5. Response to IS-MND Comments and Errata — Anaheim City Council, February 27, 2024 (part 1 of 3)

Initial Study/Mitigated Negative Declaration
Responses to Comments

Pacific Resort Plaza
Development Project No. 2019-00161

Prepared for Planning Services Division
City of Anaheim
200 South Anaheim Boulevard
Anaheim, California 92805

Prepared by Psomas
5 Hutton Centre Drive, Suite 300
Santa Ana, California 92707-8708
January 2024

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RESPONSES TO COMMENTS ON THE

INITIAL STUDY/MITIGATED NEGATIVE DECLARATION FOR THE

PACIFIC RESORT PLAZA
Pursuant to the California Environmental Quality Act (CEQA), the potential environmental effects of the proposed Pacific Resort Plaza (Project) have been analyzed in an Initial Study/Mitigated Negative Declaration (IS/MND) dated October 2023. The IS/MND was subject to a 20-day public review period which began on October 19, 2023 and ended on November 8, 2023. The City distributed a Notice of Intent (NOI) to adopt an MND along with the IS.

Two letters commenting on the information and analysis in the IS/MND were received during the public review period from the following agencies and/or individuals:
 California Department of Transportation, District 12 (November 8, 2023)  Brian Flynn, Lozeau Drury LLC (November 8, 2023)
Three letters commenting on the information and analysis in the IS/MND were received after the public review period from the following individuals:
 Brian Flynn, Lozeau Drury LLC (November 29, 2023)
 Mitchell M. Tsai, Law Firm (December 4, 2023)
 Jordan R. Sisson, GK Law (December 4, 2023)
CEQA Guidelines Section 15074(b) states that prior to approving a project, the lead agency must consider the proposed IS/MND together with any comments received during the public review process. Written responses to comments are not required; however, the City of Anaheim, as lead agency, has prepared a written response to the comment received for consideration by the City Council. The comment letter followed by the City’s response are attached. The number provided in the right margin of the comment letters corresponds to the response to the comment.

Based on the evaluation in the IS/MND and the comment received, the City has determined that all potential impacts associated with the proposed project are less than significant with incorporation of identified mitigation measures (MMs). A Mitigation Monitoring and Reporting Program has also been prepared and will be implemented for the proposed project. Therefore, the City of Anaheim has determined that an MND in accordance with CEQA is the appropriate environmental document for the proposed project.

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California Department of Transportation, District 12
November 8, 2023

Response 1.1. The comment requests coordination with Caltrans District 12 Electrical System Branch to ensure that signal improvements are feasible and acceptable to optimize traffic flow between the City and Caltrans intersections to ensure effective operation of the intersections. The comment in noted, and coordination will occur directly with Caltrans.

Response 1.2 The comment recommends adding buffers to the proposed Class II bike lane and installing hazards striping across driveways and intersections. Flashing bike/ped beacons are also recommended. As stated on Page 5-76 of the IS/MND, due to the proposed bikeways connecting to the Proposed Project, it is recommended that the developer provide visible and adequate bike and bike parking facilities for both employees and patrons. Also, the developer will coordinate with the City of Anaheim regardi ng any proposed bicycle and pedestrian pathway improvements as part of the project.

Response 1.3 The comment considers encouraging or incentivizing the use of transit among both construction workers and the proposed development and future employees. Increasing multimodal transportation will lead to a reduction in congestion and vehicle miles traveled (VMT), and improve air quality. As stated on Page 5-18 of the IS/MND, the project proposes hotel uses in a Transit Priority Area (TPA). The Orange County Transportation Authority (OCTA) and Anaheim Resort Transportation (ART) all operate bus lines within the area of the Project Site.

Line 46 and 47 of the OCTA lines and Line 8 and Line 17 of the ART Lines are proximate to the Project Site. ART would provide service at 20- to 40-minute headways for the project while OCTA lines provide 15- to 40-minute headways. The Proposed Project is located immediately adjacent to bus stops on Anaheim Boulevard. As detailed in the project’s VMT Screening Memorandum, the project would be consistent with the applicable Sustainable Communities Strategy (SCS) as the project’s land uses are consistent with the General Plan land use designation. The development of a mix of uses at the site would likewise reduce vehicular trips. The developer intends to include rideshare and vanpooling opportunities for employees and patrons. In addition, the project would also be developed consistent with the stringent energy efficiency requirements detailed in the 2022 Title 24 Building Standards. Be cause the project would replace less energy efficient land uses with buildings that meet the latest energy efficiency measures and would develop uses within a TPA.

Response 1.4 The comment considers the need for equitable access to amenities and resources, and requests consideration of referencing the City’s General Plan Environmental Justice Element that is in development. In response to this comment, the following text is added on page 5-59, following the first paragraph. New text is shown as bold and underline.

As noted on the City’s website, a draft of the Environmental Justice Element is currently available for public review. The new Environmental Justice Element will become part of the City’s General Plan, which represents the community’s view of its future and is often referred to as a blueprint for growth and development.

Through the process of creating the element, the City will evaluate its existing policies and create new ones to minimize pollution and its effects on all neighborhoods, with an emphasis on those in environmental justice communities.

R:\Projects\ANA\3ANA009405\Environmental Documentation\RTC\RTC Pacific Resort Plaza-011924.docx 6 Responses to Comments distribution of resources. The Environmental Justice Element will cover the eight topics below:
 Reduce pollution exposure and improve air quality
 Promote public facilities
 Promote food access
 Promote safe and sanitary homes
 Promote physical activity
 Reduce any additional unique or compounded health risks  Promote civic engagement in the public decision-making process  Prioritize improvements and programs that address the needs of disadvantaged communities
The State of California is asking cities to incorporate environmental justice related goals, policies and programs into their general plan. The City of Anaheim is creating a stand-alone Element to have all environmental justice-related topics in one document for easy reference. An environmental justice community is an area of a community disproportionately affected by environmental pollution and other hazards that can lead to negative health effects, exposure, or environmental degradation. These areas deserve special attention to address issues of environmental justice. Within the City of Anaheim, 51 out of 75 census tracts fall under this designation. While the Environmental Justice Element will apply to all areas of the City, special attention will be given to environmental justice communities.

Response 1.5 The comment states that any work performed within Caltrans right-of-way will require discretionary review and approval by Caltrans and an encroachment permit will be required prior to construction. The comment in noted, and coordination will occur directly with Caltrans.

Response 1.6 The comment states that project plans and traffic control plans must be stamped and signed by a licensed engineer. The comment in noted, and coordination will occur directly with Caltrans.

Response 1.8 The commentor asks that all applications and associated documents/plans be submitted via email to [email protected] until further notice. Caltrans Encroachment Permits is transitioning to an online web portal base for all applications. The comment is noted, and all applicable information will be submitted via the email address listed above.

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Brian Flynn, Lozeau Drury LLC
November 8, 2023

Response 2.1. The comment states that Supporters Alliance for Environmental Responsibility (SAFER) is concerned that the IS/MND is improper under the California Environmental Quality Act (CEQA) due to the IS/MND’s failure to adequately assess the project’s potentially significant impacts. SAFER requests that an Environmental Impact Report (EIR) be prepared for the Project rather than an MND to ensure that potentially significant impacts of this project are fully disclosed, analyzed, and mitigated.

An EIR is not required for the Project because all potentially significant impacts would be mitigated to a less than significant level under the MND and the commenter has not provided any evidence to the contrary. The commenter is referred to the entirety of the IS/MND which provides a full analysis of the project, including a detailed description of the project’s elements, and an evaluation of both project construction and operations. The IS/MND also identifies multiple mitigation measures related to Biological Resources, Cultural Resources, Geology and Soils, Hydrology and Water Quality, Noise, and Tribal Cultural Resources, which are required to reduce impacts to less than significant levels. It is noted that a mitigation measure has been identified in the Utilities and Service Systems due to its applicability, however this mitigation measure is not required to reduce a potentially significant impact.

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Brian Flynn, Lozeau Drury LLC
November 29, 2023

Response 3.1. The comment is submitted on behalf of the Supporters Alliance for Environmental Responsibility (SAFER). No response is required.

Response 3.2. The commenter’s review of the IS/MND was assisted by Soil/Water/Air Protection Enterprises (SWAPE). No response is required.

Response 3.3. The comment states that there is fair argument that the Project may result in significant impacts, including significant cancer risks to nearby residents due to emissions of diesel particulate matter. Furthermore, several of the IS/MND’s conclusions are not supported by substantial evidence. These concerns are detailed in later comments and responded to accordingly in Responses 3.4 through 3.13.

The commenter also requests that the City prepare an Environmental Impact Report (EIR) in order to comply with the California Environmental Quality Act (Act). Please refer to Response 2.1 above.

Response 3.4. The comment reiterates the Project description. No response is required.

Response 3.5. The commenter describes the legal standard for Negative Declarations. No response is required.

Response 3.6. The commenter states that an EIR is required due to a fair argument that the Project may result in significant health impacts from emissions of diesel particulate matter (DPM).

Additionally, the IS/MND’s analysis of the cancer risk posed by emissions of DPM was inadequate. The commenter believes that preparation of a quantified Health Risk Assessment (HRA) is necessary for construction and operation of the Project.

Please refer to the analysis in Section III, Air Quality, of the IS/MND, under Threshold © which states that there would be relatively few pieces of off-road, heavy-duty diesel equipment in operation, and the total construction period would be relatively short when compared to a 40-year exposure period. Combined with the highly dispersive properties of DPM and the nearest sensitive uses located approximately 130 feet away as well as additional reductions in particulate emissions from newer construction equipment, as required by U.S. Environmental Protection Agency (EPA) and California Air Resources Board (CARB) regulations, construction emissions of TACs would not expose sensitive receptors to substantial emissions of TACs. Impacts were determined to be less than significant, and no mitigation is required.

Response 3.7. The comment states that the IS/MND failed to adequately analyze the Project’s health impacts from emissions of DPM. Please refer to Response 3.6 above.

Response 3.8. The comment states that the Project will result in significant increased cancer risks from emissions of DMP. Please refer to Response 3.6 above.

Response 3.9. The comment states that an EIR is required due to a fair argument that the Project may result in significant greenhouse gas emissions. The SCAQMD does not have an adopted significance threshold except for industrial uses. The SCAQMD’s Greenhouse Gas CEQA Significance Thresholds website provides guidance on how to evaluate the significance of GHG emissions from development projects. According to the SCAQMD’s website “To provide guidance to local lead agencies on determining significance for GHG emissions in their CEQA documents, Pacific Resort Plaza

R:\Projects\ANA\3ANA009405\Environmental Documentation\RTC\RTC Pacific Resort Plaza-011924.docx 18 Responses to Comments the SCAQMD staff is convening an ongoing GHG CEQA Significance Threshold Working Group.

Members of the working group include gov ernment agencies implementing CEQA and representatives from various stakeholder groups that provide input to the SCAQMD staff on developing GHG CEQA significance thresholds. On December 5, 2008, the SCAQMD Governing Board adopted the staff proposal for an interim GHG significance threshold for projects where the SCAQMD is lead agency. The board letter, resolution, interim GHG significance threshold, draft guidance document and attachments can be found below or under the Board Agenda Item 31 on the December 5, 2008, Governing Board meeting agenda.” ( https://www.aqmd.gov/home/rules- compliance/ceqa/air-quality-analysis-handbook/ghg-significance-thresholds).

The SCAQMD’s website then provides links to the Interim CEQA GHG Significance Thresholds.

One of the adopted interim GHG Significance Thresholds is 3,000 metric tonne of carbon dioxide equivalent (MTCO2e) “bright-line” threshold which is a screening threshold. As such, even though the comment mentions that the SCAQMD’s interim GHG Significance threshold is dated, it is the latest adopted GHG threshold provided by the SC AQMD. In addition, the SCAQMD’s criteria pollutant thresholds were published in 1993 and even though the air basin has gone through changes in ambient air quality attainment status, these thresholds are still in use by the SCAQMD.

The comment also fails to consider that the SCAQMD’s adopted significance threshold for industrial uses of 10,000 metric tonnes of carbon dioxide equivalent is also a “bright-line” threshold that has been in use since 2008 and is not a per capita threshold. As such, the commenter’s assertion that the 3,000 MTCO2e threshold is outdated is incorrect and contrary to the recommended interim and adopted thresholds provided by the SCAQMD.

The comment suggests that a per capita threshold is more appropriate. However, the use of a per capita threshold is also problematic based on the Golden Door Properties, LLC v. County of San Diego court decision which found that San Diego’s use of a per capita threshold was invalid since a more stringent efficiency threshold may be required for new developments where greater GHG reductions are more achievable. As such, the use of efficiency thresholds is also problematic due to this CEQA court decision.

Response 3.10. The comment states that the IS/MND’s estimate of the Project’s GHG emissions is underestimated due to:

1. Unsubstantiated changes to construction phase lengths (Ex. A, pp. 4-6.)

2. Unsubstantiated changes to off-road equipment input parameters (Ex. A, pp. 6-7.)

3. Unsubstantiated changes to architectural coating emission factors (Ex. A, pp. 7-8.)

4. Unsubstantiated changes to construction trips and VMT (Ex. A, pp. 8-9.)

5. Unsubstantiated changes to operational off-road fuel type (Ex. B, pp. 7-9.) In regard to points 1-4, the changes to the CalEEMod defaults for construction activities are based on data provided by the developer. A data request was sent to the developer to inquire about Project specific activities so as to better inform the CalEEMod emissions modeling. The data request was filled out with the developer’s best estimates of construction duration, construction equipment types and quantities, as well as hauling of demolition debris. The SCAQMD encourages adjustments to the CalEEMod modeling parameters so that the characterization of projects is customized to what is anticipated to occur for the project. Use of the CalEEMod model without customization to the specifics for each project provides generic air pollutant emissions estimates which are uninformed by specific characteristics of each project. As such, the commenter’s claim that these are “errors” is not valid.

Response 3.11. The comment states that the IS/MND’s hazards analysis is not supported by substantial evidence. Specifically, the IS/MND claims that the Project’s impacts related to hazards and hazardous materials would be less than significant solely based upon review of regulatory databases and an online review of the Cortese list.

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R:\Projects\ANA\3ANA009405\Environmental Documentation\RTC\RTC Pacific Resort Plaza-011924.docx 19 Responses to Comments The discussion in Section IX, Hazards and Hazardous Materials, of the IS/MND, under Threshold (D) identifies that the EDR Radius Map™ Report with GeoCheck®: La Quinta Hotel & Suites, 125 East Ball Road, Anaheim, CA 92805 (Inquiry Number: 6955692.2s) was prepared for the Proposed Project by Environmental Data Resources (EDR) (2022), which is based on a search of federal, State, local, tribal, and other databases. As discussed in the Section IX of the IS/MND, one listing, which includes a cluster of seven sites, was identified within the boundaries of the Project Site: ETA TRANS INC/125 E BALL RD LLC/HAHM MOTORSPORTS located at 125 East Ball Road. This site was identified on the foll owing databases: Resource Conservation and Recovery Act non generators, Facility Index System, Hazardous Waste Tracking System, Hazardous Waste Information System, Enforcement and Compliance History Online, and California Hazardous Materials Incident Report System. According to the Registered Hazardous Waste Transporter Database, the current status is “Active.” Additionally, the CHMIRS database detailed an incident that was reported on March 9, 2011, stating that “material has been stored in a barrel for the last 5 months, recent rain caused it to overflow, material flowed onto asphalt, contractor will be handling containment and clean up.” No additional violations were found.

Based on review of the Cortese List data resources, the Project Site is not located on the State of California Hazardous Waste and Substances Sites List published by the California Environmental Protection Agency (CalEPA) and compiled pursuant to Section 65962.5 of the California Government Code (referred to as the Cortese List) (CalEPA 2023). The site is not known or anticipated to have been contaminated with hazardous materials, and no hazardous material storage facilities are known to exist on site. For these reasons, the Project is not located on a site that is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5.

Response 3.12. The comment states that the IS/MND inadequately analyzes the Project’s energy impacts. Specifically, the IS/MND’s analysis of alternative energy merely relies on compliance with Title 24.

As stated in Section VI, Energy, of the IS/MND because the Project would develop hotel and restaurant uses that incorporate the latest energy efficiency standards, develop alternative energy (solar PV), provide EV parking and charging infrastructure, and meet local hotel and restaurant needs in a Transit Priority Area (TPA), energy consumption associated with the Project would not be considered inefficient, wasteful, or unnecessary, which is the significance threshold. As indicated on the project plans, solar PV will be provided on the rooftop of the hotel building and up to 25 EV charging spaces will be provided on-site.

Response 3.13. The remaining portions of the comment letter are noted for the record and will be forwarded to the decision-makers for review and consideration.

Exhibit A of this comment letter can be found in Attachment A.

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Mitchell M. Tsai, Law Firm
December 4, 2023

Response 4.1. The comment states that there is a fair argument that the Project will have a significant noise impact. The IS/MND evaluated the closest noise sensitive uses at a distance of 80 feet under “Maximum” conditions where construction activities would occur at the property line closest to the sensitive use as well as under “Ave rage” conditions where construction activities would occur at the center of the Project Site. In both instances, noise levels would be less than the noise threshold and consequently result in less than significant construction noise impacts.

There are numerous noise sensitive land uses In the area where the Project is proposed.

However, the analysis of the closest noise sensitive uses represents the worst-case noise exposure that would occur from Project relat ed construction activities. Since the Project’s construction noise levels were found to be below the noise threshold under worst-case conditions, other noise sensitive land uses located further away would result in less construction noise exposure because noise attenuates with increasing distance. As such, these other land uses located further away would likewise be exposed to noise levels that are less than the noise threshold and consequently would also result in less than significant noise impacts.

Response 4.2. The comment states that there is a fair argument that the Project will have a significant transportation impact. The VMT-scr eening analysis showed that VMT analysis is not required as part of the TIA for the Proposed Project because the Project is within a transit priority area (TPA), making it exempt from project- level CEQA VMT assessment. Additionally, the difference in Floor Area Ratio (FAR) has been revised from 0.97 to 1.08, and therefore still exceeds the 0.75 criteria.

The City has guidelines that this presumption would not apply if any of the following is true.  Has a FAR of less than 0.75;
 Includes more parking for use by residents, customers, or employees of the Project than required by jurisdiction;
 Is inconsistent with the applicable SCS (as determined by the lead agency, with input from the Metropolitan Planning Organization); or
 Replaces affordable residential units with a smaller number of moderate- or high-income residential units.

