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23 <br /> <br />conclusion that further environmental review is not required. For example, the project is <br />expected to add fewer than five vehicles per hour to the northbound left-turn <br />movements on El Camino Real at Jefferson Avenue and at James Avenue, and not to <br />trip any thresholds of significance related to turning queues. (For additional information, <br />see Hexagon’s March 15, 2017 letter.) The evidence thus includes studies of turn-lane <br />queues and “spillback.” <br /> <br />3. The Project Will Not Create Air Quality Impacts <br /> <br />Appellant’s Contention: The project would cause carbon monoxide (CO) thresholds to <br />be exceeded at busy intersections and expose sensitive receptors to substantial <br />pollution concentration given current and proposed levels of congestion on El Camino <br />Real and long queue lines. (Appeal, pp. 7-8, 16-17) <br /> <br />City Response: As stated in the Initial Study: “The Downtown Precise Plan program <br />EIR identified carbon monoxide (CO) as the pollutant of greatest concern in the Bay <br />Area region. CO levels in the Bay Area are well below ambient air quality standards, <br />and there have been no exceedances of CO standards in the Bay Area since 1991. <br />However, localized high concentrations of CO can occur near busy congested <br />intersections. According to the BAAQMD screening methodology, DTPP buildout would <br />not cause traffic volumes at affected intersections to exceed CO thresholds, and the <br />impact of development resulting from the DTPP would be less than significant; <br />therefore, no mitigations were required. (EIR p. 12-18) The proposed project is in <br />compliance with all applicable DTPP standards, and as a result, no additional criteria air <br />pollutant impacts are anticipated.” <br /> <br />Further, the applicant’s expert has prepared a report that addresses these issues and <br />confirms that the project will not have any impacts regarding toxic air contaminants. <br />(See Illingworth & Rodkin’s March 15, 2017 Letter, attached.) <br /> <br />4. The Project Will Not Create Population and Housing Impacts that <br />Require a New or Supplemental EIR <br /> <br />Appellant’s Contention: The project will bring in high-income earners and displace <br />current low-income residents by driving up rents, and existing businesses will likewise <br />be displaced, thus resulting in gentrification and “urban decay,” neither of which was <br />anticipated at the time of DTPP EIR certification. (Appeal, pp. 18-20.) <br /> <br />City Response: First, as an overarching matter, the issue is not the type of <br />development, but whether the development will lead to environmental impacts. <br />Economic and social changes resulting from a project are generally not treated as <br />significant effects on the environment. Neither is community character considered an <br />environmental impact covered by CEQA. While CEQA requires the analysis of physical <br />impacts that result from social impacts, the courts have undertaken such analyses for <br />commercial “big box” retail developments (and not residential projects) under the theory <br />that such large projects could undermine existing businesses and thereby result in <br />8.A. - Page 23