AgdaPkt 2019-02-11 Joint SA PFA - Laserfiche WebLink

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Response to Draft Environmental Impact Report Harbor View Development Project, Redwood City CA February 7, 2019 Page 6 of 7 near heavily traveled highways and rail lines with diesel locomotive operations emissions from vehicles traveling on Highway 101, on-site generators at the City Police Station and Maple Street Correctional Center, and dust and particulates emissions associated with operation of the Graniterock facility. California Air Resources Board (CARE) guidance recommends a minimum buffer of 500 feet from the edge of freeways to sensitive receptors." "The proposed soccer fields would likely be developed approximately 480 feet north of the Highway 101 and 300 feet east of the existing railroad spur to Graniterock; the three-story Parking Structure A is proposed between where the railroad spur and where the soccer fields might occur. Given these distances compared to the recommended minimum buffer of 500 feet from the edge of freeways to sensitive receptors, the TAC exposure impact with this alternative is considered potentially significant, although a health risk screening analysis was not conducted not required for this alternatives assessment. New mitigation measures would be identified that could require Preparation of a HRA to show if the health risk exceeds acceptable levels, or the Project would otherwise incorporate appropriate measures into the Project design to reduce the potential health risk due to exposure to TACs would be required with this alternative.." Path Forward concurs with ESA that the use of an adult soccer field constitutes a recreational use and thereby, a sensitive use. The proposed outdoor soccer field (and outdoor play area for day care centers) would not meet the DEIR mitigation recommendations. We further note that it would be infeasible to mitigate exposure of particulate matter from highway 101 and the upgradient Graniterock facility. Furthermore, the referenced PM2.5 concentration of 206 ug/m3 at the upgradient Graniterock would result in an air quality index (AQI) of 256 (Very Unhealthy) according to the Air Now (EPA) Calculator (EPA 2019). AQI values between 201 and 300 trigger a health alert, meaning sensitive populations may experience more serious health effects. The Graniterock facility is located less than 100 feet from the proposed location of the adult soccer field. The referenced concentrations of PM2.5 at the upgradient Graniterock facility are more than an order of magnitude above the annual CARB standard of 12 gg/m3 threshold. In addition, the 24- hour average Federal EPA standard of 35 pg/m3 is exceeded. Furthermore, CARB (2015) states: "A data analysis from CARB's Children's Health Study shows health effects in children, as well. This study showed that in communities highly polluted with PM, children's lungs developed more slowly and did not move air as efficiently as children's lungs in clean air communities. Children and infants are susceptible to harm from inhaling pollutants such as PM because they inhale more air per pound of body weight than do adults - they breathe faster, spend more time outdoors and have smaller body sizes. In addition, children's immature immune systems may cause them to be more susceptible to PM Project No.: 102-102-100 PATH ORWARD