3 - The Bowery_PUBLIC COMMENT (SAFER)

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3 of 19 particleboard. These materials are commonly used in building construction for flooring, cabinetry, baseboards, window shades, interior doors, and window and door trims. In January 2009, the California Air Resources Board (CARB) adopted an airborne toxics control measure (ATCM) to reduce formaldehyde emissions from composite wood products, including hardwood plywood, particleboard, medium density fiberboard, and also furniture and other finished products made with these wood products (California Air Resources Board 2009). While this formaldehyde ATCM has resulted in reduced emissions from composite wood products sold in California, they do not preclude that homes built with composite wood products meeting the CARB ATCM will have indoor formaldehyde concentrations that are below cancer and non-cancer exposure guidelines. A follow up study to the California New Home Study (CNHS) was conducted in 2016-2018 (Chan et. al., 2019), and found that the median indoor formaldehyde in new homes mostly (69 of 70) built in 2012 or later with CARB Phase 2 Formaldehyde ATCM materials had lower indoor formaldehyde concentrations, with a median indoor concentrations of 22.4 µg/m3 (18.2 ppb) as compared to a median of 36 µg/m3 found in the 2007 CNHS. Thus, while new homes built after the 2009 CARB formaldehyde ATCM have a 38% lower median indoor formaldehyde concentration and cancer risk, the median lifetime cancer risk is still 112 per million for homes built with CARB compliant composite wood products, which is more than 11 times the OEHHA 10 in a million cancer risk threshold (OEHHA, 2017a). With respect to this project, the buildings in The Bowery Mixed-Use Project in Santa Ana, CA consist of residential and commercial retail and restaurant spaces. The residential occupants will potentially have continuous exposure (e.g. 24 hours per day, 52 weeks per year). These exposures are anticipated to result in significant cancer risks resulting from exposures to formaldehyde released by the building materials and furnishing commonly found in residential construction.