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May 6, 2021 <br />Page 17 <br /> <br /> <br />5005-003acp <br /> <br /> printed on recycled paper <br />According to SWAPE, the air quality impacts from construction would be <br />significant. SWAPE determined that off-road construction equipment usage <br />constitutes an impact more significant than was analyzed in the General Plan EIR <br />or the Checklist.73 <br /> <br />These impacts are not adequately mitigated through the Uniformly <br />Applicable Development Policies in the General Plan and are not sufficiently <br />mitigated in the Checklist. <br /> <br />ii. Health risk <br /> <br />The CUP for this Project cannot be approved at this time because the Project <br />is not consistent with the General Plan and our experts have determined the Project <br />may have significant detrimental effects to public health. The Zoning Code states <br />that a Use Permit can only be approved by the Board of Zoning Adjustments if the <br />Board determines that the Project will not be detrimental to the public health, <br />safety or welfare of persons residing, or working in, or adjacent to, the neighborhood <br />of such use; and will not be detrimental to properties or improvements in the <br />vicinity, or to the general welfare of the City.74 <br /> <br />Our air quality and health risk experts at SWAPE determined that the <br />Project will cause an excess cancer risk of approximately 124.9 in one million over <br />the course of a residential lifetime (30 years).75 Additionally, SWAPE’s screening- <br />level Health Risk Analysis indicates a potentially significant impact. Therefore, the <br />City should prepare an Infill EIR to adequately analyze and mitigate health risk <br />impacts. <br /> <br />General Plan Action EH-3.4.B requires a Health Risk Assessment for projects <br />near freeways and high-volume roadways, as here. But the health risk analysis in <br />the Checklist fails to satisfy General Plan requirements. Additionally, SWAPE <br />determined that without making a reasonable effort to connect the Project’s <br />operational TAC emissions to the potential health risks posed to nearby receptors, <br />the Project is inconsistent with CEQA’s requirement to correlate the increase in <br />TAC emissions with potential adverse impacts on human health.76 SWAPE <br /> <br />73 SWAPE Comments p. 6. <br />74 San Leandro Zoning Code § 5.08.124(A)(2). <br />75 SWAPE Comments, p. 18. <br />76 SWAPE Comments p. 17. <br />107