Agenda — Alhambra City Council, January 24, 2022 (part 4 of 7)

DRAFT

City of Alhambra Public Review Draft Housing Element 243

Site ID AIN
Parcel
Size Address Zone Existing Use
Site
Size Category AB1397
Allowed
DUA
Max
Allowed
Capacity
Realistic
Capacity
Reuse
Potential
Score
Net
Capacity Affordability Level Lower Mod.

Above
Mod.

NV.426 5357003014 0.167 1516 S 8TH ST R-2 Residential - Single Family Residence 0.50 Nonvacant New No 18 9 90% High 3 Mod./Above Mod. 0 1 2 NV.426 5357003012 0.1668 1508 S 8TH ST R-2 Residential - Single Family Residence 0.50 Nonvacant New No 18 9 90% High 3 Mod./Above Mod. 0 1 2 NV.426 5357003013 0.1672 1512 S 8TH ST R-2 Residential - Single Family Residence 0.50 Nonvacant New No 18 9 90% High 3 Mod./Above Mod. 0 1 2 NV.427 5357003026 0.1678 1517 S 7TH ST R-2 Residential - Single Family Residence 0.17 Nonvacant New No 18 3 90% Strong 1 Above Mod. 0 0 1 NV.428 5357004006 0.1663 600 W VALLEY BLVD Valley Commercial - Auto, Recreation Equipment, Construction Equipment Sales and Service 0.42 Nonvacant New No 43 18 70% Medium 6 Mod./Above Mod. 0 2 4 NV.428 5357004005 0.1291 600 W VALLEY BLVD Valley Commercial - Parking Lot (Commercial Use Property) 0.42 Nonvacant New No 43 18 70% Medium 6 Mod./Above Mod. 0 2 4 NV.428 5357004004 0.1255 622 W VALLEY BLVD Valley Commercial - Professional Building 0.42 Nonvacant New No 43 18 70% Medium 6 Mod./Above Mod. 0 2 4 NV.429 5357004007 0.1775 1413 S 6TH ST R-2 Residential - Single Family Residence 0.18 Nonvacant New No 18 3 90% Strong 1 Above Mod. 0 0 1 NV.430 5357004014 0.1732 1511 S 6TH ST R-2 Residential - Single Family Residence 0.17 Nonvacant New No 18 3 90% Strong 1 Above Mod. 0 0 1 NV.431 5357006044 0.3958 400 W VALLEY BLVD Valley Commercial - Parking Lot (Commercial Use Property) 0.54 Nonvacant New No 43 23 90% High 17 Lower Mixed 11 2 4 NV.431 5357006014 0.1432 424 W VALLEY BLVD Valley Commercial - Auto, Recreation Equipment, Construction Equipment Sales and Service 0.54 Nonvacant New No 43 23 90% High 17 Lower Mixed 11 2 4 NV.432 5357006016 0.1098 448 W VALLEY BLVD Valley Commercial - Store 0.22 Nonvacant New No 24 5 90% Strong 5 Mod./Above Mod. 0 2 3 NV.432 5357006015 0.113 434 W VALLEY BLVD Valley Commercial - Auto, Recreation Equipment, Construction Equipment Sales and Service 0.22 Nonvacant New No 43 10 70% Strong 7 Mod./Above Mod. 0 2 5 NV.433 5357006018 0.1982 1521 S 4TH ST R-3 Residential - Single Family Residence 0.40 Nonvacant New No 34.4 14 70% High 7 Mod./Above Mod. 0 2 5 NV.433 5357006017 0.205 1525 S 4TH ST R-3 Residential - Single Family Residence 0.40 Nonvacant New No 34.4 14 70% High 7 Mod./Above Mod. 0 2 5 NV.434 5357008013 0.2089 1412 S 3RD ST R-3 Residential - Double, Duplex, or Two Units 0.60 Nonvacant New No 43 26 90% High 14 Lower Mixed 9 1 4 NV.434 5357008023 0.2063 1419 S 2ND ST R-3 Residential - Double, Duplex, or Two Units 0.60 Nonvacant New No 43 26 90% High 14 Lower Mixed 9 1 4 NV.434 5357008024 0.1859 1415 S 2ND ST R-3 Residential - Double, Duplex, or Two Units 0.60 Nonvacant New No 43 26 90% High 14 Lower Mixed 9 1 4 NV.435 5357009011 0.1999 1414 S 2ND ST Valley Commercial - Parking Lot (Commercial Use Property) 0.99 Nonvacant New No 43 43 90% High 27 Lower Mixed 17 3 7 NV.435 5357009010 0.1992 1418 S 2ND ST Valley Residential - Four Units (Any Combination) 0.99 Nonvacant New No 43 43 90% High 27 Lower Mixed 17 3 7 NV.436 5357010006 0.2018 1620 S 2ND ST R-2 Residential - Single Family Residence 0.81 Nonvacant New No 18 15 90% Strong 5 Mod./Above Mod. 0 2 3 NV.436 5357010023 0.3076 1616 S 2ND ST R-2 Residential - Single Family Residence 0.81 Nonvacant New No 18 15 90% Strong 5 Mod./Above Mod. 0 2 3 NV.436 5357010005 0.2974 1700 S 2ND ST R-2 Residential - Single Family Residence 0.81 Nonvacant New No 18 15 90% Strong 5 Mod./Above Mod. 0 2 3 NV.437 5357010021 0.2104 1617 S GARFIELD AVE, NO 1-5 PO Residential - Five or More Units or Apartments (Any Combination) 0.69 Nonvacant New No 43 30 90% Medium 10 Lower Mixed 7 1 2 NV.437 5357010014 0.2492 1627 S GARFIELD AVE PO Residential - Single Family Residence 0.69 Nonvacant New No 43 30 90% Medium 10 Lower Mixed 7 1 2 NV.437 5357010022 0.2274 1619 S GARFIELD AVE PO Residential - Single Family Residence 0.69 Nonvacant New No 43 30 90% Medium 10 Lower Mixed 7 1 2 NV.438 5357011004 0.2046 1628 S 3RD ST R-2 Residential - Single Family Residence 0.20 Nonvacant New No 18 4 90% High 1 Above Mod. 0 0 1 NV.439 5357011010 0.1889 1604 S 3RD ST R-2 Residential - Single Family Residence 0.72 Nonvacant New No 18 13 90% Strong 4 Mod./Above Mod. 0 1 3 NV.439 5357011019 0.3076 1601 S 2ND ST R-2 Residential - Double, Duplex, or Two Units 0.72 Nonvacant New No 18 13 90% Strong 4 Mod./Above Mod. 0 1 3 NV.439 5357011011 0.2192 1600 S 3RD ST R-2 Residential - Single Family Residence 0.72 Nonvacant New No 18 13 90% Strong 4 Mod./Above Mod. 0 1 3 NV.440 5357011013 0.2058 1715 S 2ND ST R-2 Residential - Single Family Residence 0.60 Nonvacant New No 18 11 90% Strong 4 Mod./Above Mod. 0 1 3 NV.440 5357011012 0.3924 1719 S 2ND ST R-2 Residential - Single Family Residence 0.60 Nonvacant New No 18 11 90% Strong 4 Mod./Above Mod. 0 1 3 NV.441 5357011025 0.2912 1609 S 2ND ST R-2 Residential - Single Family Residence 0.49 Nonvacant New No 18 9 90% High 3 Mod./Above Mod. 0 1 2 NV.441 5357011020 0.1989 1608 S 3RD ST R-2 Residential - Double, Duplex, or Two Units 0.49 Nonvacant New No 18 9 90% High 3 Mod./Above Mod. 0 1 2 NV.442 5357012005 0.1986 1704 S 4TH ST R-2 Residential - Single Family Residence 0.40 Nonvacant New No 18 7 90% High 2 Above Mod. 0 0 2 NV.442 5357012004 0.1999 1708 S 4TH ST R-2 Residential - Single Family Residence 0.40 Nonvacant New No 18 7 90% High 2 Above Mod. 0 0 2 NV.443 5357012014 0.2084 1715 S 3RD ST R-2 Residential - Single Family Residence 0.41 Nonvacant New No 18 7 90% High 2 Above Mod. 0 0 2 NV.443 5357012015 0.2053 1709 S 3RD ST R-2 Residential - Single Family Residence 0.41 Nonvacant New No 18 7 90% High 2 Above Mod. 0 0 2 NV.444 5357014021 0.1849 1617 S 5TH ST R-2 Residential - Single Family Residence 0.39 Nonvacant New No 18 7 90% High 2 Above Mod. 0 0 2 NV.444 5357014008 0.2039 1616 S 6TH ST R-2 Residential - Single Family Residence 0.39 Nonvacant New No 18 7 90% High 2 Above Mod. 0 0 2 NV.445 5357014012 0.1496 1600 S 6TH ST R-2 Residential - Single Family Residence 0.15 Nonvacant New No 18 3 90% High 1 Above Mod. 0 0 1 NV.446 5357017006 0.1966 1616 S 9TH ST R-2 Residential - Single Family Residence 0.59 Nonvacant New No 18 11 90% High 4 Mod./Above Mod. 0 1 3 NV.446 5357017004 0.2006 1608 S 9TH ST R-2 Residential - Single Family Residence 0.59 Nonvacant New No 18 11 90% High 4 Mod./Above Mod. 0 1 3 NV.446 5357017005 0.1953 1612 S 9TH ST R-2 Residential - Single Family Residence 0.59 Nonvacant New No 18 11 90% High 4 Mod./Above Mod. 0 1 3 NV.447 5357017009 0.195 1700 S 9TH ST R-2 Residential - Single Family Residence 0.58 Nonvacant New No 18 11 90% High 4 Mod./Above Mod. 0 1 3 NV.447 5357017011 0.1937 1708 S 9TH ST R-2 Residential - Single Family Residence 0.58 Nonvacant New No 18 11 90% High 4 Mod./Above Mod. 0 1 3 NV.447 5357017010 0.1962 1706 S 9TH ST R-2 Residential - Single Family Residence 0.58 Nonvacant New No 18 11 90% High 4 Mod./Above Mod. 0 1 3 NV.448 5357018030 0.1953 1709 S 9TH ST R-2 Residential - Single Family Residence 0.59 Nonvacant New No 18 11 90% High 4 Mod./Above Mod. 0 1 3 NV.448 5357018037 0.1936 1701 S 9TH ST R-2 Residential - Single Family Residence 0.59 Nonvacant New No 18 11 90% High 4 Mod./Above Mod. 0 1 3 NV.448 5357018009 0.1991 1705 S 9TH ST R-2 Residential - Single Family Residence 0.59 Nonvacant New No 18 11 90% High 4 Mod./Above Mod. 0 1 3 NV.449 5357019002 0.1402 1801 S 9TH ST R-2 Residential - Single Family Residence 0.14 Nonvacant New No 18 3 90% High 1 Above Mod. 0 0 1

Page 290 of 886 ends

DRAFT

City of Alhambra Public Review Draft Housing Element 244

Site ID AIN
Parcel
Size Address Zone Existing Use
Site
Size Category AB1397
Allowed
DUA
Max
Allowed
Capacity
Realistic
Capacity
Reuse
Potential
Score
Net
Capacity Affordability Level Lower Mod.

Above
Mod.

NV.450 5357019010 0.192 1833 S 9TH ST R-2 Residential - Single Family Residence 0.59 Nonvacant New No 18 11 90% Strong 4 Mod./Above Mod. 0 1 3 NV.450 5357019008 0.1969 1825 S 9TH ST R-2 Residential - Single Family Residence 0.59 Nonvacant New No 18 11 90% Strong 4 Mod./Above Mod. 0 1 3 NV.450 5357019009 0.1979 1829 S 9TH ST R-2 Residential - Single Family Residence 0.59 Nonvacant New No 18 11 90% Strong 4 Mod./Above Mod. 0 1 3 NV.451 5357020010 0.1938 1832 S 9TH ST R-2 Residential - Single Family Residence 0.59 Nonvacant New No 18 11 90% High 4 Mod./Above Mod. 0 1 3 NV.451 5357020011 0.1958 1836 S 9TH ST R-2 Residential - Single Family Residence 0.59 Nonvacant New No 18 11 90% High 4 Mod./Above Mod. 0 1 3 NV.451 5357020034 0.1972 N/A R-2 - 0.59 Nonvacant New No 18 11 90% High 4 Mod./Above Mod. 0 1 3 NV.452 5357023025 0.1218 1828 S 6TH ST R-2 Residential - Single Family Residence 0.50 Nonvacant New No 18 9 90% High 3 Mod./Above Mod. 0 1 2 NV.452 5357023006 0.1775 1820 S 6TH ST R-2 Residential - Single Family Residence 0.50 Nonvacant New No 18 9 90% High 3 Mod./Above Mod. 0 1 2 NV.452 5357023005 0.2009 1824 S 6TH ST R-2 Residential - Single Family Residence 0.50 Nonvacant New No 18 9 90% High 3 Mod./Above Mod. 0 1 2 NV.453 5357023011 0.1851 1800 S 6TH ST R-2 Residential - Single Family Residence 0.19 Nonvacant New No 18 3 90% High 1 Above Mod. 0 0 1 NV.454 5357023012 0.1712 1845 S 5TH ST R-2 Residential - Single Family Residence 0.52 Nonvacant New No 18 9 90% Strong 3 Mod./Above Mod. 0 1 2 NV.454 5357023014 0.1768 1837 S 5TH ST R-2 Residential - Single Family Residence 0.52 Nonvacant New No 18 9 90% Strong 3 Mod./Above Mod. 0 1 2 NV.454 5357023013 0.1757 1841 S 5TH ST R-2 Residential - Single Family Residence 0.52 Nonvacant New No 18 9 90% Strong 3 Mod./Above Mod. 0 1 2 NV.455 5357023021 0.175 1809 S 5TH ST R-2 Residential - Single Family Residence 0.17 Nonvacant New No 18 3 90% High 1 Above Mod. 0 0 1 NV.456 5357024010 0.1767 1832 S 5TH ST R-2 Residential - Single Family Residence 0.52 Nonvacant New No 18 9 90% Strong 3 Mod./Above Mod. 0 1 2 NV.456 5357024009 0.1741 1836 S 5TH ST R-2 Residential - Single Family Residence 0.52 Nonvacant New No 18 9 90% Strong 3 Mod./Above Mod. 0 1 2 NV.456 5357024011 0.173 1828 S 5TH ST R-2 Residential - Single Family Residence 0.52 Nonvacant New No 18 9 90% Strong 3 Mod./Above Mod. 0 1 2 NV.457 5357024030 0.1756 1812 S 5TH ST R-2 Residential - Single Family Residence 0.52 Nonvacant New No 18 9 90% Strong 3 Mod./Above Mod. 0 1 2 NV.457 5357024014 0.1731 1816 S 5TH ST R-2 Residential - Single Family Residence 0.52 Nonvacant New No 18 9 90% Strong 3 Mod./Above Mod. 0 1 2 NV.457 5357024031 0.1735 N/A R-2 - 0.52 Nonvacant New No 18 9 90% Strong 3 Mod./Above Mod. 0 1 2 NV.458 5357024017 0.1354 1804 S 5TH ST R-2 Residential - Single Family Residence 0.35 Nonvacant New No 18 6 90% Strong 2 Above Mod. 0 0 2 NV.458 5357024018 0.2101 1800 S 5TH ST R-2 Residential - Single Family Residence 0.35 Nonvacant New No 18 6 90% Strong 2 Above Mod. 0 0 2 NV.459 5357025005 0.1772 1844 S 4TH ST R-2 Residential - Single Family Residence 0.35 Nonvacant New No 18 6 90% Strong 2 Above Mod. 0 0 2 NV.459 5357025006 0.174 1840 S 4TH ST R-2 Residential - Single Family Residence 0.35 Nonvacant New No 18 6 90% Strong 2 Above Mod. 0 0 2 NV.460 5357025012 0.19 1816 S 4TH ST R-2 Residential - Single Family Residence 0.19 Nonvacant New No 18 3 90% High 1 Above Mod. 0 0 1 NV.461 5357025020 0.1751 1837 S 3RD ST R-2 Residential - Single Family Residence 0.18 Nonvacant New No 18 3 90% Strong 1 Above Mod. 0 0 1 NV.462 5357025026 0.1759 1813 S 3RD ST R-2 Residential - Single Family Residence 0.18 Nonvacant New No 18 3 90% High 1 Above Mod. 0 0 1 NV.463 5357025029 0.171 1801 S 3RD ST R-2 Residential - Single Family Residence 0.17 Nonvacant New No 18 3 90% Strong 1 Above Mod. 0 0 1 NV.464 5357026023 0.1733 1819 S 2ND ST R-2 Residential - Single Family Residence 0.17 Nonvacant New No 18 3 90% Strong 1 Above Mod. 0 0 1 NV.465 5359001018 0.1556 1528 S GARFIELD AVE Valley Commercial - Professional Building 0.61 Nonvacant New No 43 26 90% Medium 9 Lower Mixed 6 1 2 NV.465 5359001015 0.1555 1518 S GARFIELD AVE, APT 01-4 Valley Residential - Four Units (Any Combination) 0.61 Nonvacant New No 43 26 90% Medium 9 Lower Mixed 6 1 2 NV.465 5359001039 0.2997 1522 S GARFIELD AVE Valley Commercial - Office Building 0.61 Nonvacant New No 43 26 90% Medium 9 Lower Mixed 6 1 2 NV.466 5359001008 0.1552 1422 S GARFIELD AVE Valley Commercial - Parking Lot (Commercial Use Property) 0.37 Nonvacant New No 43 16 70% Strong 11 Mod./Above Mod. 0 3 8 NV.466 5359001042 0.2141 1416 S GARFIELD AVE Valley Commercial - Store Combination 0.37 Nonvacant New No 43 16 70% Strong 11 Mod./Above Mod. 0 3 8 NV.467 5359002002 0.1272 112 E VALLEY BLVD Valley Commercial - Auto, Recreation Equipment, Construction Equipment Sales and Service 0.48 Nonvacant New No 43 21 70% Strong 15 Mod./Above Mod. 0 4 11 NV.467 5359002001 0.2236 100 E VALLEY BLVD Valley Commercial - Auto, Recreation Equipment, Construction Equipment Sales and Service 0.48 Nonvacant New No 43 21 70% Strong 15 Mod./Above Mod. 0 4 11 NV.467 5359002003 0.1272 120 E VALLEY BLVD Valley Commercial - Auto, Recreation Equipment, Construction Equipment Sales and Service 0.48 Nonvacant New No 43 21 70% Strong 15 Mod./Above Mod. 0 4 11 NV.468 5359002004 0.0953 126 E VALLEY BLVD Valley Commercial - Store 0.38 Nonvacant New No 43 16 70% High 9 Mod./Above Mod. 0 3 6 NV.468 5359002006 0.1879 134 E VALLEY BLVD Valley Commercial - Store 0.38 Nonvacant New No 43 16 70% High 9 Mod./Above Mod. 0 3 6 NV.468 5359002005 0.0953 130 E VALLEY BLVD Valley Commercial - Store 0.38 Nonvacant New No 43 16 70% High 9 Mod./Above Mod. 0 3 6 NV.469 5359003034 0.2551 1415 S CHAPEL AVE Valley Commercial - Parking Lot (Commercial Use Property) 1.40 Nonvacant New No 43 60 90% Strong 54 Lower Mixed 34 7 13 NV.469 5359003032 0.73 204 E VALLEY BLVD Valley Commercial - Store 1.40 Nonvacant New No 43 60 90% Strong 54 Lower Mixed 34 7 13 NV.469 5359003033 0.2347 N/A Valley Commercial - Commercial 1.40 Nonvacant New No 43 60 90% Strong 54 Lower Mixed 34 7 13 NV.469 5359003031 0.1804 200 E VALLEY BLVD Valley Commercial - Auto, Recreation Equipment, Construction Equipment Sales and Service 1.40 Nonvacant New No 24 34 90% Strong 31 Mod./Above Mod. 0 8 23 NV.470 5359004023 0.2327 1423 S SIERRA VISTA AVE R-2 Residential - Single Family Residence 0.71 Nonvacant New No 18 13 90% Strong 5 Mod./Above Mod. 0 2 3 NV.470 5359004024 0.2292 1429 S SIERRA VISTA AVE R-2 Residential - Single Family Residence 0.71 Nonvacant New No 18 13 90% Strong 5 Mod./Above Mod. 0 2 3 NV.470 5359004022 0.2478 1419 S SIERRA VISTA AVE R-2 Residential - Single Family Residence 0.71 Nonvacant New No 18 13 90% Strong 5 Mod./Above Mod. 0 2 3 NV.471 5359004027 0.2314 1501 S SIERRA VISTA AVE R-2 Residential - Single Family Residence 0.69 Nonvacant New No 18 12 90% Strong 4 Mod./Above Mod. 0 1 3 NV.471 5359004025 0.2349 1431 S SIERRA VISTA AVE R-2 Residential - Single Family Residence 0.69 Nonvacant New No 18 12 90% Strong 4 Mod./Above Mod. 0 1 3 NV.471 5359004026 0.2245 1435 S SIERRA VISTA AVE R-2 Residential - Single Family Residence 0.69 Nonvacant New No 18 12 90% Strong 4 Mod./Above Mod. 0 1 3 NV.472 5359004030 0.2249 1513 S SIERRA VISTA AVE R-2 Residential - Single Family Residence 0.22 Nonvacant New No 18 4 90% Strong 1 Above Mod. 0 0 1 NV.473 5359005008 0.1961 1416 S SIERRA VISTA AVE R-2 Residential - Single Family Residence 0.39 Nonvacant New No 18 7 90% Strong 2 Above Mod. 0 0 2 NV.473 5359005009 0.191 1420 S SIERRA VISTA AVE R-2 Residential - Single Family Residence 0.39 Nonvacant New No 18 7 90% Strong 2 Above Mod. 0 0 2

Page 291 of 886 ends

DRAFT
City
of Alhambra Public Review Draft Housing Element 245
Site ID AIN
Parcel
Size Address Zone Existing Use
Site
Size Category AB1397
Allowed
DUA
Max
Allowed
Capacity
Realistic
Capacity
Reuse
Potential
Score
Net
Capacity Affordability Level Lower Mod.

Above
Mod.

NV.474 5359005010 0.197 1424 S SIERRA VISTA AVE R-2 Residential - Single Family Residence 0.38 Nonvacant New No 18 7 90% High 2 Above Mod. 0 0 2 NV.474 5359005011 0.1867 1428 S SIERRA VISTA AVE R-2 Residential - Single Family Residence 0.38 Nonvacant New No 18 7 90% High 2 Above Mod. 0 0 2 NV.475 5359005020 0.1881 1524 S SIERRA VISTA AVE R-2 Residential - Single Family Residence 0.39 Nonvacant New No 18 7 90% Strong 2 Above Mod. 0 0 2 NV.475 5359005019 0.198 1520 S SIERRA VISTA AVE R-2 Residential - Single Family Residence 0.39 Nonvacant New No 18 7 90% Strong 2 Above Mod. 0 0 2 NV.476 5359021005 0.1929 1616 S SIERRA VISTA AVE R-2 Residential - Single Family Residence 0.38 Nonvacant New No 18 7 90% Strong 2 Above Mod. 0 0 2 NV.476 5359021006 0.1893 1620 S SIERRA VISTA AVE R-2 Residential - Single Family Residence 0.38 Nonvacant New No 18 7 90% Strong 2 Above Mod. 0 0 2 NV.477 5359021028 0.2808 1713 S ALMANSOR ST R-2 Residential - Single Family Residence 0.57 Nonvacant New No 18 10 90% High 3 Mod./Above Mod. 0 1 2 NV.478 5359022011 0.1607 1605 S SIERRA VISTA AVE R-2 Residential - Single Family Residence 0.16 Nonvacant New No 18 3 90% High 1 Above Mod. 0 0 1 NV.479 5359025012 0.1562 1716 S GARFIELD AVE PO Residential - Three Units (Any Combination) 0.48 Nonvacant New No 43 21 70% High 8 Mod./Above Mod. 0 2 6 NV.479 5359025011 0.1553 1712 S GARFIELD AVE PO Residential - Double, Duplex, or Two Units 0.48 Nonvacant New No 43 21 70% High 8 Mod./Above Mod. 0 2 6 NV.479 5359025013 0.1665 1720 S GARFIELD AVE PO Residential - Double, Duplex, or Two Units 0.48 Nonvacant New No 43 21 70% High 8 Mod./Above Mod. 0 2 6 NV.480 5359028019 0.2297 1815 S SIERRA VISTA AVE R-2 Residential - Double, Duplex, or Two Units 0.69 Nonvacant New No 18 12 90% High 4 Mod./Above Mod. 0 1 3 NV.480 5359028021 0.2297 1821 S SIERRA VISTA AVE R-2 Residential - Single Family Residence 0.69 Nonvacant New No 18 12 90% High 4 Mod./Above Mod. 0 1 3 NV.480 5359028020 0.2297 1817 S SIERRA VISTA AVE R-2 Residential - Single Family Residence 0.69 Nonvacant New No 18 12 90% High 4 Mod./Above Mod. 0 1 3 NV.481 5359029002 0.1908 1804 S SIERRA VISTA AVE R-2 Residential - Single Family Residence 0.38 Nonvacant New No 18 7 90% High 2 Above Mod. 0 0 2 NV.481 5359029003 0.1901 1808 S SIERRA VISTA AVE R-2 Residential - Single Family Residence 0.38 Nonvacant New No 18 7 90% High 2 Above Mod. 0 0 2 NV.482 5359029004 0.1889 1812 S SIERRA VISTA AVE R-2 Residential - Single Family Residence 0.38 Nonvacant New No 18 7 90% Strong 2 Above Mod. 0 0 2 NV.482 5359029005 0.1915 1816 S SIERRA VISTA AVE R-2 Residential - Single Family Residence 0.38 Nonvacant New No 18 7 90% Strong 2 Above Mod. 0 0 2 NV.483 5359029010 0.1913 1836 S SIERRA VISTA AVE R-2 Residential - Single Family Residence 0.19 Nonvacant New No 18 3 90% Strong 1 Above Mod. 0 0 1 NV.484 5359029012 0.187 1844 S SIERRA VISTA AVE R-2 Residential - Single Family Residence 0.19 Nonvacant New No 18 3 90% High 1 Above Mod. 0 0 1 NV.485 5359005001 0.2004 400 E VALLEY BLVD Valley Commercial - Store 1.08 Nonvacant New No 43 46 90% High 33 Lower Mixed 21 4 8 NV.485 5359005041 0.7047 444 E VALLEY BLVD Valley Commercial - Bank, Savings and Loan 1.08 Nonvacant New No 43 46 90% High 33 Lower Mixed 21 4 8 NV.485 5359005002 0.1713 408 E VALLEY BLVD Valley Commercial - Store 1.08 Nonvacant New No 43 46 90% High 33 Lower Mixed 21 4 8 NV.486 5353019011 1.126 1621 GARVEY AVE R-2 Institutional - Children's Day Care Center 1.13 Nonvacant New No 18 20 90% High 9 Mod./Above Mod. 0 3 6 Nv.487 5337021021 0.4827 N/A R-3 Commercial - Parking Lot (Commercial Use Property) 1.20 Nonvacant New No 64 77 90% High 55 Lower Mixed 35 7 13 Nv.487 5337021020 0.7128 210 N GARFIELD AVE R-3 Commercial - Office Building 1.20 Nonvacant New No 64 77 90% High 55 Lower Mixed 35 7 13 Nv.488 5338020028 1.3445 21 N OLIVE AVE CPD Institutional - Church 1.34 Nonvacant New No 48 65 90% High 43 Lower Mixed 27 6 10 Nv.489 5292001015 0.2608 200 N HUNTINGTON DR R-2 Commercial - Supermarket 1.89 Nonvacant New No 43 81 90% High 36 Lower Mixed 23 5 8 Nv.489 5292001016 1.6276 2810 W ALHAMBRA RD R-2 Commercial - Supermarket 1.89 Nonvacant New No 43 81 90% High 36 Lower Mixed 23 5 8 Nv.490 5337025009 0.2416 N/A CBD Commercial - Parking Lot (Commercial Use Property) 2.29 Nonvacant New No 64 146 90% Strong 131 Lower Mixed 82 18 31 Nv.490 5337025008 0.9656 N/A CBD Commercial Building 2.29 Nonvacant New No 64 146 90% Strong 131 Lower Mixed 82 18 31 Nv.490 5337026025 0.6766 N/A CBD Commercial - Parking Lot (Commercial Use Property) 2.29 Nonvacant New No 64 146 90% Strong 131 Lower Mixed 82 18 31 Nv.490 5337026026 0.3133 N/A CBD Commercial - Parking Lot (Commercial Use Property) 2.29 Nonvacant New No 64 146 90% Strong 131 Lower Mixed 82 18 31 Nv.490 5337026909 0.0896 N/A CBD Commercial - Parking Lot (Commercial Use Property) 2.29 Nonvacant New No 64 146 90% Strong 131 Lower Mixed 82 18 31 Nv.491 5350007002 0.5054 N/A Valley Commercial - Parking Lot (Commercial Use Property) 0.51 Nonvacant New No 43 22 90% Strong 20 Lower Mixed 13 2 5 Nv.492 5342031040 0.1014 N/A IPD Industrial - Parking Lot (Industrial Use Property) 4.31 Nonvacant New No 43 185 90% Strong 167 Lower Mixed 104 23 40 Nv.492 5342031038 0.3847 1021 S FREMONT AVE IPD Industrial - Light Manufacturing 4.31 Nonvacant New No 43 185 90% Strong 167 Lower Mixed 104 23 40 Nv.492 5342031041 0.3112 1031 S FREMONT AVE IPD Industrial - Light Manufacturing 4.31 Nonvacant New No 43 185 90% Strong 167 Lower Mixed 104 23 40 Nv.492 5342031039 0.8018 1105 S FREMONT AVE IPD Industrial - Light Manufacturing 4.31 Nonvacant New No 43 185 90% Strong 167 Lower Mixed 104 23 40 Nv.492 5342031004 0.8733 1003 S FREMONT AVE IPD Industrial - Light Manufacturing 4.31 Nonvacant New No 43 185 90% Strong 167 Lower Mixed 104 23 40 Nv.492 5342032007 0.4871 1109 S FREMONT AVE IPD Industrial - Light Manufacturing 4.31 Nonvacant New No 43 185 90% Strong 167 Lower Mixed 104 23 40 Nv.492 5342032008 0.483 1111 S FREMONT AVE IPD Industrial - Light Manufacturing 4.31 Nonvacant New No 43 185 90% Strong 167 Lower Mixed 104 23 40 Nv.492 5342031042 0.8668 1011 S FREMONT AVE IPD Industrial - Light Manufacturing 4.31 Nonvacant New No 43 185 90% Strong 167 Lower Mixed 104 23 40 Nv.493 5349001022 8.1912 1495 E VALLEY BLVD Valley Commercial - Shopping Center (Neighborhood, Community) 8.19 Nonvacant New No 43 352 90% Medium 158 Lower Mixed 98 22 38

