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I I I I I I I I I I I I I I I I I I I Because it exceeds the applicable threshold for number of parking spaces, the proposed project will require an Indirect Source Permit (ISP), to be administered by the Minnesota Pollution Control Agency (MPCA). Ryan is in the process of preparing an ISP Permit Application to be submitted to the MPCA. This application will include extensive analysis to estimate the potential impact of the proposed project upon air quality in the vicinity of the site. This analysis focuses upon carbon monoxide (CO), which is the primary pollutant of concern with vehicle emissions. Although the ISP has not been completed to date, for purposes of responding to this section of the EA W, calculations predicting carbon monoxide levels in the vicinity of the development have been conducted. Data used in the CO calculations for this EA W has been discussed with the MPCA and will be incorporated into the ISP application. It is anticipated that a final ISP application will be submitted in the near future. The basic methodological approach used in performing CO calculations for ISP Permit Applications, and this analysis, is as follows: 1. Establish an assessment year defined as one year following the anticipated occupancy of the project. 2. Determine busiest intersection in the vicinity of the project which will be significantly impacted by the project (source intersection). 3. Project CO levels generated at the source intersection for the assessment year by non-project traffic in combination with project-related traffic. 4. Determine potentially sensitive receptors which could be impacted by CO dispersion from the source intersection. 5. Model CO dispersion from the source intersection to the identified receptors. 6. Add the CO from the source intersection to projected background CO levels, and compare this sum to state air quality standards for CO concentrations. The year 2004 has been established as the assessment year (estimated one year after development). Source intersections modeled in this analysis were determined to be the intersection of Cleveland Avenue and County Road C and Cleveland Avenue and County Road D. Vehicular CO generation for 2004 at the source intersection was projected using MOBILES a with traffic projection information from the Benshoof and Associates, Inc. referenced in Response 21. Receptor locations for the modeling study were selected based upon locations where the general population may be during the appropriate averaging times for the MPCA CO standard (one hour and eight hour). The receptor locations used in the ISP analysis for the proposed project are identified on the attached figure. CO dispersion from the source intersections to the receptor locations was modeled using the CAL3QHC model. Background CO levels for the area were based upon historical data projected to 2004 levels taking into account anticipated overall increases in traffic levels and other factors. The methods and procedures used in this analysis were consistent with Indirect Source Permit Application Guidelines provided by the Minnesota Pollution Control Agency. Page 25