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further mitigation measures are not feasible and why approval of a project with significant unavoidable impacts is warranted." Y As you can see, an impact can only be labeled as significant and unavoidable after all available, feasible mitigation is considered. However, as previously stated, the DEIR determines that `[tlhere are no feasible mitigation measures that would reduce VOC emissions to below the SCAQM D threshold" (p. 5.2-16). However, this is incorrect, and as result, mitigation measures should be identified and incorporated, such as thosesuggested in the section of this letter titled "Feasible Mitigation Measures Available to Reduce Operational Emissions,o1° in order to reduce the Projeces air quality impacts to the maximum extent possible. Until all feasible mitigation is reviewed and incorporated into the Project, impacts from operational VOC cannot be considered significant and unavoidable. Diesel Particulate Matter Health Risk Emissions Inadequately Evaluated The DEIR concludes that the Projeces construction and operational health risk impacts would be less than sign!ificant without conducting a quantified construction or operational health risk assessment IHRA). More specifically, the DEIR attempts to justify this claim by stating; "Aceording to SCAQMD L5T methodology, LSTs would apply to the operational phase of proposed project, if the project includes stationary sources, or attracts mobile sources that may spend long periods queuing and idling at the site (e.g., transfer facilities and warehouse buildings). The proposed project does not include such uses, and thus, due to the lack of significant stationary source emissions, no long-term localized significance threshold analysis is needed" (Appendix R, pp. 49). The DEIR goes on to state, "Results of the LST analysis indicate that, with application of mitigation, the Project will not exceed the SCAQMD localized significance thresholds during construction. Therefore, sensitive receptors would not be exposed to substantial criteria pollutant concentration during Project construction. Results of the LST analysis indicate that the Project will not exceed the SCAQMD localized significance thresholds during operational a ctivity...Therefore, sensitive receptors would not be exposed to substantial pollutant concentrations as the result of Project operations" (Appendix R, pp. 54). However, these justifications and subsequent less than significant impact finding are incorrect [Of several reasons. First, the use of the LST method to determine the Projects health risk impacts on nearby, existing sensitive receptors is incorrect. While the L.ST method assesses the impact of pollutants at a local level, it onlyevaluates 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 NO„ s hup,tYwww.vallevair.omhransoorution/GAMAQI 3-19-15.odf. P. 115 of 125 °"5aa sMinn tidad "Faatihl> Mitigation M>asures gvaiUhle Pn Rath ma ❑porn Hnnal Emissions" on p 19 of Yhis comment letter. These measures would effectively reduce operational VQG emissions. 34 35 75C-176