South Coast
Air Quality Management District
21865 Copley Drive, Diamond Bar, CA 91765-4178
(909) 396-2000   www.aqmd.gov

SENT VIA E-MAIL AND USPS:
kle@cityofchino.org

January 16, 2015

Kim Le, Assistant Planner
City of Chino
Community Development Department
13220 Central Ave.,
Chino, CA 91708
Draft Environmental Impact Report (Draft EIR) for the Borba Track Residential (Frontier Homes)
The South Coast Air Quality Management District (SCAQMD) staff appreciates the opportunity to
comment on the above-mentioned document. The following comments are meant as guidance for the
Lead Agency and should be incorporated into the Final EIR. In the project description, the Lead Agency
proposes to grade 17.68 acres and construct 84 single family homes.
In the Draft EIR, the Lead Agency notes that the proposed residences will be sited near the Route 60
freeway. These residences would be approximately 100 feet south of the freeway1, of which Route 60 has
an average daily traffic volume of 225,000 vehicles, which includes diesel trucks. Because of the close
proximity to the existing freeway, residents would be exposed to diesel particulate matter, which is a toxic
air contaminant. The SCAQMD staff recommends that the Lead Agency disclose the potential health
risks to the residents from vehicles that use the freeway including diesel-fueled vehicles that emit diesel
particulate matter, which the California Air Resources Board (CARB) has determined to be carcinogenic.
Numerous health studies have demonstrated the potential adverse health effects of living near highly
travelled roadways. As a result of these studies, the California Air Resources Board recommended in
2005 avoiding the siting of housing within 500 feet of a freeway in their Land Use Handbook.2 Since the
time of that study, additional research has continued to build the case that the near roadway environment
also contains elevated levels of many pollutants that adversely affect human health, including some
pollutants that are unregulated (e.g., ultrafine particles) and whose potential health effects are still
emerging.3
While the health science behind recommendations against placing new homes close to freeways is clear,
SCAQMD staff recognizes the many factors lead agencies must consider when siting new housing.
Further, many mitigation measures have been proposed for other projects to reduce exposure, including
building filtration systems, sounds walls, vegetation barriers, etc. However, because of the potential
health risks involved it is critical that any proposed mitigation must be carefully evaluated prior to
determining if those health risks would be brought below recognized significance thresholds.

1

Aerial map inspection.
California Air Resources Board. April 2005. “Air Quality and Land Use Handbook: A Community Health Perspective.”
Accessed at: http://www.arb.ca.gov/ch/landuse.htm
3
See Chapter 9 of the 2012 AQMP for further information
Accessed at: http://www.aqmd.gov/aqmp/2012aqmp/Final-February2013/Ch9.pdf
2

 Limits to Enhanced Filtration Units
The lead agency should consider the limitations of the proposed mitigation for this project (enhanced
filtration) on housing residents. For example, in a study that SCAQMD conducted to investigate filters4
similar to those proposed for this project, costs were expected to range from $120 to $240 per year to
replace each filter. In addition, because the filters would not have any effectiveness unless the HVAC
system is running, there may be increased energy costs to the resident. The proposed mitigation assumes
that the filters operate 100 percent of the time while residents are indoors. These filters also have no
ability to filter out any toxic gases from vehicle exhaust. The presumed effectiveness and feasibility of
this mitigation should therefore be evaluated in more detail prior to assuming that it will sufficiently
alleviate near roadway exposures.
The SCAQMD staff is available to work with the Lead Agency to address these concerns and any other
air quality questions that may arise. Please contact Jack Cheng, Air Quality Specialist at (909) 396-2448,
if you have any questions regarding these comments. We look forward to reviewing and providing
comments for the Final MND associated with this project.
Sincerely,

Jillian Baker
Jillian Baker, Ph.D.
Program Supervisor
Planning, Rule Development & Area Sources
JB:JC

SBC 150108-01
Control Number

4

This study evaluated filters rated MERV 13+ while the proposed mitigation calls for less effective MERV 6 or better filters.
Accessed at: http://www.aqmd.gov/docs/default-source/ceqa/handbook/aqmdpilotstudyfinalreport.pdf?sfvrsn=0 .

2