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City of Santa Ana– First American Mixed-Use Project [114 and 117 East Fifth Street] – Comments to City Council November 18, 2019 Page 9 of 13 evaluated for cancer risks to nearby sensitive receptors. Id. The OEHHA also recommends that exposure from projects with operations lasting more than 6 months be evaluated for the duration of the project, and recommends an exposure duration of 30 years. Id. As a result, pursuant to the OEHHA guidance, the Addendum should have evaluated health risks from Project construction and operation. Id. Furthermore, Screening-Level HRA conducted by Mr. Hagemann and Mr. Rosenfeld indicates that the Project will have a significant impact from DPM emissions. Exhibit C, p. 7. The DPM emission rate during construction is 0.001368 grams per second (g/s). Id. The DPM emissions rate during operation is 0.001125 g/s, generating approximately 78 lbs. of DPM per year throughout the life of the Project’s operation. Id. at p. 7-8. The SCAQMD also gives a numerical threshold of 10 in one million to evaluate projects. Id. Taking into account the age sensitivity factors, the excess cancer risk posed to especially children and infants of the closest receptors far exceeds the SCAQMD threshold at approximately 6.5 (adults), 58 (children), 63 (infants) and 2.7 (third trimester of pregnancy) in one million. Id. at 10. The City must prepare an EIR which includes an analysis of health risks that connects the Project’s air emissions with the health risk posed by those emissions. B. The Addendum Fails to Adequately Analyze, Disclose and Mitigate the Project’s Significant Greenhouse Gas Impacts The Addendum erroneously concludes that the Project would have less than significant greenhouse gas (GHG) impacts, relying on the analyses indicated in the 2010 EIR for the Transit Zoning Code. According to Mr. Hagemann and Mr. Rosenfeld, the Addendum’s GHG impacts analyses are deficient for the following reasons, which are detailed in their letter in Exhibit C, p. 11-24: (1) The Addendum fails to demonstrate consistency with the 2010 EIR, fails to commit to the use of the same mitigation measures provided in the 2010 EIR (MM 4.13-8 through 4.13-23), and fails to explain how the mitigation measures would be implemented, monitored, and enforced, (2) The Santa Ana County CAP cannot be relied upon to determine Project significance because it does not apply to the Project because the Project will not be fully operational by 2020;