Agenda — Adelanto City Council, June 2, 2022 (part 1 of 3)

AGENDA

SPECIAL MEETING

OF THE ADELANTO CITY COUNCIL,

ADELANTO PUBLIC FINANCING AUTHORITY,

ADELANTO PUBLIC UTILITY AUTHORITY,

ADELANTO COMMUNITY BENEFIT CORPORATION,

AND THE SUCCESSOR AGENCY BOARD
June 2, 2022

City Council
Gabriel Reyes, Mayor
Daniel Ramos, Mayor Pro Tem
Stevevonna Evans, Councilor
Joy Jeannette, Councilor
Keron Jones, Councilor
City Manager
Jessie Flores
City Attorney
Marc Tran
Meetings held:
2 nd & 4th Wednesday
Adelanto Governmental Center
City Council Chambers
11600 Air Expressway, Adelanto
Closed Session: 10:00 a.m.

Open Session: Thereafter
Until further notice, only Council members and essential staff are allowed to be physically present inside Council Chambers, and will be seated the recommended distance from each other. Public participation is solely via call-in or via written correspondence. TO PARTICIPATE, please call, email, or send mail to the contact info provided below/on the City Council Agenda.

On March 4, 2020, Governor Newsom proclaimed a State of Emergency in California as a result of the threat of COVID-19. On September 16, 2021, Governor Newsom signed Assembly Bill 361 (“AB 361”), which was effective immediately and amends Government Code § 54953 to allow a local legislative body to hold public meetings via teleconferencing and to make public meetings accessible telephonically or otherwise electronically to all members of the public seeking to observe and to address the local legislative body. Pursuant to AB 361, please be advised that members of the Adelanto City Council may participate in meetings telephonically.

Participate via zoom please log in using any of the options below:
• https://zoom.us/j/95612357515?pwd=S2d2MUM2TGtsSjl0SjA3bVNHK2tMQT09 Or Telephone:

US: +1 669 900 6833
Webinar ID: 956 1235 7515
Passcode: 7601
1 SPECIAL MEETING
JUNE 2, 2022
11600 Air Expressway • Adelanto, CA 92301 • (760) 246-2300 • www.ci.adelanto.ca.us Submit written comments:

We encourage submittal of written comments supporting, opposing, or otherwise commenting on an agenda item, for distribution to the City Council prior to the meeting. Send emails to [email protected]; written correspondence may be sent to Brenda Lopez, 11600 Air Expressway Adelanto CA 92301.

Rules of Decorum
“Members of the Public are advised that all PAGERS, CELLULAR TELEPHONES and any OTHER COMMUNICATION DEVICES are to be turned off upon entering the City Council Chambers.” If you need to have a discussion with someone in the audience, kindly step out into the lobby. Under the Government Code, the City Council may regulate disruptive behavior that impedes the City Council Meeting.

Disruptive conduct may include, but is not limited to:
• Screaming or yelling during another audience member’s public comments period; • Profane language directed at individuals in the meeting room; • Throwing objects at other individuals in the meeting room; • Physical or verbal altercations with other individuals in the meeting room; and • Going beyond the allotted three-minute public comment period granted.

When a person’s or group’s conduct disrupts the meeting, the Mayor or presiding officer will request that the person or group stop the disruptive behavior, and WARN the person or group that they will be asked to leave the meeting room if the behavior continues.

If the person or group refuses to stop the disruptive behavior, the Mayor or presiding officer may order the person or group to leave the meeting room, and may request that those persons be escorted from the meeting room. Any person who, without authority of law, willfully disturbs or breaks up a City Council meeting is guilty of a misdemeanor. (Pen. Code, § 403.) It should also be noted that any person who WILLFULLY disturbs or breaks up the City Council meeting may be arrested for a misdemeanor offense. (Penal Code, § 403.)

MEMBERS OF THE PUBLIC WISHING TO ADDRESS THE CITY COUNCIL MEMBERS

ARE REQUIRED TO FILL OUT A SPEAKER REQUEST FORM AND PLACE IT IN THE TRAY ON THE PODIUM PRIOR TO MEETING. Thank you, Administrative Staff The City Council packet may be reviewed by the public at the reception counter in City Hall. Any writings or documents pertaining to an open session item, provided to a majority of the City Council Members within seventy-two (72) hours of a Regular Meeting and twenty-four (24) hours of a Special Meeting. Members of the public can view the agenda or download any staff reports in advance by accessing the City’s website at www.ci.adelanto.ca.us on the Thursday of the week before the scheduled meeting.

AMERICANS WITH DISABILITIES ACT: In compliance with the Americans with Disabilities Act, if you need special assistance to participate in this meeting, please contact the City Clerk at (760) 246-2300, ext. 11123, no later than seventy-two (72) hours prior to the meeting per 28 2 SPECIAL MEETING
JUNE 2, 2022
11600 Air Expressway • Adelanto, CA 92301 • (760) 246-2300 • www.ci.adelanto.ca.us CFR 34.102.104.

TIME: _____________
ROLL CALL: Councilor Evans ________
Councilor Jeannette ________
Councilor Jones ________
Mayor Pro Tem Ramos ________
Mayor Reyes ________

1. City Manager to announce if there is any addition/removal of items from the agenda.

C. APPROVAL OF AGENDA
C. ANNOUNCEMENT OF CLOSED SESSION ITEMS

1. CONFERENCE WITH LEGAL COUNSEL – ANTICIPATED LITIGATION Pursuant to Government Code § 54956.9 Subparts (a), (d)(2) and (e)(3).

Two cases
D. PUBLIC COMMUNICATIONS ON CLOSED SESSION ITEM
E. CONVENE INTO CLOSED SESSION
TIME: _____________

1. Motion to go into Closed Session.

A. CALL TO ORDER—CLOSED SESSION
B. DELETIONS/ADDITIONS TO AGENDA
3 SPECIAL MEETING
JUNE 2, 2022
11600 Air Expressway • Adelanto, CA 92301 • (760) 246-2300 • www.ci.adelanto.ca.us M__________________S__________________ACTION_________________ F. CALL TO ORDER— SPECIAL MEETING
TIME: _____________
ROLL CALL: Councilor Evans ________
Councilor Jeannette ________
Councilor Jones ________
Mayor Pro Tem Ramos ________
Mayor Reyes ________
INVOCATION:

FLAG SALUTE: ______________________
G. CLOSED SESSION REPORT
H. PUBLIC COMMUNICATIONS
This is the time and place for members of the public to comment on any matter within the jurisdiction of the City Council. Members of the public wishing to address the City Council Members on items not on the agenda can push *3 on their telephones to raise their hands. The City Clerk will call on you in the order received. You will be asked to un-mute - to do so you must push *6. Please state your name for the record. There is a time limit of three (3) minutes.

Members of the audience may address the City Council on non-agenda items; however, in accordance with Government Code section 54954.2, the City Council may not take action on an item not appearing on the agenda
4 SPECIAL MEETING
JUNE 2, 2022
11600 Air Expressway • Adelanto, CA 92301 • (760) 246-2300 • www.ci.adelanto.ca.us I. PUBLIC HEARING

OPEN PUBLIC HEARING: CLOSE PUBLIC HEARIING:

1. PUBLIC HEARING – APPEAL OF PLANNING COMMISSION APPROVAL/ADOPTION OF

THE INITIAL STUDY/MITIGATED NEGATIVE DECLARATION FOR CONDITIONAL USE PERMIT 21-04, LOCATION AND DEVELOPMENT PLAN 21-04, TENTATIVE PARCEL MAP 20437 (DAVE/JIM)
RECOMMENDATION: Staff recommends that the City Council, DENY THE APPEAL and APPROVE/ADOPT the Initial Study/Mitigated Negative Declaration (IS/MND) for Conditional Use Permit 21-04, Location and Development Plan 21-03 & Tentative Parcel Map 20437 and adopt Council Resolution No. 22-21 (Attached as Exhibit A) adopting the findings and approving/adopting the IS/MND for Conditional Use Permit 21-04, Location and Development Plan 21-03 & Tentative Parcel Map 20437, a 15-acre site located on Auburn Avenue, between Montezuma Street and Jonathan Street in the Airport Development District (ADD) zone in the City of Adelanto, California (APN’s: 0459-053-70, 71, 72 &74).

M__________________S__________________ACTION____________________ OPEN PUBLIC HEARING: CLOSE PUBLIC HEARIING:

2. PUBLIC HEARING – PUBLIC HEARING – APPEAL OF PLANNING COMMISSION

APPROVAL/ADOPTION OF THE INITIAL STUDY/MITIGATED NEGATIVE DECLARATION FOR CONDITIONAL USE PERMIT 21-16 & LOCATION AND DEVELOPMENT PLAN 21-14 (DAVE/JIM)
RECOMMENDATION: Staff recommends that the City Council, DENY THE APPEAL and APPROVE/ADOPT the Initial Study/Mitigated Negative Declaration (IS/MND) for Conditional Use Permit 21-16 and Location and Development Plan 21-14 and adopt Council Resolution No. 22-22 (Attached as Exhibit A) adopting the findings and approving/adopting the IS/MND for Conditional Use Permit 21-16 and Location and Development Plan 21-14, a 3.03-acre site located at the West side of Koala Road midway between Rancho Road and Violet Road in the Manufacturing Industrial (MI) zoning district in the City of Adelanto, California (APN: 3210-631- 14).

M__________________S__________________ACTION____________________ 5 SPECIAL MEETING
JUNE 2, 2022
11600 Air Expressway • Adelanto, CA 92301 • (760) 246-2300 • www.ci.adelanto.ca.us J. ADJOURNMENT
The next Regular Meeting of the City Council will be held on June 8, 2022 at 7:00 p.m.

TIME OUT: ______________
M__________________S__________________ACTION____________________

I, BRENDA LOPEZ, CITY CLERK OF THE CITY OF ADELANTO, OR MY DESIGNEE,

HEREBY CERTIFY THAT A TRUE, ACCURATE COPY OF THE FOREGOING AGENDA WAS POSTED ON MAY 31, 2022, TWENTY-FOUR (24) HOURS PRIOR TO THE MEETING PER GOVERNMENT CODE 54954.2 IN THE GOVERNMENTAL CENTER’S DISPLAY CASE, 11600 AIR EXPRESSWAY, AND ADELANTO, CALIFORNIA.

Brenda Lopez, City Clerk, CMC
K. DECLARATION OF POSTING
6 SPECIAL MEETING
JUNE 2, 2022
11600 Air Expressway • Adelanto, CA 92301 • (760) 246-2300 • www.ci.adelanto.ca.us

YOUR CITY GOVERNMENT
CHARTER CITY: Ratified by the electors of the City at an election on November 3, 1992. “A Charter City can do what the Charter permits it to do, so long as there is not direct violation of the State Constitution.”
CITY COUNCIL: The City Council is the legislative and policy-making body of the City. The City Council is composed of one elected Mayor and four Council Members, elected at large (to represent the entire City), to serve four (4) year, staggered terms.

CITY MANAGER: The City Manager is the chief executive officer responsible for the day-to-day administration of City affairs.

CITY COUNCIL MEETING: The regular meeting of your City Council is a vital part of the democratic process in the conduct of the City’s affairs. These meetings are open to the public and conducted by your elected representatives who are responsible, as a body, for the operation of Adelanto’s City government. The City Council appreciates your interest and urges citizen participation in government matters.

LEGISLATIVE TERMS
ORDINANCES: Ordinances are the means by which the City enacts its local laws. Unless an urgent situation exists, ordinances will first be presented at a City Council meeting as a “first reading.” At a subsequent City Council meeting, there will be a “second reading” and vote for or against adoption. Ordinances go into effect after a waiting period of thirty (30) days, in most cases, during which time the summary of the ordinance is published in a local newspaper approved for this purpose.

RESOLUTIONS: Resolutions and minute orders are the means by which the City Council formally adopts policies and/or approves specific actions. These go into effect upon adoption 7 Adelanto City Hall ~ 11600 Air Expressway, Adelanto, CA 92301 ~ (760) 246-2300 ~ Fax (442) 249-1121

SPECIAL MEETING

OF THE ADELANTO CITY COUNCIL

ADELANTO PUBLIC FINANCING AUTHORITY,

ADELANTO PUBLIC UTILITY AUTHORITY,

ADELANTO COMMUNITY BENEFIT CORPORATION,

AND THE SUCCESSOR AGENCY BOARD
JUNE 2, 2022
On March 4, 2020, Governor Newsom proclaimed a State of Emergency in California as a result of the threat of COVID-19. On September 16, 2021, Governor Newsom signed Assembly Bill 361 (“AB 361”), which was effective immediately and amends Government Code § 54953 to allow a local legislative body to hold public meetings via teleconferencing and to make public meetings accessible telephonically or otherwise electronically to all members of the public seeking to observe and to address the local legislative body. Pursuant to AB 361, please be advised that members of the Adelanto City Council may participate in meetings telephonically.

Pursuant to AB 361, the public may view the meeting and participate in public comment remotely as follows:
• All of our meetings are streamed live at
https://adelanto.granicus.com/ViewPublisher.php?view_id=1 and are also available for playback after the meeting.
• https://zoom.us/j/95612357515?pwd=S2d2MUM2TGtsSjl0SjA3bVNHK2tMQT09 To Participate and Call in for public comments:

TIME
Closed Session 10:00 A.M.

Open Session – Thereafter

TELECONFERENCE
To Participate and and Call in for public
comments:

Please call 1-669-900-6833 along with
conference code 956 1235 7515
Should you wish to speak on the item push *9, you
will be placed in the que. *

Brenda Lopez, City Clerk, CMC
DATED: May 31, 2022
8 CITY COUNCIL AGENDA REPORT
DATE: June 2, 2022
TO: Honorable Mayor and City Council Members
FROM: Jessie Flores, City Manager
THROUGH Dave Martinez, Development Services Director
BY: Mary Blais, Planning Consultant
SUBJECT: PUBLIC HEARING – APPEAL OF PLANNING COMMISSION APPROVAL/ADOPTION

OF THE INITIAL STUDY/MITIGATED NEGATIVE DECLARATION FOR CONDITIONAL USE PERMIT 21-04, LOCATION AND DEVELOPMENT PLAN 21-04, TENTATIVE PARCEL MAP 20437
STAFF RECOMMENDATION:

Staff recommends that the City Council, DENY THE APPEAL and APPROVE/ADOPT the Initial Study/Mitigated Negative Declaration (IS/MND) for Conditional Use Permit 21-04, Location and Development Plan 21-03 & Tentative Parcel Map 20437 and adopt Council Resolution No. 22-21 (Attached as Exhibit A) adopting the findings and approving/adopting the IS/MND for Conditional Use Permit 21-04, Location and Development Plan 21-03 & Tentative Parcel Map 20437, a 15-acre site located on Auburn Avenue, between Montezuma Street and Jonathan Street in the Airport Development District (ADD) zone in the City of Adelanto, California (APN’s: 0459-053-70, 71, 72 &74); BACKGROUND:

At the meeting of January 19, 2022, the Planning Commission unanimously approved (vote of 4-0) Conditional Use Permit 21-04, Location & Development Plan 21-03 and Tentative Parcel Map 20437 and adopted a Mitigated Negative Declaration for the project. The signed Planning Commission Resolution is attached as Exhibit B.

An Appeal of the Planning Commission Approval was filed on February 2, 2022, ten (10) working days following the Planning Commission by the Southwest Regional Council of Carpenters (SWRCC). The appeal application, attached as Exhibit C, opposes to the adoption of the IS/MND for Conditional Use Permit 21-04, Location & Development Plan 21-03, Tentative Tract Map 20437.

An Appeal Hearing was scheduled for City Council for April 26, 2022; however it was subsequently cancelled due to technical difficulties. The Council Hearing was then rescheduled to June 2, 2022, and a new public notice was published.
9 CUP 21-04, LDP 21-04, TPM 20437
Council Appeal

Page 2 ends

PROJECT DESCRIPTION:

The project involves a Conditional Use Permit No. 21-04 to establish commercial cannabis uses, including adult and medical, cultivation, non-volatile manufacturing and distribution as well as approval for a Location and Development Plan to construct twelve 30,375 square feet (SF) (including mezzanine) buildings and relating parking, drainage, landscaping and on and off-site improvements in Four (4) Phases. Each building consists of 30,375 SF of floor area, including a 6,000SF mezzanine; thus 364,500 SF total building square footage is proposed on the site. Three buildings would be constructed during each of the three phases. Each building would be divided in to two units. All twelve buildings would have the same architectural design and floor plans.

APPEAL DISCUSSION OF THE ADOPTION/APPROVAL OF INITIAL STUDY/MITIGATED NEGATIVE DECLARATION (IS/MND):

The Appellant, SWRCC, outlines their basis for appealing the adoption of the IS/MND for CUP 21-04, LDP 21-04 and TPM 20437, attached as Exhibit C. In summary, SWRCC argues the following:

I. The Final IS/MND requires recirculation;
II. The Project would be approved in violation of CEQA (EIR must be prepared); and III. The Project violates the State Planning and Zoning Law as well as the City’s General Plan In response to the Appellant’s contentions, Blodgette Baylosis, the Environmental Consultant that prepared the IS/MND CEQA document, responded to the Appeal claims in a memorandum, Attached as Exhibit E, which is summarized as follows:

I. The Final IS/MND does not require recirculation pursuant to the California Environmental Quality Act (CEQA), § 15073.5, which states provides the basis for determining whether to recirculate an MND. The Mitigation Measures that were revised are outline in Exhibit E; and II. A Mitigated Negative Declaration was determined to be the appropriate environmental document, rather than an EIR because following the preparation of an Initial Study, the City, as Lead Agency determined that in light of the whole record, the proposed project would not result in significant impacts to the project with the application of mitigation measures pursuant CEQA §15070; and
III. The project does not violate State Planning and Zoning Laws or the City’s General Plan as it does not directly conflict with the City’s General Plan, nor does it interfere or frustrate the General Plan’s policies or objectives as evidenced by the findings and whole of the record.

FISCAL IMPACT:

An Appeal of Planning Commission Decision fee of $1,806.00 was paid by the SWRCC.

EXHIBITS:
10 CUP 21-04, LDP 21-04, TPM 20437
Council Appeal

Page 2 ends

A. Council Resolution No. 22-21 denying the appeal
B. Planning Commission Resolution 21-27 (Signed)
C. Southwest Regional Council of Carpenters (SWRCC) Appeal Package D. Planning Commission Staff Report Package, February 19, 2020 E. Blodgett Baylosis Response to Appeal Memo, April 2, 2022 11 EXHIBIT A
RESOLUTION NO. 22-21

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF

ADELANTO, COUNTY OF SAN BERNARDINO, CALIFORNIA,

MAKING FINDINGS, DENYING APPEAL OF PLANNING

COMMISSION DECISION, AND APPROVING AND ADOPTING THE

INITIAL STUDY/MITIGATED NEGATIVE DECLARATION (IS/MND)
FOR CONDITIONAL USE PERMIT 21-04, LOCATION AND
DEVELOPMENT PLAN 21-03 & TENTATIVE PARCEL MAP 20437, A 15-

ACRE SITE LOCATED ON AUBURN AVENUE, BETWEEN

MONTEZUMA STREET AND JONATHAN STREET IN THE AIRPORT

DEVELOPMENT DISTRICT (ADD) ZONE IN THE CITY OF
ADELANTO, CALIFORNIA (APN’S: 0459-053-70, 71, 72 &74)
WHEREAS, the Southwest Regional Council of Carpenters (SWRCC) filed an appeal of the Planning Commission’s adoption of the Initial Study/Mitigated Negative Declaration (IS/MND) for Conditional Use Permit 21-04, Location & Development Plan 21-03, Tentative Tract Map 20437 (“the Project”) on February 2, 2022, which was within ten (10) working days following the Planning Commission’s unanimous approval of the Project; and WHEREAS, on January 19, 2022, the Planning Commission unanimously approved (vote of 4-0) Conditional Use Permit 21-04, Location & Development Plan 21-03 and Tentative Parcel Map 20437 and adopted a Mitigated Negative Declaration for the project; and WHEREAS, the applicant timely appealed the Planning Commission’s decision; and WHEREAS, the City of Adelanto, as lead agency, determined that a Mitigated Negative Declaration and Mitigation, Monitoring and Reporting Program forthe proposed was the appropriate environmental document to adopt for project pursuant to Sections 20192 of the California Public Resources Code and 15072 of the California Environmental Quality Act, Guidelines; and WHEREAS, the Planning Commission reviewed and considered the environmental information included in the staff report prior to acting on proposed the Project (Conditional Use Permit 21-04 and Location and Development Plan 21-03 and Tentative Tract Map 20437) and determined that the City has complied with the California Environmental Quality Act; and WHEREAS, the Planning Commission reviewed and considered the Project (Conditional Use Permit 21-04 and Location and Development Plan 21-03 and Tentative Tract Map 20437) and the Council affirms and adopts the Planning Commission findings of General Plan consistency, as presented in the record, as well as all Planning Commission findings outlined in the record for the Project; and
WHEREAS, in accordance with State law, on April 26, 2022, a duly noticed public hearing was scheduled with the City Council; however due to technical difficulties the hearing was cancelled; and
12 RESOLUTION NO. 22-21
June 2, 2022

Page 2 ends

WHEREAS, in accordance with State law, on June 2, 2022, City Council conducted a duly notice public hearing on the project, took information presented by City staff and public testimony regarding the Project, and considered the Project; and
NOW, THEREFORE, BE IT RESOLVED by the City Council as follows:

SECTION 1. The above recitals are all true and correct.

SECTION 2. The City Council has reviewed and considered the information included in the staff reports prior to taking action on the Appeal. The City Council further finds and determines that the City has complied with the California Environmental Quality Act and the City Council determinations reflect the independent judgment of the City Council.

SECTION 3. The City Council hereby denies the appeal and upholds the Planning Commission’s decision to adopt the Initial Study/ Mitigated Negative Declaration (IS/MND), the and the Project and finds and determines that City as Lead Agency met the requirements established by the City of Adelanto Municipal Code, Section 17.190 (Environmental Review) and the provisions of California Public Resources Code 21000 et seq. pursuant to the Guidelines adopted by the Secretary of Resources and incorporated into the California Code of Regulations, Title 14, Section 15000 et seq.

SECTION 4. The City Council hereby upholds the Planning Commission adoption of the IS/MND for the Project (CUP 21-04, LDP 21-04, TPM 20437) as well as the approval of the Project.

