Response to Comments - Presidio Trust

sources, it has superior air quality. The nearest point within the Point Reyes National Seashore isapproximately ten miles (16 kilometers) to the northwest, and generally upwind, of the PHSH district.Construction-phase emissions would be of limited duration and quantity, and the longer-term emissionsassociated with occupation and use of the alternatives would not adversely affect regional or localized airquality. Table 19 shows that emissions of each alternative would be well below 80 lb/day (less than 14.4tons per year) of reactive organic gases (ROG), nitrogen oxides (NOx), and particulate matter (PM 10 ).These emissions would mainly occur from mobile sources, and they would not be subject to federalpermitting requirements for protecting air quality-related values (including visibility). However, forcomparison, the emissions from the alternatives would not qualify as significant according to the federalstationary-source permitting program for Prevention of Significant Deterioration (PSD) [40 CFR52.21(b)(23)]. Because of the limited emissions of each alternative and the generally upwind andrelatively distant location of the Point Reyes National Seashore, no adverse impact on air quality-relatedvalues (including visibility) is anticipated to occur.AQ-5. Federal Standards for Fine Particulate MatterThe CCSF noted that there are additional federal standards for fine particulate matter, i.e., PM 2.5 . Theyasked that the SEIS discuss these values and how the alternatives relate to these standards.Response AQ-5 – The federal designations for PM 2.5 attainment were established in 2005. The SanFrancisco Bay Area was found to attain the federal PM 2.5 standards, and this information has beenupdated and included in the Final SEIS. The most recent regional air quality attainment plan was updatedby the BAAQMD in January 2006, and although it addresses ozone, it also indirectly helps to managePM 2.5 . Despite the fact that the BAAQMD is not required to develop an attainment strategy specificallyfor PM 2.5 , the control of ozone precursors specified by the ozone plan will consequently help to controlthe reactions that lead to formation of secondary PM 2.5 in the atmosphere. The BAAQMD has not yetdeveloped recommendations on how to quantify or characterize PM 2.5 impacts. However, none of thealternatives are anticipated to adversely affect PM 2.5 concentrations because 1) the alternatives would beconsistent with the local ozone plan for attainment, which addresses precursors to both ozone and PM 2.5formation; and 2) none of the alternatives would cause significant emissions of any pollutant includingPM 10 , which includes PM 2.5 as a subset.AQ-6. Characterization of Noise Levels within Alternatives 2 and 3RPN doubted the Draft SEIS conclusion that the evening and weekend noise for Alternative 3 wouldlikely be similar to Alternative 2. They suggested that the conclusion defies common sense and lackssupporting data given the differential in tenant population and traffic.Response AQ-6 – Alternative 3 would involve a residential population equivalent to that of the revisedAlternative 2, and Alternative 3 would mainly be distinguished by a lack of the office and educationaluses that would occur under Alternative 2. Traffic for daily and peak hour conditions and parking66 Responses to Comments Public Health Service Hospital