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8. B. - Page 176 Comment A-8: Here, the City's response to Dr. Cla�lc's conunents simply disiniss lus calcL�lations, sl�rmnarily claimu�g that he L�sed an incorrect ca��cer risk adjustment factor, exposure duration for year ) a��d breathu�g rate. The City neither offered a jL�stification or expla��ation for its a��alysis, nor presented substa�ltial evidence that the Project would ha�e a less-tha�l-significa��t impact on residential receptors. Dr. Clark reviewed t1�e Final EIR a��d provided comments, wluch are inclL�ded here as Attachment A. Dr. Clark conducted the BAAQMD-reconunended a�7alysis �vit�� the C'itv-r'ecomnzended ex�oszire dzir°ation for year° 0 and breathing rate. Dr. Clarlc still concluded that impacts would exceed the 10 u7 1 nullion significatice threshold. Dr. Clark's conui�ents also show that the City°s a�lalysis of TAC impacts remains L�nsL�pported, incoinplete, and, thus, does not qualify as substantial evidence of a less than significant impact. BAAQMD issued guida��ce for estimating operational iinpacts from TACs. BAAQNID gL�idance states that a proper analysis woi�ld include "multiplying each SWF by the corresponding enussions (grams/vehicle nule) for that year." Dr. Clark explains that the City incorrectly applied the Sensitivity Weighting Factor ("SWF") to the cancer risk, instead of the enussions rate for each year residents woL�ld be exposed to enussions on El Ca�7uno Real. According to Dr. Clark, the City's "nusapplication of the SWF to the ca��cer risk instead of fl�e einission rate L�nderestimates the potential health risk froin roadway einissions." Therefore, the Final EIR continues to lacks [sic] sL�bsta��tial evidence to sL�pport the City's conclusion. The City's disnussal of Dr. Clarlc's comments does not constitute an adeqL�ate response L�nder CEQA. The City ml�st explain why it failed to follow the BAAQNID-recommended analysis a��d justify its a�7alysis of TAC impacts. The Final EIR remauls inadeqL�ate a�1d substantial evidence shows t11at fi�h�re residents of 2580 El Ca�r�ino Real will be e�posed to caticer-causing air enussions in excess of the Bay Area's reconm�ended threshold. Resuonse A-8: The City a��d the City's air quality expert responded in detail, relying upon releva��t data a�1d appropriately i�tilizing reconunended methodology, in the Final EIR (pages 42-46 and 59-70)as to why it was concluded that Dr. Clark's methodology was flawed and wlry the Draft EIR's origu�al a��alysis is correct a��d compliant with flie BAAQMD guidelines. As discussed ul the responses to Dr. Clark's specific conunents below (see Responses A-12 a��d A-13), Dr. Clarlc did not actually follow the same methodology as the City in his reanalysis of operational TAC impacts. Therefore, it is L�ndersta�ldable that he did not reach the same qua��titative conclusion as fl7e City. Comment A-9: II. Concll�sion The Fina1 EIR fails to fiilfill the City's responsibility under CEQA. The comments presented above a�1d in our previoL�s conullents identify significant impacts fllat remain undisclosed, erroneously evaluated or insL�fficiently nutigated. Therefore, the City must prepare a revised draft EIR to correct these deficiencies and recirculate the revised draft EIR to the pl�blic for review a��d comment. Otherwise, the Project's significa�lt impacts would create inore burdens on the conununity a�1d the environment than opportunities. 2580 El Cainino Real Residenrial Project 8 Response to Conmients Recei��ed on Final EIR Cin� of Red��ood Cin Jannai� 2012