80A - SUPPLEMENTAL - SANTA ANA TRANSITZONINGCODE POST- RESPONSE TO COMMENTS - FEIR

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Chapter 12 Responses to Comments Received Since Publication of the Final EIR Response to Letter AQMD: South Coast Air Quality Management District (AQMD) Response to Comment AQMD -1 This comment contains introductory language as well as a request to be included on future CEQA document distribution lists. Though the City's records indicate that a copy of the Draft EIR was mailed to the AQMD, the comment is noted and the City will ensure that all future CEQA projects include distribution to AQMD. Response to Comment AQMD -2 The commenter is concerned about future residential uses being sited in proximity to industrial uses and Interstate 5, and the impacts to future sensitive receptors caused thereby. The commenter also suggests that the City examine the California ARB Handbook for guidance on the siting of potential sensitive receptors near sources of high pollutant emissions. According to the California ARB Handbook, sensitive receptors should be located at least 300 feet from Interstate 5 as well as dry cleaners using Perchloroethylene. The Handbook also states that residential uses should not occupy the same building as dry cleaners using said chemical. In addition, other examples cited by the commenter such as auto - body paint shops and other manufacturing operations (as shown in Table 1 -3 of the Handbook) are required to obtain a permit from the AQMD, which carries with it certain requirements relating to production methodologies. It should be noted that, with the exception of the Developer Project (described in Chapter 3 of the DEIR), the Transit Zoning Code EIR is a programmatic document, and future projects that could occur within the planning area are unknown and speculative at this time. Therefore, future projects would be subject to City plan review and, depending on their nature, subject to subsequent CEQA review. The City's Municipal Code sets forth specific land use compatibility requirements for industrial and sensitive receptors. In urbanized infill projects (especially those that utilize transit - oriented development), it is often infeasible to site projects more than 300 feet from high -traffic freeways and may (in some cases) minimize the project's benefit as a reducer of automobile trips. As a result, mitigation measures may be required for projects such as these that could require the use of American Society of Heating, Refrigerating, and Air Conditioning Engineers (ASHRAE) Standard 170-2008—Ventilation of Health Care Facilities (as a worst -case example of standards) for intake systems as well as compliance with the standards for "Protective Environment" under the aforementioned Standard, which requires a dual - phase filtration intake systems with efficiency ratings classified by the MERV standards for filtration'. Finally, mitigation measure MM4.2 -21 requires that subsequent projects within the Transit Zoning Code complete site - specific air quality analyses to determine their impacts and provide mitigation (if necessary) that reduces impacts associated with said projects. 1 American Society of Heating, Refrigerating, and Air Conditioning Engineers, Standard 170 -2008 Ventilation of Health Care Failzties, 2008. City of Santa Ana Transit Zoning Code (SD 84A and SD 84B) EIR 12 -7