The Proposed Project is located immediately adjacent to bus stops on Anaheim Boulevard. The peak hour headways are 15 minutes or less than on Anaheim Boulevard. The Proposed Project’s FAR is 1.08, so the FAR exceeds 0.75. The Proposed Project meets but does not exceed the parking required by the City. Additionally, the Project is consistent with the applicable SCS as the Project’s mix of land uses is consistent with the City’s General Plan land use designation. There are no existing residential units on the Project Site, so no affordable units are being removed or replaced. Therefore, the Project could be screened from a VMT analysis based on the criteria for Type 1: TPA Screening and would be considered a less than significant impact on VMT, per the City of Anaheim TIA Guidelines for CEQA Analysis.

Response 4.3. The comment states that there is a fair argument that the Project will have a significant tribal cultural resources impact. MM 18-1 addresses all fundamental elements of a mitigation measure related to 1) what needs to be done; 2) how it will be done; 3) who is responsible for doing it, and 4) when it needs to be done. MM 18-1 clearly identifies the actions Pacific Resort Plaza

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Exhibit A of this comment letter can be found in Attachment B.

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GK Law
Jordan R. Sisson
December 4, 2023
Response 5.1. The commenter provides background on their represented party, UNITE HERE Local 11 and summarizes their understanding of the Project. The comment refers to a Conditional Use Permit (CUP) to allow for a greater Floor Areas Ratio (FAR) than permitted by the Code (0.98 proposed, 0.5 permitted). As discussed in Response 4.2 above, the difference in FAR has been revised from 0.97 to 1.08.

Response 5.2. The comment states that Local 11 is concerned with various aspects of the Project including the IS/MND’s analysis of air quality, hazards, and noise. The comment also states the Project should be required to maximize solar panels on all structures and commit to a robust hotel-specific rideshare program and food/plastic recycling program that will reduce waste and vehicle miles traveled (VMT) caused by the Project’s hotel component. Collectively, these failings may conceal potentially significant Project impacts and may allow for the avoidance of needed additional mitigation measures. All fundamental assumptions, project design features, and mitigation measures should be incorporated into the Mitigation Monitoring Reporting Program (MMRP). These concerns are detailed in later comments and responded to accordingly in Responses 5.3 through 5.22.

Response 5.3. The commenter identifies the Local 11 interest in the Project due to the number of members who live and work in the City of Anaheim. Local 11 wants to ensure responsible and sustainable development that reduces adver se impacts on its members and the nearby communities that they serve. No response is required.

Response 5.4. The comment indicates that because a more comprehensive EIR was not prepared, the Project is subject to deferential fair argument standard, which requires a lead agency to prepare an EIR whenever substantial evidence in the record supports a fair argument that a project may have a significant effect on the environment. Please refer to Response 2.1 above.

Response 5.5. The comment states that air quality impacts from construction may be significant.

The IS/MND claims localized air impacts from construction emissions would not exceed applicable thresholds under the South Coast Air Quality Management District (SCAQMD) localized significance threshold (LST) methodol ogy. As shown in Table 6, the IS/MND uses linearly interpolated SCAQMD thresholds (between 25- and 50-meter thresholds), based on the assumption that the “closest off-site sensitive receptors to the Project Site are residential uses located approximately 130 feet to the north of the Project boundary.” These threshold emissions are then compared to the purported maximum daily on-site emissions for various pollutants.

These concerns are detailed in later comments and responded to accordingly in Responses 5.6 through 5.13.

Response 5.6. The comment states that purported maximum emissions are unclear because emissions are reported in whole numbers instead of reporting to the hundredths place. The IS/MND reports maximum emissions in whole numbers, referencing the CalEEMod worksheets as the source.

Further, the thresholds are expressed in whole numbers unless the Project’s emissions are close to the threshold such that decimals would be needed. Therefore, the use of decimals not necessary and the emissions are instead shown as whole numbers.

Pacific Resort Plaza

R:\Projects\ANA\3ANA009405\Environmental Documentation\RTC\RTC Pacific Resort Plaza-011924.docx 60 Responses to Comments Response 5.7. The comment states that SCAQMD thresholds should be lower because the distance from sensitive receptors is less than 40 meters. As mentioned above, the IS/MND utilizes interpolated SCAQMD thresholds based on the assumption that the closest sensitive receptor (i.e., multi-family residence) is 130 feet (i.e., 40 meters) to the north of the Project boundary.

However, the IS/MND inconsistently reports the distance between the Project Site and this sensitive receptor. According to Google Maps, the distance between the Project Site (i.e., northern boundary) and the multi-family (southern property boundary) is roughly 75 feet (i.e.,

22.86 meters), which corresponds to the distance used in the IS/MND’s noise calculations contained within Appendix H.

According to SCAQMD, projects with boundaries closer than 25 meters to the nearest receptor “should use the LSTs for receptors located at 25 meters.” Hence, the correct threshold for PM10
and PM2.5 is 4 and 3 lbs/day (respectively)—not 9 and 4 as used in the IS/MND. Hence, it appears that even the Project’s currently reported maximum emissions would exceed applicable thresholds and require mitigation. A fair argument of air quality impacts likely exists here.

Sensitive receptors are defined as children, elderly, asthmatics and others who are at a heightened risk of negative health outcomes due to exposure to air pollution. As detailed in Section III, Air Quality, the closest off-site sensitive receptors to the Project Site are residential uses located approximately 130 feet to the north of the Project boundary. The emissions thresholds are for receptors within 40 meters (130 feet) of the Project Site which account for worker exposure at residential uses proximate to the Project Site. The IS/MND does not inconsistently report the distance between the Proj ect Site and sensitive receptor. For example, as discussed later in Section XIII, Noise, noise exposure levels at nearby noise sensitive uses are measured at a maximum of 80 feet. Furthermore, the vibration annoyance assessment at nearby uses was measured at a distance of 125 feet from residential uses to the north. This is due to the fact that vibration is measured to the nearest structure instead of the property line. As such, there are different noise measurements through the analyses of the IS/MND due to differences in sensitive receptor definitions in the topics of air quality, noise, and vibration.

Response 5.8. The comment states that the anticipated start of construction is likely inaccurate.

The IS/MND states that the construction of the Project will occur in two phases, including Phase 1 demolition of the existing 10,530-sf building and construction of the walk-up/drive-through fast food restaurant and associated parking over an approximately 6-month period and Phase 2 includes additional demolition, excavation, and construction of the parking puzzle lift and hotel structure over an approximately 18-month period. The IS/MND identifies an October 2023 construction start, which represents a conservative scenario since construction vehicle emission rates decline in future years. Construction start dates occurring substantially after October 2023 would result in the same or less emissions due to improvements in emission rates.

The Proposed Project was modeled with small overlap during construction. Delays in the construction of the Project would not impact proj ect emissions except for the better as cleaner technology is introduced. The use of an earlier start date for construction or operations air quality modeling provides a more conservative estimate of emissions. Since construction emissions are less than half of the SCAQMD’s significance thresholds, changes in the construction schedule to a later date would result in project related emissions being further below the significance thresholds and result in the same less than significant impact finding.

Response 5.9. The comment states the emission modeling assumes no construction during summer. Please refer to Response 5.8 above. Since construction emissions attributable to the Project are less than half of the SCAQMD significance thresholds, seasonal variations related to construction related emission rates would not substantially change the magnitude of emissions such that there would be an exceedance of the SCAQMD significance threshold nor a change to the less than significant impact finding. In term s of emissions occurring during the operations Pacific Resort Plaza

R:\Projects\ANA\3ANA009405\Environmental Documentation\RTC\RTC Pacific Resort Plaza-011924.docx 61 Responses to Comments phase of the walk-up/drive-thru fast food restaurant, the totality of emissions associated with both the walk-up/drive-thru fast food restaurant and hotel use results in emissions that are approximately 10 percent of the SCAQMD’s operations phase thresholds. This shows the very small magnitude of emissions from the entire project for which the walk-up/drive-thru fast food restaurant is only a portion of. As such, emissions associated with the operations of the walk- up/drive-thru fast food restaurant opening prior to the hotel would likewise result in emissions that are less than SCAQMD significance thresholds and less than significant air quality impacts.

Disaggregation of emissions from the Project’s proposed restaurant and hotel uses would not result in a change to the less than significant impact finding disclosed within the IS/MND.

Response 5.10. The comment states that the MND describes sequential construction (i.e., Phase 1 followed by Phase 2), with no overlapping construction of either (i) the phases (i.e., Phase 1 and Phase 2) or (ii) components of individual phases (i.e., demolition, site preparation, grading/excavation, building construction, paving, architectural coating). (MND, p. 3-2.) However, the MND does not state that construction phasing would not overlap. As such, this portion of the comment is not addressed further.

The comment is correct in their statement that the CalEEMod modeling shows Phase 1 paving (3/3/24 – 3/6/24), Phase 1 architectural coating (2/28/24 – 3/16/24), and Phase 2 paving (3/7/24 – 3/22/24) would overlap. The comment states that this phasing seems inaccurate given Phase 2 paving would typically occur after—not before—Phase 2 demolition, site preparation, grading, and excavation, building construction. The comment is correct in that Phase 2 paving construction dates were incorrect. Phase 2 pa ving would be more accurately represented as occurring between 12/09/2024 and 12/27/2024. However, while Phase 2 paving emissions were incorrectly modeled, when peak day emissions for Phase 2 paving are added to the overall peak day for 2024 construction, emissions for all analyzed criteria pollutants would still be substantially below the established SCAQMD thresholds and impacts would remain less than significant.

Moreover, paving emissions are nominal due to the small number of equipment used for this phase and would not result in a substantial increase in emissions.

Response 5.11. The comment states that excavated material from Puzzle Lift seems uncounted for. The Air Quality analyses, and all excavation quantities were provided by the Project Applicant which include all aspects of the proposed Project. Site preparation accounts for 1,050 cubic yards (cy) of exported material; the commentor states that excavation would consist of approximately 1,103 cy of excavated material. The commentor’s approximated excavation estimate is 53 cy greater than that which was modeled. As maximum daily emission levels for all criteria pollutants are less than half of the SCAQMD’s significance thresholds, a nominal increase of 53 cy of material, consistent with that approximated by the commentor, would not result in a substantial change in the magnitude of emissions nor a change in the less than significant impact finding for Project related construction activities. A less than significant impact related to Project related construction emissions would remain. Response 5.12. The comment states that no discussion of cumulative impacts related to overlapping construction of a nearby project. As detailed in Section XXI, Mandatory Findings of Significance, of t he IS/MND, the Proposed Project’s impacts would be limited and its contribution to cumulative impacts would not be cumulatively considerable.

Additionally, the property noted at 1200 South Anaheim Boulevard is not currently proposed for development, and therefore would not result in overlapping construction impacts related to the Proposed Project.

Response 5.13. The comment states that the issues mentioned above need to be resolved because they affect the IS/MND’s air quality impact analysis. There likely is a fair argument of air quality impacts during construction. All assumptions should be included as a project design feature in the Project’s MMRP, as well as any mitigation measures that may be necessary to reduce impacts to less than significant. The Ci ty should consider project-level mitigation Pacific Resort Plaza

R:\Projects\ANA\3ANA009405\Environmental Documentation\RTC\RTC Pacific Resort Plaza-011924.docx 62 Responses to Comments recommended by the Southern California Association of Governments (SCAG), the CARB, SCAQMD, and CAPCOA, including but not limited to requiring Tier 4 Final construction equipment for all off-road construction equipment. This comment is noted for the record and will be forwarded to the decision-makers for review and consideration.

Response 5.14. The comment states that the environmental hazards discussion needs more analysis. The potential existence of toxic contamination on a Project Site is a significant impact requiring CEQA review. Please refer to Response 3.11 above.

Response 5.15. The comment states that the Project Site contains seven sites registered on relevant databases. Please refer to Response 3.11 above.

Response 5.16. The comment states that the site appears to have been long used for heavy- duty/vehicle storage. Please refer to Response 3.11 above.

Response 5.17. The comment states that evidence in the EDR Radius Search and of long-term vehicle storage is substantial evidence that further investigation is necessary. Please refer to Response 3.11 above.

Response 5.18. The comment states that more details about solar panels and battery storage are needed. Please refer to Response 3.12 above.

Response 5.19. The comment states that construction noise from excavating of Puzzle Lifts needs better analysis.

Table 18, Construction Noise Levels at Nearby Noise Sensitive Uses, of the IS/MND shows both the maximum average and typical average noise levels. Maximum noise levels represent the noise levels from construction occurring near the property boundary closest to the noise sensitive use/receptor. Average noise levels represent the noise exposure to sensitive uses based on the distance to the center of all components of the Proposed Project. Noise levels from general construction activities related to the Proposed Project are evaluated against the Federal Transit Administration’s (FTA) Detailed Analysis Construction Noise Criteria. These criteria include thresholds of 80 dBA L
eq for an 8-hour daytime period, a 70 dBA Leq nighttime limit, and a 75 dBA day/night average sound level (L dn) 30-day average. Since the Project will only involve daytime construction activities, the applicable significance threshold is 80 dBA Leq. As shown in Table 18, noise exposure levels (i.e., excavation) at the nearest off-site residential use is below the FTA’s noise threshold.

Response 5.20. The comment states that intended rideshare/vanpool should be clarified. The IS/MND claims that the hotel operator intends to include “rideshare and vanpooling opportunities for employees and patrons.” More details about this program should be given, as well as a commitment to it as a project design feature to be included in the Project’s MMRP. Local 11 urges the City to consider robust TDM measures for hotel operations, which also can substantially contribute to air quality issues. Measures such as a hotel-specific mandatory commuter reduction program could include:
 Specific performance level to be reached (e.g., specific VMT or average daily trip reduction or both);
 Specified participation level (e.g., 100% employees);  Participation in guaranteed ride programs;
 Inventive employee carpool/vanpool access to preferential parking spaces or hotel valet service or both;
Pacific Resort Plaza

R:\Projects\ANA\3ANA009405\Environmental Documentation\RTC\RTC Pacific Resort Plaza-011924.docx 63 Responses to Comments  Subsidized transit passes for hotel workers and hotel patrons; and  Dedicated shuttle service for hotel patrons toward nearby destinations.

The Project will be subject to all applicable provisions of Anaheim Municipal Code Chapter 14.60 “TRANSPORTATION DEMAND”. This comment is noted for the record and will be forwarded to the decision-makers for review and consideration.

Response 5.21. The comment states that more can be done to address food and plastic waste.

The IS/MND does not address any Project-specifics as it relates to the State’s organic waste collection regulations that cover both multi-family and commercial developments (i.e., SB 1383) or how the Project will avoid wasteful use of pl astic materials. A hotel-specific recycling program seems appropriate to address the acute single-use plastics issues facing hotels, which generate higher than average waste per employee than other businesses, with 65 percent comprised of food waste, mixed paper, and mixed plastics. Consistent with the State’s SB 1383 and other plastic reduction efforts, Local 11 urges the City to consider requiring hotel-specific recycling and food waste programs, which can include various elements like:
 Promote recycled paper and other products like soap;
 Bans on disposable (i.e., designed to be used once and discarded) foodware items and accessories;
 Allowing customers to bring their own reusable items (waivable to accommodate kosher or other religious standards);
 Requirements for hand soap in refillable containers;
 No promotional items made of plastic;
 No water in plastic bottles or disposable single-use cups;  No expanded polystyrene (i.e., Styrofoam);
 Require reusable napkins and tablecloths with recyclable disposable napkins only allowed for takeout;
 Hand dryers in areas accessible to customers;
 Requirement for reusable laundry bags;
 Reusable dishware for room service;
 Eliminate coffee pods/coffee machines that require pods;  Offer toothpaste tablets in refillable packaging such as glass bottles or jars;  Provide bamboo toothbrushes;
 Offer toiletries on request rather than automatically;  Key cards made out of non-plastic materials, including traditional metal keys or wood, bamboo, and paper options for chip-based cards;
 Incentives for returning keys to discourage waste;
 Non-plastic shower caps, razors, shaving cream, slippers, eye masks, ear plugs;  Remove minifridge items that use plastic;
 Eliminate the use of garbage bags if possible, or use bags made of compostable material;  Choose home compostable gloves;
Pacific Resort Plaza

R:\Projects\ANA\3ANA009405\Environmental Documentation\RTC\RTC Pacific Resort Plaza-011924.docx 64 Responses to Comments  Do not use plastic wrap;
 Serve employee meals with reusable dishware and cutlery, as well as provide reusable water bottles for all employees with accessible water bottle refill stations;  Replace paper towels with reusable dish rags; and
 Source plastic-free sponges.

The Project will be subject to all applicable provisions of Anaheim Municipal Code Chapter 10.10 “WASTE RECYCLABLE MATERIALS, ORGANIC MATERIALS, AND SOLID WASTE COLLECTION AND DISPOSAL”. This comment is noted for the record and will be forwarded to the decision-makers for review and consideration.

Response 5.22. The remaining portions of the comment letter are noted for the record and will be forwarded to the decision-makers for review and consideration.

Pacific Resort Plaza

R:\Projects\ANA\3ANA009405\Environmental Documentation\RTC\RTC Pacific Resort Plaza-011924.docx 65 Errata (Clarifications and Revisions)

ERRATA (CLARIFICATIONS AND REVISIONS)
Any corrections to the IS/MND text, tables, and figures generated either from responses to comments or independently by the City of Anaheim, are stated in this section of the Final IS/MND.

The Draft IS/MND text, tables, and figures have not been modified and published in its entirety as a single document to reflect these IS/MND modifications.

These IS/MND revisions are provided to clarify, refine, and provide supplemental information for the IS/MND. Changes may be corrections or clarifications to the text and tables of the original IS/MND. Other changes to the IS/MND clarify the analysis in the IS/MND based upon the information and concerns raised by comments during the public review period. None of the information contained in these IS/MND revisions constitutes significant new information or changes to the analysis or conclusions of the IS/MND.

The information included in these IS/MND revisions that resulted from the public comment process does not constitute substantial new information that requires recirculation of the IS/MND pursuant to Section 15088.5 of the State CEQA Guidelines.

The changes to the IS/MND included in these modifications do not constitute “significant” new information. Therefore, recirculation of the IS/MND is not required because the new information added to the IS/MND through these modifications cl arifies or amplifies information already provided or makes insignificant modifications to the already adequate IS/MND.

The modifications contained in the following pages are in the same order as the information appears in the IS/MND. Deleted text is shown as strikeout and new text is bold and underline.

The applicable page numbers from the Draft EIR are also provided where necessary for easy reference.

