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considerable because operational emissions of all criteria pollutants are below the project-level thresholds and, according to the BAAQMD, effects related to criteria air pollutants are inherently cumulative impacts because no single project is sufficient in size to, by itself, result in nonattainment of ambient air quality standards. Therefore, mitigation is not required and these impacts would be less than significant. (See Revised HRA Tables 7, 8, 10, 12 in Response to Comments Appendix B; Draft SEIR pages 4.B-24-25.) • Phase 1 operational air quality impacts (not modeled separately for Phase 1 in the Draft SEIR) are less than significant. Average daily operational ROG, NOX, PM10, and PM2.5 emissions for Phase 1 would be 53.27, 53.91, 55.32, and 15.43 pounds per day, respectively. These emissions do not exceed BAAQMD's threshold for ROG,NOX, and PM2.5 of 54 pounds per day and for PM 10 of 82 pounds per day. Therefore, ROG emissions would not require mitigation and Mitigation Measure M-AQ-2,Low-VOC Architectural Coatings, (identified in the Updated Air Quality Technical Memorandum) is not required. Consequently,the Project would have a less than significant impact with regard to Phase 1 operational ROG emissions. (See Revised HRA Table 7 in Response to Comments Appendix B; Response to Comments 1-9.) • The Project would have less than significant GHG impacts. The Project would be consistent with the 2017 Scoping Plan Update, Plan Bay Area 2040, and the City's Climate Action Plan. Because the Project is consistent with these applicable plans and policies to reduce GHG emissions, and because the Project implements certain Project design features (e.g. electric vehicle charging stations and rooftop solar photovoltaic panels), the Project would generate an incremental contribution to climate change compared to existing conditions, but would not generate enough GHG emissions on its own to significantly influence global climate change. Therefore,the Project would have a less than significant impact with regard to GHG emissions. (See Updated Greenhouse Gas Analysis pages 32-46; Response to Comments pages 3-33 through 3-40.) • The Project would have less than significant energy-related impacts. As stated in the 2019 recirculated Health Risk Assessment,Phase 1 would not require haul trucks to export rubble resulting from the demolition of existing buildings at the site, as no demolition would be required or take place; all existing rubble would be reused on-site. In addition, the majority of demolition debris created during Phase 2 demolition activities of existing buildings would be reused on-site, and Phase 2 would require fewer haul trucks to export this debris, compared to conditions of all demolition debris were to be removed from the site. By using much of this material on-site as construction base, the Project would eliminate both disposal trips for the demolition debris and haul trips for new aggregated fill material,thus eliminating the diesel fuel consumption associated with each truck trip. The Project would comply with applicable construction regulations that affect energy demand, such as idling restrictions that would result in less fuel combustion and energy consumption and minimize the Project's construction-