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

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dimensions of 194.5 by 167 meters. A release height of three meters was selected to represent the height of exhaust stacks on operational equipment and other heavy-duty vehicles, and an initial vertical dimension of one and a half meters was used to simulate instantaneous plume dispersion upon release. An urban meteorological setting was selected with model -default inputs for wind speed and direction distribution. The AERSCREEN model generates maximum reasonable estimates of single -hour DPM concentrations from the Project site. EPA guidance suggests that in screening procedures, the annualized average concentration of an air pollutant be estimated by multiplying the single -hour concentration by 10%.13 Review of the AERSCREEN output files and Google Earth demonstrates that the MEIR is located approximately 125 meters from the Project site. Thus, the single -hour concentration estimated by AERSCREEN for Project construction is approximately 3.357 µg/m3 DPM at approximately 125 meters downwind. Multiplying this single -hour concentration by 10%, we get an annualized average concentration of 0.3357 µg/m3 for Project construction at the MEIR. For Project operation, the single - hour concentration estimated by AERSCREEN is 22.52 µg/m3 DPM at approximately 125 meters downwind. Multiplying this single -hour concentration by 10%, we get an annualized average concentration of 2.252 µg/m3 for Project operation at the MEIR. We calculated the excess cancer risk to the MEIR using applicable HRA methodologies prescribed by OEHHA. Consistent with the default CalEEMod construction schedule, the annualized average concentration for Project construction was used for the entire third trimester of pregnancy (0.25 years) and the first 0.97 years of the infantile stage of life (0 - 2 years). The annualized averaged concentration for operation was used for the remainder of the 30-year exposure period, which makes up the remaining 1.03 years of the infantile stage of life, the entire child stage of life (2 -16 years), and the entire the adult stage of life (16 - 30 years). Consistent with OEHHA, as recommended by the SCAQMD, BAAQMD, and SJVAPCD guidance, we used Age Sensitivity Factors ("ASF") to account for the heightened susceptibility of young children to the carcinogenic toxicity of air pollution.",1s,16 According to this guidance, the quantified cancer risk should 13 "Screening Procedures for Estimating the Air Quality Impact of Stationary Sources Revised." EPA, 1992, available at: http://www.epa.gov/ttn/scram/guidance/guide/EPA-454R-92-019 CCR.pdf; see also "Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments." CEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf p. 4-36. 14 "Draft Environmental Impact Report (DEIR) for the Proposed The Exchange (SCH No. 2018071058)." SCAQMD, March 2019, available at: http://www.agmd.gov/docs/default-source/cega/comment- letters/2019/march/RVC190115-03.pdf?sfvrsn=8, p. 4. 11 "California Environmental Quality Act Air Quality Guidelines." BAAQMD, May 2017, available at: http://www.baagmd.gov/-/media/files/planning-and-research/cega/cega guidelines may2017-pdf.pdf?la=en, p. 56; see also "Recommended Methods for Screening and Modeling Local Risks and Hazards." BAAQMD, May 2011, available at: http://www.baagmd.gov/-/media/Files/Planning%20and%20Research/CEQA/BAAQMD%20Modeling%20Approac h.ashx, p. 65, 86. 16 "Update to District's Risk Management Policy to Address CEHHA's Revised Risk Assessment Guidance Document." SJVAPCD, May 2015, available at: https://www.valleyair.org/busind/pto/staff-report-5-28-15.pdf, p. 8, 20, 24. 10