Item 26 - EIR No. 2020-03 and GPA No.2020-06 Santa Ana General Plan Update

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