Page 292 of 886 ends

DRAFT
City
of Alhambra Public Review Draft Housing Element 246
Site ID AIN
Parcel
Size Address Zone Existing Use
Site
Size Category AB1397
Allowed
DUA
Max
Allowed
Capacity
Realistic
Capacity
Reuse
Potential
Score
Net
Capacity Affordability Level Lower Mod.

Above
Mod.

Nv.494 5359006016 0.8473 1000 E VALLEY BLVD Valley Commercial - Shopping Center (Regional) 15.97 Nonvacant New No 43 687 90% Medium 308 Lower Mixed 191 43 74 Nv.494 5359006037 1.6748 600 E VALLEY BLVD Valley Commercial - Store 15.97 Nonvacant New No 43 687 90% Medium 308 Lower Mixed 191 43 74 Nv.494 5359006039 0.2833 726 E VALLEY BLVD Valley Commercial - Shopping Center (Neighborhood, Community) 15.97 Nonvacant New No 43 687 90% Medium 308 Lower Mixed 191 43 74 Nv.494 5359006038 0.3587 748 E VALLEY BLVD Valley Commercial - Shopping Center (Regional) 15.97 Nonvacant New No 43 687 90% Medium 308 Lower Mixed 191 43 74 Nv.494 5359006011 3.5918 1000 E VALLEY BLVD Valley Commercial - Shopping Center (Regional) 15.97 Nonvacant New No 43 687 90% Medium 308 Lower Mixed 191 43 74 Nv.494 5359006017 0.093 N/A Valley Commercial - Shopping Center (Regional) 15.97 Nonvacant New No 43 687 90% Medium 308 Lower Mixed 191 43 74 Nv.494 5359006018 0.4318 920 E VALLEY BLVD Valley Commercial - Shopping Center (Regional) 15.97 Nonvacant New No 43 687 90% Medium 308 Lower Mixed 191 43 74 Nv.494 5359006019 0.6635 830 E VALLEY BLVD Valley Commercial - Shopping Center (Regional) 15.97 Nonvacant New No 43 687 90% Medium 308 Lower Mixed 191 43 74 Nv.494 5359006020 0.6281 800 E VALLEY BLVD Valley Commercial - Shopping Center (Regional) 15.97 Nonvacant New No 43 687 90% Medium 308 Lower Mixed 191 43 74 Nv.494 5359006027 0.3625 1020 E VALLEY BLVD Valley Commercial - Shopping Center (Regional) 15.97 Nonvacant New No 43 687 90% Medium 308 Lower Mixed 191 43 74 Nv.494 5359006045 6.6016 N/A Valley Commercial - Parking Lot (Commercial Use Property) 15.97 Nonvacant New No 43 687 90% Medium 308 Lower Mixed 191 43 74 Nv.494 5359006021 0.0939 N/A Valley Commercial - Shopping Center (Regional) 15.97 Nonvacant New No 43 687 90% Medium 308 Lower Mixed 191 43 74 Nv.494 5359006025 0.115 N/A Valley Commercial - Shopping Center (Regional) 15.97 Nonvacant New No 43 687 90% Medium 308 Lower Mixed 191 43 74 Nv.494 5359006026 0.2259 N/A Valley Commercial - Shopping Center (Regional) 15.97 Nonvacant New No 43 687 90% Medium 308 Lower Mixed 191 43 74 Nv.495 5342005026 4.8811 2400 W COMMONWEALTH AVE CPD Commercial - Supermarket 14.11 Nonvacant New No 48 677 90% Medium 304 Lower Mixed 189 42 73 Nv.495 5342005028 0.6255 2528 W COMMONWEALTH AVE CPD Commercial - Restaurant, Cocktail Lounge 14.11 Nonvacant New No 48 677 90% Medium 304 Lower Mixed 189 42 73 Nv.495 5342005027 0.6436 2588 W COMMONWEALTH AVE CPD Commercial - Restaurant, Cocktail Lounge 14.11 Nonvacant New No 48 677 90% Medium 304 Lower Mixed 189 42 73 Nv.495 5342005030 5.6482 N/A CPD Commercial - Shopping Center (Regional) 14.11 Nonvacant New No 48 677 90% Medium 304 Lower Mixed 189 42 73 Nv.495 5342010031 2.3138 N/A CPD Commercial - Shopping Center (Regional) 14.11 Nonvacant New No 48 677 90% Medium 304 Lower Mixed 189 42 73 Nv.496 5338035007 0.1761 115 N 3RD ST R-3 Residential - Single Family Residence 0.18 Nonvacant New No 64 11 70% Strong 7 Mod./Above Mod. 0 2 5 Nv.497 5338035011 0.1726 29 N 3RD ST R-3 Residential - Four Units (Any Combination) 0.17 Nonvacant New No 64 11 70% Medium 2 Mod./Above Mod. 0 1 1 Nv.498 5345009022 0.5811 507 S STONEMAN AVE PO Commercial - Non-Auto Service and Repair Shop, Paint Shop, or Laundry 0.58 Nonvacant New No 43 25 90% High 18 Lower Mixed 12 2 4 Nv.499 5347017002 0.2484 745 S CHAPEL AVE R-3 Residential - Four Units (Any Combination) 0.25 Nonvacant New No 43 11 70% Strong 5 Mod./Above Mod. 0 2 3 Nv.500 5347022032 0.2066 823 S SIERRA VISTA AVE R-3 Residential - Single Family Residence 0.21 Nonvacant New No 43 9 70% Strong 6 Mod./Above Mod. 0 2 4 Nv.501 5347026006 0.2065 808 S SIERRA VISTA AVE R-3 Residential - Single Family Residence 0.21 Nonvacant New No 43 9 70% Strong 6 Mod./Above Mod. 0 2 4 Nv.502 5347026011 0.2159 820 S SIERRA VISTA AVE R-3 Residential - Double, Duplex, or Two Units 0.22 Nonvacant New No 43 9 70% High 4 Mod./Above Mod. 0 1 3 Nv.503 5336021041 0.2165 25 N GRANADA AVE EMC Commercial - Auto, Recreation Equipment, Construction Equipment Sales and Service 2.43 Nonvacant New No 30 73 90% Strong 59 Lower Mixed 37 8 14 Nv.503 5336021040 0.2189 21 N GRANADA AVE EMC Commercial - Parking Lot (Commercial Use Property) 2.43 Nonvacant New No 30 73 90% Strong 59 Lower Mixed 37 8 14 Nv.503 5336021023 0.0581 801 E MAIN ST, REAR EMC Commercial - Auto, Recreation Equipment, Construction Equipment Sales and Service 2.43 Nonvacant New No 30 73 90% Strong 59 Lower Mixed 37 8 14 Nv.503 5336021039 0.3461 17 N GRANADA AVE EMC Commercial - Auto, Recreation Equipment, Construction Equipment Sales and Service 2.43 Nonvacant New No 30 73 90% Strong 59 Lower Mixed 37 8 14 Nv.503 5336021038 0.4259 807 E MAIN ST EMC Commercial - Auto, Recreation Equipment, Construction Equipment Sales and Service 2.43 Nonvacant New No 30 73 90% Strong 59 Lower Mixed 37 8 14 Nv.503 5336021027 0.173 817 E MAIN ST EMC Commercial - Auto, Recreation Equipment, Construction Equipment Sales and Service 2.43 Nonvacant New No 30 73 90% Strong 59 Lower Mixed 37 8 14 Nv.503 5336021028 0.6528 801 E MAIN ST EMC Commercial - Auto, Recreation Equipment, Construction Equipment Sales and Service 2.43 Nonvacant New No 30 73 90% Strong 59 Lower Mixed 37 8 14 Nv.503 5336021026 0.3428 835 E MAIN ST EMC Commercial - Auto, Recreation Equipment, Construction Equipment Sales and Service 2.43 Nonvacant New No 30 73 90% Strong 59 Lower Mixed 37 8 14 Nv.504 5336023053 0.1287 645 E MAIN ST EMC Commercial - Restaurant, Cocktail Lounge 0.43 Nonvacant New No 30 13 90% Strong 11 Mod./Above Mod. 0 3 8 Nv.504 5336023007 0.2785 625 E MAIN ST EMC Commercial - Office Building 0.43 Nonvacant New No 30 13 90% Strong 11 Mod./Above Mod. 0 3 8 Nv.504 5336023009 0.0181 N/A EMC Commercial - Parking Lot (Commercial Use Property) 0.43 Nonvacant New No 30 13 90% Strong 11 Mod./Above Mod. 0 3 8 Nv.505 5336023035 0.4653 18 N ALMANSOR ST EMC Commercial - Parking Lot (Commercial Use Property) 0.47 Nonvacant New No 30 14 90% Strong 13 Mod./Above Mod. 0 4 9 Nv.506 5345023027 1.4673 726 E MAIN ST EMC Commercial - Auto, Recreation Equipment, Construction Equipment Sales and Service 1.81 Nonvacant New No 30 54 90% Medium 24 Lower Mixed 15 3 6 Nv.506 5345023012 0.1722 17 S CORDOVA ST EMC Commercial - Parking Lot (Commercial Use Property) 1.81 Nonvacant New No 30 54 90% Medium 24 Lower Mixed 15 3 6 Nv.506 5345023013 0.1722 21 S CORDOVA ST EMC Residential - Single Family Residence 1.81 Nonvacant New No 30 54 90% Medium 24 Lower Mixed 15 3 6 Nv.507 5345022021 0.5441 7 S HIDALGO AVE EMC Commercial - Store Combination 0.54 Nonvacant New No 30 16 90% Strong 14 Lower Mixed 9 1 4 Nv.508 5345016014 0.3444 21 S ALMANSOR ST EMC Commercial - Parking Lot (Commercial Use Property) 1.30 Nonvacant New No 30 39 90% Medium 18 Lower Mixed 12 2 4 Nv.508 5345016004 0.959 512 E MAIN ST EMC Institutional - Cemetery, Mausoleum, Mortuary 1.30 Nonvacant New No 30 39 90% Medium 18 Lower Mixed 12 2 4 Nv.509 5345015016 0.2107 360 E MAIN ST EMC Commercial - Restaurant, Cocktail Lounge 2.43 Nonvacant New No 30 73 90% Strong 66 Lower Mixed 41 9 16 Nv.509 5345015071 0.7078 300 E MAIN ST EMC Commercial - Bank, Savings and Loan 2.43 Nonvacant New No 30 73 90% Strong 66 Lower Mixed 41 9 16 Nv.509 5345015008 0.2226 22 S CHAPEL AVE EMC Commercial - Office Building 2.43 Nonvacant New No 30 73 90% Strong 66 Lower Mixed 41 9 16 Nv.509 5345015009 0.2263 16 S CHAPEL AVE EMC Commercial - Parking Lot (Commercial Use Property) 2.43 Nonvacant New No 30 73 90% Strong 66 Lower Mixed 41 9 16 Nv.509 5345015010 0.8812 14 S CHAPEL AVE EMC Commercial - Parking Lot (Commercial Use Property) 2.43 Nonvacant New No 30 73 90% Strong 66 Lower Mixed 41 9 16 Nv.509 5345015901 0.1824 N/A EMC Commercial - Parking Lot (Commercial Use Property) 2.43 Nonvacant New No 30 73 90% Strong 66 Lower Mixed 41 9 16

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ATTACHMENT 7
Events & Milestones
The f
ollowing provides a timeline summarizing events and major milestones in preparing Alhambra’s draft 2021-2029 Housing Element Update:
• Cit
y Council Presentation (October 10, 2020): The City Council was provided with a presentation by ECONorthwest that included an overview of the project, including State mandates and the Regional Housing Needs Assessment (RHNA) process. • Planning Commission Presentation (October 19, 2020): The Planning Commission was provided with the presentation shared with the City Council at their October 10, 2021, meeting.
• RHNA Appeal Filed by the City (October 26, 2021): The City of Alhambra submitted a formal appeal with the Southern California Association of Governments (SCAG) requesting the RHNA appeals board consider a reduction in the number of residential units allocated to the City of Alhambra during the 6th Cycle (2021-2029). • RHNA Appeals Board Hearing (January 11, 2021): The Southern California Association of Governments RHNA Appeals Board considered the City’s formal appeal and denied the City’s request to reduce the number of residential units allocated to Alhambra during the 6 th Cycle (2021-2029).
• Community Meeting #1 (February 17, 2021): The first virtual community meeting took place on February 17, 2021. Public notice of the meeting was advertised on social media, in the Around Alhambra (on the upper half of the front page), Chamber of Commerce email blast and social media, and verbal announcements at Planning Commission meetings.

The project website and direct email also provided notice of the meeting in English, Spanish and Traditional Chinese. The workshop was formatted to help educate the public about the Housing Element, RHNA process, and inform the community on how they can get involved and provide feedback. The presentation incorporated an interactive live survey designed to help gain input on various aspects related to housing and to gauge the community’s appetite and willingness to consider alternatives to help meet our RHNA. • Availability of an Online Survey (February 18- March 12, 2021): For those unable to attend the community meeting on February 17, 2021, presentation materials were made available on the project website and the survey was made available through March 12, 2021, to allow for additional community input. The online survey was made available in English, Spanish, and Traditional Chinese.
• City Council Town Hall Meetings (April 2021): During the month of April, the Mayor and City Council members each hosted virtual Town Hall events to discuss the Housing Element project with presentations including an overview of the RHNA and discussion of potential housing strategies for community input. Town Hall meetings were held on April 6, 8, 10, and 15, 2021.
• Planning Commission Presentation (May 3, 2021): The Planning Commission was provided with a presentation that had a strong focus on RHNA and was presented an analysis of various options available to the City for working towards RHNA compliance for the 2021 -2029 Housing Element. The meeting was intended to solicit input from the

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Planning Commission as the Consultant and City staff began drafting the Draft Housing Element. The Planning Commission provided good feedback and took action to receive and file the informational report with no additional recommendations added or to delete any of the strategies presented. After this meeting, ECONorthwest, in conjunction with staff, refined strategies presented and continued to look at additional strategies to ensure the City will meet its RHNA target.
• City Council Presentation (August 9, 2021): The City Council was provided with a presentation about the status of the City’s 2021- 2029 Housing Element update.

ECONorthwest shared an overview of outreach done to date, a schedule moving forward, a synopsis of what was heard from the community and stakeholders, and the approach to meeting the City’s RHNA allocation target. A good discussion ensued about the process and the various components of the Draft Housing Element which was anticipated to be released later in the month.
• Release of the Draft Housing Element for Public Review (August 26, 2021): The Draft Housing Element was released for public review on August 26, 2021, with the public comment period concluding on September 26, 2021. Public notice regarding the release of the Draft Housing Element was provided on social media, in the Around Alhambra, and verbal announcements at Planning Commission and Chamber of Commerce meetings.

The project website and direct email also informed the community in English, Spanish, and Traditional Chinese about the release of the Draft Housing Element for public review.

The Draft document was made available on project website, at City Hall and the Civ ic Center Library.
• Community Meeting #2 (September 8, 2021): A virtual community meeting was held to inform the public with the status of the project and continue to update the community about the Housing Element process, key dates, and state requirement s. Public notice of the meeting was advertised on social media, in the Around Alhambra, and verbal announcements at Planning Commission meetings. The project website and direct email also provided notice of the meeting in English, Spanish and Traditional C hinese. Given that the City was in the midst of the official public comment period for the Housing Element, the focus of the community meeting was on providing an overview of the chapters contained in the Draft Housing Element and highlighting key aspects of each chapter to help the public understand the document as they reviewed it and submitted public comment. Information was also shared on how to provide feedback during the public review period before concluding on September 26, 2021.
• City Council Presentation (September 13, 2021) : The City Council was provided with an update and overview of the status of the Housing Element, particularly focusing on feedback received at the second community meeting held on September 8, 2021. At this meeting, the City Council requested an additional update after a meeting with the Planning Commission on September 20, 2021 and before submitting the Draft Housing Element to HCD.
• Planning Commission Presentation (September 20 2021): ECONorthwest provided the Planning Commission with a presentation and facilitated an in-depth discussion on the components of the Draft Housing Element. After comments from the public and discussion and feedback by the Commissioners, the Planning Commission recommended to the City Council that they direct staff to submit the Draft Housing Element to the HCD to begin their formal sixty (60) day review of the document.
• End of the Official Public Review Comment Period for the Draft Housing Element (September 26, 2021): The Draft Housing Element was made available for a 32- day

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public review comment period extending from August 26 to September 26, 2021. During this time, a total of 28 letters and emails were received and are included in Attachment 3d.
• Cit
y Council Presentation (September 27, 2021): ECONorthwest provided the City Council a presentation and facilitated an in- depth discussion on the components of the Draft Housing Element. After comments from the public and discussion and feedback by the councilmembers, the City Council directed staff to submit the Draft Housing Element to the HCD to begin their format (60) day review of the document. • Document Submittal to HCD (October 5, 2021): Based on the City Council’s direction on September 27, 2021, the 2021-2029 Draft Housing Element was submitted to HCD on Tuesday, October 5. HCD acknowledged receipt of the document and began its official 60-day review period.
• Response from HCD (December 2, 2021): On December 3, 2021, staff received a letter from HCD dated December 2, 2021 (Attachment 3a) identifying results of their review of Alhambra’s Draft Housing Element. The letter addresses many statutory requirements, and areas that need modification prior to resubmittal to HCD. Comments from HCD and responses to their comments are discussed in more detail in the “Comments from HCD” section of this report and was the sole focus of discussion at the January 3, 2022, Planning Commission meeting.
• Planning Commission Public Hearing (January 3, 2022): On January 3, 2022, the Planning Commission held a public hearing on the 2021- 2029 Draft Housing Element.

ECONorthwest provided the Planning Commission with an in- depth presentation regarding the content contained in a letter from HCD in response to their review of the City’s Draft Hou sing Element submitted on October 5, 2021. The presentation also explained how each of HCD’s comments has been addressed and how the changes are reflected in the revised Draft. There were a total of 3 speakers for this item and 3 comment letters read into the record. Once the public hearing was closed, the Planning Commission approved a resolution recommending the City Council adopt the 2021- 2029 Housing Element and Negative Declaration, and direct staff to submit the Housing Element to HCD.

The Planning Commission adopted a resolution with the following additional recommendations:

1. The addi
tion of a new program to the Housing Plan to specifically address Special Housing Needs. This program will direct the City to continue to develop internal policies and coordinate with housing providers to address special housing needs for persons with disabilities, seniors, large families, single-parent households, and extremely low income households. The program will include amendments to the zoning code that are required by state law to remove barriers to developing housing for households with special needs. It also recommends the continuation of the City’s Homeless Outreach Services Program and an update to the City’s Reasonable Accommodations Ordinance that is already under consideration.

2. Based on additional analysis requested by HCD, it is recommended the City expand on meaningful actions in its programs to Affirmatively Further Fair Housing.

Actions in these programs address strengthening community education and access to public participation, actions to improve housing mobility and access to opportunity, and actions to mitigate displacement risk as a result of economic and market pressures.

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ATTACHMENT 8
Comm
unity Outreach
The pr
oject commenced in 2020 during the first year of the COVID -19 pandemic which posed a challenge to the way traditional community outreach is conducted. Due to the COVID -19 state- wide Safer At Home mandate issued by C alifornia’s G overnor, community outreach had to prioritize strategies for meaningful public input within a virtual online environment, instead of in- person meetings. Diligent efforts were made to notify City residents, the business community, and various organizations about the project and to solicit input via print, direct email, social media, and verbal announcements at meetings. Diligent effort was also made to provide translated materials in English, Spanish and Traditional Chinese. Additional information regarding outreach is identified on the following page.

Publi
c Comment
Over
the course of the project and at the time this report was finalized, the City received a total of 51 written comment letters/emails commenting on various aspects of the Housing Element. Of the total 50 comment letters, 19 were submitted during the official public review comment period on the Draft Housing Element that took place from August 26, 2021 to September 26, 2021. The remaining 29 comment letters were provided either prior to or after the comment period. An additional 3 letters were read into the record at the January 3, 2022 Planning Commission meeting. Based on comments received, the City learned that (1) preserving single family neighborhoods and affordable housing is of importance; (2) there is mixed support and concern about housing developments on East Main Street; (3) there is preference for development in the downtown area and along corridors; (4) there is community support for ADU’s; (5) there is mixed- support for solutions that add housing to new areas or upzone existing zones; and (6) there is a desire to support development on City -owned sites. Attachments 9 and 10 provide the public comment letters received over the course of the project.

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Community Outreach: 2021-2029 Housing Element Update
• Project Website. The City established a new, dedicated project website that went live in October 2020 ( alhambrahousingelement.com). The goal of the website is to serve as a resource to the community and provide information about the Housing Element process, timeline, public participation opportunities, and repository for documents and videos of past meetings and events. The website also incorporates a fillable form to allow individuals to conveniently submit feedback directly through the website. • City Website . Information was shared on the City’s website throughout the project, including the use of a front page banner, and announcement of 5 City Council Town Hall meetings on the website’s main page. A direct link on the City’s website redirects readers to the dedicated project website.
• City Newsletter. The City publishes a monthly newsletter that is directly emailed to interested parties and posted on the City’s website. Information was shared in 2 monthly issues.
• Direct Email. When the Housing Element update began, the City created a dedicated email address ([email protected]) for the project. This would allow the public to be notified about the Housing Element Update and provide a convenient way for the public to submit written commen ts under an email address that would be easily recognizable. Staff designed and sent a total of 2 2 direct email blasts to interested parties that were sent in English, Spanish, and Traditional Chinese. Over the course of the project, the email list has grown to 348 interested parties, all of which were also notified in English, Spanish, and Traditional Chinese about the January 3, 2022 Planning Commission Public Hearing.
• Social Media. Staff utilized the City’s social media platforms to help disseminate information to the public about the Housing Element update and directed people to the dedicated project website for further information. Since November 2020, there were a total of 86 posts shared across the City’s Facebook, Twitter, and Instagram social media accounts, as well as the Nextdoor App. From December 2020 to December 2001, the City saw the number of followers grow across all accounts which helped to provide greater outreach to the public. Over the course of this last year, the City’s Twitter followers grew from 3,142 to 3,391, Facebook followers grew from 4,425 to 5,100, and Instagram followers grew from 4,563 to 6,349.
• Leisure Guide. The C ity of Alhambra’s Parks and Recreation Department publis hes a Leisure Guide that is distributed by direct mail to 31,000 households. The Winter/Spring 2020/2021 Leisure Guide included an advertisement on Page 3 to inform residents about the project.

