75E - PH 2525 MAIN ST - Laserfiche WebLink

Home Browse Search

November 26, 2018 Comment on Environmental Impact Report, 2525 N. Main Street Multi -Family Residential Project (aka Magnolia at the Park) SCH 2018021031, DP No. 2017-34 page 10 A Recirculated Draft EIR should be prepared to analyze the impacts of the Project's lack of affordable housing and the impact on urban decay. It should 16 propose feasible mitigation measures, such as requiring more affordable housing in the Project, contributions to low-income housing funding, etc. 5. The EIR Fails to Adequately Analyze or Mitigate the Project' Significant Air Quality Impacts. The expert consulting firm, Soil, Water, Air Protection Enterprise (SWAPE), demonstrates that the EIR improperly calculates air quality impacts. SWAPE calculates that the Project will have highly significant airborne cancer risk impacts, far above CEQA significance thresholds. SWAPE calculates that the Project will create an airborne cancer risk from construction and operation of the Project of 220 per million — far above the SCAQMD CEQA significance threshold of 10 per million. Most of this cancer risk is created by diesel engine exhaust associated with construction and operation of the Project. SWAPE states: As demonstrated above, the excess cancer risk to adults, children, infants, and 3rd trimester gestations at a sensitive receptor located approximately 25 meters away, over the course of Project construction and operation, are approximately 10, 92, 110, and 5.5 in one million, respectively. Furthermore, the excess cancer risk over the course of a residential lifetime (30 years) is approximately 220 in one million. Consistent with OEHHA guidance, exposure was assumed to begin in the 3rd trimester stage of pregnancy to provide the most conservative estimates of air quality hazards. The infantile, child, adult, and lifetime cancer risks all exceed the SCAQMD's threshold of 10 in one million, thus resulting in a potentially significant impact not previously addressed or identified by the DEIR or FEIR. The EIR also conducts a different health risk assessment that allegedly shows a cancer risk less than 10 per million. However, the HRA used in the EIR fails to comply with the recent California Office of Environmental Health Hazard Assessment (OEHHA) methodology. The lead agency is required to use the 75E-254 17