Item 18 - Appeal Application Nos. 2023-02 and 2023-03 for Cabrillo Town Center project

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Operation of the Overlay Zone would generate emissions that exceed the thresholds of significance recommended by the SCAQMD for VOC, NO, CO, and particulate matter 10 (PM,o). The exceedance of the SCAQMD thresholds for these four criteria pollutants is primarily due to the increase in motor vehicles traveling to and from the project site. As no feasible mitigation is available to reduce these emissions, this impact was determined to be significant and unavoidable. Expose Sensitive Receptors The Certified EIR stated that as was done to assess existing carbon monoxide (CO) concentrations, the simplified CALINE4 screening procedure was used to predict future CO concentrations. CO concentrations were calculated 20 intersections evaluated in the traffic report (included in its entirety as Appendix H to the Draft EIR portion of the Certified EIR) that is expected to operate at LOS E or F (unacceptable levels) at project buildout. Intersections operating at LOS E or F typically generate high CO concentrations that could exceed the federal or state 1-hour and 8-hour standards and are analyzed at project buildout to show the maximum effect of implementation of the Overlay Zone on ambient CO concentrations. Future CO concentrations near these intersections would not exceed the national 35.0 ppm and state 20.0 ppm 1-hour ambient air quality standards or the national or state 9.0 ppm 8-hour ambient air quality standards when the Overlay Zone is fully implemented in 2030. Therefore, sensitive receptors located in close proximity to these intersections would not be exposed to substantial pollutant concentrations, and the potential impacts of the Overlay Zone were determined to be less than significant. No mitigation is required. It should be noted that projected CO concentrations shown in the Certified EIR are lower than the baseline CO concentrations due to anticipated improvements in vehicle emission rates projected for the future by the California Air Resources Board (CARB). Odors The Certified EIR stated that construction activities do not usually emit offensive odors. Although construction activities occurring in association with the Overlay Zone could generate airborne odors associated with the operation of construction vehicles (i.e., diesel exhaust) and the application of interior and exterior architectural coatings, these emissions would only occur during daytime hours, would generally be restricted to the immediate vicinity of the construction site and activity, and would not affect a substantial number of people. Potential operational airborne odors could result from cooking activities associated with the new residential units and restaurants. These odors would be similar to existing residential and restaurant uses in the vicinity and would be confined to the immediate vicinity of the Overlay Zone. Restaurants are also typically required to have ventilation systems that avoid substantial adverse odor impacts. The other potential source of odors would be new trash receptacles within the Overlay Zone. Implementation of Mitigation Measure MM-OZ 4.2-1 would ensure the Overlay Zone would not create substantial objectionable odors, and this impact was determined to be less than significant. Cabrillo Town Center City of Santa Ana Technical Memorandum August 2023 City Council 18 — 505 10/3/2023