Item No. 2 Public Comment_Yundt - Laserfiche WebLink

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7 “EPA’s Exposure Assessment Guidelines recommend completing exposure assessments iteratively using a tiered approach to ‘strike a balance between the costs of adding detail and refinement to an assessment and the benefits associated with that additional refinement’ (U.S. EPA, 1992). In other words, an assessment using basic tools (e.g., simple exposure calculations, default values, rules of thumb, conservative assumptions) can be conducted as the first phase (or tier) of the overall assessment (i.e., a screening-level assessment). The exposure assessor or risk manager can then determine whether the results of the screening- level assessment warrant further evaluation through refinements of the input data and exposure assumptions or by using more advanced models.” As demonstrated above, screening-level analyses warrant further evaluation in a refined modeling approach. Thus, as our screening-level HRA demonstrates that construction and operation of the Project could result in a potentially significant health risk impact, an EIR should be prepared to include a refined health risk analysis which adequately and accurately evaluates health risk impacts associated with both Project construction and operation. Greenhouse Gas Failure to Adequately Evaluate Greenhouse Gas Impacts The Project claims an exemption from the California Environmental Quality Act (“CEQA”) pursuant to Guidelines Section 15183. Specifically, the Staff Report states: “Pursuant to the California Environmental Quality Act (CEQA) and the CEQA Guidelines, the project is exempt from further review pursuant to 15183 of the CEQA Guidelines. This type of exemption analysis evaluates whether the potential environmental impacts of the proposed demolition of three office buildings, which total 105,558 square feet, and construction of a new 91,500 square foot light industrial warehousing building that would accommodate two tenants are addressed in the City of Santa Ana General Plan Update Final Recirculated Program Environmental Impact Report (GPU EIR). As set forth in California Public Resources Code (PRC) Section 21083.3 and State CEQA Guidelines Section 15183, projects that are “consistent with the development density established by the existing zoning, community plan or general plan policies for which an EIR was certified shall not require additional environmental review, except as might be necessary to examine whether there are project-specific significant effects which are peculiar to the project or its site” (State CEQA Guidelines Section 15183(a) and PRC Section 21083.3(b)). The State CEQA Guidelines further state that “[i]f an impact is not peculiar to the parcel or to the project, has been addressed as a significant effect in the prior EIR, or can be substantially mitigated by the imposition of uniformly applied development policies or standards […] then an additional EIR need not be prepared for the project solely on the basis of that impact” (State CEQA Guidelines Section 15183(c))” (p. 2-6 – 2-7).