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AIR QUALITY
Mobile Emission Sources
The DEIS scope notes that the proposed “operation of heavy machinery and trucks on and off site over a
long duration of time . . . could result in moderate adverse impacts to local air quality” (p.18). The DEIS
fails to adequately address this concern. Its conclusion that “on-road vehicle emission generated from
the project construction would not have a significant adverse impact on air quality” (p.266), and that
“no significant adverse impacts from mobile off-road emissions would be expected” (p.268), are not
supported by the data provided.
The DEIS scope calls for the Applicant to complete and append to the DEIS an air quality assessment that
includes an analysis of off-road and on-road mobile source emissions using the Motor Vehicle Emission
Simulator (MOVES 2014b), developed by the USEPA Office of Transportation and Air Quality 1. In regard
to on-road vehicle emissions the DEIS scope calls for:
Vehicle miles traveled (VMT) data for each on-road construction vehicle and employee
trips will be estimated from roundtrip distances and the number of vehicles and
employees based on the activity specific construction schedule. It is assumed that all on-
road equipment will use either gasoline or diesel fuel. Typical vehicle types will be
passenger car, passenger truck, single unit short-haul, and commercial short-haul. The
emission rates for criteria pollutants on-road construction vehicles will be computed
and compared to USEPA National Ambient Air Quality Standards (NAAQS). Emission
rates for hazardous air pollutants (HAPs) will be computed and compared to New York
State Department of Environmental Conservation DAR-1 Guidelines for the Evaluation
and Control of Ambient Air Contaminants under Part 212” (p.18).2
As VMT increases, so do emissions. The air quality analysis indicates that, as required, it utilized USEPA’s
MOVES software to estimate “Total carbon dioxide (CO)[sic]3, nitrogen oxides (NOx) and fine particulate
matter (PM-10)” (DEIS Appendix S, p. 7) for off-road vehicles. It is unclear as to whether it used MOVES
to calculate emissions from on-road vehicles (as called for by the DEIS scope) or relied solely on the
USEPA’s Diesel Emission Quantifier online tool to calculate the emissions from on-road construction
vehicles.
1 The DEIS scope requires that, “if available, emission factors will be obtained from the NYSDEC or NYSDOT MOVES specific data
for the County of Suffolk, otherwise national average emission factors in MOVES for Suffolk County using default distribution
assumptions will be used” (p.18).
2 Neither the DEIS nor the Air Quality Report (DEIS Appendix S) mention NYSDEC DAR-1. No comparison of calculated on-road
construction vehicle emission rates with DAR-1, as called for in the DEIS scope, is included in either document.
3 It is unclear whether carbon monoxide (CO) or carbon dioxide (CO2) is being referred to. The MOVES software deals with
both. Other potentially confusing editorial errors are noted below.
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The air quality analysis (Appendix S) has employed a number of questionable, and possibly incorrect,
assumptions to estimate air quality impacts from on-road mobile emissions during the construction
phases of the Project.
In calculating VMT the air quality analysis and the DEIS assume that
“construction vehicles (i.e., delivery trucks and trucks removing debris and material
from the site) would be traveling to/from the west and within 25 miles of the site to the
nearest commercial area where a registered or permitted NYSDEC Part 360 facility and
equipment suppliers are most-likely to be located. Twenty-five miles was used in the
calculator as a conservative estimate, but it is more likely that excavated material and
suppliers would be located within 15 miles of the project location. It is estimated that 40
trips would take place to and from the site during a 10-hour workday, for a five-day
work week” (Appendix S p.9; DEIS pp.263, 297; see also p. 34).
No explanation is provided as to how either the 25 mile (conservative) estimate for the “trucks removing
debris and material,” or the “more likely” 15-mile estimate were derived. The revised DEIS has indicated
that the Project truck route will extend from the Project site to the entrance to the Long Island
Expressway (I-495) in Riverhead. The distance between these two points is approximately 14 miles.
Clearly, the total on-way mileage travelled by “trucks removing debris and material from the site” will
not be the “more likely” 15 miles because there does not appear to be a Part 360 facility within that
distance from the Project site. It is also possible that the distance to a Part 360 facility will exceed the
“conservative” 25 miles. It is apparent that the VMT used to in the air quality analysis may have been
significantly underestimated.
In addition, no actual VMT estimate for each vehicle type is provided, making it impossible to verify
analyses requiring this information.
