5. Appendix to Minutes (02/27/24) — Anaheim City Council, September 10, 2024 (part 1 of 2)

SusanaBarrios
From: jodiemosley <[email protected]>
Sent: Friday, February
To: Public Comment
Subject:\[ EXTERNAL\] Noonitem5
Youdon'toftengetemailfrom Learnwhythisisimportant
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Don'tvoteforanearlyhalfmilliondollarelectric carsforAnaheimiftheycan'tcleanupBeachblvdorhelpwest Anaheims fightagainstlevelingthemotelsthatcauseddecadesofcrime.

YOUDON'TDESERVEITandmoneyshouldfirstgotohelpourcommunity.

Isuggestthecitycounciltakeapoliceridealongwithundercover policeandseethedamage onBeachbeforerewarding AnaheimwithANYTHING.

Youarenotentitled.

SentfrommyT-Mobile5GDevice
1 SusanaBarrios
From: MargotPierrong <margotpierrong@roadrunner. com>
Sent: Wednesday, February
To: Public Comment
Subject:\[ EXTERNAL\] SIDEWALK VENDORS ONVALENTINE'SDAYFEB. 14TH Youdon'toftengetemailfrom Learnwhythisisimportant
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Justacomment:

WhileIguessAnaheim’sCity “Eyes” getclosed onValentine’sDayforalltheillegal sidewalk vendors (thatdon’tpaycitytaxes) – I’msuretheVon’sgrocery storecan’tbe happywiththatsidewalk vendor selling flowers & Valentine itemsrightoutside ofthe storeentrance – Von’sissellingexactly thesamething & theyfollowtherules & regulations.

Justcommenting….

MargotPierrong
Anaheim resident
1 SusanaBarrios
From: MargotPierrong <margotpierrong@roadrunner. com>
Sent: Friday, February
To: Public Comment
Subject:\[ EXTERNAL\] THRILLED ! THANK YOU !
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DearCityCouncil !....

Thank youforvotingtomakeitapriority tocitethesesidewalk sellerswhodonotpay citytaxes & takesalesawayfrombusinesses thatselltheproduct! THANK YOU nowhopefully youwill thinkabout & votetoridtheGREAT CITYOFANAHEIM of alltheHookah lounges – omg! UGH ! Horrible message forthisgreatcity! THANK YOU !! THANK YOU !! THANK YOU !!
MargotPierrong
Anaheim resident – OrangeAve, Anaheim 92804
1 SusanaBarrios
From: JoeAcosta <joeacosta@sbcglobal. net>
Sent: Friday, February
To: Public Comment
Subject:\[ EXTERNAL\] StreetVendors
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First, Iwant tothank TheCity Council forregulating street vendors, andkeeping thehealth ofWeThePeople ofAnaheim a priority. And, respecting therights ofthebrick andmortar businesses thatpay significant amounts intoTheCitycaufers.

Ifsaid ordinance toregulate street vendors was notimplemented itwould have setaprecedent thatwould have been unfair to brick andmortar businesses, and visually created blight through outTheCityofAnaheim.

Again, Thank you
JoeAcosta
1 SusanaBarrios
From: JANET TAYLOR <[email protected]>
Sent: Saturday, February
To: Public Comment
Subject:\[ EXTERNAL\] StreetVendors
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Wehavebeenconcerned aboutthegrowing number ofpop-uprestaurants inourcommunity. They seemtotakeoverentireside-walksparticularly nearbusyintersections whichdoesn'tseemsafe. We don'tfrequent themaswedon'tknowiftheyhavepermits orifthefoodissafe. Wehopethepending ordinance willbeameans toensure thehealth andsafetyoffoodsalesinAnaheim.

Thank youforregulating street vendors andkeeping thehealthofthepeople ofAnaheim apriority.

JanetandHarvey Taylor
Anaheim
1 SusanaBarrios
From: MargotPierrong <margotpierrong@roadrunner. com>
Sent: Monday, February
To: Public Comment
Subject:\[ EXTERNAL\] THESE STREET SELLERS AREANUISANCE - Youdon'toftengetemailfrom Learnwhythisisimportant
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IcanonlyhopethattheAnaheim CityCouncil willdefinitely allocate extrafundsforthe CodeEnforcement depttoworkontheweekends (Sat.&Sunare
whenthesesellersappear!) toridthesidewalks oftheseunslightly street sellers thathavenolicensetosellfooditems & takemoney awayfromourbusinesses thatDOfollowtherules & regulations. Onmystreetalonelastweekend (ORANGE AVE./AGATE ST. – ANAHEIM 92804) thesidewalk sellercaused atraffic snafubecause thecarsjuststopinthemiddle ofthestreet! OrangeAvenue (92804) hasbecome a busybusystreetnowbecause drivershavediscovered itgoesallthewaythrough to LongBeach & iseasiertonavigate thansayLincoln, BallRd. OrKatellaAve. – sothis streetisamagnet forthesesellers thatleavetheirmessonthesidewalks.

Thank youforaddressing thisissue & Iamseeing thatmanyothercitiesarefollowing suitwithdealing withunlicensed sellersonthestreet!
MargotPierrong
OrangeAve – Anaheim 92804
1 SusanaBarrios
From: BobOlea <bobbyolea070522@gmail. com>
Sent: Tuesday,
To: Public Comment
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IsuggestyouputtherecallitemontheNovember ballotSentfrommyiPhone 1 SusanaBarrios
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Cc: Natalie Rubalcava; Norma C. Kurtz; Ashleigh Aitken; JoseDiaz; Stephen Faessel; Natalie Meeks; CarlosA. Leon
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appearssimilartosomeonewhopreviously sentyouemail, butmaynotbethatperson.

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Goodeveningeveryone. Iwantyouguys, theMayorcouncilmember Diazcouncil, member, Leoncouncil, member, Faesselcouncil, member, Meeks, andMayorprotentostandUnitedwithcouncilmemberRubalcava onontheissues thatshe’sgoingthroughwiththerecall, Louisesweetlady, andshedon’tdon’tdeservetobetreatedthis standbyher SentfrommyiPhone
1 SusanaBarrios
From: BrianFlynn <[email protected]>
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To: PublicComment; CityClerk; Thomas Gorham
Cc: Rebecca Davis; Madeline Dawson
Subject:\[ EXTERNAL\] PublicComment- PacificResort PlazaProject (DEV2019-00161)_Feb27 CityCouncil Meeting
Attachments: 2024.02.22SAFER Comment toAnaheim CityCouncil_Pacific ResortPlazaMND (DEV 2019-00161)_Feb27CCMeeting.pdf
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TotheAnaheimCityCouncil, CityClerkBass, andCityPlannerGorham, Pleasefindattachedacomment submitted onbehalfofSupportersAllianceForEnvironmental Responsibility (SAFER) regarding themitigatednegativedeclaration prepared forthePacificResortPlazaProject (DEV2019-00161) scheduled tobeheardattheCityCouncil'sFebruary27, 2024meeting.

Acknowledgment ofreceiptofthisemailandcommentwouldbegreatlyappreciated.

Thankyou,
BrianB. Flynn
Lozeau | DruryLLP
1939HarrisonStreet, Suite150
Oakland, California 94612
510) 836-4200
510) 836-4205 (fax)
[email protected]
1 VIA EMAIL
February 22, 2024
Ashleigh E. Aitken, Mayor
Norma Campos Kurtz, Mayor Pro Tem
Jose Diaz
Carlos A. Leon
Natalie Rubalcava
Stephen Faessel
Natalie Meeks
Anaheim City Council
200 South Anaheim Boulevard
Anaheim, California 92805
[email protected]
Theresa Bass, City Clerk
Office of the City Clerk
200 S. Anaheim Boulevard
2nd Floor, Room 217
Anaheim, CA 92805
cityclerk@anaheim. net
Thomas Gorham, City Planner
Planning and Building Department
City of Anaheim
200 South Anaheim Boulevard, Suite 162
Anaheim, CA 92805
tgorham@anaheim. net
Re: Comment on Mitigated Negative Declaration
Pacific Resort Plaza Development Project ( DEV 2019- 00161) Dear Mayor Aitken, Mayor Pro Tem Kurtz, and Honorable City Councilmembers:

This comment is submitted on behalf of Supporters Alliance for Environmental Responsibility (“SAFER”) regarding the mitigated negative declaration (“ MND”) prepared for the Pacific Resort Plaza Development Project ( DEV 2019- 00161) (“ Project”). The Project is scheduled to be heard at the City Council’ s February 27, 2024 meeting.

SAFER previously submitted a comment to the Planning Commission on November 29, 2023, which raised concerns that the MND was improper under the California Environmental Quality Act (“CEQA”) due to potentially significant impacts to human health and greenhouse gas emissions as well as inadequate analyses of the Project’ s impacts on air quality, hazardous materials, and energy use. SAFER’s November 29, 2023 comment to the Planning Commission is attached as Exhibit 1 and incorporated by reference herein.

The purpose of this comment is to address the MND’ s inadequate analysis of the Project’ s noise impacts. SAFER retained noise expert Silas Bensing of Wilson Ihrig to review the MND. Mr. Bensing found several deficiencies in the MND’ s noise analysis and concluded that the MND failed to identify multiple potentially significant impacts. Mr. Bensing’ s written comment and CV are attached hereto as Exhibit 2.

SAFER Comment
Pacific Resort Plaza Development Project
DEV 2019-00161
February 22, 2024

Page 2 ends

Due to the Project’ s potentially significant noise impacts identified by Mr. Bensing and the failure of the MND to support its noise conclusions with substantial evidence, as well as the additional reasons raised in SAFER’ s previous November 29, 2023 comment, SAFER respectfully requests that the City Council refrain from further consideration of this Project until an environmental impact report (“ EIR”) is prepared and circulated in accordance with CEQA.

PROJECT DESCRIPTION
The 1.57-acre Project site is located at 125 East Ball Road ( APN 234- 161- 04 and 234- 161-26) and is currently occupied by a vacant 10,530 sf two-story commercial building, auxiliary storage sheds, and surface parking/ vehicle storage space.

The Project proposes the demolition of the existing structures and the development of a hotel, fast food restaurant, and associated parking. The proposed hotel is a 120-room La Quinta Inn and Suites, with five stories ( 55 feet) and approximately 67,715 square feet. The stand- alone fast-food restaurant would consist of a single story (sixteen feet tall) and would include drive-thru service. Hotel parking will be provided in two four- story puzzle- lift enclosed parking structures three stories above ground and one story below ground) totaling 3,310 square feet with 72 spaces, seven standard spaces, eight EV spaces, four ADA accessible spaces. Restaurant parking will include seven standard spaces and one ADA accessible space.

Project construction would be divided into two phases with the fast-food restaurant building and site area being constructed during Phase One, and the hotel building and site area to be constructed during Phase Two. Phase One will also include the demolition of the existing commercial building.

Page 3 ends

of Sacramento ( 2004) 124 Cal.App.4th 903, 927.) The EIR is an “ environmental ‘ alarm bell’ whose purpose is to alert the public and its responsible officials to environmental changes before they have reached the ecological points of no return.” ( Bakersfield Citizens, supra, 124 Cal.App.4th at 1220.) The EIR also functions as a “ document of accountability,” intended to demonstrate to an apprehensive citizenry that the agency has, in fact, analyzed and considered the ecological implications of its action.” ( Laurel Heights Improvements Assn. v. Regents of Univ. of Cal. ( 1988) 47 Cal.3d 376, 392.) The EIR process “ protects not only the environment but also informed self-government.” ( Pocket Protectors v. City of Sacramento (2004) 124 Cal.App.4th 903, 927.)
An EIR is required if “there is substantial evidence, in light of the whole record before the lead agency, that the project may have a significant effect on the environment.” (PRC § 21080( d); see also Pocket Protectors, supra, 124 Cal.App.4th at 927.) An MND instead of an EIR is proper only if project revisions would avoid or mitigate the potentially significant effects identified in the initial study “ to a point where clearly no significant effect on the environment would occur, and . . . there is no substantial evidence in light of the whole record before the public agency that the project, as revised, may have a significant effect on the environment.” Mejia v. City of Los Angeles (2005) 130 Cal.App.4th 322, 331 [quoting PRC §§ 21064.5, 21080( c)(2)].) In that context, “ may” means a reasonable possibility of a significant effect on the environment. (PRC §§ 21082.2(a), 21100, 21151(a); Pocket Protectors, supra, 124 Cal.App.4th at 927; League for Protection of Oakland' s etc. Historic Res. v. City of Oakland ( 1997) 52 Cal.App.4th 896, 904-05.)
An EIR must be prepared rather than an MND “whenever it can be fairly argued on the basis of substantial evidence that the project may have a significant environmental impact.” ( No Oil, Inc. v City of Los Angeles (1974) 13 Cal.3d 68, 75.) Under this “fair argument” standard, an EIR is required if any substantial evidence in the record indicates that a project may have an adverse environmental effect—even if contrary evidence exists to support the agency’ s decision. 14 CCR § 15064( f)(1); Pocket Protectors, supra, 124 Cal.App.4th at 931; Stanislaus Audubon Society v. County of Stanislaus (1995) 33 Cal.App.4th 144, 150-51; Quail Botanical Gardens Found., Inc. v. City of Encinitas ( 1994) 29 Cal.App.4th 1597, 1602.) The “ fair argument” standard creates a “low threshold” favoring environmental review through an EIR rather than through issuance of negative declarations or notices of exemption from CEQA. ( Pocket Protectors, supra, 124 Cal.App.4th at 928.)
The “fair argument” standard is virtually the opposite of the typical deferential standard accorded to agencies. As a leading CEQA treatise explains:

This ‘ fair argument’ standard is very different from the standard normally followed by public agencies in making administrative determinations.

