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the table above, although we do not recommend utilizing these values for health risk analysis. Regardless, the excess cancer risk to adults, children, infants, and during the 3'd trimester of pregnancy at the MEIR located approximately 75 meters away, over the course of Project construction and operation, without age sensitivity factors, are approximately 9.4, 28, 12, and 0.53 in one million, respectively. The excess cancer risk over the course of a residential lifetime (30 years), without age sensitivity factors, is approximately 50 in one million. The infant, child, and lifetime cancer risks, without 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 Addendum. While we recommend the use of age sensitivity factors, health risk impacts exceed the SCAQMD threshold regardless. 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. 30 The purpose of the screening -level construction and operational 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 and operation 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 HRA indicates a potentially significant impact, the City should prepare a Project -specific EIR with an HRA which makes a reasonable effort to connect the Project's air quality emissions and the potential health risks posed to nearby receptors. Thus, the City should prepare an updated, quantified air pollution model as well as an updated, quantified refined health risk assessment which adequately and accurately evaluates health risk impacts associated with both Project construction and operation. Greenhouse Gas Failure to Adequately Evaluate Greenhouse Gas Impacts The Addendum estimates that the Project would generate net annual GHG emissions of 1,493 metric tons of CO2 equivalents per year ("MT CO2e/year') (p. 3.5-2, Table 3.5-1). As a result, the Addendum concludes that the Project would result in a service population efficiency value of 2.0 metric tons of CO2 equivalents per service population per year ("MT CO2e/SP/year"), based on a service population value of 747 people (see excerpt below) (p. 3.5-2, Table 3.5-1). ""Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments." OEHHA, February 2015, available at: https://oehha.ca.aov/media/downloads/crnr/2015auidancemanual.pdf, p. 1-5 19 75C-94