Bell Middle School Modernization Project · 1,164 students (SDUSD 2011). The proposed school...

Final Initial Study/ Mitigated Negative Declaration

for the

Bell Middle School Modernization Project

Prepared for the:

Facilities Planning & Construction

4860 Ruffner Street San Diego, CA 92111

December 2012

Prepared by:

ICF International 9775 Businesspark Ave., Suite 200

San Diego, CA 92131 (858) 578-8964

BELL MIDDLE SCHOOL MODERNIZATION PROJECT FINAL INITIAL STUDY/ MITIGATED NEGATIVE DECLARATION

San D iego Un i f i ed Schoo l D is t r i c t TOC- i December 2012

TABLE OF CONTENTS Page

Contents Miscellaneous Project Information ............................................................................................................................... 1

Environmental Factors Potentially Affected ................................................................................... 10

Determination ....................................................................................................................................... 11

Environmental Setting ......................................................................................................................... 12

Environmental Effects ......................................................................................................................... 12

I. Aesthetics ...............................................................................................................13

II. Agricultural Resources ...........................................................................................14

III. Air Quality .............................................................................................................16

IV. Biological Resources .............................................................................................23

V. Cultural Resources .................................................................................................25

VI. Geology and Soils ..................................................................................................26

VII. Greenhouse Gas Emissions ....................................................................................28

VIII. Hazards and Hazardous Materials .........................................................................33

IX. Hydrology and Water Quality ................................................................................37

X. Land Use and Planning ..........................................................................................39

XI. Mineral Resources .................................................................................................40

XII. Noise ......................................................................................................................41

XIII. Population and Housing .........................................................................................48

XIV. Public Services .......................................................................................................49

XV. Recreation ..............................................................................................................50

XVI. Transportation/Traffic ............................................................................................51

XVII. Utilities and Service Systems.................................................................................53

XVIII. Mandatory Findings of Significance ......................................................................55

Preparers ......................................................................................................................................56

Reviewers ......................................................................................................................................56

References .....................................................................................................................................56

Comments Received in Response to the Draft MND ................................................................59


San D iego Un i f i ed Schoo l D is t r i c t TOC- i i December 2012

Appendices:

Appendix A Air Quality Modeling Details

Appendix B Hazardous Materials/Title 5 Analysis


San D iego Un i f i ed Schoo l D is t r i c t TOC- i i i December 2012

Figures Page

Figure 1 Vicinity Map ...................................................................................................................... 4

Figure 2 School Site Location Map ................................................................................................. 5

Figure 3 Hardscape Plan ................................................................................................................... 6

Figure 4 Utility Plan .......................................................................................................................... 7

Tables Page

Table 1 Federal and State Ambient Air Quality Standards ....................................................... 17

Table 2 SDAPCD Screening Level Thresholds ......................................................................... 18

Table 3 Construction-Related Criteria Pollutant Emissions (pounds per day) ....................... 21

Table 4 Key Characteristics of Principle Greenhouse Gases .................................................... 29

Table 5 Construction-Related Greenhouse Gas Emissions (metric tons per year) ................. 31

Table 6 1-Hour Average Noise Level Thresholds within the City of San Diego ................... 42

Table 7 Loudest Construction Phase Noise Levels at 50 Feet .................................................. 43

Table 8 Typical Vibration Levels for Construction Equipment ............................................... 46

Table 9 Reaction of People and Damage to Buildings at Various Continuous Vibration Levels ............................................................................................................................... 46


San D iego Un i f i ed Schoo l D is t r i c t 1 December 2012

1. PROJECT TITLE:

Bell Middle School Modernization Project 2. LEAD AGENCY NAME AND ADDRESS:

San Diego Unified School District Facilities Planning & Construction 4860 Ruffner Street San Diego, CA 92111

3. CONTACT PERSON:

Gary Stanford, Director, Project Management Department (858) 637-6280 [email protected]

4. PROPOSED PROJECT LOCATION:

Bell Middle School is located on an approximately 35-acre site owned by the San Diego Unified School District (District) at 620 Briarwood Road in the County of San Diego, California, City of San Diego, Community of Paradise Hills (Figure 1). Access to the site is via Briarwood Road (Figure 2).

5. PROJECT SPONSOR’S NAME AND ADDRESS:

San Diego Unified School District Facilities Planning & Construction 4860 Ruffner Street San Diego, CA 92111

6. GENERAL PLAN DESIGNATION1:

Existing school site – Institutional Middle School 7. ZONING1:

Existing school site is zoned RS-1-7, Residential—Single Unit (City of San Diego 2012a)

8. DESCRIPTION OF THE PROJECT:

Background

In 2008, San Diego voters passed Proposition S (Prop S), the San Diego School Repair and Safety Measure, to improve existing school facilities throughout San Diego. This 2.1 billion general obligation bond measure was developed to provide resources to renovate, repair, and revitalize deteriorating school facilities at 181 existing school campuses within the District.

1 By State law, school facilities can be exempted from local land use development requirements such as general plans and zoning ordinances. It is expected that the San Diego Unified School District Board of Education will exempt this project from such land use controls. General plan and zoning information is therefore provided only for reference, as they will not apply to the property.



Many of the school facilities at Bell Middle School (constructed between 1967 and 1968) were identified during a comprehensive planning process as needing repairs, renovations, and/or upgrades as part of Prop S. These needed school improvements would be implemented by the proposed Bell Middle School Modernization Project (project). Project Objective

The proposed project would implement the needed school facilities improvements as identified in Prop S. Detailed Project Description

Bell Middle School is located in the Paradise Hills community of San Diego and serves grades 6 through 8. School facilities comprise 14 permanent buildings (147,851 square feet of space), which include 78 classrooms (58 permanent classrooms and 20 portable classrooms). The school program capacity is 1,699 students with student enrollment during the 2007/2008 school year at 1,374 students, and enrollment in 2016/2017 projected to be 1,164 students (SDUSD 2011). The proposed school modernization project would not increase the existing school’s capacity or the net number of classrooms.

The list below contains the individual school improvements proposed by the Bell Middle School Modernization Project. Figure 3 depicts the District’s hardscape plan (including parking lot and fire lane improvements) for the proposed project. The District’s utility plan (involving water connections and storm drains) for the southwestern portion of the project is provided in Figure 4.

School Improvements to Support Student Health, Safety, and Security

Improve the student drop-off and pick-up area

Renovate the existing parking and fire lane

Install security lighting, as well as increase vandalism and intrusion safeguards, including modifications to fencing and gates

Install a site safety communication system

Improve hardscape and landscaping

Install air-conditioning in learning environments

Renovate/expand food service areas to increase service efficiency, provide healthier food choices, and improve eating environment

Projects to Improve School Accessibility, Code Compliance Upgrades

Renovate existing restrooms and locker rooms

Improve accessibility to all classrooms, labs, restrooms, and other school facilities to comply with accessibility regulations, including the Americans with Disabilities Act (ADA) Titles I & II



Install three-compartment sink in kitchen

Install a grease trap in kitchen to comply with city regulations

Provide new kitchen staff restroom and locker area

Major Building Systems Repair/Replacement

Replace aging wiring and upgrade electrical systems, including adding additional receptacles throughout campus

Repair/replace buckling sidewalks and improve path of travel on site

Repair broken steps

Repair/restore building interiors, exteriors, finishes, and fixtures

Repair/replace inefficient heating and ventilation systems

Repair/replace deteriorating plumbing and sewer lines as needed (includes chilled water line, storm drains, and gas pipes)

Repair/replace/upgrade performance spaces/multipurpose rooms

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Figure 1Vicinity Map


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Construction Activities and Schedule – The construction activities to implement the school improvements listed above would involve a small number of vendor trips (i.e., material delivery) and some truck hauling of construction debris. Trenching would also be involved for utility repairs and/or replacement. Construction is scheduled for approximately 24 months, and would occur between the hours of 7 a.m. and 7 p.m. (Monday through Friday) in accordance with City of San Diego operational requirements for construction. Construction activities would also occur in phases, which would allow school activities to continue throughout construction.

9. SETTING AND SURROUNDING LAND USES

The proposed project site is the existing Bell Middle School campus located on a hill within the Paradise Hills community. Briarwood Road abuts the project site along its eastern border, and other roadways in the school’s vicinity include Paradise Valley Road to the north of the site, Alsacia Street to the south, and South Woodman Street to the west. A portion of the project site, currently the students’ playing field, was formerly used as a sanitary landfill from approximately 1962 to 1967. None of the school buildings are located on the landfill (landfill boundary line depicted in Figure 3 and Appendix B).

Surrounding land uses of the project site primarily consist of single- and multi-family residential uses with some commercial uses, schools, and parks mixed within (Figure 2). Commercial uses, including retail and chain restaurants, are located just northwest of the school site. A number of other schools exist within a mile of the Bell Middle School project site, including Zamorano Elementary School, Boone Elementary School, Penn Elementary School, Fulton Elementary School, Morse High School, and the San Diego School of Performing Arts. Other uses in the surrounding neighborhood include parks and recreational centers such as Paradise Hills Park, located approximately 0.4 miles to the west of the project site, and the Hillsborough Recreational Center, located approximately 0.5 mile east of the site. Both of these sites include a mix of recreational facilities and open space. Another notable land use in the surrounding area is the Sweetwater Reservoir, a 960-acre artificial lake built on the Sweetwater River, located approximately 1.7 miles east of the project site. The 44,000-acre San Diego National Wildlife Refuge is located farther east past the reservoir, approximately 2.7 miles from the project site.

10. OTHER PUBLIC AGENCIES WHOSE APPROVAL MAY BE REQUIRED

The following agencies may be Responsible Agencies under the California Environmental Quality Act (CEQA). They may need to issue approvals for the project and, thus, rely upon this Initial Study (IS). Federal agencies and their potential permit responsibilities are also listed.

Office of the Division of the State Architect – Compliance City of San Diego, Solid Waste Local Enforcement Agency (LEA)- Review of proposed modernization activities as well as Master Community Health and Safety Plan (CHSP) and Master Soil Management Plan (SMP)



11. CEQA REQUIREMENTS

This project is subject to the requirements of CEQA. The lead agency is the San Diego Unified School District (District). The purpose of this Initial Study is to provide a basis for deciding whether to prepare an Environmental Impact Report, a Mitigated Negative Declaration, or a Negative Declaration for this project. This Initial Study is intended to satisfy the requirements of CEQA (Public Resources Code, Division 13, Sections 21000–21177) and the State CEQA Guidelines (California Code of Regulations, Title 14, Sections 15000–15387). CEQA encourages lead agencies and applicants to modify their projects to avoid significant adverse impacts.

Section 15063(d) of the State CEQA Guidelines states the content requirements of an Initial Study as follows:

15063(d) Contents. An Initial Study shall contain in brief form: (1) A description of the project including the location of the project; (2) An identification of the environmental setting; (3) An identification of environmental effects by use of a checklist, matrix,

or other method, provided that entries on a checklist or other form are briefly explained to indicate that there is some evidence to support the entries;

(4) A discussion of the ways to mitigate the significant effects identified, if any;

(5) An examination of whether the project would be consistent with existing zoning, plans, and other applicable land use controls;

(6) The name of the person or persons who prepared or participated in the Initial Study.

12. RESULTS OF THE PUBLIC REVIEW

( ) No comments were received during the public input period.

( ) Comments were received during the public input period, but they did not address the Draft Mitigated Negative Declaration findings or the accuracy or completeness of the Initial Study. No response is necessary. The letters are attached.

(X) Comments addressing the findings of the Draft Mitigated Negative Declaration and/or accuracy or

completeness of the Initial Study were received during the public input period. The letters and responses are presented in the Comments Received in Response to Draft MND Section of this Final MND.

October 2012 Signature Date of Draft MND Mr. Gary Stanford December 2012 Director, Project Management Department Date of Final MND



ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED

The following checklist is used to evaluate the potential for significant environmental impacts caused by the proposed project. All responses must consider the project in its entirety and any actions involved, including offsite as well as onsite impacts, cumulative as well as project-level impacts, indirect as well as direct impacts, and construction as well as operational impacts.

