3.0 Responses to Comments
the RP-DEIR on May 31st, 2012. As part of the RP-DEIR, Mitigation Measure Air Quality 12 was added to reduce localized construction impacts to the extent feasible. See Section 2.A-III of the RP-DEIR for the revised analysis of localized construction air quality impacts. The comment also notes that the Original DEIR did not quantify peak daily emissions from site specific projects and that the SCAQMD’s thresholds for such emissions should be applied in making a significance determination regarding such emissions. The EIR is a programmatic document and there are no specific development projects proposed at this time, so the quantification of peak daily construction emissions from site specific projects would be remote and speculative. However, air quality analysis related to regional construction emissions has been revised and recirculated in the RP-DEIR on May 31st, 2012. Table 2.A-1 was included as part of the revised analysis, which discloses peak construction emissions from construction activities, as computed using CalEEMod. Cirteria air pollutant peak daily emission values were compared to SCAQMD’s regional mass based emissions thresholds. The analysis concluded that peak emissions levels of Reactive organic gases (ROG), Oxides of Nitrogen (NOx), Carbon Monoxide, and PM10 would exceed the SCAQMD thresholds and amount to a significant and unavoidable impact after the incorporation of feasible mitigation measures. See Section 2.A-II of the RP-DEIR for the revised regional construction air quality analysis. 2-8
The comment is noted on the need to quantify daily construction emissions from the proposed Alternative, apply the SCAQMD’s localized significant thresholds and incorporate mitigation measures. See Response to Comment 2-7 related to revised regional construction air quality analysis and the application of localized significant thresholds. Also, see Section 2.A-II of the RP-DEIR for the revised regional construction air quality analysis and Section 2.A-III of the RP-DEIR for the revised analysis of localized construction air quality impacts. The comment requests that new projects located in the Project Area shall conduct a localized construction emission analysis and mitigate to below the level of significance. As stated on Page 2.A-27 of Section 2.A-III of the RP-DEIR, the Specific Plan is a regulatory document and does not establish a specific sequence under which specific project developments will be constructed. Therefore, there is no reasonable means to determine if an impact of one project in the Project Area will result in a significant localized construction air quality impact to an existing or future sensitive receptor. In the preface of the SCAQMD’s Final LST Methodology (SCAQMD, 2008), the report authors state that “the LST methodology was developed to be used as a tool to assist lead agencies to analyze localized impacts associated with project-specific level proposed projects... and are not applicable regional projects such as General Plans.” In addition, Section 15145 of the CEQA Guidelines states that if a lead agency finds that a particular impact is too speculative for evaluation, the agency should note its conclusion and terminate discussion of the impact. Due to the magnitude of potential emissions from all cumulative construction activities, and the addition of sensitive receptors beyond those existing in the Project Area, it is reasonable to assume that construction air quality emission impacts for projects permitted Cornfield Arroyo Seco Specific Plan FEIR
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