2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
The
following
bullet
is
added
to
Mitigation
Measure
4.B-1
on
Draft
EIR
page
4.B-22:
Construction
foreman
and
crew
shall
receive
training
from
contractors
on
implementation
of
the
above
emission
reduction
techniques
prior
to
each
development
phase.
Consistency
of
Project
Site
development
with
the
Clean
Air
Act
is
addressed
in
Impact
4.B-9
of
the
Draft
EIR,
and
the
impact
related
to
this
criterion
was
found
to
be
significant
and
unavoidable.
As
discussed
in
Draft
EIR
Impacts
4.B-2
and
4.B-4,
Project
Site
development
would
result
in
significant
and
unavoidable
emissions
of
criteria
pollutants
during
both
construction
and
operations,
and
there
is
no
feasible
mitigation
to
reduce
or
avoid
this
impact.
Consequently,
applying
methodology
of
BAAQMD,
Project
Site
development
as
currently
proposed
would
not
support
the
primary
goals
of
the
Clean
Air
Plan.
Cumulative
air
quality
impacts
are
assessed
on
pages
6-17
through
6-20
of
the
Draft
EIR.
Emissions
from
the
landfill
(which
are
from
the
existing
landfill
gas
collection
system
that
would
be
replaced
or
renovated
during
Title
27
landfill
closure)
are
an
existing
source
that
would
be
replaced
or
renovated
as
the
remediation
component
of
Project
Site
development.
As
stated
on
page
4.G-79
of
the
Draft
EIR,
final
remedial
actions
implemented
at
the
former
landfill
ultimately
will
be
defined
by
the
RWQCB,
CalRecycle/San
Mateo
County
Department
of
Health
Services,
and
the
City
of
Brisbane
within
the
Final
Closure
and
Post-closure
Plans,
and
would
be
influenced
by
the
nature
of
the
proposed
development
within
and
adjacent
to
the
former
landfill.
These
Final
Closure
and
Post-closure
Plans
would
include
operation
and
maintenance
of
a
landfill
gas
collection
and
monitoring
system.
Operators
of
this
system
would
need
to
obtain
a
permit
from
the
BAAQMD.
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,
implementation
of
Project
Site
development
would
have
a
beneficial
impact
on
landfill
emissions
by
upgrading
the
existing
landfill
gas
collection
system
which
has
an
existing
excess
cancer
risk
of
54
in
one
million,
with
an
updated
system
that
would
have
an
excess
cancer
risk
of
10
in
one
million
or
less.
Comment
acknowledges
the
air
quality
conclusions
of
the
Draft
EIR,
and
does
not
raise
any
significant
environmental
issues.
The
Draft
EIR
recognizes
that
site
remediation,
a
pre-requisite
to
actual
development
within
the
Baylands,
would
Brisbane
Baylands
Final
EIR
2.9.8-3
May
2015