SECTION 3.0: PROJECT DESCRIPTION
The text on page 3-1 has been revised and incorporated into the Final IS/MND as follows:

The second through fifth floor of the hotel would consist of the guest rooms which would provide both general guest rooms and three to four two to three designated Americans with Disabilities Act (ADA) accessible guest rooms per floor on floors 2-4 (refer to Exhibits 5a through 5c, Floor Plans – Hotel and Exhibit 5d, Floor Plan – Walk-Up/Drive Thru Fast Food Restaurant).

SECTION 3.3.1: PROJECT DESCRIPTION
The text on Page 3-3 has been revised and incorporated into the Final IS/MND as follows:
 A CUP to allow for a Floor Area Ratio (FAR) of 0.97 1.08. The current maximum FAR is

0.50 per Municipal Code Section 18.08.045 Floor Area Ratio Table 8-E.  A Minor Conditional Use Permit for Valet Parking.

Pacific Resort Plaza

R:\Projects\ANA\3ANA009405\Environmental Documentation\RTC\RTC Pacific Resort Plaza-011924.docx 66 Errata (Clarifications and Revisions) SECTION XI: LAND USE AND PLANNING
The following text is added on page 5-59, following the first paragraph.

The Environmental Justice Element will ensure that residents have a say in decisions that affect their quality of life and will address disproportionate impacts to certain environmental justice communities in order to ensure an equal distribution of resources. The Environmental Justice Element will cover the eight topics below:
 Reduce pollution exposure and improve air quality
 Promote public facilities
 Promote food access
 Promote safe and sanitary homes
 Promote physical activity
 Reduce any additional unique or compounded health risks  Promote civic engagement in the public decision-making process  Prioritize improvements and programs that address the needs of disadvantaged communities
The State of California is asking cities to incorporate environmental justice related goals, policies and programs into their general plan. The City of Anaheim is creating a stand-alone Element to have all environmental justice-related topics in one document for easy reference. An environmental justice community is an area of a community disproportionately affected by environmental pollution and other hazards that can lead to negative health effects, exposure, or environmental degradation. These areas deserve special attention to address issues of environmental justice. Within the City of Anaheim, 51 out of 75 census tracts fall under this designation. While the Environmental Justice Element will apply to all areas of the City, special attention will be given to environmental justice communities.

SECTION XVIII: TRANSPORTATION
The following correction has been added to page 5-77 in the second paragraph.

The Proposed Project is located immediately adjacent to bus stops on Anaheim Boulevard. The peak hour headways are 15 minutes or less on Anaheim Boulevard. The Proposed Project’s FAR is 0.981.08, so the FAR exceeds 0.75. The Proposed Project meets but does not exceed the parking required by the City. Additionally, the Project is consistent with the applicable SCS as the Project’s mix of land uses is consistent with the City’s General Plan land use designation. There are no existing residential units on the Project Site, so no affordable units are being removed or replaced. Therefore, the Project could be screened from a VMT analysis based on the criteria for Pacific Resort Plaza

R:\Projects\ANA\3ANA009405\Environmental Documentation\RTC\RTC Pacific Resort Plaza-011924.docx 67 Errata (Clarifications and Revisions) Type 1: TPA Screening, and would be considered a less than significant impact on VMT, per the City of Anaheim TIA Guidelines for CEQA Analysis.

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R:\Projects\ANA\3ANA009405\Environmental Documentation\RTC\RTC Pacific Resort Plaza-011924.docx 69 Errata (Clarifications and Revisions) EXHIBIT 4: SITE PLAN

The exhibit below follows page 3-1 and has been replaced.

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R:\Projects\ANA\3ANA009405\Environmental Documentation\RTC\RTC Pacific Resort Plaza-011924.docx 70 Errata (Clarifications and Revisions) EXHIBIT 7: CONCEPTUAL PLANTING PLAN

The exhibit below follows page 3-1 and has been replaced.

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R:\Projects\ANA\3ANA009405\Environmental Documentation\RTC\RTC Pacific Resort Plaza-011924.docx 71 Errata (Clarifications and Revisions) EXHIBIT 8: VALET PARKING PLAN

The exhibit below follows page 3-1 and has been replaced.

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ATTACHMENT A

EXHIBIT A OF COMMENT LETTER 3

BRIAN FLYNN, LOZEAU DRURY LLC

&9)*#*5"
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]
November 22, 2023
Brian Flynn
Lozeau | Drury LLP
1939 Harrison Street, Suite 150
Oakland, CA 94618
Subject: Co mments on the Pacific Resort Plaza Project
Dear Mr. Flynn,
We have reviewed the October 2023 Initial Study and Mitigated Negative Declaration (“IS/MND”) for the Pacific Resort Plaza Project (“Project”) located in the City of Anaheim (“City”). The Project proposes to construct a 67,715-square-foot (“SF”) hotel, a 1,200-SF walkup/drive-thru fast-food restaurant, and 100 parking spaces on the 1.47-acre site.

Our review concludes that the IS/MND fails to adequately evaluate the Project’s hazards, hazardous materials, air quality, health risk, and greenhouse gas impacts. As a result, emissions and health risk impacts associated with construction and operation of the proposed Project may be underestimated and inadequately addressed. An Environmental Impact Report (“EIR”) should be prepared to adequately assess and mitigate the potential hazards, hazardous materials, air quality, health risk, and greenhouse gas impacts that the project may have on the environment.

Hazards and Hazardous Materials
Inadequate Disclosure and Analysis of Impacts
Review of Google map images indicate the Project site was previously used as a motorcycle and personal watercraft dealer, a past use not disclosed in the IS/MND. Despite this past use, a Phase I Environmental Site Assessment (ESA) has not been prepared for the Project site. The IS/MND states only that a computerized review of regulatory databases and an online review of the Cortese list was conducted to determine if hazardous materials sites were present in the Project vicinity (p. 5-52).

Past use of the Project site as a motorsports dealer may have resulted in the release of hazardous materials, including fuel and lubricants. The preparation of a Phase I ESA is often undertaken in CEQA

2 matters to identify and disclose hazardous materials issues that may present impacts to the public, workers, or the environment, and which may require further investigation, including environmental sampling and cleanup. Standards for performing a Phase I ESA have been established by the US EPA and the American Society for Testing and Materials Standards (“ASTM”).1 Phase I ESAs are conducted to identify conditions that would indicate a release of hazardous substance and include:
x A review of all known sites in the vicinity of the subject property that are on regulatory agency databases undergoing assessment or cleanup activities;
x An inspection;
x Interviews with people knowledgeable about the property; and x Recommendations for further actions to address potential hazards.

Phase I ESAs conclude with the identification of any “recognized environmental conditions” (“RECs”) and recommendations to address such conditions. A REC is the presence or likely presence of any hazardous substances or petroleum products on a property under conditions that indicate an existing release, a past release, or a material threat of a release of any hazardous substances or petroleum products into structures on the property or into the ground, groundwater, or surface water of the property. If RECs are identified, then a Phase II ESA generally follows, which includes the collection of soil, soil vapor and groundwater samples, as necessary, to identify the extent of contamination and the need for cleanup to reduce exposure potential to the public.

A Phase I ESA, completed by a licensed environmental professional, is necessary for inclusion in an EIR to evaluate if RECs are present at the proposed Project site. If RECs are found, a Phase II should be conducted to sample for residual concentrations of contaminants in soil and groundwater. Any contamination that is identified above regulatory screening levels, including DTSC Soil Screening Levels2, should be further evaluated and cleaned up, if necessary, in coordination with DTSC.

Air Quality
Failure to Provide Complete CalEEMod Output Files
Land use development projects under the California Environmental Quality Act (“CEQA”) typically evaluate air quality impacts and calculate potential criteria air pollutant emissions using the California Emissions Estimator Model (“CalEEMod”). 3 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 CEQA requires that such changes be justified by substantial evidence. Once all of the values are inputted into the model, the Project’s construction and operational emissions are calculated, and “output files” are generated. These output 1 https://www.astm.org/e1527-21.html
2 https://dtsc.ca.gov/wp-content/uploads/sites/31/2022/02/HHRA-Note-3-June2020-Revised-May2022A.pdf 3 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide.
3 files disclose to the reader what parameters are used in calculating the Project’s air pollutant emissions and demonstrate which default values are changed. Justifications are provided for the selected values.

According to the IS/MND, CalEEMod Version 2022.1 is relied upon to estimate Project emissions (p. 5- 16). However, this poses a problem as the version of CalEEMod 2022.1 currently available is described as a “soft release” which fails to provide complete output files.4 Specifically, the “User Changes to Default Data” table no longer provides the quantitative counterparts to the changes to the default values (see excerpt below) (Appendix A, pp. 64):

However, previous CalEEMod Versions, such as 2020.4.0, include the specific numeric changes to the model’s default values (see example excerpt below):

The output files associated with CalEEMod Version 2022.1 fail to present the exact parameters used to calculate Project emissions. To remedy this issue, the IS/MND should have provided access to the model’s “.JSON” output files, which allow third parties to review the model’s revised input parameters.5 Without access to the complete output files, including the specific numeric changes to the default values, we cannot verify that the IS/MND’s air modeling and subsequent analysis is an accurate reflection of the proposed Project. As a result, an EIR should be prepared to include an updated air 4 “CalEEMod California Emissions Estimator Model Soft Release.” California Air Pollution Control Officers Association (CAPCOA), 2022, available at: https://caleemod.com/. 5 “Video Tutorials for CalEEMod Version 2022.1.” California Air Pollution Control Officers Association (CAPCOA), May 2022, available at: https://www.caleemod.com/tutorials.

4 quality analysis that correctly provides the complete output files for CalEEMod Version 2022.1, or includes an updated air model using an older release of CalEEMod.6 Unsubstantiated Input Parameters Used to Estimate Project Emissions As previously discussed, the IS/MND relies on CalEEMod Version 2022.1 to estimate the Project’s air quality emissions and fails to provide the complete output files required to adequately evaluate model’s analysis (p. 5-16). Regardless, when reviewing the Project’s CalEEMod output files, provided in the Air Quality and Greenhouse Gas Emissions Modeling Data (“AQ & GHG Report”) as Appendix A to the IS/MND, we were able to identify several model inputs that are inconsistent with information disclosed in the IS/MND. As such, the Project’s construction and operational emissions may be underestimated.

An EIR should be prepared to include an updated air quality analysis that adequately evaluates the impacts that construction and operation of the Project will have on local and regional air quality.

Unsubstantiated Changes to Individual Construction Phase Lengths Review of the CalEEMod output files demonstrates that the “La Quinta v4” model includes changes to the default construction schedule (see excerpt below) (Appendix A, pp. 64).

As a result of these changes, the model includes the following construction schedule (see excerpt below) (Appendix A, pp. 121):
6 “CalEEMod Version 2020.4.0.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at: http://www.aqmd.gov/caleemod/download-model.

5 The CalEEMod User’s Guide requires any changes to model defaults be justified.7 As demonstrated above in the “User Changes to Default Data” table, the justification provided for these changes is:
“Schedule provided by Applicant
Phase 2 Paving represented by "Architectural Coating" Phase type as CalEEMod only allows for one paving phase. However, construction schedule and equipment inputs are accurate for paving as applicable inputs were changed from defaults based on data provided by the applicant” (Appendix A, pp. 64).

Regarding the Project’s anticipated construction duration, the IS/MND states:
“Phase One (walk-up/drive-thru fast food restaurant) includes the demolition of the existing 10,530 sf, two-story commercial building which is expected to occur over a two-week period beginning shortly after Project approval. Site preparation would occur for approximately one week, grading/excavation would occur approximately for one week, building construction would occur for approximately 16 weeks (four months), paving would occur for approximately one week, and architectural decoration and coating would occur approximately for three weeks (Refer to Exhibit 9, Demolition Plan). Demolition activities associated with Phase Two (hotel) would include the demolition of the existing wood carport and sheet metal garage which is expected to occur over a one-day period. Site preparation would occur for approximately one week, grading/excavation would occur approximately for one week, building construction would occur for approximately 15 months, paving would occur for approximately three weeks, and architectural decoration and coating would occur approximately for four weeks (one month)” (p. 3-2).

However, the changes to the individual construction phase lengths remain unsubstantiated. While the IS/MND’s CalEEMod output files demonstrate that the total length of Project construction would be approximately 15 months, the IS/MND fails to substantiate the individual construction phase lengths. 7 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 1, 14.

6 Until specific evidence is provided, the model should have included proportionately altered individual phase lengths to match the proposed construction duration of approximately 15 months.

The construction schedule included in the model presents an issue, as the construction emissions are improperly spread out over a longer period of time for some phases, but not for others. According to the CalEEMod User’s Guide, each construction phase is associated with different emissions activities (see excerpt below).8
By disproportionately altering and extending some of the individual construction phase lengths without proper justification, the model assumes there are a greater number of days to complete the construction activities required by the prolonged phases. As a result, there will be less construction activities required per day and, consequently, less pollutants emitted per day. Until we are able to verify the revised construction schedule, the model may underestimate the peak daily emissions associated with some phases of construction and should not be relied upon to determine Project significance.

Unsubstantiated Changes to Off-Road Equipment Input Parameters Review of the CalEEMod output files demonstrates that the “La Quinta v4” model includes changes to the off-road construction equipment input parameters (see excerpt below) (Appendix A, pp. 64). 8 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 32.

7 The CalEEMod User’s Guide requires any changes to model defaults be justified.9 As demonstrated above, the justification provided in the “User Changes to Default Data” table is:
“Data provided by applicant” (Appendix A, pp. 64).

Regarding the Project constructions off-road equipment usage, the IS/MND states:
“Typical heavy equipment used during construction would include an excavator, track loader, motor grader, skip loader, scraper, compacter, backhoe, concrete machine, large bulldozer, small bulldozer, and loaded trucks. Construction activities are anticipated to occur for eight- hours a day, five-days a week” (p. 3-2).

However, these changes remain unsupported, as the IS/MND fails to provide the purported construction assumptions, as mentioned in the justification provided by the “User Changes to Default Data” table. As previously discussed, the CalEEMod User’s Guide requires changes to be supported by substantial evidence.10 As the Project documents fail to provide substantial evidence to support the updated construction equipment list, we cannot verify the changes.

These unsubstantiated changes present an issue, as CalEEMod uses the off-road equipment unit amounts, horsepower, and hours of use per day values to calculate the emissions associated with off- road construction equipment.11 By including unsubstantiated changes to the default off-road construction equipment values, the model may underestimate the Project’s construction-related emissions and should not be relied upon to determine Project significance.

Unsubstantiated Changes to Architectural Coating Emission Factors Review of the CalEEMod output files demonstrates that the “La Quinta v4” model includes changes to the default architectural coating emission factors (see excerpt below) (Appendix A, pp. 64). 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. 2, 9 10 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 13, 14.
11 “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. 32

8 As previously mentioned, the CalEEMod User’s Guide requires any changes to model defaults be justified.12 As demonstrated above in the “User Changes to Default Data” table, the justification provided for these changes is:
“Data provided by applicant” (Appendix A, pp. 64).

However, the reductions to the architectural coating emission factors remain unsubstantiated for two reasons.

First, the IS/MND and associated documents fail to discuss the revisions to the architectural coating emission factors whatsoever. As previously discussed, the CalEEMod User’s Guide requires changes to be supported by substantial evidence.13 As the Project documents fail to provide substantial evidence to support the updated architectural coating, we cannot verify the changes.

Second, as previously discussed, the output files for CalEEMod 2022.1 do not present the numeric changes to any model defaults. Upon further review of the output files, Table 5.5 contains the only mention of architectural coatings (see excerpt below) (Appendix A, pp. 52):

However, as demonstrated above, Table 5.5 only provides the square footage of area to be coated.

Since the output files fail to demonstrate the architectural coating emission factors that the model relies on, we cannot verify that the values included in the model are accurate.

These unsubstantiated reductions present an issue, as CalEEMod uses the architectural coating emission factors to calculate the Project’s volatile organic compounds (“VOC”) emissions.14 By including unsubstantiated reductions to the default architectural coating emission factors, the model may underestimate the Project’s construction-related VOC emissions and should not be relied upon to determine Project significance.

Unsubstantiated Changes to Construction Trips and VMT Parameter Review of the CalEEMod output files demonstrates that the “La Quinta v4” model includes changes to the construction trips and VMT values (see excerpt below) (Appendix A, pp. 64). 12 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 1, 14.
13 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 13, 14.
14 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 35, 40.

9 The CalEEMod User’s Guide requires any changes to model defaults be justified.15 As demonstrated above, the justification provided in the “User Changes to Default Data” table is:
“Data provided by applicant” (Appendix A, pp. 64).

These changes remain unsupported for two reasons.

First, the IS/MND and associated documents fail to discuss the revisions to the construction trips and VMT values whatsoever. As previously discussed, the CalEEMod User’s Guide requires changes to be supported by substantial evidence.
16 As the Project documents fail to provide substantial evidence to support the updated construction trips and VMT values, we cannot verify the changes.

Second, the IS/MND fails to provide the purported construction assumptions, as mentioned in the justification provided by the “User Changes to Default Data” table. Consequently, we cannot verify that the construction trips and VMT values included in the model are accurate.

These unsubstantiated reductions present an issue, as CalEEMod uses the trips and VMT values to estimate the construction-related emissions associated with on-road vehicles.17 By including unsubstantiated changes to the construction trips and VMT values, the model may underestimate the Project’s mobile-source construction-related emissions and should not be relied upon to determine Project significance.

Diesel Particulate Matter Emissions Inadequately Evaluated The IS/MND concludes that the Project would have a less-than-significant health risk impact without conducting a quantified construction or operational health risk analysis (“HRA”). Regarding the health risk impacts associated with the Project construction, the IS/MND states:
“There would be relatively few pieces of off-road, heavy-duty diesel equipment in operation, and the total construction period would be relatively short when compared to a 40-year 15 “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. 2, 9 16 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 13, 14.
17 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 34.

10 exposure period. Combined with the highly dispersive properties of DPM and the nearest sensitive uses located approximately 130 feet away as well as additional reductions in particulate emissions from newer construction equipment, as required by USEPA and CARB regulations, construction emissions of TACs would not expose sensitive receptors to substantial emissions of TACs. The impact would be less than significant, and no mitigation is required” (p. 5-22).

As demonstrated above, the IS/MND claims that the Project’s construction and operation would not emit significant amounts of toxic air contaminants (“TAC”) due to the limited use of equipment during operation, and the short construction period. However, the IS/MND’s evaluation of the Project’s potential health risk impacts, as well as the subsequent less-than-significant impact conclusion, is incorrect for two reasons.

