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In addition, page 5.2-18 of the Draft EIR describes that the highest trips on a segment of road with the Project traffic is 9,378 vehicles per hour on Jamboree Road and Barranca Parkway. This is much lower than 44,000 vehicles per hour and is not high enough to generate a CO "hot spot" per SCAQMD. Therefore, impacts related to CO "hot spots" that could affect health from operation of the proposed Project would be less than significant. A HRA analyzing the project's construction emissions of diesel particulate matter is not warranted. The primary purpose of an HRA is to determine long-term health risks, such as cancer risks over, for example, a 30-year residency or 70-year lifetime. As discussed in the EIR, construction of the project would take 27 months. Exposure of such duration would not create long-term health effects to adjacent receptors. Additionally, the City follows SCAQMD guidance for air quality analysis. SCAQMD's HRA procedures recommend evaluating risk from extended exposures measured across several years and not for short term construction exposures or for infrequent operational exposure to diesel truck deliveries or trash hauling. I Urban Crossroads, Inc. has also reviewed the referenced OEHHA Guidance Manua12 to determine applicability of the use of early life exposure adjustments to diesel particulate matter (DPM) emissions resulting from construction activity. Specifically, the OEHHA Guidance states "Due to the uncertainty in assessing cancer risk from very short- term exposures, we do not recommend assessing cancer risk for projects lasting less than two months at the MEIR. We recommend that exposure from projects longer than 2 months but less than 6 months be assumed to last 6 months (e.g., a 2-month project would be evaluated as if it lasted 6 months)." (2015 Guidance Manual p. 8-18 [emphasis added].) As such, the determination of whether a construction HRA is warranted is dependent on whether or not early life exposure adjustments apply to DPM emissions resulting from construction activity. The following discussion outlines the substantial evidence to support why early life exposure adjustments are not applicable to construction DPM and therefore a construction health risk assessment is not required due to the short-term duration of construction activity (long-term exposure e.g. 9 or 30 years of activity are typically used to generate a risk estimates). For risk assessments conducted under the auspices of The Air Toxics "Hot Spots" Information and Assessment Act of 1987 (AB 2588), OEHHA applies specific adjustment factors to all carcinogens regardless of purported mechanism of action. Notwithstanding, applicability of AB 2588 is limited to commercial and industrial operations. There are two broad classes of facilities subject to the AB 2588 Program: 1) Core facilities and 2) facilities identified within discrete industry -wide source categories. Core facilities subject to AB 2588 compliance are sources whose criteria pollutant emissions (particulate matter, oxides of sulfur, oxides of nitrogen and volatile organic compounds) are 25 tons per year or more as well as those facilities whose criteria pollutant emissions are 10 tons per year or more but less than 25 tons per year. Industry- wide source facilities are classified as smaller operations with relatively similar emission profiles (e.g., auto body shops, gas stations and dry cleaners using perchloroethylene). The emissions generated from off - road mobile sources are not classified in AB 2588 as core operations nor subject to industry -wide source evaluation. In comments presented to the South Coast Air Quality Management District (SCAQMD) Governing Board (Meeting Date: June 5, 2015, Agenda No. 28) relating to toxic air contaminant exposures under Rules 1401, 1401.1, 1402 and 212 revisions, use of the OEHHA Guidelines specifically related to the SCAQMD. 2015. Risk Assessment (RA) Procedures for Rules IAOI and 212. Accessed July 2017 at http://www.agmd.gov/home/permits/risk- assessment; SCAQMD. 2016. AB2588 Supplemental Guidelines. Accessed July 2017 at http://www.agmd.gov/home/regulations/co mp li once/toxic-hot-spots-ob-2588/health-risk-assessment ' http://oehho.co.gov/air/hot_Spots/hotspots20l 5.html 75C-196