Albright Initial Study Attachment 1-4 Use Adobe 7 Or Greater

INITIAL STUDY – 90-160 ALBRIGHT WAY AND 14600 WINCHESTER BOULEVARD

ATTACHMENT 1

APPLICANT’S TREE PRESERVATION STATEMENT

M E M O R A N D U M

To: Geoff Bradley, Joel Paulson and Fletcher Parson, Town of Los Gatos

From: Mike Keaney

Date: 2/4/11

Subject: Albright Way, Tree Preservation

After visiting the site and reviewing the conceptual site plan we are proposing to use our best efforts (we do not know for certain the impacts of grading and utilities on the existing trees) to preserve trees in the following locations:

On the slope adjacent to the existing residential uses all of the trees behind the masonry wall that is currently on the site can be preserved. This includes the following trees: 25, 26, 27, 28, 106, 107, 116, 115, 114, 113.

On the southern property line adjacent to the existing residential near Charter Oaks Drive we will setback parking 15’ from the property line. This will allow for the preservation of the majority of the trees along this edge of the project. This applies to the following trees: 124 – 132, 134 – 141.

Along the railroad right of way the majority of our improvements will be in areas of the site that are already developed with parking and other improvements. This should allow for the preservation of many trees in this area including: 324, 326-346.

Of course, if any of these trees must be removed, we will follow the tree mitigation requirements. INITIAL STUDY – 90-160 ALBRIGHT WAY AND 14600 WINCHESTER BOULEVARD

ATTACHMENT 2

AIR QUALITY AND GREENHOUSE GAS ASSESSMENT ALBRIGHT WAY DEVELOPMENT PROJECT

RBF CONSULTING

MARCH 2011

Albright Way Development Project AIR QUALITY & GREENHOUSE GAS ASSESSMENT

Consultant:

RBF CONSULTING 14725 Alton Parkway Irvine, California 92618 Contact: Mr. Eddie Torres, INCE, REA Director of Technical Studies 949.855.3612

March 31, 2011

JN 40‐100419 Albright Way Development Project

TABLE OF CONTENTS

EXECUTIVE SUMMARY ...... 1

1.0 INTRODUCTION...... 3 1.1 Project Location ...... 3 1.2 Project Characteristics...... 3

2.0 EXISTING AIR QUALITY SETTING...... 8 2.1 Environmental Setting...... 8 2.2 Regulatory Framework...... 11 2.3 Sensitive Receptors...... 19

3.0 MONITORED AIR QUALITY ...... 21

4.0 SIGNIFICANCE CRITERIA AND METHODOLOGY ...... 27 4.1 Significance Criteria ...... 27

5.0 POTENTIAL AIR QUALITY AND GREENHOUSE GAS IMPACTS...... 30

6.0 REFERENCES ...... 62 6.1 List of Preparers...... 62 6.2 Documents...... 62 6.3 Web Sites/Programs ...... 63

APPENDIX A – AIR MODELING DATA

Air Quality & Greenhouse Gas Assessment i March 2011 Albright Way Development Project

LIST OF EXHIBITS

Exhibit 1 – Regional Vicinity ...... 5

Exhibit 2 – Site Vicinity ...... 6

Exhibit 3 – Site Plan ...... 7

Exhibit 4 – Phased Approach for Estimating Community Risks and Hazards...... 47

Exhibit 5 – Residential Development Limitations...... 50

LIST OF TABLES

Table 1 – National and California Ambient Air Quality Standards ...... 12

Table 2 – Sensitive Receptors...... 20

Table 3 – Local Air Quality Levels...... 21

Table 4 – BAAQMD Emissions Thresholds...... 27

Table 5 – BAAQMD GHG Thresholds...... 29

Table 6 – Construction Emissions...... 33

Table 7 – Long‐Term Operational Air Emissions ...... 38

Table 8 – Risk and Health Hazards from State Route 85...... 49

Table 9 – Scenario 1 Business as Usual Greenhouse Gas Emissions Projections ...... 54

Table 10 – Project Consistency With the BAAQMD Greenhouse Gas Mitigation Measures...... 55

Table 11 – Scenario 1 Greenhouse Gas Emissions With BAAQMD Sector Reductions...... 57

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LIST OF ACRONYMS

μg/m3 micrograms per cubic meter AB Assembly Bill ABAG Association of Bay Area Governments APS Alternative Planning Strategy AQMP Air Quality Management Plan BAAQMD Bay Area Air Quality Management District BAU Business as Usual CAAQS California Ambient Air Quality Standards CARB California Air Resources Board CAT Climate Action Team CCAA California Clean Air Act CCR California Code of Regulations CEC California Energy Commission CEQA California Environmental Quality Act CFCs Chlorofluorocarbons CH4 Methane CO carbon monoxide CO2 carbon dioxide CO2e CO2 equivalent CPUC California Public Utilities Commission EAC Early Action Compact EPA U.S. Environmental Protection Agency F Fahrenheit FCAA Federal Clean Air Act GHG greenhouse gas GWP Global Warming Potential H2O water vapor HCFCs Hydrochlorofluorocarbons HFCs Hydrofluorocarbons IPCC International Panel for Climate Change km kilometer LCFS Low Carbon Fuel Standard LOS level of service LSTs Localized Significance Thresholds MMT million metric tons MPO Metropolitan Planning Organization MTC Metropolitan Transportation Commission MTCO2eq metric tons of carbon dioxide equivalents N2O nitrous oxide N/A Not Applicable NAAQS National Ambient Air Quality Standards NOA naturally occurring asbestos

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NO2 nitrogen dioxide NOx nitrogen oxides O3 ozone OPR Office of Planning and Research Pb lead PFCs Perfluorocarbons PM10 particulate matter less than 10 microns in diameter PM2.5 particulate matter less than 2.5 microns in diameter ppm parts per million ppt parts per trillion PST Pacific Standard Time RCPG Regional Comprehensive Plan and Guide RH relative humidity ROG Reactive Organic Gasses SB Senate Bill SCS Sustainable Community Strategy SF6 Sulfur hexafluoride SIP State Implementation Plan SO2 sulfur dioxide SOx sulfur oxides SRA source receptor area UV‐B ultraviolet rays VHT vehicle hours traveled VMT vehicle miles traveled VOC Volatile Organic Compound

Air Quality & Greenhouse Gas Assessment iv March 2011 Albright Way Development Project

EXECUTIVE SUMMARY

The purpose of this Air Quality and Greenhouse Gas Assessment is to evaluate potential short‐ and long‐term air quality and greenhouse gas impacts resulting from implementation of the proposed Albright Way Development project (project). The project is located in the Town of Los Gatos (Town), along Albright Way, southeast of the State Route 85 (SR‐85) and Winchester Boulevard interchange.

The project proposes a Planned Development zoning that will allow for flexibility in the ultimate mix of land uses on the project site. The project may consist of office alone or a mix of office and high‐density /senior residential units. As currently proposed, the project could include up to a maximum of 550,000 square feet of office space, or a combination of less office space with residential uses. Residential uses could include up to a maximum of 516 high‐ density dwelling units or 600 senior residential uses. This Air Quality and Greenhouse Gas Assessment evaluates Scenario 1 as identified in the Albright Way Development Traffic Impact Analysis (Traffic Impact Analysis), prepared by Hexagon Transportation Consultants, Inc. on March 17, 2011. Scenario 1 consists of the replacement of 250,000 square feet of existing office park buildings with new office buildings totaling 550,000 square feet. Under Scenario 1, the new office buildings would provide an additional 300,000 square feet of office space and result in additional 3,126 daily vehicle trips. Three parking structures are also proposed under this Scenario. As noted, the Planned Development zoning will provide flexibility for mixed use scenarios, provided that the air quality and GHG impacts of those scenarios are not substantially more severe than the air quality and GHG impacts of Scenario 1.

Construction activities would consist of demolition of existing buildings, site grading, trenching, paving, building construction, and architectural coating. Staging for construction equipment would occur within the boundaries of the project site.

Temporary Impacts. Based upon the results of the analysis, construction emissions would not exceed the Bay Area Air Quality Management District thresholds with implementation of recommended mitigation measures. Short‐term construction impacts would be considered less than significant.

Long‐Term Impacts. The analysis has demonstrated that project implementation would result in less than significant long‐term impacts. Carbon monoxide hot‐spots impacts would also be less than significant with implementation of recommended mitigation within the project’s Traffic Impact Analysis. The proposed project would result in less than significant impacts for all long‐term operational emissions.

Greenhouse Gas Emissions Impacts. The proposed project would generate minimal amounts of GHG emissions as a result of construction activities, and would result in a less than significant impact. Long‐term operational greenhouse gas emissions would be less than significant with implementation of the recommended mitigation measure.

Air Quality & Greenhouse Gas Assessment 1 March 2011 Albright Way Development Project

Cumulative Impacts. The proposed project would be consistent with the Bay Area Air Quality Management District’s 2010 Clean Air Plan, as the proposed project complies with the goals and policies of the General Plan and does not exceed the Bay Area Air Quality Management District’s short‐ and long‐term significance criteria. The proposed project would result in a less than significant impact for cumulative long‐ and short‐term operational emissions.

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1.0 INTRODUCTION

The purpose of this Air Quality and Greenhouse Gas Assessment is to evaluate potential short‐ and long‐term air quality and greenhouse gas (GHG) impacts resulting from implementation of the proposed Albright Way Development project (project) in the Town of Los Gatos (Town).

1.1 PROJECT LOCATION

The project is located in the Town of Los Gatos, California; refer to Exhibit 1, Regional Vicinity. Specifically, the project site is located along Albright Way, southeast of the State Route 85 (SR‐ 85) and Winchester Boulevard interchange; refer to Exhibit 2, Local Vicinity Map.

1.2 PROJECT CHARACTERISTICS

The project proposes a Planned Development zoning that will all for flexibility in the ultimate mix of land uses on the site. The project may consist of office alone or a mix of office and high‐ density /senior residential units. As currently proposed, the project could include up to a maximum of 550,000 square feet of office space, or a combination of less office space with residential uses. Residential uses could include up to a maximum of 516 high‐density dwelling units or 600 senior residential uses. This Air Quality and Greenhouse Gas Assessment evaluates Scenario 1 as identified in the Albright Way Development Traffic Impact Analysis (Traffic Impact Analysis), prepared by Hexagon Transportation Consultants, Inc. on March 17, 2011. An evaluation of each of the potential land use scenarios indicates that the development of the project site as all office uses would result in the greatest amount of traffic being added to the roadway system.1 Therefore, as vehicle trips are typically largest source of air quality and greenhouse gas (GHG) emissions for development projects, this analysis evaluates the “worst‐ case” project scenario consisting of the replacement of 250,000 square feet (s.f.) of existing office park buildings with new buildings totaling 550,000 s.f.; refer to Exhibit 3, Site Plan.

As noted, the Planned Development zoning will provide flexibility for mixed use scenarios, provided that the air quality and GHG impacts of those scenarios are not substantially more severe than the air quality and GHG impacts of Scenario 1. The Town has developed the following additional illustrative land uses scenarios:

• Scenario 1: Replacement of the 250,000 s.f. of existing office park buildings on the site with new office buildings totaling 550,000 s.f. • Scenario 2: Minimum of 200,000 s.f. new office plus 141,000 s.f. (remaining) office • Scenario 3: 200,000 s.f. new office plus up to 516 high‐density units • Scenario 4: 200,000 s.f. new office plus up to 600 senior units

1 Hexagon Transportation Consultants, Inc., Albright Way Development Traffic Impact Analysis, March 17, 2011.

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Because the office use would generate more daily and peak hour trips than would residential, this study first presents the analysis of a proposed project scenario consisting of the replacement of the 250,000 s.f. of existing office park buildings on the site with new office buildings totaling 550,000 s.f. Then, in order to determine whether the addition of residential uses would generate any greater impacts than the 550,000 s.f. office scenario, supplemental analyses were completed for the additional scenarios.

The project site is bound by Winchester Boulevard, a rail line and SR‐85 to the north and west, a residential neighborhood and the Los Gatos Creek Trail to the east, and an office building to the south. The design goals for future buildings on the project site are to fit into that transitional environment and to provide adequate density for a transit oriented development to meet the Townʹs goals. In order to work with the project site’s natural grades, the site design would utilize walls, terraces, and landscaped steps in natural materials that would become an extension of the building architecture, and create useful outdoor social gathering spaces.

Air Quality & Greenhouse Gas Assessment 4 March 2011 Sebastopol NAPA 505 YOLO SACRAMENTO 29 COUNTY COUNTY 116 COUNTY Rohnert 12 84 Park 121 Vacaville Cotati SONOMA 80 113 Bodega COUNTY Napa SOLANO 5 Bay Sonoma Fairfield COUNTY 101 160 104 Petaluma Suisun City Galt 116 220 12 121 12 Rio 29 Vista 99 37 Vallejo 680 Lodi 12 Novato Benicia MARIN 160 COUNTY 780 1 San 4 4 Rafael 80 Hercules Richmond Martinez Antioch 4 580 Concord Stockton 101 Lafayette CONTRA COSTA 24 Walnut Creek SAN COUNTY 4 Berkley Orinda JOAQUIN Sausalito COUNTY Danville 80 13 SAN FRANCISCO Lathrop 680 COUNTY Oakland 120 San San Ramon Alameda 205 Francisco 580 Tracy Dublin 5 Daly 101 San 580 Hayward Livermore 580 City Leandro 880 Pleasanton Pacifica 84 238 132 San 92 ALAMEDA Millbrae Mateo Union COUNTY City 33 1 280 Hillsborough 5 Redwood 84 Newark City Fremont 92 Half Moon Bay 35 82 Palo Milpitas Alto 880 680 SAN MATEO 280 101 COUNTY Los Altos Santa STANISLAUS Clara COUNTY 84 Cupertino San Jose Saratoga 85 87 82 SANTA 9 CLARA COUNTY Los Project 35 Gatos 17 236 Site P A COF I C E A N Morgan Hill 9 Scotts 1 Valley SANTA CRUZ COUNTY 156 152 Santa Capitola Gilroy Cruz 152

25 Watsonville 129

Hollister 156 SAN BENITO COUNTY 156 101 MONTEREY 25 COUNTY 1 183 Salinas Marina

ALBRIGHT WAY DEVELOPMENT PROJECT AIR QUALITY AND GREENHOUSE GAS ASSESSMENT 0 10 20 miles

APPROXIMATE Regional Vicinity 1/26/11 JN 40-100419-17194 MAS Exhibit 1 Source: Google Earth aerial. ALBRIGHT WAY DEVELOPMENT PROJECT AIR QUALITY AND GREENHOUSE GAS ASSESSMENT not to scale Local Vicinity 1/26/11 JN 40-100419-17194 MAS Exhibit 2 Source: Form4 Architecture. ALBRIGHT WAY DEVELOPMENT PROJECT 0 160' AIR QUALITY AND GREENHOUSE GAS ASSESSMENT APPROXIMATE Conceptual Site Layout 1/26/11 JN 40-100419-17194 MAS Exhibit 3 Albright Way Development Project

2.0 EXISTING AIR QUALITY SETTING

2.1 ENVIRONMENTAL SETTING

The California Air Resources Board (CARB) divides the State into 15 air basins that share similar meteorological and topographical features. The project site is located within the San Francisco Bay Area Air Basin (Basin). This Basin comprises all of Alameda, Contra Costa, Marin, Napa, San Francisco, San Mateo, and Santa Clara counties, the southern portion of Sonoma, and the southwestern portion of Solano County. Air quality in this area is determined by such natural factors as topography, meteorology, and climate, in addition to the presence of existing air pollution sources and ambient conditions. These factors along with applicable regulations are discussed below.

The Town of Los Gatos is located within the Santa Clara Valley climatological subregion of the Basin. The Santa Clara Valley is bounded by the San Francisco Bay to the north and by mountains to the east, south, and west.

The climate is dominated by the strength and location of a semi‐permanent, subtropical high‐ pressure cell. During the summer, the Pacific high pressure cell is centered over the northeastern Pacific Ocean resulting in stable meteorological conditions and a steady northwesterly wind flow. Upwelling of cold ocean water from below to the surface because of the northwesterly flow produces a band of cold water off the California coast. The cool and moisture‐laden air approaching the coast from the Pacific Ocean is further cooled by the presence of the cold water band resulting in condensation and the presence of fog and stratus clouds along the Northern California coast. In the winter, the Pacific high‐pressure cell weakens and shifts southward resulting in wind flow offshore, the absence of upwelling, and the occurrence of storms. Weak inversions coupled with moderate winds result in a low air pollution potential.

Wind Patterns

During the summer, winds flowing from the northwest are drawn inland through the Golden Gate and over the lower portions of the San Francisco Peninsula. Immediately south of Mount Tamalpais, the northwesterly winds accelerate considerably and come more directly from the west as they stream through the Golden Gate. This channeling of wind through the Golden Gate produces a jet that sweeps eastward and splits off to the northwest toward Richmond and to the southwest toward San Jose when it meets the East Bay hills.

Wind speeds may be strong locally in areas where air is channeled through a narrow opening, such as the Carquinez Strait, the Golden Gate or the San Bruno gap. For example, the average wind speed at San Francisco International Airport in July is about 17 knots (from 3:00 p.m. to 4:00 p.m.), compared with only seven knots at San Jose and less than six knots at the Farallon Islands. The air flowing in from the coast to the Central Valley, called the sea breeze, begins developing at or near ground level along the coast in late morning or early afternoon. As the

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day progresses, the sea breeze layer deepens and increases in velocity while spreading inland. The depth of the sea breeze depends in large part upon the height and strength of the inversion. If the inversion is low and strong, and hence stable, the flow of the sea breeze will be inhibited and stagnant conditions are likely to result.

In the winter, the Basin frequently experiences stormy conditions with moderate to strong winds, as well as periods of stagnation with very light winds. Winter stagnation episodes are characterized by nighttime drainage flows in coastal valleys. Drainage is a reversal of the usual daytime air‐flow patterns; air moves from the Central Valley toward the coast and back down toward the Bay from the smaller valleys within the Basin.

Temperature

Summertime temperatures in the Basin are determined in large part by the effect of differential heating between land and water surfaces. Because land tends to heat up and cool off more quickly than water, a large‐scale gradient (differential) in temperature is often created between the coast and the Central Valley, and small‐scale local gradients are often produced along the shorelines of the ocean and bays. The temperature gradient near the ocean is also exaggerated, especially in summer, because of the upwelling of cold ocean bottom water along the coast. On summer afternoons the temperatures at the coast can be 35 degrees Fahrenheit (ºF) cooler than temperatures 15 to 20 miles inland. At night this contrast usually decreases to less than 10ºF. In the winter, the relationship of minimum and maximum temperatures is reversed. During the daytime the temperature contrast between the coast and inland areas is small, whereas at night the variation in temperature is large.

Precipitation

The Basin is characterized by moderately wet winters and dry summers. Winter rains account for about 75 percent of the average annual rainfall. The amount of annual precipitation can vary greatly from one part of the Basin to another even within short distances. In general, total annual rainfall can reach 40 inches in the mountains, but it is often less than 16 inches in sheltered valleys. During rainy periods, ventilation (rapid horizontal movement of air and injection of cleaner air) and vertical mixing are usually high, and thus pollution levels tend to be low. However, frequent dry periods do occur during the winter where mixing and ventilation are low and pollutant levels build up.

Air Pollution Potential

The potential for high pollutant concentrations developing at a given location depends upon the quantity of pollutants emitted into the atmosphere in the surrounding area or upwind, and the ability of the atmosphere to disperse the contaminated air. The topographic and climatological factors discussed above influence the atmospheric pollution potential of an area. Atmospheric pollution potential, as the term is used here, is independent of the location of emission sources and is instead a function of factors described below.

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Wind Circulation

Low wind speed contributes to the buildup of air pollution because it allows more pollutants to be emitted into the air mass per unit of time. Light winds occur most frequently during periods of low sun (fall and winter, and early morning) and at night. These are also periods when air pollutant emissions from some sources are at their peak, namely, commute traffic (early morning) and wood burning appliances (nighttime). The problem can be compounded in valleys, when weak flows carry the pollutants upvalley during the day, and cold air drainage flows move the air mass downvalley at night. Such restricted movement of trapped air provides little opportunity for ventilation and leads to buildup of pollutants to potentially unhealthful levels.

Inversions

An inversion is a layer of warmer air over a layer of cooler air. Inversions affect air quality conditions significantly because they influence the mixing depth, which is the vertical depth in the atmosphere available for diluting air contaminants near the ground. The highest air pollutant concentrations in the Basin generally occur during inversions.

