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required to meet new emission standards for formaldehyde from composite wood products in order to reduce exposures to formaldehyde and avoid adverse health effects. Typical composite wood products include hardwood plywood, medium -density fiberboard, and particleboard, as well as household and other finished goods containing these products. The new emission limits include the following: • Hardwood Plywood: 0.05 parts per million (ppm) • Particleboard: 0.09 ppm • Medium -density fibreboard: 0.1 1 ppm • Thin Medium -density fibreboard: 0.13 ppm These emission levels were determined to be incompliance with and result in less exposure (e.g., daily intake) than the California Proposition 65 safe harbor level for formaldehyde (40 µg/day), which is based on Proposition 65's risk criterion of 1 in 100,000. Thus, products manufactured to TSCA Title VI and California Proposition 65 safe harbor standards, which is now required by the U.S. EPA for all products manufactured or imported into the United States, would not generate formaldehyde emissions that would exceed the SCAQMD significance threshold of 10 per million. CARB identifies that these standards are projected to lead to a reduction in statewide formaldehyde emissions of 500 tons per year. Reduced risk of cancer from formaldehyde exposure is also a resulting benefit, and implementation of these standards is estimated to reduce excess cancer cases per million people from formaldehyde exposure by about 40 percent (https://www.arb.ca.gov/toxics/compwood/implementation/faq.htm#G). The CalGreen Building Code also includes similar formaldehyde limits for building products. The Project would be implemented pursuant to these formaldehyde requirements, as all products manufactured or imported in the United States would be required to meet these regulations. This would limit the potential of human health and cancer risks to a less than significant level pursuant to the SCAQMD significance threshold of 10 per million. Thus, building material manufacturer compliance with existing regulations would avoid potentially significant impacts related to formaldehyde. Thereby, the Project would also result in less than significant impacts. Comment 5: This comment states that the City has the duty to investigate potential environmental impacts related to formaldehyde emissions to reduce the cancer risk below the SCAQMD threshold. The comment provides references to case law and statutes related to assessing potential health impacts and asserts that the Project would generate substantial formaldehyde emissions. The comment further states that the information provided establishes a fair argument that the Project will have a significant adverse environmental impact and a revised EIR is required. Response 5: As described above in Response 4, the Project would not exceed SCAQMD thresholds for formaldehyde, and health risks or other substantial adverse effects on human beings related to formaldehyde would not occur from the Project. Thus, mitigation measures would not be required. In addition, the comment does not constitute substantial evidence of a fair argument of a significant environmental impact. Comment 6: This comment states that attached comments of traffic engineer Dan Smith indicate that the Project will have significant impacts on traffic and that the EIR relies on a hypothetical traffic baseline rather than conditions that exist at the time environmental analysis begins. The comment provides references to case law and statutes related to baseline conditions and states that rather than relying on 75C-108