L. Air QualityLSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR
JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES
L. AIR QUALITY
L. AIR QUALITY
This section has been prepared using the methodologies and assumptions contained in the Bay Area
Air Quality Management District's (BAAQMD) Air Quality CEQA Guidelines'. In keeping with
these guidelines, this section describes existing air quality and the regulatory framework for air
quality including the litigation status of the BAAQMD's CEQA Guidelines. The section also
describes the potential effects of the project on air quality, including the effects of project construc-
tion and operational traffic on regional pollutant levels and health risks. Mitigation measures to
reduce potentially significant air quality impacts are identified, where appropriate.
1. Setting
This section describes existing air quality conditions in the City of Cupertino, beginning with a
discussion of typical air pollutant types and sources, health effects, and climatology relating to air
quality.
a. Air Pollutants and Health Effects. Both State and federal governments have established
health -based Ambient Air Quality Standards for six criteria air pollutants:Z carbon monoxide (CO),
ozone (03), nitrogen dioxide (NOA sulfur dioxide (SOA lead (Pb), and suspended particulate matter
(PM). In addition, the State has set standards for sulfates, hydrogen sulfide, vinyl chloride and visibil-
ity -reducing particles. These standards are designed to protect the health and welfare of the populace
with a reasonable margin of safety. Long-term exposure to elevated levels of criteria pollutants may
result in adverse health effects. However, emission thresholds established by an air district are used to
manage total regional emissions within an air basin based on the air basin's attainment status for
criteria pollutants. These emission thresholds were established for individual projects that would
contribute to regional emissions and pollutant concentrations and could adversely affect or delay the
projected attainment target year for certain criteria pollutants.
Because of the conservative nature of the thresholds and the basin -wide context of individual project
emissions, there is no direct correlation between a single project and localized air quality -related
health effects. One individual project that generates emissions exceeding a threshold does not neces-
sarily result in adverse health effects for residents in the project vicinity. This condition is especially
true when the criteria pollutants exceeding thresholds are those with regional effects, such as ozone
precursors like nitrogen oxides (NOJ and reactive organic gases (ROG).
Occupants of facilities such as schools, day care centers, parks and playgrounds, hospitals, and
nursing and convalescent homes are considered to be more sensitive than the general public to air
pollutants because these population groups have increased susceptibility to respiratory disease.
Persons engaged in strenuous work or exercise also have increased sensitivity to poor air quality.
Residential areas are considered more sensitive to air quality conditions, compared to commercial and
industrial areas, because people generally spend longer periods of time at their residences, with
greater associated exposure to ambient air quality conditions. Recreational uses are also considered
sensitive compared to commercial and industrial uses due to greater exposure to ambient air quality
conditions associated with exercise.
1 Bay Area Air Quality Management District, 2011. CEQA Air Quality Guidelines. May.
2 Criteria pollutants are defined as those pollutants for which the federal and State governments have established
ambient air quality standards, or criteria, for outdoor concentrations in order to protect public health.
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Air pollutants and their health effects, and other air pollution -related considerations are summarized
in Table V.L-1 and are described in more detail below.
Table V.L-1: Sources and Health Effects of Air Pollutants
Pollutants
Sources
Primary Effects
Carbon Monoxide
Incomplete combustion of fuels and
Reduced tolerance for exercise.
(CO)
other carbon -containing substances,
Impairment of mental function.
such as motor exhaust.
Impairment of fetal development.
Natural events, such as decomposition
Death at high levels of exposure.
of organic matter.
Aggravation of some heart diseases (angina).
Nitrogen Dioxide
Motor vehicle exhaust.
Aggravation of respiratory illness.
(NO2)
High temperature stationary combus-
Reduced visibility.
tion.
Reduced plant growth.
Atmospheric reactions.
Formation of acid rain.
Ozone
Atmospheric reaction of organic gases
Aggravation of respiratory and cardiovascular
(03)
with nitrogen oxides in sunlight.
diseases.
Irritation of eyes.
Impairment of cardiopulmonary function.
Plant leaf injury.
Lead
Contaminated soil.
Impairment of blood functions and nerve con -
(Pb)
struction.
Behavioral and hearing problems in children.
Suspended Particulate
Stationary combustion of solid fuels.
Reduced lung function.
Matter
Construction activities.
Aggravation of the effects of gaseous pollut-
(PM2.5 and PM10)
Industrial processes.
ants.
Atmospheric chemical reactions.
Aggravation of respiratory and
cardiorespiratory diseases.
Increased cough and chest discomfort.
Soiling.
Reduced visibility.
Sulfur Dioxide
Combustion of sulfur -containing fossil
Aggravation of respiratory diseases (asthma,
(SO2)
fuels.
emphysema).
Smelting of sulfur -bearing metal ores.
Reduced lung function.
Industrial processes.
Irritation of eyes.
Reduced visibility.
• Plant injury.
Deterioration of metals, textiles, leather, fin-
ishes, coatings, etc.
Source: California Air Resources Board (ARB), 2012.
(1) Ozone. Ozone is a secondary air pollutant produced in the atmosphere through a complex
series of photochemical reactions involving ROG and NO,. The main sources of ROG and NO,, often
referred to as ozone precursors, are combustion processes (including combustion in motor vehicle
engines) and the evaporation of solvents, paints, and fuels. In the Bay Area, automobiles are the
single largest source of ozone precursors. Ozone is referred to as a regional air pollutant because its
precursors are transported and diffused by wind concurrently with ozone production through the
photochemical reaction process. Ozone causes eye irritation, airway constriction, and shortness of
breath and can aggravate existing respiratory diseases such as asthma, bronchitis, and emphysema.
(2) Carbon Monoxide. CO is an odorless, colorless gas usually formed as the result of the
incomplete combustion of fuels. The single largest source of CO is motor vehicles. While CO
transport is limited, it disperses with distance from the source under normal meteorological condi-
tions. However, under certain extreme meteorological conditions, CO concentrations near congested
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roadways or intersections may reach unhealthful levels that adversely affect local sensitive receptors
(e.g., residents, schoolchildren, the elderly, and hospital patients). Typically, high CO concentrations
are associated with roadways or intersections operating at unacceptable levels of service (LOS) or
with extremely high traffic volumes. Exposure to high concentrations of CO reduces the oxygen -
carrying capacity of the blood and can cause headaches, nausea, dizziness, and fatigue, impair central
nervous system function, and induce angina (chest pain) in persons with serious heart disease.
Extremely high levels of CO, such as those generated when a vehicle is running in an unventilated
garage, can be fatal.
(3) Particulate Matter. Particulate matter is a class of air pollutants that consists of hetero-
geneous solid and liquid airborne particles from manmade and natural sources. Particulate matter is
categorized in two size ranges: PMIo for particles less than 10 microns in diameter and PM2.5 for
particles less than 2.5 microns in diameter. In the Bay Area, motor vehicles generate about half of the
air basin's particulates, through tailpipe emissions as well as brake pad and tire wear. Wood burning in
fireplaces and stoves, industrial facilities, and ground -disturbing activities such as construction are
other sources of such fine particulates. These fine particulates are small enough to be inhaled into the
deepest parts of the human lung and can cause adverse health effects. According to the California Air
Resources Board (ARB), studies in the United States and elsewhere have demonstrated a strong link
between elevated particulate levels and premature deaths, hospital admissions, emergency room visits,
and asthma attacks, and studies of children's health in California have demonstrated that particle
pollution may significantly reduce lung function growth in children. The ARB also reports that
Statewide attainment of particulate matter standards could prevent thousands of premature deaths,
lower hospital admissions for cardiovascular and respiratory disease and asthma -related emergency
room visits, and avoid hundreds of thousands of episodes of respiratory illness in California.'
(4) Nitrogen Dioxide. NO2 is a reddish brown gas that is a byproduct of combustion
processes. Automobiles and industrial operations are the main sources of NO2. Aside from its
contribution to ozone formation, NO2 also contributes to other pollution problems, including a high
concentration of fine particulate matter, poor visibility, and acid deposition. NO2 may be visible as a
coloring component on high pollution days, especially in conjunction with high ozone levels. NO2
decreases lung function and may reduce resistance to infection. On January 22, 2010, the U.S.
Environmental Protection Agency (U.S. EPA) strengthened the health -based National Ambient Air
Quality Standards (NAAQS) for NO2.
(5) Sulfur Dioxide. SO2 is a colorless acidic gas with a strong odor. It is produced by the
combustion of sulfur -containing fuels such as oil, coal, and diesel. SO2 has the potential to damage
materials and can cause health effects at high concentrations. It can irritate lung tissue and increase
the risk of acute and chronic respiratory disease.4 SO2 also reduces visibility and the level of sunlight
at the ground surface.
(6) Lead. Lead is a metal found naturally in the environment as well as in manufactured
products. The major sources of lead emissions have historically been mobile and industrial sources.
As a result of the phase-out of leaded gasoline, metal processing is currently the primary source of
3 California Air Resources Board, 2011. Fact Sheets. Website: www.arb.ca.gov/htm/fslist.htm#Health.pdf. October.
4 Bay Area Air Quality Management District, 2012. CEQA Air Quality Guidelines. May
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lead emissions. The highest levels of lead in air are generally found near lead smelters. Other
stationary sources are waste incinerators, utilities, and lead -acid battery factories.
Twenty years ago, mobile sources were the main contributor to ambient lead concentrations in the air.
In the early 1970s, the U.S. EPA established national regulations to gradually reduce the lead content
in gasoline. In 1975, unleaded gasoline was introduced for motor vehicles equipped with catalytic
converters. The U.S. EPA banned the use of leaded gasoline in highway vehicles in December 1995.
As a result of the U.S. EPA's regulatory efforts to remove lead from gasoline, emissions of lead from
the transportation sector and overall levels of lead in the air decreased dramatically.
(7) Odors. Odors are also an important element of local air quality conditions. Specific
activities can raise concerns related to odors on the part of nearby neighbors. Major sources of odors
include restaurants and manufacturing plants. Other odor producers include the industrial facilities
within the region. While sources that generate objectionable odors must comply with air quality
regulations, the public's sensitivity to locally -produced odors often exceeds regulatory thresholds.
(8) Toxic Air Contaminants. In addition to the criteria pollutants discussed above, Toxic
Air Contaminants (TACs) are another group of pollutants of concern. Some examples of TACs
include: benzene, butadiene, formaldehyde, and hydrogen sulfide. Potential human health effects of
TACs include birth defects, neurological damage, cancer, and death. There are hundreds of different
types of TACs with varying degrees of toxicity. Individual TACs vary greatly in the health risk they
present; at a given level of exposure, one TAC may pose a hazard that is many times greater than
another.
TACs do not have ambient air quality standards, but are regulated by the U.S. EPA, ARB, and the
Bay Area Air Quality Management District (BAAQMD). In 1998, ARB identified particulate matter
from diesel -fueled engines as a TAC. ARB has completed a risk management process that identified
potential cancer risks for a range of activities and land uses that are characterized by use of diesel -
fueled engines.' High-volume freeways, stationary diesel engines, and facilities attracting heavy and
constant diesel vehicle traffic (distribution centers, truck stops) were identified as posing the highest
risk to adjacent receptors. Other facilities associated with increased risk include warehouse distribu-
tion centers, large retail or industrial facilities, high volume transit centers, and schools with a high
volume of bus traffic. Health risks from TACs are a function of both concentration and duration of
exposure.
Monitoring data and emissions inventories of TACs help the BAAQMD determine potential health
risks to Bay Area residents. Ambient monitoring concentrations of TACs indicate that pollutants
emitted primarily from motor vehicles (1,3 -butadiene and benzene) account for slightly over 50
percent of the average calculated cancer risk from ambient air in the Bay Area.6
5 California Air Resources Board, 2000. Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel -
Fueled Engines and Vehicles. October.
6 Bay Area Air Quality Management District, 2007. Toxic Air Contaminant Control Program Annual Report 2003
Volume 1. August.
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Unlike TACs emitted from industrial and other stationary sources noted above, most diesel particulate
matter is emitted from mobile sources — primarily "off-road" sources such as construction and mining
equipment, agricultural equipment, and truck -mounted refrigeration units, as well as trucks and buses
traveling on freeways and local roadways.
Agricultural and mining equipment is not commonly used in urban parts of the Bay Area, while
construction equipment typically operates for a limited time at various locations. As a result, the
readily identifiable locations where diesel particulate matter is emitted in the City of Cupertino
include high -traffic roadways and other areas with substantial truck traffic.
Although not specifically monitored, recent studies indicate that exposure to diesel particulate matter
may contribute significantly to a cancer risk (a risk of approximately 500 to 700 in 1,000,000) that is
greater than all other measured TACs combined .7 The technology for reducing diesel particulate
matter emissions from heavy-duty trucks is well established, and both State and federal agencies are
moving aggressively to regulate engines and emission control systems to reduce and remediate diesel
emissions. ARB anticipates that by 2020 average Statewide diesel particulate matter concentrations
will decrease by 85 percent from levels in 2000 with full implementation of the Diesel Risk Reduc-
tion Plan, meaning that the Statewide health risk from diesel particulate matter is expected to decrease
from 540 cancer cases in 1,000,000 to 21.5 cancer cases in 1,000,000. It is likely that the Bay Area
cancer risk from diesel particulate matter will decrease by a similar factor by 2020.
(9) High Volume Roadways. Air pollutant exposures and their associated health burdens
vary considerably within places in relation to sources of air pollution. Motor vehicle traffic is perhaps
the most important source of intra -urban spatial variation in air pollution concentrations. Air quality
research consistently demonstrates that pollutant levels are substantially higher near freeways and
busy roadways, and human health studies have consistently demonstrated that children living within
100 to 200 meters (328 to 656 feet) of freeways or busy roadways have reduced lung function and
higher rates of respiratory disease.'At present, it is not possible to attribute the effects of roadway
proximity on non -cancer health effects to one or more specific vehicle types or vehicle pollutants.
Engine exhaust, from diesel, gasoline, and other combustion engines, is a complex mixture of
particles and gases, with collective and individual toxicological characteristics. Four epidemiological
studies on roadways and health impacts conducted in California populations are described below.
• In Oakland, California, children at schools in proximity to high volume roadways experi-
enced more asthma and bronchitis symptoms.9
• In a low-income population of children in San Diego, children with asthma living within
550 feet of roadways with high traffic volumes were more likely than those residing near
roadways with lower traffic volumes to have more medical care visits for asthma.'o
Ibid.
8 Delfino, RJ., 2002. Epidemiologic Evidence for Asthma and Exposure to Air Toxics: Linkages Between
Occupational, Indoor, and Community Air Pollution Research Environmental Health Perspectives.
9 Kim, J., et al., 2004. Traffic -Related Air Pollution and Respiratory Health: East Bay Children's Respiratory Health
Study. American Journal of Respiratory and Critical Care Medicine.
10 English, P., et al., 1999. Examining Associations Between Childhood Asthma and Traffic Flow Using a Geo-
graphic Information System. Environmental Health Perspectives.
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• In a study of Southern California school children, residence location within 75 meters (246
feet) of a major road was associated with an increased risk of asthma."