There are two types of inversions that occur regularly in the Basin. One is more common in the summer and fall, while the other is most common during the winter. The frequent occurrence of elevated temperature inversions in summer and fall months acts to cap the mixing depth, limiting the depth of air available for dilution. Elevated inversions are caused by subsiding air from the subtropical high pressure zone, and from the cool marine air layer that is drawn into the Basin by the heated low pressure region in the Central Valley.

The inversions typical of winter, called radiation inversions, are formed as heat quickly radiates from the earthʹs surface after sunset, causing the air in contact with it to rapidly cool. Radiation inversions are strongest on clear, low‐wind, cold winter nights, allowing the build‐up of such pollutants as carbon monoxide and particulate matter. When wind speeds are low, there is little mechanical turbulence to mix the air, resulting in a layer of warm air over a layer of cooler air next to the ground. Mixing depths under these conditions can be as shallow as 50 to 100 meters, particularly in rural areas. Urban areas usually have deeper minimum mixing layers because of heat island effects and increased surface roughness. During radiation inversions downwind transport is slow, the mixing depths are shallow, and turbulence is minimal, all factors which contribute to ozone formation.

Although each type of inversion is most common during a specific season, either inversion mechanism can occur at any time of the year. Sometimes both occur simultaneously. Moreover, the characteristics of an inversion often change throughout the course of a eday. Th terrain of the Basin also induces significant variations among subregions.

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Solar Radiation

The frequency of hot, sunny days during the summer months in the Basin is another important factor that affects air pollution potential. It is at the higher temperatures that ozone is formed. In the presence of ultraviolet sunlight and warm temperatures, reactive organic gases and oxides of nitrogen react to form secondary photochemical pollutants, including ozone. Because temperatures in many of the inland valleys are so much higher than near the coast, the inland areas are especially prone to photochemical air pollution. In late fall and winter, solar angles are low, resulting in insufficient ultraviolet light and warming of the atmosphere to drive the photochemical reactions. Ozone concentrations do not reach significant levels in the Basin during these seasons.

Sheltered Terrain

The hills and mountains in the Basin contribute to the high pollution potential of some areas. During the day, or at night during windy conditions, areas in the lee sides of mountains are sheltered from the prevailing winds, thereby reducing turbulence and downwind transport. At night, when wind speeds are low, the upper atmospheric layers are often decoupled from the surface layers during radiation conditions. If elevated terrain is present, it will tend to block pollutant transport in that direction. Elevated terrain also can create a recirculation pattern by inducing upvalley air flows during the day and reverse downvalley flows during the night, allowing little inflow of fresh air.

The areas having the highest air pollution potential tend to be those that experience the highest temperatures in the summer and the lowest temperatures in the winter. The coastal areas are exposed to the prevailing marine air, creating cooler temperatures in the summer, warmer temperatures in winter, and stratus clouds all year. The inland valleys are sheltered from the marine air and experience hotter summers and colder winters. Thus, the topography of the inland valleys creates conditions conducive to high air pollution potential.

2.2 REGULATORY FRAMEWORK

U.S. ENVIRONMENTAL PROTECTION AGENCY

The EPA is responsible for implementing the Federal Clean Air Act (FCAA), which was first enacted in 1955 and amended numerous times after. The FCAA established Federal air quality standards known as the National Ambient Air Quality Standards (NAAQS). These standards identify levels of air quality for “criteria” pollutants that are considered the maximum levels of ambient (background) air pollutants considered safe, with an adequate margin of safety, to protect the public health and welfare. The criteria pollutants are ozone (O3), carbon monoxide (CO), nitrogen dioxide (NO2, which is a form of nitrogen oxides [NOx]), sulfur dioxide (SO2, which is a form of sulfur oxides [SOx]), particulate matter less than 10 and 2.5 microns in diameter (PM10 and PM2.5, respectively), and lead (Pb); refer to Table 1, National and California Ambient Air Quality Standards.

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Table 1 National and California Ambient Air Quality Standards

California1 Federal2 Pollutant Averaging Time Standard3 Attainment Status Standards4 Attainment Status 1 Hour 0.09 ppm (180 μg/m3) Nonattainment N/A5 N/A5 Ozone (O3) 8 Hours 0.07 ppm (137 μg/m3) N/A 0.075 ppm (147 μg/m3) Nonattainment 24 Hours 50 μg/m3 Nonattainment 150 μg/m3 Unclassified Particulate Annual Arithmetic Matter (PM10) 20 μg/m3 Nonattainment N/A6 Unclassified Mean Fine Particulate 24 Hours No Separate State Standard 35 μg/m3 Nonattainment Matter Annual Arithmetic 12 μg/m3 Nonattainment 15.0 μg/m3 Nonattainment (PM2. 5) Mean Unclassified/ 8 Hours 9.0 ppm (10 mg/m3) Attainment 9 ppm (10 mg/m3) Carbon Attainment Monoxide (CO) Unclassified/ 1 Hour 20 ppm (23 mg/m3) Attainment 35 ppm (40 mg/m3) Attainment Annual Arithmetic Unclassified/ 0.030 ppm (57 μg/m3) N/A 53 ppb (100 μg/m3) Nitrogen Dioxide Mean Attainment (NO2)7 1 Hour 0.18 ppm (339 μg/m3) Attainment 100 ppb (188 μg/m3) N/A 30 days average 1.5 μg/m3 Attainment N/A N/A Lead (Pb) Calendar Quarter N/A N/A 1.5 μg/m3 N/A 24 Hours 0.04 ppm (105 μg/m3) Attainment N/A Attainment Sulfur Dioxide 3 Hours N/A N/A N/A Attainment (SO2) 1 Hour 0.25 ppm (655 μg/m3) Attainment 75 ppb (196 μg/m3) N/A Visibility- 8 Hours (10 a.m. to Extinction coefficient = Reducing Unclassified 6 p.m., PST) 0.23 km@<70% RH Particles No Federal Sulfates 24 Hour 25 μg/m3 Attainment Standards Hydrogen Sulfide 1 Hour 0.03 ppm (42 μg/m3) Unclassified Vinyl Chloride 24 Hour 0.01 ppm (26 μg/m3) N/A μg/m3 = micrograms per cubic meter; ppm = parts per million; ppb = parts per billion; km = kilometer(s); RH = relative humidity; PST = Pacific Standard Time; N/A = Not Applicable 1. California standards for ozone, carbon monoxide (except Lake Tahoe), sulfur dioxide (1- and 24-hour), nitrogen dioxide, suspended particulate matter-PM10 and visibility-reducing particles are values that are not to be exceeded. All others are not to be equaled or exceeded. California ambient air quality standards are listed in the Table of Standards in Section 70200 of Title 17 of the California Code of Regulations. In 1990, the California Air Resources Board (CARB) identified vinyl chloride as a toxic air contaminant, but determined that there was not sufficient available scientific evidence to support the identification of a threshold exposure level. This action allows the implementation of health-protective control measures at levels below the 0.010 parts per million ambient concentration specified in the 1978 standard. 2. National standards (other than ozone, particulate matter and those based on annual averages or annual arithmetic mean) are not to be exceeded more than once a year. EPA also may designate an area as attainment/unclassifiable, if: (1) it has monitored air quality data that show that the area has not violated the ozone standard over a three-year period; or (2) there is not enough information to determine the air quality in the area. For PM10, the 24-hour standard is attained when the expected number of days per calendar year with a 24-hour average concentration above 150 μg/m3 is equal to or less than one. For PM2.5, the 24-hour standard is attained when 98 percent of the daily concentrations, averaged over three years, are equal to or less than the standard. 3. Concentration is expressed first in units in which it was promulgated. Equivalent units given in parentheses are based upon a reference temperature of 25°C and a reference pressure of 760 mm of mercury. Most measurements of air quality are to be corrected to a reference temperature of 25°C and a reference pressure of 760 mm of mercury (1,013.2 millibar); ppm in this table refers to ppm by volume, or micromoles of pollutant per mole of gas. 4. National Primary Standards: The levels of air quality necessary, with an adequate margin of safety, to protect the public health. 5. The Federal 1-hour ozone standard was revoked on June 15, 2005 in all areas except the 14 8-hour ozone nonattainment Early Action Compact (EAC) areas. 6. The Environmental Protection Agency revoked the annual PM10 standard in 2006 (effective December 16, 2006). 7. To attain this standard, the 3-year average of the 98th percentile of the daily maximum 1-hour average at each monitor within an area must not exceed 0.100 ppm (effective January 22, 2010). Note that EPA standards are in units of ppb and California standards are in units of ppm. Source: California Air Resources Board and U.S. Environmental Protection Agency, September 8, 2010.

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CALIFORNIA AIR RESOURCES BOARD

CARB administers the air quality policy in California. The California Ambient Air Quality Standards (CAAQS) were established in 1969 pursuant to the Mulford‐Carrell Act. These standards, included with the NAAQS in Table 1, are generally more stringent and apply to more pollutants than the NAAQS. In addition to the criteria pollutants, CAAQS have been established for visibility reducing particulates, hydrogen sulfide, and sulfates.

The California Clean Air Act (CCAA), which was approved in 1988, requires that each local air district prepare and maintain an Air Quality Management Plan (AQMP) to achieve compliance with CAAQS. These AQMP’s also serve as the basis for the preparation of the State Implementation Plan (SIP) for the State of California. Like the EPA, CARB also designates areas within California as either attainment or nonattainment for each criteria pollutant based on whether the CAAQS have been achieved. Under the CCAA, areas are designated as nonattainment for a pollutant if air quality data shows that a State standard for the pollutant was violated at least once during the previous three calendar years. Exceedances that are affected by highly irregular or infrequent events are not considered violations of a State standard, and are not used as a basis for designating areas as nonattainment.

BAY AREA AIR QUALITY MANAGEMENT DISTRICT

The Bay Area Air Quality Management District (BAAQMD) is the regional agency with jurisdiction over the nine‐county region located in the Basin. The Association of Bay Area Governments (ABAG), the Metropolitan Transportation Commission (MTC), county transportation agencies, cities and counties, and various nongovernmental organizations also join in the efforts to improve air quality through a variety of programs. These programs include the adoption of regulations and policies, as well as implementation of extensive education and public outreach programs.

The BAAQMD is responsible for attaining and/or maintaining air quality in the Basin within Federal and State air quality standards. Specifically, theMD BAAQ has the responsibility to monitor ambient air pollutant levels throughout the Basin and to develop and implement strategies to attain the applicable Federal and State standards.

In June 2010, the BAAQMD adopted its updated California Environmental Quality Act (CEQA) Air Quality Guidelines as a guidance document to provide lead government agencies, consultants, and project proponents with uniform procedures for assessing air quality impacts and preparing the air quality sections of environmental documents for projects subject to CEQA. The CEQA Air Quality Guidelines include methodologies and thresholds for addressing project and program level air quality and GHG emissions.

In March 2010, the BAAQMD, in cooperation with the MTC and ABAG, published the draft 2010 Bay Area Clean Air Plan, which, supersedes the Bay Area 2005 Ozone Strategy. The 2010 Bay

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Area Clean Air Plan updates the 2005 Ozone Strategy in accordance with the requirements of the CCAA to achieve the following:

• Implement all feasible measures to reduce ozone; provide a control strategy to reduce ozone, particulate matter, toxic air contaminants, and GHGs in a single, integrated plan; • Review progress in improving air quality in recent years; and • Establish emission control measures to be adopted or implemented in the 2010 to 2012 time frame.

The control strategy includes stationary‐source control measures to be implemented through BAAQMD regulations; mobile‐source control measures to be implemented through incentive programs and other activities; and transportation control measures to be implemented through transportation programs in cooperation with the MTC, local governments, transit agencies, and others. The 2010 Bay Area Clean Air Plan also represents the Bay Area’s most recent triennial assessment of the region’s strategy to attain the State one‐hour ozone standard.

GLOBAL CLIMATE CHANGE REGULATORY PROGRAMS

Federal

The FCAA requires the EPA to define national ambient air quality standards (national standards) to protect public health and welfare in the United States. The FCAA does not specifically regulate GHG emissions; however, on April 2, 2007 the U.S. Supreme Court in Massachusetts v. U.S. Environmental Protection Agency, determined that GHGs are pollutants that can be regulated under the FCAA. The EPA adopted an endangerment finding and cause or contribute finding for GHGs on December 7, 2009. Under the endangerment finding, the Administrator found that the current and projected atmospheric concentrations of the six, key, well‐mixed GHGs (CO2, CH4, N2O, HFCs, PFCs, and SF6) threaten the public health and welfare of current and future generations. Under the cause of contribute finding, the Administrator found that the combined emissions of these well‐mixed GHGs from new motor vehicles and new motor vehicle engines contribute to the GHG pollution which threatens public health and welfare.

Based on these findings, on April 1, 2010, the EPA finalized the light‐duty vehicle rule controlling GHG emissions. This rule confirmed that January 2, 2011, is the earliest date that a 2012 model year vehicle meeting these rule requirements may be sold in the United States. On May 13, 2010, the EPA issued the final GHG Tailoring Rule. This rule set thresholds for GHG emissions that define when permits under the Prevention of Significant Deterioration and Title V Operating Permit programs are required for new and existing industrial facilities. Implementation of the Federal rules is expected to reduce the level of emissions from new motor vehicles and large stationary sources.

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State

Various statewide and local initiatives to reduce California’s contribution to GHG emissions have raised awareness that, even though the various contributors to and consequences of global climate change are not yet fully understood, global climate change is occurring, and that there is a real potential for severe adverse environmental, social, and economic effects in the long term. Every nation emits GHGs and as a result makes an incremental cumulative contribution to global climate change; therefore, global cooperation will be required to reduce the rate of GHG emissions enough to slow or stop the human‐caused increase in average global temperatures and associated changes in climatic conditions.

Executive Order S‐1‐07. Executive Order S‐1‐07 proclaims that the transportation sector is the main source of GHG emissions in California, generating more than 40 percent of statewide emissions. It establishes a goal to reduce the carbon intensity of transportation fuels sold in California by at least ten percent by 2020. This order also directs CARB to determine whether this Low Carbon Fuel Standard (LCFS) could be adopted as a discrete early‐action measure as part of the effort to meet the mandates in AB 32.

Executive Order S‐3‐05. Executive Order S‐3‐05 set forth a series of target dates by which statewide emissions of GHGs would be progressively reduced, as follows:

• By 2010, reduce GHG emissions to 2000 levels; • By 2020, reduce GHG emissions to 1990 levels; and • By 2050, reduce GHG emissions to 80 percent below 1990 levels.

The Executive Order directed the secretary of the California Environmental Protection Agency (Cal/EPA) to coordinate a multi‐agency effort to reduce GHG emissions to the target levels. The secretary will also submit biannual reports to the governor and California Legislature describing the progress made toward the emissions targets, the impacts of global climate change on California’s resources, and mitigation and adaptation plans to combat these impacts. To comply with the executive order, the secretary of Cal/EPA created the California Climate Action Team (CAT), made up of members from various State agencies and commissions. The team released its first report in March 2006. The report proposed to achieve the targets by building on the voluntary actions of California businesses, local governments, and communities and through State incentive and regulatory programs.

Executive Order S‐13‐08. Executive Order S‐13‐08 seeks to enhance the Stateʹs management of climate impacts including sea level rise, increased temperatures, shifting precipitation, and extreme weather events by facilitating the development of State’s first climate adaptation strategy. This will result in consistent guidance from experts on how to address climate change impacts in the State of California.

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Executive Order S‐14‐08. Executive Order S‐14‐08 expands the Stateʹs Renewable Energy Standard to 33 percent renewable power by 2020. Additionally, Executive Order S‐21‐09 (signed on September 15, 2009) directs CARB to adopt regulations requiring 33 percent of electricity sold in the State come from renewable energy by 2020. CARB adopted the “Renewable Electricity Standard” on September 23, 2010, which requires 33 percent renewable energy by 2020 for most publicly owned electricity retailers.

Executive Order S‐20‐04. Executive Order S‐20‐04, the California Green Building Initiative, (signed into law on December 14, 2004), establishes a goal of reducing energy use in State‐ owned buildings by 20 percent from a 2003 baseline by 2015. It also encourages the private commercial sector to set the same goal. The initiative places the California Energy Commission (CEC) in charge of developing a building efficiency benchmarking system, commissioning and retro‐commissioning (commissioning for existing commercial buildings) guidelines, and developing and refining building energy efficiency standards under Title 24 to meet this goal.

Executive Order S‐21‐09. Executive Order S‐21‐09, 33 percent Renewable Energy for California, directs CARB to adopt regulations to increase Californiaʹs Renewable Portfolio Standard (RPS) to 33 percent by 2020. This builds upon SB 1078 (2002) which established the California RPS program, requiring 20 percent renewable energy by 2017, and SB 710 (2006) which advanced the 20 percent deadline to 2010, a goal which was expanded to 33 percent by 2020 in the 2005 Energy Action Plan II.

Assembly Bill 32 (California Global Warming Solutions Act of 2006). California passed the California Global Warming Solutions Act of 2006 (AB 32; California Health and Safety Code Division 25.5, Sections 38500 ‐ 38599). AB 32 establishes regulatory, reporting, and market mechanisms to achieve quantifiable reductions in GHG emissions and establishes a cap on statewide GHG emissions. AB 32 requires that statewide GHG emissions be reduced to 1990 levels by 2020. AB 32 specifies that regulations adopted in response to AB 1493 should be used to address GHG emissions from vehicles. However, AB 32 also includes language stating that if the AB 1493 regulations cannot be implemented, then CARB should develop new regulations to control vehicle GHG emissions under the authorization of AB 32.

Assembly Bill 1493. AB 1493 (also known as the Pavley Bill) requires that CARB develop and adopt, by January 1, 2005, regulations that achieve “the maximum feasible reduction of GHG emitted by passenger vehicles and light‐duty trucks and other vehicles determined by CARB to be vehicles whose primary use is noncommercial personal transportation in the State.”

To meet the requirements of AB 1493, CARB approved amendments to the California Code of Regulations (CCR) in 2004 by adding GHG emissions standards to California’s existing standards for motor vehicle emissions. Amendments to CCR Title 13, Sections 1900 and 1961 and adoption of 13 CCR Section 1961.1 require automobile manufacturers to meet fleet‐average GHG emissions limits for all passenger cars, light‐duty trucks within various weight criteria, and medium‐duty weight classes for passenger vehicles (i.e., any medium‐duty vehicle with a gross vehicle weight rating less than 10,000 pounds that is designed primarily to transport

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people), beginning with the 2009 model year. Emissions limits are reduced further in each model year through 2016. When fully phased in, the near‐term standards will result in a reduction of about 22 percent in GHG emissions compared to the emissions from the 2002 fleet, while the mid‐term standards will result in a reduction of about 30 percent.

Assembly Bill 3018. AB 3018 established the Green Collar Jobs Council (GCJC) under the California Workforce Investment Board (CWIB). The GCJC will develop a comprehensive approach to address California’s emerging workforce needs associated with the emerging green economy. This bill will ignite the development of job training programs in the clean and green technology sectors.

Senate Bill 97. SB 97, signed in August 2007 (Chapter 185, Statutes of 2007; PRC Sections 21083.05 and 21097), acknowledges that climate change is a prominent environmental issue that requires analysis under CEQA. This bill directs the Governor’s Office of Planning and Research (OPR), which is part of the State Natural Resources Agency, to prepare, develop, and transmit to CARB guidelines for the feasible mitigation of GHG emissions (or the effects of GHG emissions), as required by CEQA.

OPR published a technical advisory recommending that CEQA lead agencies make a good‐faith effort to estimate the quantity of GHG emissions that would be generated by a proposed project. Specifically, based on available information, CEQA lead agencies should estimate the emissions associated with project‐related vehicular traffic, energy consumption, water usage, and construction activities to determine whether project‐level or cumulative impacts could occur, and should mitigate the impacts where feasible. OPR requested CARB technical staff to recommend a method for setting CEQA thresholds of significance as described in CEQA Guidelines Section 15064.7 that will encourage consistency and uniformity in the CEQA analysis of GHG emissions throughout the State.

The Natural Resources Agency adopted the CEQA Guidelines Amendments prepared by OPR, as directed by SB 97. On February 16, 2010, the Office of Administration Law approved the CEQA Guidelines Amendments, and filed them with the Secretary of State for inclusion in the California Code of Regulations. The CEQA Guidelines Amendments became effective on March 18, 2010.

