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Response to Comment City of Santa Ana 2 Magnolia at the Park Multi-Family Residential Project December 2018 manufactured, or imported in the United States are required to meet new emission standards for formaldehyde from composite wood products in order to reduce exposures to formaldehyde and avoid adverse health effects. Typical composite wood products include hardwood plywood, medium-density fiberboard, and particleboard, as well as household and other finished goods containing these products. The new emission limits include the following: • Hardwood Plywood: 0.05 parts per million (ppm) • Particleboard: 0.09 ppm • Medium-density fibreboard: 0.11 ppm • Thin Medium-density fibreboard: 0.13 ppm These emission levels were determined to be incompliance with and result in less exposure (e.g., daily intake) than the California Proposition 65 safe harbor level for formaldehyde (40 μg/day), which is based on Proposition 65's risk criterion of 1 in 100,000. Thus, products manufactured to TSCA Title VI and California Proposition 65 safe harbor standards, which is now required by the U.S. EPA for all products manufactured or imported into the United States, would not generate formaldehyde emissions that would exceed the SCAQMD significance threshold of 10 per million. CARB identifies that these standards are projected to lead to a reduction in statewide formaldehyde emissions of 500 tons per year. Reduced risk of cancer from formaldehyde exposure is also a resulting benefit, and implementation of these standards is estimated to reduce excess cancer cases per million people from formaldehyde exposure by about 40 percent (https://www.arb.ca.gov/toxics/compwood/implementation/faq.htm#G). The CalGreen Building Code also includes similar formaldehyde limits for building products. The project would be implemented pursuant to these formaldehyde requirements, as all products manufactured or imported in the United States would be required to meet these regulations. This would limit the potential of human health and cancer risks to a less than significant level pursuant to the SCAQMD significance threshold of 10 per million. Thus, building material manufacturer compliance with existing regulations would avoid potentially significant impacts related to formaldehyde. Thereby, the project would also result in less than significant impacts. Comment 5: This comment states that when a project exceeds an adopted CEQA significance threshold it establishes a fair argument that the project will have a significant adverse environmental impact. The comment further asserts that since expert evidence demonstrates that the project will exceed the Bay Area Air Quality Management District’s (BAAQMD) CEQA significance threshold, there is a fair argument that the project will have significant adverse and an EIR is required. Response 5: As described above in Response 4, the project will not exceed SCAQMD thresholds for formaldehyde. Further, the project site is located in the SCAQMD, which includes all of Orange County and the urban parts of Los Angeles, Riverside, and San Bernardino counties. The BAAQMD is located in the San Francisco Bay Area and includes the following counties: Alameda, Contra Costa, Marin, Napa, San Francisco, San Mateo, Santa Clara, southwestern Solano, and southern Sonoma. The thresholds of the BAAQMD are therefore irrelevant to this project. The comment appears to be left over from a comment letter prepared for a different project. Comment 6: This comment refers to recommended mitigation measures, such as requiring the use of no-added- formaldehyde composite wood products, requiring air ventilation systems that would reduce formaldehyde levels. In addition, the comment states that the EIR does not analyze effects related to formaldehyde or consider mitigation measures. 2-298