NO2), particulate 

matter 10 microns or less in diameter (PM10), particulate matter 2.5 microns or less in diameter

(PM2.5), and sulfur dioxide (SO2). Locations for the monitoring stations are shown on Figure 1. 

A summary of the monitoring data includes the following: 

• Monitored data from 2016 through 2018 do not exceed either the state or federal standards 

for CO. 
Section 3 Air Quality Conditions in the Study Area

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Figure 1 Air Quality Monitoring Stations Closest to the Project
Section 3 Air Quality Conditions in the Study Area

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

Air 

Pollutant Standard/Exceedance

1630 N Main Street 

Los Angeles

752 Wilson Avenue 

Pasadena

2016 2017 2018 2016 2017 2018

Carbon 

Monoxide 

(CO)3

Year Coverage NM NM NM NM NM NM

Max. 1-hour Concentration (ppm) 1.9 2.0 2.0 1.5 2.2 2.0

Max. 8-hour Concentration (ppm) 1.4 1.8 1.7 1.0 1.7 1.4

Number of Days>Federal 1-hour Standard of >35 ppm 0 0 0 0 0 0

Number of Days>Federal 8-hour Standard of >9 ppm 0 0 0 0 0 0

Number of Days>California 8-hour Standard of >9 ppm 0 0 0 0 0 0

Ozone (O3) Year Coverage1 98% 96% 96% 95% 96% 98%

Max. 1-hour Concentration (ppm) 0.103 0.116 0.098 0.126 0.139 0.112

Max. 8-hour Concentration (ppm) 0.078 0.086 0.073 0.090 0.100 0.090

Number of Days>Federal 8-hour Standard of >0.075 ppm 4 14 4 18 36 19

Number of Days>California 1-hour Standard of >0.09 ppm 2 6 2 12 18 8

Number of Days>California 8-hour Standard of >0.07 ppm 4 16 4 19 38 20

Nitrogen 

Dioxide 

(NO2) 

Year Coverage 97% 95% 97% 96% 94% 95%

Max. 1-hour Concentration (ppm) 64.7 80.6 70.1 71.9 72.3 68.2

Annual Average (ppm) 21 21 19 15 15 14

Number of Days>Federal 1-hour Standard of >100 ppm 0 0 0 0 0 0

Sulfur 

Dioxide 

(SO2) 

Year Coverage 13.4 5.7 17.9 NM NM NM

Max. 24-hour Concentration (ppm) 1.3 1.5 1.3 NM NM NM

Annual Average (ppm) 0.30 0.36 0.34 NM NM NM

Number of Days>California 24-hour Standard of >0.04 ppm 0 0 0 NM NM NM
Section 3 Air Quality Conditions in the Study Area

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Air 

Pollutant Standard/Exceedance

1630 N Main Street 

Los Angeles

752 Wilson Avenue 

Pasadena

2016 2017 2018 2016 2017 2018

Respirable 

Particulate 

Matter 

(PM10) 

Year Coverage 98% 94% 90% NM NM NM

Max. 24-hour Concentration (μg/m3)2 74.6 96.2 81.2 NM NM NM

Number of Days>Federal 24-hour Standard of >150 μg/m3 0 0 0 NM NM NM

Number of Days>California 24-hour Standard of >50 μg/m3 21 40 31 NM NM NM

Annual Average2 (μg/m3) 25.8 25.7 30.2 NM NM NM

Fine 

Particulate 

Matter 

(PM2.5) 

Year Coverage 98% 98% 95% 98% 100% 99%

Max. 24-hour Concentration (μg/m3) 49.4 61.7 65.3 29.2 22.8 32.5

State Annual Average (μg/m3) 12.0 16.3 16.0 9.5 9.7 10.3

Number of Days>Federal 24-hour Standard of >35 μg/m3 2 6 6 0 0 0

Annual Average2 (μg/m3) 11.7 12.0 12.8 9.5 9.6 10.2

Source: California Air Resources Board, 2019 and U.S. Environmental Protection Agency, 2019 1 Coverage is for the 8-hour standard. 2 Coverage is for the national standard.

3 CO data for the 752 Wilson Avenue, Pasadena station monitoring site.

> = greater than

μg/m3 = micrograms per cubic meter

CARB = California Air Resources Board

Max. = maximum

NM = not monitored

PM2.5 = particulate matter 2.5 microns or less in diameter

PM10 = particulate matter 10 microns or less in diameter

ppm = parts per million
Section 3 Air Quality Conditions in the Study Area

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• O3 values for the region exceed the national 8-hour O3 standards at all stations for every year. 

O3 values exceed the state 8-hour O3 standards at both stations every year from 2016

through 2018. O3 values for the region also exceed the state 1-hour O3 standard at both

stations for every year from 2016 through 2018. 

• The PM10 values for the region did not exceed the national 24-hour PM10 standard. The state 

24-hour PM10 standard was exceeded at the Los Angeles station for every year. PM10

emissions were not measured at the Pasadena station from 2016 through 2018. 

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

Angeles station for the years 2016, 2017, and 2018. The Los Angeles station exceeded the 

national 24-hour PM2.5 standard between 2016 and 2018. 

• SO2 values were not exceeded at any of the two stations between 2016 and 2018. SO2

emissions were not measured at the Pasadena station from 2016 through 2018.

• The 1-hour and annual NO2 values were not exceeded at any of the two stations between 

2016 and 2018. 

3.3 Study Area Emissions

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

inventory for the South Coast Air Basin consists of data submitted to CARB by the SCAQMD plus 

estimates for certain source categories, which are provided by CARB staff. Table 3 summarizes 

the 2019 inventory data for the SCAQMD. Note that Table 3 shows tons per day, whereas the 

emissions estimates for the Project are shown in tons per year. 

In the SCAQMD, mobile-source emissions account for more than 90 and 80 percent of the South 

Coast Air Basin’s CO and NOX emissions, respectively. Mobile-source emissions also account for 

more than 40 percent of the South Coast Air Basin’s reactive organic gas emissions. Area-source 

emissions account for approximately 80 percent of the South Coast Air Basin’s PM, and 

stationary sources account for more than 70 and 50 percent, respectively, of the South Coast Air 

Basin’s total organic gases and SOX emissions. 

3.4 Project Study Area Designations

Under the federal criteria, the South Coast Air Basin is currently designated as nonattainment for 

the federal 8-hour O3, PM2.5, and lead standards; unclassified for the federal NO2 and SO2

standards; attainment/maintenance for the federal PM10 and CO standards; and 

attainment/unclassified for all other standards. The South Coast Air Basin is considered in 

nonattainment for the state 1-hour O3, 8-hour O3, PM2.5, and PM10 standards; unclassified for the 

state CO standards; in attainment for the state NO2, SO2, and lead standards; and in 

attainment/unclassified for all other state standards.
Section 3 Air Quality Conditions in the Study Area

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Table 3 Estimated 2019 Annual Average Emissions for the South Coast Air Quality 

Management District (tons/day)

Source Category TOG ROG CO NOX SOX PM PM10 PM2.5

Stationary Sources

Fuel Combustion 53.06 11.56 49.18 44.23 6.27 5.82 5.65 5.55

Waste Disposal 696.57 14.65 1.12 2.47 0.59 0.36 0.25 0.23

Cleaning and Surface Coatings 106.16 43.66 0.07 0.04 0.00 1.84 1.77 1.71

Petroleum Production and Marketing 68.20 21.17 5.20 1.30 2.09 2.66 1.74 1.53

Total Industrial Processes 14.10 11.96 0.52 0.46 0.26 18.11 12.29 7.27

Total Stationary Sources 938.09 102.99 56.08 48.51 9.22 28.80 21.70 16.28

Stationary Sources Percentage of Total 72.2% 26.5% 3.8% 12.8% 58.0% 9.5% 12.0% 24.2%

Area-wide Sources

Solvent Evaporation 124.82 105.60 – – – 0.03 0.03 0.03

Miscellaneous Processes 47.30 13.40 58.37 14.88 0.54 240.51 125.68 33.51

Total Area-wide Sources 172.11 119.00 58.37 14.88 0.54 240.54 125.71 33.54

Area-wide Sources Percentage of Total 13.3% 30.6% 3.9% 3.9% 3.4% 79.4% 69.8% 49.8%

Mobile Sources

On-Road Motor Vehicles 96.59 85.90 659.96 179.15 1.92 25.89 25.38 11.27

Other Mobile Sources 91.63 81.25 717.48 136.96 4.23 7.71 7.35 6.25

Total Mobile Sources 188.21 167.15 1377.45 316.10 6.15 33.60 32.72 17.52

Mobile Sources Percentage of Total 14.5% 43.0% 92.3% 83.3% 38.7% 11.1% 18.2% 26.0%

Grand Total 1,298.41 389.14 1,491.90 379.49 15.91 302.93 180.13 67.34

Source: California Air Resources Board, 2018 

Rounded to the nearest percentage; category percentages do not sum to 100 percent due to rounding.

