November 18, 2010

Mr. Scott Vurbeff

Environmental Coordinator
City of Encinitas
505 S. Vulcan Avenue
Encinitas, CA 92024

RE: Air Quality and Mobile Source Air Toxics Analyses

I-5 North Coast Corridor Project

Dear Mr. Vurbeff:

At the request of the City of Encinitas, Scientific Resources Associated (SRA) has
conducted a technical review of the Air Quality Section of the Draft EIR/EIS, and a
technical review of the Air Quality and Mobile Source Air Toxics (MSAT) Analyses
provided as appendices to the Draft EIR/EIS.

General comments on the analysis are as follows:

• There is substantial evidence in published studies that demonstrate that residents

and sensitive receptors, including children, experience adverse health effects from
freeway air emissions. None of these studies were discussed or evaluated in the
Draft EIR/EIS. SRA has provided a list of current studies in the attached
literature review that summarize the available evidence.
• The analysis is based on technical studies (Air Quality and MSAT Analyses) that
were prepared in 2007 and 2008, respectively, which are outdated. Updated
information, data, and guidance have been issued since the reports were written.
• The analysis focuses on standard guidance from the Federal Highway
Administration (FHWA) to evaluate potential particulate matter impacts, but does
not address additional issues under the California Environmental Quality Act.
The analysis states that the project is not a project of air quality concern for
particulate matter; however, the I-5 North Coast Corridor is located in a state
nonattainment area, and with increases in traffic does have the potential to
increase the frequency and/or severity of exceedances of the state standard. Also,
the document states that background particulate matter concentrations are
decreasing in the San Diego Air Basin, which is not shown by the data. While
there is no standard methodology currently available to address potential health

1328 Kaimalino LaneSan Diego, CA 92109 (858) 488-2987

Mr. Scott Vurbeff
November 18, 2010
Page 2

effects from exposure to ultra-fine particulate matter, in recent studies, ultra-fine

particulate matter has been identified as a potential health concern. Future studies
may show that additional analysis is warranted.
• The analysis does not address the potential for impacts to additional receptors to
due the widening of the I-5 corridor, which will result in travel lanes placed from
48 to 73 feet closer to existing land uses in the vicinity of the freeway. The
California Air Resources Board, in their Air Quality and Land Use Handbook,
recommend that sensitive receptors not be sited within 500 feet of a freeway due
to potential adverse health effects. The attached figures illustrate the existing
500-foot buffer, and the additional receptors/land uses that will be included in a
500-foot buffer with the widening of the I-5 North Coast Corridor through the
City of Encinitas.
• No discussion of potential exposure to elevated levels of NO2 was provided in the
Draft EIR/EIS. While there is no standard methodology for evaluating health
effects due to exposure to NO2, recent studies indicate that NO2 may be associated
with increased incidence of childhood asthma. NO2 emissions as calculated with
the EMFAC2007 Model increase with increasing speeds. According to the Draft
EIR/EIS, under the Build Alternatives both traffic volumes and speeds will
increase, leading to increases in NO2 emissions over the No Build Alternative.
No discussion of the potential for increased emissions has been provided.
• The analysis states that there is no technical approach for evaluating potential
health effects from MSAT exposure. The California Air Resources Board and the
Office of Environmental Health Hazard Assessment recommend use of the
USEPA’s AERMOD model to evaluate potential exposures, and the HotSpots
Analysis and Reporting Program (HARP) to address potential health risks. These
models are in standard usage throughout the state of California for both stationary
and mobile source projects.

SRA is providing additional specific comments on the Draft EIR/EIS, Draft Air Quality
Analysis, and Draft MSAT Analysis, which are attached.

In conclusion, it is SRA’s opinion that the current analysis is based on outdated

information and standard FHWA guidance. The analysis does not address potential
impacts to populations that will be affected by the widening of the roadway and does not
follow standard technical approaches and guidance for evaluating impacts under CEQA.
The project warrants additional analysis, including a quantitative evaluation of health
effects associated with exposure to freeway emissions, and an evaluation of additional
receptors within the City that would be exposed with widening of the freeway corridor.

Sincerely,

Valorie L. Thompson, Ph.D.

Principal

1328 Kaimalino LaneSan Diego, CA 92109 (858) 488-2987