Chapter 12: Air Quality - New York...PM2.5 for Brooklyn (JHS 126), the de minimis criterion for the...

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Bedford Union Armory CEQR No: 16DME005K 12-1 Chapter 12: Air Quality Chapter 12: Air Quality I. INTRODUCTION This chapter examines the potential for the Proposed Actions to result in significant adverse impacts to air quality due to air pollutant emissions from on-site stationary sources of heating, ventilation, and air conditioning (HVAC) equipment, emissions from mobile sources generated by the Proposed Development, and emissions from on-site parking facilities. The assessment also evaluates the impact of existing air pollutant sources near the Project Site on the Proposed Development. The air quality analyses followed the procedures outlined in the City Environmental Quality Review (CEQR) Technical Manual and guidance from the New York City (NYC) Department of Environmental Protection (DEP). The results of the analysis are used to determine the potential for the Proposed Actions to cause exceedances of ambient air quality standards, de minimis values, or health-related guideline values. As described in Chapter 1, “Project Description,” the Proposed Actions would facilitate the redevelopment of the historic Bedford Union Armory into an approximately 542,393 gross square feet (gsf) three-building mixed-used development, which would consist of approximately 390 residential dwelling units (DUs), including approximately 177 affordable DUs, up to 48,997 gross square feet (gsf) of office space, up to 18,122 gsf of academic space, approximately 72,252 gsf of community facility space, and a minimum of 118 parking spaces on the Project Site (Analysis Scenario 1) 1 . The air quality analysis is based on Analysis Scenario 1 for the 2020 analysis year. II. PRINCIPAL CONCLUSIONS Air quality analyses addressed mobile sources, parking facilities, stationary HVAC systems, and air toxics. Based on the information and analyses provided in this chapter, no significant adverse impacts are projected for air quality due to the Proposed Actions. This includes the effects of the Proposed Actions on the surrounding community, the effects of the surrounding community on the Proposed Actions, and potential project-on-project impacts. The results of the analyses are summarized below: A screening analysis was completed to determine the impact of carbon monoxide (CO) and particulate matter (PM) from additional motor vehicles due to the Proposed Development. The results of this analysis indicated that modeling of traffic air quality was warranted for PM2.5 and PM10 at the intersection of Bedford Avenue and President Street. Further screening of this intersection based on a Tier I CAL3QHCR analysis showed that motor vehicles due to the Proposed Development would not result in a significant adverse impact on air quality. Due to the number of parking spaces (118 spaces) in the proposed on-site parking garage, a detailed analysis was completed of the impact of PM2.5 emissions from the parking facility. This analysis that the parking garage would not result in a significant air quality impact. An (E) Designation (E-428) will be assigned to the Project Site and will require the use of natural gas for Building 2 on the Project Site. With these measures in place, the emissions from on-site 1 Should the 18,122 gsf of academic space be determined infeasible, 25 additional DUs (including 14 affordable DUs) would be incorporated into the Proposed Development in lieu of the 18,122 gsf of academic space and associated office space (approximately 8,278 gsf). The additional 25 DUs is included—as “Analysis Scenario 2”—in the relevant analysis areas to ensure the most conservative analysis is achieved.

Transcript of Chapter 12: Air Quality - New York...PM2.5 for Brooklyn (JHS 126), the de minimis criterion for the...

Page 1: Chapter 12: Air Quality - New York...PM2.5 for Brooklyn (JHS 126), the de minimis criterion for the 24-hour concentration of PM2.5 would be 6.0 ug/m 3 . A project increment greater

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Chapter 12: Air Quality

I. INTRODUCTION

This chapter examines the potential for the Proposed Actions to result in significant adverse impacts to air quality due to air pollutant emissions from on-site stationary sources of heating, ventilation, and air conditioning (HVAC) equipment, emissions from mobile sources generated by the Proposed Development, and emissions from on-site parking facilities. The assessment also evaluates the impact of existing air pollutant sources near the Project Site on the Proposed Development. The air quality analyses followed the procedures outlined in the City Environmental Quality Review (CEQR) Technical Manual and guidance from the New York City (NYC) Department of Environmental Protection (DEP). The results of the analysis are used to determine the potential for the Proposed Actions to cause exceedances of ambient air quality standards, de minimis values, or health-related guideline values.

As described in Chapter 1, “Project Description,” the Proposed Actions would facilitate the redevelopment of the historic Bedford Union Armory into an approximately 542,393 gross square feet (gsf) three-building mixed-used development, which would consist of approximately 390 residential dwelling units (DUs), including approximately 177 affordable DUs, up to 48,997 gross square feet (gsf) of office space, up to 18,122 gsf of academic space, approximately 72,252 gsf of community facility space, and a minimum of 118 parking spaces on the Project Site (Analysis Scenario 1)1. The air quality analysis is based on Analysis Scenario 1 for the 2020 analysis year.

II. PRINCIPAL CONCLUSIONS

Air quality analyses addressed mobile sources, parking facilities, stationary HVAC systems, and air toxics. Based on the information and analyses provided in this chapter, no significant adverse impacts are projected for air quality due to the Proposed Actions. This includes the effects of the Proposed Actions on the surrounding community, the effects of the surrounding community on the Proposed Actions, and potential project-on-project impacts.

The results of the analyses are summarized below:

A screening analysis was completed to determine the impact of carbon monoxide (CO) and particulate matter (PM) from additional motor vehicles due to the Proposed Development. The results of this analysis indicated that modeling of traffic air quality was warranted for PM2.5 and PM10 at the intersection of Bedford Avenue and President Street. Further screening of this intersection based on a Tier I CAL3QHCR analysis showed that motor vehicles due to the Proposed Development would not result in a significant adverse impact on air quality.

Due to the number of parking spaces (118 spaces) in the proposed on-site parking garage, a detailed analysis was completed of the impact of PM2.5 emissions from the parking facility. This analysis that the parking garage would not result in a significant air quality impact.

An (E) Designation (E-428) will be assigned to the Project Site and will require the use of natural gas for Building 2 on the Project Site. With these measures in place, the emissions from on-site

1 Should the 18,122 gsf of academic space be determined infeasible, 25 additional DUs (including 14 affordable DUs) would be incorporated into the Proposed Development in lieu of the 18,122 gsf of academic space and associated office space (approximately 8,278 gsf). The additional 25 DUs is included—as “Analysis Scenario 2”—in the relevant analysis areas to ensure the most conservative analysis is achieved.

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HVAC systems would not cause significant adverse air quality impacts to other buildings on the Project Site or existing sensitive land uses.

