Item 27 - Appeal Application Nos. 2020-03 and 2020-04 - Central Pointe Mixed-Use Development

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Central Pointe Mixed -Use Development Project November 9, 2020 Page 8 of 14 mitigation measures that are considerably different from those analyzed in the previous EIRs would substantially reduce one or more significant effects on the environment. VI. THERE IS SUBSTANTIAL EVIDENCE OF NEW INFORMATION OF SUBSTANTIAL IMPORTANCE, WHICH WAS NOT KNOWN AND COULD NOT HAVE BEEN KNOWN WITH THE EXERCISE OF REASONABLE DILIGENCE AT THE TIME THE MEMU EIR WAS CERTIFIED AS COMPLETE SHOWING THE PROJECT WILL HAVE A SIGNIFICANT HEALTH RISK IMPACT FROM ITS INDOOR AIR QUALITY NOT DISCUSSED IN THE MEMU EIR. Certified Industrial Hygienist, Francis "Bud" Offermann, PE, CIH, conducted a review of the proposed Project and relevant documents regarding the Project's indoor air emissions. Indoor Environmental Engineering Comments (November 3, 2020) (Exhibit B). Mr. Offermann concludes that it is likely that the Project will expose future residents and employees of the Project to significant impacts related to indoor air quality, and in particular, emissions of the cancer -causing chemical formaldehyde. Mr. Offermann's calculations are based on new information from a study published in 2019 on formaldehyde emissions. Mr. Offermann is a leading expert on indoor air quality and has published extensively on the topic. See attached CV. Mr. Offermann explains that many composite wood products used in modern hotel 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 particleboard. These materials are commonly used in building construction for flooring, cabinetry, baseboards, window shades, interior doors, and window and door trims." Ex. B, pp. 2-3. Formaldehyde is a known human carcinogen. Mr. Offermann states that the residents and employees of the Project are expected to experience significant exposures. Id., p. 4. This exposure would result in "significant cancer risks resulting from exposures to formaldehyde released by the building materials and furnishing commonly found in offices, warehouses, residences and hotels." Id. Mr. Offermann calculates that the residents of the Project will likely be exposed to a cancer risk from formaldehyde of approximately 120 in one million, 12 times the SCAQMD significance threshold for airborne cancer risk of 10 in one million. Id., p. 5. Mr. Offermann also calculates that employees of the Project will likely be exposed to a cancer risk from formaldehyde of approximately 17.7 per million, which also exceeds the SCAQMD threshold of 10 in one million. Id., p. 4. Mr. Offermann also notes that the high cancer risk that may be posed by the Project's indoor air emissions likely will be exacerbated by the additional cancer risk that exists as a result of the Project's location in the South Coast Air Basin, which is a State and Federal non -attainment area for PM2.5. Id., p. 11. The City should conduct an air quality analysis to determine the concentrations of PM2.5 in the outdoor and indoor air that people inhale each day, and the analysis needs to consider the cumulative impacts of