D.13 Transportation and Traffic

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This section addresses transportation and traffic issues and impacts related to the Proposed Project. Section D.13.1 provides a description of the affected environment for the Proposed Project. Applicable transportation and traffic regulations are described in Section D.13.2. Significance criteria and analyses of the Proposed Project impacts and proposed mitigation are presented in Sections D.13.3. The analysis of project alternatives, including the no project alternative, are included below as Sections D.13.4 through D.13.6. The purpose of this Traffic Impact Analysis (TIA) is to identify and analyze the impacts to the traffic if the proposed Liberty XXIII Renewable Energy Power Plant is developed. The objectives of this study are to: Review the current traffic conditions; Project and analyze future traffic conditions, with and without the project; Compare the with/without traffic situations; Identify traffic impacts that are created by the project; and Propose mitigation for any impacts. D.13.1 Environmental Setting The project site is located along the south side of Westward Avenue, east of the intersection with South Hathaway Street, in the City of Banning, County of Riverside, California. The site is just south of the Banning Municipal Airport and Interstate 10 (I-10). I-10 is under the jurisdiction of the California Department of Transportation (Caltrans). The site is located on 20.3 acres across three parcels. The Assessor s Parcel Numbers are 532-180-034, 532-180-035, and 532-180-038. The project site spans partially across all three parcels (all of 034, ½ of 035, all of 038-lot 16 and ½ of 038-lot 15). Tractor-trailer trucks will access the site from the north side along Westward Avenue and a private paved road will be constructed from the current end of pavement on Westward Avenue to the site. Existing Roadway Facilities There are four main roadways within the project study area. East Lincoln Street. East Lincoln Street is currently a two-lane roadway which extends east to west through study area. Within the study area, it intersects with South Hargrave Street and South Hathaway Street. Adjacent land uses along East Lincoln Street between Hargrave Street and Hathaway Street include residential and several existing churches. Also, the Banning Municipal Airport s runway runs north of East Lincoln Street as it approaches South Hathaway Street. The roadway is designated as a major highway in the City of Banning Circulation Element. South Hargrave Street. South Hargrave Street is currently a two-lane roadway which extends north to south through the study area. Within the study area, the roadway has an interchange with the I-10, providing access to both east and west. Adjacent land uses along South Hargrave Street include commercial convenience just north of the interchange, and between Lincoln and the I-10 interchange, there is residential to the west and industrial to the east. The roadway is designated as a secondary highway in the City of Banning Circulation Element. South Hathaway Street. South Hathaway Street is currently a two-lane roadway which extends north to south through the study area. Within the study area, the roadway intersects East Lincoln Street and Westward Avenue. Adjacent land uses along South Hathaway Street include residential to the west and industrial to the Draft EIR D.13-1 June 2008

east. The roadway is planned to be a secondary highway at buildout according to the City of Banning Circulation Element. Westward Avenue. Westward Avenue is currently a two-lane roadway which extends east to west through the study area. Within the study area, the roadway intersects South Hathaway Street and also borders the north side of the project site and provides access into the Liberty XXIII Biofuels Power, LLC (Liberty Energy) facility. The City has plans to extend the roadway east to Cottonwood Road where there are plans to build an additional interchange with the I-10 freeway. The added interchange at Cottonwood will help alleviate congestion at the Hargrave interchange. Existing Bus Transit Facilities Pass Transit provides bus service within the study. There is one bus route which operates within the study area. Route 6 Southern provides service from the Kmart Garden Center on Sunlakes Boulevard within the city limits to Sunset Avenue and West Ramsey Street. Service is provided on one-hour headways on weekdays from 6:00 AM to 7:00 PM. Bicycle/Pedestrian Network There are no existing bicycle facilities located within the project study area. There are no sidewalks along the project frontage, but there are intermittent sidewalks along other roadways within the study area. Traffic Data Collection and Intersection Operations Traffic counts at three existing intersections were collected in November and December 2007. These counts are summarized in Figure D.13-1. As shown in Table D.13.1-1, all intersections operate at LOS C or better during the peak hours, except for the interchanges with the I-10 Eastbound at Hargrave Street. The LOS threshold currently applied by the City of Banning is LOS C, except where LOS D is allowed at interchanges with I-10. Table D.13-1. Intersection Levels of Service - Existing Conditions Intersection Control AM Peak Hour PM Peak Hour Delay LOS Delay LOS S. Hathaway Street/ Unsignalized 2.6 A 2.3 A Westward Avenue S. Hargrave Street/ E. Unsignalized 8.5 A 8.6 A Lincoln Street S. Hargrave Street/ I-10 Unsignalized >50 F 18.2 C Eastbound Ramps S. Hargrave Street/ I-10 Westbound Ramps Unsignalized 16.1 C 16.3 C Notes: Average delay reported in seconds per vehicle. For side-street stop controlled intersection worst case movement delay reported. HCM 2000 methodology employed. LOS= Level of Service Source: Fehr & Peers, 2008. The Existing Roadway Segment LOS is shown in Table D.13-2. Table D.13-2. Roadway Segment Daily Level of Service- Existing Conditions Roadway Segment Classification (Number of Existing LOS C Capacity Lanes) ADT LOS C or Better South Hargrave Street north of East Secondary Highway (2) 24,000 15,140 Yes Lincoln Street East Lincoln Street Major Highway (2) 30,400 1,520 Yes South Hathaway Street Collector (2) 12,800 950 Yes Westward Avenue Collector (2) 12,800 200 Yes Notes: ADT = Average Daily Traffic June 2008 D.13-2 Draft EIR

