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40 thresholds during any year of construction….”8 However, Illingworth & Rodkin (p. 10-13) noted that “[General Plan] Program PS-2 requires projects to implement feasible air emission reduction measures….” Illingworth & Rodkin (pp. 12-13) concluded that standard dust control Best Management Practices (BMPs), which are identified in the 2022 BAAQMD CEQA Guidelines, would be necessary to ensure that temporary construction dust effects associated with grading and new construction would be less than significant. The following BMPs are typically implemented by construction projects throughout the Bay Area under the guidance of BAAQMD: 1. All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times per day. 2. All haul trucks transporting soil, sand, or other loose material off-site shall be covered. 3. All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited. 4. All vehicle speeds on unpaved roads shall be limited to 15 miles per hour (mph). 5. All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used. 6. All excavation, grading, and/or demolition activities shall be suspended when average wind speeds exceed 20 mph. 7. All trucks and equipment, including their tires, shall be washed off prior to leaving the site. 8. Unpaved roads providing access to sites located 100 feet or further from a paved road shall be treated with a 6- to 12-inch layer of compacted layer of wood chips, mulch, or gravel. 9. Publicly visible signs shall be posted with the telephone number and name of the person to contact at the lead agency regarding dust complaints. This person shall respond and take corrective action within 48 hours. The Air District’s General Air Pollution Complaints number shall also be visible to ensure compliance with applicable regulations. The analysis also included estimated emissions from operational activities and used CalEEMod to estimate emissions from proposed operations, assuming full build-out. The Illingworth & Rodkin analysis (pp. 13-15) estimated Housing Component operation emissions primarily from autos driven by future residents but also included evaporative emissions from architectural coatings and maintenance products (e.g., consumer products), which are typical ROG emission sources from these types of land uses. Project component vehicle trips for future residents was based on data provided by the Housing Component transportation consultant Hexagon Transportation Consultants, Inc., and conservative vehicle model years were used to reflect a more conservative emissions estimate. Other inputs included emissions associated with solid waste generation, water use/wastewater generation, and existing uses (to take into account for the existing emissions produced on the site). Illingworth & Rodkin (p. 15) determined that “unmitigated net average daily operational emissions of ROG, NOX, total PM10, and total PM2.5 during operation of the project….would not exceed the BAAQMD significance thresholds…” This would be a less-than-significant impact. With Housing Component implementation of the standard BAAQMD-recommended dust control measures identified in the air quality analysis prepared as required by Focused GPU program EIR Mitigation Measure AIR-2 (above), construction and operational criteria air pollutant and toxic air contaminant emissions impacts would be less than significant. Potential for Cumulative Impacts As discussed above in Item III(b) – 901 El Camino Real Commercial Component, cumulative 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. 8 As explained by Illingworth & Rodkin (p. 1), ROG, NOX, PM10 exhaust, and PM2.5 exhaust are reactive organic gases (ROG), nitrogen oxides (NOX), respirable particulate matter (PM10), and fine particulate matter (PM2.5). ATTY/RESO.0028/CC RESO CEQA GUIDLINES (920 SHASTA) - EXHIBIT A REV: 04-22-25 VR Page 40 of 148