2.
Response
to
Comments
2.10
Individual
Responses
to
Comments
from
Individuals
2.10.14
Alissa
Perrucci
Watering
of
exposed
surfaces
has
been
demonstrated
as
an
effective
method
of
mitigating
construction-related
particulate
emissions
and
is
a
recommended
measure
of
the
BAAQMD.
The
CalEEMod
emissions
estimator
model
of
the
California
Air
Pollution
Control
Officers
Association
estimates
that
twice
daily
watering
of
construction
sites
results
in
as
much
as
a
55
percent
reduction
in
particulate
matter.
This
reduction
estimate
is
also
consistent
with
estimates
of
the
U.S.
EPA.
Watering
of
exposed
surfaces
does
not
affect
the
presence
of
chemicals
in
the
dust;
it
is
protective
of
human
health
and
air
quality
because
the
water
molecules
cause
the
dust
particles
to
cohere
and
thus
reduce
the
amount
of
dust
lifted
into
the
air
by
wind,
compared
with
unwetted
conditions.
Implementation
of
the
stormwater
pollution
prevention
plan
and
compliance
with
additional
site
specific
NPDES
permit
requirements
for
dewatering
activities,
as
required
in
Draft
EIR
Mitigation
Measures
4.H-1a
and
4.H-1b
(Draft
EIR
page
4.H-22),
would
reduce
the
water
quality
impacts
of
Project
Site
development
to
less
than
significant
levels.
Draft
EIR
Impact
4.B-5
assesses
the
impact
of
Project
Site
development
on
the
environment
from
toxic
air
contaminants
(TACs)
at
a
programmatic-level.
At
the
programmatic-level
there
would
be
very
few
new
sources
of
toxic
air
contaminants
generated
by
Project
Site
development
under
any
of
the
four
development
scenarios.
Largely
these
would
consist
of
the
relatively
small
percentage
of
new
vehicle
trip
operations
that
would
operate
on
diesel
fuel
(approximately
8
percent
as
specified
in
CalEEMod),
largely
commercial
delivery
trucks.
While
some
future
uses
within
the
Baylands
may
require
back-up
diesel
generators
that
can
produce
TACs,
the
size
and
number
of
such
uses
are
not
and
cannot
be
known
at
this
time.
Thus,
project-level
CEQA
analysis
for
subsequent
site-specific
development
within
the
Baylands
would
address
the
specific
environmental
effects
of
such
uses
should
they
actually
be
proposed.
Consistent
with
the
requirements
of
its
Policy
and
Procedure
Manual,
the
BAAQMD
would
deny
an
Authority
to
Construct
or
a
Permit
to
Operate
for
any
new
or
modified
source
of
TACs
that
exceeds
a
cancer
risk
of
10
in
one
million
or
a
chronic
or
acute
hazard
index
of
1.0.
Consequently,
future
uses
that
would
create
significant
impacts
would
not
be
approved
by
the
BAAQMD.
Impact
4.B-5
identifies
a
less
than
significant
impact
based
on
modeling
of
mobile
emissions
and
assessment
of
health
risks
conducted
in
accordance
with
technical
guidelines
developed
by
federal,
state,
and
regional
agencies,
including
US
Environmental
Protection
Agency
(USEPA),
California
Environmental
Protection
Agency
(CalEPA),
California
Office
of
Environmental
Health
Hazard
Assessment
Brisbane
Baylands
Final
EIR
2.10.14-1
May
2015