There are no major sources of emissions from stationary HVAC sources within 1,000-feet of the Project Site. Consequently, these sources would not cause a significant air quality impact to the Proposed Development.

On-line information from DEP and New York State Department of Environmental Conservation (NYSDEC) was reviewed to identify permitted industrial facilities within 400-feet of the Project Site. Field reconnaissance was carried out to identify any unpermitted facilities. A review of this information indicated there are no active operational permits for industrial operations within 400-feet of the Project Site. Consequently, these types of emissions sources would not result in a significant adverse impact on the Proposed Development.

III. METHODOLOGY

Standards and Guidelines

National Ambient Air Quality Standards

National Ambient Air Quality Standards (NAAQS) have been promulgated by The U.S. Environmental Protection Agency (EPA) for six major pollutants, deemed criteria pollutants, because threshold criteria can be established for determining adverse effects on human health. They consist of primary ambient air quality standards, established to protect public health, and secondary ambient air quality standards, established to protect plants and animals and to prevent economic damage. These six pollutants are:

Carbon Monoxide (CO), which is a colorless, odorless gas produced from the incomplete combustion of gasoline and other fossil fuels.

Lead (Pb) is a heavy metal principally associated with industrial sources.

Nitrogen dioxide (NO2), which is formed by chemical conversion from nitric oxide (NO), which is emitted primarily by industrial furnaces, power plants, and motor vehicles.

Ozone (O3), a principal component of smog, is formed through a series of chemical reactions between hydrocarbons and nitrogen oxides in the presence of sunlight.

Inhalable Particulates (PM10/PM2.5) are primarily generated by diesel fuel combustion, brake and tire wear on motor vehicles, and the disturbance of dust on roadways. The PM10 standard covers those particulates with diameters of 10 micrometers or less. The PM2.5 standard covers particulates with diameters of 2.5 micrometers or less.

Sulfur dioxides (SO2) are heavy gases primarily associated with the combustion of sulfur-containing fuels such as coal and oil.

Table 12-1 National and New York State Ambient Air Quality Standards shows the New York and NAAQS, as well as monitored values at stations closest to the Project Site.

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Table 12-1: National and New York State Ambient Air Quality Standards

Pollutant Averaging Period Standard

Sulfur Dioxide 1-hour averagee 196 μg/m3 (75 ppb)

Inhalable Particulates (PM10) 24-hour average 150 μg/m3

Inhalable Particulates (PM2.5) 3-yr average annual meanc 12 μg/m3

Maximum 24-hr. 3-yr. avg.d 35 μg/m3

Ozone Maximum daily 8-hr avg.b 0.075 ppm

Carbon Monoxide 8-hour avg.a 9 ppm

1-hour avg.a 35 ppm

Nitrogen Dioxide 12-month arithmetic mean 100 μg/m3 (53 ppb)

1-hr averagee 188 μg/m3 (100 ppb)

Lead Quarterly mean 1.5 μg/m3 Notes: ppm = parts per million; μg/m3 = micrograms per cubic meter. a. Not to be exceeded more than once a year. b. Three-year average of the annual fourth highest maximum 8-hour average concentration effective May 27, 2008. c. Not to be exceeded by the 98th percentile of 24-hour PM2.5 concentrations in a year (averaged over 3 years). d. Three-year average of the 98th percentile of the daily maximum 1-hour average, effective January 22, 2010. e. Three-year average of the 99th percentile of the daily maximum 1-hour average, final rule signed June 2, 2010. Sources: New York State Department of Environmental Conservation; New York State Ambient Air Quality Development Report, 2015; New York City Department of Environmental Protection, 2015.

NYC De Minimis Criteria and Interim Guidelines

NYC “de minimis” criteria are used to determine the significance of the incremental increases in CO concentrations that would result from a proposed action. These set the minimum change in an 8-hour average CO concentration that would constitute a significant environmental impact. These criteria indicate that a significant CO impact would occur with:

An increase of 0.5 parts per million (ppm) or more in the maximum 8-hour average CO concentration at a location where the predicted No-Action 8-hour concentration is equal to or above 8 ppm.

An increase of more than half the difference between the baseline (i.e., No-Action) concentrations and the 8-hour CO standard, where No-Action CO concentrations are below 8 ppm.

NYC has also established de minimis criteria for PM2.5. These de minimis criteria indicate that a significant PM2.5 impact would occur with:

Predicted increase of more than half the difference between the background concentration and the 24-hour standard;

Predicted annual average PM2.5 concentration increments greater than 0.1 ug/m3 at ground level on a neighborhood scale (i.e., the annual increase in concentration representing the average over an area of approximately 1 square kilometer, centered on the location where the maximum ground-level impact is predicted for stationary sources; or at a distance from a roadway corridor similar to the minimum distance defined for locating neighborhood scale monitoring stations); or

Predicted annual average PM2.5 concentration increments greater than 0.3 µg/m3 at a discrete or ground-level receptor location.

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Based on the NYSDEC’s annual air quality report (2015), which lists a background value of 23 ug/m3 for PM2.5 for Brooklyn (JHS 126), the de minimis criterion for the 24-hour concentration of PM2.5 would be 6.0 ug/m3. A project increment greater than this value would be considered a significant air quality impact.

New York State Short-Term and Annual Guideline Concentrations

NYSDEC has established Short-Term Guideline Concentrations (SGCs) and Annual Guideline Concentrations (AGCs) for certain toxic or carcinogenic non-criteria pollutants for which EPA has no established standards. They are maximum allowable 1-hour and annual guideline concentrations, respectively, that are considered acceptable concentrations below which there should be no adverse effects on the health on the general public.

SGCs are intended to protect the public from acute, short-term effects of pollutant exposures, and AGCs are intended to protect the public from chronic, long-term effects of the exposures. However, DEP considers that, for pollutants for which the NYSDEC-established AGC is based on a health risk criteria (i.e., a one-in-a-million cancer risk), impacts less than 10 times the AGC are not considered significant. This is because NYSDEC developed the AGCs for these pollutants by reducing the health risk criteria by a factor of 10 as an added safety measure. In determining potential impacts, therefore, DEP considers concentrations within ten times the AGC to be acceptable. Pollutants with no known acute effects have no SGC criteria, but do have AGC criteria. NYSDEC DAR-1 (October 18, 2010) contains the most recent compilation of the SGC and AGC guideline concentrations.

No NAAQs, SGCs, or AGCs exist for emissions of pollutants that are grouped together such as total solid particulates, total hydrocarbons, or total organic solvents. Therefore, as recommended by DEP, all solid particulates are assumed to be PM10. For total organic solvents or total hydrocarbons, the SGCs and AGCs for specific compounds should be obtained and used in an analysis.

