Agmt21 Environmental Science Associates Transit District

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Proposed Work Program June 2021 City of Redwood City / Transit District Subsequent EIR 14 Environmental science associates REV: 06-22-21 MI 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 Transit District 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 criteria as a basis to conclude that the project would not create a significant health risk impact. ESA will collaborate with City staff to develop an appropriate project(s) for this analysis. Climate Change (Greenhouse Gas Emissions, Energy and Sea Level Rise) Greenhouse Gas Emissions. The DTPP Final EIR determined greenhouse gas emission impacts under the DTPP would be less than significant. The DTPP Final EIR used the BAAQMD’s project-level GHG emission efficiency metric threshold of 4.6 metric tons of CO2e per service population (future residents and full-time workers) per year to determine GHG impacts. However, this threshold only covers development through the year 2020 because it was based on the State’s 2020 target codified in Assembly Bill (AB) 32.1 To incorporate Senate Bill (SB) 32’s 2030 target into City-level planning, the City adopted its Climate Action Plan (CAP) in November 2020. The CAP focuses on reducing community-wide GHG emissions from activities within the City based on its General Plan 2030 land use forecasts and sets a target of a 50 percent reduction below 2005 levels by 2030, which is generally consistent with AB 32. The CAP also sets a long-term target of achieving carbon neutrality before 2045, which is consistent with the EO S-3-05 target of 80 percent below 1990 emission levels by 2050. CEQA Guidelines §15064(h)(3) provides that a lead agency may evaluate GHG emission impacts in the context of applicable programs and/or other regulatory schemes to reduce GHG emissions. The programmatic analysis of GHG emissions can therefore be based in part on consistency with the CAP’s GHG reduction strategies and actions as they apply to new development. However, because the CAP is based on the City’s General Plan 2030 land use forecasts and associated General Plan Final EIR, and the Transit District may exceed the General Plan’s citywide land use forecasts and require General Plan amendments, it is unlikely that the Transit District are 1 The BAAQMD has not adopted thresholds beyond 2020; the most relevant legislative standard establishing a GHG reduction target beyond 2020 is Senate Bill (SB) 32, which requires a reduction of 40 percent in statewide GHG emissions from 1990 levels by 2030. ATTY/AGR.2021.149/ESA (Transit District CEQA) (Page 24 of 26)