Ordinarily, public agencies weigh the evidence in the record before them and reach a decision based on a preponderance of the evidence. [Citations]. The fair argument standard, by contrast, prevents the lead agency from weighing SAFER Comment
Pacific Resort Plaza Development Project
DEV 2019-00161
February 22, 2024

Page 4 ends

competing evidence to determine who has a better argument concerning the likelihood or extent of a potential environmental impact. The lead agency’ s decision is thus largely legal rather than factual; it does not resolve conflicts in the evidence but determines only whether substantial evidence exists in the record to support the prescribed fair argument.

Kostka & Zishcke, Practice Under CEQA, § 6.29, pp. 273- 74.) The Courts have explained that it is a question of law, not fact, whether a fair argument exists, and the courts owe no deference to the lead agency’ s determination. Review is de novo, with a preference for resolving doubts in favor of environmental review.” (Pocket Protectors, supra, 124 Cal.App.4th at 928.)

DISCUSSION
I. The MND inadequately analyzes and mitigates the Project’s potentially significant noise impacts.

Noise expert Silas Bensing of the consulting firm Wilson Ihrig reviewed the MND’ s analysis of the Project’ s noise impacts. Mr. Bensing’ s comment letter and CV are attached as Exhibit 2. As discussed below, Mr. Bensing concludes that the MND failed to properly analyze and mitigate the Project’ s noise impacts and, as a result, the Project may cause significant impacts.

A. The MND fails to establish a proper baseline for noise impacts.

An adequate analysis of a project’ s impacts under CEQA begins with establishing a proper baseline against which the project’ s impacts can be compared. Here, the MND fails to establish a proper noise baseline and, as a result, the MND’ s analysis of noise impacts are not reliable. The MND’s baseline noise analysis was based on only four 20-minute measurements taken between 11 a.m. and 1 p.m. on a single day ( February 15, 2023). ( MND, p. 5-61; Appendix H pp. 2-9.) However, as noted by Mr. Bensing, “[ n]o data is presented for nighttime conditions when ambient noise levels are lower and residents would be more sensitive to noise increases, and the data does not document variation in noise level that typically occur throughout a day.” Ex. 2, p. 2.) The MND fails to explain how the measurements taken at “ only 1% of the time on one particular day during mid-day hours” are representative of the actual baseline noise conditions at and around the Project site. ( Id.)
Because the baseline noise measurements are not indicative of the actual noise conditions at the Project site, the MND’s comparison of the Project’s noise impacts to the MND’s faulty baseline measurements do not constitute substantial evidence of the Project’ s noise impacts. At the very least, the MND must be revised with an updated noise analysis utilizing a baseline that accurately reflects “ the existing baseline conditions at all relevant times.” ( Ex. 2, p. 2.) SAFER Comment
Pacific Resort Plaza Development Project
DEV 2019-00161
February 22, 2024

Page 5 ends

B. The MND fails to show that the Project’ s noise impacts will be less than significant.

As discussed below, Mr. Bensing found several inconsistencies in the MND’s noise analysis that undermine the MND’ s conclusion that noise impacts will be less than significant.

1. The MND fails to account for the noise impacts of all construction equipment.

To calculate the noise impacts of construction equipment for the Project, the MND relies on estimated noise levels for the “ minimum required equipment present at site” provided by the U.S. EPA. (See Appendix H, p. 10.) However, the EPA actually provides two separate noise estimate categories: ( 1) “ minimum required equipment present at site” ( as utilized in the MND) and (2) “all pertinent equipment present at site” ( which are 10-14 dBA higher that the “minimum required” values. ( Ex. 2, pp. 2-3.)
The MND provides no justification for why the “ minimum required” values were used rather than the “ all pertinent equipment” values. (Ex. 2, pp. 2-3.) If the City wants to rely on the analysis provided in the MND, then mitigation measures must be imposed that ensure that the Project will use on the “ minimum required” equipment. Without such a mitigation measure, the MND conclusion that the Project’ s noise impacts will be less than significant is not supported by substantial evidence in violation of CEQA.

2. There is a fair argument that construction of the Project will result in significant noise impacts.

In order to conclude that the Project’ s noise impacts will be less than significant, the MND compares the Project’ s noise levels to the absolute noise threshold (80 dBA Leq over an 8- hour period) established by the Federal Transit Administration (“ FTA”). ( MND at p. 5-67.) However, as noted by Mr. Bensing, “[ e]valuating the noise over an 8-hour period is not appropriate for an MND, since noise levels would be higher for shorter intervals, and this shorter-duration increase in ambient noise levels may be substantial and potentially significant.” Ex. 2, p. 4.)
Using the information from the MND, Mr. Bensing calculated the increase over existing ambient noise at the two distances from the nearest noise sensitive property boundary (80 feet away and 265 feet away). ( Ex. 2, p. 4.) Mr. Bensing’ s calculations are presented in the table below:

SAFER Comment
Pacific Resort Plaza Development Project
DEV 2019-00161
February 22, 2024

Page 6 ends

The increased-over-existing noise levels shown in the table above are significant impacts that have not been mitigated in the MND. For ground clearing/ demolition, the 22 dBA increase over ambient will be perceived as more than 4x louder than existing noise levels. (Id.) The 16-17 dBA increase for excavation and foundation construction will be perceived as 3x louder than existing noise levels. (Id.) As Mr. Bensing concludes, “[ t]his is a substantial increase that would cause adverse community reaction and would be significant. ( Id.) Because Mr. Bensing’ s calculations above establish a fair argument that the Project may result in significant noise impacts, the City cannot rely on MND and must prepare an EIR for the Project.

3. The MND’ s discussion of noise impacts is inconsistent with the information provided in the MND’s technical noise study.

In Table 18 of the MND, the noise levels for the north residential receptor located 80 feet away are listed as 75, 70, 69, 66, and 66 (dBA Leq) for the five phases of construction. ( MND, p. 5-67.) However, in the MND’s technical noise appendix, the noise levels for the north residential receptor located 80 feet away are reported as 80, 75, 74, 71, 71. It is likely that the appendix’ s technical calculations are the correct calculations and, as a result, the MND has underestimated the Project’ s noise impacts. For example, the 22 dBA increase discussed above in section I.B.2 would increase to 27 dBA, which is 6.5x louder than existing noise levels, indicating an even greater potentially significant impact requiring the preparation of an EIR.

C. The MND’ s analysis of the Project’ s HVAC- related noise is inadequate.

The MND claims that the Project’ s mechanical HVAC equipment will be located at least 300 feet from the nearest neighboring residential uses. (MND, p. 5-63.) However, some of the Project’ s hotel rooms will be only 80-100 feet from the nearest residences and, as Mr. Bensing explains, “that would be an unusually far distance to pipe conditioned air. (Ex. 2, p. 5.) SAFER Comment
Pacific Resort Plaza Development Project
DEV 2019-00161
February 22, 2024

Page 7 ends

Furthermore, the MND states that “ HVAC units would ductless individual units that each serve 4 rooms.” ( MND, p. 5-63.) Therefore, as Mr. Bensing concludes, “ it seems implausible that the HVAC equipment will be 250 feet from the nearest residences.” ( Ex. 2, p. 5.) Although the MND claims that the units would result in 60 dBA at 20 feet, the MND does not appear to have considered the noise impacts of multiple units operating at once, which will surely happen on hot nights. (Ex. 2, p. 5.) As a result, the MND’s conclusion that noise impacts will be less than significant cannot be relied upon.

Similar to the construction noise impacts discussed above in Section I.B.2, the MND only discussed the absolute noise level generated by the HVAC units but failed to assess whether HVAC noise would result in a substantial increase over existing noise levels. ( Ex. 2, p. 5.) According to the MND, the existing mid-day noise level at the northern property line was 45 dBA. ( MND, p. 5-61.) Although the MND failed to take any measurements of ambient nighttime noise levels, nighttime noise levels are typically lower than mid-day, meaning that operational noise from the HVAC units would be more noticeable to nearby residents during the night. ( Ex. 2, p 5.) Even assuming that nighttime and mid-day ambient noise levels were the same (45 dBA), the HVAC’ s 60 dBA noise levels represent a 15 dBA increase, which would be perceived as more than 2x as loud as the baseline noise levels. (Id.) As Mr. Bensing concluded, “[ t]his is a substantial increase that would cause adverse community reaction and would be significant.” Id.) Therefore, the noise impacts of the Project’ s HVAC units must be properly analyzed and mitigated in an EIR prior to approval of this Project.

CONCLUSION
As discussed in SAFER’ s November 29, 2023 comment letter to the Planning Commission, SAFER’ s experts established a fair argument that the Project may have significant impacts related to emissions of diesel particulate matter and greenhouse gases. Furthermore, the MND failed to provide substantial evidence to support its conclusions regarding the Project’ s impacts to air quality, hazards, and energy.

As discussed in this comment letter, the MND failed to adequately analyze and mitigate the Project’ s noise impacts and, as a result, there is a fair argument that the Project’s construction- and HVAC- related noise impacts will be significant.

For those reasons, SAFER respectfully requests that the City Council refrain from taking any action on this Project at this time and instead direct Planning staff to prepare an EIR prior to further consideration of the Project.

Sincerely,
Brian B. Flynn
Lozeau Drury LLP
EXHIBIT 1

VIA EMAIL
November 29, 2023
Lucille Kring, Chairperson
Grant Henninger, Vice Chairperson
Jeanne Tran-Martin
Michelle Lieberman
LuisAndres Perez
Christopher Walker
Amelia Castro
Anaheim Planning Commission
200 South Anaheim Boulevard
Anaheim, California 92805
[email protected]
Thomas Gorham, City Planner
Planning and Building Department
City of Anaheim
200 South Anaheim Boulevard, Suite 162
Anaheim, CA 92805
tgorham@anaheim. net
Re: Comment on Mitigated Negative Declaration
Pacific Resort Plaza Development Project (DEV 2019-00161) Dear City of Anaheim Planning Commission:

This comment is submitted on behalf of Supporters Alliance for Environmental Responsibility (“ SAFER”) regarding the mitigated negative declaration (“ MND”) prepared for the Pacific Resort Plaza Development Project (DEV 2019-00161) (“ Project”). The Project is tentatively scheduled to be heard at the Planning Commission’ s December 4, 2023 meeting.

SAFER’ s review of the MND was assisted by air quality experts Matt Hagemann, P.G., C.Hg., and Paul E. Rosenfeld, Ph.D., of the Soil/Water/Air Protection Enterprise (“ SWAPE”).

SWAPE’ s written comment and CVs are attached hereto as Exhibit A.

As discussed below, there is a 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 MND’ s conclusions are not supported by substantial evidence. SAFER respectfully requests that the City prepare an environmental impact report (“ EIR”) in order to comply with the California Environmental Quality Act (“ CEQA”) prior to approval of the Project.

PROJECT DESCRIPTION
The 1.57-acre Project site is located at 125 East Ball Road (APN 234-161-04 and 234- SAFER Comment
Pacific Resort Plaza Development Project
DEV 2019- 00161
November 29, 2023

Page 2 ends

161-26) and is currently occupied by a vacant 10,530 sf two-story commercial building, auxiliary storage sheds, and surface parking/ vehicle storage space.

The Project proposes the demolition of the existing structures and the development of a hotel, fast food restaurant, and associated parking. The proposed hotel is a 120-room La Quinta Inn and Suites, with five stories ( 55 feet) and approximately 67,715 square feet. The stand- alone fast -food restaurant would consist of a single story (sixteen feet tall) and would include drivethru service. Hotel parking will be provided in two four- story puzzle- lift enclosed parking structures (three stories above ground and one story below ground) totaling 3,310 square feet with 72 spaces, seven standard spaces, eight EV spaces, four ADA accessible spaces. Restaurant parking will include seven standard spaces and one ADA accessible space.

Project construction would be divided into two phases with the fast- food restaurant building and site area being constructed during Phase One, and the hotel building and site area to be constructed during Phase Two. Phase One will also include the demolition of the existing commercial building.