Senate Bill 375. SB 375, signed in September 2008 (Chapter 728, Statutes of 2008), aligns regional transportation planning efforts, regional GHG reduction targets, and land use and housing allocation. SB 375 requires Metropolitan Planning Organizations (MPOs) to adopt a sustainable communities strategy (SCS) or alternative planning strategy (APS) that will prescribe land use allocation in that MPOs regional transportation plan. CARB, in consultation with MPOs, will provide each affected region with reduction targets for GHGs emitted by passenger cars and light trucks in the region for the years 2020 and 2035. These reduction targets will be updated every eight years but can be updated every four years if advancements in emissions technologies affect the reduction strategies to achieve the targets. CARB is also charged with reviewing each MPO’s SCS or APS for consistency with its assigned targets. If MPOs do not

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meet the GHG reduction targets, transportation projects may not be eligible for funding programmed after January 1, 2012.

Senate Bills 1078 and 107. SB 1078 (Chapter 516, Statutes of 2002) requires retail sellers of electricity, including investor‐owned utilities and community choice aggregators, to provide at least 20 percent of their supply from renewable sources by 2017. SB 107 (Chapter 464, Statutes of 2006) changed the target date to 2010.

Senate Bill 1368. SB 1368 (Chapter 598, Statutes of 2006) is the companion bill of AB 32 and was signed into law in September 2006. SB 1368 required the California Public Utilities Commission (CPUC) to establish a performance standard for baseload generation of GHG emissions by investor‐owned utilities by February 1, 2007. SB 1368 also required the CEC to establish a similar standard for local publicly owned utilities by June 30, 2007. These standards could not exceed the GHG emissions rate from a baseload combined‐cycle, natural gas–fired plant. Furthermore, the legislation states that all electricity provided to California, including imported electricity, must be generated by plants that meet the standards set by CPUC and CEC.

CARB Scoping Plan

On December 11, 2008, CARB adopted its Scoping Plan, which functions as a roadmap to achieve GHG reductions in California required by AB 32 through subsequently enacted regulations. CARB’s Scoping Plan contains the main strategies California will implement to reduce CO2eq emissions by 174 million metric tons (MT), or approximately 30 percent, from the State’s projected 2020 emissions level of 596 million MT CO2eq2 under a business as usual (BAU)3 scenario. This is a reduction of 42 million MT CO2eq, or almost ten percent, from 2002 to 2004 average emissions, but requires the reductions in the face of population and economic growth through 2020.

CARB’s Scoping Plan calculates 2020 BAU emissions as the emissions that would be expected to occur in the absence of any GHG reduction measures. The 2020 BAU emissions estimate was derived by projecting emissions from a past baseline year using growth factors specific to each of the different economic sectors (e.g., transportation, electrical power, commercial and residential, industrial, etc.). CARB used three‐year average emissions, by sector, for 2002 to 2004 to forecast emissions to 2020. At the time CARB’s Scoping Plan process was initiated, 2004 was the most recent year for which actual data was available. The measures described in CARB’s Scoping Plan are intended to reduce the projected 2020 BAU to 1990 levels, as required by AB 32. However, the San Francisco Superior Court has recently issued a tentative ruling, that if issued as proposed, would suspend the implementation of the Scoping Plan pending additional CEQA review.

2 Carbon Dioxide Equivalent (CO2eq) ‐ A metric measure used to compare the emissions from various greenhouse gases based upon their global warming potential. 3 “Business as Usual” refers to emissions that would be expected to occur in the absence of GHG reductions. See http://www.arb.ca.gov/cc/inventory/data/forecast.htm. Note that there is significant controversy as to what BAU means. In determining the GHG 2020 limit, CARB used the above as the “definition.” It is broad enough to allow for design features to be counted as reductions.

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In Association of Irritated Residents, et al. v. California Air Resources Board, et al., the Superior Court of California for the County of San Francisco (Superior Court) issued a ʺtentative statement of decisionʺ (Tentative Decision) that prevents CARB from implementing a state‐wide GHG regulatory program under AB 32 until the agency complies with the requirements of CEQA. The Tentative Decision partially grants a petition for a writ of mandate brought by a coalition of environmental justice organizations (Petitioners) that alleged that CARBʹs Scoping Plan violated both AB 32 and CEQA. Although the Superior Court denied all claims related to AB 32, the court found that CARB: 1) failed to adequately discuss and analyze the impacts of alternatives in its proposed Scoping Plan as required by its CEQA implementing regulations; and 2) improperly approved the Scoping Plan prior to completing the environmental review required by CEQA. In upholding the Petitionersʹ challenge on these two CEQA issues, the Superior Court issued a Peremptory Writ of Mandate and enjoined CARB from further implementation of the Scoping Plan until it complies with all CEQA requirements. Parties to the case had 15 days from the issuance of the Tentative Decision to file objections before the Superior Court issued a final decision in the case.

On March 18, 2011, the Superior Court issued its Final Statement of Decision, which is substantially similar to the Tentative Decision. The Superior Court ruled in favor of CARB concerning AB 32 mandates and how to best reach the GHG reduction goals set by AB 32. However, the Superior Court determined that CARB failed to conduct adequate CEQA review for the Scoping Plan. Specifically, the Superior Court concluded that CARB failed to consider adequate alternatives to the mix of measures adopted in the Scoping Plan, including especially alternatives to cap‐and‐trade measures, and that CARB improperly began implementing the Scoping Plan measures before its CEQA review process was complete. Therefore, the Superior Court has suspended any further implementation of the measures contained in the Scoping Plan until the State has complied with CEQA.

2.3 SENSITIVE RECEPTORS

Sensitive populations are more susceptible to the effects of air pollution than is the general population. Sensitive populations (sensitive receptors) that are in proximity to localized sources of toxics and CO are of particular concern. Land uses considered sensitive receptors include residences, schools, playgrounds, childcare centers, long‐term health care facilities, rehabilitation centers, convalescent centers, and retirement homes. Table 2, Sensitive Receptors, lists the distances and locations of sensitive receptors within the project vicinity.

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Table 2 Sensitive Receptors

Distance from Project Type Name Direction from Project Site Site (feet) 475 North 875 Northeast 230 East 1,660 Southeast Residential Residential Uses Adjoining East/South 1,200 South 900 Southwest 130 West 600 Northwest Schools Yavneh Day School 820 Southeast Los Gatos Swim and Racquet Club 1,000 East Parks/Recreation Courtside Club 350 Southwest Addison Penzack Jewish Community Center 820 Southeast Places of Worship First Assembly of God 1,400 South Congregation Tsemach Adonai 1,450 South Hospitals El Camino Hospital Los Gatos 1,900 Northwest Source: Google Earth 2010.

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3.0 MONITORED AIR QUALITY

CARB monitors ambient air quality at approximately 250 air monitoring stations across the state. Air quality monitoring stations usually measure pollutant concentrations ten feet aboveground level; therefore, air quality is often referred to in terms of ground‐level concentrations. The closest air monitoring station to the project site is the Los Gatos Monitoring Station, which monitors eight‐hour ozone only. Therefore, the remaining data was collected from the San Jose‐Jackson Street Monitoring Station (next closest station to the project site). Local air quality data from 2007 to 2009 is provided in Table 3, Local Air Quality Levels. This table lists the monitored maximum concentrations and number of exceedances of Federal/State air quality standards for each year.

Table 3 Local Air Quality Levels

Days (Samples) California Federal Maximum1 Pollutant Year State/Federal Standard Standard Concentration Std. Exceeded 2007 0.084 ppm 0/NA Ozone (O3) 0.09 ppm NA 2008 0.122 2/NA (1-Hour) 3 for 1 hour 2009 0.102 3/NA 2007 0.065 ppm 0/0 Ozone (O3) 0.07 ppm 0.075 ppm 2008 0.097 2/6 (8-Hour) 3 for 8 hours for 8 hours 2009 0.082 4/8 2007 3.51 ppm 0/0 Carbon Monoxide 20 ppm 35 ppm 2008 3.32 0/0 (CO) (1-Hour) 2 for 1 hour for 1 hour 2009 3.43 0/0 2007 2.71 ppm 0/0 Carbon Monoxide 9.0 ppm 9.0 ppm 2008 2.48 0/0 (CO) (8-Hour) 2 for 8 hours for 8 hours 2009 2.50 0/0 2007 0.065 ppm 0/NA Nitrogen Dioxide 0.18 ppm 0.100 ppm 2008 0.080 0/NA (NO2) 2,4 for 1 hour for 1 hour 2009 0.069 0/NA 2007 69.1 μg/m3 3/0 Particulate Matter 50 µg/m3 150 µg/m3 2008 57.3 1/0 (PM10) 2,5,6 for 24 hours for 24 hours 2009 43.3 0/0 2007 57.5 μg/m3 NA/9 Fine Particulate No Separate State 35 µg/m3 2008 41.9 NA/5 Matter (PM2.5) 2,5,6 Standard for 24 hours 2009 35.0 NA/0 ppm = parts per million; PM10 = particulate matter 10 microns in diameter or less; NM = not measured; μg/m3 = micrograms per cubic meter; PM2.5 = particulate matter 2.5 microns in diameter or less; NA = not applicable. Notes: 1. Maximum concentration is measured over the same period as the California Standards. 2. San Jose-Jackson Street Monitoring Station located at 158 East Jackson Street, San Jose, CA. 3. Los Gatos Monitoring Station located at 306 University Avenue, Los Gatos, CA. 4. The United States Environmental Protection Agency revoked the Federal 1-hour Standard in June of 2005. 5. PM10 exceedances are based on State thresholds established prior to amendments adopted on June 20, 2002. 6. PM10 and PM2.5 exceedances are derived from the number of samples exceeded, not days. Source: Aerometric Data Analysis and Measurement System (ADAM), summaries from 2007 to 2009, http://www.arb.ca.gov/adam.

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CARBON MONOXIDE (CO)

CO is an odorless, colorless toxic gas that is emitted by mobile and stationary sources as a result of incomplete combustion of hydrocarbons or other carbon‐based fuels. In cities, automobile exhaust can cause as much as 95 percent of all CO emissions. At high concentrations, CO can reduce the oxygen‐carrying capacity of the blood and cause headaches, dizziness, and unconsciousness.

OZONE (O3)

O3 occurs in two layers of the atmosphere. The layer surrounding the earthʹs surface is the troposphere. The troposphere extends approximately 10 miles above ground level, where it meets the second layer, the stratosphere. The stratospheric (the “good” ozone) layer extends upward from about ten to 30 miles and protects life on earth from the sunʹs harmful ultraviolet rays (UV‐B). “Bad” ozone is a photochemical pollutant, and needs VOCs, NOX and sunlight to form. Therefore, VOCs and NOX are ozone precursors. VOCs and NOX are emitted from various sources throughout the Town. Significant ozone formation generally requires an adequate amount of precursors in the atmosphere and several hours in a stable atmosphere with strong sunlight. High ozone concentrations can form over large regions when emissions from motor vehicles and stationary sources are carried hundreds of miles from their origins.

Many respiratory ailments, as well as cardiovascular disease, are aggravated by exposure to high O3 levels. O3 also damages natural ecosystems (such as forests and foothill plant communities) and damages agricultural crops and some man‐made materials (such as rubber, paint and plastics). Societal costs from ozone damage include increased healthcare costs, the loss of human and animal life, accelerated replacement of industrial equipment and reduced crop yields.

NITROGEN DIOXIDE (NO2)

NOX are a family of highly reactive gases that are a primary precursor to the formation of ground‐level O3, and react in the atmosphere to form acid rain. NO2 (often used interchangeably with NOX) is a reddish‐brown gas that can cause breathing difficulties at high levels. Peak readings of NO2 occur in areas that have a high concentration of combustion sources (e.g., motor vehicle engines, power plants, refineries, and other industrial operations). NO2 can irritate and damage the lungs, and lower resistance to respiratory infections such as influenza. The health effects of short‐term exposure are still unclear. However, continued or frequent exposure to NO2 concentrations that are typically much higher than those normally found in the ambient air may increase acute respiratory illnesses in children and increase the incidence of chronic bronchitis and lung irritation. Chronic exposure to NO2 may aggravate eyes and mucus membranes and cause pulmonary dysfunction.

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COARSE PARTICULATE MATTER (PM10)

PM10 refers to suspended particulate matter, which is smaller than ten microns or ten one‐ millionths of a meter. PM10 arises from sources such as road dust, diesel soot, combustion products, construction operations, and dust storms. PM10 scatters light and significantly reduces visibility. In addition, these particulates penetrate the lungs and can potentially damage the respiratory tract. On June 19, 2003, CARB adopted amendments to the statewide 24‐hour particulate matter standards based upon requirements set forth in the Children’s Environmental Health Protection Act (SB 25).

FINE PARTICULATE MATTER (PM2.5)

Due to recent increased concerns over health impacts related to fine particulate matter (particulate matter 2.5 microns in diameter or less), both State and Federal PM2.5 standards have been created. Particulate matter impacts primarily affect infants, children, the elderly, and those with pre‐existing cardiopulmonary disease. In 1997, the EPA announced new PM2.5 standards. Industry groups challenged the new standard in court and the implementation of the standard was blocked. However, upon appeal by the EPA, the U.S. Supreme Court reversed this decision and upheld the EPA’s new standards.

On June 20, 2002, CARB adopted amendments for statewide annual ambient particulate matter air quality standards. These standards were revised/established due to increasing concerns by CARB that previous standards were inadequate, as almost everyone in California is exposed to levels at or above the current State standards during some parts of the year, and the statewide potential for significant health impacts associated with particulate matter exposure was determined to be large and wide‐ranging.

VOLATILE ORGANIC COMPOUNDS (VOCs or Reactive Organic Gases [ROG])

Hydrocarbons are organic gases that are formed solely of hydrogen and carbon. There are several subsets of organic gases including ROGs and VOCs. Both ROGs and VOCs are emitted from the incomplete combustion of hydrocarbons or other carbon‐based fuels. The major sources of hydrocarbons are combustion engine exhaust, oil refineries, and oil‐fueled power plants; other common sources are petroleum fuels, solvents, dry cleaning solutions, and paint (via evaporation).

LEAD (Pb)

In the Basin, atmospheric lead is generated almost entirely by the combustion of leaded gasoline and contributes less than one percent of the material collected as total suspended particulate. Atmospheric lead concentrations have been reduced substantially in recent years due to the lowering of average lead content in gasoline. Exceedances of the State air quality standard for lead (monthly average concentration of 1.50 μg/m3) now are confined to densely populated

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areas, where vehicle traffic is greatest. Lead was not monitored at the nearby monitoring locations. The Basin has achieved attainment for lead under both State and Federal standards.

GLOBAL CLIMATE CHANGE GASES

The natural process through which heat is retained in the troposphere is called the “greenhouse effect.”4 The greenhouse effect traps heat in the troposphere through a three‐fold process, summarized as follows: short wave radiation emitted by the Sun is absorbed by the Earth; the Earth emits a portion of this energy in the form of long wave radiation; and GHGs in the upper atmosphere absorb this long wave radiation and emit this long wave radiation into space and toward the Earth. This “trapping” of the long wave (thermal) radiation emitted back toward the Earth is the underlying process of the greenhouse effect.

The most abundant GHGs are water vapor and carbon dioxide. Many other trace gases have greater ability to absorb and re‐radiate long wave radiation; however, these gases are not as plentiful. For this reason, and to gauge the potency of GHGs, scientists have established a Global Warming Potential (GWP) for each GHG based on its ability to absorb and re‐radiate long wave radiation. The GWP of a gas is determined using carbon dioxide as the reference gas with a GWP of one (1).

GHGs normally associated with the proposed project include the following:5

• Water Vapor (H2O). Although water vapor has not received the scrutiny of other GHGs, it is the primary contributor to the greenhouse effect. Natural processes, such as evaporation from oceans and rivers, and transpiration from plants, contribute 90 percent and 10 percent of the water vapor in our atmosphere, respectively. The primary human related source of water vapor comes from fuel combustion in motor vehicles; however, this is not believed to contribute a significant amount (less than one percent) to atmospheric concentrations of water vapor. The Intergovernmental Panel on Climate Change (IPCC) has not determined a GWP for water vapor.

• Carbon Dioxide (CO2). CO2 is primarily generated by fossil fuel combustion in stationary and mobile sources. Due to the emergence of industrial facilities and mobile sources in the past 250 years, the concentration of CO2 in the atmosphere has increased 36 percent.6 CO2 is the most widely emitted GHG and is the reference gas (GWP of 1) for determining GWPs for other GHGs.

4 The troposphere is the bottom layer of the atmosphere, which varies in height from the Earth’s surface to 10 to 12 kilometers. 5 All Global Warming Potentials are given as 100 year GWP. Unless noted otherwise, all Global Warming Potentials were obtained from the Intergovernmental Panel on Climate Change. Climate Change (Intergovernmental Panel on Climate Change, Climate Change, The Science of Climate Change – Contribution of Working Group I to the Second Assessment Report of the IPCC, 1996). 6 U.S. Environmental Protection Agency, Inventory of United States Greenhouse Gas Emissions and Sinks 1990 to 2008, April 2010.

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• Methane (CH4). CH4 is emitted from biogenic sources, incomplete combustion in forest fires, landfills, manure management, and leaks in natural gas pipelines. In the United States, the top three sources of CH4 are landfills, natural gas systems, and enteric fermentation. CH4 is the primary component of natural gas, which is used for space and water heating, steam production, and power generation. The GWP of CH4 is 21.

• Nitrous Oxide (N2O). N2O is produced by both natural and human related sources. Primary human related sources include agricultural soil management, animal manure management, sewage treatment, mobile and stationary combustion of fossil fuel, adipic acid production, and nitric acid production. The GWP of N2O is 310.

• Hydrofluorocarbons (HFCs). HFCs are typically used as refrigerants for both stationary refrigeration and mobile air conditioning. The use of HFCs for cooling and foam blowing is growing, as the continued phase out of chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs) gains momentum. The GWP of HFCs range from 140 for HFC‐152a to 11,700 for HFC‐23.7

• Perfluorocarbons (PFCs). PFCs are compounds consisting of carbon and fluorine. They are primarily created as a byproduct of aluminum production and semi conductor manufacturing. PFCs are potent GHGs with a GWP several thousand times that of CO2, depending on the specific PFC. Another area of concern regarding PFCs is their long atmospheric lifetime (up to 50,000 years).8 The GWP of PFCs range from 6,500 to 9,200.

• Sulfur hexafluoride (SF6). SF6 is a colorless, odorless, nontoxic, nonflammable gas. It is most commonly used as an electrical insulator in high voltage equipment that transmits and distributes electricity. SF6 is the most potent GHG that has been evaluated by the Intergovernmental Panel on Climate Change with a GWP of 23,900. However, its global warming contribution is not as high as the GWP would indicate due to its low mixing ratio compared to carbon dioxide (4 parts per trillion [ppt] in 1990 versus 365 parts per million [ppm], respectively).9

In addition to the six major GHGs discussed above (excluding water vapor), many other compounds have the potential to contribute to the greenhouse effect. Some of these substances were previously identified as stratospheric O3 depletors; therefore, their gradual phase out is currently in effect. The following is a listing of these compounds:

• Hydrochlorofluorocarbons (HCFCs). HCFCs are solvents, similar in use and chemical composition to CFCs. The main uses of HCFCs are for refrigerant products and air conditioning systems. As part of the Montreal Protocol, all developed countries that adhere to the Montreal Protocol are subject to a consumption cap and gradual phase out of HCFCs. The United States is scheduled to achieve a 100 percent reduction to

7 U.S. Environmental Protection Agency, High GWP Gases and Climate Change, June 22, 2010. 8 Ibid. 9 Ibid.

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the cap by 2030. The GWPs of HCFCs range from 93 for HCFC‐123 to 2,000 for HCFC‐142b.10

• 1,1,1 trichloroethane. 1,1,1 trichloroethane or methyl chloroform is a solvent and degreasing agent commonly used by manufacturers. The GWP of methyl chloroform is 110 times that of CO2.11

• Chlorofluorocarbons (CFCs). CFCs are used as refrigerants, cleaning solvents, and aerosols spray propellants. CFCs were also part of the U.S. Environmental Protection Agency’s (EPA) Final Rule (57 FR 3374) for the phase out of O3 depleting substances. Currently, CFCs have been replaced by HFCs in cooling systems and a variety of alternatives for cleaning solvents. Nevertheless, CFCs remain suspended in the atmosphere contributing to the greenhouse effect. CFCs are potent GHGs with GWPs ranging from 4,600 for CFC 11 to 14,000 for CFC 13.12

10 U.S. Environmental Protection Agency, Protection of Stratospheric Ozone: Listing of Global Warming Potential for Ozone Depleting Substances, November 7, 2006. 11 Ibid. 12 U.S. Environmental Protection Agency, Class I Ozone Depleting Substances, March 7, 2006.

