Cities Index.
Agenda

Alhambra City Council
January 31, 2022

Document
Agenda
Meeting
January 31, 2022
Body
Alhambra City Council
Pages
919
Original file
67.3 MB
Text extracted from the city's file for reading and search. Open the original on www.alhambraca.gov. That file is the official record.

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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Paul E. Rosenfeld, Ph.D. Page 5 of 10 June 2019
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 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. (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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Paul E. Rosenfeld, Ph.D. Page 7 of 10 June 2019
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:

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.

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:

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.

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:

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.

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
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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.

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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.

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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.

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From: Cliff Bender
To: Housing Element
Subject: [Alhambra HE] Draft Housing Element Comments - new submission Date: Sunday, September 26, 2021 6:13:36 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.

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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.

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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 of​Abundant 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, and​has 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 the​likelihood of developmentand the ​net new units if developed ​of inventory sites

2. Using an HCD-recommended “safe harbor” methodology for​forecasting 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 a​total 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 that​no 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 a​total 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 a​real 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 maintained​at 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”).

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.

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

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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 reduction 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 help

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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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 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:

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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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.
‘”‡””‹’•ƒ†
”‡‡Š‘—•‡
ƒ•ƒŽ
—Žƒ–‹‘•
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. ‡ˆƒ—Ž–‘”‡””‹’ƒ”ƒ‡–‡”•ƒ†‘–‡–‹ƒŽ‘
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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. ”ƒ
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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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5 ‹•
Žƒ‹‡”
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.

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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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.

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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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 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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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. ( 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:

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.

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). 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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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). 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 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). 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 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.

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 Environm ental 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. (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 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. 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 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, 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 C ontrol of Odor Emissions from Biosolids Application To Forest Soil. Biofest. Lecture conducted from Lake Chelan, Washington.

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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. , 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 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.

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

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.

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:
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.

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:
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.
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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., 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 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., 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 . , 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. 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. 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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Read about the coalition here

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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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A. The housing element should estimate and report both the likelihood of discontinuation and the realistic capacity of all inventory sites, including those that were on the 5th cycle site inventory.

B. A buffer of at least 15-30% extra capacity should be included in the housing element site inventory. This capacity buffer is especially necessary in order to accommodate the lower-income RHNA target.

Proposed No Net Loss buffers
Income Category RHNA Target
Claimed Realistic
Capacity in Draft HE NNL Buffer
VLI 1,774 1,830 3%
LI 1,036 1,333 29%
MI 1,079 1,192 10%
AMI 2,936 3,645 24%
Total 6,825 8,000 17%
C. The housing element should provide a quantitative estimate of the likelihood that in-pipeline projects will be completed, based on historical data, and should adjust the number of in-pipeline units counted towards the 6th cycle RHNA target accordingly.

D. The housing element should commit to a mid-cycle review to verify the housing element’s assumptions about development probabilities.

5. Affirmatively Furthering Fair Housing
A. The housing element should meaningfully increase the concentration of lower-income households in areas of the city where the existing concentration of lower-income households is low.

B. The housing element should meaningfully reduce the concentration of lower-income households in areas with significant exposure to noise/pollution and commit to reducing/addressing noise and pollution.

C. The housing element should ensure community-serving investment in historically disinvested areas. This includes place-based strategies that create a net gain of affordable housing and stop displacement, prioritize environmental justice, enhance community health and strengthen equitable community leadership in land use planning.

D. The housing element should include a thorough analysis of local patterns in socioeconomic/racial segregation and integration, including patterns of overt racial or ethnic discrimination in the housing and land development market. 6

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E. The housing element should adequately 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.

F. The housing element should adequately identify funding sources, public resources, and density bonus programs to maximize the likelihood that projects with below-market-rate units are built.

G. The jurisdiction should adequately solicit public feedback and commentary on the housing element in a way that accurately reflects the jurisdiction’s socioeconomic makeup.

6. Forecasts of ADU Development
A. The housing element should use an HCD-recommended safe harbor methodology for forecasting future ADU production.

B. The housing element should provide for mid-cycle adjustments if inventory sites are developed at lower rates, or lesser densities, than the housing element anticipated and if ADU production falls short of projections. Mid-cycle adjustments should automatically implement a by-right density bonus on inventory sites, starting mid-cycle, and be large enough to make up for an ADU shortfall.

C. The housing element should assess the affordability of forecasted ADUs using city-specific data; it instead uses a regional average. ***
We request the opportunity to meet with you and your colleagues to address the concerns raised in this letter. Thank you for your time and consideration.

Sincerely,
Our Future LA
Steering Committee Members
CC: Jason Elliott, Senior Counselor to Governor Gavin Newsom Megan Kirkeby, Deputy Director, Housing Policy Development, HCD Melinda Coy, Land Use and Planning Manager, HCD
Tyrone Buckley, Assistant Deputy Director of Fair Housing, HCD Paul McDougall, Housing Policy Development Manager, HCD 7

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1 Lam, Paul
From: Jim Gallagher <[email protected]>
Sent: Tuesday, December 28, 2021 12:50 PM
To: Lam, Paul
Subject: Re: Housing Element
CAUTION: This email originated from outside your organization.

There is an approximate 10 acre site at 1100 South Meridian Avenue in town. It is owned by South Meridian LLC. It is across Fremont from the Ratkovich property. On quick glance I don’t see it in the Housing Element. It would seem to be an excellent site for housing. What is happening with that property now? Sent from my iPhone

On Apr 13, 2021, at 9:14 AM, Jim Gallagher <[email protected]> wrote:

Thank you.

Sent from my iPhone

On Apr 13, 2021, at 8:15 AM, Lam, Paul <[email protected]> wrote:

Good morning Mr. Gallagher,

I apologize for the lateness of this response.

In response to your question, no, the housing element update is not being undertaken to satisfy RHNA, not exactly.

The Housing Element ("HE") is one of the eight (8) mandatory chapters of the General Plan, and unlike the other chapters, the HE is the only chapter of the General Plan that is required by State Law to be updated every eight (8) years. Alhambra's current HE addresses the period of 2013-2021, so our HE is due for the mandatory eight year update that will cover the period of 2021-2029.

Generally, the HE discusses numerous factors relating to housing such as current housing types, future housing needs, zoning, and programs and policies governing housing development, including the Regional Housing Needs Allocation ("RHNA"). As you may be aware, the City has received a RHNA of 6,825 units. The updated HE will include discussion about the RHNA and will address how the City will be able to accommodate that many units through zoning, and programs and policies

The Draft 2021-2029 Housing Element is anticipated to be made available for public review later this Spring.