PASSED, APPROVED AND ADOPTED by the City Council this 2 nd day of June, 2022.
_________________________________

GABRIEL REYES, MAYOR
13 RESOLUTION NO. 22-21
June 2, 2022

Page 3 ends

ATTEST:
___________________________________

BRENDA LOPEZ, CITY CLERK CMC
14 RESOLUTION NO. 22-21
June 2, 2022

Page 4 ends

I, Brenda Lopez, City Clerk of the City of Adelanto, California, do hereby certify that the foregoing Resolution No. 22-21 was duly and regularly adopted at a regular meeting of the City Council of the City of Adelanto on the 2
nd day of June, 2022, by the following vote, to-wit:

AYES:

NOES:

ABSENT:

ABSTAIN:

IN WITNESS WHEREOF, I hereunto set my hand and affix the official seal of the City of Adelanto on the 2
nd day of June, 2022.
___________________________________
Brenda Lopez, CMC
City Clerk
SEAL
15 RESOLUTION NO. P-21-27

A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF

ADELANTO, SAN BERNARDINO COUNTY, CALIFORNIA, ADOPTING THE

MITIGATED NEGATIVE DECLARATION AND APPROVING CONDITIONAL USE PERMIT 21-04 TO ESTABLISH COMMERCIAL MEDICAL AND ADULT-USE

CANNABIS CULTIVATION, NON-VOLATILE MANUFACTURING,

DISTRIBUTION AND TRANSPORTATION AND LOCATION AND
DEVELOPMENT PLAN 21-03 TO CONSTRUCT TWELVE 30,375 SF (INCLUDING MEZZANINE) BUILDINGS AND TENTATIVE PAREL MAP 20437 TO SUBDIVIDE THE PROPERTY INTO 12 PARCELS ON 15-ACRES LOCATED ON AUBURN

AVENUE BETWEEN MONTEZUMA STREET AND JONATHAN STREET IN THE

AIRPORT DEVELOPMENT DISTRICT (ADD) ZONE IN THE CITY OF
ADELANTO, CALIFORNIA (APN: 0459-053-70, 71, 72 & 74) SUBJECT TO

CONDITIONS AND MAKING FINDINGS IN SUPPORT THEREOF
WHEREAS, the applicant, Pontious Architecture (Mike Pontious, AIA) has proposed Conditional Use Permit 21-04 to establish commercial medical and adult use cannabis cultivation, non-volatile manufacturing and distribution and ancillary uses, Location and Development Plan 21-03 to construct twelve 30,375 sf (including mezzanine) buildings and Tentative Parcel Map 20437 to subdivide the property into 12 parcels on 15-acres located on Auburn Avenue, between Montezuma Street and Jonathan Street in the Airport Development District (ADD) zone in the City of Adelanto, California (APN’s: 0459-053-70, 71, 72 &74); and
WHEREAS, the applicant has consented to all conditions of approval (Exhibit A) and WHEREAS, a duly noticed public hearing was held by the Adelanto Planning Commission on December 1, 2021, to hear and consider testimony for or against the proposed project; however, the project was continued to December 15, 2021. The project was continued at the December 15, 2021 Planning Commission hearing to January 19, 2022 to the allow the applicant additional time to address comments received on the Mitigated Negative Declaration document; and WHEREAS, the City of Adelanto, as lead agency, determined that a Mitigated Negative Declaration and a Mitigating and Reporting Program for the proposed project should be prepared for adoption pursuant to Sections 20192 of the California Public Resources Code and 15072 of the California Environmental Quality Act, Guidelines; and
NOW, THEREFORE, BE IT RESOLVED by the Planning Commission as follows:

SECTION 1. The above recitals are all true and correct.

SECTION 2. The Planning Commission has reviewed and considered the environmental information included in the staff report prior to acting on proposed Conditional Use Permit 21-04 and Location and Development Plan 21-03 and Tentative Tract Map 20437. The Planning Commission further finds and determines that the City has complied with the California Environmental Quality Act and the Planning Commission determinations reflect the independent judgment of the Planning Commission.

SECTION 3. The Planning Commission hereby finds and determines that:
16 Conditional Use Permit 21-04
(a) That the proposed Conditional Use Permit is consistent with the General Plan; The project is consistent with the General Plan as the site is designated Airport Development District (ADD), which is consistent with Appendix A of Title 17 of the Zoning Code which allows Cannabis uses with approval of a Location and Development Plan and Conditional Use Permit.
(b) That the nature, condition, and development of adjacent uses, buildings, and structures have been considered, and that the use will not adversely affect or be materially detrimental to these adjacent uses, buildings, or structures; Surrounding properties to the north, south, east and west are all currently zoned for ADD uses, which permits similar compatible uses and as such, the project would not adversely affect these surrounding properties.
(c) That the site for the proposed use is of adequate size and shape to accommodate the use and buildings proposed;
The project site is 15-acres and is far larger than the minimum required 20,000 square feet parcel size required in this zoning district and further provides for sufficient width and depths and required setbacks for the proposed buildings. (d) That the proposed use complies with all applicable development standards of the Zoning district; and
The proposed project has been designed and conditioned to meet all applicable City zoning and development standards.
(e) That the proposed use observes the spirit and intent of this Zoning Code.

The proposed project meets the requirements of the Zoning Code. However, to ensure all Code requirements are met, conditions of approval has been added reflecting these requirements.

Location and Development Plan 21-03
(a) That the proposed Location and Development Plan is consistent with the General Plan; The project is consistent with the General Plan as the site is designated Airport Development District (ADD), which is consistent with Title 17 of the Zoning Code, which allows for the proposed uses in the ADD zoning district with an approved Location and Development Plan.
(b) That the nature, condition, and development of adjacent uses, buildings, and structures have been considered, and that the use will not adversely affect or be materially detrimental to these adjacent uses, buildings, or structures; The nature, condition and development of adjacent uses, buildings and structures have been considered and the use will not adversely affect or be detrimental to these uses, 17 building or structures, as surrounding properties to the north, south, east and west are all currently zoned for ADD uses, which permits similar compatible uses and as such, the project would not adversely affect these surrounding properties. (c) That the site for the proposed use is of adequate size and shape to accommodate the use and buildings proposed;
The overall site is approximately 15-acres in size, which exceeds the minimum 20,000 square feet required in the ADD zoning district and is of adequate size and shape to accommodate the use and proposed building and improvements. (d) That the proposed use complies with all applicable development standards of the zoning district; and
The proposed project has been designed and conditioned to meet all applicable City zoning and development standards for the ADD zoning district. (e) That the proposed use observes the spirit and intent of this Zoning Code.

The proposed project meets the requirements of the Zoning Code. In addition, to ensure all Code requirements are met, conditions of approval have been added requiring that the project meet code requirements.

Tentative Parcel Map 20437
(a) That the proposed Tentative Parcel Map is consistent with the General Plan; The proposed tentative parcel map project is consistent with the General Plan as the map has been conditioned to meet all design requirements. (b) That the design or improvement of the proposed subdivision is consistent with applicable general and specific plans.

The design of the proposed subdivision is consistent with the City’s general Plan in that it meets all requirements of Title 16 (Subdivisions) of the Adelanto Municipal Code, which implements the General Plan.
(c) That the site is physically suitable for the type of development.

The proposed site is physically suitable for the development in that the site is of adequate size to accommodate future uses and provides for street dedications and easements sufficient for future development.
(d) That the site is physically suitable for the proposed density of development.

The proposed site is physically suitable for the proposed density of the development in that it meets or exceeds all development standards of the zoning district. 18 (e) That the design of the subdivision or the proposed improvements are not likely to cause substantial environmental damage or substantially and avoidably injure fish or wildlife or their habitat.

The design of the subdivision is not likely to cause substantial environmental damage and/or injure fish or wildlife in that mitigation measures have been proposed to eliminate the potential for environmental damage.
(f) That the design of the subdivision or type of improvements is not likely to cause serious public health problems.

The design of the subdivision is unlikely to cause serious public health problems in that the site as mitigation measures have been proposed to eliminate the potential for serious health problems.
(g) That the design of the subdivision or the type of improvements will not conflict with easements, acquired by the public at large, for access through or use of, property within the proposed subdivision.

The design of the subdivision will not conflict with easements acquired by the public for access through or use of property, in that all easements have been identified and no conflicts have been identified.

ATTACHMENTS:

Attachment B: Exhibit A - Conditions of Approval CUP 21-04, LDP 21-03, TPM 20437 PASSED, APPROVED AND ADOPTED by the Planning Commission this 19th day of January, 2022.

Chris Waggener
Chairman of the Planning Commission
Nyeka Allen
Secretary to the Planning Commission
19 I, Nyeka Allen, Planning Secretary for the Planning Commission of the City of Adelanto, California, do hereby certify that the foregoing Resolution No. P-21-27 was duly and regularly adopted at a regular meeting of the Planning Commission of the City of Adelanto on the 19 th
day of January 2022, by the following vote, to-wit:

AYES:

NOES:

ABSENT:

ABSTAIN:

IN WITNESS WHEREOF, I hereunto set my hand and affix the official seal of the City of Adelanto on the 19th day of January, 2022.

Nyeka Allen
Secretary to the Planning Commission
Chair Waggener, Vice-Chair Delgado, Commissioners Meza, Villa None
None
None
20 Attachment B
Exhibit A (Resolution 21-27)
Morris Mu - Conditions of Approval
CUP 21-04, LDP 21-03, TPM 20437 – January 19, 2022
PROJECT: Conditional Use Permit 21-04 to establish commercial medical and adult use cannabis cultivation, non-volatile manufacturing and distribution and ancillary uses, Location and Development Plan 21-03 to construct twelve 30,375 sf (including mezzanine) buildings and Tentative Parcel Map 20437 to subdivide the property into 12 parcels on 15-acres located on Auburn Avenue, between Montezuma Street and Jonathan Street in the Airport Development District (ADD) zone in the City of Adelanto, California (APN’s: 0459-053-70, 71, 72 &74) Applicant: Pontious Architecture, Mike Pontious, AIA, 17795 Hwy 18, Suite 4, Apple Valley, CA 92307

PLANNING DEPARTMENT
General Conditions:

1. Approval Period. Approval of this project will become valid only after a signed copy of the City’s approval letter is received by the Planning Department acknowledging acceptance of all conditions of approval. If not received within 10 working days after approval action, this approval will be null and void.

This approval shall be used within two (2) years of the approval date of this project; by January 19, 2024, otherwise, it shall become null and void and of no effect whatsoever.

Use means the beginning of the substantial construction under this approval within the two (2) year period which is thereafter diligently pursued to completion and in the event the use hereby permitted ceases operation for a period of one (1) year or more, this approval shall become null and void.

2. Modification to Plans. Subsequent modifications of this approval, which do not intensify the use, including but not limited to reorientation of structures, alteration of parking and circulation design, minor changes to the Conditions of Approval, interpretations of the Conditions of Approval relative to intent, necessity of, and timing, may be approved by the Community Development Director, unless the Director requires a Substantial Conformance or Revised Permit application in accordance with the City’s Development Code. 21 CUP 21-04, LDP 21-03, TPM 20437
Conditions of Approval

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3. Phasing. The project will be constructed in Four (4) Phases per the below table:

Table 1: Construction Phasing

PHASES IMPROVEMENTS
Phase 1 –
Buildings E and I
• Site Work for the first phase of construction including building footings, utility lines, and other underground infrastructure;
• Construction of two, 30,375SF buildings including a 6,000SF mezzanine • Auburn Avenue access and street improvements, on-site paving, trash enclosures, loading, landscaping, and improvements for the three buildings; • Parking spaces for the buildings, including ADA & EV spaces; Phase 2 –
Buildings A, F and J
• Site Work for the site for the second phase of construction, including such as footings, utility lines, and other underground infrastructure; • Internal access, on-site paving, trash enclosures, loading, landscaping, and improvements for the two buildings;
• Construction of three, 30,375SF buildings including a 6,000SF mezzanine • Western-most Jonathan Street access and street improvements, on-site paving, trash enclosures, loading, landscaping, and improvements for the three buildings;
• Parking spaces for the buildings, including ADA & EV spaces; Phase 3 –
Buildings B, G and K
• Site Work including footings, utility lines, and other underground infrastructure; • Middle access from Jonathan Street, and one access from Montezuma Street, street improvements, internal drive-aisles, on-site paving, trash enclosures, loading, landscaping, and improvements for the three buildings; • Construction of three, 30,375SF buildings including a 6,000SF mezzanine • Parking spaces for the buildings, including ADA & EV spaces; Phase 4 –
Buildings C, H, L and
D
• Site Work including footings, utility lines, and other underground infrastructure; • Eastern-most access on Jonathan Street, Internal access, on-site paving, trash enclosures, loading, landscaping, and improvements for the two buildings; • Construction of four, 30,375SF buildings including a 6,000SF mezzanine • On-site paving, trash enclosure, loading, landscaping, and improvements for the two buildings;
• Parking spaces for the buildings, including ADA & EV spaces;

4. Indemnity. The applicant shall defend (with attorneys approved by the City), indemnify and hold harmless the City of Adelanto, its agents, officers, and employees from any claims, damages, action, or proceeding against the City or its agents, officers, or employees to attack, set aside, void, or annul, an approval of the City, its advisory agencies, appeal boards, or legislative body concerning Location and Development Plan 19-15. The City will promptly notify the permittee of any such claim, action, or proceeding against the City and will cooperate fully in the defense.

5. Indemnification of the City. (a) Applicant shall defend and indemnify the City, its agents, officers and employees from all claims against the City for damages, and other action, liability or proceeding to attack, set aside, void or annual the Project or any act or determination related to City’s approval of the Project. Applicant’s obligations under this Agreement shall include, without limitation, payment of all court costs and attorney fees, all litigation-related costs, all judgments and awards against the City, and all settlement costs. (b) The City shall notify the Applicant promptly of any claim, action or proceeding and reasonably cooperate in the defense. Upon receiving such notification, Applicant shall assume the defense of the claim, action, or proceeding, including the employment of counsel satisfactory to City, which approval shall not be unreasonably withheld. In the event of a disagreement between the City and Applicant over litigation issues, City shall have authority to control the litigation and make litigation decisions, including but not limited to, settlement or other disposition of the matter. City’s participation in the defense of any 22 CUP 21-04, LDP 21-03, TPM 20437
Conditions of Approval

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such action shall not relieve the Applicant of any obligation imposed by this condition. If City determines that having common counsel would create a conflict of interest, or if Applicant fails to promptly assume the defense or to promptly employ counsel satisfactory to City, then City may hire counsel for its own defense, and Applicant shall pay the reasonable attorney fees and costs of such counsel within 30 days after receiving itemized invoices. Applicant shall also pay for all costs and fees related to any additional investigation or study, or for supplementing or revising any document, including, without limitation, environmental documents.

6. Fees. All fees and charges the City has or intends to adopt that are due at the time of utility connection or when building permit(s) is/are issued shall be paid for the Developed Area, as required by the City.

7. Outstanding Costs. Any fees due to the City of Adelanto for processing this project shall be paid to the City within 30 calendar days of final action. Failure to pay such outstanding fees within the time specified shall invalidate any approval or conditional approval granted by this action. No permits, site work, or other actions authorized by this entitlement shall be permitted, authorized or commenced until all outstanding fees are paid to the City.

8. CEQA/Fish and Game Fees. The applicant/owner shall file a Notice of Determination with San Bernardino County and pay related County fee for such within five (5) days after the effective date of conditional approval. The applicant should be aware that Section 21089(b) of the Public Resources Code provides that any project approved under CEQA is not operative, vested or final until the required fee is paid. Proof of filing is required prior to issuance of any permits.

9. Mitigation Monitoring Reporting Program for CUP 21-04, LDP 21-04, TPM 20437. The project shall incorporate mitigation measures specified in the adopted IS/MND that would avoid or mitigate effects to point where clearly no significant environmental impacts on the environment would occur.

10. Architectural Design. The proposed architectural design shall be consistent with the design standards provided in the Adelanto General Plan and Industrial Design Guidelines, as shown on the revised site plan package presented to the Planning Commission.

11. City Codes. The project shall comply with all disabled access requirements of the Americans with Disabilities Act and Title 24 of the State Code, and all local requirements of the City of Adelanto Municipal Code, including Title 17 (Zoning Code), especially the following Manufacturing/Industrial zoning district regulations, approved site plan package, stamped 3.18.20, presented to the Planning Commission.

12. Maintenance Responsibility. The maintenance of graded slopes and landscaped areas shall be the responsibility of the developer until the transfer to an approved maintenance authority. Grading permits shall not be issued for any areas to be graded and remain undeveloped for an extended period (i.e. for subsequent phases of a development) until a re-vegetation plan is approved by the Planning Department, and until bonds are posted for re-vegetation, or erosion control program for wind erosion. 23 CUP 21-04, LDP 21-03, TPM 20437
Conditions of Approval

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13. Plans. Plan submittals shall be prepared and signed by a California Licensed Architect or Engineer per State of California, Business and Professions Code. All plans shall be drawn to a standard scale.

14. Development Restrictions. The physical development of the site shall be reviewed and approved by the City. Any use, activity, and/or development occurring on the site without appropriate City approvals shall constitute a code violation and shall be treated as such.

Placement of any construction trailer or storage of construction materials shall require separate review and approval by the City.

15. Trash Enclosures. All required trash receptacles proposed for the site shall be enclosed by a six (6) foot high solid masonry wall with solid, view-obstructing gates. A pedestrian entrance shall be provided into each trash enclosure.

16. Approved Uses. All new uses within the property boundaries shall be reviewed and approved by the Planning Department. Should the developer propose a more intensive use requiring additional parking spaces, additional employees, more restroom facilities, significant change from original conceptual landscaping plans, etc., the proposed use shall be presented for review by the Planning Department for compliance with the original approval. The new proposed use may be subject, but not limited to: A Modification to Location and Development Plan application, a new Location and Development Plan Application, and/or a Utility Feasibility Study application.

17. Required Approvals. The developer shall obtain the following clearances or approvals:
a. Verification from the Planning Department that all pertinent conditions of approval have been met, including any administrative development plan review approvals, as mandated by the Adelanto Municipal Code.
b. Building and Safety Department
c. Engineering Department/Public Works
d. San Bernardino County Fire Department
e. Mojave Desert AQMD
f. California Department of Fish and Wildlife
g. Any other required approval from an outside agency.

Prior to Issuance of Grading Permits:

18. Grading Plans. Grading plans shall be reviewed and approved by the Planning Department for compliance with the approved Development Plan prior to the issuance of a grading permit.

19. Joshua Trees. Prior to the commencement of grading, when Joshua Trees are present onsite, the applicant shall obtain an Incidental Take Permit from the State Fish & Wildlife 24 CUP 21-04, LDP 21-03, TPM 20437
Conditions of Approval

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regulations prior to site disturbance activities, per the California Desert Native Plant Act.

20. Proof of Mitigation. Prior to the issuance of grading permits, the developer shall submit written proof, satisfactory to the Development Services Director, that the Mitigation Measures outlined in the Mitigation Monitoring and Reporting Program as part of the project Mitigated Negative Declaration have been completed.

21. Signed Approval Letter. A signed copy of the City’s approval letter shall be on file with the Planning Department. If ownership of the property or the developer of the property has changed since the original approval, a new copy of the City approval letter shall be signed by the current development parties.

22. Conditions of Approval. The conditions of approval for Conditional Use Permit 21-04, Location and Development Plan 21-03 and Tentative Parcel Map 20437 shall be included on the construction plans and submittal to the Building and Safety Department for Plan Check.

23. Approved Site Plan. The site plan presented to the Planning Commission and stamped approved by the Planning Division shall be included on the construction plans submitted to the Building and Safety Department for Plan Check.

Prior to Issuance of Building Permits:

23. Development Impact Fees. The City of Adelanto has implemented development impact fees for various infrastructure and capital facilities needs generated by new development.

These fees will provide for various capital facilities including, but not limited to, roads, parks, flood control and drainage, public facilities, and fire fighting facilities. This project shall be subject to all such existing and future development impact fees, which are in effect at the time building permits are issued.

24. Assessment Districts. Prior to the issuance of building permits, this project shall annex into Assessment Districts for the maintenance of Street Lighting, public landscaping and street sweeping, and the applicant hereby agrees to waive the right to protest the formation of said districts.

25. Building Plans. Building plans shall be reviewed and approved the Planning Department for conformance to the Conditions of Approval and the approved Development Plan prior to issuance of a building permit.

26. Water Quality. The applicant shall submit to the City Engineer for approval, a Water Quality Management Plan (WQMP), including a project description and identifying Best Management Practices (BMPs) that will be used on-site to reduce pollutants into the storm drain system to the maximum extent practicable. The Water Quality Management Plan shall identify the structural and non-structural measures consistent with the City’s adopted requirements.

27. Equipment Screening. All mechanical equipment and vents, ground or rooftop shall be screened from public view. Roof gutters and downspouts are not permitted on the exterior of the building unless integrated into the architecture of the building. In addition, all screening shall be an integral part of the building, details of which shall be provided to the Planning Department for review and approval. Any proposed change shall be reviewed and approved by the Planning Department.

28. Signage. Proposed signs for this development shall require a separate application approval by the Planning Department prior to installation. Furthermore, all signs proposed 25 CUP 21-04, LDP 21-03, TPM 20437
Conditions of Approval

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for this development shall remain in full compliance with all City sign regulations at all times.

29. Utility Lines. All proposed utility lines shall be placed underground.

30. Landscaping. The developer shall submit three (3) copies of construction level Landscape and Irrigation Plans to the Planning Department, accompanied by the appropriate filing fee.

The plans shall be prepared by a registered landscape architect and include the location, number, genus, species, and container size of the plants. The cover page shall identify the total square footage of the landscaped area and note how it is to be maintained. Use of water efficient fixtures and drought tolerant plants is required. Landscaping shall consist of native or drought-tolerant plants capable of surviving the desert environment and climate with a minimum of maintenance and supplemental watering. A list of plants determined capable of meeting this criterion is contained in Section 17.60.080 . a. All landscaping and irrigation systems shall follow Section 17.60 of the Adelanto Municipal Code. Plans will be reviewed and approved by the Planning Department. b. A minimum of 5% of the project site shall be landscaped, exclusive of areas within the public right-of-way as per the conceptual landscape plans presented to the Planning Commission and shall be in compliance with Table 30-1 in Chapter 17.30 (Manufacturing /Industrial District) of the Municipal Code. c. The developer shall be responsible for planting landscaping in compliance with Section 17.60 of the Adelanto Municipal Code, entitled “Water Conservation/Landscaping Ordinance”, including but not limited to native droughttolerant plants and efficient irrigation systems. Species shall follow Section

17.60.80. 31. Parking/Ingress Reciprocal. The entire project shall provide a minimum of 268 parking spaces, including ADA spaces, EVCS, Clean Air spaces and bicycle parking. Parking shall be installed at each phase to serve each building constructed. All parking spaces and access areas shall meet the City’s requirements. The Final Map shall indicate that all drive aisles, parking spaces are shared in common for the benefit of all parcels or reciprocal parking/access agreement shall be recorded prior to recordation of the final map.

32. Signed Approval Letter. A signed copy of the City’s approval letter shall be on file with the Planning Department. If ownership of the property or the developer of the property has changed since the original approval or issuance of grading permits, a new copy of the City approval letter shall be signed by the current development parties.

During Construction:

33. Approved Plans. All construction shall be per building permits issued by the Building Department and UBC Standards, and dust control shall be exercised at all times during construction.

34. Dust Control. The applicant shall apply water to the disturbed portions of the project site at least two times per day. On days where wind speeds are sufficient to transport fugitive dust beyond the working area boundary, the applicant shall increase watering to the point that fugitive dust no longer leaves the property (typically a moisture content of 10%), and/or the applicant shall terminate grading and loading operations.