First, by failing to prepare a quantified construction and operational HRA, the Project is inconsistent with CEQA’s requirement to make “a reasonable effort to substantively connect a project’s air quality impacts to likely health consequences.”18 This poses a problem, as according to the IS/MND, construction of the Project would produce DPM emissions through the exhaust of off-road, heavy-duty diesel equipment over a duration of approximately 15 months (p. 5-22). However, the IS/MND and associated documents fail to evaluate the TAC emissions associated with Project construction or indicate the concentrations at which such pollutants would trigger adverse health effects. Without making a reasonable effort to connect the Project’s TAC emissions to the potential health risks posed to nearby receptors, the IS/MND is inconsistent with CEQA’s requirement to correlate Project-generated emissions with potential adverse impacts on human health.

Second, the Office of Environmental Health Hazard Assessment (“OEHHA”) released its most recent Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments in February 2015.

This guidance document describes the types of projects that warrant the preparation of an HRA.

Specifically, OEHHA recommends that all short-term projects lasting at least 2 months assess cancer risks.19 Furthermore, according to OEHHA:
“Exposure from projects lasting more than 6 months should be evaluated for the duration of the project. In all cases, for assessing risk to residential receptors, the exposure should be assumed to start in the third trimester to allow for the use of the ASFs (OEHHA, 2009).”20 As the Project’s anticipated construction duration exceeds the 2-month and 6-month requirements set forth by OEHHA, construction of the Project meets the threshold warranting a quantified HRA under OEHHA guidance and should be evaluated for the entire 15-month construction period. Furthermore, OEHHA recommends that an exposure duration of 30 years should be used to estimate the individual

18 “Sierra Club v. County of Fresno.” Supreme Court of California, December 2018, available at:
https://ceqaportal.org/decisions/1907/Sierra%20Club%20v.%20County%20of%20Fresno.pdf. 19 “Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 8-18. 20 “Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 8-18. 11 cancer risk at the maximally exposed individual resident (“MEIR”).21 While the IS/MND fails to provide the expected lifetime of the proposed Project, we can reasonably assume that the Project would operate for at least 30 years, if not more. Therefore, operation of the Project also exceeds the 2-month and 6-month requirements set forth by OEHHA and should be evaluated for the entire 30-year residential exposure duration, as indicated by OEHHA guidance. These recommendations reflect the most recent state health risk policies, and as such, an EIR should be prepared to include an analysis of health risk impacts posed to nearby sensitive receptors from Project-generated DPM emissions.

Third, by claiming a less than significant impact without conducting a quantified construction or operational HRA for nearby, existing sensitive receptors, the IS/MND fails to compare the excess health risk impact to the South Coast Air Quality Management District’s (“SCAQMD”) specific numeric threshold of 10 in one million.22 In accordance with the most relevant guidance, an assessment of the health risk posed to nearby, existing receptors from Project construction and operation should have been conducted.

Screening-Level Analysis Demonstrates Potentially Significant Health Risk Impact In order to conduct our screening-level risk assessment we relied upon AERSCREEN, which is a screening level air quality dispersion model.23 The model replaced SCREEN3, and AERSCREEN is included in the OEHHA and the California Air Pollution Control Officers Associated (“CAPCOA”) guidance as the appropriate air dispersion model for Level 2 health risk screening assessments (“HRSAs”).24, 25 A Level 2 HRSA utilizes a limited amount of site-specific information to generate maximum reasonable downwind concentrations of air contaminants to which nearby sensitive receptors may be exposed. If an unacceptable air quality hazard is determined to be possible using AERSCREEN, a more refined modeling approach should be conducted prior to the approval of the Project.

We prepared a preliminary HRA of the “La Quinta v4” model’s construction and operational health risk impact to residential sensitive receptors using the annual PM10 exhaust estimates from the AQ & GHG Report’s CalEEMod output files. Consistent with recommendations set forth by OEHHA, we assumed residential exposure begins during the third trimester stage of life.26 The AQ & GHG Report’s CalEEMod model indicates that construction activities will generate approximately 115.5 pounds of DPM over the 463-day construction period.27 The AERSCREEN model relies on a continuous average emission rate to

21 “Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 2-4. 22 “South Coast AQMD Air Quality Significance Thresholds.” SCAQMD, April 2019, available at:
http://www.aqmd.gov/docs/default-source/ceqa/handbook/scaqmd-air-quality-significance-thresholds.pdf. 23 “Air Quality Dispersion Modeling - Screening Models,” U.S. EPA, available at: https://www.epa.gov/scram/air- quality-dispersion-modeling-screening-models.
24 “Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf. 25 “Health Risk Assessments for Proposed Land Use Projects.” CAPCOA, July 2009, available at:
http://www.valleyair.org/transportation/CAPCOA_HRA_LU_Guidelines_8-6-09.pdf. 26 “Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 8-18. 27 See Attachment C for health risk calculations.
12 simulate maximum downward concentrations from point, area, and volume emission sources. To account for the variability in equipment usage and truck trips over Project construction, we calculated an average DPM emission rate by the following equation:
݊݋݅ݏݏ݅݉ܧ ݁ݐܴܽ ݏ݉ܽݎ݃
݀݊݋ܿ݁ݏቁ = 115.5 ݏܾ݈
463 ݏݕܽ݀× 453.6 ݏ݉ܽݎ݃
ݏܾ݈× 1 ݕܽ݀
24 ݏݎݑ݋݄× 1 ݎݑ݋݄
3,600 ݏ݀݊݋ܿ݁ݏ= ૙. ૙૙૚૜૚ ࢍ/࢙
Using this equation, we estimated a construction emission rate of 0.00131 grams per second (“g/s”).

Subtracting the 463-day construction period from the total residential duration of 30 years, we assumed that after Project construction, the sensitive receptor would be exposed to the Project’s operational DPM for an additional 28.73 years. The AQ & GHG Report’s operational CalEEMod emissions indicate that operational activities will generate approximately 40 pounds of DPM per year throughout operation. Applying the same equation used to estimate the construction DPM rate, we estimated the following emission rate for Project operation:
݊݋݅ݏݏ݅݉ܧ ݁ݐܴܽ ݏ݉ܽݎ݃
݀݊݋ܿ݁ݏቁ = 40 ݏܾ݈
365 ݏݕܽ݀× 453.6 ݏ݉ܽݎ݃
ݏܾ݈× 1 ݕܽ݀
24 ݏݎݑ݋݄× 1 ݎݑ݋݄
3,600 ݏ݀݊݋ܿ݁ݏ= ૙. ૙૙૙૞ૡ ࢍ/࢙

Using this equation, we estimated an operational emission rate of 0.00058 g/s. Construction and operation were simulated as a 1.47-acre rectangular area source in AERSCREEN, with approximate dimensions of 109- by 55-meters. A release height of three meters was selected to represent the height of stacks of operational equipment and other heavy-duty vehicles, and an initial vertical dimension of one and a half meters was used to simulate instantaneous plume dispersion upon release. An urban meteorological setting was selected with model-default inputs for wind speed and direction distribution.

The population of Anaheim was obtained from U.S. 2021 Census data.28 The AERSCREEN model generates maximum reasonable estimates of single-hour DPM concentrations from the Project Site. The United States Environmental Protection Agency (“U.S. EPA”) suggests that the annualized average concentration of an air pollutant be estimated by multiplying the single-hour concentration by 10% in screening procedures.29 According to the IS/MND, the nearest sensitive receptors are multi-family residences 110 feet, or 33.5 meters, to the north of the Project site (p. 5-4).

However, according to the AERSCREEN output files, the Maximally Exposed Individual Receptor (“MEIR”) is located approximately 50 meters downwind of the Project site. The single-hour concentration estimated by AERSCREEN for Project construction is therefore approximately 5.057 μg/m3 DPM at approximately 50 meters downwind. Multiplying this single-hour concentration by 10%, we get an annualized average concentration of 0.5057 μg/m3 for Project construction at the MEIR. For Project operation, the single-hour concentration estimated by AERSCREEN is 2.221 μg/m3 DPM at approximately

28 “Anaheim.” U.S. Census Bureau, 2021, available at: https://datacommons.org/place/geoId/0602000. 29 “Screening Procedures for Estimating the Air Quality Impact of Stationary Sources Revised.” U.S. EPA, October 1992, available at: http://www.epa.gov/ttn/scram/guidance/guide/EPA-454R-92-019_OCR.pdf. 13 50 meters downwind. Multiplying this single-hour concentration by 10%, we get an annualized average concentration of 0.2221 μg/m3 for Project operation at the MEIR.30 We calculated the excess cancer risk to the MEIR using applicable HRA methodologies prescribed by OEHHA, as recommended by SCAQMD.31 Specifically, guidance from OEHHA and CARB recommends the use of a standard point estimate approach, including high-point estimate (i.e. 95th percentile) breathing rates and age sensitivity factors (“ASF”) in order to account for the increased sensitivity to carcinogens during early-in-life exposure and accurately assess risk for susceptible subpopulations such as children.

The residential exposure parameters utilized for the various age groups in our screening-level HRA are as follows:

Exposure Assumptions for Residential Individual Cancer Risk Age Group
Breathing
Rate
(L/kg-day)32
Age
Sensitivity
Factor33
Exposure
Duration
(years)
Fraction of
Time at
Home34
Exposure
Frequency
(days/year)35
Exposure
Time
(hours/day)
3rd Trimester 361 10 0.25 1 350 24
Infant (0 - 2) 1090 10 2 1 350 24
Child (2 - 16) 572 3 14 1 350 24
Adult (16 - 30) 261 1 14 0.73 350 24
For the inhalation pathway, the procedure requires the incorporation of several discrete variates to effectively quantify dose for each age group. Once determined, contaminant dose is multiplied by the cancer potency factor (“CPF”) in units of inverse dose expressed in milligrams per kilogram per day (mg/kg/day-1) to derive the cancer risk estimate. Therefore, to assess exposures, we utilized the following dose algorithm:

30 See Attachment D for AERSCREEN output files.
31 “AB 2588 and Rule 1402 Supplemental Guidelines.” SCAQMD, October 2020, available at:
http://www.aqmd.gov/docs/default-source/planning/risk-assessment/ab-2588-supplemental- guidelines.pdf?sfvrsn=19, p. 2.
32 “Supplemental Guidelines for Preparing Risk Assessments for the Air Toxics ‘Hot Spots’ Information and Assessment Act.” SCAQMD, October 2020, available at: http://www.aqmd.gov/docs/default-source/planning/risk- assessment/ab-2588-supplemental-guidelines.pdf?sfvrsn=19, p. 19; see also “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at:
https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf. 33 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 8-5 Table 8.3. 34 “Risk Assessment Procedures.” SCAQMD, August 2017, available at: http://www.aqmd.gov/docs/default- source/rule-book/Proposed-Rules/1401/riskassessmentprocedures_2017_080717.pdf, p. 7. 35 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 5-24. 14 ஺ூோ,௣௘௥ ௔௚௘ ௚௥௢௨௣ = ௔௜௥ × ܨܧ× ܴܤ
ܹܤ൨ × ܣ× ܨܥ
where:

DoseAIR = dose by inhalation (mg/kg/day), per age group Cair сĐŽŶĐĞŶƚƌĂƚŝŽŶŽĨĐŽŶƚĂŵŝŶĂŶƚŝŶĂŝƌ;ʅŐͬŵϯͿ
EF = exposure frequency (number of days/365 days)
BR/BW = daily breathing rate normalized to body weight (L/kg/day) A = inhalation absorption factor (default = 1)
CF = conversion factor (1x10-ϲ͕ʅŐƚŽŵŐ͕>ƚŽŵϯͿ
To calculate the overall cancer risk, we used the following equation for each appropriate age group:
ݎ݁ܿ݊ܽܥ ஺ூோ = ஺ூோ ×ܨܲܥ×ܨܵܣ×ܪܣܨ×ܦܧ
ܶܣ
where:

DoseAIR = dose by inhalation (mg/kg/day), per age group CPF = cancer potency factor, chemical-specific (mg/kg/day)-1 ASF = age sensitivity factor, per age group
FAH = fraction of time at home, per age group (for residential receptors only) ED = exposure duration (years)
AT = averaging time period over which exposure duration is averaged (always 70 years) Consistent with the 463-day construction schedule, the annualized average concentration for construction was used for the entire third trimester of pregnancy (0.25 years), and the first 1.02 years of the infantile (0 – 2) stage of life. The annualized average concentration for operation was used for the remainder of the 30-year exposure period, which makes up the latter 0.98 years of the infantile stage of life, the entire child stage of life (2 – 16), as well the entire adult (16 – 30 years) stage of life. The results of our calculations are shown in the table below.

The Maximally Exposed Individual at an Existing Residential Receptor Age Group Emissions Source Duration (years) Concentration (ug/m3) Cancer Risk
3rd Trimester Construction 0.25 0.5057 6.88E-06
Construction 1.02 0.5057 8.46E-05
Operation 0.98 0.2221 3.58E-05
Infant (0 - 2) Total 2 1.20E-04
Child (2 - 16) Operation 14 0.2221 8.04E-05
15 Adult (16 - 30) Operation 14 0.2221 8.93E-06
Lifetime 30 2.17E-04
As demonstrated in the table above, the excess cancer risks for the 3rd trimester of pregnancy, infants, children, and adults at the MEIR located approximately 50 meters away, over the course of Project construction and operation, are approximately 6.88, 120.0, 80.4, and 8.93 in one million, respectively.

The excess cancer risk over the course of a residential lifetime (30 years) is approximately 217 in one million. The infant, child and lifetime cancer risks exceed the SCAQMD threshold of 10 in one million, resulting in a potentially significant impact not previously addressed or identified by the IS/MND.

Our analysis represents a screening-level HRA, which is known to be conservative and tends to err on the side of health protection. The purpose of the screening-level HRA is to demonstrate the potential link between Project-generated emissions and adverse health risk impacts. According to the U.S. EPA:
“EPA’s Exposure Assessment Guidelines recommend completing exposure assessments iteratively using a tiered approach to ‘strike a balance between the costs of adding detail and refinement to an assessment and the benefits associated with that additional refinement’ (U.S.

EPA, 1992).

In other words, an assessment using basic tools (e.g., simple exposure calculations, default values, rules of thumb, conservative assumptions) can be conducted as the first phase (or tier) of the overall assessment (i.e., a screening-level assessment).

The exposure assessor or risk manager can then determine whether the results of the screening- level assessment warrant further evaluation through refinements of the input data and exposure assumptions or by using more advanced models.” As demonstrated above, screening-level analyses warrant further evaluation in a refined modeling approach. As our screening-level HRA demonstrates that construction and operation of the Project could result in a potentially significant health risk impact, an EIR should be prepared to include a refined health risk analysis which adequately and accurately evaluates health risk impacts associated with both Project construction and operation. If the refined analysis similarly concludes that the Project would result in a significant health risk impact, then mitigation measures should be incorporated, as described below in the “Feasible Mitigation Measures Available to Reduce Emissions” section.

Greenhouse Gas
Failure to Adequately Evaluate Greenhouse Gas Impacts
The IS/MND estimates that the Project would generate net annual greenhouse gas (“GHG”) emissions of 1,909 metric tons of carbon dioxide equivalents per year (“MT CO2e/year”) (Table 13, p. 5-51). 16 As such, the IS/MND states:
“As shown in Table 13, Estimated Total Project Annual Greenhouse Gas Emissions, with consideration of amortized construction emissions, the total annual estimated GHG emissions for the proposed Project is 1,909 MTCO2e/yr. This value is less than the proposed SCAQMD Tier 3 screening threshold (e.g., 3,000 MTCO2e/yr for all land use types) that is being applied in this analysis. Because the Proposed Project’s GHG emissions would be less than 3,000 MTCO2e/yr, the emissions would not be cumulatively considerable. Therefore, the Proposed Project would result in less than significant GHG emissions” (p. 5-51).

As demonstrated above, the IS/MND concludes that since the Project’s GHG emissions would not exceed the Tier 3 screening threshold, the Project will result in a less-than-significant impact. However, the IS/MND’s analysis, as well as the subsequent less-than-significant impact conclusion, is incorrect for three reasons.
(1) The IS/MND’s quantitative GHG anal ysis relies upon a flawed air model; (2) The IS/MND’s quantitative GHG analysis relies upon an outdated threshold; and (3) The IS/MND’s unsubstantiated air model ind icates a potentially significant impact. 1) Incorrect and Unsubstantiated Qua ntitative Analysis of Emissions As previously stated, the IS/MND estimates that the Project would generate net annual GHG emissions of 1,909 MT CO2e/year (Table 13, p. 5-51). However, the IS/MND’s quantitative GHG analysis is unsubstantiated. As previously discussed, the IS/MND relies on CalEEMod Version 2022.1 to estimate the Project’s air quality emissions and fails to provide the complete output files required to adequately evaluate model’s analysis. Furthermore, when reviewing the CalEEMod output files included in the AQ & GHG Report, we were able to identify several model inputs that are inconsistent with information disclosed in the IS/MND. As a result, the models may underestimate the Project’s emissions, and the IS/MND’s quantitative GHG analysis should not be relied upon to determine Project significance. An EIR should be prepared that adequately assesses the potential GHG impacts that construction and operation of the proposed Project may have on the environment.

