Agmt21 Environmental Science Associates

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Proposed Work Program June 2021 City of Redwood City / Gatekeeper Projects Subsequent EIR 15 environmental science associates Ai r Quality The DTPP Final EIR identified potentially significant but mitigable air quality impacts under the DTPP associated with sensitive receptors’ exposure to toxic air contaminants (TACs) during operation (mitigated by implementation of General Plan policies and programs related to filtration, and for preparation of health risk analyses for applicable projects), and odors (mitigated by implementation of odor reduction measures). The SEIR Setting section will update any pertinent changes to the DTPP Final EIR related to regulatory background, analysis approach, and significance thresholds. ESA will address air quality impacts associated with changes to the DTPP as a result of the Gatekeeper Projects. The Bay Area Air Quality Management District (BAAQMD) updated its 2010 CEQA Guidelines (referenced in the 2010 DTPP Final EIR) in 2017. The significance criteria for evaluating impacts from plans has not changed in the 2017 update, and includes the following:  Consistency with the current air quality plan, and  Comparison of project vehicles miles traveled (VMT) growth to project population growth. ESA will use VMT values provided by the transportation analysis conducted in support of the SEIR to evaluate VMT growth compared to population growth. In addition, policies and control measures from the BAAQMD’s most recent, 2017 Bay Area Clean Air Plan (“Spare the Air and Cool the Climate”) will be compared to those included in the proposed projects for evaluation of consistency. Impacts will be discussed qualitatively in comparison to these above significance criteria. Mitigation measures included in the DTPP Final EIR will be evaluated and updated as necessary, based on potential changes to impacts from the Gatekeeper projects. In addition, ESA will include a qualitative analysis of criteria pollutant emissions and health risks from toxic air contaminants (TACs), given that Individual development projects in the DTPP area under the Gatekeeper projects could potentially exceed one or more of BAAQMD’s project-specific criteria pollutant significance thresholds. ESA’s qualitative analyses will reach significance conclusions requiring mitigation, and propose mitigation in order to facilitate tiering of future projects without the need for a supplemental or subsequent project-specific EIR. Consistent with Bay Area Air Quality Management District (BAAQMD) guidance at the time, the DTPP Final EIR analyzed health risk impacts related to exposure of new sensitive receptors (residential uses, schools, child care and the like) to existing levels of air pollutants—the so-called effects of the environment on a project. This approach is inconsistent with the California Supreme Court’s 2015 ruling in California Building Industry Association (CBIA) v. Bay Area Air Quality Management District, which held that CEQA, with certain exceptions, is concerned with the impacts of a project on the environment, not whether the existing environment may adversely affect a new project. Consequently, the health risk analysis in the SEIR will focus on whether the Gatekeeper projects may exacerbate existing effects of exposure to TACs. ESA will prepare a quantitative health risk assessment of construction and operational impacts from one representative future project. The purpose of this analysis is to create screening criteria for when a future development project, especially the smaller projects, might be well below the BAAQMD health risk significance thresholds, and could therefore avoid further analysis and/or mitigation. This is similar to what the BAAQMD already has developed for criteria pollutants (such as square feet of construction, cubic yards of excavation, and proximity to sensitive receptors). Subsequent development projects in the DTPP area could use these screening REV: 06-23-21 MI ATTY/AGR.2021.150/Environmental Sciences Associates (Gatekeeper Projects) (Page 25 of 58)