• In a study conducted in 12 Southern California communities, children who lived within 500
feet of a freeway had reduced growth in lung capacity compared to those living greater than
1,500 feet from a freeway. 12
Federal and State regulations control air pollutants at the regional level by limiting vehicle and
stationary source emissions. However, air quality regulations have not limited the use of vehicles and
generally have not protected sensitive land uses from air pollution "hot spots" associated with
proximity to transportation facilities.
b. Existing Climate and Air Quality. Regional air quality, local climate, and air quality in the
Santa Clara Valley region, and air pollution climatology are described below.
(1) Local Climate and Topography. The City of Cupertino is located in the San Francisco
Bay Area, a large shallow air basin ringed by hills that taper into a number of sheltered valleys around
the perimeter. Two primary atmospheric outlets exist. One is through the strait known as the Golden
Gate, a direct outlet to the Pacific Ocean. The second extends to the northeast, along the west delta
region of the Sacramento and San Joaquin Rivers.
Air quality is a function of both local climate and local sources of air pollution. Air quality is the
balance of the natural dispersal capacity of the atmosphere and emissions of air pollutants from
human uses of the environment. Northwesterly and northerly winds are most common in Cupertino,
reflecting the orientation of the Bay and the San Francisco Peninsula. Winds from these directions
carry pollutants released by autos and factories from upwind areas of the Bay Area toward Cupertino,
particularly during the summer months. Winds are lightest on average in the fall and winter at which
time local pollutants tend to build up in the atmosphere.
Pollutants can be diluted by mixing in the atmosphere both vertically and horizontally. Vertical
mixing and dilution of pollutants are often suppressed by inversion conditions, when a warm layer of
air traps cooler air close to the surface. During the summer, inversions are generally elevated above
ground level, but are present over 90 percent of both the morning and afternoon hours. In winter, sur-
face -based inversions dominate in the morning hours, but frequently dissipate by afternoon.
Topography can restrict horizontal dilution and mixing of pollutants by creating a barrier to air
movement. The South Bay has significant terrain features that affect air quality. The Santa Cruz
Mountains and Diablo Range on either side of the South Bay restrict horizontal dilution, and this
alignment of the terrain also channels winds from the north to the south, carrying air pollution from
the northern Peninsula toward Cupertino.
11 McConnell, R., et al., 2006. Traffic, Susceptibility, and Childhood Asthma. Environmental Health Perspectives.
12 Gauderman, W. J. The Effect of Air Pollution on Lung Development From 10 to 18 Years of Age. New England
Journal of Medicine. September 2004 and March 2005.
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The combined effects of moderate ventilation, frequent inversions that restrict vertical dilution, and
terrain that restricts horizontal dilution give Cupertino a relatively high atmospheric potential for air
pollution compared to other parts of the San Francisco Bay Air Basin.
(2) Air Monitoring Data. The City of Cupertino is within the jurisdiction of the BAAQMD,
which has seen air quality conditions improve significantly since the BAAQMD was created in 1955.
Ambient concentrations of air pollutants and the number of days during which the region exceeds air
quality standards have fallen dramatically. Exceedances of air quality standards occur primarily
during meteorological conditions conducive to high pollution levels, such as cold, windless winter
nights or hot, sunny summer afternoons.
The Air Monitoring Program of the BAAQMD operates a 28 -station monitoring network which
provides the data required to determine whether the Bay Area is in compliance with State and federal
air quality standards. Most monitoring stations sample air levels for criteria pollutants, while only
some of the monitoring sites include toxics sampling equipment. The monitored toxic compounds
include benzene; 1,1,1 trichloroethane (TCA); trichloroethylene (TCE); chloroform (TCM); 1,2
dichloroethane (EDC); 1,2 dibromoethane (EDB); methylene dichloride (DCM); carbon tetrachloride,
and tetrachloroethylene (perc); and vinyl chloride and toluene (while not considered a toxic air
contaminant, toluene was chosen to better assess the origin of benzene emissions). In addition,
sampling for the heavy metals lead, nickel, manganese and total chromium is carried out at the five
ARB sites in Fremont, Richmond, Concord, San Francisco and San Jose.
Pollutant monitoring results for the years 2008 to 2012 at the 22601 Voss Avenue (Cupertino)
ambient air quality monitoring station (the closest monitoring station to the project site) and where
data were not available in Cupertino, the Jackson Street monitoring station in San Jose, are shown in
Table V.L-2.
Pollutant monitoring results shown in Table V.L-2 indicate that air quality in the project area has
generally been good. Based on the monitoring data, Cupertino air pollutant levels were well below all
applicable State and National Ambient Air Quality Standards for gaseous criteria pollutants including
ozone, CO, SO2, and NO2. In general, levels of criteria pollutants were in the middle of the distribu-
tion of Bay Area air monitoring sites, with as many locations measuring levels higher as locations
measuring lower than Cupertino. NO2 and SO2 levels are similar to levels at other suburban locations
within the Bay Area. The same was true for SO2 emissions, with measurements similar to San Pablo
and Concord. CO measurements in Cupertino were among the lowest in the Bay Area, with only the
rural location at Bethel Island being lower. SO2 and NO2 standards were not exceeded in this area
during the 4 -year pen od.13
Cupertino PM levels were among the lowest in the Bay Area, with levels similar to Redwood City
and Gilroy. The annual average PM2.5 levels were also below the NAAQS and the more stringent
annual average State standards, with levels similar to, but lower than, Livermore. No violations of the
State's PM2.5 standard were recorded during the 4 -year period. PM2.5 levels exceeded the federal 24-
hour standard five times in 2008 and three times in 2010.
13 Bay Area Air Quality Management District, 2012. Summary and Analysis of Cupertino Air Monitoring Results,
May 16.
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Table V.L-2: Ambient Air Quality at the 22601 Voss Ave, Cupertino, Monitoring Station
Pollutant
Standard
2008a
I 2009a
2010
2011
2012
Carbon Monoxide CO
Maximum 1 -hour concentration m
3.3
3.4
1.5
ND
1.9
Number of days exceeded:
State: > 20 ppm
0
0
0
0
0
Federal: > 35 ppm 0 0 0 0
0
Maximum 8 -hour concentration (ppm)
2.48
2.50
0.93
0.95
1 0.8
Number of days exceeded:
State: > 9 ppm
0
0
0
0
0
Federal: > 9 ppm 0 0 0 0
0
Ozone 03
Maximum 1 -hour concentration (ppm)
0.118
0.088
0.127
0.086
0.083
Number of days exceeded:
State: > 0.09 ppm
1
0
1
0
0
Maximum 8 -hour concentration (ppm)
0.080
0.068
0.092
0.067
0.066
Number of days exceeded:
State: > 0.07 ppm
3
0
3
0
0
Federal: > 0.08 ppm 2 0 1 0
0
Coarse Particulates PM,o
Maximum 24-hour concentration (µg/m)
57.3
43.3
27.9
28.3
39.0
Number of days exceeded:
State: > 50 µg/m
1
0
0
0
0
Federal: > 150 /m 0
0
0 0
0
Annual arithmetic average concentration (µg/in)
23
23
10.3
13.9
ND
Exceeded for the year:
State: > 20 µg/m
Federal: > 50 [Lj/m7_j
Yes
No
Yes
No
No
ND
I No
I No I No
ND
Fine Particulates PM2.5
Maximum 24-hour concentration /m
41.9
35.0
25.0
20.0
38.4a
Number of days exceeded:
Federal: > 35 µg/m
5
0
ND
ND
ND
Annual arithmetic average concentration (µg/m)
11.5
10.1
9.0
8.7
ND
Exceeded for the year:
State: > 12 µg/M3No
Federal: > 15 /m
No
No
No
ND
ND
I No I No ND
ND
Nitrogen Dioxide 02
Maximum 1 -hour concentration (ppm)
0.080
0.069
0.049
0.043
0.045
Number of days exceeded:
State: ->0.250 ppm
0
0
0
0
0
Annual arithmetic average concentration (ppm)
0.017
0.015
0.014 a
ND
ND
Exceeded for the year:
Federal: > 0.053 ppm
0
0
0
ND
ND
Sulfur Dioxide SO2
Maximum 1 -hour concentration (ppm)
ND
0.06
0.05
0.009
0.028
Number of days exceeded:
State: > 0.25 ppm
ND
0
0
0
0
Maximum 3 -hour concentration m
ND
ND
ND
ND
ND
Number of days exceeded:
Federal: > 0.50 ppm
ND
ND
ND
ND
ND
Maximum 24-hour concentration m
ND
0.001
0.003
0.003
0.003
Number of days exceeded:
State: > 0.04 ppm
ND
0
0
0
0
Federal: > 0.14 ppm ND 0 0 1 0
0
Annual arithmetic average concentration (ppm)
ND
ND
ND
0.0008
ND
Exceeded for the year:
I Federal: > 0.030 ppm
ND
ND
ND
ND
ND
a Results based on readings at the San Jose -Jackson Street monitoring station.
ppm = parts per million
µg/m3 = micrograms per cubic meter
ND = No data. There was insufficient (or no) data to determine the value.
Source: ARB, EPA, and BAAQMD, 2013.
As indicated in the monitoring results, exceedances of the State PMIo daily standard were recorded in
2008 and 2009 while no exceedances of the federal PMIo standards were recorded from 2008 to 2012.
The area is considered a nonattainment area for this pollutant relative to the State standards. The Bay
Area is an unclassified area for the federal PMIo standard. Cupertino lead levels for the year 2011
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were less than 1 percent of the State standard, less than 10 percent of the recently revised national
standard, and less than levels in San Francisco.
Ozone levels, measured by peak concentrations and the number of days over the State 1 -hour stan-
dard, have declined substantially as a result of aggressive programs by the BAAQMD and other
regional, State, and federal agencies. The reduction of peak concentrations represents progress in
improving public health. However, levels of ozone have exceeded the State's 1 -hour standard in 2008
and 2010; in addition, both the State and federal 8 -hour standards were exceeded in 2008 and 2010.
For ozone, levels at Cupertino were below the national standard and similar to Napa and Vallejo.
The BAAQMD also recently documented monitored toxic air contaminants in the City of Cupertino.
Results indicate that diesel PM concentrations contribute approximately 70 percent of the total cancer
risk at the Cupertino air monitoring site. Total cancer risk in Cupertino based on ambient air monitor-
ing data is 405 cancer cases in 1 million, which is somewhat less than the risk in Benicia and signifi-
cantly less than the risk in San Jose, Berkeley, and San Francisco. San Jose has the highest risk at 649
cases in 1 million. 14
Arsenic and mercury make the highest contribution to the chronic hazard index at the Cupertino site.
At other Bay Area air monitoring sites, the arsenic level of detection was not nearly as sensitive as the
Cupertino site, and mercury was not measured at all; for these reasons there is no Bay Area air
monitoring site that can reasonably be compared to the Cupertino site for arsenic and mercury.
However, based on a literature review, the arsenic and mercury concentrations measured at the
Cupertino site appear to be within or lower than the range found for rural areas. The annual average
concentration of arsenic measured at the Cupertino air monitoring site is 0.00018 microgram/cubic
meter (µg/m3). The annual average concentration of mercury measured at the Cupertino air monitor-
ing site is 0.0024 µg/m3 is Complete results for all toxic compounds are indicated in the BAAQMD's
report titled Summary and Analysis of Cupertino Air Monitoring Results from May 2012.
C. Regulatory Framework. Air quality standards, the regulatory framework, and State and
federal attainment status are discussed below.
The BAAQMD is primarily responsible for regulating air pollution emissions from stationary sources
(e.g., factories) and indirect sources (e.g., traffic associated with new development), as well as for
monitoring ambient pollutant concentrations. The BAAQMD's jurisdiction encompasses seven
counties — Alameda, Contra Costa, Marin, San Francisco, San Mateo, Santa Clara, and Napa — and
portions of Solano and Sonoma counties. The ARB and the U.S. EPA regulate direct emissions from
motor vehicles.
(1) United States Environmental Protection Agency. At the federal level, the U.S. EPA
has been charged with implementing national air quality programs. U.S. EPA's air quality mandates
are drawn primarily from the Federal Clean Air Act (FCAA), which was enacted in 1963. The FCAA
was amended in 1970, 1977, and 1990.
14 Ibid.
" Ibid.
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L. AIR QUALITY
The FCAA required U.S. EPA to establish primary and secondary NAAQS and required each state to
prepare an air quality control plan referred to as a State Implementation Plan (SIP). The Federal Clean
Air Act Amendments of 1990 (FCAAA) added requirements for states with nonattainment areas to
revise their SIPS to incorporate additional control measures to reduce air pollution. The SIP is
periodically modified to reflect the latest emissions inventories, planning documents, and rules and
regulations of the air basins as reported by their jurisdictional agencies. U.S. EPA has responsibility
to review all state SIPS to determine conformity with the mandates of the FCAAA and determine if
implementation will achieve air quality goals. If the U.S. EPA determines a SIP to be inadequate, a
Federal Implementation Plan (FIP) may be prepared for the nonattainment area, which imposes
additional control measures. Failure to submit an approvable SIP or to implement the plan within the
mandated timeframe may result in sanctions on transportation funding and stationary air pollution
sources in the air basin.
The U.S. EPA is also required to develop National Emission Standards for Hazardous Air Pollutants,
which are defined as those which may reasonably be anticipated to result in increased deaths or
serious illness and which are not already regulated. An independent science advisory board reviews
the health and exposure analyses conducted by the U.S. EPA on suspected hazardous pollutants prior
to regulatory development.
(2) California Air Resources Board. In 1992 and 1993, the ARB requested delegation of
authority for the implementation and enforcement of specified New Source Performance Standards
and National Emission Standards for Hazardous Air Pollutants to the BAAQMD. U.S. EPA's review
of the State of California's laws, rules, and regulations showed them to be adequate for the imple-
mentation and enforcement of federal standards, and the U.S. EPA granted the delegations as
requested.
The ARB is the agency responsible for the coordination and oversight of State and local air pollution
control programs in California and for implementing the California Clean Air Act (CCAA), adopted
in 1988. The CCAA requires that all air districts in the State achieve and maintain the California
Ambient Air Quality Standards (CAAQS) by the earliest practical date. The CCAA specifies that
districts should focus on reducing the emissions from transportation and air -wide emission sources,
and provides districts with the authority to regulate indirect sources.
ARB is also primarily responsible for developing and implementing air pollution control plans to
achieve and maintain the NAAQS. ARB is primarily responsible for Statewide pollution sources and
produces a major part of the SIP. Local air districts provide additional strategies for sources under
their jurisdiction. ARB combines this data and submits the completed SIP to U.S. EPA.
Other ARB duties include monitoring air quality (in conjunction with air monitoring networks main-
tained by air pollution control and air quality management districts), establishing CAAQS (which in
many cases are more stringent than the NAAQS), determining and updating area designations and
maps, and setting emissions standards for mobile sources, consumer products, small utility engines,
and off-road vehicles. The ARB's Diesel Risk Reduction Plan 16 is intended to substantially reduce
16 California Air Resources Board, 2000. Stationary Source Division and Mobile Source Control Division. Risk
Reduction Plan to Reduce Particulate Matter Emissions from Diesel -Fueled Engines and Vehicles. October.
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diesel particulate matter emissions and associated health risks through introduction of ultra -low -sulfur
diesel fuel — a step already implemented — and cleaner -burning diesel engines.
The State of California's regulatory efforts for toxic air contaminants are embodied in the Tanner
1311117 (effective 1984), which defines a process for the identification and control of toxic air contami-
nants. The ARB identifies the most important toxic pollutants by considering risk of harm to public
health, amount or potential amount of emissions, manner of usage of the substance, its persistence in
the atmosphere, and its concentration in outdoor air. The California Office of Environmental Health
Hazard Assessment prepares health assessment documents that outline the toxicity of compounds.
