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City of Santa Ana – The Bowery <br />May 11, 2020 <br />Page 10 of 28 <br />D. The EIR Fails to Disclose Significant and Unmitigated Environmental <br />Impacts Relating to Air Quality <br />As stated above, an EIR must disclose, evaluate, and ultimately provide feasible <br />mitigation measures for significant environmental impacts. Here, the EIR fails to <br />disclose significant impacts relating to construction and operational health risks. <br />According to Mr. Hagemann and Dr. Rosenfeld, the DEIR finds a less than significant <br />impact “without conducting a quantified construction or health risk assessment” which <br />the DEIR incorrectly justified. Mr. Hagemann and Dr. Rosenfeld make the following <br />three points on the DEIR Air Quality analysis: <br />• the use of the LST method to determine the Projects health risk <br />impacts on nearby, existing sensitive receptors is incorrect. While <br />the LST method assesses the impact of pollutants at a local level, it <br />only evaluates impacts from criteria air pollutants. According to the <br />Final Localized Significance Threshold Methodology document <br />prepared by the SCAQMD, the LST analysis is only applicable to <br />NOx, CO, PM10, and PM2.5 emissions, which are collectively <br />referred to as criteria air pollutants. Because the LST method can <br />only be applied to criteria air pollutants, this method cannot be used <br />to determine whether emissions from DPM, a known human <br />carcinogen, will result in a significant health risk impact to nearby <br />sensitive receptors. As a result, health impacts from exposure to <br />toxic air contaminants (TACs), such as diesel particulate matter <br />(DPM), were not analyzed, thus leaving a gap within the DEIR’s <br />analysis. <br />• the omission of a quantified HRA is inconsistent with the most <br />recent guidance published by the Office of Environmental Health <br />Hazard Assessment (OEHHA), the organization responsible for <br />providing guidance on conducting HRAs in California. In February <br />of 2015, OEHHA released its most recent Risk Assessment <br />Guidelines: Guidance Manual for Preparation of Health Risk <br />Assessments. This guidance document describes the types of <br />projects that warrant the preparation of an HRA. Construction of <br />the Project will produce emissions of DPM, a human carcinogen, <br />through the exhaust stacks of construction equipment over a