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Cabrillo Town Center Project City of Santa Ana October 2, 2023 Page 4 of 6 the Project. Mr. Offermann is one of the world's leading experts on indoor air quality, in particular emissions of formaldehyde, and has published extensively on the topic. As discussed below and set forth in Mr. Offermann's comment, the Project's emissions of formaldehyde to air will result in very significant cancer risks to future residents and employees of the Project. Mr. Offermann's comment and CV are attached as Exhibit A. Formaldehyde is a known human carcinogen and listed by the State of California as a Toxic Air Contaminant ("TAC"). The South Coast Air Quality Management District ("SCAQMD") has established a significance threshold of health risks for carcinogenic TACs of 10 in a million. (Ex. A, p. 2.) Mr. Offermann explains that many composite wood products typically used in home and apartment building 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 particle board. These materials are commonly used in residential, office, and retail building construction for flooring, cabinetry, baseboards, window shades, interior doors, and window and door trims." (Id., p. 3.) Mr. Offermann concludes that future residents of the Project will be exposed to a cancer risk from formaldehyde of approximately 120 per million, even assuming that all materials are compliant with the California Air Resources Board's ("CARB") formaldehyde airborne toxics control measure. (Ex. A, p. 4.) This exceeds SCAQMD's CEQA significance threshold for airborne cancer risk of 10 per million. Importantly, Mr. Offermann's conclusions are based on studies conducted in 2019 and therefore were not available when the 2007 EIR or 2018 SEIR were approved. Mr. Offermann concludes that these significant environmental impacts must be analyzed and mitigation measures should be imposed to reduce the risk of formaldehyde exposure. (Ex. A, pp. 5-7, 13-14.) He prescribes a methodology for estimating the Project's formaldehyde emissions to do a more project -specific health risk assessment. (Id., pp. 7-9.). Importantly, the previous 2007 EIR and 2018 SEIR did not address indoor air quality impacts or formaldehyde emissions. Because these impacts were not previously analyzed at all, the fair argument standard applies and an EIR is required to address and mitigate this impact. When a Project exceeds a duly adopted CEQA significance threshold, as here, this alone establishes substantial evidence that the project will have a significant adverse environmental impact. Indeed, in many instances, such air quality thresholds are the only criteria reviewed and treated as dispositive in evaluating the significance of a project's air quality impacts. (See, e.g. Schenck v. County of Sonoma (2011) 198 Cal.AppAth 949, 960 [County applies Air District's "published CEQA quantitative criteria" and "threshold level of cumulative significance"]; see also Communities for a Better Environment v. California Resources Agency (2002) 103 Cal.AppAth 98, 110-111 ["A `threshold of significance' for a given environmental effect is simply that level at which the lead agency finds the effects of the project to be significant"].) The California Supreme Court made clear the substantial importance that an air district