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NOP Comments RE.Related Bristol Specific Plan April 17,2023 Page 3 of 4 of being updated, such as: CARB's 2022 Scoping Plan;7 SCAG's 2024 RTP/SCS;8 SCAQMD's 2022 AQMP;9 and SCAQMD's updated"Air Quality Analysis Guidance Handbook" ("Handbook")to replace the 1993 Handbook.10 To the extent feasible,the SEIR's air/GHG impact analysis should be consistent with current methodologies discussed in these new documents. Fourth, the SEIR should consider all feasible mitigation measures for significant impacts and explain with substantial evidence why anv measures are not considered.The Final PEIR determined the Housing Element would result in significant and unavoidable impacts to air quality, cultural resources, GHG emissions,noise,recreation,population and housing. (See Final PEIR,11 Tbl. 1-5.) The City should explore all feasible measures to minimize these impacts,as well as new impacts created by this Project. Local 11 urges the City to consider those measures and project design features that reduce mobile emissions and increase renewable energy sources,such as those urged by the State Office of Policy and Research ("OPR"),the California Air Pollution Control Officers Association ("CAPCOA"),SCAG, and CARB.12 The SEIR should explore all of these options and explain with substantial evidence why any specific measures were not considered for those impacts that remain significant and purportedly unavoidable. Fifth, the City should consider more than iust compliance with the Santa Ana Municipal Code C"SAMC"or"Code")for biological/tree impacts. For example,the PEIR relied on compliance with established tree removal regulations and focused solely on parcels designated as open space. (PEIR,13 pp. 5.3-3, 5.3-18 - 5.3-19; see also SAMC§ 33-181 et seq.) Neither the PEIR nor the Code address the loss of urban tree canopies—particularly as they relate to the general public (loss of shade) or bird populations (loss of habitat). Code compliance alone may not reduce impacts to less than significance.14 The SEIR should consider additional mitigation measures and alternatives that minimize tree removal (e.g., relocating/redesigning proposed structures, detailed construction plans that minimize the need for grading and clearing) and promote native landscaping(e.g., relocating existing trees,tree replacement rate greater than Code requirements). See SCAQMD 2022 Scoping Plan Documents,https://ww2.arb.ca.gov/our-work/programs/ab-32-climate- change-scop ing-plan/202 2-scoping-p Ian-documents. 8 See SCAG's 2020 RTP/SCS website,https://scag.ca.gov/connect-socal;see also adopted 2024 RTP/SCS Framework and Guidelines,https://scag.ca.gov/sites/main/files/file-attachments/2024-subregional-scs- f ra me wo rk-gui d e 1 in e s.pd f. 9 SCAQMD's 2022 AQMP Website,http://www.agmd.gov/home/air-quality/clean-air-plans/air-quality-mgt- plan; 10 See SCAQMD Handbook Website,https://www.agmd.gov/home/rules-compliance/ceqa/air-quality- analysis-handbook. 11 Supra fn.6. 12 See e.g.,CAPCOA(August 2010)Quantifying GHG Measures,http://www.aqmd.gov/docs/default- source/ceqa/handbook/capcoa-quantifying-greenhouse-gas-mitigation-measures.pdf,CAPCOA(Dec.2021) Handbook for Analyzing GHG Emission Reductions,https://www.airquality.org/ClimateChange/Documents/ Final%20Handbook_AB434.pdf;OPR(Dec.2018)Technical Advisory,http://opr.ca.gov/docs/20190122- 743_Technical_Advisory.pdf;CARB(Jan.2017) 2017 Scoping Plan,Appendix B-Local Action,pp.7-9, https://www.arb.ca.gov/cc/scopingplan/app_b_local_action_final.pdf, 2022 Scoping Plan,Appendix B-Local Actions,https://ww2.arb.ca.gov/sites/default/files/2022-11/2022-sp-appendix-d-local-actions.pdf;2022 SCAG(2020) Final Program EIR,pp.2.0-18-2.0-71,https://scag.ca.gov/sites/main/files/file- attachments/exhibit-a_connectsocal_peir.pdP 1606004156. 13 Supra fn.6. 14 See Californians for Alternatives to Toxics v.Department of Food and Agriculture (2005) 136 Cal.App.4th 1, 17 ("[c]ompliance with the law is not enough to support a finding of no significant impact under the CEQA.").