CAJA offers a broad range of environmental consulting services with a particular emphasis on California Environmental Quality Act (CEQA) and National Environmental Policy Act (NEPA) documentation. In addition to CEQA and NEPA related analysis and documentation (described in detail below), CAJA provides specialized environmental analyses and services to meet each client’s individual needs. CAJA’s diverse assortment of services includes:
- CEQA/NEPA Documentation
- Aesthetics/View Studies and Simulations
- Air Quality Studies
- Noise Studies
- Land Use/Zoning Analyses
- Environmental Review Management
- Mitigation Monitoring Programs
- Peer Review Services
- Expert Witness Testimony
- Environmental Constraints Analyses
- Strategic Assistance
- Project Benefit Analyses
- Preparation of Community Impact Reports
ENVIRONMENTAL IMPACT REPORT/STATEMENT PREPARATION AND TECHNICAL ANALYSIS
CAJA approaches the preparation of each environmental document with an emphasis on quality and thoroughness of analysis. Because a project’s environmental document is sometimes scrutinized by interested parties, the potential environmental effects of the project must be fully analyzed and disclosed. Although any environmental document can be challenged, a document that is prepared using a comprehensive approach with appropriately conservative assumptions is likely to withstand any legal challenges that might be raised. In addition, an Environmental Impact Report/Statement (EIR/EIS) must respond directly to issues introduced by responsible agencies, interest groups, and community organizations. A document that provides thoughtful and well written responses to issues raised during the environmental review process is the best means of allowing applicants to proceed with their projects in the most expeditious manner. CAJA is responsible for all document preparation tasks, including:
Reviewing quality and content of all technical analyses.
Ensuring compliance with style, format, and content requirements of responsible and lead agencies.
Reviewing technical methodologies.
Developing new methodologies as appropriate to meet the specific needs of a particular project.
Additionally, since CAJA specializes in environmental analysis and documentation, the project management staff can apply all available resources towards regularly upgrading our analytical approach and quality standards. With regard to this, the firm has earned a reputation for being conscientious in its approach and responsive to tight schedules and emergent problems. CAJA’s EIRs are prepared to the standards and requirements of CEQA, the State CEQA Guidelines, the Office of Planning and Research guidelines, State planning and zoning laws, and applicable lead agency regulations. Environmental documents are always prepared in a manner that meets CAJA’s exacting standards of quality, with specific emphasis placed on a clear and substantive writing style.
INITIAL STUDY/NEGATIVE DECLARATION & ENVIRONMENTAL ASSESSMENT/FINDING OF NO SIGNIFICANT IMPACT PREPARATION
CAJA specializes in a wide-ranging identification of constraints and opportunities created by a project and identification of project alternatives that minimize or avoid significant impacts to the environment. In addition to more extensive environmental documentation, CAJA prepares Initial Studies (ISs) and Environmental Assessments (EAs) that investigate the scope of potential impacts resulting from a project and ultimately determine whether or not an EIR under CEQA or EIS under NEPA is required. If the results of the analysis indicate that an EIR or EIS is not required, CAJA will prepare a Negative Declaration (ND) or Mitigated Negative Declaration (MND) pursuant to CEQA, or a Finding of No Significant Impact (FONSI) pursuant to NEPA. Overall, this process generally includes:
- Preparing Environmental Information forms and a detailed IS or EA.
- Identifying viable mitigation measures and project conditions that would reduce impacts to a less-than-significant level
- Preparing, noticing, and distributing the IS/MND or EA/FONSI.
The comprehensive approach CAJA brings to these tasks provides extensive evaluation of a project while eliminating costly and unnecessary environmental analysis.
AESTHETICS/VIEW STUDIES AND SIMULATIONS
AIR QUALITY ANALYSIS
CAJA offers expert assistance in air quality assessment and mitigation, including:
• Construction Pollutant Modeling
• Project Operational Pollutant Modeling
• Carbon Monoxide Hotspots Modeling
• Air Quality Dispersion Modeling
• Human Health Risk Assessment
• Greenhouse Gas Emission Analysis
EMISSION INVENTORY DEVELOPMENT AND AIR DISPERSION MODELING
Most regulatory agencies require an evaluation of air pollutant emissions levels and/or concentration levels of criteria pollutants such as ozone, nitrogen dioxide, carbon monoxide, sulfur dioxide, and particulate matter to determine the impact of a project to air quality. CAJA utilizes the latest air quality modeling practices and techniques to accurately and precisely quantify air pollutant emission and concentration levels both during construction and after project completion. The type of modeling utilized is determined by the latest industry standards and the needs of both the regulatory agencies involved and the project specific demands.