After a pollutant is listed as a toxic air contaminant, control measures are developed by the ARB and
local air districts.
Other relevant legislation is the Air Toxics "Hot Spots" Information and Assessment Act18 (AB2588).
This bill was enacted in 1987 with the objective of collecting information concerning industrial
emissions of toxic air contaminants and making the information available to the public. The bill
established a formal regulatory program for site-specific air toxics emissions inventory and health risk
quantification that is managed by California air districts. Under this program, a wide variety of
industrial, commercial, and public facilities are required to report the types and quantities of toxic
substances their facilities routinely release into the air. The goals of the Air Toxics Hot Spots
Program are to collect emissions data, identify facilities with potential for localized health impacts,
ascertain health risks, notify nearby residents of risks that are determined to warrant such notification,
and reduce significant risks.
Because of the robust evidence relating proximity to roadways and a range of non -cancer and cancer
health effects, the ARB also created guidance for avoiding air quality conflicts in land use planning in
its Air Quality and Land Use Handbook: A Community Health Perspective.19In its guidance, the
ARB advises that new sensitive uses (e.g. residences, schools, day care centers, playgrounds, and
hospitals) not be located within 500 feet of a freeway or urban roads carrying 100,000 vehicles per
day, or within 1,000 feet of a distribution center (warehouse) that accommodates more than 100
trucks or more than 90 refrigerator trucks per day.
ARB guidance suggests that the use of these guidelines be customized for individual land use
decisions, and take into account the context of development projects. The Air Quality and Land Use
Handbook specifically states that these recommendations are advisory and acknowledges that land
use agencies must balance other considerations, including housing and transportation needs, eco-
nomic development priorities, and other quality of life issues.
(3) National and State Ambient Air Quality Standards. Pursuant to the FCAA of 1970,
the U.S. EPA established NAAQS. The NAAQS were established for major pollutants, termed
"criteria" pollutants. Criteria pollutants are defined as those pollutants for which the federal and State
17 California Air Resources Board, 1997. Technical Support Document, Proposed Identification oflnorganic Lead
as a Toxic Air Contaminant. Part A — Exposure Assessment. March.
18 AB 2588, Connelly, 1987. Chaptered in the California Health and Safety Code Section 44300, et al.
19 California Environmental Protection Agency and Air Resources Board, 2005. Air Quality and Land Use
Handbook A Community Health Perspective. Website: www.arb.ca.gov/ch/landuse.htm.
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governments have established ambient air quality standards, or criteria, for outdoor concentrations in
order to protect public health.
Both the U.S. EPA and the ARB have established ambient air quality standards for the following
common pollutants: CO, 03, NO2, SO2, Pb, and PM. In addition, the State has set standards for
sulfates, hydrogen sulfide, vinyl chloride, and visibility -reducing particles. These standards are
designed to protect the health and welfare of the populace with a reasonable margin of safety. These
ambient air quality standards are levels of contaminants that avoid specific adverse health effects
associated with each pollutant.
Federal standards include both primary and secondary standards. Primary standards establish limits to
protect public health, including the health of sensitive populations such as asthmatics, children, and
the elderly. Secondary standards set limits to protect public welfare, including protection against
decreased visibility, and damage to animals, crops, vegetation, and buildings .20 State and federal
standards for the criteria air pollutants are listed in Table V.L-3.
(4) Bay Area Air Quality Management District. The BAAQMD seeks to attain and
maintain air quality conditions in the San Francisco Bay Area Air Basin through a comprehensive
program of planning, regulation, enforcement, technical innovation, and education. The clean air
strategy includes the preparation of plans for the attainment of ambient air quality standards, adoption
and enforcement of rules and regulations, and issuance of permits for stationary sources. The
BAAQMD also inspects stationary sources and responds to citizen complaints, monitors ambient air
quality and meteorological conditions, and implements programs and regulations required by law.
BAAQMD Regulation 721 places general limitations on odorous substances and specific emission
limitations on certain odorous compounds. This regulation limits the "discharge of any odorous
substance which causes the ambient air at or beyond the property line ... to be odorous and to remain
odorous after dilution with four parts of odor -free air." The BAAQMD must receive odor complaints
from ten or more complainants within a 90 -day period in order for the limitations of this regulation to
go into effect. If this criterion has been met, an odor violation can be issued by the BAAQMD if a test
panel of people can detect an odor in samples collected periodically from the source.
Clean Air Plan. The BAAQMD is responsible for developing a Clean Air Plan 22 which guides
the region's air quality planning efforts to attain the CAAQS. The BAAQMD's 2010 Clean Air Plan
is the latest Clean Air Plan which contains district -wide control measures to reduce ozone precursor
emissions (i.e., ROG and NO,), particulate matter, and greenhouse gas emissions.
20 U.S. Environmental Protection Agency, 2007. Website: www.epa.gov/air/clitelia.html. January.
21 Bay Area Air Quality Management District, 1982. Rules and Regulations, Regulation 7: Odorous Substances.
Amended March 17.
22 Bay Area Air Quality Management District, 2010. Bay Area 2010 Clean Air Plan. September.
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Table V.L-3: State and Federal Ambient Air Quality Standards
Table notes included on next page.
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Averaging
California Standardsa
Federal Standardsb
Concentration`
Method
Primary','
Seconda y`,f
Methodg
Pollutant
Time
1 -Hour
0.09 ppm
3
No Federal
Same as
Ozone
180 /m
Ultraviolet
Standard
Primary
Ultraviolet
8 -Hour
0.07 ppm
0.075 ppm
(03)
Photometry
Standard
Photometry
137 It /m3
147 /m3
Respirable
24 -Hour
50 /m
150 /m
Same as
Inertial
Annual
Particulate
Gravimetric or
Primary
Separation and
Matter
Arithmetic
20 pg/m3
Beta Attenuation
—
Standard
Gravimetric
(PM10
Mean
Analysis
Same as
Fine
24 -Hour
No Separate State Standard
35 pg/m3
Primary
Inertial
Particulate
Standard
Separation and
Matter
Annual
Gravimetric
Gravimetric
(PM2.5)
Arithmetic
12 Iug/m3
12 ug/mr I3
15 Iug/m3
Analysis
Mean
on
Beta Attenuation
8 -Hour
9.0 ppm
9 ppm
Carbon
10 Mg/M3)
Non -Dispersive
10 Mg/M3)
None
Non -Dispersive
1 -Hour
20 ppm
35 ppm
Monoxide
Infrared
Infrared
(CO)
23 m /m3
Photometry
40 Mg/M3)
Photometry
8 -Hour
6 ppm
(NDIR)
(NDIR)
Lake Tahoe
7 Mg/M3)
Annual
0.03m
53 b
Same as
Nitrogen
Arithmetic
(57 Itg/m3)
Gas Phase
(100 pg/m3)
Primary
Gas Phase
Dioxide
Mean
Chemilumi-
Standard
Chemilumi-
mTO2)h
(
nescence
nescence
1 -Hour
0.18 ppm
100 ppb
None
339 /m
188 /m3
30 -day
1.5 pg/m3
—
average
High -Volume
Calendar
1.5 pg/M3
Lead
Quarter
—
Atomic
(for certain
Same as
Sampler and
(Pb) ,k
Absorption
areas)k
Primary
Atomic
Rolling 3-
Standard
Absorption
month
—
0.15 pg/m3
average'
24 -Hour
0.04 ppm
0.14 ppm
(105 pg/m3)
(for certain areas)'
Ultraviolet
0.5 ppm
Sulfur
3 -Hour
—
_
1300 /m 3
Flourescence;
Dioxide
Ultraviolet
Spectro-
0.25 ppm
75 ppb
(S02)'
1 -Hour
655 /m3
Fluorescence
196 /m3
—
photometry
(Pararosanilin
Annual
Arithmetic
—
0.030 ppm
—
Method)
(for certain areas)
Mean
Extinction coefficient of 0.23 per
kilometer - visibility of 10 miles or more
Visibility-
(0.07-30 miles or more for Lake Tahoe)
Reducing
8 -Hour
due to particles when relative humidity is
No
Particles
less than 70 percent. Method: Beta
Attenuation and Transmittance through
Filter Tape.
Federal
Standards
Sulfates
24 -Hour
25 pg/m3
lon
Chromatography
Hydrogen
1 -Hour
0.03 ppm
Ultraviolet
Sulfide
42 /m3
Fluorescence
Vinyl
24 -Hour
0.01 ppm
Gas
Chloride`
26 /m3
Chromatography
Table notes included on next page.
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a California standards for ozone, carbon monoxide (except 8 -hour Lake Tahoe), sulfur dioxide (1- and 24-hour), nitrogen
dioxide, suspended particulate matter (PMIO, PM2.5, 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.
b 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. The ozone standard is attained when the fourth highest 8 -hour
concentration measured at each site in a year, averaged over 3 years, is equal to or less than the standard. For PMl0, the
24 hour standard is attained when the expected number of days per calendar year with a 24-hour average concentration
above 150 gg/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 3 years, are equal to or less than the standard. Contact U.S. EPA for further clarification
and current federal policies.
Concentration 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 torr. Most measurements of air quality are to be
corrected to a reference temperature of 25°C and a reference pressure of 760 torr; ppm in this table refers to ppm by
volume, or micromoles of pollutant per mole of gas.
d Any equivalent procedure which can be shown to the satisfaction of the ARB to give equivalent results at or near the
level of the air quality standard may be used.
National Primary Standards: The levels of air quality necessary, with an adequate margin of safety to protect the public
health.
1 National Secondary Standards: The levels of air quality necessary to protect the public welfare from any known or
anticipated adverse effects of a pollutant.
9 Reference method as described by the U.S. EPA. An "equivalent method" of measurement may be used but must have a
"consistent relationship to the reference method" and must be approved by the U.S. EPA.
h To attain the 1 -hour national standard, the 3 -year average of the annual 98th percentile of the 1 -hour daily maximum
concentrations at each site must not exceed 100 ppb. Note that the national standards are in units of parts per billion
(ppb). California standards are in units of parts per million (ppm). To directly compare the national standards to the
California standards the units can be converted from ppb to ppm. In this case, the national standards of 53 ppb and 100
ppb are identical to 0.053 ppm and 0.100 ppm, respectively.
On June 2, 2010, a new 1 -hour SO2 standard was established and the existing 24-hour and annual primary standards were
revoked. To attain the 1 -hour national standard, the 3 -year average of the annual 99th percentile of the 1 -hour daily
maximum concentrations at each site must not exceed 75 ppb. The 1971 SO2 national standards (24-hour and annual)
remain in effect until one year after an area is designated for the 2010 standard, except that in areas designated
nonattainment for the 1971 standards, the 1971 standards remain in effect until implementation plans to attain or maintain
the 2010 standards are approved. Note that the 1 -hour national standard is in units of parts per billion (ppb). California
standards are in units of parts per million (ppm). To directly compare the 1 -hour national standards to the California
standard the units can be converted to ppm. In this case, the national standard of 75 ppb is identical to 0.075 ppm.
The ARB has identified lead and vinyl chloride as "toxic air contaminants" with no threshold level of exposure for
adverse health effects determined. These actions allow for the implementation of control measures at levels below the
ambient concentrations specified for these pollutants.
k The national standard for lead was revised on October 15, 2008, to a rolling 3 -month average. The 1978 lead standard
(1.5 gg/m3 as a quarterly average) remains in effect until one year after an area is designated for the 2008 standard,
except that in areas designated nonattainment for the 1978 standard, the 1978 standard remains in effect until
implementation plans to attain or maintain the 2008 standard are approved.
In 1989, the ARB converted both the general Statewide 10 -mile visibility standard and the Lake Tahoe 30 -mile visibility
standard to instrumental equivalents, which are "extinction of 0.23 per kilometer" and "extinction of 0.07 per kilometer'
for the Statewide and Lake Tahoe Air Basin standards, respectively.
°C = degrees Celsius
ARB = California Air Resources Board
U.S. EPA = United States Environmental Protection Agency
µg/m3 = micrograms per cubic meter
Mg/M3 = milligrams per cubic meter
ppm = parts per million
ppb = parts per billion
Source: ARB, 2013.
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The Bay Area 2010 Clean Air Plan, which was adopted on September 15, 2010 by the BAAQMD's
board of directors:
• Updates the Bay Area 2005 Ozone Strategy in accordance with the requirements of the
California Clean Air Act to implement "all feasible measures" to reduce ozone;
• Provides a control strategy to reduce ozone, PM, TACs, and greenhouse gases in a single,
integrated plan;
• Reviews progress in improving air quality in recent years; and
• Establishes emission control measures to be adopted or implemented in the 2010 to 2012
timeframe.
BAAQMD CARE Program. The Community Air Risk Evaluation (CARE) program was
initiated in 2004 to evaluate and reduce health risks associated with exposures to outdoor TACs in the
Bay Area. The program examines TAC emissions from point sources, area sources, and on -road and
off-road mobile sources with an emphasis on diesel exhaust, which is a major contributor to airborne
health risk in California. The CARE program is an on-going program that encourages community
involvement and input. The technical analysis portion of the CARE program is being implemented in
three phases that include an assessment of the sources of TAC emissions, modeling and measurement
programs to estimate concentrations of TACs, and an assessment of exposures and health risks.
Throughout the program, information derived from the technical analyses will be used to focus
emission reduction measures in areas with high TAC exposures and a high density of sensitive
populations. Risk reduction activities associated with the CARE program are focused on the most at -
risk communities in the Bay Area. The BAAQMD has identified six affected communities. The City
of Cupertino has not been included as an affected community. However, nearby Redwood City, East
Palo Alto, and San Jose have all been identified as in need of immediate mitigation action.
For commercial and industrial sources, the BAAQMD regulates TACs using a risk-based approach.
This approach uses a health risk assessment to determine what sources and pollutants to control as
well as the degree of control. A health risk assessment is an analysis in which human health exposure
to toxic substances is estimated and considered together with information regarding the toxic potency
of the substances, in order to provide a quantitative estimate of health risks.23 As part of ongoing
efforts to identify and assess potential health risks to the public, the BAAQMD has collected and
compiled air toxics emissions data from industrial and commercial sources of air pollution throughout
the Bay Area.
BAAQMD CEQA Air Quality Guidelines. The BAAQMD CEQA Air Quality Guidelines
were prepared to assist in the evaluation of air quality impacts of projects and plans proposed within
the Bay Area. The guidelines provide recommended procedures for evaluating potential air impacts
during the environmental review process, consistent with CEQA requirements, and include recom-
mended thresholds of significance, mitigation measures, and background air quality information.
They also include recommended assessment methodologies for air toxics, odors, and greenhouse gas
emissions. In June 2010, the BAAQMD's Board of Directors adopted CEQA thresholds of signifi-
23 In general, a health risk assessment is required if the BAAQMM concludes that projected emissions of a specific air
toxic compound from a proposed new or modified source suggests a potential public health risk. Such an assessment generally
evaluates chronic, long-term effects, including the increased risk of cancer as a result of exposure to one or more TACs.
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cance and an update of the CEQA Guidelines. In May 2011, the updated BAAQMD CEQA Air
Quality Guidelines24 were amended to include a risk and hazards threshold for new receptors and
modified procedures for assessing impacts related to risk and hazard impacts.