LEGAL STANDARD FOR NEGATIVE DECLARATIONS
As the California Supreme Court held, “[ i]f no EIR has been prepared for a nonexempt project, but substantial evidence in the record supports a fair argument that the project may result in significant adverse impacts, the proper remedy is to order preparation of an EIR.” Communities for a Better Env’ t v. South Coast Air Quality Mgmt. Dist. ( 2010) 48 Cal.4th 310, 319-20.) “Significant environmental effect” is defined very broadly as “ a substantial or potentially substantial adverse change in the environment.” ( Pub. Res. Code [“ PRC”] § 21068; see also 14 CCR § 15382.) An effect on the environment need not be “ momentous” to meet the CEQA test for significance; it is enough that the impacts are “ not trivial.” ( No Oil, Inc. v. City of Los Angeles (1974) 13 Cal.3d 68, 83.) “ The ‘foremost principle’ in interpreting CEQA is that the Legislature intended the act to be read so as to afford the fullest possible protection to the environment within the reasonable scope of the statutory language.” ( Communities for a Better Env’ t v. Cal. Res. Agency ( 2002) 103 Cal.App.4th 98, 109.) The EIR is the very heart of CEQA. ( Bakersfield Citizens for Local Control v. City of Bakersfield (2004) 124 Cal.App.4th 1184, 1214 (Bakersfield Citizens); Pocket Protectors v. City of Sacramento ( 2004) 124 Cal.App.4th 903, 927.) The EIR is an “ environmental ‘ alarm bell’ whose purpose is to alert the public and its responsible officials to environmental changes before they have reached the ecological points of no return.” ( Bakersfield Citizens, supra, 124 Cal.App.4th at 1220.) The EIR also functions as a “ document of accountability,” intended to demonstrate to an apprehensive citizenry that the agency has, in fact, analyzed and considered the ecological implications of its action.” ( Laurel Heights Improvements Assn. v. Regents of Univ. of Cal. ( 1988) 47 Cal.3d 376, 392.) The EIR process “ protects not only the environment but also informed self-government.” ( Pocket Protectors v. City of Sacramento (2004) 124 Cal.App.4th 903, 927.)
SAFER Comment
Pacific Resort Plaza Development Project
DEV 2019- 00161
November 29, 2023

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An EIR is required if “there is substantial evidence, in light of the whole record before the lead agency, that the project may have a significant effect on the environment.” ( PRC § 21080( d); see also Pocket Protectors, supra, 124 Cal.App.4th at 927.) An MND instead of an EIR is proper only if project revisions would avoid or mitigate the potentially significant effects identified in the initial study “ to a point where clearly no significant effect on the environment would occur, and . . . there is no substantial evidence in light of the whole record before the public agency that the project, as revised, may have a significant effect on the environment.” Mejia v. City of Los Angeles (2005) 130 Cal.App.4th 322, 331 [quoting PRC §§ 21064.5, 21080( c)( 2)].) In that context, “ may” means a reasonable possibility of a significant effect on the environment. (PRC §§ 21082.2(a), 21100, 21151(a); Pocket Protectors, supra, 124 Cal.App.4th at 927; League for Protection of Oakland's etc. Historic Res. v. City of Oakland (1997) 52 Cal.App.4th 896, 904- 05.)
An EIR must be prepared rather than an MND “ whenever it can be fairly argued on the basis of substantial evidence that the project may have a significant environmental impact.” ( No Oil, Inc. v City of Los Angeles ( 1974) 13 Cal.3d 68, 75.) Under this “ fair argument” standard, an EIR is required if any substantial evidence in the record indicates that a project may have an adverse environmental effect— even if contrary evidence exists to support the agency’ s decision. 14 CCR § 15064(f)(1); Pocket Protectors, supra, 124 Cal.App.4th at 931; Stanislaus Audubon Society v. County of Stanislaus ( 1995) 33 Cal.App.4th 144, 150- 51; Quail Botanical Gardens Found., Inc. v. City of Encinitas (1994) 29 Cal.App.4th 1597, 1602.) The “fair argument” standard creates a “ low threshold” favoring environmental review through an EIR rather than through issuance of negative declarations or notices of exemption from CEQA. (Pocket Protectors, supra, 124 Cal.App.4th at 928.)
The “ fair argument” standard is virtually the opposite of the typical deferential standard accorded to agencies. As a leading CEQA treatise explains:

This ‘ fair argument’ standard is very different from the standard normally followed by public agencies in making administrative determinations.

Ordinarily, public agencies weigh the evidence in the record before them and reach a decision based on a preponderance of the evidence. [ Citations]. The fair argument standard, by contrast, prevents the lead agency from weighing competing evidence to determine who has a better argument concerning the likelihood or extent of a potential environmental impact. The lead agency’ s decision is thus largely legal rather than factual; it does not resolve conflicts in the evidence but determines only whether substantial evidence exists in the record to support the prescribed fair argument.

Kostka & Zishcke, Practice Under CEQA, § 6.29, pp. 273- 74.) The Courts have explained that it is a question of law, not fact, whether a fair argument exists, and the courts owe no deference to the lead agency’ s determination. Review is de novo, with a preference for resolving doubts in SAFER Comment
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favor of environmental review.” (Pocket Protectors, supra, 124 Cal.App.4th at 928.)

DISCUSSION
I. An EIR is Required Due to a Fair Argument that the Project May Result in Significant Health Impacts from Emissions of Diesel Particulate Matter.

Matt Hagemann, P.G., C.Hg., and Dr. Paul E. Rosenfeld, Ph.D., from SWAPE reviewed the Project’s impacts to human health due to emissions of diesel particulate matter (“ DPM”).

SWAPE concluded that the MND failed to identify a significant impact from emissions of DPM.

Due to this fair argument that the Project may result in significant health impacts, CEQA requires the preparation of an EIR, rather than an MND, prior to approval of the Project.

A. The MND failed to adequately analyze the Project’s health impacts from emissions of diesel particulate matter.

The MND’ s analysis of the cancer risk posed by emissions of DPM was inadequate.

Although the MND compared the Project’s emissions to the SCAQMD localized significance thresholds (“ LSTs”) established by the South Coast Air Quality Management District SCAQMD”), the MND does not include a quantified health risk assessment (“ HRA”) to measure the increased cancer risk to nearby sensitive receptors from construction and operation of the Project.

As noted by SWAPE, CEQA requires that that the MND “correlate Project-generated emissions with potential adverse impacts on human health.” ( Ex. A, p. 10.) However, such an analysis is not possible without a quantified HRA. Furthermore, the failure of the MND to provide a quantified HRA is inconsistent with the most recent guidance of the Office of Environmental Health Hazard Assessment (“ OEHHA”). (Ex. A, p. 10-11.) OEHHA recommends that exposure from projects lasting more than 6 months be evaluated for the duration of the project and recommends that an exposure duration of 30 years be used to estimate individual cancer risk for the maximally exposed individual resident (“ MEIR”). ( Ex. A, p. 10.) Due to the Project’ s 15-month construction schedule and its operation for the foreseeable future, a quantified HRA for construction and operation of the Project is necessary to ensure that the Project’ s health risks are disclosed and compared to the applicable SCAQMD significance threshold for increased cancer risk.

B. The Project will result in significant increased cancer risks from emissions of diesel particulate matter.

SWAPE prepared a screening-level HRA to evaluate potential impacts to human health from DPM during construction and operation of the Project using AERSCREEN, the leading screening-level air quality dispersion model. (Ex. A, pp. 11-15.) According to the MND’s air quality modeling data, construction of the Project would result in 115.5 pounds of DPM SAFER Comment
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emissions and operation of the Project would result in an additional 40 pounds of DPM emissions per year. ( Ex. A, pp. 11-12.) Using those values, SWAPE conducted their HRA to calculate the increased cancer risk resulting from those DPM emissions to the Maximally Exposed Individual Receptor (“ MEIR”) located approximately 50 meters downwind of the Project site. (Ex. A, p. 12.) The HRA also utilized age sensitivity factors in order to account for the increased sensitivity to carcinogens during early- in-life exposure and to assess the risk for susceptible subpopulations such as children. (Ex. A, p. 13.) SWAPE’ s HRA found that increased cancer risk to infants and children during construction and operation of the Project would be 120.0 in one million and 80.4 in one million, respectively. (Ex. A, pp. 14-15.) Additionally, the increased cancer risk for a 30-year residential lifetime would be 217 in one million. (Id.) Each of the above increased cancer risks exceed SCAQMD’ s CEQA significance threshold of 10 in one million and, thus, establishes a fair argument that the Project may result in significant, unmitigated impacts. (Ex. A, p. 15.) Due to this fair argument, CEQA requires that the City prepare an EIR, rather than an MND, prior to approval of the Project.

II. An EIR is Required Due to a Fair Argument that the Project May Result in Significant Greenhouse Gas Emissions.

According to the MND’ s analysis of the Project greenhouse gas (“ GHG”) emissions, the Project will generate 1,909 metric tons of carbon dioxide equivalents per year (“ MT CO2e/year”) MND, p. 5-51 [ Table 13].) The MND then claims that these GHG emissions are less than significant because they do not exceed the 3,000 MT CO2e/year significance threshold allegedly adopted by SCAQMD. ( Id.) As an initial matter, the MND likely underestimates the Project’ s GHG emissions (see ante Section III) and cannot be relied upon as an accurate estimate of the Project’ s GHG emissions. But even more importantly, the 3,000 MT CO2e/ year significance threshold utilized in the MND is woefully outdated and, using a more up-to-date threshold, the Project is likely to result in significant impacts.

The 3,000 MT CO2e/ year significance threshold was adopted in 2008 as an interim threshold in response to the Global Warming Solutions Act of 2006 (commonly known as “ AB 32”), which required requires California to reduce GHG emissions to 1990 levels by 2020. ( Ex.

A, p. 17.) Now that 2020 has come and gone, the 3,000 MT CO2e/year significance threshold “is outdated and inapplicable to the proposed Project.” ( Id.) Instead, the SCAQMD threshold to reduce GHG emissions by a target date of 2035 should be employed, which is an efficiency threshold based on service population of 3.0 MT CO2e/ year, where “ service population” is the sum of the number of residents and the number of jobs supported by the Project. (Id.) In other words, the Project’ s annual GHG emissions must be divided by the service population and then compared to the 3.0 MT CO2e/year threshold.

Here, the service population of the Project is the 26 jobs that the Project will provide (as a hotel, the Project does not have any residents). (MND, p. 5-70.) Dividing the Project’ s 1,909 MT SAFER Comment
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CO2e/year of GHG emissions by the service population of 26 results in 73.4 MT CO2e/year, well in excess of the 3.0 MT CO2e/ year threshold. This exceedance of SCAQMD’ s threshold establishes a fair argument that the Project may result in significant GHG emission and, as a result, an EIR is required.

III. The MND’ s Air Quality Analysis Is Not Supported by Substantial Evidence.

SWAPE found that the MND underestimated the Project’ s emissions and therefore cannot be relied upon to determine the significance of the Project’ s air quality impacts. (Ex. A, pp. 4-9.) To estimate the Project’ s emissions, the MND utilized the California Emissions Estimator Model version 2022.1 (“CalEEMod”). (Ex. A, p. 3.) CalEEMod relies on recommended default values based on site specific information related to a number of factors Ex. A, p. 2.) CEQA requires that any changes to the default values must be justified by substantial evidence. (Id.)
Typically, CalEEMod provides output files that provide the quantitative changes that were made to model’ s default values. ( Ex. A, p. 3.) However, the CalEEMod version utilized in the MND is a “ soft release” and does not provide complete output files indicating the quantitative changes that were made to the default values. ( Id.) Instead, the MND only provides a qualitative description of the changed default values, thereby hindering public review and comment. At the very least, an updated analysis should be prepared that provides all relevant output files. (Ex. A, pp. 3-4.)
Notwithstanding the above, SWAPE reviewed the Project’ s CalEEMod output files and found that the values input into the model were inconsistent with information provided in the MND, resulting in an underestimation of the Project’ s emissions. (Ex. A, p. 4.) As a result, the MND lacks substantial evidence to conclude that impacts will be less than significant. ( Id.) Specifically, SWAPE found that the following values used in the MND’ s air quality analysis were either inconsistent with information provided in the MND or otherwise unjustified:

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.) As a result of these errors, the MND underestimates the Project’ s construction and operational emissions and cannot be relied upon to determine the significance of the Project’ s air quality impacts.

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IV. The MND’s Hazards Analysis Is Not Supported by Substantial Evidence.

The MND claims that the Project’ s impacts related to hazards and hazardous materials would be less than significant based solely upon review of regulatory databases and an online review of the Cortese list. (MND, p. 5-52.) The MND never mentions the fact that the previous use of the Project site was a motorsports dealership ( Hahm Motorsports), which sold motorcycles, jet skis, ATVs, and generators.1 This past use of the Project site “ may have resulted in the release of hazardous materials, including fuel and lubricants.” ( Ex. A, p. 1.) In order to accurately assess the Project’ s hazards, the MND should have contained a Phase I Environmental Site Assessment (“ ESA”). (Ex. A, pp.1-2.) As SWAPE explains, The preparation of a Phase I ESA is often undertaken in CEQA 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.

Id.) A Phase I ESA would assist the City in identifying any “recognized environmental conditions” (“ RECs”), which are “ 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.” Ex. A, p. 2.) If any RECs are identified, a Phase II ESA would follow, 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.” ( Id.) Without preparing a Phase I ESA, the City lacks substantial evidence to conclude that the Project’ s impacts would be less than significant. At the very least, the MND should be revised to include a Phase I ESA prior to approval of the Project.

