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39 of Mitigation Measures AIR-2 discussed below, would ensure that impacts related to conflicts with the air quality control plan would be less than significant. As noted above, the Focused GPU EIR found the impacts related to conflicts with the applicable air quality plan to be significant and unavoidable. Because the project component would not conflict with or obstruct the Clean Air Plan, the Housing Component, with implementation of Mitigation Measures AIR-2 discussed below, would ensure that impacts related to conflicts with the air quality control plan would be less than significant. Therefore, the Housing Component would be consistent with the analysis of the Focused GPU EIR because it would not create new impacts or increase impacts and there is no new information of substantial importance for CEQA purposes. b. According to the Focused GPU program EIR (p. 4.3-18 through 4.3-22), growth facilitated by the Focused GPU would result in long-term regional emissions of criteria air pollutants from operation of area sources, energy sources, and mobile sources. The Focused GPU program EIR concluded that criteria air pollutant and other air emissions resulting from construction activities and operation from future development facilitated by the Focused GPU would generate short-term construction and long-term operational emissions of regulated air pollutants (i.e., criteria air pollutants and TACs). If the emissions from an individual project exceed the BAAQMD CEQA significance thresholds, then this impact would be cumulatively considerable and significant. With regard to operational emissions of criteria air pollutants, the Focused GPU program EIR determined that based on the net change in long-term operational emissions generated by future development facilitated by the Focused GPU, there would be an increase in overall emissions but the emissions per capita would be reduced and would not have a significant impact. With respect to construction emissions of criteria air pollutants, the Focused GPU program EIR concluded that because it is not possible to accurately assess the level of emissions from any individual future project until the project details are known (i.e., submittal of a project application), analysis of future project construction activities would be speculative. However, the Focused GPU program EIR determined that despite these unknowns, future individual projects facilitated by the Focused GPU could have the potential to exceed one or more of the BAAQMD’s construction criteria air pollutant thresholds of significance, including: (1) fugitive dust (PM10 and PM2.5) emissions during building demolition, site preparation, and grading activities; (2) NOX emissions from diesel-fuels powered heavy-duty construction equipment (“NOX” is the collective term used for referring to nitrogen dioxide [NO2] and nitric oxide [NO]), both of which contribute to ozone formation; and (3) ROG emissions from architectural coating (“ROG” or reactive organic gases include any compounds of carbon with certain exceptions), which also contribute to ozone formation. Exceeding the BAAQMD standards for these pollutants would result in a potentially significant impact requiring mitigation. Focused GPU program EIR Mitigation Measure AIR-2 (“Require a Project-level Construction Assessment for New Discretionary Development Projects”) requires project-level analysis of construction criteria air pollutant and toxic air contaminant emissions analysis compared against the BAAQMD thresholds of significance, with mitigation measures recommended as necessary to reduce emissions below the BAAQMD thresholds. However, because it could not be definitively known or stated at the time that all future development projects occurring under the Focused GPU would be able to reduce potential criteria air pollutant emissions to levels that are below BAAQMD thresholds, criteria air pollutant emission generated during construction activities were considered significant and unavoidable even with the incorporation of feasible mitigation measures. An air quality analysis for the proposed Housing Component was prepared by Illingworth & Rodkin, Inc. (“920 Shasta Street Affordable Housing Project Air Quality Assessment & Greenhouse Gas Assessment, Redwood City, California;” Illingworth & Rodkin, Inc.; April 12, 2024). As discussed in the Illingworth & Rodkin analysis (p. 1), “Air quality impacts would be associated with demolition of the existing land uses, construction of the new building and infrastructure, and operation of the project. Air pollutant emissions were estimated using appropriate computer models. In addition, the potential health risks associated with construction and operation of the project and the impact of existing toxic air contaminant (TAC) sources affecting the nearby and proposed sensitive receptors were evaluated.” The air quality assessment was prepared following BAAQMD’s CEQA Guidelines. Illingworth & Rodkin used CalEEMod to estimate emissions from construction that are based on the project type, size, and acreage. Housing Component land use types and size, and anticipated construction schedule, were also included in the CalEEMod model run. Based on BAAQMD construction period thresholds of significance, Illingworth & Rodkin (p. 12) determined that “the unmitigated annualized average daily construction emissions of ROG, NOX, PM10 exhaust, and PM2.5 exhaust during construction of the project … would not exceed the BAAQMD significance ATTY/RESO.0028/CC RESO CEQA GUIDLINES (920 SHASTA) - EXHIBIT A REV: 04-22-25 VR Page 39 of 148