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40 vehicles per hour, no CO hotspots would result, and this impact would be less than significant; (2) Construction Emissions – because construction emissions associated with future development activities could exceed BAAQMD construction thresholds, including cancerogenic and non-cancerogenic thresholds, this impact is considered significant and unavoidable even with implementation of Mitigation Measure AIR-2 (“Require a Project- level Construction Assessment for New Discretionary Development Projects”); and (3) Exacerbation of Existing Sources of Pollutants – because changes in land use anticipated to occur with new development facilitated by the Focused GPU, including the proposed project component, “would occur primarily in areas focused for redevelopment” and would be characterized as “long-term emissions, primarily associated with area and mobile sources,” compliance with BAAQMD standards and implementation of Mitigation Measures AIR-2 would ensure that pollutant concentrations at sensitive receptor locations would not be substantial to exacerbate or contribute to significant health risks and this impact would be considered less than significant. With respect to development of the project component, the following effects would be anticipated: (1) CO Hotspots – as discussed in section XVII, Transportation, of this checklist, the project component would not increase traffic to a level that would exceed peak hour traffic in the city (e.g., the BAAQMD screening threshold of 44,000 vehicles per hour), and the project component impacts related to CO emissions (“CO hotspots”) would be less than significant; (2) Construction Emissions – as determined by the Focused GPU program EIR, future development activities could exceed BAAQMD construction thresholds and therefore would be required to implement Mitigation Measure AIR-2 (“Require a Project-level Construction Assessment for New Discretionary Development Projects”); see item “b” above for a discussion of the project component construction criteria air pollutant and toxic air contaminant emissions analysis, and see below for the Health Risk Analysis prepared for the project component; and (3) Exacerbation of Existing Sources of Pollutants – as discussed above, the changes in land use anticipated to occur with the Focused GPU “would occur primarily in areas focused for redevelopment” – such as the project component – and would be characterized as “long-term emissions, primarily associated with area and mobile sources.” Project component compliance with BAAQMD standards and implementation of Mitigation Measures AIR-2 (discussed above in item “b”) would ensure that pollutant concentrations at sensitive receptor locations would not be in substantial quantifies or concentrations to exacerbate or contribute to significant health risks and this project component impact would be considered less than significant. In accordance with Mitigation Measure AIR-2, a health risk analysis (HRA) was prepared for the proposed project component by Illingworth & Rodkin, Inc. (“847 Woodside Road Affordable Housing Project Air Quality & Greenhouse Gas Assessment;” Illingworth & Rodkin, Inc.; May 17, 2024). Illingworth & Rodkin used CalEEMod to estimate toxic air contaminants (TAC) sources during construction (onsite construction and truck hauling emissions, and dust) and operation (mobile and stationary sources). The health risk analysis was based on BAAQMD methodologies and utilized the AERMOD dispersion model. Thresholds of significance were based on regional standards adopted by BAAQMD. Based on the analysis, Illingworth & Rodkin (pp. 19-31) determined that “The project’s unmitigated construction maximum cancer risk exceed[s] the BAAQMD single-source threshold. …The annual PM2.5 concentration and HI, unmitigated and mitigated, do not exceed the single-source or cumulative-source thresholds.” Because one of these health risk categories exceeds its respective thresholds of significance, emission reduction measures in Focused GPU program EIR Mitigation Measure AIR-2 would be required as discussed in Impact AIR-3 (Focused GPU EIR p. 4-3.25), which states (Focused GPU EIR, pp. 4.3-21 and 4.3-22) that “if emissions are shown to be above BAAQMD thresholds, the City shall require the imposition and implementation of mitigation measures to reduce emissions below the thresholds that have been exceeded.” Mitigation Measure AIR-2 includes a sample list of possible measures to reduce emissions that “could include, but are not limited to,” selection of specific construction equipment, use of U.S. EPA Tier IV equipment, and minimizing idling time of diesel-powered construction equipment. Illingworth & Rodkin (p. 30) determined that the project component would need to “Implement a feasible plan to reduce diesel particulate matter emissions by 60 percent such that increased cancer risk from construction would be reduced below TAC significance levels as follows: 1. All diesel-powered construction equipment larger than 25 horsepower used at the site for more than two continuous days or 20 hours total shall meet U.S. EPA Tier 4 emission standards for PM (PM10 and PM2.5), if feasible, otherwise, a. If use of Tier 4 equipment is not available, alternatively use equipment that meets U.S. EPA emission standards for Tier 3 engines and include particulate matter emissions control equivalent to CARB Level 3 ATTY/RESO.0074/CC RESO 847 WOODSIDE (CEQA) - EXHIBIT 1 - CEQA CONSISTENCY CHECKLIST REV: 10-23-24 VR Page 40 of 135