V. The MND inadequately analyzes the Project’ s energy impacts.

CEQA provides that all Projects must include measures “ to reduce the wasteful, inefficient, and unnecessary consumption of energy.” ( Pub. Res. Code § 21100(b)(3).) Energy conservation under CEQA is defined as the “ wise and efficient use of energy.” ( CEQA Guidelines, app. F, § I.) The “ wise and efficient use of energy” is achieved by “(1) decreasing overall per capita energy consumption, ( 2) decreasing reliance on fossil fuels such as coal, 1 Google Maps Street View of Project site, https://www.google.com/maps/@33.8181752,- 117.9070051,3a,75y,2.37h,90t/data=! 3m6!1e1!3m4!1sxeKJKqS_NTqWrKDTg7uSRw!2e0!7i16 384!8i8192?entry=ttu
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natural gas and oil, and (3) increasing reliance on renewable energy resources.” ( Id.) Mere compliance with the California Building Energy Efficiency Standards (Cal. Code Regs., tit. 24, part 6) (“ Title 24”) does not constitute an adequate analysis of energy. ( League to Save Lake Tahoe Mountain Area Preservation Foundation v. County of Placer (2022) 75 Cal.App.5th 63, 165 ( League to Save Lake Tahoe); Ukiah Citizens for Safety First v. City of Ukiah (2016) 248 Cal. App. 4th 256, 264-65; California Clean Energy Committee v. City of Woodland ( 2014) 225 Cal.App.4th 173, 209- 13.) Even where an agency has concluded that a project’ s impacts on energy resources would be less than significant, a lead agency must still analyze implementation of all “ renewable energy options that might have been available or appropriate for [a] project.” ( League to Save Lake Tahoe, supra, 75 Cal.App.5th at 166-67.) A lead agency’ s failure to consider implementation of all feasible renewable energy proposals raised during the environmental review process constitutes a “ prejudicial error.” ( Id. at 168.) Despite CEQA’ s requirement to consider all renewable energy options, the MND’ s analysis of alternative energy merely relies on compliance with Title 24. (MND, pp. 5-32 to 5-

33.) Because mere compliance with Title 24 is insufficient to determine that energy impacts are less than significant, the MND’s energy analysis is inadequate and its conclusion that the Project’ s energy impacts will be less than significant is unsupported.

The MND also claims that the Project will “ develop alternative energy ( solar PV) [ and] provide EV parking and charging infrastructure.” ( MND, p. 5-34.) However, there is no indication of how much solar PV or EV parking will be provided by the Project or whether it is feasible to provide more of either. Furthermore, there is no indication that solar PV or EV parking will actually be required for the Project. Without more information about the solar PV or EV parking (and without an express requirement for both in the Project’s conditions of approval, the City lacks substantial evidence to conclude that the Project’ s energy impacts will be less than significant. The Project’ s energy analysis should be updated to consider the implementation of all feasible renewable energy features in accordance with CEQA.

CONCLUSION
SAFER’ s experts have established a fair argument that the Project may have significant impacts related to emissions of DPM and GHGs. Furthermore, the MND fails to provide substantial evidence to support its conclusions regarding the Project’ s impacts to air quality, hazards, and energy. For those reasons, SAFER respectfully requests that the City not rely on the MND but instead prepare and circulate an EIR prior to further consideration of the Project.

Sincerely,
Brian B. Flynn
Lozeau Drury LLP

EXHIBIT A
2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
949) 887-9013
mhagemann@swape. com
Paul E. Rosenfeld, PhD
310) 795-2335
prosenfeld@swape. com
November 22, 2023
Brian Flynn
Lozeau | Drury LLP
1939 Harrison Street, Suite 150
Oakland, CA 94618
Subject: Comments 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:

A review of all known sites in the vicinity of the subject property that are on regulatory agency databases undergoing assessment or cleanup activities;
An inspection;
Interviews with people knowledgeable about the property; and 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 Levels 2, should be further evaluated and cleaned up, if necessary, in coordination with DTSC.

Air Quality Failure toProvide CompleteCalEEModOutputFiles 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 toEstimate 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 eighthours 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 offroad 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/ defaultsource/ 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/ defaultsource/ 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/ defaultsource/ 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-LevelAnalysisDemonstratesPotentiallySignificant 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/ airquality- 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:
115. 5463 453. 6
1 24
13,600 Using this equation, we estimated aconstruction emission rate of0.00131 grams per second (“g/s”). Subtracting the463-day construction period from the total residential duration of 30 years, weassumed that after Project construction, the sensitive receptor would be exposed tothe Project’s operational DPM foran additional 28.73years. The AQ & GHG Report’s operational CalEEMod emissions indicate that operational activities will generate approximately 40pounds ofDPM per year throughout operation. Applying the same equation used to estimate the construction DPM rate, we
estimated the following emission rate for Project operation: 40 365 453.6 124 1 3,600
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- by55-meters. Arelease height ofthree meters was selected torepresent the height of stacks of operational equipment and other heavy-duty vehicles, and an initial vertical dimension ofone and ahalf meters was used to simulate instantaneous plume dispersion upon release. Anurban 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 ofanair pollutant be estimated by multiplying the single-hour concentration by10% in screening procedures. 29 According to the IS/MND, the nearest sensitive receptors are multi- family residences 110feet, or33.5meters, to thenorth ofthe 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 singlehour concentration estimated by AERSCREEN for Project construction istherefore approximately 5.057 µg/ m3 DPM at approximately 50 meters downwind. Multiplying this single-hour concentration by 10%, we get an annualized average concentration of0.5057µg/m3 for Project construction at the MEIR. For Project operation, the single- hour concentration estimated by AERSCREEN is2.221 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 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
Factor 33
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-supplementalguidelines. 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/ riskassessment/ 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/ defaultsource/ 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 where: DoseAIR = dose by inhalation (mg/
kg/ day), per agegroup Cair = concentration of
contaminant inair (g/m3) EF = exposure frequency (
number of days/365days) BR/BW = daily breathing rate normalized to body weight (L/kg/day) A =
inhalation absorption factor (default = 1) CF = conversion factor ( 1x10- 6, g tomg, Ltom3) To calculate the overall cancer risk, we used thefollowing equation for each appropriate age
group:
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 oftime 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 the463- 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 theinfantile (0 – 2) stage of life. The annualized average concentration for operation was used for the remainder of the 30-year exposure period, which makes upthe latter

0.98 years ofthe infantile stage of life, the entire child stage of life ( 2 – 16), as well the entire adult ( 16 – 30 years) stage oflife. The results of
our calculations areshown 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 -
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 screeninglevel 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 toAdequately 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 analysis 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 indicates a potentially significant impact. 1) Incorrect and Unsubstantiated Quantitative 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)-ceqasignificance- 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/ wpcontent/ 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/ fileattachments/ 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 heavyduty 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 total 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 total 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, maintained, and serviced as recommended by the emission control technology manufacturer.

Diesel vehicles, construction equipment, and generators 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 address, plus contact person responsible for the vehicles or equipment.
ii. Equipment type, equipment manufacturer, equipment 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 that, for each on road diesel vehicle, nonroad construction equipment, or generator onsite, includes:
i. Hour-meter readings on arrival on-site, the first 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 ridematching 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 reduction 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.
h Z Ž
Z^ Z E K
D s
W ZŽ s
Annual Emissions ( tons/ year) 0.03 Total DPM (lbs) 115.5342466 Annual Emissions ( tons/ year) 0.02 Daily Emissions ( lbs/ day) 0.164383562 Total DPM (g) 52406.33425 Daily Emissions ( lbs/ day) 0.109589041 Construction Duration ( days) 92 Emission Rate (g/ s) 0.001310054 Total DPM (lbs) 40 Total DPM (lbs) 15.12328767 Release Height (meters) 3 Emission Rate (g/ s) 0.000575342 Total DPM (g) 6859.923288 Total Acreage 1.47 Release Height (meters) 3 Start Date 10/ 1/2023 Max Horizontal ( meters) 109.08 Total Acreage 1.47 End Date 1/ 1/2024 Min Horizontal ( meters) 54.54 Max Horizontal ( meters) 109.08 Construction Days 92 Initial Vertical Dimension ( meters) 1.5 Min Horizontal ( meters) 54.54 Setting Urban Initial Vertical Dimension ( meters) 1.5
Annual Emissions ( tons/ year) 0.05 Population 345,940 Setting Urban Daily Emissions ( lbs/ day) 0.273972603 Start Date 10/ 1/2023 Population 345,940 Construction Duration ( days) 366 End Date 1/ 6/ 2025
Total DPM (lbs) 100.2739726 Total Construction Days 463 Total DPM (g) 45484.27397 Total Years of Construction 1.27 Start Date 1/ 1/2024 Total Years of Operation 28.73
End Date 1/ 1/2025
Construction Days 366
Annual Emissions ( tons/ year) 0.005
Daily Emissions ( lbs/ day) 0.02739726
Construction Duration (days) 5
Total DPM (lbs) 0.136986301
Total DPM (g) 62.1369863
Start Date 1/ 1/2025
End Date 1/ 6/2025
Construction Days 5
2025
2024
Construction Operation
2023 Total Emission Rate
Attachment A
AERSCREEN 21112 AERMOD 21112 11/ 15/ 23
10: 56: 32
TITLE: Pacific Resort Plaza, Construction

AREA PARAMETERS
SOURCE EMISSION RATE: 0. 131E 02 g/ s 0. 104E 01 lb/hr
AREA EMISSION RATE: 0. 220E 06 g/( s m2) 0. 175E 05 lb/( hr m2) AREA HEIGHT: 3. 00 meters 9. 84 feet
AREA SOURCE LONG SIDE: 109. 08 meters 357. 87 feet
AREA SOURCE SHORT SIDE: 54. 54 meters 178. 94 feet
INITIAL VERTICAL DIMENSION: 1. 50 meters 4. 92 feet
RURAL OR URBAN: URBAN
POPULATION: 345940
INITIAL PROBE DISTANCE 5000. meters 16404. feet

BUILDING DOWNWASH PARAMETERS

BUILDING DOWNWASH NOT USED FOR NON POINT SOURCES

FLOW SECTOR ANALYSIS
25 meter receptor spacing: 1. meters 5000. meters

MAXIMUM IMPACT RECEPTOR
Zo SURFACE 1 HR CONC RADIAL DIST TEMPORAL
SECTOR ROUGHNESS ug/ m3) deg) m) PERIOD
1* 1. 000 5. 057 0 50. 0 WIN
worst case diagonal
Attachment B

MAKEMET METEOROLOGY PARAMETERS
MIN/ MAX TEMPERATURE: 250. 0 310. 0 K)
MINIMUM WIND SPEED: 0. 5 m/ s
ANEMOMETER HEIGHT: 10. 000 meters
SURFACE CHARACTERISTICS INPUT: AERMET SEASONAL TABLES
DOMINANT SURFACE PROFILE: Urban
DOMINANT CLIMATE TYPE: Average Moisture
DOMINANT SEASON: Winter
ALBEDO: 0. 35
BOWEN RATIO: 1. 50
ROUGHNESS LENGTH: 1. 000 meters)
SURFACE FRICTION VELOCITY U*) NOT ADUSTED

METEOROLOGY CONDITIONS USED TO PREDICT OVERALL MAXIMUM IMPACT

YR MO DY JDY HR
10 01 10 10 01
H0 U* W* DT/ DZ ZICNV ZIMCH M O LEN Z0 BOWEN ALBEDO REF WS

1. 30 0. 043 9. 000 0. 020 999. 21. 6. 0 1. 000 1. 50 0. 35 0. 50

HT REF TA HT

10. 0 310. 0 2. 0
AERSCREEN 21112 AERMOD 21112 11/ 15/ 23
10: 59: 02
TITLE: Pacific Resort Plaza, Operations

AREA PARAMETERS
SOURCE EMISSION RATE: 0. 575E 03 g/ s 0. 457E 02 lb/hr
AREA EMISSION RATE: 0. 967E 07 g/( s m2) 0. 768E 06 lb/( hr m2) AREA HEIGHT: 3. 00 meters 9. 84 feet
AREA SOURCE LONG SIDE: 109. 08 meters 357. 87 feet
AREA SOURCE SHORT SIDE: 54. 54 meters 178. 94 feet
INITIAL VERTICAL DIMENSION: 1. 50 meters 4. 92 feet
RURAL OR URBAN: URBAN
POPULATION: 345940
INITIAL PROBE DISTANCE 5000. meters 16404. feet

BUILDING DOWNWASH PARAMETERS

BUILDING DOWNWASH NOT USED FOR NON POINT SOURCES

FLOW SECTOR ANALYSIS
25 meter receptor spacing: 1. meters 5000. meters

MAXIMUM IMPACT RECEPTOR
Zo SURFACE 1 HR CONC RADIAL DIST TEMPORAL
SECTOR ROUGHNESS ug/ m3) deg) m) PERIOD
1* 1. 000 2. 221 0 50. 0 WIN
worst case diagonal

METEOROLOGY CONDITIONS USED TO PREDICT OVERALL MAXIMUM IMPACT

YR MO DY JDY HR
10 01 10 10 01
H0 U* W* DT/ DZ ZICNV ZIMCH M O LEN Z0 BOWEN ALBEDO REF WS

1. 30 0. 043 9. 000 0. 020 999. 21. 6. 0 1. 000 1. 50 0. 35 0. 50

HT REF TA HT

10. 0 310. 0 2. 0

AERSCREEN AUTOMATED DISTANCES

OVERALL MAXIMUM CONCENTRATIONS BY DISTANCE

MAXIMUM MAXIMUM
DIST 1 HR CONC DIST 1 HR CONC
m) ug/ m3) m) ug/ m3)

