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Page 3 PUD-105 and P14-0852 July 9, 2019 JDEDZ The technical memorandum also discusses health effects of criteria pollutants along with the JDEDZ's potential cumulative health-related impacts consistent with the California Supreme Court's ruling in Sierra Club v. County of Fresno(2018)6 Ca1.5th 502. Consistent with the HRA,this analysis uses the updated and conservative assumptions about the timing of construction and the scope of project-related activity within the JDEDZ project area. For near-term activities, such as the first phase of construction, realistic assumptions are made based on the anticipated construction activity and phasing of development. For longer-term activities that may occur beyond the first phase of development, such as the development of commercial and retail space during phase 2,more conservative assumptions were made in order to provide a worst-case analysis of potential JDEDZ impact, because the actual construction activity and phasing of this development is currently unknown. These assumptions are provided in greater detail in Chapter 1 of the technical memorandum. For construction,this analysis shows the Project's criteria pollutant emissions are below the corresponding BAAQMD significance thresholds except for NOx emissions from Phase 1 construction. Phase 1 construction NOx emissions are estimated to be an average of 55.74 pounds per day(lbs./day), exceeding the significance threshold of 54 lbs./day. Therefore, mitigation is required to reduce JDEDZ impacts during Phase 1 construction. As such,all off-road equipment greater than 50 horsepower would be required to have engines that meet United States Environmental Protection Agency(USEPA)Tier 3 off-road emission standards. Implementation of this mitigation measure would reduce this impact to a less-than-significant level. For operations, Phase 1 operational activities are estimated to be an average of 54.60 pounds of ROG per day (lbs./day), exceeding the significance threshold of 54 lbs./day.Therefore, mitigation is required to reduce JDEDZ impacts during Phase 1 operations. As such,the JDEDZ would require all future tenants and building owners to use low-volatile organic compound(VOC)paints during maintenance activities.The VOC content of paints shall not exceed 10 grams of VOCs per liter.Implementation of this mitigation measure would reduce this impact to a less-than-significant level. Because of certain updated JDEDZ project details used in this analysis as compared to those used in the Draft SEIR(e.g. changes in square footage of some proposed land uses, construction phasing and equipment fleets), the conclusions with regard to the JDEDZ's criteria pollutants emissions have changed with this updated analysis. For example, conclusions about construction emissions changed from less than significant for all criteria pollutants in the Draft SEIR to less than significant with mitigation in this updated analysis(due to average daily unmitigated emissions during Phase 1 construction exceeding the BAAQMD threshold);the conclusions about project operational emissions have changed from significant and unavoidable impacts (attributable to average daily and total annual NOx and PM10 emissions)during full buildout operations in the Draft SEIR to less than significant for all operational scenarios including the full buildout operations. Greenhouse Gas Analysis Following the original approval of the project and certification of the JDEDZ SEIR,the California Office of Planning and Research adopted amendments to the CEQA Guidelines, including changes to CEQA Guidelines section 15064.4 addressing analysis of GHG emissions. Further, Senate Bill 32(2016)set a statewide GHG emissions reduction target of 40 percent below 1990 levels by 2030. The amendments became effective on December 28, 2018. The City's adopted Climate Action Plan(CAP)is only considered qualified through 2020 for purposes of GHG analysis under CEQA, but project buildout is expected to occur beyond 2020. In COMMUNITY DEVELOPMENT— P. O. BOX 520, Pleasanton, CA 94566-0802 Planning Building&Safety Engineering Traffic Inspection 200 Old Bernal Ave. 200 Old Bernal Ave. 200 Old Bernal Ave. 200 Old Bernal Ave. 157 Main St. (925)931-5600 (925)931-5300 (925)931-5650 (925)931-5650 (925)931-5680 Fax: 931-5483 Fax: 931-5478 Fax: 931-5479 Fax: 931-5479 Fax: 931-5484