This checklist is adapted from the form provided in Appendix G of the State CEQA Guidelines as last amended on December 30, 2009 (California Natural Resources Agency 2009). The checklist is modified as appropriate for this project. There are 18 CEQA subject categories to be considered, with this checklist organized as such. Each subject discussion includes an evaluation matrix, followed by a brief discussion explaining the evaluation rationale. As appropriate, each subject discussion may address more than one specific issue question if there is a salient interrelation.

The 18 CEQA subject categories—or environmental factors—that must be considered are presented below. Each category is scored according to the potential level of [impact] significance the proposed project may have on the environment. The levels of significance are indicated and described below.

3 = Potentially Significant: There is substantial evidence that an effect is significant.

2 = Less than Significant with Mitigation: Applies in situations where a “potentially significant” impact can be reduced to a “less than significant” level with the incorporation of an adequate and feasible mitigation measure(s).

1 = Less than Significant: This is an effect that is discernible, but would not cause lasting significant impact.

0 = No Impact: This is an adequate determination if the referenced information sources show that the impact simply does not apply to projects like the one involved.

1 Aesthetics 0 Agriculture and Forestry Resources 1 Air Quality

0 Biological Resources 1 Cultural Resources 1 Geology and Soils

1 Greenhouse Gas Emissions 2 Hazards & Hazardous Materials

1 Hydrology & Water Quality

0 Land Use and Planning 0 Mineral Resources 2 Noise

0 Population and Housing 0 Public Services 0 Recreation

1 Transportation/Traffic 1 Utilities and Service Systems 2 Mandatory Findings of Significance



DETERMINATION

On the basis of this initial evaluation:

I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.

I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.

I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.

I find that the proposed project MAY have a “potentially significant impact” or “potentially significant unless mitigated” impact on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.

I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (1) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required.

___________________________________________ October 4, 2012 Gary Stanford Date Director, Project Management Department



ENVIRONMENTAL SETTING

The Bell Middle School campus (project site) is located on an approximately 35-acre, District-owned site at 620 Briarwood Road in the City of San Diego, Community of Paradise Hills. The site is located on top of a small hill with access via Briarwood Road (Figure 2). Between 1962 and 1967, a portion of the site was used as a sanitary landfill. No school buildings are located on the landfill; however, the students’ playing field is built over the top deck of the landfill (landfill boundary line depicted in Figure 3 and Appendix B).

Bell Middle School currently has 14 permanent buildings comprising 147,851 square feet of space. School facilities include 78 classrooms (58 permanent classrooms and 20 portable classrooms). The school’s program capacity is 1,699 students with student enrollment during the 2007/2008 school year at 1,374 students, and enrollment for 2016/2017 projected to be 1,164 students (SDUSD 2011). The school’s existing capacity and net number of classrooms would not increase as a result of the proposed project.

The surrounding area of the project site is developed and densely populated. Existing and proposed surrounding land uses that immediately surround the site primarily consist of single- and multi-family residences with some commercial uses to the northwest of the project site. Other surrounding uses include a number of schools and small parks/recreation centers that dot the area within a 1-mile radius of the project site. Also, the Sweetwater Reservoir lies approximately 1.7 miles to the east of the site, and farther east (across the reservoir) is the 44,000-acre San Diego National Wildlife Refuge.

ENVIRONMENTAL EFFECTS

With recommended mitigation measures, no significant adverse environmental effects are expected from the proposed project. An environmental checklist follows that addresses potential environmental impacts and provides mitigation measures that reduce potentially significant impacts to a less-than-significant level.



Potentially Significant

Impact

Less than Significant with

Mitigation

Less than Significant

Impact

No Impact

I. Aesthetics

Would the Project:

a) Have a substantial adverse effect on a scenic vista? b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway?

c) Substantially degrade the existing visual character or quality of the site and its surrounding?

d) Create a new source of substantial light or glare that would adversely affect day or nighttime views in the area?

I. a) No Impact. The proposed project would not have a substantial adverse effect on a scenic vista. The project would improve and modernize an existing middle school, and the improvements proposed would not substantially change the appearance of the existing site. Improvements would consist of only internal and exterior modifications to existing structures. No structures would be demolished and no new large structures are proposed on the campus. Additionally, all project activities would occur within the existing school property, which is located on top of a hill within a densely populated residential/commercial neighborhood. Therefore, there would be no impact.

I. b) No Impact. There are no designated scenic highways within the surrounding area of the project site that would be affected by the proposed project (Caltrans 2012). Therefore, there would be no impact on scenic resources within a state scenic highway.

I. c) No Impact. See response to I.a. Implementation of the proposed project would not degrade the existing visual character or quality of the project site or its surroundings. The project site is a middle school surrounded by residential and commercial development. The project is limited to improvements to an existing middle school. Therefore, there would be no impact.

I. d) Less than Significant. The proposed improvements to the school would not create a new source of substantial light or glare that would affect day or nighttime views. Security lighting would be installed at the site to better safeguard the school from vandalism. However, all lighting would comply with the City of San Diego regulations on glare and outdoor lighting (Municipal Code Sections 142.0730 and 142.0740), which protect nighttime views and light-sensitive land uses from excessive light generation. Additionally, all lighting would be set by a timer to turn off at 9:30 pm, Monday through Friday. Therefore, the impact would be less than significant.




Impact


Mitigation


Impact

No Impact

II. Agriculture and Forest Resources

In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impact to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board.

Would the project:

a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use?

b) Conflict with existing zoning for agricultural use, or a Williamson Act contract? c) Conflict with existing zoning for, or cause of rezoning of, forest land (as defined in Public Resource Code section 12220 (g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))?

d) Result in the loss of forest land or conversion of forest land to non-forest use? e) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use?



II. a–e) No Impact. The proposed project would have no impact on agricultural or forest resources. The project site is within a built-out neighborhood where no farmlands or forest resources exist and is identified by the Farmland Mapping and Monitoring Program as Urban and Built-Up Land (California Department of Conservation 2008a). Also, there are no Williamson Act contracts in the project vicinity (California Department of Conservation 2008b). Therefore, there would be no impact associated with these issues.




Impact


Mitigation


Impact

No Impact

III. Air Quality

Where available, the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make the following determinations.

Would the project:

a) Conflict with or obstruct implementation of the applicable air quality plan? b) Violate any air quality standard or contribute substantially to an existing or projected air quality violation?

c) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors)?

d) Expose sensitive receptors to substantial pollutant concentrations? e) Create objectionable odors affecting a substantial number of people?

This section summarizes the air quality analysis prepared for the project by ICF International in July 2012. Details of this analysis are provided in Appendix A, “Air Quality Modeling Details,” of this document. This discussion is divided into three parts (Existing Conditions, Significance Thresholds, and Impact Analysis), and describes existing air quality conditions in the vicinity of the project area, summarizes relevant significance thresholds, and assesses air quality impacts associated with the proposed project, respectively. Existing Conditions

The proposed project is located within the San Diego Air Basin (SDAB). Climate in southern California, including the SDAB, is controlled largely by the strength and position of a subtropical high-pressure cell over the Pacific Ocean. Precipitation is mostly limited to a few storms during the winter season. Winds in the vicinity of the project site are usually driven by the dominant land/sea breeze circulation system. Temperature inversions, which can trap air pollutants near the ground, are common during the summer months when daytime winds are light. Wind patterns can also concentrate and carry pollutants from other cities to the area (e.g., Los Angeles), adding to the local pollutant mix.



The air quality management agencies of direct importance in the project area are the U.S. Environmental Protection Agency (EPA), the California Air Resources Board (ARB), and the San Diego County Air Pollution Control District (SDAPCD). EPA and ARB have established national ambient air quality standards (NAAQS) and California ambient air quality standards (CAAQS), respectively, for the following six pollutants: carbon monoxide (CO), nitrogen dioxide (NO2), sulfur dioxide (SO2), ozone (O3), lead, and particulate matter, including particulate matter less than or equal to 10 microns in diameter (PM10) and particulate matter less than or equal to 2.5 microns in diameter (PM2.5). ARB and SDAPCD are responsible for ensuring that these standards are met. Table 1 summarizes the NAAQS and CAAQS and the respective attainment status of San Diego County.

Table 1. Federal and State Ambient Air Quality Standards

Criteria Pollutant

Average Time

California Standards

National Standardsa Attainment Status of San Diego Countyb

Primary Secondary State National

Ozone 1-hour 0.09 ppm None None Nonattainment - -c

8–hour 0.070 ppm 0.075 ppm 0.075 ppm Nonattainment Former Subpart 1

Particulate Matter (PM10)

24-hour 50 g/m3 150 g/m3 150 g/m3 Unclassified Nonattainment

Annual mean 20 g/m3 None None Unclassified --

Fine Particulate Matter (PM2.5)

24-hour None 35 mg/m3 35 mg/m3 -- Nonattainment

Annual mean 12 g/m3 15.0 g/m3 15.0 g/m3 Attainment Nonattainment

Carbon Monoxide

8-hour 9.0 ppm 9 ppm None Attainment Attainment/ Maintenance

1-hour 20 ppm 35 ppm None Attainment Attainment/ Maintenance

Nitrogen Dioxide

Annual mean 0.030 ppm 0.053 ppm 0.053 ppm Attainment Attainment

0.18 ppm 0.100 ppm None 0.18 ppm Attainment Attainment

Sulfur Dioxided

Annual mean None 0.030 ppm None -- Attainment

24-hour 0.04 ppm 0.014 ppm None Attainment Attainment

3-hour None None 0.5 ppm -- --

1-hour 0.25 ppm 0.075 ppm None Attainment Attainment

Lead

30-day Average 1.5 g/m3 None None Attainment --

Calendar quarter

None 1.5 g/m3 1.5 g/m3 -- Attainment

3-month average

None 0.15 g/m3 0.15 g/m3 -- Attainment

Sulfates 24-hour 25 g/m3 None None Attainment --

Hydrogen Sulfide

1-hour 0.03 ppm None None Unclassified --



Criteria Pollutant

Average Time

California Standards

National Standardsa Attainment Status of San Diego Countyb

Primary Secondary State National

Vinyl Chloride 24-hour 0.01 ppm None None Unclassified -- Sources: California Air Resources Board (ARB) 2012, U.S. Environmental Protection Agency (EPA) 2012, San Diego Air Pollution Control District (SDAPCD) 2010. Notes: ppm= parts per million g/m3 = micrograms per cubic meter a. National standards are divided into primary and secondary standards. Primary standards are intended to protect public health,

whereas secondary standards are intended to protect public welfare and the environment. b. Local monitoring data are used to designate areas as nonattainment, maintenance, attainment, or unclassified for the NAAQS

and CAAQS. The four designations are further defined as: Nonattainment—assigned to areas where monitored pollutant concentrations consistently violate the standard in question. Maintenance—assigned to areas where monitored pollutant concentrations exceeded the standard in question in the past but are no longer in violation of that standard. Attainment—assigned to areas where pollutant concentrations meet the standard in question over a designated period of time. Unclassified—assigned to areas were data are insufficient to determine whether a pollutant is violating the standard in question.

c. The federal 1-hour standard of 12 parts per hundred million was in effect from 1979 through June 15, 2005. The revoked standard is referenced because it was employed for such a long period and is a benchmark for State Implementation Plans.

d. The annual and 24-hour NAAQS for SO2 only apply for one year after designation of the new 1-hour standard to those areas that were previously nonattainment for 24-hour and annual NAAQS.

Significance Thresholds

Applicable air quality analysis guidelines for the project area do not outline quantitative significance thresholds. However, the SDAPCD has established “Air Quality Impact Analysis (AQIA) Trigger Levels” in Regulation II, Rule 20.2 that can be used as screening criteria to identify significant air quality impacts. Emissions in excess of SDAPCD’s emission thresholds could contribute to air quality problems in the SDAB and would therefore result in a significant air quality impact. Applicable emissions thresholds are summarized in Table 2.

