Item 41 - Amendment Application No. 2022-01 and Appeal Nos. 2022-01 and 2022-02

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City Response to Comment Letter Lozeau Drury, dated October 10, 2022 respiratory diseases. As shown on page 39 of the Community Plan Exemption Checklist, maximum daily construction emissions would not exceed the screening -level LSTs, and impacts would be less than significant. As described in Response 4, the GPU Update EIR provided screening level mitigation to implement the risk thresholds established by South Coast AQMD for potential DPM related operational impacts; and the Project would generate 44 non -refrigerated truck trips per day, which is less than the 100 unrefrigerated truck trips that would have the potential to result in an impact. Thus, no further evaluation of DPM emissions is required. As no potential new or greater impact would result, a mitigated negative declaration is not required. Comment 6: This comment states that SWAPE prepared a screening -level HRA to evaluate potential impacts from the construction and operation of the Project posed to residential sensitive receptors as a result of the Project's construction -related and operational TAC emissions. The comment states that SWAPE used AERSCREEN and applied a sensitive receptor distance of 200 meters (656 feet) and analyzed impacts to individuals at different stages of life based on OEHHA and SCAQMD guidance utilizing age sensitivity factors and found that 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. Response 6: The DPM evaluation that was completed for the GPU EIR, which identified Mitigation Measure AQ-3, that was implemented for the Project provides the appropriate evaluation of the Project pursuant to SCAQMD, CARB, and OEHHA recommended methodology, which determined that potential health impacts to sensitive receptors would be less than significant because the Project would result in less than 100 truck trips per day and residences are located approximately 2,200 feet from the Project, which is farther than the 1,000-foot setback recommended by the SCAQMD. The AERSCREEN model is widely acknowledged (including by the US EPA)2 as being overly conservative. AERSCREEN only produces worst -case scenario health risk impacts, without considering local meteorology and terrain, i.e. site -specific information, such as spatial relation, geography, or local meteorology. Therefore, the air quality model used by the commenter does not accurately identify risks of the Project and is not consistent with SCAQMD, CARB, and OEHHA recommended methodology. Comment 7: This comment states that the use of the 3,000 MT CO2e/year threshold is outdated because its past 2020 and that thresholds for 2020 are not applicable to the proposed Project and should be revised to reflect the current GHG reduction target, and states that the SCAQMD 2035 service population efficiency target of 3.0 metric tons of carbon dioxide equivalents per service population per year, which was calculated by applying a 40% reduction to the 2020 targets. Response 7: The commenter is incorrect in the implied assertion that the 3,000 MTCO2e per year threshold is based on the year 2020 statewide GHG reduction target under Assembly Bill 32 (AB 32) and that it is an outdated threshold. The 3,000 MTCO2e/yr threshold for development projects is based on a market capture approach and is not directly tied to a GHG reduction plan, such as CARB's Scoping Plan. In general, the threshold was developed based on a review of 711 projects in the Governor's Office of Planning and Research database of CEQA projects in the 2 United States Environmental Protection Agency, AERSCREEN User's Guide, April 2021 Exhibit 13 Page 3 of 7