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Mr. Offermann then assumes that because "residential occupants inhale 20 m3 of air per day," a claim that he makes without any supporting evidence, "the average 70-year lifetime formaldehyde daily dose is 482 tag/day for continuous exposure in the residences," which he equates with "a cancer risk of 120 per million." There are at least three issues with this projection (that are in addition to issues that have been previously identified and discussed). First, Mr. Offermann claims that residential occupants would inhale 20 cubic meters of air per day, yet cites no evidence to substantiate this claim. According to the American Lung Association, the average person inhales approximately 2,000 gallons of air per day or roughly 7.57 cubic meters per day.4 Second, Mr. Offermann cites no authority in support of his assumed 70-year lifetime" exposure duration. In fact, his assumption of a "70-year lifetime" exposure duration contradicts the 30-year exposure duration that is consistent with OEHHA recommendations for estimating individual cancer risks. This demonstrates, once again, how Mr. Offermann has resorted to speculative assumptions that are unsupported by relevant regulatory guidance. Third, by assuming that a future Project resident would inhale 482 tag/day of formaldehyde for 70 years (which, as explained, represents two sets of unsupported assumptions), Mr. Offermann overlooks the fact that emissions of formaldehyde gas from composite wood products decrease over time. This is perhaps the most serious deficiency in his analysis. The OEHHA's Proposition 65 webpage for formaldehyde notes how "the release of formaldehyde gas from composite wood decreases over time."' The U.S. Consumer Product Safety Commission also notes that for formaldehyde sources, "emissions generally decrease as the product ages. ,6 CARB explains that "[f]or products that are made with formaldehyde based resins or adhesives, rapid off -gassing of formaldehyde occurs initially when the product is made, and over time the formaldehyde emissions decrease."' The CDC's Agency for Toxic Substances and Disease Registry (ATSDR) states that "[m]ost formaldehyde is released from products within 2 years."$ The CDC's ATSDR raises a particularly salient point because of the 70 homes that were sampled as part of the HENGH study, nearly 70% were 2 years or newer when sampled. This suggests that whatever these homes' proportion of indoor formaldehyde concentrations from building materials might have been, it would have been relatively elevated at the time of the HENGH study due to the age of these homes.9 Over time, formaldehyde concentrations associated with these homes' building materials would be expected to attenuate. Mr. Offermann's analysis runs contrary to this understanding of formaldehyde emissions. Without accounting for the natural decay of formaldehyde emissions over time, Mr. Offermann assumes that a resident's exposure to indoor formaldehyde concentrations from the Project's composite wood building materials would be exactly the same whether it is the first day or the 70th year of their occupancy — a clearly erroneous assumption. 4 American Lung Association, How Your Lungs Get the Job Done, website: https✓/www.lung.org/blog/how-your-lungs-work, accessed July 2023. 5 OEHHA, Formaldehyde in Furniture Products. p65warnings.ca.gov/fact-sheets/formaldehyde-furniture-products. April 2016. 6 U.S. Consumer Product Safety Commission (CPSC), An Update on Formaldehyde. Publication 725. 2013. CARB, Frequently Asked Questions for Consumers (Reducing Formaldehyde Emissions from Composite Wood Products). Accessed January 3, 2022, 8 Agency for Toxic Substances and Disease Registry (ATSDR), Formaldehyde in Your Home: What You Need to Know. atsdr.cdc.gov/formaldehyde/home/index.html. Accessed January 3, 2022. 9 As explained earlier, Singer et al. did not determine or speculate as to what proportion of its measured formaldehyde concentrations were resultant from building materials only. Page 6