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2 If you wish to learn more about the HE update project, sign up for email updates, and see a calendar of events, you can do so by visiting this link:
https://www.alhambrahousingelement.com/about

Please let me know if you have any additional questions,

Best,

Paul Lam

<image001.png> Paul Lam | Principal Planner
Community Development Department
111 S. First St. | Alhambra, CA 91801
T: 626-570-5040 | F: 626-458-4201
www.cityofalhambra.org
<image002.jpg>

<image003.jpg>

<image004.jpg>

<image005.png>

-----Original Message-----
From: Jim Gallagher <[email protected]>
Sent: Tuesday, April 6, 2021 2:52 PM
To: Lam, Paul <[email protected]>
Subject: Housing Element

CAUTION: This email originated from outside your organization.

Is the city doing a housing element to satisfy Rhina? If so, when do you expect a first draft to be available online?

Thank you.

Sent from my iPhone

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From: Hank Fung
To: Lam, Paul
Subject: Comment for tonight’s planning commission meeting item 4 Date: Monday, January 3, 2022 4:25:51 PM
CAUTION: This email originated from outside your organization.

Dear Planning Commissioners,
It is like having your cake and eating it too to include the Villages project and the Industrial Planned Development zoned properties and have that count towards your required units in the housing element. Unless the Planning Commission and City Council is willing to state how many units they will approve, by right, or unless staff is willing to commit to a certain number of units which will be approved, by right, on the site, zero units from the IPD zones nor 1000 S Fremont should be counted in the housing element. Planning commissioners have indicated on the dais how they feel that housing development is not appropriate for industrially zoned areas. They have stated concern about toxic vapor, proximity to railroads and truck pollution, and need to preserve the City's job base. One of the IPD zoned properties is across the street from the Villages at the Alhambra and housing on that lot was rejected by that community and replaced by a home improvement store. If that is the case, then why is Alhambra proposing that more housing be built in the city's industrial areas, and counting on this to meet its RHNA goals? In addition, the City Council is considering implementing additional restrictions on SB 9 lot splits. it is unclear if these restrictions will be extended as well to accessory dwelling units, and confusion regarding ADU requirements vs. SB 9 lot splits once the SB 9 emergency ordinance is imposed will reduce the amount of ADUs generated. While I recognize that the city wants to place a draconian measure on SB 9 lot splits in order to look at the issue more comprehensively, and possibly loosen the proposed strict limits, this could have a chilling effect on future ADU development.

Please ask EcoNorthwest to increase the maximum densit of the zones currently listed in Figure 99 to allow more housing, and loosen parking requirements near transit. Alhambra could go even further than AB 744 in incentivizing affordable housing development and require zero parking spaces for very low or low income units within one half mile of a transit stop. Lower income people are less likely to have cars and they should not pay for an amenity they will not use. This will allow for more units to be built downtown and along Valley and Atlantic Boulevards, near transit, and address the need and desire of planning commissioners to permit for more affordable housing. This must be addressed as part of Program 18 in the comprehensive zoning code update.

Sincerely,
Henry Fung

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From: Huffman, Mandy
To: Lam, Paul
Subject: NOI Response to 2021-2029 City of Alhambra Housing Element Date: Monday, January 3, 2022 1:45:22 PM
Attachments: image001.png
DMS-#6419172-v2-Response Letter to City of Alhambra re_ NOI for 2021-2029 City of Alhambra Housing Element.PDF
CAUTION: This email originated from outside your organization.

Dear Mr. Lam:

Attached please find Los Angeles County Sanitation Districts’ response to the subject project.

Sincerely,

Mandy Huffman
Environmental Planner | Wastewater Planning
562-908-4288 ext. 2743
[email protected]
–––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––– Website | Facebook | Twitter | Instagram | YouTube

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VIA E-MAIL
January 14, 2022
Lauren Myles
City Clerk
City of Alhambra
111 South First Street
Alhambra, CA 91801
Em: [email protected]
RE: City of Alhambra’s 6th Cycle Housing Element Update.

Dear Lauren Myles,
On behalf of the Southwest Regional Council of Carpenters (“Southwest Carpenter” or “SWRCC”), my Office is submitting these comments for the City of Alhambra’s (“City”) Negative Declaration for its draft 2021-2029 update to the City’s General Plan Housing Element (“Project”).

The Southwest Carpenters is a labor union representing 50,000 union carpenters in six states, including California, 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.

SWRCC 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.

SWRCC 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

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to the Project’s environmental documentation may assert any issue timely raised by other parties).

Moreover, SWRCC requests that the City 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 reduction of construction-related GHG emissions, though the significance of the reduction would vary based on the location and urbanization level of the project site.

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

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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 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 1 California Workforce Development Board (2020) Putting California on the High Road: A Jobs and Climate Action Plan for 2030 at p. ii, available at https://laborcenter.berkeley.edu/ wp-content/uploads/2020/09/Putting-California-on-the-High-Road.pdf. 2 South Coast Air Quality Management District (May 7, 2021) Certify Final Environmental Assessment and Adopt Proposed Rule 2305 – Warehouse Indirect Source Rule – Warehouse Actions and Investments to Reduce Emissions Program, and Proposed Rule 316 – Fees for Rule 2305, Submit Rule 2305 for Inclusion Into the SIP, and Approve Supporting Budget Actions, available at
http://www.aqmd.gov/docs/default-
source/Agendas/Governing-Board/2021/2021-May7-027.pdf?sfvrsn=10 3 City of Hayward (2014) Hayward 2040 General Plan Policy Document at p. 3-99, available at https://www.hayward-ca.gov/sites/default/files/documents/General_Plan_FINAL.pdf.

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housing and nonresidential developments to require contractors to utilize apprentices from state-approved, joint labor-management training programs, . . .”4 In addition, the City of Hayward requires all projects 30,000 square feet or larger to “utilize apprentices from state-approved, joint labor-management training programs.”5
Locating jobs closer to residential areas can have significant environmental benefits. .

As the California Planning Roundtable noted in 2008:

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

In nearly 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 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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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
[email protected]
Paul E. Rosenfeld, PhD
(310) 795-2335
[email protected]
March 8, 2021

Mitchell M. Tsai
155 South El Molino, Suite 104
Pasadena, CA 91101

Subject: Local Hire Requirements and Considerations for Greenhouse Gas Modeling Dear Mr. Tsai,
Soil Water Air Protection Enterprise (“SWAPE”) is pleased to provide the following draft technical report explaining the significance of worker trips required for construction of land use development projects with respect to the estimation of greenhouse gas (“GHG”) emissions. The report will also discuss the potential for local hire requirements to reduce the length of worker trips, and consequently, reduced or mitigate the potential GHG impacts.