1. 00 1. 711 2525. 00 0. 1073E 01

25. 00 2. 010 2550. 00 0. 1059E 01

50. 00 2. 221 2575. 00 0. 1045E 01

75. 00 1. 484 2600. 00 0. 1031E 01
100. 00 0. 9430 2625. 00 0. 1018E 01
125. 00 0. 6811 2650. 00 0. 1005E 01
150. 00 0. 5250 2675. 00 0. 9919E 02
175. 00 0. 4219 2700. 00 0. 9793E 02
200. 00 0. 3497 2725. 00 0. 9670E 02
225. 00 0. 2965 2750. 00 0. 9550E 02
250. 00 0. 2561 2775. 00 0. 9433E 02
275. 00 0. 2245 2800. 00 0. 9318E 02
300. 00 0. 1990 2825. 00 0. 9205E 02
325. 00 0. 1781 2850. 00 0. 9094E 02
350. 00 0. 1609 2875. 00 0. 8986E 02
375. 00 0. 1462 2900. 00 0. 8881E 02
400. 00 0. 1338 2925. 00 0. 8777E 02
425. 00 0. 1230 2950. 00 0. 8675E 02
450. 00 0. 1138 2975. 00 0. 8575E 02
475. 00 0. 1056 3000. 00 0. 8478E 02
500. 00 0. 9844E 01 3025. 00 0. 8382E 02
525. 00 0. 9206E 01 3050. 00 0. 8288E 02
550. 00 0. 8634E 01 3075. 00 0. 8196E 02
575. 00 0. 8122E 01 3100. 00 0. 8106E 02
600. 00 0. 7661E 01 3125. 00 0. 8017E 02
625. 00 0. 7244E 01 3150. 00 0. 7930E 02
650. 00 0. 6865E 01 3174. 99 0. 7845E 02
675. 00 0. 6519E 01 3199. 99 0. 7761E 02
700. 00 0. 6203E 01 3225. 00 0. 7679E 02
725. 00 0. 5912E 01 3250. 00 0. 7598E 02
750. 00 0. 5644E 01 3275. 00 0. 7519E 02
775. 00 0. 5397E 01 3300. 00 0. 7441E 02
800. 00 0. 5169E 01 3325. 00 0. 7364E 02
825. 00 0. 4956E 01 3350. 00 0. 7289E 02
850. 00 0. 4758E 01 3375. 00 0. 7216E 02
875. 00 0. 4573E 01 3400. 00 0. 7143E 02
900. 00 0. 4400E 01 3425. 00 0. 7072E 02
925. 00 0. 4237E 01 3450. 00 0. 7002E 02
950. 00 0. 4085E 01 3475. 00 0. 6933E 02
975. 00 0. 3941E 01 3500. 00 0. 6865E 02
1000. 00 0. 3807E 01 3525. 00 0. 6799E 02
1025. 00 0. 3695E 01 3550. 00 0. 6733E 02
1050. 00 0. 3575E 01 3575. 00 0. 6669E 02
1075. 00 0. 3461E 01 3600. 00 0. 6606E 02
1100. 00 0. 3354E 01 3625. 00 0. 6543E 02
1125. 00 0. 3252E 01 3650. 00 0. 6482E 02
1150. 00 0. 3155E 01 3675. 00 0. 6422E 02
1175. 00 0. 3063E 01 3700. 00 0. 6363E 02
1200. 00 0. 2976E 01 3725. 00 0. 6304E 02
1225. 00 0. 2893E 01 3750. 00 0. 6247E 02
1250. 00 0. 2814E 01 3775. 00 0. 6190E 02
1275. 00 0. 2738E 01 3800. 00 0. 6135E 02
1300. 00 0. 2666E 01 3825. 00 0. 6080E 02
1325. 00 0. 2598E 01 3849. 99 0. 6026E 02
1350. 00 0. 2532E 01 3875. 00 0. 5973E 02
1375. 00 0. 2469E 01 3900. 00 0. 5920E 02
1400. 00 0. 2409E 01 3925. 00 0. 5869E 02
1425. 00 0. 2351E 01 3950. 00 0. 5818E 02
1450. 00 0. 2296E 01 3975. 00 0. 5768E 02
1475. 00 0. 2242E 01 4000. 00 0. 5719E 02
1500. 00 0. 2191E 01 4025. 00 0. 5670E 02
1525. 00 0. 2142E 01 4050. 00 0. 5622E 02
1550. 00 0. 2095E 01 4075. 00 0. 5575E 02
1575. 00 0. 2049E 01 4100. 00 0. 5529E 02
1600. 00 0. 2006E 01 4125. 00 0. 5483E 02
1625. 00 0. 1963E 01 4149. 99 0. 5438E 02
1650. 00 0. 1923E 01 4175. 00 0. 5393E 02
1675. 00 0. 1884E 01 4200. 00 0. 5349E 02
1700. 00 0. 1846E 01 4225. 00 0. 5306E 02
1725. 00 0. 1809E 01 4250. 00 0. 5264E 02
1750. 00 0. 1774E 01 4275. 00 0. 5221E 02
1775. 00 0. 1740E 01 4300. 00 0. 5180E 02
1800. 00 0. 1707E 01 4325. 00 0. 5139E 02
1825. 00 0. 1675E 01 4350. 00 0. 5099E 02
1850. 00 0. 1644E 01 4375. 00 0. 5059E 02
1875. 00 0. 1614E 01 4400. 00 0. 5020E 02
1900. 00 0. 1585E 01 4425. 00 0. 4981E 02
1924. 99 0. 1557E 01 4450. 00 0. 4943E 02
1950. 00 0. 1529E 01 4475. 00 0. 4905E 02
1975. 00 0. 1503E 01 4500. 00 0. 4868E 02
2000. 00 0. 1477E 01 4525. 00 0. 4831E 02
2025. 00 0. 1452E 01 4550. 00 0. 4795E 02
2050. 00 0. 1428E 01 4575. 00 0. 4759E 02
2075. 00 0. 1405E 01 4600. 00 0. 4723E 02
2100. 00 0. 1382E 01 4625. 00 0. 4689E 02
2125. 00 0. 1359E 01 4650. 00 0. 4654E 02
2150. 00 0. 1338E 01 4675. 00 0. 4620E 02
2175. 00 0. 1317E 01 4700. 00 0. 4587E 02
2200. 00 0. 1296E 01 4725. 00 0. 4553E 02
2225. 00 0. 1276E 01 4750. 00 0. 4521E 02
2250. 00 0. 1257E 01 4775. 00 0. 4488E 02
2275. 00 0. 1238E 01 4800. 00 0. 4456E 02
2300. 00 0. 1220E 01 4825. 00 0. 4425E 02
2325. 00 0. 1202E 01 4850. 00 0. 4394E 02
2350. 00 0. 1184E 01 4875. 00 0. 4363E 02
2375. 00 0. 1167E 01 4900. 00 0. 4332E 02
2400. 00 0. 1151E 01 4924. 99 0. 4302E 02
2425. 00 0. 1135E 01 4950. 00 0. 4273E 02
2450. 00 0. 1119E 01 4975. 00 0. 4243E 02
2475. 00 0. 1103E 01 5000. 00 0. 4214E 02
2500. 00 0. 1088E 01

AERSCREEN MAXIMUM IMPACT SUMMARY
3 hour, 8 hour, and 24 hour scaled
concentrations are equal to the 1 hour concentration as referenced in

SCREENING PROCEDURES FOR ESTIMATING THE AIR QUALITY
IMPACT OF STATIONARY SOURCES, REVISED Section 4. 5. 4)
Report number EPA 454/ R 92 019
http:// www. epa. gov/ scram001/ guidance_ permit. htm
under Screening Guidance

MAXIMUM SCALED SCALED SCALED SCALED
1 HOUR 3 HOUR 8 HOUR 24 HOUR ANNUAL

CALCULATION CONC CONC CONC CONC CONC
PROCEDURE ug/ m3) ug/ m3) ug/ m3) ug/ m3) ug/ m3)
FLAT TERRAIN 2. 256 2. 256 2. 256 2. 256 N/ A
DISTANCE FROM SOURCE 55. 00 meters

IMPACT AT THE
AMBIENT BOUNDARY 1. 711 1. 711 1. 711 1. 711 N/ A
DISTANCE FROM SOURCE 1. 00 meters
2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
949) 887-9013
mhagemann@swape. com
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:

Founding Partner, Soil/ Water/ Air Protection Enterprise ( SWAPE) ( 2003 – present); Geology Instructor, Golden West College, 2010 – 2104, 2017; Senior Environmental Analyst, Komex H2O Science, Inc. (2000 2003); Attachment C
2 Executive Director, Orange Coast Watch ( 2001 – 2004); Senior Science Policy Advisor and Hydrogeologist, U.S. Environmental Protection Agency ( 1989– 1998);
Hydrogeologist, National Park Service, Water Resources Division ( 1998 – 2000); Adjunct Faculty Member, San Francisco State University, Department of Geosciences ( 1993 – 1998);
Instructor, College of Marin, Department of Science ( 1990 – 1995); Geologist, U.S. Forest Service ( 1986 – 1998); and
Geologist, Dames & Moore ( 1984 – 1986).

Senior Regulatory and Litigation Support Analyst:

With SWAPE, Matt’ s responsibilities have included:

Lead analyst and testifying expert in the review of over 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.

Stormwater analysis, sampling and best management practice evaluation at more than 100 industrial facilities.

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.

Technical assistance and litigation support for vapor intrusion concerns.

Lead analyst and testifying expert in the review of environmental issues in license applications for large solar power plants before the California Energy Commission.

Manager of a project to evaluate numerous formerly used military sites in the western U.S.

Manager of a comprehensive evaluation of potential sources of perchlorate contamination in Southern California drinking water wells.

Manager and designated expert for litigation support under provisions of Proposition 65 in the review of releases of gasoline to sources drinking water at major refineries and hundreds of gas stations throughout California.

With Komex H2O Science Inc., Matt’ s duties included the following:

Senior author of a report on the extent of perchlorate contamination that was used in testimony by the former U.S. EPA Administrator and General Counsel.

Senior researcher in the development of a comprehensive, electronically interactive chronology of MTBE use, research, and regulation.

Senior researcher in the development of a comprehensive, electronically interactive chronology of perchlorate use, research, and regulation.

Senior researcher in a study that estimates nationwide costs for MTBE remediation and drinking water treatment, results of which were published in newspapers nationwide and in testimony against provisions of an energy bill that would limit liability for oil companies.

Research to support litigation to restore drinking water supplies that have been contaminated by MTBE in California and New York.
3 Expert witness testimony in a case of oil production related contamination in Mississippi.

Lead author for a multi volume remedial investigation report for an operating school in Los Angeles that met strict regulatory requirements and rigorous deadlines.

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

Executive Director:

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

Hydrogeology:

As a Senior Hydrogeologist with the U.S. Environmental Protection Agency, Matt led investigations to characterize and cleanup closing military bases, including Mare Island Naval Shipyard, Hunters Point Naval Shipyard, Treasure Island Naval Station, Alameda Naval Station, Moffett Field, Mather Army Airfield, and Sacramento Army Depot. Specific activities were as follows:

Led efforts to model groundwater flow and contaminant transport, ensured adequacy of monitoring networks, and assessed cleanup alternatives for contaminated sediment, soil, and groundwater.

Initiated a regional program for evaluation of groundwater sampling practices and laboratory analysis at military bases.

Identified emerging issues, wrote technical guidance, and assisted in policy and regulation development through work on four national U.S. EPA workgroups, including the Superfund Groundwater Technical Forum and the Federal Facilities Forum.

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

As a hydrogeologist with the EPA Groundwater Protection Section, Matt worked with provisions of the Safe Drinking Water Act and NEPA to prevent drinking water contamination. Specific activities included the following:

Received an EPA Bronze Medal for his contribution to the development of national guidance for the protection of drinking water.

Managed the 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.

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

Matt served as a hydrogeologist with the RCRA Hazardous Waste program. Duties were as follows:

Supervised the hydrogeologic investigation of hazardous waste sites to determine compliance with Subtitle C requirements.

Reviewed and wrote part B permits for the disposal of hazardous waste.

Conducted RCRA Corrective Action investigations of waste sites and led inspections that formed the basis for significant enforcement actions that were developed in close coordination with U.S.

EPA legal counsel.

Wrote contract specifications and supervised contractor’ s investigations of waste sites.

With the National Park Service, Matt directed service wide investigations of contaminant sources to prevent degradation of water quality, including the following tasks:

Applied pertinent laws and regulations including CERCLA, RCRA, NEPA, NRDA, and the Clean Water Act to control military, mining, and landfill contaminants.

Conducted watershed scale investigations of contaminants at parks, including Yellowstone and Olympic National Park.

Identified high levels of perchlorate in soil adjacent to a national park in New Mexico and advised park superintendent on appropriate response actions under CERCLA.

Served as a Park Service representative on the Interagency Perchlorate Steering Committee, a national workgroup.

Developed a program to conduct environmental compliance audits of all National Parks while serving on a national workgroup.

Co authored two papers on the potential for water contamination from the operation of personal watercraft and snowmobiles, these papers serving as the basis for the development of nation wide policy on the use of these vehicles in National Parks.

Contributed to the Federal 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:

Advised the Regional Administrator and senior management on emerging issues such as the potential for the gasoline additive MTBE and ammonium perchlorate to contaminate drinking water supplies.

Shaped EPA’ s national response to these threats by serving on workgroups and by contributing to guidance, including the Office of Research and Development publication, Oxygenates in Water: Critical Information and Research Needs.

Improved the technical training of EPAs scientific and engineering staff. Earned an EPA Bronze Medal for representing theregion’s 300 scientists and engineers innegotiations with the Administrator andsenior management tobetter integrate scientific 5 principles into the policy making process.

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:

Mapped geology in the field, and used aerial photographic interpretation and mathematical models to determine slope stability.

Coordinated his research with community members who were concerned with natural resource protection.

