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Response to Supporters Alliance for Environmental Responsibility (SAFER) Letter dated October 2, 2023 Response to Comment No. 1 It should be noted at the outset that the alleged impact of formaldehyde on the future residents of the Project is not relevant to CEQA. The Supreme Court's holding in California Building Industry Assn v. Bay Area Air Quality Mgmt. Dist. (2015) 62 Cal.4th 369, 386 found that CEQA does not require a project to evaluate the impact of the existing environment on future residents of the Project, unless the Project exacerbates the impact. There is no evidence that there is an existing formaldehyde issue at the Project site or that the Project could result in any exacerbation of any such issue. Mr. Offermann claims that the Project would expose residents and commercial employees of the Project to airborne cancer risks in excess of 10 per million due to formaldehyde emissions and that this would constitute a significant impact. In his letter, Mr. Offermann introduces the correlation between indoor formaldehyde concentrations and excess cancer cases by citing the results of the 2009 California New Home Study (CNHS), which he authored. Though this introduction has limited relevance to the comment's claims regarding the Project's alleged airborne cancer risk due to formaldehyde emissions, one statement merits a brief clarifying discussion. Mr. Offermann notes that in his CNHS study of "108 new homes in California," the median indoor formaldehyde concentration was 36 pg/m3. "Therefore," he claims, "the cancer risk of a resident living in a California home with the median indoor formaldehyde concentration of 36 pg/m3, is 180 per million as a result of formaldehyde alone." The wording of this statement comes close to suggesting that the median indoor formaldehyde concentration of a California home is 36 fag/m3. Whether this is the intended meaning or not, such a conclusion would not be supported by the results of Mr. Offermann's CNHS study, which was limited to single-family homes that were built between 2002 and 2004. The study itself refrains from inferring such a broad conclusion, and there is no evidence that such a narrowly tailored selection of study homes — specifically, detached single-family homes constructed over a three-year period nearly 20 years ago — should be broadly representative of statewide conditions. Mr. Offermann then engages in a series of inaccurate statements and unfounded speculation in his process of surmising the Project's future indoor formaldehyde concentration and the risk it may pose to future Project residents and employees. In this process, Mr. Offermann relies heavily on a 2020 paper by Singer et al.' that presents the methods and results of the Healthy Efficient New Gas Home (HENGH) study. Mr. Offermann is also credited as a co-author to this paper. The discussion below explains why each step in Mr. Offermann's process is variously misguided, erroneous, or unsupported by fact. Mr. Offermann begins by mischaracterizing critical details of the HENGH study, inaccurately stating that the study "found that median indoor formaldehyde in new homes built after 2009 with CARB Phase 2 Formaldehyde ATCM materials had... median indoor concentrations of 22.4 fag/m3 (18.2 ppb)." This is incorrect: though the study did find that its 70 sample homes had a median indoor formaldehyde concentration of 18.2 ppb, the study offers no evidence, nor does it explicitly express or infer, that sampled homes were built with CARB Phase 2 ATCM materials. The HENGH study assessed 70 sample homes that were built between 2011 and 2017, but the final Phase 2 ATCM rules did not go into effect until January 2014. Thus, not all sampled homes were built after the final Phase 2 ATCM rules went into effect, and it is Singer, B.C., Chan, W.R., Kim, Y., Offermann, F.J., and Walker I.S. 2020. Indoor Air Quality in California Homes with Code - Required Mechanical Ventilation. Indoor Air, Vol 30, Issue 5, 885-899. Page 2