17 2) Incorrect Reliance on an Outdated Quantitative GHG Threshold As previously stated, the IS/MND estimates that the Project would generate net annual GHG emissions of 1,909 MT CO2e/year, which would not exceed the SCAQMD threshold of 3,000 MT CO2e/year (p. 4- 37). However, the guidance that provided the 3,000 MT CO2e/year threshold, the SCAQMD’s 2008 Interim CEQA GHG Significance Threshold for Stationary Sources, Rules, and Plans report, was developed when the Global Warming Solutions Act of 2006, commonly known as “AB 32”, was the governing statute for GHG reductions in California. AB 32 requires California to reduce GHG emissions to 1990 levels by 2020.36 Furthermore, AEP guidance states:
“[F]or evaluating projects with a post 2020 horizon, the threshold will need to be revised based on a new gap analysis that would examine 17 development and reduction potentials out to the next GHG reduction milestone.”37
As it is currently November 2023, thresholds for 2020 are not applicable to the proposed Project and should be revised to reflect the current GHG reduction target. As such, the SCAQMD bright-line threshold of 3,000 MT CO2e/year is outdated and inapplicable to the proposed Project, and the DEIR’s less-than-significant GHG impact conclusion should not be relied upon. Instead, we recommend that the Project apply the SCAQMD 2035 service population efficiency target of 3.0 metric tons of carbon dioxide equivalents per service population per year (“MT CO2e/SP/year”), which was calculated by applying a 40% reduction to the 2020 targets.38
3) Failure to Identify a Potentially Significant GHG Impact In an effort to quantitatively evaluate the Project’s GHG emissions, we compared the Project’s GHG emissions, as estimated by the IS/MND, to the SCAQMD 2035 service population efficiency target of 3.0 MT CO2e/SP/year. When applying this threshold, the Project’s air model indicates a potentially significant GHG impact. As previously stated, the IS/MND estimates that the Project would generate net annual GHG emissions of 1,909 MT CO2e/year (Table 13, p. 5-51). According to CAPCOA’s CEQA & Climate Change report, a service population (“SP”) is defined as “the sum of the number of residents and the number of jobs supported by the project.”39 As the Project does not propose any residential land uses, we estimate that the Project would not support any residents. Furthermore, according to the IS/MND, the Project would support 26 employees (p. 5-70).40 Based on this estimate, we calculated an SP of 26 people. When dividing the Project’s net annual GHG emissions, as estimated by the IS/MND, by

36 “Health & Safety Code 38550.” California State Legislature, January 2007, available at:
https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=HSC&sectionNum=38550. 37 “Beyond Newhall and 2020: A Field Guide to New CEQA Greenhouse Gas Thresholds and Climate Action Plan Targets for California.” Association of Environmental Professionals (AEP), October 2016, available at:
https://califaep.org/docs/AEP-2016_Final_White_Paper.pdf, p. 39. 38 “Minutes for the GHG CEQA Significance Threshold Stakeholder Working Group #15.” SCAQMD, September 2010, available at: http://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa- significance-thresholds/year-2008-2009/ghg-meeting-15/ghg-meeting-15-minutes.pdf, p. 2. 39 CAPCOA (Jan. 2008) CEQA & Climate Change, p. 71-72, http://www.capcoa.org/wp- content/uploads/2012/03/CAPCOA-White-Paper.pdf.
40 Calculated: 14 hotel employees + 12 fast food restaurant employees = 26 total employees. 18 an SP of 26 people, we find that the Project would emit approximately 73.4 MT CO2e/SP/year (see table below).41
IS/MND Greenhouse Gas Emissions
Annual Emissions (MT CO2e/year) 1,909
Service Population 26
Service Population Efficiency (MT CO2e/SP/year) 73.4
SCAQMD 2035 Threshold 3.0
Exceeds? Yes

As demonstrated above, the Project’s service population efficiency value, as estimated by the IS/MND’s provided net annual GHG emission estimates and SP, exceeds the SCAQMD 2035 efficiency target of 3.0 MT CO2e/SP/year, indicating a potentially significant impact not previously identified or addressed by the IS/MND. As a result, the IS/MND’s less-than-significant GHG impact conclusion should not be relied upon. An EIR should be prepared to include an updated GHG analysis which incorporates additional mitigation measures to reduce the Project’s GHG emissions to less-than-significant levels.

Mitigation
Feasible Mitigation Measures Available to Reduce Emissions Our analysis demonstrates that the Project would result in potentially significant air quality, health risk, and GHG impacts that should be mitigated further. As such, in an effort to reduce the Project’s emissions, we identified several mitigation measures that are applicable to the proposed Project.

Therefore, to reduce the Project’s emissions, we recommend consideration of SCAG’s 2020 RTP/SCS PEIR’s Air Quality Project Level Mitigation Measures (“PMM-AQ-1”) and Greenhouse Gas Project Level Mitigation Measures (“PMM-GHG-1”), as described below: 42 SCAG RTP/SCS 2020-2045
Air Quality Project Level Mitigation Measures – PMM-AQ-1:

In accordance with provisions of sections 15091(a)(2) and 15126.4(a)(1)(B) of the State CEQA Guidelines, a Lead Agency for a project can and should consider mitigation measures to reduce substantial adverse effects related to violating air quality standards. Such measures may include the following or other comparable measures identified by the Lead Agency:

41 Calculated: (1,909 MT CO2e/year) / (26 service population) = (73.4 MT CO2e/SP/year). 42 “4.0 Mitigation Measures.” Connect SoCal Program Environmental Impact Report Addendum #1, September 2020, available at: https://scag.ca.gov/sites/main/files/file- attachments/fpeir_connectsocal_addendum_4_mitigationmeasures.pdf?1606004420, p. 4.0-2 – 4.0-10; 4.0-19 –

4.0-23; See also: “Certified Final Connect SoCal Program Environmental Impact Report.” Southern California Association of Governments (SCAG), May 2020, available at: https://scag.ca.gov/peir. 19 a) Minimize land disturbance.
b) Suspend grading and earth moving when wind gusts exceed 25 miles per hour unless the soil is wet enough to prevent dust plumes.
c) Cover trucks when hauling dirt.
d) Stabilize the surface of dirt piles if not removed immediately. e) Limit vehicular paths on unpaved surfaces and stabilize any temporary roads. f) Minimize unnecessary vehicular and machinery activities. g) Sweep paved streets at least once per day where there is evidence of dirt that has been carried on to the roadway.
h) Revegetate disturbed land, including vehicular paths created during construction to avoid future off-road vehicular activities.
j) Require contractors to assemble a comprehensive inventory list (i.e., make, model, engine year, horsepower, emission rates) of all heavy-duty off-road (portable and mobile) equipment (50 horsepower and greater) that could be used an aggregate of 40 or more hours for the construction project. Prepare a plan for approval by the applicable air district demonstrating achievement of the applicable percent reduction for a CARB-approved fleet.
k) Ensure that all construction equipment is properly tuned and maintained. l) Minimize idling time to 5 minutes—saves fuel and reduces emissions. m) Provide an operational water truck on-site at all times. Use watering trucks to minimize dust; watering should be sufficient to confine dust plumes to the project work areas. Sweep paved streets at least once per day where there is evidence of dirt that has been carried on to the roadway. n) Utilize existing power sources (e.g., power poles) or clean fuel generators rather than temporary power generators.
o) Develop a traffic plan to minimize traffic flow interference from construction activities. The plan may include advance public notice of routing, use of public transportation, and satellite parking areas with a shuttle service.

Schedule operations affecting traffic for off-peak hours. Minimize obstruction of through-traffic lanes. Provide a flag person to guide traffic properly and ensure safety at construction sites. p) As appropriate require that portable engines and portable engine-driven equipment units used at the project work site, with the exception of on-road and off-road motor vehicles, obtain CARB Portable Equipment Registration with the state or a local district permit. Arrange appropriate consultations with the CARB or the District to determine registration and permitting requirements prior to equipment operation at the site. q) Require projects within 500 feet of residences, hospitals, or schools to use Tier 4 equipment for all engines above 50 horsepower (hp) unless the individual project can demonstrate that Tier 4 engines would not be required to mitigate emissions below significance thresholds. r) Projects located within the South Coast Air Basin should consider applying for South Coast AQMD “SOON” funds which provides funds to applicable fleets for the purchase of commercially available low-emission heavy- duty engines to achieve near-term reduction of NOx emissions from in-use off-road diesel vehicles. s) Projects located within AB 617 communities should review the applicable Community Emissions Reduction Plan (CERP) for additional mitigation that can be applied to individual projects. t) Where applicable, projects should provide information about air quality related programs to schools, including the Environmental Justice Community Partnerships (EJCP), Clean Air Ranger Education (CARE), and Why Air Quality Matters programs.
u) Projects should work with local cities and counties to install adequate signage that prohibits truck idling in certain locations (e.g., near schools and sensitive receptors). y) Projects that will introduce sensitive receptors within 500 feet of freeways and other sources should consider installing high efficiency of enhanced filtration units, such as Minimum Efficiency Reporting Value (MERV) 13 or better. Installation of enhanced filtration units can be verified during occupancy inspection prior to the issuance of an occupancy permit.
20 z) Develop an ongoing monitoring, inspection, and maintenance program for the MERV filters. aa) Consult the SCAG Environmental Justice Toolbox for potential measures to address impacts to low-income and/or minority communities.
bb) The following criteria related to diesel emissions shall be implemented on by individual project sponsors as appropriate and feasible:
- Diesel nonroad vehicles on site for more than 10 to tal days shall have either (1) engines that meet EPA on road emissions standards or (2) emission control technology verified by EPA or CARB to reduce PM emissions by a minimum of 85%
- Diesel generators on site for more than 10 tota l days shall be equipped with emission control technology verified by EPA or CARB to reduce PM emissions by a minimum of 85%. - Nonroad diesel engines on site shall be Tier 2 or higher. - Diesel nonroad construction equipment on site for more than 10 total days shall have either (1) engines meeting EPA Tier 4 nonroad emissions standards or (2) emission control technology verified by EPA or CARB for use with nonroad engines to reduce PM emissions by a minimum of 85% for engines for 50 hp and greater and by a minimum of 20% for engines less than 50 hp. - Emission control technology shall be operated, ma intained, and serviced as recommended by the emission control technology manufacturer.
- Diesel vehicles, construction equipment, and genera tors on site shall be fueled with ultra-low sulfur diesel fuel (ULSD) or a biodiesel blend approved by the original engine manufacturer with sulfur content of 15 ppm or less.
- The construction contractor shall maintain a list of all diesel vehicles, construction equipment, and generators to be used on site. The list shall include the following:
i. Contractor and subcontractor name and addre ss, plus contact person responsible for the vehicles or equipment.
ii. Equipment type, equipment manufacturer, e quipment serial number, engine manufacturer, engine model year, engine certification (Tier rating), horsepower, engine serial number, and expected fuel usage and hours of operation.
iii. For the emission control technology installed: technology type, serial number, make, model, manufacturer, EPA/CARB verification number/level, and installation date and hour-meter reading on installation date.
- The contractor shall establish generator sites and truck-staging zones for vehicles waiting to load or unload material on site. Such zones shall be located where diesel emissions have the least impact on abutters, the general public, and especially sensitive receptors such as hospitals, schools, daycare facilities, elderly housing, and convalescent facilities. - The contractor shall maintain a monthly report th at, for each on road diesel vehicle, nonroad construction equipment, or generator onsite, includes:
i. Hour-meter readings on arrival on-site, the fi rst and last day of every month, and on off-site date.
ii. Any problems with the equipment or emission controls. iii. Certified copies of fuel deliveries for the time period that identify:

1. Source of supply

2. Quantity of fuel

3. Quantity of fuel, including sulfur content (percent by weight) cc) Project should exceed Title-24 Building Envelope Energy Efficiency Standards (California Building Standards Code). The following measures can be used to increase energy efficiency:
- Provide pedestrian network improvements, such as interconnected street network, narrower roadways and shorter block lengths, sidewalks, accessibility to transit and transit shelters, traffic calming measures, parks and public spaces, minimize pedestrian barriers. - Provide traffic calming measures, such as:
i. Marked crosswalks
ii. Count-down signal timers
iii. Curb extensions iv. Speed tables
21 iv. Raised crosswalks
v. Raised intersections
vi. Median islands
vii. Tight corner radii
viii. Roundabouts or mini-circles
ix. On-street parking
x. Chicanes/chokers
- Create urban non-motorized zones
- Provide bike parking in non-residential and multi-unit residential projects - Dedicate land for bike trails
- Limit parking supply through:
i. Elimination (or reduction) of minimum parking requirements ii. Creation of maximum parking requirements
iii. Provision of shared parking
- Require residential area parking permit.
- Provide ride-sharing programs
i. Designate a certain percentage of parking spacing for ride sharing vehicles ii. Designating adequate passenger loading and unloading and waiting areas for ride-sharing vehicles
iii. Providing a web site or messaging board for coordinating rides iv. Permanent transportation management association membership and finding requirement.

Greenhouse Gas Project Level Mitigation Measures – PMM-GHG-1 In accordance with provisions of sections 15091(a)(2) and 15126.4(a)(1)(B) of the State CEQA Guidelines, a Lead Agency for a project can and should consider mitigation measures to reduce substantial adverse effects related to violating air quality standards. Such measures may include the following or other comparable measures identified by the Lead Agency:
b) Reduce emissions resulting from projects through implementation of project features, project design, or other measures, such as those described in Appendix F of the State CEQA Guidelines. c) Include off-site measures to mitigate a project’s emissions. d) Measures that consider incorporation of Best Available Control Technology (BACT) during design, construction and operation of projects to minimize GHG emissions, including but not limited to:
i. Use energy and fuel-efficient vehicles and equipment; ii. Deployment of zero- and/or near zero emission technologies; iii. Use lighting systems that are energy efficient, such as LED technology; iv. Use the minimum feasible amount of GHG-emitting construction materials; v. Use cement blended with the maximum feasible amount of flash or other materials that reduce GHG emissions from cement production;
vi. Incorporate design measures to reduce GHG emissions from solid waste management through encouraging solid waste recycling and reuse;
vii. Incorporate design measures to reduce energy consumption and increase use of renewable energy;
viii. Incorporate design measures to reduce water consumption; ix. Use lighter-colored pavement where feasible;
x. Recycle construction debris to maximum extent feasible; xi. Plant shade trees in or near construction projects where feasible; and xii. Solicit bids that include concepts listed above.
22 e) Measures that encourage transit use, carpooling, bike-share and car-share programs, active transportation, and parking strategies, including, but not limited to the following:
i. Promote transit-active transportation coordinated strategies; ii. Increase bicycle carrying capacity on transit and rail vehicles; iii. Improve or increase access to transit;
iv. Increase access to common goods and services, such as groceries, schools, and day care; v. Incorporate affordable housing into the project;
vi. Incorporate the neighborhood electric vehicle network; vii. Orient the project toward transit, bicycle and pedestrian facilities; viii. Improve pedestrian or bicycle networks, or transit service; ix. Provide traffic calming measures;
x. Provide bicycle parking;
xi. Limit or eliminate park supply;
xii. Unbundle parking costs;
xiii. Provide parking cash-out programs;
xiv. Implement or provide access to commute reduction program; f) Incorporate bicycle and pedestrian facilities into project designs, maintaining these facilities, and providing amenities incentivizing their use; and planning for and building local bicycle projects that connect with the regional network;
g) Improving transit access to rail and bus routes by incentives for construction and transit facilities within developments, and/or providing dedicated shuttle service to transit stations; and h) Adopting employer trip reduction measures to reduce employee trips such as vanpool and carpool programs, providing end-of-trip facilities, and telecommuting programs including but not limited to measures that:
i. Provide car-sharing, bike sharing, and ride-sharing programs; ii. Provide transit passes;
iii. Shift single occupancy vehicle trips to carpooling or vanpooling, for example providing ride- matching services;
iv. Provide incentives or subsidies that increase that use of modes other than single-occupancy vehicle;
v. Provide on-site amenities at places of work, such as priority parking for carpools and vanpools, secure bike parking, and showers and locker rooms;
vi. Provide employee transportation coordinators at employment sites; vii. Provide a guaranteed ride home service to users of non-auto modes. i) Designate a percentage of parking spaces for ride-sharing vehicles or high-occupancy vehicles, and provide adequate passenger loading and unloading for those vehicles; j) Land use siting and design measures that reduce GHG emissions, including:
i. Developing on infill and brownfields sites;
ii. Building compact and mixed-use developments near transit; iii. Retaining on-site mature trees and vegetation, and planting new canopy trees; iv. Measures that increase vehicle efficiency, encourage use of zero and low emissions vehicles, or reduce the carbon content of fuels, including constructing or encouraging construction of electric vehicle charging stations or neighborhood electric vehicle networks, or charging for electric bicycles; and
v. Measures to reduce GHG emissions from solid waste management through encouraging solid waste recycling and reuse.
23 k) Consult the SCAG Environmental Justice Toolbox for potential measures to address impacts to low-income and/or minority communities. The measures provided above are also intended to be applied in low income and minority communities as applicable and feasible.
l) Require at least five percent of all vehicle parking spaces include electric vehicle charging stations, or at a minimum, require the appropriate infrastructure to facilitate sufficient electric charging for passenger vehicles and trucks to plug-in.
m) Encourage telecommuting and alternative work schedules, such as:
i. Staggered starting times
ii. Flexible schedules
iii. Compressed work weeks
n) Implement commute trip reduction marketing, such as:
i. New employee orientation of trip re duction and alternative mode options ii. Event promotions
iii. Publications
o) Implement preferential parking permit program
p) Implement school pool and bus programs
q) Price workplace parking, such as:
i. Explicitly charging for parking for its employees;
ii. Implementing above market rate pricing;
iii. Validating parking only for invited guests;
iv. Not providing employee parking and transportation allowances; and v. Educating employees about available alternatives.

These measures offer a cost-effective, feasible way to incorporate lower-emitting design features into the proposed Project, which subsequently, reduce emissions released during Project construction and operation.

As it is policy of the State that eligible renewable energy resources and zero-carbon resources supply 100% of retail sales of electricity to California end-use customers by December 31, 2045, we emphasize that the energy mix that will charge the batteries and power electrical equipment must be 100% renewable energy resources. Until the feasibility of charging the batteries with renewable energy resources only is evaluated, the Project should not be approved.

An EIR should be prepared to include all feasible mitigation measures, as well as include updated air quality, health risk, and GHG analyses to ensure that the necessary mitigation measures are implemented to reduce emissions to below thresholds. The EIR should also demonstrate a commitment to the implementation of these measures prior to Project approval, to ensure that the Project’s significant emissions are reduced to the maximum extent possible.

Disclaimer
SWAPE has received limited discovery regarding this project. 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 24 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.

