November 15, 2024
Mayor Alice Patino and City Councilmembers Sent via Email: [email protected] City of Santa Maria
Attn: City Clerk’s Office
110 E. Cook Street
Santa Maria, CA 93454
Re: Santa Barbara County Air Pollution Control District Concerns Regarding the Final Environmental Impact Report for the Richards Ranch Annexation Project (AN2021-0001)
Dear Mayor Patino and City Councilmembers:
As a responsible and commenting agency under the California Environmental Quality Act (CEQA), the Santa Barbara County Air Pollution Control District (District) reviews CEQA documents to ensure that a project’s air quality impacts are accurately identified and analyzed, and that mitigation is applied to reduce the severity of any significant impacts.
The District has concerns that the Final Environmental Impact Report (EIR) for the Richards Ranch Annexation Project may not adequately disclose, assess, and mitigate impacts to air quality from the future buildout of the project site, and as such, the CEQA document may not fulfill its purpose to inform the public agency, decision makers and general public of the potential environmental impacts of future development of the site.
Specifically, based on the District’s review of the Final EIR and Response to Comments, mobile emissions from the conceptual development plan have been underestimated; therefore, the potential impacts of the project may be mischaracterized. The Final EIR concludes that the project’s emissions do not exceed adopted thresholds of significance for air quality and greenhouse gas emissions. However, the Final EIR appears to underestimate mobile vehicle emissions due to several errors and/or issues with the modeling methodology, including an inaccurate vehicle trip rate, inappropriate accounting of internal trip capture for purposes of air quality impact analysis, and double-counting of trip-reducing measures.
Therefore, we strongly encourage that individual Planned Development Permit applications for future project buildout receive thorough project-specific analysis under CEQA. Potentially significant impacts resulting from the development of the site should be assessed and adequately mitigated through later, project-specific review. If the City considers “tiering” or other methods of streamlining environmental review of future discretionary permitting from the subject Final EIR, the City should ensure that the potentially significant air quality and greenhouse gas effects of the development plan are adequately identified, avoided, and/or mitigated as necessary through a later EIR or negative declaration or other site-specific revisions, conditions, or other means in connection with the approval of the later project that avoid or reduce significant impacts (see Public Resources Code Section 21093 and 21094, CEQA Guidelines Section 15152 and 15163). Regarding aspects of the project requiring a District permit, the City should consult with the District as a responsible agency under CEQA through preapplication consultation (see CEQA Guidelines 15060.5).
District Comments on the Final EIR for Richard’s Ranch Annexation Project November 15, 2024
In sum, we ask that the City ensures that the air quality and greenhouse gas impacts from future build out of the proposed development are properly evaluated, disclosed and mitigated as appropriate under CEQA. Please contact Emily Waddington, Air Quality Specialist, at (805) 979-8334 or by e-mail at [email protected] if you have questions.
Sincerely,
Alex Economou
Planning Division Manager
Santa Barbara County Air Pollution Control District
cc: Dana Eady, Interim Director of Community Development, City of Santa Maria [email only] Planning Chron File