CO = carbon monoxide ROG = reactive organic gas

NOX = nitrogen oxides SCAQMD = South Coast Air Quality Management District

PM = particulate matter SOX = sulfur oxides

PM10 = particulate matter smaller than or equal to 10 microns in diameter TOG = total organic gas

PM2.5 = particulate matter smaller than or equal to 2.5 microns in diameter
Section 4 Relationship to NEPA

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4 RELATIONSHIP TO NEPA

The Burbank to Los Angeles Project Section Final EIR/EIS identifies potential environmental 

impacts of the Project, 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 Project’s implementation be analyzed and disclosed. For purposes 

of NEPA, the air quality impacts of the Project were determined by identifying the Project’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 Project 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, and 3.3.8 of the EIR/EIS.

To appropriately identify and offset, where necessary, the emissions resulting from the Burbank 

to Los Angeles section of the HSR system, the FRA is issuing this final General Conformity 

Determination. The Authority is committing to the purchase of additional offsets to net all criteria 

pollutant emissions to levels that are below the General Conformity de minimis level for each 

calendar year that exceedances occur.
Section 4 Relationship to NEPA

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Section 5 Avoidance and Mitigation Measures to Reduce Emissions to be Incorporated in the Project

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5 AVOIDANCE AND MITIGATION MEASURES TO REDUCE EMISSIONS 

TO BE INCORPORATED IN THE PROJECT

To reduce impacts on the environment and as required by NEPA and CEQA, the construction of 

the Project will include impact avoidance and minimization features and mitigation measures that 

will be implemented as part of the Project to minimize, avoid, and mitigate air quality impacts. 

These impact avoidance and minimization features (IAMF) and mitigation measures will be 

required components of the Project. They will be included in the Mitigation Monitoring and 

Enforcement Program, which will be issued concurrently with the Authority’s Record of Decision

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

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

IAMFs and mitigation measures into the construction contract, which will create binding and 

enforceable commitments 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 design features 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.
Section 5 Avoidance and Mitigation Measures to Reduce Emissions to be Incorporated in the Project

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− 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. 

− 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 South Coast 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 South Coast 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 percent 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 5 Avoidance and Mitigation Measures to Reduce Emissions to be Incorporated in the Project

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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 vehicle miles traveled (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 project’s construction emissions that cannot be reduced by IAMFs and any other mitigation 

measures, will be offset through a South Coast Air Quality Management District (SCAQMD) rule 

or contractual agreement by funding equivalent emissions reductions that achieve reductions in 

the same years as construction emissions occur, thus offsetting project-related air quality impacts 

in real time. The project will implement measures and best practices to minimize emissions from 

project construction. After implementation of these measures, emission levels that still exceed 

thresholds will be offset to the extent necessary to satisfy General Conformity. The Authority’s 

Sustainability Policy has a goal to achieve net zero emissions from construction. As this project 

section advances through project delivery towards construction, the Authority will work with 

SCAQMD to assess the estimated emissions, availability of offsets, and cost for achieving the 

Authority’s Sustainability Policy goal to the extent possible. 

AQ-MM#2: Construction Emissions Reduction – Requirements for use of Zero Emission 

and/or Near Zero Emission Vehicles and Off-Road Equipment 

This mitigation measure would reduce the impact of construction emissions from project-related 

on-road vehicles and off-road equipment. All remaining emissions after implementation of this 

measure would be offset with emission credits required under Mitigation Measure AQ-MM#1.

The Authority and all project construction contractors will require that a minimum of 25 percent, 

with a goal of 100 percent, of all light-duty on-road vehicles (e.g., passenger cars, light-duty 

trucks) associated with the project (e.g., on-site vehicles, contractor vehicles) use zero-emission 

(ZE) or near-zero emission (NZE) technology.

The Authority and all project construction contractors will have the goal that a minimum of 25 

percent of all heavy-duty on-road vehicles (e.g., for hauling, material delivery and soil 

import/export) associated with the project use ZE or NZE technology. 

The Authority and all project construction contractors will have the goal that a minimum of 10 

percent of off-road construction equipment use ZE or NZE vehicles. 

If local or state regulations mandate a faster transition to using ZE and/or NZE vehicles at the 

time of construction, the more stringent regulations will be applied. For example, Executive Order 

(EO) N-79-20, issued by California Governor Newsom on September 23, 2020, currently states 

the following:

• Light duty and passenger car sales be 100 percent ZEV by 2035

• Full transition to ZEV short haul/drayage trucks by 2035

• Full transition to ZEV heavy-duty long-haul trucks, where feasible, by 2045

• Full transition to ZE off-road equipment by 2035, where feasible. 
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The project will have a goal of surpassing the requirements of these or other future regulations as 

a mitigation measure. 
Section 6 Regulatory Procedures

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6 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 Project. 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. This

Final General Conformity Determination will be published concurrent with the Authority’s Record 

of Decision for the Burbank to Los Angeles section of the HSR system. This Final 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 South Coast Air Basin. 

6.1 Use of Latest Planning Assumptions 

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

area encompassing the Project, derived from the estimates of population, employment, travel, 

and congestion most recently approved by the area’s metropolitan planning organization (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 metropolitan planning organizations for traffic volume growth 

rates, including forecast changes in vehicle miles traveled and vehicle hours traveled. The 

Authority developed these estimates based on the metropolitan planning organizations’ 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 Transportation Improvement Plan. 

6.2 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. 

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

roadway and rail bridges, retained-fill rail segments, and HSR stations (including parking areas 

and platform facilities) were calculated using the California Emissions Estimator Model 

(CalEEMod), which uses emission factors from the OFFROAD2011 model. The OFFROAD2011 

model provides the latest emission factors for construction off-road equipment and accounts for 

lower fleet population and growth factors because of the economic recession and updated load 

factors based on feedback from engine manufacturers. For emission rates not available in 

OFFROAD2011, rates from OFFROAD2007 were conservatively applied. The use of emission 

rates from the OFFROAD models reflects the recommendation of CARB to capture the latest offroad construction assumptions. OFFROAD2011 default load factors (the ratio of average 

equipment horsepower used to maximum equipment horsepower) and useful life parameters 
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were used for emission estimates. Mobile-source emission burdens from worker vehicle trips and 

truck trips were calculated using vehicle miles traveled estimates and appropriate emission 

factors from EMFAC2014. Fugitive dust emissions from dirt and aggregate handling were 

calculated in CalEEMod, which uses emission factors derived from equations from the USEPA’s 

AP-42 (USEPA 2006). 

Construction exhaust emissions from equipment, fugitive dust emissions from earthmoving 

activities, and emissions from worker vehicle trips, deliveries, and materials hauling were 

calculated and compiled in a spreadsheet tool specific to the HSR Build Alternative for each year 

of construction. Project-specific data, including construction equipment lists and the construction 

schedule, were used for construction associated with the HSR Build Alternative. Construction 

exhaust emissions were modeled using Tier 4 emission rates (AQ-IAMF#4) from CalEEMod.

Fugitive dust reductions from earthmoving best management practices were applied in 

CalEEMod (AQ-IAMF#1)2. PM exhaust and greenhouse gas emission reductions (30 percent and 

99.1 percent, respectively) would occur from use of renewable diesel (AQ-IAMF#3) in all off-road 

diesel-powered engines (not applied in CalEEMod, instead applied by manual calculations in the 

Tables).