The DEIS is quite clear that 40 haul trucks will be employed by the Project, and that there would be 40
round-trips each week-day during the construction excavation phases of the Project. Clearly, this means
that each truck will make one round trip per day.4 It seems improbable that each haul truck would
require 10 hours (the DEIS-specified length of each workday) to travel to the Project site, load, travel to
a destination within 25 or 15 miles of the Project site, and return to its point of origin.5 Each truck would
4 In contrast, the DEIS indicates that during the clearing and grubbing portion of the construction phase “One truck with 30-
yard trailer would be used to remove ground-up debris 3 to 4 times per day. The truck with trailer would not remain on site
but would return to its base each night” (p. 204). This is further confused by the equipment list in Appendix F which indicates
use during the excavation phases of “40 trailers with operator (1 vehicle for operator)” for excavation phase 1, and “40
trailers with operator - 1 vehicle” for excavation phase 2.
5 Traveling from the Project site to any destination within 15 or 25 miles would require considerably less than one hour. Even if
one assumes that each haul truck’s start and end stop each day is Red Rock Industries in Plainview, LI, NY (Red Rock
Industries is the Project’s designated construction manager), located less than 60 miles from the Project site, no more than
2.5 hours would be required for a round trip. That would leave 6.5 hours to load and unload each haul truck.
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therefore have the ability to travel considerably farther than 25 miles from the Project site (or make
multiple trips per day, eliminating the need for 40 vehicles).
The DEIS states that “the material from the subject property would likely be transported to a registered
or permitted NYSDEC Part 360 facility, likely located within 15 miles of the project location, for
processing and re-use” (DEIS p. 297). Fifteen road miles from the Project site includes only portions of
the towns of Southold, Riverhead, and Southampton. The number of permitted Part 360 facilities in this
area is limited. Potential Part 360 facilities are not identified although the DEIS scope (p.21) calls for the
DEIS to “[I]dentify the off-site disposal location.” The DEIS needs to identify how many haul truck trips
during the excavation phases of the Project will, or will not, travel the entire length of the designated
truck route between the Project site and the entrance to the Long Island Expressway in Riverhead.
Further reasons to question the transport distance assumptions (integral to calculating VMT) are the
qualifying statements in the DEIS that “Given that this project is still in the environmental review
process, and the ultimate re-use facility or location is driven by market conditions and the local need, it
is not possible to identify the specific reuse location or alternative locations. However, the
transportation costs of these types of aggregates often drive their use, and it often becomes financially
restrictive to transport these types of materials greater than 50 miles” (pp.34, 297). It is clear that the
“conservative” distance employed in the air quality analysis should have been 50 miles—not 25. All of
this is seemingly contradicted by the statements in the DEIS and Appendix S that material will be
transported “to the nearest commercial area where a registered or permitted NYSDEC Part 360 facility”
(emphasis added) is located (DEIS pp.263; Appendix S p.9). The DEIS could and should have identified
potential disposal locations. It does not.
The DEIS also states that “Vehicle miles traveled (VMT) data for each . . . employee trip was estimated
from roundtrip distances and the number of vehicles and employees based on the activity specific
construction schedule” (DEIS pp. xxv, 263, Appendix S p.9). As noted above, both the DEIS and the air
quality study are silent as to the actual VMT counts employed, making it impossible to judge the validity
of the assumptions/estimates employed.
It is also possible that Benimax Trucking in Middle Island, LI, NY will be the origin and end point for each haul truck’s
workday. (Benimax is named in DEIS Appendix R as the company that assisted in the preparation of the acoustics report.
Google Earth views of Benimax’s Middle Island facility show the presence of numerous haul trucks, including 22-wheel dump
trailers). Benimax is located approximately 28 miles from the Project site.
Alternatively, it is possible that truck trips would originate from multiple points, and be dispatched at staggered times so as
to arrive at the Project site at staggered times throughout the day. It is also possible that multiple destinations might be
involved. These complexities highlight the need for the DEIS to be much more specific about the assumptions it employed in
its air quality and traffic analyses, and employ those that are truly conservative.
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A second assumption relates to vehicle classification type 6. The air quality analysis has employed the
suspect assumption that “[T]ypical vehicle types will be passenger car, passenger trucks, and single unit
short-haul construction vehicles (U.S. Department of Transportation Class 7 type vehicle)” (emphasis
added) (Appendix S p.9; also, DEIS p. 63). Table 4 in Appendix S is quite clear that Class 7 single unit
vehicles were used in the air quality analysis.
