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4 Environmental Analysis 4.3 Air Quality violation or result in a considerable net increase in criteria air pollutants. As discussed above, emissions of air pollutants are less than significant, consistent with the SJVAPCD applicable air plan, and the Project's incremental contribution to the cumulative impact in the region would not be considered cumulatively considerable. While emissions are not significant, Mitigation Measures AQ-1, AQ-2, and AQ-3 would be implemented to further limit impacts from the Project. Additionally, as discussed above, the Project would not conflict with or obstruct implementation of the SJVAPCD's air quality plans. Therefore, the Project construction would not result in a cumulatively considerable increase in emissions of nonattainment pollutants. Project operation would include very minimal emissions of ozone precursors ROG and NO, PM1o, and PM2.5, well below the SJVAPCD's thresholds; therefore, O&M would not result in a cumulatively considerable increase in emissions of nonattainment pollutants. Project emissions of pollutants for which the SJVAB is in attainment for state and federal air quality standards also would not lead to a cumulative impact because the individual Project emissions would be well below the thresholds in an area that does not experience violations of these standards. Lastly, the SJVAPCD considers TAC emissions to be localized impacts. The SJVAPCD has established thresholds of significance for TACs that are conservative and protective of health impacts on sensitive receptors. Because impacts from TACs are localized and the thresholds of significance for TACs have been established at such a conservative level, Project risks over the individual thresholds of significance are also considered cumulatively significant (SJVAPCD 2015a).As discussed above, the Project diesel PM10 emissions from construction would not result in health risk impacts in excess of the SJVAPCD 20 in 1 million cancer threshold and chronic Hazard Index of 1 due to the use of Tier 4 engines (Mitigation Measure AQ-1). Therefore, the Project would not result in a cumulatively significant impact related to TACs. Similarly, odor impacts from the Project would be very minimal and localized and would not contribute to cumulative odors impacts in the area. 4.3.10 References Alameda County. 2014. Alameda County (Unincorporated Area) Community Climate Action Plan. Available online at: http://www.acgov.org/cda/planning/generalplans/documents/110603_Alameda_CCAP_F inal.pdf BAAQMD (Bay Area Air Quality Management District). 2017a. California Environmental Quality Act Air Quality Guidelines. Available online at: https://www.baagmd.gov/—/media/files/planning-and- research/cepa/cepa guidelines may2017-pdf.pdf?la=en. BAAQMD (Bay Area Air Quality Management District). 2017b. Final Clean Air Plan — Spare the Air Cool the Climate. Available online at: https://www.baagmd.gov/—/media/files/planning-and-research/plans/2017-clean-air- plan/attachment-a -proposed-final-cap-vol-1-pdf.pdf?la=en CAPCOA (California Air Pollution Control Officers Association). 2021. California Emissions Estimator Model (CaIEEMod) User's Guide Version 2020.4.0. Prepared by BREEZE Griffith Energy Storage Project 4.3-33 Tetra Tech/SCH 2022120675 Draft Environmental Impact Report August 2023