Agmt16 Moore, Iacofano, Goltsman, Inc.

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General Plan policies and City regulations intended to reduce air quality impacts during project construction and operation. The impact analysis will evaluate whether project construction and operation could result in significant air quality impacts. The analysis will evaluate the project's consistency with the BAAQMD's 2010 Clean Air Plan and the significance of the amount of pollutants that would be generated by project construction and operation. The proposed project's net increase in square footage is below BAAQMD construction screening size parameters for general office use (277, 000 square feet). However, if the project involves extensive material transport (more than 10,000 cubic yards) associated with building demolition and excavation for underground parking, then the project will require a detailed construction emissions assessment. In addition , project construction emissions may generate pollutant concentrations that result in potentially significant health risks at nearby residential and day care receptors located approximately 300 feet east and 280 feet southwest, respectively, of the project site. The construction emissions assessment will use methodologies recommended by or consistent with the most recent guidelines available from the BAAQMD (2011 ), and will include: 1 . Use of the California Emissions Estimator Model (CaIEEMod) to quantify the mass amount of pollutants, including fugitive dust, produced by project construction. Depending on the amount of pollutants that could be emitted by the project, the California Air Resources Board's (CARB ) latest EMFAC and OFFROAD models may be used to refine CALEEMOD emissions estimates. These CARB models contain more detailed information on the type, operating modes, and emissions associated with on-road and off-road vehicles and equipment. 2. Use of the American Meteorological Society's/U .S . EPA's Regulatory Model (AERMOD) to quantify pollutant dispersion and resulting pollutant concentrations at sensitive receptor locations . Modeled pollutant concentrations will be used to calculate carcinogenic and non-carcinogenic health risks from project emissions. The construction health risk (toxic air contaminants — TACs) analysis will follow the latest recommendations from the BAAQMD and/or the California Office of Environmental Health Hazard Assessment. Feasible mitigation measures (if necessary) and construction best management practices will be identified to reduce construction emissions to less-than-significant levels . Similar to construction parameters, the proposed project's net increase in square footage is substantially below BAAQMD operational screening size parameters for general office (346,000 square feet) and office park (323,000) land uses ; therefore, the project is not expected to require a detailed operational emissions assessment nor result in significant operational emissions. REV: 07-13-16 RL Page 16 of 17 ATTY/AGR.2016. 184/Moore, lacofano, Goltsman Inc.