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

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provided guidance for analyzing mobile source diesel emissions.41 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. In addition, the CARB-mandated airborne toxic control measures (ATCM) limits 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. The Project would generate long-term emissions on -site from area and energy sources that would generate negligible pollutant concentrations of CO, NO2, PM2.5, or PM10 at nearby sensitive receptors. 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 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 2027.42 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 peak A.M. and P.M. hours, respectively.43 This would represent a reduction in peak hour traffic, which would benefit arterials like Fourth Street between Tustin Avenue and Cabrillo Park Drive, which carry 23,828 vehicles during a weekday.aa This would help reduce any potential that traffic volumes would generate CO exceedances of the ambient air quality standard.45 Finally, the Project would not result in any substantial emissions of TACs during the construction or operations phase. During the construction phase, the primary air quality impacts would be associated with the combustion of diesel fuels, which produce exhaust -related particulate matter that is considered 41 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. 42 Linscott Law & Greenspan, Memorandum: Vehicle Miles Traveled Assessment for the Proposed Cabrillo Town Center Mixed -Use Project; June 27, 2023. 43 Ibid. 44 City of Santa. Ana GIS Open Data portal, accessed July 26, 2023. 2015 traffic counts adjusted by a one percent adjustment to reflect ambient traffic growth. https://gis-santa- ana.opendata.arcgis.com/datasets/927fOb948fcf4OOeafl c13d35239a7b1 /explore?location =33.749256%2C- 117.838786%2C17.62 45 South Coast Air Quality Management District; 2003 AQMP. As discussed in the 2003 AQMP, the 1992 CO Plan included a CO hotspot analysis at four intersections in the peak A.M. and P.M. time periods, including Long Beach Boulevard and Imperial Highway (Lynwood), Wilshire Boulevard and Veteran Avenue (Westwood), Sunset Boulevard and Highland Avenue (Hollywood), and La Cienega Boulevard and Century Boulevard (Inglewood). The busiest intersection was Wilshire and Veteran, used by 100,000 vehicles per day. The 2003 AQMP estimated a 4.6 ppm one -hour concentration at this intersection, which meant that an exceedance (20 ppm) would not occur until daily traffic exceeded more than 400,000 vehicles per day. Cabrillo Town Center Project PAGE 32 City of Santa Ana Air Quality 1vtour C 18 — 678 10/3/20233U1y2o2s