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75C - PH - THE BOWERY
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8/13/2020 5:10:27 PM
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8/13/2020 4:53:25 PM
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City Clerk
Doc Type
Agenda Packet
Agency
Planning & Building
Item #
75C
Date
8/18/2020
Destruction Year
2025
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percent of the residences did not use their windows during the entire preceding week. The comment asserts <br />that because the Project is located near high traffic roadways that generate noise, the Project will require <br />mechanical supply of outdoor air ventilation air to allow for a habitable interior environment with closed <br />windows and doors. <br />Response 23: Refer to Response to Comment 21. Based on this comment a majority (68 percent) of <br />residences opened windows the day of the testing and 85 percent opened their windows during the week <br />of the testing. Thus, the study indicates that a majority of study residences had open windows at least part <br />of the time. In addition, as described by previous responses, building ventilation with air filtration systems <br />that equal to or exceed California Building Code requirements would be installed. Thus, the proposed <br />Project includes a mechanical supply of filtered outdoor air ventilation air for all of the residences. <br />Comment 24: This comment states that traffic associated with the Project would result in increased outdoor <br />concentrations of PM2.5 and that the Project is within a non -attainment area for PM2.5, and that an air <br />quality analysis should be conducted to determine concentrations of PM2.5 and consider cumulative impacts. <br />The comment further states that if outdoor concentrations exceed state and national standards, a <br />mechanical air filtration system for PM2.5 concentrations should be used. <br />Response 24: As described in Draft EIR Section 5.2, Air Quality, the South Coast Air Quality Management <br />District (SCAQMD) maintains monitoring stations that monitor air quality and compliance with associated <br />ambient standards. The Project site is located within the monitoring boundary of the Central Orange <br />County monitoring station (SRA 17), which is 10.2 miles northwest of the Project site. As detailed on Draft <br />EIR page 5.2-9, in 2018 the concentrations of PM2.5 exceeded standards for 3 days. Thus, the level of <br />PM2.5 in the Project area is limited. <br />In addition, as shown in Draft EIR Tables 5.2-7 through 5.2-9, implementation of the Project would not <br />result in exceedances of PM2.5 thresholds. Thus, impacts related to PM2.5 emissions would not occur from the <br />Project. Also, as described in Response 19, the proposed Project includes building ventilation with air <br />filtration systems that equal to or exceed the California Building code. <br />Comment 25: This comment provides recommended mitigation measures to reduce indoor formaldehyde <br />concentrations, which includes: 1) use of only composite wood materials that are CARB approved no - <br />added formaldehyde (NAF) resins or ultralow emitting formaldehyde (ULEF) resins, or complete the <br />previously provided emissions assessment to determine formaldehyde concentrations; 2) provide all <br />habitable rooms with a continuous mechanical supply of outdoor air that meets or exceeds the California <br />2016 Building Energy Efficiency Standards; and 3) install air filtration with a minimum efficiency of MERV <br />13 to filter the outdoor air entering the mechanical outdoor air supply system. <br />Response 25: As described in Responses to Comments 19, 21, and 22, the levels of indoor formaldehyde <br />within Project buildings would not exceed the SCAQMD significance threshold of 10 per million and the <br />Project would result in less than significant impacts related to formaldehyde. Therefore, no mitigation is <br />required. However, as required by the U.S. EPA and CARE, the proposed Project would utilize products <br />that have to be manufactured or imported pursuant to TSCA Title VI and California Proposition 65 safe <br />harbor standards. In addition, the Project includes air filtration systems with efficiencies equal to or <br />exceeding the California Building Code requirements. <br />Comment 26: This comment provides a discussion regarding CARB ATCM regulations related to <br />formaldehyde and states that it does not regulate the formaldehyde emissions from composite wood <br />products. The comment also states that if CARB Phase 2 compliant composite wood products are utilized in <br />construction, then emissions assessment to determine formaldehyde concentrations should be completed or <br />75C-117 <br />
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