Worker Trips and Greenhouse Gas Calculations
The California Emissions Estimator Model (“CalEEMod”) is a “statewide land use emissions computer model designed to provide a uniform platform for government agencies, land use planners, and environmental professionals to quantify potential criteria pollutant and greenhouse gas (GHG) emissions associated with both construction and operations from a variety of land use projects.”1 CalEEMod quantifies construction-related emissions associated with land use projects resulting from off-road construction equipment; on-road mobile equipment associated with workers, vendors, and hauling; fugitive dust associated with grading, demolition, truck loading, and on-road vehicles traveling along paved and unpaved roads; and architectural coating activities; and paving.2
The number, length, and vehicle class of worker trips are utilized by CalEEMod to calculate emissions associated with the on-road vehicle trips required to transport workers to and from the Project site during construction.3 1 “California Emissions Estimator Model.” CAPCOA, 2017, available at: http://www.aqmd.gov/caleemod/home. 2 “California Emissions Estimator Model.” CAPCOA, 2017, available at: http://www.aqmd.gov/caleemod/home. 3 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/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:

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

Default Worker Trip Parameters and Potential Local Hire Requirements As previously discussed, the number, length, and vehicle class of worker trips are utilized by CalEEMod to calculate emissions associated with the on-road vehicle trips required to transport workers to and from the Project site during construction.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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Location Type Location Name Rural H-W
(miles)
Urban H-W
(miles)
Air Basin Great Basin 16.8 10.8
Air Basin Lake County 16.8 10.8
Air Basin Lake Tahoe 16.8 10.8
Air Basin Mojave Desert 16.8 10.8
Air Basin Mountain 16.8 10.8
Air Basin North Central 17.1 12.3
Air Basin North Coast 16.8 10.8
Air Basin Northeast 16.8 10.8
Air Basin Sacramento 16.8 10.8
Air Basin Salton Sea 14.6 11
Air Basin San Diego 16.8 10.8
Air Basin San Francisco

10.8 10.8
Air Basin San Joaquin 16.8 10.8
Air Basin South Central 16.8 10.8
Air Basin South Coast 19.8 14.7
Air District Amador County 16.8 10.8
Air District Antelope Valley 16.8 10.8
Air District Bay Area AQMD 10.8 10.8
Air District Butte County 12.54 12.54
Air District Calaveras

16.8 10.8
Air District Colusa County 16.8 10.8
Air District El Dorado

16.8 10.8
Air District Feather River 16.8 10.8
Air District Glenn County 16.8 10.8
Air District Great Basin 16.8 10.8
Air District Imperial County 10.2 7.3
Air District Kern County 16.8 10.8
Air District Lake County 16.8 10.8
Air District Lassen County 16.8 10.8
Air District Mariposa

16.8 10.8
Air District Mendocino

16.8 10.8
Air District Modoc County 16.8 10.8
Air District Mojave Desert 16.8 10.8
Air District Monterey Bay

16.8 10.8
Air District North Coast

16.8 10.8
Air District Northern Sierra 16.8 10.8
Air District Northern

16.8 10.8
Air District Placer County 16.8 10.8
Air District Sacramento 15 10
Attachment A

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Air District San Diego

16.8 10.8
Air District San Joaquin

16.8 10.8
Air District San Luis Obispo

13 13
Air District Santa Barbara

8.3 8.3
Air District Shasta County 16.8 10.8
Air District Siskiyou County

16.8 10.8
Air District South Coast 19.8 14.7
Air District Tehama County 16.8 10.8
Air District Tuolumne 16.8 10.8
Air District Ventura County 16.8 10.8
Air District Yolo/Solano 15 10
County Alameda 10.8 10.8
County Alpine 16.8 10.8
County Amador 16.8 10.8
County Butte 12.54 12.54
County Calaveras 16.8 10.8
County Colusa 16.8 10.8
County Contra Costa 10.8 10.8
County Del Norte 16.8 10.8
County El Dorado-Lake 16.8 10.8
County El Dorado- 16.8 10.8
County Fresno 16.8 10.8
County Glenn 16.8 10.8
County Humboldt 16.8 10.8
County Imperial 10.2 7.3
County Inyo 16.8 10.8
County Kern-Mojave 16.8 10.8
County Kern-San 16.8 10.8
County Kings 16.8 10.8
County Lake 16.8 10.8
County Lassen 16.8 10.8
County Los Angeles- 16.8 10.8
County Los Angeles- 19.8 14.7
County Madera 16.8 10.8
County Marin 10.8 10.8
County Mariposa 16.8 10.8
County Mendocino- 16.8 10.8
County Mendocino- 16.8 10.8
County Mendocino- 16.8 10.8
County Mendocino- 16.8 10.8
County Merced 16.8 10.8
County Modoc 16.8 10.8
County Mono 16.8 10.8
County Monterey 16.8 10.8
County Napa 10.8 10.8

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County Nevada 16.8 10.8
County Orange 19.8 14.7
County Placer-Lake 16.8 10.8
County Placer-Mountain 16.8 10.8
County Placer- 16.8 10.8
County Plumas 16.8 10.8
County Riverside- 16.8 10.8
County Riverside-

19.8 14.7
County Riverside-Salton 14.6 11
County Riverside-South 19.8 14.7
County Sacramento 15 10
County San Benito 16.8 10.8
County San Bernardino-

16.8 10.8
County San Bernardino-

19.8 14.7
County San Diego 16.8 10.8
County San Francisco 10.8 10.8
County San Joaquin 16.8 10.8
County San Luis Obispo 13 13
County San Mateo 10.8 10.8
County Santa Barbara-

8.3 8.3
County Santa Barbara-

8.3 8.3
County Santa Clara 10.8 10.8
County Santa Cruz 16.8 10.8
County Shasta 16.8 10.8
County Sierra 16.8 10.8
County Siskiyou 16.8 10.8
County Solano- 15 10
County Solano-San 16.8 10.8
County Sonoma-North 16.8 10.8
County Sonoma-San 10.8 10.8
County Stanislaus 16.8 10.8
County Sutter 16.8 10.8
County Tehama 16.8 10.8
County Trinity 16.8 10.8
County Tulare 16.8 10.8
County Tuolumne 16.8 10.8
County Ventura 16.8 10.8
County Yolo 15 10
County Yuba 16.8 10.8
Statewide Statewide 16.8 10.8

