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emissions generated for each project would vary depending on its size, the land area that would <br />need to be disturbed during construction, and the length of the construction schedule. Under these <br />conditions, no further feasible mitigation measures are available and this impact would be <br />considered significant and unavoidable. The City will make site -specific determinations of <br />significance during the review of these individual development projects to determine which <br />projects for which construction emissions may exceed significance thresholds. <br />For the purpose of analysis in this EIR, a programmatic level of analysis is provided for the <br />proposed development under the Overlay Zone. The Overlay Zone would develop 5,400 <br />residential units, a total of 1.1 million square feet of commercial space, and 1.7 million square feet <br />of office uses by the year 2030. As the Overlay Zone has the potential to exceed SCAQMD's <br />recommended thresholds of significance and results in short-term air quality impacts, the impact <br />of the Overlay Zone is anticipated to be significant. Mitigation Measures MM-OZ 4.2-2 through <br />MM-OZ 4.2-13 shall be implemented where appropriate. <br />In addition, emission levels of VOCs, which are a precursor for ozone, would likely exceed <br />SCAQMD significance thresholds during the application of architectural coatings (paint and <br />primer) for the Overlay Zone. In order to reduce the VOC emissions levels associated with <br />architectural coatings, Mitigation Measures MM-OZ 4.2-14 through MM-OZ 4.2-16. <br />However, because construction emissions for an individual project typically exceed the <br />SCAQMD's recommended thresholds of significance and results in short-term air quality impacts, <br />the impact of the Overlay Zone, which takes into consideration the construction emissions <br />generated from all of the development proposed under the Overlay Zone, were determined to be <br />significant and unavoidable. <br />Operation <br />The Certified EIR stated that operational emissions generated by both stationary and mobile <br />sources would result from normal day-to-day activities on the project site after occupation. <br />Stationary, area source emissions would be generated by the consumption of natural gas for <br />space and water heating devices, and the operation of landscape maintenance equipment. Mobile <br />emissions would be generated by the motor vehicles traveling to and from the Overlay Zone. <br />The analysis of daily operational emissions from the Overlay Zone has been prepared utilizing <br />the URBEMIS 2002 computer model recommended by the SCAQMD. In terms of operational <br />emissions, the Overlay Zone would incorporate certain features in its design that would help <br />reduce the operational emissions that would otherwise be generated by the Overlay Zone. These <br />design features include the following: <br />• Street lighting to provide safety along pedestrian routes <br />• Shade trees to shade sidewalks to encourage use by pedestrians <br />The Overlay Zone's design features would encourage pedestrian activity, which would reduce the <br />emissions from the operation of motor vehicles by project employees and residents. <br />Cabrillo Town Center City of Santa Ana <br />Technical Memorandum August 2023 <br />City Council 18 — 504 10/3/2023 <br />