State Implementation Plan (SIP)

The Clean Air Act (CAA), as amended in 1990, (1) defines non-attainment areas (NAA) as geographic regions that have been designated as not meeting one or more of the NAAQS; and (2) requires states to submit to EPA a State Implementation Plan (SIP) delineating how the state plans to achieve the NAAQS, followed by a plan for maintaining attainment status once the area is in attainment. Kings County is in attainment of the PM10 NAAQS.

Kings County is part of the NYC CO maintenance area. Although EPA re-designated NYC as in attainment for CO in 2002, site-specific control measures must be implemented in each county to ensure that CO levels remain in attainment. A second CO maintenance plan for the region was approved by EPA on May 30, 2014.

EPA designated the entire state of New York as “unclassifiable/attainment” of the 1-hour NO2 standard as of February 29, 2012. Additional monitoring is required for the 1-hour standard; therefore, areas will be reclassified when three years of monitoring data are available. All counties within NYC are currently in attainment of the annual standard for NO2.

For ozone, Kings County is part of the New York–Northern New Jersey–Long Island, NY-NJ-CT non-attainment area that was classified in 2012 as Marginal for the 2008 ozone NAAQS. However, EPA reclassified the area to Moderate non-attainment as of April 11, 2016. New York State is currently submitting documents to demonstrate how the ozone NAAQS will be achieved.

As part of the New York–Northern New Jersey–Long Island, NY-NJ-CT, Kings County was previously designated as a nonattainment area for PM2.5. As of April 18, 2014, EPA re-designated the Bronx, Kings, New York, Queens, and Richmond Counties as PM2.5 maintenance areas. On April 15, 2005, EPA designated the area as in attainment of the 12 μg/m3 NAAQS established in March 2013.

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EPA has established a one-hour SO2 standard, replacing the former 24-hour and annual standards, effective August 23, 2010. All New York State counties currently meet this standard. Draft attainment designations published by EPA in February 2013 indicated that EPA is deferring action to designate areas in New York State and expects to proceed with designations once additional data are gathered.

Ambient Concentrations

Ambient concentrations for SO2, NO2, and PM were obtained from the NYSDEC annual report for 2015 as shown in Table 12-2.

Table 12-2: Ambient Concentrations

Pollutant Averaging

Period 2015 Monitored Concentrations

Monitoring Station

SO2 1-Houra 11.1 ppb Queens College 2 NO2 Annual 17.16 ppb Queens College 2 NO2 1-Hourb 60.2 ppb Queens College 2 PM10 24-Hour 40 ug/m3 Queens College 2 PM2.5 24-Hourb 23.0 ug/m3 JHS 126 PM2.5 Annualc 9.1 ug/m3 JHS 126 CO 1-Hour 1.9 ppm Queens College 2 CO 8-Hour 1.4 ppm Queens College 2

Notes: a. Average of 99th percentile for last 3 years; b. Average of 98th percentile for last 3 years; c. Average of last 3 years

Background Concentrations

Background concentrations for SO2, NO2, and PM were derived from the NYSDEC annual report for 2015, as shown in Table 12-3. They are identical to the ambient concentrations shown in Table 12-2 except that the value for PM10 in Table 12-3 is the second highest whereas the maximum value was shown in Table 12-2. For the purposes of comparison with the results of AERMOD and CAL3QHCR modeling, they are presented in micrograms per cubic meter.

Table 12-3: Background Concentrations

Pollutant Averaging

Period

Background Concentrations

(ug/m3) Monitoring Station

SO2 1-Hour 29 Queens College 2 NO2 Annual 32 Queens College 2 NO2 1-Hour 113 Queens College 2 PM10 24-Hourb 38 Queens College 2 PM2.5 24-Hour 23.0 JHS 126 PM2.5 Annual 9.1 JHS 126 CO 1-Houra 2,166 Queens College 2 CO 8-Houra 1,596 Queens College 2

Notes: a. Based on second highest value from past five years (2011-2015). b. Second highest during past year

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Mobile Source Modeling

The EPA CAL3QHCR model was used to determine future (2020) PM10 and PM2.5 concentrations from vehicular traffic. CAL3QHCR is a Gaussian dispersion model that determines pollutant concentrations at specified receptor points. It accounts for pollutant emissions from both free-flowing vehicles and vehicles idling at signalized intersections. In accordance with EPA guidance, the queuing algorithm is not used with the CAL3QHCR model. Therefore, average speeds that included intersection delay were calculated for the roadway links.

Inputs to the model include coordinates for receptors and free-flow approach and departure links, and peak hour traffic volumes, speeds, and vehicular emission factors for each link. MOVES2014a was used to estimate pollutant emission factors for free-flow links in grams/vehicle-mile. The vehicular mix and speeds used in MOVES2014a were based on the Project traffic studies summarized in Chapter 11, “Transportation”. Inputs pertaining to inspection/maintenance, anti-tampering programs, age distribution, meteorology, etc., were obtained from DEP. The pollutant processes included running exhaust and crankcase running exhaust, as well as brake and tire wear for PM10 and PM2.5.

MOVES2014a was run for January 1st for the 2020 analysis year for the weekday PM peak period (5 pm to 6 pm). Post-processing was carried out to obtain emission factors for use in a Tier I analysis with CAL3QHCR. A Tier I analysis assumes that the traffic is the same for every hour of the day. A more refined Tier II analysis would use traffic volumes, speeds, vehicular mix, and emission factors specific to each hour of the day.

Fugitive dust from re-entrainment of dust was calculated using the formulas from Section 13.2.1-3 of EPA’s AP-42 Document. The formulas were based on an average fleet weight that varied according to the vehicular mix for a given roadway and a silt loading factor of 0.4 g/m2 for paved roads with fewer than 5,000 average daily traffic volumes (ADT) and 0.10 g/m2 for arterials, as recommended by the CEQR Technical Manual. The resulting fugitive dust emissions for PM10 and PM2.5 were added to the emission factors calculated by MOVES2014a.

As noted above, all links were set up as free-flowing traffic links in CAL3QHCR. Free-flow links were modeled for a distance of 1,000 feet from the modeled intersection in each direction. The mixing zone for free-flow links was equal to the width of the traveled way plus an additional ten feet (three meters) on each side of the travel lanes. Idle times were incorporated into the calculated average speeds, which included delay periods.

Idle emissions were treated as a link with a length of 0 feet, and the emission factor was obtained as grams per hour. Idle emissions were used in the garage analysis, where outgoing vehicles are assumed to idle for one minute before departing. For free-flow links, the idle emission was averaged into the free-flow and not modeled as a separate link with 0 feet.

