75C - PH MORTIMER MIXED USE - Laserfiche WebLink

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City of Santa Ana 4th and Mortimer Project FEIR. With respect to Title 24, the project is required to comply with the standards set by the 2010 FEIR to minimize the wasteful, inefficient, or unnecessary consumption of energy resources during project operation. Response 18 The commenter states that, based on conclusions from Dr. Paul Rosenfeld, Ph.D. and Matthew Hagemann, C. Hg, P.G. of the environmental consulting firm SWAPE, the Addendum's air quality analysis is flawed due to unsubstantiated input parameters used estimate the project's air quality emissions. The commenter adds that SWAPE concluded that the project would create a cancer risk from airborne pollution of up to 210 per million — over 20 times above the SCAQMD significance threshold of 10 per million. The commenter states that SWAPE also calculated significance greenhouse gas impacts associated with the project. The commenter concludes that the Addendum fails to implement all feasible mitigation measures to reduce the project's air quality emissions and adds that an EIR is required to analyze and mitigate the project's significant air quality and greenhouse gas emissions impacts. According to the Air Quality Assessment conducted for the project, which is included as Appendix B to the Addendum, emissions were modeled using the California Emissions Estimator Model version 2016.2.3 (CalEEMod). CalEEMod is a Statewide land use emissions computer model designed to quantify potential criteria pollutant emissions associated with both construction and operations from a variety of land use projects. Air quality impacts were adequately assessed according to methodologies recommended by CARB and the SCAQMD. Regulatory measures that apply to the project include compliance with SCAQMD Rules 402 and 403 (prohibition of nuisances, watering of inactive and perimeter areas, track out requirements, etc.) and SCAQMD Rule 1113 (low -Volatile Organic Compound paint) and were included in CalEEMod. Furthermore, the air quality and greenhouse gas emissions associated with the project and reported in the Addendum conservatively do not take credit for the emissions currently associated with the existing uses that would be removed. As discussed in the Air Quality Assessment and Section 3.2, Air Quality, of the Addendum, construction would result in the generation of diesel particulate matter (DPM) emissions from the use of off -road diesel equipment. The amount to which the receptors are exposed (a function of concentration and duration of exposure) is the primary factor used to determine health risk (i.e., potential exposure to Toxic Air Contaminant [TAC] emission levels that exceed applicable standards). Health -related risks associated with diesel -exhaust emissions are primarily linked to long-term exposure and the associated risk of contracting cancer. The use of diesel trucks would be most prevalent during the temporary construction period of the project rather than during operation of the project. Current models and methodologies for conducting health risk assessments are associated with longer -term exposure periods of 9, 30, and 70 years, which do not correlate well with the temporary and highly variable nature of construction activities. DPM emissions from the 21-month construction period of the project would represent a range of 2.5 to 19.4 percent of the typical exposure duration used in health risk assessments. The closest sensitive receptors are located adjacent to the site, approximately 55 feet from the project site boundary. Project construction involves phased activities in several areas across the site and the project would not require the extensive use of heavy-duty equipment or diesel trucks in any one location over the duration of construction, which would limit the exposure of any proximate individual sensitive receptor to TACs. The project would not result in a significant cancer risk from airborne pollution. As such, Section 3, Environmental Impact Analysis, of the Addendum supports the conclusion that 75C-294