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4th and Mortimer CEQA Addendum October 12, 2020 Page 8 of 15 D. THE ADDENDUM'S CONCLUSIONS ARE NOT SUPPORTED BY SUBSTANTIAL EVIDENCE AND THERE IS SUBSTANTIAL EVIDENCE OF A FAIR ARGUMENT THAT THE PROJECT WILL HAVE SIGNIFICANT ENVIRONMENTAL IMPACTS. Even if the addendum provisions applied to the Project (which they do not), a supplemental EIR would be required to analyze new significant impacts of the Project resulting from changes to the 2010 Project and new impacts that were not analyzed in the 2010 EIR. 1. There is Substantial Evidence that the Project Will Result in 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 (Exhibit A). Mr. Offerman concludes that it is likely that the Project will expose future residents of the Project's residential units to significant impacts related to indoor air quality, and in particular, emissions of the cancer -causing chemical formaldehyde. Mr. Offermann is one of the world's leading experts on indoor air quality and has published extensively on the topic. See attached CV. Mr. Offermann explains that many composite wood products typically used in modern 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 particle board. These materials are commonly used in building construction for flooring, cabinetry, baseboards, window shades, interior doors, and window and door trims." Offermann Comment, pp. 2-3. Mr. Offermann states: Indoor air quality in homes is particularly important because occupants, on average, spend approximately ninety percent of their time indoors with the majority of this time spent at home (EPA, 2011). Some segments of the population that are most susceptible to the effects of poor IAQ, such as the very young and the elderly, occupy their homes almost continuously. Additionally, an increasing number of adults are working from home at least some of the time during the workweek. Offermann Comment, p. 1. Formaldehyde is a known human carcinogen. Mr. Offermann states that there is a fair argument that residents of the Project will be exposed to a cancer risk from formaldehyde of between 112 and 180 per million. (Offermann Comment, pp. 2-3.) This is far above the South Coast Air Quality Management District (SCAQMD) CEQA 75C-27