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

miles traveled estimates and appropriate emission factors from EMFAC2014. Model year 2010 or 

newer on-road engines in heavy-duty, diesel powered truck emissions (AQ-IAMF#5) were 

modeled using emission rates derived from the CalEEMod. 

6.3 Major Construction-Phase Activities

Project-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 8 

of this report): 

• Land Clearing

• Land Clearing Haul Roads

• Earthmoving

• Tunneling Cut-and-Cover

• Materials Handling

• Laying Track At Grade

• System Facilities

• Buildings Demolition

• Bridge Demolition

• Elevated Structures Roads

• Elevated Structures Rail

• Roadway Construction

• Burbank Airport Station Construction

• Maintenance Station Facilities

• Los Angeles Union Station Platform Construction

These major construction activities are used in the construction emission estimates. Construction 

exhaust emissions were modeled using Tier 4 construction equipment emission rates (AQIAMF#4) from CalEEMod. Fugitive dust reductions from earthmoving best management practices 

were applied in CalEEMod (AQ-IAMF#1). PM exhaust and GHG emission reductions (30 percent 

and 99.1 percent, respectively) would occur from use of renewable diesel (AQ-IAMF#3) in all offroad diesel-powered engines (not applied in CalEEMod, instead applied by manual calculations in 

the Tables). Mobile-source emission burdens from worker trips and truck trips were calculated 

 

2

 The IAMF requires watering on all unpaved surfaces, which would achieve additional reductions (up to 61 percent). 
Section 6 Regulatory Procedures

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using VMT estimates and appropriate emission factors from EMFAC2014. Model year 2010 or 

newer on-road engines in heavy-duty, diesel powered truck emissions (AQ-IAMF#5) were 

modeled using emission rates derived from the CalEEMod. Section 9.0 provides details of the 

construction emission calculations. 

6.4 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 Project 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 Project. 

• 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 Project would be less than those emitted in the No-Build 

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.

• 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 

Project’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

levels. 

Annual emissions were estimated for each year of the Project’s construction period. These 

emissions, which are the maximum values for the Project, are described in more detail in Section 

9 of this report.
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Section 7 Applicability Analysis

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7 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 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.

7.1 Attainment Status of Project Area

The USEPA and the 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 4 summarizes the federal (under 

NAAQS) and state (under California Ambient Air Quality Standards) attainment status for the 

South Coast Air Basin. 

Table 4 Federal and State Attainment Status 

Pollutant Federal Classification State Classification 

O3 1-hour N/A Nonattainment

O3 8-hour Nonattainment Nonattainment

PM2.5 Nonattainment Nonattainment

PM10 Attainment/Maintenance Nonattainment

CO Attainment/Maintenance Attainment

NO2 Attainment/Unclassified Attainment

SO2 Attainment/Unclassified Attainment/Unclassified

Lead Nonattainment Attainment

All Others Attainment/Unclassified Attainment/Unclassified 

Source: California Air Resources Board, 2019

CO = carbon monoxide PM2.5 = particulate matter 2.5 microns or less in diameter

NO2 = nitrogen dioxide PM10 = particulate matter 10 microns or less in diameter

NOX = nitrogen oxides SO2 = sulfur dioxide

O3 = ozone
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Section 8 Construction Activities Considered

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8 CONSTRUCTION ACTIVITIES CONSIDERED 

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

Project 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 Project 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 focuses on the emissions generated from the 

construction period emissions for the Burbank to Los Angeles Project Section. 

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:

• 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

• 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 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 discusses 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 Burbank 

to Los Angeles Project Section: Air Quality and Global Climate Change Technical Report for this 

Project (Authority 2020).

Construction activities associated with the Project would result in criteria pollutant and 

greenhouse gas emissions. Construction emissions for the Project are quantified and analyzed in 

Section 3.3.6.3 of the EIR/EIS. The analysis assumed that project construction would take place

from 2020 to 2028. Although the construction schedule has been updated, the analysis is still 

valid as the equipment quantities and annual emission rates would remain unchanged. 

8.1 Site Preparation

8.1.1 Demolition

For purposes of this air quality analysis, demolition of existing structures along the HSR 

alignment and HSR stations would take place from December 2020 through October 2021. 

Demolition emissions were calculated using CalEEMod using the project specific equipment list. 
Section 8 Construction Activities Considered

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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. 

8.1.2 Land Clearing/Grubbing

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

Emissions from land grubbing were estimated using OFFROAD 2011 emission factors as well as 

a site-specific equipment list. For purposes of this air quality analysis, land clearing and grubbing 

was assumed to take place along the route ahead of earthmoving and to construct haul roads 

from January 2020 to July 2025. Fugitive dust from land-grubbing activities includes that from 

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

8.2 Earthmoving

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

construction. For purposes of this air quality analysis, earthmoving would take place from January 

2020 to January 2025. 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 earthmoving activities includes that from worker trips, 

construction equipment exhaust, and truck-hauling exhaust. 

8.3 Trenching/Tunneling

The trenching and tunneling activities include excavation, cut/fill activities, and concrete 

installation for the below-grade portion of the HSR alignment. Cut-and-cover equipment would be 

used to cut through the ground, progressively installing concrete linings to support the excavated 

trench. The excavated material would be transported through the machine to the surface for 

removal by trucks. For purposes of this air quality analysis, the sequential excavation method and 

cut-and-cover activities would take place from January 2020 to January 2026. The emissions 

associated with the cut-and-cover activities were estimated using CalEEMod with OFFROAD 

2011 emission factors, in conjunction with the site-specific equipment list. Fugitive dust includes 

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

8.4 High-Speed Rail Alignment Construction 

For purposes of this air quality analysis, the HSR alignment construction is expected to take place

from January 2020 to January 2027. Although the construction schedule has been updated, the 

analysis is still valid, as the equipment quantities and annual emission rates would remain 

unchanged. The construction analysis includes the following construction phases: 

• Constructing roadway and rail bridges

• Laying cut-and-cover rail, retained-fill rail, and at-grade rail 

Emissions from construction of the track were calculated using CalEEMod. Equipment counts, 

horsepower, hours of operation, and load factors used in CalEEMod are included in Appendix A 

of the Burbank to Los Angeles Project Section: Air Quality and Global Climate Change Technical 

Report for this Project (Authority 2020).

8.4.1 Material Hauling

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

materials) to the construction site were calculated using heavy-duty truck emission factors from 

EMFAC2014 and anticipated travel distances of haul trucks within the South Coast Air Basin. 

Quarries with 200 or more acres of permitted area are considered to be of sufficient size to 

effectively serve the demand (URS et al. 2011). At least three quarries in the vicinity of the project 

met this criterion; however, it was assumed that the smallest number of quarries would be used 

for efficiency. Therefore, one quarry with the largest acreage nearest to the project vicinity was 

selected for this analysis. Ballast-hauling activities would take place with the use of locomotives. 

Locomotive activity would take place in two working days. 
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8.4.2 System Facilities

For purposes of this air quality analysis, system facilities construction is expected from January 

2022 to July 2028. 

8.5 Station Construction

Emissions from Burbank Airport Station construction would result from mass site grading and 

excavation, underground and above-ground facility construction (i.e., train-boarding platforms, the 

station building, pick-up/drop-off facilities for private automobiles, and the transit center for buses 

and shuttles), asphalt paving activates for surface roadways and parking areas, and architectural 

coatings. Emissions from Los Angeles Union Station would be a result of construction activities

for raising the existing platforms and installation of the overhead catenary system. Where 

applicable, emissions resulting from worker trips, vendor trips, and construction equipment 

exhaust were included. CalEEMod was used to estimate emissions from the construction phases 

of the HSR stations.

8.6 Roadway Crossing Construction

The HSR Build Alternative would include the relocation and the expansion of local roads and

roadway undercrossings and overcrossings, and reconstruction of several intersections to provide 

grade separations between roads and the HSR Alignment. Roadway demolition emissions are 

included in the CalEEMod analysis using the project-specific equipment list. Roadway project 

construction would begin in July 2021 and be completed by January 2027. Based on projectspecific data, a simplified construction schedule was used to estimate construction emissions. 

