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

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and Local Planning. Together, the CARB and SCAQMD guidelines recommend siting distances for both the development of sensitive land uses in proximity to TAC sources and the addition of new TAC sources in proximity to existing sensitive land uses. The primary sources of potential air toxics associated with Project operations include diesel PM from delivery trucks (e.g., truck traffic on local streets and idling on adjacent streets) and to a lesser extent, facility operations (e.g., natural gas -fired boilers). However, these activities and the land uses associated with the Project, are not considered land uses that generate substantial TAC emissions. It should be noted that the SCAQMD recommends that health risk assessments (HRAs) be conducted for substantial individual sources of diesel PM (e.g., truck stops and warehouse distribution facilities that generate more than 100 trucks per day or more than 40 trucks with operating transport refrigeration units) and has provided guidance for analyzing mobile source diesel emissions.4 Based on this guidance, the Project would not include these types of land uses and is not considered to be a substantial source of DPM warranting a refined HRA since daily truck trips to the Project Site would not exceed 100 trucks per day or more than 40 trucks with operating transport refrigeration units. Further, Mitigation Measure MM-OZ 4.6-1 of the Certified EIR requires that an HRA for diesel exhaust be prepared for future residential uses that are developed within the Overlay Zone and within 500 feet of an existing freeway. However, the Project Site is more than 500 feet from the nearest freeway, and as such, Mitigation Measure MM-OZ 4.6-1 does not apply to the Project. In addition, the CARB-mandated airborne toxic control measures (ATCM) limit diesel -fueled commercial vehicles (delivery trucks) to idle for no more than five minutes at any given time, which would further limit diesel particulate emissions. As the Project would not contain substantial TAC sources and is consistent with the CARB and SCAQMD guidelines, the Project would not result in the exposure of off -site sensitive receptors to carcinogenic or toxic air contaminants that exceed the maximum incremental cancer risk of 10 in one million or an acute or chronic hazard index of 1.0, and potential TAC impacts would be less than significant. While long-term operations of the Project would add traffic to local roads that produces off -site emissions, these would not result in exceedances of CO air quality standards at roadways in the area due to three key factors. First, CO hotspots are extremely rare and only occur in the presence of unusual atmospheric conditions and extremely cold conditions, neither of which applies to this Project Site area. Second, auto -related emissions of CO continue to decline because of advances in fuel combustion technology in the vehicle fleet. Finally, the Project would not contribute to the levels of congestion that would be needed to produce emissions concentrations needed to trigger a CO hotspot, as it would add 875 vehicle trips to the local roadway network on weekdays when the development could be leased and operational in 2027.5 However, peak hour vehicle travel would generally reduce from existing conditions, as traffic to and from Project Site would reduce by 50 trips and zero trips during the A.M. and P.M. peak hours, respectively.6 This would represent 4 South Coast Air Quality Management District, Health Risk Assessment Guidance for Analyzing Cancer Risks from Mobile Source Diesel Idling Emissions for CEQA Air Quality Analysis, 2002. Linscott Law & Greenspan, Memorandum: Vehicle Miles Traveled Assessment for the Proposed Cabrillo Town Center Mixed -Use Project; June 27, 2023. 6 Ibid. Cabrillo Town Center City of Santa Ana Technical Memorandum August 2023 City Council 18 — 515 10/3/2023