As indicated in the CEQR Technical Manual, “sensitive” air quality receptors include homes, parks, schools, or other land uses where people congregate and which would be sensitive to air quality impacts. For the purposes of the air quality analysis, any point to which the public has continuous access can be deemed a sensitive receptor site. Numerous receptor points are typically modeled at each intersection to identify the points of maximum potential pollutant concentrations. Receptor points were modeled on the corners of the intersections, and additional points were modeled at twenty-foot intervals for a distance of 350 feet along both sides of each intersection leg. Receptors for the 24-hour averaging periods of PM10 and PM2.5 were placed at mid-sidewalk and outside the air quality mixing zone. Receptors for PM2.5 for the annual period were placed outside the air quality mixing zone and at least fifteen meters from the roadway.

CAL3QHCR was run with five years of meteorological data (2011-2015) from JFK Airport. A surface roughness of 175 centimeters (cm) was used in the modeling. A Tier I analysis was used, which assumes that a set of worst-case peak-hour traffic inputs are the same for all 24 hours of the day. This is a very

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conservative analysis, as the traffic volumes and speeds would show less congestion during off-peak hours.

CAL3QHCR provides maximum 24-hour and annual concentrations for fine particulates. The 24-hour results for PM10 were added to background concentrations and compared with the NAAQS. For PM2.5, the modeled 24-hour and annual concentrations were averaged for the five-year meteorological period. The averages were compared with the NAAQS, and the differences between the modeled No-Action and With-Action concentrations were compared with the DEP de minimis criteria.

Stationary Source Screen

Consistent with guidance in the CEQR Technical Manual, the assessment of impacts from stationary sources is completed through a multi-step air quality impact assessment procedure. The first step in the HVAC analysis is a screening analysis based on Figure 17-5 (SO2 boiler screen for residential #2 fuel oil) and Figure 17-6 (SO2 boiler screen for #2 fuel for commercial and other non-residential development) in the CEQR Technical Manual Appendices. The size of the proposed building was plotted against the distance to the nearest building of similar or greater height (receptor building). The nomograph figures are applicable to buildings where the lot lines are at least 30 feet apart.

If the plotted point is below the applicable curve, the site passes the screen, and no further analysis is necessary. If the plotted point is on or above the applicable curve, the potential for a significant air quality impact exists, and further analysis is required using AERSCREEN or AERMOD modeling. If the distance between the lots is less than 30 feet, a more detailed analysis must be carried out, and no nomograph is necessary. If a detailed analysis indicates the potential for impacts using fuel oil #2, then a screen for natural gas using Figure 17-7 (NO2 boiler screen for residential natural gas) or 17-8 (NO2 boiler screen for commercial and other nonresidential development) would be carried out. More detailed analysis would be required if the project fails the NO2 screen.

Stationary Source Modeling

AERMOD, designed to support the EPA’s regulatory modeling programs, is a steady-state Gaussian plume model with three separate components: AERMOD (a dispersion model), AERMAP (a terrain preprocessor), and AERMET (a meteorological preprocessor). AERMOD can handle emissions from point, line, area, and volume sources. The model is run with five years of meteorological data that include surface mixing height, wind speed, stability class, temperature, and wind direction.

Model Parameters

The model was run with flat terrain. All buildings and receptors were placed at an elevation of zero (0), which is the standard approach.

The one-hour and annual NOx emissions were run with the PVMRM method and ozone files.

AERMOD was run using concatenated meteorological data sets for 2011 through 2015. The same hourly emission factors were used for both short-term and annual averaging periods.

The nearest major airport (JFK) and the site are in urban locations. Therefore, AERMOD’s URBAN option was selected. The population used for the urban area was 8,000,000, and the default urban surface roughness length of 1.0 meter was used for the site.

The Building Profile Input Program (BPIP) was run in conjunction with AERMOD.

The model was run with data from LaGuardia Airport for 2011 through 2015. The upper air station used with LaGuardia is Brookhaven. An elevation of 3.4 meters was used. Hourly ozone values for use in modeling NO2 were obtained from the Queens College 2 monitor for 2011 through 2015.

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Stack Parameters

The EPA defines good engineering practice (GEP) stack height as the height necessary to ensure that emissions from a building’s stack do not result in excessive concentrations of any air pollutant in the immediate vicinity of the source as a result of atmospheric downwash, eddies, or wakes that may be created by the source itself, nearby structures, or nearby terrain obstacles.

The model was run both with and without building downwash to determine which condition would provide worst-case results.

British thermal units (Btus) for the source buildings were calculated as 60.3 thousand Btu per square foot (sf) of heated area.

Per guidance from DEP, the stack parameters are based on the DEP CA Permit database and the heat input (with units of 106 Btu) of the boilers. Based on the square footage of the areas to be heated in the buildings, the calculated Btu ratings of the twelve boilers in Building 2 were 0.05 MMBtu. The stacks were assigned an exhaust temperature of 300.0° F2 and inside stack diameters of 0.5 feet. The closest average exhaust velocity provided by the CA database was 7.8 m/s.

Stacks were assumed to be three feet higher than the roof. They were placed as close as feasible to the receptor building, but at least ten feet from the edge of the roof.

For NO2, the PVMRM option was used with an equilibrium ratio of 0.9, and an in-stack ratio of 0.5.

Pollutant Emissions

Because the Selected Developer has committed to the use of natural gas, pollutants included NO2 (one-hour, annual) and PM2.5 (24-hour, annual) from natural gas.

Emission factors for natural gas were based on an annual consumption rate of 45.2 cubic feet of natural gas per sf for a residential structure, as indicated in the CEQR Technical Manual. The annual consumption of natural gas, in cubic feet, was converted to pounds using a multiplier of as recommended in Table 1.4-1 of EPA’s AP-42 publication for external combustion sources. Based on Table E7, Natural Gas Consumption and Energy Intensities by End Use for Non-Mall Buildings 2003 (released September 2008) by the Energy Information Administration, natural gas for water heating for buildings in the northeast is about 11.4% of the typical total usage of natural gas for heating, hot water, and cooking. This multiplier was used to derive the emission factors for hot water heating.

PM2.5 from natural gas was calculated using 7.6 pound (lbs) per one million cubic feet.

The resulting annual emissions were converted to hourly emission rates in grams per second based on 8,760 hours per year of use for hot water.

Receptors

Receptors were placed across the façade facing Building 2 at window height on the floor corresponding with the 93-foot stack release height and for two floor above it. Because Buildings 2 and 3 are contiguous, no floors would have windows lower than the Building 2 height of 90 feet.