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Air Basin Rural (miles) Urban (miles)
Great Basin Valleys 16.8 10.8
Lake County 16.8 10.8
Lake Tahoe 16.8 10.8
Mojave Desert 16.8 10.8
Mountain Counties 16.8 10.8
North Central Coast 17.1 12.3
North Coast 16.8 10.8
Northeast Plateau 16.8 10.8
Sacramento Valley 16.8 10.8
Salton Sea 14.6 11
San Diego 16.8 10.8
San Francisco Bay Area 10.8 10.8
San Joaquin Valley 16.8 10.8
South Central Coast 16.8 10.8
South Coast 19.8 14.7
Average 16.47 11.17
Mininum 10.80 10.80
Maximum 19.80 14.70
Range 9.00 3.90
Worker Trip Length by Air Basin

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

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

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company Southern California Edison
2028Operational Year
CO2 Intensity
(lb/MWhr)
702.44 0.029CH4 Intensity
(lb/MWhr)

0.006N2O Intensity
(lb/MWhr)
Village South Specific Plan (Proposed)
Los Angeles-South Coast County, Annual
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 1 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual Attachment B

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Project Characteristics - Consistent with the DEIR's model.

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

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

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

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

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

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

Area Mitigation - See SWAPE comment regarding operational mitigation measures.

Water Mitigation - See SWAPE comment regarding operational mitigation measures.

Table Name Column Name Default Value New Value
tblFireplaces FireplaceWoodMass 1,019.20 0.00
tblFireplaces FireplaceWoodMass 1,019.20 0.00
tblFireplaces NumberWood 1.25 0.00
tblFireplaces NumberWood 48.75 0.00
tblVehicleTrips ST_TR 7.16 6.17
tblVehicleTrips ST_TR 6.39 3.87
tblVehicleTrips ST_TR 2.46 1.39
tblVehicleTrips ST_TR 158.37 79.82
tblVehicleTrips ST_TR 8.19 3.75
tblVehicleTrips ST_TR 94.36 63.99
tblVehicleTrips ST_TR 49.97 10.74
tblVehicleTrips SU_TR 6.07 6.16
tblVehicleTrips SU_TR 5.86 4.18
tblVehicleTrips SU_TR 1.05 0.69
tblVehicleTrips SU_TR 131.84 78.27
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2.0 Emissions Summary
tblVehicleTrips SU_TR 5.95 3.20
tblVehicleTrips SU_TR 72.16 57.65
tblVehicleTrips SU_TR 25.24 6.39
tblVehicleTrips WD_TR 6.59 5.83
tblVehicleTrips WD_TR 6.65 4.13
tblVehicleTrips WD_TR 11.03 6.41
tblVehicleTrips WD_TR 127.15 65.80
tblVehicleTrips WD_TR 8.17 3.84
tblVehicleTrips WD_TR 89.95 62.64
tblVehicleTrips WD_TR 42.70 9.43
tblWoodstoves NumberCatalytic 1.25 0.00
tblWoodstoves NumberCatalytic 48.75 0.00
tblWoodstoves NumberNoncatalytic 1.25 0.00
tblWoodstoves NumberNoncatalytic 48.75 0.00
tblWoodstoves WoodstoveDayYear 25.00 0.00
tblWoodstoves WoodstoveDayYear 25.00 0.00
tblWoodstoves WoodstoveWoodMass 999.60 0.00
tblWoodstoves WoodstoveWoodMass 999.60 0.00
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2.1 Overall Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2021 0.1713 1.8242 1.1662 2.4000e-
003

0.4169 0.0817 0.4986 0.1795 0.0754 0.2549 0.0000 213.1969 213.1969 0.0601 0.0000 214.6993 2022 0.6904 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721.682 6 1,721.682
6 0.1294 0.0000 1,724.918
7 2023 0.6148 3.3649 5.6747 0.0178 1.1963 0.0996 1.2959 0.3203 0.0935 0.4138 0.0000 1,627.529 5 1,627.529
5 0.1185 0.0000 1,630.492
5 2024 4.1619 0.1335 0.2810 5.9000e-
004

0.0325 6.4700e-
003

0.0390 8.6300e-
003

6.0400e-
003

0.0147 0.0000 52.9078 52.9078 8.0200e-
003

0.0000 53.1082
Maximum 4.1619 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721.682 6 1,721.682
6 0.1294 0.0000 1,724.918
7 Unmitigated Construction
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2.1 Overall Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2021 0.1713 1.8242 1.1662 2.4000e-
003

0.4169 0.0817 0.4986 0.1795 0.0754 0.2549 0.0000 213.1967 213.1967 0.0601 0.0000 214.6991 2022 0.6904 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721.682 3 1,721.682
3 0.1294 0.0000 1,724.918
3 2023 0.6148 3.3648 5.6747 0.0178 1.1963 0.0996 1.2959 0.3203 0.0935 0.4138 0.0000 1,627.529 1 1,627.529
1 0.1185 0.0000 1,630.492
1 2024 4.1619 0.1335 0.2810 5.9000e-
004

0.0325 6.4700e-
003

0.0390 8.6300e-
003

6.0400e-
003

0.0147 0.0000 52.9077 52.9077 8.0200e-
003

0.0000 53.1082
Maximum 4.1619 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721.682 3 1,721.682
3 0.1294 0.0000 1,724.918
3 Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Quarter Start Date End Date Maximum Unmitigated ROG + NOX (tons/quarter) Maximum Mitigated ROG + NOX (tons/quarter) 1 9-1-2021 11-30-2021 1.4103 1.4103
2 12-1-2021 2-28-2022 1.3613 1.3613
3 3-1-2022 5-31-2022 1.1985 1.1985
4 6-1-2022 8-31-2022 1.1921 1.1921
5 9-1-2022 11-30-2022 1.1918 1.1918
6 12-1-2022 2-28-2023 1.0774 1.0774
7 3-1-2023 5-31-2023 1.0320 1.0320
8 6-1-2023 8-31-2023 1.0260 1.0260
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2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Area 5.1437 0.2950 10.3804 1.6700e-
003

0.0714 0.0714 0.0714 0.0714 0.0000 220.9670 220.9670 0.0201 3.7400e- 003
222.5835
Energy 0.1398 1.2312 0.7770 7.6200e-
003

