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■ Any problems with the equipment or emission controls. <br />■ Certified copies of fuel deliveries for the time period that identify: <br />• Source of supply <br />• Quantity of fuel <br />• Quality of fuel, including sulfur content (percent by weight) <br />Furthermore, the following mitigation measures should be considered to reduce the Project's <br />operational criteria pollutant emissions: <br />• Site Design <br />o Incorporate urban infill, higher density, mixed use and walkable, bikeable, and transit - <br />oriented designs to significantly reduce vehicle activity and associated air quality <br />impacts. <br />• Energy Efficiency <br />o Orient buildings to maximize natural heating and cooling to reduce building energy <br />demand and reduce emissions at the power plant source and natural gas combustion in <br />homes and commercial buildings. <br />• Transportation <br />o Reduce the demand for single -occupancy vehicle trips to reduce vehicle emissions. <br />o Use cleaner fueled vehicles or retrofitting equipment with emission control devices to <br />reduce the overall emissions without impacting operations. <br />These measures offer cost-effective, feasible ways to reduce the Project's construction -related and <br />operational criteria air pollutant emissions. As additional mitigation measures are available to reduce <br />the Project's emissions, the proposed Project's reliance on the 2018 DSEIR and the subsequent <br />significant -and -unavoidable air quality impact conclusion is incorrect. A subsequent EIR should be <br />prepared and recirculated to adequately evaluate the Project's air quality impacts and implement all <br />feasible mitigation to reduce the Project's emissions to a less -than -significant levels. <br />2) Health Risk Emissions Inadequately Evaluated <br />Exhibit 11 calculates the excess cancer risk from exposure to vehicle exhaust to be 3.58 in a million, <br />which would not exceed the South Coast Air Quality Management District ("SCAQMD") significance <br />threshold of 10 in one million (p. 1-46). However, the Staff Report's evaluation of the Project's health <br />risk impacts in insufficient for two reasons. <br />First, the Staff Report's cancer risk estimate of 3.58 in one million should not be considered in isolation. <br />Additional impacts related to non -cancer health risks have been documented for those people living <br />near congested roadways. Key findings from a 2005 California Air Resources Board ("CARB") report3 on <br />health risk impacts from nearby freeways include: <br />3 "Air Quality and Land Use Handbook: A Community Health Perspective." CARB, April 2005, available at: <br />https://ww3.arb.ca.gov/ch/handbook.pdf. <br />5 <br />