CORRESPONDENCE - 75D - Laserfiche WebLink

Metadata

Thumbnails

Annotations

Air Quality Failure to Evaluate Impacts from Construction Emissions The 2019 Addendum concludes that there are no new construction impacts, however the 2019 Addendum fails to quantify or evaluate the proposed Project's construction -related criteria air pollutant emissions. As a result, the Project's air quality impacts and associated emissions are inadequately addressed and mitigated. Until the Applicant prepares an updated analysis which quantifies and evaluates the Project's construction emissions, the conclusions made within the 2019 Addendum cannot be relied upon to determine Project significance. Regarding the Project's construction emissions, the 2019 Addendum's Air Quality Assessment, provided as Appendix F, qualitatively states: "The implementation of the improved off -road equipment emissions standards that have occurred since the time of the Final EIR would result in Project construction emissions that are substantially lower than what was anticipated in the Final EIR. The Main Place Specific Plan also identified sustainability features to enhance sustainability of the Project. These sustainability features include the compliance with all SCAQMD standards for construction equipment and the use of Tier 4 equipment where available during grading. Additionally, construction of the Proposed Project would be required to comply with various SCAQMD rules, including Rule 402 (Nuisance) and Rule 403 (Fugitive Dust). SCAQMD Rules 402 and 403 identify measures to be implemented for the control fugitive dust generated during ground -disturbance activities. As such, construction emissions would be lower than what was anticipated forthe Approved Project. No new construction impacts would occur" (2019 Addendum, Appendix F, p. 29). As stated in the excerpt above, the 2019 Addendum claims that the air pollutant emissions resulting from construction of the currently proposed Project would be lower than the emissions anticipated by the 1983 EIR, and thus the Project would not result in any new significant impacts. This justification is entirely unsubstantiated, as neither the 2019 Addendum nor the 1983 EIR quantified or evaluated the Project's construction criteria air pollutant emissions. Therefore, the Applicant cannot make a comparison between the respective 1983 and 2019 emission levels or rely upon such comparison to determine Project significance. The South Coast Air Quality Management District (SCAQMD), the lead air pollution control agency for the proposed Project, provides quantitative maximum daily significance thresholds for emissions of several criteria air pollutants during construction and operational activities (see excerpt below).3 'South Coast AQMD Air Quality Significance Thresholds. SCAQMD, April 2019, available at: httn://www.ag md.eov/dots/d efau It -sou rce/cega/hand book/stag md-air-gAglity-siznificance-thresholds.pdf