On March 5, 2012, the Alameda County Superior Court issued a judgment finding that the BAAQMD
had failed to comply with CEQA when it adopted the thresholds of significance in the BAAQMD
CEQA Air Quality Guidelines. The court did not determine whether the thresholds of significance
were valid on their merits, but found that the adoption of the thresholds was a project under CEQA.
The court issued a writ of mandate ordering the BAAQMD to set aside the thresholds and cease
dissemination of them until the BAAQMD complied with CEQA. In May of 2012, the BAAQMD
filed an appeal of the court's decision, the results of which are pending as of May 2013.
In view of the court's order, the BAAQMD is no longer recommending that the thresholds of
significance from the 2011 CEQA Air Quality Guidelines be used as a generally applicable measure
of a project's significant air quality impacts.25 Following the court's order, the BAAQMD released
revised CEQA Air Quality Guidelines in May of 2012 that include guidance on calculating air
pollution emissions, obtaining information regarding the health impacts of air pollutants, and
identifying potential mitigation measures, and which set aside the significance thresholds. The
BAAQMD recognizes that lead agencies may rely on the previously recommended Thresholds of
Significance contained in its CEQA Guidelines adopted in 1999.26
The court's invalidation of BAAQMD's thresholds presents uncertainty for current project applicants
and local agencies regarding proper evaluation of air quality and greenhouse gas emissions in CEQA
documents. Although reliance on the 2011 thresholds is no longer required, local agencies still have a
duty to evaluate impacts related to air quality and greenhouse gas emissions. In addition, CEQA
grants local agencies broad discretion to develop their own thresholds of significance, or to rely on
thresholds previously adopted or recommended by other public agencies or experts so long as they are
supported by substantial evidence.27 Accordingly, the City of Cupertino is using the BAAQMD's
2011 thresholds to evaluate project impacts in order to protectively evaluate the potential effects of
the project on air quality. The City believes that these protective thresholds are appropriate in the
context of the size, scale, and location of the project in close proximity to sensitive residential uses.
The City also notes that the Alameda County Superior Court, in ordering BAAQMD to set aside the
thresholds, did not address the merits of the science or evidence supporting the thresholds. The City
finds that, despite the court ruling, the science and reasoning contained in the BAAQMD 2011 CEQA
Air Quality Guidelines provide the latest state-of-the-art guidance available. For that reason, substan-
tial evidence supports continued use of the BAAQMD 2011 CEQA Air Quality Guidelines.
24 Bay Area Air Quality Management District, 2011, op. cit
25 Bay Area Air Quality Management District, 2013. Website: baagmd.Rov/Divisions/Planning-and-
Research/CEQA-Guidelines. aspx.
26 Bay Area Air Quality Management District, 1999. BAAQMD CEQA Guidelines, Assessing the Air Quality
Impacts of Projects and Plans. December
27 Public Resources Code Section 21082: 14 Cal. Code Regs. And Section 15064.7, 15064.4 (addressing greenhouse
gas emissions impacts). See also Citizens for Responsible and Equitable Environmental Development v. City of Chula Vista
(2011) 197 Cal.App.4th.327 (upholding city's greenhouse gas emissions threshold based on Assembly Bill 32 compliance).
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(5) Attainment Status Designations. The ARB is required to designate areas of the State as
attainment, nonattainment, or unclassified for each State standard. An "attainment" designation for an
area signifies that pollutant concentrations did not violate pollutant standards. A "nonattainment"
designation indicates that a pollutant concentration violated the standard at least once, excluding
those occasions when a violation was caused by an exceptional event, as defined in the criteria. An
"unclassified" designation signifies that data do not support either an attainment or nonattainment
status. The law divides districts into moderate, serious, and severe air pollution categories, with
increasingly stringent control requirements mandated for each category.
The U.S. EPA designates areas for ozone, CO, and NO2 as "does not meet the primary standards,"
"cannot be classified," or "is better than national standards." For SO2, areas are designated as "does
not meet the primary standards," "does not meet the secondary standards," "cannot be classified" or
"is better than national standards." In 1991, new nonattainment designations were assigned to areas
for PMIo based on the likelihood that they would violate national PMIo standards. All other areas are
designated "unclassified." Table V.L-4 provides a summary of the attainment status for the San
Francisco Bay Area with respect to national and State ambient air quality standards.
Table V.L-4: Bay Area Attainment Status
Table notes included on next page.
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California Standards a
National Standards n
Attainment
Attainment
Averaging
Pollutant
Time
Concentration
Status
Concentration `j
Status
8 -Hour
0.070 pp3m
Nonattainment h
0.075 ppm
Nonattamment d
Ozone
(03)
1 -Hour
1809 ppm
Nonattainment
Not Applicable
Not Applicable e
8 -Hour
m
Attainments
Carbon
10 Mg/M3)Attainment
10 /m3
Monoxide (CO)
1 -Hour
20 ppm 3
23 m /m
Attainment
35 ppm 3
40 m /m
Attainment
1 -Hour
0.18 ppm
339 /m
Attainment
0.100 ppm
Unclassified
Nitrogen Dioxide
Annual
(NO2)
Arithmetic
0.030 ppm
Not Applicable
0.053 ppm
Attainment
Mean
(57 µg/m3)
(100 µg/m3)
24 -Hour
0.04 ppm
Attainment
3654 ppm3
Attainment
Sulfur Dioxide
1 -Hour
0.25 ppm
655 /m
Attainment
Not Applicable
Not Applicable
(SO2)
Annual
Arithmetic
Not Applicable
Not Applicable
0.030 ppm
(80 µg/m3)
Attainment
Mean
Particulate
Annual
Arithmetic
20 µg/m
Nonattamment 9
Not Applicable
Not Applicable
Matter
Mean
Coarse (PM10)
24 -Hour
50 /m
Nonattamment
150 /m
Unclassified
Particulate
Annual
Arithmetic
3
12 µg/m
Nonattamment 9
12 µg/m3
Attainment
Matter
Fine (PM2.5)Mean
24 -Hour
Not A licable
Not Applicable
35 /m
Nonattainment
Table notes included on next page.
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a California standards for ozone, carbon monoxide (except in the Lake Tahoe air basin), sulfur dioxide (1 -hour and 24-
hour), nitrogen dioxide, suspended particulate matter — PM10, and visibility reducing particles are values that are not to be
exceeded. The standards for sulfates, Lake Tahoe carbon monoxide, lead, hydrogen sulfide, and vinyl chloride are not to
be equaled or exceeded. If the standard is for a 1 -hour, 8 -hour or 24-hour average (i.e., all standards except for lead and
the PM10 annual standard), then some measurements may be excluded. In particular, measurements are excluded that
ARB determines would occur less than once per year on average. The Lake Tahoe CO standard is 6.0 ppm, a level one-
third the national standard and two-thirds the State standard.
b National standards shown are the "primary standards" designed to protect public health. National standards other than for
ozone, particulates and those based on annual averages are not to be exceeded more than once a year. The 1 -hour ozone
standard is attained if, during the most recent 3 -year period, the average number of days per year with maximum hourly
concentrations above the standard is equal to or less than 1. The 8 -hour ozone standard is attained when the 3 -year
average of the fourth highest daily concentrations is 0.075 ppm (75 ppb) or less. The 24-hour PM10 standard is attained
when the 3 -year average of the 99th percentile of monitored concentrations is less than 150 µg/m3. The 24-hour PM2.5
standard is attained when the 3 -year average of 98th percentiles is less than 35 µg/m3. Except for the national particulate
standards, annual standards are met if the annual average falls below the standard at every site. The national annual
particulate standard for PM10 is met if the 3 -year average falls below the standard at every site. The annual PM2.5 standard
is met if the 3 -year average of annual averages spatially -averaged across officially -designed clusters of sites falls below
the standard.
National air quality standards are set by U.S. EPA at levels determined to be protective of public health with an adequate
margin of safety.
d In June 2004, the Bay Area was designated as a marginal nonattainment area for the national 8 -hour ozone standard. U.S.
EPA lowered the national 8 -hour ozone standard from 0.80 to 0.75 PPM (i.e., 75 ppb), effective May 27, 2008.
The national 1 -hour ozone standard was revoked by U.S. EPA on June 15, 2005.
f In April 1998, the Bay Area was redesignated to attainment for the national 8 -hour carbon monoxide standard.
9 In June 2002, ARB established new annual standards for PM2.5 and PM10.
h The 8 -hour California ozone standard was approved by the ARB on April 28, 2005 and became effective on May 17,
2006.
U.S EPA lowered the 24-hour PM2.5 standard from 65 µg/m3 to 35 µg/m3 in 2006. The U.S. EPA designated the Bay
Area as nonattainment for the 35 µg/m3 PM2.5 standard on October 8, 2009. The effective date of the designation is
December 14, 2009, and the BAAQMD has 3 years to develop a plan called a State Implementation Plan (SIP) that
demonstrates how the Bay Area will achieve the revised standard by 2014. The SIP for the new standard must be
submitted to the U.S. EPA by December 14, 2012.
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).
Lead (Pb) is not listed in the above table because it has been in attainment since the 1980s.
ppm = parts per million
Mg/M3 = milligrams per cubic meter
µg/m3 = micrograms per cubic meter
Source: Bay Area Air Quality Management District, Bay Area Attainment Status, 2013.
(6) City of Cupertino General Plan. The Environmental Resources/Sustainability Element
of the Cupertino General Plan includes the following policies related to air quality.28
Policy 5-4: Air Pollution Effects of New Development
Minimize the air quality impacts of new development projects and the impacts affecting new development.
28 Cupertino, City of, 2005. Cupertino General Plan. November.
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Strategies
1. Toxic Air Contaminants. Review projects for potential generation of toxic air contaminants at the
time of approval and confer with BAAQMD on controls needed if impacts are uncertain.
2. Dust Control. Require water application to non-polluting dust control measures during demolition
and the duration of the construction period.
3. Planning Decisions. Assess the potential for air pollution effects of future land use and transportation
planning, and ensure that planning decisions support regional goals of improving air quality.
4. Environmental Review. Evaluate the relationship of sensitive receptors, such as convalescent
hospitals and residential uses, to pollution sources through the environmental assessment of new
development.
Policy 5-5: Air Pollution Effects of Existing Development
Minimize the air quality impacts of existing development.
Strategies
1. Public Education Programs. Establish a Citywide public education program regarding the
implications of the Clean Air Act and provide information on ways to reduce and control emissions;
provide information about carpooling and restricting physical activities on "Spare the Air" high -
pollution days.
2. Home Occupations. Expand the allowable home occupations in residentially zoned properties to
reduce the need to commute to work.
3. Tree Planting. Increase planting of trees on City property and encourage the practice on private
property.
4. Fuel -Efficient Vehicles. Maintain City use of fuel-efficient and low polluting vehicles.
Policy 5-6: Walking, Jogging and Bicycling
Encourage walking, jogging and bicycling instead of driving in the City.
Policy 5-7: Use of Open Fires and Fireplaces. Discourage high pollution fireplace use.
Strategies
1. BAAQMD Literature. Make available BAAQMD literature on reducing pollution from fireplace use.
2. Installation of New Fireplaces. Prohibit the use of wood -burning fireplaces in new construction,
except for Environmental Protection Agency Certified Woodstoves.
2. Impacts and Mitigation Measures
This section provides an assessment of the potential adverse impacts related to air quality associated
with the proposed project. It begins with the criteria of significance, which establish the thresholds for
determining whether an impact is significant. The latter part of this section identifies potential
impacts. Where potentially significant impacts are identified, mitigation measures are recommended.
a. Significance Criteria. Consistent with guidance from the BAAMQD and Appendix G of the
CEQA Guidelines, the proposed project would have a significant impact on the environment related to
air quality if it would:
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• Violate any air quality standard or contribute substantially to an existing or projected air
quality violation by:
C Contributing to CO concentrations exceeding the State ambient air quality standards;
Generate construction emissions of ROG, NOx or PM2.5 greater than 54 pounds per day
or PM10 exhaust emissions greater than 82 pounds per day; or
Generate operational emissions of ROG, NOx or PM2.5 of greater than 10 tons per year
or 54 pounds per day, or PMJo emissions greater than 15 tons per year or 82 pounds per
day.
• Result in a cumulatively considerable net increase of any criteria pollutant for which the
project region is non -attainment under an applicable federal or State ambient air quality
standard (including releasing emissions which exceed quantitative thresholds for ozone
precursors);
• Expose sensitive receptors or the general public to substantial pollutant concentrations by:
o Individually exposing sensitive receptors (such as residential areas) to toxic air
contaminants in excess of the following thresholds:
■ Increased cancer risk greater than 10.0 in one million;
■ Increased non -cancer risk of greater than 1.0 on the hazard index (chronic or
acute);
■ Ambient PM2.5 increase greater than 0.3 µg/m3 annual average; or
o Cumulatively exposing sensitive receptors to toxic air contaminants in excess of the
following thresholds:
■ Increased cancer risk greater than 100.0 in one million;
■ Increased non -cancer risk of greater than 10.0 on the hazard index (chronic);
■ Ambient PM2.5 increase greater than 0.8 µg/m3 annual average;
• Conflict with or obstruct implementation of the current Air Quality Plan; or
• Create objectionable odors affecting a substantial number of people.
The emission thresholds were established based on the attainment status of the air basin for specific
criteria pollutants. Because the concentration standards were set at a level that protects public health
with an adequate margin of safety according to the U.S. EPA, these emission thresholds are regarded
as protective.
For purposes of assessing impacts, this analysis evaluates air quality emissions associated with
conditions on the site as of August 2011, at the time the Notice of Preparation was published. Under
the August 2011 baseline conditions, approximately 4,844 employees worked on the project site. The
current employee numbers on the site reflect Apple's relocation of its employees in preparation for
the project and Hewlett Packard's consolidation of its employees in Palo Alto. The site has histori-
cally operated at its capacity level of 9,800 employees.
b. Less -Than -Significant Impacts. Implementation of the project would result in less -than -
significant air quality impacts related to odors and consistency with the BAAQMD Clean Air Plan.
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(1) Odors. During construction, the various diesel powered vehicles and equipment in use
on-site would create localized odors. These odors would be temporary and are not likely to be
noticeable for extended periods of time beyond the project site. The potential for diesel odor impacts
is therefore considered less than significant. Odors from existing uses are not generally noticeable
beyond the site boundary. A public records request to the BAAQMD revealed no odor complaints at
the existing project site (which includes Apple office and research and development facilities). The
proposed uses that would be developed within the project site would be similar to existing uses with
the addition of open space, and are not expected to produce any offensive odors that would result in
frequent odor complaints.
(2) Consistency with BAAQMD's Clean Air Plan. The applicable air quality plan is the
BAAQMD 2010 Clean Air Plan, which was adopted on September 15, 2010. The Clean Air Plan is a
comprehensive plan to improve Bay Area air quality and protect public health. The Clean Air Plan
defines a control strategy to reduce emissions and ambient concentrations of air pollutants; safeguard
public health by reducing exposure to air pollutants that pose the greatest health risk, with an
emphasis on protecting the communities most heavily affected by air pollution; and reduce green-
house gas emissions to protect the climate. Consistency with the Clean Air Plan can be determined if
the project does the following: 1) supports the goals of the Clean Air Plan; 2) includes applicable
control measures from the Clean Air Plan; and 3) would not disrupt or hinder implementation of any
control measures from the Clean Air Plan. The project's consistency with these objectives is
described below.
