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May 19, 2021 <br />Page 18 <br /> <br /> <br />5005-004acp <br /> <br /> printed on recycled paper <br />As demonstrated in the table above, SWAPE estimated the excess cancer risk <br />of approximately 124.9 in one million over the course of a residential lifetime from <br />Project construction and operation combined.77 The infant, child, adult, and lifetime <br />cancer risks all exceed the BAAQMD threshold of 10 in one million, thus resulting <br />in a potentially significant impact which is more severe than the health risk <br />identified in the Checklist, and was not previously addressed in the General Plan <br />EIR or the Checklist. <br /> <br />SWAPE concluded that the screening-level health risk analysis (“HRA”) <br />demonstrates that construction and operation of the Project could result in a <br />potentially significant health risk impact, when correct exposure assumptions and <br />up-to-date, applicable guidance are used.78 SWAPE further explains that the <br />Checklist contains no mitigation to address the Project’s operational health risk, <br />and that the Project’s construction-related health risk would not be substantially <br />mitigated by the Uniformly Applicable Development Policies because the Checklist <br />applied Tier 4 Interim emissions reductions in its health risk modeling which is not <br />required by the City’s Standard Conditions of Approval. Thus, the Project’s health <br />risk remains significant and unmitigated. <br /> <br />Since SWAPE’s screening-level HRA indicates a potentially significant <br />impact, the City should prepare an Infill EIR with an HRA which makes a <br />reasonable effort to connect the Project’s air quality emissions and the potential <br />health risks posed to nearby receptors. Thus, the City should prepare an updated, <br />quantified air pollution model as well as an updated, quantified refined HRA which <br />adequately and accurately evaluates health risk impacts associated with both <br />Project construction and operation.79 <br /> <br />General Plan Action EH-3.4.B requires a Health Risk Assessment for projects <br />near freeways and high-volume roadways, as here. But the health risk analysis in <br />the Checklist fails to satisfy General Plan requirements.80 Additionally, SWAPE <br />determined that without making a reasonable effort to connect the Project’s <br />operational TAC emissions to the potential health risks posed to nearby receptors, <br />the Project is inconsistent with CEQA’s requirement to correlate the increase in <br />TAC emissions with potential adverse impacts on human health.81 SWAPE <br /> <br />77 SWAPE Comments p. 21. <br />78 SWAPE Comments p. 22. <br />79 Id. <br />80 SWAPE Comments p. 18. <br />81 SWAPE Comments p. 17. <br />77