PREPARED BY Aspen Environmental Group Source: Fehr & Peers, 2008 Figure D.13-1 Existing Traffic Counts June 2008 D.13-3 Draft EIR

D.13.2 Applicable Regulations, Plans, and Standards D.13.2.1 Local City of Banning The local regulations that apply in the City of Banning include the policies outlined in the City of Banning General Plan as well as requirements listed in the Riverside County Transportation Department Traffic Impact Analysis Preparation Guide. Intersection Analysis The Riverside County Transportation Department (RCTD) requires the use of the Transportation Research Board Highway Capacity Manual (HCM), 2000 update. Unsignalized intersections are required to be analyzed using Chapter 17 of the Highway Capacity Manual. Analysis Scenarios The RCTD requires that all traffic impact analysis include the following scenarios: Existing Traffic, Project Completion, Cumulative, and Project Phasing (if the project is proposed to be built in phases). Relevant Policies in the Circulation Element of the City of Banning s General Plan include: Policy 6: The City shall maintain peak hour Level of Service C or better on all local intersections, except those on Ramsey Street and at I-10 interchanges, where Level of Service D or better shall be maintained. Policy 7: New development proposals shall pay their fair share for the improvement of street within and surrounding their project on which they have an impact, including roadways, bridges, grade separations, and traffic signals. Policy 11: Sidewalks or other pedestrian walkways shall be required on all streets within all new subdivisions. Policy 18: The city shall review its transit service to major regional attractions, and intra-city recreational locations in future planning efforts, based on need. Policy 19: Bus pullouts shall be designed into all new projects on arterial roadways, to allow buses to leave the flow of traffic and reduce congestion. Policy 21: Update the Airport Master Plan every five years to meet the needs of the general aviation, business, and tourist segments of the community. Policy 25: The City shall develop and implement plans for a coordinated and connected bicycle lane network in the community that allows for safe use of bicycles on City streets. Policy 27: The City shall provide for a comprehensive, interconnected recreational trails system suitable for bicycles, equestrians, and/or pedestrians. D.13.3 Environmental Impacts and Mitigation Measures for the Proposed Project This section explains how impacts are assessed including the presentation of the significance criteria in Section D.13.3.1 on which impact determinations are based, and Section D.13.3.2 lists all impacts identified for the Proposed Project. June 2008 D.13-4 Draft EIR

Analysis Scenarios The analysis considers both near term and cumulative traffic impacts. The near-term analysis reflects the existing conditions, as recorded in recent traffic counts, the immediate impact of project trips, and the addition of traffic from projects directly adjacent to the project site. The cumulative analysis includes traffic from approved and proposed development projects within the study area, as well as ambient growth in traffic volumes on study area roadways, as defined by the City of Banning General Plan. Five scenarios are therefore considered: Existing, Project Opening Year (2013), Project Opening Year Plus Project (2013), Cumulative (Post 2030), and Cumulative (Post 2030) Plus Project. Analysis Methodology The analysis considers both intersections and roadway segments. Signalized Intersections Signalized intersection operations are evaluated using methodologies listed in the 2000 Highway Capacity Manual (HCM) (Transportation Research Board).These methods assess average control delays and then assign a corresponding letter grade that represents the overall condition of the intersection. These grades range from Level of Service (LOS) A (minimal delay) to LOS F (excessive congestion). Descriptions of the LOS grades for signalized intersections are provided in Table D.13-3. Table D.13-3. Signalized Intersection Criteria Level of Service Description A Operations with very low delay occurring with favorable progression and/or short cycle length. B Operations with low delay occurring with good progression and/or short cycle lengths. C Operations with average delay occurring with fair progression and/or longer cycle lengths. Individual cycle failures begin to appear. D Operations with longer delays due to a combination of unfavorable progression, long cycle lengths, or high V/C ratios. Many vehicles stop and individual cycle failures are noticeable. E Operations with high delay values indicating poor progression, long cycle lengths, and high V/C ratios. Individual cycle failures are frequent occurrences. This is considered to be the limit of acceptable delay. F Operations with delays unacceptable to most drivers occurring due to over saturation, poor progression, and/or very long cycle lengths. Source: Highway Capacity Manual (Transportation Research Board, 2000) Average Control Delay Per Vehicle (Seconds) 10.0 > 10.0 to 20.0 > 20.0 to 35.0 > 35.0 to 55.0 > 55.0 to 80.0 Levels of service are calculated using Synchro 6.0 software, which implements 2000 HCM methodologies. Synchro allows the input of signal timing and coordination data to more accurately reflect actual conditions. Delay and the resulting LOS is based on total intersection operations. Individual movements through the intersection will have varying levels of delay due to unique conditions affecting each movement. > 80.0 Draft EIR D.13-5 June 2008

