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<br />Sequoia Ecological Consulting, Inc. <br />CalVTP Project-Specific Analysis and Addendum <br />Augustin Bernal Community Park Fuel Reduction <br />November 2025 <br />4-11 <br /> <br /> <br />4.3.1. Discussion <br />4.3.1.1. Impact AQ-1 <br />The use of vehicles, mechanical equipment, prescribed herbivory, herbicides, and prescribed burning <br />during initial and maintenance treatments would result in emissions of criteria pollutants that could <br />exceed CAAQS or NAAQS thresholds for the San Francisco Bay Area Air Basin. The potential for emissions <br />of criteria pollutants to exceed CAAQS or NAAQS thresholds was examined in the PEIR and was found to <br />be potentially significant because treatment activities could generate pollutants—such as particulate <br />matter, ozone precursors, or nitrogen oxides—in quantities that might surpass regulatory limits, especially <br />in areas already designated as nonattainment for one or more pollutants. Emissions of criteria air <br />pollutants related to the proposed treatment are within the scope of the PEIR because the associated <br />equipment and duration of use are consistent with those analyzed in the PEIR. <br />The SPRs applicable to this treatment project are AD-1, AD-4, AQ-1 through AQ-4, and AQ-6, which require <br />public notification for prescribed burning; compliance with applicable BAAD air quality requirements; <br />submittal of an SMP and Burn Plan if the prescribed burning triggers the threshold (17 CCR Section 80160); <br />minimizing dust; and following all safety procedures required of a CAL FIRE crew. SPR AQ-5 would not <br />apply because no NOA, ultramafic rock outcrops, or former asbestos mines are mapped in or near the <br />treatment area (USGS 2011, 2017). Additionally, the City would implement the emission reduction <br />techniques included in MM AQ-1 to the extent feasible. However, because the treatments would be <br />implemented by a public agency with limited funding, procuring or paying additional amounts for <br />contractors that use equipment meeting the latest efficiency standards, including meeting USEPA’s Tier 4 <br />emission standards, using renewable diesel fuel, using electric- and gasoline-powered equipment, and <br />using equipment with Best Available Control Technology may be cost-prohibitive. Carpooling would be <br />encouraged by the City, but because crews may not all be employed with the same company, carpooling <br />may not be feasible to implement for most of the workers. The City would document the extent the agency <br />and/or its contractors are able to implement MM AQ -1. Renewable diesel would be used by the City and/or <br />its contractors to the extent required by state regulations. For these reasons, and as explained in the PEIR, <br />this impact would remain significant and unavoidable. In addition to the CalVTP PEIR SPRs and MMs, <br />additional project-specific measures are described below each applicable measure. <br />• MM AQ-1: Implement On-Road Vehicle and Off-Road Equipment Exhaust Emission Reduction <br />Techniques <br />The City would document the extent that it and/or its contractors are able to implement MM AQ-1 by <br />documenting each unit’s certified engine tier specification and applicable CARB fleet regulation <br />compliance certificates prior to mobilization. This information would be compiled in an annual monitoring