The construction vehicle type that will have the greatest on-road VMT is the 30 CY dump trailers used to
haul sand from the Project site during the excavation phases. These vehicles are not Class 7 single unit
vehicles.7 Trucks with 30-cubic yard trailers, which is the vehicle type described most frequently in the
DEIS, will be Class 10 (6 or more axle, single trailer)8 vehicles. The air quality analysis has employed an
incorrect vehicle type as a basis for much of its emissions modeling. The use of the wrong vehicle
classification is also significant because heavier vehicles have higher emissions. As a consequence, the
reported results do not accurately reflect potential emissions estimates, and have underestimated
actual emission levels.
The Project traffic study (DEIS Appendix O) and the DEIS note “that the construction company engaged
to complete the work has committed to utilize company multi-occupant vehicles to transport many of
the construction workers to the site to minimize the number of vehicles being utilized and thus minimize
associated air emissions” (Appendix S p.10, DEIS p. 263, Appendix O p. 57). While the construction
company’s commitment will certainly help reduce the volume of traffic traveling to the Project site,
there is no way to know if total emissions will be reduced. That assumption is only valid if one fails to
take into account how far each construction worker must travel to and from his/her home to the
carpool pick-up location.
Section 2.2 (Off-Road Mobile Emissions) of the Air Quality Study includes the following statements: “[A]s
indicated in Table 4 below, emission estimates are well within significant threshold values and,
therefore, the impact due to mobile off-road emissions would be less than significant” (emphasis
added); and “[E]mission rates were estimated for all of the off-road mobile construction vehicles
anticipated to be operating on site during each phase of the project. Detailed results are displayed in
Appendix B and summarized in Table 4” (emphasis added)(p.8). However, Table 4 (p.11) is titled
“Estimated On-Road Vehicle Emission Rates” (emphasis added). Table 4 is clearly correctly captioned
and the references to Table 4 in the text are incorrect.
6 MOVES covers all highway vehicles, divided into 13 source use types (source types): motorcycles, passenger cars, passenger
trucks, light commercial trucks, other buses, transit buses, school buses, refuse trucks, single-unit short-haul trucks, single-unit
long-haul trucks, motorhomes, short-haul combination trucks and long-haul combination trucks” (p.4, Overview of EPA’s
MOtor Vehicle Emission Simulator [MOVES3], EPA-420-R-21-004, March 2021).
7 The acoustics analysis for the Project (DEIS Appendix R) also assumed that Project haul trucks would be single unit Class 7
vehicles.
8 The DEIS states that “The proposed haul road would be stabilized to allow the passage of 22-wheel, 30-yard dump trailers”
(p.270). 22-wheel vehicles have 6 axles and would be Class 10 vehicles.
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On page 12 of Appendix S one finds the statement that “As indicated on Table 5 above, the anticipated
emission rates for each phase of the project are well within the annual Conformity De Minimis
threshold, therefore it can be concluded that on-road vehicle emission generated from the Project
construction would not have a significant adverse impact on air quality.” It is clear that reference should
be to Table 4 as Table 5 is a list of construction area acreages.
Additional confusing editorial errors can also be found on page 7 and in Table 4. “The excavation phase
for removal of 135,000 cy of material is projecting 4,500 cy trailers over a 6-month period” (p. 7). This
should be “4,500 30-CY trailers.” On Table 4 (p.11) the second footnote should be “**,” not “*”. All of
these seemingly minor errors are significant because they have the potential to confuse the reader.
They also speak to the care with which the results of the air quality analysis have been reported.9
The statement that “Areas of the United States where the ambient air does do not meet NAAQS are
considered nonattainment or maintenance areas. Currently, Suffolk County ambient air quality is within
NAAQS and, therefore, maintains attainment status for all criteria pollutants” (DEIS p.248, Appendix S
p.2) is incorrect. Suffolk County is presently a non-attainment area for ozone.10
The DEIS, in numerous locations where air quality impacts are addressed, makes statements to the
effect that “all trucks utilized would be Tier 4 certified by U.S. EPA standards” (xxxix, 19, 140, 144, 173, 228,
259, 261, 274, 287, 293, 294, 299, 335). However, Tier 4 standards do not apply to on-road vehicles such as
the haul trucks to be used by the Project. According the Section Chief, Heavy Duty Vehicles, of the
NYSDEC’s Bureau of Air Resources “On-road vehicles don’t go by engine Tier, they go by engine model
year standards.”11, 12
Adding confusion is the fact that the DEIS states (pp. xxxvi, xxxviii, 266, 274, 287, 294, 335) that the use of
all Tier 4 certified trucks11 and equipment will further reduce emissions of PM and NOx” (emphasis
added). The ambiguity between the use of the phrases “trucks” and “trucks and equipment” needs to be
resolved, especially in light of the possibly careless (?) wording of other statements in the DEIS. For
example, the DEIS states that “Tier 4 regulations are the strictest U.S. EPA emissions requirements for
off-highway diesel engines. As such, the use of all Tier 4 compliant trucks 13 and equipment would
9 Table 42 in the DEIS is a duplicate of Table 4 in the air quality study (Appendix S). The DEIS correctly cites Table 3 in Appendix S
as referring to off-road emissions.
