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ARROYO LAGO RESIDENTIAL PROJECT <br /> ADDENDUM <br /> <br /> <br />76 FCS <br />Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/2148/21480036/Addendum/21480036 Arroyo Lago Residential Project Addendum.docx <br />However, limiting construction to five days per week introduces non-operational periods, reducing the <br />frequency of short-term exposures. As such, the original 7-day assumption is conservative, and <br />refining it improves realism without increasing long-term risk estimates. <br />With respect to significance thresholds established by the Bay Area Air District, construction-related <br />emissions are typically evaluated on a daily basis (e.g., pounds per day). Under a 5-day schedule, <br />daily emission rates during active construction would remain unchanged, and therefore maximum <br />daily emissions—and associated threshold comparisons—would not be affected. <br />The proposed project would be substantially similar to the County Project, though with fewer <br />proposed dwelling units. The proposed project would also reflect an elimination of a substantial <br />amount of off-site utility improvements from the County Project, including the removal of the proposed <br />water storage and booster pump facility, WWTP, recycled water storage, and agricultural irrigation <br />fields. The County Project was found to result in operational and construction-related criteria air <br />pollutants or ozone precursors below the Bay Area Air District’s thresholds of significance for all <br />criteria pollutants. The proposed project is also substantially similar to Alternative 2, which, because it <br />anticipated annexation to the City, did not consider a water storage and booster pump facility, WWTP, <br />recycled water storage facility, and agricultural irrigation fields. Alternative 2 was also determined to <br />result in a less than significant impact in this regard for both construction and operation. Therefore, <br />given the reduced scope of the proposed project, it would result in fewer total emissions and would <br />also result in operational and construction-related criteria air pollutants or ozone precursors below the <br />Bay Area Air District’s thresholds of significance for all criteria pollutants. <br />The Bay Area Air District does not have a quantitative emissions threshold for determining potentially <br />significant impacts related to construction fugitive dust. Instead, consistent with the approach taken in <br />the Prior FEIR, this analysis identified a potentially significant impact related to construction fugitive <br />dust given that the Bay Area Air District considers a project to result in a potentially significant impact <br />if that project were not to implement construction BMPs to minimize the extent of fugitive dust <br />emissions, such as soil erosion, sediment migration, roadway dust re-entrainment, and soil trackout, <br />during project construction. For purposes of a conservative analysis, this assessment (consistent with <br />the approach taken in the Prior FEIR) incorporated the implementation of construction BMPs into <br />mitigation to minimize fugitive dust emissions. Therefore, MM AIR-1, discussed above, would still be <br />required to ensure implementation of construction BMPs recommended by the Bay Area Air District, <br />irrespective of the emissions reductions achieved by those BMPs. Consequently, consistent with the <br />analysis in the Prior FEIR, given the reduced nature and scope of the proposed project, combined <br />with the adherence to applicable control measures, other applicable laws and regulations, and the <br />implementation of MM AIR-1, project construction emissions would be less than significant. <br />The proposed project would not result in any new or more severe significant impacts related to <br />cumulative criteria pollutant emissions beyond what was analyzed in the Prior FEIR. Therefore, the <br />proposed project would not introduce new significant impacts or create substantially more severe <br />significant impacts than those previously identified in the Prior FEIR. No additional analysis is <br />required.