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35 The input data also considered project size, acreage, and land use (general office building, health club, and enclosed parking with elevator). In addition, CalEEMod analysis was conducted for the new recycled water line, and those results were included to incorporate water line construction emissions into the Commercial Component analysis (p. 20). Based on BAAQMD construction period thresholds of significance, the Illingworth & Rodkin (p. 20) determined that “the predicted average daily project construction emissions would not exceed the BAAQMD significance thresholds during any year of construction.” The analysis also included estimated emissions from operational activities and used CalEEMod to estimate emissions from proposed operations, assuming full build-out. The analysis (pp. 21-24) estimated the Commercial Component’s operation emissions using information provided by the applicant regarding vehicle trips for future employees (trip generation rates were provided by the Commercial Component’s transportation consultant Kimley-Horn, and conservative vehicle model years were used to reflect a more conservative emissions estimate); the diesel-powered emergency generator; the two component evaporative cooling towers; and evaporative emissions from architectural coatings and maintenance products (e.g., consumer products). Other inputs included emissions associated with solid waste generation, water use/wastewater generation, and existing uses (to take into account the existing emissions produced on the site). Illingworth & Rodkin (pp. 23-24) determined the daily emissions during Commercial Component operation of reactive organic gases (ROG), nitrogen oxides (NOX), and total particulate matter (PM10 with particles having a diameter of 10 micrometers or less and PM2.5 with particles having a diameter of 2.5 micrometers or less). Based on BAAQMD operational thresholds of significance, the analysis concluded, assuming year-round operations (e.g., 365 days of operation), “The operational period emissions would not exceed the BAAQMD significance thresholds.” Because the Commercial Component would not exceed the construction and operational criterial air pollutant significance thresholds established by BAAQMD, this component would result in less than significant impacts and emission reduction measures in Mitigation Measure AQ-2b would not be required. For the reasons above, the Commercial Component would not result in significant impacts that were not identified in the EIR/SEIR and no additional mitigation measures would be required. Therefore, this component would be consistent with the analysis within the EIR/SEIR because it would not create new impacts or increase impacts, and there is no new information of substantial importance for CEQA purposes. Potential for Cumulative Impacts Impacts associated with the two Project components were evaluated by Illingworth & Rodkin in a combined analysis of emissions for both the Commercial and the Housing Components (“901 El Camino Real & 920 Shasta Street Combined Construction & Operational Emissions;” Memo from Illingworth & Rodkin, Inc. to Melinda Hue, City of Redwood City; December 5, 2024). The memo assessed the combined construction and operational emissions of both Project components. Based on the anticipated construction schedule for 901 El Camino Real to start in 2025 and end in 2027 and 920 Shasta Street to start in 2026 and end in 2027, Illingworth & Rodkin (p. 1) concluded that the two construction schedules would overlap for the years 2026 and 2027, resulting in simultaneous construction emissions. Illingworth & Rodkin used CalEEMod to estimate emissions from construction activity and operation for each project. The land use types and size, anticipated construction schedule, traffic, and other factors were input to CalEEMod for each development component as described above for the Commercial Component and below for the Housing Component in item (b) – 920 Shasta Street. For construction emissions, Illingworth & Rodkin (pp. 1-2) determined that the combined construction period emissions do not exceed the BAAQMD thresholds of significance during any construction year (2025-2027). For operational emissions, Illingworth & Rodkin (p. 2) based its analysis on net increase in annual emissions and daily emissions, assuming 365 days of operation. The analysis determined that net increases in annual and daily operational emissions of ROG, NOX, total PM10, and total PM2.5 during operation of both components would not exceed the BAAQMD thresholds of significance. The combined construction and operational impacts of both Project components would be considered less than significant, resulting in a less than significant cumulative impact, and no additional mitigations would be required. As previously discussed, the SEIR determined significant and unavoidable impacts to air quality with mitigation. However, the Commercial Component, after implementation of Mitigation Measure AQ-2a, would be considered less than significant, and no additional mitigations would be required. Therefore, the Commercial Component would be consistent with the analysis within the EIR/SEIR because it would not create new impacts or increase impacts, and there is no new information of substantial importance for CEQA purposes. ATTY/RESO.0028/CC RESO CEQA GUIDLINES (920 SHASTA) - EXHIBIT A REV: 04-22-25 VR Page 35 of 148