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CEQA HRA Guide

CEQA HRA work is the slow link in many EIRs.
Here is where the workflow usually breaks.

A Human Health Risk Assessment in a CEQA Environmental Impact Report is split across dispersion modeling, OEHHA 2015 exposure math, and reviewer-facing reporting. The methodology has been stable since 2015. The data sources, the SDOH expectations, and reviewer scrutiny have not. This guide covers what changed and what LSARS does about it.

See the HRA engine
Aerial visualization of a California project site with dispersion plumes and nearby sensitive receptors, illustrating a CEQA Human Health Risk Assessment workflow

The reality of CEQA HRA work

Three things every CEQA HRA team is dealing with in 2026.

The workflow problem

HRA is the slow link in many EIRs

When a project sits near sensitive receptors, the Human Health Risk Assessment is often the section of the air quality analysis that holds up the EIR schedule. Dispersion modeling, OEHHA exposure math, sensitive receptor identification, and reviewer reporting are stitched together by hand on most projects. Any input change resets the chain.

Methodology stable, scrutiny not

OEHHA 2015 is settled. The expectations are not.

The OEHHA 2015 Air Toxics Hot Spots Program Risk Assessment Guidelines have been the methodological reference for a decade. Lead agency and air district reviewers, however, increasingly expect SDOH context, cumulative impact discussion, and clearer audit trails. The science did not change. The bar for the documentation did.

The gap LSARS fills

Most teams are still in Excel and Word

In 2026, most CEQA HRAs are still authored in Excel workbooks and Word documents, with dispersion model outputs pasted by hand and exposure assumptions tracked in cells nobody else can read. That works for one project. It does not scale to a portfolio, and it does not survive aggressive review cycles.

What LSARS provides

CEQA HRA workflow, built around OEHHA 2015.

LSARS implements the same OEHHA 2015 methodology that CARB HARP2 implements, with construction-phase and operational-phase HRA in one workflow and SDOH context built into every receptor.

5 sig figs
HARP2 parity
OEHHA 2015
Methodology aligned
84,807
Census tracts
2 phases
Construction and operational

OEHHA 2015 with Age Sensitivity Factors

The full OEHHA 2015 Air Toxics Hot Spots Program Risk Assessment Guidelines methodology, including the Age Sensitivity Factors that weight exposure for the third trimester through age 16. Reproduces what CARB HARP2 produces, validated to five significant figures.

Construction and operational HRA in one workflow

Construction-phase emissions and operational-phase emissions live in the same project. Cancer risk and hazard index can be reported by phase or summed across phases without rebuilding the calculation when an input changes.

Sensitive receptor identification with SDOH context

Schools, daycares, hospitals, and residences are flagged at the receptor level, with CDC SVI 2022 and ACS 2023 demographic context attached automatically. Reviewers see cancer risk and the social vulnerability of the exposed population in the same view.

Reviewer-shareable HEM reports with audit trail

Human Exposure Model reports with worked examples, full citations, and a Validate Data workflow. Every receptor, every input, every assumption traces back to the methodology document so a lead agency or air district reviewer can reproduce the result.

Why LSARS for CEQA HRA

Built for the consultants and in-house teams running this work as a discipline.

LSARS is the production layer underneath the CEQA HRA. It does not replace the consulting work or the lead agency review. It makes the iteration cycle and the audit trail faster and cleaner.

OEHHA 2015 methodology with Age Sensitivity Factors built in
CARB HARP2 parity validated at five significant figures
Construction-phase and operational-phase HRA in one project
Sensitive receptor identification with CDC SVI 2022 and ACS 2023 context
AERMOD and AERSCREEN dispersion model outputs accepted as inputs
HEM reports with worked examples and full citation pills
Recalculation in seconds when an input changes, not a workbook rebuild

CEQA HRA inputs

What goes into the calculation.

Dispersion model outputAERMOD or AERSCREEN

Concentration fields by receptor for project TACs and DPM, construction and operational phases

Receptor locationsProject-specific

Maximally exposed individuals at nearest residences, point of maximum impact, and sensitive land uses

Exposure assumptionsOEHHA 2015 aligned

Breathing rates, exposure durations, Age Sensitivity Factors, residential and worker scenarios

Sensitive land usesSchools, daycares, hospitals, residences

Identified within the zone of impact and prioritized for receptor placement

Demographic contextCDC SVI 2022 + ACS 2023

Census-tract social vulnerability and demographics attached automatically to each receptor

LSARS does not replace OEHHA or CARB. It implements the OEHHA 2015 methodology and is validated against HARP2.

Significance thresholds

By lead agency.

SCAQMD typically uses 10 in a million (1 x 10 to the negative 5) for project-level cancer risk and a chronic hazard index of 1.0. Other air districts and lead agencies publish their own thresholds. Confirm with the relevant district before the HRA is finalized. LSARS lets you switch the applied threshold without rebuilding the calculation.

Honest about scope

Two ways to get a CEQA HRA done. Pick the right one for the project.

LSARS is not a replacement for the established CEQA consulting firms. For a single project where you want a turnkey deliverable from a firm with decades of CEQA experience, hire one of them. LSARS is the production layer for the teams running this work as a recurring discipline.

Hire a CEQA HRA consulting firm

Turnkey, single-project deliverable

Established firms doing this as a service line: Yorke Engineering, Environmental Science Associates (ESA), Urban Crossroads, Trinity Consultants, Integral Consulting, Davenport Engineering, CAJA Environmental Services.

