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that the primary source of formaldehyde indoors is composite wood products manufactured with urea - formaldehyde resins, and that the CARB standards adopted in 2009 have reduced emissions from composite wood products sold in California, but they do not preclude that homes built with composite wood products meeting the CARB ATCM will have indoor formaldehyde concentrations that are below cancer and non -cancer exposure guidelines. Response 20: Refer to Response 19. The U.S. EPA requires all products manufactured or imported into the United States to meet TSCA Title VI and California Proposition 65 safe harbor standards that include regulations related to composite wood products manufactured with urea -formaldehyde resins, would preclude the Project from resulting in indoor formaldehyde emissions that would exceed the SCAQMD significance threshold of 10 per million. Thus, impacts would be less than significant. 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 38 percent, the median lifetime cancer risk is still 112 per million for homes built with CARB compliant composite wood products which is more than 11 times the 10 in a million threshold. The comment also states that employees on the site would have a cancer risk of 16.4 per million, which exceeds the CEQA cancer risk of 10 per million and that the EIR should impose mitigation measures to reduce this impact. 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/gt2xg7s5nv/gt2xg7s5nv.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 California Building Code regulations. Thus, the lack of ventilation that occurred during the studies referenced by this comment would not occur in the proposed Project. 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 and no mitigation measures would be required. Comment 22. This comment states that a formaldehyde emissions assessment should be used in the environmental review under CEQA to assess the indoor formaldehyde concentrations from the proposed loading of building materials/furnishings and minimum air ventilation rates. The comment also provides specific methodology to determine formaldehyde concentrations, and states that the methodology ensures that the materials and furnishings would have acceptable cancer risks related to formaldehyde off gassing. Response 22: Refer to Response to Comment 19. The U.S. EPA requires all products manufactured or imported into the United States to meet TSCA Title VI and California Proposition 65 safe harbor standards that include regulations related to composite wood products manufactured with urea -formaldehyde resins, would preclude the Project from resulting in indoor formaldehyde emissions that would exceed the SCAQMD significance threshold of 10 per million. Thus, impacts would be less than significant, and the formaldehyde emissions assessment described by the comment is not required. Comment 23: 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 75C-116