8.7 Early Action Project Construction 

As described in Chapter 2 of the EIR/EIS, early action projects would be completed in 

collaboration with local and regional agencies, and they include grade separations and 

improvements at regional passenger rail stations. These early action projects are analyzed in 

further detail to allow the agencies to adopt the findings and mitigation measures as needed to 

construct the projects. The early action projects would include four roadway undercrossing grade 

separations (i.e., Sonora Avenue, Grandview Avenue, Flower Street, and Goodwin 

Avenue/Chevy Chase Drive), one roadway overcrossing grade separation (i.e., Main Street) and 

improvements at a regional passenger rail station (Burbank Metrolink Station). The projects are 

described in more detail in Section 2.6 of the Burbank to Los Angeles Project Section: Air Quality

and Global Climate Change Technical Report for this Project [Authority 2020]. 

Construction emissions include exhaust emissions from heavy equipment used during the 

construction phase of each of the project components. The bulk of the construction activities 

would occur simultaneously and were broken down on a project-by-project component basis to 

evaluate the construction activities that would take place at a particular location during a peak day 

and average calendar year period. The construction schedule analysis was used to identify the 

type and number of equipment that would operate on a typical workday during the period of 

maximum construction activity. The number of each type of equipment was entered into a 

spreadsheet. Emission factors from the CARB’s OFFROAD2011, EMFAC2014, and HSR 

inventory of air emissions were identified for each type of equipment and for heavy-duty trucks.

Peak day and annual average emissions then were determined by summing emissions from 

overlapping construction activities as indicated in the proposed construction schedule. 
Section 8 Construction Activities Considered

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Section 9 Estimated Emissions Rates and Comparison to De Minimis Thresholds – Burbank-Los Angeles

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9 ESTIMATED EMISSIONS RATES AND COMPARISON TO DE MINIMIS 

THRESHOLDS – BURBANK-LOS ANGELES

Total annual estimated emissions generated within the South Coast Air Basin during the Project’s 

construction period, as presented in the HSR EIR/EIS, are provided in Table 5. As shown in the 

table, direct emissions from the construction phase of the Burbank to Los Angeles Project Section 

would exceed the GC applicability level for NOx in certain calendar years in which construction 

would take place. The following shows the maximum estimated annual values of each pollutant, 

by non-attainment or maintenance area, and the percentage of the 2019 estimated emission 

rates in the South Coast Air Basin (see Table 3) for Burbank to Los Angeles Project Section 

construction:

• VOC: 3.09 tons per year (tpy) (<0.01%)

• CO: 72.16 tpy (0.01%)

• NOx: 22.07 tpy (<0.01%)

• SOx: 0.18 tpy (<0.01%)

• PM10: 16.07 tpy (0.02%)

• PM2.5: 2.94 tpy (0.01%)

Table 5 Estimated Annual Average Emissions 

Pollutants

Emissions (Tons/Year)3 Conformity 

Applicability 

Level 

(tons/year)2 2020 2021 2022 2023 2024 2025 2026 2027 2028 

VOC 1.21 2.55 3.09 2.57 2.87 0.05 0.05 0.06 0.05 10 

CO 28.95 57.34 65.28 63.29 72.16 1.85 1.84 1.85 1.86 100

NOx 11.88 22.07 20.88 16.49 20.46 0.22 0.22 0.22 0.22 10 

SOx 0.07 0.15 0.16 0.16 0.18 0.00 0.00 0.00 0.00 N/A 

PM101 9.57 13.02 13.69 13.58 16.07 0.20 0.20 0.20 0.20 100

PM2.51 1.66 2.50 2.68 2.62 2.94 0.03 0.03 0.03 0.03 70 

Source: California High-Speed Rail Authority, 2020

Note: Bold values exceed applicability thresholds 1 The PM10 and PM2.5 emissions consist of exhaust and fugitive dust emissions. 2 Pursuant to NEPA, effects on air quality would be considered an impact if the HSR Build Alternative criteria pollutant emissions would be equal to 

or exceed the general conformity de minimis levels in a nonattainment or maintenance area. It is currently assumed that general conformity would 

apply only to construction of the HSR Build Alternative, as operation of the HSR Build Alternative is expected to decrease regional emissions of 

criteria pollutants. 3 The emissions presented in this table reflect the impact of the Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule, per the California Air 

Resources 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).

CO = carbon monoxide PM10 = particulate matter 10 microns or less in diameter

HSR = high-speed rail SCAQMD = South Coast Air Quality Management District

N/A = not applicable SOX = sulfur oxides

NEPA = National Environmental Policy Act tons/year = tons per year

NOX = nitrogen oxides VOC = volatile organic compound

PM2.5 = particulate matter 2.5 microns or less in diameter
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Section 10 Regional Effects

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10 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 Project than under No-Build conditions 

(and will therefore not exceed the de minimis emission level). As such, only emissions generated 

during the construction phase were compared to the conformity levels to determine conformity 

compliance. As shown in Table 5, construction-phase emissions, compared to the General 

Conformity applicability rates, are discussed below

• Annual estimated VOC emissions in the South Coast Air Basin are less than the applicability 

rate of 10 tons per year for construction in 2020 through 2028 for the HSR Project Alternative. 

• Annual estimated CO emissions in the South Coast Air Basin are less than the applicability 

rate of 100 tons per year for construction in 2020 through 2028 for the HSR Project 

Alternative. 

• Annual estimated NOx emissions are greater than the applicability rate of 10 tons per year in 

years 2020 through 2024 for the HSR Project Alternative. 

• Annual estimated PM10 emissions are less than the applicability rate of 100 tons per year for 

construction in 2020 through 2028 for the HSR Project Alternative. 

• Annual estimated PM2.5 emissions are less than the applicability rate of 70 tons per year for 

construction in 2020 through 2028 for the HSR Project Alternative. 

• There are no applicable thresholds for SOx annual emissions.

As such, a General Conformity Determination is required for this Project for NOx for the years 

during construction where the emissions would exceed the de minimis levels and do not meet any 

of the exceptions cited in 40 C.F.R. § 93.154(c). This Final Conformity Determination identifies 

the Authority’s commitment to the purchase of additional offsets to net all criteria pollutant 

emissions to levels that are below the General Conformity de minimis level for each calendar year 

that exceedances occur, as explained in Section 13. 
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Section 11 General Conformity Evaluation

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11 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 used to make the determination for the Project. 

11.1 Conformity Requirements of Project

Based on the results shown in Table 5, conformity determinations are required for constructionphase emissions for NOx because annual estimated emissions are greater than the applicability 

rates of 10 tpy for NOx in the South Coast Air Basin. 

11.2 Compliance with Conformity Requirements

NOx emissions caused by the construction of the Project that would exceed the General 

Conformity de minimis levels are considered to have the potential to cause air quality impacts.

The Authority has committed to the purchase of additional offsets to net all criteria pollutant 

emissions to levels that are below the General Conformity de minimis level for each calendar year 

that exceedances occur. 

The requirements for offsets would be implemented as part of the Project as described in the 

mitigation measures from the Final EIR/EIS:

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

Programs 

Emissions that cannot be reduced by IAMFs and any other mitigation measures, would be fully 

offset within the South Coast Air Basin through a South Coast Air Quality Management District 

(SCAQMD) rule or contractual agreement by funding equivalent emissions reductions that 

achieve reductions in the same years as construction emissions occur, thus offsetting projectrelated air quality impacts in real time. The project will implement measures and best practices to 

minimize emissions from project construction. After implementation of these measures, emission 

levels that still exceed thresholds will be offset to the extent necessary to satisfy General 

Conformity. The Authority’s Sustainability Policy has a goal to achieve net zero emissions from 

construction. As this project section advances through project delivery towards construction, the 

Authority will work with SCAQMD to assess the estimated emissions, availability of offsets, and 

cost for achieving the Authority’s Sustainability Policy goal to the extent possible. 

AQ-MM#2: Construction Emissions Reduction – Requirements for use of Zero Emission 

and/or Near Zero Emission Vehicles and Off-Road Equipment 

This mitigation measure would reduce the impact of construction emissions from project-related 

on-road vehicles and off-road equipment. All remaining emissions after implementation of this 

measure would be offset with emission credits required under Mitigation Measure AQ-MM#1.

