Critics of the Nishi project have pointed toward air quality concerns as a reason to potentially oppose student housing on the site. They cite the EIR as evidence of the potentially significant impact.
Here the EIR notes:
The level of health risk exposure from TACs [toxic air contaminants] generated by nearby stationary sources and diesel PM [particulate matter] generated by trains passing on the Union Pacific Rail Road line would not be substantial. However, the level of health risk exposure from pollutants generated on I-80 would be substantial. Based on measurements collected near the project site it is estimated that the level of cancer risk on the project site is approximately 235-in-a-million, which exceeds the 100-in-a-million cancer risk level specified by BAAQMD [Bay Area Air Quality Management District]. Substantially high UFP [ultrafine particle] concentrations were also measured near the project site and subsequent elemental analysis indicates that the UFPs contain transitional metals associated with severe adverse health effects. For these reasons, exposure to diesel PM and UFPs on the project site is considered to be a significant impact.
However, simply citing this passage is tantamount to cherry-picking from the EIR, which proceeds to go through a series of mitigation measures.
For example, the EIR suggests, “All residential buildings shall be located as far as feasible from I-80, and no residential buildings shall be located on the southwest portion of the project site along the elevated segment of I-80. Residential buildings shall be sited more distant from I-80 than non-residential buildings…”
It goes on to state that “housing where individuals typically reside for a longer period of time, such as for-sale residential units, shall be located more distant from I-80 than other residential units.”
The current version of the project does not have any for-sale units, which will clearly make a huge difference.
Alan Pryor, who opposed the original Nishi project, downplayed the issue of air quality this week.
“I was very clear in the No on Nishi campaign that I didn’t share that concern, particularly if we restricted it to students who are only going to be there for a few years and we have the highest quality air filtration there,” he said.
“By having it only be student housing there, that takes half the equation off the table,” he said. “And installing hepa-filtration, I’m comfortable that’s not going to be a significant quality (issue).”
The site will also utilize vegetative filtration, and the air filtration systems on “all residential buildings and buildings in which people work shall achieve a minimal removal efficiency of 95 percent for UFP.” These measures including pressurizing buildings, double-door entrances, and a high-volume, low-pressure drop air exchange system.
Some have asked whether the residents would be expected to keep their windows shut constantly. One of the claims has been that the prevailing wind from the southwest direction would simply funnel particulate matter toward the project and the matter would be trapped by the Union Pacific Railroad (UPRR) berm.
However, studies of the prevailing winds indicate otherwise (see here and here). The delta breeze comes more from the south than the southwest, and north winds are predominant at other times, which would actually act to keep the particulate matter away from Nishi.
Charles Salocks, an environmental toxicologist working with the California Environmental Protection Agency, in an op-ed from the spring of 2016, wrote that he reviewed Dr. Cahill’s rationale for supporting the New Harmony housing project, which is even closer to I-80 than the proposed Nishi property housing.
Professor Salocks notes, “(Thomas Cahill) supported New Harmony in part because it was upwind of the freeway, while Nishi is downwind.” However, the professor believes “this perspective is simplistic and misrepresents the complexity of climatic conditions in Davis.”
He explains, “Wind roses – which are a clever way of graphically presenting wind speed and direction – clearly show that wind speed and direction vary from month to month, and also depend on whether it’s day or night.”
He writes, “This is important, because in order for Cahill’s ‘ultra-fine particulates generated by braking on an elevated portion of the freeway’ exposure scenario to be relevant, a southwest wind and the traffic backups have to occur at the same time. The monthly wind rose graphs suggest to me that, for much of the year, these two factors are not likely to occur at the same time.”
Others note that the five-foot tall berm that the railroad tracks sit on above the ground level is not going to “trap” pollutants on the site. They argue that if there is no breeze, the tracks are not a barrier and, if the winds are as indicated on the graphs linked above, “the UPRR would not be an obstacle or trap pollutants.”
The EIR concludes that these mitigation measures “would reduce health risk exposure to residential areas.” The EIR was most concerned with the for-sale units, “where individuals typically reside for a longer period of time.”
Still, the report concludes, “While Mitigation Measures 4.3-5a, 4.3-5b, and 4.3-5c are expected to result in substantial reductions to exposure levels of UFPs and diesel PM, the level of effectiveness cannot be quantified. For this reason, and because ‘safe’ levels of UFP exposure and diesel PM exposure have not been identified by any applicable agency, or by a consensus of scientific literature, this analysis assumes that resultant levels UFP exposure and diesel PM on the project site could potentially be associated with a substantial increase in health risks. Therefore, this impact would be significant and unavoidable.”
But what are the actual risk factors here? One of the big questions that arises is not whether exposure to these particulate matters is harmful to the health of residents, but how to place that within an overall risk assessment.
The point I have been making from the start here is that the levels are clearly high enough to trigger significant and unavoidable impacts, but they don’t appear to rise to the level of a health alarm – particularly since most of the impacts are gauged based on long-term exposure not the expected two- to three-year maximum exposure that a student living at Nishi would most likely face.
