2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
sources,
are
similar
within
each
geographical
region
of
the
Bay
Area.
That
is,
cities
within
each
of
the
major
valleys
of
the
Bay
Area
tend
to
have
similar
air
quality
levels.
Consequently,
a
few
sites
can
characterize
an
area
4
.
Winds
passing
through
the
Alemany
Gap
result
in
more
frequent
winds
and
higher
wind
speeds
than
at
the
Arkansas
Street
Monitoring
Station.
Consequently,
because
wind
disperses
pollution,
the
existing
pollution
summary
provided
in
Table
4.B-1
on
Page
4.B-4
of
the
Draft
EIR
likely
overestimates
the
pollution
concentrations
that
exist
at
the
Baylands
Project
site.
Air
dispersion
modeling
conducted
to
the
standards
of
OEHHA
Guidance
requires
a
5-year
collection
of
specific
data
sets
that
include
not
only
hourly
surface
data
such
as
wind
speed
and
direction
but
also
temperature,
dew
point,
cloud
cover,
cloud
layers,
ceiling
height,
visibility,
current
weather,
and
precipitation
as
well
as
upper
air
data.
Such
data
sets
are
limited
in
geographic
availability,
and
for
the
Baylands
site
area
consist
of
Mission
Bay
in
San
Francisco
(surface
data
only)
and
the
San
Francisco
Airport.
Such
data
sets
are
not
available
for
San
Bruno
Mountain,
the
elevation
of
which
would
result
in
much
greater
wind
speeds
and
dispersion
than
occurs
at
the
Brisbane
Baylands.
Consequently,
data
from
San
Francisco
Airport
less
than
five
miles
to
the
south
and
at
a
similar
elevation
as
the
Baylands
site
is
the
best
available
meteorological
data
for
analysis
and
the
most
reflective
of
the
Baylands
Project
Site
because
proximity
and
similar
elevation
both
contribute
to
best
characterizing
the
meteorological
dispersion
conditions.
This
comment
combines
a
consideration
of
criteria
pollutant
emissions
and
hazards,
which
are
distinctly
different.
Criteria
pollutants
have
been
identified
though
the
federal
Clean
Air
Act
and
the
US
Environmental
Protection
Agency
has
promulgated
and
regularly
revises
National
ambient
air
quality
standards
(NAAQS).
These
ambient
air
quality
standards
are
intended
to
protect
the
public
health
and
welfare,
and
they
specify
the
concentration
of
pollutants
to
which
the
public
can
be
exposed
without
adverse
health
effects.
By
contrast,
hazards
from
toxic
air
contaminants
(TACs)
are
different
in
that
TACs
do
not
have
ambient
air
quality
standards,
but
are
regulated
by
BAAQMD
using
a
risk-based
approach.
This
approach
uses
a
health
risk
assessment
to
determine
what
sources
and
pollutants
to
control
as
well
as
the
degree
of
control.
A
health
risk
assessment
is
an
analysis
in
which
human
health
exposure
to
toxic
substances
is
estimated
and
considered
together
with
information
regarding
the
toxic
potency
of
the
substances,
to
provide
quantitative
estimates
of
health
risks.
With
respect
to
criteria
pollutant
emissions
and
ozone,
the
Draft
EIR
analysis
includes
an
estimate
of
ozone
precursor
emissions
that
would
be
generated
by
4
BAAQMD,
2013
Air
Monitoring
Network
Plan,
July
1,
2014
Available
online
at
http://www.baaqmd.gov/~/media/
Files/Technical%20Services/2013_Network_Plan.ashx?la=en
Brisbane
Baylands
Final
EIR
2.9.1-7
May
2015