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pollution.", 16, 11, 18 According to the most updated guidance, quantified cancer risk should be multiplied by a factor of ten during the third trimester of pregnancy and during the first two years of life (infant) and should be multiplied by a factor of three during the child stage of life (2 to 16 years). However, we also included the quantified cancer risk without adjusting for the heightened susceptibility of young children to the carcinogenic toxicity of air pollution in accordance with older OEHHA guidance from 2003. This guidance utilizes a less health protective scenario than what is currently recommended by BAAQMD, the air quality district responsible for the City, and several other air districts in the state. In order to evaluate impacts most conservatively, we strongly recommend the use of age sensitivitv factors as is recommended by the most recent guidance. Furthermore, in accordance with guidance set forth by OEHHA, we used the 951h percentile breathing rates for infants.19 Finally, according to BAAQMD guidance, we used a Fraction of Time At Home (FAH) value of 0.85 for the 3rd trimester and infant receptors, 0.72 for child receptors, and 0.73 for the adult receptors.20 We used a cancer potency factor of 1.1 (mg/kg-day)-1 and an averaging time of 25,550 days. OEHHA recommends that a 30-year exposure duration be used as the basis for estimating cancer risk at the MEIR.21 Consistent with OEHHA guidance, exposure to the MEIR was assumed to begin in the third trimester to provide the most conservative estimate of air quality hazards. The results of our calculations are shown below. The Closest Exposed Individual at an Existing Residential Receptor Duration Concentration Breathing Activity (years) (ug/m3) Rate (L/kg- day) Cancer Risk without ASF ASFs* Cancer Risk with ASFs* Construction 0.25 0.1954 361 2.7E-07 10 2.7E-06 " "Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments." OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf. 16 "Draft Environmental Impact Report (DEIR) for the Proposed The Exchange (SCH No. 2018071058)." SCAQMD, March 2019, available at: http://www.agmd.gov/docs/default-source/cega/comment- letters/2019/march/RVC190115-03.pdf?sfvrsn=8, p. 4. 17 "California Environmental Quality Act Air Quality Guidelines." BAAQMD, May 2017, available at: http://www.baagmd.gov/—/media/files/planning-and-research/cega/cega guidelines may2017-pdf.pdf?la=en, p. 56; see also "Recommended Methods for Screening and Modeling Local Risks and Hazards." BAAQMD, May 2011, available at: http://www.baagmd.gov/—/media/Files/Planning%20and%2OResearch/CEQA/BAAQMD%2OModeling%2OApproac h.ashx, p. 65, 86. 11 "Update to District's Risk Management Policy to Address OEHHA's Revised Risk Assessment Guidance Document." SJVAPCD, May 2015, available at: https://www.valleyair.org/busind/pto/staff-report-5-28-15.pdf, p. 8, 20, 24. 19 "Supplemental Guidelines for Preparing Risk Assessments for the Air Toxics 'Hot Spots' Information and Assessment Act," June 5, 2015, available at: http://www.agmd.gov/docs/default-source/planning/risk- assessment/ab2588-risk-assessment-guidelines.pdf?sfvrsn=6, p. 19. "Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments." OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf 21 "Air Toxics NSR Program Health Risk Assessment (HRA) Guidelines." BAAQMD, January 2016, available at: http://www.baagmd.gov/—/media/files/planning-and-research/rules-and-regs/workshops/2016/reg-2-5/hra- guidelines clean man 2016-pdf.pdf?la=en ""Risk Assessment Guidelines Guidance Manual for preparation of Health Risk Assessments." OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 8-6. 0