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8. B. - Page 179 Resqonse A-11: The City in no way disnussed Clarlc's or BAAQNIDs fu�dings. Dr. Clarlc's coinments and opiiuons were ca�efi�lly considered by the City in light of BAAQNID's guidelines and methodology. The Final EIR discL�ssed in detail why the City a��d the City's air quality expei�t believe Dr. Clark's a��alysis to be flawed a��d provided detailed expla��ations on the EIR analysis which is based on BAAQMD guidelines (pages 42-46 and 59-70). As noted above, the City's air quality expert is based u� the Bay Area a��d has prepared numerous studies of this type throughout tlie Bay Area in fi�ll accordance with BAAQNID guidelines a�1d is thoroughly versed with the reqi�irements a�ld methodologies of BAAQNID. The proposed project is not Luuque or even unusual in regards to other housing projects along major roadways in the Bay Area atid the atialysis completed for the proposed project was prepared in the same maiu�er as all other a��alyses of this type completed by the City's e�pert. There was nothiiig in Dr. Clarlc's original coimnents that deinonstrated the City L�sed faL�lty methodology in its analysis a��d fl�e fact that Dr. Clark, using different inethodology and assumptions, arrived at a different conclusion in no way invalidates the City's analysis, which concluded the fi�ture project residents would be exposed to air toxic enussions just below BAAQMD's pL�blished thresholds. Comment A-12: The Air Quality Analysis Utilizes Contradictoiy Methodology a�7d Underestimates TAC Impacts. The City L�sed two different mefl�odologies to calculate TAC enussions dL�ring the construction phase and the operational phase of fl�e Project. There was no explanation as to why the City adopted two differing methodologies. According to Clark, the methodology adopted by the City to a��alyze impacts during the operational phase is flawed a�1d underestimates the Project impacts. To a�7alyze operational impacts, the City applied the Sensitivity Weightu7g Factor (SWF) to the cancer risk ulstead of tlie enzission rc�te for each year. The SWF is the age sensitivity factor inL�ltiplied by the length of exposure divided by the 70 year life spa�l. The nus�ipplic�ition of the SWF to the cancer rislc instead of the emission rate Lu�derestimates the potential health risk from roadway einissions. The problem with applying the SWF' to the ca�lcer risk instead of the emission rate is that according to the BAAQMD the age sensitivity factors are designed to u�crease to the 70 ye�cr �aver�age coficentr�ation of cheinicals to be a��alyzed. Accordulg to BAAQMD gL�ida��ce, u� order to estimate the 70-yea� a�erage enussions, the user would generally average the enussions e�tracted from the EMFAC model. BAAQMD reconunends a three step process that reqL�ires a sigiufica�lt number of compL�tations. Step 1. The first step is to develop sensitivity weightulg factors (SWF) that are the age sensitivity valL�es mL�ltiplied by the duration of fl�e exposure by the lifetime of the exposure. This is expressed as: Sensitivity Weighing Factor = ASF x Length of E�posure (year) / 70 year lifespan. The City complied with this step as Shov�nl in Appendix G. Step 2. The user then estimates 70 ye«r aver�ige erriission r«tes (emphasis added) by multiplying each SWF by fl�e corresponding emissions (grains/vehicle nule) for that year. 2580 El Cainino Real Residenrial Project 11 Response to Conmients Recei��ed on Final EIR Cin� of Red��ood Cin� Jannai� 2012