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• Verbal Announcements. A total of 8 verbal project updates throughout the project were provided at Planning Commission meetings under the “Director’s Report” portion of the agenda.
• Public Notices. A notice of public hearing for the January 3, 2022 Planning Commission meeting was published in the Pasadena Star Newspaper on December 17, 2021.

In c
ollaboration with the City, the Alhambra Chamber of Commerce also shared information about the Housing Element in the following ways:
• Around Alhambra. Articles were published in the December 2020, February 2021 (front page news), May 2021, and September 1, 2021, issues. The Mayor’s Corner in the May 2021 issue also provided information discussing the RHNA and City Council Town Hall meetings scheduled to discuss the Housing Element and housing in Alhambra. The Around Alhambra has a circulation of 40,000 and is mail carrier, route delivered to every business and residence in the City of Alhambra. It is also provided to local, state and county officials and available at various news racks in the City.
• Direct Email. A total of 5 direct emails were sen t to their membership list comprised of 900 individuals/businesses.
• Social Media. There were 11 posts across the Chamber of Commerce Instagram and Facebook social media sites.
• Meeting Announcements. There were 2 announcements made at 2 separate meetings hosted by the Chamber of Commerce to inform attendees about the February 17, 2021, community meeting.

In addition to the outreach performed by staff, other news sources picked up on the information distributed by the City and voluntarily augmented the City’s efforts by sharing the news about the Housing Element update with their readers and followers. The information below provides information on how other organizations helped distribute information:
• San
Gabriel Valley Economic Partnership . Direct email sent in April 2021 to their members announcing “Alhambra Hosts Housing Town Hall Series”. • Old Town Alhambra (Facebook). On April 9, 2021 and April 10, 2021, posts were shared about an upcoming Town Hall meeting. A post in Spanish was also shared on September 9, 2021, to inform readers about the Draft Housing Element being available for public review. At the time of posting, the Facebook page had 636 followers. • Informed Alhambra (Facebook). On March 29, 2021 and April 5, 2021, posts were shared about upcoming Town Hall meetings to discuss the Housing Element and RHNA.

At the time of posting, the Facebook page had 537 followers. • ColoradoBlvd.Net. Advertisements were published on April 6, 2021 and April 7, 2021 sharing information on 2 of the 5 City Council Town Hall meetings regarding the Housing Element and RHNA.

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1 Reynoso, Vanessa
From: ADAM Bray-Ali <[email protected]> Sent: Thursday, August 26, 2021 12:56 PM
To: Housing Element
Subject: [Alhambra HE] Draft Housing Element Comments - new submission CAUTION: This email originated from outside your organization. ???
ADAM Bray-Ali just submitted your form: Dra ft Housing Element Comments on Alhambra HE

Message Details:

First Name: ADAM
Last Name: Bray-Ali
Email: Adam@propertybyadamcom
Enter your comments on the Draft Housing Element here. (1,000 characters): On Page 104, there is a reference to the Howard Street property that the city developed. It appears that the property address is incorrect. there is no 534 Howard but there is a 536 Howard and a 538 Howard. Each address has 4 units inside. Can you provide more clairity on when those were sold, who was
permitted to buy them and what

restrictions may exist to keep these as affordable in the future? ???

If you think this submission is spam, report it as spam .

???

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To help protect your privacy, Microsoft Office prevented automa tic download of this picture from the Internet. ???
ATTACHMENT 9

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1 Reynoso, Vanessa
From: ADAM Bray-Ali <[email protected]> Sent: Thursday, August 26, 2021 12:57 PM
To: Housing Element
Subject: [Alhambra HE] Draft Housing Element Comments - new submission CAUTION: This email originated from outside your organization. ???
ADAM Bray-Ali just submitted your form: Dra ft Housing Element Comments on Alhambra HE

Message Details:

First Name: ADAM
Last Name: Bray-Ali
Email:

Adam@propertybyadamcom
Enter your comments on the Draft Housing Element here. (1,000 c
haracters): On Page 104, there are several projects in
proposal/undertaking stages that do not appear to be held to any particular schedule or timeline. Can more information be provided and improved grammar be used for the last bullet point? Who is Related California, what APN/
Parcel on Chapel is being proposed, what timeline

is ex
pected?
???

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1 Reynoso, Vanessa
From: ADAM Bray-Ali <[email protected]> Sent: Thursday, August 26, 2021 1:35 PM
To: Housing Element
Subject: [Alhambra HE] Draft Housing Element Comments - new submission CAUTION: This email originated from outside your organization. ???
ADAM Bray-Ali just submitted your form: Dra ft Housing Element Comments on Alhambra HE

Message Details:

First Name: ADAM
Last Name: Bray-Ali
Email:

Adam@propertybyadamcom
Enter your comments on the Draft Housing Element here. (1,000 c
haracters): On page 128, there is a description of the down payment assistance program. From discussions with city staff, there was zero funding for this program in 2021 and I was told that there was only one grant per year for the entire city available in p
rior years. The details of
this program are not easy to find and there does not appear to be any

accountability for this.
???

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From: Kimberly Thacker
To: Housing Element
Subject: Draft housing
Date: Saturday, August 28, 2021 2:13:58 PM
CAUTION: This email originated from outside your organization.

Considering Alhambra's population has a large number of elderly 65+, multigenerational housholds, the 65+ as low income, and the cost of housing raising above the means of so many...

I think it makes sense that Alhambra continue to streamline the ADU process and
ADD funding loans help residents pursue ADUs. There is still no Federal or State loans that assist homeowners, only HELOC and HELoan, Credit Card Laons or Bank Construction loans...all of which DO NOT make the process affordable.

Alhambra should create its own ADU loan program so that so homeowners can affordable build ADUs.

Sent from ProtonMail mobile

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1 Reynoso, Vanessa
From: David Bond <[email protected]>
Sent: Wednesday, September 8, 2021 7:26 PM
To: Housing Element
Subject: [Alhambra HE] Draft Housing Element Comments - new submission CAUTION: This email originated from outside your organization. ???
David Bond just submitted your form: Draft Housing Element Comments on Alhambra HE

Message Details:

First Name: David
Last Name: Bond
Email: djb85511@gmailcom
Enter your comments on the Draft Housing Element here. (1,000 characters): After review of the Housing Element, and discussing the draft with ECONorthWest during the Community Meeting, there were no constraints for the city, working with the state and federal government, to provide public owned and managed housing, however there is no action recommending public housing in this element. The profit motive, the extra regulatory efforts, and the funding efforts are all costs for affordable development described by ECONW. If these can all be mitigated by the public housing option, and the fear is that affordable housing unit availability isn't likely to be met, then why don't we include

public housing in this element?
???

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1 Reynoso, Vanessa
From: Brandon Young <[email protected]>
Sent: Wednesday, September 8, 2021 4:10 PM
To: Housing Element
Cc: Mitchell Tsai; Greg Sonstein; Cindy Pain
Subject: SWRCC - [City of Alhambra, 6th Cycle Housing Element Update] - HE Workshop Comment Letter
Attachments: 20210908_AlhambraHEU_ComtyMeetingComments_Signed_Complete.pdf CAUTION: This email originated from outside your organization.

Dear Community Development Department,
Please see the attached comme
nt letter on City of Alhambra's 9/8/2021 Housing Element Workshop and confirm receipt of this email and its attachment.

Thank you,
Brandon Young
Office Manager
Mitchell M. Tsai, Attorney At Law
139 South Hudson Avenue, Suite 200
Pasadena, CA 91101
Office: (
626) 381-9248
Fax: (626) 389-5414
Email: brandon@mitchtsailawcom
Website:
http://www.mitchtsailaw.com
*** Our Office Has Recently Moved. Please Note New Mailing Address **** CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages accompanying it, may cont
ain confidential information that is legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that any disclosure, copying, distribution or use of any of the information contained in or attached to this message is STRICTLY PROHIBITED and may violate applicable laws in cluding the Electronic Communications Privacy Act. If you have received this transmission in error, please immediately notify us by reply e-mail at mitc
h@mitchtsailawcom or by telephone at (626) 381-9248 and destroy the original transmission and its attac
hments without reading them or saving them to disk. Thank you.

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VIA U.S. MAIL & E-MAIL
September 8, 2021
City of Alhambra
Community Development Department
111 South First Street
Alhambra, C
A 91801
Em: housingelement@cityofalhambraorg
RE: 2021-2029 Housing Element Update
To Whom it May Concern,
On behalf of the Southwest Regional Council of Carpenters (“Commenter” or “Carpenter”), my Office is submitting these comments on the City of Alhambra’s (“City”) 2021-2029 Housing Element Update (“Project”).

The Southwest Carpenters is a labor union representing 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.

Commenters 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.

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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.

Commenters incorporates by reference all comments raising issues regarding the EIR submitted prior to certification of the EIR 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, Commenter 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.

The City should require the use of a local skilled and trained workforce to benefit the community’s economic development and environment. 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:
[A]ny local hire requirement that results in a decreased worker trip length from the default value has the potential to result in a redu ction of

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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 Local skilled and trained workforce requirements and policies have significant environmental benefits since they improve an area’s jobs-housing balance, decreasing the amount of and length of job commutes and their associated greenhouse gas emissions. Recently, on May 7, 2021, the South Coast Air Quality Management District found that 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 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

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help achieve a more positive jobs-housing balance, and reduce regional commuting, gas consumption, and greenhouse gas emissions.”3 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 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. 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.

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trained workforce policies to local development permits to address transportation issues. As Cervero and Duncan note:

In nearly bu ilt-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 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.

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).

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EXHIBIT A

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2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
mhagemann@swapecom
Paul E. Rosenfeld, PhD
(310) 795-2335
prosenfeld@swapecom
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/default- source/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 34.

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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:

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.7 In 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 project- specific 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/default- source/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/default- source/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/default- source/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/default- source/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.

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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.9 Furthermore, 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/default- source/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/default- source/caleemod/05_appendix-d2016-3-2.pdf?sfvrsn=4, p. D-84 – D-86.

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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/default- source/caleemod/05_appendix-d2016-3-2.pdf?sfvrsn=4, p. D-85.

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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.

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EXHIBIT B

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SOIL WATER AIR PROTECTION ENTERPRISE
2656 29th Street, Suite 201
Santa Monica, California 90405
Attn: Paul Rosenfeld, Ph.D.

Mobil: (310) 795-2335
Office: (310) 452-5555
Fax: (310) 452-5550
Email: prosenfeld@swapecom
Paul E. Rosenfeld, Ph.D. Page 1 of 10 June 2019
Paul Rosenfeld, Ph.D. Chemical Fate and Transport & Air Dispersion Modeling Principal Environmental Chemist Risk Assessment & Remediation Specialist Education
Ph.D. Soil Chemistry, University of Washington, 1999. Dissertation on volatile organic compound filtration.

M.S. Environmental Science, U.C. Berkeley, 1995. Thesis on organic waste economics.

B.A. Environmental Studies, U.C. Santa Barbara, 1991. Thesis on wastewater treatment.

Professional Experience
Dr. Rosenfeld has over 25 years’ experience conducting environmental investigations and risk assessments for evaluating impacts to human health, property, and ecological receptors. His expertise focuses on the fate and transport of environmental contaminants, human health risk, exposure assessment, and ecological restoration. Dr.

Rosenfeld has evaluated and modeled emissions from unconventional oil drilling operations, oil spills, landfills, boilers and incinerators, process stacks, storage tanks, confined animal feeding operations, and many other industrial and agricultural sources. His project experience ranges from monitoring and modeling of pollution sources to evaluating impacts of pollution on workers at industrial facilities and residents in surrounding communities.

Dr. Rosenfeld has investigated and designed remediation programs and risk assessments for contaminated sites containing lead, heavy metals, mold, bacteria, particulate matter, petroleum hydrocarbons, chlorinated solvents, pesticides, radioactive waste, dioxins and furans, semi- and volatile organic compounds, PCBs, PAHs, perchlorate, asbestos, per- and poly-fluoroalkyl substances (PFOA/PFOS), unusual polymers, fuel oxygenates (MTBE), among other pollutants. Dr. Rosenfeld also has experience evaluating greenhouse gas emissions from various projects and is an expert on the assessment of odors from industrial and agricultural sites, as well as the evaluation of odor nuisance impacts and technologies for abatement of odorous emissions. As a principal scientist at SWAPE, Dr. Rosenfeld directs air dispersion modeling and exposure assessments. He has served as an expert witness and testified about pollution sources causing nuisance and/or personal injury at dozens of sites and has testified as an expert witness on more than ten cases involving exposure to air contaminants from industrial sources.

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Paul E. Rosenfeld, Ph.D. Page 2 of 10 June 2019
Profe
ssional History:

Soil Water Air Protection Enterprise (SWAPE); 2003 to present; Principal and Founding Partner UCLA School of Public Health; 2007 to 2011; Lecturer (Assistant Researcher) UCLA School of Public Health; 2003 to 2006; Adjunct Professor UCLA Environmental Science and Engineering Program; 2002-2004; Doctoral Intern Coordinator UCLA Institute of the Environment, 2001-2002; Research Associate Komex H2O Science, 2001 to 2003; Senior Remediation Scientist National Groundwater Association, 2002-2004; Lecturer
San Diego State University, 1999-2001; Adjunct Professor Anteon Corp., San Diego, 2000-2001; Remediation Project Manager Ogden (now Amec), San Diego, 2000-2000; Remediation Project Manager Bechtel, San Diego, California, 1999 – 2000; Risk Assessor King County, Seattle, 1996 – 1999; Scientist
James River Corp., Washington, 1995-96; Scientist
Big Creek Lumber, Davenport, California, 1995; Scientist Plumas Corp., California and USFS, Tahoe 1993-1995; Scientist Peace Corps and World Wildlife Fund, St. Kitts, West Indies, 1991-1993; Scientist Publications:

Remy, L.L., Clay T., Byers, V., Rosenfeld P. E. (2019) Hospital, Health, and Community Burden After Oil Refinery Fires, Richmond, California 2007 and 2012. Environmental Health. 18:48 Simons, R.A., Seo, Y. Rosenfeld, P., (2015) Modeling the Effect of Refinery Emission On Residential Property Value. Journal of Real Estate Research. 27(3):321-342
Chen, J. A, Zapata A. R., Sutherland A. J., Molmen, D.R., Chow, B. S., Wu, L. E., Rosenfeld, P. E., Hesse, R. C., (2012) Sulfur Dioxide and Volatile Organic Compound Exposure To A Community In Texas City Texas Evaluated Using Aermod and Empirical Data. American Journal of Environmental Science , 8(6), 622-632.

Rosenfeld, P.E. & Feng, L. (2011). The Risks of Hazardous Waste. Amsterdam: Elsevier Publishing.

Cheremisinoff, N.P., & Rosenfeld, P.E. (2011). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Agrochemical Industry, Amsterdam: Elsevier Publishing.

Gonzalez, J., Feng, L., Sutherland, A., Waller, C., Sok, H., Hesse, R., Rosenfeld, P. (2010). PCBs and Dioxins/Furans in Attic Dust Collected Near Former PCB Production and Secondary Copper Facilities in Sauget, IL.

Procedia Environmental Sciences. 113–125.

Feng, L., Wu, C., Tam, L., Sutherland, A.J., Clark, J.J., Rosenfeld, P.E. (2010). Dioxin and Furan Blood Lipid and Attic Dust Concentrations in Populations Living Near Four Wood Treatment Facilities in the United States. Journal of Environmental Health. 73(6), 34-46.

Cheremisinoff, N.P., & Rosenfeld, P.E. (2010). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Wood and Paper Industries. Amsterdam: Elsevier Publishing.

Cheremisinoff, N.P., & Rosenfeld, P.E. (2009). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Petroleum Industry. Amsterdam: Elsevier Publishing.

Wu, C., Tam, L., Clark, J., Rosenfeld, P. (2009). Dioxin and furan blood lipid concentrations in populations living near four wood treatment facilities in the United States. WIT Transactions on Ecology and the Environment, Air Pollution, 123 (17), 319-327.

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Paul E. Rosenfeld, Ph.D. Page 3 of 10 June 2019
Tam
L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). A Statistical Analysis Of Attic Dust And Blood Lipid Concentrations Of Tetrachloro-p-Dibenzodioxin (TCDD) Toxicity Equivalency Quotients (TEQ) In Two Populations Near Wood Treatment Facilities. Organohalogen Compounds, 70, 002252-002255.

Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). Methods For Collect Samples For Assessing Dioxins And Other Environmental Contaminants In Attic Dust: A Review. Organohalogen Compounds , 70, 000527- 000530.

Hensley, A.R. A. Scott, J. J. J. Clark, Rosenfeld, P.E. (2007). Attic Dust and Human Blood Samples Collected near a Former Wood Treatment Facility. Environmental Research. 105, 194-197.

Rosenfeld, P.E., J. J. J. Clark, A. R. Hensley, M. Suffet. (2007). The Use of an Odor Wheel Classification for Evaluation of Human Health Risk Criteria for Compost Facilities. Water Science & Technology 55(5), 345-357.

Rosenfeld, P. E., M. Suffet. (2007). The Anatomy Of Odour Wheels For Odours Of Drinking Water, Wastewater, Compost And The Urban Environment. Water Science & Technology 55(5), 335-344.

Sullivan, P. J. Clark, J.J.J., Agardy, F. J., Rosenfeld, P.E. (2007). Toxic Legacy, Synthetic Toxins in the Food, Water, and Air in American Cities. Boston Massachusetts: Elsevier Publishing Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash. Water Science and Technology. 49(9),171-178.

Rosenfeld P. E., J.J. Clark, I.H. (Mel) Suffet (2004). The Value of An Odor-Quality-Wheel Classification Scheme For The Urban Environment. Water Environment Federation’s Technical Exhibition and Conference (WEFTEC) 2004. New Orleans, October 2-6, 2004.

Rosenfeld, P.E., and Suffet, I.H. (2004). Understanding Odorants Associated With Compost, Biomass Facilities, and the Land Application of Biosolids. Water Science and Technology. 49(9), 193-199.

Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash, Water Science and Technology, 49( 9), 171-178.

Rosenfeld, P. E., Grey, M. A., Sellew, P. (2004). Measurement of Biosolids Odor and Odorant Emissions from Windrows, Static Pile and Biofilter. Water Environment Research. 76(4), 310-315.

Rosenfeld, P.E., Grey, M and Suffet, M. (2002). Compost Demonstration Project, Sacramento California Using High-Carbon Wood Ash to Control Odor at a Green Materials Composting Facility. Integrated Waste Management Board Public Affairs Office, Publications Clearinghouse (MS–6), Sacramento, CA Publication #442-02-008.

Rosenfeld, P.E., and C.L. Henry. (2001). Characterization of odor emissions from three different biosolids. Water Soil and Air Pollution. 127(1-4), 173-191.

Rosenfeld, P.E., and Henry C. L., (2000). Wood ash control of odor emissions from biosolids application. Journal of Environmental Quality. 29, 1662-1668.

Rosenfeld, P.E., C.L. Henry and D. Bennett. (2001). Wastewater dewatering polymer affect on biosolids odor emissions and microbial activity. Water Environment Research. 73(4), 363-367.

Rosenfeld, P.E., and C.L. Henry. (2001). Activated Carbon and Wood Ash Sorption of Wastewater, Compost, and Biosolids Odorants. Water Environment Research, 73, 388-393.

Rosenfeld, P.E., and Henry C. L., (2001). High carbon wood ash effect on biosolids microbial activity and odor.

Water Environment Research. 131(1-4), 247-262.

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Paul E. Rosenfeld, Ph.D. Page 4 of 10 June 2019
Choll
ack, T. and P. Rosenfeld. ( 1998). Compost Amendment Handbook For Landscaping. Prepared for and distributed by the City of Redmond, Washington State.

Rosenfeld, P. E. (1992). The Mount Liamuiga Crater Trail. Heritage Magazine of St. Kitts, 3(2).

Rosenfeld, P. E. (1993). High School Biogas Project to Prevent Deforestation On St. Kitts. Biomass Users Network, 7(1).

Rosenfeld, P. E. ( 1998). Characterization, Quantification, and Control of Odor Emissions From Biosolids Application To Forest Soil. Doctoral Thesis. University of Washington College of Forest Resources.

Rosenfeld, P. E. (1994). Potential Utilization of Small Diameter Trees on Sierra County Public Land. Masters thesis reprinted by the Sierra County Economic Council. Sierra County, California.

Rosenfeld, P. E. (1991). How to Build a Small Rural Anaerobic Digester & Uses Of Biogas In The First And Third World. Bachelors Thesis. University of California.

Presentations:

Rose
nfeld, P.E., Sutherland, A; Hesse, R.; Zapata, A. (October 3-6, 2013). Air dispersion modeling of volatile organic emissions from multiple natural gas wells in Decatur, TX. 44th Western Regional Meeting, American Chemical Society. Lecture conducted from Santa Clara, CA.

Sok, H.L.; Waller, C.C.; Feng, L.; Gonzalez, J.; Sutherland, A.J.; Wisdom-Stack, T.; Sahai, R.K.; Hesse, R.C.; Rosenfeld, P.E. (June 20-23, 2010). Atrazine: A Persistent Pesticide in Urban Drinking Water .

Urban Environmental Pollution. Lecture conducted from Boston, MA.

Feng, L.; Gonzalez, J.; Sok, H.L.; Sutherland, A.J.; Waller, C.C.; Wisdom-Stack, T.; Sahai, R.K.; La, M.; Hesse, R.C.; Rosenfeld, P.E. (June 20-23, 2010). Bringing Environmental Justice to East St. Louis, Illinois. Urban Environmental Pollution. Lecture conducted from Boston, MA.

Rosenfeld, P.E . (April 19-23, 2009). Perfluoroctanoic Acid (PFOA) and Perfluoroactane Sulfonate (PFOS) Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the United States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting , Lecture conducted from Tuscon, AZ.

Rosenfeld, P.E. (April 19-23, 2009). Cost to Filter Atrazine Contamination from Drinking Water in the United States” Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the United States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting . Lecture conducted from Tuscon, AZ.

Wu, C., Tam, L., Clark, J., Rosenfeld, P . (20-22 July, 2009). Dioxin and furan blood lipid concentrations in populations living near four wood treatment facilities in the United States. Brebbia, C.A. and Popov, V., eds., Air Pollution XVII: Proceedings of the Seventeenth International Conference on Modeling, Monitoring and Management of Air Pollution. Lecture conducted from Tallinn, Estonia.

Rosenfeld, P. E. (October 15-18, 2007). Moss Point Community Exposure To Contaminants From A Releasing Facility. The 23rd Annual International Conferences on Soils Sediment and Water. Platform lecture conducted from University of Massachusetts, Amherst MA.

Rosenfeld, P. E. (October 15-18, 2007). The Repeated Trespass of Tritium-Contaminated Water Into A Surrounding Community Form Repeated Waste Spills From A Nuclear Power Plant . The 23 rd Annual International Conferences on Soils Sediment and Water . Platform lecture conducted from University of Massachusetts, Amherst MA.

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Rose
nfeld, P. E. (October 15-18, 2007). Somerville Community Exposure To Contaminants From Wood Treatment Facility Emissions. The 23rd Annual International Conferences on Soils Sediment and Water . Lecture conducted from University of Massachusetts, Amherst MA.

Rosenfeld P. E. (March 2007). Production, Chemical Properties, Toxicology, & Treatment Case Studies of 1,2,3- Trichloropropane (TCP). The Association for Environmental Health and Sciences (AEHS) Annual Meeting . Lecture conducted from San Diego, CA.

Rosenfeld P. E. (March 2007). Blood and Attic Sampling for Dioxin/Furan, PAH, and Metal Exposure in Florala, Alabama. The AEHS Annual Meeting. Lecture conducted from San Diego, CA.

Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (August 21 – 25, 2006). Dioxin Containing Attic Dust And Human Blood Samples Collected Near A Former Wood Treatment Facility. The 26th International Symposium on Halogenated Persistent Organic Pollutants – DIOXIN2006 . Lecture conducted from Radisson SAS Scandinavia Hotel in Oslo Norway.

Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (November 4-8, 2006). Dioxin Containing Attic Dust And Human Blood Samples Collected Near A Former Wood Treatment Facility . APHA 134 Annual Meeting & Exposition. Lecture conducted from Boston Massachusetts.

Paul Rosenfeld Ph.D . (October 24-25, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.

Mealey’s C8/PFOA. Science, Risk & Litigation Conference. Lecture conducted from The Rittenhouse Hotel, Philadelphia, PA.

Paul Rosenfeld Ph.D . (September 19, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human Ingestion, Toxicology and Remediation PEMA Emerging Contaminant Conference . Lecture conducted from Hilton Hotel, Irvine California.

Paul Rosenfeld Ph.D . (September 19, 2005). Fate, Transport, Toxicity, And Persistence of 1,2,3-TCP. PEMA Emerging Contaminant Conference. Lecture conducted from Hilton Hotel in Irvine, California.

Paul Rosenfeld Ph.D. (September 26-27, 2005). Fate, Transport and Persistence of PDBEs. Mealey’s Groundwater Conference. Lecture conducted from Ritz Carlton Hotel, Marina Del Ray, California.

Paul Rosenfeld Ph.D . (June 7-8, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.

International Society of Environmental Forensics: Focus On Emerging Contaminants . Lecture conducted from Sheraton Oceanfront Hotel, Virginia Beach, Virginia.

Paul Rosenfeld Ph.D . (July 21-22, 2005). Fate Transport, Persistence and Toxicology of PFOA and Related Perfluorochemicals. 2005 National Groundwater Association Ground Water And Environmental Law Conference .

Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.

Paul Rosenfeld Ph.D . (July 21-22, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human Ingestion, Toxicology and Remediation. 2005 National Groundwater Association Ground Water and Environmental Law Conference. Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.

Paul Rosenfeld, Ph.D. and James Clark Ph.D. and Rob Hesse R.G. (May 5-6, 2004). Tert-butyl Alcohol Liability and Toxicology, A National Problem and Unquantified Liability. National Groundwater Association. Environmental Law Conference. Lecture conducted from Congress Plaza Hotel, Chicago Illinois.

Paul Rosenfeld, Ph.D. (March 2004). Perchlorate Toxicology. Meeting of the American Groundwater Trust .

Lecture conducted from Phoenix Arizona.

Hagemann, M.F., Paul Rosenfeld, Ph.D. and Rob Hesse (2004). Perchlorate Contamination of the Colorado River.

Meeting of tribal representatives. Lecture conducted from Parker, AZ.

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Paul
Rosenfeld, Ph.D. (April 7, 2004). A National Damage Assessment Model For PCE and Dry Cleaners.

Drycleaner Symposium. California Ground Water Association . Lecture conducted from Radison Hotel, Sacramento, California.

Rosenfeld, P. E ., Grey, M., (June 2003) Two stage biofilter for biosolids composting odor control. Seventh International In Situ And On Site Bioremediation Symposium Battelle Conference Orlando, FL.