Gary Jakobs, the EIR consultant, told the Vanguard that “a health risk, as presented in the Nishi EIR, is most easily and readily defined as the possibility or estimated probability of adverse health effects (e.g., illness, injury, or disease) from a person’s exposure to toxic air pollutants. The numbers presented in the EIR are a quantitative measure of the probability of such a risk.”
He noted, “A health risk is not a guarantee that a specific number will contract a particular adverse health effect, but rather an assessment of a particular condition (e.g. proximity to elevated freeway) and the probability that individuals subject to that condition could experience an adverse health effect.
“It is true that the conditions at the Nishi site do not make it the worst place to live in the state,” Mr. Jakobs stated, adding that “the relative health risks within many of the urban areas in the state are likely much greater.”
He also stated, “It is important to note that ultra-fine particulates (UFP) is not generally assessed as part of current health risk assessments, and there are no established ambient air quality standards (national or state) for UFP, as of yet.”
Back in January, Mayor Pro Tem Robb Davis, himself a public health professional, argued that the risk assessment at Nishi was actually quite low.
Section 4.3 of the Draft EIR for example, notes, “One common metric of health risk is the number of additional cancer cases that may occur in the population exposed to a particular TAC, or located in an area exposed to TACs in general. This is typically reported as additional cancer risk per million people.”
Here the EIR notes that, according to the American Cancer Society, “the lifetime probability of contracting/dying from cancer in the United States is 43.3%/22.8% among males and 37.8%/19.3% among females. In other words there is a lifetime probability that over 430,000 per 1 million males and over 370,000 per 1 million females will develop cancer over their lifetime.”
In his comments to council, Robb Davis noted that the lifetime risk of respiratory cancer was about 10 percent or 100,000 in 1 million.
The numbers shown here are 235 per 1 million.
The EIR notes, “Long-term exposure to this concentration of diesel PM corresponds to an incremental cancer risk level of 235 in one million above the background level of cancer risk from TACs in the region for residential receptors.” They add, “The estimated level of increased cancer risk based on SMAQMD’s [Sacramento Metropolitan Air Quality Management District’s] Roadway Protocol (SMAQMD 2011) is approximately 197 in one million.”
Again the key is “long-term exposure” which, as student rental units, the residents would not be receiving. But also the risk factor itself, while significant, is still very low. You are adding 0.0002 percent risk for long-term exposure.
Robb Davis last year said that in a real sense the risk of additional cancer and overall health impacts are quite low. They claim that one problem with the analysis is that they do not address the issue of additional mortality associated with the risks over what time period.
Tim Ruff made a similar comment: “The EIR consultants came to the conclusion it is significant and unavoidable because there is no ‘proof’ so to speak. There are no levels set regarding safe levels and only studies that show how promising urban forests are and other mitigating factors. Given this uncertainty the consultants made that determination.”
However, this isn’t enough to satisfy Thomas Cahill. He argues that this is an emerging area of science and he would use the term “dangerous” to describe what he believes is a significant added risk of death from exposure to the particulate matter at Nishi.
Instead, he suggested that there is the need to err on the side of caution, or what he would call the “precautionary principle.”
He said, “After getting all the scientific information possible I would have to make my judgment with the ‘Precautionary Principle.’ This requires that in the face of uncertainty, I would have to choose on the basis of the most conservative estimate of the impact, which is almost always lower than the scientist’s bottom number. In Davis, this means that (if) there is any reasonable chance that I and my colleagues are right, I would have to reject residential use and maximize protection of workers in commercial or research facilities. The best way to solve this is to have better data, covering at last a year and including all the most toxic components. This is what I recommended in Jan 2015.”
However, Dr. Salocks has a different view, concluding, “Although I respect Dr. Cahill, acknowledge that he has done excellent research, many of his claims concerning the health risks Nishi residents will face are overstated.”
From my perspective, the EIR is very thorough in laying out the risks at Nishi, and, based on a several pieces of information, I believe the risk is manageable.
First, the impacts we are talking about are based on “long term exposure.” I take that to mean at least 20 years and am told that it could be much more than that. The change from having some for-sale units to having all rental units is a huge mitigation against long-term exposure.
Second, the wind patterns suggest that this is not a “perfect storm” scenario where the pollutants are simply blowing into the project and sitting there indefinitely. The graphs show that, for much of the year, the winds would actually blow the particulate matter away from and not toward the project.
Third, the filtration, trees, and building design would mitigate some of these effects.
Fourth, all available research indicates that the risk level itself is extremely low.
Adding mitigation makes sense, but going further than that ignores just how low a risk this actually appears to be.
—David M. Greenwald reporting
I giggled when I saw that very, very green image.
Noise? Vibration? The subjective issue of pollution…. how it feels? Automatic window closing when the wind does blow from the highway into one’s bedroom? Suggestions from experts on reducing I-80 pollution at its source? Mitigation such as a dedicated bus lane?
Some graphics on wind speed and direction.
For the record, Chuck Salocks is a senior toxicologist at Cal EPA.
I noticed that too, Don, but thought D meant he had studied here…was not done going through article…corrected. Thanks!
cathy
To clarify and expand on my remarks from last week, I personally believe Dr. Cahill is absolutely right in that the low-lying location of the project sandwiched between the freeway and railroad does potentially create a “perfect storm” conditions for localized pollution to accumulate under the right conditions…but only sometimes. These include low wind speeds from the south, southeast, or southwest and winter inversion conditions. Computer simulation programs demonstrate this fairly conclusively.