1) Does the project support the goals of the Clean Air Plan?
The primary goals of the 2010 Bay Area Clean Air Plan are to: attain air quality standards; reduce
population exposure to air pollutants and protect public health in the Bay Area; and reduce green-
house gas emissions and protect the climate.
The BAAQMD has established significance thresholds for project construction and operational
impacts at a level at which the cumulative impact of exceeding these thresholds would have an
adverse impact on the region's attainment of air quality standards. The health and hazards thresholds
were established to help protect public health.
As discussed in this section of the EIR and as described in the project description, the project would
result in significant construction and operational emission impacts; however, the project contains
numerous features that would benefit regional air quality and support the goals of the Clean Air Plan,
including:
• A construction plan that maximizes the use of renewable energy and clean engine
technology to reduce exposure to air pollutants;
• A comprehensive Transportation Demand Management (TDM) Program designed to
reduce reliance on single -occupancy vehicles;
• Provision of electric vehicle parking spaces; and
• Utilization of renewable energy sources and renewable energy credits for the entire project
electricity demand.
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In addition, long-term operation of the project would not significantly affect exposure to air pollut-
ants. Overall, the project supports the goals of the Clean Air Plan.
2) Does the project include applicable control measures from the Clean Air Plan?
The control strategies of the 2010 Clean Air Plan include measures in the following categories:
stationary source measures, mobile source measures, and transportation control measures. This latest
Clean Air Plan also identifies two additional subcategories of control measures, which are land use
and local impact measures and energy and climate measures. Stationary source measures in the Clean
Air Plan such as those to control emissions from metal melting facilities, cement kilns, refineries, and
glass furnaces are not applicable to the proposed project. Therefore, consistency with the Clean Air
Plan stationary source measures is not evaluated further in this EIR. The project's consistency with
other measures in the 2010 Clean Air Plan is discussed below.
Transportation and Mobile Source Control Measures. The transportation control measures
in the 2010 Clean Air Plan are designed to reduce emissions from motor vehicles by reducing vehicle
trips and vehicle miles traveled (VMT) in addition to vehicle idling and traffic congestion.
Mobile Source Control Measure (MSM) A-2, Zero Emission Vehicles and Plug -In Hybrids, supports
State and federal efforts to expand the use of Zero Emission Vehicles and Plug -In Hybrids by promo-
tion of these vehicles through local business and local governments. The proposed project would
include 300 electric vehicle charging stations, with infrastructure to provide up to a total of 1,000
spaces. Therefore, the project is consistent with MSM A-2.
Transportation Control Measure (TCM) C-1, Voluntary Employer -Based Trip Reduction Programs,
supports voluntary efforts by Bay Area employers to encourage their employees to use alternative
commute modes, such as transit, ride sharing, bicycling, walking, or telecommuting. The purpose of
this measure is to reduce ozone precursor emissions by reducing commute trips, VMT, and vehicle
emissions. In addition this measure is intended to reduce emissions of particulate matter, air toxics,
and greenhouse gases. Apple currently operates a comprehensive TDM Program that is designed to
reduce the use of single -occupancy motor vehicles and encourage the use of carpooling, transit,
biking, and walking for work-related trips. The current program includes privately -operated buses and
shuttle services throughout the Bay Area, on-site bike facilities, transit subsidies, and on-site ameni-
ties (to reduce the need for employees to make off-site trips during the day). Apple intends to main-
tain this program and expand its measures as part of the project. These new or expanded TDM
measures could include the following (refer to Section V.1, Transportation and Circulation, for
additional detail):
• Expanded transit service hours, number of shuttles, connections, and areas served.
• Improved off -campus bicycle infrastructure.
• A transit center with an information desk on alternative commute options.
• Expanded bike -sharing program.
• Expanded Mobile Transit Applications.
• Improved signage and visibility of transit stops.
• Increased bicycle awareness.
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• Flexible work schedule for employees.
• Rewards program for alternative commute participants.
• Subsidized bicycle tune-ups.
• Real-time ridesharing to commute website.
• Employee telecommute options.
• Expanded car -sharing fleet.
• Universal transit passes for all Cupertino -based employees.
• Parking cash -out option for Cupertino -based employees.
In addition, the project includes extensive on-site pedestrian facilities, which would make it easy for
employees to move around the site by foot. The project would provide on-site support services such
as a fitness center and food services, which would minimize outside travel during the day, thus
reducing mid-day vehicle trips. These measures would reduce vehicle trips generated by the project
and would be consistent with TCM C-1 of the Clean Air Plan.
TCM D-1, Bicycle Access and Facilities Improvements, is intended to expand bicycle facilities
serving employment sites, educational and cultural facilities, residential areas, shopping districts, and
other activity centers. Typical improvements include bike lanes, routes, paths, and bicycle parking
facilities. This measure is designed to reduce ozone precursor emissions by sustaining and improving
bicycle access and facilities throughout the Bay Area. The project would provide bicycle access to the
project site and would provide bike racks on-site. In addition, the project would improve existing bike
and pedestrian infrastructure and facilities on streets surrounding the project site, including East
Homestead Road, North Tantau Avenue, Vallco Parkway, and North Wolfe Road. These improve-
ments would supplement existing nearly contiguous bike and pedestrian facilities on these streets and
would include graphically -enhanced bike lanes, landscaping, signage, and continuous sidewalks.
However, the proposed removal of a segment of Pruneridge Avenue as part of the project would
remove a section of roadway with an existing bicycle facility and would not provide a functionally
equivalent bicycle facility across the site.
Pruneridge Avenue currently functions as a motor vehicle, transit, bike, and partial pedestrian route
(as sidewalks do not connect on the south side of Pruneridge Avenue) between North Tantau Avenue
and North Wolfe Road (both of which contain bike facilities). It functions as the western segment of a
longer -distance bike route that starts in the City of Santa Clara and allows cyclists to bypass busier,
higher -volume roadways.
The removal of the segment of Pruneridge Avenue within the project site would require cyclists and
pedestrians (traveling from the vicinity of North Tantau Avenue and Pruneridge Avenue to points
west of the project site) to either proceed along North Tantau Avenue to the north, connecting to East
Homestead Road, and North Wolfe Road, the latter two of which are high-volume, multi -lane road-
ways, or proceed on North Tantau Avenue to the south, connecting to Vallco Parkway and North
Wolfe Road. The impact that removal of Pruneridge Avenue would have on bicyclists and pedestrians
would depend on their destination. For example, a bicyclist or pedestrian wishing to reach the inter-
section of North Wolfe Road and Pruneridge Avenue from points to the east of the project site could
take a detour around the site that would increase travel distance by approximately 0.5 mile over
current conditions.
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Alternatively, a bicyclist or pedestrian traveling to Vallco Shopping Mall, Stevens Creek or Cupertino
City Center from a location east of the project site could proceed south along Tantau Avenue and
west along Vallco Parkway for a trip of approximately the same distance as under existing conditions.
Similarly, a bicyclist or pedestrian located east of the project site traveling towards the North Wolfe
Road/Homestead Road intersection and beyond could travel approximately the same distance around
the site using Tantau Avenue and Homestead Road. The project would provide several bicycle and
pedestrian improvements along these alternative routes, making them safer and easier to navigate than
under existing conditions.
Therefore, the effect of the removal of the segment of Pruneridge Avenue on bicyclists and pedestri-
ans would be mixed. Some bicyclists and pedestrians would experience longer travel times and routes
that are more difficult to navigate on a bicycle or by foot as a result of the removal of the segment of
Pruneridge Avenue, while other pedestrians and bicyclists would have approximately equivalent
alternate routes in terms of distance and an improved experience due to new and improved bicycle
facilities.
In general, notwithstanding effects to alternate transportation modes associated with the removal of a
segment of Pruneridge Avenue, the project would promote the BAAQMD's initiatives to reduce
driving and increase the use of alternate means of transportation, primarily through the implementa-
tion of a comprehensive TDM Program. Therefore, in general, the project would include the
applicable Transportation Demand and Control Measures from the BAAQMD's Clean Air Plan and
would be consistent with TCM D-1 of the Clean Air Plan.
Land Use and Local Impact Measures. The BAAQMD's 2010 Clean Air Plan includes Land
Use and Local Impacts Measures to achieve the following: ensure that planned growth is focused in a
way that protects people from exposure to air pollution associated with stationary and mobile sources
of emissions; and promote mixed-use, compact development to reduce motor vehicle travel and
emissions. The Land Use and Local Impact Measures identified by the BAAQMD are not specifically
applicable to the proposed project as they relate to actions the BAAQMD will take to reduce impacts
from goods movement and health risks in affected communities at the plan level. The measures also
detail new regulatory actions the BAAQMD will undertake related to land use, including updates to
the CEQA Air Quality Guidelines, with which this project would comply, and indirect source review,
which is still under development by the BAAQMD. Therefore, the project would not conflict with
any of the Land Use and Local Impact Measures of the Bay Area 2010 Clean Air Plan.
Energy Measures. The BAAQMD's 2010 Clean Air Plan also includes Energy and Climate
Control Measures (ECM), which are designed to reduce ambient concentrations of criteria pollutants
and reduce emissions of CO2. Implementation of these measures is intended to promote energy
conservation and efficiency in buildings throughout the community, promote renewable forms of
energy production, reduce the "urban heat island" effect by increasing reflectivity of roofs and
parking lots, and promote the planting of (low volatile organic compound emitting) trees to reduce
biogenic emissions, lower air temperatures, provide shade, and absorb air pollutants.
ECM -1, Energy Efficiency, is intended to promote energy efficiency through education and outreach,
and technical assistance to local governments, and provide incentives for increased energy efficiency
in schools. The purpose of this measure is to reduce the amount of energy consumed in the Bay Area.
This measure is not specifically applicable to the proposed project; however the project would meet
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or exceed Cupertino's green building requirements and contains extensive energy efficiency
measures. Therefore, the project would not conflict with this measure.
ECM -2, Renewable Energy, is intended to promote the incorporation of renewable energy sources
into new development and foster innovative renewable energy projects through the provision of
incentives to reduce energy consumption. This measure is not specifically applicable to the proposed
project; however, the project would generate on-site renewable energy via the use of photovoltaic
panels capable of generating approximately 15,000,000 kilowatt hours/year and the use of fuel cells
capable of generating approximately 71,000,000 kilowatt hours/year, and would rely on off-site
renewable energy sources and, if needed, renewable energy credits for the remainder of the project's
energy requirements. Therefore, the project would not conflict with ECM -2.
ECM -3, Urban Heat Island Mitigation, includes regulatory and educational approaches to reduce the
"urban heat island" phenomenon by increasing the application of "cool roofing" and "cool paving"
technologies. The implementation actions of this measure are not specifically applicable to the pro-
posed project, as they specifically relate to future building code standards and other regulatory
actions. However, the proposed project would locate parking areas underground, and would increase
pervious surfaces from 43 acres to 102 acres. Therefore, the proposed project would result in a net
reduction in the heat island effect and would not conflict with ECM -3.
ECM -4, Shade Tree Planting, includes voluntary approaches to reduce the heat island effect by
increasing shading in urban and suburban areas through the planting of trees. The implementation
actions do not specifically relate to the proposed project as the actions are intended to be implemented
by local governments and the BAAQMD through regulations. However, the project would increase
the number of trees on the site from approximately 4,500 to 7,000, which would be generally
consistent with the measure.
3) Would the project disrupt or hinder implementation of any control measures from the Clean Air
Plan?
As discussed above, the proposed project would generally implement the applicable measures
outlined in the Clean Air Plan, including transportation control measures and energy measures.
Therefore, the project would not disrupt or hinder implementation of a control measure from the
Clean Air Plan and ultimately would be consistent with the Clean Air Plan.
C. Significant Impacts. Implementation of the proposed project would result in the following
significant air quality impacts.
(1) Violate Any Air Quality Standard or Contribute Substantially to an Existing or
Projected Air Quality Violation. According to the BAAQMD CEQA Air Quality Guidelines, to
meet air quality standards for operational -related criteria air pollutant and air precursor impacts, the
project must not:
• Contribute to CO concentrations exceeding the State ambient air quality standards;
• Generate construction emissions of ROG, NOx or PM2.5 (exhaust) greater than 54 pounds
per day or PM10 exhaust emissions greater than 82 pounds per day; or
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• Generate operational emissions of ROG, NOx or PM2.5 of greater than 10 tons per year or
54 pounds per day or PM10 emissions greater than 15 tons per year or 82 pounds per day.
The following section describes the project's CO impacts and construction- and operation -related air
quality impacts.
Localized CO Impacts. Emissions and ambient concentrations of CO have decreased
dramatically in the Bay Area with the introduction of the catalytic converter in 1975. No exceedances
of the State or federal CO standards have been recorded at Bay Area monitoring stations since 1991.
The May 2012 BAAQMD CEQA Air Quality Guidelines include recommended methodologies for
quantifying concentrations of localized CO levels for proposed transportation projects. Guidance is
not provided for evaluation of development projects. However, in an order to provide a comprehen-
sive analysis of the potential impacts of the project on air pollution, a screening level analysis using
guidance from the BAAQMD 2011 CEQA Air Quality Guidelines was performed. The screening
methodology provides a conservative indication of whether the implementation of a proposed project
would result in significant CO emissions. According to the BAAQMD's 2011 CEQA Air Quality
Guidelines, a proposed project would result in a less -than -significant impact to localized CO
concentrations if the following screening criteria are met:
• The project is consistent with an applicable congestion management program established
by the county congestion management agency for designated roads or highways, and the
regional transportation plan and local congestion management agency plans.
• Project traffic would not increase traffic volumes at affected intersections to more than
44,000 vehicles per hour.
• The project 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, or below -grade
roadway).
The proposed project would not conflict with the Santa Clara Valley Transportation Authority's
Congestion Management Program for designated roads or highways, a regional transportation plan, or
other agency plans. The proposed project would also not be located in an area where vertical or
horizontal mixing is substantially limited and traffic volumes on roadways in the vicinity of the
project site are less than 44,000 vehicles per hour. As shown in Table V.L-2, background CO
concentrations are substantially below State and federal standards. Therefore, as the proposed project
would not increase traffic volumes at affected intersections to more than 44,000 vehicles per hour and
the project would not result in localized CO concentrations that exceed State or federal standards,
localized CO impacts would be less than significant.
Construction Period Impacts. During construction, short-term degradation of air quality may
occur due to the release of particulate matter emissions generated by excavation, grading, hauling,
and other activities. Emissions from construction equipment are also anticipated and would include
CO, NO,, ROG, directly -emitted particulate matter (PM2.5 and PMJo), and TACs such as diesel
exhaust particulate matter.
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Impact AIR -1: Construction of the proposed project would generate air pollutant emissions
that could violate air quality standards. (S)
Site preparation and project construction would involve demolition of the existing structures on the
project site, clearing, cut -and -fill activities, grading, and building activities. Construction -related
effects on air quality from the proposed project would be greatest during the site preparation phase
because most engine emissions are associated with the excavation, handling, and transport of soils on
the site. If not properly controlled, these activities would temporarily generate PM,o, PM2.5, and to a
lesser extent CO, SO2, NO,, and volatile organic compounds. Sources of fugitive dust would include
disturbed soils at the construction sites and trucks carrying uncovered loads of soils. Unless properly
controlled, vehicles leaving the site would deposit dirt and mud on local streets, which could be an
additional source of airborne dust after it dries. PM,o emissions would vary from day to day,
depending on the nature and magnitude of construction activity and local weather conditions. PM,o
emissions would depend on soil moisture, the silt content of soil, wind speed, and the amount of
operating equipment. Larger dust particles would settle near the source, while fine particles would be
dispersed over greater distances from the construction site. These emissions would be temporary and
limited to the immediate area surrounding the construction sites.
