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City Response to Comment Letter Lozeau Drury, dated October 10, 2022 <br />Climate Action Plan. Because the Project would not exceed the applicable threshold, it would not <br />have a significant GHG impact; and the evaluation concluded that the Project would be consistent <br />with the applicable plans. Thus, the GHG analysis in the Community Plan Exemption Checklist is <br />consistent with the CEQA Guidelines and adequately evaluates GHG impacts as required by <br />CEQA. <br />Comment 9: This comment requests that the Planning Commission deny the applications for the <br />Project and, instead, direct city staff to prepare the necessary environmental documents under <br />CEQA. The City should prepare an initial study followed by an EIR or negative declaration in <br />accordance with CEQA prior to consideration of approvals for the Project. <br />Response 9: The comment is conclusionary in nature and does not raise any specific concerns <br />with the adequacy of the Community Plan Exemption Checklist and does not provide any <br />substantial evidence of a potential new impact related to the Project. Therefore, no further <br />response is required or provided. This comment will be forwarded to City decision makers as part <br />of the Project's staff report. <br />Comment 10: This comment provides a summary of the Project description and states that the <br />Project's health risk and GHG have not been adequately evaluated and emissions have been <br />underestimated and that an EIR should be prepared to assess and mitigate risks. <br />Response 10: The comment is introductory in nature, provides general comments, and does not <br />include any substantial evidence that impacts related to health risks or GHGs would occur. As <br />detailed in previous responses, the Community Plan Exemption Checklist details that pursuant to <br />agency recommendations and the City's GPU EIR, impacts related to health risks and GHG <br />emissions would be less than significant, and no new impact would occur. <br />Comment 11: This comment is consistent with Comment 5, previously. <br />Response 11: Refer to Response 5. <br />Comment 12: This comment provides the details of the screening -level HRA and the <br />AERSCREEN modeling, such as exposure assumptions, risk formulas, described in Comment 6. <br />The comment states that it provides downwind at 200 meters the Project would result in risks <br />exceed the SCAQMD threshold; and thus, is a potentially significant impact and a refined health <br />risk analysis is required. <br />Response 12: As detailed in Response 6, the AERSCREEN model is widely acknowledged as <br />being overly conservative and produces worst -case scenario health risk impacts, without <br />considering appropriate dispersion and other factors. Therefore, the air quality model used by the <br />commenter does not accurately identify risks of the Project and is not consistent with SCAQMD, <br />CARB, and OEHHA recommended methodology. Further, the Project is less than significant as <br />less than 50 percent of 100 truck trips per day would occur and residences are located <br />approximately 2,200 feet from the Project, which is farther than the 1,000-foot setback <br />recommended by the SCAQMD. <br />Exhibit 13 <br />Page 5 of 7 <br />