10 https://www3.epa.gov/airquality/greenbook/anayo_ny.html
11 Personal communication from James Symon, P.E., Section Chief, Heavy Duty Vehicles, Bureau of Mobile Sources and
Technology Development, Division of Air Resources, NYSDEC, March 28, 2022.
12 The DEIS contains a lengthy discussion of the various EPA Tier standards. Significantly, this discussion is, appropriately, under
the heading “Off-Road Mobile Emissions” (emphasis added) (DEIS p. 266).
13 As noted above, Tier 4 standards do not apply to trucks. Emission standards for on-road vehicles are based on engine model
year.
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further reduce emissions of PM and NOx ensures that federal emission standards are being achieved”
(pp. xxvi, 266). This is not the same thing as saying that only Tier 4 trucks11 and equipment 14 will be
used. In other instances the DEIS states that “the Applicant has committed to utilizing trucks11 and
equipment that are all Tier 4 compliant” (p.266) and “SYC will mandate that all construction-related
trucks be Tier 4” (pp. xxxvi, 228), but a few pages later states that “the Applicant is committed . . .”
(emphasis added) (p.294). The latter phrase suggests a desire, rather than an obligatory commitment.
Finally, the statement that “[t]his analysis evaluates the potential impacts associated with trucks11 and
equipment that are equipped with engines that are Tier 3 or Tier 4 compliant for a conservative air
quality impact assessment approach . . . ” (pp.266), adds further confusion. If only Tier 4 trucks11 and
equipment will be used, why are Tier 3 vehicles includes in the analysis and, if they were, in what
manner were they included?15
Other Emission Sources
The DEIS never discusses new and permanent emission sources associated with the Project. “The
proposed buildings would be heated but not cooled, with the heating source planned as radiant flooring
supplied by liquid propane gas (LPG). Each building would be serviced with two, 2,000-gallon LPG tanks”
(DEIS p. 13, also pp. 161, 292). The DEIS contains no information relating to what type of heating
equipment will be fueled by the propane. Nor does it contain any information relating to how much
propane would be consumed each year. It is therefore impossible to calculate how air quality will be
impacted by Project operation. One gallon of propane emits 12.61 pounds (5,719 grams) of carbon
dioxide CO2 when combusted. The 8,000 gallons of propane stored on the Project site would generate
approximately 50 tons of carbon dioxide.
The DEIS also states that “existing buildings at SYC would continue to be heated using recycled engine
waste oil” (DEIS pp. 292)16. The emissions from burning waste oils reflect the compositional variations
of the waste oils. Potential pollutants include carbon monoxide (CO), sulfur oxides (SOx), nitrogen oxides
(NOx), particulate matter (PM), toxic metals, organic compounds, hydrogen chloride, carbon dioxide
(CO2), methane (CH4]). These emissions have not been included in the air quality analysis.
14 Essentially, pre-Tier 4” heavy equipment was manufactured before the EPA’s mandate required all new equipment to meet
the Tier 4 regulations. The EPA doesn’t require every currently operating piece of equipment to meet the new
standards. Older equipment is “grandfathered” into the current ecosystem.
15 The language in the DEIS appears in all of these instances to have been taken verbatim from DEIS Appendix S.
16 Table 13 in the DEIS states that waste oil is “repurposed as fuel oil for furnace in shop.”
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Carbon Sequestration
The DEIS scope calls for an evaluation and discussion of “the need to remove 493 trees17 and carbon
sequestration and if planting of trees elsewhere can be accomplished to offset tree loss” (p.9). Section
4.4 of the air quality study (DEIS Appendix S) and pp. 272-273 of the DEIS discuss two types of carbon
stock loss mitigation for the Project. These are hard clam farming and proposed supplemental plantings.
