DATE: August 25, 2023
TO: Rafael Cobian, City of Anaheim
FROM: Jose Alire/Robert Vu, Urban Crossroads
JOB NO: 14736-13 Response
SCHOLARSHIP PREP SCHOOL (DEV2021-00218) RESPONSE TO THE APPEAL OF THE PLANNING COMMISSION’S DECISION
Urban Crossroads, Inc. is pleased to submit the following Response to the Appeal of the Planning Commission’s Decision received by the City Clerk for the proposed Scholarship Prep School development ( Project), which is located at 2780 E.
Wagner Avenue in the City of Anaheim . Urban Crossroads prepared the Scholarship Prep Schools (DEV2021-00218) Vehicle Miles Traveled (VMT) Screening Evaluation (dated November 8, 2022) and Scholarship Prep School Traffic Impact Analysis (dated May 22, 2023). The VMT and traffic impact analysis reports were revised to respond to the C ity’s traffic consultant, Kimley Horn , Peer Review comments dated May 28, 2021 , October 6, 2022 and October 10, 2022. As such, only comments related to the VMT and traffic impact analysis have been responded to. A copy of the Appeal letter dated July 24 , 2023, is provided in Attachment A.
COMMENT #1
Increased air pollution: This project will unnecessarily increase resident exposure to air pollution. The vehicles needed to collect and transport 480 children to and from school will intensify pollution hotspots in and around school premises, especially as vehicles idle in the drop -off and pick -up queue every morning and afternoon. Paired with the air pollution from the adjacent 57 freeway, this project will only compound resident exposure to fi ne particulate matter and impact the health of vulnerable populations in our neighborhood, including those with asthma and respiratory diseases.
RESPONSE #1
The California Air Pollution Control Officers Association ( CAPCOA) Handbook for Analyzing Greenhouse Gas Emission Reductions Assessing Climate Vulnerabilities and Advancing Health and Equity (dated December 2021) states that the greenhouse gas ( GHG) emissions are proportional to the emissions source. For the proposed Project, the main emission source would be vehicles traveling to and from the Project site or vehicle miles traveled ( VMT). The VMT analysis has been prepared in accordance with the City of Anaheim TIA Guidelines for CEQA (June 2020) (City Guidelines). As stated in the City Guidelines, local‐serving K‐12 schools can be screened from project ‐level assessment as they are presumed to have a less than significant impact due to their local serving nature.