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NOP Comments RE.Related Bristol Specific Plan April 17,2023 Page 2 of 4 2 02 0.3 Roughly one year later(in response to City Planning Commission concerns),the City recirculated for a 45-day public review another 3-volume, 2,229-page Draft PEIR that incorporated the original Draft PEIR by reference.4 A Final PEIR was certified in April 2022,which was subsequently subject to a June 2022 PEIR"Addendum"to reflect changes associated with the Housing Element.5 Given that the PEIR is already thousands of pages contained in numerous volumes,6 Local 11 requests that the City provide a 65-day public comment review of the forthcoming SEIR-just as before.This is appropriate given the prior Draft PEIR received a similar comment period length and is necessary for the public and the City decision-making body to consider the SEIR in context of the previously adopted PEIR and Addendum. Second, the SEIR should consider the Proiect's consistency with greenhouse gas CGHG") and vehicle miles traveled C'VMT") assumptions under the PEIR, as well as newer applicable plans. For example,the PEIR found the Housing Element would not have a significant VMT impact,in part, because it was projected to generate 22.0 VMTs per service population. (PEIR,6 pp. 5.16-36.) Similarly,the PEIR found some GHG impacts to be less than significant because the development would achieve 3.5 MTCO2e per service population. (See PEIR,6 pp. 5.7-33.) The SEIR should analyze whether the Project will achieve these levels of VMT/GHG performance throughout the build out of the Specific Plan. Furthermore,the PEIR assumed the City would update its 2015 Climate Action Plan ("CAP") to substantially lessen significant GHG impacts. (See PEIR, pp. 5.7-37- 5.7-40.) However, it does not appear that the City has updated its 2015 CAP,which undermines the City's reliance on a supplemental EIR in lieu of a subsequent, project-specific EIR. The lack of an updated CAP must be adequately addressed. Third, the SEIR should consider new applicable plans affecting air quality and GHG emissions. The PEIR's air quality and GHG analysis relied on various plans prepared by the California Air Resources Board ("CARB"), South Coast Air Quality Management District("SCAQMD"), and the Southern California Association of Governments ("SCAG"). (Id., 5.7-9, 5.7-12, 5.7-35 [referencing CARB's 2017 Scoping Plan, SCAG's 2020 RTP/SCS]; see also PEIR,6 pp.5.2-10 [referencing SCAQMD's 2016 AQMP].) However,these and other relevant plans have been and/or in the process 3 See OPR,Santa Ana General Plan Draft Program Environmental Impact Report,https://ceganet.opr.ca.gov/ 2020029087/3;see also Notice of Availability("NOA") (8/3/2020),p.1,https://files.ceganetopr.ca.gov/ 2 59509-3/attachment/rPOG9KVMv9 FuVohMGyOWRhQDMDTtUcCC4nTHY9ggeIBGjOiLN4PzOvvfQtWWv UngNgOwQFgvjVoyAxIxO;see also NOA,infra fn.4. 4 See OPR,Santa Ana General Plan Update Recirculated Draft Program Environmental Impact Report, https://ceganet.opr.ca.gov/2020029087/4;see also NOA(8/6/2021),pp.2-3,https://files.ceganet.opr.ca .gov/2 595 09-4/attachment/fN QOgJ LxLO mSQZHS neSMgZYCOdYbN4PJGdJ-y7 RuvLj Vx9 HeHfbJ FA9 7y1b414ogL7vBtFN1B0 RQRI6_0. 5 See Notice of Determination(signed 4/20/2022),https://files.ceqanet.opr.ca.gov/259509- 5/attachment/RNYUgTODtWU4xw77VnOS1ZXiOOGosufGgyONdJtapVxro2 L4ehNyXmHGuarrReO2 3jbfQG3 MPJ LvTSYQO;see also Addendum(Jun.2022),p.1,https://storage.googleapis.com/proudcity/ santaanaca/uploads/2022/07/Santa-Ana-Housing-Element_Addendum_June_202 2.pdf. 6 https://www.santa-ana.org/general-plan-environmental-documents/.