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inaccurate or erroneous, or evidence of social or economic impacts which do not contribute to, or are not caused by, physical impacts on the environment, is not substantial evidence. Substantial evidence shall include facts, reasonable assumptions predicated upon facts, and expert opinion supported by facts." Mr. Offermann's inferences from the HENGH study findings are not reasonable, and at times they directly contradict the explicit admissions and published results of the study itself. Mr. Offermann's assumptions are also erroneous, and at times they directly contradict OEHHA guidance. Furthermore, Mr. Offermann's conclusion that the Project would result in significant cancer risks and that CARB ATCM regulations "do not assure healthful indoor air quality" directly contradict statements from numerous State and Federal agencies regarding formaldehyde emissions, including CARB itself. CARB states that "[f]rom a public health standpoint, the CWP Regulation's emission standards [i.e., the CARB ATCM] are set at low levels intended to protect public health." CARB reiterates this elsewhere, stating that "[t]he Composite Wood Products Regulation establishes emission standards at levels intended to protect public health." The CDC adds that "[f]ormaldehyde exposure from new products or new construction in the home would generally be much lower and would last for less time than the exposures linked to cancer. We estimated the risk of cancer from exposure to typical indoor air levels and it's low." Response to Comment No. 2 Mr. Offermann states that "An air quality analyses should be conducted to determine the concentrations of PM2.5 in the outdoor and indoor air that people inhale each day." The effect of PM2.5 is also not relevant based on California Building Industry Assn v. Bay Area Air Quality Mgmt. Dist. (2015) 62 CalAth 369, 386. 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. The commentator presents no evidence that there is an existing PM2.5 issue at the Project Site. Further, the commentator is referred to the Technical Memo the Project would not generate PM2.5 emissions in excess of SCAQMD's significance threshold, and no significant impacts related to PM2.5 emissions would occur. Response to Comment No. 3 Regarding the suggested mitigation measures, CEQA requires mitigation measures only for significant impacts, and the commentator has not presented any substantial evidence that the Project would result in significant air quality impacts. Additionally, as outlined in the Technical Memo, the Project would not result in any significant air quality impacts. Therefore, the mitigation measures are not applicable to the Project. Page 8