The Authority and all project construction contractors will require that a minimum of 25 percent, 

with a goal of 100 percent, of all light-duty on-road vehicles (e.g., passenger cars, light-duty 

trucks) associated with the project (e.g., on-site vehicles, contractor vehicles) use zero emission 

(ZE) or near-zero emission (NZE) technology.

The Authority and all project construction contractors will have the goal that a minimum of 25 

percent of all heavy-duty on-road vehicles (e.g., for hauling, material delivery and soil 

import/export) associated with the project use ZE or NZE technology. 

The Authority and all project construction contractors will have the goal that a minimum of 10 

percent of off-road construction equipment use ZE or NZE vehicles. 

If local or state regulations mandate a faster transition to using ZE and/or NZE vehicles at the 

time of construction, the more stringent regulations will be applied. For example, Executive Order 

(EO) N-79-20, issued by California Governor Newsom on September 23, 2020, currently states 

the following:
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• Light duty and passenger car sales be 100 percent ZEV by 2035

• Full transition to ZEV short-haul/drayage trucks by 2035

• Full transition to ZEV heavy-duty long-haul trucks, where feasible, by 2045

• Full transition to ZE off-road equipment by 2035, where feasible. 

The project will have a goal of surpassing the requirements of these or other future regulations as 

a mitigation measure. 

11.3 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 Project were assessed for 

SIP consistency for this evaluation.

11.3.1 Applicable Requirements from the USEPA 

The USEPA has already promulgated, and will continue to promulgate, numerous 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. Because 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.

11.3.2 Applicable Requirements from the 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. Only the USEPA can set emission standards for preempted equipment.

11.3.3 Applicable Requirements from SCAQMD 

To support the attainment and maintenance of the NAAQS in the South Coast Air Basin, 

SCAQMD is primarily responsible for regulating emissions from stationary sources. SCAQMD

develops and updates its Air Quality Management Plan regularly to support the California SIP. 

While the Air Quality Management Plan 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.

11.3.4 Consistency with Applicable Requirements for the Authority

The Authority already complies with, and will continue to comply with, a number of rules and 

regulations implemented and enforced by federal, state, regional, and local agencies to protect 

and enhance ambient air quality in the South Coast Air Basin. 

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 SCAQMD rules that are standard practice and best 

management practices for construction in the SCAQMD and include control of emissions and 

exhaust:
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• SCAQMD Rule 402, Nuisance: This rule restricts the discharge of any contaminant in 

quantities that cause, or have a natural ability to cause, injury, damage, nuisance, or 

annoyance to businesses, property, or the public. The proposed project does not plan to 

discharge any contaminants in quantities that would cause injury to the public or property. 

• SCAQMD Rule 403, Fugitive Dust: This rule requires the prevention, reduction, or mitigation 

of fugitive dust emissions from a project site. Rule 403 restricts visible fugitive dust to a 

project property line, restricts the net PM10 emissions to less than 50 micrograms per cubic 

meter and restricts the tracking out of bulk materials onto public roads. Additionally, Rule 403 

requires an applicant to use one or more of the best available control measures (identified in 

the tables within the rule). Mitigation measures may include adding freeboard to haul 

vehicles, covering loose material on haul vehicles, using dust suppressants such as watering 

or chemical soil stabilizers, and/or ceasing all activities. 

• SCAQMD Rule 1113, Architectural Coatings: This rule limits the amount of VOCs from 

architectural coatings and solvents, which lowers the emissions of odorous compounds.
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Section 12 Reporting and Public Comments

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12 REPORTING AND PUBLIC COMMENTS

To support a decision concerning the Project, the FRA issued a 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 SCAQMD on a variety of technical and modeling issues. The 

Authority has also consulted with the USEPA and the CARB on the overall approach to general 

conformity.

12.1 Availability of Final General Conformity Determination

The FRA will provide copies of this Final General Conformity Determination to the appropriate 

regional offices of USEPA, CARB, and SCAQMD. The Final General Conformity Determination is 

available at the FRA website (https://railroads.dot.gov/environment/environmental-reviews/cleanair-act-california-general-conformity-determinations) and on FRA’s docket at 

https://www.regulations.gov/, Docket FRA-2021-0082. 
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Section 13 Findings and Conclusions

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13 FINDINGS AND CONCLUSIONS

FRA conducted a General Conformity evaluation pursuant to 40 C.F.R. Part 93 Subpart B, and 

based on the Authority’s coordination with USEPA, SCAQMD, and CARB. The General 

Conformity regulations apply at this time to this Project because the Project is in an area that is 

currently designated as nonattainment for the federal 8-hour O3, PM2.5, and lead standards; 

unclassified for the federal NO2 and SO2 standards; attainment/maintenance for the federal PM10

and CO standards; and attainment/unclassified for all other standards. The FRA has determined 

that the Project will conform to the approved SIP, based on an agreement between the Authority 

and SCAQMD to ensure that construction-phase NOx emissions will be offset to levels that are 

below the General Conformity de minimis level. The agreement between the Authority and 

SCAQMD (Appendix A to this document) provides, in part, for the following: 

• The Authority will work with SCAQMD to ensure the lowest levels of construction 

emissions are generated through the use of IAMFs and mitigation measures, outlined in 

this report, and rolling review of best available technologies, with priority given first to the 

use of zero emission (ZE) technology such as electric construction equipment and then to 

near-zero emission (NZE) technology.

• After receipt of construction funding but prior to construction start, the Authority will

o review emission estimates, revise if warranted, and present a final estimate for 

review and use by SCAQMD; and 

o if emissions exceed General Conformity de minimis thresholds, ensure all

remaining emissions, after implementation of the IAMFs and onsite mitigation 

measures, will be offset. Through a contractual agreement with SCAQMD, the 

Authority and SCAQMD will specify the applicable emissions reduction 

program(s), which will be funded by the Authority and administered by SCAQMD. 

Applicable emission reduction programs may include state or federal incentive 

programs that achieve emissions reductions by providing incentive funds for the 

incremental cost of cleaner than required engines and equipment.

o The Authority will not start construction until any necessary agreements are 

executed. 
Section 13 Findings and Conclusions

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Section 14 References

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14 REFERENCES

California Air Resources Board (CARB). 2018. Almanac Emissions Projection Data. 2019 

Estimated Annual Average Emissions. South Coast AQMD. 

https://www.arb.ca.gov/app/emsinv/fcemssumcat/fcemssumcat2016.php?_ga=2.1664773

67.825502129.1616506775-1397874119.1606087613 (accessed April 2021). 

———. 2019. National Ambient Air Quality Standards (NAAQS) and California Ambient Air 

Quality Standards (CAAQS) Attainment Status for South Coast Air Basin. February 2016. 

https://ww2.arb.ca.gov/resources/documents/maps-state-and-federal-area-designations

(accessed January 2021). 

———. 2019. iADAM: Air Quality Data Statistics. Top 4 Summary. https://www.arb.ca.gov/

adam/topfour/topfour1.php (accessed December 2019). 

California High-Speed Rail Authority (Authority). 2018. Los Angeles to Anaheim Project Section 

Air Quality and Global Climate Change Technical Report. December 2018.

———. 2019. Palmdale to Burbank Section Administrative Draft Environmental Impact 

Report/Environmental Impact Statement. September 2019. 

———. 2020. Burbank to Los Angeles Project Section: Air Quality and Global Climate Change 

Technical Report. November 2020.

———. 2021. Burbank to Los Angeles Section Final Environmental Impact Report/Environmental 

Impact Statement. March 2021. 

California High-Speed Rail Authority and Federal Railroad Administration (Authority and FRA).

2013. Technical Memorandum 1.1.21 Typical Cross Sections for 15% Design. August 

2013.

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, 2019. 

Office of Environmental Health Hazard Assessment (OEHHA). 2015. Air Toxics Hot Spots 

Program, Risk Assessment Guidelines, Guidance Manual for Preparation of Health Risk 

Assessments. February 2015. http://oehha.ca.gov/media/downloads/crnr/2015

guidancemanual.pdf (accessed August 2016). 

