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Response to Comment City of Santa Ana 10 Magnolia at the Park Multi-Family Residential Project December 2018 Comment 24: This comment provides information about the San Francisco Department of Health requirements that all residences within 500 feet of a freeway or high traffic roadway is required to install air filtration with a minimum efficiency of MERV 13 to remove PM 2.5 . The comment also states that Santa Ana is within a non-attainment area for PM 2.5 and that due to the high traffic near the project site installation of MERVE 13 filters is warranted. Response 24: The City of Santa Ana is not under the jurisdiction of the San Francisco Department of Health. However, as described in previous Responses 19, 21, and 22, the proposed project includes building ventilation with air filtration systems that equal to or exceed MERV 16 values that are included as PDF-3. The MERV 16 filters would exceed the filtration and efficiency function of the MERVE 13 filters, resulting in improved air quality in comparison to the filtration that is recommended by the comment. The comment appears to be left over from a comment letter prepared for a different project. Comment 25: This comment provides recommended mitigation measures to reduce indoor formaldehyde concentrations, which includes: 1) use of only composite wood materials that are CARB approved no-added formaldehyde (NAF) resins or ultralow emitting formaldehyde (ULEF) resins; 2) provide all habitable rooms with a continuous mechanical supply of outdoor air that meets or exceeds the California 2016 Building Energy Efficiency Standards; and 3) install air filtration with a minimum efficiency of MERV 13 to filter the outdoor air entering the mechanical outdoor air supply system. Response 25: As described in Responses 4, 6, 19, 20, and 21, the levels of indoor formaldehyde within residential units would not exceed the SCAQMD significance threshold of 10 per million and the project would result in less than significant impacts related to formaldehyde. Therefore, no mitigation is required. However, as required by the U.S. EPA and CARB, the proposed project would utilize products that have to be manufactured or imported pursuant to TSCA Title VI and California Proposition 65 safe harbor standards. In addition, the project includes air filtration systems with efficiencies equal to or exceeding a MERV 16 as defined by the ASHRAE Standard 52.2 within all buildings (included as PDF-3). This would provide improved indoor air quality over the recommended MERV 13 filtration. Comment 26: This comment provides an introductory statement that describes the proposed project and states that that EIR fails to adequately evaluate air quality impacts from construction and operation of the project because emissions are underestimated and that a revised EIR should be prepared. Response 26: This comment is general in nature and does not provide any examples or citations of where analysis within the EIR is flawed. The air quality analysis for the proposed project (Appendix C of the Draft EIR and Section 4.2, Air Quality, of the Draft EIR) was prepared pursuant to current SCAQMD guidelines and determined that impacts would be less than significant with implementation of construction related mitigation, which requires that off-road diesel construction equipment comply with EPA/CARB Tier 3 emissions standards that would reduce emissions below the applicable SCAQMD thresholds, and recirculation of the EIR is not required. Comment 27: This comment asserts that the Draft EIR fails to conduct a quantified HRA as a result of diesel particulate matter (DPM) emissions that would be emitted during project activities for nearby existing sensitive receptors. The comment asserts that the construction and operational health risk impacts posed to nearby existing sensitive receptors resulting from the proposed project need to be quantified and compared to applicable thresholds. Response 27: The project does not propose significant operational sources of toxic air contaminants (TACs), such as freeways and high-traffic roads, commercial distribution centers, rail yards, ports, refineries, chrome platers, dry cleaners, or gasoline stations. The project would generate a limited amount of passenger vehicle traffic which would not exceed SCAQMD thresholds (as shown on Table 4.2-7) and per SCAQMD is not a substantial TAC source. Only 2-306