Table 2. SDAPCD Screening Level Thresholds

Air Contaminant Emissions Rate

Pounds/Hour Pounds/Day Tons/Year Particulate Matter (PM10) -- 100 15 Fine Particulate Matter (PM2.5)a -- 55 10 Oxides of Nitrogen (NOX) 25 250 40 Oxides of Sulfur (SOX) 25 250 40 Carbon Monoxide (CO) 100 550 100 Lead and Lead Compounds (Pb) -- 3.2 0.6 Reactive Organic Compounds (ROG)b -- 75 13.7 Source: SDAPCD Regulation II, Rule 20.2. Notes: a. The AQIA does not include trigger levels for PM2.5. The SDAQMD recommends using the EPA’s “Proposed Rule to

Implement the Fine Particle National Ambient Air Quality Standards” published September 8, 2005 as a threshold of significance. This threshold is also used by the South Coast Air Quality Management District (SCAQMD).

b. The AQIA does not include trigger levels for ROG. The SDAPCD recommends using thresholds established by the SCAQMD, which has similar federal and state attainment status as San Diego.



SDAPCD has established analysis guidelines for sensitive receptors, including exposure to CO hotspots, toxic air contaminants (TACs), and odors. The following criteria were used to determine whether the project would expose sensitive receptors to substantial pollutant concentrations.

Would the project place sensitive receptors near CO “hotspots” or create CO “hotspots” near sensitive receptors?

Would the project result in exposure to TACs resulting in a maximum incremental cancer risk greater than 1 in 1 million without application of Toxics Best Available Control Technology, or a health hazard index greater than 1, and thus be deemed as having a potentially significant impact?

Would project either generate objectionable odors or place sensitive receptors next to existing objectionable odors, which would affect a considerable number of persons or the public?

SDAPCD has not established quantitative thresholds to determine whether a project would make a cumulatively considerable contribution to air quality impacts. Therefore, the following County of San Diego thresholds, which were developed by the SDAPCD and the South Coast Air Quality Management District (SCAQMD), are utilized for the analysis cumulative air quality impacts (County of San Diego 2012).

A project that has a significant direct impact on air quality with regard to emissions of PM10, PM2.5, NOX, and/or ROGs, would also have a significant cumulatively considerable net increase.

In the event direct impacts from the proposed project are less than significant, a project may still have a cumulatively considerable impact on air quality if the emissions of concern from the proposed project, in combination with the emissions of concern from other past, present, or reasonably foreseeable future projects within the proximity relevant to the pollutants of concern, are in excess of direct air quality impact thresholds.

Impact Analysis

III. a) Less than Significant. San Diego County is currently designated a nonattainment area for the federal 8-hour ozone standard and the state ozone, PM10, and PM2.5 standards (see Table 1). The San Diego Regional Air Quality Strategy (RAQS) is the region’s plan for improving air quality and attaining the federal and state air quality standards. The RAQS relies on information from ARB and the San Diego Association of Governments (SANDAG) to project future emissions and determine appropriate emissions reduction strategies. SDAPCD has also adopted a State Implementation Plan (SIP) for ozone, as well as measures to help attain the PM CAAQS.

A project is deemed inconsistent with air quality plans if it would result in population and/or employment growth that exceeds estimates used to develop applicable air quality plans, which, in turn, would generate emissions not accounted for in the regional emissions budgets. Therefore, the proposed project is evaluated to determine if it is consistent with the land use designations and growth anticipated in the RAQS and ozone SIP prepared for the San Diego region.



The purpose of the proposed project is to implement needed school facilities improvements as identified in Prop S. The proposed modernization improvements would not increase the student capacity of the school and therefore would not involve an increase to the number of employees at the school or indirectly cause an increase in the population of residents in the area with students at the school. As discussed in Section XVI, Transportation/Traffic, the proposed project would not permanently change the existing or planned transportation network or traffic patterns in the area. The project would also not add any additional capacity to existing roadways. Likewise, as described in Section X, Land Use and Planning, the project would not conflict with any applicable land use plan or policy. The proposed project would generate emissions during construction (discussed below), but these emissions would be short term and are not expected to impede attainment or maintenance of the NAAQS or CAAQS. Consequently, the project would not conflict with or obstruct implementation of RAS or ozone SIP. Therefore, the impact would be less than significant.

III. b) Less than Significant. The proposed project consists of several school facilities improvements. These upgrades would not result in increased operational emissions, relative to existing conditions. Rather, replacement of inefficient building fixtures and other retrofits would likely reduce energy consumption and result in a regional reduction of criteria air pollutants. In addition, as described in Section XVI, Transportation/Traffic, the project would neither generate a significant number of new vehicles trips nor add additional capacity to area roadways. The following assessment therefore focuses exclusively on construction-related emissions because there would be no impact related to project operations.

Construction activities associated with the proposed project would generate short-term emissions of ROG, NOX, CO, PM10, and PM2.5 (refer to Section VII, Greenhouse Gas Emissions, for a discussion of greenhouse gas impacts). Emissions would originate from construction equipment exhaust, employee vehicle exhaust, and haul truck vehicle exhaust. Construction-related emissions would vary substantially depending on the level of activity, the specific construction operations, and wind and precipitation conditions.

Construction emissions from heavy-duty equipment and worker and haul trips were estimated using emission factors generated by the California Emissions Estimator Model (CalEEMod), version 2011.1.1, and ARB’s EMFAC2011. Based on information provided by the District, it was assumed that construction would involve 16 phases between July 2013 and August 2015 (see Appendix A for a description of construction phases). Construction activities during several of these phases would likely occur concurrently. To ensure a conservative analysis, maximum daily emissions during these periods of overlap were estimated assuming all equipment would operate at the same time. Detailed information on emissions modeling and quantification methods can be found in Appendix A.

An estimate of emissions associated with construction of the proposed project is presented in Table 3. As noted above, emissions are summarized during periods of construction activity overlap, as opposed to by individual construction phase. This approach is necessary to evaluate the maximum daily emissions that would be generated by concurrent construction activities.



Table 3. Construction-Related Criteria Pollutant Emissions (pounds per day)

Construction Perioda ROG NOX CO PM10 PM2.5 SO2 7/1/2013 – 7/31/2013 0.01 0.02 0.16 0.00 0.00 0.00 8/1/2013 – 8/7/2013 0.02 0.05 0.48 0.00 0.00 0.00 8/8/2013 – 8/27/2013 0.01 0.02 0.16 0.00 0.00 0.00 8/27/2013 – 8/30/2013 5.07 42.69 22.50 2.45 2.42 0.06 9/1/2013 – 12/23/2013 5.06 42.67 22.34 2.45 2.42 0.06 12/24/201 – 3/31/2014 3.81 30.72 19.90 1.78 1.77 0.04 4/1/2014 – 6/30/2014 2.42 22.44 14.34 0.95 0.94 0.04 7/1/2014 – 8/25/2014 11.28 83.98 53.76 5.05 5.04 0.11 8/26/2014 – 12/22/2014 3.27 28.04 18.28 1.42 1.41 0.04 12/23/2014 – 4/20/2015 0.01 0.03 0.25 0.00 0.00 0.00 4/21/2015 – 8/10/2015 3.33 24.74 16.81 1.39 1.39 0.04 SDAPCD Trigger Levels 75 250 550 100 55 250 Significant? No No No No No No Source: ICF emissions modeling (Appendix A). Notes: a. The Construction periods were identified based on concurrent construction activities. Emissions shown represent the

maximum levels that would be generated during each period.

As shown in Table 3, criteria pollutant emissions associated with construction of the proposed project would be well below the applicable emissions thresholds. Therefore, air quality impacts as a result of project construction would be less than significant.

III. c) Less than Significant. The SDAB is currently in nonattainment for the federal 8-hour ozone standard and the state ozone, PM10, and PM2.5 standards (see Table 1). Therefore, the emissions of concern within the SDAB are ozone precursors (ROG and NOX), PM10, and PM2.5. The project would result in a cumulatively considerable net increase of these pollutants if emissions exceed the AQIA Trigger Levels shown in Table 2. In addition, cumulative impacts could occur if emissions of concern from other past, present, or reasonably foreseeable future projects within the proximity relevant to the pollutants of concern are in excess of direct air quality impact thresholds.

As discussed above, the proposed project would have a less-than-significant direct impact on air quality (see Table 3). Construction activities associated with roadway improvement projects might occur during the same period as project construction. Possible cumulative impacts on air quality as a result of these combined activities would be addressed by the standard SDAPCD measures that apply to construction projects, in addition to project-level mitigation strategies identified for each project. Therefore, the proposed project would not result in a cumulatively considerable net increase in emissions. This impact is less than significant.

III. d) Less than Significant. In 1998, ARB classified diesel particulate matter (DPM) as a carcinogenic TAC. TACs are pollutants that may result in an increase in mortality or serious illnesses or pose a present or potential hazard to human health. Health effects related to TACs include cancer, birth defects, neurological damage, damage to the body’s natural defense system, and diseases that lead to death. Heavy-duty construction equipment and haul trucks represent sources of DPM from project construction.



Sensitive receptors are defined as locations where pollutant-sensitive members of the population may reside or where the presence of air pollutant emissions could adversely affect use of the land. Sensitive members of the population include those who may be more negatively affected by poor air quality than other members of the population, such as children, the elderly, or the infirm. In general, residential areas, hospitals, daycare facilities, elder-care facilities, elementary schools, and parks typically contain a high concentration of these sensitive population groups.

Construction of the project would occur within an existing school facility that would be considered a sensitive receptor. There are also several homes located immediately adjacent to the construction site. Site improvements activities, which generate the most DPM of all phases, would occur during the summer when students are not present (7/1/2013–8/25/2013). Other construction activities, such as building modernization and electrical installation, could potentially occur during the school year, but these construction activities would not involve much use of diesel powered construction equipment. Emissions are expected to be minimal, despite conservative assumptions that equipment would operate concurrently. Moreover, construction activities would occur for less than 3 years, which is well below the assumed 70-year exposure period used to estimate lifetime cancer risks. The facility improvements would not generate any additional TACs during normal building operations, relative to existing conditions. Accordingly, neither construction nor operation of proposed project would expose sensitive populations to substantial pollutant concentrations. As a result, this impact is considered less than significant.

III. e) Less than Significant. Although offensive odors rarely cause any physical harm, they can be unpleasant, leading to considerable distress among the public and often generating citizen complaints to local governments and air districts. Project-related odor emissions would be limited to the construction period, when emissions from equipment may be evident in the immediately surrounding area. Potential sources that may emit odors during construction activities include asphalt paving and architectural coating of the building. These activities would be short term and are not likely to result in nuisance odors that would violate SDAPCD Rule 51. This impact is, therefore, considered less than significant.




Impact


Mitigation


Impact

No Impact

IV. Biological Resources

Would the project:

a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?

b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?

c) Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, etc.) through direct removal, filling, hydrological interruption, or other means?

d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery site?

e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?

f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?

IV. a–f) No Impact. The proposed project would not result in impacts on biological resources. The project site is currently developed and has been used as a middle school campus since 1969. The site is also located in the center of a densely populated area. The project site itself contains no biological resources, including habitats or wildlife corridors, and the nearest identified resources are located just over 0.5 mile west and north of the site. These resources include two small canyons identified as Conserved Land under the City of San Diego Multiple Species Conservation Program (MSCP) Multiple Habitat Planning Area (MHPA), each containing grassland and coastal sage scrub vegetation communities (City of San Diego 1997). Project construction would be far removed from these sensitive vegetation communities because all



construction activities would be conducted within the boundaries of the school campus. Therefore, project implementation would not result in impacts on biological resources.