I also believe in the precautionary principle and, as such, would never recommend that any susceptible populations live there at all. These include seniors, young kids, or anyone with a serious respiratory illness such as asthma. Nor would I recommend that anybody plan on spending a good portion of their lifetimes living there if they value their respiratory health. And if I were a student living there (which I would do so only if the buildings were equipped with HEPA filtration and I did not have asthma or a related respiratory problem), I would never open my windows or exercise heavily in the area under those conditions in which pollution can accumulate.
Those who dismiss the potential pollution problem at Nishi outright by claiming there is only a very slight increase in cancer risk over a lifetime have taken a very myopic view of the overall health risks. These somewhat low projected increased risks of cancer may be true. But the real risks, in my opinion, is that the potential poor air quality at the site site can exacerbate preexisting respiratory problems such as asthma or COPD in seniors or others similarly afflicted (which includes plenty of young kids too). Such poor air quality can also impede respiratory development in young children which can last a lifetime. The science is very clear on both of these points.
Finally, I also agree with Dr. Cahill that the developers should have taken the intervening time between the last election and now to actually measure the concentrations of pollutants that accumulate there over the course of the year. This would have answered a lot of questions about which we can now only speculate.
I agree with what Alan has said here. To add to some of the points that Alan made (which he may or may not agree with) — students may not know that they have respiratory problems. I myself did not show obvious symptons — a very bad asthma attack — until I was 21, but looking back earlier, I can see that I was showing symptoms before and no one knew. (My swimming and track coaches literally laughed at the sounds of my labored breathing, apparently mistaking a health condition for being out of shape, which I definitely was not). And, as I have said before, they will not know about the conditions at the site. They will not know that they should keep their windows closed. They will not know that they should not exercise heavily while in the area. They will not know that they should not get pregnant. They will not know that they should spend the rest of their lives trying to avoid additional exposure.
I know that David has put forward this point previously. I believe that it bears repeating. Neither Dr. Cahill, nor any of the opponents of either Nishi 1 or the revised version have seriously addressed the impacts of the alternative of having these same students commute from a distance, say Vacaville, or Woodland, or Sacramento. This travel would put them at risk from air pollution, but also from the risks of automobile related injury and death. I would ask opponents of Nishi to include these statistics and apply the precautionary principle to them as well. I have no idea what the relative risk would turn out to be, but I do believe that lack of assessment of the alternative demonstrates a clear bias against the project.
David,
It is pretty astonishing that you no background or expertise in air pollution impacts on health like Dr Cahill, yet you try to undermine the issue that even the preliminary data exposed of significant impact of the diesel utlrafine particulate matter from I-80:
So, let’s look at credentials on this subject. Dr. Cahill has a Ph.D in physics (specializing in particulate matter) and his academic career at UCD which focused on air pollution impacts (including ultra-fine particulate matter) on health. He is a world recognized authority on this subject who has studies, collaborated and written and co-written countless papers on it. He also started the DELTA scientific group which entirely focuses on air pollution impacts on health all over the world, which has produced the evidence showing how significant air pollution impacts are on health.
This subject of air pollution impacts has been studied by other universities (like USC) and agencies particularly in areas impacted significantly, like the LA area. There is a report from earlier this year from USC documenting the health impacts of air pollution on residents living near highways:
http://envhealthcenters.usc.edu/infographics/infographic-living-near-busy-roads-or-traffic-pollution/references-living-near-busy-roads-or-traffic-pollution
And here is another very recent one documenting how air pollution is a major cause of health impacts worldwide:
https://www.yahoo.com/news/study-world-pollution-deadlier-wars-disasters-hunger-003053909.html
Yet, David your background is political science which is an area which focuses on making political arguments. So I just find it pretty disappointing that you are trying dismiss an incredibly important health impact concern by a world expert and others, simply because you are trying to promote the latest Nishi proposal.
Just to re-state and obvious issue which you did not mention in your article, which is if there are no air quality problems at Nishi, why have the developers not yet done the air quality studies to prove that? The developers have been asked for years now by Dr. Cahill to do the air quality studies and even explained what data needed to be collected, yet the Nishi developers continue to refuse to do them.
What are the Nishi developers afraid of learning about the air quality at Nishi if (as they claim) it were not really a problem? The developers need a year of data and they could have been collecting that data over the last year. Why didn’t the Nishi developers have that air quality data for the Nishi site done this past year?
Just out of curiosity have you had any meetings or discussions with the Nishi developers regarding this new proposal?
Just to restate my reply to this argument of yours: since there are no standards for the substances you want tested, it would be impossible to “prove that” there are “no air quality problems at Nishi.”
The point of the article is that there are other qualified experts who do not share Dr. Cahill’s conclusions.
There is no way, no matter what additional studies are done, for those in the crowd that are much more opposed to development, and Nishi in particular (or particulater), than they are about air quality or science, to be satisfied… if the study was done, there would be some of the same ones questioning its methodology, the actual measurements, the epidemiology, and the results/conclusions… not the proverbial snowball’s chance in hell. And, of course, they’d not show their hand until the money was expended, and the research complete.
