3 - The Bowery_PUBLIC COMMENT_RAMSEY

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13 3rd Trimester Duration 0.25 7.3E-08 3rd Trimester Exposure 7.3E-07 Construction 1.93 0.05355 1090 1.7E-06 10 1.7E-05 Operation 0.07 0.122 1090 1.4E-07 10 1.4E-06 Infant Exposure Duration 2.00 1.8E-06 Infant Exposure 1.8E-05 Operation 14.00 0.122 572 1.5E-05 3 4.4E-05 Child Exposure Duration 14.00 1.5E-05 Child Exposure 4.4E-05 Operation 14.00 0.122 261 4.9E-06 1 4.9E-06 Adult Exposure Duration 14.00 4.9E-06 Adult Exposure 4.9E-06 Lifetime Exposure Duration 30.00 2.2E-05 Lifetime Exposure 6.8E-05 * We, along with CARB and SCAQMD, recommend using the more updated and health protective 2015 OEHHA guidance, which includes ASFs. The excess cancer risk posed to adults, children, infants, and during the third trimester of pregnancy at the closest receptor, located approximately 450 meters away, over the course of Project construction and operation, utilizing age sensitivity factors, are approximately 4.9, 44, 180, and 0.73 in one million, respectively. The excess cancer risk over the course of a residential lifetime (30 years) at the closest receptor, with age sensitivity factors, is approximately 68 in one million. The infant, child, and lifetime cancer risks, using age sensitivity factors, all exceed the SCAQMD threshold of 10 in one million, thus resulting in a potentially significant impact not previously addressed or identified by the DEIR. Results without age sensitivity factors are presented in the table above, although we do not recommend utilizing these values for health risk analysis, as they are less conservative and health-protective according to the most recent guidance. Regardless, the excess cancer risk over the course of a residential lifetime (30 years) at the closest receptor, without age sensitivity factors, is approximately 22 in one million. Thus, the Project may result in a significant impact regardless of the use of age sensitivity factors. An agency must include an analysis of health risks that connects the Project’s air emissions with the health risk posed by those emissions. Our analysis represents a screening-level HRA, which is known to be conservative and tends to err on the side of health protection. The purpose of the screening-level construction HRA shown above is to demonstrate the link between the proposed Project’s emissions and the potential health risk. Our screening-level HRA demonstrates that construction of the Project could result in a potentially significant health risk impact, when correct exposure assumptions and up- to-date, applicable guidance are used. Therefore, since our screening-level construction HRA indicates a potentially significant impact, an updated CEQA analysis should include a reasonable effort to connect the Project’s air quality emissions and the potential health risks posed to nearby receptors. Thus, an updated CEQA analysis should include a quantified air pollution model as well as an updated, quantified