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4.0 SIGNIFICANCE CRITERIA AND METHODOLOGY

4.1 SIGNIFICANCE CRITERIA

BAAQMD THRESHOLDS

Under CEQA, the BAAQMD is a commenting responsible agency on air quality within its jurisdiction or impacting its jurisdiction. The BAAQMD reviews projects to ensure that they would: (1) support the primary goals of the latest Air Quality Plan; (2) include applicable control measures from the Air Quality Plan; and (3) not disrupt or hinder implementation of any Air Quality Plan control measures.

As described above, the BAAQMD adopted their CEQA Air Quality Guidelines to assist lead agencies in evaluating air quality impacts of projects and plans proposed in the Basin. The CEQA Air Quality Guidelines provide BAAQMD‐ recommended procedures for evaluating potential air quality and GHG impacts during the environmental review process consistent with CEQA requirements. In addition to providing new thresholds for GHG emissions, the 2010 CEQA Air Quality Guidelines provide updated significance thresholds for criteria pollutants and supersede the BAAQMD’s previous CEQA guidance titled BAAQMD CEQA Guidelines: Assessing the Air Quality Impacts of Projects and Plans (1999).

If the project proposes development in excess of the established thresholds, as illustrated in Table 4, BAAQMD Emission Thresholds, a significant air quality impact may occur and additional analysis is warranted to fully assess the significance of impacts.

Table 4 BAAQMD Emissions Thresholds

Average Daily Emissions (lbs/day) Pollutant/Precursor Maximum Annual Emissions (tpy) (Construction and Operational) ROG 10 54 NOX 10 54 PM10 15 82 PM2.5 10 54 tpy = tons per year; PM2.5 = fine particulate matter with a diameter of 2.5 micrometers or less; lb/day = pounds per day; PM10 = respirable particulate matter with a diameter of 10 micrometers or less; NOX = oxides of nitrogen; ROG = reactive organic gases. Source: Bay Area Air Quality Management District, CEQA Air Quality Guidelines, June 2010.

Localized CO Thresholds

The BAAQMD screening criteria provides that the proposed project would result in a less‐than‐ significant impact to localized CO concentrations if the following are met:

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• Project is consistent with an applicable congestion management program established by the county congestion management agency for designated roads or highways, regional transportation plan, and local congestion management agency plans. • The project traffic would not increase traffic volumes at affected intersections to more than 44,000 vehicles per hour. • The project traffic would not increase traffic volumes at affected intersections to more than 24,000 vehicles per hour where vertical and/or horizontal mixing is substantially limited (e.g., tunnel, parking garage, bridge underpass, natural or urban street canyon, below‐grade roadway).

If none of the above criteria are met, then the project would require a quantitative analysis that would compare emissions to the CAAQS.

Health Risk Screening Thresholds

The BAAQMD has developed methods whereby local community risk and hazard impacts from projects for both new sources and new receptors can be determined based on comparison with applicable thresholds of significance and screening criteria and (2) to recommend mitigation measures for these impacts. The screening methods are provided in the BAAQMD guidance document entitled Recommended Methods for Screening and Modeling Local Risks and Hazards (May 2010). The BAAQMD guidance provides screening tables to determine whether emissions would create a significant health hazard impact based on project size and receptor distance. Additionally, the BAAQMD recommends that all toxic sources are identified within a 1,000 foot radius of the project site to determine any risk and health hazards. It is noted that the BAAQMD has revised the effective date for the risk and hazards thresholds for new receptors from January 1, 2011 to May 1, 2011 to allow lead agencies to become fully prepared to implement the risk and hazards thresholds.

GREENHOUSE GAS EMISSIONS THRESHOLDS

Under CEQA, the BAAQMD is a commenting responsible agency on air quality and GHG emissions within its jurisdiction or impacting its jurisdiction. The BAAQMD’s approach to developing a threshold of significance for GHG emissions is to identify the emissions level for which a project would not be expected to substantially conflict with existing California legislation adopted to reduce statewide GHG emissions needed to move us towards climate stabilization. If a project would generate GHG emissions above the threshold level, it would be considered to contribute substantially to a cumulative impact, and would be considered significant.

Stationary‐source projects include land uses that would accommodate processes and equipment that emit GHG emissions and would require an Air District permit to operate. If annual emissions of operational‐related GHGs exceed these levels, the proposed project would result in a cumulatively considerable contribution of GHG emissions and a cumulatively significant

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impact to global climate change. Table 5, BAAQMD GHG Thresholds presents the June 2010 adopted project‐level thresholds for GHG emissions.

Table 5 BAAQMD GHG Thresholds

Project Type Construction-Related Operational-Related Compliance with Qualified Climate Action Plan OR Projects other than Stationary Sources1 None 1,100 MTCO2eq/yr OR 4.6 MTCO2eq/SP2/yr Stationary Sources1 None 10,000 MTCO2eq/yr MTCO2eq/yr = metric tons of carbon dioxide equivalent per year Notes: 1: According to the BAAQMD CEQA Guidelines, a stationary source project is one that includes land uses that would accommodate processes and equipment that emit GHG emissions and would require a BAAQMD permit to operate. Projects other than stationary sources are land use development projects including residential, commercial, industrial, and public uses that do not require a BAAQMD permit to operate. 2: SP = service population (residents + employees) Source: Bay Area Air Quality Management District, CEQA Air Quality Guidelines, June 2010.

The BAAQMD does not have an adopted threshold of significance for construction‐related GHG emissions. However, the BAAQMD CEQA Air Quality Guidelines recommend quantification and disclosure of construction GHG emissions. The BAAQMD also recommends that the Lead Agency should make a determination on the significance of these construction generated GHG emission impacts in relation to meeting AB 32 GHG reduction goals, as required by the Public Resources Code, Section 21082.2. The Lead Agency is encouraged to incorporate best management practices to reduce GHG emissions during construction, as feasible and applicable.

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5.0 POTENTIAL AIR QUALITY AND GREENHOUSE GAS IMPACTS

CEQA THRESHOLDS

The environmental analysis in this section is patterned after the Initial Study Checklist recommended by the CEQA Guidelines, as amended. The issues presented in the Initial Study Checklist have been utilized as thresholds of significance in this section. Accordingly, a project may create a significant environmental impact if it causes one or more of the following to occur:

• Conflict with or obstruct implementation of the applicable air quality plan (refer to Impact Statement AQ‐1);

• Violate any air quality standard or contribute substantially to an existing or projected air quality violation (refer to Impact Statement AQ‐2);

• Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in nonattainment under an applicable Federal or State ambient air quality standard (including releasing emissions that exceed quantitative thresholds for O3 precursors) (refer to Impact Statement AQ‐3);

• Expose sensitive receptors to substantial pollutant concentrations (refer to Impact Statement AQ‐4);

• Create objectionable odors affecting a substantial number of people (refer to Impact Statement AQ‐5);

• Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment (refer to Impact Statement GHG‐1); and/or

• Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases (refer to Impact Statement GHG‐2).

Based on these standards and thresholds, the effects of the proposed project have been categorized as either a “less than significant impact” or a “potentially significant impact.” Mitigation measures are recommended for potentially significant impacts.

AQ‐1 CONFLICT WITH OR OBSTRUCT IMPLEMENTATION OF THE APPLICABLE AIR QUALITY PLAN?

Level of Significance Before Mitigation: Potentially Significant.

Scenario 1

The most recently adopted air quality plan in the Basin is the 2010 Bay Area Clean Air Plan (Clean Air Plan). This Clean Air Plan outlines how the San Francisco Bay Area will attain air quality standards, reduce population exposure and protect public health, and reduce GHG emissions.

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Scenario 1 proposes to remove and replace existing buildings (which currently total 250,000 s.f.) with 550,000 s.f. of office development (net total of 300,000 s.f.).

The Town’s General Plan designates the project site as Office/Professional and Light Industrial. The project would not conflict with the Town’s General Plan designations. The Office/Professional designation allows for professional and business offices, and the Light Industrial designation allows for large‐scale office development and well‐controlled research and development uses. As indicated in the analysis below, the proposed project would not result in significant long‐term operational air quality impacts regarding ROG, NOX, and PM emissions. Additionally, the project would incorporate transportation demand management features (included as project design features required by Mitigation Measure GHG‐1) that would be consistent with those of the Clean Air Plan. Construction‐related air quality impacts would be reduced to less than significant levels with implementation of Mitigation Measures AQ‐1 through AQ‐3. Therefore, the project would not hinder the region’s ability achieve compliance with the State ozone standards. Therefore, the proposed project would not conflict with the Clean Air Plan, and impacts would be less than significant.

Scenario 2

Similar to Scenario 1, the development of Scenario 2 would result in commercial office space at the project site. Scenario 2 would not conflict with the Town’s General Plan designations. Scenario 2 would not result in significant long‐term operational air quality impacts regarding ROG, NOX, and PM emissions. Additionally, the project would incorporate transportation demand management features (included as project design features required by Mitigation Measure GHG‐1) that would be consistent with those of the Clean Air Plan. Construction‐ related air quality impacts would be reduced to less than significant levels with implementation of Mitigation Measures AQ‐1 through AQ‐3. Therefore, as with Scenario 1, Scenario 2 would not conflict with the Clean Air Plan, and impacts would be less than significant.

Scenario 3

The development of Scenario 3 would result in less commercial office space than considered under Scenario 1. However, Scenario 3 also includes up to 516 high‐density units. Scenario 3 would not conflict with the Town’s General Plan designations. Also, Scenario 3 would not result in significant long‐term operational air quality impacts regarding ROG, NOX, and PM emissions. Construction‐related air quality impacts would be reduced to less than significant levels with implementation of Mitigation Measures AQ‐1 through AQ‐3. Therefore, as with Scenario 1, Scenario 3 would not conflict with the Clean Air Plan, and impacts would be less than significant.

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Scenario 4

The development of Scenario 4 would result in a similar development plan as Scenario 3; however, Scenario 4 proposes 600 senior units instead of 516 high‐density units. Scenario 4 would not conflict with the Town’s General Plan designations. Also, Scenario 4 would not result in significant long‐term operational air quality impacts regarding ROG, NOX, and PM emissions. Construction‐related air quality impacts would be reduced to less than significant levels with implementation of Mitigation Measures AQ‐1 through AQ‐3. Therefore, as with Scenario 1, Scenario 4 would not conflict with the Clean Air Plan, and impacts would be less than significant.

Mitigation Measures: Refer to Mitigation Measures AQ‐1 through AQ‐3, GHG‐1.

Level of Significance After Mitigation: Less Than Significant.

AQ‐2 VIOLATE ANY AIR QUALITY STANDARD OR CONTRIBUTE SUBSTANTIALLY TO AN EXISTING OR PROJECTED AIR QUALITY VIOLATION?

Level of Significance Before Mitigation: Potentially Significant.

SHORT‐TERM EMISSIONS

Scenario 1

Short‐term air quality impacts are predicted to occur during demolition, grading and construction operations associated with implementation of the proposed project. Temporary air emissions would result from the following activities:

• Particulate (fugitive dust) emissions from demolition, grading, and building construction; and • Exhaust emissions from the construction equipment and the motor vehicles of the construction crew.

Potential odors could arise from the diesel construction equipment used on‐site, as well as from architectural coatings and asphalt off‐gassing. Odors generated during construction activities would be temporary and are not considered to be a significant impact. Emissions produced during demolition, grading, and construction activities are short‐term, as they would exist only during construction.

Construction activities for the proposed project would include demolition, grading, trenching, construction of buildings, paving, and architectural coatings. Project construction would result in approximately 1.61 acres of site grading per day with up to 2,730c cubi yards per day of cut and fill during mass grading. Grading for the site would require the export of 95,500 cubic

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and fill during mass grading. Grading for the site would require the export of 95,500 cubic yards. The analysis of daily construction emissions has been prepared utilizing the URBEMIS 2007 computer model; refer to Appendix A, Air Modeling Data. Table 6, Construction Emissions, presents the anticipated daily short‐term construction emissions. Where emissions exceed the BAAQMD thresholds, the Basic mitigation measures required by the BAAQMD have been analyzed and quantified. Should emissions still exceed the BAAQMD thresholds, enhanced mitigation measures have been evaluated and quantified.

Table 6 Construction Emissions

Emissions (lbs/day) Emissions Source ROG NOX PM10 PM2.5 Year 1 Total Unmitigated Emissions 8.20 105.08 179.99 40.54 BAAQMD Threshold 54 54 821 541 Unmitigated Emissions Exceed BAAQMD Threshold? No Yes Yes No Total Basic Mitigated Emissions1 8.20 105.08 32.23 9.68 BAAQMD Threshold 54 54 821 541 Basic Mitigated Emissions Exceed No Yes No No BAAQMD Threshold? Total Enhanced Mitigated Emissions2,3 4.82 53.85 30.07 7.88 Enhanced Mitigated Emissions Exceed BAAQMD No No No No Threshold? Year 24 Total Unmitigated Emissions 85.52 58.07 261.96 57.38 BAAQMD Threshold 54 54 821 541 Unmitigated Emissions Exceed BAAQMD Threshold? Yes Yes Yes Yes Total Basic Mitigated Emissions1 85.52 58.07 44.83 12.03 BAAQMD Threshold 54 54 821 541 Basic Mitigated Emissions Exceed Yes Yes No No BAAQMD Threshold? Total Enhanced Mitigated Emissions 2,3 52.57 53.10 43.01 10.54 Enhanced Mitigated Emissions Exceed BAAQMD No No No No Threshold? Year 3 Total Unmitigated Emissions 85.26 60.21 94.95 21.79 BAAQMD Threshold 54 54 821 541 Unmitigated Emissions Exceed BAAQMD Threshold? Yes Yes Yes No Total Basic Mitigated Emissions1 85.26 60.21 16.80 5.07 BAAQMD Threshold 54 54 821 541 Basic Mitigated Emissions Exceed Yes Yes No No BAAQMD Threshold? Total Enhanced Mitigated Emissions 2,3 52.30 44.73 16.80 5.07 Enhanced Mitigated Emissions Exceed BAAQMD No No No No Threshold?

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Table 6 (Continued) Construction Emissions

Emissions (lbs/day) Emissions Source ROG NOX3 PM10 PM2.5 Year 4 Total Unmitigated Emissions 85.00 78.03 205.45 45.07 BAAQMD Threshold 54 54 821 541 Unmitigated Emissions Exceed BAAQMD Threshold? Yes Yes Yes No Total Basic Mitigated Emissions1 85.00 78.03 35.33 9.54 BAAQMD Threshold 54 54 821 541 Basic Mitigated Emissions Exceed Yes Yes No No BAAQMD Threshold? Total Enhanced Mitigated Emissions 2,3 52.05 53.83 34.26 8.68 Enhanced Mitigated Emissions Exceed BAAQMD No No No No Threshold? Year 5 Total Unmitigated Emissions 5.32 30.60 79.47 17.52 BAAQMD Threshold 54 54 821 541 Unmitigated Emissions Exceed BAAQMD Threshold? No No No No Total Basic Mitigated Emissions1 5.32 30.60 13.46 3.58 BAAQMD Threshold 54 54 821 541 Basic Mitigated Emissions Exceed No No No No BAAQMD Threshold? Total Enhanced Mitigated Emissions 2,3 5.32 30.60 13.46 3.58 Enhanced Mitigated Emissions Exceed BAAQMD No No No No Threshold? ROG = reactive organic gases; NOX = nitrogen oxides; PM10 = particulate matter less than 10 microns; PM2.5 = particulate matter less than 2.5 microns; lbs/day = pounds per day Notes: 1. The reduction/credits for construction emission mitigations are based on mitigation included in the URBEMIS2007 version 9.2.4 computer model and as typically required by the BAAQMD (Basic Control Measures and Regulation 6: Particulate Matter and Visible Emissions). The mitigation includes the following: replace ground cover on disturbed areas quickly, water exposed surfaces twice daily, and proper loading/unloading of mobile and other construction equipment. 2. Enhanced Mitigation involves compliance with an additional control measure requiring the use of low volatile organic compound (VOC) coatings (compliance with BAAQMD Regulation 8, Rule 3; Architectural Coatings). Specifically, the VOX content in coatings shall not exceed 150 grams per liter. 3. Enhanced Mitigation accounts for the VMT reduction during soil hauling, as required by Mitigation Measure AQ-3. 4. Phase 1 and Phase 2 would have construction activities occurring in Year 2. However, the construction activities in each phase would not overlap. Therefore, the maximum daily emissions occurring in Year 2 are reported. Refer to Appendix A, Air Modeling Data, for assumptions used in this analysis.

Fugitive Dust Emissions

Construction activities are a source of fugitive dust (also known as PM10 and PM2.5) emissions that may have a substantial, temporary impact on local air quality. Fugitive dust is often a nuisance to those living and working within the vicinity of the project site. Fugitive dust emissions are associated with demolition, land clearing, ground evacuation, cut and fill operations, and truck travel on unpaved roadways. Fugitive dust emissions also vary substantially from day to day, depending on the level of activity, the specific operations, and weather conditions.

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PM10 and PM2.5 are both emitted during construction activities and as a result of wind erosion over exposed soil surfaces. Clearing and grading activities comprise the major sources of construction dust emissions, but traffic and general disturbance of the soil also generates significant dust emissions. PM10 and PM2.5 emissions can vary greatly depending on the level of activity, the specific operations taking place, the equipment being operated, local soils, weather conditions, and other factors making quantification difficult. The highest potential for construction dust impacts would occur during the dry late spring, summer, and early fall months when soils are dry. Despite this variability in emissions, experience has shown that there are a number of feasible control measures that can be reasonably implemented to significantly reduce PM10 and PM2.5 emissions from construction activities. The BAAQMD recommends the implementation of all Basic Construction Mitigation Measures, whether or not construction‐related emissions exceed applicable significance thresholds. As shown in Table 6, above, unmitigated fugitive dust emissions would exceed the BAAQMD thresholds for PM10 and PM2.5. However, implementation of the BAAQMD’s Basic Construction Mitigation Measures would be required for the proposed project; refer to Mitigation Measure AQ‐1. Implementation of the BAAQMD Basic Construction Mitigation (included in Mitigation Measure AQ‐1) would reduce fugitive dust impacts to a less than significant level.

ROG Emissions

In addition to gaseous and particulate emissions, the application of asphalt and surface coatings creates ROG emissions, which are O3 precursors. In accordance with the methodology prescribed by the BAAQMD, the ROG emissions associated with paving have been quantified with the URBEMIS 2007 model. In addition, based upon the size of the buildings, architectural coatings were also quantified within the URBEMIS 2007 model.

The highest concentration of ROG emissions would be generated during the application of architectural coatings towards the end of construction. As required by law, all architectural coatings for the proposed project structures would comply with BAAQMD Regulation 8, Rule 3: Architectural Coating. Regulation 8, Rule 3 provides specifications on painting practices as well as regulates the ROG content of paint. As indicated in Table 6, the project construction would result in an exceedance of ROG emissions and compliance with BAAQMD Additional Control Measures to reduce ROG emissions is required. Specifically, the VOC content for coatings shall not exceed 150 grams per liter. Therefore, implementation of Mitigation Measure AQ‐2 (compliance with BAAQMD Additional Control Measures [i.e., Regulation 8, Rule 3]) would be required to reduce ROG emissions from architectural coatings. With implementation of Mitigation Measures AQ‐2, impacts would be reduced to a less than significant level.

Construction Equipment and Worker Vehicle Exhaust

Exhaust emission factors for typical diesel‐powered heavy equipment are based on the URBEMIS 2007 program defaults. Variables factored into estimating the total construction emissions include: level of activity, length of construction period, number of pieces/types of equipment in use, site characteristics, weather conditions, number of construction personnel,

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and the amount of materials to be transported on‐site or off‐site. A listing of mobile and stationary construction equipment is included in Appendix A, Air Modeling Data.

Exhaust emissions from construction activities include emissions associated with the transport of machinery and supplies to and from the project site, emissions produced on‐site as the equipment is used, and emissions from trucks transporting materials to and from the site. Emitted pollutants would include ROG, NOX, PM10, and PM2.5. Thresholds for ROG, PM10, and PM2.5 would not be exceeded by exhaust emissions (note that exhaust emissions are included in total ROG, PM10, and PM2.5 emissions in Table 6), as the majority of these emissions are attributed to fugitive dust and architectural coatings. However, due to the amount of soil hauling required for the proposed project, NOX thresholds would be exceeded in all three construction phases. Therefore, implementation of Mitigation Measure AQ‐3 would limit the vehicle miles traveled (VMT) from soil hauling trucks during grading to ensure NOX emissions would not exceed the BAAQMD thresholds. As indicated in Table 6, NOX emissions would be less than significant with implementation of Mitigation Measure AQ‐3.

