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argument that the maximum daily NOx emissions may exceed the SCAQMD's daily maximum threshold of 100 Ibs/day.' Thus, Project construction may result in a new significant impact which was not identified or addressed by either the 2019 Addendum or 1983 EIR. Prior to Project approval the construction emissions should be quantified and compared to the SCAQMD's thresholds in an updated, Project -specific EIR. Diesel Particulate Matter Health Risk Emissions Inadequately Evaluated The Project Applicant conducts a health risk assessment (HRA) in orderto determine the health risk posed to new, on -site residential receptors due to proximity to the Interstate 5 freeway and State Route 22 (2019 Addendum, p. 117). Based on this HRA for new, on -site receptors, the 2019 Addendum concludes that "impacts related to toxic air contaminates would be less than significant" (2019 Addendum, p. 118). This significance determination is incorrect, however, as the 2019 Addendum fails to conduct a construction or operational HRA to determine the health risk posed to existing, nearbv sensitive receptors as a result of Project construction and operation. The 2019 Addendum attempts to justify the omission of an HRA for existing receptors 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" (2019 Addendum, p. 114). The 2019 Addendum goes onto state, "Although the closest sensitive receptors are located approximately 300 feet from the property line of the Project, construction would not occur at the property line, but would be setback approximately 300 feet the property line that is closest to the sensitive receptors... According to the CARB Air Quality and Land Use Handbook (2005), pollutant concentrations drop off drastically with distance (i.e., a 70 percent drop off in pollutant concentrations at 500 feet from the source). Additionally, construction equipment and vehicles in general have become cleaner and release less emissions than when the 1983 EIR was certified and when the 1996 Addendum was adopted. As a result, construction emissions would be lower than what was anticipated in both the 1983 EIR and the 1996 EIR, and no new impacts would occur" (2019 Addendum, p. 114). As the above excerpt demonstrates, the 2019 Addendum claims that health risk impacts associated with construction and operation of the currently proposed Project would be lower than the impacts disclosed ' South Coast AQMD Air Quality Significance Thresholds. SCAQMD, April 2019, available at: httl)://www.agrnd.gov/dots/default-source/cega/handbook/scag md-air-g ua lity-sign ifi cance-th resholds.pdf