Characterized the geology of an aquifer that serves as the sole source of drinking water for the city of Medford, Oregon.

As a consultant with Dames and Moore, Matt led geologic investigations of two contaminated sites ( later listed on the Superfund NPL) in the Portland, Oregon, area and a large hazardous waste site in eastern Oregon. Duties included the following:

Supervised year long effort for soil and groundwater sampling.

Conducted aquifer tests.

Investigated active faults beneath sites proposed for hazardous waste disposal.

Teaching:

From 1990 to 1998, Matt taught at least one course per semester at the community college and university levels:

At San Francisco State University, held an adjunct faculty position and taught courses in environmental geology, oceanography ( lab and lecture), hydrogeology, and groundwater contamination.

Served as a committee member for graduate and undergraduate students.

Taught courses in environmental geology and oceanography at the College of Marin.

Matt 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 Groundwater. 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 Char ac terization and Cl ean up at 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: prosenfeld@swape. com
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.

Attachment D
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 H2O Science, 2001 to 2003; Senior Remediation Scientist National Groundwater Association, 2002-2004; Lecturer
San Diego State University, 1999-2001; Adjunct Professor Anteon Corp., San Diego, 2000-2001; Remediation Project Manager Ogden (now Amec), San Diego, 2000-2000; Remediation Project Manager Bechtel, San Diego, California, 1999 – 2000; Risk Assessor King County, Seattle, 1996 – 1999; Scientist
James River Corp., Washington, 1995-96; Scientist
Big Creek Lumber, Davenport, California, 1995; Scientist Plumas Corp., California and USFS, Tahoe 1993-1995; Scientist Peace Corps and World Wildlife Fund, St. Kitts, West Indies, 1991-1993; Scientist Publications:

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 facilities in the United States. Brebbia, C.A. and Popov, V., eds., Air Pollution XVII: Proceedings of the Seventeenth International Conference on Modeling, Monitoring and Management of Air Pollution. Lecture conducted from Tallinn, Estonia.

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

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 23rd Annual International Conferences on Soils Sediment and Water. Platform lecture conducted from University of Massachusetts, Amherst MA.

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

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

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

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

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

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

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

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

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

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

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

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

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

Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.

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

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

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

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

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

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

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

Rosenfeld, P.E. and Grey, M. A. (November 11-14, 2002). Using High-Carbon Wood Ash to Control Odor at a Green Materials Composting Facility. Soil Science Society Annual 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 Biosolids Management Conference Proceedings. Lecture conducted from Bellevue Washington.

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

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 grant awarded to University of Washington: Goal: To investigate odor emissions from biosolids application and the effect of polymers and ash on VOC emissions. 1998.

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

Paul E. Rosenfeld, Ph.D. Page 8 of 12 October 2022
James River Corporation, Oregon: $ 10,000 grant was awarded to investigate the success of genetically engineered Poplar trees with resistance to round-up. 1996.

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

Kellogg Foundation, Washington D.C. $500 grant was awarded to construct a large anaerobic digester on St. Kitts in West Indies. 1993
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. CIVDS1711810
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 4th 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, 112th 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 17th 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
EXHIBIT 2
Letter EMY
WI #23-001.18
December 1, 2023
Brian B. Flynn
Lozeau | Drury LLP
1939 Harrison Street, Suite 150
Oakland, California 94612
SUBJECT: Comments on Pacific Resort Plaza Initial Study/ Mitigated Negative Declaration Dear Mr. Flynn,
Per your request, I have reviewed the noise analysis in the Initial Study ( IS)/ Mitigated Negative Declaration ( MND) for the proposed Pacific Resort Plaza development project at 125 East Ball Road in the City of Anaheim, Orange County, California. The following documents were reviewed:

Pacific Resort Plaza, Development Project No. 2019-00161 Initial Study/ Mitigated Negative Declaration
October 2023
Appendix H – Noise Calculations
The noise analysis is contained in Section 5 chapter XIII of the MND, with supplemental calculations in Appendix H.

The proposed project involves the demolition of an existing two-story commercial building and hardscape and the construction of afive-story hotel. The hotel would include two puzzle-lift enclosed parking structures and an outdoor pool located on ground level. The proposed project also includes a separate single- story fast-food restaurant building with drive- thru lane. The project is surrounded by multi-family residential, 80 feet north of the boundary, and commercial and industrial uses to the east, west, and south of the boundary.

There are several errors and omissions in the MND noise analysis. Correcting these would potentially identify several significant impacts. The MND should include thorough baseline noise measurements taken at key locations over a multi- day period to establish existing ambient noise levels, address potentially significant noise due to construction activities, and provide supporting information to validate HVAC noise assumptions.

WILSON IHRIG
Pacific Resort Plaza, Anaheim, Calif.

Review of MND Noise Analysis

Page 2 ends

Baseline Noise is Not Properly Established
An essential aspect of CEQA is documenting the baseline environment so that potential changes may be adequately assessed. The manner in which the MND has determined the existing noise environment is inadequate for two reasons: 1. It neglects the nighttime hours when noise is more likely to cause an impact, and 2. It does not consider the variability that can occur over several days, particularly between a weekday and the weekend. An updated noise study should be prepared that includes thorough baseline measurements taken at key locations throughout the 24-hour days over a multi- day period.

The noise analysis included four short- term measurements of 20-minute duration conducted on Wednesday, February 15, 2023, between 11 A.M. and 1 P.M. [MND at p. 5-61 and Appendix H pp. 2 to 9] No data is presented for nighttime conditions when ambient noise levels are lower and residents would be more sensitive to noise increases, and the data does not document variation in noise level that typically occur throughout a day.

The MND states “ The existing noise environment in and near the Project Site is primarily influenced by traffic noise on East Ball Road and South Anaheim Boulevard”. [ MND p. 5-61] However, the baseline noise measurements consisted of short-term measurements during mid-day hours without any discussion of how typical these data were for daytime conditions or how they would apply to evening or nighttime conditions. Environmental noise that is affected by transportation sources can vary widely throughout the day (perhaps +/- 10 dBA or more for areas with intermittent local traffic) and relying on measurements that represent only 1% of the time on one particular day during mid-day hours is not a sound basis for a technical analysis. CEQA requires some effort to document the existing baseline conditions at all relevant times.

Potentially Significant Impacts from Construction Noise are Not Addressed The construction noise analysis has some inconsistencies and is insufficient to show there would be no potentially significant impacts.

Not All Equipment Accounted For
More details on the noise sources during construction need to be provided. Depending on the noise sources and equipment used during construction, some activities might produce significant noise and it might not be possible to mitigate them.

The estimated noise levels are calculated using noise levels published in 1971 by the U.S. EPA1 for Office Building, Hotel, Hospital, School, and Public Works” construction sites. The noise levels calculated in the MND are based on the “Minimum required equipment present at site” [ Appendix H at p. 10] although the cited EPA document also has source levels for “All pertinent equipment present at site.” An excerpt from the U.S. EPA document is provided in Figure 1 below. For certain construction phases, the noise levels accounting for all pertinent equipment ( values indicated in red) are 10 to 14 dBA higher than the noise levels for the minimum required equipment used in the present noise level calculations ( values indicated inblue). The MND does not provide any justification 1 “ Noise from Construction Equipment and Operations, Building Equipment, and Home Appliances”, Prepared by Bolt, Beranek and Newman for the U.S. Environmental Protection Agency, December 31, 1971.

WILSON IHRIG
Pacific Resort Plaza, Anaheim, Calif.

Review of MND Noise Analysis

Page 3 ends

for why the minimum required equipment was selected as a basis for the noise level calculations, instead of all pertinent equipment.

The MND must account for all potentially significant scenarios; given the fact that land is expensive in California and that construction workers are in short supply, barring any substantive information about how the project will be built with “minimal equipment”, Ithink itis only proper to use the “all pertinent equipment” noise level data. If only “ the minimum equipment” is to be used during construction, the exact limitations on types and numbers of equipment must be explicitly incorporated into the mitigation measures.

Figure 1 Typical Ranges of Noise Level at Construction Sites Published by U.S. EPA ( 1971) Improper Application of FTA Thresholds
The construction noise assessment does not account for the existing noise environment and therefore does not adequately identify substantial and potentially significant increases in ambient noise levels that might occur in the vicinity of the project during construction.

WILSON IHRIG
Pacific Resort Plaza, Anaheim, Calif.

Review of MND Noise Analysis

Page 4 ends

The noise analysis evaluates construction noise against the Federal Transit Administration ( FTA) construction noise guideline criteria for a Detailed Analysis2. [ MND at p. 5-67] While the FTA provides guidance for limits on absolute noise levels during construction activities to minimize adverse community reaction, it also emphasizes that the “Project construction noise criteria should account for the existing noise environment”. [ FTA at p. 179] The FTA Detailed Analysis Construction Noise criterion for daytime residential land use is 80 dBA Leq over an 8-hour period. Evaluating the noise over an 8-hour period is not appropriate for an MND, since noise levels would be higher for shorter intervals, and this shorter- duration increase in ambient noise levels may be substantial and potentially significant.

As noted above, the MND does not adequately establish existing noise levels, nor does it account for all pertinent equipment present during construction; nevertheless, I used the data presented in the MND to develop Table 1 which shows construction noise levels at the two distances from the nearest noise sensitive property boundary. As seen, noise levels would be up to 22 dB higher than existing ambient daytime noise levels at the nearest noise sensitive land use. This is a substantial increase that would cause adverse community reaction and would be significant given that it would be perceived as more than four times louder than the baseline noise levels .3 A 16 to 17 dB increase would be perceived as trebling of loudness.

Table 1 Comparison of Calculated Construction Noise Levels to Existing Daytime Ambient Noise Levels at Closest Noise Sensitive Use North of the Project Location Calculated Construction
Noise Level per MND
Table 18, Leq ( dBA)
Measured Noise
Level per MND
Table 15, Leq
dBA)
Increase over
Existing ( dBA),
range from 265 ft
to 80 ft
80 ft 265 ft Existing
Ground Clearing / Demolition 75 65 53 12 - 22
Excavation 70 60 53 7 - 17
Foundation Construction 69 59 53 6 - 16
Building Construction 66 56 53 3 - 13
Paving and Site Cleanup 66 56 53 3 - 13
Errors in MND Appendix
The construction noise analysis results are not correctly summarized. The backup calculations for construction generated noise shown in Appendix H do not match Table 18 in the MND. In Appendix H construction noise for the north residential receptor located at a distance of 80 feet are indicated as 80, 75, 74, 71, 71 ( dBA Leq) for the five phases of construction. In Table 18 of the MND the construction noise for the same receptor at 80 feet is indicated as 75, 70, 69, 66, and 66 for the five phases of construction. It is more likely that the figures in the technical appendix are the correct 2 See Section 7 of FTA “ Transit Noise and Vibration Impact Assessment Manual.” September 2018. 3 A 10 dB increase in noise level is commonly perceived as a doubling of loudness. [ Bies D., Hansen C., Howard C., Engineering Noise Control ( 5ed., Taylor & Francis, 2018) at p. 74] 20 dB is two 10 dB increases, therefore two doublings, i.e., a fourfold increase in the perception of loudness.

WILSON IHRIG
Pacific Resort Plaza, Anaheim, Calif.

Review of MND Noise Analysis

Page 5 ends

values, and, if so, the increase over the existing ambient would be up to 27 dBA which is 6-1/ 2 times louder than the existing baseline.

Operational HVAC Noise Assessment Requires Supporting Information The HVAC noise assessment does not provide sufficient evidence to rule out all potentially significant impacts. An analysis should be prepared that assesses the project noise in the context of the existing ambient noise as required by CEQA.

Potential for Higher HVAC Noise
The Project would include new mechanical equipment which the MND presumes “ would be located at least 300 feet from the nearest residential uses north of the site”. [MND at p. 5-63] The distance used in the Appendix H noise calculations is 250 feet. However, the closest hotel rooms are on the order of 80 to 100 feet away from the nearest residential property line [ MND Exhibit 4]. In my experience, that would be an unusually far distance to pipe conditioned air. In addition, itis very common for hotels to use Packaged Terminal Air Conditioners ( PTAC) which are individual units for each room, and the MND states “ HVAC units would ductless individual units that each serve 4 rooms.” [ MND at p. 5-63] So, it seems implausible that the HVAC equipment will be 250 feet from the nearest residences.

The MND presumes the Project will include “ quiet” units which produce a sound pressure level of 60 dBA at 20 feet. It should provide citation or evidence for the source noise level used in the calculations. It describes that each unit serves 4 rooms, but it is unclear whether the noise calculations have considered more than one unit operating atthe same time. During cold nights, more than one unit could be operating. As noted above, several units could be closer to the property line than 250 feet.

Substantial Increase over Existing Ambient
The MND does not consider whether the HVAC noise would cause a substantial noise increase over existing noise, particularly during nighttime conditions when ambient noise levels are lower and residents would be more sensitive to noise increases. The daytime, 20-minute noise data reported in the MND shows the minimum noise level at the northern project boundary is 45 dBA during the middle of the day [ MND at p. 5-61]; nighttime levels are typically lower. HVAC noise at the property line was assessed using the Anaheim Local Municipal Code limit of 60 dBA at the property line. [MND at p. 5-63] Even if nighttime noise levels ( which have not been established) are on the order of 45 dBA, HVAC noise on the order of 60 dBA would be 15 dBA louder than the existing ambient noise.

