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CITY OF SAN LEANDRO <br />RE: Exhibit A -CONSISTENCY MEMORANDUM FOR THE SLTC MIXED-USE PROJECT (PLN16-0067) <br />JULY 17, 2017 <br />Page 20 <br /> <br />Environmental Protection Agency Conformity Determination Thresholds <br />The BAAQMD is responsible for preparing plans to attain ambient air quality standards in the San <br />Francisco Bay Area Air Basin. The BAAQMD prepares ozone attainment plans and clean air plans in order <br />to achieve national air pollutant standards under the Clean Air Act. These plans provides local guidance <br />for the State Implementation Plan (SIP), a framework for air quality basins to achieve attainment of <br />federal ambient air quality standards. As shown in Table 7, below, projected emissions resulting from <br />SLTC buildout fall below the EPA Conformity Determination thresholds. <br />Table 7 <br />Annual Construction and Operational Emissions (Metric Tons per Year) <br />Project ROG NOx Total <br />PM10 <br />Total <br />PM2.5 CO SO2 <br />Project Construction 1.4 3.2 0.4 0.2 3.0 0.0 <br />Project Operations 1.7 1.9 0.8 0.3 5.2 0.0 <br />Thresholds <br />EPA Conformity <br />Determination Thresholds <br />(40 CFR 93.153) <br />50 100 100 100 100 100 <br />Source: CalEEMod version 2016.3.1. See Appendix A for emission model outputs. <br />Note: ROG and NOx thresholds are based on the San Francisco Bay Area Air Basin’s “Marginal” <br />nonattainment status for ozone. The SO2, CO, and PM10 thresholds are for air basins classified as attainment <br />for those pollutants. The EPA only has one threshold for PM2.5, regardless of attainment status. <br /> <br />Cumulative Air Quality Impacts <br />According to the BAAQMD, if a project exceeds identified significance thresholds, the project would be <br />cumulatively considerable. As stated above, the total SLTC buildout under Scenario 3, identified in <br />Appendix C, would not exceed thresholds for air pollutant emissions during construction or operation. <br />The project would include only the residential land use and commercial space, a fraction of the total <br />estimated emissions. Therefore, the project would not be cumulatively considerable, as it would not <br />result in a violation of any air quality standard or contribute substantially to an existing or projected air <br />quality violation. <br />Furthermore, by its very nature, air pollution is largely a cumulative impact. According to the BAAQMD, <br />no single project is sufficient in size, by itself, to result in nonattainment of ambient air quality standards. <br />Instead, a project’s individual emissions contribute to existing cumulatively significant adverse air quality <br />impacts. The project would not exceed the buildout proposed in the TOD Strategy and analyzed in the <br />TOD Strategy EIR. The TOD Strategy EIR found that cumulative air quality impacts for TOD Strategy <br />buildout would be less than significant. No further analysis is needed, and the project would be consistent <br />with the City’s TOD Strategy EIR. <br />Greenhouse Gas Emissions <br />The project’s greenhouse gas (GHG) emissions would occur over the short construction duration, and <br />would consist primarily of emissions from equipment exhaust. There would also be long-term regional <br />166