Page 6 - northlake_appeal_20180423

Jodie Sackett, County of Los Angeles
June 16, 2017
Page 4

At 5.1-13, under "Relevant Regulations" as to the South Coast Air Quality Management District
("SCAQMD"), your discussion of the 2012 and 2016 Air Quality Management Plans
("AQMPs") is misleading in that it does not reference EPA's disapproval of them based on the
RECLAIM program's failure to meet RACM/RACT, which relates to both PM2.s and NOx.

Threshold 5.1-1: Would the Project conflict with or obstruct implementation of an applicable
AQMP? Per the SCAQMD CEQA Handbook (1993), the questions you are required to address
here are (1) whether the Project would cause an increase in the frequency or severity of existing
violations, cause or contribute to new violations, or delay timely attainment of an ambient air
quality standard, and (2) whether the Project would exceed the assumptions in an AQMP. Under
the Handbook, if you answer either one of these questions in the affirmative, there is a significant
impact. See Handbook,§ 12.3. Therefore, you should make a finding of significance as to this
threshold.

Threshold 5.1-2: Would the Project violate an air quality standard or contribute substantially to
an existing or projected air quality violation? We first of all question, with respect to
construction, your assumption that you would only conduct 1,000 hauling trips in clearing and
grading a 1,330-acre site. You concede that you will have NOx emissions in excess of
SCAQMD thresholds for 2018, 2019 and 2020 even with your mitigation measure for the use of
1
Tier 3 equipment. You claim that emissions of PM10 and PM2.s from blasting will not occur for
more than 114 acre per day and at 8 lbs per 114 acre, you will not exceed SCAQMD thresholds.
There is no mitigation measure limiting the applicant from blasting more than 114 acre per day so
this simply provides no substantial evidence to support your conclusion.

With respect to your LST analysis, you did not use the LST lookup tables which means you
probably exceeded the thresholds in those tables, a fact that the public should have been advised
of. As it is, with your modeling Project plus ambient N02 would exceed federal standards.
Also, you assert that PM10 and PM2.s LSTs would not be exceeded, but there is no indication that
you included blasting in your analysis.

MM 5.1-6 prohibits mass grading within 1600 feet of Northlake Hills Elementary School "when
school is not in session," which makes no sense: the prohibition should be on grading when
school is in session. Moreover, the MM only requires this "to the maximum extent feasible,"
which provides absolutely no assurances and is not substantial evidence supporting a conclusion
of no significant impact.

And MM 5.7-22 provides that the "master developer" is to establish a "Transportation
Management Association" which is to establish a rideshare program for employees of on-site
commercial and industrial businesses as well as a commuter bus program to extend existing bus

Your mitigation measure ("MM") actually calls for the use of Tier 4 equipment "where
available," which is hopelessly vague and unenforceable and it was thus appropriate for you to
have evaluated impacts as if Tier 3 equipment would be used.