The following are some of the models used to develop emission inventories and conduct air dispersion analysis.
alEEMod is a statewide land use emissions computer model designed to quantify potential criteria pollutant and greenhouse gas emissions associated with both construction and operations from a variety of land use projects. The model quantifies direct emissions from construction and operations (including vehicle and off-road equipment use), as well as indirect emissions, such as greenhouse gas emissions from energy use, solid waste disposal, vegetation planting and/or removal, and water use. The mobile source emission factors used in the model (EMFAC2011) includes the Pavley standards and Low Carbon Fuel standards. Further, the model identifies mitigation measures to reduce criteria pollutant and greenhouse gas emissions along with calculating the benefits achieved from measures chosen by the user.
The URBEMIS 2007 software estimates emissions associated with both construction and operational activities. Construction emissions are evaluated based on the timing of construction phases and the size of the project site. User overrides for defaults provide additional site-specific flexibility. Operational emissions are evaluated for mobile sources operating during the use of a development as well as area sources once the development is operational.
The EMFAC 2007 model estimates emission rates of criteria pollutants for on- road mobile sources operating in California. Emissions are calculated based on vehicle type, model year, ambient weather conditions, and time frame.
The OFFROAD 2007 model estimates the activity and emissions of off-road mobile emission sources such as construction equipment. OFFROAD contains a database of default values for construction equipment information and can calculate emission factors based on the type of equipment and year of use.
ISC3 is a steady-state Gaussian plume model which can be used to assess pollutant concentrations from a wide variety of sources associated with
an industrial complex. This model is used by the South Coast Air Quality Management District to assess potential localized significant impacts, and can account for the following: dry plume depletion of particles; down wash; point, area, line, and volume sources; plume rise as a function of downwind distance; separation of point sources; and limited terrain adjustment. ISC3 operates in both long-term and short-term modes.
AERMOD is an advanced plume model that incorporates updated treatments of the boundary layer theory, understanding of turbulence and dispersion, and handling of terrain interactions. This is the dispersion model recommended
by the United States Environmental Protection Agency (US EPA), and can be adapted to meet the diverse modeling challenges faced in the state of California. Several model enhancements were made as a result of public comment, including the installation of the PRIME down-wash algorithm. AERMOD is a refined model that is utilized to provide the most accurate analysis possible.
The California LINE Source Dispersion Model, Version 4 (CALINE4) is the standard modeling program used by Caltrans to assess carbon monoxide (CO) impacts near transportation infrastructure. The model is based on the Gaussian diffusion equation and employs a mixing zone concept to characterize pollutant dispersion over the roadway.
HUMAN HEALTH RISK ASSESSMENT
Many regulatory agencies require performing human Health Risk Assessments (HRAs) to evaluate impacts from the release of toxic air contaminants (TACs). These risk assessments estimate cancer risks and non-cancer effects from TAC emissions on nearby residents and other sensitive receptors. Such evaluations include diesel particulate matter from diesel trucks servicing distribution centers and large retail centers, benzene from gasoline service stations, and process TACs at large industrial facilities. In addition, CAJA has the technical capabilities to evaluate the impact from TACs to a project site from existing sources such as the impact of nearby industrial facilities to a proposed residential project. HRAs are prepared by quantifying toxic air emissions and resulting health risks at sensitive receptors using advanced toxic air emission and health risk assessment tools, including Hotspots Analysis and Reporting Program (HARP) and proprietary analytical tools.
The Hotspots Analysis and Reporting Program (HARP) is a tool that combines emission inventories, air dispersion modeling and risk assessment analysis to estimate chronic and acute health impacts consistent with the Office of Environmental Health Hazard Assessment (OEHHA) Air Toxics “Hot Spot” Program.