South Coast Air Quality Management District (SCAQMD). 2006. California State Implementation 

Plan (SIP) for Carbon Monoxide (CO) in the South Coast Air Basin. September 2006. 

https://ww3.arb.ca.gov/planning/sip/sccosip05/sccosip05.htm (accessed December 4, 

2019). 

———. 2009. 2010 South Coast Air Basin Request for PM10 Redesignation Request and 

Maintenance Plan. December 2009. https://ww3.arb.ca.gov/planning/sip/planarea/

scabsip/2010pm10maint.pdf (accessed December 4, 2019). 

———. 2013. Final 2026 Air Quality Management Plan. February 2013. https://www.aqmd.gov/

home/air-quality/clean-air-plans/air-quality-mgt-plan/final-2012-air-quality-managementplan (accessed August 2017). 

———. 2016. Final 2015 Annual Air Quality Monitoring Network Plan. July 2016. www.aqmd.gov/

docs/default-source/clean-air-plans/air-quality-monitoring-network-plan/annual-air-qualitymonitoring-network-plan-v2.pdf?sfvrsn=2 (accessed August 2016).

———. 2017. Final 2016 Air Quality Management Plan. March 2017. www.aqmd.gov/docs/

default-source/clean-air-plans/air-quality-management-plans/2016-air-qualitymanagement-plan/final-2016-aqmp/final2016aqmp.pdf?sfvrsn=15 (accessed August 

2017). 
Section 14 References

November 2021 California High-Speed Rail Project Environmental Document

14-2 | Page Burbank to Los Angeles Project Section Final General Conformity Determination

URS, HMM, and Arup Joint Venture. 2011. Estimated Emissions from hauling Ballast Material –

Merced to Fresno and Fresno to Bakersfield Sections of the California High-Speed Train 

Project. July 21, 2011.

U.S. Environmental Protection Agency (USEPA).1994. General Conformity Guidance: Questions 

and Answers. July 13, 1994. https://www.epa.gov/sites/production/files/2016-03/

documents/gcgqa_940713.pdf (accessed December 4, 2019).

———. 2006. Emission Factors & AP 42. https://www.epa.gov/air-emissions-factors-andquantification/ap-42-compilation-air-emissions-factors (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 December 4, 

2019). 

———. 2019. Monitor Values Report. https://www.epa.gov/outdoor-air-quality-data/monitorvalues-report (accessed December 2019). 
Section 15 Preparer Qualifications

California High-Speed Rail Project Environmental Document November 2021

Burbank to Los Angeles Project Section Final General Conformity Determination Page | 15-1 

15 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 CalEEMod, Emission Factor 

models (EMFAC/OFFROAD), Road Construction Estimator Model (RoadMod) and Line 

Dispersion Models (CALINE). 

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 analyses for 

residential, commercial, and infrastructure projects, as well as stand-alone air quality impact 

studies.
Section 15 Preparer Qualifications

November 2021 California High-Speed Rail Project Environmental Document

15-2 | Page Burbank to Los Angeles Project Section Final General Conformity Determination

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AAppendix A

California High-Speed Rail Project Environmental Document November 2021

Burbank to Los Angeles Project Section Final General Conformity Determination Page | A-1 

APPENDIX A: GENERAL CONFORMITY DETERMINATION LETTER 

BETWEEN AUTHORITY AND SOUTH COAST AIR QUALITY MANAGEMENT 

DISTRICT
Appendix A 

November 2021 California High-Speed Rail Project Environmental Document

A-2 | Page Burbank to Los Angeles Project Section Final General Conformity Determination

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November 9, 2021

Mr. Ben Benoit, Chair 

South Coast Air Quality Management District 

21865 Copley Drive 

Diamond Bar, CA 91765 

Re: General Conformity for the Burbank to Los Angeles Section of California High-Speed Rail 

Dear Mr. Benoit: 

Thank you for your active participation with the California High-Speed Rail Authority (Authority) 

to address the General Conformity requirements ofthe California High-Speed Rail Burbank to Los 

Angeles Project Section of the California High-Speed Rail (HSR) System, which is located within 

the jurisdiction of the South Coast Air Quality Management District (South Coast AQMD or

District). The 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. 

Air Quality and Public Health Benefits of the High-Speed Rail System 

The HSR System will use 100 percent renewable electrically-powered, zero emission high-speed 

trains and is identified in the California Air Resources Board's 2017 Scoping Plan as part of a 

sustainable statewide transportation system necessary to achieve the state's climate goals. With 

HSR, the Authority states that total statewide greenhouse gas (GHG) emissions in 2040 would be 

less than 2015 GHG levels, with HSR predicted to help achieve that goal by reducing 2040 GHG 

emissions by approximately 1.1 to 1.7 million metric tons. The Authority also states that the HSR 

System would result in a net reduction of criteria pollutant emissions. Phase 1 ofthe HSR System, 

which consists of distinct sections from San Francisco in the north to Los Angeles and Anaheim 

in the south, is expected to result in reductions to nitrogen oxides (NOx) emissions of 

approximately 1, 140-1, 150 tons per year, , particulate matter (PM) emissions of approximately 

500-700 tons per year, and reactive organic gases (ROG) emissions of 130-150 tons per year 

compared to the No HSR System Project Alternative in 2040. 

As part of its first phase, the Burbank to Los Angeles Project Section (also referred to as the 

Project) is critical to bringing the HSR System to Southern California. Operation of the HSR 

System within the South Coast region would result in a net regional decrease in emissions of 

criteria pollutants and associated public health impacts, and emission levels would be less than the 

general conformity de minimis levels. This overall net decrease in operational emissions would 

help the South Coast Air Basin (Basin) meet its attainment goals of federal ambient air quality 

770 L Street, Suite 620, Sacramento, CA 95814 • T: (916) 324-1541 • F: (916) 322-0827 • www.hsr.ca.gov 
Mr. Ben Benoit 

November 9, 2021 

Page2 

standards for Ozone (03) by reducing precursor emissions ofNOx, ROG and PM and will result 

in long-term air quality and public health benefits. 

However, the construction of the HSR System is expected to result in a net increase in criteria 

pollutant emissions ofNOx beyond de minimis thresholds during construction years. As such, the 

Authority and the South Coast AQMD have agreed to the commitments in this letter to track and 

mitigate construction emissions from the Project to meet General Conformity Requirements. 

General Conformity Rule 

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 Project 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 attaimnent. The 

Authority, as the Project proponent, is receiving federal grant funds through the Federal Railroad 

Administration's (FRA) High-Speed Intercity Passenger Rail program. The Project may also 

receive FRA safety approvals. Because of the federal funding and potential safety approvals, the 

Project in relation to the Burbank to Los Angeles Section of the HSR System is subject to the 

General Confonnity Rule; and because construction-phase emissions (without mitigation) would 

exceed General Conformity de minimis emission thresholds, the Project is not exempt and must 

demonstrate conformity. 

Emission Reductions vs. Emission Mitigation 

The Authority has not yet secured construction funding for the Burbank to Los Angeles Section of 

the HSR System and has not yet set a finn construction schedule for this section. The Authority 

explains that the emission numbers provided in the Authority's EIR/EISs are reasonable estimates 

based on the available inf01mation to date. The methodology used in creating these estimates is 

similar to what was used for estimating the emissions for the Merced to Fresno and Fresno to 

Bakersfield project section environmental documents. After seven years of construction in the 

central valley it has become clear that the estimates in the EIR/EIS are conservative and actual 

emissions from constrnction are currently lower than estimates by 50-70%. It is therefore difficult 

for the Authority to cmTently engage with South Coast AQMD on implementing available or future 

mechanisms for the reduction of construction emissions. While the construction schedule has not 

been firmly established for this section, the Authority agrees with South Coast AQMD's 

encouragement to reduce emissions locally by avoiding and minimizing emissions from 

construction, before funding incentive programs to fully mitigate remaining construction 

emissions. 

The Authority has a long history of being proactive towards reducing construction emissions. As 

shown in 
Mr. Ben Benoit 

November 9, 2021 

Page 3 

Figure 1, the Authority has continually updated its policies and procedures to ensure that the 

project embraces and pushes the boundaiies towards reducing emissions. 

