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AUGUSTIN BERNAL MOUNTAIN BIKE TRAIL PROJECT DRAFT INITIAL STUDY Regarding impacts from GHGs, the California Air Pollution Control Officers Association (CAPCOA) consider GHG impacts to be exclusively cumulative impacts (CAPCOA 2008);therefore, assessment of significance is based on a determination of whether the GHG emissions from a project represent a cumulatively considerable contribution to the global atmosphere.This analysis uses both a quantitative and a qualitative approach. The quantitative approach is used to address the first significance criterion listed above. The quantifiable thresholds developed by BAAQMD were formulated based on Assembly Bill (AB) 32 and California Climate Change Scoping Plan reduction targets; these strategies will reduce GHG emissions statewide. Thus, a project cannot exceed a numeric BAAQMD threshold without also conflicting with an applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions. Therefore, if a project exceeds a numeric threshold and results in a significant cumulative impact, it would also result in a significant cumulative impact with respect to consistency with a plan, policy, or regulation, even though the project may incorporate measures or have features that would reduce its contribution to cumulative GHG emissions. The BAAQMD has established the following three separate thresholds of significance for operational emissions from nonstationary sources: • Compliance with a Qualified Greenhouse Gas Reduction Strategy(i.e., if a project is found to be out of compliance with a Qualified Greenhouse Gas Reduction Strategy,its GHG emissions may be considered significant). • 1,100 MT CO2e per year(i.e., emissions above this level may be considered significant). • 4.6 MT CO2e per service population per year (i.e., emissions above this level may be considered significant).(Service population is the sum of residents plus employees expected for a development project.) This analysis uses the quantitative threshold of 1,100 MT CO2e annually. If the project GHG emissions would exceed this threshold, it would be considered to have a cumulatively considerable contribution of GHG emissions and a cumulatively significant impact on climate change. Impact Discussion a) Would the project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? Construction. Construction of the project would result in GHG emissions, primarily due to the use of off-road construction equipment,on-road vendor(material delivery)trucks,and worker vehicles. Since the BAAQMD has not established construction-phase GHG thresholds, construction GHG emissions were compared to the BAAQMD operational GHG threshold. Construction is expected to require approximately 3 months to complete and to generate a total of 63.88 MT CO2e,as shown in Table 3.8-1. A detailed depiction of the construction schedule - including information regarding equipment,trucks,and worker vehicles - is included in Appendix B. 12956 DUDEK 57 April 2022