The BAAQMD has established standard measures for reducing fugitive dust emissions (PM2.5 and
PM,o) including the use of water or other soil stabilizers. Apple's construction plans include use of
such dust suppression measures. With the implementation of standard construction measures such as
frequent watering (e.g., two times per day at a minimum), fugitive dust emissions from construction
activities would not result in adverse air quality impacts. 29
The proposed construction schedule for the project, including Phase 2 (the timing of which has not
been determined) is estimated to be approximately 48 months. Construction emissions were estimated
for the project using CalEEMod (for fugitive emissions and ROG from architectural coatings/paving)
and emission factors by equipment type and duration as shown in the project's Construction
Equipment Summary using ARB's EMFAC 2011 model and U.S. EPA's off-road engine Tier
Standards (Code of Federal Regulations Title 40 Part 1039.102), in conjunction with the brake horse
powers by equipment type provided in the Construction Equipment Summary or in CalEEMod.
Construction -related emissions are presented in Table VL -5. Detailed calculations are provided in
Appendix E.
The effects of construction activities would be increased dust and locally elevated levels of PM,o
downwind of construction activity. Construction dust would be generated at levels that could create
an annoyance to occupants of nearby properties. As shown in Table VL -5, construction emissions of
ozone precursors (ROG and NOx) would exceed the BAAQMD's threshold for average daily con-
struction emissions.
29 BAAQMM, 2011, op. cit.
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Table V.L-5: Project Construction Emissions in Pounds Per Day
a Would not exceed threshold with implementation of BMPs (Mitigation Measure AIR -1).
NA = Not Applicable, the BAAQMD does not have threshold
BMP = Best Management Practices
Source: LSA Associates, Inc., 2013 and ENVIRON, 2013.
The BAAQMD recommends the implementation of Best Management Practices to reduce construc-
tion impacts to a less -than -significant level. The project's Construction Equipment Summary
indicates the project would implement aggressive emission reduction measures during construction,
including the BAAQMD's Best Management Practices. To allow the City to enforce and monitor
construction activities, mitigation would be required. Implementation of Mitigation Measure AIR -1
would require implementation of the BAAQMD's Best Management Practices and additional
measures to reduce diesel PM exhaust emissions and other construction pollutants. Implementation of
this mitigation measure would reduce PM emissions to a less -than -significant level, but ROG and
NO, levels would not be reduced below the BAAQMD's significance threshold. Therefore, this
impact would be significant and unavoidable.
Mitigation Measure AIR -1: Consistent with guidance from the BAAQMD, the following
actions shall be required in relevant construction contracts and specifications for the project:
• 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 tracked -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 miles per hour (mph).
• All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible.
Building pads shall be laid as soon as possible after grading unless seeding or soil binders
are used.
• Construction equipment idling times shall be minimized either by shutting equipment off
when not in use or reducing the maximum idling time to 2 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.
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Fugitive
Fugitive
Exhaust
Dust
Total
Exhaust
Dust
Total
Project Construction
ROG
NOX
PMzs
PM1.5
PM1.5
PMio
PMio
PMio
Average Daily
Exhaust Emissions
6.1
181.2
1.8
21.1
22.9
1.8
55.32
57.12
Average Daily
Architectural Coating/
179.9
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Paving Emissions
Total Construction
Emissions
186.0
181.2
1.8
21.1
22.9
1.8
55.32
57.12
BAAQMD Thresholds
54.0
54.0
54.0
BMP
NA
82.0
BMP
NA
Exceed Threshold?
Yes
Yes
No
No a
NA
No
No a
NA
a Would not exceed threshold with implementation of BMPs (Mitigation Measure AIR -1).
NA = Not Applicable, the BAAQMD does not have threshold
BMP = Best Management Practices
Source: LSA Associates, Inc., 2013 and ENVIRON, 2013.
The BAAQMD recommends the implementation of Best Management Practices to reduce construc-
tion impacts to a less -than -significant level. The project's Construction Equipment Summary
indicates the project would implement aggressive emission reduction measures during construction,
including the BAAQMD's Best Management Practices. To allow the City to enforce and monitor
construction activities, mitigation would be required. Implementation of Mitigation Measure AIR -1
would require implementation of the BAAQMD's Best Management Practices and additional
measures to reduce diesel PM exhaust emissions and other construction pollutants. Implementation of
this mitigation measure would reduce PM emissions to a less -than -significant level, but ROG and
NO, levels would not be reduced below the BAAQMD's significance threshold. Therefore, this
impact would be significant and unavoidable.
Mitigation Measure AIR -1: Consistent with guidance from the BAAQMD, the following
actions shall be required in relevant construction contracts and specifications for the project:
• 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 tracked -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 miles per hour (mph).
• All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible.
Building pads shall be laid as soon as possible after grading unless seeding or soil binders
are used.
• Construction equipment idling times shall be minimized either by shutting equipment off
when not in use or reducing the maximum idling time to 2 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.
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• All construction equipment shall be maintained and properly tuned in accordance with the
manufacturer's specifications. All equipment shall be checked by a certified mechanic and
determined to be running in proper condition prior to operation.
• The project applicant shall post a publicly visible sign with the telephone number and
person to contact at the City of Cupertino regarding dust complaints. This person shall
respond to complaints and take corrective action within 48 hours. The BAAQMD's phone
number shall also be visible to ensure compliance with applicable regulations.
• All exposed surfaces shall be watered at a frequency adequate to maintain minimum soil
moisture of 12 percent. Moisture content can be verified by lab samples or a moisture
probe.
• All excavation, grading, and/or demolition activities shall be suspended when average wind
speeds exceed 20 mph.
• Vegetative ground cover (e.g., fast -germinating native grass seed) or other plants that offer
dust mitigation measures shall be planted in disturbed areas as soon as possible and watered
appropriately until vegetation is established.
• The simultaneous occurrence of excavation, grading, and ground -disturbing construction
activities on the same area at any one time shall be limited. To the extent feasible, activities
shall be phased to reduce the amount of disturbed surfaces at any one time.
• All trucks and equipment, including their tires, shall be washed off prior to leaving the site.
• Sandbags or other erosion control measures shall be installed to prevent silt runoff to public
roadways from sites with a slope greater than 1 percent.
• Use low volatile organic compound (i.e., ROG) coatings beyond the local requirements
(i.e., Regulation 8, Rule 3: Architectural Coatings).
• To the maximum extent feasible, all construction equipment, diesel trucks, and generators
shall be equipped with Best Available Control Technology for emission reductions of NO,
and PM.
• To the maximum extent feasible, all contractors shall use equipment that meets ARB's
most recent certification standard for off-road heavy duty diesel engines.
• Excluding the following equipment, ensure that all diesel -powered off-road equipment used
on-site meets U.S. EPA "Tier 2" exhaust emission standards, and that engines are equipped
with California ARB "Level 3 Verified Diesel Emission Control Strategies" (which include
diesel particulate filters) or are certified to meet the U.S. EPA "Tier 4 Interim" standard for
particulate matter emissions. Equipment that will meet U.S. EPA "Tier 2" exhaust emission
standards but will not be equipped with California "Level 3 Verified Diesel Emission
Control Strategy" shall be limited to:
C Scrapers 623G
C Scrapers 633B
C Four of the six proposed Scrapers 657G
• Ensure that trucks used at the site to haul material and/or soil are model year 2007 or newer
(or meet equivalent U.S. EPA emission standards).
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• Require all aerial and personnel lifts less than 50 horsepower to be fueled with natural gas
or propane. (SU)
Implementation of the above measures would minimize construction emissions, but not to a less -than -
significant level.
Operational Emissions - Regional Emissions Analysis. The project would generate long-
term air emissions associated with changes in the permanent use of the project site. These long-term
emissions are primarily mobile source emissions that would result from vehicle trips associated with
the proposed project. Area sources, such as natural gas heaters, landscape equipment, and use of
consumer products such as pressurized air canisters would also result in pollutant emissions.
Existing On -Site Emissions. The project
would result in the demolition of all structures
currently used by Apple and formerly used by
Hewlett-Packard within the project site (compris-
ing approximately 2,657,000 square feet of interior
space). The California Emissions Estimator Model
(CalEEMod v.2011.1.1), which the BAAQMD
approves for use in estimating emissions associated
with land use development projects, was used to
calculate long-term mobile and area source
emissions for existing on-site emissions.
CalEEMod output sheets are included in Appendix
E of this EIR.
Table V.L-6: Regional Emissions from
Existing On -Site Uses
According to the Transportation Impact Analysis
(TIA) prepared for the project, existing trip Source: LSA Associates, Inc., 2013.
generation on the project site is equal to 15,872
trips per day,30 which was used to estimate criteria air pollutants for existing vehicle emissions. Area
source emissions associated with the existing uses were calculated using the existing employee count
data, existing building square footages, and CalEEMod default assumptions based on the land use
type. Daily and annual emissions for the existing uses on the project site are shown in Table V.L-6.
Project Emissions. According to the TIA prepared for the project (see Appendix B), the project
is expected to generate approximately 50,978 trips per day (or 35,106 net trips, taking into account
existing uses on the site)."The trip rate assumed for the project accounts for reductions associated
with implementation of Apple's existing TDM Program (see Chapter III, Project Description, for a
discussion of this TDM Program). The proposed project would initially provide 300 electric vehicle
charging stations which would primarily utilize renewable energy generated on-site. The parking lot
would also be configured to ultimately allow for up to 1,000 electric vehicle charging stations. This
analysis accounts for the use of the provided 300 electric vehicle parking stalls. Also included in the
emissions model are mobile source emissions that account for ridership associated with existing
30 Fehr & Peers, 2013. fipple Campus 2 Transportation Impact Analysis.
31 Ibid.
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Reactive
Organic
Nitrogen
Gases
Oxides
PM10
PM2.5
Emissions in Pounds Per Da
Area Source
37.59
0.00
0.00
0.00
Emissions
Energy Source
1.15
10.42
0.79
0.79
Mobile Source
104.28
178.54
128.84
9.92
Emissions
Total Emissions
143.02
188.96
129.63
10.71
Emissions in Tons Per Year
Area Source
6.86
0.00
0.00
0.00
Emissions
Energy Source
0.35
3.22
0.24
0.24
Mobile Source
13.67
24.66
14.70
1.40
Emissions
Total Emissions
20.88
27.88
14.94
1.64
According to the Transportation Impact Analysis
(TIA) prepared for the project, existing trip Source: LSA Associates, Inc., 2013.
generation on the project site is equal to 15,872
trips per day,30 which was used to estimate criteria air pollutants for existing vehicle emissions. Area
source emissions associated with the existing uses were calculated using the existing employee count
data, existing building square footages, and CalEEMod default assumptions based on the land use
type. Daily and annual emissions for the existing uses on the project site are shown in Table V.L-6.
Project Emissions. According to the TIA prepared for the project (see Appendix B), the project
is expected to generate approximately 50,978 trips per day (or 35,106 net trips, taking into account
existing uses on the site)."The trip rate assumed for the project accounts for reductions associated
with implementation of Apple's existing TDM Program (see Chapter III, Project Description, for a
discussion of this TDM Program). The proposed project would initially provide 300 electric vehicle
charging stations which would primarily utilize renewable energy generated on-site. The parking lot
would also be configured to ultimately allow for up to 1,000 electric vehicle charging stations. This
analysis accounts for the use of the provided 300 electric vehicle parking stalls. Also included in the
emissions model are mobile source emissions that account for ridership associated with existing
30 Fehr & Peers, 2013. fipple Campus 2 Transportation Impact Analysis.
31 Ibid.
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L. AIR QUALITY
shuttle use, which would continue to occur under operation of the project. Mobile source emissions
were calculated using the ARB's EMFAC2011 model.
Area source emissions associated with the project would include consumer product use, architectural
coatings, and the use of landscaping equipment which were calculated using CalEEMod. Electricity
use on-site accounts for the use of solar-photovolataics, natural gas for boilers, and electricity -
generating fuel cells.
The project would include emergency generators that would undergo routine testing, resulting in
diesel combustion emissions. Emissions were calculated assuming 50 hours per year of testing (the
maximum allowed under BAAQMD permitting requirements).
The net new daily and annual emissions associated with the project are identified in Table V.L-7 for
ROG, NO,, PMIo, and PM2.5. All calculation details are provided in Appendix E. The results indicate
the net new project emissions would exceed the BAAQMD's threshold for ROG, NO,, PM2.5 and
PMIo; therefore, the proposed project would have a significant effect on regional air quality.
Table V.L-7: Project Regional Emissions
NA = Not Available. Emission estimates not available.
Source: LSA Associates, Inc., 2013.
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Emissions in Pounds Per Day
Emissions in Tons Per Year
Reactive
Organic
Gases
Nitrogen
Oxides
PMio
PM's
Reactive
Organic
Gases
Nitrogen
Oxides
PM"
PM2.5
Phase 1 Project Emissions
Area Source Emissions
92.66
0.00 0.00 0.00 16.91
0.00
0.00
0.00
Transit Emissions
16.49
252.01 70.44 22.17 3.01
45.99
12.86
4.05
All Other Mobile
Source Emissions
123.13
148.01 194.02 52.27 22.47
27.01
35.41
9.54
Boiler Emissions
7.76
34.56 10.73 10.73 1.42
6.31
1.96
1.96
Fuel Cell Emissions
4.2
4.2 NA NA 1.0
1.0
NA
NA
Stand-by Generator
Testing Emissions
0.63
31.64 0.23 0.23 0.12
5.78
0.04
0.04
Total Phase 1 Emissions
244.87
470.42 275.42 85.40 44.93
86.09
50.27
15.59
Phase 2 Project Emissions
Area Source Emissions
8.32
0.0
0.0
0.0
1.52
0.0
0.0
0.0
Mobile Source
Emissions
11.67
13.93
17.97
4.85
2.13
2.54
3.28
0.89
Total Phase 2 Emissions
19.99
13.93
17.97
4.85
3.65
2.54
3.28
0.89
Total Project Emissions
264.86
484.35
293.39
90.25
48.58
88.63
53.55
16.48
Existing Emissions
143.02
188.96
129.63
10.71
20.88
27.88
14.94
1.64
Net New Total
Project Emissions
121.84
295.39
163.76
79.54
27.70
60.75
38.61
14.84
BAAQMD Significance
Threshold
54.00
54.00
82.00
54.00
10.00
10.00
15.00
10.00
Exceed'
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
NA = Not Available. Emission estimates not available.
Source: LSA Associates, Inc., 2013.