Paul Rosenfeld, Ph.D. and James Clark Ph.D. (February 20-21, 2003) Understanding Historical Use, Chemical Properties, Toxicity and Regulatory Guidance of 1,4 Dioxane. National Groundwater Association. Southwest Focus Conference. Water Supply and Emerging Contaminants .. Lecture conducted from Hyatt Regency Phoenix Arizona.

Paul Rosenfeld, Ph.D. (February 6-7, 2003). Underground Storage Tank Litigation and Remediation. California CUPA Forum. Lecture conducted from Marriott Hotel, Anaheim California.

Paul Rosenfeld, Ph.D . (October 23, 2002) Underground Storage Tank Litigation and Remediation. EPA Underground Storage Tank Roundtable. Lecture conducted from Sacramento California.

Rosenfeld, P.E . and Suffet, M. (October 7- 10, 2002). Understanding Odor from Compost, Wastewater and Industrial Processes. Sixth Annual Symposium On Off Flavors in the Aquatic Environment. International Water Association. Lecture conducted from Barcelona Spain.

Rosenfeld, P.E. and Suffet, M. (October 7- 10, 2002). Using High Carbon Wood Ash to Control Compost Odor.

Sixth Annual Symposium On Off Flavors in the Aquatic Environment. International Water Association . Lecture conducted from Barcelona Spain.

Rosenfeld, P.E. and Grey, M. A. (September 22-24, 2002). Biocycle Composting For Coastal Sage Restoration.

Northwest Biosolids Management Association . Lecture conducted from Vancouver Washington..

Rosenfeld, P.E. and Grey, M. A. (November 11-14, 2002). Using High-Carbon Wood Ash to Control Odor at a Green Materials Composting Facility. Soil Science Society Annual Conferenc e. Lecture conducted from Indianapolis, Maryland.

Rosenfeld. P.E. (September 16, 2000). Two stage biofilter for biosolids composting odor control. Water Environment Federation. Lecture conducted from Anaheim California.

Rosenfeld. P.E. ( October 16, 2000). Wood ash and biofilter control of compost odor. Biofest. Lecture conducted from Ocean Shores, California.

Rosenfeld, P.E. ( 2000). Bioremediation Using Organic Soil Amendments. California Resource Recovery Association. Lecture conducted from Sacramento California.

Rosenfeld, P.E ., C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur Emissions Following Biosolids Incorporation With High-Carbon Wood-Ash. Water Environment Federation 12th Annual Residuals and Biosolids Management Conference Proceedings . Lecture conducted from Bellevue Washington.

Rosenfeld, P.E., and C.L. Henry. (1999). An evaluation of ash incorporation with biosolids for odor reduction. Soil Science Society of America. Lecture conducted from Salt Lake City Utah.

Rosenfeld, P.E. , C.L. Henry, R. Harrison. (1998). Comparison of Microbial Activity and Odor Emissions from Three Different Biosolids Applied to Forest Soil. Brown and Caldwell. Lecture conducted from Seattle Washington.

Rosenfeld, P.E. , C.L. Henry. (1998). Characterization, Quantification, and Control of Odor Emissions from Biosolids Application To Forest Soil. Biofest. Lecture conducted from Lake Chelan, Washington.

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Rose
nfeld, P.E, C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur Emissions Following Biosolids Incorporation With High-Carbon Wood-Ash. Water Environment Federation 12th Annual Residuals and Biosolids Management Conference Proceedings. Lecture conducted from Bellevue Washington.

Rosenfeld, P.E. , C.L. Henry, R. B. Harrison, and R. Dills. (1997). Comparison of Odor Emissions From Three Different Biosolids Applied to Forest Soil. Soil Science Society of America . Lecture conducted from Anaheim California.

Teaching Experience:

UCLA
Department of Environmental Health (Summer 2003 through 20010) Taught Environmental Health Science 100 to students, including undergrad, medical doctors, public health professionals and nurses. Course focused on the health effects of environmental contaminants.

National Ground Water Association, Successful Remediation Technologies. Custom Course in Sante Fe, New Mexico. May 21, 2002. Focused on fate and transport of fuel contaminants associated with underground storage tanks.

National Ground Water Association; Successful Remediation Technologies Course in Chicago Illinois. April 1, 2002. Focused on fate and transport of contaminants associated with Superfund and RCRA sites.

California Integrated Waste Management Board, April and May, 2001. Alternative Landfill Caps Seminar in San Diego, Ventura, and San Francisco. Focused on both prescriptive and innovative landfill cover design.

UCLA Department of Environmental Engineering, February 5, 2002. Seminar on Successful Remediation Technologies focusing on Groundwater Remediation.

University Of Washington, Soil Science Program, Teaching Assistant for several courses including: Soil Chemistry, Organic Soil Amendments, and Soil Stability.

U.C. Berkeley, Environmental Science Program Teaching Assistant for Environmental Science 10.

Academic Grants Awarded:

Cal
ifornia Integrated Waste Management Board. $41,000 grant awarded to UCLA Institute of the Environment.

Goal: To investigate effect of high carbon wood ash on volatile organic emissions from compost. 2001.

Synagro Technologies, Corona California: $10,000 grant awarded to San Diego State University.

Goal: investigate effect of biosolids for restoration and remediation of degraded coastal sage soils. 2000.

King County, Department of Research and Technology, Washington State. $100,000 grant awarded to University of Washington: Goal: To investigate odor emissions from biosolids application and the effect of polymers and ash on VOC emissions. 1998.

Northwest Biosolids Management Association, Washington State. $20,000 grant awarded to investigate effect of polymers and ash on VOC emissions from biosolids. 1997.

James River Corporation, Oregon: $10,000 grant was awarded to investigate the success of genetically engineered Poplar trees with resistance to round-up. 1996.

United State Forest Service, Tahoe National Forest: $15,000 grant was awarded to investigating fire ecology of the Tahoe National Forest. 1995.

Kellogg Foundation, Washington D.C. $500 grant was awarded to construct a large anaerobic digester on St. Kitts in West Indies. 1993

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Paul E. Rosenfeld, Ph.D. Page 8 of 10 June 2019
Depo
sition and/or Trial Testimony:

In
the United States District Court For The District of New Jersey Duarte et al, Plaintiffs, vs. United States Metals Refining Company et. al. Defendant.

Case No.: 2:17-cv-01624-ES-SCM
Rosenfeld Deposition. 6-7-2019
In the United States District Court of Southern District of Texas Galveston Division M/T Carla Maersk, Plaintiffs, vs. Conti 168., Schiffahrts-GMBH & Co. Bulker KG MS “Conti Perdido” Defendant.

Case No.: 3:15-CV-00106 consolidated with 3:15-CV-00237 Rosenfeld Deposition. 5-9-2019
In The Superior Court of the State of California In And For The County Of Los Angeles – Santa Monica Carole-Taddeo-Bates et al., vs. Ifran Khan et al., Defendants Case No.: No. BC615636
Rosenfeld Deposition, 1-26-2019
In The Superior Court of the State of California In And For The County Of Los Angeles – Santa Monica The San Gabriel Valley Council of Governments et al. vs El Adobe Apts. Inc. et al., Defendants Case No.: No. BC646857
Rosenfeld Deposition, 10-6-2018; Trial 3-7-19
In United States District Court For The District of Colorado Bells et al. Plaintiff vs. The 3M Company et al., Defendants Case: No 1:16-cv-02531-RBJ
Rosenfeld Deposition, 3-15-2018 and 4-3-2018
In The District Court Of Regan County, Texas, 112 th Judicial District Phillip Bales et al., Plaintiff vs. Dow Agrosciences, LLC, et al., Defendants Cause No 1923
Rosenfeld Deposition, 11-17-2017
In The Superior Court of the State of California In And For The County Of Contra Costa Simons et al., Plaintiffs vs. Chevron Corporation, et al., Defendants Cause No C12-01481
Rosenfeld Deposition, 11-20-2017
In The Circuit Court Of The Twentieth Judicial Circuit, St Clair County, Illinois Martha Custer et al., Plaintiff vs. Cerro Flow Products, Inc., Defendants Case No.: No. 0i9-L-2295
Rosenfeld Deposition, 8-23-2017
In The Superior Court of the State of California, For The County of Los Angeles Warrn Gilbert and Penny Gilber, Plaintiff vs. BMW of North America LLC Case No.: LC102019 (c/w BC582154)
Rosenfeld Deposition, 8-16-2017, Trail 8-28-2018
In the Northern District Court of Mississippi, Greenville Division Brenda J. Cooper, et al., Plaintiffs, vs. Meritor Inc., et al., Defendants Case Number: 4:16-cv-52-DMB-JVM
Rosenfeld Deposition: July 2017

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Paul E. Rosenfeld, Ph.D. Page 9 of 10 June 2019
In
The Superior Court of the State of Washington, County of Snohomish Michael Davis and Julie Davis et al., Plaintiff vs. Cedar Grove Composting Inc., Defendants Case No.: No. 13-2-03987-5
Rosenfeld Deposition, February 2017
Trial, March 2017
In The Superior Court of the State of California, County of Alameda Charles Spain., Plaintiff vs. Thermo Fisher Scientific, et al., Defendants Case No.: RG14711115
Rosenfeld Deposition, September 2015
In The Iowa District Court In And For Poweshiek County
Russell D. Winburn, et al., Plaintiffs vs. Doug Hoksbergen, et al., Defendants Case No.: LALA002187
Rosenfeld Deposition, August 2015
In The Iowa District Court For Wapello County
Jerry Dovico, et al., Plaintiffs vs. Valley View Sine LLC, et al., Defendants Law No,: LALA105144 - Division A
Rosenfeld Deposition, August 2015
In The Iowa District Court For Wapello County
Doug Pauls, et al.,, et al., Plaintiffs vs. Richard Warren, et al., Defendants Law No,: LALA105144 - Division A
Rosenfeld Deposition, August 2015
In The Circuit Court of Ohio County, West Virginia
Robert Andrews, et al. v. Antero, et al.

Civil Action N0. 14-C-30000
Rosenfeld Deposition, June 2015
In The Third Judicial District County of Dona Ana, New Mexico Betty Gonzalez, et al. Plaintiffs vs. Del Oro Dairy, Del Oro Real Estate LLC, Jerry Settles and Deward DeRuyter, Defendants
Rosenfeld Deposition: July 2015
In The Iowa District Court For Muscatine County
Laurie Freeman et. al. Plaintiffs vs. Grain Processing Corporation, Defendant Case No 4980
Rosenfeld Deposition: May 2015
In the Circuit Court of the 17th Judicial Circuit, in and For Broward County, Florida Walter Hinton, et. al. Plaintiff, vs. City of Fort Lauderdale, Florida, a Municipality, Defendant.

Case Number CACE07030358 (26)
Rosenfeld Deposition: December 2014
In the United States District Court Western District of Oklahoma Tommy McCarty, et al., Plaintiffs, v. Oklahoma City Landfill, LLC d/b/a Southeast Oklahoma City Landfill, et al. Defendants.

Case No. 5:12-cv-01152-C
Rosenfeld Deposition: July 2014

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Paul E. Rosenfeld, Ph.D. Page 10 of 10 June 2019
In
the County Court of Dallas County Texas
Lisa Parr et al, Plaintiff, vs. Aruba et al, Defendant.

Case Number cc-11-01650-E
Rosenfeld Deposition: March and September 2013
Rosenfeld Trial: April 2014
In the Court of Common Pleas of Tuscarawas County Ohio
John Michael Abicht, et al., Plaintiffs, vs. Republic Services, Inc., et al., Defendants Case Number: 2008 CT 10 0741 (Cons. w/ 2009 CV 10 0987) Rosenfeld Deposition: October 2012
In the United States District Court of Southern District of Texas Galveston Division Kyle Cannon, Eugene Donovan, Genaro Ramirez, Carol Sassler, and Harvey Walton, each Individually and on behalf of those similarly situated, Plaintiffs, vs. BP Products North America, Inc., Defendant.

Case 3:10-cv-00622
Rosenfeld Deposition: February 2012
Rosenfeld Trial: April 2013
In the Circuit Court of Baltimore County Maryland
Philip E. Cvach, II et al., Plaintiffs vs. Two Farms, Inc. d/b/a Royal Farms, Defendants Case Number: 03-C-12-012487 OT
Rosenfeld Deposition: September 2013

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EXHIBIT C

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1640 5th St.., Suite 204 S anta
Santa Monica, California 90401
Tel: (949) 887‐9013
Email: mhagemann@swapecom
Matthew F. Hagemann, P.G., C.Hg., QSD, QSP
Geologic a
nd Hydrogeologic Characterization
Industrial Stormwater Compliance
Investigation and Remediation Strategies
Litigation Support and Testifying Expert
CEQA Review
Education:

M.S. Degree, Geology, California State University Los Angeles, Los Angeles, CA, 1984.

B.A. Degree, Geology, Humboldt State University, Arcata, CA, 1982.

Professional Certifications:

California Professional Geologist
California Certified Hydrogeologist
Qualified SWPPP Developer and Practitioner
Professional Experience:

Matt has 25 years of experience in environmental policy, assessment and remediation. He spent nine years with the U.S. EPA in the RCRA and Superfund programs and served as EPA’s Senior Science Policy Advisor in the Western Regional Office where he identified emerging threats to groundwater from perchlorate and MTBE. While with EPA, Matt also served as a Senior Hydrogeologist in the oversight of the assessment of seven major military facilities undergoing base closure. He led numerous enforcement actions under provisions of the Resource Conservation and Recovery Act (RCRA) while also working with permit holders to improve hydrogeologic characterization and water quality monitoring.

Matt has worked closely with U.S. EPA legal counsel and the technical staff of several states in the application and enforcement of RCRA, Safe Drinking Water Act and Clean Water Act regulations. Matt has trained the technical staff in the States of California, Hawaii, Nevada, Arizona and the Territory of Guam in the conduct of investigations, groundwater fundamentals, and sampling techniques.

Positions Matt has held include:
• Founding Partner, Soil/Water/Air Protection Enterprise (SWAPE) (2003 – present); • Geology Instructor, Golden
West College, 2010 – 2014;
• Senior Environmental Analyst,
Komex H2O Science, Inc. (2000 ‐‐ 2003);

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• Executive Director, Orange Coast Watch (2001 – 2004); • Senior Science Policy Advisor and Hydrogeologist, U.S. Environmental Protection Agency (1989– 1998);
• Hydrogeologist, National Park Service, Water Resources Division (1998 – 2000); • Adjunct Faculty Member, San Francisco State University, Department of Geosciences (1993 – 1998);
• Instructor, College of Marin, Department of Science (1990 – 1995); • Geologist, U.S. Forest Service (1986 – 1998); and
• Geologist, Dames & Moore (1984 – 1986).

Senior Regulatory and Litigation Support Analyst:

With SWAPE, Matt’s responsibilities have included:
• Lead analyst and testifying expert in the review of over 100 environmental impact reports since 2003 under CEQA that identify significant issues with regard to hazardous waste, water resources, water quality, air quality, Valley Fever, greenhouse gas emissions, and geologic hazards. Make recommendations for additional mitigation measures to lead agencies at the local and county level to include additional characterization of health risks and implementation of protective measures to reduce worker exposure to hazards from toxins and Valley Fever.
• Stormwater analysis, sampling and best management practice evaluation at industrial facilities. • Manager of a project to provide technical assistance to a community adjacent to a former Naval shipyard under a grant from the U.S. EPA.
• Technical assistance and litigation support for vapor intrusion concerns. • Lead analyst and testifying expert in the review of environmental issues in license applications for large solar power plants before the California Energy Commission. • Manager of a project to evaluate numerous formerly used military sites in the western U.S. • Manager of a comprehensive evaluation of potential sources of perchlorate contamination in Southern California drinking water wells.
• Manager and designated expert for litigation support under provisions of Proposition 65 in the review of releases of gasoline to sources drinking water at major refineries and hundreds of gas stations throughout California.
• Expert witness on two cases involving MTBE litigation. • Expert witness and litigation support on the impact of air toxins and hazards at a school. • Expert witness in litigation at a former plywood plant.

With Komex H2O Science Inc., Matt’s duties included the following:
• Senior author of a report on the extent of perchlorate contamination that was used in testimony by the former U.S. EPA Administrator and General Counsel. • Senior researcher in the deve lopment of a comprehensive, electronically interactive chronology of MTBE use, research, and regulation.
• Senior researcher in the development of a comprehensive, electronically interactive chronology of perchlorate use, research, and regulation.
• Senior researcher in a study that estimates nationwide costs for MTBE remediation and drinking water treatment, results of which were published in newspapers nationwide and in testimony against provisions of an energy bill that would limit liability for oil companies. • Research to support litigation to restore drinking water supplies that have been contaminated by MTBE in California and New York.

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• Expert witness testimony in a case of oil production‐related contamination in Mississippi. • Lead author for a multi‐volume remedial investigation report for an operating school in Los Angeles that met strict regulatory requirements and rigorous deadlines.

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• Development of strategic approaches for cleanup of contaminated sites in consultation with clients and regulators.

Executive Director:

As Executive Director with Orange Coast Watch, Matt led efforts to restore water quality at Orange County beaches from multiple sources of contamination including urban runoff and the discharge of wastewater. In reporting to a Board of Directors that included representatives from leading Orange County universities and businesses, Matt prepared issue papers in the areas of treatment and disinfection of wastewater and control of the discharge of grease to sewer systems. Matt actively participated in the development of countywide water quality permits for the control of urban runoff and permits for the discharge of wastewater. Matt worked with other nonprofits to protect and restore water quality, including Surfrider, Natural Resources Defense Council and Orange County CoastKeeper as well as with business institutions including the Orange County Business Council.

Hydrogeology:

As a Senior Hydrogeologist with the U.S. Environmental Protection Agency, Matt led investigations to characterize and cleanup closing military bases, including Mare Island Naval Shipyard, Hunters Point Naval Shipyard, Treasure Island Naval Station, Alameda Naval Station, Moffett Field, Mather Army Airfield, and Sacramento Army Depot. Specific activities were as follows:
• Led efforts to model groundwater flow and contaminant transport, ensured adequacy of monitoring networks, and assessed cleanup alternatives for contaminated sediment, soil, and groundwater.
• Initiated a regional program for evaluation of groundwater sampling practices and laboratory analysis at military bases.
• Identified emerging issues, wrote technical guidance, and assisted in policy and regulation development through work on four national U.S. EPA workgroups, including the Superfund Groundwater Technical Forum and the Federal Facilities Forum.

At the request of the State of Hawaii, Matt developed a methodology to determine the vulnerability of groundwater to contamination on the islands of Maui and Oahu. He used analytical models and a GIS to show zones of vulnerability, and the results were adopted and published by the State of Hawaii and County of Maui.

As a hydrogeologist with the EPA Groundwater Protection Section, Matt worked with provisions of the Safe Drinking Water Act and NEPA to prevent drinking water contamination. Specific activities included the following:
• Received an EPA Bronze Medal for his contribution to the development of national guidance for the protection of drinking water.
• Managed the Sol e Source Aquifer Program and protected the drinking water of two communities through designation under the Safe Drinking Water Act. He prepared geologic reports, conducted public hearings, and responded to public comments from residents who were very concerned about the impact of designation.

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• Reviewed a number of Environmental Impact Statements for planned major developments, including large hazardous and solid waste disposal facilities, mine reclamation, and water transfer.

Matt served as a hydrogeologist with the RCRA Hazardous Waste program. Duties were as follows:
• Supervised the hydrogeologic investigation of hazardous waste sites to determine compliance with Subtitle C requirements.
• Reviewed and wrote ʺpart Bʺ permits for the disposal of hazardous waste. • Conducted RCRA Corrective Action investigations of waste sites and led inspections that formed the basis for significant enforcement actions that were developed in close coordination with U.S.

EPA legal counsel.
• Wrote contract specifications and supervised contractor’s investigations of waste sites.

With the National Park Service, Matt directed service‐wide investigations of contaminant sources to prevent degradation of water quality, including the following tasks:
• Applied pertinent laws and regulations including CERCLA, RCRA, NEPA, NRDA, and the Clean Water Act to control military, mining, and landfill contaminants. • Conducted watershed‐scale investigations of contaminants at parks, including Yellowstone and Olympic National Park.
• Identified high‐levels of perchlorate in soil adjacent to a national park in New Mexico and advised park superintendent on appropriate response actions under CERCLA. • Served as a Park Service representative on the Interagency Perchlorate Steering Committee, a national workgroup.
• Developed a program to conduct environmental compliance audits of all National Parks while serving on a national workgroup.
• Co‐authored two papers on the potential for water contamination from the operation of personal watercraft and snowmobiles, these papers serving as the basis for the development of nation‐ wide policy on the use of these vehicles in National Parks. • Contributed to the Federal M ulti‐Agency Source Water Agreement under the Clean Water Action Plan.

Policy:

Served senior management as the Senior Science Policy Advisor with the U.S. Environmental Protection Agency, Region 9. Activities included the following:
• Advised the Regional Administrator and senior management on emerging issues such as the potential for the gasoline additive MTBE and ammonium perchlorate to contaminate drinking water supplies.
• Shaped EPA’s national response to these threats by serving on workgroups and by contributing to guidance, including the Office of Research and Development publication, Oxygenates in Water: Critical Information and Research Needs.
• Improved the technical training of EPAʹs scientific and engineering staff. • Earned an EPA Bronze Medal for representing the region’s 300 scientists and engineers in negotiations with the Administrator and senior management to better integrate scientific principles into the policy‐making process.
• Established national protocol for the peer review of scientific documents.

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Geology:

With the U.S. Forest Service, Matt led investigations to determine hillslope stability of areas proposed for timber harvest in the central Oregon Coast Range. Specific activities were as follows:
• Mapped geology in the field, and used aerial photographic interpretation and mathematical models to determine slope stability.
• Coordinated his research with community members who were concerned with natural resource protection.
• Characterized the geology of an aquifer that serves as the sole source of drinking water for the city of Medford, Oregon.

As a consultant with Dames and Moore, Matt led geologic investigations of two contaminated sites (later listed on the Superfund NPL) in the Portland, Oregon, area and a large hazardous waste site in eastern Oregon. Duties included the following:
• Supervised year‐long effort for soil and groundwater sampling. • Conducted aquifer tests.
• Investigated active faults beneath sites proposed for hazardous waste disposal.

Teaching:

From 1990 to 1998, Matt taught at least one course per semester at the community college and university levels:
• At San Francisco State University, held an adjunct faculty position and taught courses in environmental geology, oceanography (lab and lecture), hydrogeology, and groundwater contamination.
• Served as a committee member for graduate and undergraduate students. • Taught courses in environmental geology and oceanography at the College of Marin.

Matt taught physical geology (lecture and lab and introductory geology at Golden West College in Huntington Beach, California from 2010 to 2014.

Invited Testimony, Reports, Papers and Presentations:

Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Presentation to the Public Environmental Law Conference, Eugene, Oregon.

Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Invited presentation to U.S.

EPA Region 9, San Francisco, California.

Hagemann, M.F., 2005. Use of Electronic Databases in Environmental Regulation, Policy Making and Public Participation. Brownfields 2005, Denver, Coloradao.

Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in Nevada and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Las Vegas, NV (served on conference organizing committee).

Hagemann, M.F., 2004. Invited testimony to a California Senate committee hearing on air toxins at schools in Southern California, Los Angeles.

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Brown, A., Farrow, J., Gray, A. and Hagemann, M., 2004. An Estimate of Costs to Address MTBE Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells.

Presentation to the Ground Water and Environmental Law Conference, National Groundwater Association.

Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in Arizona and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Phoenix, AZ (served on conference organizing committee).

Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in the Southwestern U.S. Invited presentation to a special committee meeting of the National Academy of Sciences, Irvine, CA.

Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a tribal EPA meeting, Pechanga, CA.

Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a meeting of tribal repesentatives, Parker, AZ.

Hagemann, M.F., 2003. Impact of Perchlorate on the Colorado River and Associated Drinking Water Supplies. Invited presentation to the Inter‐Tribal Meeting, Torres Martinez Tribe.

Hagemann, M.F., 2003. The Emergence of Perchlorate as a Widespread Drinking Water Contaminant.

Invited presentation to the U.S. EPA Region 9.

Hagemann, M.F., 2003. A Deductive Approach to the Assessment of Perchlorate Contamination. Invited presentation to the California Assembly Natural Resources Committee.

Hagemann, M.F., 2003. Perchlorate: A Cold War Legacy in Drinking Water. Presentation to a meeting of the National Groundwater Association.

Hagemann, M.F., 2002. From Tank to Tap: A Chronology of MTBE in Groundwater. Presentation to a meeting of the National Groundwater Association.

Hagemann, M.F., 2002. A Chronology of MTBE in Groundwater and an Estimate of Costs to Address Impacts to Groundwater. Presentation to the annual meeting of the Society of Environmental Journalists.

Hagemann, M.F., 2002. An Estimate of the Cost to Address MTBE Contamination in Groundwater (and Who Will Pay). Presentation to a meeting of the National Groundwater Association.

Hagemann, M.F., 2002. An Estimate of Costs to Address MTBE Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells. Presentation to a meeting of the U.S. EPA and State Underground Storage Tank Program managers.

Hagemann, M.F., 2001. From Tank to Tap: A Chronology of MTBE in Groundwater. Unpublished report.

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Hagemann, M.F ., 2001. Estimated Cleanup Cost for MTBE in Groundwater Used as Drinking Water.

Unpublished report.

Hagemann, M.F., 2001. Estimated Costs to Address MTBE Releases from Leaking Underground Storage Tanks. Unpublished report.

Hagemann, M.F., and VanMouwerik, M., 1999. Potential Water Quality Concerns Related to Snowmobile Usage. Water Resources Division, National Park Service, Technical Report.

VanMouwerik, M. and Hagemann, M.F. 1999, Water Quality Concerns Related to Personal Watercraft Usage. Water Resources Division, National Park Service, Technical Report.

Hagemann, M.F ., 1999, Is Dilution the Solution to Pollution in National Parks? The George Wright Society Biannual Meeting, Asheville, North Carolina.

Hagemann, M.F., 1997, The Potential for MTBE to Contaminate Groundwater. U.S. EPA Superfund Groundwater Technical Forum Annual Meeting, Las Vegas, Nevada.

Hagemann, M.F., and Gill, M., 1996, Impediments to Intrinsic Remediation, Moffett Field Naval Air Station, Conference on Intrinsic Remediation of Chlorinated Hydrocarbons, Salt Lake City.

Hagemann, M.F., Fukunaga, G.L., 1996, The Vulnerability of Groundwater to Anthropogenic Contaminants on the Island of Maui, Hawaii. Hawaii Water Works Association Annual Meeting, Maui, October 1996.

Hagemann, M. F., Fukanaga, G. L., 1996, Ranking Groundwater Vulnerability in Central Oahu, Hawaii. Proceedings, Geographic Information Systems in Environmental Resources Management, Air and Waste Management Association Publication VIP‐61.

