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May 6, 2021 <br />Page 9 <br /> <br /> <br />5005-003acp <br /> <br /> printed on recycled paper <br />Project that was not analyzed in the General Plan EIR which stated “the projects <br />and measures cannot be known” at the time of drafting.36 <br /> <br />Further, SWAPE determined that the Checklist’s calculation regarding off- <br />road vehicles is not supported by substantial evidence.37 SWAPE also determined <br />that the Checklist underestimated the Project’s mobile source operational <br />emissions. The Project’s mobile-source emissions may constitute a new and <br />potentially significant impact in the Project, that was not addressed or mitigated in <br />the prior EIR. <br /> <br />Additionally, the Project’s impacts from gas fireplaces may be a new specific <br />effect because the 2035 General Plan EIR did not analyze or substantially mitigate <br />the potentially significant impacts from gas fireplaces. SWAPE determined that the <br />Checklist failed to provide substantial evidence to support the gas fireplace <br />calculations in the Checklist.38 SWAPE also found that the unsubstantiated <br />reductions to the default Title 24 electricity energy intensity and Title 24 natural <br />gas intensity values, may cause the Checklist to underestimate the Project’s energy- <br />source operational emissions.39 This constitutes a new and significant impact that <br />was not analyzed or mitigated in the prior EIR. The Checklist also underestimates <br />indoor and outdoor water use rates, which cause the Checklist to underestimate the <br />Project’s water related operational emissions. This represents a new and <br />potentially significant impact that must be adequately address in an EIR. <br /> <br />An Infill EIR is required to remedy these significant construction and <br />operational emission analysis deficiencies, in order to adequately mitigate such <br />issues prior to Project approval. <br /> <br />b. Health Risk <br /> <br />The Cancer Risk for this Project exceeds allowable thresholds. The Project’s <br />unmitigated construction health risk assessment indicates that the Project would <br />pose an excess cancer risk of 54.7 in one million to people living nearby.40 This <br />health risk exceeds the BAAQMD significance threshold of 10 in one million, and <br /> <br />36 General Plan EIR, p. 3-4. <br />37 SWAPE Comments, p. 7. <br />38 Id. at p. 8. <br />39 SWAPE Comments, p. 9-10. <br />40 Checklist p. 4-17, Table 4-3. <br />99