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The Bowery Mixed -Use Project CEQA Comment May 11, 2020 Page 5 III. ANALYSIS A. THERE IS SUBSTANTIAL EVIDENCE THAT THE PROJECT WILL HAVE SIGNIFICANT INDOOR AIR QUALITY IMPACTS. Certified Industrial Hygienist, Francis "Bud" Offermann, 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 of the cancer -causing chemical formaldehyde. Mr. Offermann is a leading expert on indoor air quality and has published extensively on the topic. See attached CV. Mr. Offermann explains that many composite wood products used in modern apartment home construction contain formaldehyde -based glues which off -gas formaldehyde over a very long time period. He states, "The primary source of formaldehyde indoors is composite wood products manufactured with urea -formaldehyde resins, such as plywood, medium density fiberboard, and particleboard. These materials are commonly used in building construction for flooring, cabinetry, baseboards, window shades, interior doors, and window and door trims." Offermann, pp. 2-3. Formaldehyde is a known human carcinogen. Mr. Offermann 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 toxics 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. Offermann concludes that these significant environmental impacts must be analyzed in the EIR and mitigation measures should be imposed to reduce the risk of formaldehyde exposure. 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 exists as a result of the Project's location near roadways with moderate to high traffic (i.e. CA-55, Camegie Avenue, Warner Drive, Red Hill Avenue, and Pullman Street) and the high levels of PM 2.5 already present in the ambient air. Offermann, pp. 10-11. No analysis has been conducted of the significant cumulative health impacts that will result to fixture residents of the 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