The developers and/or City would waste their money, and the consultants doing the ‘studies’ would put more bread on their table.
Don: Eileen has repeatedly referenced the Nishi EIR, including the standards cited. Not sure why you’re repeatedly ignoring this.
She has repeatedly ignored the part of the EIR saying that the UFP toxicology/epidemiology is unsubstantiated at this point in science. I previously quoted that part, it has been ignored… again, and again, and yet again.
Perhaps because it doesn’t support the “campus only” narrative.
Yes, Ron, I have noted that selected excerpts from the EIR have been quoted. For example:
“Substantially high UFP [ultrafine particle] concentrations were also measured near the project site and subsequent elemental analysis indicates that the UFPs contain transitional metals associated with severe adverse health effects. For these reasons, exposure to diesel PM and UFPs on the project site is considered to be a significant impact.”
So let’s look at some more passages from the EIR.
Here’s one that is relevant to the point I am making.
” Unit risk factors for estimating health risk from exposure to UFP and many of its constituents are not yet established by EPA and the Office of Environmental Health Hazard Assessment.”
Please also note:
” Based on the information provided by Dr. Cahill at that time, the City requested that air quality monitoring be conducted by UC Davis using their monitoring equipment on the Nishi site to characterize air quality conditions on the site.
Per Dr. Cahill’s suggestion, concentrations of various sizes of particulate matter were monitored and measured, including UFP, which is defined as particles with an aerodynamic diameter of 0.1 microns or smaller.
Additionally, per Dr. Cahill’s suggestion, the monitoring collected the elemental signature of these particles to understand whether the particulates were from diesel exhaust and/or brake wear and tire wear emissions.
In addition, the City began evaluating mitigation measures suggested by Dr. Cahill at the meeting on January 27, 2015, including positive pressure air filtration systems in buildings, vegetative barriers along I-80, and a tree canopy throughout the project site.
All of the mitigation suggestions provided by Dr. Cahill in January 2015 were incorporated into the Draft EIR—see Mitigation Measure 4.3-5b and Mitigation Measure 4.3-5c.”
Furthermore:
“It is important to note that there is no established standard or threshold for determining what concentration of UFPs results in an unacceptably high level of health risk. Under Impact 4.3-5 in the EIR it is concluded that exposure to the concentrations of UFP on the project site would be a significant impact because the average concentration of UFP measured on the project site during a 10-day period, 14.6 micro grams per cubic meter (µg/m3), exceeds the annual California and national ambient air quality standard (AAQS) for PM2.5 of 12.0 µg/m3.
While an acceptable concentration for UFP has not been established, it is reasoned that the standard would be less than the established AAQS for the larger particle size PM2.5 and, therefore, a concentration of UFP that exceeds the AAQS for PM2.5 is unacceptably high. Thus, all feasible mitigation measures for reducing exposure to UFP, as discussed above, are included in the Draft EIR. Implementation of Mitigation Measure 4.3-5c requires installation of an air filtration system that will achieve a removal efficiency of 95 percent for UFP. As noted on pages 4.3-30 of the Draft EIR, the average UFP concentration during a 10-day measurement period at the project site was 14.6 µg/m3.
Through implementation of only Mitigation Measure 4.3-5c, concentrations of UFP inside proposed buildings at the Nishi site would be reduced to approximately 0.7 µg/m3. Moreover, according to the academic literature reviewed in the Draft EIR, concentrations of UFP would be further reduced because of the implementation of a vegetative barrier along I-80 and inclusion of a tree canopy throughout the project site, as required by Mitigation Measure 4.3-5b.
However, as noted on page 4.3-33 of the Draft EIR, “safe” levels of UFP exposure have not been established against which the Ascent Environmental Comments and Responses to Comments City of Davis Nishi Gateway Project Final EIR 2-113 resultant mitigated concentration could be compared. Thus, without an established standard or threshold for UFP exposure it’s difficult to determine whether this mitigation would reduce UFP exposure to an acceptable level.”
Don,
There are standards, and the BAAQMD (Bay Area Air Quality Management District) standards were used to make the “significant impact” air quality determination in the Nishi EIR. It was in regards to the preliminary data on the I-80 diesel ultrafine particulate matter, which is what gets into lungs, but never gets back out.
The point is, this preliminary air quality data is a “red flag” to collect the year of data needed to get enough information to see the overall situation regarding air quality impacts on health at the Nishi site.
You’re right Eileen, I have no ability to read statistical analysis or risk analysis. I have no ability whatsoever to compile a host of experts to weigh in on a subject. I have no ability to read the EIR.
I’m glad that you hold Dr. Cahill up highly, but it seems from reading through the literature (that I’m apparently incapable of understanding) that a number of other very qualified people disagree with his conclusions.
David,
Yes. To begin with you are not an expert on air pollution impacts on health, but Dr. Cahill is. I find it very telling that your quest is not to find out the bottom line about the air quality impacts at the Nishi site, but instead it is to search out anyone who agrees with your per-conceived position that air quality is not an issue at Nishi. There is nothing objective about how you are approaching or writing about this air pollution impact on health issue at Nishi.
