The question here really is one of time. For the staff in the Chino Hills Planning Department, in their response to public comment on the DEIR, this was simply a matter of mitigation through disallowing grading of the property on days where the pollution index was high and then calling for a Statement of Overriding Considerations (SOC) to justify the project because "grading is short-term." In other words, it's OK if this project emits more pollution than lax thresholds call for, because it would all be over in a matter of months.
What the consultant hired by the city identified in the EIR was that emission of particulate matter and nitrous oxides during the grading process would be 40% over thresholds established by the South Coast Air Quality Management District (SCAQMD).
The response was to establish mitigation by stopping grading during high-index days and five other measures: 1) having diesel oxidation catalysts on vehicles to reduce pollution by 15%; 2) proper maintenance of vehicles subject to AQMD inspection (provided these inspections will actually take place regularly during the grading process); 3) turning vehicles off when not in use; 4) using electrical rather than diesel hookups for power tools; and 5) a traffic control plan for safe detour.
Taking all of these into account and, assuming that these proposed mitigations are actually feasible and monitored, the reduction in emissions would still be 12-15% over thresholds that are actually lower than they should be, given that we live in the most polluted region in the United States and have for decades and decades. Whatever advances have been made in our pollution situation, and there were periods of significant improvement, it still hasn't been enough.
A sidenote: when a certain Sleepy Hollow-based commentor noted that AQMD's "thresholds" were too low, staff decided to respond that "the reference to 'standards' is not entirely accurate . . . the ambient air quality standards are concentration based, and the thresholds are project-specific emission based."
No, they were only accurate! Why it was deemed necessary to include that statement, which did nothing to counter or correct (except to make a point in the name of semantical purity!) a substantive issue is more than a little mystifying.
However, when the main mitigation measure concerns a prohibition of grading for that day and we can assume that there will be rigorous observances of that prohibition by the grading contractor and city inspectors, note that "this will likely prevent an exceedance of an ambient air quality standard and therefore prevent health effects." Actually, wouldn't it simply prevent? Why would it be "likely"?
It was also interesting that staff stated that "reductions afforded by mitigation measure AQ-6 [grading prohibitions on high pollution days] were not included in the migitated construction emissions table because the table displays emissions, whereas mitigation measure AQ-6 deals with the concentration of pollutants. Mitigation measures AQ-1 through AQ-5 [see above] also reduce emissions during construction."
Yet, how will there be guarantees that diesel oxidation catalysts will be on grading vehicles, and that vehicles will be properly maintained according to AQMD inspection and, especially, that vehicles will be turned off when not in use, and that there will be electrical, not diesel, hookups for power tools and, finally, just what will be the traffic control plan for "safe detour"?
There is only one way into and out of the proposed development: from Carbon Canyon Road, a two-line state highway already operating at E or F levels of traffic during peak commuter hours. Will the vehicles be parked on site during off hours? Fine, but there still has to be 700,000 cubic yards of "remedial grading" (a cubic yard, by the way, is 202 gallons) around the site and, presumably, a significant amount taken to and from the location on this two-lane road.
This goes back, again, to the question of time. Because it is short-term and because grading will supposedly be terminated on high pollution days, "the project is implementing feasible measures to reduce potential impacts during grading activities." Still, the pollutant concentration is over thresholds that are already inadequate.
Whether it is short term, be it three months or six months or whatever length of time it is, there is too much pollution emitted in a region still saddled with the worst air quality in the country.
Like the traffic argument, in which the developer says that their contribution to the overburdened traffic on Carbon Canyon Road is only 1.5% of the total, therefore the project does not contribute any significance to the overall traffic problem, this pollution rebuttal insinuates that the short-term nature of grading-emitting pollutants is a minor irritant (literally and figuratively) that is minor in the grand scheme of things. And, that it should be casually brushed aside via the ever-convenient "Statement of Overriding Considerations" which, once again, don't really provide Canyon-specific benefits, but those that are truly ephemeral and vaguely identifiable to the city as a whole, such as needed luxury housing and the contribution to two traffic signals that won't serve the development and likely won't even be installed for several years to come (and certainly will not help commuter times on Carbon Canyon Road!)
As has been said plenty of times already, Carbon Canyon is a unique place within Chino Hills and even 28 homes among the potential of nearly 450 that could someday be built within the Brea and Chino Hills portions of the Canyon is a major contribution to its degradation.
To pretend that destroying irreplaceable scenic and open space areas in the Canyon can be mitigated by benefits that have nothing to do with the Canyon is bad public policy.
Just as pretending that emissions at 12-15% over already low thresholds is an adequate mitigation is bad public policy.
We need to reduce pollution significantly for the benefit of the health of our citizens (pollution, by the way, being a major contributor to high asthma and other lung-related problems that raise health care costs and boost insurance premiums--issues that happen to be on the front burner at the moment.)
Anything that increases it, short-term or not, is bad public policy.
No comments:
Post a Comment