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L formaldehyde concentrations from mostly single-family constructions built before 2011, and used that to speculate about potential health risks at the Project. The reference study addressed and evaluated indoor formaldehyde concentration in single-family homes, which are neither representative nor relevant to the Project(the Project is a new mid-rise multi-family development). Even if the project building were constructed using the same type of materials as the single-family homes studied previously (which is a speculative assumption), there would be no significant impacts; the ventilation requirements for new mid-rise mixed-use buildings are different from those for single-family dwelling units built before 2011 (see Title 24 building code). Mid-rise mixed-use buildings are also continuously ventilated with more advanced systems than single-family spaces.The outdated single-family data is not applicable. III. LINUA apparently uses inappropriate and overly conservative assumptions to estimate potential health risks for future residents and workers at the Project site. LINUA appears to assume that formaldehyde emission rates will remain the same over time. Formaldehyde emissions from the composite wood products LIUNA referenced are primarily due to outgassing of unreacted formaldehyde and to a degree due to decomposition of resins. Outgassing process is therefore highest for newly manufactured materials and decrease as the material weathers and cures.Z The underlying assumption of LINUA's comment is unrealistic based on scientific literature. IV. There is no information at this time that there will be any materials that will lead to elevated indoor air formaldehyde concentrations. LINUA's comment made speculative assumptions that could have underestimated the Project ventilation and overestimated the long-term formaldehyde concentrations with no analysis or reference.Thus the cancer risk estimates from LINUA's comment are unfounded and unreasonable. Additionally, even though LINUA acknowledges existing regulations that specifically address indoor air quality issues from building material usage, they ignore how the regulations address the issues raised. First, based on an unsubstantiated claim of expert comment on building materials, LINUA asserts that BAAQMD's CEQA significance threshold of cancer risk will be exceeded.There are no requirements or guidance from BAAQMD or relevant agencies to evaluate such on-site health risks from specific building materials. In particular, the CARB has developed an airborne toxic control measure to regulate formaldehyde emissions from composite wood products. Additionally, the project and its construction materials will be compliant with the City of Pleasanton's uniformly applied development standards in its Municipal Code, which requires compliance with other existing codes and regulations in California. The myriad of standard regulations the project will be subject to adequately address potential emissions and risks from building materials to ensure safe practices and healthy indoor air. These codes include: I. Title 243: The Building Energy Efficiency Standards (Energy Standards) already address the "energy and water efficiency requirements(and indoor air quality requirements) for newly constructed buildings, and alterations to existing buildings". The Standards are applicable to Mechanical Systems whose one of the primary functions is "indoor air quality foroccupant comfort and health". These Standards addresses ventilation, indoor air quality, and air filtration requirements (including the use of high efficiency filters), the checks and balances and need to be performed, and the acceptance test requirements. One of the General Envelope Requirements is that manufacturers must certify that insulating materials comply with the California Quality Standards for Insulating Materials to assure that"insulation sold or 5. EPA (2015) Questions on Formaldehyde(Updated 2/1C/2C16; ,N epa,cov/sites/production/files/2C'_c ^2/documents ,ae auest,ors arc answers 2022 Scalding Energy Efficiency Standards: ?rd torics/rroQrarns,oui'!d rg ergy-efficiency-standards/2022-oudding-erer - 2/4