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Cabrillo at First Mixed-Use Residential <br /> Air Quality, Global Climate Change, HRA, and Energy Impact Analysis <br /> 39 19386 <br />CUMULATIVE AIR QUALITY IMPACTS <br /> <br />There are a number of cumulative projects in the project area that have not yet been built or are currently <br />under construction. Since the timing or sequencing of the cumulative projects is unknown, any quantitative <br />analysis to ascertain daily construction emissions that assumes multiple, concurrent construction projects <br />would be speculative. Further, cumulative projects include local development as well as general growth within <br />the project area. However, as with most development, the greatest source of emissions is from mobile sources, <br />which travel well out of the local area. Therefore, from an air quality standpoint, the cumulative analysis would <br />extend beyond any local projects and when wind patterns are considered would cover an even larger area. <br />The SCAQMD recommends using two different methodologies: (1) that project-specific air quality impacts be <br />used to determine the potential cumulative impacts to regional air quality;8 and (2) that a project’s consistency <br />with the current AQMP be used to determine its potential cumulative impacts. <br /> <br />Project Specific Impacts <br /> <br />The project area is out of attainment for ozone, PM10, and PM2.5. Construction and operation of cumulative <br />projects will further degrade the local air quality, as well as the air quality of the South Coast Air Basin. The <br />greatest cumulative impact on the quality of regional air cell will be the incremental addition of pollutants <br />mainly from increased traffic volumes from residential, commercial, and industrial development and the use <br />of heavy equipment and trucks associated with the construction of these projects. Air quality will be <br />temporarily degraded during construction activities that occur separately or simultaneously. However, in <br />accordance with the SCAQMD methodology, projects that do not exceed the SCAQMD criteria or can be <br />mitigated to less than criteria levels are not significant and do not add to the overall cumulative impact. A <br />significant impact may occur if a project would add a cumulatively considerable contribution of a federal or <br />state non-attainment pollutant. <br /> <br />Project operations would generate emissions of NOx, ROG, CO, PM10, and PM2.5, which, would not exceed <br />the SCAQMD regional or local thresholds and would not be expected to result in ground level concentrations <br />that exceed the NAAQS or CAAQS. Since the project would not introduce any substantial stationary sources <br />of emissions, CO is the benchmark pollutant for assessing local area air quality impacts from post-construction <br />motor vehicle operations. As indicated earlier, no violations of the state and federal CO standards are <br />projected to occur for the project, based on the magnitude of traffic the project is anticipated to create. <br />Therefore, operation of the project would not result in a cumulatively considerable net increase for non- <br />attainment of criteria pollutants or ozone precursors. As a result, the project would result in a less than <br />significant cumulative impact for operational emissions. <br /> <br />Air Quality Compliance <br /> <br />The California Environmental Quality Act (CEQA) requires a discussion of any inconsistencies between a <br />proposed project and applicable General Plans and Regional Plans (CEQA Guidelines Section 15125). The <br />regional plan that applies to the proposed project includes the SCAQMD Air Quality Management Plan <br />(AQMP). Therefore, this section discusses any potential inconsistencies of the proposed project with the <br />AQMP. <br /> <br />The purpose of this discussion is to set forth the issues regarding consistency with the assumptions and <br />objectives of the AQMP and discuss whether the proposed project would interfere with the region’s ability to <br />comply with Federal and State air quality standards. If the decision-makers determine that the proposed <br />project is inconsistent, the lead agency may consider project modifications or inclusion of mitigation to <br />eliminate the inconsistency. <br /> <br /> <br />8 South Coast Air Quality Management District, Potential Control Strategies to Address Cumulative Impacts from Air Pollution White <br />Paper, 1993, http://www.aqmd.gov/home/regulations/ceqa/air-quality-analysis-handbook. <br />396/27/2022 <br />Planning Commission 2 –92