75A - One Broadway Plaza Addendum_4.20.2020_wAppendices

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ONE BROADWAY PLAZA PROJECT EIR ADDENDUM CITY OF SANTA ANA 5. Environmental Analysis regulations; establishes permitting requirements for stationary sources; inspects emissions sources; and enforces such measures through educational programs or fines, when necessary for over an approximately 10,743 square - mile area. The SCAQMD is directly responsible for reducing emissions from stationary (area and point), mobile, and indirect sources. The Proposed Project supports AQMP objectives to reduce trips, promote infill development, and balance jobs and housing and would not conflict with implementation of the AQMP. In March of 2017, the SCAQMD Governing Board released the Final 2016 AQMP, which continues to evaluate current integrated strategies and control measures to meet the NAAQS, as well as, explore new and innovative methods to reach its goals. Some of these approaches include utilizing incentive programs, recognizing existing co -benefit programs from other sectors, and developing a strategy with fair -share reductions at the federal, state, and local levels. The two principal criteria for conformance with the AQMP are: 1. Whether the project would result in an increase in the frequency or severity of existing air quality violations or contribute to new violations or delay the timely attainment of air quality standards or the interim emissions reductions specified in the AQMP. 2. Whether the project would exceed the assumptions in the AQMP based on the years of Project build -out phase. With respect to the first criterion, implementation of the Proposed Project would not exceed the regional significance thresholds for construction or operational activity after implementation. Therefore, the Proposed Project would not conflict with the AQMP according to this criterion. The Proposed Project would not generate short-term or long-term emissions of criteria pollutants that could potentially cause an increase in the frequency or severity of existing air quality violations; cause or contribute to new violations; or delay timely attainment of air quality standards beyond those impacts considered in the Certified EIR. With respect to the second criterion, implementation of the Proposed Project according to the AQ/GHG Memo prepared by Urban Crossroads would not exceed regional or local thresholds for construction or operational impacts and would therefore have less than significant impacts. The Proposed Project would not exceed SCAG's population, housing, or employment projections. The Project would not result in or cause NAAQS or CAAQS violations nor would it result in any regional daily construction -source or operational - source emissions exceedances. The Project would support AQMP objectives to reduce trips, promote infill development, and balance jobs and housing, and would not conflict with implementation of the AQMP. The Project is therefore considered to be consistent with the AQMP. Therefore, the Proposed Project would be consistent with the region's AQMP. There would be no new significant impact or a substantial increase in the severity of previously identified effects. b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non -attainment under an applicable federal or state ambient air quality standard? Less Than Significant Impact/No Changes or New Information Requiring Preparation of an EIR. The Certified EIR disclosed that construction -related NO, and PM10 emissions would be significant and Page 30 PlaceWorks