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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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQualiry.doc (06/03/13) P UBLIC REVIEW DRAFT 519 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY 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 P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQuality.doc (06/03/13) P UBLIC REVIEW DRAFT 520 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY 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 P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQualiry.doc (06/03/13) P UBLIC REVIEW DRAFT 521 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQuality.doc (06/03/13) P UBLIC REVIEW DRAFT 522 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQualiry.doc (06/03/13) P UBLIC REVIEW DRAFT 523 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY • 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQuality.doc (06/03/13) P UBLIC REVIEW DRAFT 524 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQuality.doc (06/03/13) P UBLIC REVIEW DRAFT 525 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY 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 P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQuality.doc (06/03/13) P UBLIC REVIEW DRAFT 526 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQuality.doc (06/03/13) P UBLIC REVIEW DRAFT 527 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQualiry.doc (06/03/13) P UBLIC REVIEW DRAFT 528 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQualiry.doc (06/03/13) P UBLIC REVIEW DRAFT 529 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQuality.doc (06/03/13) P UBLIC REVIEW DRAFT 530 LSA ASSOCIATES, INC. JUNE 2015 APPLE CAMPUS 2 PROJECT EIR V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY Table V.L-3: State and Federal Ambient Air Quality Standards Table notes included on next page. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQualiry.doc (06/03/13) P UBLIC REVIEW DRAFT 531 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQualiry.doc (06/03/13) P UBLIC REVIEW DRAFT 531 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQuality.doc (06/03/13) P UBLIC REVIEW DRAFT 532 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQuality.doc (06/03/13) P UBLIC REVIEW DRAFT 533 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY 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). P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQuality.doc (06/03/13) P UBLIC REVIEW DRAFT 534 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY (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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQualiry.doc (06/03/13) P UBLIC REVIEW DRAFT 535 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQualiry.doc (06/03/13) P UBLIC REVIEW DRAFT 535 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQualiry.doc (06/03/13) P UBLIC REVIEW DRAFT 536 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY 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: P:\COC1101 Apple 2 Ca pus\PRODUCTS\DEIR\Public\51-AirQualiry.doc(06/03/13) P UB%IC REVIEW DRAFT 537 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY • 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQuality.doc (06/03/13) P UBLIC REVIEW DRAFT 538 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY (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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQualiry.doc (06/03/13) P UBLIC REVIEW DRAFT 539 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQuality.doc (06/03/13) P UBLIC REVIEW DRAFT 540 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY • 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQualiry.doc (06/03/13) P UBLIC REVIEW DRAFT 541 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY 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 P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQualiry.doc (06/03/13) P UBLIC REVIEW DRAFT 542 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY 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 P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQuality.doc (06/03/13) P UBLIC REVIEW DRAFT 543 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY • 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQuality.doc (06/03/13) P UBLIC REVIEW DRAFT 544 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQuality.doc (06/03/13) P UBLIC REVIEW DRAFT 545 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQuality.doc (06/03/13) P UBLIC REVIEW DRAFT 546 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQuality.doc (06/03/13) P UBLIC REVIEW DRAFT 546 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY • 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). P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQuality.doc (06/03/13) P UBLIC REVIEW DRAFT 547 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY • 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQuality.doc (06/03/13) P UBLIC REVIEW DRAFT 548 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQuality.doc (06/03/13) P UBLIC REVIEW DRAFT 548 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQuality.doc (06/03/13) P UBLIC REVIEW DRAFT 549 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQuality.doc (06/03/13) P UBLIC REVIEW DRAFT 549 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES 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: P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQuality.doc (06/03/13) P UBLIC REVIEW DRAFT 550 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQuality.doc (06/03/13) P UBLIC REVIEW DRAFT 551 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY (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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQualiry.doc (06/03/13) P UBLIC REVIEW DRAFT 552 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQuality.doc (06/03/13) P UBLIC REVIEW DRAFT 553 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQualiry.doc (06/03/13) P UBLIC REVIEW DRAFT 554 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY 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 P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQualiry.doc (06/03/13) P UBLIC REVIEW DRAFT 555 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQuality.doc (06/03/13) P UBLIC REVIEW DRAFT 556 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY 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. P:\COC1101 Apple 2 Ca pus\PRODUCTS\DEIR\Public\51-AirQualiry.doc(06/03/13) P UB%IL' RESEW DRAFT 557 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. P:\COC1101 Apple 2 Ca pus\PRODUCTS\DEIR\Public\51-AirQualiry.doc(06/03/13) P UB%IL' RESEW DRAFT 557 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY 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 P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQualiry.doc (06/03/13) P UBLIC REVIEW DRAFT 558 LSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY • 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQualiry.doc (06/03/13) P UBLIC REVIEW DRAFT 559 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQualiry.doc (06/03/13) P UBLIC REVIEW DRAFT 559 LSA ASSOCIATES, INC. JUNE 2015 APPLE CAMPUS 2 PROJECT EIR V. SETTING, IMPACTS AND MITIGATION MEASURES L. AIR QUALITY Table V.L-11: Cumulative Operational Health Risk Imnacts NA = Results not available for this category. Source: LSA Associates, Inc., 2013. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQualiry.doc (06/03/13) P UBLIC REVIEW DRAFT 560 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. P:\COC1101 Apple 2 Campus\PRODUCTS\DEIR\Public\51-AirQualiry.doc (06/03/13) P UBLIC REVIEW DRAFT 560