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Finally, the omission of a quantified health risk assessment is inconsistent with the most recent guidance published by Office of Environmental Health Hazard Assessment (OEHHA), the organization responsible for providing recommendations and guidance on how to conduct health risk assessments in California. In February of 2015, OEHHA released its most recent Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments, which was formally adopted in March of 2015.11 This guidance document describes the types of projects that warrant the preparation of a health risk assessment. Grading and construction activities for the proposed Project will produce emissions of DPM through the exhaust stacks of construction equipment over an approximately 16-year period, according to the construction schedule utilized to model construction GHG emissions (2019 Addendum, pp. 2769). The OEHHA document recommends that all short-term projects lasting at least two months be evaluated for cancer risks to nearby sensitive receptors." Once construction is complete, Project operation will include approximately 61,050 daily vehicle trips, which will generate substantial additional exhaust emissions, thus continuing to expose nearby sensitive receptors to DPM emissions (Table T-4, 2019 Addendum, p. 78). The OEHHA document recommends that exposure from projects lasting more than six months should be evaluated for the duration of the project, and recommends that an exposure duration of 30 years be used to estimate cancer risk for the maximally exposed individual resident (MEIR)." Even though we were not provided with the expected lifetime of the Project, we can reasonably assume that the Project will operate for at least 30 years, if not more. Therefore, per SCAQMD and OEHHA guidelines, health risk impacts from Project construction and operation should have been evaluated by the 2019 Addendum. These recommendations reflect the most recent health risk assessment policy, and as such, an assessment of health risks to nearby, existing sensitive receptors from construction and operation should be included in a Project -specific EIR. Greenhouse Gas Greenhouse Gas Efficiency Incorrectly Evaluated In order to determine the significance of the Project's GHG emissions, the 2019 Addendum prepared an efficiency based GHG analysis. Based on the GHG efficiency analysis, the Applicant concludes that the proposed Project's GHG efficiency would be approximately 2.84 MT CO2e/year/service population, which falls below the SCAQMD's 3.0 MT COze/year/service population significance threshold for the year 2035, and thus would not result in any new GHG emissions impacts (2019 Addendum, P. 119). This significance conclusion is incorrect, however, as the Applicant relies on incorrect methodology to calculate the Project's GHG emissions efficiency. In an attempt to quantitatively demonstrate a less than significant GHG impact, the Applicant first calculates the Project's "net emissions" by subtracting the GHG emissions associated with the existing land uses from the GHG emissions associated with the proposed Project, which results in annual to "OEHHA (Feb.2015) Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments, https://oeh ha. ca.aov/media/down loads/crnr/2015eu idancem a n u al. pdf. " "OEHHA (Feb.2015) Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments, https://oehha.ca.gov/med_ia/`downloads/crnr/2015xuidancemanual.pdf, p. 8-18 12 "OEHHA (Feb.2015) Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments, httos://oehha.ca.eov/media/downloads/crnr/2015guidancemanual.pdf, p. 8-6, p. 8-15