Figure 1 - History of Environmental Commitments Designed to Reduce Emissions 

2008- Board Adopts 100-percent renewable energy for operations 

2011 - Incorporated in California Air Resources Board (ARB) Scoping Plan for AB32 

2012 

» Net-Zero direct greenhouse gas emissions (GHG) for construction

» Net-Zero air quality emissions for construction

Proactive construction requirements, including requiring Tier 4 vehicles and 100-percent recycling requirements

2013 - CEO Signs Sustainability Policy 

2014 

First infrastructure project to require disclosure on major materials, informed AB 262 Buy Clean California Act 

EMMA developed to track and monitor program and contractor progress 

2016 - Board Adopts Sustainability Policy 

2017 - Incorporated in ARB Scoping Plan Update 

2019 

Required performance targets for embodied energy (concrete and steel)

Zero emissions fleet vehicles (25 percent of on road fleet) for contractors 

Required use of renewable diesel 

Direct GHG emissions target set for construction tied to a bonus/penalty 

Impact Avoidance and Minimization Features 

Avoiding and minimizing emissions is a strategy that is consistent with the net-zero greenhouse 

gas objectives of the Authority's Sustainability Policy. As such, based on the Draft Environmental 

Impact Report/Draft Environmental Impact Statement, the Authority has incorporated the 

following Impact Avoidance and Minimization Features (IAMFs) into the Burbank to Los Angeles 

Section of the HSR System: 

• AQ-IAMF#2: Selection of Coatings: The contractor would use lower VOC content

paint than that required by South Coast AQMD Rule 1113. 

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

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

phase would meet Tier 4 engine requirements.

• AQ-IAMF#S: Reduce Criteria Exhaust Emissions from On-Road Construction

Equipment: All on-road trucks would consist of model year 2010 or newer.

• AQ-IAMF#6: Reduce the Potential Impact of Concrete Batch Plants: The

contractor would prepare a technical memorandum documenting the concrete batch

plant siting criteria, including locating the plant at least 1,000 feet from sensitive

receptors, and utilization of typical control measures.
Mr. Ben Benoit 

November 9, 2021 

Page4 

• AQ-IAMF#l: Fugitive Dust Emissions: The contractor would employ several control

measures to minimize and control fugitive dust emissions and prepare a fugitive dust

control plan for each distinct construction segment.

• AQ-IAMF#3: Renewable Diesel: 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 tlucks.

According to the Authority, these IAMFs have helped to reduce the constrnction emissions 

generated by the HSR project sections that are located outside the South Coast AQMD's 

jurisdiction. For example, Figure 2 highlights the significant criteria pollutant emission 

reductions demonstrated by the project due to the IAMF#4. 

Figure 2 - Emission Savings due to Tier 4 Equipment in 2020 

TIER 4 REQUIREMENTS MINIMIZE AIR POLLUTION 

Protecting communities in construction 

NOx ROG PM BC 

Nitrogen Oxide Reactive Organic Gas Particulate Matter Black Carbon 

150,000 lbs. 13,S00lbs. 8,4001bs. 6,300 lbs. 

66% LESS 71% LESS 55% LESS 58% LESS 

50,000 lbs. 3,900 lbs. 3,700 lbs. 2,600 lbs. 

Tier 4 requirements have had a significant positive impact to date. 

Mitigation Measures 

The Authority is continually incorporating mitigation measures that would reduce the generation 

of constrnction emissions in constrnction contracts and practices. For example, the Authority 

redently incorporated the following mitigation measure into the environmental documentation and 

is already incorporating portions of this measure into existing contracts. 

A Q-MM - Construction Emissions Reductions - Requirements for use of Zero 

Emission (ZE) and/or Near Zero Emission (NZE) vehicles and off-road equipment 
Mr. Ben Benoit 

November 9, 2021 

Page 5 

This mitigation measure would reduce the impact of construction emissions from the use 

of on-road vehicles and off-road equipment for the Burbank to Los Angeles Section of

the HSR System. All remaining emissions after implementation of this measure would 

be mitigated with emission reduction programs required under Mitigation Measure AQMM#l. 

The Authority and all project construction contractors shall require that by the start of 

construction a minimum of 25 percent, with a goal of 100 percent, of all light-duty onroad vehicles (e.g., passenger cars, light-duty trucks) associated with the construction 

activities for the Burbank to Los Angeles Section of the HSR System ( e.g., on-site 

vehicles, contractor vehicles) use zero emission (ZE) or near-zero emission (NZE) 

technology. 

The Authority and all project construction contractors shall have the goal that by the start 

of construction a minimum of 25 percent of all heavy-duty on-road vehicles ( e.g., for 

hauling, material delivery and soil import/export) associated with the construction 

activities for the Burbank to Los Angeles Section of the HSR System use ZE or NZE 

technology. 

The Authority and all project construction contractors shall have the goal that by the start 

of construction a minimum of 10 percent of off-road construction equipment be ZE 

which includes electric technologies or NZE during the construction activities for the 

Burbank to Los Angeles Section of the HSR System. 

If local or state regulations mandate a faster transition to ZE and/or NZE vehicles and 

off-road equipment at the time of construction for the Burbank to Los Angeles Section of 

the HSR System, the more stringent regulations will be required and applied. For 

example, Executive Order (EO) N-79-20 currently states the following: 

• Light duty and passenger car sales be 100% ZEV by 2035

• Full transition to ZEV short haul/drayage trucks by 2035

• Full transition to ZEV heavy-duty long-haul trucks, where feasible, by 2045

• Full transition to ZE off-road equipment by 2035, where feasible.

The Authority has a goal of surpassing the requirements of these or other future 

regulations as a mitigation measure. 

The Authority claims that it already mandates that all such equipment meet the highest emission 

standard codified by the U.S. Environmental Protection Agency (EPA)-Tier 4. This has had a 

significant positive impact on emission reductions, as 172,000 pounds of criteria air pollutants to 

date would have otherwise been released. This implementation strategy will go further, 

mandating that by 2030, 10 percent of off-road equipment be ZEV, not just Tier 4, at start of 

construction, and sets the goal of 100 percent ZEV for such equipment by 2035. 
Gasoline Gasoline Gasoline 

Gasoline Diesel HEV PHEV EREV EV I 

Annual Well-to-Wheels Petroleum Use (bar-rels) 

Small Equipment Petroleum Use 11 

Large Equipment Petroleum Use 

Annual Well-to-Wheels GHGs_(short tons) 

Small Equipment GHGs 

Large Equipment GHGs 

Annual Vehicle OP.eration Air Pollutants (lb) 

Small Equipment - Commercial Turf 

Equipment 

co 

NOx 

PMlO 

PM2.5 

voe 

SOx 

Large Equipment - Forklifts 

co 

NOx 

PMl0 

PM2.5 I 

voe I 

SOX 

..•. ·-- \ ,·,,_,-,.-.-..._._. . , " -- " .. . . I 

I 

Mr. Ben Benoit 

November 9, 2021

Page 6 

This is the most recent step the Authority is taking to ensure California High-Speed Rail System 

is the greenest infrastructure project in both operation and construction. The Authority has 

captured or avoided more than 180,000 tons of greenhouse gas emissions through planting more 

than 6,000 trees and other forest projects. The HSR System has also prevented more than 

180,000 tons of construction mate1ials from being sent to landfills with its 97 percent 

construction waste recycling rate. 

The Authority will continue to work with contractors to encourage and mandate the use of ZE 

vehicles and off-road equipment. In addition, the Authority will encourage contractors to utilize 

available tools that will aid decision makers in their purchases of new equipment and include the 

use of ZE technologies in applicable bid documents, purchase orders, and contracts with 

contractors. For example, a current tool that the Authority has presented to contractors is 

Argonne National Laboratory's Alternative Fuel Life-Cycle Enviromnental and Economic 

Transportation (AFLEET) Tool (https://greet.es.anl.gov/afleet). This tool examines both the 

environmental and economic costs and benefits of alternative fuel and advanced vehicles and 

provides output to the user quantifying specific case scenarios based on user input (Figure 3). 

Figure 3 -AFLEET Sample Output 

Annual Simple Payback Calculator Output - Energy Use and Emissions 
Mr. Ben Benoit 

November 9, 2021 

Page 7 

Future Steps 

The Authority will continue to pursue construction methods, materials and equipment that will 

reduce the generation of air pollutants. Even with these measures however, some pollution will 

be emitted during the construction phase. To ensure that the Burbank to Los Angeles Section of 

the HSR System meets all the General Conformity requirements, the following steps will be taken 

once construction funding is established. 

