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Response to Comment City of Santa Ana 7 Magnolia at the Park Multi-Family Residential Project December 2018 Response 16: Refer to Responses 1, 13, and 14. The proposed project would not result in potentially significant impacts related to the lack of affordable housing or result in urban decay. Mitigation measures related to affordable housing are not required. However, compliance with the City’s existing municipal code would be required to provide for low income units, that include contributions to low-income housing funding, which would be implemented through project permitting procedures. Additionally, 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 17: This comment states that Soil, Water, Air Protection Enterprise (SWAPE), a private consulting company, has provided information that demonstrates that the EIR improperly calculates air quality impacts and that the project would have airborne cancer risk impacts from construction and operation of the project. The comment asserts that a cancer risk of 220 per million – above the SCAQMD CEQA significance threshold of 10 per million – would result from diesel engine exhaust associated with construction and operation of the project. The comment states that this was determined over 30 years and consistent with California Office of Environmental Health Hazard Assessment (OEHHA) guidance that assumed exposure to begin in the third trimester stage of pregnancy to provide the most conservative estimates of air quality hazards. The comment asserts that the HRA fails to comply with the OEHHA methodology and a revised EIR is required to analyze these impacts. Response 17: The HRA prepared for the project was conducted consistent with all protocols promulgated by the SCAQMD, which is the regulatory agency for air quality in the project region. The HRA utilized the California Air Resource Board’s (ARB) EMFAC2017 emission factor model, the AMS/EPA Regulatory Model AERMOD, and ARB and SCAQMD data, as directed by SCAQMD methodology. In addition, exposure assumptions were obtained from the 2015 OEHHA Guidelines and SCAQMD methodology, and the assessment utilized the U.S. Environmental Protection Agency’s (EPA) Exposure Factors Handbook. In compliance with this guidance and methodology, lifetime risk values for residents were adjusted to account for an exposure duration of 350 days per year for 30 years (i.e., 95th percentile). Additionally, the HRA included analysis pursuant to the OEHHA guidance, which indicates that both the prenatal and postnatal life stages can be impacted differently than adults. The HRA included age sensitivity factors from the third trimester of pregnancy through adulthood and the related variations of breathing rates, exposure duration, and time at home (Table 2-3 in the HRA). Thus, the analysis accounted for impacts to the entire population prenatal infants through adults. This methodology is consistent with CEQA and provides an evaluation of environmental effects of proposed project in a manner that reflects both reasonable and feasible assumptions. Furthermore, this methodology is consistent with current guidance prescribed by SCAQMD; and is not obsolete. The results of the HRA analysis (provided in Appendix C of the Draft EIR and Section 4.2, Air Quality, of the Draft EIR) identified that the maximum exposed residential receptor totaled 7.57 in one million and would not exceed the SCAQMD significance threshold of 10 in one million. In addition, the analysis showed that other emissions would not exceed the California Ambient Air Quality Standards (CAAQS). The analysis provided in the EIR substantiates that the project would not result in potentially significant health risks, and that impacts would be less than significant. 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. Thus, recirculation of the Draft EIR is not required. Comment 18: This comment states that for the foregoing reasons, and for the reasons set forth by other commenters (which are incorporated herein by reference), a revised draft EIR is required to analyze and mitigate the proposed project’s significant impacts. Response 18: This is a conclusionary statement. Refer to Responses 1 through 17. As detailed in the previous responses and the Final EIR, none of the requirements for recirculation listed in CEQA Guidelines Section 15088.5 2-303