2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
both
construction
and
operation
of
the
four
proposed
development
scenarios
in
Draft
EIR
Tables
4.B-5
and
4.B-13,
respectively.
These
estimates
include
emissions
from
natural
gas
combustion
from
all
land
uses
for
the
purposes
of
space
heating.
Project
Site
development
would
not
result
in
appreciable
increased
air
transportation
or
increased
landfill
off-gassing
at
the
Baylands
Project
Site
(although
GHG
emissions
from
increased
solid
waste
generation
at
off-site
disposal
locations
are
considered
in
the
GHG
section).
Impact
4.G-2
of
Section
4.G,
Hazards
and
Hazardous
Materials,
in
the
Draft
EIR
identified
significant
hazard
impacts
with
regard
to
landfill
off-gassing
and
identified
mitigation
measures
to
reduce
this
impact
to
a
less
than
significant
level.
An
assessment
of
cumulative
air
quality
hazard
and
exposure
impacts
is
presented
on
page
6-19
of
the
Draft
EIR,
which
indicates
that
cumulative
cancer
risks
from
stationary,
roadway
and
rail
sources
would
be
less
than
the
BAAQMD
cumulative
thresholds.
The
cancer
risk
estimates
provided
in
Table
4.B-3
of
the
Draft
EIR
are
BAAQMD
estimates
at
the
property
line
of
the
facility.
For
diesel
generators
or
other
internal
combustion
sources
these
risks
may
be
scaled
down
at
receptor
locations
based
on
distance
from
the
property
line
using
the
BAAQMD’s
diesel
multiplier
tool,
which
is
what
was
done
to
estimate
the
risks
on
proposed
residential
uses
as
shown
in
Tables
4.B-20
and
6-3
of
the
Draft
EIR.
These
risk
calculations
are
based
on
upper
end
permit
values.
Compliance
with
BAAQMD
permit
conditions
is
assumed.
If
an
operator
added
equipment
or
increased
throughput
a
permit
revision
would
be
required,
necessitating
a
re-calculation
of
risk.
The
quoted
text
in
the
comment
is
an
opinion
of
the
California
Air
Resources
Board
(CARB,
2005)
in
reference
to
general
recommendations
for
setbacks
of
sensitive
land
uses
from
railways
and
high
volume
roadways.
These
general
recommendations
do
not
take
into
account
site-specific
conditions
or
direction
of
prevailing
winds.
The
Draft
EIR
assesses
site-
and
scenario-specific
risk
levels
on
proposed
receptors
including
residents
and
school
children
in
Tables
4.B-15
through
4.B-18
of
the
Draft
EIR
for
each
Project
Site
development
scenario.
The
results
of
the
cumulative
analysis
of
all
stationary
and
transportation
sources
are
presented
in
Table
6-3
of
the
Draft
EIR.
Scenario-specific
and
cumulative
cancer
risk
and
hazard
impacts
from
these
sources
were
found
to
be
less
than
significant
using
BAAQMD
recommended
methodologies.
This
comment
does
not
provide
documentation
for
the
assertion
that
area
winds
are
blowing
contaminated
soils
over
the
Baylands
as
part
of
the
site’s
existing
setting.
However,
site
remediation
and
landfill
closure
pursuant
to
the
regulatory
authority
of
the
RWQCB
and
DTSC
would
preclude
any
such
possibility.
Brisbane
Baylands
Final
EIR
2.9.1-8
May
2015