“Currently SYC hosts and partially funds a shellfish restoration program operated by Cornell
Cooperative Extension Marine Program at its facility” (p.20). In its discussion of carbon stock loss
mitigation efforts, the DEIS states, under the heading of “Proposed Mitigation” (Section 3.8.2) that the
“projected 1.5 million clams harvested annually have the potential to sequester 9,680 lbs. of carbon. As
such, this program has the beneficial impact of carbon sequestration” (p.273).
While hosting of the shellfish restoration program is certainly a laudable activity that contributes to
carbon sequestration, it is not mitigation of the carbon stock loss that will result from the Project. The
Applicant’s support of the shellfish restoration program is part of the existing conditions at the Project
site, and presumably would continue even if the Project did not proceed. It should be treated as
mitigation only if the Applicant indicates he intends to cease hosting the program if the Project is denied
approvals.18
The DEIS indicates that that the Applicant has included supplemental planting as a carbon stock loss
mitigation measure, and points out that the “proposed action includes the planting of 135 trees,
including 95 pitch pine trees (minimum 4-5 feet height) and 40 trees consisting of staghorn, sumac, and
shadbush to offset carbon stock loss in the Project Area. The planting of 135 pine trees would reduce
the carbon sink loss from the assumed 650 trees (for the purpose of this analysis, as described above) to
515 trees” (p.259).
This is very misleading as it assumes that the trees that will be lost are equivalent to the trees that will
be planted. They are not. It is inappropriate to measure net carbon sink loss by merely measuring the
net change in the number of trees. The 630-650 19 trees that will be destroyed have an average DBH
(Diameter at Breast Height) of 12.8-inches (DEIS Appendix N, p.22), almost all of which are hardwoods20,
and most of which have an estimated height of 80 feet (Appendix C- Tree Removal Carbon Stock
17 This number has been revised upward to 630-650 trees. DEIS Appendix N (table 7) gives the number as 634.
18 The agreement between the applicant and the Cornell Cooperative Extension (Appendix C in DEIS Appendix M) is clear that
the applicant to “has the right to terminate this agreement for any reason.”
19 The actual number of trees destroyed will almost certainly be higher as the 630-650 number as the tree survey included only
trees greater than 6 inches diameter (DEIS Appendix N, p.1).
20 “Approximately 70% of these trees consist of various oak (Quercus sp.) and American beech trees with the remainder
comprised largely of red maple, black locust, and black cherry” (DEIS Appendix N, p.22).
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Estimates, in DEIS Appendix S). These trees are in no way equivalent to the 4- to 5-foot-high softwoods,
only a few inches in diameter, that are being proposed as replacements.
The DEIS is misleading in another regard when it states that “it is estimated that 95 adult pitch pine
trees would store 80,191 lbs. (40± tons) of carbon, decreasing total carbon storage loss (above & below-
ground biomass) from 391 tons to 351 tons” (emphasis added) (p.273). The replacement trees are not
adult trees. Pitch pines can take 20-30 years to reach maturity, and considerably longer to reach a
height of 80 feet.
The DEIS concludes its discussion of proposed supplemental planting with the statement that
“Accordingly, based on the above, no significant adverse air quality impacts would result from the
proposed action” (p.273)”. It is unclear whether this conclusion is meant to apply just to impacts
resulting from tree loss, or all air quality related impacts. In either case, the conclusion is not supported
by the data presented.
The DEIS also concludes that the size of the forest area to be cleared for the Project “is not considered
to be a significantly sized clearing area and, therefore, adverse impacts due to tree clearing/carbon
stock loss are considered negligible” (pp. xxvii, 272). No basis for this is provided. Even if one uses the
DEIS’ figure of 351 tons for total carbon loss resulting from forest clearing, this is figure is huge
compared to the less than 5 tons of carbon sequestered by the shellfish restoration Project hosted by
the Applicant and presented in the DEIS as a mitigation measure.21 If a 351-ton loss is “negligible,” what
is a 5-ton gain?
At least two errors are evident in DEIS Appendix S’ discussion of carbon sequestration. In the first case,
Appendix S states that, “[S]tudies have estimated that >1% [of total forest carbon stock] is stored in
dead wood . . . “(p.17). However, Table 6 (p.17) indicates that it is “< 1%”. The latter figure is correct.22
The second instance is found in Appendix S Table 7 (Carbon Storage Loss Estimates) which incorrectly
totals the estimated on-site loss of stored forest carbon. The table indicates the total as 3,402,604 lbs.