Attachment A: Updated Health Risk Calculations
Attachment B: AERSCREEN Output Files
Attachment C: Matt Hagemann CV
Attachment D: Paul Rosenfeld CV

0.005

0.02739726
5 0.136986301

62.1369863
1/1/2025
1/6/2025
5 AERSCREEN21112/AERMOD21112 11/15/23
10:56:32
TITLE:PacificResortPlaza,Construction
ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ******************************AREAPARAMETERS**************************** ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ SOURCEEMISSIONRATE: 0.131E Ş02g/s 0.104E Ş01lb/hr
AREAEMISSIONRATE: 0.220E Ş06g/(sŞm2) 0.175E Ş05lb/(hrŞm2) AREAHEIGHT: 3.00 meters 9.84 feet
AREASOURCELONGSIDE: 109.08 meters 357.87 feet
AREASOURCESHORTSIDE: 54.54 meters 178.94 feet
INITIALVERTICALDIMENSION: 1.50 meters 4.92 feet
RURALORURBAN: URBAN
POPULATION: 345940
INITIALPROBEDISTANCE= 5000. meters 16404. feet
ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ***********************BUILDINGDOWNWASHPARAMETERS********************** ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ BUILDINGDOWNWASHNOTUSEDFORNONŞPOINTSOURCES
ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ **************************FLOWSECTORANALYSIS*************************** 25meterreceptorspacing:1.metersŞ5000.meters
ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ MAXIMUMIMPACTRECEPTOR
Zo SURFACE 1ŞHRCONCRADIALDISTTEMPORAL
SECTORROUGHNESS(ug/m3)(deg)(m)PERIOD ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ 1*1.0005.057050.0WIN
*= worstcasediagonal
ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ƚƚĂĐŚŵĞŶƚ
**********************MAKEMETMETEOROLOGYPARAMETERS********************* ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ MIN/MAXTEMPERATURE:250.0/310.0(K)
MINIMUMWINDSPEED:0.5m/s
ANEMOMETERHEIGHT:10.000meters
SURFACECHARACTERISTICSINPUT:AERMETSEASONALTABLES
DOMINANTSURFACEPROFILE:Urban
DOMINANTCLIMATETYPE:AverageMoisture
DOMINANTSEASON:Winter
ALBEDO:0.35
BOWENRATIO:1.50
ROUGHNESSLENGTH:1.000(meters)
SURFACEFRICTIONVELOCITY(U*)NOTADUSTED
METEOROLOGYCONDITIONSUSEDTOPREDICTOVERALLMAXIMUMIMPACT ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ŞŞŞŞŞŞ YRMODYJDYHR
ŞŞŞŞŞŞŞŞŞŞŞ
1001101001
H0U*W*DT/DZZICNVZIMCHMŞOLENZ0BOWENALBEDOREFWS ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ŞŞŞŞŞŞŞ Ş1.300.043Ş9.0000.020Ş999.21.6.01.0001.500.350.50 HT
REFTAHT
ŞŞŞŞŞŞŞŞŞŞŞ
10.0310.02.0
AERSCREEN21112/AERMOD2111211/15/23 10:59:02 TITLE:PacificResortPlaza,Operations ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ******************************AREAPARAMETERS**************************** ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ SOURCEEMISSIONRATE:0.575EŞ03g/s0.457EŞ02lb/hr AREAEMISSIONRATE:0.967EŞ07g/(sŞm2)0.768EŞ06lb/(hrŞm2) AREAHEIGHT:3.00meters9.84feet AREASOURCELONGSIDE:109.08meters357.87feet AREASOURCESHORTSIDE:54.54meters178.94feet INITIALVERTICALDIMENSION:1.50meters4.92feet RURALORURBAN:URBAN
POPULATION:345940
INITIALPROBEDISTANCE=5000.meters16404.feet ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ***********************BUILDINGDOWNWASHPARAMETERS********************** ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ BUILDINGDOWNWASHNOTUSEDFORNONŞPOINTSOURCES ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ **************************FLOWSECTORANALYSIS*************************** 25meterreceptorspacing:1.metersŞ5000.meters ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ MAXIMUMIMPACTRECEPTOR
ZoSURFACE1ŞHRCONCRADIALDISTTEMPORAL SECTORROUGHNESS(ug/m3)(deg)(m)PERIOD ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ 1*1.0002.221050.0WIN *=worstcasediagonal
ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ **********************MAKEMETMETEOROLOGYPARAMETERS********************* ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ MIN/MAXTEMPERATURE:250.0/310.0(K)
MINIMUMWINDSPEED:0.5m/s
ANEMOMETERHEIGHT:10.000meters
SURFACECHARACTERISTICSINPUT:AERMETSEASONALTABLES
DOMINANTSURFACEPROFILE:Urban
DOMINANTCLIMATETYPE:AverageMoisture
DOMINANTSEASON:Winter
ALBEDO:0.35
BOWENRATIO:1.50
ROUGHNESSLENGTH:1.000(meters)
SURFACEFRICTIONVELOCITY(U*)NOTADUSTED
METEOROLOGYCONDITIONSUSEDTOPREDICTOVERALLMAXIMUMIMPACT ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ŞŞŞŞŞŞ YRMODYJDYHR
ŞŞŞŞŞŞŞŞŞŞŞ
1001101001
H0U*W*DT/DZZICNVZIMCHMŞOLENZ0BOWENALBEDOREFWS ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ŞŞŞŞŞŞŞ Ş1.300.043Ş9.0000.020Ş999.21.6.01.0001.500.350.50 HT
REFTAHT
ŞŞŞŞŞŞŞŞŞŞŞ
10.0310.02.0
ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ************************AERSCREENAUTOMATEDDISTANCES********************** OVERALLMAXIMUMCONCENTRATIONSBYDISTANCE ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ MAXIMUMMAXIMUM DIST1ŞHRCONCDIST1ŞHRCONC (m)(ug/m3)(m)(ug/m3) ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ŞŞŞŞ 1.001.7112525.000.1073EŞ01 25.002.0102550.000.1059EŞ01 50.002.2212575.000.1045EŞ01 75.001.4842600.000.1031EŞ01 100.000.94302625.000.1018EŞ01 125.000.68112650.000.1005EŞ01 150.000.52502675.000.9919EŞ02 175.000.42192700.000.9793EŞ02 200.000.34972725.000.9670EŞ02 225.000.29652750.000.9550EŞ02 250.000.25612775.000.9433EŞ02 275.000.22452800.000.9318EŞ02 300.000.19902825.000.9205EŞ02 325.000.17812850.000.9094EŞ02 350.000.16092875.000.8986EŞ02 375.000.14622900.000.8881EŞ02 400.000.13382925.000.8777EŞ02 425.000.12302950.000.8675EŞ02 450.000.11382975.000.8575EŞ02 475.000.10563000.000.8478EŞ02 500.000.9844EŞ013025.000.8382EŞ02 525.000.9206EŞ013050.000.8288EŞ02 550.000.8634EŞ013075.000.8196EŞ02 575.000.8122EŞ013100.000.8106EŞ02 600.000.7661EŞ013125.000.8017EŞ02 625.000.7244EŞ013150.000.7930EŞ02 650.000.6865EŞ013174.990.7845EŞ02 675.000.6519EŞ013199.990.7761EŞ02 700.000.6203EŞ013225.000.7679EŞ02 725.000.5912EŞ013250.000.7598EŞ02 750.000.5644EŞ013275.000.7519EŞ02 775.000.5397EŞ013300.000.7441EŞ02 800.000.5169EŞ013325.000.7364EŞ02 825.000.4956EŞ013350.000.7289EŞ02 850.000.4758EŞ013375.000.7216EŞ02 875.000.4573EŞ013400.000.7143EŞ02 900.000.4400EŞ013425.000.7072EŞ02 925.000.4237EŞ013450.000.7002EŞ02 950.000.4085EŞ013475.000.6933EŞ02 975.000.3941EŞ013500.000.6865EŞ02 1000.000.3807EŞ013525.000.6799EŞ02 1025.000.3695EŞ013550.000.6733EŞ02 1050.000.3575EŞ013575.000.6669EŞ02 1075.000.3461EŞ013600.000.6606EŞ02 1100.000.3354EŞ013625.000.6543EŞ02 1125.000.3252EŞ013650.000.6482EŞ02 1150.000.3155EŞ013675.000.6422EŞ02 1175.000.3063EŞ013700.000.6363EŞ02 1200.000.2976EŞ013725.000.6304EŞ02 1225.000.2893EŞ013750.000.6247EŞ02 1250.000.2814EŞ013775.000.6190EŞ02 1275.000.2738EŞ013800.000.6135EŞ02 1300.000.2666EŞ013825.000.6080EŞ02 1325.000.2598EŞ013849.990.6026EŞ02 1350.000.2532EŞ013875.000.5973EŞ02 1375.000.2469EŞ013900.000.5920EŞ02 1400.000.2409EŞ013925.000.5869EŞ02 1425.000.2351EŞ013950.000.5818EŞ02 1450.000.2296EŞ013975.000.5768EŞ02 1475.000.2242EŞ014000.000.5719EŞ02 1500.000.2191EŞ014025.000.5670EŞ02 1525.000.2142EŞ014050.000.5622EŞ02 1550.000.2095EŞ014075.000.5575EŞ02 1575.000.2049EŞ014100.000.5529EŞ02 1600.000.2006EŞ014125.000.5483EŞ02 1625.000.1963EŞ014149.990.5438EŞ02 1650.000.1923EŞ014175.000.5393EŞ02 1675.000.1884EŞ014200.000.5349EŞ02 1700.000.1846EŞ014225.000.5306EŞ02 1725.000.1809EŞ014250.000.5264EŞ02 1750.000.1774EŞ014275.000.5221EŞ02 1775.000.1740EŞ014300.000.5180EŞ02 1800.000.1707EŞ014325.000.5139EŞ02 1825.000.1675EŞ014350.000.5099EŞ02 1850.000.1644EŞ014375.000.5059EŞ02 1875.000.1614EŞ014400.000.5020EŞ02 1900.000.1585EŞ014425.000.4981EŞ02 1924.990.1557EŞ014450.000.4943EŞ02 1950.000.1529EŞ014475.000.4905EŞ02 1975.000.1503EŞ014500.000.4868EŞ02 2000.000.1477EŞ014525.000.4831EŞ02 2025.000.1452EŞ014550.000.4795EŞ02 2050.000.1428EŞ014575.000.4759EŞ02 2075.000.1405EŞ014600.000.4723EŞ02 2100.000.1382EŞ014625.000.4689EŞ02 2125.000.1359EŞ014650.000.4654EŞ02 2150.000.1338EŞ014675.000.4620EŞ02 2175.000.1317EŞ014700.000.4587EŞ02 2200.000.1296EŞ014725.000.4553EŞ02 2225.000.1276EŞ014750.000.4521EŞ02 2250.000.1257EŞ014775.000.4488EŞ02 2275.000.1238EŞ014800.000.4456EŞ02 2300.000.1220EŞ014825.000.4425EŞ02 2325.000.1202EŞ014850.000.4394EŞ02 2350.000.1184EŞ014875.000.4363EŞ02 2375.000.1167EŞ014900.000.4332EŞ02 2400.000.1151EŞ014924.990.4302EŞ02 2425.000.1135EŞ014950.000.4273EŞ02 2450.000.1119EŞ014975.000.4243EŞ02 2475.000.1103EŞ015000.000.4214EŞ02 2500.000.1088EŞ01
ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ **********************AERSCREENMAXIMUMIMPACTSUMMARY********************* ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ 3Şhour,8Şhour,and24Şhourscaled
concentrationsareequaltothe1Şhourconcentrationasreferencedin SCREENINGPROCEDURESFORESTIMATINGTHEAIRQUALITY
IMPACTOFSTATIONARYSOURCES,REVISED(Section4.5.4)
ReportnumberEPAŞ454/RŞ92Ş019
http://www.epa.gov/scram001/guidance_permit.htm
underScreeningGuidance
MAXIMUMSCALEDSCALEDSCALEDSCALED 1ŞHOUR3ŞHOUR8ŞHOUR24ŞHOURANNUAL CALCULATIONCONCCONCCONCCONCCONC PROCEDURE(ug/m3)(ug/m3)(ug/m3)(ug/m3)(ug/m3) ŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞŞ ŞŞŞŞŞŞŞŞŞŞŞŞŞ FLATTERRAIN2.2562.2562.2562.256N/A DISTANCEFROMSOURCE55.00meters
IMPACTATTHE
AMBIENTBOUNDARY1.7111.7111.7111.711N/A DISTANCEFROMSOURCE1.00meters
2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
[email protected]
Matthew F. Hagemann, P.G., C.Hg., QSD, QSP
Geologic and Hydrogeologic Characterization
Investigation and Remediation Strategies
Litigation Support and Testifying Expert
Industrial Stormwater Compliance
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 30 years of experience in environmental policy, contaminant assessment and remediation, stormwater compliance, and CEQA review. 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) and directed efforts to improve hydrogeologic characterization and water quality monitoring. For the past 15 years, as a founding partner with SWAPE, Matt has developed extensive client relationships and has managed complex projects that include consultation as an expert witness and a regulatory specialist, and a manager of projects ranging from industrial stormwater compliance to CEQA review of impacts from hazardous waste, air quality and greenhouse gas emissions.

Positions Matt has held include:
x Founding Partner, Soil/Water/Air Protection Enterprise (SWAPE) (2003 – present); x Geology Instructor, Golden West College, 2010 – 2104, 2017; x Senior Environmental Analyst, Komex H2O Science, Inc. (2000 -- 2003); ƚƚĂĐŚŵĞŶƚ
2 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 300 environmental impact reports and negative declarations since 2003 under CEQA that identify significant issues with regard to hazardous waste, water resources, water quality, air quality, 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 more than 100 industrial facilities.
x Expert witness on numerous cases including, for example, perfluorooctanoic acid (PFOA) contamination of groundwater, MTBE litigation, air toxins at hazards at a school, CERCLA compliance in assessment and remediation, and industrial stormwater contamination. 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.

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.
3 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. 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 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:
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 4 public hearings, and responded to public comments from residents who were very concerned about the impact of designation.
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 Policy 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 5 principles into the policy-making process.
x Established national protocol for the peer review of scientific documents.

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 listed 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 is currently a part time geology instructor at Golden West College in Huntington Beach, California where he taught from 2010 to 2014 and in 2017.

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

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.

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

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., 1994. Groundwater Ch ar ac te r i z a t i o n and Cl ean up 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. 8 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 examinations, 2009-2011.

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: [email protected]
Paul E. Rosenfeld, Ph.D. Page 1 of 12 October 2022
Paul Rosenfeld, Ph.D. Chemical Fate and Transport & Air Dispersion Modeling Principal Environmental Chemist Risk Assessment & Remediation Specialist Education
Ph.D. Soil Chemistry, University of Washington, 1999. Dissertation on volatile organic compound filtration.

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

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

Professional Experience
Dr. Rosenfeld has over 25 years of 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 oil spills, landfills, boilers and incinerators, process stacks, storage tanks, confined animal feeding operations, industrial, military and agricultural sources, unconventional oil drilling operations, and locomotive and construction engines. 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 also successfully modeled exposure to contaminants distributed by water systems and via vapor intrusion.

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, creosote, 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 sites and has testified as an expert witness on numerous cases involving exposure to soil, water and air contaminants from industrial, railroad, agricultural, and military sources.
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Paul E. Rosenfeld, Ph.D. Page 2 of 12 October 2022

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 Associate 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 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:

Rosenfeld P. E., Spaeth K., Hallman R., Bressler R., Smith, G., (2022) Cancer Risk and Diesel Exhaust Exposure Among Railroad Workers. Water Air Soil Pollution. 233, 171.

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.

Paul E. Rosenfeld, Ph.D. Page 3 of 12 October 2022

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.

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.

Paul E. Rosenfeld, Ph.D. Page 4 of 12 October 2022

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.

Chollack, 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:

Rosenfeld, P.E ., "The science for Perfluorinated Chemicals (PFAS): What makes remediation so hard?" Law Seminars International, (May 9-10, 2018) 800 Fifth Avenue, Suite 101 Seattle, WA.

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). Dioxin and furan blood lipid concentrations in populations living near four wood treatment fa cilities in the Un ited States. Breb bia, C.A. and P opov, 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.

Paul E. Rosenfeld, Ph.D. Page 5 of 12 October 2022

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.

Rosenfeld, P. E. (October 15-18, 2007). Somerville Community Exposure To Contaminants From Wood Treatment Facility Emissions. The 23
rd 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 E. Rosenfeld, Ph.D. Page 6 of 12 October 2022

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.

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 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 Conference. 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 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 Society of America. Lecture conducted from Salt Lake City Utah.

Paul E. Rosenfeld, Ph.D. Page 7 of 12 October 2022

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.

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 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:

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 gran t 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.

Paul E. Rosenfeld, Ph.D. Page 8 of 12 October 2022

James River Corporation, Ore gon: $10 ,000 grant was awarded to investigate the success of gen etically 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 awa rded to construct a large anaerobic d igester on St. Kitts in West Indies. 1993

Deposition and/or Trial Testimony:

In the Superior Court of the State of California, County of San Bernardino Billy Wildrick, Plaintiff vs. BNSF Railway Company
Case No. CI VDS1711810
Rosenfeld Deposition 10-17-2022

In the State Court of Bibb County, State of Georgia
Richard Hutcherson, Plaintiff vs Norfolk Southern Railway Company Case No. 10-SCCV-092007
Rosenfeld Deposition 10-6-2022

In the Civil District Court of the Parish of Orleans, State of Louisiana Millard Clark, Plaintiff vs. Dixie Carriers, Inc. et al.

Case No. 2020-03891
Rosenfeld Deposition 9-15-2022

In The Circuit Court of Livingston County, State of Missouri, Circuit Civil Division Shirley Ralls, Plaintiff vs. Canadian Pacific Railway and Soo Line Railroad Case No. 18-LV-CC0020
Rosenfeld Deposition 9-7-2022

In The Circuit Court of the 13th Judicial Circuit Court, Hillsborough County, Florida Civil Division Jonny C. Daniels, Plaintiff vs. CSX Transportation Inc.

Case No. 20-CA-5502
Rosenfeld Deposition 9-1-2022

In The Circuit Court of St. Louis County, State of Missouri Kieth Luke et. al. Plaintiff vs. Monsanto Company et. al.

Case No. 19SL-CC03191
Rosenfeld Deposition 8-25-2022

In The Circuit Court of the 13th Judicial Circuit Court, Hillsborough County, Florida Civil Division Jeffery S. Lamotte, Plaintiff vs. CSX Transportation Inc.

Case No. NO. 20-CA-0049
Rosenfeld Deposition 8-22-2022

In State of Minnesota District Court, County of St. Louis Sixth Judicial District Greg Bean, Plaintiff vs. Soo Line Railroad Company
Case No. 69-DU-CV-21-760
Rosenfeld Deposition 8-17-2022

In United States District Court Western District of Washington at Tacoma, Washington John D. Fitzgerald Plaintiff vs. BNSF
Case No. 3:21-cv-05288-RJB
Rosenfeld Deposition 8-11-2022

Paul E. Rosenfeld, Ph.D. Page 9 of 12 October 2022

In Circuit Court of the Sixth Judicial Circuit, Macon Illinois Rocky Bennyhoff Plaintiff vs. Norfolk Southern
Case No. 20-L-56
Rosenfeld Deposition 8-3-2022

In Court of Common Pleas, Hamilton County Ohio
Joe Briggins Plaintiff vs. CSX
Case No. A2004464
Rosenfeld Deposition 6-17-2022

In the Superior Court of the State of California, County of Kern George LaFazia vs. BNSF Railway Company.

Case No. BCV-19-103087
Rosenfeld Deposition 5-17-2022

In the Circuit Court of Cook County Illinois
Bobby Earles vs. Penn Central et. al.