Unsignalized Intersections Unsignalized intersection levels of service are analyzed using Synchro software, which implements the 2000 HCM methodologies. Please note that delay is calculated for movements that operate under traffic control. Therefore, the delay value at side-street stop-controlled reflects only the delay accruing for vehicles that are stopping at the stop sign. The LOS ranges for unsignalized intersections are shown in Table D.13-4. Table D.13-4. Unsignalized Intersection Criteria Level of Service Description Average Control Delay Per Vehicle (Seconds) A Little or no delays 10.0 B Short traffic delays > 10.0 to 15.0 C Average traffic delays > 15.0 to 25.0 D Long traffic delays > 25.0 to 35.0 E Very long traffic delays > 35.0 to 50.0 F Extreme traffic delays with intersection capacity exceeded > 50.0 Source: Highway Capacity Manual (Transportation Research Board, 2000) Roadway Segment Capacities Staff applied the Roadway Segment LOS capacities in Table D.13-5 to determine whether the roadway segments would meet the city of Banning s daily trip thresholds, as set forth in their General Plan. Table D.13-5. Roadway Segment LOS Criteria Roadway Type Number of Lanes LOS C LOS D LOS E Collector 2 12,800 14,400 16,000 Secondary 4 24,000 27,000 30,000 Major 4 30,400 34,200 38,000 Source: City of Banning General Plan Update Traffic Study 2004 Project Trip Generation The project trip generation was developed by reviewing trip generation sources and then estimating project trip generation based on these assumptions. At the request of the City of Banning, a standardized Institute of Transportation Engineers (ITE) trip generation was applied. While staff had proposed to use trip generation derived directly from the characteristics of the site, the City requested the ITE data be applied instead. The ITE trip generation category most similar to the Proposed Project in operation was Light Industrial (Land Use 110). Table D.13-6 provides the ITE trip generation estimates for Light Industrial uses. It was determined that the use of ITE data, instead of project specific data provided by Liberty Energy, would result in a conservative estimate of the project trips for the following reasons: Unlike most light industrial facilities, this project would operate 24 hours a day meaning that traffic would be distributed through all hours of the day at the Liberty Energy facility. The trip generation is based on the square footage of the entire facility (approximately 86,600 square feet). The City requested that trip generation estimates are calculated using square footage of the facility, which provides a more accurate estimate of trip generation in comparison to total acreage of the site. Using square footage also produces the highest number of peak hour trips, which will conservatively estimate the potential impacts of the site. Instead of work areas or offices that might be found at a typical light industrial facility, much of this square footage would be power facilities. The actual work or office areas of this facility would be limited. As this approach would likely overestimate the likely trips generated by the project, it provides a conservative representation of the trips generated by the project. For example, it was determined that the project may only June 2008 D.13-6 Draft EIR

generate 30 AM and PM Peak Hour trips, assuming 24-hour schedule of operations. This estimate of peak hour trips is much less than what was estimated using ITE rates, as shown in Table 13.3-6. As shown in Table D.13-6., the project is anticipated to generate 80 AM Peak Hour trips, 85 PM Peak Hour trips, and 604 daily trips. Of the 604 daily trips, 40 are expected to be made by the 20 employees working at the facility. Table D.13-6. Trip Generation Estimates ITE Trip Rates Trips Code AM Peak Hour PM Peak Hour Land Use Used Size/EMP AM PM Daily In Out Total In Out Total Daily Light Industrial 110 86.6 KSF 0.92 0.98 6.97 70 10 80 10 75 85 604 Notes: KSF= 1,000 sq. ft. Trip Distribution Project trips were distributed based on the following assumptions: Biomass and biosolids would be delivered to the facility via the I-10 freeway, exiting Hargrave Street, traveling southbound to East Lincoln Street, and turn east on Lincoln Street, and then travel eastbound to Hathaway Street. The trucks would then turn southbound on Hathaway Street to Westward Avenue where they would turn east and follow Westward Avenue to the project entrance. Trucks leaving the facility would follow this route in reverse to I-10. The most likely biomass sources would be from Los Angeles, Riverside, and San Bernardino Counties, according to information provided by the project applicant. Therefore, vehicles accessing the vehicles carry biomass would be accessing the site mainly from the west. Approximately 10 employees working at the site would commute from Beaumont/Banning, and 5 would commute from Riverside, most of whom are likely to travel eastbound on the I-10 to access the facility. Five employees are expected to commute from the Coachella Valley, for a total of 20 employees. The project trip distribution is shown on Figure D.13-2. Trip Assignment Project trips were assigned using the distribution shown in Figure D.13-3. The most direct access to the site from I-10 would occur from Hargrave Street at the existing interchange. D.13.3.1 Criteria for Determining Significance The following significance criteria were employed to determine if the project caused significant traffic impacts, based on the results of the traffic study. These criteria reflect input from the City of Banning General Plan as well as the application of standard traffic engineering guidelines. The project, including project driveways, will disrupt traffic operations. Traffic impacts were assessed using both quantitative (Level of Service (LOS)) and qualitative criteria. A disruption of traffic operations is defined as any of the following a. If the addition of project traffic causes the LOS to degrade at a signalized intersection from LOS C or better to D, E, or F at a signalized intersections. b. If the addition of project traffic causes an increase in traffic volumes at a signalized intersection already operating at LOS D, E, or F. c. If the addition of project traffic causes an unsignalized intersection to degrade to LOS D, E or F and one of more traffic signal warrants (as defined by the Manual of Uniform Traffic Control Devices (MUTCD)) are met. Draft EIR D.13-7 June 2008