35. Construction Practices. To reduce potential noise and air quality nuisances, the following items shall be listed as “General Notes” on the construction drawings:
26 CUP 21-04, LDP 21-03, TPM 20437
Conditions of Approval

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a. Construction activity and equipment maintenance is limited to the hours between 7:00 a.m. and dusk on weekdays. Construction may not occur on weekends or State holidays, without prior consent of the Building Official. Non-noise generating activities (e.g. interior painting) are not subject to these restrictions. b. Stationary construction equipment that generates noise in excess of 65 dBA at the project boundaries must be shielded and located at least 100 feet from occupied residences. The equipment area with appropriate acoustic shielding shall be designated on building and grading plans. Equipment and shielding shall remain in the designated location throughout construction activities. c. Construction routes are limited to City of Adelanto designated truck routes. d. Water trucks or sprinkler systems shall be used during clearing, grading, earth moving, excavation, or transportation of cut or fill materials to prevent dust from leaving the site and to create a crust after each day’s activities cease. At a minimum, this would include wetting down such areas in the later morning and after work is completed for the day and whenever wind exceeds 15 miles per hour. e. A person or persons shall be designated to monitor the dust control program and to order increased watering as necessary to prevent transport of dust off-site. The name and telephone number of such person(s) shall be provided to the City. f. All grading equipment shall be kept in good working order per factory specifications.

36. Construction Activity.
a. The contractor shall provide verification that all construction equipment is inproper tune per the manufacturer’s recommendation.
b. Roll off trash bins and chemical toilets for construction workers shall be required on all construction sites and temporary fencing provided around the construction sites and/or a row of temporary fencing provided at such location as to prevent any building materials from blowing off of the construction site. c. During those periods when grading is being conducted, the contractor shall inspect the adjacent paved roadways at least two times per week, and shall sweep the street if visible dirt or dust, attributable to the project, can be seen on the roadway.

37. Archeological Resources. If prehistoric or historic resources over 50 years of age are encountered during land modification, then activities in the immediate area of the finds shall be halted so that an archaeologist can assess the find, determine its significance, and make recommendations for appropriate mitigation measures. A historical resources management report shall be submitted by the professional to document the monitoring, to evaluate resource significance and integrity, and if necessary, to evaluate project impacts and propose mitigation measures to mitigate potential adverse impacts. If archeological resources are encountered during grading, ground disturbance activities shall cease so a qualified archeological monitor can evaluate the resources. If discovered resources merit long-term consideration, adequate funding shall be provided to collect, curate and report their resources in accordance with standard archaeological management requirements. If the City finds that a developer encounters cultural resources and fails to notify the Planning 27 CUP 21-04, LDP 21-03, TPM 20437
Conditions of Approval

Page 8 of 9 ends

Department, the City will place those responsible for the destruction of historic and archaeologically significant resources on file with the County of San Bernardino and the State of California, Office of Historic Preservation.

38. Paleontological Resources. If paleontological resources are encountered during grading, ground disturbance activities shall cease so a qualified paleontological monitor can evaluate any paleontological resources exposed during the grading activity. If paleontological resources are encountered, adequate funding shall be provided to collect, curate and report on these resources to ensure the values inherent in the resources are adequately characterized and preserved. Collected specimens will be sent to the Earth Sciences Division of the San Bernardino County Museum.

39. Human Remains. If human remains are encountered on the property, then the San Bernardino County Coroner's Office MUST be contacted within 24 hours of the find, and all work halted until a clearance is given by that office and any other involved agencies.

Contact the County Coroner at either 1) 15329 Bonanza Road, Unit 8, Victorville, CA 92392 or (760) 955-8535; or 2) 175 South Lena Road, San Bernardino, CA 92415-0037 or (909) 387-2978.

40. Abandoned Wells. Any abandoned wells on the property or similar structures that might result in groundwater contamination shall be destroyed in a manner approved by the City and San Bernardino County Environmental Health Department.

Prior to Certificate of Occupancy:

41. Landscaping and Irrigation. Landscaping and irrigation shall be consistent with the approved Landscape Plan for the project. The variety of tree to be provided is subject to approval of Planning and Public Works Departments and the trees are to be maintained by the property owner. The Developer shall be responsible for planting landscaping in compliance with Section 17.60 of the Adelanto Municipal Code, entitled “Water Conservation/Landscaping Ordinance”, including but not limited to native drought-tolerant plants and efficient irrigation systems. Species shall be in compliance with Section 17.60.80.

Perimeter landscaping pertains to Cassia and Raccoon only and onsite employee parking and building area.

42. Fencing/Walls/Screening. All walls and fences shall be constructed as shown on approved site plan package and 8’ tall chain link perimeter fence with slats and electric vehicle entry gates.

CONSERVATION

43. Mandatory Organic Recycling in accordance with AB 1826. Contact Burrtec – Robert Rios ([email protected]) for recycling information.

44. “Saving by Design” Southern California Edison Energy Efficiency – Contact Maya Aubrey [email protected] for electrical efficiency information.

45. For water conservation, use Hydroponics or other low water use irrigation systems. Water should be recycled as much as possible.

ENGINEERING/PUBLIC WORKS DEPARTMENT/BUILDING & SAFETY
28 CUP 21-04, LDP 21-03, TPM 20437
Conditions of Approval

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46. The project shall meet all Engineering/Public Woks and Building & Safety conditions of approval.

SAN BERNARDINO COUNTY FIRE DEPARTMENT

47. All conditions of approval specified by the San Bernardino County Fire Department shall be met.

MOJAVE DESERT AIR QUALITY MANAGEMENT DISTRICT (MDAQMD)

48. All conditions and requirements specified by the MDAQMD shall be met. 29 11600 Air Expressway • P.O. Box 10 • Adelanto, CA 92301 • (760) 246-2300 • www.ci.adelanto.ca.us P a g e | 1 Revised 5.3.2021

DEVELOPMENT SERVICES DEPARTMENT

COMPREHENSIVE APPLICATION FOR DEVELOPMENT

REVIEW AND LAND USE APPROVAL
CASE NUMBER: _________________________
DATE SUBMITTED: _________________________
APPLICATION TYPE FEE* APPLICATION TYPE FEE*

APPEAL OF DIRECTOR

DECISION
$1,806.00 _____ LOT LINE ADJUSTMENT/LOT MERGER/LOT

SPLIT/CERTIFICATE OF COMPLIANCE
$1,806.00 _____
APPEAL OF PC DECISION $1,806.00 _____ PRELIMINARY REVIEW $1,212.00 _____

CONDITIONAL USE PERMIT
(CUP)
$4,861.00 _____ TENTATIVE PARCEL MAP (TPM) $3,503.00 _____

MINOR CUP

DENSITY BONUS

AGREEMENT
$2,430.00
$4,352.00
_____
_____
TPM AMENDMENT $1,806.00 _____

ENVIRONMENTAL
ASSESSMENT*

FILING FEE
$2,230.00

85.00 _____
_____
TENTATIVE TRACT MAP (TTM) $4,861.00+
$60.00/lot
_____

GENERAL PLAN

AMENDMENT
$5,540.00 _____ TTM AMENDMENT $2,824.00 _____

MAJOR VARIANCE

MAJOR MODIFICATION
$2,485.00
$2,824.00
_____
_____
TIME EXTENSION $2,146.00 _____
MINOR VARIANCE $1,636.00 _____ ZONE CHANGE $5,540.00 _____ MINOR MODIFICATION $1,752.00 _____ ZONE CODE AMENDMENT $6,049.00 _____

MINOR LDP

LOCATION
&DEVELOPMENT PLAN
$2,430.00
$4,861.00
_____
_____

SPECIFIC PLAN AMENDMENT

SPECIFIC PLAN
$4,352.00
$6,898.00
_____
_____
*ADDITIONAL FEES:

San Bernardino County (SBC) Fire fees will be billed separately by SBC at the time your project is submitted & reviewed by the Fire Department. Plans must be uploaded separately through SBC EZ Online permitting system, “EZ Online Permitting Citizen Access Portal.” The California Environmental Quality Act (CEQA) applies to all discretionary “projects” and all applicants must complete an Environmental Assessment and submit an Environmental Assessment Fee of $2,230.00 as part of the land use approval application process. The appropriate CEQA determination must be made by a qualified environmental consulting firm, which shall be hired and paid for by the applicant. The City has established a list of qualified consultants, which is available at the front counter of the Development Services Department. Once a project is approved by the designated decisionmaking body a Notice of Exemption (NOE) or Notice of Determination (NOD) must be filed with the San Bernardino County Clerk of the Board of Supervisors. Separate filing fees apply.

Applicant/Contact Person: Company:

Telephone No. (____) Fax No. (____) E-mail:

Mailing Address:

STREET CITY STATE ZIP
X
Mitchell Tsai Mitchell M. Tsai, Attorney at Law
139 S Hudson St, Ste 200, Pasadena CA 91101
[email protected]
21-04 21-03 20437
626 314 - 3821 626 389 - 5414
30 11600 Air Expressway • P.O. Box 10 • Adelanto, CA 92301 • (760) 246-2300 • www.ci.adelanto.ca.us P a g e | 2 Revised 10.21.2021
Owner /Contact Person: Company:

Telephone No. (____) Fax No. (____) E-mail:

Mailing Address:

STREET CITY STATE ZIP
Arch-Eng/Contact Person: Company:

Telephone No. (____) Fax No. (____) E-mail:

Mailing Address:

STREET CITY STATE ZIP
General location or address location:

Assessor’s Parcel No(s):

Township: Range: Section Number:

Acreage: Zoning: RDA Project Area: _____
Associated Case(s): _______
_______
Complete Project Description/Reason for Request: If necessary, attach a detailed description to explain all proposed uses for this property or project.

Construction of twelve (12) 30,625 square foot buildings referred to as Building A through L. Each building would include a main floor and a mezzanine level consisting of 6,250 square feet. Each building would also be provided with 22 parking spaces. The total floor area of all 12 buildings would be 367,500 square feet. It would be constructed in four phrases within a 15.4 acre site.

The buildings would be used for adult and medical cannabis cultivation, manufacturing and distrbution 0459-053-70, 0459-053-71, 0459-053-72, 0459-053-74
San Be
Auburn Avenue, east of Montezuma Street, west of Jonathan Street, and north of Vintage Road

15.4 Airport Development District
31 11600 Air Expressway • P.O. Box 10 • Adelanto, CA 92301 • (760) 246-2300 • www.ci.adelanto.ca.us P a g e | 3 Revised 10.21.2021
_______

HAZARDOUS WASTE SITE CERTIFICATION
(Required pursuant to Section 65962.5 (f) of the California Government Code) The applicant/owner hereby certifies that they have consulted the list of hazardous waste sites for the City of Adelanto, dated , and the project is/is not (circle one) located on a site included on the list of hazardous waste sites for the City of Adelanto.

Air Quality/Hazardous Materials Certification: (Required pursuant to Section 65850.2 of the California Government Code)

1. The applicant/owner herby certifies that the project will/will not (circle one) need to comply with the requirements for a permit for construction or modification from the Mojave Desert Air Quality Management District, 14306 Park Avenue, Victorville, CA 92392, (760) 245-1661.

2. The applicant/owner herby certifies that the project will/will not (circle one) have more than a threshold quantity of a regulated substance, or will contain a source or modified source of hazardous air emissions. Please attach a list of any regulated substances and quantities anticipated, if applicable. (Note: Any quantity of hazardous waste or handling or storage of any quantity of acutely hazardous materials requires filing of a Management Plan and a permit from County Environmental health Services. A Management Plan and permit is also required for other hazardous materials if more than the threshold quantities are present, which are typically either 55 gallons of liquid, 200 cubic feet of pressurized gases, or a weight of 500 pounds.)

3. Describe any use, storage, or discharge of hazardous and/or toxic materials in the known history of this property.

Please list the materials and dates, if known.

4. The project is/is not (circle one) located within one-quarter (1/4) mile of a school.

NOTE: Plan review, permits, and inspections are also required from Engineering and Building and Safety prior to occupancy of the proposed project.

Certification: I hereby certify that I understand the information regarding deposits for processing costs, information, and requirements referenced in this application and that the information furnished above and in any attached exhibits is true and correct.

The property owner further certifies that they are the legal owner of the property and consent to the application.

Applicant’s Signature Date Property Owner’s signature Date Applicant’s Printed Name Property Owner’s Printed Name
32 11600 Air Expressway • P.O. Box 10 • Adelanto, CA 92301 • (760) 246-2300 • www.ci.adelanto.ca.us P a g e | 4 Revised 10.21.2021

PROPERTY OWNER(S) AUTHORIZATION FORM

AUTHORIZATION FOR AGENT TO ACT ON BEHALF OF LEGAL PROPERTY OWNER I/We, the owner(s) of the subject property, do hereby authorize to act in my/our behalf on matters pertaining to
PROCESSING COSTS: The City operates on the basis of full cost recovery for the processing of planning projects. Deposits made at the time of application are projected to be sufficient for the processing of most applications, however, additional deposits may be required to cover the projected costs for review of projects.

If at any time deposits are insufficient to cover projected costs, processing of the project will be stopped until sufficient additional funds are deposited with the City. Lack of sufficient funds on deposit will suspend any required processing time frames.

CERTIFICATION: I hereby certify that I understand the information regarding deposits for processing costs, information, and requirements referenced in this application. The property owner further certifies that they are the legal owner of the property and consent to the application.

Dated this day of , 20 .

Printed Name
Signature(s) of Legal Owner(s)
State of California )
County of San Bernardino )
On this day of 20 , before me
a Notary Public, personally appeared known to me to be the person(s) whose name(s) are/is subscribed to the within instrument and acknowledged that he/she/they executed the same.

Witness My Hand and Official Seal
Signature
Name (printed)
NOTE: If the property is a part of a corporation a list of authorized corporate officers must be provided. 33 11600 Air Expressway • P.O. Box 10 • Adelanto, CA 92301 • (760) 246-2300 • www.ci.adelanto.ca.us P a g e | 5 Revised 10.21.2021
Submittal Items Required for Application Types
• Application types are listed across the top of the chart, and items required along the side. An “X” in the box, means this item is required for that application type.
• Applications for modifications or extensions require the same information as the original project without the additional studies.
• Submit hard copies as well as electronic copies of required submittal items, either on a USB drive or via email at the time of application.

Tentative Tract or Parcel MapZone Change/ General Plan AmendmentConditional Use PermitMinor CUPLocation Development PlanMinor LDPMajor VarianceMinor VariancePreliminary Review Application and fee X X X X X X X X X
Preliminary Industrial Pretreatment and Wastewater
Discharge Permit (IPWDP)application - ALL

INDUSTRIAL, MANUFACTURING AND CANNABIS

ACTIVITIES MUST SUBMIT IPWDP

X X X X X X X X X
All Proposed Cannabis Projects Must Provide A
Written description of how cannabis wastewater is
treated (i.e., haul away, reverse osmosis or ?)
Biological Habitat Survey
(if required by Planning)

X X X X
Water & Sewer Utility Feasibility Study (All Cannabis
projects must provide)

X X X X X X X
Mailing Labels (3 sets) X X X X X
Preliminary Title Report ( within last 90 days) X X X X X X X X X Assessor’s Parcel Map X X X X X X X X X
Electronic copy of all items listed on this page (USB or e-mail)

X X X X X X X X X
The items listed below must be submitted as a full-size, 24”x36” plan package, stapled and folded to 8.5” x 11” size with the title block facing out. Two, full-size (2) sets and one (1) plan set reduced to 8.5”x 11 are required along with a USB drive containing an electronic plan set.

Site Plan X X X X X X X
Parcel/Tract Map X
Preliminary Grading and Drainage X X X
Architectural Elevations X X X X X X X
Colors and Materials Board X X X
Floor Plans X X X X X X X
Conceptual Landscape Plans X X
Date: ______________ Applicant Signature: _______________________________________ 34 11600 Air Expressway • P.O. Box 10 • Adelanto, CA 92301 • (760) 246-2300 • www.ci.adelanto.ca.us P a g e | 6 Revised 10.21.2021

REQUIRED PROPERTY OWNER(S) NOTIFICATION INFORMATION
THE FOLLOWING ITEMS WILL BE REQUIRED.

1. THREE identical packages to be inserted in separate 8 ¾ x 11-¼ manila envelopes. These envelopes shall indicate the case number and the word “labels”, and shall contain the following:
a. One typed set of gummed labels indicating all: the Assessor’s Parcel Numbers, property owner(s) name(s) and the mailing addresses that are within a 300-foot radius (700 feet if the site is 20 acres or more) of the exterior of their proposed project (this list shall be ascertained from the last equalized assessment roll). b. One label each for the owner/applicant/engineer.
c. A photocopy of the aforementioned labels.

2. TWO additional typed sets of gummed labels each for the applicant, owner, engineer, and representative with their mailing addresses. Do not include duplicate sets where applicant and owner, etc. are the same. These should be inserted in a letter-sized envelope and stapled to the outside of one of the large manila envelopes mentioned in item 1 above.

3. A 300-foot radius map on assessor’s map pages, which clearly shows the Assessor’s Parcel Numbers for each affected parcel.

Example:

PROPERTY OWNERS CERTIFICATION
_______(Print name), certify that on ______(month-day-year) ____________________ the attached property owners list was prepared by______________(Print company or individual’s name) pursuant to application requirements furnished by the City of Adelanto. Said list is a complete and true compilation of owner of the subject property and all other owners within 300 feet of the property involved in the application and is based upon the latest equalized assessment rolls.

I further certify that the information filed is true and correct to the best of my knowledge. I understand that incorrect or erroneous information may be grounds for rejection or denial of the application.

NAME ________________________________________ TITLE __________________________________ ADDRESS ______________________________________________________________________ PHONE __________________________ FAX
SIGNATURE_______________________ DATE _____________________________ 35 11600 Air Expressway • P.O. Box 10 • Adelanto, CA 92301 • (760) 246-2300 • www.ci.adelanto.ca.us P a g e | 7 Revised 10.21.2021

ENVIRONMENTAL INFORMATION FORM
(TO BE COMPLETED BY APPLICANT)
Date Filed
General Information
l. Name and address of developer or project sponsor:

2. Address of project:

Assessor’s Block and Lot Number:

3. Name, address, and telephone number of person to be contacted concerning this project:

4. Indicate number of the permit application for the project to which this form pertains:

5. List and describe any other related permits and other public approvals required for this project, including those required by city, regional, state and federal agencies:

6. Existing zoning district::

7. Proposed use of site (Project for which this form is filed):

Project Description:

8. Site size.

9. Square footage.

10. Number of floors of construction.

11. Amount of off-street parking provided.

12. Attach plans.

13. Proposed scheduling.

14. Associated projects.

15. Anticipated incremental development.

16. If residential, include the number of units, schedule of unit sizes, range of sale prices or rents, and type of household size expected.

17. If commercial, indicate the type, whether neighborhood, city or regionally oriented, square footage of sales area, and loading facilities.

18. If industrial, indicate type, estimated employment per shift, and loading facilities.

19. If institutional, indicate the major function, estimated employment per shift, estimated occupancy, loading facilities, and community benefits to be derived from the project.

20. If the project involves a variance, conditional use or rezoning application, state this and indicate clearly why the application is required.

Are the following items applicable to the project or its effects? Discuss below all items checked yes (attach additional sheets as necessary).

Yes No
36 11600 Air Expressway • P.O. Box 10 • Adelanto, CA 92301 • (760) 246-2300 • www.ci.adelanto.ca.us P a g e | 8 Revised 10.21.2021

21. Change in existing features of any bays, tidelands, beaches, or hills, or substantial alteration   of ground contours.

22. Change in scenic views or vistas from existing residential areas or public lands or roads.  

23. Change in pattern, scale or character of general area of project.  

24. Significant amounts of solid waste or litter.  

25. Change in dust, ash, smoke, fumes or odors in vicinity.  

26. Change in ocean, bay, lake, stream or ground water quality or quantity, or alteration of   existing drainage patterns.

27. Substantial change in existing noise or vibration levels in the vicinity.  

28. Site on filled land or on slope of 10 percent or more.  

29. Use of disposal of potentially hazardous materials, such as toxic substances, flammables   or explosives.

30. Substantial change in demand for municipal services (police, fire, water, sewage, etc.).  

31. Substantially increase fossil fuel consumption (electricity, oil, natural gas, etc.).  

32. Relationship to a larger project or series of projects.   Environmental Setting

33. Describe the project site as it exists before the project, including information on topography, soil stability, plants and animals, and any cultural, historical or scenic aspects. Describe any existing structures on the site, and the use of the structures. Attach photographs of the site.

34. Describe the surrounding properties, including information on plant~ and animals and any cultural, historical or scenic aspects.

Indicate the type of land use (residential, commercial, etc.), intensity of land use (one-family, apartment houses, shops, department stores, etc.), and scale of development (height, frontage, set-back, rear yard, etc.). Attach photographs of the vicinity.

Certification
I hereby certify that the statements furnished above and in the attached exhibits present the data and information required for this initial evaluation to the best of my ability, and that the facts, statements, and in formation presented are true and correct to the best of my knowledge and belief.

Date Signature
For
37 11600 Air Expressway • P.O. Box 10 • Adelanto, CA 92301 • (760) 246-2300 • www.ci.adelanto.ca.us P a g e | 9 Revised 10.21.2021

CHECKLIST OF REQUIRED INFORMATION

TENTATIVE TRACT AND PARCEL MAPS
_____ Tentative Map Number (Assigned by County Surveyor’s Office) _____ The licensed land surveyor or registered civil engineer shall sign, seal and provide their California registration or license number and the date of expiration of such number. _____ List the names, addresses and telephone numbers of the owners of record, the subdivider and the surveyor or engineer preparing the map.
_____ List the names, addresses and telephone numbers of all utility companies which will serve the subdivision including, but not limited to, water supply, sewage disposal, telephone, cable, electrical and natural gas. _____ Clearly show the north arrow (directed toward the top of the map),the scale of the map, the boundary lines, dimensions of the project and the date of preparation of the map. ____ Provide a vicinity map at a scale of one (1) inch equals eight hundred (800) feet of the area showing the proposed subdivision in relation to the adjacent subdivision, established roads, landmarks, etc., within one –quarter (1/4) mile of the exterior boundaries of the proposed subdivision. _____ List the Assessor’s Parcel Number (s) for the entire subdivision. _____ Provide a legal description of the land included within the proposed tentative map. _____ Provide information demonstrating legal, dedicated access to the subdivision and all proposed lots within the subdivision. Also demonstrate that no adjoining parcels are landlocked subsequent to the proposed subdivision. _____ Show all boundary lines of the proposed subdivision with appropriate bearings and distances. _____ Show the lot layout, dimensions of each lot (ditto marks are not acceptable) and a number or letter for each lot in consecutive order, Circle the last lot number and/or letter. _____ List the total acreage, the number of numbered lots and the number of lettered lots. Also list the size of each numbered and /or lettered lot and remainder parcels, if shown. _____ List the minimum, maximum and average lot size. Also list the existing and proposed zoning district classification for each lot and its proposed use.
_____ Show the General Plan land use designation, zoning district classification and land use or uses of the adjoining property within one hundred (100) feet of the proposed subdivision, including that which is across any streets.