Hagemann, M.F., 1994. Groundwater Characterization and Cleanup a t Closing Military Bases in California. Proceedings, California Groundwater Resources Association Meeting.

Hagemann, M. F. and Sabol, M.A., 1993. Role of the U.S. EPA in the High Plains States Groundwater Recharge Demonstration Program. Proceedings, Sixth Biennial Symposium on the Artificial Recharge of Groundwater.

Hagemann, M.F., 1993. U.S. EPA Policy on the Technical Impracticability of the Cleanup of DNAPL‐ contaminated Groundwater. California Groundwater Resources Association Meeting.

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Hagemann, M.F., 1992. Dense Nonaqueous Phase Liquid Contamination of Groundwater: An Ounce of Prevention... Proceedings, Association of Engineering Geologists Annual Meeting, v. 35.

Other Experience:

Selected as subject matter expert for the California Professional Geologist licensing examination, 2009‐ 2011.

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1 Reynoso, Vanessa
From: Ray Gonzales <[email protected]>
Sent: Wednesday, September 8, 2021 8:08 AM
To: Housing Element
Subject: [Alhambra HE] Draft Housing Element Comments - new submission CAUTION: This email originated from outside your organization. ???
Ray Gonzales just submitted your form: Draft Housing Element Comments on Alhambra HE

Message Details:

First Name: Ray
Last Name: Gonzales
Email: gonzarayray@gmailcom
Enter your comments on the Draft Housing Element here. (1,000 characters): I am an Alhambra resident and I read the Housing element draft. On the face of it, it seems like a good thing???Promote the maintenance of the existing housing supply, and try to increase the amount of low to moderate-income housing so that it???s not all in one

part of the city.
???

If you think this submission is spam, report it as spam .

???

To edit your email settings, go to your Inbox on desktop.

To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet. ???

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1 Reynoso, Vanessa
From: Ted Slaught <[email protected]>
Sent: Monday, September 13, 2021 3:37 PM
To: Reynoso, Vanessa
Subject: Alhambra Housing Element Draft Report and Recommendations CAUTION: This email originated from outside your organization.

Vanessa,
Although I have not had the opportunity to thoroughly review all the details of the entire Draft Housing Element document, which was made available to the public a few days ago, I have noted a consistency of several valid report observations with many of the sound planning recommendations contained in this draft report, including;

1.) Consolidation of small lots for purposes of developing appropriately-sized multi-family residential projects,

2.) Densification of multi-family and mixed commercial/residential uses in the Downtown CBD and Valley Blvd. areas, 3.) Placement of new multi-family residential developments on major commercial thoroughfares having access to public transportation and walkable amenities, and 4.) Preservation and protection of single family homes located in R-1 zoned neighborhoods. Unfortunately, many of these draft recommendations and observations directly contradict numerous former planning decisions and actions undertaken by prior Alhambra Planning Commissions, and Alhambra City Councils. Nevertheless, I am very encouraged with the thorough and detailed process which has preceded the issuance of the Draft Housing Element report, and I wish to respectively offer the following observations, comments, and recommendations for inclusion in the Final Alhambra Housing Element Report. But first, a bit of history...

In addition to several other Alhambra commercial development partnerships, I am the Managing Partner of Hillcrest Main Street Associates, LP, located at 410 to 412 East Main Street, which property consists of the existing LA Fitness, and Dog Haus Restaurant, and is situated on approximately 100,000 square feet of commercially zoned property, fronting on both Main and Chapel Streets, in what has been referred to as The Central Business District (CBD) Planning area of Alhambra for at least the past 50 years. I am also the Managing Partner of Hillcrest Monterey Associates, LP, which developed the current Ross Dress for Less store in the CBD at 201 East Main Street, at Monterey Street. Both of these CBD commercial projects were planned and developed in conjunction with the City's simultaneous construction of the Chapel Street parking structure to the north of the Ross store, and extending all the way to Chapel Street. These two Alhambra CBD development projects were completed in 1997, and resulted from our company's highly complex private assemblages of land, and subsiquent cooperative transfers of a portion of this land to the City, for purposes of the City's construction of this public parking structure, which structure provides 100% of the City code required parking for the Ross Dress for Less, and over 50% of the City code required parking for the LA Fitness and Dog House Restaurant.

At the suggestion of senior City staff, in 2005, and then again in 2009, we approached two neighboring property owners of the LA Fitness Dog House surface parking lots for the purpose of purchasing these under utilized properties to expand our existing site to approximately 135,000 sq. ft., and thereby allow for development of another major national retailer at the southeast corner of Main and Chapel Streets, plus development of badly needed multi-family housing above this ground level Main Street retail, and additional structured public parking to the south of this proposed 5 story, mixed-use CBD project. Although we were unsuccessful in negotiating the acquisition of both of these neighboring properties, we continued to attempt these land purchases and parcel consolidation, until the Alhambra Redevelopment Agency was disbanded by the State in late 2012, resulting in a series of City senior staff changes, and subsiquent decline of focus on vital economic development and housing production by the City.

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2 In 2015, a group of homeowners residing in a single family neighborhood near Main Street, at the eastern border of the city, immediately adjacent to the planning area east of the CBD, then referred to as Main Street Commercial district, (MSC- Main Street, between Almansor Street and the City of San Gabriel border) became concerned with a proposed high density, multi-story, multi-family development application submitted for a very small commercial MSC lot located on Main Street, immediately adjacent to their R1 zoned single family homes. Although this proposed multi-family use was conditionally permitted in the MSC zone, the homeowners' legitimate concerns about the immediate proximity of this proposed high density multi-story development to thier single family homes resulted in an appropriate response by these homeowners to apply pressure on the then City Council to reject this multi-family development, and pass a new city ordinance banning ALL multi-family development on these small MSC area commercial lots, which directly abutted single family homes, in R1 zoned neighborhoods.

Unfortunately, what resulted from this very well intentioned, but rushed effort by these residents living in close proximity to these small MSC zoned and R1 adjacent commercial properties, (as well as the then Planning Commission and City Council) was the highly improper, and likely unlawfull ⁰2015 passage of The East Main Street Corridor Ordinance, which ordinance not only eliminated ALL future housing and hospitality uses from the entire MSC zoned area, regardless of parcel size or adjacency to single-family R1 zoned homes, but also improperly attempted to expand the MSC zoning area, by use of this flawed ordinance, with the goal of significantly down-zoning all CBD zoned properties, located on Main Street, between Chapel and Almansor Streets, by attempting to improperly include these CBD zoned properties into the East Main Street Corridor Ordinance.

As was correctly pointed out in the recently released Alhambra Housing Element Draft Report, many of the properties located at the westerly portion of the MSC zoned area are larger in size than the smaller Main Street lots located close the eastern border of the City, which larger parcel sizes would make these westerly MSC Main Street lots more suitable for mid-rise, medium density residential development, even though several of these larger Main Street properties abut single family homes in R1 zoned areas.

These westerly MSC zoned areas, with larger size properties, generally lie between Almansor Street and Granada Avenue, and have been recommended in the Housing Element Report to be zoned for up to 30 residential units per acre of land. Nevertheless, there do exist several large properties, or potential large land assemblages, located on Main Street, east of Granada which I believe should also be considered for potential appropriately-sized low to mid-rise, medium density multifamily residential or mixed-use development, even if these larger Main Street properties abut single family homes in R1 zoned areas.

With respect to the very large CBD zoned properties fronting Main Street, between Chapel and Almansor Streets, were an improper attempt was made to include these properties in The East Main Street Corridor Ordinance, these large CBD properties, which do NOT abut any R1 zoned property, or single family residences, should be legally entitled to develop multifamily housing at the same density, in the same manner, and under the same criteria, as all other properties located within the CBD zoning area. Furthermore, inlight of the Draft Housing Element report's findings and recomended housing zoning for the EMC, I propose that this highly flawed East Main Street Corridor Ordinance be either entirely overturned, or at a minimum, be amended through the ongoing East Main Street Corridor Study Project, to specifically and correctly exclude those CBD zoned properties between Chapel and Almansor Streets, which properties include those owned by Hillcrest Main Street Associates, LP.

Finally, as noted and recommended in the Draft Alhambra Housing Element Report, the City should exercise all reasonable means available to it in order to consolidate smaller properties, which are suitable for multifamily development, into larger assembled parcels, which can be more properly and efficiently developed with badly

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3 needed housing. Unfortunately, with the loss of Redevelopment in 2012, the City has been without any means, or authority to facilitate the assemblage of smaller parcels for purposes of encouraging and facilitating residential development.

Although the draft report does not make any definitive recommendations as to means by which the City might best undertake this recommended parcel assemblage and housing development program, I highly recommend that Final Housing Element report include a specific recommendation for the establishment of a City controlled Housing Authority, or other legal housing production entity, which would provide the City with the legal and financial means to facilitate the timely and efficient acquisition and consolidation of property suitable for residential development, as well as the ability to facilitate both City sponsored acquisition and development financing of this badly needed housing, and resulting economic uplift created by new housing.

Thank you for your time and consideration of my long-winded observations and recommendations pertaining to the Draft Alhambra Housing Element Report. I welcome any comments from City staff or Councilmembers, and look forward to the completion and certification of the Alhambra Housing Element Final Report, The East Main Street Corridor Plan, and subsequent Alhambra Zoning Code Update.

Regards
Ted Slaught | Lic. #00817465
Senior Managing Director: Charles Dunn Company, Inc.

Managing Member: Hillcrest Development Partners, LLC
Cell: (213) 804-9144 | L #01201641
800 West 6th Street, Suite 600, Los Angeles, CA 90017

Real estate service excellence through knowledge, dedication and teamwork This e-mail message and any attachments are intended solely for the individual or entity to which it is addressed, and is confidential. If the reader of this message and any attachments is not the intended recipient, you are hereby notified that any examination, distribution, or copying of the material is strictly prohibited. If you received this message in error, please notify the sender promptly and delete this message and attachments.

Sent via the Samsung Galaxy Note8, an AT&T 5G Evolution capable smartphone Get Outlook for Androi

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From: David Anderson
To:

Subject:

Date:

Housing Element; Imyles@cityofalhambraorg
Housing Density Alhambra
Wednesday, September 22, 2021 11:21:14 AM
CAUTION: This email originated from outside your organization.

The following are some of the density issues suggested by the Chamber, but I have long felt too much weight has been put on those who advocate NIMBY and wish to return to the 1950's.

Regards, David
I’m a business owner in the City of Alhambra, and I’m asking that you include the following in the City’s final Housing Element submitted to the State:

1. The commercial areas along East Main Street from Almansor to Chapel should be returned to the Central Business District (of which it was originally part) and the housing allowed there should match the CBD.

2. Extend housing allowance on East Main Street easterly to the city border, at a minimum of 30 units/acre, to align with areas west of Granada.

3. We believe higher densities than currently recommended on Valley Blvd. would maximize the available property for housing production. The repeal of the Valley Blvd. Specific Plan to allow for housing density recommendations on Valley Blvd. is a positive first step.

Thank you for your consideration. Denser housing in our commercial corridors will support a strong, local workforce as well as a larger, local customer base - a benefit to the city for decades to come.

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From: Jo"s Garage Inc.

To: Housing Element
Date: Wednesday, September 22, 2021 12:33:51 PM
CAUTION: This email originated from outside your organization.

To whom it may concern,
I’m a business owner in the City of Alhambra, and I’m asking that you include the following in the City’s final Housing Element submitted to the State:

2. Extend housing allowance on East Main Street easterly to the city border, at a minimum of 30 units/acre, to align with areas west of Granada.

Thank you for your time,
--
Javier Mendez
Jo's Garage Inc.
120 E. Valley Blvd. | Alhambra, CA 91801
ph: (626) 872-0705 | fax: (626) 872-0698
www.josgaragecom

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From: Anthony Dedousis
To: Housing Element; Myles, Lauren
Cc: Leonora Camner; Jon Wizard; Henry Fung
Subject: Alhambra housing element - comment letter
Date: Friday, September 24, 2021 2:17:31 PM
Attachments: 210924 Alhambra HE Comment Letter.pdf
CAUTION: This email originated from outside your organization.

Dear Councilmembers and Planning staff:

Hope your week is going well. I'm reaching out to share a letter from Abundant Housing LA and YIMBY Law regarding Alhambra's draft housing element. We applaud the City for undertaking a high-quality, analytical approach to estimating the city's sites inventory and assessing rezoning needs in a way that properly meets the state's guidelines. Nevertheless, our letter expresses major concerns about portions of the City's intended approach to updating the housing element, which we believe must be amended before finalizing the housing element.

The attached letter contains a detailed explanation of where we view the City as having fallen short of HCD's standards and state law.

We request the opportunity to discuss our concerns.

Thank you for your consideration.

Regards,
Anthony
--
Anthony Dedousis
Director, Policy and Research
Abundant Housing LA
515 S Flower Street, 18th Floor
Los Angeles, CA 90071
516-660-7402

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From: Albert Alaan
To: Housing Element; Myles, Lauren
Subject: Alhambra"s Housing Element
Date: Friday, September 24, 2021 10:35:17 AM
CAUTION: This email originated from outside your organization.

I work in the City of Alhambra, and I’m asking that you include the following in the City’s final Housing Element submitted to the State:

2. Extend housing allowance on East Main Street easterly to the city border, at a minimum of 30 units/acre, to align with areas west of Granada.

Best regards,
Albert Alaan

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From: Angela Babcock
To: Housing Element
Subject: Public Comment: Alhambra Housing Element
Date: Friday, September 24, 2021 12:50:12 PM
CAUTION: This email originated from outside your organization.

We’re writing to raise key issues related to the draft Housing Element currently being circulated for review and comment. As we all are aware, the history of housing development in Alhambra has been chronically unaligned with actual needs. It has unfortunately limited growth and excluded people from living in the City.

Today, we have the opportunity to rectify mistakes of the past. Thus, the following are the corrections we request be made to the Draft Housing Element Report:

1. Extend housing allowance on East Main Street easterly to the city border, at a minimum of 30 units/acre, to align with areas west of Granada

2. As the Draft Housing Element accurately recommends with regard to the Valley Blvd.

Specific Plan, the whole East Main Corridor designation should also be repealed. The Housing Element, Zoning Code update, and other studies dictate its future.

3. The commercial areas along East Main Street from Almansor to Chapel, which was formerly part of the CBD, should be returned to it. The housing allowed there should match the CBD, which is 48 units/acre.

4. While we applaud the repeal of the Valley Blvd. Specific Plan to allow for housing

density recommendations on Valley Blvd., we request higher densities than currently recommended on Valley Blvd. to optimize the available property for housing production to meet the local housing supply demand.

We also ask that you include the following assertions in revising the draft Housing Element:

1. Alhambra needs to build housing at all levels, especially Workforce Housing.

We urge you to consider zoning to meet the needs of the market by allowing development that is in the densities and areas noted above. Alhambra lacks sufficient housing for populations that are critical to the city’s growth and future vision as a balanced, liveable community within the region. While Affordable Housing is a central element of this vision, too little attention is paid to those who work in Alhambra, who are not able to qualify for Affordable Housing as it is currently defined.

Thus, it is Workforce Housing that we wish to call your attention to at this time. If this group is overlooked by the City these buyers will be attracted to other cities where

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there is a market-priced residence that they can afford. There is a synergy that results from having these types of new communities since they are typically “walkable” to nearby businesses and community amenities, where the new money is spent.

The outcome typically rewards nearby businesses and provides a lift in appreciation to existing homeowners.

2. The City should include a recommended mechanism in the plan to support the assumptions of assembling parcels to allow for sufficient and actual housing production. Without a legal entity that can assist in the financing and assembly of the parcels, it will be difficult to realize the development goals set forth in the draft plan. We recommend that their created a City-controlled Housing Authority, or other legal housing production entity, which would provide the City with the legal and financial means to facilitate the timely and efficient acquisition and consolidation of property suitable for residential development, as well as the ability to facilitate both City-sponsored acquisition and development financing of this badly needed housing.

3. The City must consider where fees-in-lieu would go. Is the intention to create a City Housing Production office? How can a mechanism be put into place that ensures these funds will be used to support true housing production? (see #2 as a possible solution)

4. The City must avoid displacing families currently in residences. The recommendation to upzone existing multi-family units would displace families and eliminate existing affordable units.

We look forward to working with the City to ensure the draft Housing Element is reflective of Alhambra’s housing needs in the years to come.

Sincerely,
Angela Babcock
Alhambra Main Street Alliance

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From: CEO
To: Housing Element
Subject: Comments on Housing Element
Date: Friday, September 24, 2021 12:21:58 PM
Attachments: Alhambra Chamber Draft Housing Element Letter.pdf CAUTION: This email originated from outside your organization.

Please consider the attached letter as comments on the draft Housing Element. I'm happy to talk with you or answer any questions you might have so we can create more housing in the city.

JOHN
John Bwarie
CEO, Alhambra Chamber of Commerce
626-282-8481 (office)
ceo@alhambrachamberorg
104 South First Street
Alhambra Ca. 91801

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From: Johnson Lin
To: Housing Element
Date: Friday, September 24, 2021 7:58:32 PM
CAUTION: This email originated from outside your organization.

I’m a business owner in the City of Alhambra, and I’m asking that you include the following in the City’s final Housing Element submitted to the State:

2. Extend housing allowance on East Main Street easterly to the city border, at a minimum of 30 units/acre, to align with areas west of Granada.

Johnson S. Lin
Managing Partner,
Lin & Associates
CalBRE #02022997
KW Executive
388 E. Valley Blvd #106
Alhambra, CA 91801
310-753-1719
626-792-2743
tppgroup.kwrealtycom

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From: Alhambra Tenants Union
To: Housing Element
Subject: Draft Housing Element Comments
Date: Sunday, September 26, 2021 7:25:53 PM
CAUTION: This email originated from outside your organization.

To the ECONorthwest Team and the City of Alhambra,
We are writing to comment on the current Draft of the Housing Element for the City of Alhambra.

The stated purpose of the Housing Element is to “ensure that the city establishes policies, procedures, and incentives in its land use planning and development activities that result in the maintenance and expansion of the housing supply to adequately accommodate households currently living and expected to live in Alhambra".

However, as currently
written, the Draft focuses primarily on the issue of expansion of housing supply through private means, and insufficiently on the protection of renters who make up the majority of

those households that the Housing Element is intended to serve.

The Draft Housing Element finds that 60% of renter households experience some form of “housing problem” (i.e. physical defects, overcrowding, housing cost burdens). As such, the Housing Element can and must address strategies to protect renters from displacement caused by exhorbitant or illegal rent increases, illegal evictions, landlord harassment, habitability issues, and loopholes in statewide Just Cause and Rent Stabilization protections.

First, Rent Stabilization and Just Cause Protection Ordinances are currently included in the City’s strategic plan and ought to be considered in the suite of recommended programs.

The authors should look towards the tenant protection policies of cities like Baldwin Park and Culver City as examples for increasing both the types of units and tenants covered, and strengthening existing statewide tenant protections locally.

Second, while “Program 1: Housing Rehabilitation Program” and “Program 2: Code Enforcement'' represent a first step towards addressing habitability issues, the Housing Element should explore protections that prevent landlords from using repairs as a reason to pass on costs to or displace tenants. Furthermore, the report should recommend enforcement options for non-compliant landlords by drawing from programs such as the LA Rent Escrow Account Program (REAP), which allows for the municipality to withhold landlord rents until landlords address habitability violations.

Regarding policies concerning the production of housing, Alhambra’s Inclusionary Housing Ordinance’s (IHO) in-lieu fees per square foot are low a) in comparison to the cost of constructing income-restricted housing and b) in comparison with the policies of neighboring cities like South Pasadena. The Housing Element should provide an analysis

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of and recommendations for addressing the impact of these gaps on the construction of income-restricted housing through the IHO.

Finally, the Housing Element focuses primarily on the production of private housing—both income-restricted and market rate—by incentivizing or reducing costs borne by for-profit and nonprofit developers. However, thus far, the private sector has proven inadequate in meeting the substantial needs outlined by the RHNA recommendations. The City should explore public sector development strategies to enable municipal or County production of housing that would be open to residents of all incomes and allow the City to retain control of and realize returns from its investments. While there are undoubtedly barriers on both the state and federal level to such a strategy, the Housing Element is a long term planning document and should anticipate shifts in funding and priorities. With the federal move towards investment in hard infrastructure, and the introduction of CA Assembly Bill 387 and the H.R. 5244 Homes for All Act in Congress, the City of Alhambra should identify both the opportunities and constraints of financing and utilizing public lands for public sector production of housing.

Please confirm receipt of this letter.

We look forward to hearing your responses to our
concerns and thank you for your efforts thus far.

Sincerely,
The Alhambra Tenants Union

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From: Cliff Bender
To: Housing Element
Subject: [Alhambra HE] Draft Housing Element Comments - new submission Date: Sunday, September 26, 2021 6:11:12 PM
CAUTION: This email originated from outside your organization.

Cliff Bender just submitted your form: Draft Housing Element Comments on Alhambra HE
Message Details:

First Name: Cliff
Last Name: Bender
Email: cbender99@sbcglobalnet
Enter your comments on the Draft Housing Element here. (1,000 characters): General: If the sole purpose of this Housing Element proposal is to demonstrate to the State that Alhambra can meet its RHNA requirements, then it serves its purpose. If, however, the City Leaders were to use this document as a guide to future housing development in the City, Alhambra will cease to be a suburban residential community and become an urban housing center. Whether this type of gentrification over time is viewed as beneficial or harmful to current and future populations is a matter of personal opinion, but regardless of opinion, some of the byproducts of this plan???s implementation will be displacement of many local residents and small businesses, and increased community division, often pitting neighbor against neighbor. The document may show that the city can meet its RHNA requirements, but it leaves much to be desired in providing guidance for reasonable, responsible, and supportive community development.

If you think this submission is spam, report it as spam.

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From: Cliff Bender
To: Housing Element
Subject: [Alhambra HE] Draft Housing Element Comments - new submission Date: Sunday, September 26, 2021 6:12:08 PM
CAUTION: This email originated from outside your organization.

Cliff Bender just submitted your form: Draft Housing Element Comments on Alhambra HE
Message Details:

First Name: Cliff
Last Name: Bender
Email: cbender99@sbcglobalnet
Enter your comments on the Draft Housing Element here. (1,000 characters): Re: Report pg. 78, ???What Can the City of Alhambra Do;??? Reducing parking restrictions and expanded use of waivers will harm small business if they are forced to share limited parking space with larger tenants within their new development. Less parking availability will also create safety problems for residents who will be forced to compete for limited parking on the streets. Reduced parking will only become practicable when safe, clean, efficient and more expansive public transit becomes a viable option to driving.

If you think this submission is spam, report it as spam.

To edit your email settings, go to your Inbox on desktop.

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From: Cliff Bender
To: Housing Element
Subject: [Alhambra HE] Draft Housing Element Comments - new submission Date: Sunday, September 26, 2021 6:12:37 PM
CAUTION: This email originated from outside your organization.

Cliff Bender just submitted your form: Draft Housing Element Comments on Alhambra HE
Message Details:

First Name: Cliff
Last Name: Bender
Email: cbender99@sbcglobalnet
Enter your comments on the Draft Housing Element here. (1,000 characters): Re: Report pg. 94, Constraints Summary; Fees should adequately cover costs, but not generate profits.

If you think this submission is spam, report it as spam.

To edit your email settings, go to your Inbox on desktop.

Page 371 of 886 ends

From: Cliff Bender
To: Housing Element
Subject: [Alhambra HE] Draft Housing Element Comments - new submission Date: Sunday, September 26, 2021 6:13:36 PM
CAUTION: This email originated from outside your organization.

Cliff Bender just submitted your form: Draft Housing Element Comments on Alhambra HE
Message Details:

First Name: Cliff
Last Name: Bender
Email: cbender99@sbcglobalnet
Enter your comments on the Draft Housing Element here. (1,000 characters): Re: Report pg. 150, Program 16: Rezone and Upzone Strategies to Meet RHNA Targets and Buffers; Rezoning/Upzoning of East Main Street, and Valley Blvd. in particular, would displace dozens of small business currently operating in those areas. As lots are assembled and/or developed, rents would be raised by new property owners or buildings demolished to make way for new projects. Few, if any of these small businesses would be able to return, also impacting housing for owners and employees.

If you think this submission is spam, report it as spam.

To edit your email settings, go to your Inbox on desktop.

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From: Cliff Bender
To: Housing Element
Subject: [Alhambra HE] Draft Housing Element Comments - new submission Date: Sunday, September 26, 2021 6:14:45 PM
CAUTION: This email originated from outside your organization.

Cliff Bender just submitted your form: Draft Housing Element Comments on Alhambra HE
Message Details:

First Name: Cliff
Last Name: Bender
Email: cbender99@sbcglobalnet
Enter your comments on the Draft Housing Element here. (1,000 characters): Re: Report pg. 154, Program 25: Housing Production Education Program; ???The city will work with the community to achieve support for housing across income levels.??? How would you propose that the City do this? The community is already aware of the need for housing, but much of the community (the majority?) is simply opposed to sacrificing current residents??? quality of life when they feel that other, less invasive options are available.

If you think this submission is spam, report it as spam.

To edit your email settings, go to your Inbox on desktop.

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From: Cliff Bender
To: Housing Element
Subject: [Alhambra HE] Draft Housing Element Comments - new submission Date: Sunday, September 26, 2021 6:14:52 PM
CAUTION: This email originated from outside your organization.

Cliff Bender just submitted your form: Draft Housing Element Comments on Alhambra HE
Message Details:

First Name: Cliff
Last Name: Bender
Email: cbender99@sbcglobalnet
Enter your comments on the Draft Housing Element here. (1,000 characters): Re: Report pg. 154, Program 24: Reduce Development Constraints for Affordable Housing; I doubt that anyone would disagree with the stated objective to, ???Reduce development constraints for market-rate and affordable housing projects by increasing achievable maximum densities within the zoning code, reducing the total cost of development, or speeding up the development review process,??? however, a thorough and comprehensive review must not be sacrificed.

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From: Cliff Bender
To: Housing Element
Subject: [Alhambra HE] Draft Housing Element Comments - new submission Date: Sunday, September 26, 2021 6:15:35 PM
CAUTION: This email originated from outside your organization.

Cliff Bender just submitted your form: Draft Housing Element Comments on Alhambra HE
Message Details:

First Name: Cliff
Last Name: Bender
Email: cbender99@sbcglobalnet
Enter your comments on the Draft Housing Element here. (1,000 characters): Re: Report pg. 161, Lot Assemblage; ???The City of Alhambra will promote aggressive policies and programs that directly and indirectly facilitate lot assemblage. Program 22 directs the city to play an active role in lot assemblage.??? Is this eminent domain? If you think this submission is spam, report it as spam.