PREPARED BY Aspen Environmental Group Source: Fehr & Peers, 2008 Figure D.13-2 Project Trip Distribution June 2008 D.13-8 Draft EIR

PREPARED BY Aspen Environmental Group Source: Fehr & Peers, 2008 Figure D.13-3 Project Trips with Existing Roadways June 2008 D.13-9 Draft EIR

d. If the project contributes traffic to an unsignalized intersection operating at LOS F and one or more traffic signal warrants (as defined by the Manual of Uniform Traffic Control Devices (MUTCD)) are met. e. If the project contributes traffic to a roadway segment LOS to degrade from LOS C or better to LOS D or F. f. If the project contributes traffic to a roadway segment operating at LOS D, E or F prior to the addition of project traffic. g. A project interferes with, conflicts with or precludes other planned improvements such as roadway extensions/ expansions, planned trail facilities, proposed creek restoration projects, etc. h. A project conflicts with or creates inconsistencies with adopted traffic plans, guidelines, policies or standards. i. The construction of a project creates a temporary but prolonged impact due to lane closures, need for temporary signals, emergency vehicles access, traffic hazards to bike, pedestrians, damage to roadbed, truck traffic on roadways not designated as truck routes, etc. Transit Impacts were considered significant if: a. A project or project related mitigation disrupts existing transit services or facilities. This includes disruptions caused by proposed-project driveways on transit streets and impacts to transit stops/shelters; and impacts to transit operations from traffic improvements proposed or resulting from a project. b. A project interferes with planned transit services or facilities. c. A project conflicts with or creates inconsistencies with adopted transit system plans, guidelines, policies or standards. d. The project created demand for public transit services above the capacity which is provided, or planned. Bicycle impacts were considered significant if: a. A project disrupts existing bicycle services. b. A project interferes with planned bicycle facilities. This includes failure to dedicate right-of-way for planned on- and off-street bicycle facilities included in an adopted Bicycle Master Plan or to contribute toward construction of planned bicycle facilities along the project s frontages. c. A project conflicts with or creates inconsistencies with adopted bicycle system plans, guidelines, policies or standards. Pedestrian impacts were considered if: a. A project disrupts existing pedestrian facilities. This can include adding new vehicular, bicycle or pedestrian traffic to an area experiencing pedestrian safety concerns such as an adjacent crosswalk or school, particularly if the added traffic reduces the number of acceptable pedestrian gaps at unsignalized crossings or cause queues to spillback towards pedestrian crossings. b. A project interferes with planned pedestrian facilities. In existing and/or planned urbanized areas, main streets or pedestrian districts, this can include impacts to the quality of the walking environment. c. A project conflicts or creates inconsistencies with adopted pedestrian system plans, guidelines, policies or standards. Project site plans and proposed site improvements, including mitigation, were reviewed for consistency with local design standards, parking codes, and other adopted guidelines. Project impacts were considered significant if: a. Project designs for on-site circulation, access and parking fail to meet industry standard design guidelines. b. A project fails to provide a sufficient quantity of on-site parking for vehicles. This analysis will consider both the anticipated parking demand and the parking, as required by the City of Banning Municipal Code. c. A project fails to provide accessible and safe pedestrian connections between buildings. d. A project fails to provide adequate accessibility for service and delivery trucks on-site including access to truck loading areas. e. A project violates access management standards (e.g. driveway spacing, signal spacing, sight distance, etc.) in a way that causes an adverse effect on the environment or reduction in public safety. June 2008 D.13-10 Draft EIR

