Item No. 2 Public Comment_Yundt - Laserfiche WebLink

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Comment on Garry Avenue Business Park Project Planning Commission Agenda Item 2 (Amendment Application No. 2022 -01; Conditional Use Permit No. 2022-14) October 10, 2022 Page 5 of 7 First of all, the Project’s potential air quality impacts were not addressed in the previous General Plan EIR, because the air quality impacts of the Project as proposed could not have been foreseen at the time the General Plan was prepared. Emissions for the proposed Project must be modeled using a program such as CalEEMod, and project-specific input parameters must be measured against applicable thresholds. Further, a screening-level HRA must be prepared to determine the risk posed to nearby residential receptors, as well as propose mitigation as necessary. If the Project’s criteria air pollutant and/or toxic air contaminant emissions exceed the relevant South Coast Air Quality Management District’s (“SCAQMD”) thresholds, the Project’s greenhouse gas emissions must also be modeled using a program such as CalEEMod and mitigation must be implemented if necessary. As discussed below, these considerations all represent potential project-specific significant effects that were not addressed in the previous General Plan EIR, and therefore, the City must review these impacts under CEQA. A. The Project Could Have Significant Air Quality Impacts, Requiring Additional CEQA Analysis Under Section 15183. In support of the Exemption, the City claims that the Project is not required to submit an HRA, as Mitigation Measure AQ-3 (“MM-AQ-3”) included in the GPU EIR is not applicable to the Project. (See, Exhibit A, pp. 1-2.) However, as SWAPE notes, “regardless of the [Exemption Checklist] claims, the State of California Department of Justice recommends that all warehouse projects prepare a quantitative HRA pursuant to the Office of Environmental Health Hazard Assessment (“OEHHA”), the organization responsible for providing guidance on conducting HRAs in California, as well as local air district guidelines.” OEHHA released its most recent guidance document in 2015 describing which types of projects warrant preparation of an HRA. (See, e.g., “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: http://oehha.ca.gov/air/hot_spots/hotspots2015.html.) OEHHA recommends that projects lasting at least 2 months be evaluated for cancer risks to nearby sensitive receptors, a time period which this Project easily exceeds. (Exhibit A, p. 2.) Because “the Project’s anticipated construction duration exceeds the 2-month and 6-month requirements set forth by OEHHA, construction of the Project meets the threshold warranting a quantified HRA under OEHHA guidance and should be evaluated for the entire 12-month construction period.” (Id.) The OEHHA document also recommends that if a project is expected to last over 6 months, the exposure should be evaluated throughout the project using a 30-year exposure duration to estimate individual cancer risks. (Id.) Based on its extensive experience, SWAPE reasonably assumes that the Project will last at least 30 years, and therefore recommends that health risk impacts from project-generated Diesel Particulate Matter (“DPM”) emissions be evaluated. (Id.) An initial study and mitigated negative declaration or environmental impact report is needed to adequately address the air quality impacts of the proposed Project, and to mitigate those impacts accordingly. B. The Project Will Have a Significant Health Impact as a Result of Diesel Particulate Emissions into the Air.