Indicate the distances from all property lines and use of any structures on adjoining property. _____ Show the locations, names and existing rights-of all adjoining highways, streets, alleys and /or ways, roads, etc. If none exist, show access to the property. _____ Show the centerline profile (i.e. cross section) and grade for each proposed highway, street or drainage improvement shown on the tentative map.
_____ Show the width and location of all recorded and/or proposed easements, dedication of streets or rights-of-way. _____ Show the radius of all curves on highways and streets. _____ Show the location, all flood hazard areas and their designations. _____ Show the location and outline, to scale, of each existing building, utility pole or other above ground structure. Note on the map whether such building, pole or structure is to be removed from, or remain within the subdivision. _____ Show the location of existing and proposed water lines, sewers, culverts, bridges, drain pipes, fire hydrants and water wells within the subdivision.
38 11600 Air Expressway • P.O. Box 10 • Adelanto, CA 92301 • (760) 246-2300 • www.ci.adelanto.ca.us P a g e | 10 Revised 10.21.2021

CHECKLIST OF REQUIRED INFORMATION

SITE PLANS
_____ The licensed land surveyor or registered civil engineer shall sign, seal and provide their California registration or license number and the date of expiration of such number. _____ List the names, addresses and telephone numbers of the owners of record, and the surveyor, or engineer preparing the map.
_____ List the names, addresses and telephone numbers of all utility companies which will serve the project including, but not limited to, water supply, sewage disposal, telephone, cable, electrical and natural gas. _____ Clearly show the north arrow (directed toward the top of the map),the scale of the plan, the boundary lines, dimensions of the project and the date of preparation of the plan. _____ Provide a vicinity map at a scale of one (1) inch equals eight hundred (800) feet of the area showing the proposed subdivision in relation to the adjacent subdivision, established roads, landmarks, etc., within one –quarter (1/4) mile of the exterior boundaries of the proposed project. _____ List the Assessor’s Parcel Number (s) for the entire project. _____ Provide a legal description of the land included within the proposed project. _____ Provide information demonstrating legal, dedicated access to the subdivision and all proposed lots within the subdivision. Also demonstrate that no adjoining parcels are landlocked subsequent to the proposed project. _____ Show all boundary lines of the proposed project with appropriate bearings and distances. _____ Show the General Plan land use designation, zoning district classification and land use or uses of the adjoining property within one hundred (100) feet of the proposed project, including that which is across any streets. Indicate the distances from all property lines and use of any structures on adjoining property. _____ Show the locations, names and existing rights-of all adjoining highways, streets, alleys and /or ways, roads, etc. If none exist, show access to the property. _____ Show the centerline profile and grade for each proposed highway, street or drainage improvement shown on the plan.
_____ Show the width and location of all recorded and/or proposed easements, dedication of streets or rights-of-way. _____ Show the radius of all curves on highways and streets. _____ Show the location and outline, to scale, of each existing building, utility pole or other above ground structure. Note on the map whether such building, pole or structure is to be removed from, or remain within the project. _____ Show the location of existing and proposed water lines, sewers, culverts, bridges, drain pipes, fire hydrants and water wells within the project.
_____ Total square footage of each building, number of stories, number and size of dwelling units and number of bedrooms, it applicable.
_____ Number of parking and loading spaces required and provided. _____ Square footage and percent of the site devoted to building, landscaping, and paved areas for parking and circulation.
_____ Property lines, dimensions, and net lot area.
_____ Footprint of all structures and any overhangs or projections. _____ Location of all entrances and loading doors.
39 11600 Air Expressway • P.O. Box 10 • Adelanto, CA 92301 • (760) 246-2300 • www.ci.adelanto.ca.us P a g e | 11 Revised 10.21.2021
_____ All setbacks and distances between buildings and/or structures. _____ Location, typical dimensions, and type of surfacing for all driveways, parking spaces and loading areas. _____ Location of all trash enclosures, transformers and any equipment outside of building. _____ Location, height, and materials of all walls and fences. _____ Location of all existing fire hydrants.
_____ Proposed phases of project (if any).

CHECKLIST OF REQUIRED INFORMATION

PRELIMINARY GRADING AND DRAINAGE PLANS
____ Proposed grades, elevations, slopes, and structures on the site ____ All existing contours and structures on the site and within twenty-five feet (25’) of the boundaries of the site ____ Show proposed sections around property boundaries
____ Show locations and limits of any existing floodway and floodplain areas ____ Location and elevation of all existing and proposed circulation and drainage improvements, including streets, curbs, driveways, sidewalks, median islands, and drainage courses on the site and within 100 feet of the boundaries of the site
____ Preliminary drainage plan shall show or explain the drainage area tributary to the site and include a statement setting forth in detail the manner in which storm water runoff will enter the site, the manner in which it will be carried through the site, and the manner in which disposal beyond the site boundaries be accomplished. Detention basins may be required unless storm water is directed to an improved storm drain facility.

ARCHITECTURAL ELEVATIONS
____ Fully dimension all elevations from lowest to highest points ____ Call out material and colors (provide samples)
____ Show variation in plane and textures to demonstrate architectural compatibility with surrounding developments

FLOOR PLANS
____ Show dimensions and Square footage of unit(s)
____ Show eave projections past wall
____ Shade in additions(s)

CONCEPTUAL LANDSCAPING PLANS
____ Plant pallet and sizes of materials
____ Locations and numbers of trees, shrubs and acres of ground covering, including spacing of ground cover. Identify slope areas.
____ Proposed wall & fences and their materials
____ For Tentative Tract Maps landscape plans should address streetscapes, entry statements, and public spaces such as detention basins.

SPECIAL STUDIES - Studies that may be appropriate to identify necessary mitigation measures to support findings of “No Significant Impact” after mitigation. These may typically include the following:
• Preliminary Drainage and hydrology studies. The Preliminary Hydrology Study shall identify offsite flows the impact the proposed development and identify the increased onsite flows. The Study shall address how the proposed development shall accept offsite flows that impact the proposed development and demonstrate how the proposed development will safely convey the offsite flows while protecting the proposed development. The Study shall also demonstrate how the proposed development will reduce the increased onsite runoff to less than 90% of pre-developed drainage runoff flows. The Preliminary Hydrology Study shall be engineered using County of San Bernardino Flood Control methodologies and included 40 11600 Air Expressway • P.O. Box 10 • Adelanto, CA 92301 • (760) 246-2300 • www.ci.adelanto.ca.us P a g e | 12 Revised 10.21.2021
calculations, maps, diagrams and a written summary that contains recommendation of how offsite flows and increased onsite runoff shall be mitigated.
• Biological Habitat Survey (Primary Focus: Desert Tortoise, Mojave Ground Squirrel, Burrowing Owl, Loggerhead Shrike, Sharpshinned Hawk)
• Utility Feasibility Study (UFS). A UFS is prepared by the City Engineer to determine if sufficient sewer or water capacity is available to service the proposed project, and to determine how the project shall connect to existing sewer or water infrastructure. If a UFS is required, a UFS application shall to be completed by the project applicant and submitted to the Public Works Engineering Department for processing. • Traffic Circulation Plan. The Traffic Circulation Plan shall include internal circulation, the minimum County Fire required points of connection from internal circulation to external existing circulation, and shall include two paved all-weather access points to existing paved all-weather circulation access. Within the Traffic Circulation Plan the applicant shall demonstrate full legal access and right-of-way for all improvements not completely contain within the applicants project site.

Internal circulation shall not allow cul-de-sacs longer than 600 feet and local roads with driveways longer than 1,000 feet. Local Streets along the project boundary shall be constructed to a minimum half-width of 30 feet of asphalt concrete paving with 18 feet of paving to the centerline plus a lane of 12 feet of paving on the other side of the centerline plus a 6 feet wide graded shoulder a shall have a total right-of-way of 60 feet. Internal Local Streets shall be constructed to full width of a of 36 feet wide and shall have a total right-of-way of 60 feet. Cul-de-sacs shall be constructed of a radius of 45 feet to curb-face and shall have a right-of-way radius of 57 feet. The minimum County Fire required points of connection from internal circulation to external existing circulation are as follows:
1 to 50 Dwelling Units 2 connection points
51 to 100 Dwelling Units 3 connection points
101 to 175 Dwelling Units 4 connection points
176 to 275 Dwelling Units 5 connection points
276 to 375 Dwelling Units 6 connection points
376 to 475 Dwelling Units 7 connection points
The two paved all-weather access points to existing paved all-weather circulation access must travel along two separate non-intersecting paths and one access point must be along a road designated General Plan Major Collector or larger. Minimum paved all-weather access shall be 26 feet wide with 6 feet wide graded shoulders on each side.

Preliminary Drainage and Hydrology Studies
Please explain how post constructed storm water will be mitigated:
41 11600 Air Expressway • P.O. Box 10 • Adelanto, CA 92301 • (760) 246-2300 • www.ci.adelanto.ca.us P a g e | 13 Revised 10.21.2021

Development Services Department

DEPOSIT FEE ACKNOWLEDGEMENT
The City operates on the basis of full cost recovery for the processing of planning projects. Deposits made at the time of application are estimated costs for processing of applications, however, additional deposits may be required to cover the projected costs for review of projects. If at any time deposits are insufficient to cover projected costs, processing of the project will be stopped until sufficient additional funds are deposited with the City. Lack of sufficient funds on deposit will suspend any required processing time frames.

Acknowledgement: I hereby certify that I understand the information regarding deposits for processing costs.
_______________________________________________________________________________ Applicant’s Signature Date Property Owner’s Signature Date 42 P: (626) 381-9248
F: (626) 389-5414
E: [email protected]
Mitchell M. Tsai
Attorney At Law
139 South Hudson Avenue
Suite 200
Pasadena, California 91101
VIA Email
February 2, 2022
Nyeka Allen
City of Adelanto
11600 Air Expressway
Adelanto, CA 92301
Em: [email protected]
RE: Morris Mu & Partners Auburn Avenue Project (CUP 21-04, LDP 21-03, TPM 20437)
Dear Nyeka Allen,
On behalf of the Southwest Regional Council of Carpenters (“Southwest Carpenters” or “SWRCC”), my Office is submitting an appeal on the City of Adelanto’s (“City” or “Lead Agency”) approval on the Final Initial Study / Mitigated Negative Declaration (“IS/MND”) (SCH No. 2021100503) for the Morris Mu & Partners Auburn Avenue Project (CUP 21-04, LDP 21-03, TPM 20437) (“Project”).

This appeal justification letter reiterates, and supplements comments submitted by Commenter on January 19, concerning the IS/MND.

The Southwest Carpenters is a labor union representing more than 50,000 union carpenters in six states and has a strong interest in well ordered land use planning and addressing the environmental impacts of development projects.

Individual members of the Southwest Carpenters live, work and recreate in the City and surrounding communities and would be directly affected by the Project’s environmental impacts.

The Southwest Carpenters expressly reserves the right to supplement these comments at or prior to hearings on the Project, and at any later hearings and proceedings related to this Project. Cal. Gov. Code § 65009(b); Cal. Pub. Res. Code § 21177(a); Bakersfield Citizens for Local Control v. Bakersfield (2004) 124 Cal. App. 4th 1184, 1199-1203; see Galante Vineyards v. Monterey Water Dist. (1997) 60 Cal. App. 4th 1109, 1121. 43 City of Adelanto – Morris Mu & Partners Auburn Avenue Project February 2, 2022

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SWRCC incorporates by reference all comments raising issues regarding the IS/MND submitted prior to certification of the IS/MND for the Project. Citizens for Clean Energy v City of Woodland (2014) 225 Cal. App. 4th 173, 191 (finding that any party who has objected to the Project’s environmental documentation may assert any issue timely raised by other parties).

Moreover, SWRCC requests that the Lead Agency provide notice for any and all notices referring or related to the Project issued under the California Environmental Quality Act (“CEQA”), Cal Public Resources Code (“PRC”) § 21000 et seq, and the California Planning and Zoning Law (“Planning and Zoning Law”), Cal. Gov’t Code §§ 65000–65010. California Public Resources Code Sections 21092.2, and 21167(f) and Government Code Section 65092 require agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency’s governing body.

I. The Final IS/MND Requires Recirculation
SWRCC was generally pleased to see revisions made to the Final IS/MND’s sections on Project Description, Aesthetics impacts, Air Quality impacts, Biological Resources impacts, Energy impacts, Greenhouse Gas Emissions impacts, Hazards and Hazardous Materials impacts, Hydrology & Water Quality impacts, Noise impacts, Transportation impacts, and Utilities impacts. However, some of these revisions are substantial and require recirculation because they introduce new mitigation measures for environmental effects not previously identified and otherwise changed previous mitigation measures to make them feasible or effective in response to comments. Once a negative declaration has been circulated, it may need to be recirculated for another round of review and comment if it is "substantially revised" after the public notice of the first circulation period has been given. CEQA Guidelines §15073.5(a). A substantial revision includes two situations (CEQA Guidelines §15073.5(b)):
• A new, avoidable significant effect is identified, and to reduce that effect to a level of insignificance, mitigation measures or project revisions must be added.
• The lead agency finds that the mitigation measures or project revisions originally included in the negative declaration will not reduce potentially significant impacts to a level of insignificance, and new mitigation measures or project revisions are required. 44 City of Adelanto – Morris Mu & Partners Auburn Avenue Project February 2, 2022

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• The addition of mitigation measures is governed by case law and CEQA Guidelines §15073.5. Changes in mitigation measures are governed by PRC §21080(f) and CEQA Guidelines §15073.5.

These provisions establish the following general rules
governing recirculation of a negative declaration.

In response to CDFW recommendations, the Final IS/MND has extensively amended its Biological Resources analysis and added new mitigation measures including BIO1~11 to address impacts to protected species that may impact or result in take of CESA-listed species including Joshua trees, other special status plants and native species, desert tortoise, Mohave ground squirrel, burrowing owls, Desert kit fox, and nesting birds and birds of prey. (Final IS/MND, 46-51.) The impacts to these species had not been previously identified nor were mitigation measures provided to reduce impacts to these species.

The Final IS/MND also added new mitigation measures to mitigate impacts to energy resources including Energy mitigation measures 1-3. (Final IS/MND, 61.) No measures were previously introduced in the Draft IS/MND and mitigation was needed to reduce impacts to energy resources.

As a result of the addition of many new mitigation measures to address impacts to previously unanalyzed resource areas or to reduce impacts to levels less than significant, recirculation is required under the CEQA Guidelines.

II. THE PROJECT WOULD BE APPROVED IN VIOLATION OF THE

CALIFORNIA ENVIRONMENTAL QUALITY ACT
A. The City Must Prepare and Environmental Impact Report for the Project It would be unlawful for the City to approve the Project in reliance on the incomplete and flawed IS/MND. Because the Project would result in significant impacts to the environment, the City is obligated to develop and circulate an Environmental Impact Report (“EIR”) for the Project.

1. Legal Background Concerning the Need for Environmental Impact Reports 45 City of Adelanto – Morris Mu & Partners Auburn Avenue Project February 2, 2022

Page 4 of 14 ends

Built into CEQA is a strong presumption in favor of requiring preparation of an EIR.

This presumption is reflected in what is known as the “fair argument” standard, under which an agency must prepare an EIR whenever substantial evidence in the record supports a fair argument that a project may have a significant effect on the environment. Quail Botanical Gardens Found., Inc. v City of Encinitas (1994) 29 CA4th 1597, 1602; Friends of “B” St. v City of Hayward (1980) 106 CA3d 988, 1002.

The fair argument test stems from the statutory mandate that an EIR be prepared for any project that “may have a significant effect on the environment.” PRC § 21151; No Oil, Inc. v City of Los Angeles (1974) 13 C3d 68, 75; Jensen v City of Santa Rosa (2018) 23 CA5th 877, 884. Under this test, if a proposed project is not exempt and may cause a significant effect on the environment, the lead agency must prepare an EIR. PRC §§ 21100(a), 21151; 14 California Code of Regulations (“CCR” or “CEQA Guidelines”) § 15064(a)(1), (f)(1). An EIR may be dispensed with only if the lead agency finds no substantial evidence in the initial study or elsewhere in the record that the project may have a significant effect on the environment. Parker Shattuck Neighbors v Berkeley City Council (2013) 222 CA4th 768, 785. In such a situation, the agency must adopt a negative declaration. PRC § 21080(c)(1); CEQA Guidelines §§ 15063(b)(2), 15064(f)(3).
“Significant effect upon the environment” is defined as “a substantial or potentially substantial adverse change in the environment.” PRC § 21068; CEQA Guidelines § 15382. A project “may” have a significant effect on the environment if there is a “reasonable probability” that it will result in a significant impact. No Oil, Inc. v City of Los Angeles, 13 Cal. 3d at 83 fn. 16; Sundstrom v County of Mendocino (1988) 202 Cal. App. 3d 296, 309. If any aspect of the project may result in a significant impact on the environment, an EIR must be prepared even if the overall effect of the project is beneficial. CEQA Guidelines § 15063(b)(1). See County Sanitation Dist. No. 2 v County of Kern (2005) 127 Cal. App. 4th 1544, 1580.

This standard sets a “low threshold” for preparation of an EIR. Consolidated Irrig. Dist. v City of Selma (2012) 204 Cal. App. 4th 187, 207; Nelson v County of Kern (2010) 190 Cal.

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supports a fair argument that the project may have a significant environmental effect, the lead agency must prepare an EIR even if other substantial evidence before it indicates the project will have no significant effect. See Jensen v City of Santa Rosa (2018) 23 Cal. App. 5th 877, 886; Clews Land & Livestock v City of San Diego (2017) 19 Cal. App. 5th 161, 183; Stanislaus Audubon Soc'y, Inc. v County of Stanislaus (1995) 33 Cal. App. 4th 144, 150; Brentwood Ass'n for No Drilling, Inc. v City of Los Angeles (1982) 134 Cal. App. 3d 491; Friends of “B” St. v City of Hayward (1980) 106 Cal. App. 3d 988; CEQA Guidelines § 15064(f)(1).

As explained in full below, there is a fair argument that the Project will have a significant effect on the environment. As a result, the “low threshold” for preparation of an EIR has been met and the City must prepare an EIR.

B. CEQA Requires Revision and Recirculation of an Initial Study whenever Substantial Revisions are Required
Section 15073.5 of the CEQA Guidelines provides that a negative declaration must be recirculated whenever the document must be substantially revised. A substantial revision includes the identification of new, avoidable significant effects requiring mitigation measures or project revisions to be added to reduce the effect to less than significant levels or upon the agency determining that a proposed mitigation measure or project change would not reduce a potential impact to insignificance. Id.

For all of the reasons discussed below, significant new information has been raised relating to the Project that requires revision and recirculation of the IS/MND or EIR.

C. The IS/MND Fails to Include an Adequate Project Description “[A]n accurate, stable and finite project description is the sine qua non of an informative and legally sufficient” environmental document. (County of Inyo v. City of Los Angeles (1977) 71 Cal. App. 3d 185, 200.) “A curtailed or distorted project description may stultify the objectives of the reporting process” as an accurate, stable and finite project description is necessary to allow “affected outsiders and public decision-makers balance the proposal's benefit against its environmental cost, consider mitigation measures, assess the advantage of terminating the proposal (i.e., the "no project" alternative) and weigh other alternatives in the balance. (Id. at 192 – 93.) Courts 47 City of Adelanto – Morris Mu & Partners Auburn Avenue Project February 2, 2022

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determine de novo whether an agency proceeded “in a manner required by law” in maintaining a stable and consistent project description. (Id. at 200.) Here, the IS/MND does not adequately describe the project. The cultivation buildings are not described in any meaningful detail other than a basic site plan on p. 16 of the IS/MND and an outline of the building sizes. It is further unknown how much of the proposed 15.4-acre site will be disturbed by construction activities, or where the buildings will be located on the site, which could crucially determine impacts to, for example, biological resources, cultural resources, hydrology, etc. The project description provided simply is not specific enough to allow for a complete evaluation of the Project’s potential environmental impacts.

D. The IS/MND Fails to Support Its Findings with Substantial Evidence When new information is brought to light showing that an impact previously discussed in the IS/MND but found to be insignificant with or without mitigation in the IS/MND’s analysis has the potential for a significant environmental impact supported by substantial evidence, the IS/MND must consider and resolve the conflict in the evidence. See Visalia Retail, L.P. v. City of Visalia (2018) 20 Cal. App. 5th 1, 13, 17; see also Protect the Historic Amador Waterways v. Amador Water Agency (2004) 116 Cal. App. 4th 1099, 1109. While a lead agency has discretion to formulate standards for determining significance and the need for mitigation measures—the choice of any standards or thresholds of significance must be “based to the extent possible on scientific and factual data and an exercise of reasoned judgment based on substantial evidence. CEQA Guidelines § 15064(b); Cleveland Nat'l Forest Found. v. San Diego Ass'n of Gov'ts (2017) 3 Cal. App. 5th 497, 515; Mission Bay Alliance v. Office of Community Inv. & Infrastructure (2016) 6 Cal. App. 5th 160, 206. And when there is evidence that an impact could be significant, an EIR cannot adopt a contrary finding without providing an adequate explanation along with supporting evidence. East Sacramento Partnership for a Livable City v. City of Sacramento (2016) 5 Cal. App. 5th 281, 302.

In addition, a determination that regulatory compliance will be sufficient to prevent significant adverse impacts must be based on a project-specific analysis of potential impacts and the effect of regulatory compliance. Californians for Alternatives to Toxics v.

Department of Food & Agric. (2005) 136 Cal. App. 4th 1; see also Ebbetts Pass Forest Watch v Department of Forestry & Fire Protection (2008) 43 Cal. App. 4th 936, 956 (fact that Department of Pesticide Regulation had assessed environmental effects of certain 48 City of Adelanto – Morris Mu & Partners Auburn Avenue Project February 2, 2022

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herbicides in general did not excuse failure to assess effects of their use for specific timber harvesting project).

1. The IS/MND Omits Information Crucial to Allowing the Public to Evaluate the IS/MND’s Conclusions
Under CEQA Guidelines § 15063(d), an initial study must include in brief form:
• A description of the project, including its location; • Identification of the environmental setting;
• Identification of the project's environmental effects by use of a checklist, matrix, or other method, with a brief explanation or reference to indicate the evidence supporting the checklist or matrix entries;
• A discussion of ways to mitigate the significant effects identified in the initial study;
• An examination of whether the project would be consistent with existing zoning, plans, and other applicable land use controls; and • The names of the persons who prepared or participated in the initial study.

An initial study ordinarily should disclose the data or evidence supporting the study's environmental findings. Citizens Ass'n for Sensible Dev. v County of Inyo (1985) 172 Cal.App.3d 151, 171. CEQA requires that an environmental document identify and discuss the significant effects of a Project, alternatives and how those significant effects can be mitigated or avoided. CEQA Guidelines § 15126.2; PRC §§ 21100(b)(1), 21002.1(a). An environmental documents discussion of potentially significant effects must “provide an adequate analysis to inform the public how its bare numbers translate to create potential adverse impacts or it must adequately explain what the agency does know and why, given existing scientific constraints, it cannot translate potential health impacts further.” Sierra Club v. County of Fresno (2018) 6 Cal. 5th 502, 521; see also citing Laurel Heights Improvement Assn. v. Regents of University of California (1988) 47 Cal.3d 376, 405; see also PRC §§ 21002.1(e), 21003(b).

A reviewing court may determine whether a CEQA environmental document sufficiently discloses information required by CEQA de novo as “noncompliance with 49 City of Adelanto – Morris Mu & Partners Auburn Avenue Project February 2, 2022

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the information disclosure provisions” of CEQA is a failure to proceed in a manner required by law. PRC § 21005(a); see also Sierra Club v. County of Fresno (2018) 6 Cal. 5th 502, 515; CEQA Guidelines.