GREENHOUSE GAS EMISSION ANALYSIS
Since the passage of Assembly Bill 32, California Global Warming Solutions Act of 2006 (AB 32), CAJA has been helping public and private sector clients comply with emerging greenhouse gas regulations and policies. This includes using agency-approved methods to estimate existing and potential greenhouse gas emissions from direct and indirect sources (greenhouse gas inventories), recommending innovative greenhouse gas/air pollutant reduction methods during the construction and operation of a project, investigating the use of renewable energy sources/energy efficient products, and quantifying the benefits of resource conservation (e.g., electricity usage, recycling).
CAJA’s innovative approach to greenhouse gas analysis utilizes the latest methodologies recommended by reputable sources, such as the Climate Action Registry General Reporting Protocol, the California Air Resources Board (CARB) AB 32 Scoping Plan, the US EPA, and the Greenhouse Gas Protocol developed by the World Resources Institute and the World Business Council.
CAJA offers expert assistance in transportation and community noise assessment and mitigation, including:
• On-Site Noise Measurement
• Residential Noise Studies
• Construction Noise Measurement, Analysis, and Mitigation
• Community Noise Surveys
• Traffic Noise Analysis
CAJA utilizes the following noise modeling practices and techniques to accurately and precisely quantify ambient noise levels both prior to construction and after project completion.
The first step in quantifying the impact a particular project may have on the existing noise environment is identifying the baseline noise conditions. CAJA’s technical experts record existing ambient noise levels using the Larson-Davis 831 noise meter. The Model 831’s measurement capabilities include instantaneous Sound Pressure Level; Lmin; Lmax; Lpeak and Unweighted Peak Levels; Ln (statistics); Leq; Sound Exposure Level (SEL); and Time Weighted Average (TWA). All of these parameters are measured simultaneously, making this tool very flexible in many different applications.
To determine a project’s potential construction-related noise impacts, CAJA uses a set of construction noise level data published by the US EPA that outlines the noise ranges of typical construction equipment that can be found at various types of construction sites. Under conditions where a more refined analysis is required, CAJA utilizes the Federal Highway Administration Roadway Construction Noise Model (FHWA RCNM) that is capable of predicting noise from construction operations based on a compilation of empirical data and the application of acoustical propagation formulas.
FHWA HIGHWAY TRAFFIC NOISE PREDICTION MODEL FHWA-RD-77-108
To determine a project’s operational noise levels associated with project- generated traffic CAJA utilizes the FHWA Highway Traffic Noise Prediction Model (FHWA-RD-77-108). The FHWA Model calculates the peak hour Leq and 24-hour Ldn or Community Noise Equivalent Level (CNEL) noise levels associated with traffic based on a particular reference set of input conditions, including site-specific traffic volumes, distances, speeds, and/or noise barriers.
LAND USE/ZONING ANALYSIS
CAJA provides assistance to clients with researching and analyzing land use and zoning regulations to help determine the extent of development permitted under existing designations and/or additional entitlements that could be required.
ENVIRONMENTAL REVIEW MANAGEMENT
The most important consultant function in the environmental review process is effective project management.
CAJA’s project management approach is based on our understanding that each project presents a unique set of challenges based on the level of detail proposed in the project plans, available site-specific information, perceived public controversy, and pro-posed timing of project implementation. CAJA’s overall approach to project management is based on clear communication. As the leader of the environmental team, CAJA communicates all project milestones, issues, and pending processes with project team members and City staff to ensure compliance with the schedule, scope of work, and budget.
CAJA’s management approach allows regular interaction between the project team, lead agency staff, and the other consultants; and requires frequent information sharing among team members. This approach fosters efficient data acquisition and provides advance notice of environmental findings. Such participation minimizes environmental impacts and duplication of research efforts, improves the technical quality and accuracy of the environmental analysis, and ultimately assists in the preparation of a quality project design and therefore, a technically accurate environmental document.
CAJA reviews all project communications and technical reports in a timely fashion to ensure that issues are recognized early in the process and communicated to appropriate parties, and that an action plan is formulated for resolving issues. This ensures that the environmental review focuses appropriately on environmental issues of most controversy and importance, that all environmental review is conducted to the highest standards and considers all appropriate environmental thresholds, and that all client and public concerns are addressed appropriately. In this role, CAJA is also responsible for:
- Supervising technical consultants who prepare specialized technical studies;
- Coordinating with the lead agency; and
- Facilitating communication between agencies, the project development team (including the applicant, attorney, architect, et al.), and all consultants.
