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With respect to the alleged impact to future employees of the Project's commercial spaces, Mr. Offermann's claims and analysis fall short for similar reasons as those explained previously. In summary, the following is a review of the various issues associated with Mr. Offermann's claims and analysis regarding alleged formaldehyde impacts to future Project residents and employees: 1. Contrary to statements made by Mr. Offermann, the HENGH study did not measure indoor formaldehyde concentrations in new homes built only with CARB Phase 2 Formaldehyde ACTM materials, and the study does not establish what median indoor formaldehyde concentrations for such homes might be. 2. Mr. Offermann's 7.5% "correction" to the 22.4 pg/m3 (18.2 ppb) median indoor formaldehyde concentration finding by the HENGH study is unsupported by Singer et al., and Mr. Offermann's "corrected" figure is not evident anywhere in the paper by Singer et al. 3. Mr. Offermann assumes that future Project residents will spend every hour of every day in their apartments, a clearly inaccurate assumption. 4. In making claims about the Project's ventilation, Mr. Offermann demonstrates no understanding of what the Project's ventilation would be or what the HENGH sample homes' ventilation was. Additionally, he fails to substantiate why the Project would have any similarity in ventilation to the 70 detached single-family homes that were sampled as part of the HENGH study. 5. Mr. Offermann overlooks the fact that HENGH study sample homes were occupied and therefore presumably furnished. The HENGH study did not determine or speculate what proportion of its measured formaldehyde concentrations were resultant from building materials only. It also did not determine or speculate what proportion of concentrations were due to consumer product use by sample home occupants. By assigning the median formaldehyde concentrations measured by the HENGH study to the Project, Mr. Offermann compels the Project to consider the impact of formaldehyde emissions that are outside the scope of CEQA relevance (i.e., formaldehyde emissions from the objects and actions of residents — not those that are directly generated by the Project's building materials). 6. The HENGH study specifically instructed participants to not use windows and doors normally as they might do for routine ventilation, a condition that limits the real -world applicability of the study's findings. 7. Mr. Offermann's cancer risk projection for future Project residents relies on a 70-year lifetime" exposure duration, a speculative assumption that is unsupported by existing regulatory guidance. 8. Mr. Offermann disregards the fact that emissions of formaldehyde gas from composite wood products decrease overtime. Given these considerations, Mr. Offermann's analysis offers no substantial evidence as to why the Project's formaldehyde emissions from CARB Phase 2 Formaldehyde ATCM building materials would be expected to result in significant cancer risks to future Project residents and employees. Under Public Resources Code Section 21082.2(c), "[a]rgument, speculation, unsubstantiated opinion or narrative, evidence which is clearly Page 7