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ARROYO LAGO RESIDENTIAL PROJECT <br />ADDENDUM <br /> <br /> <br />FCS 73 <br />Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/2148/21480036/Addendum/21480036 Arroyo Lago Residential Project Addendum.docx <br />Discussion <br />a) Air Quality Plan Conflict <br />Would the project: Conflict with or obstruct implementation of the applicable air quality <br />plan? <br />Prior FEIR Conclusions <br />The Prior FEIR determined that the project site is located within the San Francisco Bay Area Air Basin <br />(SFBAAB), which is regulated by the Bay Area Air Quality Management District (Bay Area Air District). <br />The 2017 Clean Air Plan includes control measures aimed at reducing regional air pollutants and <br />GHGs. Under the Bay Area Air District’s CEQA Air Quality Guidelines, a project’s consistency with the <br />Clean Air Plan is evaluated in part by determining its consistency with the regional significance <br />thresholds. Although the County Project’s construction emissions would be below these thresholds <br />and therefore would not result in substantial new regional emissions not already accounted for in <br />regional air quality planning, the Bay Area Air District also requires implementation of its <br />recommended Best Management Practices (BMPs) for construction dust as a qualitative criterion for <br />determining CEQA significance. <br />Importantly, the Bay Area Air District’s construction dust guidance is based not on the level of <br />modeled emissions, but on whether the project incorporates the recommended BMPs. Because <br />projects that do not implement dust-control BMPs are considered potentially significant regardless of <br />calculated reductions, the Prior FEIR required implementation of Mitigation Measure (MM) AIR-1 22 to <br />ensure consistency with Bay Area Air District guidance. <br />With MM AIR-1 incorporated, the County Project would implement the Bay Area Air District’s <br />recommended BMPs and therefore would not conflict with the control measures in the 2017 Clean Air <br />Plan. Alternative 2 would result in similar construction activities, and MM AIR-1 would also be required <br />to ensure consistency with the guidance. Therefore, the Prior FEIR concluded that neither the County <br />Project’s nor Alternative 2’s impacts would conflict with the applicable air quality plan, and impacts <br />would be less than significant with mitigation incorporated. (Draft EIR, pp. 3.2-44, 6-11, 6 -12). <br />Proposed Project Analysis and Conclusion <br />The Bay Area Air District is responsible for reducing emissions from area, stationary, and mobile <br />sources in the SFBAAB to achieve National and California Ambient Air Quality Standards (AAQS). <br />The Bay Area Air District 2017 Clean Air Plan is a regional and multiagency effort to reduce air <br />pollution in the Air Basin. A consistency determination with the 2017 Clean Air Plan plays an important <br />role in local agency project review by linking local planning and individual projects to the 2017 Clean <br />Air Plan. It fulfills the CEQA goal of informing decision-makers of the proposed project's <br />environmental effects under consideration early enough to ensure that air quality concerns are fully <br /> <br />22 Note: MM AIR-1 includes minor modifications to update the abbreviation for the Bay Area Air Quality Management <br />District, which has changed since the publication of the Prior FEIR. These edits reflect minor typographical corrections.