The IS/MND fails to disclose information to the public that is necessary for the public to determine whether the environmental impacts of the Project are less than significant or have been reduced to a level below significance by the mitigation measures proposed in the IS/MND. These inappropriate omissions include:
• Failing to include as attachments or appendices to the IS/MND any of the studies and reports relied on by the IS/MND in determining that the Project’s environmental impacts are less than significant (or less than significant with applied mitigations), including but not limited to greenhouse gas studies, hydrology reports, geotechnical reports, and traffic and VMT analyses; • Failing to provide any analysis or reasoning whatsoever for concluding that the Project will have less than significant impacts on energy;
• Failing to include any discussion of methodology, significance threshold selection, data, or findings related to greenhouse gas emissions, and failing to discuss at all the Project’s conflict or conformance with plans, policies, and regulations adopted for the purpose of reducing the emission of greenhouse gases;
• Failing to discuss conformance with any part of the City’s General Plan or applicable specific plan apart from mere compatibility with land use and zoning designations relating to cannabis cultivation (IS/MND, 71);
• Failing to analyze anticipated effects of construction or operational noise levels; and
• Concluding that the Project’s impact on VMT and other transportation impacts would be less than significant without including any analysis of those potential impacts.
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The aforementioned omissions of information violate the disclosure requirements of CEQA. The IS/MND should be revised to include these excluded discussions, data, and documents so that the public may accurately review and comment on the Project’s environmental impacts.

2. The IS/MND Fails to Support its Findings on Air Quality Impacts with Substantial Evidence and Defers Mitigation to Reduce Impacts.

The IS/MND’s conclusions regarding air quality impacts are unsupported by substantial evidence. The IS/MND concludes that the Project will have a potentially significant impact relating to odor emissions that could affect a substantial number of people near the Project site. (IS/MND, 34-5.)
In response, the IS/MND fails to specify with any degree of specificity or certainty how the proposed mitigation measures will reduce the potentially significant impact and defers formulation of such mitigation until after Project approval (IS/MND, 38.) The IS/MND relies upon the enactment of an Odor Management Plan to reduce air quality impacts but fails to include any details of that plan or how it would be enforced—deferring such mitigation until after Project approval. (Id.) If the Odor Management Plan is undefined, it is also not possible to determine whether such mitigation will reduce the potentially significant impact to levels below significance, or if additional mitigation measures should also be considered and adopted.

Without more information, it is indeterminable whether the IS/MND’s conclusions regarding air quality impacts are supported by substantial evidence.

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concerns over energy consumption issues related to the cannabis cultivation industry, especially indoor cannabis cultivation facilities.
1 The IS/MND needs to be revised to expand its analysis of the Project’s projected energy consumption, and whether it will result in wasteful, inefficient, or unnecessary consumption of energy resources, or result in the obstruction of state or local renewable energy or energy efficiency plans and goals.

The IS/MND simply offers up a number of ideas or measures for how cannabis cultivation facilities generally can lower their energy consumption, but does not apply any of these measures to the Project in the IS/MND. (See IS/MND at 50-1.)

5. The IS/MND Fails to Support its Findings on Greenhouse Gas Emissions with Substantial Evidence
Here, the IS/MND has not provided any evidence, let alone substantial evidence, to support the conclusion that the Project greenhouse gas emissions impacts would be less than significant. The IS/MND simply identifies a MDAQMD threshold of 100,000/MTCO2e and supposes that the Project will be under that threshold. (IS/MND, 59.) The IS/MND does not substantiate use of the MDAQMD threshold for its proposed land use nor does it provide any underlying analysis that operational emissions will be under that threshold. Notably, the IS/MND does not account for all 1 See, e.g., Natalie Fertig and Gavin Bade, Politico, “An inconvenient truth (about weed),” August 10, 2021, available at: https://www.politico.com/news/2021/08/10/weedcannabis-legalization-energy-503004; Jyoti Madhusoodana, Nature, “Can cannabis go green?” August 28, 2019, available at: https://www.nature.com/articles/d41586-019- 02526-3.
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of the Project’s operational emissions, including but not limited to mobile emissions and vehicle miles traveled which the IS/MND has failed to characterize or analyze.

Furthermore, the IS/MND also fails to amortize the Project’s construction-related GHG emissions and combine that figure with the Project’s operational emissions.

For all these reasons, the GHG emissions analysis is not supported by substantial evidence.

6. The IS/MND Fails to Support its Findings on Biological Resources with Substantial Evidence.

The IS/MND bases analysis of the Project’s impacts to biological resources on a August 17, 2020 assessment conducted by RCA Associates Inc. However, the City has not provided a copy of this assessment and no details of the scope and methods of the assessment were provided in the IS/MND. From the information provided, there is no way to determine if there has been adequate analysis and disclosure of impacts or if inaccurate and incomplete information has been provided. The lack of information is particularly concerning given that the IS/MND has identified sensitive species on the Project site. Additionally, the California Dept. of Fish and Wildlife (CDFW) has provided extensive comments on the IS/MND deficiencies relating to its biological resources analysis which SWRCC incorporates herein by reference.2 The IS/MND needs to be revised to provide accurate and complete information about the biological assessment, attach a copy of that assessment, and provide all detailed information relating to biological resources surveys conducted or any other field assessments.

7. The IS/MND Fails to Support its Findings on Land Use with Substantial Evidence.
2 Nov. 19, 2021 Letter from CDFW to Mary Blais re Morris Mu & Partners, available at https://files.ceqanet.opr.ca.gov/273778-
1/attachment/qwZEg9c7DVXcHK8BPMWYrZNbmHWmzRnvIerXPeGkIyduk7bhcfQde0 ZKegG-Bpl4AtTXGDTIJd7tVWLt0.
53 City of Adelanto – Morris Mu & Partners Auburn Avenue Project February 2, 2022

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The IS/MND does not provide any analysis of consistency with either the City’s General Plan or Regional Plans such as the Connect SoCal RTP/SCS Plan. The IS/MND is barren of information and analysis on land use consistency. The IS/MND makes, again, a conclusory statement that because cannabis cultivation is generally allowed in the City and at the Project site under existing zoning rules, the Project would not run afoul of any other plans or policies. Without actually conducting the required analysis, this conclusion is utterly unsupported.

8. The IS/MND Fails to Support its Findings on Transportation with Substantial Evidence.

CEQA Guidelines section 15064.3 requires that an environmental document include analysis of transportation impacts relating to vehicle miles traveled (VMT) unless the proposed project is within a specified distance of a public transit stop or otherwise is a more densely populated transportation priority area. Here, the IS/MND’s sum total of analysis on VMT is that “the proposed project will not create a significant amount of traffic in the surrounding area…” and that “the Project will not result in a conflict or be inconsistent with Section 15064.3 subdivision (b) of the CEQA Guidelines…” (IS/MND, 85.) Again, the IS/MND has provided another conclusory statement which is not supported by any evidence or analysis, let alone substantial evidence.

The IS/MND provides that over 200 employees will come and go from the Project site on a daily basis, and presumably a number of truck trips will be created at the facilities because the cannabis that is grown there will need to be distributed to its end location. The IS/MND does not provide any analysis of the potential VMT impacts that would be created by the facility’s operation. The IS/MND needs to be revised and recirculated with a transportation analysis which includes an estimate of the Project’s construction and operational phase VMT output.

III. THE PROJECT VIOLATES THE STATE PLANNING AND
ZONING LAW AS WELL AS THE CITY’S GENERAL PLAN
A. Background Regarding the State Planning and Zoning Law Each California city and county must adopt a comprehensive, long-term general plan governing development. Napa Citizens for Honest Gov. v. Napa County Bd. of Supervisors (2001) 91 Cal.App.4th 342, 352, citing Gov. Code §§ 65030, 65300. The general plan sits at the top of the land use planning hierarchy, and serves as a “constitution” or 54 City of Adelanto – Morris Mu & Partners Auburn Avenue Project February 2, 2022

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“charter” for all future development. DeVita v. County of Napa (1995) 9 Cal.4th 763, 773; Lesher Communications, Inc. v. City of Walnut Creek (1990) 52 Cal.3d 531, 540.

General plan consistency is “the linchpin of California’s land use and development laws; it is the principle which infused the concept of planned growth with the force of law.” See Debottari v. Norco City Council (1985) 171 Cal.App.3d 1204, 1213.

State law mandates two levels of consistency. First, a general plan must be internally or “horizontally” consistent: its elements must “comprise an integrated, internally consistent and compatible statement of policies for the adopting agency.” See Gov.

Code § 65300.5; Sierra Club v. Bd. of Supervisors (1981) 126 Cal.App.3d 698, 704. A general plan amendment thus may not be internally inconsistent, nor may it cause the general plan as a whole to become internally inconsistent. See DeVita, 9 Cal.4th at 796 fn. 12.

Second, state law requires “vertical” consistency, meaning that zoning ordinances and other land use decisions also must be consistent with the general plan. See Gov. Code § 65860(a)(2) [land uses authorized by zoning ordinance must be “compatible with the objectives, policies, general land uses, and programs specified in the [general] plan.”]; see also Neighborhood Action Group v. County of Calaveras (1984) 156 Cal.App.3d 1176, 1184. A zoning ordinance that conflicts with the general plan or impedes achievement of its policies is invalid and cannot be given effect. See Lesher, 52 Cal.3d at 544.

State law requires that all subordinate land use decisions, including conditional use permits, be consistent with the general plan. See Gov. Code § 65860(a)(2); Neighborhood Action Group, 156 Cal.App.3d at 1184.

A project cannot be found consistent with a general plan if it conflicts with a general plan policy that is “fundamental, mandatory, and clear,” regardless of whether it is consistent with other general plan policies. See Endangered Habitats League v. County of Orange (2005) 131 Cal.App.4th 777, 782-83; Families Unafraid to Uphold Rural El Dorado County v. Bd. of Supervisors (1998) 62 Cal.App.4th 1332, 1341-42 (“FUTURE”).

Moreover, even in the absence of such a direct conflict, an ordinance or development project may not be approved if it interferes with or frustrates the general plan’s policies and objectives. See Napa Citizens, 91 Cal.App.4th at 378-79; see also Lesher, 52 Cal.3d at 544 (zoning ordinance restricting development conflicted with growth-oriented policies of general plan).
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The Project fails to discuss its conformity with the goals, objectives, and policies laid out in the City’s General Plan, (IS/MND, 71.) This discussion is relevant not only to compliance with land use and zoning law, but also with the contemplation of the Project’s consistency with land use plans, policies, and regulations adopted for the purpose of avoiding or mitigating environmental impacts. The IS/MND should be amended to include analysis of the Project’s comportment with the Goals, Policies, and Programs of the City’s General Plan and other applicable land use plans.

IV. CONCLUSION
If the City has any questions or concerns, feel free to contact my Office.

Sincerely,
__________________________
Mitchell M. Tsai
Attorneys for Southwest Regional
Council of Carpenters
Attached:

January 19 Southwest Regional Council of Carpenters Comment Letters Concerning the IS/MND (Attachment A)
56 EXHIBIT A
57 P: (626) 381-9248
F: (626) 389-5414
E: [email protected]
Mitchell M. Tsai
Attorney At Law
139 South Hudson Avenue
Suite 200
Pasadena, California 91101

VIA E-MAIL
November 29, 2021
Mary Blais, Planning Consultant
Community Development Department, Planning Division
City of Adelanto
11600 Air Expressway
Adelanto, CA 92301
Em: [email protected]
RE: Morris Mu & Partners Auburn Avenue Project (CUP 21-04, LDP 21-03, TPM 20437) – Comments on Initial Study / Mitigated Negative Declaration (SCH No. 2021100503)
Dear Mary Blais,
On behalf of the Southwest Regional Council of Carpenters (“Southwest Carpenters” or “SWRCC”), my Office is submitting these comments on the City of Adelanto’s (“City” or “Lead Agency”) Initial Study / Mitigated Negative Declaration (“IS/MND”) (SCH No. 2021100503) for the Morris Mu & Partners Auburn Avenue Project (CUP 21-04, LDP 21-03, TPM 20437) (“Project”).

The City proposes to adopt the IS/MND for the Project, which seeks to construct twelve buildings labeled A through L, each with 30,625 square feet, on a 15.4-acre site for the purpose of cannabis cultivation, manufacturing, and distribution.

Individual members of the Southwest Carpenters live, work and recreate in the City and surrounding communities and would be directly affected by the Project’s environmental impacts.

The Southwest Carpenters expressly reserves the right to supplement these comments at or prior to hearings on the Project, and at any later hearings and proceedings related 58 City of Adelanto – Morris Mu & Partners Auburn Avenue Project November 29, 2021

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to this Project. Cal. Gov. Code § 65009(b); Cal. Pub. Res. Code § 21177(a); Bakersfield Citizens for Local Control v. Bakersfield (2004) 124 Cal. App. 4th 1184, 1199-1203; see Galante Vineyards v. Monterey Water Dist. (1997) 60 Cal. App. 4th 1109, 1121.

The City should require the Applicant provide additional community benefits such as requiring local hire and use of a skilled and trained workforce to build the Project. The City should require the use of workers who have graduated from a Joint Labor Management apprenticeship training program approved by the State of California, or have at least as many hours of on-the-job experience in the applicable craft which would be required to graduate from such a state approved apprenticeship training program or who are registered apprentices in an apprenticeship training program approved by the State of California.

Community benefits such as local hire and skilled and trained workforce requirements can also be helpful to reduce environmental impacts and improve the positive economic impact of the Project. Local hire provisions requiring that a certain percentage of workers reside within 10 miles or less of the Project Site can reduce the length of vendor trips, reduce greenhouse gas emissions and providing localized economic benefits. Local hire provisions requiring that a certain percentage of workers reside within 10 miles or less of the Project Site can reduce the length of vendor trips, reduce greenhouse gas emissions and providing localized economic benefits. As environmental consultants Matt Hagemann and Paul E. Rosenfeld note:
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[A]ny local hire requirement that results in a decreased worker trip length from the default value has the potential to result in a reduction of construction-related GHG emissions, though the significance of the reduction would vary based on the location and urbanization level of the project site.

March 8, 2021 SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and Considerations for Greenhouse Gas Modeling.

Skilled and trained workforce requirements promote the development of skilled trades that yield sustainable economic development. As the California Workforce Development Board and the UC Berkeley Center for Labor Research and Education concluded:
. . . labor should be considered an investment rather than a cost – and investments in growing, diversifying, and upskilling California’s workforce can positively affect returns on climate mitigation efforts. In other words, well trained workers are key to delivering emissions reductions and moving California closer to its climate targets.1
Recently, on May 7, 2021, the South Coast Air Quality Management District found that the “[u]se of a local state-certified apprenticeship program or a skilled and trained workforce with a local hire component” can result in air pollutant reductions.2 Cities are increasingly adopting local skilled and trained workforce policies and requirements into general plans and municipal codes. For example, the City of Hayward 2040 General Plan requires the City to “promote local hiring . . . to help achieve a more positive jobs-housing balance, and reduce regional commuting, gas consumption, and greenhouse gas emissions.”3
1 California Workforce Development Board (2020) Putting California on the High Road: A Jobs and Climate Action Plan for 2030 at p. ii, available at https://laborcenter.berkeley.edu/ wp-content/uploads/2020/09/Putting-California-on-the-High-Road.pdf 2 South Coast Air Quality Management District (May 7, 2021) Certify Final Environmental Assessment and Adopt Proposed Rule 2305 – Warehouse Indirect Source Rule – Warehouse Actions and Investments to Reduce Emissions Program, and Proposed Rule 316 – Fees for Rule 2305, Submit Rule 2305 for Inclusion Into the SIP, and Approve Supporting Budget Actions, available at http://www.aqmd.gov/docs/default-source/Agendas/Governing-Board/2021/2021- May7-027.pdf?sfvrsn=10
3 City of Hayward (2014) Hayward 2040 General Plan Policy Document at p. 3-99, available at https://www.hayward-ca.gov/sites/default/files/documents/General_Plan_FINAL.pdf. 60 City of Adelanto – Morris Mu & Partners Auburn Avenue Project November 29, 2021

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In fact, the City of Hayward has gone as far as to adopt a Skilled Labor Force policy into its Downtown Specific Plan and municipal code, requiring developments in its Downtown area to requiring that the City “[c]ontribute to the stabilization of regional construction markets by spurring applicants of housing and nonresidential developments to require contractors to utilize apprentices from state-approved, joint labor-management training programs, . . .”4 In addition, the City of Hayward requires all projects 30,000 square feet or larger to “utilize apprentices from state-approved, joint labor-management training programs.”5
Locating jobs closer to residential areas can have significant environmental benefits. As the California Planning Roundtable noted in 2008:

People who live and work in the same jurisdiction would be more likely to take transit, walk, or bicycle to work than residents of less balanced communities and their vehicle trips would be shorter. Benefits would include potential reductions in both vehicle miles traveled and vehicle hours traveled.6
In addition, local hire mandates as well as skill training are critical facets of a strategy to reduce vehicle miles traveled. As planning experts Robert Cervero and Michael Duncan noted, simply placing jobs near housing stock is insufficient to achieve VMT reductions since the skill requirements of available local jobs must be matched to those held by local residents.7 Some municipalities have tied local hire and skilled and trained workforce policies to local development permits to address transportation issues. As Cervero and Duncan note:

In nearly built-out Berkeley, CA, the approach to balancing jobs and housing is to create local jobs rather than to develop new housing.” The city’s First Source program encourages businesses to hire local residents, especially for entry- and intermediate-level jobs, and sponsors vocational 4 City of Hayward (2019) Hayward Downtown Specific Plan at p. 5-24, available at https://www.hayward-ca.gov/sites/default/files/Hayward%20Downtown% 20Specific%20Plan.pdf. 5 City of Hayward Municipal Code, Chapter 10, § 28.5.3.020(C). 6 California Planning Roundtable (2008) Deconstructing Jobs-Housing Balance at p. 6, available at https://cproundtable.org/static/media/uploads/publications/cpr-jobs-housing.pdf 7 Cervero, Robert and Duncan, Michael (2006) Which Reduces Vehicle Travel More: Jobs-Housing Balance or Retail-Housing Mixing? Journal of the American Planning Association 72 (4), 475-490, 482, available at http://reconnectingamerica.org/assets/Uploads/UTCT-825.pdf. 61 City of Adelanto – Morris Mu & Partners Auburn Avenue Project November 29, 2021

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training to ensure residents are employment-ready. While the program is voluntary, some 300 businesses have used it to date, placing more than 3,000 city residents in local jobs since it was launched in 1986. When needed, these carrots are matched by sticks, since the city is not shy about negotiating corporate participation in First Source as a condition of approval for development permits.

The City should consider utilizing skilled and trained workforce policies and requirements to benefit the local area economically and mitigate greenhouse gas, air quality and transportation impacts.

The City should also require the Project to be built to standards exceeding the current 2019 California Green Building Code to mitigate the Project’s environmental impacts and to advance progress towards the State of California’s environmental goals.

I. THE PROJECT WOULD BE APPROVED IN VIOLATION OF THE

1. Legal Background Concerning the Need for Environmental Impact Reports Built into CEQA is a strong presumption in favor of requiring preparation of an EIR.

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Guidelines”) § 15064(a)(1), (f)(1). An EIR may be dispensed with only if the lead agency finds no substantial evidence in the initial study or elsewhere in the record that the project may have a significant effect on the environment. Parker Shattuck Neighbors v Berkeley City Council (2013) 222 CA4th 768, 785. In such a situation, the agency must adopt a negative declaration. PRC § 21080(c)(1); CEQA Guidelines §§ 15063(b)(2), 15064(f)(3).
“Significant effect upon the environment” is defined as “a substantial or potentially substantial adverse change in the environment.” PRC § 21068; CEQA Guidelines § 15382. A project “may” have a significant effect on the environment if there is a “reasonable probability” that it will result in a significant impact. No Oil, Inc. v City of Los Angeles, 13 Cal. 3d at 83 fn. 16; Sundstrom v County of Mendocino (1988) 202 Cal. App. 3d 296, 309. If any aspect of the project may result in a significant impact on the environment, an EIR must be prepared even if the overall effect of the project is beneficial. CEQA Guidelines § 15063(b)(1). See County Sanitation Dist. No. 2 v County of Kern (2005) 127 Cal. App. 4th 1544, 1580.

This standard sets a “low threshold” for preparation of an EIR. Consolidated Irrig. Dist. v City of Selma (2012) 204 Cal. App. 4th 187, 207; Nelson v County of Kern (2010) 190 Cal.

App. 4th 252; Pocket Protectors v City of Sacramento (2004) 124 Cal. App. 4th 903, 928; Bowman v City of Berkeley (2004) 122 Cal. App. 4th 572, 580; Citizen Action to Serve All Students v Thornley (1990) 222 Cal. App. 3d 748, 754; Sundstrom v County of Mendocino (1988) 202 Cal. App. 3d 296, 310. If substantial evidence in the record supports a fair argument that the project may have a significant environmental effect, the lead agency must prepare an EIR even if other substantial evidence before it indicates the project will have no significant effect. See Jensen v City of Santa Rosa (2018) 23 Cal. App. 5th 877, 886; Clews Land & Livestock v City of San Diego (2017) 19 Cal. App. 5th 161, 183; Stanislaus Audubon Soc'y, Inc. v County of Stanislaus (1995) 33 Cal. App. 4th 144, 150; Brentwood Ass'n for No Drilling, Inc. v City of Los Angeles (1982) 134 Cal. App. 3d 491; Friends of “B” St. v City of Hayward (1980) 106 Cal. App. 3d 988; CEQA Guidelines § 15064(f)(1).

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For all of the reasons discussed below, significant new information has been raised relating to the Project that requires revision and recirculation of the IS/MND or EIR.

C. Due to the COVID-19 Crisis, the City Must Adopt a Mandatory Finding of Significance that the Project May Cause a Substantial Adverse Effect on Human Beings and Mitigate COVID-19 Impacts
CEQA requires that an agency make a finding of significance when a Project may cause a significant adverse effect on human beings. PRC § 21083(b)(3); CEQA Guidelines § 15065(a)(4).

Public health risks related to construction work requires a mandatory finding of significance under CEQA. Construction work has been defined as a Lower to Highrisk activity for COVID-19 spread by the Occupations Safety and Health Administration. Recently, several construction sites have been identified as sources of community spread of COVID-19.8

SWRCC recommends that the Lead Agency adopt additional CEQA mitigation measures to mitigate public health risks from the Project’s construction activities.

SWRCC requests that the Lead Agency require safe on-site construction work practices as well as training and certification for any construction workers on the Project Site.

In particular, based upon SWRCC’s experience with safe construction site work practices, SWRCC recommends that the Lead Agency require that while construction activities are being conducted at the Project Site:
8 Santa Clara County Public Health (June 12, 2020) COVID-19 CASES AT CONSTRUCTION SITES HIGHLIGHT NEED FOR CONTINUED VIGILANCE IN SECTORS THAT HAVE REOPENED, available at https://www.sccgov.org/sites/covid19/Pages/press-release-06-12-2020-cases-at-construction-sites.aspx. 64 City of Adelanto – Morris Mu & Partners Auburn Avenue Project November 29, 2021

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Construction Site Design:
• The Project Site will be limited to two controlled entry points. • Entry points will have temperature screening technicians taking temperature readings when the entry point is open. • The Temperature Screening Site Plan shows details
regarding access to the Project Site and Project Site logistics for conducting temperature screening.
• A 48-hour advance notice will be provided to all trades prior to the first day of temperature screening.
• The perimeter fence directly adjacent to the entry points will be clearly marked indicating the appropriate 6-foot social distancing position for when you approach the screening area. Please reference the Apex temperature screening site map for additional details.
• There will be clear signage posted at the project site directing you through temperature screening.
• Provide hand washing stations throughout the construction site.