0.0966 0.0966 0.0966 0.0966 0.0000 3,896.073
2 3,896.073
2 0.1303 0.0468 3,913.283
3 Mobile 1.5857 7.9962 19.1834 0.0821 7.7979 0.0580 7.8559 2.0895 0.0539 2.1434 0.0000 7,620.498 6 7,620.498
6 0.3407 0.0000 7,629.016
2 Waste 0.0000 0.0000 0.0000 0.0000 207.8079 0.0000 207.8079 12.2811 0.0000 514.8354 Water 0.0000 0.0000 0.0000 0.0000 29.1632 556.6420 585.8052 3.0183 0.0755 683.7567 Total 6.8692 9.5223 30.3407 0.0914 7.7979 0.2260 8.0240 2.0895 0.2219 2.3114 236.9712 12,294.18 07 12,531.15
19 15.7904 0.1260 12,963.47
51 Unmitigated Operational
9 9-1-2023 11-30-2023 1.0265 1.0265
10 12-1-2023 2-29-2024 2.8857 2.8857
11 3-1-2024 5-31-2024 1.6207 1.6207
Highest 2.8857 2.8857
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2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Area 5.1437 0.2950 10.3804 1.6700e-
003

0.0714 0.0714 0.0714 0.0714 0.0000 220.9670 220.9670 0.0201 3.7400e- 003
222.5835
Energy 0.1398 1.2312 0.7770 7.6200e-
003

0.0966 0.0966 0.0966 0.0966 0.0000 3,896.073
2 3,896.073
2 0.1303 0.0468 3,913.283
3 Mobile 1.5857 7.9962 19.1834 0.0821 7.7979 0.0580 7.8559 2.0895 0.0539 2.1434 0.0000 7,620.498 6 7,620.498
6 0.3407 0.0000 7,629.016
2 Waste 0.0000 0.0000 0.0000 0.0000 207.8079 0.0000 207.8079 12.2811 0.0000 514.8354 Water 0.0000 0.0000 0.0000 0.0000 29.1632 556.6420 585.8052 3.0183 0.0755 683.7567 Total 6.8692 9.5223 30.3407 0.0914 7.7979 0.2260 8.0240 2.0895 0.2219 2.3114 236.9712 12,294.18 07 12,531.15
19 15.7904 0.1260 12,963.47
51 Mitigated Operational

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

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 7 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 9/1/2021 10/12/2021 5 30
2 Site Preparation Site Preparation 10/13/2021 11/9/2021 5 20 3 Grading Grading 11/10/2021 1/11/2022 5 45
4 Building Construction Building Construction 1/12/2022 12/12/2023 5 500 5 Paving Paving 12/13/2023 1/30/2024 5 35
6 Architectural Coating Architectural Coating 1/31/2024 3/19/2024 5 35 OffRoad Equipment
Residential Indoor: 2,025,000; Residential Outdoor: 675,000; Non-Residential Indoor: 326,400; Non-Residential Outdoor: 108,800; Striped Parking Area: 0 (Architectural Coating ±sqft)
Acres of Grading (Site Preparation Phase): 0
Acres of Grading (Grading Phase): 112.5
Acres of Paving: 0
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Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Demolition Concrete/Industrial Saws 1 8.00 81 0.73
Demolition Excavators 3 8.00 158 0.38
Demolition Rubber Tired Dozers 2 8.00 247 0.40
Site Preparation Rubber Tired Dozers 3 8.00 247 0.40
Site Preparation Tractors/Loaders/Backhoes 4 8.00 97 0.37 Grading Excavators 2 8.00 158 0.38
Grading Graders 1 8.00 187 0.41
Grading Rubber Tired Dozers 1 8.00 247 0.40
Grading Scrapers 2 8.00 367 0.48
Grading Tractors/Loaders/Backhoes 2 8.00 97 0.37
Building Construction Cranes 1 7.00 231 0.29
Building Construction Forklifts 3 8.00 89 0.20
Building Construction Generator Sets 1 8.00 84 0.74
Building Construction Tractors/Loaders/Backhoes 3 7.00 97 0.37 Building Construction Welders 1 8.00 46 0.45
Paving Pavers 2 8.00 130 0.42
Paving Paving Equipment 2 8.00 132 0.36
Paving Rollers 2 8.00 80 0.38
Architectural Coating Air Compressors 1 6.00 78 0.48
Trips and VMT
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3.2 Demolition - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0496 0.0000 0.0496 7.5100e-
003

0.0000 7.5100e-
003

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 0.0475 0.4716 0.3235 5.8000e-
004

0.0233 0.0233 0.0216 0.0216 0.0000 51.0012 51.0012 0.0144 0.0000 51.3601 Total 0.0475 0.4716 0.3235 5.8000e-
004

0.0496 0.0233 0.0729 7.5100e-
003

0.0216 0.0291 0.0000 51.0012 51.0012 0.0144 0.0000 51.3601 Unmitigated Construction On-Site

3.1 Mitigation Measures Construction
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Demolition 6 15.00 0.00 458.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Site Preparation 7 18.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Grading 8 20.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Building Construction 9 801.00 143.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Paving 6 15.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Architectural Coating 1 160.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 10 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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3.2 Demolition - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 1.9300e-
003

0.0634 0.0148 1.8000e-
004

3.9400e-
003

1.9000e-
004

4.1300e-
003

1.0800e-
003

1.8000e-
004

1.2600e-
003

0.0000 17.4566 17.4566 1.2100e-
003

0.0000 17.4869
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 9.7000e-
004

7.5000e-
004

8.5100e-
003

2.0000e-
005

2.4700e-
003

2.0000e-
005

2.4900e-
003

6.5000e-
004

2.0000e-
005

6.7000e-
004

0.0000 2.2251 2.2251 7.0000e-
005

0.0000 2.2267
Total 2.9000e-
003

0.0641 0.0233 2.0000e-
004

6.4100e-
003

2.1000e-
004

6.6200e-
003

1.7300e-
003

2.0000e-
004

1.9300e-
003

0.0000 19.6816 19.6816 1.2800e-
003

0.0000 19.7136
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0496 0.0000 0.0496 7.5100e-
003

0.0000 7.5100e-
003

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 0.0475 0.4716 0.3235 5.8000e-
004

0.0233 0.0233 0.0216 0.0216 0.0000 51.0011 51.0011 0.0144 0.0000 51.3600 Total 0.0475 0.4716 0.3235 5.8000e-
004

0.0496 0.0233 0.0729 7.5100e-
003

0.0216 0.0291 0.0000 51.0011 51.0011 0.0144 0.0000 51.3600 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 11 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

