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Santa Ana — Garden Grove Fixed Guideway Project <br />Findings and Facts in Support of Findings and Statement of Overriding Considerations <br />Findings for Mitigation Measures <br />Mitigation Measures for the proposed project have been identified in the Mitigation Monitoring <br />and Reporting Program. None of the recommended measures that are within the City of Santa <br />Ana jurisdiction have been rejected. To the extent that these findings conclude that various <br />proposed Mitigation Measures outlined in the Mitigation Monitoring and Reporting Program are <br />feasible and have not been modified, superseded or withdrawn, the City of Santa Ana hereby <br />binds itself to implement or, as appropriate, require implementation of these measures. These <br />findings, in other words, are not merely informational, but rather constitute a binding set of <br />obligations that will come into effect when the City of Santa Ana adopts a resolution approving <br />the proposed project. <br />Environmentally Superior Alternative <br />Section 15126.6(e)(2) of the CEQA Guidelines requires that an environmentally superior <br />alternative be identified among the selected alternatives. If the No Build Alternative is identified <br />as the environmentally superior alternative, the identification of the next best environmentally <br />superior alternative must be identified. As described in the EA/DEIR and the REA/FEIR, the No <br />Build Alternative has been found to have the least amount of environmental impacts and is the <br />environmentally superior alternative. Of the remaining alternatives, the TSM Alternative is the <br />CEQA environmentally superior alternative because no impacts were identified in the EA /DEIR. <br />However, the City hereby finds that the TSM alternative would not achieve the project's basic <br />objectives and thereby rejects this alternative. <br />9. STATEMENT OF OVERRIDING CONSIDERATIONS <br />The REA/FEIR has identified and discussed significant environmental effects that will occur as a <br />result of implementation of the proposed project. With implementation of feasible mitigation <br />measures, standard conditions, and /or BMPs, as discussed in the REA/FEIR, these effects can <br />be mitigated to levels considered less than significant except for the significant impacts related <br />to regional construction emissions and localized construction emissions, as described above in <br />Section 6 of this document. Specifically, implementation of the proposed project would result in <br />the following significant impacts even after imposition of all feasible mitigation measures, <br />standard conditions, and /or BMPs and would require adoption of a Statement of Overriding <br />Considerations: <br />• Construction emissions associated with the proposed project would result in exceedance of <br />the SCAQMD's NOx threshold for construction activities for the years 2012 and 2013 and, <br />as such, would result in a significant regional air quality impact. Implementation of <br />Mitigation Measure AQ1 would reduce NOx emissions, although emissions would still <br />exceed the SCAQMD significance threshold. <br />• Construction emissions of PM1e were found to exceed the SCAQMD's Localized <br />Significance Thresholds and would, therefore, result in a local air quality impact to sensitive <br />receptors in the vicinity of the O & M Facility. The proposed project is subjected to <br />SCAQMD Rule 403 (Fugitive Dust), which requires that dust control measures (i.e., <br />watering, offsite dirt trackout, and haul truck freeboard clearance) be applied to minimize the <br />generation of fugitive dust during construction activities. Despite the application of these <br />36 January 2015 <br />