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Santa Ana General Plan Update <br />CEQA Findings of Fact and Statement <br />Of Overriding Considerations -41- October 2021 <br />technological, or other benefits, including regionwide or statewide environmental benefits, of the <br />GPU outweigh its significant effects on the environment. <br />Impact 5.2-3: Implementation of the General Plan Update would generate long-term <br />emissions in exceedance of South Coast AQMD’s threshold criteria. <br />Support for this environmental impact conclusion is fully discussed in Section 5.2, Air Quality, <br />starting on page 5.2-48 of the Updated Draft PEIR. <br />Buildout in accordance with the GPU would generate long-term emissions that would exceed <br />South Coast AQMD’s regional significance thresholds and cumulatively contribute to the <br />nonattainment designations of the SoCAB. Mitigation Measure AQ-2, in addition to the goals and <br />policies of the GPU, would reduce air pollutant emissions to the extent feasible. The measures <br />and policies covering topics such as expansion of the pedestrian and bicycle networks, promotion <br />of public and active transit, and support to increase building energy efficiency and energy <br />conservation would also reduce criteria air pollutants in the city. Further, compared to existing <br />baseline year conditions, emissions of NOx, CO, and SOx are projected to decrease from current <br />levels despite growth associated with the GPU. <br />However, Impact 5.2-3 would remain significant and unavoidable due to the magnitude of the <br />overall land use development associated with the GPU. Contributing to the nonattainment status <br />would also contribute to elevating health effects associated with these criteria air pollutants. <br />Reducing emissions would further contribute to reducing possible health effects related to criteria <br />air pollutants. <br />It is speculative for this broad-based GPU to determine how exceeding the regional thresholds <br />would affect the number of days the region is in nonattainment, since mass emissions are not <br />correlated with concentrations of emissions, or how many additional individuals in the air basin <br />would suffer health effects. South Coast AQMD is the primary agency responsible for ensuring <br />the health and welfare of sensitive individuals to elevated concentrations of air quality in the <br />SoCAB, and at the present time it has not provided methodology to assess the specific correlation <br />between mass emissions generated and the effect on health in order to address the issue raised <br />in the Friant Ranch case. <br />Ozone concentrations are dependent upon a variety of complex factors, including the presence <br />of sunlight and precursor pollutants, natural topography, nearby structures that cause building <br />downwash, atmospheric stability, and wind patterns. Because of the complexities of predicting <br />ground-level ozone concentrations in relation to the National and California Ambient Air Quality <br />Standards, it is not possible to link health risks to the magnitude of emissions exceeding the <br />significance thresholds. To achieve the health-based standards established by the EPA, the air <br />districts prepare air quality management plans that detail regional programs to attain the ambient <br />air quality standards. However, because cumulative development within the city would exceed <br />the regional significance thresholds, the proposed project could contribute to an increase in health <br />effects in the basin until the attainment standards are met in the SoCAB.