Testing Procedures:
• The temperature screening being used are non-contact
devices.
• Temperature readings will not be recorded.
• Personnel will be screened upon entering the testing center and should only take 1-2 seconds per individual.
• Hard hats, head coverings, sweat, dirt, sunscreen or any other cosmetics must be removed on the forehead before
temperature screening.
• Anyone who refuses to submit to a temperature screening or does not answer the health screening questions will be
refused access to the Project Site.
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• Screening will be performed at both entrances from 5:30 am to 7:30 am.; main gate [ZONE 1] and personnel gate
[ZONE 2]
• After 7:30 am only the main gate entrance [ZONE 1] will continue to be used for temperature testing for anybody gaining entry to the project site such as returning personnel, deliveries, and visitors.
• If the digital thermometer displays a temperature reading above 100.0 degrees Fahrenheit, a second reading will be taken to verify an accurate reading.
• If the second reading confirms an elevated temperature, DHS will instruct the individual that he/she will not be allowed to enter the Project Site. DHS will also instruct the individual to promptly notify his/her supervisor and his/her human resources (HR) representative and provide them with a copy of Annex A.

Planning
• Require the development of an Infectious Disease Preparedness and Response Plan that will include basic infection prevention measures (requiring the use of personal protection equipment), policies and procedures for prompt identification and isolation of sick individuals, social distancing (prohibiting gatherings of no more than 10 people including all-hands meetings and all-hands lunches) communication and training and workplace controls that meet standards that may be promulgated by the Center for Disease Control, Occupational Safety and Health Administration, Cal/OSHA, California Department of Public Health or applicable local public health agencies.9
9 See also The Center for Construction Research and Training, North America’s Building Trades Unions (April 27 2020) NABTU and CPWR COVIC-19 Standards for U.S Constructions Sites, available at https://www.cpwr.com/wpcontent/uploads/publications/NABTU_CPWR_Standards_COVID-19.pdf; Los Angeles County Department of Public Works (2020) Guidelines for Construction Sites During COVID-19 Pandemic, available at https://dpw.lacounty.gov/building-and-safety/docs/pw_guidelines-construction-sites.pdf. 66 City of Adelanto – Morris Mu & Partners Auburn Avenue Project November 29, 2021

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The United Brotherhood of Carpenters and Carpenters International Training Fund has developed COVID-19 Training and Certification to ensure that Carpenter union members and apprentices conduct safe work practices. The Agency should require that all construction workers undergo COVID-19 Training and Certification before being allowed to conduct construction activities at the Project Site.

SWRCC has also developed a rigorous Infection Control Risk Assessment (“ICRA”) training program to ensure it delivers a workforce that understands how to identify and control infection risks by implementing protocols to protect themselves and all others during renovation and construction projects in healthcare environments.10 ICRA protocols are intended to contain pathogens, control airflow, and protect patients during the construction, maintenance and renovation of healthcare facilities.

ICRA protocols prevent cross contamination, minimizing the risk of secondary infections in patients at hospital facilities.

The City should require the Project to be built using a workforce trained in ICRA protocols.

D. The IS/MND Fails to Include an Adequate Project Description “[A]n accurate, stable and finite project description is the sine qua non of an informative and legally sufficient” environmental document. (County of Inyo v. City of Los Angeles (1977) 71 Cal. App. 3d 185, 200.) “A curtailed or distorted project description may stultify the objectives of the reporting process” as an accurate, stable and finite project description is necessary to allow “affected outsiders and public decision-makers balance the proposal's benefit against its environmental cost, consider mitigation measures, assess the advantage of terminating the proposal (i.e., the "no project" alternative) and weigh other alternatives in the balance. (Id. at 192 – 93.) Courts determine de novo whether an agency proceeded “in a manner required by law” in maintaining a stable and consistent project description. (Id. at 200.) Here, the IS/MND does not adequately describe the project. The cultivation buildings are not described in any meaningful detail other than a basic site plan on p. 16 of the IS/MND and an outline of the building sizes. It is further unknown how much of the proposed 15.4-acre site will be disturbed by construction activities, or where the buildings will be located on the site, which could crucially determine impacts to, for 10 For details concerning SWRCC’s ICRA training program, see https://icrahealthcare.com/. 67 City of Adelanto – Morris Mu & Partners Auburn Avenue Project November 29, 2021

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example, biological resources, cultural resources, hydrology, etc. The project description provided simply is not specific enough to allow for a complete evaluation of the Project’s potential environmental impacts.

E. The IS/MND Fails to Support Its Findings with Substantial Evidence When new information is brought to light showing that an impact previously discussed in the IS/MND but found to be insignificant with or without mitigation in the IS/MND’s analysis has the potential for a significant environmental impact supported by substantial evidence, the IS/MND must consider and resolve the conflict in the evidence. See Visalia Retail, L.P. v. City of Visalia (2018) 20 Cal. App. 5th 1, 13, 17; see also Protect the Historic Amador Waterways v. Amador Water Agency (2004) 116 Cal. App. 4th 1099, 1109. While a lead agency has discretion to formulate standards for determining significance and the need for mitigation measures—the choice of any standards or thresholds of significance must be “based to the extent possible on scientific and factual data and an exercise of reasoned judgment based on substantial evidence. CEQA Guidelines § 15064(b); Cleveland Nat'l Forest Found. v. San Diego Ass'n of Gov'ts (2017) 3 Cal. App. 5th 497, 515; Mission Bay Alliance v. Office of Community Inv. & Infrastructure (2016) 6 Cal. App. 5th 160, 206. And when there is evidence that an impact could be significant, an EIR cannot adopt a contrary finding without providing an adequate explanation along with supporting evidence. East Sacramento Partnership for a Livable City v. City of Sacramento (2016) 5 Cal. App. 5th 281, 302.

Department of Food & Agric. (2005) 136 Cal. App. 4th 1; see also Ebbetts Pass Forest Watch v Department of Forestry & Fire Protection (2008) 43 Cal. App. 4th 936, 956 (fact that Department of Pesticide Regulation had assessed environmental effects of certain herbicides in general did not excuse failure to assess effects of their use for specific timber harvesting project).

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• Identification of the project's environmental effects by use of a checklist, matrix, or other method, with a brief explanation or reference to indicate the evidence supporting the checklist or matrix entries;
• A discussion of ways to mitigate the significant effects identified in the initial study;
• An examination of whether the project would be consistent with existing zoning, plans, and other applicable land use controls; and • The names of the persons who prepared or participated in the initial study.

An initial study ordinarily should disclose the data or evidence supporting the study's environmental findings. Citizens Ass'n for Sensible Dev. v County of Inyo (1985) 172 Cal.App.3d 151, 171. CEQA requires that an environmental document identify and discuss the significant effects of a Project, alternatives and how those significant effects can be mitigated or avoided. CEQA Guidelines § 15126.2; PRC §§ 21100(b)(1), 21002.1(a);. An environmental documents discussion of potentially significant effects must “provide an adequate analysis to inform the public how its bare numbers translate to create otential adverse impacts or it must adequately explain what the agency does know and why, given existing scientific constraints, it cannot translate potential health impacts further.” Sierra Club v. County of Fresno (2018) 6 Cal. 5th 502, 521; see also citing Laurel Heights Improvement Assn. v. Regents of University of California (1988) 47 Cal.3d 376, 405; see also PRC §§ 21002.1(e), 21003(b).

A reviewing court may determine whether a CEQA environmental document sufficiently discloses information required by CEQA de novo as “noncompliance with the information disclosure provisions” of CEQA is a failure to proceed in a manner required by law. PRC § 21005(a); see also Sierra Club v. County of Fresno (2018) 6 Cal. 5th 502, 515; CEQA Guidelines.

The IS/MND fails to disclose information to the public that is necessary for the public to determine whether the environmental impacts of the Project are less than significant, or have been reduced to a level below significance by the mitigation measures proposed in the IS/MND. These inappropriate omissions include:
• Failing to include as attachments or appendices to the IS/MND any of the studies and reports relied on by the IS/MND in determining that the Project’s environmental impacts are less than significant (or less than significant with 69 City of Adelanto – Morris Mu & Partners Auburn Avenue Project November 29, 2021

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applied mitigations), including but not limited to greenhouse gas studies, hydrology reports, geotechnical reports, and traffic and VMT analyses; • Failing to provide any analysis or reasoning whatsoever for concluding that the Project will have less than significant impacts on energy; • Failing to include any discussion of methodology, significance threshold selection, data, or findings related to greenhouse gas emissions, and failing to discuss at all the Project’s conflict or conformance with plans, policies, and regulations adopted for the purpose of reducing the emission of greenhouse gases;
• Failing to discuss conformance with any part of the City’s General Plan or applicable specific plan apart from mere compatibility with land use and zoning designations relating to cannabis cultivation (IS/MND, 71); • Failing to analyze anticipated effects of construction or operational noise levels; and
• Concluding that the Project’s impact on VMT and other transportation impacts would be less than significant without including any analysis of those potential impacts.

2. The IS/MND Fails to Support its Findings on Air Quality Impacts with Substantial Evidence and Defers Mitigation to Reduce Impacts.

The IS/MND’s conclusions regarding air quality impacts are unsupported by substantial evidence. The IS/MND concludes that the Project will have a potentially significant impact relating to odor emissions that could affect a substantial number of people near the Project site. (IS/MND, 34-5.)
In response, the IS/MND fails to specify with any degree of specificity or certainty how the proposed mitigation measures will reduce the potentially significant impact and defers formulation of such mitigation until after Project approval (IS/MND, 38.) The IS/MND relies upon the enactment of an Odor Management Plan to reduce air quality impacts but fails to include any details of that plan or how it would be enforced—deferring such mitigation until after Project approval. (Id.) If the Odor 70 City of Adelanto – Morris Mu & Partners Auburn Avenue Project November 29, 2021

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Management Plan is undefined, it is also not possible to determine whether such mitigation will reduce the potentially significant impact to levels below significance, or if additional mitigation measures should also be considered and adopted.

Without more information, it is indeterminable whether the IS/MND’s conclusions regarding air quality impacts are supported by substantial evidence.

3. The IS/MND Fails to Support its Findings on Energy Impacts with Substantial Evidence
The IS/MND’s analysis of energy-related impacts is entirely lacking and does not attempt to analyze or disclose the Project’s energy consumption, and is thus unsupported by substantial evidence. This is particularly concerning given growing concerns over energy consumption issues related to the cannabis cultivation industry, especially indoor cannabis cultivation facilities.
11 The IS/MND needs to be revised to expand its analysis of the Project’s projected energy consumption, and whether it will result in wasteful, inefficient, or unnecessary consumption of energy resources, or result in the obstruction of state or local renewable energy or energy efficiency plans and goals.

4. The IS/MND Fails to Support with Substantial Evidence its Findings Regarding Utilities and Service Systems
The IS/MND notes that the proposed Project would “consume 60,102 gallons of water per day and generate 48,082 gallons of effluent per day.” (IS/MND, 91.) The IS/MND does not include any analysis of how the City can adequately cover this water consumption and effluent with existing infrastructure. The IS/MND speculates that the City can meet the increased demand but does not provide any substantive analysis to support this conclusion beyond this conclusory statement. 11 See, e.g., Natalie Fertig and Gavin Bade, Politico, “An inconvenient truth (about weed),” August 10, 2021, available at: https://www.politico.com/news/2021/08/10/weedcannabis-legalization-energy-503004; Jyoti Madhusoodana, Nature, “Can cannabis go green?” August 28, 2019, available at: https://www.nature.com/articles/d41586-019- 02526-3.
71 City of Adelanto – Morris Mu & Partners Auburn Avenue Project November 29, 2021

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5. The IS/MND Fails to Support its Findings on Greenhouse Gas Emissions with Substantial Evidence
Here, the IS/MND has not provided any evidence, let alone substantial evidence, to support the conclusion that the Project greenhouse gas emissions impacts would be less than significant. The IS/MND simply identifies a MDAQMD threshold of 100,000/MTCO2e and supposes that the Project will be under that threshold. (IS/MND, 59.) The IS/MND does not substantiate use of the MDAQMD threshold for its proposed land use nor does it provide any underlying analysis that operational emissions will be under that threshold. Notably, the IS/MND does not account for all of the Project’s operational emissions, including but not limited to mobile emissions and vehicle miles traveled which the IS/MND has failed to characterize or analyze.

Furthermore, the IS/MND also fails to amortize the Project’s construction-related GHG emissions and combine that figure with the Project’s operational emissions.

For all these reasons, the GHG emissions analysis is not supported by substantial evidence.

6. The IS/MND Fails to Support its Findings on Biological Resources with Substantial Evidence.

The IS/MND bases analysis of the Project’s impacts to biological resources on a August 17, 2020 assessment conducted by RCA Associates Inc. However, the City has not provided a copy of this assessment and no details of the scope and methods of the assessment were provided in the IS/MND. From the information provided, there is no way to determine if there has been adequate analysis and disclosure of impacts or if inaccurate and incomplete information has been provided. The lack of information is particularly concerning given that the IS/MND has identified sensitive species on the Project site. Additionally, the California Dept. of Fish and Wildlife (CDFW) has provided extensive comments on the IS/MND deficiencies relating to its biological resources analysis which SWRCC incorporates herein by reference.12 The IS/MND needs to be revised to provide accurate and complete information about the biological assessment, attach a copy of that assessment, and provide all detailed 12 Nov. 19, 2021 Letter from CDFW to Mary Blais re Morris Mu & Partners, available at https://files.ceqanet.opr.ca.gov/273778-
1/attachment/qwZEg9c7DVXcHK8BPMWYrZNbmHWmzRnvIerXPeGkIyduk7bhcfQde0 ZKegG-Bpl4AtTXGDTIJd7tVWLt0.
72 City of Adelanto – Morris Mu & Partners Auburn Avenue Project November 29, 2021

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information relating to biological resources surveys conducted or any other field assessments.

7. The IS/MND Fails to Support its Findings on Land Use with Substantial Evidence.

8. The IS/MND Fails to Support its Findings on Transportation with Substantial Evidence.

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II. THE PROJECT VIOLATES THE STATE PLANNING AND
ZONING LAW AS WELL AS THE CITY’S GENERAL PLAN
A. Background Regarding the State Planning and Zoning Law Each California city and county must adopt a comprehensive, long-term general plan governing development. Napa Citizens for Honest Gov. v. Napa County Bd. of Supervisors (2001) 91 Cal.App.4th 342, 352, citing Gov. Code §§ 65030, 65300. The general plan sits at the top of the land use planning hierarchy, and serves as a “constitution” or “charter” for all future development. DeVita v. County of Napa (1995) 9 Cal.4th 763, 773; Lesher Communications, Inc. v. City of Walnut Creek (1990) 52 Cal.3d 531, 540.

A project cannot be found consistent with a general plan if it conflicts with a general plan policy that is “fundamental, mandatory, and clear,” regardless of whether it is consistent with other general plan policies. See Endangered Habitats League v. County of Orange (2005) 131 Cal.App.4th 777, 782-83; Families Unafraid to Uphold Rural El Dorado 74 City of Adelanto – Morris Mu & Partners Auburn Avenue Project November 29, 2021

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County v. Bd. of Supervisors (1998) 62 Cal.App.4th 1332, 1341-42 (“FUTURE”).

III. CONCLUSION
SWRCC request that the City prepare an environmental impact report or revise the IS/MND for the Project to address the aforementioned concerns. If the City has any questions or concerns, feel free to contact my Office.

Sincerely,
__________________________
Mitchell M. Tsai
Attorneys for Southwest Regional
Council of Carpenters
Attached:

March 8, 2021 SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and Considerations for Greenhouse Gas Modeling (Exhibit A); Air Quality and GHG Expert Paul Rosenfeld CV (Exhibit B); and Air Quality and GHG Expert Matt Hagemann CV (Exhibit C). 75 EXHIBIT A
76 1
2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
[email protected]
Paul E. Rosenfeld, PhD
(310) 795-2335
[email protected]
March 8, 2021
Mitchell M. Tsai
155 South El Molino, Suite 104
Pasadena, CA 91101
Subject: Local Hire Requirements and Considerations for Greenhouse Gas Modeling Dear Mr. Tsai,
Soil Water Air Protection Enterprise (“SWAPE”) is pleased to provide the following draft technical report explaining the significance of worker trips required for construction of land use development projects with respect to the estimation of greenhouse gas (“GHG”) emissions. The report will also discuss the potential for local hire requirements to reduce the length of worker trips, and consequently, reduced or mitigate the potential GHG impacts.

Worker Trips and Greenhouse Gas Calculations
The California Emissions Estimator Model (“CalEEMod”) is a “statewide land use emissions computer model designed to provide a uniform platform for government agencies, land use planners, and environmental professionals to quantify potential criteria pollutant and greenhouse gas (GHG) emissions associated with both construction and operations from a variety of land use projects.”1 CalEEMod quantifies construction-related emissions associated with land use projects resulting from off-road construction equipment; on-road mobile equipment associated with workers, vendors, and hauling; fugitive dust associated with grading, demolition, truck loading, and on-road vehicles traveling along paved and unpaved roads; and architectural coating activities; and paving.2
The number, length, and vehicle class of worker trips are utilized by CalEEMod to calculate emissions associated with the on-road vehicle trips required to transport workers to and from the Project site during construction.3 1 “California Emissions Estimator Model.” CAPCOA, 2017, available at: http://www.aqmd.gov/caleemod/home. 2 “California Emissions Estimator Model.” CAPCOA, 2017, available at: http://www.aqmd.gov/caleemod/home. 3 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 34. 77 2
Specifically, the number and length of vehicle trips is utilized to estimate the vehicle miles travelled (“VMT”) associated with construction. Then, utilizing vehicle-class specific EMFAC 2014 emission factors, CalEEMod calculates the vehicle exhaust, evaporative, and dust emissions resulting from construction-related VMT, including personal vehicles for worker commuting.4
Specifically, in order to calculate VMT, CalEEMod multiplies the average daily trip rate by the average overall trip length (see excerpt below):
“VMTd = Σ(Average Daily Trip Rate i * Average Overall Trip Length i) n Where:
n = Number of land uses being modeled.”5
Furthermore, to calculate the on-road emissions associated with worker trips, CalEEMod utilizes the following equation (see excerpt below):
“Emissionspollutant = VMT * EFrunning,pollutant
Where:

Emissionspollutant = emissions from vehicle running for each pollutant VMT = vehicle miles traveled
EFrunning,pollutant = emission factor for running emissions.” 6 Thus, there is a direct relationship between trip length and VMT, as well as a direct relationship between VMT and vehicle running emissions. In other words, when the trip length is increased, the VMT and vehicle running emissions increase as a result. Thus, vehicle running emissions can be reduced by decreasing the average overall trip length, by way of a local hire requirement or otherwise.

Default Worker Trip Parameters and Potential Local Hire Requirements As previously discussed, the number, length, and vehicle class of worker trips are utilized by CalEEMod to calculate emissions associated with the on-road vehicle trips required to transport workers to and from the Project site during construction.7In order to understand how local hire requirements and associated worker trip length reductions impact GHG emissions calculations, it is important to consider the CalEEMod default worker trip parameters. CalEEMod provides recommended default values based on site-specific information, such as land use type, meteorological data, total lot acreage, project type and typical equipment associated with project type. If more specific project information is known, the user can change the default values and input projectspecific values, but the California Environmental Quality Act (“CEQA”) requires that such changes be justified by substantial evidence.8 The default number of construction-related worker trips is calculated by multiplying the 4 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 14-15. 5 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 23. 6 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 15. 7 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 34. 8 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 1, 9. 78 3
number of pieces of equipment for all phases by 1.25, with the exception of worker trips required for the building construction and architectural coating phases.9Furthermore, the worker trip vehicle class is a 50/25/25 percent mix of light duty autos, light duty truck class 1 and light duty truck class 2, respectively.”10 Finally, the default worker trip length is consistent with the length of the operational home-to-work vehicle trips.11 The operational home-to-work vehicle trip lengths are:
“[B]ased on the location and urbanization selected on the project characteristic screen. These values were supplied by the air districts or use a default average for the state. Each district (or county) also assigns trip lengths for urban and rural settings” (emphasis added). 12 Thus, the default worker trip length is based on the location and urbanization level selected by the User when modeling emissions. The below table shows the CalEEMod default rural and urban worker trip lengths by air basin (see excerpt below and Attachment A).13
Worker Trip Length by Air Basin
Air Basin Rural (miles) Urban (miles)
Great Basin Valleys 16.8 10.8
Lake County 16.8 10.8
Lake Tahoe 16.8 10.8
Mojave Desert 16.8 10.8
Mountain Counties 16.8 10.8
North Central Coast 17.1 12.3
North Coast 16.8 10.8
Northeast Plateau 16.8 10.8
Sacramento Valley 16.8 10.8
Salton Sea 14.6 11
San Diego 16.8 10.8
San Francisco Bay Area 10.8 10.8
San Joaquin Valley 16.8 10.8
South Central Coast 16.8 10.8
South Coast 19.8 14.7
Average 16.47 11.17
Minimum 10.80 10.80
Maximum 19.80 14.70
Range 9.00 3.90
9 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 34. 10 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at:
http://www.aqmd.gov/docs/default-source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 15. 11 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at:
http://www.aqmd.gov/docs/default-source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 14. 12 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at:
http://www.aqmd.gov/docs/default-source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 21. 13 “Appendix D Default Data Tables.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/05_appendix-d2016-3-2.pdf?sfvrsn=4, p. D-84 – D-86. 79 4
As demonstrated above, default rural worker trip lengths for air basins in California vary from 10.8- to 19.8- miles, with an average of 16.47 miles. Furthermore, default urban worker trip lengths vary from 10.8- to 14.7- miles, with an average of 11.17 miles. Thus, while default worker trip lengths vary by location, default urban worker trip lengths tend to be shorter in length. Based on these trends evident in the CalEEMod default worker trip lengths, we can reasonably assume that the efficacy of a local hire requirement is especially dependent upon the urbanization of the project site, as well as the project location.

Practical Application of a Local Hire Requirement and Associated Impact To provide an example of the potential impact of a local hire provision on construction-related GHG emissions, we estimated the significance of a local hire provision for the Village South Specific Plan (“Project”) located in the City of Claremont (“City”). The Project proposed to construct 1,000 residential units, 100,000-SF of retail space, 45,000-SF of office space, as well as a 50-room hotel, on the 24-acre site. The Project location is classified as Urban and lies within the Los Angeles-South Coast County. As a result, the Project has a default worker trip length of 14.7 miles.14 In an effort to evaluate the potential for a local hire provision to reduce the Project’s construction-related GHG emissions, we prepared an updated model, reducing all worker trip lengths to 10 miles (see Attachment B). Our analysis estimates that if a local hire provision with a 10-mile radius were to be implemented, the GHG emissions associated with Project construction would decrease by approximately 17% (see table below and Attachment C).