You’re not an expert either. You’re realying on Dr. Cahill, I’m pointing out that there are others who disagree with him who are experts too.
“Just to re-state and obvious issue which you did not mention in your article”
You realize this article was already 2000 words, I couldn’t possibly mention everything. Instead what I tried to draw out was a few key areas where others who are qualified disagree with Dr. Cahill.
Well let’s just say that it seems pretty glaring that you did not raise the most important question or even elude to it in your very long article which is. “Why weren’t the air quality studies at Nishi done this past year, or before then?”.
The entire article is dedicated to trying convince the readers of your position, which is that air quality is not an issue at Nishi. So again, you are not showing any objectivity on this issue, just advocacy for Nishi or else you would be asking for the air quality studies to be done.
Because there would be no point in doing them. The numbers would not be meaningful, mitigation measures are included, and duration of residency is typically limited.
“The developers have been asked for years now by Dr. Cahill to do the air quality studies and even explained what data needed to be collected, yet the Nishi developers continue to refuse to do them.”
As I understand it, the developers met extensively with Dr. Cahill and implemented about all of his suggestions. I’m not exactly sure what you think additional study of the air quality is going to prove, it seems that we have a relatively good grasp of the issues – where they can be mitigated and how. What do you expect additional study to show?
“The developers need a year of data and they could have been collecting that data over the last year. ”
What do you believe a year of data is going to give them that they do not have already?
Wow, I am surprised but glad you asked, David. The info in the EIR was preliminary and based upon data collected in a very short period of time (around 10 days), and the news was not good. In fact, it made clear that the preliminary data indicated that ultra-fine particulate matter from I-80 was a significant impact.
The point is, more data needs to be collected over a longer period of time to have enough information to make clear the air quality situation at Nishi and the health impacts it would have on residential if it were there. Dr. Cahill defined the year of data needed and it makes complete sense. Your question David, sounds like you are afraid of getting the data needed as well as the Nishi developers.
You’ve claimed that given the prevailing wind conditions that the days of low air quality would be few. This is one thing that the tests could show. Or do you just want to keep making unsubstantiated claims? Perhaps you think those are more scientific?
“Just out of curiosity have you had any meetings or discussions with the Nishi developers regarding this new proposal?”
Not yet. Just a couple of emails exchanged. The developers feel like they spent a lot of time addressing Cahill’s concerns in the original proposal and that with the absence of the for sale units, you don’t have long term exposure and without long term exposure all the health risks are vastly reduced even from the very low levels.
David,
In your communications with the Nishi developers, did you ask them why they have not done the air quality studies?
What would be the point? Unless there was a demonstrable health benefit, you and others would still say “unacceptable”…
Now that I’ve addressed those points, perhaps you can explain to me why you are making as big a deal out of a 0.0002 percent increase in cancer risk over long term exposure? Because while it is true it’s been 25 years since I last took a math course (differential equations btw), I do kind of remember that 0.0002 percent is a very low number.
David,
You have “addressed” points but not answered the questions. However, this statistic you mention is based upon preliminary data which is the reason why a full year of data is needed. Dr. Cahill has repeatedly asked the Nishi developers, yet they continue to refuse to do the air quality studies. Why are the developers refusing to get the data?
Eileen, the answer is embedded in your question … “a full year of data is needed.”
With that said, it appears that absolutely no one believes that a study is needed. The evidence of that is that no one has stepped up to get the study funded and started.
That is absolutely not “evidence”.
In full view of all, pick and choose the expert that agrees with your political view, discount all other experts, and write verbose defense essays over and over with no new arguments. Your blind obsession is hurting your own cause.
Well said Alan.
With all due respect – yes, you, David and others have “pointed this out” previously. The assumptions of this argument remain just as ludicrous as it did the first time it was mentioned.
The “alternative” location is on campus.
“The “alternative” location is on campus.”
Not if campus doesn’t build it.
You can’t count on Nishi being approved, either. Nor should the city be sacrificing other sites exclusively for megadorms.
That wasn’t the question.
Tia: “have (not) seriously addressed the impacts of the alternative of having these same students commute from a distance, say Vacaville, or Woodland, or Sacramento”
Ron: “The “alternative” location is on campus.”
David: “Not if campus doesn’t build it”
You had no question.
Perhaps it’s not time to “give up” on UCD, one way or another. Might be wise, given that you cannot count on Nishi (or other sites in the city) being approved for megadorms.
Actually what we are doing is discussing the impact of Nishi and the alternatives and deciding on the best course of action.
Seems that there’s disagreement, about that.
David… many posting here see no “alternative”… seems to be clear that some will only accept “on-campus”, and “will hold their breath and turn blue” before accepting any new MF housing anywhere else.
Perhap when we get to a 0.002% vacancy rate… nah, not even then…
Howard: And some advocate that the city continue to accommodate UCD’s plans, regardless of the impact on the city.
Some are apparently so desperate that they might even purposefully downplay air quality concerns. Makes one wonder who is actually concerned about the students.
And your concern is primarily about students, Ron, not anything else?
