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22 threshold of 10 in one million, thus resulting in a potentially significant impact not addressed in the General Plan EIR nor identified by the Checklist. An agency must include an analysis of health risks that connects the Project’s air emissions with the health risk posed by those emissions. Our analysis represents a screening‐level HRA, which is known to be conservative and tends to err on the side of health protection. 39 The purpose of the screening‐level construction and operational HRA shown above is to demonstrate the link between the proposed Project’s emissions and the potential health risk. Our screening‐level HRA demonstrates that construction and operation of the Project could result in a potentially significant health risk impact, when correct exposure assumptions and up‐to‐date, applicable guidance are used. Therefore, since our screening‐level HRA indicates a potentially significant impact, the City should prepare a full CEQA analysis with an HRA which makes a reasonable effort to connect the Project’s air quality emissions and the potential health risks posed to nearby receptors. Thus, the City should prepare an updated, quantified air pollution model as well as an updated, quantified refined HRA which adequately and accurately evaluates health risk impacts associated with both Project construction and operation. Greenhouse Gas Failure to Adequately Evaluate Greenhouse Gas Emissions The Checklist estimates that the Project would generate net annual construction‐related and operational greenhouse gas (“GHG”) emissions of 472 metric tons of carbon dioxide equivalents per year (“MT CO2e/year”) (see excerpt below) (p. 4‐55, Table 4‐8). 39 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 1‐5 137