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in height. Each building of these buildings would have an adjacent parking structure. Two parking structures would provide 7-levels of above ground parking and two would provide 6 levels of above ground parking. The tallest point of the Project would be approximately 94 feet from the ground level, which would be at the top of the architectural trim of the 6- story buildings. The height and size of the proposed structures are also shown in the Draft EIR Figure 3-4, Proposed Site Plan and Figures 5.1-9 through 5.1-11. The tallest building structures are featured on Draft EIR Figures 5.1-10 and 5.1-1 1. The height and size of the proposed structures (including the parking structures) are evaluated on Draft EIR pages 5.1-24 through 5.1-32, which determined that the Project would not substantially degrade the existing visual character or quality of public views of the site and its surroundings and would not conflict with applicable zoning and other regulations governing scenic quality. As the information discussed by this comment is included in the EIR, and the analysis has determined that impacts would be less than significant, recirculation of the Draft EIR is not warranted. Comment 10: The comment asserts that the changes to the Project that will have new, significant undisclosed energy and air quality impacts. The comment states that the Final EIR discloses that rather than having a 24-month construction period as originally discussed, the Final EIR states that the Project will be under construction for 27 months. Response 10: The Project has always assumed a 27-month construction period, as detailed in Section 3.0, Project Description (page 3-19), of the Draft EIR. The comment refers to a typographical error on page 5.4-5 in the Draft EIR, which has been corrected in the Final EIR. In addition, the energy discussion includes other references to the 27-month construction period, which was evaluated in the air quality modeling, and is included as Appendix B of the EIR. Overall, the EIR discloses the air quality emissions and energy usage of the project, which were determined to be less than significant. No new or additional impacts related to air quality and energy would occur. Comment 11: The comment asserts that the Draft EIR fails to conduct a quantified HRA as a result of diesel particulate matter (DPM) emissions that would be emitted during project activities for nearby existing sensitive receptors. The comment asserts that the construction and operational health risk impacts posed to nearby existing sensitive receptors resulting from the proposed project need to be quantified and compared to applicable thresholds. The comment states that because the LST method can only be applied to criteria air pollutants, this method cannot be used to determine whether emissions from DPM, will result in a significant health risk impact to nearby sensitive receptors. The comment further states that the EIR should compare emissions from the project to the SCAQMD DPM emissions cancer risk threshold of 10 in one million; and has attached a screening level analysis that asserts that the Project would exceed the threshold. Response 11: The project does not propose significant operational sources of DPM emissions or other toxic air contaminants (TACs), such as freeways and high -traffic roads, commercial distribution centers, rail yards, ports, refineries, chrome platers, dry cleaners, or gasoline stations. Only diesel delivery trucks would be considered a TAC source, of which the mixed -use Project would generate a limited amount that would not result in a health risk at the nearby residential receptors. Additionally, the air quality analysis for the proposed project (Appendix B of the Draft EIR and Section 5.2, Air Quality, of the Draft EIR) evaluates both construction and operational emissions that would be generated by the proposed Project and could affect nearby existing sensitive receptors. SCAQMD does not state that construction based HRAs are required. However, as directed by SCAQMD, the local significance thresholds (LSTs) are used to evaluate potential impacts from particulate matter emissions to sensitive receptors in the project's vicinity from project construction. As shown in Table 5.2-9 of the Draft EIR, local construction related emissions would not exceed SCAQMD LST thresholds. 75C-195