D.13.3.2 Impact Analysis This section documents the project impacts during the Opening year Scenario. The Opening Year scenario reflects conditions in 2013, which is anticipated to be the likely Buildout. Impact T-1: The project, including project driveways, would disrupt existing traffic operations (Class II) Traffic volumes for the Opening Year scenario were estimated by applying a 2% background growth percentage to the existing traffic counts at the existing study intersections. In addition, project traffic from three projects scheduled to be built within the study area were added since those projects are likely to be present when the Proposed Project opens. By adding traffic from these projects in the Opening Year, the projections represent a conservative view of Opening Year conditions. These volumes are shown in Figure D.13-4. The Opening Year Project Trips added to existing condition volumes are shown on Figure D.13-5. Daily Volumes were estimated by assuming that the PM Peak Hour volumes were estimated to be 10% of the daily volumes. Tables D.13-7 provides the delay and LOS at the time of project completion. As shown in this table, several of the study intersections would operate at LOS F prior to and after the addition of project traffic. Table D.13-8 provides the roadway segment LOS for the No Project and With Project condition. Table D.13-7. Intersection Levels of Service - Year 2013 Conditions Year 2013 No Project Year 2013 Plus Project Intersection Control AM Peak PM Peak AM Peak PM Peak Delay LOS Delay LOS Delay LOS Delay LOS S. Hathaway Street/ Unsignalized 9.5 A 9.2 A 9.5 A 9.6 A Westward Avenue S. Hargrave Street/ E. Unsignalized 13.3 B 12.6 B 15.2 C 13.8 B Lincoln Street S. Hargrave Street/ I-10 Unsignalized >50 F >50 F >50 F >50 F Eastbound Ramps S. Hargrave Street/ I-10 Westbound Ramps Unsignalized 37.7 E >50 F 43.1 E >50 F Notes: Average delay reported in seconds per vehicle. For side-street stop controlled intersection worst case movement delay reported. HCM 2000 methodology employed. LOS= Level of Service Source: Fehr & Peers, 2008. Table D.13-8. Roadway Segment Daily Level of Service - Year 2013 Conditions Roadway Segment Classification (Number of Lanes) LOS C Opening Year No Project Opening Year With Project Capacity LOS C or LOS C or ADT ADT Better Better 24,000 20,550 Yes 21,150 Yes South Hargrave Street north of East Lincoln Street Secondary Highway (2) East Lincoln Street Major Highway (2) 30,400 10,170 Yes 10,770 Yes South Hathaway Street Collector (2) 12,800 7,210 Yes 7,810 Yes Westward Avenue Collector (2) 12,800 220 Yes 820 Yes Notes: ADT = Average Daily Traffic Source: City of Banning General Plan Update Traffic Study, 2004. Draft EIR D.13-11 June 2008

PREPARED BY Aspen Environmental Group Source: Fehr & Peers, 2008 Figure D.13-4 Project Opening Year - No Project Trips June 2008 D.13-12 Draft EIR

PREPARED BY Aspen Environmental Group Source: Fehr & Peers, 2008 Figure D.13-5 Project Opening Year With Project Trips June 2008 D.13-13 Draft EIR

Based on the significance criteria above, impacts were evaluated related to signalized intersections, unsignalized intersections, roadway segments, planned roadway improvements, transportation policies, and construction traffic impacts. Additional information regarding each area is presented below. Signalized Intersections: All four of the study area intersections currently operate as unsignalized intersections. Therefore, no impacts to signalized intersections would occur (No Impact). Unsignalized Intersections: With the addition of project trips, two of the four study intersections would operate at LOS F and would meet peak hour traffic signal warrants as defined by the MUTCD and a significant traffic impact would occur. Based on the previously defined significance criteria, the impacted intersections would be the I-10 Westbound Ramps/Hargrave Street and the I-10 Eastbound Ramps/Hargrave Street. Mitigation Measure T-1a (Install Traffic Signals) would require the installation of two traffic signals at the I-10 Eastbound Ramps/Hargrave Street and the I-10 Westbound Ramps/Hargrave Street intersections. Both of the intersections will operate at LOS F in the near-term.the signalization of these intersections was addressed in the City of Banning General Plan but may not occur prior to the development of the project site. With the implementation of this mitigation measure, the project impacts would be reduced to a less than significant level (Class II). Roadway Segments: Even with the addition of project trips, the roadway segment LOS would remain at LOS C or better. Therefore, the impacts related to roadway segments would be less than significant and no mitigation would be required (Class III). Planned Roadway Improvements: The City of Banning s General Plan anticipates several significant roadway improvements within the City. However, none of these proposed improvements would occur on the project site or be affected by the development of the project. Therefore it can be concluded that the project impacts related to planned roadway improvements would be less than significant and no mitigation would be required (Class III). Transportation Policies: The City of Banning s General Plan contains numerous policies related to transportation facilities. Specific policies include the requirement to maintain LOS C on a majority of the City roadways and policies designed to encourage alternative transportation modes. Therefore, it can be concluded that the development of the project would not conflict with the City s policies related to transportation. For example, the project would implement several improvements at impacted roadways to maintain the required LOS. Any conflicts would be less than significant (Class III). Construction Traffic: Construction traffic would include haul trucks required for any import/export of fill material, construction equipment traveling to and from the site, and the influx of construction workers. This evaluation of construction traffic impacts considers not only the likely traffic as well as the context area involved including the adjacent uses. Based on the following considerations, it was determined that a construction related impact would occur, resulting in a significant traffic impact: Construction of the site would involve the import of construction equipment including bulldozers, concrete mixers, and other related items. Construction will also require the daily importation of construction materials such as concrete and other construction materials in addition to workers traveling to and from the site on a daily basis. These materials would have to be transported to the site, stored on the site, and removed from the June 2008 D.13-14 Draft EIR