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From: Cliff Bender
To: Housing Element
Subject: [Alhambra HE] Draft Housing Element Comments - new submission Date: Sunday, September 26, 2021 6:17:09 PM
CAUTION: This email originated from outside your organization.

Cliff Bender just submitted your form: Draft Housing Element Comments on Alhambra HE
Message Details:

First Name: Cliff
Last Name: Bender
Email: cbender99@sbcglobalnet
Enter your comments on the Draft Housing Element here. (1,000 characters): Transit: Currently, an ADU located within one-half mile of a public transit stop or station is not required to have a dedicated off- street parking space. In my neighborhood, the Midwick Tract, a number of ADUs have been built over the past few years, with presumably many more to come. Recently, Metro discontinued bus service along Fremont Ave. south of Hellman, leaving the whole western portion of our tract farther than a half-mile to the nearest public transit. Do these units no longer qualify for the parking exemption?
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From: Cliff Bender
To: Housing Element
Subject: [Alhambra HE] Draft Housing Element Comments - new submission Date: Sunday, September 26, 2021 6:17:43 PM
CAUTION: This email originated from outside your organization.

Cliff Bender just submitted your form: Draft Housing Element Comments on Alhambra HE
Message Details:

First Name: Cliff
Last Name: Bender
Email: cbender99@sbcglobalnet
Enter your comments on the Draft Housing Element here. (1,000 characters): Transit: Developments permitted under AB 1763 offer a significant challenge as they have been given a substantial density bonus because of their proximity to a major transit stop. Once the permit has been granted, or after the building is occupied, what happens of Metro decides to relocate the bus line or major transit stop? This case may be more unlikely than with ADUs and their parking qualifications, but nevertheless quite possible. How can the City be expected to provide density bonuses when the ongoing qualification for such a bonus is at the discretion of an outside agency? If you think this submission is spam, report it as spam.

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From: Lewis McCammon
To: Housing Element
Subject: [Alhambra HE] Draft Housing Element Comments - new submission Date: Sunday, September 26, 2021 12:22:08 AM
CAUTION: This email originated from outside your organization.

Lewis McCammon just submitted your form: Draft Housing Element Comments on Alhambra HE
Message Details:

First Name: Lewis
Last Name: McCammon
Email: leweldizamccammon@earthlinknet
Enter your comments on the Draft Housing Element here. (1,000 characters): One typo to remember to correct: In Chapter 7 on p.158 about 25-30% of the way down the page, in section on "Summary of Alhambra's Regional Housing Need" the second sentence should be corrected to read "Among these, approximately 41% [NOT 31%] must be appropriate for lower-income (very low, low) households." [26% very low + 15% low = 41%]. Overall, you have done a great job of assembling a tremendous amount of data in one place and have invested a lot of time especially in the lot-by-lot analysis. The task the state (thru regional entities like SCAG) has placed on us completely disregards (a) the amount of vacant and easily developable space available and (b) other competing possible needs/good uses (such as the Chinatown Service Center's interest in the empty East Main St.

Wondries Nissan dealership building for a major state funded comprehensive senior day care program mostly serving low income seniors), etc.

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From: Lewis McCammon
To: Housing Element
Subject: [Alhambra HE] Draft Housing Element Comments - new submission Date: Sunday, September 26, 2021 11:55:04 PM
CAUTION: This email originated from outside your organization.

Lewis McCammon just submitted your form: Draft Housing Element Comments on Alhambra HE
Message Details:

First Name: Lewis
Last Name: McCammon
Email: leweldizamccammon@earthlinknet
Enter your comments on the Draft Housing Element here. (1,000 characters): Two final suggestions: (1) Build in a plan for a FULL MID TERM (4 year) REVIEW of progress on this Housing Element, especially in regard to (a) meeting the goals on the very low (26%) and low (15%) income categories and moderate income category -- all of which fell far short of the goals for RHNA cycle 5. This review should also look at the interim results on (a) ADUs, (b) the IHO, (c) SB9 and (d) the actual outcome vs.the assumptions on the affordability levels of housing built on the various individual parcels specified in the Draft's Sites Inventory. Then amend the Housing Element if a need is found. (2) Have the City Council assign an existing committee (HCDA?) or create a new committee to focus on housing issues (especially affordable housing) on an ongoing basis and report annually or semi annually to the City Council.

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Lam, Paul
From:

Sent:

To:

Subject:

Shirley Tatsuno <[email protected]>
Sunday, September 26, 2021 11 :00 PM
Housing Element
[Alhambra HE] Draft Housing Element Comments - new submission CAUTION: This email originated from outside your organization.

Shirley Tatsuno just submitted your form: Draft Housing Element Comments on Alhambra_!::!J;;
Message Details:

First Name: Shirley
Last Name: Tatsuno
Email: [email protected]
Enter your comments on the Draft Housing Element here. (1,000 characters): The requirement of 2 parking spaces per unit should not be required especially if the property is near mass transit or if it is an older building and has 1 parking space per unit. I am an owner of an 8 unit older building near Valley Blvd and I have 1 parking space per unit. If God forbid my building was destroyed, for instance, in an earthquake and I had to rebuild right now, I would only be able to build 4 units with at least 8 parking spaces. There are many older apartments in Alhambra. This is unfair and will lead to less housing which is so desperately needed. Please revise this.
you think this submission is spam, report it as spam.

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From: Lewis McCammon
To: Housing Element
Subject: [Alhambra HE] Draft Housing Element Comments - new submission Date: Sunday, September 26, 2021 11:55:59 PM
CAUTION: This email originated from outside your organization.

Lewis McCammon just submitted your form: Draft Housing Element Comments on Alhambra HE
Message Details:

First Name: Lewis
Last Name: McCammon
Email: leweldizamccammon@earthlinknet
Enter your comments on the Draft Housing Element here. (1,000 characters): ( I hope this is going thru.) Two final suggestions: (1) Build in a plan for a FULL MID TERM (4 year) REVIEW of progress on this Housing Element, especially in regard to (a) meeting the goals on the very low (26%) and low (15%) income categories and moderate income category -- all of which fell far short of the goals for RHNA cycle 5. This review should also look at the interim results on (a) ADUs, (b) the IHO, (c) SB9 and (d) the actual outcome vs.the assumptions on the affordability levels of housing built on the various individual parcels specified in the Draft's Sites Inventory. Then amend the Housing Element if a need is found. (2) Have the City Council assign an existing committee (HCDA?) or create a new committee to focus on housing issues (especially affordable housing) on an ongoing basis and report annually or semi annually to the City Council.

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ATTACHMENT 10

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October 15, 2020
Mayor David Mejia
City of Alhambra
111 South First Street
Alhambra, CA 91801
Dear Mayor Mejia,
We are writing on behalf ofAbundant Housing LAregarding Alhambra’s upcoming 6th Cycle housing element update. Abundant Housing LA is a pro-housing education and advocacy organization working to help solve Southern California’s housing crisis. We support efforts to reform zoning codes and expand housing production, which are needed to reduce rents, improve access to jobs and transit, strengthen the local economy and job market, and combat segregation. We have a large and growing membership base throughout Los Angeles County, including Alhambra.

California has a statewide housing shortage of nearly 3.5 million homes, andhas the highest poverty rate in the nationafter accounting for housing costs. Households at all levels of income face a historically high rent burden. Exclusionary zoning and longstanding constraints on denser housing have led to an undersupply of medium and high density housing near jobs and transit.

This contributes to high rents and displacement of households.

Over the past few years, new state laws (e.g. AB 686 (2018), SB 166 (2017), AB 1397 (2017), SB 828 (2018), SB 35 (2017), etc.) have strengthened the Regional Housing Needs Assessment (RHNA), which sets a housing growth target for individual jurisdictions and requires jurisdictions to update their housing elements in order to achieve these targets.

These changes to state law have led to historically high jurisdiction-level housing growth targets in the upcoming 6th Cycle Housing Element Planning Cycle, and have empowered the state Department of Housing and Community Development (HCD) to enforce appropriately high standards for housing element updates. We are encouraged that Alhambra was given a target of 6,810 new homes, of which 2,802 must be affordable to lower-income households.

As jurisdictions start the housing element update process, AHLA seeks to provide guidance on how jurisdictions should fulfill both the letter and the spirit of housing element law. Unfortunately, some jurisdictions are already seeking to skirt their obligation to sufficiently plan to meet their housing needs. AHLA will scrutinize jurisdictions’ housing elements, submit comments to HCD as needed, and collaborate closely with nonprofits that bring legal action against jurisdictions that fail to comply with state housing laws.

Of course, AHLA recognizes that the COVID-19 pandemic and resulting economic devastation have made it more difficult for jurisdictions to meet ambitious RHNA targets. But the pandemic 1

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has made it even more critical than ever for jurisdictions to solve the region’s housing crisis and encourage economic recovery. We seek to collaborate with you and your team on policy efforts to achieve the RHNA goals.

To that end, we have published a memo,Requirements and Best Practices for Housing Element Updates: The Site Inventory, explaining the key legal requirements, as well as HCD and AHLA’s recommended best practices, for housing element updates. Additionally, this checklist provides a summary of our core policy recommendations . We respectfully encourage you to incorporate the concepts detailed in these documents into Alhambra’s housing element update.

As your team begins to develop Alhambra’s housing element update, we would like to draw particular attention to four critical components of the site inventory analysis:

1. Incorporating an estimate of thelikelihood of developmentand the net new units if developed of inventory sites

2. Using an HCD-recommended “safe harbor” methodology forforecasting future ADU production

3. Prioritizing high-opportunity census tracts and well-resourced areas (e.g. near transit, jobs, schools, parks, etc.) when selecting sites for lower-income housing opportunities, in order to affirmatively further fair housing

4. Including the HCD-recommended buffer of at least 15-30% extra capacity in the site inventory, in order to avoid violating the No Net Loss requirement Component #1 : Housing elements should estimate and report both the likelihood of development and the net new units if developed of inventory sites.

Just because jurisdictions zone for more housing doesn’t mean that the housing will actually be built. The economic cycle, uncertainty of market conditions, the current usage of nonvacant sites, and land use regulations all influence the extent to which rezoned parcels are built to their maximum theoretical capacity.

A parcel’s maximum theoretical capacity is not the same as its realistic capacity. To draw a parallel to college admissions, when UCLA wants 2,000 students in its incoming class, they admit 4,000 students. Similarly, to achieve housing production targets, jurisdictions must increase zoned capacity well above the target number of new homes.

An accurate assessment of site capacity is necessary in order for the housing element to achieve sufficient housing production. The site capacity estimate should account for the following two factors:
● What is the likelihood that the site will be developed during the planning period? 2

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● If the site were to be developed during the planning period, how many net new units of housing are likely to be built on it?
These are the likelihood of development and net new units if developed factors, as 1 2 required by HCD guidelines. The portion of the jurisdiction’s RHNA target that a site will realistically accommodate during the planning period is:
(likelihood of development) x (net new units if developed) = realistic capacity.

In past planning cycles, the likelihood of development factor was not expressly considered; housing elements frequently assumed that most or all site inventory locations would be redeveloped to their maximum theoretical capacity. Since this generally did not happen, jurisdictions consistently fell short of their RHNA targets as a result. This is the case for Alhambra, which is not on a path to achieving its 5th cycle RHNA targets for very low, low, and moderate income housing. Through 2019, it has permitted 5 homes that are affordable at these income levels, out of a total RHNA target of 850 homes. 5th Cycle RHNA Targets vs. Actual Housing Production (2014-19) Income Bucket RHNA Target Homes Permitted
VLI 380 0
LI 224 2
MI 246 3
AMI 642 279
Total 1,492 284
According to Alhambra’s 5th cycle housing element, the city had theoretical capacity for 1,498 more housing units. Through 2019, Alhambra permitted 284 housing units , which equates to 3 4 379 housing units permitted by the end of the 5th cycle (assuming that the same annual permitting pace continues in 2020 and 2021). This implies that in Alhambra, excess zoned capacity has a 25% likelihood of being developed (379 actual units divided by 1,498 theoretical units).

Alhambra’s 6th cycle housing element should incorporate this likelihood of development estimate into its site inventory analysis. This would be consistent with HCD guidelines,while 5 also ensuring that enough zoned capacity is available to encourage 6,810 housing units to be 1 HCD Site Inventory Guidebook, pg. 20
2 HCD Site Inventory Guidebook, pg. 21
3 Alhambra 5th Cycle Housing Element, pg. 75
4 HCD Annual Progress Report dataset, 2020
5 HCD Site Inventory Guidebook, pg. 20
3

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built by the end of the 6th cycle. Assuming that zoned capacity has a 25% likelihood of being developed in the next 8 years,the housing element must allow for 27,240 units of zoned capacity in order to achieve 6,810 actual housing units.If Planning believes that a higher likelihood of development (and thus a smaller zoned capacity increase) is justified for certain parcels in the site inventory, persuasive data to support this assumption must be provided. 6 Component #2: Housing element updates should use an HCD-recommended “safe harbor” methodology for forecasting future ADU production.

Local jurisdictions frequently use overly optimistic estimates of future ADU production to avoid necessary housing reform and rezoning. ADU development estimates must reflect actual on-the-ground conditions to ensure that they are realistic. Overly aggressive ADU production estimates set jurisdictions up for failure in providing the required housing for residents.

To that end, HCD has established two safe harbors for forecasting ADU production during the 6th Cycle . One option (“Option #1”) is to project forward the local trend in ADU construction 7 since January 2018. The other, for use when no other data is available (“Option #2”), assumes ADU production at five times the local rate of production prior to 2018. Jurisdictions are also permitted to include programs that aggressively promote and incentivize ADU construction.

Where no other data is available, jurisdictions may assume an average increase of five times the previous planning period construction trends prior to 2018. Jurisdictions may also use regional ADU production trends, and include programs that aggressively promote and incentivize ADU construction. Jurisdictions should clearly and explicitly state their methodology and data sources for future ADU development forecasts.

According to HCD, Alhambra issued permits for 0 ADUs in 2017, 7 ADUs in 2018, and 0 ADUs in 2019. Under HCD’s “Option #1”, Alhambra could take the average of the 2018 and 2019 ADU production trends, and forecast that 3.5 ADUs will be permitted per year during the 6th cycle.

This would allow for a total 6th cycle forecast of 28 ADUs.

Under HCD’s “Option #2”, Alhambra could multiply the 2017 ADU production trend by five, and forecast that 0 ADUs will be permitted per year during the 6th cycle. This would allow for atotal 6th cycle forecast of 0 ADUs.Abundant Housing LA does not recommend this methodology, since based on the ADU permit totals in 2018, it is extremely unlikely thatno ADUs would be permitted between 2021 and 2029.

Another, more aggressive, option would take the average of the 2018 and 2019 ADU production trends, and multiply that average by five. This methodology would forecast that 18 ADUs will be permitted per year during the 6th cycle. This would allow for atotal 6th cycle forecast of 140 6 HCD Site Inventory Guidebook, pg. 20-21
7 HCD Site Inventory Guidebook, pg. 31
4

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ADUs. Abundant Housing LA does not recommend this methodology, since it is not an HCD-defined safe harbor forecasting option.

Alhambra should use HCD’s Option 1 safe harbor when projecting annual ADU production. If it believes that higher ADU production forecasts are warranted, it must provide well-grounded estimates, based on the pace of ADU production in neighboring jurisdictions, and must explain programs or policy efforts that could lead to higher ADU production.

Finally, per HCD, the housing element “should also include a monitoring program that a) tracks ADU and JADU creation and affordability levels, and b) commits to a review at the planning cycle midpoint to evaluate if production estimates are being achieved.” Alhambra’s housing 8 element should commit to mid-cycle rezoning if ADU production is lower than forecasted, and its midpoint review should be linked with immediate and automatic programs to increase housing production in the second half of the RHNA cycle. AHLA’s recommended approach is to incorporate by-right density bonuses on inventory sites, which would automatically take effect mid-cycle if the ADU target is not met. The density bonus should be large enough, and apply to enough parcels, to fully make up for any ADU production shortfall.

Component #3 : Housing elements must prioritize high-opportunity census tracts and well-resourced areas (e.g. near transit, jobs, schools, parks, etc.) when selecting sites for lower-income housing opportunities, in order to affirmatively further fair housing.

AB 686 (2018) requires housing element updates to “affirmatively further fair housing”, which is defined as “taking meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and fosters inclusive communities free from barriers that restrict access to opportunity based on protected characteristics.”
Alhambra’s history details examples of how housing policy and land use regulations were once used to exclude members of minority groups. Redlining and restrictive covenants, which restricted where Black Americans could live, were once commonplace. Thankfully, Alhambra is much more welcoming today; 50% of the city’s population is Asian-American, and 38% of the city’s population is Hispanic . However, exclusion continues on the basis of income: the median 9 home sale price in Alhambra was $641,250 in 2018 , and 53% of the city’s renters are 10 “rent-burdened” (i.e. they spend more than 30% of their income on rent) . High housing costs 11 place a disproportionate burden on lower-income communities of color, and have the effect of excluding them from the city altogether.
8 HCD Site Inventory Guidebook, pg. 31
9 American Community Survey, 2014-18
10 SCAG Pre-Certified Local Housing Data, Alhambra
11 American Community Survey, 2014-18
5

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Jurisdictions must address this issue by accommodating the lower-income RHNA targets in a way that conforms with AFFH requirements. HCD’s Site Inventory Guidebook offers recommendations for how jurisdictions should accomplish this. HCD is likely to require jurisdictions to distribute lower-income housing opportunities throughout the jurisdiction, and recommends that jurisdictions first identify development potential for lower-income housing in high-opportunity neighborhoods . 12 Given that single-family, exclusionary zoning predominates in many of Alhambra’s high-opportunity census tracts (as defined in the TCAC/HCD Opportunity Map), rezoning is required in order to accommodate the RHNA targets for lower-income households. Additionally, focusing rezoning in single-family zoned areas will expand housing opportunities while minimizing the impact on existing renters in multifamily-zoned areas.

In order to fairly distribute housing opportunities citywide, Alhambra should develop a quantitative methodology for scoring neighborhoods, based on factors like housing costs, median income, access to transit, access to jobs, access to schools, and environmental quality.

Neighborhoods that score higher on these dimensions should be allocated higher housing growth targets, and rezoning should be based on these neighborhood-level housing growth targets.

Finally, Alhambra should identify funding sources, public resources, and density bonus programs to maximize the likelihood that housing projects with below market-rate units are actually built. Local measures like areal estate transfer taxand congestion pricingcould help generate new funding to support affordable housing production and preservation.

Component #4: Housing elements should include the HCD-recommended buffer of at least 15-30% extra capacity in the site inventory, in order to avoid violating the No Net Loss requirement.

SB 166 (2017) requires adequate sites to be maintainedat all timesthroughout the planning period to accommodate the remaining RHNA target by each income category. This means that 13 if a jurisdiction approves a development on a parcel listed in the site inventory that will have fewer units (either in total or at a given income level) than the number of units (either in total or at a given income level) anticipated in the site inventory, then the jurisdiction must identify and make available enough sites to accommodate the remaining unmet RHNA target for each income category. 14
If additional sites with adequate zoned capacity don’t exist, then the jurisdiction must rezone enough sites to accommodate the remaining unmet RHNA target within 180 days. If the 12 HCD Site Inventory Guidebook, pg. 3
13 HCD No Net Loss Law Memo, pg. 1
14 HCD Site Inventory Guidebook, pg. 22
6

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jurisdiction fails to accomplish this rezoning in the required period, then the consequences will include decertification of the housing element and potential state legal action.

To ensure that adequate housing capacity at all income levels exists in the housing element through the 6th Cycle, HCD recommends that “the jurisdiction create a buffer in the housing element inventory of at least 15-30% more capacity than required, especially for capacity to accommodate the lower income RHNA.” Alhambra should “overshoot” on total site 15 capacity for each income level, in order to ensure that the City’s RHNA target is achieved at all income levels.

The City of Alhambra has an obligation to sufficiently plan to meet current and future residents’ housing needs. The housing element update affords Alhambra, and the broader Southern California region, the chance to take bold action on lowering housing costs, reducing car dependency, strengthening the local economy, and guaranteeing access to opportunity for Californians of all racial and ethnic backgrounds. We urge you and your colleagues to fully embrace this opportunity to transform Alhambra for the better.

Finally, it is worth noting that state law imposes penalties on jurisdictions that fail to adopt a compliant 6th cycle housing element update by October 15, 2021. On that date, noncompliant jurisdictions will forfeit the right to deny residential projects on the basis of local zoning, so long as projects include at least a 20% set-aside for below market-rate units . Jurisdictions that want 16 to maintain local control over new development should therefore plan to adopt a compliant housing element update on time.

We would be glad to engage with your office and with the Planning Department throughout the housing element update process. We look forward to a productive and collaborative working relationship with the City of Alhambra on this critical effort. Thank you for your consideration.

Sincerely,
Leonora Camner
Executive Director
Abundant Housing LA
Anthony Dedousis
Director of Policy and Research
Abundant Housing LA
15 HCD Site Inventory Guidebook, pg. 22
16 California Government Code 65589.5(d)(5)
7

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1 Reynoso, Vanessa
From: Susan Saunders <[email protected]>
Sent: Sunday, March 14, 2021 3:16 PM
To: Housing Element
Subject: Comments
Follow Up Flag: Follow up
Flag Status: Flagged
CAUTION: This email originated from outside your organization.

Why build up? It’s ugly and we need family places for entertainment and youth activities‐ green spaces! Please do not destroy the Mountain View’s for the sake of profits and money‐ go elsewhere! Sent from my iPhone

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Dear ECONorthwest,
I have spent many months wondering, how to fairly re-zone for 6,808 housing units in Alhambra and still retain a homey feeling? All five districts must contribute housing units. Historical homes should definitely be saved. Let us learn from out past mistakes of a mish mash of different housing units that do not line up in the front like many R2 and R3 areas in Alhambra. I would prefer that housing even mixed use would be 2 stories high but I fear this is not realistic.

These are my thoughts.

Low density residential areas (Red areas)

1. Low density residential areas should be allowed to build Accessory Dwelling Units and the city should make it as easy as possible and not add unnecessary requirements.

2. Per Councilman Maza, he said 4 units are a possibility. This includes the original house, garage, expanding the main house in the back and a free-standing house in the backyard.

This should be allowed if there is enough land.

3. Recently, I recently read an LA Times article about LA wanting to encourage free standing ADU options for low or moderate-income tenants. They have an innovative, eclectic list of approved housing units which can be approved over the counter. They are often more affordable than market-rate housing produced by developers. Alhambra should look into this.

3. I think small, attractive 2 to 4-unit buildings that line up with the other homes should be allowed. For example, on 4
th Street north of Valley Blvd. there is a 3 unit (1201 S. 4th) and a duplex (1144 /1146 S. 4th ) that blend beautifully in that single home neighborhood. Why can’t that be allowed in other single home neighborhoods? Medium-density areas_R2 (Gold areas)

1. It seems inevitable that they would become R3 or denser. However, I would like to see only 2 story buildings and if there is a front lawn that should remain.

2. If there are still homes that remain on that block, the multi-units should line up with the other homes.

3. Up-zoning in the Fremont corridor needs to be well thought. The large Ratkovich development is likely to be built and this only will add to the nightmare traffic in this area.

Downtown Core (Dark Blue)

1. This is already a dense area. I would hate to see buildings taller than 2 stories except Main Street. Hopefully not taller than 3-4 story high.

Existing Corridors (Light Blue) We live in this area.

1. My husband and I own a 2-story apartment on 5
th Street just behind the Valley Blvd.
commercial buildings. The commercial lots are very narrow. Hopefully a 3-4 story building in front of us also blocking my Valley Blvd. view, wil
l not be built. However, on the bigger lots I
can see 3-4 story mix-use buildings being built.

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Upzone Exi
sting High-Density Residential areas? (Green). I live in that area.

1. I absolutely do not think the high-density residential area should be up-zoned. We should be able to have lawns like the R1 areas. Although I am wondering if the parking requirement could be reduced to one for some units. We own an older apartment with 8 units but we only have 8 parking spaces. Only 3 units need 2 cars spaces. This may become more common in the future. With a reduction in parking spaces maybe an extra unit or two can be built depending on the situation.

2. In the area south of Huntington and east of the Old Twohey’s there are a lot of 1-4 story multi-units with a little front yard. I do not want our dense areas (R3) to look like this. I like areas with homes and multiple units that are 1-2 stories high. Glendon Way from Garfield and Atlantic, where I used to live, is like this.

3. I offer my residential block on 5
th Street and Valley Blvd as a good example of what I would like to see. 9 of the 11 properties have lawns. Children play there and I love that we have green spaces like the R1 areas. 8 of the properties also line up in the front which looks good.

Housing in areas where it is not currently allowed (Red)

1. I would like to see mixed use in the area that is designated the “entertainment area” from Almansor to New Avenue on Valley Blvd. Again, I hope it is not taller than 4 stories. There is a lot of room to build because the lots are big.

2. I would love to see a Children’s Museum, rock climbing, water fun areas etc. in this area.

3. Garfield is such a noisy street. I would hate to see buildings so close to the street. The multi housing complexes have lawns which helps buffer it a bit.

4. I think the East Main Street Corridor is a good place for mix use housing.

5. I do not know about the 2 red oval areas for housing. It is so close to the Fremont Corridor.

This will just add to the horrible traffic problem they already have. Good mass transportation is a must.

ALMANSOR GOLF COURSE

1. This absolutely must be considered. It is such a large open piece of land which benefits only a few people. In the golf presentation by the consultant a few years ago, he said many cities were closing golf courses and building homes on them because the need it so great.

We have also come to this point. The golf course also does not make a lot of money.

2. All the new large Alhambra housing developments I have seen have few green spaces that the residents/children can enjoy. If a housing development was built here, I hope there would have such areas. There should be a green space(s) for the public also. Of course, the trees should be saved as much as possible.

I hope we can avoid in the dense residential areas, blocks and blocks of 2-4 story multi-unit buildings with very little green space. Mix use is good for the commercial areas. I know the city is working on it but excellent mass transportation is a must.

Thank you,

Shirley Tatsuno

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1 Reynoso, Vanessa
From: Lewis McCammon <[email protected]>
Sent: Sunday, March 14, 2021 11:58 PM
To: Housing Element
Subject: The Golf Course site as possible housing
CAUTION: This email originated from outside your organization.

Earlier today I completed the Housing Element survey. In doing so I included a significant suggestion beyond those previously considered in the Housing Element study -- namely considering the repurposing all or
part of the city owned Golf Course site for housing -- especially affordable housing.

Please add the Golf Course to the list of the regions of the city to be considered for possible housing where it is not currently allowed (in addition to the other 4 areas already shown on one of the presentation's "Where and How?" slides -- namely the industrial area, much of the Garfield corridor, the East Main corridor, and much of the Valley corridor already mentioned in your survey).