Page 510 of 919 ends

3.2 Demolition - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 1.9300e-
003

0.0634 0.0148 1.8000e-
004

3.9400e-
003

1.9000e-
004

4.1300e-
003

1.0800e-
003

1.8000e-
004

1.2600e-
003

0.0000 17.4566 17.4566 1.2100e-
003

0.0000 17.4869
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 9.7000e-
004

7.5000e-
004

8.5100e-
003

2.0000e-
005

2.4700e-
003

2.0000e-
005

2.4900e-
003

6.5000e-
004

2.0000e-
005

6.7000e-
004

0.0000 2.2251 2.2251 7.0000e-
005

0.0000 2.2267
Total 2.9000e-
003

0.0641 0.0233 2.0000e-
004

6.4100e-
003

2.1000e-
004

6.6200e-
003

1.7300e-
003

2.0000e-
004

1.9300e-
003

0.0000 19.6816 19.6816 1.2800e-
003

0.0000 19.7136
Mitigated Construction Off-Site

3.3 Site Preparation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.1807 0.0000 0.1807 0.0993 0.0000 0.0993 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0389 0.4050 0.2115 3.8000e-
004

0.0204 0.0204 0.0188 0.0188 0.0000 33.4357 33.4357 0.0108 0.0000 33.7061 Total 0.0389 0.4050 0.2115 3.8000e-
004

0.1807 0.0204 0.2011 0.0993 0.0188 0.1181 0.0000 33.4357 33.4357 0.0108 0.0000 33.7061 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 12 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

Page 511 of 919 ends

3.3 Site Preparation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 7.7000e-
004

6.0000e-
004

6.8100e-
003

2.0000e-
005

1.9700e-
003

2.0000e-
005

1.9900e-
003

5.2000e-
004

1.0000e-
005

5.4000e-
004

0.0000 1.7801 1.7801 5.0000e-
005

0.0000 1.7814
Total 7.7000e-
004

6.0000e-
004

6.8100e-
003

2.0000e-
005

1.9700e-
003

2.0000e-
005

1.9900e-
003

5.2000e-
004

1.0000e-
005

5.4000e-
004

0.0000 1.7801 1.7801 5.0000e-
005

0.0000 1.7814
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.1807 0.0000 0.1807 0.0993 0.0000 0.0993 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0389 0.4050 0.2115 3.8000e-
004

0.0204 0.0204 0.0188 0.0188 0.0000 33.4357 33.4357 0.0108 0.0000 33.7060 Total 0.0389 0.4050 0.2115 3.8000e-
004

0.1807 0.0204 0.2011 0.0993 0.0188 0.1181 0.0000 33.4357 33.4357 0.0108 0.0000 33.7060 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 13 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

Page 512 of 919 ends

3.3 Site Preparation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 7.7000e-
004

6.0000e-
004

6.8100e-
003

2.0000e-
005

1.9700e-
003

2.0000e-
005

1.9900e-
003

5.2000e-
004

1.0000e-
005

5.4000e-
004

0.0000 1.7801 1.7801 5.0000e-
005

0.0000 1.7814
Total 7.7000e-
004

6.0000e-
004

6.8100e-
003

2.0000e-
005

1.9700e-
003

2.0000e-
005

1.9900e-
003

5.2000e-
004

1.0000e-
005

5.4000e-
004

0.0000 1.7801 1.7801 5.0000e-
005

0.0000 1.7814
Mitigated Construction Off-Site

3.4 Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.1741 0.0000 0.1741 0.0693 0.0000 0.0693 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0796 0.8816 0.5867 1.1800e-
003

0.0377 0.0377 0.0347 0.0347 0.0000 103.5405 103.5405 0.0335 0.0000 104.3776 Total 0.0796 0.8816 0.5867 1.1800e-
003

0.1741 0.0377 0.2118 0.0693 0.0347 0.1040 0.0000 103.5405 103.5405 0.0335 0.0000 104.3776 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 14 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

Page 513 of 919 ends

3.4 Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 1.6400e-
003

1.2700e-
003

0.0144 4.0000e-
005

4.1600e-
003

3.0000e-
005

4.2000e-
003

1.1100e-
003

3.0000e-
005

1.1400e-
003

0.0000 3.7579 3.7579 1.1000e-
004

0.0000 3.7607
Total 1.6400e-
003

1.2700e-
003

0.0144 4.0000e-
005

4.1600e-
003

3.0000e-
005

4.2000e-
003

1.1100e-
003

3.0000e-
005

1.1400e-
003

0.0000 3.7579 3.7579 1.1000e-
004

0.0000 3.7607
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.1741 0.0000 0.1741 0.0693 0.0000 0.0693 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0796 0.8816 0.5867 1.1800e-
003

0.0377 0.0377 0.0347 0.0347 0.0000 103.5403 103.5403 0.0335 0.0000 104.3775 Total 0.0796 0.8816 0.5867 1.1800e-
003

0.1741 0.0377 0.2118 0.0693 0.0347 0.1040 0.0000 103.5403 103.5403 0.0335 0.0000 104.3775 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 15 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

Page 514 of 919 ends

3.4 Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 1.6400e-
003

1.2700e-
003

0.0144 4.0000e-
005

4.1600e-
003

3.0000e-
005

4.2000e-
003

1.1100e-
003

3.0000e-
005

1.1400e-
003

0.0000 3.7579 3.7579 1.1000e-
004

0.0000 3.7607
Total 1.6400e-
003

1.2700e-
003

0.0144 4.0000e-
005

4.1600e-
003

3.0000e-
005

4.2000e-
003

1.1100e-
003

3.0000e-
005

1.1400e-
003

0.0000 3.7579 3.7579 1.1000e-
004

0.0000 3.7607
Mitigated Construction Off-Site

3.4 Grading - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0807 0.0000 0.0807 0.0180 0.0000 0.0180 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0127 0.1360 0.1017 2.2000e-
004

5.7200e-
003

5.7200e-
003

5.2600e-
003

5.2600e-
003

0.0000 19.0871 19.0871 6.1700e-
003

0.0000 19.2414
Total 0.0127 0.1360 0.1017 2.2000e-
004

0.0807 5.7200e-
003

0.0865 0.0180 5.2600e-
003

0.0233 0.0000 19.0871 19.0871 6.1700e-
003

0.0000 19.2414
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 16 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