2 Preliminary runs show this results in higher concentrations than the 293o shown in the CEQR Technical Manual.

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IV. PRELIMINARY ASSESSMENT

Preliminary assessments were carried out for the analysis of mobile source, parking, HVAC, and air toxics impacts. Figure 12-1: Project Site and Surrounding Land Uses Within 400-Feet shows the Project Site and land uses within 400-feet of the Project Site. The area within 400-feet of the Project Site is largely residential, interspersed with several institutional uses including three churches and the W.E.B. Dubois High School. Bedford Avenue also has an automotive maintenance building operated by the MTA NYCT, as well as several commercial uses.

Mobile Source Air Quality

Localized increases in CO levels may result from increased vehicular traffic volumes and changed traffic patterns in the study area due to the Proposed Actions. The mobile source analysis outlined in the CEQR Technical Manual considers actions that add new vehicles to roadways or change traffic patterns, either of which may have significant adverse air quality impacts. Accordingly, screening analyses were carried out for CO and PM2.5 to determine whether the Proposed Development-generated increases in traffic had the potential to cause a significant air quality impact.

Table 12-4: 2020 Traffic Volume Increments shows the projected traffic volumes for the study area for 2020. The Proposed Development would generate a maximum of 72 auto trips during the peak AM period, 55 during the Midday period, 86 during the PM period, and 46 during the Saturday Midday period. The worst-case increment of 86 vehicles would occur at the intersection of Bedford Avenue and President Street during the weekday PM peak period. Although the Proposed Development’s increment would include 8 trucks in the AM and 6 in the MD weekday periods, these were categorized as pick-up trucks or panel-type delivery trucks that would be classified in the same category as autos for the purposes of the mobile screening analysis. This is a typical assumption for this type of development, as larger trucks would avoid deliveries during peak periods. Equivalent heavy duty trucks were calculated for the incremental peak period volumes, and the peak PM period was identified as a worst case for modeling.

Table 12-4: 2020 Traffic Volume Increments

As identified in the CEQR Technical Manual, the threshold volume for a more detailed CO analysis is an increment of 170 vehicles through an intersection during a peak traffic hour. Since the greatest increment due to the Proposed Development would be 86 vehicles in the PM peak traffic hour at the intersection of Bedford and President Streets, would be less that the 170-vehicle threshold, no CO modeling is required.

ID Intersection Increment (Auto Trips/Peak Hour)

AM PM Midday Saturday

1 Bedford & President 69 86 55 37

2 Rogers & President 72 64 49 40

3 Bedford & Union 55 55 41 26

4 Bedford & EB Service 46 50 38 25

5 Bedford & Eastern Pkwy 58 67 48 33

6 Bedford & WB Service 16 21 13 8

7 President St. Garage 50 54 26 46

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Rog

ers

Ave

Rog

ers

Ave

Bedf

ord

Ave

Bedf

ord

Ave

0 250 500125Feet

Project Site

400-Foot Radius

One & Two Family ResidenceMulti-Family Residence (Walkup)Multi-Family Residence (Elevator)Mixed Residential & CommercialCommercial Use

Parking

All Others or No Data (Vacant Structure)

In Development

Transportation / Utility

Public Facilities & Institutions

Bedford Union Armory

Figure 12-1

Source: 2015 Pluto, NYCDCP and verified through field visits March 2016

PROJECT SITE & SURROUNDING

LAND USES

1555 Bedford Avenue, Brooklyn°

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A PM2.5 screening analysis was conducted using the spreadsheet referenced on page 17-12 of the CEQR Technical Manual. The algorithm uses traffic volumes by vehicular class and determines the number of heavy duty diesel vehicles (HDDVs) that would generate equivalent emissions. The equivalent number of HDDVs varies by type of roadway. Based on guidance from DEP, the minor leg of an intersection determines its classification as a local road, collector, arterial, or expressway. A more detailed analysis is required if a proposed action would meet or exceed the following thresholds:

12 HDDV for paved roads with average daily traffic fewer than 5,000 vehicles;

19 HDDV for collector-type roads;

23 HDDV for principal and minor arterial roads; and

23 HDDV for expressways and limited-access roads.

Table 12-5: NYCDOT Functional Classifications within Project Area shows the New York State (NYSDOT) functional classifications for the roadways within the project area. Based on this guidance, all roadways can be characterized as urban roads. For urban areas, the classifications are: principal arterial (interstate), principal arterial (other freeway/expressway), principal arterial (other), minor arterial, major collection, minor collector, and local. For screening purposes, local roads are treated as paved roads with average daily traffic of fewer than 5,000 vehicles.

Table 12-5: NYCDOT Functional Classifications within Project Area

Roadway From To NYS Urban

Code Urban

Classification

Bedford Avenue Linden Avenue Eastern Parkway 14 Principal arterial

President Street Rochester Avenue Franklin Avenue 19 Local street

Rogers Avenue Linden Avenue Eastern Parkway 14 Principal arterial

Union Street Franklin Avenue Rochester

Avenue 19 Local street

Eastbound Service Road

Bedford Avenue Rogers Avenue 14 Principal arterial

Eastern Parkway Bedford Avenue Rogers Avenue 14 Principal arterial Westbound Service

Road Rogers Avenue Bedford Avenue 14 Principal arterial

Bedford Avenue Eastern Parkway Rogers Avenue 14 Principal arterial

Source: New York State Functional Class Maps.

As summarized in Table 12-4: 2020 Traffic Volume Increments, the highest increment would be 86 vehicles at the intersection of Bedford Avenue and President Street in the PM peak hour. As indicated in Table 12-5: NYCDOT Functional Classifications within Project Area, Bedford Avenue is classified as an arterial and President Street is classified as a local road. Consistent with guidance from DEP, the screen is based on the less traveled road. Furthermore, the 86 incremental vehicles would all be on President Street. The equivalent truck calculations showed that the 86-vehicle increment is equivalent to 41 diesel trucks. The results of this screening level assessment indicate that the intersection fails the screen for local roads (13 HDDV) and requires further screening of PM2.5 and PM10 using MOVES 2014a and CAL3QHCR in a Tier I analysis. Although other intersections would also fail the screen, this intersection would be a worst case because it has the highest incremental increase in auto trips.

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Therefore, the Bedford Avenue at President Street intersection was modeled as a worst-case for PM10 and PM2.5 for the peak PM period as detailed below in Section V, “Detailed Assessment.”

Parking Facilities

Since the proposed garage in the Proposed Development would have a minimum of 118 spaces, a garage analysis was carried out for PM2.5. This analysis is described below in Section V, “Detailed Assessment.”