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L. AIR QUALITY
Impact AIR -2: Operation of the proposed project would generate air pollutant emissions that
would exceed the BAAQMD criteria and could substantially contribute to a violation of air
quality standards. (S)
The primary emissions associated with the project are regional in nature, meaning that air pollutants
are rapidly dispersed on emission or, in the case of vehicle emissions associated with the project,
emissions are released in other areas of the air basin. Because the resulting emissions are dispersed
rapidly and contribute only a small fraction of the region's air pollution, air quality in the immediate
vicinity of the project site would not substantially change compared to existing conditions or the air
quality monitoring data reported in Table V.L-2. However, regional emissions would exceed the
BAAQMD's significance criteria. Therefore mitigation would be required.
As shown in Table V.L-7 the primary source of emissions associated with the project are mobile
source emissions generated by employee, visitor, and vendor trips to and from the project site. The
primary strategy for reducing these trips is the implementation of a TDM Program. Apple currently
provides a variety of TDM measures to reduce the number of employee trips by single occupant
vehicles (SOV) to and from work on a daily basis by 28 percent (72 percent of employees commute
in single -occupant vehicles). Apple administers the TDM Program and actively collaborates with
Apple employees to improve and adapt TDM strategies to employee needs. Current strategies
employed at the project site include:
• Outreach to commuters in the form of carpool matching, TDM coordination, and bicycle
route matching;
• Mass transit options, including Apple shuttles, and transit subsidies;
• Interface with public transit through shuttle connections at approximately 10 transit hubs
throughout the Bay Area;
• Encouragement of bicycling through subsidies, bike racks, showers, and a bicycle sharing
program; and
• Other strategies such as carpool priority parking, electric vehicle charging stations, and a
car share program.
As described in Chapter III, Project Description, an expanded TDM Program beyond implementation
of the existing TDM Program for the Apple Campus 2 project that provides for a reduction of peak
hour trips by 28 percent is not included as part of the project. However, Apple would be required to
improve its TDM Program participation rate to a target of 34 percent for the project with a commen-
surate reduction in peak hour vehicle trips (a 6 percent point increase) as mitigation for the project's
impacts (see the discussion in Section V.I, Transportation and Circulation, regarding new and
expanded TDM measures and monitoring of the program's effectiveness, and Mitigation Measure
TRANS -9b). However, because the specifics of the new or expanded TDM measures to be imple-
mented are still being refined, there is no quantifiable evidence to support additional reductions in
trips and pollutant emissions necessary to reduce the impact to a less -than -significant level. While the
goal of the TDM Program is to continually reduce mobile source emissions over time, the emission of
regional pollutants by the project is considered significant and unavoidable, even with
implementation of the following mitigation measure:
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L. AIR QUALITY
Mitigation Measure AIR -2: Implement Mitigation Measure TRANS -9b (which requires Apple
to expand its TDM Program and increase the reduction in peak hour trips from 28 percent to 34
percent). (SU)
Even with implementation of Mitigation Measure AIR -2, the project's operational air emission
impacts would remain significant and unavoidable .12
(2) Result in a cumulatively considerable net increase of any criteria pollutant. Other
land use development projects within the Bay Area and within the City of Cupertino contribute to
regional air pollution emissions. Other projects within the City of Cupertino include the Tantau Retail
Center and Parking Garage, the Cupertino Village retail project, and the Main Street Cupertino
project, which includes commercial and office uses. Criteria pollutant emissions for these projects
were calculated and are presented in Appendix E for informational purposes.
According to the BAAQMD, regional air pollution is largely a cumulative impact. No single project
is sufficient in size to independently create regional nonattainment of ambient air quality standards.
Instead, a project's individual emissions contribute to existing cumulatively significant adverse air
quality impacts. Therefore, if daily average or annual emissions of construction- or operational -
related criteria air pollutants exceed any applicable threshold established by the BAAQMD, the
proposed project would result in a cumulatively significant impact. 33
Impact AIR -3: Construction and operation of the proposed project would result in a significant
cumulative net increase in criteria pollutant emissions. (S)
As discussed above, the Bay Area 2010 Clean Air Plan defines the control strategies to reduce
emissions and ambient concentrations of air pollutants at the cumulative level. Based on the analysis
of the project's consistency with the Clean Air Plan, the project would not disrupt or hinder imple-
mentation of a control measure from the Clean Air Plan and ultimately would be consistent with the
Clean Air Plan. However, as shown in Tables V.L-5 and V.L-7, the proposed project would exceed
the threshold for construction and operational impacts for criteria pollutants at the project level;
therefore, the project would also make a significant contribution to a cumulatively significant criteria
air pollutant impact. While implementation of Mitigation Measures AIR -1 and AIR -2 would reduce
this impact, the project's significant contribution to the cumulative regional air quality impact would
remain significant and unavoidable.
Mitigation Measure AIR -3: Implement Mitigation Measures AIR -1 and AIR -2. (SU)
32 As described in the analysis above, the determination of significance for the purposes of CEQA utilizes occupancy
conditions at the time of publication of the Notice of Preparation (August 2011), and at that time employment on the site
(4,844 employees) was well below the employee capacity of the site (9,800 employees). The site has historically operated at
or near full capacity; however, the current condition reflects Apple's relocation of its employees in preparation for the
project and Hewlett-Packard's consolidation of its employees in Palo Alto. According to the TIA, new vehicle trips
associated with the project, when compared to traffic conditions under full occupancy of the existing buildings, would be
16,873 trips. As shown in Table V.L-7, the primary source of emissions associated with the project is vehicle emissions.
Therefore, net new emissions associated with the project when compared to a full occupancy scenario would be substantially
less than those identified in the analysis above.
33 BAAQMD 2011, op. cit.
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(3) Expose Sensitive Receptors to Substantial Pollutant Concentrations. According to the
BAAQMD, a project would result in a significant impact if it would: individually expose sensitive
receptors to TACs resulting in an increased cancer risk greater than 10.0 in one million, increased
non -cancer risk of greater than 1.0 on the hazard index (chronic or acute), or an annual average
ambient PM2.5 increase greater than 0.3 µg/m3. A significant cumulative impact would occur if the
project in combination with other projects located within a 1,000 -foot radius of the project site would
expose sensitive receptors to TACs resulting in an increased cancer risk greater than 100.0 in one
million, an increased non -cancer risk of greater than 10.0 on the hazard index (chronic), or an ambient
PM2.5 increase greater than 0.8 µg/m3 on an annual average basis.
The health risk assessment (HRA) conducted for this project was based on three current guidance
documents: 1) the California EPA Air Toxics Hot Spots Program Risk Assessment Guidelines, 34 2)
The California Air Pollution Control Officers Association (CAPCOA) Health Risk Assessment for
Proposed Land Use Projects, 15 and 3) the BAAQMD Recommended Methods for Screening and
Modeling Local Risks and Hazards. 16 The BAAQMD document was released in May 2011 with the
purpose of assisting lead agencies in conducting a risk and hazard analysis as part of the environmen-
tal review process for proposed land use projects. It provides Bay Area -specific guidance on how to
screen projects and provides specific inputs for HRA modeling.
This section describes the potential impact on sensitive receptors from construction and operation of
the proposed project.
Project Construction — Toxic Air Contaminants. The project site is located in an urban area
in close proximity to existing residential uses that could be exposed to diesel emission exhaust during
the construction period. To estimate the potential cancer risk associated with construction of the
proposed project from equipment exhaust (including diesel particulate matter), a dispersion model
was used to translate an emission rate from the source location to a concentration at the receptor
location of interest (i.e., a nearby residence). Dispersion modeling varies from a simpler, more
conservative screening -level analysis to a more complex and refined detailed analysis. This assess-
ment was conducted using ARB's exposure methodology, with the air dispersion modeling performed
using the U.S. EPA dispersion model AERMOD. The model provides a detailed estimate of exhaust
concentrations based on site and source geometry, source emissions strength, distance from the source
to the receptor, and site-specific meteorological data.
Construction Emission Estimation. PMIo and PM2.5 off-road construction equipment exhaust
emissions from the proposed project were calculated using emission factors from the U.S. EPA's off-
road engine Tier Standards (code of Federal Regulations Title 40 Part 1039.102) in conjunction with
brake horse powers (BHP) by equipment type. On -road mobile source emissions were calculated
using the ARB's EMFAC2011 online system in conjunction with BHPs by equipment type identified
in CalEEMod. Modeled construction equipment emissions are based on the equipment list provided
34 California Environmental Protection Agency, 2003. Air Toxics Hot Spots Program Riskflssessment Guidelines.
August.
35 California Air Pollution Control Officers Association, 2009. Health Risk flssessment for Proposed Land Use
Projects. July.
36 Bay Area Air Quality Management District, 2011. Recommended Methods for Screening and Modeling Local
Risks and Hazards. May.
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to LSA by the project sponsor that is included in Appendix E. The proposed construction equipment
and operations would incorporate the following best practices:
Excluding the following equipment, ensure that all diesel -powered off-road equipment used
on the site meets U.S. EPA "Tier 2" exhaust emission standards, and that engines are
equipped with California ARB "Level 3 Verified Diesel Emission Control Strategies"
(which include diesel particulate filters) or are certified to meet the U.S. EPA "Tier 4
Interim" standard for particulate matter emissions. Equipment that will meet U.S. EPA
"Tier 2" exhaust emission standards but will not be equipped with California ARB "Level 3
Verified Diesel Emission Control Strategies" are:
C Scrapers 623G
C Scrapers 633B
C Four of the six proposed Scrapers 657G
• Limit idling times by either shutting off equipment when not in use or reducing the
maximum idling time to 2 minutes.
• Ensure that trucks used at the site to haul material or soil, are model year 2007 or newer (or
meet equivalent U.S. EPA emission standards).
• Require all aerial and personnel lifts less than 50 horsepower to be fueled with natural gas
or propane.
• To the maximum extent feasible, material staging roads would be set back from the curb by
at least 65 feet.
PM10 exhaust emissions were used in the model as a surrogate for diesel particulate matter (DPM).
TAC emissions from construction activities were evaluated using the BAAQMD's speciation profile
for diesel in combination with the estimated ROG emissions. Emissions were estimated for the 48 -
month construction period. Table V.L-8 provides a list of considered TACs and their speciation
percentages. The construction equipment list, emission factors for construction equipment, and total
project construction emissions are shown in Appendix E.
Model Use. To estimate the construction PMIo exhaust concentrations, the AERMOD model
was used with all regulatory options selected. The model was run using the San Jose meteorological
dataset from the years 2006 through 2010. Terrain data from Lakes' WebGIS website was also used
to evaluate terrain near the project site. Emissions from construction activities were modeled as a
volume source encompassing the project site with a release height of 16.4 feet. Following BAAQMD
guidance, concentrations were calculated at 0, 6, and 20 feet. The resulting modeled concentrations
were then post -processed using BAAQMD methodology.
The total construction emissions were summed using specific operational assumptions, including
hourly and daily equipment usage for each phase of construction, as shown in Appendix E. The total
emissions from operations were then modeled using conservative operational conditions (i.e., 13
hours per day, 350 days per year) to determine an average emission concentration. The resulting
concentration represents the maximum exposure concentration to off-site receptors.
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Table V.L-8: Construction Equipment TACs
Chemical
Component
Diesel
Speciation
(Percent
TOG)
Unit
Factor
(HARP)
Residential
Cancer Risk
Factors
cm3 1
Unit Cancer
Risk
Weighted
Factor
cm3 1
Chronic
Noncancer
Reference
Dose
cm3
Unit
Chronic
Noncancer
Risk
Weighted
Factor
cm3
Acute
Noncancer
Reference
Dose
cm3
Unit Acute
Noncancer
Risk
Weighted
Factor
cm3
acetaldehyde
7.30
0.07353
0.0000027
1.985E-07
140
10.2942
470
34.5591
benzaldehyde
0.70
0.00699
0
0.000E+00
0
0
0
0
benzene
2.00
0.02001
0.000029
5.803E-07
60
1.2006
1300
26.013
ethanol
0.01
0.00009
0
0.000E+00
0
0
0
0
eth lbenzene
0.31
0.00305
2.52E-06
7.686E-09
2000
6.1
0
0
ethylene
14.38
0.14377
0
0.000E+00
0
0
0
0
formaldehyde
14.71
0.14714
6.08E-06
8.946E-07
9
1.32426
55
8.0927
isobutane
1.22
0.01222
0
0
0
0
0
0
isopentane
0.60
0.00602
0
0
0
0
0
0
methane
4.08
0.04084
0
0
0
0
0
0
methyl ethyl ketone
mek 2-butanone
1.48
0.01477
0
0
4000
59.08
28000
413.56
meth lc clo entane
0.15
0.00149
0
0
0
0
0
0
m -xylene
0.61
0.00611
0
0
700
4.277
22000
134.42
n -butane
0.10
0.00104
0
0
0
0
0
0
n -hexane
0.16
0.00157
0
0
0
0
0
0
n -pentane
0.18
0.00175
0
0
0
0
0
0
o - xylene
0.34
0.00335
0
0
700
2.345
22000
73.7
propionaldehyde
0.97
1 0.0097
0
0
0
0
0
0
propylene
2.60
1 0.02597
0
0
3000
77.91
0
0
toluene
1.47
1 0.01473
0
0
300
4.419
3.70E+04
545.01
diesel
Potency Factor 1.1
0
0
5
0
0
0
Notes: Chemical Abstract Number (CAS); Total Organic Gases (TOG)
Source: BAAQIM, 2011. BAAQIM Specified Speciation Profile for OFFROAD Diesel TOG.
Construction Receptor Grid. A survey of the project vicinity indicated that sensitive receptors
are located adjacent to the project site. A construction receptor grid was established as part of the
modeling effort to capture locations representing existing off-site receptors that may be affected by
emissions associated with construction of the project. The construction grid identifies blocks of
nearby receptors that were modeled in the analysis to determine if they would be adversely affected
using the thresholds identified by the BAAQMD. A grid space sufficient to ensure that nearby
residents are adequately assessed was used. The BAAQMD recommends a receptor spacing of
between 33 and 82 feet (10 and 25 meters) and heights of 6 feet and 20 feet (2 and 6 meters) when
conducting refined modeling .17 Therefore, in order to conduct a cautious impact analysis that is
protective of human health, a receptor spacing of 33 feet (10 meters) was used.
Exposure Assumptions. Also called dose -response assessment, exposure assumptions involve
the process of characterizing the relationship between exposure to an agent and incidence of an
adverse health effect in exposed populations. In a quantitative carcinogenic risk assessment such as
this, the dose -response relationship is expressed in terms of a potency slope that is used to calculate
the probability or risk of cancer associated with an estimated exposure. Cancer potency factors are
expressed as the 95th percent upper confidence limit of the slope of the estimated dose -response
37 Ibid.
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curve, assuming continuous lifetime exposure to a substance at a dose of 1 milligram per kilogram of
body weight per day and commonly expressed in units of inverse dose (i.e., (mg/kg/day)-'). It is
assumed in cancer risk assessments that risk is directly proportional to dose and that there is no
threshold for carcinogenesis. The Office of Environmental Health and Hazard (OEHHA) has
compiled cancer potency factors, which are used in risk assessments.
For non -carcinogenic effects, dose -response data developed from animal or human studies are used to
develop acute and chronic non -cancer Reference Exposure Levels (RELs). The acute and chronic
RELs are defined as the concentration at which no adverse non -cancer adverse health effects are
anticipated. The most sensitive health effect is chosen to determine the REL if the chemical affects
multiple organ systems. Unlike cancer health effects, non -cancer acute and chronic health effects are
generally assumed to have thresholds for adverse effects. In other words, acute or chronic injury from
a pollutant will not occur until exposure to that pollutant has reached or exceeded a certain concentra-
tion (i.e., threshold). The acute and chronic RELs are intended to be below the threshold for health
effects for the general population. The actual threshold for health effects in the general population is
generally not known with any precision.