This is a substantial increase that would cause adverse community reaction and would be significant given that it would be perceived as more than twice as loud as the baseline noise levels.

Conclusions
No baseline noise data is presented for nighttime conditions when ambient noise levels are lower and project noise is more likely to cause significant impacts.

Baseline noise data does not document variation in noise level that typically occur throughout a day, and over several days.

The MND construction noise analysis does not account for all potentially significant scenarios; it provides no justification for why the calculated noise levels are based on

WILSON IHRIG
Pacific Resort Plaza, Anaheim, Calif.

Review of MND Noise Analysis

Page 6 ends

minimum required equipment”. If only “ the minimum equipment” is to be used during construction, the exact limitation on types and numbers of equipment must be explicitly incorporated into the mitigation measures.

The MND construction noise assessment does not account for the existing noise environment and does not consider whether construction would generate a substantial increase in ambient noise levels as required by CEQA.

There are discrepancies inthe construction generate noise levels shown in MND Table 18 and the Appendix H noise calculations.

The HVAC noise assessment does not provide sufficient evidence to rule out all potentially significant impacts due to more than one unit operating simultaneously, and multiple units located closer to the property line than 250 feet. No citation or evidence for the source noise level used in the calculation is given.

The MND does not consider whether the HVAC noise would cause a substantial noise increase over existing noise, as required by CEQA, particularly during nighttime conditions when ambient noise levels are lower and residents would be more sensitive to noise increases.

Given the errors and omissions in the MND, we have shown that potentially significant noise impacts may be caused by the project. At a minimum, the MND should be revised and recirculated to address our comments, however, it may be advisable to prepare a full environmental impact report for the project.

Please feel free to contact me with any questions on this information.

Very truly yours,

WILSON IHRIG
Silas Bensing, INCE Bd. Cert
Associate Principal
wilson ihrig - comments on pacific resort plaza noise analysis. docx SILAS BENSING, INCE Bd. Cert.

Associate Principal
Silas joined Wilson Ihrig in 2008 and works on a variety of projects involving environmental noise, construction noise and vibration, architectural/ HVAC noise, rail transit noise and vibration, and structural vibration. He has extensive experience in techniques and instrumentation for field measurement of noise and vibration. He is proficient in the use of GIS and noise modeling software such as SoundPLAN, CadnaA, and TNM for calculation, assessment, and mapping of railway, highway, and other environmental noise sources. He is Board Certified in noise control engineering through the Institute of Noise Control Engineering of the USA ( INCE- USA).

Education
M.Eng., Acoustics, The Pennsylvania State University ( expected Spring 2024) B.A., Audio Arts and Acoustics; Columbia College Chicago Professional Memberships
Acoustical Society of America ( ASA) Full Member
Institute of Noise Control Engineering ( INCE- USA) Board Certified Member National Council of Acoustical Consultants ( NCAC) Director- at-Large/ Individual Member Project Experience
Millennium Bulk Terminals, Longview, WA
Prepared noise analysis for the project’ s NEPA and SEPA environmental impact statements. Tasks included future rail traffic modeling using CadnaA and preparation of noise contours using GIS.

Bayview Waterfront DEIR San Francisco 49ers Stadium Operational Noise Study, CA Developed SoundPLAN model to analyze noise impacts on surrounding community.

California High-Speed Rail EIR/ EIS, San Francisco to San Jose Section, CA Prepared the noise analysis for the project’ s environmental impact assessment. Conducted existing ambient noise characterization, performed wayside noise prediction and evaluated noise impacts and mitigation. GIS and SoundPLAN operation.

California High-Speed Rail EIR/ EIS, San Jose to Merced Section, CA Prepared the vibration analysis for the project’ s environmental impact assessment. Tasks included assessing vibration from transit operations and GIS operations.

Caltrain Electrification, San Mateo County Transit District, CA Prepared the noise and vibration analysis for the project’ s environmental impact assessment.

Tasks included characterizing the existing noise and vibration conditions and assessing noise and vibration from transit operations and construction- related activities.

I-880 Operational and Safety Improvements, Oakland, CA
Developed highway noise model and performed sound barrier analysis using FHWA TNM.

WILSON IHRIG
Silas Bensing – Page 2
State Route 24 Pre-NBSSR Noise Study, Oakland, CA
Analyzed field data, developed highway noise model and performed sound barrier analysis using FHWA TNM, and prepared report.

Jordan Ranch Residential Project, Dublin, CA
Prepared noise study report as required by California Code of Regulations Title 24 for two neighborhoods of the proposed residential project. Tasks included modeling future traffic noise levels using FHWA TNM and evaluating exterior- to-interior noise control.

Kaiser Vallejo Building E Demolition, Vallejo, CA
Made estimates of noise and vibration levels due to planned demolition work, and recommended practices for contractor to minimize noise and vibration- related disruptions on hospital occupants within the adjacent hospital building.

Union City Sanitation District Admin Building / New Headquarters Acoustical design of new headquarters building. Issues addressed included exterior noise control for rooftop HVAC equipment and emergency generator, interior HVAC noise control, and interior acoustics of offices and conference rooms.

San Pablo Dam Seismic Retrofit, El Sobrante, CA
Responsible for remote noise data management and preparation of monthly construction noise monitoring reports.

San Rafael High School, CA
Prepared construction noise reduction plan for a new two-story building. Tasks included noise calculations from equipment and report preparation.

Shri Guru Ravidas Sabha Construction Noise Plan, Union City, CA Prepare construction noise and vibration control plan for new building. Tasks included noise and vibration calculations and report preparation.

Stanford University Construction Noise, Palo Alto, CA
Assisted Stanford planning department evaluate construction noise from planned projects.

Tyco Electronics, Menlo Park, CA
Developed comprehensive 3D computer model using CadnaA to model noise from existing outdoor mechanical equipment, predict effects on noise levels from planned equipment upgrades and additions, and evaluate compliance with local noise legislation.

New York MTA Long Island Railroad East Side Access, NY
Consultation on multiple contracts. Work included estimates of noise levels from construction equipment, and preparation of site-specific construction noise plans outlining the control methods required to comply with project noise limits.

New York MTA Metro- North Railroad Park Avenue Viaduct Master Plan Study, NY Noise and vibration subconsultant on Master Plan team to develop recommendations for phased replacement and rehabilitation of the Park Avenue Viaduct. Managed project and authored technical reports to address existing train noise and noise control considerations for new and rehabilitated structure.

WILSON IHRIG
Silas Bensing – Page 3
New York City Council Proposed Noise Code Amendment for Noise Monitoring Near Schools, NY Reviewed and provided recommendations to attorney with regard to Int. No. 420-2014, the proposed New York City Council amendment for construction noise monitoring near schools. 50 Pine Street Condominiums, New York, NY
Project involved evaluating noise at residential dwelling units for NYC noise code compliance.

Measured noise levels from mechanical equipment in enclosed courtyard.

State University of New York at Albany, Rehabilitation of Water Tower and Foundations, NY Developed a noise and vibration control program for rehabilitation of the campus water tower and main fountain with recommended noise and vibration controls for surrounding academic buildings during construction. Installed a remote continuous noise monitoring system.

Bay Park Conveyance Noise Monitoring Plan, Nassau County, Long Island, NY Prepared noise control and monitoring plan for construction work associated with microtunneling along a 11-mile-long corridor and construction of two pump stations. Identified noise- sensitive receivers within 500 feet of work and reviewed noise ordinances for five municipalities to identify site-specific noise limitations for each work site.

WMATA A/ E Planning Services Metro Center and L’Enfant Plaza Station Improvements, DC Evaluated potential construction noise and vibration impacts associated with the Metro Center Station and L’Enfant Plaza Center Station improvements consisting of the addition of new streetmezzanine elevators and interior elevators and escalators.

SusanaBarrios
From: Steven Thong <steven@mitchtsailaw. com>
Sent: Tuesday, February 27, 202410:05AM
To: PublicComment; CityClerk
Cc: Mitchell M. TsaiAttorney atLaw, P.C.; Mitchell Tsai; GraceHolbrook Subject:\[ EXTERNAL\] WSRCC - \[ CityofAnaheim, LaQuinta Inn & Suites\] - 2/27/24Comment letter
Attachments: 20240227_WSRCC_LaQuintaInn&Suites_CC_Cmt_Complete.pdf Youdon'[email protected]. Learnwhythisisimportant Warning: Thisemailoriginated fromoutsidetheCityofAnaheim. Donotclicklinksoropenattachments unlessyou recognize thesenderandareexpecting themessage.

Goodmorning,
PleaseseetheattachedComment LetterfortheCityofAnaheim'sCityCouncilhearingregardingAgendaNo. 31.

Additionally, pleaseconfirmreceiptofthisemailanditsattachment.

Best,
Steven
StevenThong
Paralegal
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Mitchell M. Tsai
Law Firm
139 South Hudson Avenue
Suite 200
Pasadena, California 91101

VIA E-MAIL
February 27, 2024
City of Anaheim
200 South Anaheim Boulevard
Anaheim, CA 92805
Em: [email protected]
Em: [email protected]
RE: Agenda Item No. 31: City of Anaheim’ s La Quinta Inn & Suites Project (DEV2019-00161)
Dear Mayor Aitken, Mayor Pro Tem Kurtz, and Honorable Councilmembers, On behalf of the Western States Regional Council of Carpenters (“ Western Carpenters” or “WSRCC”), my Office is submitting these comments to the City of Anaheim (“ City”) regarding the La Quinta Inn & Suites Project (“Project”).

The Project consists of an approximately 67,715 sf hotel and a detached 1,200 sf walk-up/ drive thru fast-food restaurant with associated parking at 125 East Ball Road . . . The hotel component of the Project would consist of a 120-room hotel that would be five stories, 55-feet in height. The hotel is standard stay with limited food service ( continental breakfast). The first floor of the hotel would contain the designated lobby area with a meeting room, sales and manager’s office, shop, pantry, breakfast area, and restroom facility. 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 designated Americans with Disabilities Act (ADA) accessible guest rooms per floor . . . An observation deck is proposed on the second level for guest-viewing of fireworks at Disneyland Theme Park. Also, a fitness center and a conference room are proposed to be located on the second floor, and an outdoor pool would be located on ground level adjacent to the hotel building.

The Western Carpenters is a labor union representing almost 90,000 union carpenters in 12 states, including California, and has a strong interest in well-ordered land use planning and in addressing the environmental impacts of development projects.

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The Western States Regional Council of Carpenters expressly reserves the right to supplement these comments at or prior to hearings on the Project, and at any later hearing and proceeding related to this Project. Gov. Code, § 65009, subd. (b); Pub.

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

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

I. THE CITY SHOULD REQUIRE THE USE OF A LOCAL
WORKFORCE TO BENEFIT THE COMMUNITY’ S ECONOMIC

DEVELOPMENT AND ENVIRONMENT
The City should require the Project to be built using a local workers who have graduated from a Joint Labor- Management Apprenticeship Program approved by the State of California, have at least as many hours of on-the-job experience in the applicable craft which would be required to graduate from such a state-approved apprenticeship training program, or who are registered apprentices in a state- approved apprenticeship training program.

Community benefits such as local hire can also be helpful to reduce environmental impacts and improve the positive economic impact of the Project. Local hire provisions requiring that a certain percentage of workers reside within 10 miles or less of the Project site can reduce the length of vendor trips, reduce greenhouse gas emissions, and provide localized economic benefits. As environmental consultants Matt Hagemann and Paul E. Rosenfeld note:

A]ny local hire requirement that results in a decreased worker trip length from the default value has the potential to result in a reduction of construction-related GHG emissions, though the significance of the reduction would vary based on the location and urbanization level of the project site.

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

Workforce requirements promote the development of skilled trades that yield sustainable economic development. As the California Workforce Development Board and the University of California, Berkeley Center for Labor Research and Education concluded:

L]abor should be considered an investment rather than a cost—and investments in growing, diversifying, and upskilling California’s workforce can positively affect returns on climate mitigation efforts. In other words, well-trained workers are key to delivering emissions reductions and moving California closer to its climate targets.1
Furthermore, workforce policies have significant environmental benefits given that they improve an area’s jobs-housing balance, decreasing the amount and length of job commutes and the associated greenhouse gas (GHG) emissions. In fact, on May 7, 2021, the South Coast Air Quality Management District found that that the “[ u]se of a local state-certified apprenticeship program” can result in air pollutant reductions.2 Locating jobs closer to residential areas can have significant environmental benefits.