BACKGROUND: As consultant ECONorthwest's study has noted, up until a bout a year ago the outlook on affordable housing in Alhambra was bleak. During the first 6 1/3 years of RHNA Cycle 5 (the period from Oct. 2013 thru the end of 2019) large private developers had produced in Alhambra hundreds of “above moderate income” housing units (often termed “luxury” or “market rate”) while producing exactly ZERO housing units at the very low income level.

The City Council made excellent progress on Affordable Housing in two ways during the past year, first with adoption of the Inclusionary Housing Ordinance and second by moving forward with two very affordable housing projects now underway totaling about 100 units which include the family sized units and units at the “very low” income level that are so badly needed. But these latter two projects were really possible only because THE CITY OWNED THE LAND – namely two surface parking lots -- and because City leaders were willing to repurpose them.

But the City is now OUT of city owned parking lots to develop for affordable housing. So, WHERE DO WE GO FROM HERE?

SUGGESTION: Take a serious close look at the 18 hole ALHAMBRA GOLF COURSE. Is a golf course the best possible use of this big chunk of city owned land? Would part or all of this land be

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2 better used for affordable housing and/or for more free public park space? To a degree this is an issue of needs and priorities.

Consider the following:

The Alhambra Golf Course largely duplicates nearby public golf courses nearby. There are four other municipally owned or otherwise public golf courses that are only 3 to 4 miles distant from our golf course:
(1) the Arroyo Seco one in South Pasadena and those in
(2) Monterey Park,
(3) Montebello and
(4) the Whittier Narrows Golf Course.

Within an additional 3 mile radius you can find five mo re municipally owned or otherwise public golf courses:
(5) Brookside in Pasadena
(6) Eaton Canyon in Pasadena and those in
(7) Altadena
(8) Santa Anita and
(9) Arcadia's Par 3 golf course.

And the above list does not even include nearby private golf courses like the San Gabriel Country Club only 1.5 miles away just north of Las Tunas Dr.

Alhambra golfers would still have many conveniently nearby golf courses to choose from, whether our Alhambra course was reduced to 9 holes or even completely repurposed.

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3 I remember that Alhambra Golf Course being there in the 1950's when I lived very near by just 5 houses south of Martha Baldwin School. At that time there was a lot of vacant land in the city. The three large city blocks between E. Shorb St and E. Valley Bl. from Almansor St. all the way to the San Gabriel City border except for Crawford's store on New Av. were vacant land filled with weeds. South of that was the huge area with the remains of the old Alhambra Airport, etc.

Back in those days, I remember many houses putting in swimming pools in their back yards and every city seemed to want its own golf course. Well, times have changed. If (a) substantial space for affordable housing the the need now and (b) there are convenient alternatives places nearby to play golf nearby and (c) the city is "built out" (City Manager Jessica Binnquist's term in her letter to SCAG), and (d) the Golf Course is CITY OWNED LAND (now a scarce commodity), then we should at least take a look at possibly repurposing all or part of the Golf Course.

If all or part of the Golf Course were to be repurposed for housing (and possibly additional park space), I would hope that it could be done in a way that retains the mature trees to the maximum extent possible.

It may turn out that repurposing all or part of the golf course is unworkable or not even a good idea, but we will only know that if we look at it.

Lewis McCammon
105 N. Cordova St.

Alhambra, CA 91801-2708
(626) 363-3516
[email protected]

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1 Reynoso, Vanessa
From: Paul Talbot <[email protected]>
Sent: Friday, June 4, 2021 12:09 PM
To: Housing Element
Subject: Comments on the Housing Element
CAUTION: This email originated from outside your organization.

For the past thirty years I have supported a reasoned and thoughtful approach to housing development in Alhambra and the other communities in which I have served. In the 90’s we down zoned many neighborhoods at the bequest of our residents, moving R-3’s to R-2’s and R-2’s to R-1’s. In the 2000’s we approved mixed use projects in high density and high traffic areas that tried to address our responsibility to our community and to our region. While some approved of these changes, others disagreed. The 1990’s and the 2000’s were very different times than today. The need for more appropriate housing could not be more pressing than it is right now.

In the former Regional Housing Needs Assessment (2014-2021) it indicated that Alhambra’s “fair share” was almost 1500 units. The new round through 2029 is almost 7000. This just speaks to the need that all of the cities throughout L.A. County are facing. I hope Alhambra doesn’t take the same position that some of our neighboring cities are, by completely ignoring the need and trying to litigate. No one city is more special than others and no section of the City is more special than others. We are all in this together! The plan to address more housing needs to be citywide and not piecemealed into special parts of the community.

While some may want to curtail development altogether, I don’t think Alhambra can take that position. As an Alhambran, a Californian, an American, it is all of our duties to share the burden and the blessing of properly caring for our community and our neighbors. Housing is one of the most essential responsibilities we must provide. If we do not address Alhambra’s responsibilities, then Sacramento will. That is not a position we ever want to get into. When we talk about housing, we need to be talking about all forms of housing, inclusive of; market rate, work force, low income, senior, veterans, homeless, etc. We must provide all forms of housing to make our community a great place to live.

As an Economics graduate from UCLA, the first lesson I learned was about “supply and demand”. Without increasing the supply of housing in Alhambra, the natural outcome will be more expensive neighborhoods and less families that can afford to live in our community. This would be terribly detrimental to our schools, parks, libraries and businesses. In recent years our school district has been challenged by declining enrollment. This hurts each and every student in the Alhambra Unified School District. Our community must grow and progress if our community is to succeed and thrive. You’ve seen the outcry of many of our neighboring communities when their School District’s were forced to close local elementary schools due to declining enrollment. I would hate to see that happen to Fremont Elementary, or Emery Park School, or Park Elementary.

I am completing my sixth decade as a lifelong resident here in Alhambra. I’m born and raised here and am never moving out. I certainly have seen much change over those decades, but Alhambra has adapted to the change gracefully in the past and I am hopeful it will be just as gracious to our future.

The City Council is tasked with the challenge and the burden of overseeing the proper care of our community.

I urge you to be thoughtful and deliberate as you not only consider this Housing Element, but also the appropriate Zoning changes to come. It is your responsibility to look out for Alhambra’s future. This includes both today’s residents, as well as the many generations who too will call themselves Alhambrans.

Sincerely,
Paul L. Talbot

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P: (626) 381-9248
F: (626) 389-5414
E: info@mitchtsailawcom
Mitchell M. Tsai
Attorney At Law
139 South Hudson Avenue
Suite 200
Pasadena, California 91101

VIA E-MAIL
September 27, 2021
City of Alhambra
Community Development Department
111 South First Street
Alhambra, CA 91801
Em: housingelement@city
ofalhambraorg
RE: 2021-2029 Housing Element Update
To Whom it May Concern,
On behalf of the Southwest Regional Council of Carpenters (“Commenter” or “Carpenter”), my Office is submitting these comments on the City of Alhambra’s (“City”) Draft 2021-2029 Housing Element Update (“Project”).

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.

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City of Alhambra – Housing Element Update
September 23, 2021

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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.

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City of Alhambra – Housing Element Update
September 23, 2021

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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.

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

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City of Alhambra – Housing Element Update
September 23, 2021

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achieve a more positive jobs-housing balance, and reduce regional commuting, gas consumption, and greenhouse gas emissions.”3
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:

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. 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.

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City of Alhambra – Housing Element Update
September 23, 2021

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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 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.

Sincerely,

______________________
Mitchell M. Tsai
Attorneys for Southwest Regional
Council of Carpenters
Attached:

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EXHIBIT A

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1 2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
mhagemann@swapecom
Paul E. Rosenfeld, PhD
(310) 795-2335
prosenfeld@swapecom
March 8, 2021
Mitchell M. Tsai
155 South El Molino, Suite 104
Pasadena, CA 91101
Subject: Local Hire Requirements and Considerations for Greenh ouse 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.

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/default- source/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 34.

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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.

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.7 In 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 project- specific 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/default- source/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/default- source/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/default- source/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/default- source/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.

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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.9 Furthermore, 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/default- source/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-a2 016-3-2.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-a2 016-3-2.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/default- source/caleemod/05_appendix-d2016-3-2.pdf?sfvrsn=4, p. D-84 – D-86.

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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.

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).

14 “Appendix D Default Data Tables.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/05_appendix-d2016-3-2.pdf?sfvrsn=4, p. D-85.

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5

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.

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EXHIBIT B

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SOIL WATER AIR PROTECTION ENTERPRISE
2656 29th Street, Suite 201
Santa Monica, California 90405
Attn: Paul Rosenfeld, Ph.D.

Mobil: (310) 795-2335
Office: (310) 452-5555
Fax: (310) 452-5550
Email: prosenfeld@swapecom
Paul E. Rosenfeld, Ph.D. Page 1 of 10 June 2019
Paul Rosenfeld, Ph.D. Chemi cal Fate and Transport & Air Dispersion Modeling Principal Environmental Chemist Risk Assessment & Remediation Specialist Education
Ph.D. Soil Chemistry, University of Washington, 1999. Dissertation on volatile organic compound filtration.

M.S. Environmental Science, U.C. Berkeley, 1995. Thesis on organic waste economics.

B.A. Environmental Studies, U.C. Santa Barbara, 1991. Thesis on wastewater treatment.

Professional Experience
Dr. Ro sen
feld has over 25 years’ experience conducting environmental investigations and risk assessments for evaluating impacts to human health, property, and ecological receptors. His expertise focuses on the fate and transport of environmental contaminants, human health risk, exposure assessment, and ecological restoration. Dr.

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Paul E. Rosenfeld, Ph.D. Page 2 of 10 June 2019

Professional History:

Soil Water Air Protection Enterprise (SWAPE); 2003 to present; Principal and Founding Partner UCLA School of Public Health; 2007 to 2011; Lecturer (Assistant Researcher) UCLA School of Public Health; 2003 to 2006; Adjunct Professor UCLA Environmental Science and Engineering Program; 2002-2004; Doctoral Intern Coordinator UCLA Institute of the Environment, 2001-2002; Research Associat e Komex H
2O Science, 2001 to 2003; Senior Remediation Scientist
National Groundwater Association, 2002-2004; Lecturer
San Diego State University, 1999-2001; Adjunct Professor Anteon Corp., San Diego, 2000-2001; Remediation Project Manager Ogden (now Amec), San Diego, 2000-2000; Remediation Project Man ager Bechtel, San Diego, California, 1999 – 2000; Risk Assessor King County, Seattle, 1996 – 1999; Scientist
James River Corp., Washington, 1995-96; Scientist
Big Creek Lumber, Davenport, California, 1995; Scientist Plumas Corp., California and USFS, Tahoe 1993-1995; Scientist Peace Corps and World Wildlife Fund, St. Kitts, West Indies, 1991-1993; Scientist

Publications:

Remy, L.L., Clay T., Byers, V., Rosenfeld P. E. (2019) Hospital, Health, and Community Burden After Oil Refinery Fires, Richmond, California 2007 and 2012. Environmental Health. 18:48

Simons, R.A., Seo, Y. Rosenfeld, P., (2015) Modeling the Effect of Refinery Emission On Residential Property Value. Journal of Real Estate Research. 27(3):321-342

Chen, J. A, Zapata A. R., Sutherland A. J., Molmen, D.R., Chow, B. S., Wu, L. E., Rosenfeld, P. E., Hesse, R. C., (2012) Sulfur Dioxide and Volatile Organic Compound Exposure To A Community In Texas City Texas Evaluated Using Aermod and Empirical Data. American Journal of Environmental Science , 8(6), 622-632.

Rosenfeld, P.E. & Feng, L. (2011). The Risks of Hazardous Waste. Amsterdam: Elsevier Publishing.

Cheremisinoff, N.P., & Rosenfeld, P.E. (2011). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Agrochemical Industry, Amsterdam: Elsevier Publishing.

Procedia Environmental Sciences. 113–125.

Cheremisinoff, N.P., & Rosenfeld, P.E. (2010). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Wood and Paper Industries. Amsterdam: Elsevier Publishing.

Cheremisinoff, N.P., & Rosenfeld, P.E. (2009). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Petroleum Industry. Amsterdam: Elsevier Publishing.

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Paul E. Rosenfeld, Ph.D. Page 3 of 10 June 2019

Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). A Statistical Analysis Of Attic Dust And Blood Lipid Concentrations Of Tetrachloro-p-Dibenzodioxin (TCDD) Toxicity Equivalency Quotients (TEQ) In Two Populations Near Wood Treatment Facilities. Organohalogen Compounds, 70, 002252-002255.

Hensley, A.R. A. Scott, J. J. J. Clark, Rosenfeld, P.E. (2007). Attic Dust and Human Blood Samples Collected near a Former Wood Treatment Facility. Environmental Research. 105, 194-197.

Rosenfeld, P. E., M. Suffet. (2007). The Anatomy Of Odour Wheels For Odours Of Drinking Water, Wastewater, Compost And The Urban Environment. Water Science & Technology 55(5), 335-344.

Sullivan, P. J. Clark, J.J.J., Agardy, F. J., Rosenfeld, P.E. (2007). Toxic Legacy, Synthetic Toxins in the Food, Water, and Air in American Cities. Boston Massachusetts: Elsevier Publishing

Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash. Water Science and Technology. 49(9),171-178.

Rosenfeld, P.E., and Suffet, I.H. (2004). Understanding Odorants Associated With Compost, Biomass Facilities, and the Land Application of Biosolids. Water Science and Technology. 49(9), 193-199.

Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash, Water Science and Technology, 49( 9), 171-178.

Rosenfeld, P. E ., Grey, M. A., Sellew, P. (2004). Measurement of Biosolids Odor and Odorant Emissions from Windrows, Static Pile and Biofilter. Water Environment Research. 76(4), 310-315.

Rosenfeld, P.E., Grey, M and Suffet, M. (2002). Compost Demonstration Project, Sacramento California Using High-Carbon Wood As h to Control Odor at a Green Materials Composting Facility. Integrated Waste Management Board Public Affairs Office, Publications Clearinghouse (MS–6), Sacramento, CA Publication #442-02-008.

Rosenfeld, P.E., and C.L. Henry. (2001). Characterization of odor emissions from three different biosolids. Water Soil and Air Pollution. 127(1-4), 173-191.

Rosenfeld, P.E., and Henry C. L., (2000). Wood ash control of odor emissions from biosolids application. Journal of Environmental Quality. 29, 1662-1668.

Rosenfeld, P.E., C.L. Henry and D. Bennett. (2001). Wastewater dewatering polymer affect on biosolids odor emissions and microbial activity. Water Environment Research. 73(4), 363-367.

Rosenfeld, P.E., and C.L. Henry. (2001). Activated Carbon and Wood Ash Sorption of Wastewater, Compost, and Biosolids Odorants. Water Environment Research, 73, 388-393.

Rosenfeld, P.E., and Henry C. L., (2001). High carbon wood ash effect on biosolids microbial activity and odor.

Water Environment Research. 131(1-4), 247-262.

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Paul E. Rosenfeld, Ph.D. Page 4 of 10 June 2019

Chollack, T. and P. Rosenfeld. ( 1998). Compost Amendment Handbook For Landscaping. Prepared for a n d distributed by the City of Redmond, Washington State.

Rosenfeld, P. E. (1992). The Mount Liamuiga Crater Trail. Heritage Magazine of St. Kitts, 3(2).

Rosenfeld, P. E. (1993). High School Biogas Project to Prevent Deforestation On St. Kitts. Biomass Users Network, 7(1).

Rosenfeld, P. E. (1994). Potential Utilization of Small Diameter Trees on Sierra County Public Land. Masters thesis reprinted by the Sierra County Economic Council. Sierra County, California.

Rosenfeld, P. E. (1991). How to Build a Small Rural Anaerobic Digester & Uses Of Biogas In The First And Third World. Bachelors Thesis. University of California.

Presentations:

Rosenfeld, P.E., Sutherland, A; Hesse , R.; Zapata, A. (October 3-6, 2013). Air dispersion modeling of volatile organic emissions from multiple natural gas wells in Decatur, TX. 44th Western Regional Meeting, American Chemical Society. Lecture conducted from Santa Clara, CA.

Urban Environmental Pollution. Lecture conducted from Boston, MA.

Wu, C., Tam, L., Clark, J., Rosenfeld, P . (20-22 July, 2009). Dioxi n and furan blood lipid concentratio ns in populations living near four wood treatment facilities in the United States. Brebbia, C.A. and Popov, V., eds., Air Pollution XVII: Proceedings of the Seventeenth International Conference on Modeling, Monitoring and Management of Air Pollution. Lecture conducted from Tallinn, Estonia.

Rosenfeld, P. E. (October 15-18, 2007). Moss Point Community Exposure To Contaminants From A Releasing Facility. The 23
rd Annual International Conferences on Soils Sediment and Water. Platform lecture conducted from University of Massachusetts, Amherst MA.

Rosenfeld, P. E. (October 15-18, 2007). The Repeated Trespass of Tritium-Contaminated Water Into A Surrounding Community Form Repeated Waste Spills From A Nuclear Power Plant . The 23 rd Annual International
Conferences on Soils Sediment and Water . Platform lecture conducted from University of Massachusetts, Amherst MA.

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Paul E. Rosenfeld, Ph.D. Page 5 of 10 June 2019

Rosenfeld, P. E. (October 15-18, 2007). Somerville Community Exposure To Contaminants From Wood Treatment Facility Emissions. The 23rd Annual International Conferences on Soils Sediment and Water . Lecture conducted from University of Massachusetts, Amherst MA.

Rosenfeld P. E. (March 2007). Blood and Attic Sampling for Dioxin/Furan, PAH, and Metal Exposure in Florala, Alabama. The AEHS Annual Meeting. Lecture conducted from San Diego, CA.

Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (November 4-8, 2006). Dioxin Containing Attic Dust And Human Blood Sa mples Collected Near A Form er Wood Treatment Faci lity. APHA 134 Annual Meeting & Exposition. Lecture conducted from Boston Massachusetts.

Paul Rosenfeld Ph.D . (October 24-25, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.

Mealey’s C8/PFOA. Science, Risk & Litigation Conference. Lecture conducted from The Rittenhouse Hotel, Philadelphia, PA.

Paul Rosenfeld Ph.D . (September 19, 2005). Fate, Transport, Toxicity, And Persistence of 1,2,3-TCP. PEMA Emerging Contaminant Conference. Lecture conducted from Hilton Hotel in Irvine, California.

Paul Rosenfeld Ph.D. (September 26-27, 2005). Fate, Transport and Persistence of P DBEs. Mealey’s Groundwater Conference. Lecture conducted from Ritz Carlton Hotel, Marina Del Ray, California.

Paul Rosenfeld Ph.D . (June 7-8, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.

International Society of Environmental Forensics: Focus On Emerging Contaminants . Lecture conducted from Sheraton Oceanfront Hotel, Virginia Beach, Virginia.

Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.

Paul Rosenfeld, Ph.D. (Marc
h 2004). Perchlorate Toxicology. Meeting of the American Groundwater Trust .

Lecture conducted from Phoenix Arizona.

Hagemann, M.F., Paul Rosenfeld, Ph.D. and Rob Hesse (2004). Perchlorate Contamination of the Colorado River.

Meeting of tribal representatives. Lecture conducted from Parker, AZ.

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Paul E. Rosenfeld, Ph.D. Page 6 of 10 June 2019

Paul Rosenfeld, Ph.D. (April 7, 2004). A National Damage Assessment Model For PCE and Dry Cleaners.

Drycleaner Symposium. California Ground Water Association . Lecture conducted from Radison Hotel, Sacramento, California.

Rosenfeld, P. E., Grey, M., (June 2003) Two stage biofilter for biosolids composting odor control. Seventh International In Situ And On Site Bioremediation Symposium Battelle Conference Orlando, FL.

Paul Rosenfeld, Ph.D. and James Clark Ph.D. (Februar y 20-21, 2003) Und erstanding His torical Use, Chemical Properties, Toxicity and Regulatory Guidance of 1,4 Dioxane. National Groundwater Association. Southwest Focus Conference. Water Supply and Emerging Contaminants .. Lecture conducted from Hyatt Regency Phoenix Arizona.

Paul Rosenfeld, Ph.D. (February 6-7, 2003). Underground Storage Tank Litigation and Remediation. California CUPA Forum. Lecture conducted from Marriott Hotel, Anaheim California.

Paul Rosenfeld, Ph.D . (October 23, 2002) Underground Storage Tank Litigation and Remediation. EPA Underground Storage Tank Roundtable. Lecture conducted from Sacramento California.

Rosenfeld, P.E . and Suffet, M. (October 7- 10, 2002). Understanding Odor from Compost, Wastewater and Industrial Processes. Sixth Annu al Symposium On Off Flavors in the Aquatic En vironment. Inte rnational Water Association. Lecture conducted from Barcelona Spain.

Rosenfeld, P.E. and Suffet, M. (October 7- 10, 2002). Using High Carbon Wood Ash to Control Compost Odor.

Sixth Annual Symposium On Off Flavors in the Aquatic Environment. International Water Association . Lecture conducted from Barcelona Spain.

Rosenfeld, P.E. and Grey, M. A. (September 22-24, 2002). Biocycle Composting For Coastal Sage Restoration.

Northwest Biosolids Management Association. Lecture conducted from Vancouver Washington..

Rosenfeld. P.E. (September 16, 2000). Two stage biofilter for biosolids composting odor control. Water Environment Federation. Lecture conducted from Anaheim California.

Rosenfeld. P.E. ( October 16, 2000). Wood ash and biofilter control of compost odor. Biofest. Lecture conducted from Ocean Shores, California.

Rosenfeld, P.E. ( 2000). Bioremediation Using Organic Soil Amendments. California Resource Recovery Association. Lecture conducted from Sacramento California.

Rosenfeld, P.E ., C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur Emissions Following Biosolids Incorporation With High-Carbon Wo od-Ash. Water Environment Federation 12th Annual Residuals and B iosolids Manag ement Confere nce Proceedings . Lecture conducted from Bellevue Washington.

Rosenfeld, P.E., and C.L. Henry. (1999). An evaluation of ash incorporation with biosolids for odor reduction. Soil Science S
ociety of America. Lecture conducted from Salt Lake City Utah.

Rosenfeld, P.E. , C.L. Henry. (1998). Characterization, Quantification, and C ontrol of Odor Emissions from Biosolids Application To Forest Soil. Biofest. Lecture conducted from Lake Chelan, Washington.

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Paul E. Rosenfeld, Ph.D. Page 7 of 10 June 2019

Rosenfeld, P.E, C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur Emissions Following Biosolids Incorporation With High-Carbon Wood-Ash. Water Environment Federation 12th Annual Residuals and Biosolids Management Conference Proceedings. Lecture conducted from Bellevue Washington.

Teaching Experience:

UCLA Department of Environmental Health (Summer 2003 through 20010) Taught Environmental Health Science 100 to students, including undergrad, medical doctors, public health professionals and nurses. Course focused on the health effects of environmental contaminants.

UCLA Department of Environmenta l Engineering, Feb ruary 5, 2002. Seminar on Successful Remediation Technologies focusing on Groundwater Remediation.

University Of Washington, Soil Science Program, Teaching Assistant for several courses including: Soil Chemistry, Organic Soil Amendments, and Soil Stability.

U.C. Berkeley, Environmental Science Program Teaching Assistant for Environmental Science 10.

Academic Grants Awarded:

California Integrated Waste Management Board. $41,000 grant awarded to UCLA Institute of the Environment.

Goal: To investigate effect of high carbon wood ash on volatile organic emissions from compost. 2001.

Synagro Technologies, Corona California: $10,000 grant awarded to San Diego State University.

Goal: investigate effect of biosolids for restoration and remediation of degraded coastal sage soils. 2000.

Northwest Biosolids Management Association, Washington State. $20,000 grant awarded to investigate effect of polymers and ash on VOC emissions from biosolids. 1997.

James River Corporation, Oregon: $10,000 grant was awarded to investigate the success of genetically engineered Poplar trees with resistance to round-up. 1996.

United State Forest Service, Tahoe National Forest: $15,000 grant was awarded to investigating fire ecology of the Tahoe National Forest. 1995.

Kellogg Foundation, Washington D.C. $500 grant was awarded to construct a large anaerobic digester on St. Kitts in West Indies. 1993

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Paul E. Rosenfeld, Ph.D. Page 8 of 10 June 2019

Deposition and/or Trial Testimony:

In the United States District Court For The District of New Jersey Duarte et al, Plaintiffs, vs. United States Metals Refining Company et. al. Defendant.

Case No.: 2:17-cv-01624-ES-SCM
Rosenfeld Deposition. 6-7-2019

In the United States District Court of Southern District of Texas Galveston Division M/T Carla Maersk, Plaintiffs, vs. Conti 168., Schiffahrts-GMBH & Co. Bulker KG MS “Conti Perd ido” Defendant.

Case No.: 3:15-CV-00106 consolidated with 3:15-CV-00237 Rosenfeld Deposition. 5-9-2019

In The Superior Court of the State of California In And For The County Of Los Angeles – Santa Monica Carole-Taddeo-Bates et al., vs. Ifran Khan et al., Defendants Case No.: No. BC615636
Rosenfeld Deposition, 1-26-2019

In The Superior Court of the State of California In And For The County Of Los Angeles – Santa Monica The San Gabriel Valley Council of Governments et al. vs El Adobe Apts. Inc. et al., Defendants Case No.: No. BC646857
Rosenfeld Deposition, 10-6-2018; Trial 3-7-19

In United States District Court For The District of Colorado Bells et al. Plaintiff vs. The 3M Company et al., Defendants Case: No 1:16-cv-02531-RBJ
Rosenfeld Deposition, 3-15-2018 and 4-3-2018

In The District Court Of Regan County, Texas, 112
th Judicial District
Phillip Bales et al., Plaintiff vs. Dow Agrosciences, LLC, et al., Defendants Cause No 1923
Rosenfeld Deposition, 11-17-2017

In The Superior Court of the State of California In And For The County Of Contra Costa Simons et al., Plaintiffs vs. Chevron Corporation, et al., Def endants Cause No C12-01481
Rosenfeld Deposition, 11-20-2017

In The Circuit Court Of The Twentieth Judicial Circuit, St Clair County, Illinois Martha Custer et al., Plaintiff vs. Cerro Flow Products, Inc., Defendants Case No.: No. 0i9-L-2295
Rosenfeld Deposition, 8-23-2017

In The Superior Court of the State of California, For The County of Los Angeles Warrn Gilbert and Penny Gilber, Plaintiff vs. BMW of North America LLC Case No.: LC 102019 (c/w BC582154)
Rosenfeld Deposition, 8-16-2017, Trail 8-28-2018

In the Northern District Court of Mississippi, Greenville Division Brenda J. Cooper, et al., Plaintiffs, vs. Meritor Inc., et al., Defendants Case Number: 4:16-cv-52-DMB-JVM
Rosenfeld Deposition: July 2017

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Paul E. Rosenfeld, Ph.D. Page 9 of 10 June 2019

In The Superior Court of the State of Washington, County of Snohomish Michael Davis and Julie Davis et al., Plaintiff vs. Cedar Grov e Composting Inc., Defendants Case No.: No. 13-2-03987-5
Rosenfeld Deposition, February 2017
Trial, March 2017

In The Superior Court of the State of California, County of Alameda Charles Spain., Plaintiff vs. Thermo Fisher Scientific, et al., Defendants Case No.: RG14711115
Rosenfeld Deposition, September 2015

In The Iowa District Court In And For Poweshiek County
Russell D. Winburn, et al., Plaintiffs vs. Doug Hoksbergen, et al., Defendants Case No.: LALA002187
Rosenfeld Deposition, August 2015

In The Iowa District Court For Wapello County
Jerry Dovico, et al., Plaintiffs vs. Valley View Sine LLC, et al., Defendants Law No,: LALA105144 - Division A
Rosenfeld Deposition, August 2015

In The Iowa District Court For Wapello County
Doug Pauls, et al.,, et al., Plaintiffs vs. Richard Warren, et al., Defendants Law No,: LALA105144 - Division A
Rosenfeld Deposition, August 2015

In The Circuit Court of Ohio County, West Virginia
Robert Andrews, et al. v. Antero, et al.