site following the completion of construction. Construction equipment, materials, and workers would travel to the site along the same roadways and intersections studied above. As noted previously, several of these intersections are projected to operate at a deficient LOS. Therefore, construction vehicles may experience delay as they travel to the site while contributing to the delay experienced by other vehicles. Consequently, construction activities could result in significant traffic impacts (Class II). Mitigating this construction related impact would require the preparation of a Construction Traffic Mitigation Plan, as outlined in Mitigation Measure T-1b (Prepare Construction Traffic Management Plan) below. Mitigation Measures for Impact T-1 T-1a T-1b Install Traffic Signals. The project would be responsible for the installation of traffic signals at the I-10 Eastbound/South Hargrave Street and I-10 Westbound/South Hargrave Street intersections. The project would be responsible for the design and construction of these two traffic signals. These traffic signals would be installed prior to the project commencing operations. Prepare Construction Traffic Management Plan. The project would be responsible for developing a construction traffic management plan to address potential traffic impacts related to the project. This plan would be provided to the City Banning for its review and approval prior to the commencement of construction activities. Specific measures included in this construction traffic management plan would include haul and equipment delivery routes, any limitations on peak hour travel during construction, and other items as applicable. Impact T-2: The project would disrupt transit service or conflict with transit policies (Class III) The Proposed Project would have the potential to disrupt existing or planned transit service, conflict with plans and policies associated with transit, or increase the demand for transit service above capacity. Construction and operational transport routes associated with the Proposed Project would not conflict with existing transit in the study area provided by Pass Transit. There is no planned transit service which would extend across the site and would therefore be affected by the development of the site. Additionally, the only roadway improvements associated with the site related to the signalization of several unsignalized intersections, which can only improve transit operations at these locations. The City s General Plan incorporates several policy statements related to transit. However, these policy statements are directed at project sites such as residential subdivisions where transit service could be utilized. As this site is not conducive to transit (as a majority of the trips would be associated with the delivery of materials to the site using trucks), there is little need to incorporate transit facilities into the site. Since the use of the site is not conducive to transit, the demand for transit service would be minimal. Consequently, any impacts associated with the disruption of transit or conflicts with transit policies would be less than significant (Class III). Impact T-3: The project would disrupt bicycle facilities or conflict with bicycle policies (Class III) There are no existing or proposed bicycle facilities within the project site or in its vicinity that would be affected by the development of the site. The City s General Plan incorporates several policy statements related to bicycling. These statements relate to the provision of bicycle facilities on roadways instead of facilities within projects. Additionally, the project is not likely to generate bicycling trips or be accessed by persons using bicycles. Any impacts associated with the disruption of bicycle use or conflicts with bicycle use policies would be less than significant (Class III). Draft EIR D.13-15 June 2008

Impact T-4: The project would disrupt pedestrian facilities or conflict with pedestrian policies (Class III) There are no existing or planned future pedestrian facilities adjacent to the project site which would be affected by the development of the Proposed Project. There are no conflicts with the policy statements in the General Plan related to pedestrians. For example, this project is not a subdivision where pedestrian walkways or sidewalks would need to be provided. It is anticipated that, given the usage of the site, pedestrian travel within the site would be limited and no external pedestrian access would be provided. Consequently, any impacts associated with pedestrians or conflicts with pedestrian policies would be less than significant (Class III). Impact T-5: Project site plans and proposed site improvements, including mitigation, are consistent with local design standards, parking codes, and other adopted guidelines (Class II) The review of the project site plan considered on-site circulation and site access, parking adequacy, pedestrian connectivity, delivery vehicle access, and access management standards. On-Site Circulation and Site Access: The project would have a single driveway on Westward Street. All of the project vehicles would take access at this location. From this driveway, vehicles would travel through the site via an internal roadway. This internal roadway would connect the various buildings including the administration building (where a majority of workers will park) and the biomass and biosolids facilities, which would be accessed by the trucks traveling to the site. Given the number of vehicles accessing the site during both the peak hour and daily basis, a single driveway and internal roadway would provide sufficient access. Based on these considerations, any impact would be less than significant and no mitigation is required (Class II). Parking Adequacy: The City of Banning Municipal Code contains no parking requirement for a facility similar to the Proposed Project. Therefore, the Municipal Code can not be utilized to assess the parking adequacy. Parking adequacy can be assessed by comparing the number of employees against the parking spaces provided on-site. The maximum number of employees at the site would be 20 with 24-hour operations on the site. With 24-hour operation, it is anticipated that no more than 2/3 of the employees would be found on the site at any time. Since 15 parking spaces are provided, the parking provided would be adequate and the impact would be less than significant (Class III). Therefore, no mitigation would be required. Internal Pedestrian Connectivity: A majority of the pedestrian travel would occur between the parking area and the administration building. There could be intermittent pedestrian travel between the administration building and the other facilities on the site using the internal roadway provided. Due to the limited pedestrian use on-site and the capacity of the internal roadway, the internal pedestrian connectivity would be adequate and any impacts would be less than significant (Class III). No mitigation would be required. Delivery Vehicle Access: A variety of delivery vehicles would take access to the site on a daily basis. The majority of these vehicles would be delivering biomass and biosolid fuel material to be consumed at the facility. The remaining delivery vehicles would carry chemical supplies and miscellaneous equipment used at the facility. Regional delivery vehicle access would be provided through roadways like I-10 with access to the site itself provided by Westward Street. From the driveway on Westward Street, delivery vehicles would take access to the areas of the site through the internal roadway provided. As the project is located close to I-10, the need for vehicles to use surface streets would be limited. As described above in Impact T-1, operational delivery access would be significant, but with the implementation of Mitigation Measure T-1a (Install Traffic Signals), any impacts would be reduced to be less than significant (Class II). June 2008 D.13-16 Draft EIR