Naturally Occurring Asbestos

Pursuant to guidance issued by the Governor’s Office of Planning and Research, State Clearinghouse, Lead Agencies are encouraged to analyze potential impacts related to naturally occurring asbestos. Naturally occurring asbestos can be released from serpentinite and ultramafic rocks when the rock is broken or crushed. At the point of release, the asbestos fibers may become airborne, causing air quality and human health hazards. These rocks have been commonly used for unpaved gravel roads, landscaping, fill projects, and other improvement projects in some localities. Asbestos may be released to the atmosphere due to vehicular traffic on unpaved roads, during grading for development projects, and at quarry operations.

Serpentinite and/or ultramafic rock are known to be present in 44 of Californiaʹs 58 counties. These rocks are particularly abundant in the counties associated with the Sierra Nevada foothills, the Klamath Mountains, and Coast Ranges. According to the Department of Conservation Division of Mines and Geology, A General Location Guide for Ultramafic Rocks in California – Areas More Likely to Contain Naturally Occurring Asbestos Report (August 2000), the project site is not located in an area where naturally occurring asbestos is likely to be present. Therefore, impacts are less than significant in this regard.

Structural Asbestos

Asbestos is a strong, incombustible, and corrosion resistant material, which was used in many commercial products since prior to the 1940s and up until the early 1970s. If inhaled, asbestos fibers can result in serious health problems. Asbestos Containing Materials (ACMs) are building materials containing more than one percent asbestos (some state and regional regulators impose a one‐tenth of one percent threshold). Multiple on‐site structures requiring demolition exist within the boundaries of the project site; therefore, the potential for ACMs to be found on‐site is considered likely. The BAAQMD regulates the demolition of buildings and

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structures containing asbestos. On‐site demolition activities would be conducted in accordance with BAAQMD Regulation 11, Rule 2 (Asbestos Demolition, Renovation and Manufacturing).

Total Daily Construction Emissions

In accordance with the BAAQMD Guidelines, URBEMIS 2007 was utilized to model construction emissions for ROG, NOX, PM10, and PM2.5. Construction would occur over a five year period, with the greatest amount of fugitive dust emissions being generated during the initial stages of each construction phase. Additionally, the greatest amount of ROG emissions would typically occur during the final stages of each construction phase due to the application of architectural coatings.

The URBEMIS 2007 model allows the user to input mitigation measures such as watering the construction area to limit fugitive dust in the project area. Mitigation measures inputted within the URBEMIS 2007 model allow for certain reduction credits and result in a decrease of pollutant emissions. Reduction credits are based upon various land use and transportation studies and were programmed within the URBEMIS 2007 model.13 As indicated in Table 6, the URBEMIS 2007 model calculates the reduction associated with recommended mitigation measures for ROG. With the implementation of Mitigation Measures AQ‐1 through AQ‐3 construction‐related impacts would be less than significant.

LONG‐TERM EMISSIONS

Operational emissions generated by both stationary and mobile sources would result from normal daily activities on the project site after occupation (i.e., increased loads of O3, PM10, and CO). Stationary area source emissions would be generated by the consumption of natural gas for space and water heating devices, the operation of landscape maintenance equipment, and the use of consumer products. Mobile emissions would be generated by the motor vehicles traveling to and from the project site. Emissions associated with each of these sources were calculated and are discussed below.

Scenario 1

Mobile Source Emissions

Mobile sources are emissions from motor vehicles, including tailpipe and evaporative emissions. Depending upon the pollutant being discussed, the potential air quality impact may be of either regional or local concern. For example, ROG, NOX, SOX, PM10, and PM2.5 are all pollutants of regional concern (NOX and ROG react with sunlight to form O3 [photochemical smog], and wind currents readily transport SOX, PM10, and PM2.5). However, CO tends to be a localized pollutant, dispersing rapidly at the source.

13 Jones and Stokes Associates, Software User’s Guide: URBEMIS2007 for Windows User’s Guide Appendices, November 2007.

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Project‐generated vehicle emissions have been estimated using the URBEMIS 2007 model. This model predicts ROG, NOX, PM10, and PM2.5 emissions from motor vehicle traffic associated with new or modified land uses; refer to Appendix A, Air Modeling Data. According to the project’s Traffic Impact Analysis, the proposed project would generate a net 3,126 daily trips. Table 7, Long‐Term Operational Air Emissions presents the anticipated mobile source emissions. As shown in Table 7, emissions generated by vehicle traffic associated with the proposed project would not exceed established BAAQMD thresholds for ROG, NOX, and PM10. Therefore, impacts from vehicle emissions would be less than significant.

Table 7 Long‐Term Operational Air Emissions

Pollutant (lbs/day)1 Project Emissions ROG NOX PM10 PM2.5 Area Source Emissions 2.03 2.02 0.01 0.01 Vehicle Emissions 15.90 17.19 44.97 8.54 Total Unmitigated Operational Emissions 17.93 19.21 44.98 8.55 BAAQMD Threshold 54 54 82 54 Unmitigated Emissions Exceed BAAQMD Threshold? No No No No (Significant Impact?)

ROG = reactive organic gases; NOX = nitrogen oxides; CO = carbon monoxide; SO2 = sulfur dioxide; PM10 = particulate matter; less than 10 microns; PM2.5 = particulate matter; less than 2.5 microns; lbs/day = pounds per day. Notes: 1. Based on URBEMIS 2007 modeling results, worst-case seasonal emissions for area and mobile emissions have been modeled.

Area Source Emissions

Area source emissions would be generated due to an increased demand for electrical energy and natural gas with the development of the proposed project. This assumption is based on the supposition that those power plants supplying electricity to the site are utilizing fossil fuels. Electric power generating plants are distributed throughout the Basin and western United States, and their emissions contribute to the total regional pollutant burden. The primary use of natural gas by the proposed land uses would be for combustion to produce space heating, water heating, other miscellaneous heating, or air conditioning, consumer products, and landscaping. As indicated in Table 7, area source emissions from the proposed project would not exceed BAAQMD thresholds. If stationary sources, such as backup generators, are installed on‐site, they would be required to obtain the applicable permits from BAAQMD for operation of such equipment. The BAAQMD is responsible for issuing permits for the operation of stationary sources in order to reduce air pollution, and to attain and maintain the national and California ambient air quality standards in the Basin. Newly modified or constructed stationary sources subject to BAAQMD permitting may be required to implement Best Available Control Technology (BACT), which may include the installation of emissions control equipment or the implementation of administrative practices that would result in the lowest achievable emission rate. Backup generators would be used only in emergency situations, and would not contribute

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a substantial amount of emissions capable of exceeding BAAQMD thresholds. Thus, impacts from area source emissions would be less than significant.

Scenario 2

The development of Scenario 2 would result in less commercial office space than considered under Scenario 1. Construction related air quality impacts would be reduced due to the reduction in required construction activities. However, Mitigation Measures AQ‐1 through AQ‐3 would still be required to ensure construction air emissions are reduced to less than the BAAQMD thresholds. It is noted that Mitigation Measure AQ‐1 is required by the BAAQMD, and Mitigation Measures AQ‐2 and AQ‐3 have been formulated based upon the “worst case” construction scenario (Scenario 1). Therefore, although emissions are expected to be less under Scenario 2, implementation of Mitigation Measures AQ‐2 and AQ‐3 would ensure emissions are reduced below BAAQMD thresholds. As with Scenario 1, impacts would be less than significant with the incorporation of the recommended construction mitigation.

At full development, Scenario 2 would result in 948 daily net new trips (as opposed to 3,126 for Scenario 1). Therefore, as the majority of operational emissions are attributed to mobile sources, Scenario 2 would result in fewer emissions than Scenario 1 (which do not exceed the BAAQMD thresholds). As with Scenario 1, operational impacts under Scenario 2 would be less than significant.

Scenario 3

At full development, Scenario 3 would result in 2,000 daily net new trips (as opposed to 3,126 for Scenario 1). Therefore, as the majority of operational emissions are attributed to mobile sources, Scenario 3 would result in fewer emissions than Scenario 1 (which do not exceed the BAAQMD thresholds). As with Scenario 1, operational impacts under Scenario 3 would be less than significant.

Scenario 4

The development of Scenario 4 would result in a similar development plan as envisioned within Scenario 3. The primary difference would be that Scenario 4 proposes 600 senior units instead of 516 high‐density units. Construction related air quality impacts would be similar to that presented for Scenario 3. Therefore, as with Scenario 1, construction air quality impacts would be less than significant with the incorporation of Mitigation Measures AQ‐1 through AQ‐3.

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At full development, Scenario 4 would result in 1,442 daily net new trips (as opposed to 3,126 for Scenario 1). Therefore, as the majority of operational emissions are attributed to mobile sources, Scenario 4 would result in fewer emissions than Scenario 1 (which do not exceed the BAAQMD thresholds). As with Scenario 1, operational impacts under Scenario 4 would be less than significant.

Mitigation Measures:

AQ‐1 Prior to issuance of any Grading Permit, the Town Engineer and the Chief Building Official shall confirm that the Grading Plan, Building Plans, and specifications stipulate that, in compliance with the BAAQMD CEQA Air Quality Guidelines, the following basic construction mitigation measures shall be implemented:

• All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times per day. • All haul trucks transporting soil, sand, or other loose material off‐site shall be covered. • All visible mud or dirt track‐out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited. • All vehicle speeds on unpaved roads shall be limited to 15 mph. • All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. • Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to five minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of California Code of Regulations [CCR]). Clear signage shall be provided for construction workers at all access points. • All construction equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation. • Post a publicly visible sign with the telephone number and person to contact at the Town regarding dust complaints. This person shall respond and take corrective action within 48 hours. The BAAQMD’s phone number shall also be visible to ensure compliance with applicable regulations.

AQ‐2 Prior to issuance of any Grading Permit, the Town Engineer and the Chief Building Official shall confirm that the Grading Plan, Building Plans, and specifications include the following BAAQMD additional construction mitigation measure:

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• Use low volatile organic compounds (VOC) (i.e., reactive organic gases [ROG]) coatings beyond the BAAQMD requirements (i.e., Regulation 8, Rule 3: Architectural Coatings). • VOC content of architectural coatings shall not exceed 150 grams VOC per liter of coating.

AQ‐3 The following limitations shall be adhered to during soil hauling activities (during mass and fine grading) for each construction phase in order to ensure NOX emissions would be reduced to less than significant levels:

• Phase 1: Trucks hauling soil during Phase 1 shall not travel more than 23 miles roundtrip. Vehicle miles traveled (VMT) during mass grading shall not exceed 1,416; VMT during fine grading shall not exceed 425. • Phase 2: Trucks hauling gsoil durin Phase 2 shall not travel more than 26 miles roundtrip. VMT during mass grading shall not exceed 1,629; VMT during fine grading shall not exceed 671. • Phase 3: Trucks hauling soil during Phase 3 shall not travel more than 36 miles roundtrip. VMT during mass grading shall not exceed 2,318; VMT during fine grading shall not exceed 625.

VMT’s shall be logged daily and supplied to the Town Engineer and the Chief Building Official on a monthly basis. These limitations shall be stipulated in construction bids, plans, and specifications.

Level of Significance After Mitigation: Less Than Significant.

AQ‐3 RESULT IN A CUMULATIVELY CONSIDERABLE NET INCREASE OF ANY CRITERIA POLLUTANT FOR WHICH THE AIR BASIN IS NONATTAINMENT UNDER AN APPLICABLE FEDERAL OR STATE AMBIENT AIR QUALITY STANDARD (INCLUDING RELEASING EMISSIONS, WHICH EXCEED QUANTITATIVE THRESHOLDS FOR OZONE PRECURSORS)?

Level of Significance Before Mitigation: Potentially Significant.

Scenario 1

CUMULATIVE SHORT‐TERM EMISSIONS

As discussed above, the project’s construction‐related emissions would not exceed any of the BAAQMD thresholds of significance with implementation of Mitigation Measures AQ‐1 through AQ‐3. The BAAQMD CEQA Air Quality Guidelines do not include significance thresholds for cumulative construction emissions. However, due to eth temporary nature of

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construction emissions, if the project’s emissions would be less than significant based on the project‐level thresholds of significance, it can be expected that the project would not be a cumulatively considerable contributor to a significant cumulative impact. In addition, the project would be required to implement the proposed BAAQMD Basic Construction Mitigation Measures (Mitigation Measure AQ‐1), which are recommended for all projects whether or not construction‐related emissions exceed the thresholds of significance. The project would also implement an Additional Control Mitigation Measure (AQ‐2) to reduce VOC/ROG emissions from architectural coatings. NOX emissions are reduced by Mitigation Measure AQ‐3. Therefore, construction emissions associated with the proposed project would not result in a cumulatively considerable contribution to cumulative air quality impacts.

CUMULATIVE LONG‐TERM EMISSIONS

The BAAQMD CEQA Air Quality Guidelines do not include separate significance thresholds for cumulative operational emissions. The BAAQMD CEQA Air Quality Guidelines note that the nature of air emissions is largely a cumulative impact. As a result, no single project is sufficient in size to, by itself, result in nonattainment of ambient air quality standards. Instead, a project’s individual emissions contribute to existing cumulatively significant adverse air quality impacts. The BAAQMD developed the operational thresholds of significance based on the level above which a project’s individual emissions would result in a cumulatively considerable contribution to the Basin’s existing air quality conditions. Therefore, a project that exceeds the BAAQMD operational thresholds would also be a cumulatively considerable contributor to a significant cumulative impact. As depicted in Table 7, above, the proposed project’s operational emissions would not exceed BAAQMD thresholds for ROG, NOX, and PM. Therefore, the impact of the proposed project, in conjunction with related cumulative projects would not be cumulatively considerable. Impacts in this regard would be less than significant.

Scenario 1

With regards to cumulative health risks and hazards (further discuss below under Impact Statement AQ‐4), the project would be located within 1,000 feet of SR‐85. However, no other sources of air toxics are located within the 1,000‐foot screening distance of the project site.

Further, Scenario 1 proposes all commercial uses, which the BAAQMD does not consider to be sensitive receptors. Additionally, Scenario 1 does not propose any uses that would be considered a significant source of air toxics. Therefore, the project would not be cumulatively considerable and a less than significant impact would occur.

Scenario 2

As discussed above, Scenario 2 would result in fewer construction‐related emissions than Scenario 1. Implementation of Mitigation Measures AQ‐1 through AQ‐3 would ensure Scenario 2 would not exceed any of the BAAQMD thresholds of significance for construction. Additionally, operational emissions under Scenario 2 would be less than those of Scenario 1

Air Quality & Greenhouse Gas Assessment 42 March 2011 Albright Way Development Project

(which do not exceed BAAQMD thresholds). Therefore, Scenario 2 would not result in a cumulatively considerable contribution to a significant cumulative impact.

With regards to cumulative health risks and hazards, although the project would be located within 1,000 feet of SR‐85, Scenario 2 proposes all commercial uses, which the BAAQMD does not consider to be sensitive receptors. Scenario 2 does not propose any uses that would be considered a significant source of air toxics. Therefore, the project would not be cumulatively considerable and a less than significant impact would occur.

Scenario 3

As discussed above, Scenario 3 would result in fewer construction‐related emissions than Scenario 1. Implementation of Mitigation Measures AQ‐1 through AQ‐3 would ensure Scenario 3 would not exceed any of the BAAQMD thresholds of significance for construction. Additionally, operational emissions under Scenario 3 would be less than those of Scenario 1 (which do not exceed BAAQMD thresholds). Therefore, Scenario 3 would not result in a cumulatively considerable contribution to a significant cumulative impact.

With regards to cumulative health risks and hazards (further discuss below under Impact Statement AQ‐4), the project would be located within 1,000 feet of SR‐85. Scenario 3 proposes commercial uses as well as high‐density residential units, which the BAAQMD considers to be sensitive receptors. Detailed modeling (which included cumulative traffic conditions) indicated that residents on‐site within 261 feet of SR‐85 would be subject to health risk. With incorporation of Mitigation Measure AQ‐5, on‐site residents would not be subject to air toxics from SR‐85 (refer to Impact Statement AQ‐4). No other sources of air toxics are located within the 1,000‐foot screening distance of the project site. Additionally, Scenario 3 does not propose any uses that would be considered a significant source of air toxics. Therefore, the project would not be cumulatively considerable and a less than significant impact would occur.

Scenario 4

As discussed above, Scenario 4 would result in fewer construction‐related emissions than Scenario 1. Implementation of Mitigation Measures AQ‐1 through AQ‐3 would ensure Scenario 4 would not exceed any of the BAAQMD thresholds of significance for construction. Additionally, operational emissions under Scenario 4 would be less than those of Scenario 1 (which do not exceed BAAQMD thresholds). Therefore, Scenario 4 would not result in a cumulatively considerable contribution to a significant cumulative impact.

With regards to cumulative health risks and hazards (further discuss below under Impact Statement AQ‐4), the project would be located within 1,000 feet of SR‐85. Similar to Scenario 3, Scenario 4 proposes commercial uses as well as senior living units, which the BAAQMD considers to be sensitive receptors. Detailed modeling (which included cumulative traffic conditions) indicated that residents on‐site within 261 feet of SR‐85 would be subject to health risk. With incorporation of Mitigation Measure AQ‐5, on‐site residents would not be subject to

Air Quality & Greenhouse Gas Assessment 43 March 2011 Albright Way Development Project

air toxics from SR‐85 (refer to Impact Statement AQ‐4). No other sources of air toxics are located within the 1,000‐foot screening distance of the project site. Additionally, Scenario 4 does not propose any uses that would be considered a significant source of air toxics. Therefore, the project would not be cumulatively considerable and a less than significant impact would occur.

Mitigation Measures: Refer to Mitigation Measures AQ‐1 through AQ‐3 and AQ‐5.

Level of Significance After Mitigation: Less Than Significant.

AQ‐4 EXPOSE SENSITIVE RECEPTORS TO SUBSTANTIAL POLLUTANT CONCENTRATIONS?

Level of Significance Before Mitigation: Potentially Significant.

Sensitive receptors are defined as facilities or land uses that include members of the population that are particularly sensitive to the effects of air pollutants, such as children, the elderly, and people with illnesses. Examples of these sensitive receptors are residences, schools, hospitals, and daycare centers. CARB has identified the following groups of individuals as the most likely to be affected by air pollution: the elderly over 65, children under 14, athletes, and persons with cardiovascular and chronic respiratory diseases such as asthma, emphysema, and bronchitis. Sensitive receptors within the immediate vicinity of the project site are the existing residences to the east, south, and west; also refer to Table 2. Localized impacts from project construction and operations are analyzed below.

Scenario 1

Localized Carbon Monoxide Hotspots

The Basin is designated as attainment for carbon monoxide (CO). As indicated in the BAAQMD CEQA Air Quality Guidelines, emissions and ambient concentrations of CO have decreased dramatically in the Basin with the introduction of the catalytic converter in 1975. No exceedances of the CAAQS or NAAQS for CO have been recorded at nearby monitoring stations since 1991.14 As a result, the screening criteria in the BAAQMD CEQA Air Quality Guidelines note that that CO impacts may be determined to be less than significant if a project is consistent with the applicable congestion management plan (CMP) and would not increase traffic volumes at local intersections to more than 24,000 vehicles per hour for locations in heavily urban areas, where “urban canyons” formed by buildings tend to reduce air circulation.

The project’s Traffic Impact Analysis has determined that the unsignalized intersections of Winchester Boulevard/Albright Way and University Avenue/Lark Avenue would be impacted with project implementation. These intersections are expected to operate at unacceptable LOS E and F during peak hours under background conditions. The addition of project traffic would

14 Bay Area Air Quality Management District, BAAQMD CEQA Air Quality Guidelines (page 6‐1), June 2010.

Air Quality & Greenhouse Gas Assessment 44 March 2011 Albright Way Development Project

cause the intersections to degrade to LOS E and F during both peak hours with project implementation. The intersections also would meet signal warrants with the addition of project traffic, which constitutes a significant impact by the Town standards. Therefore, the Traffic Impact Analysis includes mitigation requiring the signalization of the Winchester Boulevard/Albright Way and University Avenue/Lark Avenue intersections to improve both intersections to LOS B. Additionally, the project would not violate the CMP criteria at any of the CMP intersections, as noted in the Traffic Impact Analysis. Therefore, the project would be consistent with the CMP. With implementation of the Traffic Impact Analysis mitigation, the project would not significantly increase the delay or LOS at the study intersections, and would not increase traffic volumes at local intersections to more than 24,000 vehicles per hour. Therefore, effects related to CO concentrations would be less than significant.