Impact


Mitigation


No Impact

V. Cultural Resources

Would the project:

a) Cause a substantial adverse change in the significance of historical resources as defined in CEQA §15064.5?

b) Cause a substantial adverse change in the significance of an archeological resource pursuant to CEQA §15064.5?

c) Directly or indirectly destroy a unique paleontological resource or site, or unique geologic feature?

d) Disturb any human remains, including those interred outside of formal cemeteries? V. a–c) Less than Significant. A substantial change in the significance of a historic, archeological, or paleontological resource would not occur with implementation of the proposed project. The project site has been significantly disturbed by grading and excavation activities associated with prior development of the site for a landfill from approximately 1962 to 1967, and development of the middle school itself between 1967 and 1968. Any significant historical, archeological, or paleontological resources would have likely been disturbed or unearthed during these past activities. School improvements proposed for the existing school site involve minor construction activities including improvements and/or repairs to buildings and hardscaped areas; some trenching would be involved for utility repairs. Additionally, minimal grading would be necessary for the project improvements. Therefore, project-related impacts on cultural or paleontological resources are not expected to occur. In the event that buried cultural or paleontological deposits are encountered during any phase of construction, project activities in the vicinity of the resources would be temporarily halted, and a qualified archaeologist/ paleontologist would be consulted to assess the significance of the resource and to provide proper management recommendations. This proper protocol would insure that impacts for this issue would be less than significant.

V. d) Less than Significant. It is not anticipated that the project would disturb any human remains. As discussed above, the project site has been significantly disturbed by excavation and grading activities associated with the previous development of the site for a landfill and the existing school. Also, there are no human remains known to be present in the project area. For these reasons, no project-related impacts on any unknown remains are expected to occur. In the event that buried human remains are encountered during any phase of construction, project activities in the vicinity of the resources would be temporarily halted, and a qualified archaeologist would be consulted to assess the significance of the resource and to provide proper management recommendations in accordance with state and federal procedures for handling human remains. This proper protocol would insure that impacts for this issue would be less than significant.




Impact


Mitigation


Impact

No Impact

VI. Geology and Soils

Would the project:

a) Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving:

i. Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42.

ii. Strong seismic ground shaking? iii. Seismic-related ground failure, including liquefaction? iv. Landslides?

b) Result in substantial soil erosion or the loss of topsoil? c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site lateral spreading, subsidence, liquefaction, or collapse?

d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial risks to life or property?

e) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater?

VI. a) i & ii. Less than Significant. Bell Middle School is located in San Diego County, a known seismically active region where the potential for seismic hazards exists. Although no active or potentially active faults are located within the project site itself, a potentially active fault occurs approximately 300 feet west the project site (City of San Diego 2008). A seismic event on this fault could cause significant groundshaking on the project site and, therefore, the potential exists for onsite health and safety risks associated with a seismic hazard. Construction and design of the proposed improvements would comply with all seismic-safety development requirements including Title 24 standards of the 2010 California Building Code (based on the 2009 International Building Code [IBC]). Conformance with all applicable



seismic-safety development requirements would minimize seismic ground shaking effects in the event of a major earthquake and ensure that the potential seismic or geologic hazard impacts are less than significant. VI. a) iii & iv. Less than Significant. See discussion IV. a) i and ii, above. The project site is located in an area where seismic-related events could occur; however, all project improvements would comply with all state and local seismic-safety standards to minimize ground shaking effects. Additionally, all project improvements would take place within the existing school campus, which has a low potential for ground failure because the site has been previously graded and developed. Also, the project’s modernization activities would not significantly change the existing conditions of the site. For these reasons, impacts associated with these issues would be less than significant. VI. b) Less than Significant. Implementation of the proposed project would not cause substantial soil erosion or the loss of topsoil. All project improvements would occur within the existing campus, which is already developed. The site is also primarily underlain with soils that consist of Olivenhain cobbly loam, which have a slight to moderate potential of erodibility (USDA 2012, 1973). Other soils were imported to the site as fill during past landfill activities; however, none of the existing school buildings were built on top of these soils. Therefore, the project would not result in substantial soil erosion. Additionally, the project proposes to improve the storm drain system, which would further reduce the opportunity for rapid stormwater runoff that could intensify erosion potential. Therefore, impacts associated with this issue would be less than significant. VI. c & d) Less than Significant. The proposed school improvements are not anticipated to have significant impacts associated with unstable soil, including expansive soils, that would result in on- or offsite lateral spreading, subsidence, liquefaction, or collapse. A majority of the project site and surrounding area is currently developed on terrain considered to have a low to moderate risk for geologic hazards (City of San Diego 2008). Also, because of previous onsite development and grading activities, the potential for near-surface expansive soils at the project site is considered low. Furthermore, the modernization activities of the proposed project would not require substantial grading and/or excavation or significantly change the existing conditions of the site. No features of the proposed modernization efforts would occur over the area previously used for landfill purposes. Therefore, impacts would be less than significant. VI. e) No Impact. The project would not result in any impacts associated with inadequate soils to support septic systems. The school would not use septic tanks or alternative wastewater disposal systems because it uses, and proposes to improve, the existing sewer system for the disposal of wastewater. Therefore, there would be no impact.




Impact


Mitigation


Impact

No Impact

VII. Greenhouse Gas Emissions

Would the project:

a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?

b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?

This section is divided into three parts (Existing Conditions, Significance Thresholds, and Impact Analysis) and describes the existing environmental setting as it pertains to global climate change, summarizes relevant significance thresholds, and assesses greenhouse gas (GHG) impacts associated with the proposed project. Existing Conditions

Climate change is a term used to describe large-scale shifts in existing patterns in the earth’s climate system. Although the climate has historically responded to natural drivers, recent climate change has been unequivocally linked to increasing concentrations of GHGs in the earth’s lower atmosphere (Intergovernmental Panel on Climate Change 2007a). The rapid loading of GHGs into the atmosphere is primarily due to the burning of fossil fuels since the industrial revolution. Higher concentrations of heat-trapping GHGs in the atmosphere result in increasing global surface temperatures, a phenomenon commonly referred to as global warming. Warming of the earth’s lower atmosphere induces large-scale changes in planetary systems, including ocean circulation patterns, precipitation patterns, global ice cover, and biological distributions (Intergovernmental Panel on Climate Change 2007a, 2007b). Key characteristics of the primary GHGs identified by the Intergovernmental Panel on Climate Change (IPCC) are summarized in Table 4 below. Unlike criteria air pollutants, which occur locally or regionally, the long atmospheric lifetimes of these GHGs allow them to be well-mixed in the atmosphere and transported over distances.



Table 4. Key Characteristics of Principle Greenhouse Gases

GHG Primary Emissions Sources

Global Warming Potential (GWP)a

Atmospheric Lifetime (years)b

Atmospheric Abundance

(2005) Carbon dioxide (CO2) Burning of fossil fuels

Gas flaring Cement production Land use change

1 50–200 391 ppm

Methane (CH4) Burning of fossil fuels Agriculture processes Livestock Landfill outgassing Land use change

21 9–15 1,871 ppb

Nitrous oxide (N2O) Burning of fossil fuels Agriculture processes Nitric acid production Nylon production

310 120 323 ppb

Hydrofluorocarbons (HFCs)

Commercial, industrial, and consumer products

Air conditioners and refrigerants

140–11,700 1.5–264 3.9–65 ppt

Perfluorinated carbons (PFCs)

Aluminum production Semiconductor

manufacturing 6,500–9,200 10,000–50,000 2.9–74 ppt

Sulfur hexafluoride (SF6)

Power distribution Semiconductor

manufacturing 23,900 3,200 7.4 ppt

Sources: Intergovernmental Panel on Climate Change 2007a, Carbon Dioxide Information Analysis Center 2012 Notes:

ppm = parts per million

ppb = parts per billion

ppt = parts per trillion a. The GWP is used to describe emissions of GHGs in terms of a single gas, known as carbon dioxide equivalent (CO2e).

GHGs are expressed as CO2e by normalizing emissions to CO2, which as a GWP of 1. b. Defined as the half-life of the gas.

Although there is currently no federal law specifically related to climate change or the reduction of GHGs, the EPA is developing proposed regulations under the Clean Air Act that may be adopted in the next 2 years. California has adopted statewide legislation addressing various aspects of climate change and GHG emissions mitigation. Much of this establishes a broad framework for the state’s long-term GHG reduction and climate change adaptation program. Of particular importance is Assembly Bill 32 (AB 32), which establishes a statewide goal to reduce GHG emissions back to 1990 levels by 2020. The governor has also issued several executive orders related to the state’s evolving climate change policy.



Significance Thresholds

As discussed previously in Section III, Air Quality, the SDAPCD has the primary responsibility for air quality management within San Diego County. However, the SDAPCD has not developed specific thresholds of significance with regards to addressing the GHG emissions in CEQA documents. In absence of a significance threshold published by the local air district, this analysis relies on recent GHG guidance prepared by the County and City of San Diego. The County of San Diego has adopted guidelines for evaluating the significance of climate change impacts. The guidelines identify a tiered approach to determining significance of project-related GHG emissions. Two bright-light numeric thresholds are proposed for annual emissions: 10,000 metric ton carbon dioxide equivalent (MTCO2e) for stationary source projects and 2,500 MTCO2e for other development projects (County of San Diego 2012). The City of San Diego has also identified an interim GHG threshold for commercial and residential land use development projects. This interim threshold is based on the 900 metric ton (MT) screening threshold in the California Air Pollution Control Officers Association (CAPCOA) report CEQA & Climate Change and serves as a conservative screening threshold (City of San Diego 2010). The County’s and City’s proposed GHG thresholds were developed to evaluate operational-related GHG emissions, as opposed to construction-related emissions. Indeed, no air district within the state has adopted construction-related GHG emissions thresholds. However, by way of comparison, criteria pollutant thresholds for project operations are often equal to or more stringent than those adopted for construction emissions. Accordingly, operational thresholds can be used to provide a conservative analysis of construction-related GHG emissions. A significant amount of GHG emissions is therefore defined as 2,500 MTCO2e per year,2 consistent with the County’s draft guidance. In accordance with the CEQA guidelines and scientific consensus regarding the cumulative nature of GHGs,3 the following analysis includes a cumulative, rather than project-level, evaluation of GHG impacts. Impact Analysis

VII a) Less than Significant. The most common GHGs resulting from human activity are CO2, CH4, and N2O. The IPCC and AB 32 also define GHGs to include HFCs, PFCs, and SF6. These latter GHG compounds are usually emitted in industrial processes and, therefore, are not applicable to the proposed project.

As discussed in Section III, Air Quality, operation of the proposed project would neither generate a significant number of new vehicles trips nor add additional capacity to area roadways. Likewise, the project would not use any electricity or natural gas for increased lighting or operation/maintenance requirements. Consequently, the project would not generate any direct long-term operational emissions or contribute to indirect emissions. This assessment therefore focuses exclusively on GHG emissions generated during project construction.

2 Consistent with City and County guidance, construction emissions are amortized over 30 years to obtain an annual GHG estimate. 3 Climate change is a global problem, and GHGs are global pollutants, unlike criteria air pollutants (such as ozone precursors), which are primarily pollutants of regional and local concern. Given their long atmospheric lifetimes (see Table 1), GHGs tend to accumulate in the atmosphere. Therefore, GHG impacts are inherently cumulatively considerable.



Construction activities would generate short-term emissions of CO2, CH4, and N2O from the use of equipment (e.g., forklifts) and on-road vehicles (e.g., employee commuter cars and haul trucks). Construction emissions emitted by these sources were estimated using emission factors provided by CalEEMod (version 2011.1.1). Table 5 summarizes the results of the emissions modeling. Please refer to Appendix A for additional information on emissions modeling and quantification methods.

Table 5. Construction-Related Greenhouse Gas Emissions (metric tons per year)

Year Construction Equipment

On-Road Vehicles CO2e

CO2 CH4 N2O CO2 Othera

2013 149 0.008 0.004 14 0.562 164 2014 383 0.022 0.010 43 1.884 432 2015 62 0.004 0.002 12 0.516 74 Total 593 0.034 0.015 69 2.962 670 Amortized Totalb 20 0.001 0.001 2 0.099 22 Source: ICF emissions modeling (Appendix A). Notes: a. Includes CH4, N2O, and other trace GHGs emitted by on-road vehicles. b. Total construction emissions were divided by 30 to obtain the amortized emissions total.