Case No. 2020-L-000550
Rosenfeld Deposition 4-16-2022

In United States District Court Easter District of Florida Albert Hartman Plaintiff vs. Illinois Central
Case No. 2:20-cv-1633
Rosenfeld Deposition 4-4-2022

In the Circuit Court of the 4
th Judicial Circuit, in and For Duval County, Florida
Barbara Steele vs. CSX Transportation
Case No.16-219-Ca-008796
Rosenfeld Deposition 3-15-2022

In United States District Court Easter District of New York Romano et al. vs. Northrup Grumman Corporation
Case No. 16-cv-5760
Rosenfeld Deposition 3-10-2022

In the Circuit Court of Cook County Illinois
Linda Benjamin vs. Illinois Central
Case No. No. 2019 L 007599
Rosenfeld Deposition 1-26-2022

In the Circuit Court of Cook County Illinois
Donald Smith vs. Illinois Central
Case No. No. 2019 L 003426
Rosenfeld Deposition 1-24-2022

In the Circuit Court of Cook County Illinois
Jan Holeman vs. BNSF
Case No. 2019 L 000675
Rosenfeld Deposition 1-18-2022

In the State Court of Bibb County State of Georgia
Dwayne B. Garrett vs. Norfolk Southern
Case No. 20-SCCV-091232
Rosenfeld Deposition 11-10-2021

Paul E. Rosenfeld, Ph.D. Page 10 of 12 October 2022

In the Circuit Court of Cook County Illinois
Joseph Ruepke vs. BNSF
Case No. 2019 L 007730
Rosenfeld Deposition 11-5-2021

In the United States District Court For the District of Nebraska Steven Gillett vs. BNSF
Case No. 4:20-cv-03120
Rosenfeld Deposition 10-28-2021

In the Montana Thirteenth District Court of Yellowstone County James Eadus vs. Soo Line Railroad and BNSF
Case No. DV 19-1056
Rosenfeld Deposition 10-21-2021

In the Circuit Court Of The Twentieth Judicial Circuit, St Clair County, Illinois Martha Custer et al.cvs. Cerro Flow Products, Inc.

Case No. 0i9-L-2295
Rosenfeld Deposition 5-14-2021
Trial October 8-4-2021

In the Circuit Court of Cook County Illinois
Joseph Rafferty vs. Consolidated Rail Corporation and National Railroad Passenger Corporation d/b/a

AMTRAK,
Case No. 18-L-6845
Rosenfeld Deposition 6-28-2021

In the United States District Court For the Northern District of Illinois Theresa Romcoe vs. Northeast Illinois Regional Commuter Railroad Corporation d/b/a METRA Rail Case No. 17-cv-8517
Rosenfeld Deposition 5-25-2021

In the Superior Court of the State of Arizona In and For the Cunty of Maricopa Mary Tryon et al. vs. The City of Pheonix v. Cox Cactus Farm, L.L.C., Utah Shelter Systems, Inc.

Case No. CV20127-094749
Rosenfeld Deposition 5-7-2021

In the United States District Court for the Eastern District of Texas Beaumont Division Robinson, Jeremy et al vs. CNA Insurance Company et al.

Case No. 1:17-cv-000508
Rosenfeld Deposition 3-25-2021

In the Superior Court of the State of California, County of San Bernardino Gary Garner, Personal Representative for the Estate of Melvin Garner vs. BNSF Railway Company.

Case No. 1720288
Rosenfeld Deposition 2-23-2021

In the Superior Court of the State of California, County of Los Angeles, Spring Street Courthouse Benny M Rodriguez vs. Union Pacific Railroad, A Corporation, et al.

Case No. 18STCV01162
Rosenfeld Deposition 12-23-2020

In the Circuit Court of Jackson County, Missouri
Karen Cornwell, Plaintiff, vs. Marathon Petroleum, LP, Defendant.

Case No. 1716-CV10006
Rosenfeld Deposition 8-30-2019

Paul E. Rosenfeld, Ph.D. Page 11 of 12 October 2022

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 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. 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. BC646857
Rosenfeld Deposition 10-6-2018; Trial 3-7-19

In United States District Court For The District of Colorado Bells et al. Plaintiffs 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., Plaintifs 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 United States District Court For The Southern District of Mississippi Guy Manuel vs. The BP Exploration et al., Defendants
Case No. 1:19-cv-00315-RHW
Rosenfeld Deposition 4-22-2020

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 No. 4:16-cv-52-DMB-JVM
Rosenfeld Deposition July 2017

Paul E. Rosenfeld, Ph.D. Page 12 of 12 October 2022
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. 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 Circuit Court of Ohio County, West Virginia
Robert Andrews, et al. v. Antero, et al.

Civil Action No. 14-C-30000
Rosenfeld Deposition June 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 No. CACE07030358 (26)
Rosenfeld Deposition December 2014
In the County Court of Dallas County Texas
Lisa Parr et al, Plaintiff, vs. Aruba et al, Defendant.

Case No. 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 No. 2008 CT 10 0741 (Cons. w/ 2009 CV 10 0987)
Rosenfeld Deposition October 2012
In the United States District Court for the Middle District of Alabama, Northern Division James K. Benefield, et al., Plaintiffs, vs. International Paper Company, Defendant.

Civil Action No. 2:09-cv-232-WHA-TFM
Rosenfeld Deposition July 2010, June 2011
In the Circuit Court of Jefferson County Alabama
Jaeanette Moss Anthony, et al., Plaintiffs, vs. Drummond Company Inc., et al., Defendants Civil Action No. CV 2008-2076
Rosenfeld Deposition September 2010
In the United States District Court, Western District Lafayette Division Ackle et al., Plaintiffs, vs. Citgo Petroleum Corporation, et al., Defendants.

Case No. 2:07CV1052
Rosenfeld Deposition July 2009

ATTACHMENT B

EXHIBIT A OF COMMENT LETTER 4
MITCHELL M. TSAI LAW FIRM

EXHIBIT A

1 2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
[email protected]
Paul E. Rosenfeld, PhD
(310) 795-2335
[email protected]
March 8, 2021

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

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

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

1 “California Emissions Estimator Model.” CAPCOA, 2017, available at: http://www.aqmd.gov/caleemod/home. 2 “California Emissions Estimator Model.” CAPCOA, 2017, available at: http://www.aqmd.gov/caleemod/home. 3 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 34.

2 Specifically, the number and length of vehicle trips is utilized to estimate the vehicle miles travelled (“VMT”) associated with construction. Then, utilizing vehicle-class specific EMFAC 2014 emission factors, CalEEMod calculates the vehicle exhaust, evaporative, and dust emissions resulting from construction-related VMT, including personal vehicles for worker commuting.4
Specifically, in order to calculate VMT, CalEEMod multiplies the average daily trip rate by the average overall trip length (see excerpt below):
“VMTd = Σ(Average Daily Trip Rate i * Average Overall Trip Length i) n Where:
n = Number of land uses being modeled.”5
Furthermore, to calculate the on-road emissions associated with worker trips, CalEEMod utilizes the following equation (see excerpt below):
“Emissionspollutant = VMT * EFrunning,pollutant
Where:

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

Default Worker Trip Parameters and Potential Local Hire Requirements As previously discussed, the number, length, and vehicle class of worker trips are utilized by CalEEMod to calculate emissions associated with the on-road vehicle trips required to transport workers to and from the Project site during construction.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.

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-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.

4 As demonstrated above, default rural worker trip lengths for air basins in California vary from 10.8- to 19.8- miles, with an average of 16.47 miles. Furthermore, default urban worker trip lengths vary from 10.8- to 14.7- miles, with an average of 11.17 miles. Thus, while default worker trip lengths vary by location, default urban worker trip lengths tend to be shorter in length. Based on these trends evident in the CalEEMod default worker trip lengths, we can reasonably assume that the efficacy of a local hire requirement is especially dependent upon the urbanization of the project site, as well as the project location.

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

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

This serves as an example of the potential impacts of local hire requirements on estimated project-level GHG emissions, though it does not indicate that local hire requirements would result in reduced construction-related GHG emission for all projects. As previously described, the significance of a local hire requirement depends on the worker trip length enforced and the default worker trip length for the project’s urbanization level and location.

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

5 Disclaimer
SWAPE has received limited discovery. Additional information may become available in the future; thus, we retain the right to revise or amend this report when additional information becomes available. Our professional services have been performed using that degree of care and skill ordinarily exercised, under similar circumstances, by reputable environmental consultants practicing in this or similar localities at the time of service. No other warranty, expressed or implied, is made as to the scope of work, work methodologies and protocols, site conditions, analytical testing results, and findings presented. This report reflects efforts which were limited to information that was reasonably accessible at the time of the work, and may contain informational gaps, inconsistencies, or otherwise be incomplete due to the unavailability or uncertainty of information obtained or provided by third parties.

Sincerely,

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

Paul E. Rosenfeld, Ph.D.

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
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

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

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

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
Project Characteristics - Consistent with the DEIR's model.

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

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

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

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

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

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

Area Mitigation - See SWAPE comment regarding operational mitigation measures.

Water Mitigation - See SWAPE comment regarding operational mitigation measures.

Table Name
Column Name
Default Value
New Value
tblFireplaces
FireplaceWoodMass
1,019.20

0.00 tblFireplaces
FireplaceWoodMass
1,019.20

0.00 tblFireplaces
NumberWood

1.25 0.00
tblFireplaces
NumberWood

48.75 0.00
tblVehicleTrips
ST_TR

7.16 6.17
tblVehicleTrips
ST_TR

6.39 3.87
tblVehicleTrips
ST_TR

2.46 1.39
tblVehicleTrips
ST_TR
158.37

79.82 tblVehicleTrips
ST_TR

8.19 3.75
tblVehicleTrips
ST_TR

94.36 63.99
tblVehicleTrips
ST_TR

49.97 10.74
tblVehicleTrips
SU_TR

6.07 6.16
tblVehicleTrips
SU_TR

5.86 4.18
tblVehicleTrips
SU_TR

1.05 0.69
tblVehicleTrips
SU_TR
131.84

78.27 CalEEMod Version: CalEEMod.2016.3.2
Date: 1/6/2021 1:52 PM

Page 2 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

2.0 Emissions Summary
tblVehicleTrips
SU_TR

5.95 3.20
tblVehicleTrips
SU_TR

72.16 57.65
tblVehicleTrips
SU_TR

25.24 6.39
tblVehicleTrips
WD_TR

6.59 5.83
tblVehicleTrips
WD_TR

6.65 4.13
tblVehicleTrips
WD_TR

11.03 6.41
tblVehicleTrips
WD_TR
127.15

65.80 tblVehicleTrips
WD_TR

8.17 3.84
tblVehicleTrips
WD_TR

89.95 62.64
tblVehicleTrips
WD_TR

42.70 9.43
tblWoodstoves
NumberCatalytic

1.25 0.00
tblWoodstoves
NumberCatalytic

48.75 0.00
tblWoodstoves
NumberNoncatalytic

1.25 0.00
tblWoodstoves
NumberNoncatalytic

48.75 0.00
tblWoodstoves
WoodstoveDayYear

25.00 0.00
tblWoodstoves
WoodstoveDayYear

25.00 0.00
tblWoodstoves
WoodstoveWoodMass
999.60

0.00 tblWoodstoves
WoodstoveWoodMass
999.60

0.00 CalEEMod Version: CalEEMod.2016.3.2
Date: 1/6/2021 1:52 PM

Page 3 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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

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
CalEEMod Version: CalEEMod.2016.3.2
Date: 1/6/2021 1:52 PM

Page 4 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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

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
Quarter
Start Date
End Date
Maximum Unmitigated ROG + NOX (tons/quarter)
Maximum Mitigated ROG + NOX (tons/quarter)
1 9-1-2021
11-30-2021

1.4103

1.4103
2 12-1-2021
2-28-2022

1.3613

1.3613
3 3-1-2022
5-31-2022

1.1985

1.1985
4 6-1-2022
8-31-2022

1.1921

1.1921
5 9-1-2022
11-30-2022

1.1918

1.1918
6 12-1-2022
2-28-2023

1.0774

1.0774
7 3-1-2023
5-31-2023

1.0320

1.0320
8 6-1-2023
8-31-2023

1.0260

1.0260
CalEEMod Version: CalEEMod.2016.3.2
Date: 1/6/2021 1:52 PM

Page 5 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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

0.0000
220.9670
220.9670

0.0201

3.7400e-
003
222.5835
Energy

0.1398

1.2312

0.7770

7.6200e-
003

0.0966

0.0000
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
207.8079

12.2811

0.0000
514.8354
Water

0.0000

29.1632
556.6420
585.8052

3.0183

0.0755
683.7567
Total

6.8692

9.5223

30.3407

0.0914

7.7979

0.2260

8.0240

2.0895

0.2219

2.3114
236.9712
12,294.18
07 12,531.15
19 15.7904

0.1260
12,963.47
51 Unmitigated Operational
9 9-1-2023
11-30-2023

1.0265

1.0265
10 12-1-2023
2-29-2024

2.8857

2.8857
11 3-1-2024
5-31-2024

1.6207

1.6207
Highest

2.8857

2.8857
CalEEMod Version: CalEEMod.2016.3.2
Date: 1/6/2021 1:52 PM

Page 6 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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

0.0000
220.9670
220.9670

0.0201

3.7400e-
003
222.5835
Energy

0.1398

1.2312

0.7770

7.6200e-
003

0.0966

0.0000
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
207.8079

12.2811

0.0000
514.8354
Water

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
CalEEMod Version: CalEEMod.2016.3.2
Date: 1/6/2021 1:52 PM

Page 7 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

Phase
Number
Phase Name
Phase Type
Start Date
End Date
Num Days
Week
Num Days
Phase Description
1 Demolition
Demolition
9/1/2021
10/12/2021
5 30
2 Site Preparation
Site Preparation
10/13/2021
11/9/2021
5 20
3 Grading
Grading
11/10/2021
1/11/2022
5 45
4 Building Construction
Building Construction
1/12/2022
12/12/2023
5 500
5 Paving
Paving
12/13/2023
1/30/2024
5 35
6 Architectural Coating
Architectural Coating
1/31/2024
3/19/2024
5 35
OffRoad Equipment
Residential Indoor: 2,025,000; Residential Outdoor: 675,000; Non-Residential Indoor: 326,400; Non-Residential Outdoor: 108,800; Striped Parking Area: 0 (Architectural Coating
±
sqft)
Acres of Grading (Site Preparation Phase): 0
Acres of Grading (Grading Phase): 112.5
Acres of Paving: 0
CalEEMod Version: CalEEMod.2016.3.2
Date: 1/6/2021 1:52 PM

Page 8 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

Phase Name
Offroad Equipment Type
Amount
Usage Hours
Horse Power
Load Factor
Demolition
Concrete/Industrial Saws
1 8.00
81 0.73
Demolition
Excavators
3 8.00
158

0.38 Demolition
Rubber Tired Dozers
2 8.00
247

0.40 Site Preparation
Rubber Tired Dozers
3 8.00
247

0.40 Site Preparation
Tractors/Loaders/Backhoes
4 8.00
97 0.37
Grading
Excavators
2 8.00
158

0.38 Grading
Graders
1 8.00
187

0.41 Grading
Rubber Tired Dozers
1 8.00
247

0.40 Grading
Scrapers
2 8.00
367

0.48 Grading
Tractors/Loaders/Backhoes
2 8.00
97 0.37
Building Construction
Cranes
1 7.00
231

0.29 Building Construction
Forklifts
3 8.00
89 0.20
Building Construction
Generator Sets
1 8.00
84 0.74
Building Construction
Tractors/Loaders/Backhoes
3 7.00
97 0.37
Building Construction
Welders
1 8.00
46 0.45
Paving
Pavers
2 8.00
130

0.42 Paving
Paving Equipment
2 8.00
132

0.36 Paving
Rollers
2 8.00
80 0.38
Architectural Coating
Air Compressors
1 6.00
78 0.48
Trips and VMT
CalEEMod Version: CalEEMod.2016.3.2
Date: 1/6/2021 1:52 PM

Page 9 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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
Off-Road

0.0475

0.4716

0.3235

5.8000e-
004

0.0233

0.0216

0.0000

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

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 PM

Page 10 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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

1.2100e-
003

0.0000

17.4869
Vendor

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

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

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
Off-Road

0.0475

0.4716

0.3235

5.8000e-
004

0.0233

0.0216

0.0000

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

0.0144

0.0000

51.3600
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2
Date: 1/6/2021 1:52 PM

Page 11 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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

1.2100e-
003

0.0000

17.4869
Vendor

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

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

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
Off-Road

0.0389

0.4050

0.2115

3.8000e-
004

0.0204

0.0188

0.0000

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

0.0108

0.0000

33.7061
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2
Date: 1/6/2021 1:52 PM

Page 12 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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
Vendor

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

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

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
Off-Road

0.0389

0.4050

0.2115

3.8000e-
004

0.0204

0.0188

0.0000

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

0.0108

0.0000

33.7060
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2
Date: 1/6/2021 1:52 PM

Page 13 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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
Vendor

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

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

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
Off-Road

0.0796

0.8816

0.5867

1.1800e-
003

0.0377

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 PM

Page 14 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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
Vendor

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

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

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
Off-Road

0.0796

0.8816

0.5867

1.1800e-
003

0.0377

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 PM

Page 15 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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
Vendor

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

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

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
Off-Road

0.0127

0.1360

0.1017

2.2000e-
004

5.7200e-
003

5.2600e-
003

0.0000

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

6.1700e-
003

0.0000

19.2414
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2
Date: 1/6/2021 1:52 PM

Page 16 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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
Vendor

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

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

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
Off-Road

0.0127

0.1360

0.1017

2.2000e-
004

5.7200e-
003

5.2600e-
003

0.0000

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

6.1700e-
003

0.0000

19.2414
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2
Date: 1/6/2021 1:52 PM

Page 17 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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
Vendor

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

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

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

0.0963

0.0000
293.1324
293.1324

0.0702

0.0000
294.8881
Total

0.2158

1.9754

2.0700

3.4100e-
003

0.1023

0.0963

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 PM

Page 18 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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
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

0.0963

0.0000
293.1321
293.1321

0.0702

0.0000
294.8877
Total

0.2158

1.9754

2.0700

3.4100e-
003

0.1023

0.0963

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 PM

Page 19 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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
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

0.0813

0.0000
286.2789
286.2789

0.0681

0.0000
287.9814
Total

0.1942

1.7765

2.0061

3.3300e-
003

0.0864

0.0813

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 PM

Page 20 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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
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

0.0813

0.0000
286.2785
286.2785

0.0681

0.0000
287.9811
Total

0.1942

1.7765

2.0061

3.3300e-
003

0.0864

0.0813

0.0000
286.2785
286.2785

0.0681

0.0000
287.9811
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2
Date: 1/6/2021 1:52 PM

Page 21 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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
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