Risk characterization is the final step of risk assessment. Modeled concentrations and public exposure
information, which are determined through exposure assessment, are combined with potency factors
and RELs that are developed through dose -response assessment.
Cancer Risk. The maximum incremental cancer risk from exposure to TACs was calculated
following the guidelines established by OEHHA. The following equation was used to determine life
time cancer risk levels for a resident child:
Inhalation cancer risk = (Cair *DBR * A* EF * ED * 1x10-6) /AT
Inhalation Cancer Potency Factor * CRAF, where:
Cair =
concentration of PM10 in air (used as a surrogate for DPM
concentration)
DBR =
child daily breathing rate
A =
inhalation absorption factor
EF =
exposure frequency
ED =
exposure duration
AT =
time period over which exposure is averaged in days (25,550
days for a 70 -year cancer risk)
CRAF =
cancer risk adjustment factor (an age sensitivity factor of 10 for
first 2 years, 4.75 for the third year, and 3 for the fourth year)
Source: OEHHA Guidelines, August 2003 and BAAQMD's Recommended Methods
for Screening and Modeling Local Risks and Hazards, May 2011.
As recommended by BAAQMD, the breathing rate of 302 liters per kilogram per day was used. The
exposure frequency was assumed to be 350 days per year.38 The exposure duration for project
38 Bay Area Air Quality Management District, 2010. Air Toxics NSR Program Health Risk Screening Analysis
Guidelines. January
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construction was assumed to be 4 years. The inhalation absorption factor was based on the
conservative assumption that all pollution would be absorbed, and thus was 1.0. To determine
incremental cancer risk, the estimated dose through inhalation was multiplied by the OEHHA-
established cancer potency slope factor for DPM, which is 1.1 (mg/kg/day) -J.
Analyses conducted by the OEHHA indicate that both the prenatal and postnatal life stages can be,
but are not always, much more susceptible to developing cancer than the adult life stage. The analyses
also indicate that the age sensitivity factors (ASFs) for these age windows vary by chemical, gender
and species. ASFs for prenatal, postnatal and juvenile exposures are complicated by the limited data-
base of chemicals and studies available for analysis, and the broad distribution of results for different
chemicals. The BAAQMD recommends a CRAF of 10 for construction projects to account for
exposure from the third trimester to age 2. After reaching age 2, the CRAF is reduced to 3, until the
resident child reaches age 16.
The concentration of each TAC at every receptor and the equation outlined above was applied to
determine the cancer risk from all TACs using the weighted toxicity factors found in Table V.L-8.
The cancer risk level from all TACs was determined at each receptor. The cancer risk at all locations
of sensitive receptors was then determined and the highest of these was reported as the maximum
exposed individual (MEI). Work sites in the project vicinity were determined to have a lower
maximum risk level than residential areas, as the exposure duration of 8 hours for construction
workers would be much lower than the exposure duration of 24 hours for residents. Worker exposures
are also not subject to the age sensitivity factors which increase risk associated with residential
receptors. Therefore, the MEI was determined to be an off-site residential receptor.
Chronic Non -Cancer. Non -cancer health risk is based on a hazard index for chronic (long-
term) exposures. The hazard index is established by the OEHHA and is the ratio of the predicted
incremental exposure concentration (using the annual emission concentration) to the REL that could
cause adverse chronic health effects. The Chronic REL is the inhalation exposure concentration at
which no adverse chronic health effects would be anticipated following exposure. For instance, the
OEHHA has established a DPM Chronic REL of 5.0 µg/m3. This REL represents the level below
which exposure to DPM would not result in adverse health effects.
The DPM chronic risk level is calculated as follows:
Inhalation chronic risk = Cair / Inhalation Chronic REL
where: Carr = annual concentration of DPM
Inhalation Chronic REL = 5.0
This is repeated for all TACs with chronic RELs and the resulting chronic hazard indices at each
receptor are summed and reported as the total chronic hazard index.
Acute Non -Cancer. Similarly, the acute hazard index is established by the OEHHA and is the
ratio of the predicted incremental exposure concentration to the REL that could cause adverse acute
health effects. The Acute REL is the inhalation exposure concentration at which no adverse acute
health effects would be anticipated following exposure.
PM2.5. Annual average concentrations of PM2.5 were calculated using the same methodology to
determine the concentrations of TACs at all receptors. The resulting concentrations of PM2.5 were
then compared with the appropriate BAAQMD thresholds to determine significance.
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Construction Health Risk Assessment Results. Existing residents in the vicinity of the
project site would be exposed to TAC emissions generated during construction of the project. The
comprehensive receptor grid developed for this analysis allows the examination of TAC concentra-
tions throughout the area surrounding the project site, including all residents in the immediate
vicinity. Maximum construction health risk and PM2.5 concentrations are shown in Table V.L-9. The
results for acute and chronic impacts are also shown in Table V.L-9. AERMOD model inputs and
results for all height levels for construction of the project are included in Appendix E. Results of the
analysis indicate that construction of the project would not expose sensitive receptors in the project
site vicinity to health risk levels that would exceed the criteria established by the BAAQMD.
Table V.L-9: Inhalation Health Risks from Project Construction to Off -Site Receptors
CRAF = Cancer Risk Adjustment Factors
Source: LSA Associates, Inc., 2013.
Results of the analysis indicate that the highest risk during construction would be a risk level of 9.44
in one million for the residents located southeast of the project site (see Figure III -4). This analysis
conservatively assumed the resident to be an infant during the construction period and therefore
assumed the CRAF to be 10 until the resident reached age 2, when the CRAF is 3. This risk level is
below the threshold of 10 in one million. The Chronic Hazard Index would be below the threshold at
0.014.
The acute inhalation Hazard Index threshold for non -carcinogenic TACs is 1.0. As shown in Table
V.L-9, the maximum acute Hazard Index would be 0.005 at residences located on Meadow Avenue
southeast of the project site, which is below the threshold of 1.0. Therefore, the potential for short-
term acute exposure would be less than significant.
The results of the analysis also indicate that the maximum PM2.5 concentration at a receptor location
southeast of the project site would be 0.14 µg/m3, which is also below the BAAQMD's significance
threshold of 0.3 µg/m3.
As noted above, the project applicant is proposing construction practices that substantially reduce
diesel emissions in construction equipment. These emission -reducing practices are accounted for in
this analysis. The proposed equipment would generate substantially fewer diesel particulate emissions
than a typical construction project equipment fleet. Given the large size of the project and the
construction duration, the project would not meet the very conservative and protective health risk
standards established by the BAAQMD if these aggressive emission reduction strategies by the
applicant were not taken. Therefore, to be certain that project health risk levels remain below the
threshold levels, a mitigation measure that would require the project applicant to achieve the esti-
mated emissions targets would be required.
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Carcinogenic
Inhalation Health
Annual PM2.5
Risk in One Million
Chronic Inhalation
Acute Inhalation
Concentration
with CRAF
Hazard Index
Hazard Index
/m3
Maximum Exposed
9.44
0.014
0.005
0.14
Individual Location
Threshold
>10.0 in one million
>1.0
>1.0
>0.30
CRAF = Cancer Risk Adjustment Factors
Source: LSA Associates, Inc., 2013.
Results of the analysis indicate that the highest risk during construction would be a risk level of 9.44
in one million for the residents located southeast of the project site (see Figure III -4). This analysis
conservatively assumed the resident to be an infant during the construction period and therefore
assumed the CRAF to be 10 until the resident reached age 2, when the CRAF is 3. This risk level is
below the threshold of 10 in one million. The Chronic Hazard Index would be below the threshold at
0.014.
The acute inhalation Hazard Index threshold for non -carcinogenic TACs is 1.0. As shown in Table
V.L-9, the maximum acute Hazard Index would be 0.005 at residences located on Meadow Avenue
southeast of the project site, which is below the threshold of 1.0. Therefore, the potential for short-
term acute exposure would be less than significant.
The results of the analysis also indicate that the maximum PM2.5 concentration at a receptor location
southeast of the project site would be 0.14 µg/m3, which is also below the BAAQMD's significance
threshold of 0.3 µg/m3.
As noted above, the project applicant is proposing construction practices that substantially reduce
diesel emissions in construction equipment. These emission -reducing practices are accounted for in
this analysis. The proposed equipment would generate substantially fewer diesel particulate emissions
than a typical construction project equipment fleet. Given the large size of the project and the
construction duration, the project would not meet the very conservative and protective health risk
standards established by the BAAQMD if these aggressive emission reduction strategies by the
applicant were not taken. Therefore, to be certain that project health risk levels remain below the
threshold levels, a mitigation measure that would require the project applicant to achieve the esti-
mated emissions targets would be required.
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Impact AIR -4: Without the construction practices identified in the Apple Campus Construction
Equipment Summary, construction of the proposed project would expose sensitive receptors to
substantial pollutant concentrations. (S)
Implementation of the following measure would allow the City of Cupertino to monitor construction
equipment usage to ensure construction emissions would not expose sensitive receptors to substantial
pollutant concentrations.
Mitigation Measure AIR -4: The project sponsor shall implement Mitigation Measure AIR -1
and the following additional measure:
To the maximum extent feasible, material staging roads shall be set back from the curb by
at least 65 feet. (LTS)
Project Operation — Toxic Air Contaminants. The proposed project would generate 35,106
net new vehicle trips to the project site. However, mobile source emissions associated with the project
would be primarily generated by gasoline fueled vehicles and would not generate substantial toxic air
contaminants. In addition, the proposed project would utilize back-up emergency generators on-site.
These generators would be permitted by the BAAQMD. The generators would require intermittent
use as part of testing, and thereby would emit diesel particulate matter. Additionally, the project
would include gas-fired boilers which would also be a source of emissions. Therefore, a health risk
assessment was performed to determine the increased health risk to residents based on the proposed
location of each piece of equipment (See Appendix E).
The results of the health risk analysis indicate that the testing of emergency generators and operation
of equipment in the Central Plant would result in an increased risk of 1.15 in one million, which is
lower than the threshold of 10 in one million, and would be less than significant. The maximum
chronic Hazard Index would be 0.302 at the maximum exposed residence, which is below the
threshold of 1.0. The results of the analysis also indicate that the maximum PM2.5 concentration at a
receptor location would be 0.171 µg/m3, which is also below the BAAQMD's significance threshold
of 0.3 µg/m3. Therefore, operation of the proposed project would not expose sensitive receptors to
substantial pollutant concentrations.
Cumulative Construction Analysis. The cumulative construction analysis sums the risk levels
from project construction emissions, screening level values for the identified stationary sources, and
modeled roadway risk levels and other off-site construction projects within 1,000 feet of the project
site as identified by the City of Cupertino, including the following:
• Tantau Retail Center and Parking Garage, consisting of the development of 10,582 square
feet of retail space and 26,500 square feet of garage space on the northeast corner of
Stevens Creek Boulevard and North Tantau Avenue
• Cupertino Village, consisting of the development of 24,455 square feet of retail space and
approximately 54,000 square feet of garage space on the southwest corner of North Wolfe
Road and East Homestead Road
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• Main Street Cupertino, consisting of 150,000 square feet of commercial uses, 100,000
square feet of office uses, 145,000 square feet of athletic club uses, or an alternate option of
36,000 square feet of commercial uses, up to 160 units of senior housing, and up to a 250 -
room, five -story hotel located on the north side of Stevens Creek Boulevard between Finch
Avenue and Tantau Avenue.
The BAAQMD recommends that all stationary sources within 1,000 feet of a project site be included
in a cumulative impact assessment. Using the toxic air contaminant emissions reported to the
BAAQMD by the stationary sources identified in the project vicinity, LSA included the adjusted risk
levels in the cumulative analysis. Emissions from the construction projects were evaluated using
CalEEMod, with model and default values consistent with the level of detail available.
The results of the cumulative construction analysis are presented in Table V.L-10 and indicate that
the proposed project, in combination with other construction projects in the vicinity, would not
exceed the cumulative health and hazards thresholds established by the BAAQMD.
Table V.L-10: Cumulative Construction Health Risk Impacts
NA = Results not available for this category.
Source: LSA Associates, Inc., 2013.
Cumulative Operational Health Risk Analysis. As discussed above, the proposed project
would utilize back-up emergency generators on-site. These generators would be permitted by the
BAAQMD. Results of the generator and gas-fired boilers health risk analysis, in addition to the
cumulative health risk associated with roadways and stationary sources, are shown in Table V.L-11.
As shown in Table V.L-11, the cumulative health risk of all roadways, stationary sources and mobile
sources would be less than the BAAQMD's cumulative risk and hazard thresholds. Therefore,
residents in the vicinity of the project site would not be exposed to significant cumulative health risk
impacts during operation of the project.
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Cancer Risk
(in one million)
Chronic Inhalation
Hazard Index
Annual PM2.5
Concentration
(Ag/m3)
Apple Campus 2 Project
9.44
0.014
0.005
Cupertino Village
1.28
0.002
0.01
Main Street Cupertino
5.16
0.004
0.02
Tantau Retail and Parking Gama e
0.76
0.001
0.01
Arco Facility #06091
0.52
0.0009
NA
Apple Inc. (19333 Vallco Parkway)
0.11
NA
0.00004
Pruneridge Avenue
1.43
NA
0.05
North Tantau Ave
1.32
NA
0.04
Homestead Road
0.64
NA
0.02
North Wolfe Road
0.81
NA
0.03
Interstate 280
12.38
0.012
0.10
Total
33.85
0.003
0.29
BAAQMD Threshold
100.0
10.0
0.8
Exceed
No
No
No
NA = Results not available for this category.
Source: LSA Associates, Inc., 2013.
Cumulative Operational Health Risk Analysis. As discussed above, the proposed project
would utilize back-up emergency generators on-site. These generators would be permitted by the
BAAQMD. Results of the generator and gas-fired boilers health risk analysis, in addition to the
cumulative health risk associated with roadways and stationary sources, are shown in Table V.L-11.
As shown in Table V.L-11, the cumulative health risk of all roadways, stationary sources and mobile
sources would be less than the BAAQMD's cumulative risk and hazard thresholds. Therefore,
residents in the vicinity of the project site would not be exposed to significant cumulative health risk
impacts during operation of the project.
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V. SETTING, IMPACTS AND MITIGATION MEASURES
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Table V.L-11: Cumulative Operational Health Risk Imnacts
NA = Results not available for this category.
Source: LSA Associates, Inc., 2013.
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Cancer Risk
in one million
Chronic Inhalation
Hazard Index
Annual PM2.5
Concentration
/m3
Apple Campus 2 Project
1.15
0.302
0.171
Arco Facility #06091
0.52
0.0009
NA
Apple Inc. (19333 Vallco Parkway)
0.11
NA
0.00004
Pruneridge Avenue
1.43
NA
0.05
N. Tantau Ave
1.32
NA
0.04
Homestead Road
0.64
NA
0.02
North Wolf Road
0.81
NA
0.03
Interstate 280
12.38
0.012
0.10
Total
18.36
0.315
0.41
BAAQMD Threshold
100.0
10.0
0.8
Exceed
No
No
No
NA = Results not available for this category.
Source: LSA Associates, Inc., 2013.
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