As shown in Table 5, 670 MTCO2e would be emitted over the proposed 3-year construction period for the middle school. Consistent with the County’s draft GHG guidance, the sum of project-related GHG emissions (670 MT) was amortized over a 30-year period. This results in an annual GHG emission rate of approximately 22 MTCO2e. The amortized 30-year average GHG emission rate is considerably lower than the 2,500 MT per year threshold used by the County of San Diego. Moreover, modernization upgrades would involve increased use of insulation within the school structures and installation of more efficient appliances/equipment, leading to lower operational GHGs by way of less energy consumptions. These savings could potentially offset a portion of the amortized emissions. GHG impacts caused by emissions from project construction are therefore considered to be less than significant.

VII b) Less than Significant. SDAPCD has not yet adopted a qualified plan, policy, or regulation to reduce GHG emissions. Therefore, the most applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions is AB 32, which codified the State’s GHG emissions reduction targets for the future.

ARB adopted the AB 32 Scoping Plan as a framework for achieving AB 32. The Scoping Plan outlines a series of technologically feasible and cost-effective measures to reduce statewide GHG emissions. These strategies are geared towards sectors and activities that generate significant amounts of GHGs. For example, the majority of measures address building, energy, waste and wastewater generation, goods movement, on-road transportation, water usage, and high global warming potential gases. Activities associated with the project are not considered by the AB 32 Scoping Plan as having a high potential to emit GHGs. This statement is substantiated by the project-level emissions analysis, which demonstrates that the GHG emission rate is considerably lower than the 2,500 MT per year threshold used by the County of San Diego. The emissions are also less than the interim screening threshold of 900 MT per year used by the City of San Diego. Consequently, none of the AB 32 reduction strategies are applicable to construction of the project. Facility upgrades associated with long-term operation of the project are consistent with



AB 32 because they would result in energy efficiency and building energy enhancements. Implementation of the project would therefore not conflict with implementation of AB 32, and this impact is considered less than significant.




Impact


Mitigation


Impact

No Impact

VIII. Hazards/Hazardous Materials

Would the project:

a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?

b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?

c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances or waste within one-quarter mile of an existing or proposed school?

d) Be located on a site which is included in a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and as a result, would it create a significant hazard to the public or the environment?

e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area?

f) For a project within the vicinity of a private airstrip, would the project result in a safety hazard for people residing or working in the project area?

g) Impair implementation of, or physically interfere with, an adopted emergency response plan or emergency evacuation plan?

h) Expose people or structures to a significant risk of loss, injury, or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands?

A Hazardous Materials/Title 5 Safety Analysis (Appendix B of this document) was prepared for the Bell Middle School property by Ninyo & Moore in July 2012. The analysis addresses issues identified in the California Code of Regulations, Title 5, Section 14010.

VIII. a & c) Less than Significant. The modernization of the existing school would not create a significant hazard to the public or the environment associated with the handling of hazardous materials. Project construction would require the use of typical materials associated with construction such as diesel fuels, hydraulic liquids, oils, solvents, and paints. Also, the project



proposes that any potentially hazardous materials found on site are to be removed. Any hazardous materials used or removed during project construction would be transported, used, and stored in accordance with state and federal regulations regarding the handling of hazardous materials.

Post-construction activities would not change from the existing operations at the middle school. The routine transport, use, or disposal of hazardous materials used on the school site would be conducted in accordance with state and federal regulations. Therefore, construction and operational impacts for these issues would be less than significant.

VIII. b & d) Less than Significant with Mitigation. As discussed previously, the southern portion of the school project site formerly operated as a sanitary landfill from approximatley1962 to 1967. Types of waste disposed at the site are unknown but are believed to have been municipal solid waste. School buildings and structures are not located over the landfill’s waste footprint. This area is currently used for portions of the athletic fields and a small portion of the parking lot (see Appendix B).

The landfill site within the project area is identified on the California Department of Resources Recycling and Recovery Solid Waste Information Systems (SWIS) database (SWIS No. 37-CR-0088). Groundwater monitoring and reporting is currently conducted by the District in accordance with Regional Water Quality Control Board San Diego Region Order No. 97-11. Also conducted at the site are landfill gas (LFG) extraction, monitoring, and reporting in accordance with California Code of Regulations, Title 27 by the County of San Diego under the oversight of the City of San Diego, Solid Waste Local Enforcement Agency (LEA).

The school modernization activities performed within or outlying the assumed landfill footprint (e.g., trenching for utility improvements) could potentially encounter landfill wastes and contaminated soils in the vicinity of the landfill’s waste footprint. Based on the active LFG extraction system currently operating at the site, there is a low likelihood of encountering high concentrations of LFG in areas outlying the landfill’s waste footprint; however, high concentrations of LFG could be encountered in areas located within the waste footprint. The majority of the proposed improvements are not located within the landfill’s assumed waste footprint and therefore wouldn’t require disturbance of any portion of the waste footprint during construction. However, all of the proposed improvements are within 1,000 feet of the assumed waste footprint, and some of the utility improvements and a portion of the student drop-off/pick-up project area are located within the assumed waste footprint and require subsurface work. Therefore, exposure of buried waste and contaminated soils and LFGs during construction could occur, and this is considered a significant hazards impact on the public or the environment.

To mitigate this potential impact, the District would implement a Master Community Health and Safety Plan (CHSP) and a Master Soil Management Plan (SMP) during the construction of the project. Both the CHSP and SMP were prepared by Ninyo & Moore in 2011. The focus of the CHSP is to protect the public and surrounding land uses from potential health hazards during future onsite grading, excavation, trenching, or other construction activities that involve disturbing subsurface materials.



Compliance with these plans would mitigate the project’s potential for exposure to buried wastes and LFGs during construction to a less-than-significant level. A summary of both of these plans (Mitigation Measures HAZ-1 and HAZ-2) is provided below.

Mitigation Measure HAZ-1 – Master Community Health and Safety Plan (CHSP)

In accordance with the requirements of the CHSP, a site-specific health and safety plan shall be prepared by the contractor or agency performing the work prior to construction. The contents of the site specific plan shall be reviewed and approved by the District prior to starting construction. The site-specific health and safety plan shall be prepared in accordance with Federal and State Occupational Safety and Health Administration (OSHA) Hazardous Wastes Operations and Emergency Response (HAZWOPER) Standards; Code of Federal Regulations, Title 29, Section 1910.120; and California Code of Regulations, Title 8, Section 5192.

The CHSP and the site-specific health and safety plan would be applied during the project’s construction activities that involve disturbance of subsurface materials within or outlying the assumed landfill waste footprint, and at locations within approximately 1,000 feet outward from the assumed waste footprint. Specific procedures of the CHSP are attached in Appendix B of this document. Generally, the procedures identified in the CHSP that could be implemented to minimize hazards during construction include:

Evaluation of potential public exposure to hazards;

LFG and air quality perimeter monitoring;

Action planning to reduce airborne concentrations if found;

Documentation of daily instrument readings;

Implementation of administrative and engineering control methods (e.g., reduce public access, prevent or minimize fugitive vapors, odors, and dust, and reduce noise and other physical hazards);

Implementation of site security;

Daily backfill (when feasible) or fencing off of open excavations;

Use of metal, water-tight roll-off bins and multiple liners during temporary storage of stockpiled materials;

Onsite vehicle traffic tracking;

Implementation of Best Management Practices (BMPs) regarding hazardous materials;

Emergency planning in case of accidental or unauthorized release; and

Providing Public Notice and Proposition 65 Warning required under Section 25249.6 of the State of California Health and Safety Code.



Mitigation Measure HAZ-2 – Master Soil Management Plan (SMP)

The objective of the SMP is to assist construction workers at the project site with notifications of the excavation, monitoring, segregation, characterization, handling, and reuse and/or disposal (as appropriate) of wastes that may be encountered during earthwork activities. The SMP is attached as Appendix B of this document. A summary list of the SMP’s procedures that could be implemented during construction to minimize hazards is provided below:

Periodic site inspections;

Notification for disturbance of subsurface materials;

Segregation of excavated materials that are contaminated, potentially contaminated, or clean soils/materials per Environmental Professional guidance;

Determination of soils suitable for possible on- or offsite reuse;

Stockpile management (includes implementation of BMPs and odor/vapor control measures);

Waste characterization (involves stockpile sampling);

Management of contaminated soil or waste transport and disposal;

Precautions in the event of encountering unknown hazardous substance; and

Documentation of contaminated soils or wastes if encountered.

The CHSP and SMP attached as Appendix B to this document along with a description of the proposed project improvements were reviewed and approved by the LEA in 2012. In accordance with a requirement of the LEA, the District will provide a detailed project description, site map indicating the location of proposed work, and a list of contact names and phone numbers to the LEA for approval in advance of project construction.

VIII. e & f) No Impact. Impacts with implementation of the proposed project associated with nearby airports would not occur. The project site is not located within an airport land use plan or within 2 miles of a public or private airport. Therefore, there would be no impact.

VIII. g) No Impact. The proposed project is the modernization of a school within existing school property and would not impair implementation of, or physically interfere with, an adopted emergency response plan or emergency evacuation plan. Additionally, the project proposes to improve access for the onsite fire lane. Therefore, there would be no impact.

VIII. h) No Impact. The project would not expose people or structures to a significant risk of loss, injury, or death involving wildland fires. The project site is located in the center of a densely populated community where there are no wildlands within or adjacent to the site. The San Diego National Wildlife Refuge includes wildlands and has experienced recent fire damage in 2007; however, the refuge is located approximately 3 miles from all project construction activities. Therefore, there would be no impact.




Impact


Mitigation


Impact

No Impact

IX. Hydrology and Water Quality

Would the project:

a) Violate any water quality standards or waste discharge requirements? b) Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or lowering of the local groundwater table level? (e.g., the production rate of pre existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted)?

c) Substantially alter the existing drainage pattern of the site or area, including the alteration of the course of stream or river, in a manner which would result in substantial erosion or siltation on- or off-site?

d) Substantially alter the existing drainage pattern of the site or area, including the alteration of the course of stream or river, or substantially increase the rate or amount of surface runoff, in a manner which would result in flooding on- or off-site?

e) Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems?

f) Otherwise substantially degrade water quality? g) Place housing within a 100-year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map?

h) Place within a 100-year flood hazard area structures which would impede or redirect flood flows? i) Expose people or structures to a significant risk of loss, injury or death involving flooding, including flooding as a result of the failure of a levee or dam?

j) Inundation by seiche, tsunami, or mudflow? IX. a & f) Less than Significant. The proposed project would not violate any water quality standards or waste discharge requirements. During construction, short-term water quality impacts associated with increased erosion could occur; however, the project would implement BMPs, required as part of a Stormwater Pollution Prevention Plan (SWPPP), to minimize erosion effects



and ensure that significant water quality impacts during the construction phase would not occur. Implementation of a SWPPP is a standard District procedure for school modernization projects. Additionally, groundwater monitoring and reporting is currently conducted by the District in accordance with Regional Water Quality Control Board San Diego Region Order No. 97-11 to ensure water quality standards are met. Therefore, impacts associated with water quality standards or waste discharge requirements would be less than significant.

IX. b) No Impact. There would be no impacts on groundwater with implementation of the proposed school improvements. The existing site is currently serviced by the City of San Diego’s Water Utilities Department, and the project does not propose to use groundwater. Therefore, there would be no impact associated with this issue.

IX. c & d) No Impact. The proposed school improvements would consist of improvements to existing structures and would not involve major alterations to existing paved areas or to the existing storm drain system. As a result, the proposed improvements would not substantially alter the site’s existing drainage pattern in a manner which would result in substantial erosion or siltation, or increase the amount of surface runoff. The proposed activities would have minimal disturbance to the site and would result in an amount of impervious surfaces similar to what currently exists on site. Therefore, the rate of surface runoff would not be increased. Therefore, no impacts associated with these issues are anticipated to occur.