I am concerned about students and many others… but as to dangers of air pollution @ Nishi to students, I believe “there is no there, there.”
The biggest air pollution problems I had @ UCD were the damn acacias. Suggest we get all those in the Arboretum cut down…
Howard: I just see a (somewhat desperate) lack of honesty (from proponents), regarding this issue.
I’m definitely concerned about other ramifications to the city (and feel somewhat more “qualified”) to discuss those.
To be clear Ron, I am not a “proponent” of the project… but given the previous two versions (one over 15 years ago), this one I find very palatable… student housing, immediately adjacent to UCD, proposed direct MV connection to campus, none to W Olive. Like.
It is the desperation of the spaghetti throwers that is most in evidence now!
Howard:
If you “like” the proposal (and plan to vote for it), that pretty much meets the definition of a “proponent”.
The air quality issue hasn’t changed, since the earlier iteration.
Personally, I see probable unresolved issues regarding costs (which will no longer be offset by the “innovation center” component).
I haven’t lied or misled on the data. I am not ‘desperate’.
It does gripe the heck out of me when opponents don’t hesitate to mislead or mischaracterize views such as mine.
I’ve taken courses (engineering) in air pollution, and have reviewed many documents on the matter. Have you?
From Merriam-Webster, on the Internet: “a proponent is someone who proposes something, or at least supports it by speaking and writing in favor of it.”
Yeap – Howard qualifies. 🙂
(However, I did not necessarily have you in mind, regarding the “desperation” comment. One can engage in an argument without being “desperate”.)
Cute… lame… ‘no cigar’, Ron.
https://www.merriam-webster.com/dictionary/proponent
‘Nuff said…
Let me quote David Greenwald from way back in March (excerpts):
Perhaps October David should listen to March David.
“Implementation of Mitigation Measure 4.3-5c requires installation of an air filtration system that will achieve a removal efficiency of 95 percent for UFP….Moreover, according to the academic literature reviewed in the Draft EIR, concentrations of UFP would be further reduced because of the implementation of a vegetative barrier along I-80 and inclusion of a tree canopy throughout the project site….”
Air filtration system… so, students are supposed to keep their windows closed at all time, no heavy exercising outside or with windows open?
Like magic, magic, all the ultrafine particles are gone, even though we don’t know what the conditions are, we are sure that we can mitigate them? How can you mitigate if you don’t even know what you’re mitigating for?
Apparently 95%+ reduction isn’t enough for you, so I suggest you not live there.
1) Reduction assumes closed windows, no signficant exertion while outdoors 2) I still don’t know what we’re reducing from.
Needing to sign off for now, but it is relevant that when UCD LRDP head planner Bob Segar was publicly asked, “Would UCD purchase/acquire Nishi for student housing?” his reply was, “No, because of the air quality issues and the infrastructure costs. I find it interesting that UCD recognizes the air quality concerns, yet the City hasn’t yet.
It makes one also wonder, is this because UCD is not willing to take on the legal liability risks and costs of the health impacts of Nishi on students, but the City is willing to overlook the legal liability risks and costs?
Eileen, what liability and costs would the City be taking on in the current scenario? Nishi will be privately owned. If there is any liability, it would reside with the owners of the property. In the UCD scenario you have described UCD would be purchasing the property, and with it all immediate and/or potential liabilities.
Two very different scenarios. Two very different legal realities.
Honest question for those who are opposing the current iteration of Nishi ? It is hypothetical. Let’s suppose that a year’s worth of study were to be done and the results showed ( due to variable wind patterns…or whatever other reason) that the risk was estimated to be substantially lower than suggested by the 10 day data collection being sited. Would that then be the end of your opposition, or would you press other objections at that point ?
I would still ask whether we are making the best use of the land — whether it would be a better location for, say, a business park. But yes, the air quality issues are my main objection to building anything at the site where people will be exposed for any significant length of time.
Roberta, how do you define/assess “best use of the land”? I personally believe that the current proposal is indeed an inferior use of the land. A use that would be much closer to best use would be a tight cluster of high rise residential structures with all resident automobile parking remotely located somewhere on the UCD campus (ideally near one of the existing Freeway exits to minimize the amount of on-campus driving by those cars). That remote parking would be subject to standard UCD parking fees.
.
If I thought air quality was good enough to support residential use, then yes, it makes sense to have it be dense.
But it is bothersome to me that some here paint a dire picture of the City’s finances and say that we need a business park at all costs, and yet seem not to mind at all that this has completely left the proposal. Can the City afford this? Or are the City’s finances not as bad as some say? Or are they only bad when arguing for the preferred project, and then ignored when arguing for a different project?
Other uses of the land have been proposed that are interesting to me, but rather than have that discussion we have a fully developer-driven process.
I tend to agree Matt… ironically those who oppose housing on the site will likely oppose increased density, citing insufficient impact fees, seeking additional “community benefit” contributions, more ‘affordable’ units, etc.
