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"California Office of Environmental Health Hazard Assessment has not identified short-term health effects from DPM. Construction activities would be temporary and transient throughout the site (i.e., move from location to location), and would not generate emissions in a fixed location for extended periods of time. Construction activities would also be subject to and would comply with California regulations limiting the idling of heavy-duty construction equipment to no more than five minutes to further reduce nearby sensitive receptors' exposure to temporary and variable DPM emissions. As such, project construction DPM impacts to sensitive receptors would be less than significant and would not result in a substantial increase in the severity of DMP impacts beyond those analyzed in the 2010 FEIR" (p. 3.2-7). However, the Addendum's evaluation of the Project's health risk impacts, as well as the subsequent less than significant impact conclusion, is incorrect for four (4) reasons. First, the Addendum's claims that the health risk impacts associated with Project construction would be less than significant because Project construction "would be temporary and transient," "would not generate emissions in a fixed location for extended periods of time," and "would also be subject to and would comply with California regulations limiting the idling of heavy-duty construction equipment" are unsupported. As the Addendum fails to provide substantial evidence, including sources or calculations, to substantiate these claims, we are unable to verify that they are correct. Without providing a quantified construction HRA, the Addendum lacks substantial evidence to demonstrate that health risk impacts associated with Project construction would be less than significant. Second, by failing to prepare a construction HRA, the Project is inconsistent with the most recent guidance published by the Office of Environmental Health Hazard Assessment ("OEHHA"), the organization responsible for providing guidance on conducting HRAs in California. OEHHA released its most recent Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments in February 2015Y This guidance document describes the types of projects that warrant the preparation of an HRA. Construction of the Project will produce emissions of diesel particulate matter ("DPM"), a human carcinogen, through the exhaust stacks of construction equipment over a construction period of approximately 21- to 24-months (p. 2-11). The OEHHA document recommends that all short-term projects lasting at least two months be evaluated for cancer risks to nearby sensitive receptors." As the Project's proposed 21- to 24-month construction duration vastly exceeds the 2-month requirement set forth by OEHHA, it is clear that the Project meets the threshold requiring a quantified HRA under OEHHA guidance (p. 2-11). Thus, we recommend that health risk impacts from Project construction be evaluated in an EIR, per OEHHA guidelines, in order to determine the nature and extent of the Project's health risk impacts. Third, the Addendum fails to mention or evaluate the potential health risk impacts associated with Project operation whatsoever. As previously stated, the TIA indicates that Project operation would 17 "Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments." OEHHA, February 2015, available at: htti)://oehha.ca.aov/air/hot spots/hotspots2015.html 18 "Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments." OEHHA, February 2015, available at: htti)://oehha.ca.aov/air/hot spots/2015/2015GuidanceManual.pdf. p. 8-18 14 75C-89