IX. e) No Impact. The creation or contribution of runoff water that would exceed the capacity of existing or planned stormwater drainage systems would not occur with implementation of the proposed project. Drainage from the site would continue to be directed to the existing storm drain system, which the project proposes to improve. Additionally, as discussed in IX. c & d above, the project would result in an amount of impervious surfaces similar to the existing site, and, therefore, the amount of runoff volume entering the storm drain system would not create demand for new storm water facilities. Consequently, impacts associated with this issue would not occur.

IX. g & h) No Impact. Implementation of the proposed project would not involve the placement of housing or structures within a 100-year flood hazard area. As shown by flood maps provided by the U.S. Department of Homeland Security’s Federal Emergency Management Agency (FEMA), the school property is not located within a 100-year flood zone (FEMA 1997). Therefore, there would be no impact associated with these issues.

IX. i) No Impact. The proposed school improvements would not expose people or structures to significant risks involving flooding as a result of the failure of a levee or dam. No dams or levees exist in the project vicinity, and, as such, there would be no impact.

IX. j) No Impact. The project site is inland and not located on a site that could be inundated by seiche, tsunami, or mudflow. The Sweetwater Reservoir is the closest large body of water to the project site (located approximately 3 miles east of the project site). However, potential for damage due to seiche at this distance from the project site is considered unlikely. Therefore, there would no impact.




Impact


Mitigation


Impact

No Impact

X. Land Use and Planning

Would the project:

a) Physically divide an established community?

b) Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to, the General Plan, Zoning Ordinance, or any specific plan) adopted for the purpose of avoiding or mitigating an environmental effect?

c) Conflict with any applicable habitat conservation plan or natural community conservation plan?

X. a & b) No Impact. The proposed project would not conflict with any applicable land use plan or physically divide an established community. The project involves the modernization of an existing school on a site designated and zoned for school uses. Project improvements would not increase the capacity of the existing school or extend beyond its property. Furthermore, similar uses surround the project site because a number of other schools exist within the established community. Improvements to schools, as proposed by this project, would help enhance the community as a whole. Therefore, there would be no impact associated with these issues.

X. c) No Impact. The proposed project would not conflict with any applicable habitat or natural community conservation plan. The project area is currently developed as a middle school campus within a densely populated area. No sensitive habitats occur within or surrounding the middle school because existing development completely surrounds the site. Therefore, there would be no impact.




Impact


Mitigation


Impact

No Impact

XI. Mineral Resources

Would the project:

a) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?

b) Result in the loss of availability of a locally-important mineral resource recovery site delineated by the General Plan, specific plan, or other land use plan?

XI. a & b) No Impact. Implementation of the project would not result in the loss of mineral resources. The mineral land classification for the project site is Mineral Resource Zone 3 (MRZ-3), which is identified as an area containing mineral deposits that cannot be evaluated from available data (California Department of Conservation 1996). The project involves the modernization of an existing school site where no mineral extraction or other mining operations exist. Additionally, the District intends to continue school operations at the site, and, therefore, the site would not be available for mineral extraction activities in the future. Consequently, there would be no impact.




Impact


Mitigation


Impact

No Impact

XII. Noise

Would the project result in:

a) Exposure of persons to or generation of noise levels in excess of standards established in the General Plan or noise ordinance, or applicable standards of other agencies?

b) Exposure of persons to, or generation of, excessive ground borne vibration or ground borne noise levels?

c) A substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project?

d) A substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project?

e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?

f) For a project within the vicinity of a private airstrip, would the project expose people residing or working in the project area to excessive noise levels?

Noise Existing Conditions

The existing offsite noise-sensitive receivers in the vicinity of the project site include single-family residences to the north, south, and east. Multi-family residences are located to the west of the project site. Onsite noise-sensitive receivers include classrooms and other school-related facilities such as outdoor play and eating areas.

The noise environment in the area consists of noise from traffic along Briarwood and Paradise Valley Roads. Other noise sources in the project vicinity are typical of residential land uses, such as cars starting up, barking dogs, and occasional activities such as landscape maintenance.

Noise Standards and Significance Thresholds

The proposed project is subject to the policies and standards contained in City of San Diego CEQA Significance Determination Thresholds, which state that:



Temporary construction noise which exceeds 75 dB(A) Leq at a sensitive receptor would be considered significant. Construction noise levels measured at or beyond the property line of any property zoned residential shall not exceed an average sound level greater than 75-decibels (dB) during the 12-hour period from 7:00 a.m. to 7:00 p.m. In addition, construction activity is prohibited between the hours of 7:00 p.m. of any day and 7:00 a.m. of the following day, or on legal holidays as specified in Section 21.04 of the San Diego Municipal Code, with the exception of Columbus Day and Washington’s Birthday, or on Sundays, that would create disturbing, excessive, or offensive noise unless a permit has been applied for and granted beforehand by the Noise Abatement and Control Administration, in conformance with San Diego Municipal Code Section 59.5.0404.

Additionally, it shall be unlawful for any person to cause noise by any means to the extent that the one-hour average sound level exceeds the applicable limit given in the following table (Table 6 below), at any location in the City of San Diego on or beyond the boundaries of the property on which the noise is produced. The noise subject to these limits is that part of the total noise at the specified location that is due solely to the action of said person.

Table 6. 1-Hour Average Noise Level Thresholds within the City of San Diego

Land Use Time of Day One-Hour Average Sound Levels

(decibels)

Single Family Residential 7:00 a.m. to 7:00 p.m.

7:00 p.m. to 10:00p.m.

10:00 p.m. to 7:00 a.m.

50

45

40

Multi-Family Residential (up to a max density of 1/2,000)

7:00 a.m. to 7:00 p.m.

7:00 p.m. to 10:00p.m.

10:00 p.m. to 7:00 a.m.

55

50

45

All other Residential 7:00 a.m. to 7:00 p.m.

7:00 p.m. to 10:00p.m.

10:00 p.m. to 7:00 a.m.

60

55

50

Commercial 7:00 a.m. to 7:00 p.m.

7:00 p.m. to 10:00p.m.

10:00 p.m. to 7:00 a.m.

65

60

60

Industrial or Agricultural Anytime 75

Source: City of San Diego 2012b.

The sounds level limit at a location on the boundary between two zoning districts is the arithmetic mean of the respective limits for the two districts (City of San Diego 2012b).

Impact Analysis

XII. a) Less than Significant with Mitigation. Noise impacts related to construction and operation of the proposed project are discussed separately below.



Construction (offsite receivers) Construction activities related to development of the project would begin in July 2013 and continue through approximately August 2015. Construction phases during this time would require use of construction equipment ranging from hand tools and hand trucks to dump trucks and forklifts. This would cause short-term elevated noise levels at the residential land uses to the north, east, south, and west.

Noise levels generated during construction would vary dependent on the types of construction equipment used during construction activity, site geometry (i.e., shielding from intervening terrain or other structures), and the distance between the noise source and receiver. Noise from construction equipment would likely be audible at sensitive receivers surrounding the project site, the closest of which are east of the project site.

The anticipated construction noise levels for the loudest phase of construction were calculated using the Federal Highway Administration’s (FHWA) Roadway Construction Noise Model (RCNM). Inputs to the RCNM include the distance from construction equipment to receiver, construction equipment type, and the presence or absence of shielding from existing walls or buildings. Table 7 shows the noise levels calculated at a distance of 50 feet during construction.

Table 7. Loudest Construction Phase Noise Levels at 50 Feet

Construction Activity

Average Sound Level during Loudest Construction Phase

at 50 feet (dBA Leq)a

Site Improvements (Drop-off and Parking Design Upgrades)

83

Source: Federal Transit Administration 2008 Note: One sound level with all pertinent equipment operating. a. City of San Diego 2012b.

The nearest offsite noise-sensitive receivers are existing residences located approximately 300 feet to the east of where construction would take place. Construction noise levels are estimated to be as high as 68 dBA Leq at 50 feet from the construction site. These noise levels generated during construction are likely higher than the typical ambient daytime noise levels in the project area. Noise levels of this magnitude would be audible but would not likely dominate the noise environment in the area during project construction activities. Also, noise from construction would not exceed the City’s 75 dBA threshold. Therefore, impacts would be less than significant for offsite receivers.

Construction (onsite receivers) The anticipated construction noise levels for onsite noise exposure were also calculated using the FHWA’s RCNM. Table 7 above shows the noise levels calculated at a distance of 50 feet during construction.

The closest noise-sensitive receivers are existing classrooms and offices located on the campus, as close as 50 feet from where construction would take place. Construction noise levels could be as high as 83 dBA Leq. These noise levels would be considerably higher than the existing



ambient daytime noise levels on site. Noise levels of this magnitude would be clearly audible and would dominate the noise environment in the area during project construction.

As provided above, the City’s noise ordinance exempts construction activities from the noise standard (providing that such activities measured at or beyond the property line of any property zoned residential not exceed an average sound level greater than 75 dB during the 12-hour period from 7:00 a.m. to 7:00 p.m., or take place between the hours of 7:00 p.m. and 7:00 a.m., or on Sundays or any holiday). The construction activities of the proposed project would not exceed the City’s permitted construction hours. However, the short-term noise from construction would be loud at times at the nearby noise-sensitive land uses and, although temporary, could be disruptive. Therefore, Mitigation Measure NOI-1, which requires implementation of noise control measures, is provided to reduce construction noise levels to a less-than-significant level.

Mitigation Measure NOI-1

To reduce construction noise generated by the proposed project, the District will ensure that the contractor will implement the following measures:

All mobile or fixed noise-producing equipment used on the project that is regulated for noise output by a local, state, or federal agency will comply with such regulation while in the course of project activity.

Electrically powered equipment will be used instead of pneumatic or internal combustion powered equipment, where feasible.

Material stockpiles and mobile equipment staging, parking, and maintenance areas will be located as far as practicable from noise-sensitive receivers.

The use of noise-producing signals, including horns, whistles, alarms, and bells, will be for safety warning purposes only.

The onsite construction supervisor will have the responsibility and authority to receive and resolve noise complaints. A clear appeal process to the City and the District will be established prior to construction commencement that will allow for resolution of noise problems through coordination directly between the District and the City that cannot be immediately solved by the site supervisor.

Construction signs will be posted at the project site identifying a contact name and phone number to register noise complaints.

Operation Noise (offsite land uses) Project-Related Traffic Noise. The project is not anticipated to add increased capacity to the existing school, nor would the proposed project add any new ingress or egress points to the existing campus. Therefore, traffic and associated traffic noise would not be affected, and no impact would occur.

Project-Related Stationary Noise. The proposed project would include new heating, ventilation, and air conditioning (HVAC) units. The HVAC units would be located approximately 700 feet from the nearest property line where the closest sensitive offsite noise-sensitive receivers are located, with several school buildings in-between. The City’s Municipal Code states that it is



unlawful to produce noise that exceeds noise levels (listed in Table 6 above) at the property line of the property from where the noise is being produced. The City’s Municipal Codes do not specifically set noise limits for school facilities; therefore, 58 dBA Leq (the arithmetic mean of the commercial and single-family residential noise standards) was used. Because of the distance to the property line and the intervening structures, it is unlikely that noise from the new HVAC units would exceed 58 dBA Leq at the property line. However, as a precaution, the proposed project would incorporate a design standard to assure that new HVAC units would not exceed 80 dBA Leq at a distance of 50 feet.4 Therefore, noise impacts from new HVAC units would be less than significant.

XII. b) Less than Significant. The Federal Transit Administration (FTA) has compiled a list of typical vibration levels generated by construction equipment, which are commonly used as a reference for construction vibration level analysis. The vibration levels produced by construction equipment are outlined in Table 8 below.

