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8. B. - Page 177 We L�rge the Planning Comnussion to direct Staff to prepare a revised draft EIR, wluch addresses sigiuficant construction traffic a��d pL�blic health impacts, a��d to circulate the revised Draft EIIZ for public review. Resuonse A-9: The City respectfi�lly disagrees with the commentor's opinion that fl7ere are i�ndisclosed, erroneously evali�ated or insi�fficiently nutigated significa�lt impacts. The City has met its responsibilities L�nder CEQA a��d, therefore, there is no need to recircL�late the revised Draft EIR. Contra�y to the conuilent, for the reasons provided above a�ld u7 the Final EIR, the project would not be exposed to significa�lt air to�c enussions a�1d would generate construction traffic that coL�ld be acconunodated on are roadways withoL�t substa�ltial increases in delay. Comment A-10: Attachment A— Comments on the Final EIR for Proposed 2580 EL Ca�nino Real by Clarlc and Associates. At the request of Adams Broadwell Joseph a��d Cardozo (ABJC), Clark a�ld Associates (Clark) has prepa�ed the following comments on the Final Environmental Impact Repoi�t (Fu�al EIR) for the 2580 El Canuno Real Residential Project (Project). The City concluded that toxic air contanuna�lts (TAC) would pose a less-thati-significa�lt impact on residential receptors at tlie Project site. As noted in Clark's conm�ents on the Draft EIR, a��d restated here, this conclusion is based on a flawed a��alysis. Clark's review of the materials in no way constitutes a validation of conclusions or materials contained within the plan. If we do not comment on a specific itein this does not constitute acceptance of the item. Backgrotu�d — As noted in Cla�k's conuilents on the Draft EIR, both the BAAQNID and Clark concluded that residential receptors on the Project site would be exposed to sigiuficant levels of TAC enussions. As illL�st�ated in FigL�re 1, below, the BAAQNID estimates that first floor residential receptors approximately 75 feet from El Canuno Real would be exposed to TAC enussions of 10.146. According to Cla�k's initial calculations, residential receptors woL�ld be exposed to TAC emissions of 12.707. The threshold of significance adopted by fl�e City is 10 in linillion. Therefore, by both BAAQMD a��d Cla�k's calci�lations, the Project would cai�se a significant impact to residential receptors. Resuonse A-10: As stated in the Final EIlZ (Response 0-20, page 42), the 10.146 enussion rate referenced by Dr. Cla�lc is from BAAQMD's highway screeiung tables a�ld is not a site specific estimate of the proposed project's TAC exposL�re risk. According to BAAQNID's Reconzmended Methods fo�° Screening ar�d Modeling Loca1 Risk and Ha�ards, "the purpose of the lughway screenulg tables is to provide a�� easy-to-L�se initial analysis to deternune if nearby highway impacts to a new receptor are below the thresholds of significance. The oi�tcome of the screei��g may be i�sed to assess a deternunation of no fi�ture action or it may indicate fliat a more refuled analysis is warra��ted." lil accordance with BAAQMD gL�idance, it was detenl��e that a inore refined modelulg a�lalysis was reqi�ired becai�se the initial screeiung level was above the 10 per 1,000,000 threshold. BAAQMD has not completed a site specific a�lalysis a�1d has made no specific calcL�lations regardulg the TAC rislc of the propose project. 2580 El Cainino Real Residenrial Project 9 Response to Conmients Recei��ed on Final EIR Cin� of Red��ood Cin Jannai� 2012