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City of Santa Ana— First American Mixed -Use Project [114 and 117 East Fifth Street] — Comments to City Council <br />November 18, 2019 <br />Page 9 of 13 <br />evaluated for cancer risks to nearby sensitive receptors. Id. The OEHHA also <br />recommends that exposure from projects with operations lasting more than 6 months <br />be evaluated for the duration of the project, and recommends an exposure duration of <br />30 years. Id. As a result, pursuant to the OEHHA guidance, the Addendum should <br />have evaluated health risks from Project construction and operation. Id. <br />Furthermore, Screening -Level HRA conducted by Mr. Hagemann and Mr. Rosenfeld <br />indicates that the Project will have a significant impact from DPM emissions. Exhibit <br />C, p. 7. The DPM emission rate during construction is 0.001368 grams per second <br />(g/s). Id. The DPM emissions rate during operation is 0.001125 g/s, generating <br />approximately 78 lbs. of DPM per year throughout the life of the Project's operation. <br />Id. at p. 7-8. The SCAQMD also gives a numerical threshold of 10 in one million to <br />evaluate projects. Id. Taking into account the age sensitivity factors, the excess cancer <br />risk posed to especially children and infants of the closest receptors far exceeds the <br />SCAQMD threshold at approximately 6.5 (adults), 58 (children),63infants) and 2.7 <br />(third trimester of pregnancy) in one million. Id. at 10. <br />The City must prepare an EIR which includes an analysis of health risks that connects <br />the Project's air emissions with the health risk posed by those emissions. <br />B. The Addendum Fails to Adequately Analyze, Disclose and Mitigate the <br />Project's Significant Greenhouse Gas Impacts <br />The Addendum erroneously concludes that the Project would have less than <br />significant greenhouse gas (GHG) impacts, relying on the analyses indicated in the <br />2010 EIR for the Transit Zoning Code. According to Mr. Hagemann and Mr. <br />Rosenfeld, the Addendum's GHG impacts analyses are deficient for the following <br />reasons, which are detailed in their letter in Exhibit C, p. 11-24: <br />(1) The Addendum fails to demonstrate consistency with the 2010 EIR, fails to <br />commit to the use of the same mitigation measures provided in the 2010 EIR <br />(MM 4.13-8 through 4.13-23), and fails to explain how the mitigation measures <br />would be implemented, monitored, and enforced, <br />(2) The Santa Ana County CAP cannot be relied upon to determine Project <br />significance because it does not apply to the Project because the Project will <br />not be fully operational by 2020; <br />