However, adding the individual totals for each carbon pool type results in a total of 3,411,603 pounds 23.
Fugitive Dust and Particulate Emissions
The DEIS scope calls for the DEIS to calculate “Fugitive dust emissions (particulate matter or PM) from
site preparation, land clearing, equipment movement on unpaved areas, material handling” and to
consider in its analyses “Erosion control measures and water programs to minimize fugitive dust and
21 Shellfish carbon sequestration applies to carbon in sea water and is not applicable to an air quality analysis.
22 https://www.forestresearch.gov.uk/documents/8142/Ch4_Carbon_FS2021.pdf
23The 8,999 lbs in the “dead wood” category may have been omitted because the carbon stock ratio for dead wood (Table 6) is
assumed to be < 1% , and the formula used in the air quality analysis assigns a value of “0%” to dead wood.
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particulate emissions . . .” (p.10). This appears to have been done. However, the DEIS scope also calls
for the DEIS to assess “impacts associated with . . . land disturbance activities (e.g., dust) . . .” (p.20). This
has not been done. The DEIS is silent on the potential for fugitive dust to impact nearby residences,
particularly those in close proximity to the proposed haul road.
The DEIS scope also calls for “[e]stimated emission rates for particulate matter (PM) [to] be computed
and compared to USEPA National Ambient Air Quality Standards (NAAQS) for PM2.5 and PM10” (p.19).
Appendix B (Pollutant Emission Estimates from Off-Road Mobile Diesel Construction Equipment) to DEIS
Appendix S provides information on PM10 only. Both the DEIS and Appendix S correctly note that
“PM2.5 is of special concern since the smaller size of these particles allow them to enter deeper into the
human respiratory tract and damage lung tissue.” However, both documents go on to state that for
“the purposes of this study PM10 emissions were estimated. PM10 values are inclusive of both 10-
micron and 2.5-micron PM” (DEIS p.262, Appendix S p.3). The potential adverse impacts to human
health fromPM10 and PM2.5 are not the same 24, and that is the reason the USEPA treats them
separately and has established separate standards for each. As a consequence of subsuming the PM2.5
data into the PM10 category, the DEIS has, in effect, hidden the potential adverse impacts of PM2.5.25
It should be noted that it has recently been reported that particulate air pollution on Long Island is
exceeding the World Health Organization’s 2021 air quality standards (5 micrograms per cubic meter of
PM2.5).26 Data came from five air quality monitoring stations on Long Island, including one in Riverhead.
Riverhead exceeded WHO guidelines by 1 to 2 times.27
The conclusion in the DEIS and Appendix S that with “the implementation of [dust mitigation]
measures, there would be no adverse impacts created by dust generation and the resultant air quality
impacts would be avoided” (Appendix S p.14, DEIS p.269) is not supported by any of the information
provided.
24“PM10 and PM2.5 often derive from different emissions sources, and also have different chemical compositions. Emissions
from combustion of gasoline, oil, diesel fuel or wood produce much of the PM2.5 pollution found in outdoor air, as well as a
significant proportion of PM10. PM10 also includes dust from construction sites, landfills and agriculture, wildfires and
brush/waste burning, industrial sources, wind-blown dust from open lands, pollen and fragments of bacteria. . . . For PM2.5,
short-term exposures (up to 24-hours duration) have been associated with premature mortality, increased hospital
admissions for heart or lung causes, acute and chronic bronchitis, asthma attacks, emergency room visits, respiratory
symptoms, and restricted activity days” (https://ww2.arb.ca.gov/resources/inhalable-particulate-matter-and-health).
25 However, DEIS Appendix S inexplicably includes estimates of PM2.5, and not PM10 in regards to on-road emissions (DEIS
Appendix S Table 4). The DEIS and DEIS Appendix S state “[t]otal CO, NOx and PM-10 have been estimated by utilizing U.S.
EPA MOVES, Version 2014b software” (DEIS p.267, Appendix S p.7). However, the raw data outputs from the MOVES
emission output model, included as Appendix A to DEIS Appendix S, indicate that modeling for the Project included PM2.5
(pollutant ID 110 Primary Exhaust PM-2.5), but did not include PM10 (pollutant ID 100 -Primary Exhaust PM-10).
26 The baseline PM 2.5 standard for the US Environmental Protection Agency is 12 micrograms per cubic meter.
27https://www.newsday.com/long-island/air-pollution-particulates-who-x19avne7