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 6 of 7 SWAPE analyzed the Project’s emissions of Diesel Particulate Matter (DPM) into the air, and the resulting impact on human health. To do so, SWAPE prepared a screening-level Health Risk Assessment (“HRA”) to evaluate potential impacts from the construction and operation of the Project. (Exhibit A, pp. 3-7.) SWAPE prepared a screening-level HRA to evaluate potential health risk impacts posed to residential sensitive receptors as a result of the Project’s construction-related and operational TAC emissions. SWAPE used AERSCREEN, the leading screening-level air quality dispersion model. SWAPE applied a sensitive receptor distance of 200 meters and analyzed impacts to individuals at different stages of life based on OEHHA and SCAQMD guidance utilizing age sensitivity factors. SWAPE found that the excess cancer risks at a sensitive receptor located approximately 200 meters away over the course of Project construction and operation, while utilizing the recommended age sensitivity factors, are approximately 71.6 in one million for infants, 103 in one million for children, and 11.5 in one million for adults. (Id., p. 6.) Moreover, the excess cancer risk over the course of a residential lifetime (i.e. 30 years) for Project operation and construction is approximately 188 in one million. (Id.) The cancer risks to infants, children, adults, and lifetime residents appreciably exceed SCAQMD’s threshold of 10 in one million, thus indicating a significant air quality impact. Because the Project will have numerous significant air quality impacts peculiar to this project, and not analyzed in the GP EIR, additional CEQA review is required. C. The Project Will Have Significant Greenhouse Gas Impacts Requiring Additional CEQA Analysis Under 15183 Exemption. SWAPE analyzed Project’s potential greenhouse gas (“GHG”) emissions and found that the Project and GPU EIR failed to adequately analyze the Project’s greenhouse gas impacts, which SWAPE found to be potentially significant. (See, Exhibit A, pp. 8-10.) First, the Exemption Checklist’s greenhouse gas impact analysis and subsequent less- than-significant impact conclusion are based on an outdated quantitative analysis GHG threshold. (See, id., pp. 8-9.) According to SWAPE, the Exemption Checklist incorrectly “estimates that the Project would generate net annual [GHG] emissions of 1,668 metric tons of carbon dioxide equivalents per year (“MT CO2e/year”), which would not exceed the SCAQMD threshold of 3,000 MT CO2e/year.” (Id., p. 8.) SWAPE explains that this is incorrect because “the guidance that provided the 3,000 MT CO2e/year threshold, the SCAQMD’s 2008 Interim CEQA GHG Significance Threshold for Stationary Sources, Rules, and Plans report, was developed when the Global Warming Solutions Act of 2006, commonly known as “AB 32”, was the governing statute for GHG reductions in California. AB 32 requires California to reduce GHG emissions to 1990 levels by 2020.” (Id.) In addition, the Association of Environmental Professionals (AEP) guidance states: