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determined to be a sound impacted site according to Noise Impact Analysis in Appendix H <br />of the Draft EIR (Urban Crossroads, 2018). <br />As a result of the high traffic related outdoor noise levels, the current project will require <br />the need for mechanical supply of outdoor air ventilation air to allow for a habitable interior <br />environment with closed windows and doors. Such a ventilation system would allow <br />windows and doors to be kept closed at the occupant's discretion to control exterior noise <br />within residential interiors. This applies to both the residential and commercial portions of <br />this development. <br />PM2.5 Outdoor Concentrations Impact. An additional impact of the nearby motor vehicle <br />traffic associated with this project, are the increased outdoor concentrations of PM2.5. The <br />Health Risk Assessment Report for this project (Stantec, 2016), states in Table 6 that the <br />cancer risk from traffic is 21.1 per million, which exceeds the SCAQMD threshold of 10 <br />per million. <br />San Francisco is a leader in issuing regulations to remove PM2.5 from impacted areas. The <br />San Francisco Department of Public Health, 2014. Article 38, Enhanced Ventilation <br />Required for Urban Infill Sensitive Use Developments, requires that air filtration, with a <br />minimum efficiency of MERV 13 be installed to remove PM2,5 from mechanically supplied <br />outdoor air in all PM2.5 impacted areas. All areas within 500 feet of any freeway or high - <br />traffic road way (defined as urban roads with 100,000 vehicles/day or rural roads with <br />50,000 vehicles/day), unless air dispersion modeling shows total (traffic and ambient) <br />outdoor concentrations of less than an annual average of 10 µg/m3 PM2.5, are defined as <br />PM2.5 impacted areas. <br />Santa Ana is an EPA non -attainment area for PM2.s., with exceedences of both the EPA <br />maximum annual average concentration of 12 µg/ m3 and the EPA maximum 24-hour <br />average of 35 µg/m3. <br />It is my experience that based on the projected high traffic noise level, the annual average <br />concentration of PM2.5 will be substantially higher than 10 µg/m3, and warrant installation <br />5 <br />75E-261 <br />H <br />23 <br />