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Red Morton Park Regional Stormwater Capture Project <br />Redwood City, CA <br />not include, or the proposed project activities would not have the potential to substantially affect and/or <br />exacerbate, the following resources: Aesthetics/Visual Resources, Agricultural and Forestry Resources, Energy, <br />Geology and Soils, Hazards and Hazardous Materials, Land Use/Planning, Mineral Resources, Population and <br />Housing, Public Services, Utilities and Service Systems, and Wildfire. In addition, the project is anticipated to <br />have a beneficial to hydrology and water quality resources from improved downstream water quality and ground <br />water recharge. <br />The following issues and CEQA-required considerations are expected to be discussed in greatest detail in the <br />Administrative Draft IS: <br />Air Quality and Greenhouse Gases (GHG): The air quality and GHG impacts of the proposed project would <br />be primarily generated during the construction of the project. The Consultant will prepare a clear and <br />concise air quality/GHG impact assessment that evaluates and quantifies the project's potential <br />impacts in accordance with the Bay Area Air Quality Management District's (BAAQMD) CEQA Air Quality <br />Guidelines, the City's General Plan, and the City's Climate Action Plan. The analysis will focus on the <br />amount of emissions of criteria air pollutants (e.g., particulate matter, or PM, and oxides of nitrogen, or <br />NOx) and toxic air contaminants (TAC) that would be generated by project construction and operation. <br />The Consultant will use the California Emissions Estimator Model (CalEEMod) to quantify project <br />emissions and compare project emissions levels against the latest CEQA significance thresholds <br />recommended for use by the BAAQMD. The team anticipates the project would need to incorporate best <br />management practices and/or mitigation measures to reduce project construction emissions, <br />particularly fugitive dust emissions, to less than significant levels. <br />The proposed project is likely to require a large amount of soil excavation and export, on-site heavy duty <br />diesel equipment use, on-site diesel truck idling, and off-site diesel truck trips in close proximity to <br />sensitive residential and other receptors. The Consultant, therefore, will conduct a construction health <br />risk assessment (HRA) for the project. The team will use the U.S. EPA -approved and BAAQMD- <br />recommended regulatory model (AERMOD) to predict exposure to concentrations of diesel PM, a TAC, <br />at sensitive receptor locations and quantify associated health risks. The constructional HRA will be <br />prepared in accordance with the guidance and recommendations provided by the BAAQMD and the <br />California Office of Environmental Health Hazard Assessment's (OEHHA) Air Toxics Hot Spots Program <br />Guidance Manual. The Consultant anticipates the use of late model construction equipment meeting <br />U.S. EPA Tier III or IV emissions standards will be necessary to demonstrate project construction <br />activities would not result in significant adverse health risks to student or residential receptors. <br />Biological Resources and Jurisdictional Waters: The IS will present a comprehensive biological resource <br />setting discussion, a summary of applicable regulations and permits required, and mitigation measures <br />included in the project to avoid any impacts to biological resources. Should the resource agencies <br />require a biological resources report and/or jurisdictional waters delineation, the biology section will <br />present this information. <br />Cultural /Tribal Cultural Resources: The Consultant Archaeologist will evaluate potential impacts to <br />cultural and tribal cultural resources consistent with CEQA Guidelines Section 15064.5. The project is <br />anticipated to involve excavation at depths of 10 feet or more below ground surface near Arroyo Ojo, <br />and creeks are generally known to be areas with a high potential to contain recorded and/or unrecorded <br />cultural and tribal resources that may be encountered or discovered during development activities. The <br />Consultant, therefore, will request a search of the California Historical Resource Information System <br />(CHRIS) and the Native American Heritage Commission (NAHC) Sacred Lands File (SLF) to determine if <br />there are known cultural/tribal cultural resources in or near Red Morton Park. In addition, as required <br />by CEQA, local tribes will be contacted as directed by the NAHC as an extension of the SLF search to <br />identify potential tribal cultural resources that may not be known by the NAHC due to their specific <br />importance to an individual tribe. Due to the anticipated depth of excavation, The Consultant will also <br />conduct a paleontological search with the Museum of Paleontology at UC Berkeley. MIG, a <br />subconsultant, anticipates that standard measures for the protection of recorded (i.e., known) and <br />unrecorded (i.e., unknown) resources, such as stop work provisions, will be incorporated into the project <br />as Best Management Practices or mitigation measures to render impacts on cultural/tribal cultural <br />resources a less than significant impact. <br />ATTY/AGR.2020.309/Craftwater Inc (Page 21 of 34) <br />