01-14-19_AGENDA PACKET - Laserfiche WebLink

Home Browse Search

Response to Comment City of Santa Ana 12 Magnolia at the Park Multi-Family Residential Project December 2018 are designed to encompass the spectrum of potential meteorological conditions - not actual measured data; calculation of only a one-hour concentration for each of the theoretical meteorological conditions; and no differentiation is provided between daytime and nighttime conditions. As such, the model calculates one-hour concentrations under all conditions. Due to its simplicity and reliance on limited actual site-specific physical and meteorological conditions, AERSCREEN provides an overstated assessment of pollutant concentrations. Given the limited TAC emissions sources that would result from operation of the project, the assessment provided in this comment has greatly exaggerated and overestimated project operational risk impacts, and therefore is not substantial evidence of an actual project impact. As detailed in the previous responses, both construction and operational emissions resulting from the project would be below SCAQMD thresholds with implementation of Mitigation Measure AQ-1. For these reasons, health risk impacts at adjacent sensitive receptors would be less than significant and would not result in a potential impact not previously addressed in the EIR. Comment 30: This comment states that the screening‐level HRA, provided as Comment 29, is conservative and its purpose is to determine if a more refined HRA needs to be conducted. The comment asserts that based on the results of the screening-level HRA provided as Comment 29, refined construction and operational HRAs need to be prepared to examine air quality impacts generated by project construction and operation using site‐specific information. The comment further asserts that an updated analysis of the project’s health risk impact should be prepared and mitigation measures included to reduce impacts to a less‐than‐significant level. Response 30: Refer to Responses 27 through 29. Project specific analysis of potential air quality impacts have been completed pursuant to the SCAQMD methodology, which has determined that impacts would be less than significant with Mitigation Measure AQ-1 related to off-road diesel construction equipment compliance with EPA/CARB Tier 3 emissions standards. An updated analysis and additional mitigation measures are not required. Comment 31: This comment provides a list of recommended mitigation measures to reduce diesel particulate matter emissions that is emitted by on‐road vehicles and by off‐road construction equipment. Response 31: As described by Response 30, impacts would be less than significant with Mitigation Measure AQ-1 and additional mitigation measures, including those listed in this comment, are not required. Comment 32: This comment states that the recommended mitigation measures offer a cost‐effective, feasible way to incorporate lower‐emitting design features into the project, and that an updated EIR needs be prepared to additional analyses and include diesel particulate matter related mitigation measures to reduce health risk impacts to a less than significant level. Response 32: As described by Response 30, impacts would be less than significant with Mitigation Measure AQ-1 and additional mitigation measures, including those listed in this comment, are not required. 2-308