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May 6, 2021 <br />Page 12 <br /> <br /> <br />5005-003acp <br /> <br /> printed on recycled paper <br />construction-related health risk would not be substantially mitigated by the <br />Uniformly Applicable Development Policies because the Checklist applied Tier 4 <br />Interim emissions reductions in its health risk modeling which is not required by <br />the City’s Standard Conditions of Approval. Thus, the Project’s health risk remains <br />significant and unmitigated. <br /> <br />Since SWAPE’s screening-level HRA indicates a potentially significant <br />impact, the City should prepare an Infill EIR with an HRA which makes a <br />reasonable effort to connect the Project’s air quality emissions and the potential <br />health risks posed to nearby receptors. Thus, the City should prepare an updated, <br />quantified air pollution model as well as an updated, quantified refined HRA which <br />adequately and accurately evaluates health risk impacts associated with both <br />Project construction and operation.49 <br /> <br />c. Emergency Generator <br /> <br />This Project may include an emergency generator. The California Building <br />Code requires that “[w]here two or more elevators are controlled by a common <br />operating system, all elevators shall automatically transfer to standby power within <br />60 seconds after failure of normal power where the standby power source is of <br />sufficient capacity to operate all elevators at the same time.”50 <br /> <br /> The Air Quality Appendix references an Emergency Generator,51 but provides <br />no analysis thereon. The Checklist only references generator sets required for <br />building construction.52 The Checklist and the General Plan EIR fail to analyze the <br />potentially significant impact of a diesel-powered emergency generator. <br /> <br />Diesel-powered generators emit diesel particulate matter (“DPM”) a TAC. <br />The Checklist concluded that the impact of TACs on sensitive receptors would be <br />less than significant after mitigation. But without analysis of the impacts from the <br />diesel-powered generator, this statement is not supported by substantial evidence. <br /> <br />The Checklist states that the Project’s impacts in exposing sensitive receptors <br />to substantial pollutant concentrations would be less than significant with <br /> <br />49 Id. <br />50 California Building Code 2016 § 3003.1.3. <br />51 Checklist, Appendix A, p. 183. <br />52 Id. at 63 <br />102