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2 project site. The modeling conducted by the HRA includes freeway volumes from Caltrans, spatial distribution of mobile source activity traversing the freeway in relation to the proposed site and was prepared pursuant to SCAQMD methodology” (p. 4.2‐17 – 4.2‐18). The DEIR goes on to conclude, “The HRA calculations determined that the cancer risk from exposure to diesel and gasoline fuel emissions to the maximum exposed residential receptor totaled 7.57 in one million, which would not exceed the SCAQMD significance threshold of 10 in one million. Overall, impacts related to exposures associated with both toxic and criteria pollutants would be less than significant” (p. 4.2‐18). This significance determination is incorrect, as the Project Applicant cannot claim that the Project would result in a less than significant health risk impact without properly assessing the risk posed to existing sensitive receptors as a result of diesel particulate matter (DPM) emissions that will be emitted during Project activities. As a result, until the construction and operational health risk impacts posed to nearby existing sensitive receptors resulting specifically from the proposed Project are adequately quantified and compared to applicable thresholds, the DEIR cannot make any conclusions with regards to the Project’s health risk impacts. By failing to prepare a construction or an operational HRA for existing sensitive receptors, the DEIR is inconsistent with recommendations set forth by the Office of Environmental Health Hazard Assessment (OEHHA), the organization responsible for providing recommendations for 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 2015.1 This guidance document describes the types of projects that warrant the preparation of a health risk assessment. Construction of the Project will produce emissions of DPM, a human carcinogen, through the exhaust stacks of construction equipment over a construction period of 18 months (p. 3‐18). The OEHHA document recommends that all short‐term projects lasting at least two months be evaluated for cancer risks to nearby sensitive receptors.2 Therefore, per OEHHA guidelines, health risk impacts from Project construction should have been evaluated by the DEIR. Furthermore, once construction of the Project is complete, the Project will operate for a long period of time. During operation, the Project will generate vehicle trips, which will generate additional exhaust emissions, thus continuing to expose nearby sensitive receptors to emissions. The OEHHA document recommends that exposure from projects lasting more than 6 months should be evaluated for the duration of the project, and recommends that an exposure duration of 30 years be used to estimate individual cancer risk for the maximally exposed individual resident (MEIR).3 Even though we were not provided with the expected 1 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: http://oehha.ca.gov/air/hot_spots/hotspots2015.html 2 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: http://oehha.ca.gov/air/hot_spots/2015/2015GuidanceManual.pdf, p. 8‐18 3 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: http://oehha.ca.gov/air/hot_spots/2015/2015GuidanceManual.pdf, p. 8‐6, 8‐15