• A construction schedule will be developed.

• Based on the new schedule, a construction plan will be developed and analyzed to 

detennine the emission burdens generated by construction.

• At the time of the analysis, the IAMFs and mitigation measures will be revisited and

updated as discussed above, and in consultation with the South Coast AQMD, to include

technologies and methodologies that were not considered in the earlier analysis. This

review and implementation of updated measures will aid the Burbank to Los Angeles

Section of the HSR System in reducing the generation of emissions due to construction.

• Once emission estimates are calculated using the revised IAMFs and mitigation

measures, it will be determined if the estimates are above the applicable General

Conformity de minimis tlu·esholds.

• The South Coast AQMD will be notified via email or letter of the emission levels and

consulted to determine if emission reduction programs could be applied as needed prior

to the start of construction activities for the Burbank to Los Angeles Section of the HSR

System.

If emission reduction programs are required, the Authority will present a detailed plan, 

developed with the South Coast AQMD, to ensure that the program has in place a procedure to 

adequately account for and reduce emissions generated by the Burbank to Los Angeles Section 

of the HSR System. The emission accounting program the Authority currently uses to track 

emissions for the segments currently being constructed will be presented as a possible 

mechanism to quantify the construction emissions generated by the Burbank to Los Angeles 

Section of the HSR System. 

Emissions Tracking and Mitigation 

The Authority has stated its intent to reduce and/or mitigate construction emissions in the 

environmental document for the Burbank to Los Angeles Section of the HSR System in the 

mitigation section of the EIR/EIS with the following mitigation measure: 

AQ-MM: Mitigate Project Construction Emissions through Off-Site Emission 

Reduction Programs-The Authority will enter into contracted agreements with the 

South Coast AQMD to mitigate projected emissions from construction equipment and 

vehicle exhaust emissions of volatile organic compound (VOC), and Oxides of Nitrogen 
MMA Sus1a1nab1Uty• Alerts 

Construction Equipment 

CP2-3 • 2020 ... Selected Year •• QOnRoad ----- @ Of!Road 

SllOw tmlnes 

Month Year Subcontractor Name Make Model ARB Equipment fype Type of Equipment DOORS# Fuel Type Hors.e Power Engine Tler 

Fim ,.. ,.,, Flri!I i'"i'IN fiw "'" fl'tf fi!,., 

January 2020 OFJV John Oee,e 710LX TractorsJLoade,s/Backhoes TB3Y39 Diesel 148 T1er4Final 

January 2020 OFJV Genre GTHTOE Rough Terrain Forklifts Fo1khfl HK9039 Diesel 121 T1er4Fmal 

January 2020 DFJV John Deere 210l Rubber Tired loaders Skip loader JD210 Y'N8T88 Diesel 75 Tier4 Final 

January 2020 OFJV CAT 16M3 Graders Motorgrader FB6T58 Diesel 363 T1e14 Final 

January 2020 OFJV John Deere 744K II Rubber Tired Loaders loader MJ3B79 Diesel 3ll3 T1e1 4 Final 

January 2020 OFJV John Oeem:1 644K Tractors/loadersrBackhoes SC9V47 Diesel 232 Tier 4 Final 

January 2020 OFJV John Deere 644K Rubber Tired Loaders loader HU7N47 Diesel 232 T1er4 Final 

January 2020 DFJV CAT 623K Scrapers Scraper GA6J48 Diesel 408 T1er41nlenm 

January 2020 OFJV CAT MT845C T,aclor../loaders!Backhoes Tractor Chanenger HC9896 Diesel 460 Tier 4 Fmal 

Ja . Final 

- Tier2 or lo\ver - Tier 3 - Tier 4 

120 

100 

00 

60 

40 

20 

Mr. Ben Benoit 

November 9, 2021 

Page 8 

(NOx) from constrnction activities for the Burbank to Los Angeles Section of the HSR 

System, based on calculations presented to the South Coast AQMD after receipt by the 

Authority of constrnction funding but prior to the staii of constrnction. 

The Authority currently mitigates emissions in the San Joaquin Valley through a Voluntary 

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

Distiict (SJVAPCD). Through the use ofthe Enviromnental Mitigation Management Application 

(EMMA) tool, developed by the Authority, construction activity is input by the contractor 

and , applicable emission rates are applied to calculate the emission burdens generated by off-road 

and on-road constrnction equipment and activity. Figure 4 highlights some of the data input 

and calculated through EMMA. As previously noted, actual emission burdens have been 

significantly lower than the burdens estimated in the con-esponding EIR/EIS. 

Figure 4 - EMMA tracking tool - Sample data and Infographics 
Mr. Ben Benoit 

November 9, 2021

Page 9 

Conclusion 

The Authority is committed to serving as a model ofsustainable development. The HSR System 

was recently recognized with a Platinum Envision level award. The Platinum Envision award 

achieved by the Authority and its program partners demonstrates that sustainability is achievable 

across large-scale and complex transportation systems. 

Given the documented history of the HSR System's successful implementation of emission 

reduction strategies that the Authority has demonstrated for sections outside the South Coast 

AQMD's jurisdiction, the robust emission tracking and mitigation program, along with the 

Authority's vision for the California High-Speed Rail System being the greenest infrastructure 

project in operation and construction in the country, it is the Authority's firm commitment to 

partner with the air district to ensure that all General Conformity requirements are met. 

By signing this letter, the South Coast AQMD agrees to work with the Authority, using available 

mechanisms as appropriate, to reduce construction emissions and satisfy General Conformity for 

the Burbank to Los Angeles Section of the HSR System. 

• The Authority will work with the South Coast AQMD in order to ensure that the lowest

levels of construction emissions are generated through the use of IAMFs and mitigation

measures outlined in this document and rolling review of best available technologies,

with priority given first to the use of zero emission (ZE) technology such as electric

construction equipment and then to near-zero emission (NZE) technology.

• After receipt of construction funding but prior to construction start, the Authority will

review emission estimates, revise if warranted, and present a final estimate for review

and use by the District for pmposes of emission reduction contiibutions and monitoring

for the Burbank to Los Angeles Section.

• If emissions exceed General Conformity de minimis thresholds, all remaining emissions

after implementation of the IAMFs and onsite mitigation measures will be completely

mitigated to zero through the District's emission reduction programs. Applicable

emission reduction programs may include state or federal incentive programs that achieve

emissions reductions by providing incentive funds for the incremental cost of cleaner

than required engines and equipment. The Authority agrees to provide funding at the

cost-effectiveness level or amount established by the program(s) mutually selected by the

District and the Authority.

• After receipt of construction funding but prior to construction start, the Authority and the

District will enter into a contractual agreement to fully mitigate construction emissions

exceedances to zero for the Burbank to Los Angeles Section, as required by General

Conformity regulations, by providing funds for the selected emission reduction

program(s) to fund grants for projects that achieve the necessary emission reductions.
Thank you for your continuing partnership with the Authority to advance the California High-Speed Rail System.

• The Authority and the District will work together to identify opportunities and mechanisms to prioritize use of Authority 

funds for emission reductions local to where the construction activities for the Burbank to Los Angeles Section takes 

place; and, to the extent local emission reductions are unavailable the parties will work together to develop other 

strategies. 

• The Authority will contribute to the District’s actual costs of administration for implementation of the necessary 

emissions reductions for the HSR Burbank to Los Angeles Section, and the District will seek and implement the 

necessary emission-reduction measures, using Authority funds;

• The District will serve in the role of administrator of the emission reduction projects and verifier of the successful 

mitigation effort; respective Authority and District responsibilities in that effort and related emission quantification/

verification needs will be defined in a contractual agreement.

• The commitments in this letter are independent of any requirements related to any future District facility-based 

mobile source measure regulating freight rail yards or other, similar non-zero emission rail operations.

• The contractual agreement developed pursuant to this letter will be limited to the HSR System’s Burbank to Los 

Angeles Section general conformity determination.

11/12/2021

November 17, 2021