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The Bowery Mixed-Use Project CEQA Findings of Fact City of Santa Ana 47 May 2020 could easily travel to employment opportunities within the vicinity of the Project site, including areas within the Cities of Santa Ana, Tustin, and Irvine. Thus, the proposed Project would support AQMP objectives to reduce trips, promote infill/redevelopment, and balance jobs and housing, and would not conflict with implementation of the AQMP. In addition, implementing redevelopment of the site, the Project would utilize existing infrastructure such as roadways, drainage, sewer and other infrastructure, and would be consistent with the SCAG objective to “Encourage patterns of urban development and land use that reduce costs in infrastructure construction and make better use of existing facilities.” As a result, the proposed Project would comply with Consistency Criterion No. 1 listed above in the Methodology Section. Regarding Consistency Criterion No. 2, which evaluates the potential of the proposed Project to increase the frequency or severity of existing air quality violations; an impact would occur if the long-term emissions associated with the proposed Project would exceed SCAQMD’s regional significance thresholds for operation-phase emissions. As detailed below in Impact AQ-2, operation of the proposed Project would exceed the threshold of significance for emissions of VOCs and there are no feasible mitigation measures that would reduce VOC emissions to below the SCAQMD threshold. Therefore, the proposed Project would result in an impact related to Consistency Criterion No. 2. As a result, impacts related to consistency with the AQMP would be significant and unavoidable. Impact Finding: Operation of the Project would 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 (Draft EIR at p. 5.2-16). Facts in Support of Findings: Implementation of the Project would result in long-term emissions of criteria air pollutants from area sources generated by the proposed commercial and residential uses, such as vehicular emissions, natural gas consumption, landscaping, applications of architectural coatings, and use of consumer products. The emissions from the proposed Project are primarily from vehicle trips. As described in Section 5.14, Transportation, the proposed Project is anticipated to generate 11,546 daily trips, with 534 a.m. peak hour trips and 604 p.m. peak hour trips. The operational emissions from the Project are provided in the Draft EIR Table 5.2-8, on page 5.2-17, which shows that emissions from operation of the proposed Project would exceed the threshold of significance for VOCs. The majority of VOC emissions would be derived from consumer products and mobile activity. Consumer products include cleaning supplies, kitchen aerosols, cosmetics and toiletries, the use of which cannot be controlled by the City. Likewise, vehicular emissions cannot be controlled by either the Project applicant or the City. There are no feasible mitigation measures that would reduce VOC emissions to below the SCAQMD threshold. Therefore, operational emissions of the Project would be significant and unavoidable. Q. Greenhouse Gases Impact Finding: The Project would generate greenhouse gas (GHG) emissions, either directly or indirectly, that would have a significant impact on the environment (Draft EIR at p. 5.6-10). Facts in Support of Findings: The proposed Project would generate GHG emissions from vehicle trips, electricity and natural gas consumption, water and wastewater transport (the energy used to pump water), and solid waste generation. GHG emissions from electricity consumed by the 3-69