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34 AQ-2a and AQ-2b. See item (c) below for project implementation of SEIR Mitigation Measures AQ-3a, AQ-3b, and AQ-3c. The Commercial Component is in compliance with all applicable DTPP standards relevant to air quality and transportation, and as a result, no additional air quality impacts related to an applicable air quality plan or standard are anticipated. Because the proposed Commercial component would have a less than significant impact for the reasons stated above, it would be consistent with the analysis of the EIR/SEIR because it would not create new impacts or increase impacts, and there is no new information of substantial importance than identified within the EIR/SEIR for CEQA purposes. b. The Downtown Precise Plan program EIR (p. 12-18) found that the projected rate of increase in vehicle trips under the DTPP would be less than the rate of increase in population (in accordance with the BAAQMD CEQA Air Quality Guidelines at the time) and therefore, the regional air quality impacts from criteria pollutant and ozone precursor emissions associated with the DTPP were found to be less than significant and no mitigation measures were required. The DTPP Plan-Wide Amendments program SEIR (pp. 12-32 through 12-40) included a plan-level analysis and project-level analysis of criteria air pollutant emissions resulting from the DTPP Plan-Wide amendments in accordance with the 2017 BAAQMD CEQA Air Quality Guidelines. The SEIR determined that because the rate of increase in VMT would be less than the rate of service population growth, the proposed DTPP Plan-Wide Amendments would result in a less-than-significant impact with respect to regional criteria air pollutants at a plan- level. The SEIR assumed that at a project level, the Plan-Wide DTPP Amendments would indirectly result in development of new residential and office uses which would involve demolition and removal of existing structures, excavation, site preparation, and construction of new buildings and associated utilities. The SEIR conservatively determined that construction and operational emissions from resulting development from the Plan-Wide DTPP Amendments could lead to potentially significant impacts related to fugitive dust and criteria air pollutants. To address these potentially significant impacts, the SEIR included the following mitigation measures: Mitigation Measure AQ- 2a (“Best Management Practices for Construction Dust Suppression”) and Mitigation Measure AQ-2b (“Emission Reduction Measures for Projects Exceeding the Significance Thresholds for Criteria Pollutants”), to ensure implementation of best management practices consistent with BAAQMD recommendations. Mitigation Measure AQ- 2a, which applies to all projects, requires use of best management practices to reduce fugitive dust emissions during construction, consistent with BAAQMD recommendations, and has been determined by the DTPP Plan-Wide Amendments program SEIR to reduce construction period fugitive dust emissions to less-than-significant levels with mitigation. Mitigation Measure AQ-2b requires projects that exceed BAAQMD screening levels prepare a project- level criteria air pollutant assessment of construction and operational emissions at the time the project is proposed. If the analysis finds that the project could result in criteria air pollutant emissions that exceed BAAQMD significance thresholds, the project would be required to implement emission reduction measures specified in the SEIR mitigation measure related to clean construction equipment, operational emission reductions, and, if warranted, possible emission offset fees. The SEIR determined that the specific emissions associated with future projects were unknown at the time, and therefore the effectiveness of emission reduction measures could not be definitively determined, so criteria air pollutants from construction and operation of subsequent projects developed under the proposed DTPP Plan-Wide Amendments were found to result in a new and more severe impact than the impact identified in the DTPP EIR. This impact was conservatively found to be significant and unavoidable with mitigation The Commercial Component is subject to Mitigation Measure AQ-2a regarding construction dust. With the implementation of Mitigation Measure AQ-2a, the 901 El Camino Real project component would result in a less than significant impact with respect to construction/fugitive dust. In accordance with Mitigation Measure AQ-2b, an air quality analysis for the proposed Commercial Component was prepared by Illingworth & Rodkin, Inc. (“901 El Camino Real Air Quality Assessment, Redwood City, California;” Illingworth & Rodkin, Inc.; March 18, 2024, revised December 5, 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 associated with construction and operation of the project were predicted using appropriate computer models.” The air quality assessment was prepared following BAAQMD’s 2022 CEQA Guidelines. Illingworth & Rodkin used CalEEMod to estimate emissions from on-site construction activity and construction vehicle trips. The analysis estimated the Commercial Component’s emissions using information provided by the applicant on construction activity, construction schedule, vehicle trips (including worker and vendor trips, haul trips for demolition, soil import/export, and materials delivery), and evaporative emissions such as architectural coatings. ATTY/RESO.0031/CC RESO CEQA GUIDELINES (901 EL CAMINO REAL) REV: 04-22-25 VR Page 34 of 148