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

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localized standards for receptors that are within 25 meters of the Project's construction activities. Additionally, the Project would be required to implement applicable mitigation measures from the Certified EIR that would further reduce the Project's emission, which would not exceed SCAQMD's thresholds. Therefore, based on SCAQMD guidance, localized emissions of criteria pollutants would not have the potential to expose sensitive receptors to substantial concentrations that would present a public health concern. The primary toxic air contaminant TAC that would be generated by construction activities is diesel particulate matter (PM), which would be released from the exhaust stacks of construction equipment. The construction emissions modeling conservatively assumed that all equipment present on the Project Site would be operating simultaneously throughout most of the day, while in all likelihood this would rarely be the case. Average daily emissions of diesel PM would be less than one pound per day throughout the course of Project construction. Therefore, the magnitude of daily diesel PM emissions, would not be sufficient to result in substantial pollutant concentrations at off -site locations nearby. Furthermore, according to SCAQMD methodology, health risks from carcinogenic air toxics are usually described in terms of individual cancer risk. "Individual Cancer Risk" is the likelihood that a person exposed to concentrations of TACs over a 30-year period will contract cancer based on the use of standard risk -assessment methodology. The entire duration of construction activities associated with implementation of the Project is anticipated to be approximately 36 months, and the magnitude of daily diesel PM emissions will vary over this time period. No residual emissions and corresponding individual cancer risk are anticipated after construction. Because there is such a short- term exposure period, construction TAC emissions would result in a less than significant impact. Thus, construction of the Project would not expose sensitive receptors to substantial diesel PM concentrations. Therefore, no new or increased significant impacts would occur beyond the air quality impacts already identified in the Certified EIR. Operational Emissions The Project Site would be redeveloped with multi -family residences, retail, and office uses, land uses that are not typically associated with TAC emissions. Typical sources of acutely and chronically hazardous TACs include industrial manufacturing processes (e.g., chrome plating, electrical manufacturing, petroleum refinery). The Project would not include these types of potential industrial manufacturing process sources. It is expected that quantities of hazardous TACs generated on -site (e.g., cleaning solvents, paints, landscape pesticides) for the types of proposed land uses would be below thresholds warranting further study under California Accidental Release Program. When considering potential air quality impacts under CEQA, consideration is given to the location of sensitive receptors within close proximity of land uses that emit TACs. CARB has published and adopted the Air Quality and Land Use Handbook: A Community Health Perspective, which provides recommendations regarding the siting of new sensitive land uses near potential sources of air toxic emissions (e.g., freeways, distribution centers, rail yards, ports, refineries, chrome plating facilities, dry cleaners, and gasoline dispensing facilities). The SCAQMD adopted similar recommendations in its Guidance Document for Addressing Air Quality Issues in General Plans Cabrillo Town Center City of Santa Ana Technical Memorandum August 2023 City Council 18 — 514 10/3/2023