Diana Scheffler | Boquita Drive
Sure enough, the 4,500-page Draft Environmental Report (DEIR) for One Paseo includes sections on air quality and greenhouse gas (GHG) emissions and concludes there is no significant impact either in the construction or operational phase of a 1.8 million square foot project that generates more than 27,000 automobile trips daily.
But what about documents that are not yet public? In the case of One Paseo, an interim “Recirculated DEIR” was published to address some of the objections to the DEIR but did not include objections to the air quality or GHG impact sections. Members of the community organization, What Price Main Street (WPMS) www.whatpricemainstreet.com/ , followed the provisions of California’s Public Records Act and acquired all correspondence related to One Paseo from the City’s Development Services Department. Among the documents coming to light were some written by professionals commenting on those segments of the DEIR. Here are some of their observations:
• The basis for the analysis was a report prepared for Kilroy Realty Corporation (not for the City of San Diego) by Helix Environmental Planning Inc. This company engages in development and construction but has apparently made no declaration that it will not partake in design, construction, or consulting efforts related to One Paseo.
• The modelling software (URBEMIS 2007) underlying the report does not include San Diego–specific emission factors and was superseded in 2011 by another model (CalEEMod).
• 2010 Federal and State Ambient Air Quality Standards are used instead of the 2012 edition which addresses additional pollutants.
• The study cites a 2008 California Air Pollution Control Officers Association report, rather than a later 2010 City of San Diego report, as the guide to analyzing greenhouse gas impacts.
• The Marine Corp Air Station at Miramar was the source of meteorological data, although the Del Mar Heights weather station would have been more representative of Carmel Valley.
• The Kearny Mesa Overland Avenue monitoring station was used to represent particulate matter, but is not adjacent to I-5 as One Paseo would be.
• In presenting existing pollution levels, arithmetic means figures are erroneously described as maximums.
• National Ambient Air Quality Standards are erroneously stated at lower levels than actually prescribed.
• Mobile sources of toxic air contaminants such as heavy duty diesel delivery trucks are not considered even though there are schools, playgrounds and residents in the immediate vicinity.
Vehicles account for, at minimum, 46% of greenhouse gas emissions based on San Diego County averages. It would seem clear to most that a project which adds over three times the square footage currently allowed in the community plan, and more than 27,000 automobile trips daily must have a significant effect on air quality and public health. So how can the DEIR claim there is no significant impact?
With the shortcuts and errors indicated above, the DEIR is able to claim a decrease in what would otherwise be a projected increase. If it is the goal of state legislation AB 32 for communities to reduce green house gases, this project runs contrary to those mandates.