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Santa Ana General Plan Update <br />CEQA Findings of Fact and Statement <br />Of Overriding Considerations -37- October 2021 <br />B. SIGNIFICANT UNAVOIDABLE ADVERSE IMPACTS <br />The following summary describes the unavoidable adverse impact of the GPU where mitigation <br />measures were found to be either infeasible or would not lessen impacts to less than significant. <br />The following impacts would remain significant and unavoidable. <br />1. Air Quality <br />Impact 5.2-1: The additional population growth forecast for the General Plan Update and <br />the associated emissions would not be consistent with the assumptions of <br />the air quality management plan. <br />Support for this environmental impact conclusion is fully discussed in Section 5.2, Air Quality, <br />starting on page 5.2-45 of the Updated Draft PEIR. <br />The GPU would be inconsistent with the South Coast Air Quality Management Plan (AQMP) <br />because buildout under the GPU would exceed the population estimates assumed for the AQMP <br />and would cumulatively contribute to the nonattainment designations of the South Coast Air Basin <br />(SoCAB). Buildout of the GPU would exceed current population estimates for the city, and <br />therefore the emissions associated with the additional population are not included in the current <br />regional emissions inventory for the SoCAB. Additionally, air pollutant emissions associated with <br />buildout of the GPU would cumulatively contribute to the nonattainment designations in the <br />SoCAB. Therefore, overall, the GPU would be inconsistent with the AQMP. <br />Incorporation of Mitigation Measure AQ-2 into future development projects for the operation phase <br />would contribute to reduced criteria air pollutant emissions associated with buildout of the GPU. <br />Additionally, goals and policies in the GPU would promote increased capacity for alternative <br />transportation modes and implementation of transportation demand management strategies. <br />However, due to the magnitude and scale of the land uses that would be developed, no mitigation <br />measures are available that would reduce operation and construction impacts below South Coast <br />AQMD thresholds. In addition, the population and employment assumptions of the AQMP would <br />continue to be exceeded until the AQMP is revised and incorporates the projections of the GPU. <br />Therefore, Impact 5.2-1 would remain significant and unavoidable. <br />Mitigation Measure <br />AQ-2 Prior to discretionary approval by the City of Santa Ana for development projects <br />subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt <br />projects), project applicants shall prepare and submit a technical assessment <br />evaluating potential project operation phase-related air quality impacts to the City of <br />Santa Ana for review and approval. The evaluation shall be prepared in conformance <br />with South Coast Air Quality Management District (South Coast AQMD) methodology <br />in assessing air quality impacts. If operation-related air pollutants are determined to <br />have the potential to exceed the South Coast AQMD’s adopted thresholds of <br />significance, the City of Santa Ana shall require that applicants for new development