Heating Ventilation and Air Conditioning (HVAC)

Actions can result in stationary source air quality impacts when they create new stationary sources of pollutants that can affect surrounding uses (such as exhaust from boiler stack(s) used for heating/hot water, ventilation, or air conditioning systems); when they locate new sensitive uses (schools, hospitals, residences) near such stationary sources; and when new emission sources are located within a short distance of each other. As stated in the CEQR Technical Manual, air quality impacts from HVAC sources are unlikely at distances of 400-feet or more, but a large or major emission source within 1,000 feet warrants further evaluation. Figure 12-2, Axonometric View of Proposed Development shows how the three buildings would appear under the Proposed Actions. “Building 1” is the renovated Armory building, “Building 2” is the condominium building, and “Building 3” is the mixed-income rental building.

Existing Buildings on Proposed Actions

There are no existing major HVAC sources within the 1,000-foot study area based on a review of air quality operating permits found in the State Facility or Title V permits on the NYSDEC website. Based on this available information, no further analysis of existing HVAC emissions on the Proposed Actions are required.

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BUILDING 1 -ARMORY RECREATION FACILITY

DRILL SHED

HEAD HOUSE

BUILDING 2 -CONDOMINIUM

BUILDING 3 -RENTAL

BEDFORD AVE

PRESIDENT ST

UNION ST

ROGERS AVE

BFC Partners/Slate Property Group BEDFORD UNION ARMORY 02/23/16 | A-10

N

BFC Partners/Slate Property Group

AXONOMETRIC DIAGRAM

AXONOMETRIC VIEW OF PROPOSED DEVELOPMENT

Figure 12-2

Bedford Union Armory

Source: Marvel Architects

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The Impact of the Proposed Actions on Existing Buildings

As depicted in Figure 12-2: Axonometric View of Proposed Development, “Building 1” would include the renovated Head House and Drill Shed and have an approximate total floor area of 112,971 gsf, and be comprised of community facility and commercial space. The Drill Shed and much of the first floor of the Head House would be used as an approximately 67,752 gsf recreational facility and an approximately 4,500 gsf community event space. No residential uses are proposed to be in Building 1. The existing boiler stack, approximately 96 feet high, would continue to be used for heating, ventilation and air conditioning. No other buildings within 400-feet of the Project Site are of similar or greater height to Building 1. As a consequence, and as shown in Figure 12-3 Building 1 HVAC Screen on Existing Buildings, no further analysis of the potential impacts of on-site HVAC facilities is necessary.

Figure 12-3: Building 1 HVAC Screen on Existing Buildings

Stack height: 96’ Building size: 112,971 Distance to nearest building of similar or greater height: >400’ Results: pass

As depicted in Figure 12-2: Axonometric View of Proposed Development, “Building 2” would be comprised of twelve attached buildings, each approximately 90 feet tall and each with its own HVAC system, with a total of up to 60 condominium DUs. Each of the twelve buildings would have a variable refrigerant flow (VRF) system for heating and cooling. The system is electric and similar to a heat pump.

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The common areas of the Building 2 would have a VRF system using an energy recovery ventilator (ERV) that is also electric. The rooftop bulkheads on each unit would house gas-fired hot water heaters. Although the hot water heaters would operate intermittently and would not all operate at once, the cumulative effects of the emissions on Building 3 are a source of concern. The emissions from the twelve buildings are analyzed in more detail under Section V, “Detailed Assessment”. Potential impacts from Building 2 on Building 3 were modeled because Building 3 is closer to Building 2 than any existing buildings of similar or greater height.

As depicted in Figure 12-2: Axonometric View of Proposed Development, the 16-story 348,792 gsf “Building 3” would be 180 feet high. If the stack for the boiler were 3 feet high, the release height for boiler emissions would be approximately 183 feet. Since there are no existing buildings of similar or greater height within 400-feet of the Project Site, as shown in Figure 12-4, Building 3 HVAC Screen on Existing Buildings, Fuel Oil #2, no further analysis is required for Building 3.

Figure 12-4: Building 3 HVAC Screen on Existing Buildings, Fuel Oil #2

Stack height: 183 Building size: 348,792 Distance to nearest building of similar or greater height: >400’ Results: pass

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Project-on-Project Impacts

The boiler stack for Building 3 would be higher than Buildings 1 and 2. Therefore, it would not cause project-on-project impacts and needs no further analysis. Building 2, as discussed above, would not be composed of multiple small buildings with their own boiler stacks, and it is analyzed in more detail in Section V Detailed Analysis. The 96-foot high release height for the stack on Building 1 is lower than the height of Building 3. The Building 1 stack is approximately 280 feet from the footprint for Building 3. Figure 17-6 (SO2 Boiler Screen for Commercial and Other Non-Residential Development, Fuel Oil #2) from the CEQR Technical Manual was used to identify whether emissions from the Building 1 stack would have the potential to result in impacts on Building 3. As shown in Figure 12-5: Building 1 HVAC Screen on Building 3, Building 1 would screen out and no further analysis of HVAC is necessary.

Figure 12-5: Building 1 HVAC Screen on Building 3

Stack height: 96 Building size: 112,971 Distance to nearest building of similar or greater height: 280’ Results: pass

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Air Toxics and Odors

A variety of commercial, residential, institutional, commercial, and transportation-oriented uses are located near the Project Site. As indicated in the CEQR Technical Manual, existing facilities with the potential to cause adverse air quality impacts are those that would require permitting under City, State and Federal regulations. The CEQR Technical Manual lists the following types of uses as a source of concern for the residential uses that would occur under the Proposed Actions:

large emission source (e.g., solid waste or medical waste incinerators, cogeneration facilities, asphalt and concrete plants, or power generating plants) within 1,000 feet,

a medical, chemical, or research laboratory nearby,

a manufacturing or processing facility within 400-feet, and

an odor producing facility within 1,000-feet.

Consistent with guidance in the CEQR Technical Manual, on-line searches were completed of the NYSDEC Air Permit Facilities Registry, the EPA Facility Registry System for permitted facilities, the NYC Department of Buildings (DOB) data base, and the NYC Open Accessible Space Information System Cooperative (OASIS) data base. In addition, available aerial photos provided by Google and Bing were reviewed to identify emissions sources. Field reconnaissance further augmented the gathering of information.

No large emission sources or medical, chemical, or research laboratories were identified within the search radii. No industrial or odor producing facilities were found. A laundromat, NYC Laundry City Express, is located at 1566 Bedford Avenue on the southwest corner of Bedford Avenue and Union Street (Block 1273, Lot 40). Although the establishment advertises dry cleaning services, an employee at the establishment stated that the actual drying cleaning took place at a different location away from the Project Site. Based on this information, no further analysis of air toxics is required.