Access Management Standards: In addition to the items considered above, the analysis also evaluated how the project would comply with applicable access management standards, which relates to traffic signal and driveway spacing. As the project would not involve the installation of traffic signals at any project driveways, standards related to signal spacing would not apply. Additionally, the project would take access from Westward Street in a section located away from adjacent uses. The proposed driveway would therefore be located away from others, which would limit conflicts with adjacent driveways. Based on these considerations, the project would be in compliance with applicable access management standards and any impacts would be less than significant (Class III). No mitigation would therefore be required. D.13.4 Alternative 1 The Charles Street Truck Route Alternative would provide a different route for trucks delivering biofuel and removing ash. Along this Alternative, instead of turning east on Westward Avenue, trucks would continue on Hathaway Street to Charles Street, where they would turn east and follow Charles Street to the Liberty Energy facility. All other components of construction and operation of the Liberty Energy facility would remain the same as described for the Proposed Project. D.13.4.1 Alternative 1 Environmental Setting As the Charles Street Truck Route Alternative would have similar truck travel routes as the Proposed Project, and no other components of construction or operation of the Liberty Energy facility would change as compared to the Proposed Project, the environmental settings for traffic would be identical to that described previously. D.13.4.2 Alternative 1 - Environmental Impacts and Mitigation Measures Impact T-1: The project, including project driveways, would disrupt existing traffic operations (Class II) Traffic impacts associated with Alternative 1 would be the same as those identified for the Proposed Project. In particular, the significant traffic impacts identified at the I-10 Eastbound Ramps/Hathaway Street and I-10 Westbound Ramps/Hathaway Street would remain as this alternative does not change the regional access route for vehicles or the reduce the need to use I-10 to provide regional connectivity. Mitigation Measure T-1a (Install Traffic Signals) would still be required. Additionally, construction traffic impacts would also remain significant as this alternative does not change the level or intensity of construction. Therefore, Mitigation Measure T-1b (Prepare Construction Traffic Management Plan) would also still be required. Implementation of these mitigation measures would reduce impacts to be less than significant (Class II). Impact T-2: The project would disrupt transit service or conflict with transit policies (Class III) Transit impacts associated with Alternative 1 would be the same as identified for the Proposed Project. Construction and operational transport routes associated with the Proposed Project would not conflict with existing or planned transit in the study area provided by Pass Transit. Additionally, roadway improvements associated with the site related to the signalization of several unsignalized intersections would only improve transit operations at these locations. As the site is not conducive to transit, there is little need to incorporate transit facilities into the site, so the demand for transit service would be minimal. Consequently, any impacts associated with the disruption of transit or conflicts with transit policies would be less than significant (Class III). Draft EIR D.13-17 June 2008

Impact T-3: The project would disrupt bicycle facilities or conflict with bicycle policies (Class III) As there are no existing or proposed bicycle facilities within the project site or in its vicinity, bicycle impacts associated with Alternative 1 would be the same as described for the Proposed Project. The City s General Plan incorporates several policy statements related to the provision of bicycle facilities on roadways instead of facilities within projects and so would not be applicable to the alternative. Additionally, the project is not likely to generate bicycling trips or be accessed by persons using bicycles. Any impacts associated with the disruption of bicycle use or conflicts with bicycle use policies would be less than significant (Class III). Impact T-4: The project would disrupt pedestrian facilities or conflict with pedestrian policies (Class III) Pedestrian impacts associated with Alternative 1 would be identical to those identified for the Proposed Project. There are no existing or planned future pedestrian facilities adjacent to the project site which would be affected by the development of Alternative 1. There are no conflicts with the policy statements in the General Plan related to pedestrians. It is anticipated that, given the usage of the site, pedestrian travel within the site would be limited and no external pedestrian access would be provided. Consequently, any impacts associated with pedestrians or conflicts with pedestrian policies would be less than significant (Class III). Impact T-5: Project site plans and proposed site improvements, including mitigation, are consistent with local design standards, parking codes, and other adopted guidelines (Class II) Consistency with local design standards, parking codes, and other guidelines would be the same for Alternative 1 as described for the Proposed Project. Given the number of vehicles accessing the site during both the peak hour and daily basis, on-site circulation and access would be adequate. As the maximum number of employees at the site would be 20 with 24-hour operations on the site and no more than 2/3 of the employees would be found on the site at any time, the 15 parking spaces provided would be adequate. Due to the limited pedestrian use on-site and the capacity of the internal roadway, the internal pedestrian connectivity would be sufficient for Alternative 1. Alternative 1 would also be in compliance with applicable access management standards. As described above in Impact T-1, operational delivery access would be significant, but with the implementation of Mitigation Measure T-1a (Install Traffic Signals), any impacts would be reduced to be less than significant (Class II). D.13.5 Alternative 2 Under this alternative, operational truck traffic would be restricted to occur only outside of peak traffic hours. Construction of the Alternative 2 would be the same as described for the Proposed Project. With the exception of the times that operational truck traffic would be restricted, operation and maintenance of Alternative 2 would be the same as the Proposed Project. D.13.5.1 Alternative 2 Environmental Setting As the Avoid Peak Hours Traffic Alternative would have identical truck travel routes as the Proposed Project, and no other components of construction or operation of the Liberty Energy facility would change as compared to the Proposed Project, the environmental settings for traffic would be identical to that described previously. The only change would be a reduction of peak hour traffic with the restrictions on truck operations. Even with the reduction in truck operations, some peak hour trips would occur on the project site as employees would June 2008 D.13-18 Draft EIR

