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MainPlace Transformation Project City Council Agenda Item 75D June 4, 2019 Page 13 South Coast Air Quality Management District Construction -Related Significance Thresholds NOx 100 Ibs/day VOC 75 Ibs/day PM10 150 Ibs/day PM 2.5 55 Ibs/day sox 150lbs/day CO 550 Ibs/day Lead 3lbs/day Developmnet projects must use these thresholds of sigmiiance to determine the significance of emissions assoiated with proejct construction. SWAPE, p. 4. As SWAPE points out, "absent the quantification of construction air pollutant emissions and comparison to applicable thresholds, the 2019 Addendum cannot make any significance conclusions regarding the Project's air quality impacts." Id. The Project's construction -related emissions must be quantified, compared to the applicable significance thresholds, and mitigated where necessary. Without any evidence of how much the current Project or the 1983 Project will emit, the Addendum's conclusion that the substantial changes to the Project will not result in a new or more significant impact than was analyzed in the 1983 EIR. B. There is no Evidence that the Project Will not Result in a New Significant Health Risk to Nearby Sensitive Receptors. The Addendum includes a health risk assessment ("HRA"). But it looks at the health risk posed by the Project to new, on -site residential receptors as a result of proximity to I-5 and SR- 22. Addendum, p. 117. But the Addendum fails to conduct an HRA to determine the health risk posed to existing, nearby sensitive receptors as a result of Project construction and operation. The Addendum tries to justify this omission by stating: Construction is temporary, would be transient throughout the site (i.e., move from location to location), and would not generate emissions in a fixed location for extended periods of time. Construction would be subject to and would comply with California regulations limiting the idling of heavy-duty construction equipment to no more than 5 minutes to further reduce nearby sensitive receptors' exposure to temporary and variable diesel particulate matter emissions. For these reasons, diesel particulate matter emissions generated by construction activities, in and of itself, would not be expected to expose sensitive receptors to substantial amount of air toxics and the Project would have a less than significant impact. Addendum, p. 114. It goes onto say: