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The Bowery Mixed -Use Project CEQA Comment May 11, 2020 Page 5 III. ANALYSIS A. THERE IS SUBSTANTIAL EVIDENCE T'HA F THE PROJECT WILL HAVE SIGNIFICANT INDOOR AIR QUALITY IMPACTS. Certified Industrial Hygienist, Francis "Bud" Q &rmarm, PE, CIH, has conducted a review of the proposed Project and relevant documents regarding the Project's indoor air emissions. Indoor Environmental Engineering Comments (May 4, 2020) (Exhibit A). Mr. Offermann concludes that it is likely that the Project will expose residents of the Project and employees who work in the commercial space to significant impacts related to indoor air quality and in particular, emissions or the cancer -causing chemical formaldehyde. Mr. Ofi'ermann is a leading expert oa indoor air quality and has published extensively on the topic. See attached CV Mr Offorniann explains that many composite wood products used in modem apartment home eonstructien contain forrnaldchyde-based glues which off -gas formaldehyde over a very long time period. He states, "'fhe primary source of formaldehyde indoors is composite wood products manufactured with urea -formaldehyde resins, such as plywood, medium density fiberboard, and particleboard_ These materials arc commonly used in building construction for flooring, cabinetry, baseboards, window shades, interior doors, and window and door trims." Offennann, pp. 2-3. Formaldehyde is a known human carcinogen. Mr. Offemiann states that there is a fair argument that future residents of the Project will be exposed to a cancer risk from formaldehyde of approximately 112 per million, assuming all materials are compliant with the California Air Resources Board's formaldehyde airborne toxic. control measure. Id., p. 3-4. This more than 11 times the South Coast Air Quality Management District's ("SCAQMD") CEQA significance threshold for airborne cancer risk of 10 per million. In addition, Mr. Offermann concludes that people working the commercial spaces of the Project will be exposed to an increased cancer risk from formaldehyde of 16.4 per million, which also exceeds the threshold of significance. Id. at 5. Mr. Otfennann concludes that these significant envirolunental impacts must be analyzed in the FIR and mitigation measures should be imposed to reduce the risk of formaldehyde exposum. Id_, p. 4-5. Mr. Offermann also notes that the high cancer risk that may be posed by the Project's indoor air emissions likely will be exacerbated by the additional cancer risk that cxisla as a result of the Project's location near roadways with moderate to high traffic (i.e. CA-55, Carnegie Avenue, Warner Drive, Red I till Avenuc, and Pullman Street) and the high levels of PM 2.5 already present in the ambient air. 011ermamr, pp. 10-11. No analysis ha& been conducted of the significant curnulalivo health impacts that will result to Ihlure residents orlhe Project Mr. Offermann identifies mitigation measures that are available to reduce these significant health risks, including the preferred mitigation measure that would require the applicant use only composite wood materials (e_g. hardwood plywood, medium density 75C-21