still travel to and from the site during these same peak hours. Therefore, peak hour traffic would be reduced but not eliminated. D.13.5.2 Alternative 2 - Environmental Impacts and Mitigation Measures Impact T-1: The project, including project driveways, would disrupt existing traffic operations (Class II) Traffic impacts associated with Alternative 2 would be similar to those identified in Section D.13.4. In particular, the significant traffic impacts identified at the I-10 Eastbound Ramps/Hathaway Street and I-10 Westbound Ramps/Hathaway Street would remain as the project trips would be reduced but not eliminated. With the residual employee trips, the intersections would remain at LOS F and still meet one or more of the traffic signal warrants. Mitigation Measure T-1a (Install Traffic Signals) would still be required. Additionally, construction traffic impacts would also remain significant as this alternative does not change the level or intensity of construction. Therefore, Mitigation Measure T-1b (Prepare Construction Traffic Management Plan) would also still be required. Implementation of these mitigation measures would reduce impacts to be less than significant (Class II). Impact T-2: The project would disrupt transit service or conflict with transit policies (Class III) Transit impacts associated with Alternative 2 would be the same as identified for the Proposed Project. Construction and operational transport routes associated with the Proposed Project would not conflict with existing or planned transit in the study area provided by Pass Transit. Additionally, roadway improvements associated with the site related to the signalization of several unsignalized intersections would only improve transit operations at these locations. As the site is not conducive to transit, there is little need to incorporate transit facilities into the site, so the demand for transit service would be minimal. Consequently, any impacts associated with the disruption of transit or conflicts with transit policies would be less than significant (Class III). Impact T-3: The project would disrupt bicycle facilities or conflict with bicycle policies (Class III) As there are no existing or proposed bicycle facilities within the project site or in its vicinity, bicycle impacts associated with Alternative 2 would be the same as described for the Proposed Project. The City s General Plan incorporates several policy statements related to the provision of bicycle facilities on roadways instead of facilities within projects and so would not be applicable to the alternative. Additionally, the project is not likely to generate bicycling trips or be accessed by persons using bicycles. Any impacts associated with the disruption of bicycle use or conflicts with bicycle use policies would be less than significant (Class III). Impact T-4: The project would disrupt pedestrian facilities or conflict with pedestrian policies (Class III) Pedestrian impacts associated with Alternative 2 would be identical to those identified for the Proposed Project. There are no existing or planned future pedestrian facilities adjacent to the project site which would be affected by the development of Alternative 2. There are no conflicts with the policy statements in the General Plan related to pedestrians. It is anticipated that, given the usage of the site, pedestrian travel within the site would be limited and no external pedestrian access would be provided. Consequently, any impacts associated with pedestrians or conflicts with pedestrian policies would be less than significant (Class III). Draft EIR D.13-19 June 2008

Impact T-5: Project site plans and proposed site improvements, including mitigation, are consistent with local design standards, parking codes, and other adopted guidelines (Class II) Consistency with local design standards, parking codes, and other guidelines would be the same for Alternative 2 as described for the Proposed Project. Given the number of vehicles accessing the site during both the peak hour and daily basis, on-site circulation and access would be adequate. As the maximum number of employees at the site would be 20 with 24-hour operations on the site and no more than 2/3 of the employees would be found on the site at any time, the 15 parking spaces provided would be adequate. Due to the limited pedestrian use on-site and the capacity of the internal roadway, the internal pedestrian connectivity would be sufficient for Alternative 2. Alternative 2 would also be in compliance with applicable access management standards. As described above in Impact T-1, operational delivery access would be significant, but with the implementation of Mitigation Measure T-1a (Install Traffic Signals), any impacts would be reduced to be less than significant (Class II). D.13.6 No Project Alternative Under the No Project Alternative, traffic associated with the development of the site would not occur. As the site is currently vacant, the site would generate no trips. Additionally, there would be no construction related traffic. Given these considerations, Impact T-1 would no longer occur and Mitigation Measures T- 1a (Install Traffic Signals) and T-1b (Prepare Construction Traffic Management Plan) would no longer be required. D.13.7 Mitigation Monitoring, Compliance, and Reporting Table Table D.13-9 on the following page presents the mitigation monitoring recommendations for Transportation and Traffic. June 2008 D.13-20 Draft EIR