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8. B. - Page 185 Year Exposure DPM Exposure Factor Annual Risk Cumulative Risk Duration Concentration Ad'ustment ( er million) ( er million) J6-57 1 0.0108 1 O.OJ 9.62 �7-J8 1 0.0108 1 O.OJ 9.67 58-59 1 0.0108 1 0.05 9.72 J9-60 1 0.0108 1 O.OJ 9.77 60-61 1 O.OlO8 1 O.OJ 9.82 61-62 1 0.0108 1 0.05 9.87 62-63 1 0.0108 1 0.0� 9.91 63-64 1 0.0108 1 0.0� 9.96 64-65 1 0.0108 1 0.05 10.1 6J-66 1 O.OlO8 1 O.OJ lO.O6 66-67 1 0.0108 1 O.OJ 10.11 67-68 1 0.0108 1 0.05 10.16 68-69 1 0.0108 1 0.05 1021 69-70 1 0.0108 1 O.OJ 10.26 In Clark's opinion, the City used a�1 incorrect methodology to conclude that impacts to residential receptors would b�crely be less than sigiufica��t. If the City had used the same methodology to calculate impacts during both the consnuction a�7d operational phases, it would have concluded that in�pacts to residential receptors would be significant. Resuonse A-13: It should be noted that the adopted BAAQMD threshold is specifically written as< 10.0 in 1,000,000. There are no fractional cancer cases. lii other words, a��y project that woL�ld result in a�� e�posL�re risk of 9.99 or less is deemed to be less than significa��t and a��ything equal to or greater than 10.0 would be significant. CEQA does not classify impacts as"barely less than significant". It appea�s that the commentor is implying that flie conclusion is wrong or is questionable simply because it is just below the adopted threshold. As has been demonstrated in the Draft EIR, Final EIR, a�1d in responses to these conunents, tlie City a�7d fl1e City's air qL�ality expert have concluded that the mefllodology used in the atialysis is correct a�ld consistent with BAAQMD guidelu�es. Therefore, simply because the calculated rislc is near the threshold does not mean the analysis is incorrect or that the less tha�� significa�lt exposure conclusion should be reversed. As stated above, the a�lalysis is conseivative in fl�at it does not talce into accoLU�t a��ticipated firture diesel emissions reductions beyond year 2025 (year 10 of the assumed 70 year e�posure), meaning that for 60 of the 70 year exposi�re, cancer rislc will likely be less than forecasted as emission rates continue to decline. In the comments, a series of calcL�lations were provided to support the claim fl�at the cumL�lative risk from DPM along will exceed 10 in 1,000,000. The conunentor stated that the breathing rate identified and utilized by the City was also used in their calcL�lations to elinunate dispute. The breathing rate used by the City was the 8p percentile adL�lt residential breathing rate of 302 L/kg-day, as suggested by BAAQNID. Based on the stateinent in the above comment, this is presuinably the breathing rate used in the con7mentor's calculations. Examination of their calculations, however, shows that a breathing rate of 581 L/kg-day was acfially used for the first 16 yea�s of exposure, indicating that Dr. Clark's calculations contu�l�e to overstate long-term residential exposi�re. 2580 El Cainino Real Residenrial Project 17 Response to Conmients Recei��ed on Final EIR Cin� of Red��ood Cin� Jannai� 2012