Local Hire Provision Net Change
Without Local Hire Provision
Total Construction GHG Emissions (MT CO2e) 3,623
Amortized Construction GHG Emissions (MT CO2e/year) 120.77 With Local Hire Provision
Total Construction GHG Emissions (MT CO2e) 3,024
Amortized Construction GHG Emissions (MT CO2e/year) 100.80 % Decrease in Construction-related GHG Emissions 17%
As demonstrated above, by implementing a local hire provision requiring 10 mile worker trip lengths, the Project could reduce potential GHG emissions associated with construction worker trips. More broadly, any local hire requirement that results in a decreased worker trip length from the default value has the potential to result in a reduction of construction-related GHG emissions, though the significance of the reduction would vary based on the location and urbanization level of the project site.

This serves as an example of the potential impacts of local hire requirements on estimated project-level GHG emissions, though it does not indicate that local hire requirements would result in reduced construction-related GHG emission for all projects. As previously described, the significance of a local hire requirement depends on the worker trip length enforced and the default worker trip length for the project’s urbanization level and location.
14 “Appendix D Default Data Tables.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/05_appendix-d2016-3-2.pdf?sfvrsn=4, p. D-85. 80 5
Disclaimer
SWAPE has received limited discovery. Additional information may become available in the future; thus, we retain the right to revise or amend this report when additional information becomes available. Our professional services have been performed using that degree of care and skill ordinarily exercised, under similar circumstances, by reputable environmental consultants practicing in this or similar localities at the time of service. No other warranty, expressed or implied, is made as to the scope of work, work methodologies and protocols, site conditions, analytical testing results, and findings presented. This report reflects efforts which were limited to information that was reasonably accessible at the time of the work, and may contain informational gaps, inconsistencies, or otherwise be incomplete due to the unavailability or uncertainty of information obtained or provided by third parties.

Sincerely,
Matt Hagemann, P.G., C.Hg.

Paul E. Rosenfeld, Ph.D.
81 Location Type Location Name Rural H-W
(miles)
Urban H-W
(miles)
Air Basin Great Basin 16.8 10.8
Air Basin Lake County 16.8 10.8
Air Basin Lake Tahoe 16.8 10.8
Air Basin Mojave Desert 16.8 10.8
Air Basin Mountain 16.8 10.8
Air Basin North Central 17.1 12.3
Air Basin North Coast 16.8 10.8
Air Basin Northeast 16.8 10.8
Air Basin Sacramento 16.8 10.8
Air Basin Salton Sea 14.6 11
Air Basin San Diego 16.8 10.8
Air Basin San Francisco 10.8 10.8
Air Basin San Joaquin 16.8 10.8
Air Basin South Central 16.8 10.8
Air Basin South Coast 19.8 14.7
Air District Amador County 16.8 10.8
Air District Antelope Valley 16.8 10.8
Air District Bay Area AQMD 10.8 10.8
Air District Butte County 12.54 12.54
Air District Calaveras 16.8 10.8
Air District Colusa County 16.8 10.8
Air District El Dorado 16.8 10.8
Air District Feather River 16.8 10.8
Air District Glenn County 16.8 10.8
Air District Great Basin 16.8 10.8
Air District Imperial County 10.2 7.3
Air District Kern County 16.8 10.8
Air District Lake County 16.8 10.8
Air District Lassen County 16.8 10.8
Air District Mariposa 16.8 10.8
Air District Mendocino 16.8 10.8
Air District Modoc County 16.8 10.8
Air District Mojave Desert 16.8 10.8
Air District Monterey Bay 16.8 10.8
Air District North Coast 16.8 10.8
Air District Northern Sierra 16.8 10.8
Air District Northern

16.8 10.8
Air District Placer County 16.8 10.8
Air District Sacramento 15 10
Attachment A
82 Air District San Diego 16.8 10.8
Air District San Joaquin

16.8 10.8
Air District San Luis Obispo 13 13
Air District Santa Barbara 8.3 8.3
Air District Shasta County 16.8 10.8
Air District Siskiyou County 16.8 10.8
Air District South Coast 19.8 14.7
Air District Tehama County 16.8 10.8
Air District Tuolumne 16.8 10.8
Air District Ventura County 16.8 10.8
Air District Yolo/Solano 15 10
County Alameda 10.8 10.8
County Alpine 16.8 10.8
County Amador 16.8 10.8
County Butte 12.54 12.54
County Calaveras 16.8 10.8
County Colusa 16.8 10.8
County Contra Costa 10.8 10.8
County Del Norte 16.8 10.8
County El Dorado-Lake 16.8 10.8
County El Dorado- 16.8 10.8
County Fresno 16.8 10.8
County Glenn 16.8 10.8
County Humboldt 16.8 10.8
County Imperial 10.2 7.3
County Inyo 16.8 10.8
County Kern-Mojave 16.8 10.8
County Kern-San 16.8 10.8
County Kings 16.8 10.8
County Lake 16.8 10.8
County Lassen 16.8 10.8
County Los Angeles- 16.8 10.8
County Los Angeles- 19.8 14.7
County Madera 16.8 10.8
County Marin 10.8 10.8
County Mariposa 16.8 10.8
County Mendocino- 16.8 10.8
County Mendocino- 16.8 10.8
County Mendocino- 16.8 10.8
County Mendocino- 16.8 10.8
County Merced 16.8 10.8
County Modoc 16.8 10.8
County Mono 16.8 10.8
County Monterey 16.8 10.8
County Napa 10.8 10.8
83 County Nevada 16.8 10.8
County Orange 19.8 14.7
County Placer-Lake 16.8 10.8
County Placer-Mountain 16.8 10.8
County Placer- 16.8 10.8
County Plumas 16.8 10.8
County Riverside- 16.8 10.8
County Riverside-

19.8 14.7
County Riverside-Salton 14.6 11
County Riverside-South 19.8 14.7
County Sacramento 15 10
County San Benito 16.8 10.8
County San Bernardino- 16.8 10.8
County San Bernardino- 19.8 14.7
County San Diego 16.8 10.8
County San Francisco 10.8 10.8
County San Joaquin 16.8 10.8
County San Luis Obispo 13 13
County San Mateo 10.8 10.8
County Santa Barbara-

8.3 8.3
County Santa Barbara-

8.3 8.3
County Santa Clara 10.8 10.8
County Santa Cruz 16.8 10.8
County Shasta 16.8 10.8
County Sierra 16.8 10.8
County Siskiyou 16.8 10.8
County Solano- 15 10
County Solano-San 16.8 10.8
County Sonoma-North 16.8 10.8
County Sonoma-San 10.8 10.8
County Stanislaus 16.8 10.8
County Sutter 16.8 10.8
County Tehama 16.8 10.8
County Trinity 16.8 10.8
County Tulare 16.8 10.8
County Tuolumne 16.8 10.8
County Ventura 16.8 10.8
County Yolo 15 10
County Yuba 16.8 10.8
Statewide Statewide 16.8 10.8
84 Air Basin Rural (miles) Urban (miles)
Great Basin Valleys 16.8 10.8
Lake County 16.8 10.8
Lake Tahoe 16.8 10.8
Mojave Desert 16.8 10.8
Mountain Counties 16.8 10.8
North Central Coast 17.1 12.3
North Coast 16.8 10.8
Northeast Plateau 16.8 10.8
Sacramento Valley 16.8 10.8
Salton Sea 14.6 11
San Diego 16.8 10.8
San Francisco Bay Area 10.8 10.8
San Joaquin Valley 16.8 10.8
South Central Coast 16.8 10.8
South Coast 19.8 14.7
Average 16.47 11.17
Mininum 10.80 10.80
Maximum 19.80 14.70
Range 9.00 3.90
Worker Trip Length by Air Basin
85 1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population General Office Building 45.00 1000sqft 1.03 45,000.00 0 High Turnover (Sit Down Restaurant) 36.00 1000sqft 0.83 36,000.00 0 Hotel 50.00 Room 1.67 72,600.00 0
Quality Restaurant 8.00 1000sqft 0.18 8,000.00 0
Apartments Low Rise 25.00 Dwelling Unit 1.56 25,000.00 72 Apartments Mid Rise 975.00 Dwelling Unit 25.66 975,000.00 2789 Regional Shopping Center 56.00 1000sqft 1.29 56,000.00 0

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
9 Wind Speed (m/s) 2.2 Precipitation Freq (Days) 33

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company Southern California Edison
Operational Year 2028
CO2 Intensity
(lb/MWhr)
702.44 CH4 Intensity 0.029
(lb/MWhr)
N2O Intensity 0.006
(lb/MWhr)
Village South Specific Plan (Proposed)
Los Angeles-South Coast County, Annual
CalEEMod Version: CalEEMod.2016.3.2 Page 1 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual Attachment B
86 Project Characteristics - Consistent with the DEIR's model.

Land Use - See SWAPE comment regarding residential and retail land uses.

Construction Phase - See SWAPE comment regarding individual construction phase lengths.

Demolition - Consistent with the DEIR's model. See SWAPE comment regarding demolition.

Vehicle Trips - Saturday trips consistent with the DEIR's model. See SWAPE comment regarding weekday and Sunday trips.

Woodstoves - Woodstoves and wood-burning fireplaces consistent with the DEIR's model. See SWAPE comment regarding gas fireplaces.

Energy Use -
Construction Off-road Equipment Mitigation - See SWAPE comment on construction-related mitigation.

Area Mitigation - See SWAPE comment regarding operational mitigation measures.

Water Mitigation - See SWAPE comment regarding operational mitigation measures.

Table Name Column Name Default Value New Value
tblFireplaces FireplaceWoodMass 1,019.20 0.00
tblFireplaces FireplaceWoodMass 1,019.20 0.00
tblFireplaces NumberWood 1.25 0.00
tblFireplaces NumberWood 48.75 0.00
tblVehicleTrips ST_TR 7.16 6.17
tblVehicleTrips ST_TR 6.39 3.87
tblVehicleTrips ST_TR 2.46 1.39
tblVehicleTrips ST_TR 158.37 79.82
tblVehicleTrips ST_TR 8.19 3.75
tblVehicleTrips ST_TR 94.36 63.99
tblVehicleTrips ST_TR 49.97 10.74
tblVehicleTrips SU_TR 6.07 6.16
tblVehicleTrips SU_TR 5.86 4.18
tblVehicleTrips SU_TR 1.05 0.69
tblVehicleTrips SU_TR 131.84 78.27
CalEEMod Version: CalEEMod.2016.3.2 Page 2 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 87 2.0 Emissions Summary
tblVehicleTrips SU_TR 5.95 3.20
tblVehicleTrips SU_TR 72.16 57.65
tblVehicleTrips SU_TR 25.24 6.39
tblVehicleTrips WD_TR 6.59 5.83
tblVehicleTrips WD_TR 6.65 4.13
tblVehicleTrips WD_TR 11.03 6.41
tblVehicleTrips WD_TR 127.15 65.80
tblVehicleTrips WD_TR 8.17 3.84
tblVehicleTrips WD_TR 89.95 62.64
tblVehicleTrips WD_TR 42.70 9.43
tblWoodstoves NumberCatalytic 1.25 0.00
tblWoodstoves NumberCatalytic 48.75 0.00
tblWoodstoves NumberNoncatalytic 1.25 0.00
tblWoodstoves NumberNoncatalytic 48.75 0.00
tblWoodstoves WoodstoveDayYear 25.00 0.00
tblWoodstoves WoodstoveDayYear 25.00 0.00
tblWoodstoves WoodstoveWoodMass 999.60 0.00
tblWoodstoves WoodstoveWoodMass 999.60 0.00
CalEEMod Version: CalEEMod.2016.3.2 Page 3 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 88 2.1 Overall Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2021 0.1713 1.8242 1.1662 2.4000e0030.4169 0.0817 0.4986 0.1795 0.0754 0.2549 0.0000 213.1969 213.1969 0.0601 0.0000 214.6993 2022 0.6904 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721.682 6 1,721.682
6 0.1294 0.0000 1,724.918
7 2023 0.6148 3.3649 5.6747 0.0178 1.1963 0.0996 1.2959 0.3203 0.0935 0.4138 0.0000 1,627.529 5 1,627.529
5 0.1185 0.0000 1,630.492
5 2024 4.1619 0.1335 0.2810 5.9000e0040.0325 6.4700e0030.0390 8.6300e0036.0400e0030.0147 0.0000 52.9078 52.9078 8.0200e0030.0000 53.1082 Maximum 4.1619 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721.682 6 1,721.682
6 0.1294 0.0000 1,724.918
7 Unmitigated Construction
CalEEMod Version: CalEEMod.2016.3.2 Page 4 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 89 2.1 Overall Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2021 0.1713 1.8242 1.1662 2.4000e0030.4169 0.0817 0.4986 0.1795 0.0754 0.2549 0.0000 213.1967 213.1967 0.0601 0.0000 214.6991 2022 0.6904 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721.682 3 1,721.682
3 0.1294 0.0000 1,724.918
3 2023 0.6148 3.3648 5.6747 0.0178 1.1963 0.0996 1.2959 0.3203 0.0935 0.4138 0.0000 1,627.529 1 1,627.529
1 0.1185 0.0000 1,630.492
1 2024 4.1619 0.1335 0.2810 5.9000e0040.0325 6.4700e0030.0390 8.6300e0036.0400e0030.0147 0.0000 52.9077 52.9077 8.0200e0030.0000 53.1082 Maximum 4.1619 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721.682 3 1,721.682
3 0.1294 0.0000 1,724.918
3 Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Quarter Start Date End Date Maximum Unmitigated ROG + NOX (tons/quarter) Maximum Mitigated ROG + NOX (tons/quarter) 1 9-1-2021 11-30-2021 1.4103 1.4103
2 12-1-2021 2-28-2022 1.3613 1.3613
3 3-1-2022 5-31-2022 1.1985 1.1985
4 6-1-2022 8-31-2022 1.1921 1.1921
5 9-1-2022 11-30-2022 1.1918 1.1918
6 12-1-2022 2-28-2023 1.0774 1.0774
7 3-1-2023 5-31-2023 1.0320 1.0320
8 6-1-2023 8-31-2023 1.0260 1.0260
CalEEMod Version: CalEEMod.2016.3.2 Page 5 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 90 2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Area 5.1437 0.2950 10.3804 1.6700e0030.0714 0.0714 0.0714 0.0714 0.0000 220.9670 220.9670 0.0201 3.7400e003222.5835 Energy 0.1398 1.2312 0.7770 7.6200e0030.0966 0.0966 0.0966 0.0966 0.0000 3,896.073 2 3,896.073
2 0.1303 0.0468 3,913.283
3 Mobile 1.5857 7.9962 19.1834 0.0821 7.7979 0.0580 7.8559 2.0895 0.0539 2.1434 0.0000 7,620.498 6 7,620.498
6 0.3407 0.0000 7,629.016
2 Waste 0.0000 0.0000 0.0000 0.0000 207.8079 0.0000 207.8079 12.2811 0.0000 514.8354 Water 0.0000 0.0000 0.0000 0.0000 29.1632 556.6420 585.8052 3.0183 0.0755 683.7567 Total 6.8692 9.5223 30.3407 0.0914 7.7979 0.2260 8.0240 2.0895 0.2219 2.3114 236.9712 12,294.18 07 12,531.15
19 15.7904 0.1260 12,963.47
51 Unmitigated Operational
9 9-1-2023 11-30-2023 1.0265 1.0265
10 12-1-2023 2-29-2024 2.8857 2.8857
11 3-1-2024 5-31-2024 1.6207 1.6207
Highest 2.8857 2.8857
CalEEMod Version: CalEEMod.2016.3.2 Page 6 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 91 2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Area 5.1437 0.2950 10.3804 1.6700e0030.0714 0.0714 0.0714 0.0714 0.0000 220.9670 220.9670 0.0201 3.7400e003222.5835 Energy 0.1398 1.2312 0.7770 7.6200e0030.0966 0.0966 0.0966 0.0966 0.0000 3,896.073 2 3,896.073
2 0.1303 0.0468 3,913.283
3 Mobile 1.5857 7.9962 19.1834 0.0821 7.7979 0.0580 7.8559 2.0895 0.0539 2.1434 0.0000 7,620.498 6 7,620.498
6 0.3407 0.0000 7,629.016
2 Waste 0.0000 0.0000 0.0000 0.0000 207.8079 0.0000 207.8079 12.2811 0.0000 514.8354 Water 0.0000 0.0000 0.0000 0.0000 29.1632 556.6420 585.8052 3.0183 0.0755 683.7567 Total 6.8692 9.5223 30.3407 0.0914 7.7979 0.2260 8.0240 2.0895 0.2219 2.3114 236.9712 12,294.18 07 12,531.15
19 15.7904 0.1260 12,963.47
51 Mitigated Operational

3.0 Construction Detail
Construction Phase
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CalEEMod Version: CalEEMod.2016.3.2 Page 7 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 92 Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 9/1/2021 10/12/2021 5 30
2 Site Preparation Site Preparation 10/13/2021 11/9/2021 5 20 3 Grading Grading 11/10/2021 1/11/2022 5 45
4 Building Construction Building Construction 1/12/2022 12/12/2023 5 500 5 Paving Paving 12/13/2023 1/30/2024 5 35
6 Architectural Coating Architectural Coating 1/31/2024 3/19/2024 5 35 OffRoad Equipment
Residential Indoor: 2,025,000; Residential Outdoor: 675,000; Non-Residential Indoor: 326,400; Non-Residential Outdoor: 108,800; Striped Parking Area: 0 (Architectural Coating ±sqft)
Acres of Grading (Site Preparation Phase): 0
Acres of Grading (Grading Phase): 112.5
Acres of Paving: 0
CalEEMod Version: CalEEMod.2016.3.2 Page 8 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 93 Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Demolition Concrete/Industrial Saws 1 8.00 81 0.73
Demolition Excavators 3 8.00 158 0.38
Demolition Rubber Tired Dozers 2 8.00 247 0.40
Site Preparation Rubber Tired Dozers 3 8.00 247 0.40
Site Preparation Tractors/Loaders/Backhoes 4 8.00 97 0.37 Grading Excavators 2 8.00 158 0.38
Grading Graders 1 8.00 187 0.41
Grading Rubber Tired Dozers 1 8.00 247 0.40
Grading Scrapers 2 8.00 367 0.48
Grading Tractors/Loaders/Backhoes 2 8.00 97 0.37
Building Construction Cranes 1 7.00 231 0.29
Building Construction Forklifts 3 8.00 89 0.20
Building Construction Generator Sets 1 8.00 84 0.74
Building Construction Tractors/Loaders/Backhoes 3 7.00 97 0.37 Building Construction Welders 1 8.00 46 0.45
Paving Pavers 2 8.00 130 0.42
Paving Paving Equipment 2 8.00 132 0.36
Paving Rollers 2 8.00 80 0.38
Architectural Coating Air Compressors 1 6.00 78 0.48
Trips and VMT
CalEEMod Version: CalEEMod.2016.3.2 Page 9 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 94 3.2 Demolition - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0496 0.0000 0.0496 7.5100e0030.0000 7.5100e0030.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0475 0.4716 0.3235 5.8000e0040.0233 0.0233 0.0216 0.0216 0.0000 51.0012 51.0012 0.0144 0.0000 51.3601 Total 0.0475 0.4716 0.3235 5.8000e0040.0496 0.0233 0.0729 7.5100e0030.0216 0.0291 0.0000 51.0012 51.0012 0.0144 0.0000 51.3601 Unmitigated Construction On-Site

3.1 Mitigation Measures Construction
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Demolition 6 15.00 0.00 458.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Site Preparation 7 18.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Grading 8 20.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Building Construction 9 801.00 143.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Paving 6 15.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Architectural Coating 1 160.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod.2016.3.2 Page 10 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 95 3.2 Demolition - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 1.9300e0030.0634 0.0148 1.8000e0043.9400e0031.9000e0044.1300e0031.0800e0031.8000e0041.2600e0030.0000 17.4566 17.4566 1.2100e0030.0000 17.4869 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 9.7000e0047.5000e0048.5100e0032.0000e0052.4700e0032.0000e0052.4900e0036.5000e0042.0000e0056.7000e0040.0000 2.2251 2.2251 7.0000e0050.0000 2.2267 Total 2.9000e0030.0641 0.0233 2.0000e0046.4100e0032.1000e0046.6200e0031.7300e0032.0000e0041.9300e0030.0000 19.6816 19.6816 1.2800e0030.0000 19.7136 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0496 0.0000 0.0496 7.5100e0030.0000 7.5100e0030.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0475 0.4716 0.3235 5.8000e0040.0233 0.0233 0.0216 0.0216 0.0000 51.0011 51.0011 0.0144 0.0000 51.3600 Total 0.0475 0.4716 0.3235 5.8000e0040.0496 0.0233 0.0729 7.5100e0030.0216 0.0291 0.0000 51.0011 51.0011 0.0144 0.0000 51.3600 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 11 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 96 3.2 Demolition - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 1.9300e0030.0634 0.0148 1.8000e0043.9400e0031.9000e0044.1300e0031.0800e0031.8000e0041.2600e0030.0000 17.4566 17.4566 1.2100e0030.0000 17.4869 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 9.7000e0047.5000e0048.5100e0032.0000e0052.4700e0032.0000e0052.4900e0036.5000e0042.0000e0056.7000e0040.0000 2.2251 2.2251 7.0000e0050.0000 2.2267 Total 2.9000e0030.0641 0.0233 2.0000e0046.4100e0032.1000e0046.6200e0031.7300e0032.0000e0041.9300e0030.0000 19.6816 19.6816 1.2800e0030.0000 19.7136 Mitigated Construction Off-Site

3.3 Site Preparation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.1807 0.0000 0.1807 0.0993 0.0000 0.0993 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0389 0.4050 0.2115 3.8000e0040.0204 0.0204 0.0188 0.0188 0.0000 33.4357 33.4357 0.0108 0.0000 33.7061 Total 0.0389 0.4050 0.2115 3.8000e0040.1807 0.0204 0.2011 0.0993 0.0188 0.1181 0.0000 33.4357 33.4357 0.0108 0.0000 33.7061 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 12 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 97 3.3 Site Preparation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 7.7000e0046.0000e0046.8100e0032.0000e0051.9700e0032.0000e0051.9900e0035.2000e0041.0000e0055.4000e0040.0000 1.7801 1.7801 5.0000e0050.0000 1.7814 Total 7.7000e0046.0000e0046.8100e0032.0000e0051.9700e0032.0000e0051.9900e0035.2000e0041.0000e0055.4000e0040.0000 1.7801 1.7801 5.0000e0050.0000 1.7814 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.1807 0.0000 0.1807 0.0993 0.0000 0.0993 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0389 0.4050 0.2115 3.8000e0040.0204 0.0204 0.0188 0.0188 0.0000 33.4357 33.4357 0.0108 0.0000 33.7060 Total 0.0389 0.4050 0.2115 3.8000e0040.1807 0.0204 0.2011 0.0993 0.0188 0.1181 0.0000 33.4357 33.4357 0.0108 0.0000 33.7060 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 13 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 98 3.3 Site Preparation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 7.7000e0046.0000e0046.8100e0032.0000e0051.9700e0032.0000e0051.9900e0035.2000e0041.0000e0055.4000e0040.0000 1.7801 1.7801 5.0000e0050.0000 1.7814 Total 7.7000e0046.0000e0046.8100e0032.0000e0051.9700e0032.0000e0051.9900e0035.2000e0041.0000e0055.4000e0040.0000 1.7801 1.7801 5.0000e0050.0000 1.7814 Mitigated Construction Off-Site

