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37 than-significant impact, and health risk reduction measures in Mitigation Measure AQ-3a would not be required and additional mitigation measures would not be required. While tenants for the Commercial Component are unknown at this time, the project component may include an R&D/Laboratory use at a future date. When that permit application is submitted, then Mitigation Measure AQ-3b would be required for the R&D/Laboratory use (see DTPP Plan-Wide Amendments program SEIR p. 12-43), which would require a health risk screening analysis and a permit from BAAQMD for an R&D/Laboratory use among other conditions described in Mitigation Measures AQ-3b, which would reduce the operational health risk impacts related to future R&D for the Commercial Component to less than significant levels. Regarding SEIR Mitigation Measure AQ-3c, the Commercial Component applicant would be required to submit development design details indicating the loading facility/dock and project compliance with DTPP Plan-Wide Amendments program SEIR Mitigation Measure AQ-3c regarding incorporating health risk reduction measures into the development design and construction contracts as applicable to reduce potential health risk due to exposure from diesel truck toxic air contaminant emissions (SEIR p. 12-44) Potential for Cumulative Impacts Illingworth & Rodkin (pp. 32-38) evaluated cumulative health risks due to the Commercial Component’s location and proximity to existing permitted stationary TAC sources and existing sensitive receptors. Illingworth & Rodkin (pp. 33-35) identified existing health risks from nearby roadway and stationary sources, using BAAQMD geographic information systems screening maps, including Caltrain, four local roadways (El Camino Real, Broadway, Brewster Avenue, and James Avenue), and six existing stationary sources of TACs identified with the potential to affect the project MEI. According to BAAQMD Permitted Stationary Source 2021 GIS data, six existing sources were identified within a 1,000-foot radius of this component site, with four identified as being listed for having a diesel-powered emergency generator, one identified as a gas-dispensing facility, and one treated as a “generic case” for conservative risk screening because no data was available. Based on BAAQMD screening data estimates, the results of the Illingworth & Rodkin (pp. 37-38) analysis determined that cancer risk, maximum annual PM2.5 concentration, and HI would not exceed BAAQMD cumulative source thresholds. As previously discussed, the EIR found this impact to be less than significant, but the SEIR found it to be less than significant with mitigation. Implementation of DTPP Plan-Wide Amendments program SEIR Mitigation Measure AQ-3a would reduce the Commercial Component’s exposure of sensitive receptors to substantial pollutant concentrations to a less-than-significant level. 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. Onsite Health Risk Assessment for TAC Sources (related informational item) Although not required by CEQA, Illingworth & Rodkin also prepared an assessment of the impact that existing TAC sources would have on the “teen center/multi-purpose space” element of the proposed Commercial Component (sensitive receptors). Illingworth & Rodkin used the same TAC sources identified in the previous analysis. The results of this analysis (pp. 38-41) determined that cancer risk, maximum annual PM2.5 concentration, and HI would not exceed BAAQMD single-source or cumulative source thresholds at the teen center/multi-purpose space. d. The DTPP program EIR (p. 12-21) concluded that development facilitated by the DTPP could result in food service uses in close proximity or in the same building as other odor-sensitive uses, which would be reduced to a less than significant level with mitigation. Mitigation Measure 12-2 for projects with food service businesses requires implementation of odor-reducing measures consistent with the BAAQMD CEQA Air Quality Guidelines and DTPP regulation 2.2.2.1.e. These would include, for example, integral grease filtration or grease removal systems, baffle filters, activated carbon filters, oxidizing pellet beds, and exhaust stack and ventilation location with respect to receptors, subject to City review and approval. The DTPP Plan-Wide Amendments program SEIR (p. 12-44 through 12-45) generally concurred with the DTPP EIR conclusion but explained that Mitigation Measure 12-2 is no longer necessary because of the requirements of BAAQMD Rule 6-2 (Commercial Cooking Equipment). The DTPP Plan-Wide Amendments program SEIR concluded that projects would not be expected to generate odors adversely affecting a substantial number of people; the impact would be less than significant, and no mitigation measures would be required. It is not anticipated that the Commercial Component would include any food service uses. Any commercial cooking equipment for future food service uses would be required to meet the requirements of BAAQMD Rule 6-2 and no mitigation measures would be required. The Commercial Component would be consistent with the analysis of the ATTY/RESO.0031/CC RESO CEQA GUIDELINES (901 EL CAMINO REAL) REV: 04-22-25 VR Page 37 of 148