V. DETAILED ASSESSMENT

Existing Conditions

The Project Site is currently occupied by the historic Armory, which has a total floor area of approximately 175,482 gsf. As described below, the Armory is composed of three main components: Head House, Stables, and Drill Shed, in addition to a garage that was constructed in three phases between 1917 and 1931.

Head House: The approximately 58,487 gsf “Head House” is located on the western portion of the Project Site.

Stables: The approximately 28,990 gsf two-story “Stables” structure faces President Street.

Drill Shed: The approximately 57,450 gsf barrel vaulted “Drill Shed” is located between the Head House on the west, the garage on the east, Union Street on the north, and the Stables on the south.

Garage: In addition to the Armory’s three main sections, the approximately 30,555 gsf one-story parking and maintenance garage is located on the eastern portion of the Project Site between President and Union Streets.

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Future without the Proposed Actions (No-Action Condition)

In the future without the Proposed Actions (the “No-Action condition”), the Project Site in the future (2020) would remain as under existing conditions, which would be a primarily vacant Armory with its use limited to occasional events held within the space.

HVAC Analysis

As indicated previously, the Project Site would remain a primarily vacant Armory with its use limited to occasional events held within the space.

Mobile Source Air Quality

Mobile source air quality for PM10 and PM2.5 was analyzed for the No-Action condition to establish a baseline against which the impacts of the Proposed Actions can be assessed. The EPA MOVES2014a mobile source emissions model was used to obtain emission factors, and CAL3QHCR was used to estimate pollutant concentrations as described in the Methodology section. Table 12-6: Mobile Source PM10 (μg/m3), 2020 No-Action Condition summarizes the results for PM10. The highest concentration of PM10, occurred on Bedford Avenue SB at the intersection with the WB Service Road to the Eastern Parkway, and was within the NAAQS.

Table 12-6: Mobile Source PM10 (μg/m3), 2020 No-Action Condition

Intersection Receptor ID 24-Hour Modeled

Value (μg/m3) Background

(μg/m3) Total

(μg/m3) NAAQS (μg/m3)

Bedford Ave. @ President St.

R_106, Bedford Ave. SB @ WB Service Rd.

38.9 38.0 76.9 150

Table 12-7: Mobile Source PM2.5 (μg/m3), 2020 No-Action Condition shows the modeled results for PM2.5. The highest modeled values for the 24-hour and annual concentrations of PM2.5 were Bedford Avenue NB between Union Street and the Western Service Road to the Eastern Parkway and Lincoln Street. The total concentrations are within the NAAQS.

Table 12-7: Mobile Source PM2.5 (μg/m3), 2020 No-Action Condition

Time Period

Inter-section

Receptor ID Modeled Average (μg/m3)

Back-ground (μg/m3)

Total (μg/m3)

NAAQS (μg/m3)

24-Hour Bedford Ave. @

President St.

Bedford Ave. NB between Union Street and Eastern Service Rd.

8.3 23 31.3 35

Annual Bedford Ave. NB between Western

Service Rd. and Lincoln St. 1.00 9.1 10.10 12.0

Future with the Proposed Actions (With-Action Condition)

In the future with the Proposed Actions (the “With-Action condition”), the Proposed Development would be comprised of an approximately 542,393 gsf, mixed-use development that would include:

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Armory (Building 1): The renovated Armory would include the existing Head House and Drill Shed and have an approximate total floor area 112,971 gsf, comprised of approximately 72,252 gsf of community facility use and 40,719 gsf of commercial use. The approximately 72,252 gsf of community facility use would include an approximately 67,752 gsf recreational center and an approximately 4,500 gsf community event space. The Drill Shed is about 98 feet high, but the Head House is nearly 58 feet high. A 38-foot stack on the 58-foot high Head House results in a release height of 96 feet for combustion emissions. This building passed the screening analysis assuming the use of fuel oil #2, but the renovated building may have a natural gas-fired boiler.

Condominium (Building 2): The two-story Stables section of the Armory facing President Street in the southern portion of the Project Site would be demolished and replaced with a new, approximately 80,630 gsf residential condominium building, which would consist of up to 60 DUs, up to 12 DUs (20% of the total) of which would be set aside as affordable for-sale units. It would rise to a maximum of 90 feet from the base plane and would use natural gas fuel.

Mixed-Income Rental (Building 3): The existing garage on the eastern portion of the Project Site would be demolished and replaced with an approximately 348,792 gsf 16-story mixed-income rental building with basement that would rise to a maximum height of 180 feet from the base plane. This building would be comprised of approximately 330 DUs (including up to 165 affordable DUs), approximately 8,278 gsf of office space and approximately 18,122 gsf of academic space on the first floor. The office space would be accessory to the academic space, used for administrative, non-classroom purposes. Alternatively, the first floor may be programmed to provide an additional 25 DUs (including 14 affordable DUs) in lieu of office and academic space. Approximately 118 off-street parking spaces would be provided. As mentioned previously, the building would be 180 feet high, and for analysis purposes, the release height for the stack was assumed to be 183 feet high. This building passed the screening analysis assuming the use of fuel oil #2, but the renovated building may have a natural gas-fired boiler.

As discussed under the Preliminary Assessment, detailed analyses are warranted for traffic air quality and HVAC for project-on-project impacts. The analysis year is 2020.

Mobile Source Air Quality

Mobile source air quality modeling was carried out using MOVES2014a mobile source emissions model and CAL3QHCR air quality dispersion model, as described in Section III, “Methodology.” Tables 12-8 and 12-9 show the results of the CAL3QHCR modeling for PM10 and PM2.5. For PM10, the 24-hour modeling results were added to background concentrations and compared to the PM10 NAAQS of 150 ug/m3. The total is below the NAAQS of 150 ug/m3, and no impacts are projected.

Table 12-8: Mobile Source PM10 (ug/m3), 2020 With-Action Condition

Intersection Receptor ID 24-Hour Modeled

Value (μg/m3) Background

(μg/m3) Total

(μg/m3) NAAQS (μg/m3)

Bedford Ave. @ President St.

R_111, Bedford Ave. SB between EB Service Rd. and

Union St. 40.3 38.0 78.3 150

For PM2.5, the incremental changes in PM2.5 concentrations were also compared to the NYC de minimis criteria of 6.0 μg/m3 for the 24-hour averaging period and 0.1 for the annual period. Regardless of which receptor has the highest concentration under With-Action condition, the comparison is made using the worst-case receptor for No-Action condition. The results of this assessment indicated the Proposed Actions would not result in a PM2.5 impact. In fact, the annual concentrations shown under With-Action

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condition for the receptor have decreased slightly because proposed traffic mitigation measures would reduce the amount of delay on some links compared to No-Action condition.

