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Response to Comment City of Santa Ana 1 Magnolia at the Park Multi-Family Residential Project December 2018 Response to Lozeau Drury LLP Comment Letter dated November 26, 2018 Comment 1: This comment provides an introductory statement to the letter from Lozeau Drury LLP. The introductory statement notes the comments on the Draft and Final EIR are submitted on behalf of the Laborers International Union of North America (LIUNA), Local Union No. 652, and its members living in and near Santa Ana. The comment also provides generalized assertions and states that that the EIR fails as an informational document and fails to impose all feasible mitigation measures to reduce the project’s impacts and a revised Draft EIR must be circulated for public review. Response 1: This comment is general in nature and does not provide any examples or citations of where analysis within the EIR is flawed, where additional information is needed, or what feasible mitigation is recommended. In accordance with CEQA, the City of Santa Ana prepared a Draft and Final EIR for the proposed project for the purpose of informing City decision makers, governmental agencies, and the public about the potential significant environmental effects of the proposed project, identifying the ways that environmental impacts can be avoided or significantly reduced, and implementing mitigation to reduce and prevent impacts to the environment. The EIR adequately analyzes the environmental effects of the proposed project, and the conclusions in the EIR are supported by substantial evidence in the record. None of the requirements for recirculation listed in CEQA Guidelines Section 15088.5 and described in Master Response 2: Draft EIR Recirculation of the Final EIR (page 2-4), have been triggered, and recirculation of the Draft EIR is not required. Comment 2: The comment summarizes the proposed project, including the proposed discretionary actions. Response 2: The comment is an introduction and summary of the project and does not include comment about the environmental analysis in the EIR and, therefore, does not require an additional response. Comment 3: The comment provides a summary of CEQA requirements through references to case law and statutes. The comment asserts that the Final EIR fails to meet CEQA’s legal standards and includes conclusory statements that lack any factual support or analysis. Response 3: The comment is general in nature and does not identify any specific alleged deficiency with the analysis in the Draft EIR, or any other alleged noncompliance with CEQA. To the extent such argument is asserted, the Draft EIR thoroughly and appropriately evaluated the project’s potential environmental impacts, and the conclusions of the Draft EIR are supported by substantial evidence, including expert opinion. Comment 4: This comment provides an introduction to Francis Offermann, PE, CIP and describes that Mr. Offermann explains that many composite wood products typically used in modern home construction contain formaldehyde-based glues which off-gas formaldehyde. The comment asserts that there is a fair argument that residents of the Project will be exposed to a cancer risk from formaldehyde of approximately 180 per million, above the South Coast Air Quality Management District (SCAQMD) CEQA significance threshold for airborne cancer risk of 10 per million. The comment further asserts that even if the project uses modern “CARB-compliant” materials, formaldehyde will create a cancer risk of 126 per million. Response 4: The comment does not describe how the asserted formaldehyde related cancer risk of 126 per million would occur and does not identify any project-specific conditions (other than the fact that the project’s construction may use wood building materials) that would lead to impacts. Current federal and state regulations exist, which limit the potential formaldehyde emissions from building materials. On June 1, 2018, the U. S. Toxic Substances Control Act (TSCA) Title VI was implemented, which requires composite wood products sold, supplied, offered for sale, 2-297