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dwelling units. Mr. Offermann's analysis hinges entirely on the assumption that the Project's dwelling units would experience similar indoor formaldehyde concentrations as HENGH study sample homes. But, as demonstrated, this assumption is wholly unsupported by fact. There are additional aspects of the HENGH study that have not been considered by Mr. Offermann which further diminish its comparative value to the Project, as well. First, the HENGH study sample homes were occupied and therefore presumably furnished. This is a critical detail overlooked by Mr. Offermann. Formaldehyde off -gassing occurs not just from composite wood products used in building construction, but also from composite wood products used commonly in furniture construction. Tables, bedframes, dressers, sofas, chairs, and any other furniture containing composite wood products would also likely emit formaldehyde, possibly at high levels if such furniture was purchased prior to the CARB Formaldehyde ATCM or outside of California. Common indoor sources of formaldehyde also include household products such as glues, paints, caulks, pesticides, fabric softeners, and detergents. Even personal care products and cosmetics such as shampoos, soaps, hair care products, body washes, and nail polish may release formaldehyde. Moreover, many other consumer products also emit VOCs that react with ozone in the air to produce formaldehyde.3 The HENGH study did not determine or speculate what proportion of its measured formaldehyde concentrations were resultant from building materials only. Therefore, there is no way of knowing what measured proportion of indoor formaldehyde concentrations were emitted solely by the building construction materials used in HENGH study sample homes. This is a pivotal consideration because formaldehyde emissions from the objects (i.e., composite wood furniture) and actions (i.e., use of pesticides, detergents, or personal care products) of future Project residents, and any impact that they would have on themselves, is entirely speculative and outside the scope of the Project's CEQA-related impacts. Put another way, the Project is not "on the hook" for any risk that future Project residents may pose to themselves via their own formaldehyde -emitting objects and actions. But, by assuming that future Project residents would experience similar indoor formaldehyde concentrations as measured in the HENGH study, Mr. Offermann puts the Project "on the hook" for an indeterminate amount of formaldehyde emissions that were caused by the objects and actions of HENGH study participants. Second, it is worth noting that the HENGH study specifically instructed participants not to use windows and doors normally as they might do for routine ventilation (See Exhibit 2). This clearly biases the study's results in favor of increased indoor formaldehyde concentrations. While such instruction may have been relevant to the purpose of the HENGH study, in real life, it is reasonable to suspect that future Project residents would occasionally open their windows or doors for purposes of natural ventilation. Exhibit 2 3 appliance use. The participant was provided with an activity log for each day of the study and 4 asked to partake in normal household activities with the exception that windows and doors 5 should not be used for routine ventilation. Most homes were monitored for seven days, five were The highlighted excerpt indicates that HENGH study participants were instructed to not use windows and doors for "routine ventilation." (Singer et al.) 3 CARB, Formaldehyde Online Fact Sheet. ww.2.arb.ca.gov/resources/fact-sheets/formaldehyde. May 1, 2020. Page 5