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MainPlace Transformation Project City Council Agenda Item 75D June 4, 2019 Page 7 Mr. Offermann states: Indoor air quality in homes is particularly important because occupants, on average, spend approximately ninety percent of their time indoors with the majority of this time spent at home (EPA, 2011). Some segments of the population that are most susceptible to the effects of poor IAQ, such as the very young and the elderly, occupy their homes almost continuously. Additionally, an increasing number of adults are working from home at least some of the time during the workweek. Offermann Comment, p. 1. Formaldehyde is a known human carcinogen. Mr. Offermann states that there is a fair argument that residents of the Project will be exposed to a cancer risk from formaldehyde of between 125 and 180 per million. (Offermann Comment, pp. 2-3.) This is far above the South Coast Air Quality Management District (SCAQMD) CEQA significance threshold for airborne cancer risk of 10 per million. Even if the Project uses modern "GARB -compliant" materials, Mr. Offermann concludes that formaldehyde will create a cancer risk more than ten times above the CEQA significance threshold. Offermann Comment, p. 3. Mr. Offermann concludes that this significant environmental impact should be analyzed in an EIR and mitigation measures should be imposed to reduce the risk of formaldehyde exposure. In addition to residential exposure, the employees of the hotel and commercial and office buildings are also expected to experience work -day exposures. Offermann Comment, p. 4. This exposure for employees would result in "significant cancer risks resulting from exposures to formaldehyde released by the building materials and furnishing commonly found in hotels and commercial and office buildings." Id. Assuming work eight hour days, five days per week, an employee would be exposed to a cancer risk of 18.4 per million, which is nearly double the 10 per million CEQA threshold. Id. at 5. Mr. Offermann concludes that this significant environmental impact should be analyzed in an EIR and mitigation measures should be imposed to reduce the risk of formaldehyde exposure. Id., pp. 4. Mr. Offermann identifies mitigation measures that are available to reduce these significant health risks, including the installation of air filters and a requirement that the applicant use only composite wood materials (e.g. hardwood plywood, medium density fiberboard, particleboard) for all interior finish systems that are made with CARB approved no - added formaldehyde (NAF) resins or ultra -low emitting formaldehyde (ULEF) resins in the buildings' interiors. Offermann Comments, pp. 11-12 The City has a duty to investigate issues relating to a proj ect's potential environmental impacts, especially those issues raised by an expert's comments. See Cty. Sanitation Dist. No. 2 v. Cty. of Kern, (2005) 127 Cal.AppAth 1544, 1597-98 ("under CEQA, the lead agency bears a burden to investigate potential environmental impacts"). In addition to assessing the Project's potential health impacts to residents and workers, Mr. Offermann identifies the investigatory path that the City should be following in developing an EIR to more precisely evaluate the