Page 515 of 919 ends

3.4 Grading - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 2.8000e-
004

2.1000e-
004

2.4400e-
003

1.0000e-
005

7.7000e-
004

1.0000e-
005

7.7000e-
004

2.0000e-
004

1.0000e-
005

2.1000e-
004

0.0000 0.6679 0.6679 2.0000e-
005

0.0000 0.6684
Total 2.8000e-
004

2.1000e-
004

2.4400e-
003

1.0000e-
005

7.7000e-
004

1.0000e-
005

7.7000e-
004

2.0000e-
004

1.0000e-
005

2.1000e-
004

0.0000 0.6679 0.6679 2.0000e-
005

0.0000 0.6684
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0807 0.0000 0.0807 0.0180 0.0000 0.0180 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0127 0.1360 0.1017 2.2000e-
004

5.7200e-
003

5.7200e-
003

5.2600e-
003

5.2600e-
003

0.0000 19.0871 19.0871 6.1700e-
003

0.0000 19.2414
Total 0.0127 0.1360 0.1017 2.2000e-
004

0.0807 5.7200e-
003

0.0865 0.0180 5.2600e-
003

0.0233 0.0000 19.0871 19.0871 6.1700e-
003

0.0000 19.2414
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 17 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

Page 516 of 919 ends

3.4 Grading - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 2.8000e-
004

2.1000e-
004

2.4400e-
003

1.0000e-
005

7.7000e-
004

1.0000e-
005

7.7000e-
004

2.0000e-
004

1.0000e-
005

2.1000e-
004

0.0000 0.6679 0.6679 2.0000e-
005

0.0000 0.6684
Total 2.8000e-
004

2.1000e-
004

2.4400e-
003

1.0000e-
005

7.7000e-
004

1.0000e-
005

7.7000e-
004

2.0000e-
004

1.0000e-
005

2.1000e-
004

0.0000 0.6679 0.6679 2.0000e-
005

0.0000 0.6684
Mitigated Construction Off-Site

3.5 Building Construction - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.2158 1.9754 2.0700 3.4100e-
003

0.1023 0.1023 0.0963 0.0963 0.0000 293.1324 293.1324 0.0702 0.0000 294.8881 Total 0.2158 1.9754 2.0700 3.4100e-
003

0.1023 0.1023 0.0963 0.0963 0.0000 293.1324 293.1324 0.0702 0.0000 294.8881 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 18 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

Page 517 of 919 ends

3.5 Building Construction - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0527 1.6961 0.4580 4.5500e-
003

0.1140 3.1800e-
003

0.1171 0.0329 3.0400e-
003

0.0359 0.0000 441.9835 441.9835 0.0264 0.0000 442.6435
Worker 0.4088 0.3066 3.5305 0.0107 1.1103 8.8700e-
003

1.1192 0.2949 8.1700e-
003

0.3031 0.0000 966.8117 966.8117 0.0266 0.0000 967.4773
Total 0.4616 2.0027 3.9885 0.0152 1.2243 0.0121 1.2363 0.3278 0.0112 0.3390 0.0000 1,408.795 2 1,408.795
2 0.0530 0.0000 1,410.120
8 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.2158 1.9754 2.0700 3.4100e-
003

0.1023 0.1023 0.0963 0.0963 0.0000 293.1321 293.1321 0.0702 0.0000 294.8877 Total 0.2158 1.9754 2.0700 3.4100e-
003

0.1023 0.1023 0.0963 0.0963 0.0000 293.1321 293.1321 0.0702 0.0000 294.8877 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 19 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

Page 518 of 919 ends

3.5 Building Construction - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0527 1.6961 0.4580 4.5500e-
003

0.1140 3.1800e-
003

0.1171 0.0329 3.0400e-
003

0.0359 0.0000 441.9835 441.9835 0.0264 0.0000 442.6435
Worker 0.4088 0.3066 3.5305 0.0107 1.1103 8.8700e-
003

1.1192 0.2949 8.1700e-
003

0.3031 0.0000 966.8117 966.8117 0.0266 0.0000 967.4773
Total 0.4616 2.0027 3.9885 0.0152 1.2243 0.0121 1.2363 0.3278 0.0112 0.3390 0.0000 1,408.795 2 1,408.795
2 0.0530 0.0000 1,410.120
8 Mitigated Construction Off-Site

3.5 Building Construction - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.1942 1.7765 2.0061 3.3300e-
003

0.0864 0.0864 0.0813 0.0813 0.0000 286.2789 286.2789 0.0681 0.0000 287.9814 Total 0.1942 1.7765 2.0061 3.3300e-
003

0.0864 0.0864 0.0813 0.0813 0.0000 286.2789 286.2789 0.0681 0.0000 287.9814 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 20 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

Page 519 of 919 ends

3.5 Building Construction - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0382 1.2511 0.4011 4.3000e-
003

0.1113 1.4600e-
003

0.1127 0.0321 1.4000e-
003

0.0335 0.0000 417.9930 417.9930 0.0228 0.0000 418.5624
Worker 0.3753 0.2708 3.1696 0.0101 1.0840 8.4100e-
003

1.0924 0.2879 7.7400e-
003

0.2957 0.0000 909.3439 909.3439 0.0234 0.0000 909.9291
Total 0.4135 1.5218 3.5707 0.0144 1.1953 9.8700e-
003

1.2051 0.3200 9.1400e-
003

0.3292 0.0000 1,327.336
9 1,327.336
9 0.0462 0.0000 1,328.491
6 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.1942 1.7765 2.0061 3.3300e-
003

0.0864 0.0864 0.0813 0.0813 0.0000 286.2785 286.2785 0.0681 0.0000 287.9811 Total 0.1942 1.7765 2.0061 3.3300e-
003

0.0864 0.0864 0.0813 0.0813 0.0000 286.2785 286.2785 0.0681 0.0000 287.9811 Mitigated Construction On-Site
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3.5 Building Construction - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0382 1.2511 0.4011 4.3000e-
003

0.1113 1.4600e-
003

0.1127 0.0321 1.4000e-
003

0.0335 0.0000 417.9930 417.9930 0.0228 0.0000 418.5624
Worker 0.3753 0.2708 3.1696 0.0101 1.0840 8.4100e-
003

1.0924 0.2879 7.7400e-
003

0.2957 0.0000 909.3439 909.3439 0.0234 0.0000 909.9291
Total 0.4135 1.5218 3.5707 0.0144 1.1953 9.8700e-
003

1.2051 0.3200 9.1400e-
003

0.3292 0.0000 1,327.336
9 1,327.336
9 0.0462 0.0000 1,328.491
6 Mitigated Construction Off-Site

