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City of Sams Ana -The Bowery May 11, 2020 Urge 10 of 2s D. 'Ibc IiI It Pails to Disclose SiWufican 1. and Umniligatcd Iinvimnmuival Impacts Relating to Air Quality As stated alinve, an FIR must disclose, evaluate, and ultimately provide feasible mitigation measures for significant environmental impacts. Here, the FIR fails to disclose sifmi(icanL impacL$ relating to Construction and operational health risks. According to Mr. Hagemann and Dr. Rosenfeld, the DFIR finds a less than significant impact "without conducting a quantified construction or health risk assessment" which the DRIR incorrectly justified. Mt. Hagemann and Dr. Rosenfeld make the following three points on the DEIR Air Quality analysis: the use of the LST method to determine the Projects health risk impacts on nearby, existing sensitive receptors is incorrect, While the LST method assesses the impact of pollutants at a local level, it only evaluates impacts from criteria air pollutants. According to the Final Localized Significance Threshold Methodology document prepared by the SCAQMD, the LST analysis is only applicable to NOx, CO, PM10, and PM2.5 emissions, which are collectively referred to as criteria air pollutants. Because the LST method can onlybe applied to criteria air pollutants, this method cannot be used to determine whether emissions from DPM, a known human carcinogen, will result in a sibmifrcant health risk impact to nearby sensitive receptors_ As a result, health impacts from exposure to toxic air contaminants (PACs), such as diesel particulate matter (DPM), were not analyzed, thus leaving a gap within the DEIR's analysis. I.he omission of a quantified IIRA is inconsistent with the most recent guidance published by the Office of I?nvironmenlal I lealth IIazaxd Assessment (CIr1111A), the organization responsible for providing guidance on conductingHRAs in California. In Ecbruan of 2015, ORHITA released its most recent Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments. This guidance document describes the types of projects that warrant the preparation of an ITR_A. Construction of the Project will produce emissions of DPM, a human carcinogen, through the exhaust stacks of construction equipment over a 75C-130