Table 12-9: Mobile Source PM2.5 (ug/m3), 2020 With-Action Condition

Time Period

Inter-section

Receptor No-

Action

With-Action Increment

De Mini-mis

Modeled Avg.

Back-ground

Total

24-Hr Bedford Ave. @ President St.

Bedford Ave. NB between Union Street and Eastern

Service Rd. 31.3 8.7 23 31.7 0.4 6.0

Annual Bedford Ave. NB between Western Service Rd. and

Lincoln St. 10.10 0.06 9.1 9.16 -.94 <0.1

A comparison of the average modeled PM2.5 concentrations for the individual receptor points for the annual period show that some would experience an increase in PM25 and some would experience a decrease. The average difference over all 108 receptor points is an increment of 0.02 ug/m3, which is within the de minimis.

Parking Facilities

In the With-Action condition, a garage would be developed in the cellar of Building 3. It would have access on both President Street (one way westbound) and Union Street (one way eastbound). Table 12-10, Parking Lot Volumes, 2020 With-Action Condition, shows the peak period volumes. Based on the traffic study, the worst period would be during the weekday peak PM period with 37 incoming and 17 exiting vehicles. This would result in a total of 54 vehicles accessing the garage during the PM period. As a “worst-case” analysis, however, all vehicles accessing both the garage and the on-street parking on both President and Union Streets were assumed to be using the entrance located on President Street. Therefore, the highest volumes of incoming (86) and outgoing (100) vehicles were used in the analysis.

Table 12-10: Parking Lot Volumes, 2020 With-Action Condition

Period Garage Entrance

President St., On-Street

Union St., On-Street

Grand Total

In Out Total In Out Total In Out Total In Out Total

Weekday AM 9 14 23 63 19 82 14 3 17 86 36 122

Weekday MD 13 13 26 36 39 75 5 5 10 54 57 111

Weekday PM 37 17 54 27 64 91 9 19 28 73 100 173

Saturday MD 23 23 46 17 13 30 2 2 4 42 38 80

Note: Numbers in bold type are the highest in their columns.

The garage analysis was completed in accordance to guidelines provided in the CEQR Technical Manual Appendices. The EPA MOVES2014a mobile source emissions model was used to obtain PM2.5 emission factors for “hot” (entering) and “cold” (exiting) vehicles as well as idling vehicles. Exiting vehicles were assumed to idle for one minute before departing, and speeds within the facility were 5 mph.

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For analysis purposes, the cellar level would accommodate 140 parking spaces in 24,848 sf. This includes 79 spaces on slab and 61 car lift spaces. Vehicles would enter through a curb cut on President Street and drive down an entrance ramp of approximately 120 feet to the parking level in the cellar.

The garage would exhaust emissions from a raised louver in the courtyard facing Rogers Street. The courtyard is 15 feet above ground level (i.e., President Street and Rogers Avenue), and the vent would exhaust through a four-foot high louver in the middle of the courtyard. A vent emission height of three feet above the courtyard was used for the analysis, making the vent release height 15 feet above ground level. With a courtyard width of 30 feet, the mid-point location would place it approximately 15 feet from the eastern property line (Figure 12-6).

Figure 12-6: Building HVAC Screen on Building 3

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Receptor points included:

The rear yard of a home on Rogers Avenue, 15 feet away and 15 feet below the vent, where a receptor height of 6 feet was assumed;

A second-floor window at the rear of a home on Rogers Avenue, 60 feet away and at the same level as the vent; and

A window on the second floor of Building 3 (about 15 feet away). No doors provide access to the courtyard, so no receptor points were placed in the courtyard. The nearest window would be approximately 15 feet above the courtyard.

No line source was included in the analysis because the receptor points are shielded from nearby roadways by the surrounding buildings.

Table 12-11 summarize the calculations for the proposed parking garage. The results of this analysis indicate that no significant adverse air quality impacts would occur due to emissions from the parking facility.

Table 12-11: Pollutant Concentrations from Garage

Stack above President Street Entrance

PM2.5 Concentrations Rear Yard Rear Window Building 3 Window

Distance to Vent (ft.) 15.0 60 15.0

Vent Height (ft.) 18 18 18

Receptor Height (ft.) 6 18 30

Averaging Period 24-Hour Annual 24-Hour Annual 24-Hour Annual Garage PM2.5 (ug/m3) 0.72 0.12 1.1 0.22 1.0 0.17

Line Source (ug/m3) NA NA 4.59 NA NA NA

Background Value (ug/m3) 23 9.1 23 9.1 23 9.1

Total Concentration (ug/m3) 23.72 9.22 5.69 9.32 24.0 9.27

NAAQS 35 12 35 12 35 12

NYC De Minimis (ug/m3) 6.0 <0.3 6.0 <0.3 6.0 <0.3

Impact No No No

HVAC

Analysis of NO2 from Building 2’s emissions from heating and hot water were analyzed using AERMOD. For natural gas, the pollutants of interest are NO2 and PM2.5 from NO2. Building 3 was the receptor building. Table 12-12 shows the results. Since the emission factors for PM2.5 from natural gas would be lower than the emission factors for natural gas, the modeled results would therefore be lower. Therefore, PM2.5 did not require modeling to demonstrate that the concentrations would be within the NAAQS and de minimis. As presented in the table, no significant adverse impacts are projected with the use of natural gas.

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Table 12-12: Project on Project Analysis, Pollutant Concentrations, Natural Gas

Building 2 on Building 3 Total Concentrations* (µg/m3)

One-Hour NO2 Annual NO2

Modeled 3.12 0.16

Background 113 32

Total 116.12 32.16

NAAQS (μg/m3) 188 100

Results Passes Passes

To ensure the implementation of a natural gas system in Building 2, the following (E) designation (E-428) will be mapped for Block 1274, Lot 1:

Any new residential and/or commercial development on the above-referenced property must ensure that the heating, ventilating and air conditioning stack(s) use natural gas as the type of fuel for space heating and hot water (HVAC) systems to avoid any potential significant adverse air quality impacts.

VI. CONCLUSION

As detailed in this chapter, no significant adverse impacts would occur for PM10, the PM2.5 total 24-hour concentration, or the PM2.5 de minimis guidelines. No significant adverse impacts are projected from existing off-site HVAC sources or air toxics sources. No significant adverse impacts due to on-site HVAC sources are projected. As such, there would be no significant adverse impacts on air quality due to the Proposed Actions.