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May 6, 2021 <br />Page 8 <br /> <br /> <br />5005-003acp <br /> <br /> printed on recycled paper <br />A. The Project Will Result in New Specific Effects, Including Air <br />Quality, Health Risk, Hazardous Materials, Noise, and Traffic <br />Impacts <br /> <br /> The Project will result in new significant environmental impacts from air <br />quality, health risk, hazardous materials, noise, and traffic. <br /> <br />i. Air Quality Impacts <br /> <br />Air quality impacts constitute a new specific effect for this Project. CEQA <br />provides that a new specific effect may result if the prior EIR stated that sufficient <br />site-specific information was not available to analyze the significance of that <br />effect.31 The Checklist states that “[s]ite-specific impacts on a project site were not <br />evaluated in Section 4.2, Air Quality, in the prior 2035 General Plan EIR.”32 <br />Further, the General Plan EIR states that “[A]dditional measures to reduce criteria <br />air pollutant emissions would be considered during individual project-level review <br />based on site-specific and project-specific characteristics to reduce significant <br />impacts as applicable. Because those projects and measures cannot be known at this <br />time, the impact is considered significant and unavoidable.”33 The air quality <br />impacts on this Project site are new specific significant impacts because the prior <br />EIR specifically stated that there was not sufficient information to analyze project- <br />specific impacts “because those projects and measures cannot be known” at the time <br />of drafting.34 New specific effects from air quality are derived from numerous <br />sources: a) construction and operational emissions; b) emergency generator; and c) <br />traffic. <br /> <br />a. Construction and Operational Emissions <br /> <br />Air Quality expert SWAPE determined that the Project’s construction and <br />operational emissions were not consistent with information disclosed in the <br />Checklist. “As a result, [SWAPE] found the Project’s construction and operational <br />emissions are underestimated.”35 This constitutes a new specific effect for this <br /> <br />31 CEQA Guidelines § 15183.3(d)(1)(C). <br />32 Checklist p. 4-19. <br />33 General Plan EIR, p. 3-4. <br />34 Id. <br />35 SWAPE Comments p. 4. <br />98