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36 c. The DTPP program EIR (p. 12-20) analyzed the impact of existing sources of TAC emissions in Redwood City on future receptors that would be introduced to the area by the DTPP. It was found to be potentially significant and included Mitigation Measure 12-1 to reduce impacts to less than significant. However, as the DTPP Plan-Wide Amendments program SEIR states, CEQA no longer requires the analysis of the impact of the environment on the project pursuant to the California Supreme Court decision in California Building Industry Association v. Bay Area Air Quality Management District (CBIA) that ruled that impacts of existing environmental conditions on a project are not subject to review under CEQA, with some limited exceptions. Therefore, this impact was not analyzed in the SEIR. The DTPP program EIR did not analyze exposure of existing sensitive receptors to TAC emissions generated by construction and operation of future projects in the amended DTPP area. The SEIR did include such analysis in accordance with the 2017 BAAQMD CEQA Guidelines. According to the SEIR, subsequent projects developed under the proposed DTPP Plan-Wide Amendments would generate TACs, primarily DPM, during construction and operation. In regards to construction, the SEIR determined that given specific characteristics of each subsequent project under the proposed DTPP Plan-Wide Amendments and the required construction equipment information are not known, it was not possible to quantify construction-related health risks from exposure to TAC emissions from all projects in the DTPP Plan-Wide Amendments and depending on the characteristics of specific projects, projects could result in potentially significant construction health risk impacts. To address the construction health risk impacts, the SEIR included Mitigation Measure AQ-3a (“Emission Reduction Measures for Subsequent Projects Exceeding the Significance Thresholds for Health Risks from Construction”). Mitigation Measure AQ-3a requires projects within 1,000 feet of existing or approved sensitive receptor(s) to prepare a construction level health risk analysis, and if determined to result in significant construction health risks, the project would be required to implement the clean construction equipment measures included in SEIR Mitigation Measure AQ-2b. This would reduce construction health risk impacts to less than significant with mitigation. The SEIR stated that operational sources of health risk in the amended DTPP area could potentially include emergency generators, fire pumps, and standby power systems but given that these would require a permit from BAAQMD, operational health risks would be less than significant. The SEIR stated that additionally, diesel trucks serving the potential new R&D laboratories and the new office space could generate increased diesel emissions and R&D Laboratory uses could also emit TACs depending on the nature and chemical makeup of the procedures undertaken. The SEIR determined that in the absence of project-specific details, operational impacts related to R&D and loading would be potentially significant. The SEIR included Mitigation Measure AQ-3b which requires a health risk screening analysis and a permit from BAAQMD for an R&D/Laboratory use, which “may be required either prior to or as a condition of approval of the proposed individual project” (DTPP Plan-Wide Amendments program SEIR p. 12-43) and Mitigation Measure AQ-3c which requires all projects that include off-street loading facilities for diesel trucks (e.g., loading docks) to submit the designs of the loading facility to the City for review and approval, which could result in requiring health risk reduction measures to be incorporated into the project component design as deemed applicable by the City. These mitigation measures would reduce impacts related to operational health risks to less than significant with mitigation. In accordance with SEIR Mitigation Measure AQ-3a, a health risk analysis was prepared for the proposed Commercial Component by Illingworth & Rodkin, Inc. (“901 El Camino Real Air Quality Assessment, Redwood City, California;” Illingworth & Rodkin, Inc.; revised December 5, 2024). The analysis looked at both operational (see discussion below for health risk as it pertains to R&D) and construction health risks of the Commercial Component, including the new recycled water line. Illingworth & Rodkin used CalEEMod to estimate emissions from off-road construction equipment and exhaust emissions from on-road vehicles. 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 (p. 37) determined that for “both the project and cumulative health risk impacts at the sensitive receptors most affected by the project (i.e., the MEI 7)…[t]he project would not have an exceedance with respect to health risk caused by project construction and operational activities since none of the risk values exceed their respective BAAQMD single-source threshold.” More specifically, the health risk analysis concluded that maximum cancer risks did not exceed the BAAQMD single source significance threshold of 10 in one million, the BAAQMD maximum annual PM2.5 significance threshold of 0.3 μg/m3, and the BAAQMD single-source annual HI (“hazard index”) significance threshold of 1.0. Because none of these health risk categories exceeds their respective thresholds of significance, this would be a less- 7The MEI is the maximally exposed individual, identified as the sensitive receptor most impacted by the project’s construction and operation (Illingworth & Rodkin, p. 25). ATTY/RESO.0028/CC RESO CEQA GUIDLINES (920 SHASTA) - EXHIBIT A REV: 04-22-25 VR Page 36 of 148