2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
The
first
bullet
on
page
4.B-41
of
the
Draft
EIR
identifies
requiring
use
of
electrically
powered
landscape
equipment
through
CC&Rs
as
an
element
of
Mitigation
Measure
4.B-4.
The
nine-year
exposure
duration
for
school
children
is
recommended
by
BAAQMD
in
its
Air
Toxics
NSR
Program
Health
Risk
Screening
Analysis
(HRSA)
Guidelines
.
3
The
presumption
is
that
school
attendance
at
a
single
geographical
location
is
split
between
(1)
elementary
(Kindergarten
through
6
th
grade)
and
(2)
middle
and
high
school
(7
th
grade
through
12
th
grade)
with
two
to
three
years
of
additional
buffer
as
a
conservative
assumption.
The
analysis
in
the
Draft
EIR
assumes
that
there
would
be
no
increase
in
passenger
rail
operations.
As
a
practical
matter,
Caltrain
is
currently
scheduled
to
be
transferred
from
diesel
to
electrical
power
starting
in
2021.
Consequently,
the
risks
presented
in
the
Draft
EIR
are
conservative
because,
depending
on
occupation
of
proposed
residences
under
the
DSP
and
DSP-V
development
scenarios,
exposure
duration
to
diesel
particulate
matter
would
likely
be
less
than
5
years
and
not
the
70
years
assumed
in
the
health
risk
assessment.
Once
Caltrain
is
fully
electrified,
there
will
no
longer
be
TAC
exposure
associated
with
its
operations.
[See
page
for
the
original
comment]
The
main
goals
of
the
2010
Bay
Area
Clean
Air
Plan
(CAP),
the
current
air
quality
plan
to
date,
are
to:
Attain
air
quality
standards;
Reduce
population
exposure
and
protecting
public
health
in
the
Bay
Area;
and
Reduce
greenhouse
gas
emissions
and
protect
the
climate
Alternative
energy
generation
would
satisfy
these
goals.
However,
all
four
of
the
development
scenarios
would
result
in
significant
and
unavoidable
operational
air
quality
impacts
for
non-attainment
pollutants
and
precursors.
Thresholds
applied
in
the
assessment
of
significance
in
the
Draft
EIR
were
derived
by
BAAQMD
based
on
federal
and
state
stationary
source
limitation
levels
for
non-
attainment
pollutants
and
precursors
and
represent
cumulatively
considerable
contributions
to
air
quality.
Consequently,
all
four
Project
Site
development
scenarios
would
not
support
the
primary
goal
of
the
2010
CAP
to
attain
air
quality
standards.
3
BAAQMD,
2010.
BAAQMD
Air
Toxics
NSR
Program
Health
Risk
Screening
Analysis
(HRSA)
Guidelines
.
January
2011.
(http://www.baaqmd.gov/~/media/Files/Engineering/Air%20Toxics%20Programs/hrsa_guidelines.ashx)
Brisbane
Baylands
Final
EIR
2.9.3-35
May
2015