3.0500e-
003

0.0000

13.0175

4.2100e-
003

0.0000

13.1227
Paving

0.0000

0.0000
Total

6.7100e-
003

0.0663

0.0948

1.5000e-
004

3.3200e-
003

3.0500e-
003

0.0000

13.0175

4.2100e-
003

0.0000

13.1227
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2
Date: 1/6/2021 1:52 PM

Page 22 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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
Vendor

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

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

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

3.0500e-
003

0.0000

13.0175

4.2100e-
003

0.0000

13.1227
Paving

0.0000

0.0000
Total

6.7100e-
003

0.0663

0.0948

1.5000e-
004

3.3200e-
003

3.0500e-
003

0.0000

13.0175

4.2100e-
003

0.0000

13.1227
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2
Date: 1/6/2021 1:52 PM

Page 23 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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
Vendor

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

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

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

4.7400e-
003

0.0000

22.0292

7.1200e-
003

0.0000

22.2073
Paving

0.0000

0.0000
Total

0.0109

0.1048

0.1609

2.5000e-
004

5.1500e-
003

4.7400e-
003

0.0000

22.0292

7.1200e-
003

0.0000

22.2073
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2
Date: 1/6/2021 1:52 PM

Page 24 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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
Vendor

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

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

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

4.7400e-
003

0.0000

22.0292

7.1200e-
003

0.0000

22.2073
Paving

0.0000

0.0000
Total

0.0109

0.1048

0.1609

2.5000e-
004

5.1500e-
003

4.7400e-
003

0.0000

22.0292

7.1200e-
003

0.0000

22.2073
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2
Date: 1/6/2021 1:52 PM

Page 25 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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
Vendor

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

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

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
Off-Road

3.1600e-
003

0.0213

0.0317

5.0000e-
005

1.0700e-
003

0.0000

4.4682

2.5000e-
004

0.0000

4.4745
Total

4.1404

0.0213

0.0317

5.0000e-
005

1.0700e-
003

0.0000

4.4682

2.5000e-
004

0.0000

4.4745
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2
Date: 1/6/2021 1:52 PM

Page 26 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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
Vendor

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

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

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
Off-Road

3.1600e-
003

0.0213

0.0317

5.0000e-
005

1.0700e-
003

0.0000

4.4682

2.5000e-
004

0.0000

4.4745
Total

4.1404

0.0213

0.0317

5.0000e-
005

1.0700e-
003

0.0000

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 PM

Page 27 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

4.0 Operational Detail - Mobile

4.1 Mitigation Measures Mobile

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

0.0000

0.0000
Vendor

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

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

6.1000e-
004

0.0000

24.9558
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2
Date: 1/6/2021 1:52 PM

Page 28 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Mitigated

1.5857

7.9962

19.1834

0.0821

7.7979

0.0580

7.8559

2.0895

0.0539

2.1434

0.0000
7,620.498
6 7,620.498
6 0.3407

0.0000
7,629.016
2 Unmitigated

1.5857

7.9962

19.1834

0.0821

7.7979

0.0580

7.8559

2.0895

0.0539

2.1434

0.0000
7,620.498
6 7,620.498
6 0.3407

0.0000
7,629.016
2 4.2 Trip Summary Information

4.3 Trip Type Information
Average Daily Trip Rate
Unmitigated
Mitigated
Land Use
Weekday
Saturday
Sunday
Annual VMT
Annual VMT
Apartments Low Rise
145.75
154.25
154.00
506,227
506,227
Apartments Mid Rise
4,026.75
3,773.25
4075.50
13,660,065
13,660,065
General Office Building
288.45

62.55 31.05
706,812
706,812
High Turnover (Sit Down Restaurant)
2,368.80
2,873.52
2817.72
3,413,937
3,413,937
Hotel
192.00
187.50
160.00
445,703
445,703
Quality Restaurant
501.12
511.92
461.20
707,488
707,488
Regional Shopping Center
528.08
601.44
357.84
1,112,221
1,112,221
Total
8,050.95
8,164.43
8,057.31
20,552,452
20,552,452
CalEEMod Version: CalEEMod.2016.3.2
Date: 1/6/2021 1:52 PM

Page 29 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

Miles
Trip %
Trip Purpose %
Land Use
H-W or C-W
H-S or C-C
H-O or C-NW
H-W or C-W
H-S or C-C
H-O or C-NW
Primary
Diverted
Pass-by
Apartments Low Rise

14.70 5.90

8.70 40.20

19.20 40.60
86 11
3 Apartments Mid Rise

14.70 5.90

8.70 40.20

19.20 40.60
86 11
3 General Office Building

16.60 8.40

6.90 33.00

48.00 19.00
77 19
4 High Turnover (Sit Down
Restaurant)

16.60 8.40

6.90 8.50

72.50 19.00
37 20
43 Hotel

16.60 8.40

6.90 19.40

61.60 19.00
58 38
4 Quality Restaurant

16.60 8.40

6.90 12.00

69.00 19.00
38 18
44 Regional Shopping Center

16.60 8.40

6.90 16.30

64.70 19.00
54 35
11 5.0 Energy Detail

5.1 Mitigation Measures Energy

4.4 Fleet Mix
Land Use
LDA
LDT1
LDT2
MDV
LHD1
LHD2
MHD
HHD
OBUS
UBUS
MCY
SBUS
MH
Apartments Low Rise

0.543088

0.044216

0.209971

0.116369

0.014033

0.006332

0.021166

0.033577

0.002613

0.001817

0.005285

0.000712

0.000821
Apartments Mid Rise

0.543088

0.044216

0.209971

0.116369

0.014033

0.006332

0.021166

0.033577

0.002613

0.001817

0.005285

0.000712

0.000821
General Office Building

0.543088

0.044216

0.209971

0.116369

0.014033

0.006332

0.021166

0.033577

0.002613

0.001817

0.005285

0.000712

0.000821
High Turnover (Sit Down
Restaurant)

0.543088

0.044216

0.209971

0.116369

0.014033

0.006332

0.021166

0.033577

0.002613

0.001817

0.005285

0.000712

0.000821
Hotel

0.543088

0.044216

0.209971

0.116369

0.014033

0.006332

0.021166

0.033577

0.002613

0.001817

0.005285

0.000712

0.000821
Quality Restaurant

0.543088

0.044216

0.209971

0.116369

0.014033

0.006332

0.021166

0.033577

0.002613

0.001817

0.005285

0.000712

0.000821
Regional Shopping Center

0.543088

0.044216

0.209971

0.116369

0.014033

0.006332

0.021166

0.033577

0.002613

0.001817

0.005285

0.000712

0.000821
Historical Energy Use: N
CalEEMod Version: CalEEMod.2016.3.2
Date: 1/6/2021 1:52 PM

Page 30 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Electricity
Mitigated

0.0000

0.0000
2,512.646
5 2,512.646
5 0.1037

0.0215
2,521.635
6 Electricity
Unmitigated

0.0000

0.0000
2,512.646
5 2,512.646
5 0.1037

0.0215
2,521.635
6 NaturalGas
Mitigated

0.1398

1.2312

0.7770

7.6200e-
003

0.0966

0.0000
1,383.426
7 1,383.426
7 0.0265

0.0254
1,391.647
8 NaturalGas
Unmitigated

0.1398

1.2312

0.7770

7.6200e-
003

0.0966

0.0000
1,383.426
7 1,383.426
7 0.0265

0.0254
1,391.647
8 CalEEMod Version: CalEEMod.2016.3.2
Date: 1/6/2021 1:52 PM

Page 31 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
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
Land Use
kBTU/yr
tons/yr
MT/yr
Apartments Low
Rise
408494

2.2000e-
003

0.0188

8.0100e-
003

1.2000e-
004

1.5200e-
003

0.0000

21.7988

4.2000e-
004

4.0000e-
004

21.9284
Apartments Mid
Rise

1.30613e
+007

0.0704

0.6018

0.2561

3.8400e-
003

0.0487

0.0000
696.9989
696.9989

0.0134

0.0128
701.1408
General Office
Building
468450

2.5300e-
003

0.0230

0.0193

1.4000e-
004

1.7500e-
003

0.0000

24.9983

4.8000e-
004

4.6000e-
004

25.1468
High Turnover (Sit
Down Restaurant)

8.30736e
+006

0.0448

0.4072

0.3421

2.4400e-
003

0.0310

0.0000
443.3124
443.3124

8.5000e-
003

8.1300e-
003
445.9468
Hotel

1.74095e
+006

9.3900e-
003

0.0853

0.0717

5.1000e-
004

6.4900e-
003

0.0000

92.9036

1.7800e-
003

1.7000e-
003

93.4557
Quality
Restaurant

1.84608e
+006

9.9500e-
003

0.0905

0.0760

5.4000e-
004

6.8800e-
003

0.0000

98.5139

1.8900e-
003

1.8100e-
003

99.0993
Regional
Shopping Center
91840

5.0000e-
004

4.5000e-
003

3.7800e-
003

3.0000e-
005

3.4000e-
004

0.0000

4.9009

9.0000e-
005

4.9301
Total

0.1398

1.2312

0.7770

7.6200e-
003

0.0966

0.0000
1,383.426
8 1,383.426
8 0.0265

0.0254
1,391.647
8 Unmitigated
CalEEMod Version: CalEEMod.2016.3.2
Date: 1/6/2021 1:52 PM

Page 32 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

2.2000e-
003

0.0188

8.0100e-
003

1.2000e-
004

1.5200e-
003

0.0000

21.7988

4.2000e-
004

4.0000e-
004

21.9284
Apartments Mid
Rise

1.30613e
+007

0.0704

0.6018

0.2561

3.8400e-
003

0.0487

0.0000
696.9989
696.9989

0.0134

0.0128
701.1408
General Office
Building
468450

2.5300e-
003

0.0230

0.0193

1.4000e-
004

1.7500e-
003

0.0000

24.9983

4.8000e-
004

4.6000e-
004

25.1468
High Turnover (Sit
Down Restaurant)

8.30736e
+006

0.0448

0.4072

0.3421

2.4400e-
003

0.0310

0.0000
443.3124
443.3124

8.5000e-
003

8.1300e-
003
445.9468
Hotel

1.74095e
+006

9.3900e-
003

0.0853

0.0717

5.1000e-
004

6.4900e-
003

0.0000

92.9036

1.7800e-
003

1.7000e-
003

93.4557
Quality
Restaurant

1.84608e
+006

9.9500e-
003

0.0905

0.0760

5.4000e-
004

6.8800e-
003

0.0000

98.5139

1.8900e-
003

1.8100e-
003

99.0993
Regional
Shopping Center
91840

5.0000e-
004

4.5000e-
003

3.7800e-
003

3.0000e-
005

3.4000e-
004

0.0000

4.9009

9.0000e-
005

4.9301
Total

0.1398

1.2312

0.7770

7.6200e-
003

0.0966

0.0000
1,383.426
8 1,383.426
8 0.0265

0.0254
1,391.647
8 Mitigated
CalEEMod Version: CalEEMod.2016.3.2
Date: 1/6/2021 1:52 PM

Page 33 of 44 ends

Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2
CH4
N2O
CO2e
Land Use
kWh/yr
MT/yr
Apartments Low
Rise
106010

33.7770

1.3900e-
003

2.9000e-
004

33.8978
Apartments Mid
Rise

3.94697e
+006
1,257.587
9 0.0519

0.0107
1,262.086
9 General Office
Building
584550
186.2502

7.6900e-
003

1.5900e-
003
186.9165
High Turnover (Sit
Down Restaurant)

1.58904e
+006
506.3022

0.0209

4.3200e-
003
508.1135
Hotel
550308
175.3399

7.2400e-
003

1.5000e-
003
175.9672
Quality
Restaurant
353120
112.5116

4.6500e-
003

9.6000e-
004
112.9141
Regional
Shopping Center
756000
240.8778

9.9400e-
003

2.0600e-
003
241.7395
Total
2,512.646
5 0.1037

0.0215
2,521.635
6 Unmitigated
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Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

6.1 Mitigation Measures Area

6.0 Area Detail

5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2
CH4
N2O
CO2e
Land Use
kWh/yr
MT/yr
Apartments Low
Rise
106010

33.7770

1.3900e-
003

2.9000e-
004

33.8978
Apartments Mid
Rise

3.94697e
+006
1,257.587
9 0.0519

0.0107
1,262.086
9 General Office
Building
584550
186.2502

7.6900e-
003

1.5900e-
003
186.9165
High Turnover (Sit
Down Restaurant)

1.58904e
+006
506.3022

0.0209

4.3200e-
003
508.1135
Hotel
550308
175.3399

7.2400e-
003

1.5000e-
003
175.9672
Quality
Restaurant
353120
112.5116

4.6500e-
003

9.6000e-
004
112.9141
Regional
Shopping Center
756000
240.8778

9.9400e-
003

2.0600e-
003
241.7395
Total
2,512.646
5 0.1037

0.0215
2,521.635
6 Mitigated
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Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Mitigated

5.1437

0.2950

10.3804

1.6700e-
003

0.0714

0.0000
220.9670
220.9670

0.0201

3.7400e-
003
222.5835
Unmitigated

5.1437

0.2950

10.3804

1.6700e-
003

0.0714

0.0000
220.9670
220.9670

0.0201

3.7400e-
003
222.5835

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

0.4137

0.0000

0.0000
Consumer
Products

4.3998

0.0000

0.0000
Hearth

0.0206

0.1763

0.0750

1.1200e-
003

0.0143

0.0000
204.1166
204.1166

3.9100e-
003

3.7400e-
003
205.3295
Landscaping

0.3096

0.1187

10.3054

5.4000e-
004

0.0572

0.0000

16.8504

0.0161

0.0000

17.2540
Total

5.1437

0.2950

10.3804

1.6600e-
003

0.0714

0.0000
220.9670
220.9670

0.0201

3.7400e-
003
222.5835
Unmitigated
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Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

7.1 Mitigation Measures Water

7.0 Water Detail

0.4137

0.0000

0.0000
Consumer
Products

4.3998

0.0000

0.0000
Hearth

0.0206

0.1763

0.0750

1.1200e-
003

0.0143

0.0000
204.1166
204.1166

3.9100e-
003

3.7400e-
003
205.3295
Landscaping

0.3096

0.1187

10.3054

5.4000e-
004

0.0572

0.0000

16.8504

0.0161

0.0000

17.2540
Total

5.1437

0.2950

10.3804

1.6600e-
003

0.0714

0.0000
220.9670
220.9670

0.0201

3.7400e-
003
222.5835
Mitigated
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Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

Total CO2
CH4
N2O
CO2e
Category
MT/yr
Mitigated
585.8052

3.0183

0.0755
683.7567
Unmitigated
585.8052

3.0183

0.0755
683.7567
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Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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

1.62885 /

1.02688

10.9095

0.0535

1.3400e-
003

12.6471
Apartments Mid
Rise

63.5252 /

40.0485
425.4719

2.0867

0.0523
493.2363
General Office
Building

7.99802 /

4.90201

53.0719

0.2627

6.5900e-
003

61.6019
High Turnover (Sit
Down Restaurant)

10.9272 /

0.697482

51.2702

0.3580

8.8200e-
003

62.8482
Hotel

1.26834 /

0.140927

6.1633

0.0416

1.0300e-
003

7.5079
Quality
Restaurant

2.42827 /

0.154996

11.3934

0.0796

1.9600e-
003

13.9663
Regional
Shopping Center

4.14806 /

2.54236

27.5250

0.1363

3.4200e-
003

31.9490
Total
585.8052

3.0183

0.0755
683.7567
Unmitigated
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Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

8.1 Mitigation Measures Waste

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

1.62885 /

1.02688

10.9095

0.0535

1.3400e-
003

12.6471
Apartments Mid
Rise

63.5252 /

40.0485
425.4719

2.0867

0.0523
493.2363
General Office
Building

7.99802 /

4.90201

53.0719

0.2627

6.5900e-
003

61.6019
High Turnover (Sit
Down Restaurant)

10.9272 /

0.697482

51.2702

0.3580

8.8200e-
003

62.8482
Hotel

1.26834 /

0.140927

6.1633

0.0416

1.0300e-
003

7.5079
Quality
Restaurant

2.42827 /

0.154996

11.3934

0.0796

1.9600e-
003

13.9663
Regional
Shopping Center

4.14806 /

2.54236

27.5250

0.1363

3.4200e-
003

31.9490
Total
585.8052

3.0183

0.0755
683.7567
Mitigated

8.0 Waste Detail
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Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

Total CO2
CH4
N2O
CO2e
MT/yr
Mitigated
207.8079

12.2811

0.0000
514.8354
Unmitigated
207.8079

12.2811

0.0000
514.8354
Category/Year
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Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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

11.5 2.3344

0.1380

0.0000

5.7834
Apartments Mid
Rise
448.5

91.0415

5.3804

0.0000
225.5513
General Office
Building

41.85 8.4952

0.5021

0.0000

21.0464
High Turnover (Sit
Down Restaurant)
428.4

86.9613

5.1393

0.0000
215.4430
Hotel

27.38 5.5579

0.3285

0.0000

13.7694
Quality
Restaurant

7.3 1.4818

0.0876

0.0000

3.6712
Regional
Shopping Center

58.8 11.9359

0.7054

0.0000

29.5706
Total
207.8079

12.2811

0.0000
514.8354
Unmitigated
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Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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

11.5 2.3344

0.1380

0.0000

5.7834
Apartments Mid
Rise
448.5

91.0415

5.3804

0.0000
225.5513
General Office
Building

41.85 8.4952

0.5021

0.0000

21.0464
High Turnover (Sit
Down Restaurant)
428.4

86.9613

5.1393

0.0000
215.4430
Hotel

27.38 5.5579

0.3285

0.0000

13.7694
Quality
Restaurant

7.3 1.4818

0.0876

0.0000

3.6712
Regional
Shopping Center

58.8 11.9359

0.7054

0.0000

29.5706
Total
207.8079

12.2811

0.0000
514.8354
Mitigated

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

10.0 Stationary Equipment
Fire Pumps and Emergency Generators
Equipment Type
Number
Hours/Day
Hours/Year
Horse Power
Load Factor
Fuel Type
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Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

11.0 Vegetation
Boilers
Equipment Type
Number
Heat Input/Day
Heat Input/Year
Boiler Rating
Fuel Type
User Defined Equipment
Equipment Type
Number
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Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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
2028
Operational Year
CO2 Intensity
(lb/MWhr)
702.44

0.029
CH4 Intensity
(lb/MWhr)

0.006
N2O Intensity
(lb/MWhr)
Village South Specific Plan (Proposed)
Los Angeles-South Coast County, Summer
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Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer

Project Characteristics - Consistent with the DEIR's model.