Civil Action N0. 14-C-30000
Rosenfeld Deposition, June 2015

In The Third Judicial District County of Dona Ana, New Mexico Betty Gonzalez, et al. Plaintiffs vs. Del Oro Dairy, Del Oro Real Estate LLC, Jerry Settles and Deward DeRuyter, Defendants
Rosenfeld Deposition: July 2015

In The Iowa District Court For Muscatine County
Laurie Freeman et. al. Plaintiffs vs. Grain Processing Corporation, Defendant Case No 4980
Rosenfeld Deposition: May 2015

In the Circuit Court of the 17
th Judicial Circuit, in and For Broward County, Florida Walter Hinton, et. al. Plaintiff, vs. City of Fort Lauderdale, Florida, a Municipality, Defendant.

Case Number CACE07030358 (26)
Rosenfeld Deposition: December 2014

In the United States District Court Western District of Oklahoma Tommy McCarty, et al., Plaintiffs, v. Oklahoma City Landfill, LLC d/b/a Southeast Oklahoma City Landfill, et al. Defendants.

Case No. 5:12-cv-01152-C
Rosenfeld Deposition: July 2014

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Paul E. Rosenfeld, Ph.D. Page 10 of 10 June 2019

In the County Court of Dallas County Texas
Lisa Parr et al, Plaintiff, vs. Aruba et al, Defendant.

Case Number cc-11-01650-E
Rosenfeld Deposition: March and September 2013
Rosenfeld Trial: April 2014

In the Court of Common Pleas of Tuscarawas County Ohio
John Michael Abicht, et al., Plaintiffs, vs. Republic Services, Inc., et al., Defendants Case Number: 2008 CT 10 0741 (Cons. w/ 2009 CV 10 0987) Rosenfeld Deposition: October 2012

In the United States District Court of Southern District of Texas Galveston Division Kyle Cannon, Eugene Donovan, Genaro Ramirez, Carol Sassler, and Harvey Walton, each Individually and on behalf of those similarly situated, Plaintiffs, vs. BP Products North America, Inc., Defendant.

Case 3: 10-cv-00622
Rosenfeld Deposition: February 2012
Rosenfeld Trial: April 2013

In the Circuit Court of Baltimore County Maryland
Philip E. Cvach, II et al., Plaintiffs vs. Two Farms, Inc. d/b/a Royal Farms, Defendants Case Number: 03-C-12-012487 OT
Rosenfeld Deposition: September 2013

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EXHIBIT C

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1640 5th St.., Suit e 204 Santa
Santa Monica, California 90401
Tel: (949) 887-9013
Email: mhagemann@swapecom
Matthew F. Hagemann, P.G., C.Hg., QSD, QSP
Geologic and Hydrogeologic Characterization
Industrial Stormwater Compliance
Investigation and Remediation Strategies
Litigation Support and Testifying Expert
CEQA Review
Education:

M.S. Degree, Geology, California State University Los Angeles, Los Angeles, CA, 1984.

B.A. Degree, Geology, Humboldt State University, Arcata, CA, 1982.

Professional Certifications:

California Professional Geologist
California Certified Hydrogeologist
Qualified SWPPP Developer and Practitioner
Professional Experience:

Matt has 25 years of experience in environmental policy, assessment and remediation. He spent nine years with the U.S. EPA in the RCRA and Superfund programs and served as EPA’s Senior Science Policy Advisor in the Western Regional Office where he identified emerging threats to groundwater from perchlorate and MTBE. While with EPA, Matt also served as a Senior Hydrogeologist in the oversight of the assessment of seven major military facilities underg oing base closure. He led numerous enforcement actions under provisions of the Resource Conservation and Recovery Act (RCRA) while also working with permit holders to improve hydrogeologic characterization and water quality monitoring.

Positions Matt has held include:
x Founding Partner, Soil/Water/Air Protection Enterprise (SWAPE) (2003 – present); x Geology Instructor, Golden West College, 2010 – 2Ŗŗ4; x Senior Environmental Analyst, Komex H2O Science, Inc. (2000 -- 2003);

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x Executive Director, Orange Coast Watch (2001 – 2004); x Senior Science Policy Advisor and Hydrogeologist, U.S. Environmental Protection Agency (1989– 1998);
x Hydrogeologist, National Park Service, Water Resources Division (1998 – 2000); x Adjunct Faculty Member, San Francisco State University, Department of Geosciences (1993 – 1998);
x Instructor, College of Marin, Department of Science (1990 – 1995); x Geologist, U.S. Forest Service (1986 – 1998); and
x Geologist, Dames & Moore (1984 – 1986).

Senior Regulatory and Litigation Support Analyst:

With SWAPE, Matt’s responsibilities have included:
x Lead analyst and testifying expert in the review of over 100 environmental impact reports since 2003 under CEQA that identify significant issues with regard to hazardous waste, water resources, water quality, air quality, Valley Fever, greenhouse gas emissions, and geologic hazards. Make recommendations for additional mitigation measures to lead agencies at the local and county level to include additional characterization of health risks and implementation of protective measures to reduce worker exposure to hazards from toxins and Valley Fever.
x Stormwater analysis, sampling and best management practice evaluation at industrial facilities. x Manager of a project to provide technical assistance to a community adjacent to a former Naval shipyard under a grant from the U.S. EPA.
x Technical assistance and litigation support for vapor intrusion concerns. x Lead analyst and testifying expert in the review of environmental issues in license applications for large solar power plants before the California Energy Commission. x Manager of a project to evaluate numerous formerly used military sites in the western U.S. x Manager of a comprehensive evaluation of potential sources of perchlorate contamination in Southern California drinking water wells.
x Manager and designated expert for litigation support under provisions of Proposition 65 in the review of releases of gasoline to sources drinking water at major refineries and hundreds of gas stations throughout California.
x Expert witness on two cases involving MTBE litigation. x Expert witness and litigation support on the impact of air toxins and hazards at a school. x Expert witness in litigation at a former plywood plant.

With Komex H2O Science Inc., Matt’s duties included the following:
x Senior author of a report on the extent of perchlorate contamination that was used in testimony by the former U.S. EPA Administrator and General Counsel. x Senior researcher in the development of a comprehensive, electronically interactive chronology of MTBE use, research, and regulation.
x Senior researcher in the development of a comprehensive, electronically interactive chronology of perchlorate use, research, and regulation.
x Senior researcher in a study that estimates nationwide costs for MTBE remediation and drinking water treatment, results of which were published in newspapers nationwide and in testimony against provisions of an energy bill that would limit liability for oil companies. x Research to support litigation to restore drinking water supplies that have been contaminated by MTBE in California and New York.
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x Expert witness testimony in a case of oil production-related contamination in Mississippi. x Lead author for a multi-volume remedial investigation report for an operating school in Los Angeles that met strict regulatory requirements and rigorous deadlines. 3

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x Development of strategic approaches for cleanup of contaminated sites in consultation with clients and regulators.

Executive Director:

As Executive Director with Orange Coast Watch, Matt led efforts to restore water quality at Orange County beaches from multiple sources of contamination including urban runoff and the discharge of wastewater. In reporting to a Board of Directors that included representatives from leading Orange County universities and businesses, Matt prepared issu e papers in the areas of treatment and disinfection of wastewater and control of the discharge of grease to sewer systems. Matt actively participated in the development of countywide water quality permits for the control of urban runoff and permits for the discharge of wastewater. Matt worked with other nonprofits to protect and restore water quality, including Surfrider, Natural Resources Defense Council and Orange County CoastKeeper as well as with business institutions including the Orange County Business Council.

Hydrogeology:

As a Senior Hydrogeologist with the U.S. Environmen tal Protection Agency, Matt led investigations to characterize and cleanup closing military bases, including Mare Island Naval Shipyard, Hunters Point Naval Shipyard, Treasure Island Naval Station, Alameda Naval Station, Moffett Field, Mather Army Airfield, and Sacramento Army Depot. Specific activities were as follows:
x Led efforts to model groundwater flow and contaminant transport, ensured adequacy of monitoring networks, and assessed cleanup alternatives for contaminated sediment, soil, and groundwater.
x Initiated a regional program for evaluation of groundwater sampling practices and laboratory analysis at military bases.
x Identified emerging issues, wrote technical guidance, and assisted in policy and regulation development through work on four national U.S. EPA workgroups, including the Superfund Groundwater Technical Forum and the Federal Facilities Forum.

As a hydrogeologist with the EPA Groundwater Protection Section, Matt worked with provisions of the Safe Drinking Water Act and NEPA to prevent drinking water contamination. Specific activities included the following:
x Received an EPA Bronze Medal for his contribution to the development of national guidance for the protection of drinking water.
x Managed the Sole Source Aquifer Program and protected the drinking water of two communities through designation under the Safe Drinking Water Act. He prepared geologic reports, conducted public hearings, and responded to public comments from residents who were very concerned about the impact of designation.
4

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x Reviewed a number of Environmental Impact Statements for planned major developments, including large hazardous and solid waste disposal facilities, mine reclamation, and water transfer.

Matt served as a hydrogeologist with the RCRA Hazardous Waste program. Duties were as follows:
x Supervised the hydrogeologic investigation of hazardous waste sites to determine compliance with Subtitle C requirements.
x Reviewed and wrote "part B" permits for the disposal of hazardous waste. x Conducted RCRA Corrective Action investigations of waste sites and led inspections that formed the basis for significant enforcement actions that were developed in close coordination with U.S.

EPA legal counsel.
x Wrote contract specifications and supervised contractor’s investigations of waste sites.

With the National Park Service, Matt directed service-wide investigations of contaminant sources to prevent degradation of water quality, including the following tasks:
x Applied pertinent laws and regulations including CERCLA, RCRA, NEPA, NRDA, and the Clean Water Act to control military, mining, and landfill contaminants. x Conducted watershed-scale investigations of contaminants at parks, including Yellowstone and Olympic National Park.
x Identified high-levels of perchlorate in soil adjacent to a national park in New Mexico and advised park superintendent on appropriate response actions under CERCLA. x Served as a Park Service representative on the Interagency Perchlorate Steering Committee, a national workgroup.
x Developed a program to conduct environmental compliance audits of all National Parks while serving on a national workgroup.
x Co-authored two papers on the potential for water contamination from the operation of personal watercraft and snowmobiles, these papers serving as the basis for the development of nation- wide policy on the use of these vehicles in National Parks. x Contributed to the Federal Multi-Agency Source Water Agreement under the Clean Water Action Plan.

Policy:

Served senior management as the Senior Science Poli cy Advisor with the U.S. Environmental Protection Agency, Region 9. Activities included the following:
x Advised the Regional Administrator and senior management on emerging issues such as the potential for the gasoline additive MTBE and ammonium perchlorate to contaminate drinking water supplies.
x Shaped EPA’s national response to these threats by serving on workgroups and by contributing to guidance, including the Office of Research and Development publication, Oxygenates in Water: Critical Information and Research Needs.
x Improved the technical training of EPA's scientific and engineering staff. x Earned an EPA Bronze Medal for representing the region’s 300 scientists and engineers in negotiations with the Administrator and senior management to better integrate scientific principles into the policy-making process.
x Established national protocol for the peer review of scientific documents. 5

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Geology:

With the U.S. Forest Service, Matt led investigations to determine hillslope stability of areas proposed for timber harvest in the central Oregon Coast Range. Specific activities were as follows:
x Mapped geology in the field, and used aerial photographic interpretation and mathematical models to determine slope stability.
x Coordinated his research with community members who were concerned with natural resource protection.
x Characterized the geology of an aquifer that serves as the sole source of drinking water for the city of Medford, Oregon.

As a consultant with Dames and Moore, Matt led geologic investigations of two contaminated sites (later list
ed on the Superfund NPL) in the Portland, Oregon, area and a large hazardous waste site in eastern Oregon. Duties included the following:
x Supervised year-long effort for soil and groundwater sampling. x Conducted aquifer tests.
x Investigated active faults beneath sites proposed for hazardous waste disposal.

Teaching:

From 1990 to 1998, Matt taught at least one course per semester at the community college and university levels:
x At San Francisco State University, held an adjunct faculty position and taught courses in environmental geology, oceanography (lab and lecture), hydrogeology, and groundwater contamination.
x Served as a committee member for graduate and undergraduate students. x Taught courses in environmental geology and oceanography at the College of Marin.

Matt taught physical geology (lecture and lab and introductory geology at Golden West College in Hun
tington Beach, California from 2010 to 2014.

Invited Testimony, Reports, Papers and Presentations:

Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Presentation to the Public Environmental Law Conference, Eugene, Oregon.

Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Invited presentation to U.S.

EPA Region 9, San Francisco, California.

Hagemann, M.F., 2005. Use o f Electronic Databases in Environmental Regulation, Policy Making and Public Participation. Brownfields 2005, Denver, Coloradao.

Hagemann, M.F., 200 4. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in Nevada and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Las Vegas, NV (served on conference organizing committee).

Hagemann, M.F., 2004. In vited testimony to a California Senate committee hearing on air toxins at schools in Southern California, Los Angeles.
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Brown, A., Farrow, J., Gray, A. and Hagemann, M., 2004. An Estimate of Costs to Address MTBE Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells.

Presentation to the Ground Water and Environmental Law Conference, National Groundwater Association.

Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a tribal EPA meeting, Pechanga, CA.

Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a meeting of tribal repesentatives, Parker, AZ.

Hagemann, M.F., 2003. Impact of Perchlorate on the Colorado River and Associated Drinking Water Supplies. Invited presentation to the Inter-Tribal Meeting, Torres Martinez Tribe.

Hagemann, M.F., 2003. The Emergence of Perchlorate as a Widespread Drinking Water Contaminant.

Invited presentation to the U.S. EPA Region 9.

Hagemann, M.F., 2003. A Deductive Approach to the Assessment of Perchlorate Contamination. Invited presentation to the California Assembly Natural Resources Committee.

Hagemann, M.F., 2003. Perchlorate: A Cold War Legacy in Drinking Water. Presentation to a meeting of the National Groundwater Association.

Hagemann, M.F., 2002. From Tank to Tap: A Chronology of MTBE in Groundwater. Presentation to a meeting of the National Groundwater Association.

Hagemann, M.F., 2002. A Chronology of MTBE in Groundwater and an Estimate of Costs to Address Impacts to Groundwater. Presentation to the annual meeting of the Society of Environmental Journalists.

Hagemann, M.F., 2002. An Estimate of the Cost to Address MTBE Contamination in Groundwater (and Who Will Pay). Presentation to a meeting of the National Groundwater Association.

Hagemann, M.F ., 2001. From Tank to Tap: A Chronology of MTBE in Groundwater. Unpublished report.
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Hagemann, M.F ., 2001. Estimated Cleanup Cost for MTBE in Groundwater Used as Drinking Water.

Unpublished report.

Hagemann, M.F., 2001. Estimated Costs to Address MTBE Releases from Leaking Underground Storage Tanks. Unpublished report.

Hagemann, M.F ., and VanMouwerik, M., 1999. Potential W a t e r Quality Concerns Related to Snowmobile Usage. Water Resources Division, National Park Service, Technical Report.

VanMouwerik, M. and Hagemann, M.F . 1999, Water Quality Concerns Related to Personal Watercraft Usage. Water Resources Division, National Park Service, Technical Report.

Hagemann, M.F ., 1999, Is Dilution the Solution to Pollution in National Parks? The George Wright Society Biannual Meeting, Asheville, North Carolina.

Hagemann, M.F ., 1997, The Potential for MTBE to Contaminate Groundwater. U.S. EPA Superfund Groundwater Technical Forum Annual Meeting, Las Vegas, Nevada.

Hagemann, M.F ., and Gill, M., 1996, Impediments to Intrinsic Remediation, Moffett Field Naval Air Station, Conference on Intrinsic Remediation of Chlorinated Hydrocarbons, Salt Lake City.

Hagemann, M.F., Fukunaga, G.L., 1996, The Vulnerability of Groundwater to Anthropogenic Contaminants on the Island of Maui, Hawaii. Hawaii Water Works Association Annual Meeting, Maui, October 1996.

Hagemann, M.F . , 199 4. G r ou n d w a t e r Characterization and Cleanup at C los in g M i l it a r y B a s e s in California. Proceedings, California Groundwater Resources Association Meeting.

Hagemann, M.F ., 1993. U.S. EPA Policy on the Technical Impracticability of the Cleanup of DNAPL- contaminated Groundwater. California Groundwater Resources Association Meeting. 8

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Hagemann, M.F., 1992. Dense Nonaqueous Phase Liquid Contamination of Groundwater: An Ounce of Prevention... Proceedings, Association of Engineering Geologists Annual Meeting, v. 35.

Other Experience:

Selected as subject matter expert for the California Professional Geologist licensing examination, 2009- 2011.
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1 Reynoso, Vanessa
From: Kathleen Maguire <[email protected]> Sent: Monday, September 27, 2021 12:18 AM
To: Housing Element
Subject: [Alhambra HE] Draft Housing Element Comments - new submission CAUTION: This email originated from outside your organization. ???
Kathleen Maguire just submitted your form: Dra ft Housing Element Comments on Alhambra HE

Message Details:

First Name: Kathleen
Last Name: Maguire
Email:
kmaguire@ratkovichcom
Enter your comments on the Draft Housing Element here. (1,000 c
haracters): Regarding The Villages project as found on Page 169 & 170: 1. Building 12 and storage buildings will be demolished for the housing. I don???t know the square footage of the buildings that will be demolished but can review documentation further to provide it. 2. The current proposal is as follows: 790 units, 560 for rent and 230 for sale

with 84 low- and moderate-income affordable rental units. ???

If you think this submission is spam, report it as spam .

???

To edit your email settings, go to your Inbox on desktop.

To help protect your privacy, Microsoft Office prevented automa tic download of this picture from the Internet. ???

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1 Reynoso, Vanessa
From: Henry Fung <[email protected]>
Sent: Monday, October 25, 2021 8:59 PM
To: [email protected]
Cc: Housing Element
Subject: Alhambra Housing Element comments
CAUTION: This email originated from outside your organization.

To the California Department of Housing and Community Development,

At the October 25, 2021 City Council meeting, the Alhambra City Council denied the Villages at Alhambra project. This project was listed on Page 168 of the Housing Element as having a "very high likelihood of development" within the RHNA planning period. With the findings of denial, this is no longer the case. Input from councilmembers stated that, despite comments from the Regional Water Quality Control Board that the toxic vapors underneath the soil were mitigable, that they still felt the vapors were an issue for residential development. With the deletion of this project (known as 1000 Fremont in Figure 92), 790 units will need to be accommodated elsewhere in the city.

This will also call into question the other planned units to be constructed in the IPD zone (page 176), of which currently no residential development is allowed but now 43 units/acre are allowed. The IPD zones surround the Villages project and any concern about toxic soil would likely also spread to those parcels, since they are in close proximity and are also on industrial land. Any development of high or medium density would require excavation and soil disturbance.

While I believe that the situation is mitigable with modern vapor barrier technology, it is clear that the elected officials feel they know more than the environmental professionals at the State. Therefore, they are likely to deny projects on IPD zoned land in the future. It is unlikely that these properties could be built by right due to the need to review and approve environmental mitigation for the contaminated soil. None of the properties listed in the Site Inventory in the IPD zone should count towards Alhambra's RHNA goals in the housing element. These are sites NV.207 and NV.492, for a further reduction of 225 units which should be accommodated elsewhere.

Please return the Alhambra Housing Element back to the city so that these 1,015 units can be placed elsewhere by the city's consultant, and have more than a negligible chance of being developed for housing during the RHNA cycle.

Sincerely,

Henry Fung

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October 13, 2021
Alhambra City Council
Alhambra City Hall
111 South 1st Street
Alhambra, CA 91801
Dear Councilmembers:

Why does this matter? Because we face a cascade of housing crises in our region.And while nearly everyone in Los Angeles County feels the crush of our housing crisis, Black and Latino residents feel it more than most:
● Black households have 1.12% the wealth of white households, and Latino households less than 5% (Federal Reserve Bank of San Francisco)
● Black people make up 8% of the county population, but 33.7% of people experiencing homelessness (LAHSA)
● Even under COVID-related eviction moratoriums, Black and Latino neighborhoods face disproportionately higher eviction threats (Los Angeles Times, UCLA) ● One in four AAPIs pay more than half of their income toward housing costs compared to whites (16 percent), putting many on the edge of financial vulnerability. This segment of the population is considered severely cost-burdened (Crisis to Impact Report, A joint publication of the National Coalition of Asian Pacific American Community Development and the University of California, Los Angeles)
These are the effects of decades of racist policies that we have not eradicated: Restrictive covenants, exclusionary zoning, and redlining made it impossible for Black families to build wealth through homeownership, and result in lower homeownership and higher rents today. The California Constitution’s Article 34 and local “crime-free housing” policies put roadblocks in the way of addressing racial divisions in Californians’ housing affordability and security.

This impact was felt devastatingly during the pandemic, when essential workers living in overcrowded housing were exposed to COVID at work and had no choice but to expose their families at home, leading to disproportionate deaths among Black and Latino people.

Neighborhoods in South and Southeast LA, where nearly 20% of homes are overcrowded (defined as more than one person per room) had COVID rates of roughly 14,000 cases per 100,000 people. Neighborhoods on the Westside, where less than 5% of homes are overcrowded, had rates well under 5,000 cases per 100,000 people.1 Death rates were similarly disproportionate -- at a time (January 2021) when the city of Beverly Hills was reporting 21 COVID deaths, and the neighborhood of Brentwood 9, the city of Compton reported 147, and the neighborhood of Westlake 202.2 In all, COVID-19 mortality rates in LA County were roughly twice as high for Black people (31 deaths/100,000 individuals) and Latinos (29/100K) as for whites (15/100K) (from CGLA).
2 “We Are Forced to Live in These Conditions’: In Los Angeles, Virus Ravages Overcrowded Homes”, NY Times, 1/23/21 1 “When coronavirus invaded their tiny apartment, children desperately tried to protect dad”, LA Times, 1/29/21 3

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Of the 3,007 counties in the United States, L.A. County ranks last in housing affordability, overcrowding, and unsheltered homelessness. We are not doing enough to preserve and create homes for working class and lower-income people. The affordable housing crisis, rampant speculation, lack of tenant protections and rent control, and affordable housing shortage have gotten so bad that lower-income Black, Latino and AAPI families are being pushed out of their homes and communities at an alarming rate. At the rate we’re going, next generations won’t be able to live in Los Angeles County.

Los Angeles County is legally required to build 341,000 affordable homes by 2030.To truly address our needs, we need more than double that.At the rate we’re going today, we might build 25,000. That’s 7% of what’s needed. That kind of failure will fall hardest on Black and Latino families, who disproportionately face eviction, homelessness and having to choose between rent and food. Our Future LA demands we not let that happen.

In order to create a better housing future, we must make every neighborhood resource-rich so people can live where they want to live and don’t have to leave their community to find opportunity. The Housing Element must also consider the intersection between housing, public health, and environmental justice. The very communities facing the highest rent burden are often the same communities who bear the brunt of the negative impacts brought on by environmental contamination and exposure to the worst air and soil qualities. For example, in LA County, 75% of active oil wells are located within 2,500 feet of homes, the vast majority of which are occupied by low-income people of color.We must also achieve equitable land use and zoning so that historically exclusionary communities build at greater densities, with value capture, while also ensuring that areas already zoned for density are protected from environmental and spatial racism and displacement pressures. As the region plans for growth, there must be no conversion of wildlife habitat to housing or further development in wildfire hazard areas, as identified by CalFire. We understand that Alhambra cares deeply about these issues, and we hope to offer assistance in addressing them.

As it stands right now, the draft housing element will not meetAlhambra’s goals around equity and affordability. We submit these comments in the spirit of collaboration in order to partner and provide research, grounded data to help in meeting housing needs. We are interested in having a meeting to discuss these comments more.

Our Future LA Housing Element Comments

1. Protections
A. The housing element should expand just-cause eviction protections to cover all tenants and establish a corresponding enforcement program.

B. The housing element should implement a local RSO program. 4

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C. The housing element should codify a tenant’s right to counsel in an eviction proceeding.

D. The housing element should strengthen its permanent tenant education program to inform tenants of their rights and how to access eviction defense resources.

E. The housing element should create and implement a tenant anti-harassment ordinance combined with enforcement resources.

2. Preservation
A. The housing element must do more to prioritize rezoning - with value capture - in high-resource neighborhoods which are transit- and job-rich, including single-family zoned areas. This is necessary to expand affordable housing opportunities while minimizing the impact on existing renters in multifamily-zoned areas.

B. The housing element should exclude parcels containing RSO housing units in the housing element’s site inventory.

C. The housing element should require that no net loss provisions apply to parcels in the site inventory and rezoning program with a monitoring and implementation program.

D. The housing element should strengthen local programs and funding sources for preservation of existing affordable housing.

3. Prioritization of affordable housing
A. The housing element should utilize a value capture mechanism, such as inclusionary zoning, to locally fund and/or incentivize affordable housing.

B. The housing element should prioritize creation of affordable housing on public land.

C. The housing element should streamline affordable housing production.

D. The housing element should include programs for 100% affordable housing zoning overlays, and should ensure that these overlays apply to high-opportunity areas.

E. The housing element should include programs for 100% affordable housing zoning overlays, and should ensure that these overlays apply to high-opportunity areas currently zoned R1.

4. Site Capacity Assessment
5

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Alhambra City CouncilJanuary 24, 2022

Alhambra City Council
January 24, 2022