3.4 Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.1741 0.0000 0.1741 0.0693 0.0000 0.0693 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0796 0.8816 0.5867 1.1800e0030.0377 0.0377 0.0347 0.0347 0.0000 103.5405 103.5405 0.0335 0.0000 104.3776 Total 0.0796 0.8816 0.5867 1.1800e0030.1741 0.0377 0.2118 0.0693 0.0347 0.1040 0.0000 103.5405 103.5405 0.0335 0.0000 104.3776 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 14 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 99 3.4 Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 1.6400e0031.2700e0030.0144 4.0000e0054.1600e0033.0000e0054.2000e0031.1100e0033.0000e0051.1400e0030.0000 3.7579 3.7579 1.1000e0040.0000 3.7607 Total 1.6400e0031.2700e0030.0144 4.0000e0054.1600e0033.0000e0054.2000e0031.1100e0033.0000e0051.1400e0030.0000 3.7579 3.7579 1.1000e0040.0000 3.7607 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.1741 0.0000 0.1741 0.0693 0.0000 0.0693 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0796 0.8816 0.5867 1.1800e0030.0377 0.0377 0.0347 0.0347 0.0000 103.5403 103.5403 0.0335 0.0000 104.3775 Total 0.0796 0.8816 0.5867 1.1800e0030.1741 0.0377 0.2118 0.0693 0.0347 0.1040 0.0000 103.5403 103.5403 0.0335 0.0000 104.3775 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 15 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 100

3.4 Grading - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0807 0.0000 0.0807 0.0180 0.0000 0.0180 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0127 0.1360 0.1017 2.2000e0045.7200e0035.7200e0035.2600e0035.2600e0030.0000 19.0871 19.0871 6.1700e0030.0000 19.2414 Total 0.0127 0.1360 0.1017 2.2000e0040.0807 5.7200e0030.0865 0.0180 5.2600e0030.0233 0.0000 19.0871 19.0871 6.1700e0030.0000 19.2414 Unmitigated Construction On-Site
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3.4 Grading - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 2.8000e0042.1000e0042.4400e0031.0000e0057.7000e0041.0000e0057.7000e0042.0000e0041.0000e0052.1000e0040.0000 0.6679 0.6679 2.0000e0050.0000 0.6684 Total 2.8000e0042.1000e0042.4400e0031.0000e0057.7000e0041.0000e0057.7000e0042.0000e0041.0000e0052.1000e0040.0000 0.6679 0.6679 2.0000e0050.0000 0.6684 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0807 0.0000 0.0807 0.0180 0.0000 0.0180 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0127 0.1360 0.1017 2.2000e0045.7200e0035.7200e0035.2600e0035.2600e0030.0000 19.0871 19.0871 6.1700e0030.0000 19.2414 Total 0.0127 0.1360 0.1017 2.2000e0040.0807 5.7200e0030.0865 0.0180 5.2600e0030.0233 0.0000 19.0871 19.0871 6.1700e0030.0000 19.2414 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 17 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 102

3.5 Building Construction - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.2158 1.9754 2.0700 3.4100e0030.1023 0.1023 0.0963 0.0963 0.0000 293.1324 293.1324 0.0702 0.0000 294.8881 Total 0.2158 1.9754 2.0700 3.4100e0030.1023 0.1023 0.0963 0.0963 0.0000 293.1324 293.1324 0.0702 0.0000 294.8881 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 18 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 103

3.5 Building Construction - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0527 1.6961 0.4580 4.5500e0030.1140 3.1800e0030.1171 0.0329 3.0400e0030.0359 0.0000 441.9835 441.9835 0.0264 0.0000 442.6435 Worker 0.4088 0.3066 3.5305 0.0107 1.1103 8.8700e0031.1192 0.2949 8.1700e0030.3031 0.0000 966.8117 966.8117 0.0266 0.0000 967.4773 Total 0.4616 2.0027 3.9885 0.0152 1.2243 0.0121 1.2363 0.3278 0.0112 0.3390 0.0000 1,408.795 2 1,408.795
2 0.0530 0.0000 1,410.120
8 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.2158 1.9754 2.0700 3.4100e0030.1023 0.1023 0.0963 0.0963 0.0000 293.1321 293.1321 0.0702 0.0000 294.8877 Total 0.2158 1.9754 2.0700 3.4100e0030.1023 0.1023 0.0963 0.0963 0.0000 293.1321 293.1321 0.0702 0.0000 294.8877 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 19 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 104

3.5 Building Construction - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.1942 1.7765 2.0061 3.3300e0030.0864 0.0864 0.0813 0.0813 0.0000 286.2789 286.2789 0.0681 0.0000 287.9814 Total 0.1942 1.7765 2.0061 3.3300e0030.0864 0.0864 0.0813 0.0813 0.0000 286.2789 286.2789 0.0681 0.0000 287.9814 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 20 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 105

3.5 Building Construction - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0382 1.2511 0.4011 4.3000e0030.1113 1.4600e0030.1127 0.0321 1.4000e0030.0335 0.0000 417.9930 417.9930 0.0228 0.0000 418.5624 Worker 0.3753 0.2708 3.1696 0.0101 1.0840 8.4100e0031.0924 0.2879 7.7400e0030.2957 0.0000 909.3439 909.3439 0.0234 0.0000 909.9291 Total 0.4135 1.5218 3.5707 0.0144 1.1953 9.8700e0031.2051 0.3200 9.1400e0030.3292 0.0000 1,327.336 9 1,327.336
9 0.0462 0.0000 1,328.491
6 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.1942 1.7765 2.0061 3.3300e0030.0864 0.0864 0.0813 0.0813 0.0000 286.2785 286.2785 0.0681 0.0000 287.9811 Total 0.1942 1.7765 2.0061 3.3300e0030.0864 0.0864 0.0813 0.0813 0.0000 286.2785 286.2785 0.0681 0.0000 287.9811 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 21 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 106

3.6 Paving - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 6.7100e0030.0663 0.0948 1.5000e0043.3200e0033.3200e0033.0500e0033.0500e0030.0000 13.0175 13.0175 4.2100e0030.0000 13.1227 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 6.7100e0030.0663 0.0948 1.5000e0043.3200e0033.3200e0033.0500e0033.0500e0030.0000 13.0175 13.0175 4.2100e0030.0000 13.1227 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 22 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 107

3.6 Paving - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 3.7000e0042.7000e0043.1200e0031.0000e0051.0700e0031.0000e0051.0800e0032.8000e0041.0000e0052.9000e0040.0000 0.8963 0.8963 2.0000e0050.0000 0.8968 Total 3.7000e0042.7000e0043.1200e0031.0000e0051.0700e0031.0000e0051.0800e0032.8000e0041.0000e0052.9000e0040.0000 0.8963 0.8963 2.0000e0050.0000 0.8968 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 6.7100e0030.0663 0.0948 1.5000e0043.3200e0033.3200e0033.0500e0033.0500e0030.0000 13.0175 13.0175 4.2100e0030.0000 13.1227 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 6.7100e0030.0663 0.0948 1.5000e0043.3200e0033.3200e0033.0500e0033.0500e0030.0000 13.0175 13.0175 4.2100e0030.0000 13.1227 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 23 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 108

3.6 Paving - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0109 0.1048 0.1609 2.5000e0045.1500e0035.1500e0034.7400e0034.7400e0030.0000 22.0292 22.0292 7.1200e0030.0000 22.2073 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0109 0.1048 0.1609 2.5000e0045.1500e0035.1500e0034.7400e0034.7400e0030.0000 22.0292 22.0292 7.1200e0030.0000 22.2073 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 24 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 109

3.6 Paving - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 5.9000e0044.1000e0044.9200e0032.0000e0051.8100e0031.0000e0051.8200e0034.8000e0041.0000e0054.9000e0040.0000 1.4697 1.4697 4.0000e0050.0000 1.4706 Total 5.9000e0044.1000e0044.9200e0032.0000e0051.8100e0031.0000e0051.8200e0034.8000e0041.0000e0054.9000e0040.0000 1.4697 1.4697 4.0000e0050.0000 1.4706 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0109 0.1048 0.1609 2.5000e0045.1500e0035.1500e0034.7400e0034.7400e0030.0000 22.0292 22.0292 7.1200e0030.0000 22.2073 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0109 0.1048 0.1609 2.5000e0045.1500e0035.1500e0034.7400e0034.7400e0030.0000 22.0292 22.0292 7.1200e0030.0000 22.2073 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 25 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 110

3.7 Architectural Coating - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0101 6.9900e0030.0835 2.8000e0040.0307 2.3000e0040.0309 8.1500e0032.2000e0048.3700e0030.0000 24.9407 24.9407 6.1000e0040.0000 24.9558 Total 0.0101 6.9900e0030.0835 2.8000e0040.0307 2.3000e0040.0309 8.1500e0032.2000e0048.3700e0030.0000 24.9407 24.9407 6.1000e0040.0000 24.9558 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Archit. Coating 4.1372 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 3.1600e0030.0213 0.0317 5.0000e0051.0700e0031.0700e0031.0700e0031.0700e0030.0000 4.4682 4.4682 2.5000e0040.0000 4.4745 Total 4.1404 0.0213 0.0317 5.0000e0051.0700e0031.0700e0031.0700e0031.0700e0030.0000 4.4682 4.4682 2.5000e0040.0000 4.4745 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 27 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 112

4.0 Operational Detail - Mobile

4.1 Mitigation Measures Mobile

3.7 Architectural Coating - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0101 6.9900e0030.0835 2.8000e0040.0307 2.3000e0040.0309 8.1500e0032.2000e0048.3700e0030.0000 24.9407 24.9407 6.1000e0040.0000 24.9558 Total 0.0101 6.9900e0030.0835 2.8000e0040.0307 2.3000e0040.0309 8.1500e0032.2000e0048.3700e0030.0000 24.9407 24.9407 6.1000e0040.0000 24.9558 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 28 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 113
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 1.5857 7.9962 19.1834 0.0821 7.7979 0.0580 7.8559 2.0895 0.0539 2.1434 0.0000 7,620.498 6 7,620.498
6 0.3407 0.0000 7,629.016
2 Unmitigated 1.5857 7.9962 19.1834 0.0821 7.7979 0.0580 7.8559 2.0895 0.0539 2.1434 0.0000 7,620.498 6 7,620.498
6 0.3407 0.0000 7,629.016
2 4.2 Trip Summary Information

4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Apartments Low Rise 145.75 154.25 154.00 506,227 506,227 Apartments Mid Rise 4,026.75 3,773.25 4075.50 13,660,065 13,660,065 General Office Building 288.45 62.55 31.05 706,812 706,812 High Turnover (Sit Down Restaurant) 2,368.80 2,873.52 2817.72 3,413,937 3,413,937 Hotel 192.00 187.50 160.00 445,703 445,703
Quality Restaurant 501.12 511.92 461.20 707,488 707,488 Regional Shopping Center 528.08 601.44 357.84 1,112,221 1,112,221 Total 8,050.95 8,164.43 8,057.31 20,552,452 20,552,452
CalEEMod Version: CalEEMod.2016.3.2 Page 29 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 114
Miles Trip % Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by Apartments Low Rise 14.70 5.90 8.70 40.20 19.20 40.60 86 11 3 Apartments Mid Rise 14.70 5.90 8.70 40.20 19.20 40.60 86 11 3 General Office Building 16.60 8.40 6.90 33.00 48.00 19.00 77 19 4 High Turnover (Sit Down
Restaurant)

16.60 8.40 6.90 8.50 72.50 19.00 37 20 43
Hotel 16.60 8.40 6.90 19.40 61.60 19.00 58 38 4
Quality Restaurant 16.60 8.40 6.90 12.00 69.00 19.00 38 18 44 Regional Shopping Center 16.60 8.40 6.90 16.30 64.70 19.00 54 35 11

5.0 Energy Detail

5.1 Mitigation Measures Energy

4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH Apartments Low Rise 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Apartments Mid Rise 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 General Office Building 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 High Turnover (Sit Down
Restaurant)

0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Hotel 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Quality Restaurant 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Regional Shopping Center 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Historical Energy Use: N
CalEEMod Version: CalEEMod.2016.3.2 Page 30 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 115
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Electricity
Mitigated

0.0000 0.0000 0.0000 0.0000 0.0000 2,512.646
5 2,512.646
5 0.1037 0.0215 2,521.635
6 Electricity
Unmitigated

0.0000 0.0000 0.0000 0.0000 0.0000 2,512.646
5 2,512.646
5 0.1037 0.0215 2,521.635
6 NaturalGas
Mitigated

0.1398 1.2312 0.7770 7.6200e0030.0966 0.0966 0.0966 0.0966 0.0000 1,383.426 7 1,383.426
7 0.0265 0.0254 1,391.647
8 NaturalGas
Unmitigated

0.1398 1.2312 0.7770 7.6200e0030.0966 0.0966 0.0966 0.0966 0.0000 1,383.426 7 1,383.426
7 0.0265 0.0254 1,391.647
8 CalEEMod Version: CalEEMod.2016.3.2 Page 31 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 116

1.30613e
+007

0.0704 0.6018 0.2561 3.8400e0030.0487 0.0487 0.0487 0.0487 0.0000 696.9989 696.9989 0.0134 0.0128 701.1408 General Office
Building
468450 2.5300e0030.0230 0.0193 1.4000e0041.7500e0031.7500e0031.7500e0031.7500e0030.0000 24.9983 24.9983 4.8000e0044.6000e00425.1468 High Turnover (Sit
Down Restaurant)

8.30736e
+006

0.0448 0.4072 0.3421 2.4400e0030.0310 0.0310 0.0310 0.0310 0.0000 443.3124 443.3124 8.5000e0038.1300e003445.9468 Hotel 1.74095e
+006

9.3900e0030.0853 0.0717 5.1000e0046.4900e0036.4900e0036.4900e0036.4900e0030.0000 92.9036 92.9036 1.7800e0031.7000e00393.4557 Quality
Restaurant

1.84608e
+006

9.9500e0030.0905 0.0760 5.4000e0046.8800e0036.8800e0036.8800e0036.8800e0030.0000 98.5139 98.5139 1.8900e0031.8100e00399.0993 Regional
Shopping Center
91840 5.0000e0044.5000e0033.7800e0033.0000e0053.4000e0043.4000e0043.4000e0043.4000e0040.0000 4.9009 4.9009 9.0000e0059.0000e0054.9301 Total 0.1398 1.2312 0.7770 7.6200e0030.0966 0.0966 0.0966 0.0966 0.0000 1,383.426 8 1,383.426
8 0.0265 0.0254 1,391.647
8 Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Page 32 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 117

1.30613e
+007

8.30736e
+006

0.0448 0.4072 0.3421 2.4400e0030.0310 0.0310 0.0310 0.0310 0.0000 443.3124 443.3124 8.5000e0038.1300e003445.9468 Hotel 1.74095e
+006

9.3900e0030.0853 0.0717 5.1000e0046.4900e0036.4900e0036.4900e0036.4900e0030.0000 92.9036 92.9036 1.7800e0031.7000e00393.4557 Quality
Restaurant

1.84608e
+006

9.9500e0030.0905 0.0760 5.4000e0046.8800e0036.8800e0036.8800e0036.8800e0030.0000 98.5139 98.5139 1.8900e0031.8100e00399.0993 Regional
Shopping Center
91840 5.0000e0044.5000e0033.7800e0033.0000e0053.4000e0043.4000e0043.4000e0043.4000e0040.0000 4.9009 4.9009 9.0000e0059.0000e0054.9301 Total 0.1398 1.2312 0.7770 7.6200e0030.0966 0.0966 0.0966 0.0966 0.0000 1,383.426 8 1,383.426
8 0.0265 0.0254 1,391.647
8 Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Page 33 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 118

5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
Apartments Low
Rise
106010 33.7770 1.3900e0032.9000e00433.8978
Apartments Mid
Rise

3.94697e
+006
1,257.587
9 0.0519 0.0107 1,262.086
9 General Office
Building
584550 186.2502 7.6900e0031.5900e003186.9165
High Turnover (Sit
Down Restaurant)

6.1 Mitigation Measures Area

6.0 Area Detail

5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
Apartments Low
Rise
106010 33.7770 1.3900e0032.9000e00433.8978
Apartments Mid
Rise

3.94697e
+006
1,257.587
9 0.0519 0.0107 1,262.086
9 General Office
Building
584550 186.2502 7.6900e0031.5900e003186.9165
High Turnover (Sit
Down Restaurant)

1.58904e
+006
506.3022 0.0209 4.3200e003508.1135
Hotel 550308 175.3399 7.2400e0031.5000e003175.9672
Quality
Restaurant
353120 112.5116 4.6500e0039.6000e004112.9141
Regional
Shopping Center
756000 240.8778 9.9400e0032.0600e003241.7395
Total 2,512.646
5 0.1037 0.0215 2,521.635
6 Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Page 35 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 120
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 5.1437 0.2950 10.3804 1.6700e0030.0714 0.0714 0.0714 0.0714 0.0000 220.9670 220.9670 0.0201 3.7400e003222.5835 Unmitigated 5.1437 0.2950 10.3804 1.6700e0030.0714 0.0714 0.0714 0.0714 0.0000 220.9670 220.9670 0.0201 3.7400e003222.5835

6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory tons/yr MT/yr
Architectural
Coating

0.4137 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

7.1 Mitigation Measures Water

7.0 Water Detail

0.4137 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

4.3998 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Hearth 0.0206 0.1763 0.0750 1.1200e0030.0143 0.0143 0.0143 0.0143 0.0000 204.1166 204.1166 3.9100e0033.7400e003205.3295 Landscaping 0.3096 0.1187 10.3054 5.4000e0040.0572 0.0572 0.0572 0.0572 0.0000 16.8504 16.8504 0.0161 0.0000 17.2540 Total 5.1437 0.2950 10.3804 1.6600e0030.0714 0.0714 0.0714 0.0714 0.0000 220.9670 220.9670 0.0201 3.7400e003222.5835 Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Page 37 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 122
Total CO2 CH4 N2O CO2e
Category MT/yr
Mitigated 585.8052 3.0183 0.0755 683.7567
Unmitigated 585.8052 3.0183 0.0755 683.7567
CalEEMod Version: CalEEMod.2016.3.2 Page 38 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 123

7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
Apartments Low
Rise

1.62885 /

1.02688

10.9095 0.0535 1.3400e00312.6471
Apartments Mid
Rise

63.5252 /

40.0485
425.4719 2.0867 0.0523 493.2363
General Office
Building

7.99802 /

4.90201

53.0719 0.2627 6.5900e00361.6019
High Turnover (Sit
Down Restaurant)

10.9272 /

0.697482

51.2702 0.3580 8.8200e00362.8482
Hotel 1.26834 /

0.140927

6.1633 0.0416 1.0300e0037.5079
Quality
Restaurant

2.42827 /

0.154996

11.3934 0.0796 1.9600e00313.9663
Regional
Shopping Center

4.14806 /

2.54236

27.5250 0.1363 3.4200e00331.9490
Total 585.8052 3.0183 0.0755 683.7567
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Page 39 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 124

8.1 Mitigation Measures Waste

7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
Apartments Low
Rise

1.62885 /

1.02688

10.9095 0.0535 1.3400e00312.6471
Apartments Mid
Rise

63.5252 /

40.0485
425.4719 2.0867 0.0523 493.2363
General Office
Building

7.99802 /

4.90201

53.0719 0.2627 6.5900e00361.6019
High Turnover (Sit
Down Restaurant)

10.9272 /

0.697482

51.2702 0.3580 8.8200e00362.8482
Hotel 1.26834 /

0.140927

6.1633 0.0416 1.0300e0037.5079
Quality
Restaurant

2.42827 /

0.154996

11.3934 0.0796 1.9600e00313.9663
Regional
Shopping Center

4.14806 /

2.54236

27.5250 0.1363 3.4200e00331.9490
Total 585.8052 3.0183 0.0755 683.7567
Mitigated

8.0 Waste Detail
CalEEMod Version: CalEEMod.2016.3.2 Page 40 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 125
Total CO2 CH4 N2O CO2e
MT/yr
Mitigated 207.8079 12.2811 0.0000 514.8354
Unmitigated 207.8079 12.2811 0.0000 514.8354
Category/Year
CalEEMod Version: CalEEMod.2016.3.2 Page 41 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 126

8.2 Waste by Land Use
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
Apartments Low
Rise

11.5 2.3344 0.1380 0.0000 5.7834
Apartments Mid
Rise
448.5 91.0415 5.3804 0.0000 225.5513
General Office
Building

41.85 8.4952 0.5021 0.0000 21.0464
High Turnover (Sit
Down Restaurant)
428.4 86.9613 5.1393 0.0000 215.4430
Hotel 27.38 5.5579 0.3285 0.0000 13.7694
Quality
Restaurant

7.3 1.4818 0.0876 0.0000 3.6712
Regional
Shopping Center

58.8 11.9359 0.7054 0.0000 29.5706
Total 207.8079 12.2811 0.0000 514.8354
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Page 42 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 127

8.2 Waste by Land Use
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
Apartments Low
Rise

11.5 2.3344 0.1380 0.0000 5.7834
Apartments Mid
Rise
448.5 91.0415 5.3804 0.0000 225.5513
General Office
Building

41.85 8.4952 0.5021 0.0000 21.0464
High Turnover (Sit
Down Restaurant)
428.4 86.9613 5.1393 0.0000 215.4430
Hotel 27.38 5.5579 0.3285 0.0000 13.7694
Quality
Restaurant

7.3 1.4818 0.0876 0.0000 3.6712
Regional
Shopping Center

58.8 11.9359 0.7054 0.0000 29.5706
Total 207.8079 12.2811 0.0000 514.8354
Mitigated

9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type

10.0 Stationary Equipment
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type CalEEMod Version: CalEEMod.2016.3.2 Page 43 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 128

11.0 Vegetation
Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment
Equipment Type Number
CalEEMod Version: CalEEMod.2016.3.2 Page 44 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 129

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population General Office Building 45.00 1000sqft 1.03 45,000.00 0 High Turnover (Sit Down Restaurant) 36.00 1000sqft 0.83 36,000.00 0 Hotel 50.00 Room 1.67 72,600.00 0
Quality Restaurant 8.00 1000sqft 0.18 8,000.00 0
Apartments Low Rise 25.00 Dwelling Unit 1.56 25,000.00 72 Apartments Mid Rise 975.00 Dwelling Unit 25.66 975,000.00 2789 Regional Shopping Center 56.00 1000sqft 1.29 56,000.00 0

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
9 Wind Speed (m/s) 2.2 Precipitation Freq (Days) 33

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company Southern California Edison
Operational Year 2028
CO2 Intensity
(lb/MWhr)
702.44 CH4 Intensity 0.029
(lb/MWhr)
N2O Intensity 0.006
(lb/MWhr)
Village South Specific Plan (Proposed)
Los Angeles-South Coast County, Summer
CalEEMod Version: CalEEMod.2016.3.2 Page 1 of 35 Date: 1/6/2021 1:54 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 130
Project Characteristics - Consistent with the DEIR's model.