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75E - PH 2525 MAIN ST
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75E - PH 2525 MAIN ST
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Last modified
2/1/2019 4:04:49 PM
Creation date
2/1/2019 3:58:07 PM
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City Clerk
Doc Type
Agenda Packet
Agency
Planning & Building
Item #
75E
Date
2/5/2019
Destruction Year
2024
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November 26, 2018 <br />Comment on Environmental Impact Report, 2525 N. Main Street Multi -Family Residential Project <br />(aka Magnolia at the Park) SCH 2018021031, DP No. 2017-34 <br />page 5 <br />The responses to comments on a draft EIR must state reasons for rejecting <br />suggested mitigation measures and comments on significant environmental issues. <br />"Conclusory statements unsupported by factual information" are not an adequate <br />response. (14 CCR §15088(b, c); Cleary v. County of Stanislaus (1981) 118 <br />Cal.App.3rd 348) The need for substantive, detailed response is particularly <br />appropriate when comments have been raised by experts or other agencies. <br />(Berkeley Keep Jets v. Bd. of Port Commis (2001) 91 Cal.AppAth 1344, 1367; <br />People v. Kern (1976) 72 Cal.app.3d 761) A reasoned analysis of the issue and <br />references to supporting evidence are required for substantive comments raised. <br />(Calif. Oak Found. v. Santa Clarita (2005) 133 Cal.AppAth 1219) <br />The FEIR abjectly fails to meet these legal standards, as it is riddled with <br />conclusory statements lacking any factual support or analysis. <br />DISCUSSION <br />1. The EIR Fails to Analyze Indoor Air Quality Impacts. <br />We submit herewith the comments of indoor air quality expert, Francis <br />Offermann, PE, CIH. (Exhibit A). Mr. Offermann, a Certified Industrial Hygienist, <br />concludes that it is likely that the Project will expose future residents to significant <br />impacts related to indoor air quality, and in particular, emissions for the cancer- <br />causing chemical formaldehyde. Mr. Offermann is one of the world's leading experts <br />on indoor air quality and has published extensively on the topic. <br />Mr. Offermann explains that many composite wood products typically used in <br />modern home construction contain formaldehyde -based glues which off -gas <br />formaldehyde over a very long time period. He states, "The primary source <br />formaldehyde indoors is composite wood products manufactured with urea - <br />formaldehyde resins, such as plywood, medium density fiberboard, and particle <br />board. These materials are commonly used in residential building construction for <br />flooring, cabinetry, baseboards, window shades, interior doors, and window and <br />door trims." <br />Formaldehyde is a known human carcinogen. Mr. Offermann states that <br />there is a fair argument that residents of the Project will be exposed to a cancer risk <br />from formaldehyde of approximately 180 per million. This is far above the South <br />Coast Air Quality Management District (SCAQMD) CEQA significance threshold for <br />airborne cancer risk of 10 per million. <br />Even if the Project uses modern "GARB -compliant" materials, Mr. Offermann <br />concludes that formaldehyde will create a cancer risk of 126 per million, which is <br />75E-249 <br />
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