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41 Based on the anticipated construction schedule for 901 El Camino Real to start in 2025 and end in 2027 and 920 Shasta Street to start in 2026 and end in 2027, Illingworth & Rodkin (p. 1) concluded that the two construction schedules would overlap for the years 2026 and 2027, resulting in simultaneous construction emissions. Illingworth & Rodkin used CalEEMod to estimate emissions from construction activity and operation for each project. The land use types and size, anticipated construction schedule, traffic, etc., were input to CalEEMod for each Project component as described above for the 920 Shasta Street and earlier in item (b) – 901 El Camino Real for the 901 El Camino Real Commercial Component. For construction emissions, Illingworth & Rodkin (pp. 1-2) determined that the combined construction period emissions do not exceed the BAAQMD thresholds of significance during any construction year (2025-2027). For operational emissions, Illingworth & Rodkin (p. 2) based its analysis on net increase in annual emissions and daily emissions, assuming 365 days of operation. The analysis determined that net increases in annual and daily operational emissions of ROG, NOX, total PM10, and total PM2.5 during operation of both Project components would not exceed the BAAQMD thresholds of significance. The combined construction and operational impacts of both Project components would be considered less than significant resulting in a less than significant cumulative impact, and no additional mitigations would be required. As noted above, the Focused GPU EIR found this impact to be significant and unavoidable with mitigation. However, as discussed previously, the Housing Component’s implementation of the Focused GPU program EIR Mitigation Measure AIR-2 requires incorporation of mitigation measures if emissions levels are shown in a project-specific air quality analysis to be above BAAQMD-recommended thresholds of significance; this impact would be less than significant because the project-specific air quality analysis concluded that the Housing Component air emissions would not exceed BAAQMD-recommended thresholds of significance. . 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. c. The Focused GPU program EIR (pp. 4.3-5, 4.3-7 and 4.3-8, 4.3-22 through 4.3-25) concluded that growth facilitated by the Focused GPU would result in exposure of existing and new sensitive receptors to substantial concentrations of criteria air pollutants and toxic air contaminant (TAC) emissions that could pose adverse health effects. According to the Focused GPU program EIR, the pollutants and pollutant concentrations posting substantial threats to health and property in the Bay Area Basin that were evaluated included: (1) carbon monoxide (CO) “hotspots” (known as areas of high CO concentrations such as areas where vehicular traffic exceeded the level for peak hour intersection traffic volumes), meaning that the potential CO concentrations could exceed State and/or Federal ambient air quality standards for CO; (2) construction emissions, which include particulate matter (PM10 and PM2.5) and especially diesel particulate matter (DPM), which is smaller than PM2.5 and typically comes from construction equipment exhaust; and (3) existing pollutant sources that are exacerbated by additional emissions generated as a result of new development (including such pollutants and sources as localized areas of DPM concentrations; emissions of TACs from stationary sources such as dry cleaning facilities, which emit perchloroethylene; and other pollutants such as mobile sources of benzene and 1,3-Butadiene and formaldehyde from a variety of sources). The Focused GPU program EIR also discussed the potential for operational emissions from future development facilitated by the Focused GPU to pose adverse health risks to sensitive receptors but determined that changes in the land use pattern of the city from development facilitated by the Focused GPU would “not reimagine the City in a manner that would substantially increase the quantity of highly polluting land uses (e.g., industrial facilities). Therefore, the changes in land use proposed by the Project [e.g., the Focused GPU] do not have the potential to alter the City-wide emissions profile in a manner that could exacerbate or contribute to significant health risks at or in proximity of the Planning Area” as discussed above in item (b) (Focused GPU program EIR, p. 4.3-23). The Focused GPU program EIR determined that: (1) CO Hotspots – because peak hour traffic in the city would not exceed the BAAQMD screening threshold of 44,000 vehicles per hour, no CO hotspots would result, and this impact would be less than significant; (2) Construction Emissions – because construction emissions associated with future development activities could exceed BAAQMD construction thresholds, including cancerogenic and non-cancerogenic thresholds, this impact is considered significant and unavoidable even with implementation of Mitigation Measure AIR-2 (“Require a Project- level Construction Assessment for New Discretionary Development Projects”); and (3) Exacerbation of Existing Sources of Pollutants – because changes in land use anticipated to occur with new development facilitated by the Focused GPU, including the proposed project component, “would occur primarily in areas focused for redevelopment” and would be characterized as “long-term emissions, primarily associated with area ATTY/RESO.0031/CC RESO CEQA GUIDELINES (901 EL CAMINO REAL) REV: 04-22-25 VR Page 41 of 148