01-14-19_AGENDA PACKET - Laserfiche WebLink

Home Browse Search

Response to Comment City of Santa Ana 11 Magnolia at the Park Multi-Family Residential Project December 2018 diesel delivery trucks would be considered a TAC source, of which the residential project would generate a very small amount, resulting in almost no increase in health risk at the nearby residential receptors. Additionally, the air quality analysis for the proposed project (Appendix C of the Draft EIR and Section 4.2, Air Quality, of the Draft EIR) evaluates both construction and operational emissions that would be generated by the proposed project and could affect nearby existing sensitive receptors. SCAQMD does not state that construction based HRAs are required. However, the local significance thresholds (LSTs) are used to evaluate potential impacts from particulate matter emissions to sensitive receptors in the project's vicinity from project construction. Section 4.2, Air Quality, of the Draft EIR includes a local construction analysis of particulate matter (and other criteria pollutants) and compared those emissions to SCAQMD’s LSTs. As shown in Table 4.2-9 on page 4.2-17 of the Draft EIR, local construction related emissions would not exceed SCAQMD LST thresholds with implementation of Mitigation Measure AQ-1 that requires off-road diesel construction equipment to comply with EPA/CARB Tier 3 emissions standards. Therefore, no further analysis is required. The Draft EIR also includes an operational analysis of air quality that evaluates the long-term emissions of criteria pollutants that would be generated from the project, including particulate matter that determined that emissions from operation of the proposed project would not exceed the applicable regional thresholds of significance (Table 4.2-7 on page 4.2-16 of the Draft EIR). In addition, page 4.2-18 of the Draft EIR describes that the number of vehicle trips in year 2040 with project condition would not be high enough to generate an adverse CO concentration or “hot spot” per SCAQMD. Furthermore, Draft EIR Table 4.2-10 describes that the HRA determined that freeway emissions of CO, NO2, PM 10 , and PM 2.5 would not exceed the SCAQMD significance thresholds and that impacts related to exposures, including exposure of nearby existing sensitive receptors, to both toxic and criteria pollutants would be less than significant. Comment 28: This comment asserts that the Draft EIR does not include a construction or an operational HRA for existing sensitive receptors, the Draft EIR is inconsistent with recommendations set forth by the OEHHA that recommends that all short‐term projects lasting at least two months be evaluated for cancer risks to nearby sensitive receptors and that long-term projects should assume a 30-year exposure rate. The comment further asserts that this evaluation should be included in a revised CEQA evaluation for the project. Response 28: Refer to Responses 17, 23, and 27. As described in these previous responses, the air quality analysis for the proposed project (Appendix C of the Draft EIR and Section 4.2, Air Quality, of the Draft EIR) evaluates both construction and operational emissions that would be generated by the proposed project and could affect nearby existing sensitive receptors. Both short-term construction related local impacts (LSTs) and long-term operational impacts from the project and the emissions related to the nearby high traffic roadways have been evaluated and determined to be less than significant with construction related Mitigation Measure AQ-1. As a result, recirculation of the Draft EIR is not required. Comment 29: This comment provides a screening-level assessment and asserts that construction and operational diesel particulate matter emissions may result in a potentially significant health risk impact that was not previously identified or evaluated in the EIR. The screening-level assessment provided in the comment utilized the AERSCREEN model and maximum downwind concentration to generate estimates of emissions from the project. Response 29: The analysis provided by this comment relies on an imprecise screening model (i.e., AERSCREEN) to predict high impact levels and is based on CalEEMod modeling that appears to have used default conditions. As such, the analysis is imprecise and inaccurate. A screening modeling approach, such as the one used in this comment is a simplified version of a refined model and is limited to: use of theoretical, or synthetic, meteorological conditions that 2-307