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February 4, 2025 <br />Page 12 <br /> <br />7357-016j <br /> <br />negotiation.50 The addition of the East Lakes Project will substantially expand the <br />water supply needs at the Project site, and may require significant changes to the <br />LOA Cal Water is considering. The Projects’ cumulative water supply needs must <br />be quantified and discussed in a single Water Supply Assessment as part of the <br />revised DEIR. <br /> <br />3. The Revised EIR Must Analyze the Projects’ Potentially <br />Significant Air Quality Impacts <br /> <br />Under CEQA a project has significant impacts if it “[v]iolate[s] any air <br />quality standard or contribute[s] substantially to an existing or projected air quality <br />violation” or “[e]xpose[s] sensitive receptors to substantial pollutant <br />concentrations.”51 The Bay Area Air Quality Management District (“BAAQMD”) <br />maintains thresholds of significance for criteria air pollutants that are to be used in <br />determining the significance of a project’s air quality impacts under CEQA.52 The <br />DEIR acknowledges that the proposed project would result in a significant impact if <br />it exceeds the BAAQMD construction and operational significance thresholds,53 but <br />concludes that Project emissions would not exceed any of these thresholds.54 <br /> <br />East Bay Residents’ air quality and public health expert consultant, SWAPE, <br />reviewed the DEIR’s air quality analysis and performed an independent model of <br />the Arroyo Lago Project’s construction emissions.55 SWAPE concluded that the <br />DEIR underestimated the Arroyo Lago Project’s construction emissions of ROG, <br />NOX, PM10, and PM2.5 by artificially extending the construction phase lengths <br />without proper justification. SWAPE also concluded that the DEIR failed to <br />adequately analyze emissions associated with material hauling and associated <br />truck trips. Finally, SWAPE explained that the DEIR relied on modeling based on <br />Tier 4 Final engine tier, but the DEIRs’ mitigation measures only required Tier 4 <br />Interim, which has higher emissions than Tier 4 Final. These significant errors and <br /> <br /> <br />50 Id. <br />51 CEQA Appendix G. <br />52 Bay Area Air Quality Management District 2022 CEQA Guidelines Thresholds of Significant <br />(2022), available at: https://www.baaqmd.gov/~/media/files/planning -and-research/ceqa/ceqa- <br />guidelines-2022/ceqa-guidelines-chapter-3-thresholds_final_v2- <br />pdf.pdf?rev=a976830cce0c4a6bb624b020f72d25b3&sc_lang=en. <br />53 DEIR, p. 3.2-36; 3.2-38. <br />54 DEIR, p. 3.2-43. <br />55 SWAPE Comments, pp. 2-13.