CAJA is recognized for the effective execution of these responsibilities, which ultimately determines the schedule, cost, and legal adequacy of the environmental review process for any project.
MITIGATION MONITORING PROGRAMS
CAJA prepares “stand-alone” Mitigation Monitoring Programs that may be submitted concurrently with the primary environmental document or subsequent to environmental review. A subsequent program may be needed to reflect mitigation modification or design changes that could affect mitigation measures described in the primary environmental document.
Programs are developed to meet the specific needs of different agencies, documenting all stages of mitigation implementation, enforcement mechanisms, and criteria to be used to determine compliance with mitigation conditions.
PEER REVIEW SERVICES
CAJA provides impartial peer review for both private and public clients of CEQA documentation and other technical studies to ensure adherence to appropriate regulatory standards and to minimize the potential for litigation.
EXPERT WITNESS SERVICES
CAJA provides support services to private clients and public agencies on challenges to CEQA review.
ENVIRONMENTAL CONSTRAINTS ANALYSIS
Understanding the environmental and land-use constraints on a project site early in the planning stages of a project provides valuable insight to a site’s limitations and opportunities, resulting in a cost-efficient and timely entitlement and permitting process. CAJA’s staff and its technical and entitlement contract consultants are experienced in performing on-site surveys that identify and map environmentally-sensitive resources, environmental and regulatory land-use/zoning constraints, and other regulated permitting processes that might restrict or cause modifications to the development of a parcel of land. Such assistance can help identify and address environmental and planning issues prior to the start of a project, allowing the lead agency to consider adjustments in the project design that would mitigate potentially significant environmental impacts that were previously unknown or overlooked.
CAJA offers environmental constraints analysis to both private applicants and public agencies.
CAJA provides assistance in identifying CEQA compliance strategies that can minimize legal exposure and allow projects to be navigated through the CEQA process efficiently.
PROJECT BENEFIT ANALYSIS
PREPARATION OF COMMUNITY IMPACT REPORTS
In addition to preparing a wide range of environmental documents, CAJA also prepares “stand-alone” Community Impact Reports (CIRs) for both public and private sector clients. The CIR is designed to complement an environmental impact analysis by providing comprehensive and objective information regarding the social, economic, and demographic impacts of a proposed project to project applicants, policy makers, and the public.
CAJA recognizes that for a decision-making body to accurately weigh the costs and benefits of a proposed project, the CIR must address the unique set of circumstances that are relevant to each community at the time of the proposed development. As such, there is no single formulaic approach to the preparation of a CIR.
CIRs prepared by CAJA utilize spatial Geographic information system (GIS), statistical, and qualitative analysis using applicable detests, state and local economic data, and current Census data to provide a detailed cost-benefit analysis. CAJA’s ability to accurately analyze a proposed project’s impacts on local businesses, public health and safety, community services, employment opportunities, and housing, makes CAJA a leader in this area of study.
WATER SUPPLY ASSESSMENTS
CAJA provides assistance to applicants, lead agencies, and water suppliers in the preparation of water supply analyses required by state laws SB 610 and SB 221, which require projects exceeding certain size thresholds to include evaluations of long-term water supply availability in their environmental documents. While these assessments are required to be adopted by the water supplier to the project, CAJA can assist in preparing documentation that is consistent with the requirements of state law and associated case law.
CAJA understands the interactions between the sources of state water supplies, such as the Colorado River, State Water Project and Central Valley Project; regional cooperatives, such as the Metropolitan Water District of Southern California; local wholesalers; and local water purveyors, along with local water sources such as groundwater and recycled water. CAJA develops estimates of project-related water demand using appropriate local demand factors, along with cumulative demand within the service area of the water supplier, and analyzes the projected demand relative to local, regional, and state-wide water plans to assess the reliability of future supplies that would serve the project, including alternative sources of supply if necessary. CAJA also incorporates this information and analysis into the project’s environmental document to provide the specific assessments and supporting documentation required to comply with state law and court decisions.