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

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Second, while the Staff Report estimates the cancer risk posed to people that will be housed on the Project site as a result of proximity to nearby roadways, the Staff Report fails to quantify the risk posed to people living nearby the Project site as a result of Project construction and operation. Construction of the Project will produce emissions of diesel particulate matter ("DPM"), a human carcinogen, through the exhaust stacks of construction equipment. By failing to prepare a health risk assessment ("HRA") for Project construction, the Staff Report 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 2015.' This guidance document describes the types of projects that warrant the preparation of an HRA. The OEHHA document recommends that all short-term projects lasting at least two months be evaluated for cancer risks to nearby sensitive receptors.' While we were not provided the length of the Project's construction period, based on the size of the Project, we can reasonably assume that it would exceed the 2-month requirement set forth by OEHHA, thus requiring a quantified HRA per OEHHA guidance (p. 2-11). Furthermore, the Revised Traffic Impact Analysis Report ("TIA") indicates that Project operation would generate 4,121 daily vehicle trips, which will generate additional exhaust emissions and continue to expose nearby, existing sensitive receptors to DPM emissions (p. 1-146). The omission of a quantified operational HRA is inconsistent with the most recent guidance published by OEHHA. The OEHHA document recommends that exposure from projects lasting more than 6 months be evaluated for the duration of the project, and recommends that an exposure duration of 30 years be used to estimate individual cancer risk for the maximally exposed individual resident ("MEIR").' Even though we were not provided with the expected lifetime of the Project, we can reasonably assume that the Project will operate for at least 30 years, if not more. Therefore, we recommend that health risk impacts from Project operation also be evaluated, as a 30-year exposure duration vastly exceeds the 6-month requirement set forth by OEHHA. These recommendations reflect the most recent state health risk policies, and as such, we recommend that an EIR be prepared, including an assessment of health risk impacts posed to nearby, existing sensitive receptors from Project construction and operation. 3) Screening -Level Analysis Demonstrates Significant Health Risk Impacts In an effort to estimate the emissions associated with construction and operation of the Project, we prepared a CalEEMod model, using the Project -specific information provided by the Staff Report. In our model, we included 644 residential units as "Apartments Mid Rise," 11,700-SF of "Regional Shopping Center," 3,500-SF of "High Turnover (Sit Down Restaurant)," and 1,318 parking spaces as "Enclosed ' "Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments." OEHHA, February 2015, available at: http://oehha.ca.gov/air/hot spots/hotspots2015.html 8 "Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments." OEHHA, February 2015, available at: http://oehha.ca.gov/air/hot spots/2015/2015GuidanceManual.pdf, p. 8-18 ' "Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments." OEHHA, February 2015, available at: http://oehha.ca.gov/air/hot spots/2015/2015GuidanceManual.pdf, p. 8-6, 8-15 N