Construction Toxic Air Contaminants

Construction‐related activities could result in the generation of toxic air contaminants (TACs), specifically diesel particulate matter (DPM), from on‐road haul trucks and off‐road equipment exhaust emissions. Due to the variable nature of the proposed construction activity, the generation of TAC emissions would be temporary, especially considering the short amount of time such equipment is typically within an influential distance that would result in the exposure of sensitive receptors to substantial concentrations.

The project construction period would occur over three phases and would require various types of heavy equipment throughout each construction phase. Specifically, demolition activities would require tractors, dozers, and concrete/industrial saws. Grading activities would require tractors, graders, rubber tired dozers, and water trucks. Trenching activities would require excavators. Paving activities would include cement and mortar mixers, pavers, rollers, and other pieces of paving equipment. The building phase would require one crane, two forklifts, one tractor, three welders, and one generator set. As indicated in the URBEMIS 2007 model outputs (refer to Appendix A) for the proposed project, construction activities would generate a maximum of 2.41 pounds of diesel PM2.5 exhaust per day. Additionally, the project would implement the BAAQMD’s Basic Construction Mitigation Measures (Mitigation Measure AQ‐ 1), which would also reduce DPM exhaust emissions.

As noted above, the closest sensitive receptors are the residential uses adjacent to the project site to the south and east. However, construction equipment during project construction would move about the project site and would not be concentrated in one area or near one sensitive receptor for an excessive duration of time capable of causing health effects. Additionally, health risks are associated with longer‐term exposure periods of nine, 40, and 70 years, which do not correlate well with the temporary and highly variable nature of construction activities.15 Construction staging areas are generally planned to be concentrated toward the center of the project site. However, to ensure that sensitive uses in the vicinity of the project site are not exposed to substantial TACs, Mitigation Measure AQ‐4 would require the implementation of additional construction mitigation measures for off‐road equipment to reduce the exposure of

15 Bay Area Air Quality Management District, CEQA Air Quality Guidelines, June 2010.

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sensitive uses to TACs from construction emissions. The specific types of emission reduction features identified in Mitigation Measure AQ‐4 would be determined based on the acreage disturbed in a particular construction phase as well as the proximity of the construction activity to sensitive uses. With implementation of Mitigation Measures AQ‐1 and AQ‐4, impacts would be reduced to less than significant levels.

Risk and Health Hazards

It is noted that the BAAQMD has revised the effective date for the risk and hazards thresholds for new receptors from January 1, 2011 to May 1, 2011. However, the BAAQMD CEQA Air Quality Guidelines recommend that all toxic air contaminant (TAC) and particulate matter less than 2.5 microns (PM2.5) sources located within a 1,000 foot radius of the proposed project site be identified to determine any risk and health hazards. There are no stationary TAC and PM2.5 sources located within 1,000 feet of the project site.16 However, SR‐85 is located to the north of the project site with annual average daily traffic (AADT) of approximately 106,00017, which requires a risk and hazard screening analysis; refer to Exhibit 4, Phased Approach for Estimating Community Risks and Hazards.

The BAAQMD CEQA Air Quality Guidelines defines a receptor to be “a place where people live, play, or convalesce”. These types of receptors would include residences, schools, school yards, parks, daycare centers, nursing homes, and medical facilities. Scenario 1 consists of all office development, which the BAAQMD does not consider a sensitive receptor. Therefore, risk and health hazards from SR‐85 would be less than significant.

Scenario 2

The Winchester Boulevard/Albright Way and University Avenue/Lark Avenue intersections are expected to operate at an unacceptable LOS during both peak hours under background conditions and with implementation of Scenario 1. Scenario 2 would result in fewer daily trips than Scenario 1; however, it is anticipated that the intersection would stille decreas to LOS F and also meet signal warrants with the addition of project traffic, which constitutes a significant impact by the Town standards. Therefore, the mitigation requiring the signalization of the intersection with protected left‐turn phasing on Winchester Boulevard (which would improve the intersection LOS to LOS B) would also be required under Scenario 2. Therefore, effects related to CO concentrations would be less than significant under Scenario 2.

16 Bay Area Air Quality Management District, Stationary Source Risk & Hazard Analysis Tool, Santa Clara County Permitted Sources, January 27, 2011. http://www.baaqmd.gov/Divisions/Planning‐and‐Research/CEQA‐ GUIDELINES/Tools‐and‐Methodology.aspx 17 California Department of Transportation, Traffic and Vehicle Data Systems Unit, All Traffic Volumes on California State Highways, 2009. http://traffic‐counts.dot.ca.gov/2009all/Route82‐86i.htm.

Air Quality & Greenhouse Gas Assessment 46 March 2011 Project proposal submitted

NO FURTHER All roadways and YES PARTICULATE MATTER major sources > OR TAC ANALYSIS 1,000 feet away RECOMMENDED

Site and roadway Use screening tables that most characteristics closly matches project characteristics

Project PM2.5 and YES TAC risk and hazard < CEQA Threshold

NO NO FURTHER Site speci c Conduct site speci c air dispersion PARTICULATE MATTER inputs modeling and risk assessment OR TAC ANALYSIS RECOMMENDED

Project PM2.5 and YES TAC risk and hazard < CEQA Threshold

RECOMMEND APPROPRIATE MITIGATION MEASURES

Source: Bay Area Air Quality Management District, CEQA Air Quality Guidelines, June 2010

ALBRIGHT WAY DEVELOPMENT PROJECT AIR QUALITY AND GREENHOUSE GAS ASSESSMENT Phased Approach for Estimating Community Risks and Hazards 1/26/11 JN 40-100419-17194 MAS Exhibit 4 Albright Way Development Project

Similar to Scenario 1, construction equipment during Scenario 2 construction would move about the project site and would not be concentrated in one area or near one sensitive receptor long enough to cause health effects. Additionally, the project would implement the BAAQMD’s Basic Construction Mitigation Measures (Mitigation Measure AQ‐1), which would also reduce DPM exhaust emissions. To ensure that sensitive uses in the vicinity of the project site are not exposed to substantial TACs, Mitigation Measure AQ‐4 requires the implementation of additional construction mitigation measures for off‐road equipment to reduce the exposure of sensitive uses to TACs from construction emissions. The specific types of reduction features identified in Mitigation Measure AQ‐4 would be determined based on the acreage disturbed in a particular construction phase as well as the proximity of the construction activity to sensitive uses. Similar to Scenario 1, implementation of Mitigation Measures AQ‐1 and AQ‐4 would reduce impacts to less than significant levels.

As with Scenario 1, Scenario 2 consists of all office development, which the BAAQMD does not consider a sensitive receptor. Therefore, risk and health hazards from SR‐85 would be less than significant.

Scenario 3

The intersections of Winchester Boulevard/Albright Way and University Avenue/Lark Avenue are expected to operate at an unacceptable LOS during both peak hours under background conditions and with implementation of Scenario 1. Scenario 3 would result in fewer daily trips than Scenario 1; however, it is anticipated that the intersection would still decrease to LOS F and also meet signal warrants with the addition of project traffic, which constitutes a significant impact by the Town standards. Therefore, the mitigation within the Traffic Impact Analysis requiring the signalization of the intersection with protected left‐turn phasing on Winchester Boulevard (which would improve the intersection LOS to LOS B) would also be required under Scenario 3. Therefore, effects related to CO concentrations would be less than significant under Scenario 3.

Similar to Scenario 1, construction equipment during Scenario 3 construction would move about the project site and would not be concentrated in one area or near one sensitive receptor long enough to cause health effects. The project would implement the BAAQMD’s Basic Construction Mitigation Measures (Mitigation Measure AQ‐1), which would also reduce DPM exhaust emissions. To ensure that sensitive uses in the vicinity of the project site are not exposed to substantial TACs, Mitigation Measure AQ‐4 requires the implementation of additional construction mitigation measures for off‐road equipment to reduce the exposure of sensitive uses to TACs from construction emissions. The specific reduction features identified in Mitigation Measure AQ‐4 would be determined based on the acreage disturbed in a particular construction phase as well as the proximity of the construction activity to sensitive uses. Similar to Scenario 1, implementation of Mitigation Measures AQ‐1 and AQ‐4 would reduce impacts to less than significant levels.

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Scenario 3 consists of office development as well as residential uses, which could be located within the 1,000‐foot screening distance of SR‐85. Following the BAAQMD risk and hazard screening analysis process, Scenario 3 would exceed the initial and advanced screening criteria for PM2.5 and lifetime excess cancer risk, requiring further analysis and modeling. Utilizing the BAAQMD screening tables and criteria (from the BAAQMD’s Recommended Methods for Screening and Modeling Local Risks and Hazards), a 300‐foot buffer for PM2.5 and a 265‐foot buffer for lifetime excess cancer risk would be required between the centerline of SR‐85 and proposed residential uses. Because the Scenario 3 would exceed the screening criteria, consistent with the BAAQMD CEQA Guidelines, a refined dispersion modeling analysis was conducted utilizing local meteorology, emission rates, and highway estimates. Refined dispersion modeling was performed using the Breeze Roads GIS Pro interface for the EPA’s CAL3QHCR model, which is a roadway model that predicts air pollutant concentrations from motor vehicles. The dispersion modeling utilized traffic data from Caltrans, as well as emissions rates and vehicle fleet data from the EMFAC2007 model.18 Based on the results of the screening analysis described above, receptors were modeled at 100‐foot increments from the SR‐85 centerline. Table 8, Risk and Health Hazards from State Route 85, depicts the results of the modeling. As indicated in Table 8, a 300‐foot buffer would ensure that BAAQMD significance thresholds would not be exceeded. However, it should be noted that Table 8 also indicates that at 261 feet from the SR‐85 centerline, the projected cancer risk would be just below the BAAQMD threshold; refer to Exhibit 5, Residential Development Limitations.

Table 8 Risk and Health Hazards from State Route 85

PM2.5 Concentration Cancer Risk Chronic Non-Cancer Acute Non-Cancer Description (μg/m3 annual average) (in a million) Hazard Index Hazard Index Value at 100 Feet 0.09 25.27 0.019 0.022 Threshold 0.3 10 1 1 Threshold Exceeded? No Yes No No Value at 200 Feet 0.04 11.16 0.008 0.010 Threshold 0.3 10 1 1 Threshold Exceeded? No Yes No No Value at 261 Feet 0.04 9.99 0.008 0.009 Threshold 0.3 10 1 1 Threshold Exceeded? No No No No Value at 300 Feet 0.03 8.63 0.007 0.008 Threshold 0.3 10 1 1 Threshold Exceeded? No No No No Source: Breeze Roads GIS Pro dispersion model (v5.1.7) interface for CAL3QHCR. Refer to Appendix A, Air Modeling Data, for assumptions used in this analysis.

18 California Department of Transportation, Traffic and Vehicle Data Systems Unit, All Traffic Volumes on California State Highways, 2009. http://traffic‐counts.dot.ca.gov/2009all/Route82‐86i.htm.

Air Quality & Greenhouse Gas Assessment 49 March 2011 Residential Freeway Centerline Not Permitted

Source: Google Earth aerial. ALBRIGHT WAY DEVELOPMENT PROJECT AIR QUALITY AND GREENHOUSE GAS ASSESSMENT not to scale Residential Development Limitations 1/26/11 JN 40-100419-17194 MAS Exhibit 5 Albright Way Development Project

Therefore, Scenario 3 would require a minimum 261‐foot buffer between the proposed residential units and the SR‐85 centerline (Mitigation Measure AQ‐5) to ensure on‐site residents would not be exposed to risk and health hazards from SR‐85. It should be noted that SR‐85 is not a truck route and has a low volume of trucks based on the latest Caltrans data (less than one percent of the total vehicles).19 Additionally, CARB has adopted a Diesel Risk Reduction Plan (DRRP) with control measures that would reduce overall diesel emissions by approximately 85 percent from 2000 to 2020. These reduction measures are not reflected in the emissions factors and modeling used in the analysis described above. Impacts in this regard would be less than significant with implementation of Mitigation Measures AQ‐5.

Scenario 4

The unsignalized Winchester Boulevard/Albright Way and University Avenue/Lark Avenue intersections are expected to operate at an unacceptable LOS E during both peak hours under background conditions, and LOS F with implementation of Scenario 1. Scenario 4 would result in fewer daily trips than Scenario 1; however, it is anticipated that eth intersection would still decrease to LOS F and also meet signal warrants with the addition of project traffic, which constitutes a significant impact by the Town standards. Therefore, the mitigation within the Traffic Impact Analysis requiring the signalization of the intersection with protected left‐turn phasing on Winchester Boulevard (which would improve the intersection LOS to LOS B) would also be required under Scenario 4. Therefore, effects related to CO concentrations would be less than significant under Scenario 4.

Similar to Scenario 1, construction equipment during Scenario 4 construction would move about the project site and would not be concentrated in one area or near one sensitive receptor long enough to cause health effects. Additionally, the project would implement the BAAQMD’s Basic Construction Mitigation Measures (Mitigation Measure AQ‐1), which would also reduce DPM exhaust emissions. To ensure that sensitive uses in the vicinity of the project site are not exposed to substantial TACs, Mitigation Measure AQ‐4 would require construction staging areas to be sited at the minimum distance required by the BAAQMD. Similar to Scenario 1, implementation of Mitigation Measures AQ‐1 and AQ‐4 would reduce impacts to less than significant levels.

Similar to Scenario 3, Scenario 4 proposes office development as well as senior living units, which could be located within the 1,000‐foot screening distance of SR‐85. Scenario 4 would also exceed the initial and advanced screening criteria for PM2.5 and lifetime excess cancer risk and would also require a minimum 261‐foot buffer between the centerline of SR‐85 and proposed residential uses. As stated under Scenario 3, a refined dispersion modeling analysis confirmed the results of the screening analysis; refer to Table 8. As indicated in Table 8, at 261 feet from the SR‐85 centerline, the projected cancer risk would be just below the BAAQMD threshold; refer to Exhibit 5. Therefore, Scenario 4 would require at least a 261‐foot buffer between the proposed senior living units and the SR‐85 centerline (Mitigation Measure AQ‐5) to ensure on‐

19 Ibid.

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site residents would not be exposed to risk and health hazards from SR‐85. Impacts in this regard would be less than significant with implementation of Mitigation Measures AQ‐5.

Mitigation Measures:

AQ‐4 Prior to the approval of project plans and specifications, the Town Engineer, or his designee, shall confirm that the construction bid packages include a plan demonstrating that the off‐road equipment (more than 50 horsepower) to be used in the construction project (i.e., owned, leased, and subcontractor vehicles) would achieve a project wide fleet‐average 20 percent NOX reduction and 45 percent particulate matter reduction compared to the most recent CARB fleet average. Acceptable options for reducing emissions include the use of late model engines, low‐emission diesel products, alternative fuels, engine retrofit technology, after‐ treatment products, add‐on devices such as particulate filters, and/or other options as such become available. These limitations shall be stipulated in construction bids, plans, and specifications, and shall be enforced by the Town Engineer.

AQ‐5 Should residential uses be incorporated into the project design (Scenarios 3 and 4), the Applicant shall provide a minimum 261‐foot buffer between proposed residential land uses dan the centerline of SR‐85 in order to avoid health risks to future on‐site residents.

Level of Significance After Mitigation: Less Than Significant.

AQ‐5 CREATE OBJECTIONABLE ODORS AFFECTING A SUBSTANTIAL NUMBER OF PEOPLE?

Level of Significance Before Mitigation: Less Than Significant.

Scenario 1

According to the BAAQMD CEQA Air Quality Guidelines, land uses associated with odor complaints typically include wastewater treatment plants, landfills, confined animal facilities, composting stations, food manufacturing plants, refineries, and chemical plants. Scenario 1 does not include any uses identified by the BAAQMD as being associated with odors.

Construction activity associated with the project may generate detectable odors from heavy‐ duty equipment exhaust. Construction‐related odors would be short‐term in nature and cease upon project completion. Any impacts to existing adjacent land uses would be short‐term and are considered less than significant.

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Scenario 2

Refer to the discussion under Scenario 1.

Scenario 3

Refer to the discussion under Scenario 1.

Scenario 4

Refer to the discussion under Scenario 1.

Mitigation Measures: No mitigation measures are required.

Level of Significance After Mitigation: Not Applicable.

GHG‐1 GENERATE GREENHOUSE GAS EMISSIONS, EITHER DIRECTLY OR INDIRECTLY, THAT MAY HAVE A SIGNIFICANT IMPACT ON THE ENVIRONMENT?

Level of Significance Before Mitigation: Potentially Significant.

Scenario 1

Business as Usual Greenhouse Gas Emissions

Direct Project Related Sources of Greenhouse Gases

Direct project‐related GHG emissions include emissions from construction activities, area sources, and mobile sources. Table 9, Scenario 1 Business as Usual Greenhouse Gas Emissions Projections, presents the estimated CO2, N2O, and CH4 emissions without the incorporation of project design features discussed later in this section. GHG emissions from construction would result in 243 MT CO2eq in Year 1; 385 MT CO2eq in Year 2; 298 MT CO2eq in Year 3; 325 MT CO2eq in Year 4; and 159 MT CO2eq in Year 5. The BAAQMD has not adopted thresholds for GHGs associated with construction activities. However, implementation of Mitigation Measure AQ‐1 and AQ‐3 would reduce equipment idling time, ensure equipment is operating properly, and limit the amount of soil hauling truck VMT, which would reduce construction‐related GHG emissions.

The URBEMIS 2007 computer model outputs contained within the Appendix A Air Modeling Data, were used to calculate mobile source CO2 emissions. The URBEMIS 2007 model relies upon trip data within the Traffic Impact Analysis and project specific land use data to calculate emissions. Estimations are based on energy emissions from natural gas usage, as well as automobile emissions. URBEMIS 2007 model outputs were used in conjunction with the

Air Quality & Greenhouse Gas Assessment 53 March 2011 Albright Way Development Project

BAAQMD Greenhouse Gas Model (BGM) (Version 1.1.9) to calculate GHG emissions for area sources and natural gas. GHGs associated with area sources, natural gas, and mobile sources would be 0.23 MT CO2eq/yr, 420.34 MT CO2eq/yr, and 3,749.77 MT CO2eq/yr, respectively. Total project‐related direct operational emissions would result in 4,170.34 MT CO2eq/yr for Scenario 1.

Table 9 Scenario 1 Business as Usual Greenhouse Gas Emissions Projections

CO2 CH4 N2O Total Metric Metric Metric Source Metric Metric Metric Tons of Tons of Tons of Tons/year Tons/year Tons/year 2 CO2eq CO2eq CO2eq Direct Emissions Area Source1 0.23 0.00 0.00 0.00 0.00 0.23 Natural Gas1 419.26 0.04 0.84 0.00 0.24 420.34 Mobile Source1 3,749.77 ------3,749.77 Total Unmitigated Direct Emissions3 4,169.26 0.04 0.84 0.00 0.24 4,170.34 Indirect Emissions Electricity Consumption1 2,574.88 0.02 0.42 0.01 3.10 2,579.01 Water and Wastewater1 40.09 0.00 0.02 0.00 0.05 40.16 Solid Waste1 1.53 10.01 210.00 N/A N/A 211.77 Total Unmitigated Indirect Emissions2 2,616.50 10.03 210.44 0.01 3.15 2,830.94 Total Business As Usual 7,001.26 MT CO2eq/year= Project-Related Emissions 8.17 MT CO2eq/SP3/yr BAAQMD GHG Threshold 4.6 MT CO2eq/SP/yr Unmitigated GHG Emissions Exceed Yes Threshold? Notes: 1 – Emissions calculated using URBEMIS 2007 computer model and the BAAQMD Greenhouse Gas Model (BGM) (Version 1.1.9). 2 – Totals may be slightly off due to rounding. 3 – SP = service population (857 employees, based upon 350 square feet per employee). Refer to Appendix A, Air Modeling Data, for detailed model input/output data.

Indirect Project Related Sources of Greenhouse Gases. Indirect project‐related GHG emissions include emissions from consumption of electricity, natural gas, and water, as well as wastewater and solid waste generation. Indirect GHG emissions were calculated using BGM and URBEMIS 2007. Electricity consumption would indirectly result in 2,579.01 MT CO2eq/yr; water and wastewater would result in 40.16 MT CO2eq/yr; and solid waste generation would result in 211.77 MT CO2eq/yr; refer to Table 9.