3.6 Paving - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 6.7100e-
003

0.0663 0.0948 1.5000e-
004

3.3200e-
003

3.3200e-
003

3.0500e-
003

3.0500e-
003

0.0000 13.0175 13.0175 4.2100e-
003

0.0000 13.1227
Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 6.7100e-
003

0.0663 0.0948 1.5000e-
004

3.3200e-
003

3.3200e-
003

3.0500e-
003

3.0500e-
003

0.0000 13.0175 13.0175 4.2100e-
003

0.0000 13.1227
Unmitigated Construction On-Site
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3.6 Paving - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 3.7000e-
004

2.7000e-
004

3.1200e-
003

1.0000e-
005

1.0700e-
003

1.0000e-
005

1.0800e-
003

2.8000e-
004

1.0000e-
005

2.9000e-
004

0.0000 0.8963 0.8963 2.0000e-
005

0.0000 0.8968
Total 3.7000e-
004

2.7000e-
004

3.1200e-
003

1.0000e-
005

1.0700e-
003

1.0000e-
005

1.0800e-
003

2.8000e-
004

1.0000e-
005

2.9000e-
004

0.0000 0.8963 0.8963 2.0000e-
005

0.0000 0.8968
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 6.7100e-
003

0.0663 0.0948 1.5000e-
004

3.3200e-
003

3.3200e-
003

3.0500e-
003

3.0500e-
003

0.0000 13.0175 13.0175 4.2100e-
003

0.0000 13.1227
Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 6.7100e-
003

0.0663 0.0948 1.5000e-
004

3.3200e-
003

3.3200e-
003

3.0500e-
003

3.0500e-
003

0.0000 13.0175 13.0175 4.2100e-
003

0.0000 13.1227
Mitigated Construction On-Site
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Page 522 of 919 ends

3.6 Paving - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 3.7000e-
004

2.7000e-
004

3.1200e-
003

1.0000e-
005

1.0700e-
003

1.0000e-
005

1.0800e-
003

2.8000e-
004

1.0000e-
005

2.9000e-
004

0.0000 0.8963 0.8963 2.0000e-
005

0.0000 0.8968
Total 3.7000e-
004

2.7000e-
004

3.1200e-
003

1.0000e-
005

1.0700e-
003

1.0000e-
005

1.0800e-
003

2.8000e-
004

1.0000e-
005

2.9000e-
004

0.0000 0.8963 0.8963 2.0000e-
005

0.0000 0.8968
Mitigated Construction Off-Site

3.6 Paving - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0109 0.1048 0.1609 2.5000e-
004

5.1500e-
003

5.1500e-
003

4.7400e-
003

4.7400e-
003

0.0000 22.0292 22.0292 7.1200e-
003

0.0000 22.2073
Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0109 0.1048 0.1609 2.5000e-
004

5.1500e-
003

5.1500e-
003

4.7400e-
003

4.7400e-
003

0.0000 22.0292 22.0292 7.1200e-
003

0.0000 22.2073
Unmitigated Construction On-Site
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3.6 Paving - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 5.9000e-
004

4.1000e-
004

4.9200e-
003

2.0000e-
005

1.8100e-
003

1.0000e-
005

1.8200e-
003

4.8000e-
004

1.0000e-
005

4.9000e-
004

0.0000 1.4697 1.4697 4.0000e-
005

0.0000 1.4706
Total 5.9000e-
004

4.1000e-
004

4.9200e-
003

2.0000e-
005

1.8100e-
003

1.0000e-
005

1.8200e-
003

4.8000e-
004

1.0000e-
005

4.9000e-
004

0.0000 1.4697 1.4697 4.0000e-
005

0.0000 1.4706
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0109 0.1048 0.1609 2.5000e-
004

5.1500e-
003

5.1500e-
003

4.7400e-
003

4.7400e-
003

0.0000 22.0292 22.0292 7.1200e-
003

0.0000 22.2073
Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0109 0.1048 0.1609 2.5000e-
004

5.1500e-
003

5.1500e-
003

4.7400e-
003

4.7400e-
003

0.0000 22.0292 22.0292 7.1200e-
003

0.0000 22.2073
Mitigated Construction On-Site
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Page 524 of 919 ends

3.6 Paving - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 5.9000e-
004

4.1000e-
004

4.9200e-
003

2.0000e-
005

1.8100e-
003

1.0000e-
005

1.8200e-
003

4.8000e-
004

1.0000e-
005

4.9000e-
004

0.0000 1.4697 1.4697 4.0000e-
005

0.0000 1.4706
Total 5.9000e-
004

4.1000e-
004

4.9200e-
003

2.0000e-
005

1.8100e-
003

1.0000e-
005

1.8200e-
003

4.8000e-
004

1.0000e-
005

4.9000e-
004

0.0000 1.4697 1.4697 4.0000e-
005

0.0000 1.4706
Mitigated Construction Off-Site

3.7 Architectural Coating - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Archit. Coating 4.1372 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 3.1600e-
003

0.0213 0.0317 5.0000e-
005

1.0700e-
003

1.0700e-
003

1.0700e-
003

1.0700e-
003

0.0000 4.4682 4.4682 2.5000e-
004

0.0000 4.4745
Total 4.1404 0.0213 0.0317 5.0000e-
005

1.0700e-
003

1.0700e-
003

1.0700e-
003

1.0700e-
003

0.0000 4.4682 4.4682 2.5000e-
004

0.0000 4.4745
Unmitigated Construction On-Site
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Page 525 of 919 ends

3.7 Architectural Coating - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0101 6.9900e-
003

0.0835 2.8000e-
004

0.0307 2.3000e-
004

0.0309 8.1500e-
003

2.2000e-
004

8.3700e-
003

0.0000 24.9407 24.9407 6.1000e-
004

0.0000 24.9558
Total 0.0101 6.9900e-
003

0.0835 2.8000e-
004

0.0307 2.3000e-
004

0.0309 8.1500e-
003

2.2000e-
004

8.3700e-
003

0.0000 24.9407 24.9407 6.1000e-
004

0.0000 24.9558
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Archit. Coating 4.1372 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 3.1600e-
003

0.0213 0.0317 5.0000e-
005

1.0700e-
003

1.0700e-
003

1.0700e-
003

1.0700e-
003

0.0000 4.4682 4.4682 2.5000e-
004

0.0000 4.4745
Total 4.1404 0.0213 0.0317 5.0000e-
005

1.0700e-
003

1.0700e-
003

1.0700e-
003

1.0700e-
003

0.0000 4.4682 4.4682 2.5000e-
004

0.0000 4.4745
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 27 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

Page 526 of 919 ends
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