Vibration levels from construction equipment attenuate as they radiate from the source. The equation to determine vibration levels at a specific distance is

PPVequip = PPVref x (25/D)^1.5

Where “PPVref” is the Peak Particle Velocity (PPV) at a reference distance of 25 feet, and “D” is the distance from the equipment to the sensitive receptor (USDOT 2006).

Groundborne vibration typically decreases rapidly with distance. Based on the FTA data (see Table 8), vibration velocities from typical heavy construction equipment operation that would be used during project construction range from 0.076 to 0.210 inches per second PPV at 25 feet from the source of activity. At 50 feet from the source activity (the nearest building), PPV ranges from 0.027 to 0.074 inch per second could be expected.

Because neither the state nor the local municipalities maintain regulatory standards for vibration, potential structural damage and human annoyance associated with vibration from construction activities were evaluated against California Department of Transportation (Caltrans) vibration limits (see Table 9). A vibration level of 0.10 inches per second PPV was used to evaluate impacts on nearby receivers because this level represents the boundary between barely perceptible and distinctly perceptible vibration as recognized by Caltrans and others. Because the predicted vibration levels from project construction would be well below applicable vibration thresholds, impacts from groundborne vibration or groundborne noise would be less than significant.

4 A noise level of 80 dBA at a distance of 50 feet from the noise source would attenuate to approximately 57 dBA at a distance of 700 feet, which is the approximate distance to the property line. This calculation does not factor in additional noise reduction from intervening structures or atmospheric attenuation and is therefore a conservative estimate.



Table 8. Typical Vibration Levels for Construction Equipment

Equipment

Approximate Peak Particle Velocity at 25 feet

(inches/second)

Approximate Peak Particle Velocity at 50 feet

(inches/second)

Large bulldozer 0.089 0.032

Loaded trucks 0.076 0.027

Vibratory Roller 0.210 0.074 Sources: Federal Transit Administration (FTA), Transit Noise and Vibration Impact Assessment Guidelines, May 2006. Notes: Peak particle velocity measured at 25 feet unless noted otherwise. Root mean square amplitude ground velocity in decibels (VdB) referenced to 1 micro-inch/second.

Table 9. Reaction of People and Damage to Buildings at Various Continuous Vibration Levels

Peak Particle Velocity (PPV) (in/sec) Human Reaction Effect on Buildings

0.006–0.019 Threshold of perception; possibility of intrusion.

Vibrations unlikely to cause damage of any type.

0.08 Vibrations readily perceptible. Recommended upper level of the vibration to which ruins and ancient monuments should be subjected.

0.10 Level at which continuous vibrations begin to annoy people.

Virtually no risk of “architectural” damage to normal buildings.

0.20 Vibrations annoying to people in buildings (this agrees with the levels established for people standing on bridges and subjected to relative short periods of vibration).

Threshold at which there is a risk of “architectural” damage to normal dwelling-houses with plastered walls and ceilings; special types of finish such as lining of walls, flexible ceiling treatment, etc., would minimize “architectural” damage.

0.4–0.6 Vibrations considered unpleasant by people subjected to continuous vibrations and unacceptable to some people walking on bridges.

Vibrations at a greater level than normally expected from traffic, but would cause “architectural” damage and possibly minor structural damage.

Source: Caltrans, Transportation- and Construction-Induced Vibration Guidance Manual, 2004.

XII. c) Less than Significant. As described in XII. a) above, the proposed project would not increase the school’s capacity and, therefore, would not result in an increase in traffic along the local roadway system. The proposed project would add new HVAC equipment; however, the new units would be located approximately 700 feet from the property line of the nearest offsite noise-sensitive receiver. Existing school buildings would also provide shielding from any potential increase associated with noise from new HVAC units. Therefore, impacts from a substantial increase in ambient noise levels would not occur and impacts would be less than significant.



XII. d) Less than Significant with Mitigation. As described in XII. a) above, construction-related activities and equipment used during construction of the proposed project would result in a temporary or periodic increase in ambient noise levels above existing levels. The City’s municipal code exempts construction-related noise provided it does not exceed an average sound level of 75 decibels (dBA) during the 12-hour period. The construction activities of the proposed project would not exceed the City’s permitted construction hours; however, the short-term noise from construction would be loud at times at the nearby noise-sensitive land uses and could be disruptive. Therefore, Mitigation Measure NOI-1, which implements noise control measures, is provided to reduce construction noise levels to a less-than-significant level.

XII. e) No Impact. The San Diego International Airport and Coronado Naval Airbase are located approximately 10 miles to the west of the project site. The project site is not located within any airport land use plan and is not within 2 miles of any public or private airport or airstrip. As a result, the proposed project site would not receive airport-related noises, and the project would not expose people residing or working within the project area to excessive noise levels.

XII. f) No Impact. The proposed project is not within the vicinity of a private airstrip. Therefore, no impact associated with this issue would occur.




Impact


Mitigation

Less Than Significant

Impact

No Impact

XIII. Population and Housing

Would the project:

a) Induce substantial population growth in an area, either directly (e.g., by proposing new homes and businesses) or indirectly (e.g., through extension of roads or other infrastructure)?

b) Displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere?

c) Displace substantial numbers of people, necessitating the construction of replacement housing elsewhere?

XIII. a–c) No Impact. The school modernization project would not substantially induce population growth or displace a substantial number of people or existing housing. The project is located in an established, built-out community, and the improvements proposed would not increase the capacity or operations of the existing school. Additionally, the project would not result in the extension of public roads or other infrastructure, which could impact population or housing in the area. Therefore, there would be no impact.




Impact


Mitigation


Impact

No Impact

XIV. Public Services

Would the project:

Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:

a) Fire protection? b) Police protection? c) Schools? d) Parks? e) Other public facilities (e.g., public libraries, senior centers, etc.)?

XIV. a–e) No Impact. The proposed project involves the modernization of an existing middle school, which would not result in substantial adverse physical impacts on public services. Implementation of project improvements would not increase the capacity or operations of the existing school, and, therefore, the project would not increase demand for additional public services. Additionally, the project proposes improvements to the school’s fire lane to enhance accessibility during an emergency. Therefore, there would be no impacts on public services.




Impact


Mitigation

Less Than Significant

Impact

No Impact

XV. Recreation

Would the project:

a) Increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?

b) Include recreational facilities or require the construction or expansion of recreational facilities that might have an adverse physical effect on the environment?

XV. a & b) No Impact. Implementation of the proposed project would not have impacts on recreational facilities. The proposed school improvements would not increase the capacity of the existing school and, therefore, would not generate additional demand for recreational uses. Additionally, implementation of the project would not require the provision of new recreational facilities. Therefore, there would be no impact.




Impact


Mitigation


Impact

No Impact

XVI. Transportation/Traffic

Would the project:

a) Cause an increase in traffic, which is substantial in relation to the existing traffic load and capacity of the street system (i.e., result in a substantial increase in either the number of vehicles trips, the volume to capacity ratio on roads, or congestion at intersections)? Conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non-motorized travel and relevant components of the circulation system, including but not limited to intersections, streets, highways, pedestrian and bicycle paths, and mass transit.

b) Conflict with an applicable congestion management program, including, but not limited to level of service standard and travel demand measures, or other standards established by the county congestion management agency for designated roads or highways?

c) Result in a change in air traffic patterns, including either an increase in traffic levels or a change in location that results in substantial safety risks?

d) Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?

e) Result in inadequate emergency access? f) Conflict with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance or safety of such facilities?

XVI. a & b) Less than Significant. Implementation of the project would not cause an increase to existing traffic or conflict with an applicable traffic plan. The project includes improvements to the onsite student pick-up and drop-off area and fire lane; however, these improvements would not change existing traffic levels generated by traffic associated with drop-off or pick-up or negatively impact traffic patterns in the surrounding area because the student capacity of the school is not proposed to be increased. During construction, the project would include minor



construction activities that would result in a small increase in traffic related to construction traffic trips. However, this increase would be minimal and temporary. Traffic from short-term construction activities would also not conflict with standards set forth in SANDAG’s County Congestion Management Program because there would be no change in Level of Service (LOS), and substantial effects on designated roadways would not occur. Furthermore, modernization of the school would not increase operation or capacity compared to existing conditions and, therefore, would not result in an increase to existing traffic. Consequently, impacts associated with these issues would be less than significant.

XVI. c) No Impact. The proposed school improvements would not change air traffic patterns. Therefore, there would be no impact.

XVI. d–f) No Impact. The project would not increase hazards due to design features, or result in inadequate emergency access. The project proposes to improve onsite access involving the student pick-up and drop-off area and fire lane. Implementation of these improvements would lessen safety hazards and enhance emergency access. In addition, the improvements would not conflict with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities. Therefore, there would be no impacts associated with these issues.




Impact


with Mitigation


Impact

No Impact

XVII. Utilities and Service Systems Would the project:

a) Exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board? b) Require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects?

c) Require or result in the construction of new storm water drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects?

d) Have sufficient water supplies available to serve the project from existing entitlements and resources, or are new or expanded entitlements needed?

e) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?

f) Be served by a landfill with sufficient permitted capacity to accommodate the project’s solid waste disposal needs?

g) Comply with federal, state, and local statutes and regulations related to solid waste? XVII. a, b, and e) No Impact. Implementation of the proposed project would not exceed applicable wastewater treatment requirements or result in the expansion or construction of new water or wastewater treatment facilities. The proposed improvements would not result in an increase to current student capacity or school operations and, therefore, would not necessitate a greater demand for this service. Additionally, the project involves improvements to the current onsite sewer system. Therefore, the demand for wastewater treatment would not increase from existing conditions. Impacts on wastewater service would not occur. XVII. c) No Impact. The proposed middle school improvements would not require or result in the construction of new storm water drainage facilities or the expansion of existing facilities. All improvements would occur within the existing school property, and an increase in school capacity or operations would not result. Furthermore, the project includes repair or replacement of damaged storm drains. Therefore, the demand on this system would not increase and the need for new storm water drainage facilities would not occur with implementation of the project. Thus, there would be no impact.



XVII. d) No Impact. Implementation of the proposed school improvements would not increase water demand. School operations and student capacity would remain the same as existing conditions; thus, demand for water service would not increase. Therefore, impacts on water supplies with implementation of the project would not occur. XVII. f & g) Less than Significant. The project would not result in significant impacts on solid waste disposal services. School operations and student capacity would remain the same as existing conditions; thus, demand for solid waste disposal service would not increase. Solid waste generated by the school would continue to be served by a permitted landfill with sufficient capacity to accommodate the project’s disposal needs. The school would also continue to comply with all applicable regulations associated with solid waste. Therefore, impacts associated with this issue would be less than significant.




Impact


Mitigation


No Impact

XVIII. Mandatory Findings of Significance

a) Does the project have the potential to degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory?

b) Does the project have impacts which are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)?

c) Does the project have environmental effects that will cause substantial adverse effects on human beings, either directly or indirectly?

XVIII. a & b) Less than Significant. The improvements would involve modernization of structures on an existing campus. As discussed in Section IV and Section V, the proposed project would not degrade the quality of the environment or impact biological or known cultural resources.

XVIII. c) Less than Significant with Mitigation. As discussed in Section XII, the District would comply with all City noise ordinance requirements during construction and noise mitigation measures are also included to reduce short-term construction noise impacts at nearby noise-sensitive land uses to less than significant. As a result, the proposed project would not contribute to significant cumulative impacts associated with noise during construction if other projects in the area are also under construction.

The proposed project would not involve an increase in student capacity at the school. As a result, the project would not result in increased pick-up and drop-off traffic or associated air quality impacts associated with traffic emissions that could contribute cumulative impacts associated with planned development in the area. Considering the student capacity would not increase the proposed improvements would also not increase the demand for public services or modification of utilities that could contribute to cumulative impacts associated with any other development planned in the area.



