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42 and mobile sources,” compliance with BAAQMD standards and implementation of Mitigation Measures AIR-2 would ensure that pollutant concentrations at sensitive receptor locations would not be substantial to exacerbate or contribute to significant health risks and this impact would be considered less than significant. With respect to development of the Housing Component, the following effects would be anticipated: (1) CO Hotspots – as discussed in section XVII, Transportation, of this Checklist, the Housing Component would not increase traffic to a level that would exceed peak hour traffic in the city (e.g., the BAAQMD screening threshold of 44,000 vehicles per hour), and this component’s impacts related to CO emissions (“CO hotspots”) would be less than significant; (2) Construction Emissions – as determined by the Focused GPU program EIR, future development activities could exceed BAAQMD construction thresholds and therefore would be required to implement Mitigation Measure AIR-2 (“Require a Project-level Construction Assessment for New Discretionary Development Projects”); see item “b” above for a discussion of the project component construction criteria air pollutant and toxic air contaminant emissions analysis, and see below for the Health Risk Analysis prepared for the project component; and (3) Exacerbation of Existing Sources of Pollutants – as discussed above, the changes in land use anticipated to occur with the Focused GPU “would occur primarily in areas focused for redevelopment” – such as the project component – and would be characterized as “long-term emissions, primarily associated with area and mobile sources.” Housing Component compliance with BAAQMD standards and implementation of Mitigation Measures AIR-2 (discussed above in item “b”) would ensure that pollutant concentrations at sensitive receptor locations would not be in substantial quantifies or concentrations to exacerbate or contribute to significant health risks and this Component’s impact would be considered less than significant. In accordance with Mitigation Measure AIR-2, a health risk analysis (HRA) was prepared for the proposed Housing Component 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). Illingworth & Rodkin used CalEEMod to estimate emissions from off-road construction equipment and exhaust emissions from on- road vehicles. The health risk analysis was based on BAAQMD methodologies and utilized the AERMOD dispersion model. Thresholds of significance were based on regional standards adopted by BAAQMD. Based on the analysis, Illingworth & Rodkin (pp. 15-27) determined that “The project’s unmitigated construction maximum cancer risk and annual PM2.5 concentration exceed the BAAQMD single-source thresholds. …The HI [Hazard Index], unmitigated and mitigated, do not exceed the single-source or cumulative-source thresholds.” Because two of these health risk categories exceed their respective thresholds of significance, the second part of Focused GPU program EIR Mitigation Measure AIR-3 would be required. Mitigation Measure AIR-3 (Focused GPU EIR p. 4-3.25) requires implementation of Mitigation Measure AIR-2 (Focused GPU EIR, pp. 4.3-21 and 4.3-22), stating that “if emissions are shown to be above BAAQMD thresholds, the City shall require the imposition and implementation of mitigation measures to reduce emissions below the thresholds that have been exceeded.” Mitigation Measure AIR-2 includes a sample list of possible measures to reduce emissions that “could include, but are not limited to,” selection of specific construction equipment, use of U.S. EPA Tier IV equipment, and minimizing idling time of diesel-powered construction equipment. Illingworth & Rodkin (p. 27) determined that the Housing Component would need to “Implement a feasible plan to reduce diesel particulate matter emissions by 70 percent such that increased cancer risk from construction would be reduced below TAC significance levels as follows: 1. All diesel-powered construction equipment larger than 25 horsepower used at the site for more than two continuous days or 20 hours total shall meet U.S. EPA Tier 4 emission standards for PM (PM10 and PM2.5), if feasible, otherwise, a. If use of Tier 4 equipment is not available, use alternative equipment that meets U.S. EPA emission standards for Tier 4 interim standards that altogether achieve a 70 percent reduction in particulate matter exhaust in comparison to uncontrolled equipment; alternatively (or in combination). b. Installation of electric power lines during early construction phases to use electric generators and welders. 2. Alternatively, the applicant may develop another construction operations plan demonstrating that the construction equipment used on-site would achieve a reduction in construction diesel particulate matter emissions by 70 percent or greater. Elements of the plan could include a combination of some of the following measures:  Implementation of No. 1 above to use Tier 4 or alternatively fueled equipment, ATTY/RESO.0031/CC RESO CEQA GUIDELINES (901 EL CAMINO REAL) REV: 04-22-25 VR Page 42 of 148