  • Single-project EIRs where you need a turnkey deliverable
  • Projects with unusual modeling complexity or novel source types
  • Teams without an in-house CEQA HRA capability
  • Projects where decades of CEQA precedent and reviewer relationships matter
  • When you want one firm to own the analysis and the defense of it

Consulting hours scale linearly with project count. For portfolios and recurring work, that gets expensive.

Use LSARS

CEQA HRA as a recurring discipline

Built for the consulting firms themselves and for in-house teams that do CEQA HRA work all year, every year.

  • Consulting firms running CEQA HRA as a recurring service line
  • In-house EHS teams at multi-project operators
  • Anyone who needs faster iteration cycles when inputs change
  • Anyone who wants the SDOH overlay built into every receptor
  • Portfolios of similar projects (logistics, energy, infrastructure)
  • Teams that need a defensible audit trail for every calculation

OEHHA 2015 aligned. HARP2 parity to five significant figures. Construction and operational phases in one workflow.

Lead agencies (cities, counties, state agencies) are not the buyer here. The buyer is the consultant or in-house team preparing the analysis for the lead agency. LSARS makes that team faster and more defensible.

CEQA HRA FAQ

Common questions about CEQA Health Risk Assessments.

What triggers a CEQA review?

The California Environmental Quality Act applies to discretionary projects approved by state or local agencies in California. A CEQA review is triggered when a public agency considers approving a project that could have a physical effect on the environment. Where the project is sited near sensitive receptors (homes, schools, daycares, hospitals) and emits toxic air contaminants or diesel particulate matter, the lead agency typically requires a Human Health Risk Assessment as part of the air quality analysis in the Environmental Impact Report. The HRA is the section that quantifies cancer risk and chronic hazard from project emissions at the nearest exposed individuals.

When is a Human Health Risk Assessment required in a CEQA EIR?

A CEQA HRA is typically required when a project will emit toxic air contaminants or diesel particulate matter, and sensitive receptors are located within the zone of impact of the project. Lead agencies and air districts apply their own significance thresholds to decide when the analysis is required, but the trigger is almost always the combination of TAC or DPM emissions plus nearby sensitive land uses. Both construction-phase emissions (haul truck DPM, on-site equipment) and operational-phase emissions count. The HRA quantifies the resulting cancer risk and hazard index at the maximally exposed individual.

What is the cancer risk significance threshold for a CEQA HRA?

Significance thresholds for CEQA HRAs vary by lead agency. The South Coast Air Quality Management District (SCAQMD) typically uses 10 in a million (1 x 10 to the negative 5) for project-level cancer risk and a chronic hazard index of 1.0. Bay Area AQMD, San Joaquin Valley APCD, and other districts publish their own thresholds, and some lead agencies layer additional cumulative thresholds on top. The threshold the analysis is measured against should be confirmed with the lead agency and the relevant air district before the HRA is finalized.

What is the difference between a CEQA HRA and an AB2588 HRA?

Both rely on the OEHHA 2015 Air Toxics Hot Spots Program Risk Assessment Guidelines as their methodological backbone, but they live in different regulatory tracks. An AB2588 Hot Spots HRA is a recurring facility-level filing under the California Air Toxics Hot Spots Information and Assessment Act, submitted to the local air district for an existing operating facility. A CEQA HRA is a project-level analysis prepared as part of an Environmental Impact Report for a proposed project, including construction-phase emissions and operational-phase emissions. LSARS supports both because the underlying exposure math is the same.

Does CEQA require OEHHA methodology for health risk assessments?

In practice, yes. California air districts and lead agencies expect CEQA HRAs to follow the OEHHA 2015 Air Toxics Hot Spots Program Risk Assessment Guidelines, including the Age Sensitivity Factors that increase exposure assumptions for the third trimester through age 16. The CARB HARP2 software implements OEHHA 2015 and is the de facto reference implementation reviewers use to reproduce results. LSARS implements the same OEHHA 2015 methodology and is parity-validated against HARP2 to five significant figures.

What pollutants need to be modeled in a CEQA HRA?

The pollutants that drive a CEQA HRA are the toxic air contaminants on the OEHHA list of substances with health values, plus diesel particulate matter where on-site or mobile diesel equipment is involved. For most projects, DPM dominates the cancer risk number because of its high cancer unit risk factor and its prevalence in construction equipment, haul trucks, and on-site generators. The full TAC list, with cancer unit risk factors and chronic and acute reference exposure levels, is maintained by OEHHA and is built into the LSARS HRA engine.

How do you handle construction-phase HRAs in CEQA?

Construction-phase HRA is required when project construction is long enough and intense enough that emissions from equipment, haul trucks, and other on-site sources produce meaningful exposure at nearby sensitive receptors. The analysis combines a construction emissions inventory (often from CalEEMod), dispersion modeling (typically AERMOD or AERSCREEN), and OEHHA 2015 exposure math with construction-specific exposure durations. LSARS treats construction-phase and operational-phase HRA as a single workflow so cancer risk and hazard index can be summed across both phases without rebuilding the calculation.

Does CEQA require mitigation when an HRA shows significant impact?

When a CEQA HRA shows that project cancer risk or chronic hazard exceeds the lead agency significance threshold, CEQA requires the lead agency to identify and adopt feasible mitigation measures to reduce the impact to less than significant where possible. If the impact cannot be mitigated below the threshold, the lead agency must adopt a Statement of Overriding Considerations to approve the project. The HRA itself does not impose mitigation. It quantifies the impact so the lead agency can make a defensible significance determination and the public can review the analysis.

See a CEQA HRA running in LSARS.

Bring a project. We will walk through dispersion model intake, OEHHA 2015 exposure math, sensitive receptor identification, and the HEM report a reviewer would see. Walkthroughs run about 30 minutes.