PREPARERS

ICF International: Jim Harry, Project Manager Erin Pace, Environmental Planner Shannon Hatcher, Air Quality/Greenhouse Gas Emissions Laura Yoon, Air Quality/Greenhouse Gas Emissions Mike Green, Noise Peter Hardie, Noise Teal Zeisler, GIS Ninyo & Moore: Lisa Bestard, Hazards and Hazardous Materials

REVIEWERS

San Diego Unified School District: Kathryn Ferrell, CEQA Coordinator Francisco Campuzano, Project Manager

REFERENCES

Carbon Dioxide Information Analysis Center (CDIAC). 2012. Carbon Dioxide Information Analysis Center. Available: <http://cdiac.ornl.gov/>. Accessed: June 7, 2012.

California Air Resources Board (ARB). 2012. Ambient Air Quality Standards. Available: <http://www.arb.ca.gov/research/aaqs/aaqs2.pdf>. Last Updated: February 2, 2012. Accessed: June 6, 2012.

California Department of Conservation. 2008a. Farmland Mapping and Monitoring Program (FMMP). Available: <ftp://ftp.consrv.ca.gov/pub/dlrp/FMMP/pdf/2006/sdg06_west.pdf>. Accessed: April 18, 2012.

———. 2008b. San Diego County Williamson Act Lands 2008. Available: <ftp://ftp.consrv.ca.gov/pub/dlrp/wa/Map%20and%20PDF/ San%20Diego/SanDeigoWA_08_09.pdf>. Accessed: April 12, 2012.

California Department of Conservation, Division of Mines and Geology. 1996. Update of Mineral Land Classification: Aggregate Materials in the Western San Diego County Production-Consumption Region. DMG Open-File Report 96–04.

California Department of Transportation (Caltrans). 2012. California Scenic Highway Mapping System, San Diego County. Available: <http://www.dot.ca.gov/hq/LandArch/scenic_highways/index.htm>. Accessed: April 18, 2012.

————. 2004. Transportation- and Construction-Induced Vibration Guidance Manual. Available: <http://www.dot.ca.gov/hq/env/noise/pub/vibrationmanFINAL.pdf>. Accessed: September 05, 2012.



California Natural Resources Agency. 2009. California Environmental Quality Act Guidelines. December.

City of San Diego. 2008. Seismic Safety Study, Geologic Hazards and Faults. Available: <http://www.sandiego.gov/development-services/hazards/pdf/geo14.pdf>. Accessed: April 18, 2012.

———. 2010. Memorandum: UPDATED – Addressing Greenhouse Gas Emissions from Projects subject to CEQA. August 18.

———. 2012a. Development Services Department Official Zoning Map. Available: <http://www.sandiego.gov/development-services/zoning/zoning.shtml>. Accessed: April 14, 2012.

———. 2012b. City of San Diego Municipal Code, Noise Control Section 59.59.04. Available: <http://docs.sandiego.gov/municode/MuniCodeChapter05/Ch05Art9.5 Division04.pdf>. Accessed: July 12, 2012.

City of San Diego, Community and Economic Development Department. 1997. Multiple Species Conservation Plan (MSCP). March.

County of San Diego. 2012. DRAFT Guidelines for Determining Significance – Climate Change. Available: <http://www.sdcounty.ca.gov/dplu/advance/climateactionplan.html>. Accessed: July 18, 2012.

Federal Emergency Management Agency (FEMA). 1997. Flood Insurance Rate Map (FIRM). June 19, 1997. Map Numbers: 06073C1908F and 06073C1916F. Available: <http://map1.msc.fema.gov/idms/IntraView.cgi?KEY=88460074&IFIT=1>. Accessed: April 18, 2012.

Federal Transit Administration (FTA). 2006. Transit Noise and Vibration Impact Assessment, FTA-VA-90-1003-06. Prepared by U.S. Department of Transportation. Available: <http://www.fta.dot.gov/documents/ FTA_Noise_and_Vibration_Manual.pdf>. Accessed: July 23, 2012.

———. 2008. Roadway Construction Noise Model. Software Version 1.1. Prepared by U.S. Department of Transportation.

Intergovernmental Panel on Climate Change (IPCC). 2007a. Introduction. In B. Metz, O.R. Davidson, P.R. Bosch, R. Dave, and L.A. Meyer, (eds.), Contribution of Working Group III to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change, 2007. Cambridge, U.K. and New York, NY, USA: Cambridge University Press. Available: <http://www.ipcc.ch/pdf/assessment-report/ar4/wg3/ar4-wg3-chapter1.pdf>. Accessed: July 18, 2012.

———. 2007b. Climate Change 2007: The Physical Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change. S. D. Q. Solomon in M. Manning, Z. Chen, M. Marquis, K.B. Averyt, M. Tignor and H.L. Miller (eds.). Available: <http://www.ipcc.ch/ipccreports/ar4-wg1.htm>. Accessed: July 18, 2012.

San Diego Air Pollution Control District (SDAPCD). 2010. Fact Sheet: Attainment Status. Available: <http://www.sdapcd.org/info/facts/attain.pdf>. Accessed: April 18, 2012.



San Diego Unified School District (SDUSD). 2011. San Diego Unified School District Long-Range Facilities Master Plan. Available: <http://www.sandi.net/page/954>. Accessed: July 17, 2012.

United States Department of Agriculture (USDA). 1973. Soil Survey: San Diego Area, California. United States Department of Agriculture, Soil Conservation Service, and Forest Service.

———. 2012. Natural Resource Conservation Service, Web Soil Survey. Available: <http://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx>. Accessed: April 18, 2012.

U.S. Environmental Protection Agency. 2012. Greenbook of Nonattainment Areas for Criteria Pollutants. Available: <http://www.epa.gov/oar/oaqps/greenbk/>. Last Updated: March 30, 2012. Accessed: June 6, 2012.



Comments Received in Response to the Draft MND

The Draft Mitigated Negative Declaration (MND) for the Bell Middle School Modernization Project (SCH No. 2012111026) was circulated for public review beginning November 9, 2012. The Draft MND included an analysis of potential impacts that could occur as a result of the modernization of the existing middle school campus.

A Notice of Intent (NOI) to Adopt an MND for the proposed project was filed with the San Diego County Clerk’s Office and published in the Union-Tribune on November 9, 2012. Copies of the Draft MND were sent to the State Clearinghouse and responsible agencies and individuals, and were made available for review at the office of the San Diego Unified School District at the Tierra Santa Branch of the San Diego County Public Library. The public review period for the Draft MND began on November 9, 2012 and ended on December 10, 2012. Two comment letters were received by the San Diego Unified School District from the Department of Toxic Substances Control (DTSC) and the Native American Heritage Commission (NAHC) in response to issuance of the Draft MND during the 34-day public review period. The State of California Governor’s Office of Planning and Research State Clearinghouse and Planning Unit also confirmed that the State Clearinghouse received two comment letters in response to the Draft MND (a copy of the Clearinghouse letter is attached). Responses to these comments for the Draft MND are provided on the following pages. It was determined by the District that no changes to sections of the Draft MND were required to be made based on comments received during public review.

This Final MND has been prepared in accordance with the requirements of the California Environmental Quality Act (California Public Resources Code Section 21000, et seq., [revised December 1998] herein, CEQA) and the State of California CEQA Guidelines, as amended February 1999 (California Administrative Code, Title 14, Section 15000, et seq.). The purpose of the Final MND is to provide the decision-making body, responsible agencies, and the public with environmental impact information relative to the proposed project. The San Diego Unified School District must consider the information contained in this Final MND prior to approving the proposed project.



Responses to the NAHC Comment Letter (dated November 26, 2012)

Considering that the project consists of improvements to existing educational facilities it is not anticipated that any impacts to cultural resources or sacred sites discussed in the letter from the NAHC would occur. A literature records search was conducted at the South Coastal Information Center. The results were negative. No previously recorded archeological sites have been recorded within the school boundaries. As described above in Section V. Cultural Resources of the Draft MND, the site has been previously graded and excavated and minimal grading is expected during project construction. As such, impacts on cultural resources are not anticipated; however, in the event that any buried cultural or paleontological deposits are discovered, construction activities would be temporarily halted and a qualified archaeologist and/or paleontologist would be consulted. The requirement that monitoring occur is consistent with the recommendations for monitoring that are described in the letter from the NAHC. In addition, if resources are encountered the appropriate Native American Contacts would be consulted as described in the letter from NAHC.

The NAHC letter describes the process for inadvertent discovery of human remains. As described in Section V.d Cultural Resources of the Draft MND, it is not anticipated that the project would disturb any human remains. As discussed above, the project site has been significantly disturbed by excavation and grading activities associated with the previous development of the site for a landfill and the existing school. Also, there are no human remains known to be present in the project area. For these reasons, no project-related impacts on any unknown remains are expected to occur. In the event that buried human remains are encountered during any phase of construction, project activities in the vicinity of the resources would be temporarily halted, and a qualified archaeologist would be consulted to assess the significance of the resource and to provide proper management recommendations in accordance with state and federal procedures for handling human remains. Following standard state and federal procedures would insure that impacts for this issue would be less than significant.



Responses to the DTSC Comment Letter (dated November 30, 2012)

An analysis of the proposed improvements to the existing schools that addressed the presence of hazardous materials and other hazards described in the DTSC letter was completed and is summarized in the Draft MND. A Hazardous Materials/Title 5 Safety Analysis was prepared for the Bell Middle School property by Ninyo & Moore in July 2012. The analysis addresses issues identified in the California Code of Regulations, Title 5, Section 14010 as well as comments identified in the DTSC letter. This study is included as appendix B to the Draft MND.

As described above in Section VIII. Hazards/Hazardous Materials of the Draft MND, the southern portion of the school project site formerly operated as a sanitary landfill from approximatley1962 to 1967. The landfill at Bell Middle School is currently under regulatory oversight by the City of San Diego Solid Waste Local Enforcement Agency (LEA), San Diego Air Pollution Control District (air emissions only), and San Diego Regional Water Quality Control (groundwater impacts only). The San Diego Unified School District is currently in compliance with all regulatory agency requests and there are not outstanding issues or violations related to operation of the school in the vicinity of the landfill. Types of waste disposed at the site are unknown but are believed to have been municipal solid waste. School buildings and structures are not located over the landfill’s waste footprint. This area is currently used for portions of the athletic fields and a small portion of the parking lot (see Appendix B of the Draft MND). The school modernization activities performed within or outlying the assumed landfill footprint (e.g., trenching for utility improvements) could potentially encounter landfill wastes and contaminated soils in the vicinity of the landfill’s waste footprint. To mitigate this potential impact, the District would implement a Master Community Health and Safety Plan (CHSP) and a Master Soil Management Plan (SMP) during the construction of the project. Both the CHSP and SMP were prepared by Ninyo & Moore in 2011. The focus of the CHSP is to protect the public and surrounding land uses from potential health hazards during future onsite grading, excavation, trenching, or other construction activities that involve disturbing subsurface materials. The SMP and CHSP were submitted to the LEA along with the scope of work for the modernization project. In a letter date, March 27, 2012, the LEA approved the scope of work for the modernization project contingent upon the implementation of the SMP and CHSP. Compliance with these plans would mitigate the project’s potential for exposure to buried wastes and landfill gases during construction to a less-than-significant level. Based on this information, it is the opinion of the District that comments 1 through 3 and 5 through 9 in the DTSC letter have been sufficiently addressed in the Draft MND and the Hazardous Materials/Title 5 Safety Analysis.

Comment 4 of the DTSC letter relates to investigation of potential hazards from materials such as asbestos and lead based paint. For projects where buildings, structures, and/or paved surface areas are to be demolished, the District includes in the contract specifications provisions for abatement and/or removal of asbestos-containing materials (ACM), lead-based paints (LBP), and other hazardous chemicals. The contract specifications include the applicable federal, state, and local regulatory requirements for the proper removal and disposal of ACM, LBP, and other hazardous chemicals. The District also includes in the contract specification copies of the



environmental investigations for the buildings, structures, and/or paved surface areas to be demolished. Based on this information, it is the opinion of the District that comment 4 in the DTSC letter is sufficiently addressed through standard District procedures required as a part of demolishing structures and/or paved surface areas.

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