I agree though, that to pencil out the proposed UPRR crossing, and achieve the main goal of relieving the housing pressures, at least to a degree, this would be a good time to “go big”, add units/density, and decrease reliance on easy (and cheap or free) parking accommodations for motor vehicles…
I like your thoughts on this, though…
“But it is bothersome to me that some here paint a dire picture of the City’s finances and say that we need a business park at all costs, and yet seem not to mind at all that this has completely left the proposal. ”
Roberta – The original proposal was voted down that had 300,000 sf of R&D space. That certainly wasn’t a priority for the naysayers who voted it down. In the meantime, Sierra Energy who would have invested in the innovation space there has done there own and we have the URP that has come in as well. I believe that will offset the loss of R&D space at Nishi.
My preference is still a USC Village type development, but I also know that is not coming.
The perfect is the enemy of the good.
Roberta, of the four original innovation center sites, Nishi was always perceived to be the tail on the dog. There was never going to be much tax revenue generated by the businesses there because sales tax from businesses (other than services/food businesses) located there because sales taxes will only be generated by business-to-business sales of goods. Very few if any goods would have been created on-site. Unsecured property taxes were also expected to be rather low because of the absence of goods production. Research labs would have produced some increased unsecured property taxes, but only a limited amount.
So “Can the City Afford this?” is measured in the lost opportunity for synergy/collaboration between the City business community and the UCD campus. That is not a monetary loss, but a very real loss none-the-less.
Strange how some who advocated for Nishi the first time constantly espoused the financial benefit of the innovation center component, and are the same folks who are downplaying it this time.
Go figure. (No wait, you apparently can’t trust the “figures”, either.)
Ron: Why do you keep ignoring that (A) the R&D space is going elsewhere and (B) the city has needs others than fiscal?
You seem to be assuming that the business that was tentatively planning to locate at Nishi is the only business that would have done so.
An initial, primary justification for Nishi was the innovation center component. Now, that’s gone. (And, even Dr. Cahill had fewer concerns about commercial development.)
I’d suggest that your overall advocacy (regarding planning and land use) is ignoring the needs of the city. (Not just financial, and not just at Nishi.)
That assumption is irrelevant. The point is that as a result of the loss of Nishi, innovation space has opened up elsewhere. The city has needs aside from economic development. The project has adjusted to the loss and attempted to address people’s concerns (lack of affordable housing and traffic).
Do I think that the previous proposal was better? No. Would I prefer something like USC Village? Yes.
David: Innovation space has not “opened up elsewhere”. (Not unless some other site was rezoned for it.) We are actually losing these types of spaces, partly as a result of those with vision similar to yours.
All of your hopes for “replacing it” appear to lie with MRIC. Perhaps you think that the Vanguard is influential enough to make that happen, even if it includes housing. I guess we’ll see.
Your vision is so fundamentally different than mine, despite being presented with the same information. (That’s not intended as an insult, nor is it an invitation for further back-and-forth with any commenter.)
“Innovation space has not “opened up elsewhere”.”
Sure it has. Sierra Energy is creating their space, URP is creating theirs.
Assuming that no land was rezoned for it, your statement is factually untrue.
I already noted this, above.
That’s not true, at least $15 million have been invested for the express purpose of developing an innovation center that did not exist previously. You are too fixated on land use and not focused enough on investment and money. For example, Interland has been zoned as it has for a long time. BUT, many including the Vanguard have considered Interland with its single-story development, spread out, with large surface parking lots to be under utilized land and the fact that there has been a sale and a new investor means that that single story land will be redeveloped over time at three stories or higher and enable far more dense development, and so even though the land is not being rezoned, it is going to yield far more in the way of R&D space than the current configuration. You’re thinking is too much in a silo right now.
David, I do not understand your comment. Why are you addressing “the R&D space in isolation.” Nowhere in the financial analysis by and/or for the FBC was the impact of R&D tenants/space analyzed separately from the project as a whole. The total Nishi Revenues were as follows:
Annual General Fund Revenues [1]
Property Taxes
$227,000
Property Tax In-Lieu of Vehicle License Fees
$249,000
Property Transfer Tax
$22,000
Sales and Use Taxes
$165,000
Property Tax in-Lieu of Sales Tax
$55,000
Transient Occupancy Tax
$-
Business License Tax
$50,000
Municipal Service Tax
$90,000
Franchise Fees
$36,000
Charges for Services
$60,000
Community Services Revenue
$103,000
Fines and Forfeitures
$20,000
Total General Fund Revenues
$1,077,000
Other Annual Non-General Fund Revenues [1] [2]
Gas Tax Revenues
$37,000
Parks Maintenance Tax
$40,000
Prop. 172 Public Safety Sales Tax
$6,000
Public Safety Tax
$85,000
Total Other Non-General Fund Revenues
$168,000
Development Agreement Revenues
Scenario 10:Parks & Open Space Responsibility Revenues
$181,000
Community Services District Revenues (at 1.6%)
$356,000
Make Whole Provision Revenues
$93,000
Measure O Sales Tax Extension Revenues
$121,000
Nonsecured Property Tax Revenues
$9,000
Total Development Agreement Revenues
$760,000
Total Annual General Fund and Non-General Fund Revenues
$2,005,000
Of the $1.27 million of annual revenues, the first three Property Tax categories (25% of the total) will probably (pending actual presentation to the FBC) be higher than the Measure A proposal,
The three Sales Tax categories (17% of the total) were almost all based on the purchasing power of the residents of the residential portion in the Measure A proposal. The new Sales and Use Taxes and Property Tax in-Lieu of Sales Tax values are likely to change by a ratio of the new number of residents divided by the old number of residents. The Measure A proposal had “650 units with up to 1,500 beds.” The new proposal has “650 units with up to 2,600 occupants” That 73% increase in occupants is likely to produce a 73% increase in Sales Tax projections, again pending an actual presentation to the FBC)
Business License Tax (2% of the total) is likely to go down substantially.
