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CORRESPONDENCE - 75D
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CORRESPONDENCE - 75D
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6/6/2019 12:19:02 PM
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City Clerk
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75D
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6/4/2019
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in the 1983 EIR and 1996 Addendum, and thus the Project would not result in any new significant <br />sensitive receptor impacts. This justification is entirely unsubstantiated, as neither the 1983 EIR nor <br />1996 Addendum evaluated the health risk Impacts associated with any Project activities. Additionally, <br />neither the 1983 EIR nor 1996 Addendum made any significance determination regarding the Project's <br />health risk impacts. Therefore, the Applicant cannot rely on the 1983 EIR or 1996 Addendum to claim <br />that the 2019 Addendum Project would result in a less than significant impact. <br />Furthermore, the SCAQMD recommends performing an HRA for any project that is expected to generate <br />mobile emissions from diesel -powered equipment and trucks. According to SCAQMD's Mobile Source <br />Toxics Analysis page on SCAQMD's website (emphasis added): <br />"In August 2002, the SCAQMD's Mobile Source Committee approved the 'Health Risk <br />Assessment Guidance for Analyzing Cancer Risks from Mobile Source Diesel Emissions.' This <br />document provided guidance for analyzing cancer risks from diesel particulate matter from <br />mobile sources at facilities such as truck stops and warehouse distribution centers. <br />Subsequently, SCAQMD staff revised the aforementioned document to expand the analysis to <br />provide technical guidance for analyzing cancer risks from potential diesel particulate emissions <br />impacts from truck idling and movement (such as, but not limited to, truck stops, warehouse <br />and distribution centers, or transit centers), ship hotelling at ports, and train idling. This revised <br />guidance document titled, 'Health Risk Assessment Guidance for Analyzing Cancer Risks from <br />Mobile Source Diesel Idling Emissions for CEQA Air Quality Analysis' was presented to and <br />approved by the SCAQMD's Mobile Source Committee at its March 28, 2003 committee <br />meeting. It is suggested that projects with diesel powered mobile sources use the following <br />guidance document to quantify potential cancer risks from the diesel particulate emission."' <br />As you can see in the excerpt above, the SCAQMD explicitly states that if the proposed Project generates <br />or attracts vehicular trips, a mobile source health risk assessment must be prepared. Namely, the <br />SCAQMD states that "it is suggested that projects with diesel powered mobile sources" use the <br />SCAQMD's Health Risk Assessment Guidance "to quantify potential cancer risks from the diesel <br />particulate emission."' Given that Project construction is expected to occur over a 16-year period, it is <br />reasonable to assume that a significant amount of diesel particulate matter (DPM), a known human <br />carcinogen, will be emitted from the exhaust stacks of equipment required for Project construction <br />(2019 Addendum, pp. 2769). Similarly, operational activities will result in large amounts of diesel <br />exhaust from vendor trucks visiting the hotel and commercial land uses over the course of Project <br />operation (Table T-4, 2019 Addendum, p. 78). As such, the 2019 Addendum should have conducted a <br />construction and operational HRA, as long-term exposure to DPM and otherTACs may result in a <br />significant health risk impact and therefore, should be properly assessed. <br />8 SCAQMD (2019) Mobile Source Toxics Analysis, http://www.aamd,gov/home/regulations/ceaa/air-auality- <br />an a I_ysis-hand book/mobile-sou rce-toxics-analysis. <br />9 SCAQMD (2019) Mobile Source Toxics Analysis, http://www.aclmd.gov/home/regulations/ceaa/air-quality- <br />analvsis-h a nd book/mobile-sou rce-toxics-analysis. <br />
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