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Response to Comment City of Santa Ana 9 Magnolia at the Park Multi-Family Residential Project December 2018 Comment 21: This comment asserts that a follow up study to the California New Home Study conducted in 2016-2018 found that the 2009 CARB requirements reduced indoor formaldehyde emissions by 30 percent, the median lifetime cancer risk is still 125 per million for homes built with CARB compliant composite wood products which is more than 12 times the 10 in a million threshold. The comment then states that if the project is ventilated to the minimum requirements by code it would still result in a cancer risk of 125 per million, which is more than 12 times the threshold of 10 per million. Response 21: This comment is inaccurate. The follow up study referred to by this comment concluded that the residences developed in compliance to the 2009 CARB requirements showed good compliance with installed mechanical ventilation requirements; however, because the ventilation systems were not operating, the formaldehyde concentrations were similar to the previous study. Furthermore, the results of the follow up study found that adequate ventilation reduces formaldehyde to below the SCAQMD threshold. (Accessible: https://cloudfront.escholarship.org/dist/prd/content/qt2xg7s5nv/qt2xg7s5nv.pdf?t=pamtn8) As described previously, the project would utilize TSCA Title VI products that meet California Proposition 65 safe harbor standards and operate air filtration systems with efficiencies equal to or exceeding MERV 16, as defined by the ASHRAE Standard 52.2, within all buildings (included as PDF-3). Thus, the lack of ventilation that occurred during the studies referenced by this comment would not occur in the proposed project. This project’s building ventilation would be operated and maintained as required by PDF-3. Thus, the levels of indoor formaldehyde described by the comment would not occur, and as detailed in previous responses, would be less than the SCAQMD threshold. Comment 22: This comment describes the findings of the previously discussed New Home Studies and states that outdoor air ventilation is a very important factor influencing the indoor concentrations of air contaminants and that 32 percent of the residences did not use their windows during the test day, and 15 percent of the residences did not use their windows during the entire preceding week. The comment asserts that because the project is located near high traffic roadways that generate noise, the project will require mechanical supply of outdoor air ventilation air to allow for a habitable interior environment with closed windows and doors. Response 22: Refer to Response 21. Based on this comment a majority (68 percent) of residences opened windows the day of the testing and 85 percent opened their windows during the week of the testing. Thus, the study indicates that a majority of study residences had open windows at least part of the time. In addition, as described by previous responses, building ventilation with air filtration systems that equal to or exceed MERV 16 values would be operated and maintained by the property management as included by PDF-3. Thus, the proposed project includes a mechanical supply of filtered outdoor air ventilation air for all of the residences. Comment 23: This comment states that traffic associated with the project would result in increased outdoor concentrations of PM 2.5 and that the HRA for this project (Stantec, 2016), states in Table 6 that the cancer risk from traffic is 21.1 per million, which exceeds the SCAQMD threshold of 10 per million. Response 23: This comment is inaccurate. The HRA for the project was prepared by Urban Crossroads in May 2018 (Appendix C of the Draft EIR). The HRA document does not include a Table 6, and the HRA determined that the risk for the maximum exposed residential receptor would be 7.57 in one million which would not exceed the SCAQMD significance threshold of 10 in one million. The comment appears to be referencing an HRA for a different project. The comment appears to be left over from a comment letter prepared for a different project. 2-305