For the last five General Fund Revenues categories (15% of the total) and the four Non-General Fund Revenues categories (8% of the total), I don’t have enough first hand knowledge from the FBC hearings to be able to speculate.
The first three Development Agreement Revenues categories (31% of the total) were insisted upon by the FBC in order to make the project fiscally viable for the City. I personally will vote against the project in the FBC if those Revenues categories are not included in the new project’s Development Agreement.
The Measure O Sales Tax amount is included with the other two Sales Tax amounts above.
The Non-Secured Property Tax amount (less than 0.5% of the total) will be reduced to zero.
Because the R&D space is now provided external to the project itself.
People voted in all kinds of different ways for all kinds of different reasons, as previous David has noted before. Some people voted it down because it had some housing in it and they thought it should be focused solely on commercial ventures. Others voted for it because of the commercial component. You might not agree with the reasoning in those votes, but they were out there. Now those folks are going to be looking for a reason to vote for this.
(I shudder to think about the numbers that some proponents might put forward this time, perhaps regardless of the truth.) It seems that some can’t even acknowledge a loss of commercially-zoned space within the city, as it occurs.
It’s like arguing with Trump. (My apologies to Trump.)
I would like to know if an external consultant will be used again for the financial analysis. (Last time, there was a disagreement between the FBC and the external consultant.)
Statement from Tim Ruff: “We paid Cahill’s group thousands of dollars to take measurements prior to the EIR and it’s cited on page 4-3-31 of the EIR (Barnes 2015). Cahill’s recommended mitigations are included in the EIR and his studies show the effectiveness of these measures. We have now removed the For Sale housing as suggested by Cahill. We are targeting students who are driving. Getting cars off the roads improves conditions for everybody and is part of the solution”
They were not the long term studies that Cahill recommended, and they were not done on site, they were done nearby. As I am sure Ruff knows.
Maybe you can address the low baseline risk issue
I plan to, but it requires a deep dive into the literature and writing up some fairly technical stuff in a clear and accessible way, and I just haven’t had the time to do that yet. Soon, I hope.
And maybe you can reply when I raise an issue, instead of ignoring it and raising a different issue, as you do repeatedly. (Or, sometimes you just stop replying when I’ve responded to a concern you raised, only to raise it again, yet you will argue with Ron until you are blue in the face. It doesn’t reflect well on you).
Or sometimes I just respond to the most recent post and don’t see other posts until later.
Anyway the reason I responded as I did, is that I really don’t think a long term study is going to change the risk factor analysis or the fact that the project is now rental only. In fact, I probably should shoot Dr. Cahill a note to see if that changes his calculus.
It’s a pretty consistent pattern and it’s been going on for a long time.
But you didn’t “respond.” I pointed out the problems with Ruff’s quote. You “responded” by changing the subject.
As I urged you to do several times several days ago, instead of pretending to know what he would think about this project.
Ron, your 8:42 post,
‘External’ to what? Do you have problems with proceeding as we did before? If so, why, and suggest an alternative…
Howard: “External” to the city. A contractor, like last time.
It was a question. Not interested in extending this conversation at this time, beyond that.
Fine…would assume same-same, as to external consultant used, and FBC review/critique… if not, introduces ‘variables’ that, in themselves, would raise more questions/dissention… justified or not…
Have a good evening…
Thank you. Have a good evening, as well.
As I scrolled through the comments (and I might have missed it), I see no mention of the truly fundamental change in this project design–that students are much less likely to be present in Nishi during the periods of greatest potential exposure. The monthly wind roses posted here (https://wrcc.dri.edu/cgi-bin/wea_windroseclim.pl?caZDAV) show that the prevailing wind is generally out of the northwest from October-April, and with higher average speeds, and then shifts to out of the south from May to September. The UCD academic year runs from late September to early June, and we all know how town empties out from the middle of June to middle of September. And go by any on-campus housing and you’ll see how few students are around. We also know that the worst air quality occurs in that same May to September period, when Nishi will be comparatively empty.
Any air quality impacts studies should be adjusted for these differentials in exposure. (And yes, I’m professionally qualified to discuss exposure studies and statistical analysis.)
Interesting point, but my estimate is 25% of the students hang around in the summer, either for summer session, summer employment… back of the envelope estimate, no statistics… was true when I was a student 40 years ago… but a point to be considered… good catch…
Richard, I think that Dr. Cahill determined that the worst months would be the winter months. See the DEIR.
And, of course, if we actually had done the studies that Dr. Cahill recommended that we do, we would know for sure instead of opining based on wind directions. At least Dr. Cahill was making inferences from nearby measurements and what is known about similar sites.