Total Project‐Related Sources of Greenhouse Gases. The total amount of project‐related GHG emissions without accounting for any project design features that would reduce GHG emissions from direct and indirect sources combined would total 7,001.26 MT CO2eq/yr.

Consistency With the BAAQMD Greenhouse Gas Mitigation Measures

The proposed project would incorporate several design features (required to be implemented by Mitigation Measure GHG‐1A) that are also consistent with the BAAQMD mitigation

Air Quality & Greenhouse Gas Assessment 54 March 2011 Albright Way Development Project

to reduce GHG emissions. A list of the BAAQMD mitigation measures contained in the BAAQMD’s CEQA Air Quality Guidelines (June 2010) and the project’s compliance with each applicable measure are listed in Table 10, Project Consistency with the BAAQMD Greenhouse Gas Mitigation Measures. Table 10 depicts a host of potential project design features and sustainable practices that the proposed project would incorporate, which include water, energy, solid waste, land use, and transportation efficiency measures. Table 10 also identifies the associated scaled percent reduction and applicable sector based on the project’s consistency with the BAAQMD mitigation measures. The reductions have been based on BAAQMD methodology presented in the BAAQMD’s CEQA Air Quality Guidelines. It should be noted that Table 10 presents potential measures that the project would incorporate. Mitigation Measure GHG‐1 requires the implementation of any mix of GHG reduction measures necessary to achieve the required 44.34 percent scaled reduction that is required for impacts to be less than significant.

Table 10 Project Consistency With the BAAQMD Greenhouse Gas Mitigation Measures

Percent Reduction Project Design Feature Project Applicability (Sector) Transportation Measures (a) Secure Bike Parking (at Compliant. The proposed project would include bicycle parking and other least 1 space per 20 facilities for bicycle riders. vehicle spaces) (b) Information Provided on Compliant. Schedules and maps for transportation alternatives would be Transportation Alternatives available at each proposed building. (Bus Schedules, Maps) (c) Preferential Carpool/ Compliant. Parking spaces would be reserved on-site for carpool/vanpools. Vanpool Parking Compliant. The project site is located within a half-mile of residential and (d) Mix of Uses nonresidential (job-generating) uses. Compliant. The project site is located within a half mile of local serving retail (e) Local Serving Retail uses. Compliant. The project site is located along Albright Way off of Winchester (f) Transit Service Boulevard. VTA Bus Route 48 stops adjacent to the project site near the intersection of Albright Way and Winchester Boulevard. Compliant. Proposed Class II bike lanes are proposed near the project site 39.4 along Winchester Boulevard and Lark Avenue. The stretch of Winchester (transportation) Boulevard just south of the project site contains an existing Class II bike lane. The project would include sidewalks along both sides of Albright Way and (g) Bike and Pedestrian would facilitate pedestrian circulation throughout the site. The project site would also be designed to be bicycle-friendly. Additionally, the project site would have connections to Winchester Boulevard as well as the adjoining Los Gatos Creek Trail (east of the project site). (h) Employee Telecommuting Compliant. The proposed project would allow employees flexibility in working Program location and hours in order to reduce the amount of daily commute time. (i) Showers/Changing Compliant. The proposed project would provide showers/changing areas for Facilities employees on the project site. Compliant. The project would provide a carpool matching program to assist (j) Carpool Matching Program employees in finding colleagues to conveniently carpool with. Compliant. The proposed project would provide on-site amenities for (k) 100% Increase in Diversity employees such as eating and other establishments which would allow of Land Uses employees to reduce off-site trips.

Air Quality & Greenhouse Gas Assessment 55 March 2011 Albright Way Development Project

Table 10 (continued) Project Consistency With the BAAQMD Greenhouse Gas Mitigation Measures

Percent Reduction Project Design Feature Project Applicability (Sector) (l) 100% Increase in Design Compliant. The proposed project would incorporate transit oriented (i.e., presence of design development design measures. guidelines for transit oriented development, complete street standards) Natural Gas Measures Compliant. The buildings associated with the proposed project would exceed (a) Increase Energy Efficiency 20 Title 24 by 20 percent. The baseline for this standard would be the 2010 Beyond Title 24 (natural gas) California Green Building Standards which are effective January 1, 2011. (b) Require smart meters and Compliant. The project would install smart meters and energy management 5 programmable thermostats system controls for lighting, heating, and cooling equipment. (natural gas) Electricity Measures (a) Plant shade trees within 40 Compliant. Where existing, mature shade trees do not already exist, the feet of the south side or proposed project would include newly planted shade trees along the buildings 17 within 60 feet of the west and in open space areas. (electricity) sides of properties (b) Require cool roof materials Compliant. The project would use highly reflective roof materials (albedo of 20 (albedo >=30) at least 30) to reduce cooling load. (electricity) (c) Require smart meters and Compliant. The project would install smart meters and energy management 5 programmable thermostats system controls for lighting, heating, and cooling equipment. (electricity) (d) Meet Green Building Code Compliant. The project would be required to meet the 2010 Green Building 7 Standards Code Standards which would result in reduced electricity usage. (electricity) Compliant. The project would seal heating, ventilation, and air conditioning 10 (e) HVAC duct sealing (HVAC) ducts to enhance efficiency and reduce energy loss. (electricity) Total Scaled Reduction 44.34 Notes: 1. BAAQMD reductions are presented in percentage ranges for specific sectors (i.e., transportation, natural gas). Each sector’s reduction percentages are scaled proportionally to their sector of the project-generated emissions. For example, transportation emissions account for 53.56 percent of the total emissions, and a 39.40 percent reduction would apply to transportation related emissions. Therefore, the reduction is calculated by multiplying 0.5356 by 0.3940 for a scaled reduction of 0.2110 (21.10 percent). This was completed for each sector. The total emissions reduction applied to the project is a sum of the scaled sector reduction percentages (44.34 percent).

BAAQMD Sector Reduction Methodology

The BAAQMD provides GHG reduction measures and associated reduction percentages in their CEQA Air Quality Guidelines. Reductions are presented in percentage ranges for each measure, and apply specifically to mobile, electricity, and natural gas sectors. Reductions from BAAQMD measures are scaled proportionally to their sector of project‐generated emissions. For example, if measures would result in a 39.40 percent reduction in transportation‐related emissions, and transportation accounts for 53.56 percent of the total emissions, then the scaled reduction would be 21.10 percent (0.5356 x 0.3940 = 0.2110). This process is completed for each sector. The total emission reductions are summed and applied to the overall total project‐ related GHG emissions. As presented in Table 10 and Table 11, Scenario 1 Greenhouse Gas Emissions With BAAQMD Sector Reductions, the overall reduction percentages total 44.34 percent. Applying the BAAQMD reduction percentages, GHG emissions from the proposed project would be reduced by 3,104.36 MTCO2eq/yr, which equates to 4.56 MT CO2eq/SP/yr. A

Air Quality & Greenhouse Gas Assessment 56 March 2011 Albright Way Development Project

service population of 857 employees is used (based on one employee per 350 square feet of office space). Thus, the project would not exceed the 4.6 MT CO2eq/SP/yr threshold utilizing the BAAQMD scaled reduction methodology.

Table 11 Scenario 1 Greenhouse Gas Emissions With BAAQMD Sector Reductions

Reductions Breakdown % of Total GHG Sector % of Sector Scaled Reductions Scaled Business as Usual Reductions Calculation4 Reduction % Emissions Transportation 53.56 39.40 0.5356 x 0.3940 = 0.2110 21.10 Natural Gas 6.00 25.00 0.0600 x 0.2500 = 0.0150 1.50 Electricity 36.84 59.00 0.3684 x 0.5900 = 0.2174 21.74 Total Scaled % Reduction 44.34 Total Project-Related Business as 7,001.26 MT CO2eq/yr Usual Emissions1,3 Total Project-Related GHG 3,897.02 MT CO2eq/yr = Emissions WITH 48.26% 4.56 MT CO2eq/SP2/yr Reduction1,3 BAAQMD GHG Threshold 4.6 MT CO2eq/SP/yr Mitigated GHG Emissions No Exceed Threshold? Notes: 1. Total project-related GHG emissions = total direct emissions + total indirect emissions (in MT CO2eq/yr). 2. SP = service population. The SP for the project is assumed to be 857 employees, based on one employee per 350 square feet of office space. The total project-related GHG emissions were divided by the SP of 857 for the annual GHG emissions per SP. 3. Totals may be off due to rounding. 4. BAAQMD reductions are presented in percentage ranges for specific sectors (i.e., transportation, natural gas). Each sector’s reduction percentages are scaled proportionally to their sector of the project-generated emissions. For example, transportation emissions account for 53.56 percent of the total emissions, and a 39.40 percent reduction would apply to transportation related emissions. Therefore, the reduction is calculated by multiplying 0.5356 by 0.3940 for a scaled reduction of 0.2110 (21.10 percent). This was completed for each sector. The total emissions reduction applied to the project is a sum of the scaled sector reduction percentages (44.34 percent).

Conclusion

As shown in Table 9, operational‐related emissions under Scenario 1 would be 7,001.26 MTCO2eq/yr (8.17 MTCO2eq/SP/yr) without reductions from project design features, which exceeds the BAAQMD GHG significance threshold of 4.6 MT CO2eq/SP/yr. URBEMIS 2007 and the BAAQMD CEQA Air Quality Guidelines were used to quantify GHG emissions reductions associated with project design features from project operations. With implementation of project design features (which are required by Mitigation Measure GHG‐1), the project would incorporate sustainable practices which include water, energy, solid waste, and transportation efficiency measures that are summarized in Table 10. Based on the reduction measures in Table 10, Scenario 1 would reduce its GHG emissions 44.34 percent below the business as usual scenario, and would reduce the project’s operational GHG emissions to 3,897.02 MT CO2eq/yr. The project would have a service population of 857 employees and the total GHG emissions after reductions would equate to 4.56 MT CO2eq/SP/yr. Therefore, the project would not exceed the 4.6 MT CO2eq/SP/yr threshold utilizing the BAAQMD scaled reduction methodology. Impacts in this regard would be less than significant.

Air Quality & Greenhouse Gas Assessment 57 March 2011 Albright Way Development Project

Scenario 2

The development of Scenario 2 would result in less commercial office space than considered under Scenario 1. Construction impacts would be less than those associated with Scenario 1, as less development is proposed. At full development, Scenario 2 would result in 948 daily net new trips (69.67 percent reduction from 3,126r fo Scenario 1). Proportionately reducing GHG emissions by 69.67 percent (proportion that Scenario 2 square footage is reduced by compared to Scenario 1) results in a total BAU emissions total of approximately 2,123.71 MT CO2eq/yr. Utilizing a SP of 260 (350 s.f. per employee), Scenario 2 would result in 8.17 MT CO2eq/SP/yr, which would exceed the BAAQMD GHG threshold.

Therefore, Scenario 2 would be required to incorporate BAAQMD GHG mitigation measures to be below the 4.6 MT CO2eq/SP/yr threshold. Scenario 2 would be required to incorporate Mitigation Measure GHG‐1. With implementation of Mitigation Measure GHG‐1, Scenario 2 would reduce its GHG emissions by a scaled 44.34 percent, which equates to 1,182.05 MT CO2eq/yr and 4.55 MT CO2eq/SP/yr, which falls below the BAAQMD GHG threshold. With implementation of Mitigation Measure GHG‐1, impacts would be reduced to less than significant levels.

Scenario 3

The development of Scenario 3 would consist of 200,000 s.f. of commercial office space as well as up to 516 high‐density units. Utilizing the URBEMIS 2007 and BGM models, the total GHG emissions associated with Scenario 3 would be 6,870.34 MT CO2eq/yr. Utilizing a SP of 1,223 (based on 350 s.f. per employee [with a net decrease of 50,000 s.f. of office space] and 2.39 persons per household), Scenario 3 would result in 5.61 MT CO2eq/SP/yr, which is above the 4.6 MT CO2eq/SP/yr GHG threshold. Therefore, Scenario 3 would be required to incorporate BAAQMD GHG mitigation measures to be below the 4.6 MT CO2eq/SP/yr threshold. Scenario 3 would be required to incorporate Mitigation Measure GHG‐1. With implementation of Mitigation Measure GHG‐1, Scenario 3 would reduce its GHG emissions by a scaled 18.5 percent, which equates to 5,599.33 MT CO2eq/yr and 4.58 MT CO2eq/SP/yr, which falls below the BAAQMD GHG threshold. With implementation of Mitigation Measure GHG‐1, impacts would be reduced to less than significant levels.

Scenario 4

The development of Scenario 4 consists of 200,000 s.f. of commercial office space as well as up to 600 senior living units. Utilizing the URBEMIS 2007 and BGM models, the total GHG emissions associated with Scenario 4 would be 8,994.56 MT CO2eq/yr. Utilizing a SP of 1,057 (based on 350 s.f. per employee [with a net decrease of 50,000 s.f. of office space] and 2.0 persons per household), Scenario 4 would result in 8.46 MT CO2eq/SP/yr, which is above the 4.6 MT CO2eq/SP/yr GHG threshold. Therefore, Scenario 4 would be required to incorporate BAAQMD GHG mitigation measures to be below the 4.6 MT CO2eq/SP/yr threshold. Scenario 4 would be required to incorporate Mitigation Measure GHG‐1. With implementation of Mitigation Measure GHG‐1, Scenario 4 would reduce its GHG emissions by a scaled 46 percent,

Air Quality & Greenhouse Gas Assessment 58 March 2011 Albright Way Development Project

which equates to 4,857.06 MT CO2eq/yr and 4.59 MT CO2eq/SP/yr, which falls below the BAAQMD GHG threshold. With implementation of Mitigation Measure GHG‐1, impacts would be reduced to less than significant levels.

Mitigation Measures:

GHG‐1 A combination of the following is a list of sustainability and design features that shall be incorporated into Scenarios 1, 2, 3, or 4 to achieve the overall scaled reduction in GHG emissions to ensure a less than significant GHG impact (Scenarios 1 and 2 require a 44.34 percent scaled reduction, Scenario 3 requires an 18.5 percent scaled reduction, and Scenario 4 requires a 46 percent scaled reduction in GHG emissions). Prior to the issuance of building permits, the applicant shall demonstrate the incorporation of a combination (one or more) of sustainable project design features that would reduce the project’s GHG emissions by the percentage required above. Each measure and the associated GHG reduction shall be identified and included on all project plans and specifications. One or more of the following sustainability and design features, or other measures that may be available in the future, shall be included to achieve the reduction in GHG emissions:

• Provide secure on‐site bike parking (ratio shall be at least one space per 20 vehicle spaces). • Provide information on transportation alternatives (i.e., bus schedules and maps) accessible to employees within each proposed building. • Provide preferential on‐site carpool/vanpool parking. • Increase energy efficiency beyond Title 24 by 20 percent. • Install smart meters and programmable thermostats. • Plant shade trees within 40 feet of the south side or within 60 feet of the west sides of the buildings. • Install roofs with highly reflective materials (albedo of at least 30) to reduce cooling load. • Meet 2010 Green Building Code Standards. • Seal heating, ventilation, and air conditioning (HVAC) ducts to enhance efficiency and reduce energy loss. • Include solar photovoltaic or other technology to generate electricity on‐site to reduce consumption from the electrical grid. • Implement an employee telecommuting program. • Provide showers/changing facilities on‐site for employee use. • Implement an on‐site carpool matching program for employees. • Provide on‐site amenities (i.e., eating and other establishments).

Air Quality & Greenhouse Gas Assessment 59 March 2011 Albright Way Development Project

• Increase the project design by 100 percent (i.e., presence of transit oriented development design guidelines, complete streets standards). • Work with the Bay Area Air Quality Management District (BAAQMD) to implement acceptable off‐site mitigation. This involves an agreement with the BAAQMD and payment of fees or the purchase of carbon credits. The BAAQMD would commit to reducing the type and amount of emissions identified in the agreement.

Also refer to Mitigation Measures AQ‐1 and AQ‐3.

Level of Significance After Mitigation: Less Than Significant.

GHG‐2 CONFLICT WITH AN APPLICABLE PLAN, POLICY OR REGULATION ADOPTED FOR THE PURPOSE OF REDUCING THE EMISSIONS OF GREENHOUSE GASES?

Level of Significance Before Mitigation: Less Than Significant.

Scenario 1

According to the BAAQMD, a GHG reduction plan should:

• Quantify GHG emissions, both existing and projected over a specified time period, resulting from activities within a defined geographic area; • Establish a level, based on substantial evidence, below which the contribution to GHG emissions from activities covered by the plan would not be cumulatively considerable; • Identify and analyze the GHG emissions resulting from specific actions or categories of actions anticipated within the geographic area; • Specify measures or a group of measures, including performance standards, that substantial evidence demonstrates, if implemented on a project‐by‐project basis, would collectively achieve the specified emissions level; • Establish a mechanism to monitor the plan’s progress toward achieving the level and to require amendment if the plan is not achieving specified levels; and • Be adopted in a public process following environmental review.

The GHG reduction plan should identify goals, policies, and implementation measures that would achieve the goals of AB 32 for the entire community. The Town of Los Gatos does not currently have an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs. Therefore, the proposed project would not conflict with an adopted plan, policy, or regulation pertaining to GHGs. Also, as described above, the proposed project would comply with the 2010 California Green Building Code and would include design features to reduce energy and water consumption and reduce vehicle trips. The project would not hinder

Air Quality & Greenhouse Gas Assessment 60 March 2011 Albright Way Development Project

the Stateʹs GHG reduction goals established by AB 32. Thus, a less than significant impact would occur in this regard.

Scenario 2

Refer to the discussion under Scenario 1.

Scenario 3

Refer to the discussion under Scenario 1.

Scenario 4

Refer to the discussion under Scenario 1.

Mitigation Measures: No mitigation measures are required.

Level of Significance After Mitigation: Less Than Significant.

Air Quality & Greenhouse Gas Assessment 61 March 2011 Albright Way Development Project

6.0 REFERENCES

6.1 LIST OF PREPARERS

RBF CONSULTING 14725 Alton Parkway Irvine, California 92618 949/472‐3505

Eddie Torres, Director of Technical Services Kelly Chiene, Environmental Analyst Achilles Malisos, Environmental Analyst Debby Hutchinson, Graphic Artist Gary Gick, Word Processor

6.2 DOCUMENTS

1. Bay Area Air Quality Management District, CEQA Air Quality Guidelines, June 2010.

2. Bay Area Air Quality Management District, Recommended Methods for Screening and Modeling Local Risks and Hazards, May 2010.

3. California Air Resources Board, Climate Change Proposed Scoping Plan, October 2008.

4. California Air Pollution Control Officers Association, CEQA & Climate Change: Evaluating and Addressing Greenhouse Gas Emissions from Projects Subject to the California Environmental Quality Act, 2008.

5. California Climate Change Center, Our Changing Climate, Assessing the Risks to California, July 2006.

6. California Energy Commission, Inventory of California Greenhouse Gas Emissions and Sinks 1990 to 2004, December 2006.

7. California Environmental Protection Agency, Climate Action Team, Climate Action Team Report to Governor Schwarzenegger and the Legislature (Executive Summary), March 2006.

8. California Governorʹs Office of Planning and Research, CEQA AND CLIMATE CHANGE: Addressing Climate Change Through the California Environmental Quality Act (CEQA) Review, June 19, 2008.

Air Quality & Greenhouse Gas Assessment 62 March 2011 Albright Way Development Project

9. California Governors Office of Planning and Research, Proposed Amendments to 14 Sections of the CEQA Guidelines, January 2009.

10. California Natural Resources Agency. 2009 California Climate Adaptation Strategy, December 2009.

11. Energy Information Administration, Other Gases: Hydrofluorocarbons, Perfluorocarbons, and Sulfur Hexafluoride, October 29, 2001.

12. Hexagon Transportation Consultants, Inc., Albright Way Development Traffic Impact Analysis, March 17, 2011.

13. Intergovernmental Panel on Climate Change, Climate Change, The Science of Climate Change – Contribution of Working Group I to the Second Assessment Report of the IPCC, 1996.

14. Intergovernmental Panel on Climate Change, Climate Change 2007: The Physical Science Basis, Summary for Policymakers, February 2007.

15. United States Environmental Protection Agency, Inventory of U.S. Greenhouse Gas Emissions and Sinks 1990 to 2008, April 2010.

16. United States Environmental Protection Agency, High GWP Gases and Climate Change, June 22, 2010.

6.3 WEB SITES/PROGRAMS

Bay Area Air Quality Management District, BAAQMD Greenhouse Gas Model (version 1.1.9)

California Air Resources Board, Aerometric Data Analysis and Measurement System (ADAM), summaries from 2007 to 2009, http://www.arb.ca.gov/adam.

California Air Resources Board, EMFAC 2007 (version 2.3), November 1, 2006.

California Air Resources Board, www.arb.ca.gov.

Rimpo and Associates, URBEMIS 2007 (version 9.2.4), June 2007.

Air Quality & Greenhouse Gas Assessment 63 March 2011

APPENDIX A: AIR MODELING DATA

Parenthetical URBEMIS2007 (Version 9.2.4) Assumptions For: Albright Way Office Development Project Date: March 2011

LAND USES

Scenario A Amount Land Use Type Unit Type Net Trips 300 Office Park 1,000 sf 3,126

Scenario B Amount Land Use Type Unit Type Net Trips 200 Office Park 1,000 sf 948

Scenario C Amount Land Use Type Unit Type Net Trips 200 Office Park 1,000 sf 2,000 516 Multi-Family Residential Dwelling units

Scenario D Amount Land Use Type Unit Type Net Trips 200 Office Park 1,000 sf 1,442 600 Senior Living Residential Dwelling units

CONSTRUCTION SOURCES

Year Duration (months) Development 2012 9 months Demolition, Grading, Trenching, Building Construction Demolition, Grading, Trenching, Paving, Building Construction, 2013 12 months Architectural Coating 2014 12 months Grading, Paving, Building Construction, Architectural Coating Demolition, Grading, Trenching, Building Construction, Architectural 2015 12 months Coating 2016 6 months Grading, Paving, Building Construction

PHASE 1:

Demolition:

Total Daily Duration Total Volume Year Volume (days) (cubic feet) (cubic feet) 2012 30 400,000 14,000

Demolition Equipment (URBEMIS2007 Default):

Quantity Type Hours of Daily Operation 1 Concrete/Industrial Saw 8 1 Rubber Tired Dozer 1 2 Tractor/Loaders/Backhoe 6

Site Grading:

Duration- Duration- Estimated Total Acreage Acreage Mass Fine Soil Hauling Year Cut/Fill (cubic Disturbed Disturbed Daily Grading Grading (cubic yards) yards/day) (days) (days) 2012-2013 8.46 1.61 19 22 31,200 1,800

Mass Grading Equipment (URBEMIS2007 Default):

Quantity Type Hours of Daily Operation 1 Grader 6 1 Rubber Tired Dozer 6 1 Tractor/Loaders/Backhoe 7 1 Water Trucks 8

Fine Grading Equipment (URBEMIS2007 Default):

Quantity Type Hours of Daily Operation 1 Grader 6 1 Rubber Tired Dozer 6 1 Tractor/Loaders/Backhoe 7 1 Water Trucks 8

Trenching:

Year Duration 2012 36 days

Trenching Equipment (URBEMIS2007 Default):

Quantity Type Hours of Daily Operation 2 Excavators 8 1 Other General Industrial 8 Equipment

Paving:

Duration Year Acres (days) 2013 11 3.42

Equipment (URBEMIS2007 Default):

Quantity Type Hours of Daily Operation 4 Cement and Mortar Mixers 6 1 Paver 7 2 Paving Equipment 6 1 Roller 7 1 Tractor/Loader/Backhoe 7

Building Construction

Duration Year (days) 2012-2013 270

Equipment (URBEMIS2007 Default):

Quantity Type Hours of Daily Operation 1 Crane 6 2 Forklifts 6 1 Tractor/Loader/Backhoe 8 3 Welders 8 1 Generator Set 8

Architectural Coatings:

Duration – 25 days Low VOC coatings (Pursuant to BAAQMD Regulation 8, Rule 3) (150) (URBEMIS2007 default all phases)

Worker Commute

(URBEMIS2007 default all phases)

Construction Mitigation:

Refer to URBEMIS2007 file output.

PHASE 2:

Demolition:

Total Daily Duration Total Volume Year Volume (days) (cubic feet) (cubic feet) 2013 15 175,000 14,000

Demolition Equipment (URBEMIS2007 Default):

Quantity Type Hours of Daily Operation 1 Concrete/Industrial Saw 8 1 Rubber Tired Dozer 1 2 Tractor/Loaders/Backhoe 6

Site Grading:

Mass Grading Equipment (URBEMIS2007 Default):

Quantity Type Hours of Daily Operation 1 Grader 6 1 Rubber Tired Dozer 6 1 Tractor/Loaders/Backhoe 7 1 Water Trucks 8

Fine Grading Equipment (URBEMIS2007 Default):

Quantity Type Hours of Daily Operation 1 Grader 6 1 Rubber Tired Dozer 6 1 Tractor/Loaders/Backhoe 7 1 Water Trucks 8

Trenching:

Year Duration 2013 26 days

Trenching Equipment (URBEMIS2007 Default):

Quantity Type Hours of Daily Operation 2 Excavators 8 1 Other General Industrial 8 Equipment

Paving:

Duration Year Acres (days) 2014 12 3.57

Equipment (URBEMIS2007 Default):

Quantity Type Hours of Daily Operation 4 Cement and Mortar Mixers 6 1 Paver 7 2 Paving Equipment 6 1 Roller 7 1 Tractor/Loader/Backhoe 7

Building Construction

Duration Year (days) 2013-2014 260

Equipment (URBEMIS2007 Default):

Quantity Type Hours of Daily Operation 1 Crane 6 2 Forklifts 6 1 Tractor/Loader/Backhoe 8 3 Welders 8 1 Generator Set 8

Architectural Coatings:

Duration – 25 days Low VOC coatings (Pursuant to BAAQMD Regulation 8, Rule 3) (150) (URBEMIS2007 default all phases)

Worker Commute

(URBEMIS2007 default all phases)

Construction Mitigation:

Refer to URBEMIS2007 file output.

PHASE 3:

Demolition:

Total Daily Duration Total Volume Year Volume (days) (cubic feet) (cubic feet) 2015 20 246,000 14,000

Demolition Equipment (URBEMIS2007 Default):

Quantity Type Hours of Daily Operation 1 Concrete/Industrial Saw 8 1 Rubber Tired Dozer 1 2 Tractor/Loaders/Backhoe 6

Site Grading:

Mass Grading Equipment (URBEMIS2007 Default):

Quantity Type Hours of Daily Operation 1 Grader 6 1 Rubber Tired Dozer 6 1 Tractor/Loaders/Backhoe 7 1 Water Trucks 8

Fine Grading Equipment (URBEMIS2007 Default):

Quantity Type Hours of Daily Operation 1 Grader 6 1 Rubber Tired Dozer 6 1 Tractor/Loaders/Backhoe 7 1 Water Trucks 8

Trenching:

Year Duration 2015 29 days

Trenching Equipment (URBEMIS2007 Default):

Quantity Type Hours of Daily Operation 2 Excavators 8 1 Other General Industrial 8 Equipment

Paving:

Duration Year Acres (days) 2016 11 3.25

Equipment (URBEMIS2007 Default):

Quantity Type Hours of Daily Operation 4 Cement and Mortar Mixers 6 1 Paver 7 2 Paving Equipment 6 1 Roller 7 1 Tractor/Loader/Backhoe 7

Building Construction

Duration Year (days) 2015-2016 270

Equipment (URBEMIS2007 Default):

Quantity Type Hours of Daily Operation 1 Crane 6 2 Forklifts 6 1 Tractor/Loader/Backhoe 8 3 Welders 8 1 Generator Set 8

Architectural Coatings:

Duration – 25 days Low VOC coatings (Pursuant to BAAQMD Regulation 8, Rule 3) (150) (URBEMIS2007 default all phases)

Worker Commute

(URBEMIS2007 default all phases)

Construction Mitigation:

Refer to URBEMIS2007 file output.

LONG TERM OPERATIONS

YEAR 2016 AREA SOURCES

Natural Gas Fuel Combustion:

(URBEMIS2007 default all phases)

Hearth Fuel Combustion:

Off

Landscape Fuel Combustion:

Year of Completion Summer Days 2016 180

Consumer Products:

(URBEMIS2007 default all phases)

Architectural Coating:

(URBEMIS2007 default all phases)

Area Source Mitigation:

Low VOC coatings (Pursuant to BAAQMD Regulation 8, Rule 3) Refer to URBEMIS2007 file output.

YEAR 2016 OPERATIONAL SOURCES

Vehicle Fleet %:

(URBEMIS2007 default all phases)

Year:

Year of Completion – 2016

Trip Characteristics:

(URBEMIS2007 Default all phases)

Temperature Data:

40 to 90 degrees Fahrenheit

Variable Starts:

(URBEMIS2007 default all phases)

Road Dust:

Paved – 100% Unpaved – 0%

Pass By Trips (On/Off):

Off

Double-Counting(On/Off):

Off

Operational Mitigation Measures:

Refer to URBEMIS2007 file output. Page: 1 2/2/2011 2:18:34 PM Urbemis 2007 Version 9.2.4 Combined Annual Emissions Reports (Tons/Year) File Name: H:\pdata\40100419\Admin\reports\AQ_GHG\Models\URBEMIS\NOX mit\Albright_Phase1.urb924 Project Name: Albright Way Construction Phase1 No MM Project Location: Bay Area Air District On-Road Vehicle Emissions Based on: Version : Emfac2007 V2.3 Nov 1 2006 Off-Road Vehicle Emissions Based on: OFFROAD2007

Summary Report:

CONSTRUCTION EMISSION ESTIMATES

ROG NOx CO SO2 PM10 Dust PM10 Exhaust PM10 PM2.5 Dust PM2.5 PM2.5 CO2 Exhaust 2012 TOTALS (tons/year unmitigated) 0.32 2.32 1.61 0.00 1.76 0.12 1.88 0.37 0.11 0.48 355.29

2012 TOTALS (tons/year mitigated) 0.32 2.32 1.61 0.00 0.36 0.12 0.48 0.08 0.11 0.19 355.29

Percent Reduction 0.00 0.00 0.00 0.00 79.66 0.00 74.52 79.46 0.00 61.01 0.00

2013 TOTALS (tons/year unmitigated) 1.36 1.85 1.70 0.00 0.77 0.11 0.88 0.16 0.10 0.27 291.31

2013 TOTALS (tons/year mitigated) 0.95 1.85 1.70 0.00 0.12 0.11 0.24 0.03 0.10 0.13 291.31

Percent Reduction 30.30 0.00 0.00 0.00 83.69 0.00 72.88 83.33 0.00 50.52 0.00

Construction Unmitigated Detail Report:

CONSTRUCTION EMISSION ESTIMATES Annual Tons Per Year, Unmitigated

ROG NOx CO SO2 PM10 Dust PM10 Exhaust PM10 PM2.5 Dust PM2.5 Exhaust PM2.5 CO2 Page: 2 2/2/2011 2:18:34 PM

2012 0.32 2.32 1.61 0.00 1.76 0.12 1.88 0.37 0.11 0.48 355.29

Demolition 04/02/2012- 0.02 0.17 0.10 0.00 0.09 0.01 0.10 0.02 0.01 0.03 23.78 05/11/2012 Fugitive Dust 0.00 0.00 0.00 0.00 0.21 0.00 0.21 0.04 0.00 0.04 0.00

Demo Off Road Diesel 0.01 0.10 0.07 0.00 0.00 0.01 0.01 0.00 0.01 0.01 10.50

Demo On Road Diesel 0.00 0.07 0.02 0.00 0.00 0.00 0.00 0.00 0.00 0.00 11.74

Demo Worker Trips 0.00 0.00 0.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 1.53

Mass Grading 05/14/2012- 0.08 1.00 0.38 0.00 1.67 0.04 1.71 0.35 0.04 0.39 163.63 06/07/2012 Mass Grading Dust 0.00 0.00 0.00 0.00 1.67 0.00 1.67 0.35 0.00 0.35 0.00

Mass Grading Off Road Diesel 0.03 0.21 0.11 0.00 0.00 0.01 0.01 0.00 0.01 0.01 21.35

Mass Grading On Road Diesel 0.05 0.79 0.26 0.00 0.00 0.03 0.03 0.00 0.03 0.03 141.31

Mass Grading Worker Trips 0.00 0.00 0.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.97

Trenching 06/08/2012-07/27/2012 0.03 0.28 0.16 0.00 0.00 0.01 0.01 0.00 0.01 0.01 32.70

Trenching Off Road Diesel 0.03 0.27 0.14 0.00 0.00 0.01 0.01 0.00 0.01 0.01 30.86

Trenching Worker Trips 0.00 0.00 0.02 0.00 0.00 0.00 0.00 0.00 0.00 0.00 1.84

Building 07/30/2012-08/09/2013 0.19 0.88 0.97 0.00 0.00 0.06 0.06 0.00 0.05 0.06 135.18

Building Off Road Diesel 0.17 0.82 0.58 0.00 0.00 0.06 0.06 0.00 0.05 0.05 89.98

Building Vendor Trips 0.00 0.04 0.03 0.00 0.00 0.00 0.00 0.00 0.00 0.00 8.96

Building Worker Trips 0.01 0.02 0.35 0.00 0.00 0.00 0.00 0.00 0.00 0.00 36.24 Page: 3 2/2/2011 2:18:34 PM

2013 1.36 1.85 1.70 0.00 0.77 0.11 0.88 0.16 0.10 0.27 291.31

Building 07/30/2012-08/09/2013 0.25 1.18 1.32 0.00 0.00 0.08 0.08 0.00 0.07 0.07 193.67

Building Off Road Diesel 0.23 1.11 0.81 0.00 0.00 0.07 0.07 0.00 0.07 0.07 128.89

Building Vendor Trips 0.00 0.05 0.04 0.00 0.00 0.00 0.00 0.00 0.00 0.00 12.84

Building Worker Trips 0.01 0.02 0.46 0.00 0.00 0.00 0.00 0.00 0.00 0.00 51.94

Coating 01/20/2013-02/22/2013 1.03 0.00 0.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 1.23

Architectural Coating 1.03 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Coating Worker Trips 0.00 0.00 0.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 1.23

Asphalt 07/26/2013-08/31/2013 0.04 0.21 0.16 0.00 0.00 0.02 0.02 0.00 0.02 0.02 23.47

Paving Off-Gas 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Paving Off Road Diesel 0.03 0.20 0.13 0.00 0.00 0.02 0.02 0.00 0.02 0.02 18.44

Paving On Road Diesel 0.00 0.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 2.04

Paving Worker Trips 0.00 0.00 0.03 0.00 0.00 0.00 0.00 0.00 0.00 0.00 2.99

Fine Grading 08/12/2013- 0.04 0.46 0.21 0.00 0.76 0.02 0.78 0.16 0.02 0.18 72.95 09/10/2013 Fine Grading Dust 0.00 0.00 0.00 0.00 0.76 0.00 0.76 0.16 0.00 0.16 0.00

Fine Grading Off Road Diesel 0.03 0.23 0.12 0.00 0.00 0.01 0.01 0.00 0.01 0.01 24.72

Fine Grading On Road Diesel 0.02 0.23 0.08 0.00 0.00 0.01 0.01 0.00 0.01 0.01 47.10

Fine Grading Worker Trips 0.00 0.00 0.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 1.12

Phase Assumptions

Phase: Demolition 4/2/2012 - 5/11/2012 - Phase 1 Building Volume Total (cubic feet): 400000 Building Volume Daily (cubic feet): 14000 On Road Truck Travel (VMT): 194.44 Off-Road Equipment: Page: 4 2/2/2011 2:18:34 PM 1 Concrete/Industrial Saws (10 hp) operating at a 0.73 load factor for 8 hours per day 1 Rubber Tired Dozers (357 hp) operating at a 0.59 load factor for 1 hours per day 2 Tractors/Loaders/Backhoes (108 hp) operating at a 0.55 load factor for 6 hours per day

Phase: Fine Grading 8/12/2013 - 9/10/2013 - Phase 1 Total Acres Disturbed: 8.46 Maximum Daily Acreage Disturbed: 1.61 Fugitive Dust Level of Detail: Low Onsite Cut/Fill: 450 cubic yards/day; Offsite Cut/Fill: 0 cubic yards/day On Road Truck Travel (VMT): 1063.64 Off-Road Equipment: 1 Graders (174 hp) operating at a 0.61 load factor for 6 hours per day 1 Rubber Tired Dozers (357 hp) operating at a 0.59 load factor for 6 hours per day 1 Tractors/Loaders/Backhoes (108 hp) operating at a 0.55 load factor for 7 hours per day 1 Water Trucks (189 hp) operating at a 0.5 load factor for 8 hours per day

Phase: Mass Grading 5/14/2012 - 6/7/2012 - Phase 1 Total Acres Disturbed: 8.46 Maximum Daily Acreage Disturbed: 1.61 Fugitive Dust Level of Detail: Low Onsite Cut/Fill: 1350 cubic yards/day; Offsite Cut/Fill: 0 cubic yards/day On Road Truck Travel (VMT): 3694.74 Off-Road Equipment: 1 Graders (174 hp) operating at a 0.61 load factor for 6 hours per day 1 Rubber Tired Dozers (357 hp) operating at a 0.59 load factor for 6 hours per day 1 Tractors/Loaders/Backhoes (108 hp) operating at a 0.55 load factor for 7 hours per day 1 Water Trucks (189 hp) operating at a 0.5 load factor for 8 hours per day

Phase: Trenching 6/8/2012 - 7/27/2012 - Phase 1 Off-Road Equipment: Page: 5 2/2/2011 2:18:34 PM 2 Excavators (168 hp) operating at a 0.57 load factor for 8 hours per day 1 Other General Industrial Equipment (238 hp) operating at a 0.51 load factor for 8 hours per day 1 Tractors/Loaders/Backhoes (108 hp) operating at a 0.55 load factor for 0 hours per day

Phase: Paving 7/26/2013 - 8/31/2013 - Phase 1 Acres to be Paved: 3.42 Off-Road Equipment: 4 Cement and Mortar Mixers (10 hp) operating at a 0.56 load factor for 6 hours per day 1 Pavers (100 hp) operating at a 0.62 load factor for 7 hours per day 2 Paving Equipment (104 hp) operating at a 0.53 load factor for 6 hours per day 1 Rollers (95 hp) operating at a 0.56 load factor for 7 hours per day 1 Tractors/Loaders/Backhoes (108 hp) operating at a 0.55 load factor for 7 hours per day

Phase: Building Construction 7/30/2012 - 8/9/2013 - Phase 1 Off-Road Equipment: 1 Cranes (399 hp) operating at a 0.43 load factor for 6 hours per day 2 Forklifts (145 hp) operating at a 0.3 load factor for 6 hours per day 1 Generator Sets (49 hp) operating at a 0.74 load factor for 8 hours per day 1 Tractors/Loaders/Backhoes (108 hp) operating at a 0.55 load factor for 8 hours per day 3 Welders (45 hp) operating at a 0.45 load factor for 8 hours per day

Phase: Architectural Coating 1/20/2013 - 2/22/2013 - Phase 1 Rule: Residential Interior Coatings begins 1/1/2005 ends 12/31/2040 specifies a VOC of 250 Rule: Residential Exterior Coatings begins 1/1/2005 ends 12/31/2040 specifies a VOC of 250 Rule: Nonresidential Interior Coatings begins 1/1/2005 ends 12/31/2040 specifies a VOC of 250 Rule: Nonresidential Exterior Coatings begins 1/1/2005 ends 12/31/2040 specifies a VOC of 250

Construction Mitigated Detail Report: Page: 6 2/2/2011 2:18:34 PM

CONSTRUCTION EMISSION ESTIMATES Annual Tons Per Year, Mitigated

ROG NOx CO SO2 PM10 Dust PM10 Exhaust PM10 PM2.5 Dust PM2.5 Exhaust PM2.5 CO2

2012 0.32 2.32 1.61 0.00 0.36 0.12 0.48 0.08 0.11 0.19 355.29

Demolition 04/02/2012- 0.02 0.17 0.10 0.00 0.09 0.01 0.10 0.02 0.01 0.03 23.78 05/11/2012 Fugitive Dust 0.00 0.00 0.00 0.00 0.21 0.00 0.21 0.04 0.00 0.04 0.00

Demo Off Road Diesel 0.01 0.10 0.07 0.00 0.00 0.01 0.01 0.00 0.01 0.01 10.50

Demo On Road Diesel 0.00 0.07 0.02 0.00 0.00 0.00 0.00 0.00 0.00 0.00 11.74

Demo Worker Trips 0.00 0.00 0.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 1.53

Mass Grading 05/14/2012- 0.08 1.00 0.38 0.00 0.27 0.04 0.31 0.06 0.04 0.09 163.63 06/07/2012 Mass Grading Dust 0.00 0.00 0.00 0.00 0.26 0.00 0.26 0.05 0.00 0.05 0.00