As the California Planning Roundtable noted in 2008:

People who live and work in the same jurisdiction would be more likely to take transit, walk, or bicycle to work than residents of less balanced communities and their vehicle trips would be shorter. Benefits would include potential reductions in both vehicle miles traveled and vehicle hours traveled.3
1 California Workforce Development Board (2020) Putting California on the High Road: A Jobs and Climate Action Plan for 2030 at p. ii, available at https:// laborcenter.berkeley.edu/ wp-content/ uploads/ 2020/ 09/ Putting-California-on-the-High-Road.pdf. 2 South Coast Air Quality Management District (May 7, 2021) Certify Final Environmental Assessment and Adopt Proposed Rule 2305 – Warehouse Indirect Source Rule – Warehouse Actions and Investments to Reduce Emissions Program, and Proposed Rule 316 – Fees for Rule 2305, Submit Rule 2305 for Inclusion Into the SIP, and Approve Supporting Budget Actions, available at http:// www.aqmd.gov/ docs/ defaultsource/ Agendas/ Governing-Board/ 2021/ 2021-May7-027.pdf?sfvrsn=10. 3 California Planning Roundtable (2008) Deconstructing Jobs-Housing Balance at p. 6, available at https:// cproundtable.org/ static/ media/ uploads/ publications/ cpr-jobshousing.pdf City of Anaheim – La Quinta Inn & Suites
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Moreover, local hire mandates and skill-training are critical facets of a strategy to reduce vehicle miles traveled (VMT). As planning experts Robert Cervero and Michael Duncan have noted, simply placing jobs near housing stock is insufficient to achieve VMT reductions given that the skill requirements of available local jobs must match those held by local residents.4 Some municipalities have even tied local hire and other workforce policies to local development permits to address transportation issues. Cervero and Duncan note that:

In nearly built-out Berkeley, CA, the approach to balancing jobs and housing is to create local jobs rather than to develop new housing. The city’s First Source program encourages businesses to hire local residents, especially for entry- and intermediate-level jobs, and sponsors vocational training to ensure residents are employment-ready. While the program is voluntary, some 300 businesses have used it to date, placing more than 3,000 city residents in local jobs since it was launched in 1986. When needed, these carrots are matched by sticks, since the city is not shy about negotiating corporate participation in First Source as a condition of approval for development permits.

Recently, the State of California verified its commitment towards workforce development through the Affordable Housing and High Road Jobs Act of 2022, otherwise known as Assembly Bill No. 2011 (“ AB2011”). AB2011 amended the Planning and Zoning Law to allow ministerial, by-right approval for projects being built alongside commercial corridors that meet affordability and labor requirements.

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

II. THE CITY SHOULD IMPOSE TRAINING REQUIREMENTS FOR
THE PROJECT’S CONSTRUCTION ACTIVITIES TO PREVENT
COMMUNITY SPREAD OF COVID-19 AND OTHER INFECTIOUS

DISEASES
4 Cervero, Robert and Duncan, Michael (2006) Which Reduces Vehicle Travel More: JobsHousing Balance or Retail-Housing Mixing? Journal of the American Planning Association 72 (4), 475-490, 482, available at http:// reconnectingamerica. org/ assets/ Uploads/ UTCT825.pdf.

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Construction work has been defined as a Lower to High-risk activity for COVID-19 spread by the Occupations Safety and Health Administration. Recently, several construction sites have been identified as sources of community spread of COVID19.5 Western Carpenters recommend that the Lead Agency adopt additional requirements to mitigate public health risks from the Project’s construction activities. WSRCC requests that the Lead Agency require safe on-site construction work practices as well as training and certification for any construction workers on the Project Site.

In particular, based upon Western Carpenters’ experience with safe construction site work practices, WSRCC recommends that the Lead Agency require that while construction activities are being conducted at the Project Site:

Construction Site Design:

The Project Site will be limited to two controlled entry points.

Entry points will have temperature screening technicians taking temperature readings when the entry point is open.

The Temperature Screening Site Plan shows details
regarding access to the Project Site and Project Site logistics for conducting temperature screening.

A 48-hour advance notice will be provided to all trades prior to the first day of temperature screening.

The perimeter fence directly adjacent to the entry points will be clearly marked indicating the appropriate 6-foot social distancing position for when you approach the screening area. Please reference the Apex temperature screening site map for additional details.

There will be clear signage posted at the project site directing you through temperature screening.
5 Santa Clara County Public Health (June 12, 2020) COVID-19 CASES AT

CONSTRUCTION SITES HIGHLIGHT NEED FOR CONTINUED VIGILANCE IN SECTORS THAT HAVE REOPENED, available at https:// www.sccgov.org/ sites/ covid19/ Pages/ press-release-06-12-2020-cases-at-construction-sites.aspx.

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Provide hand washing stations throughout the construction site.

Testing Procedures:

The temperature screening being used are non-contact
devices.

Temperature readings will not be recorded.

Personnel will be screened upon entering the testing center and should only take 1-2 seconds per individual.

Hard hats, head coverings, sweat, dirt, sunscreen or any other cosmetics must be removed on the forehead before
temperature screening.

Anyone who refuses to submit to a temperature screening or does not answer the health screening questions will be
refused access to the Project Site.

Screening will be performed at both entrances from 5:30 am to 7:30 am.; main gate [ ZONE 1] and personnel gate
ZONE 2]
After 7:30 am only the main gate entrance [ ZONE 1] will continue to be used for temperature testing for anybody gaining entry to the project site such as returning personnel, deliveries, and visitors.

If the digital thermometer displays a temperature reading above 100.0 degrees Fahrenheit, a second reading will be taken to verify an accurate reading.

If the second reading confirms an elevated temperature, DHS will instruct the individual that he/ she will not be allowed to enter the Project Site. DHS will also instruct the individual to promptly notify his/ her supervisor and his/ her human resources (HR) representative and provide them with a copy of Annex A.

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Planning
Require the development of an Infectious Disease
Preparedness and Response Plan that will include basic
infection prevention measures (requiring the use of personal protection equipment), policies and procedures for prompt identification and isolation of sick individuals, social distancing ( prohibiting gatherings of no more than 10
people including all-hands meetings and all-hands lunches) communication and training and workplace controls that
meet standards that may be promulgated by the Center for Disease Control, Occupational Safety and Health
Administration, Cal/ OSHA, California Department of
Public Health or applicable local public health agencies. 6 The United Brotherhood of Carpenters and Carpenters International Training Fund has developed COVID-19 Training and Certification to ensure that Carpenter union members and apprentices conduct safe work practices. The Agency should require that all construction workers undergo COVID-19 Training and Certification before being allowed to conduct construction activities at the Project Site.

Western Carpenters has also developed a rigorous Infection Control Risk Assessment ICRA”) training program to ensure it delivers a workforce that understands how to identify and control infection risks by implementing protocols to protect themselves and all others during renovation and construction projects in healthcare environments.7
ICRA protocols are intended to contain pathogens, control airflow, and protect patients during the construction, maintenance and renovation of healthcare facilities. 6 See also The Center for Construction Research and Training, North America’s Building Trades Unions (April 27 2020) NABTU and CPWR COVIC-19 Standards for U.S Constructions Sites, available at https:// www.cpwr.com/ sites/ default/ files/ NABTU_ CPWR_Standards_COVID-19.pdf; Los Angeles County Department of Public Works 2020) Guidelines for Construction Sites During COVID-19 Pandemic, available at https:// dpw.lacounty.gov/ building-and-safety/ docs/ pw_guidelines-construction-sites.pdf. 7 For details concerning Western Carpenters’s ICRA training program, see https:// icrahealthcare.com/.

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

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

III. THE PROJECT WOULD BE APPROVED IN VIOLATION OF THE

CALIFORNIA ENVIRONMENTAL QUALITY ACT
The California Environmental Quality Act is a California statute designed to inform decision-makers and the public about the potential significant environmental effects of a project. 14 California Code of Regulations (“ CEQA Guidelines”), § 15002, subd. a)(1).8 At its core, its purpose is to “inform the public and its responsible officials of the environmental consequences of their decisions before they are made.” Citizens of Goleta Valley v. Board of Supervisors ( 1990) 52 Cal.3d 553, 564.

1. Background Concerning Environmental Impact Reports
CEQA directs public agencies to avoid or reduce environmental damage, when possible, by requiring alternatives or mitigation measures. CEQA Guidelines, § 15002, subds. (a)(2)-(3); see also Berkeley Keep Jets Over the Bay Committee v. Board of Port Comes ( 2001) 91 Cal.App.4th 1344, 1354; Citizens of Goleta Valley v. Board of Supervisors 1990) 52 Cal.3d 553; Laurel Heights Improvement Assn., 47 Cal.3d at p. 400. The EIR serves to provide public agencies and the public in general with information about the effect that a proposed project is likely to have on the environment and to “identify ways that environmental damage can be avoided or significantly reduced.” CEQA Guidelines, § 15002, subd. ( a)( 2). If the project has a significant effect on the environment, the agency may approve the project only upon finding that it has eliminated or substantially lessened all significant effects on the environment where feasible” and that any unavoidable significant effects on the environment are acceptable due to overriding concerns” specified in Public Resources Code section 21081. See CEQA Guidelines, § 15092, subds. (b)(2)(A)-(B). 8 The CEQA Guidelines, codified in Title 14 of the California Code of Regulations, section 15000 et seq., are regulatory guidelines promulgated by the state Natural Resources Agency for the implementation of CEQA. Cal. Pub. Res. Code, § 21083. The CEQA Guidelines are given “ great weight in interpreting CEQA except when . . . clearly unauthorized or erroneous.” Center for Biological Diversity v. Dept. of Fish & Wildlife (2015) 62 Cal.4th 204, 217.

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While the courts review an EIR using an ‘abuse of discretion’ standard, the reviewing court is not to uncritically rely on every study or analysis presented by a project proponent in support of its position. Berkeley Jets, 91 Cal.App.4th at p. 1355 (quoting Laurel Heights Improvement Assn., 47 Cal.3d at pp. 391, 409 fn. 12) (internal quotations omitted). A clearly inadequate or unsupported study is entitled to no judicial deference. Id. Drawing this line and determining whether the EIR complies with CEQA’s information disclosure requirements presents a question of law subject to independent review by the courts. Sierra Club v. County of Fresno (2018) 6 Cal.5th 502, 515; Madera Oversight Coalition, Inc. v. County of Madera (2011) 199 Cal.App.4th 48, 102, 131. As the court stated in Berkeley Jets, prejudicial abuse of discretion occurs if the failure to include relevant information precludes informed decision- making and informed public participation, thereby thwarting the statutory goals of the EIR process. 91 Cal.App.4th at p. 1355 ( internal quotations omitted).

The preparation and circulation of an EIR is more than a set of technical hurdles for agencies and developers to overcome. Communities for a Better Environment v. Richmond 2010) 184 Cal.App.4th 70, 80 (quoting Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho Cordova (2007) 40 Cal.4th 412, 449- 450). The EIR’s function is to ensure that government officials who decide to build or approve a project do so with a full understanding of the environmental consequences and, equally important, that the public is assured those consequences have been considered. Id. For the EIR to serve these goals it must present information so that the foreseeable impacts of pursuing the project can be understood and weighed, and the public must be given an adequate opportunity to comment on that presentation before the decision to go forward is made. Id.

A strong presumption in favor of requiring preparation of an EIR is built into CEQA.

This presumption is reflected in what is known as the “ fair argument” standard under which an EIR must be prepared whenever substantial evidence in the record supports a fair argument that a project may have a significant effect on the environment. Quail Botanical Gardens Found., Inc. v. City of Encinitas (1994) 29 Cal.App.4th 1597, 1602; Friends of “ B” St. v. City of Hayward ( 1980) 106 Cal.3d 988, 1002.

The fair argument test stems from the statutory mandate that an EIR be prepared for any project that “ may have a significant effect on the environment.” PRC, § 21151; see No Oil, Inc. v. City of Los Angeles (1974) 13 Cal.App.3d 68, 75; accord Jensen v. City of Santa Rosa ( 2018) 23 Cal.App.5th 877, 884. Under this test, if a proposed project is not City of Anaheim – La Quinta Inn & Suites
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exempt and may cause a significant effect on the environment, the lead agency must prepare an EIR. PRC, §§ 21100 (a), 21151; CEQA Guidelines, § 15064 (a)(1), (f)(1).

An EIR may be dispensed with only if the lead agency finds no substantial evidence in the initial study or elsewhere in the record that the project may have a significant effect on the environment. Parker Shattuck Neighbors v. Berkeley City Council (2013) 222 Cal.App.4th 768, 785. In such a situation, the agency must adopt a negative declaration. PRC, § 21080, subd. (c)(1); CEQA Guidelines, §§ 15063 (b)(2), 15064(f)(3).

Significant effect upon the environment” is defined as “ a substantial or potentially substantial adverse change in the environment.” PRC, § 21068; CEQA Guidelines, 15382. A project may have a significant effect on the environment if there is a reasonable probability that it will result in a significant impact. No Oil, Inc., 13 Cal.3d at p. 83 fn. 16; see Sundstrom v. County of Mendocino ( 1988) 202 Cal.App.3d 296, 309. If any aspect of the project may result in a significant impact on the environment, an EIR must be prepared even if the overall effect of the project is beneficial. CEQA Guidelines, § 15063(b)(1); see County Sanitation Dist. No. 2 v. County of Kern (2005) 127 Cal.App.4th 1544, 1580.

This standard sets a “ low threshold” for preparation of an EIR. Consolidated Irrigation Dist. v. City of Selma (2012) 204 Cal.App.4th 187, 207; Nelson v. County of Kern (2010) 190 Cal.App.4th 252; Pocket Protectors v. City of Sacramento ( 2004) 124 Cal.App.4th 903, 928; Bowman v. City of Berkeley (2004) 122 Cal.App.4th 572, 580; Citizen Action to Serve All Students v. Thornley (1990) 222 Cal.App.3d 748, 754; Sundstrom, 202 Cal.App.3d at p. 310. If substantial evidence in the record supports a fair argument that the project may have a significant environmental effect, the lead agency must prepare an EIR even if other substantial evidence before it indicates the project will have no significant effect. See Jensen, 23 Cal.App.5th at p. 886; Clews Land & Livestock v. City of San Diego (2017) 19 Cal.App.5th 161, 183; Stanislaus Audubon Society, Inc. v. County of Stanislaus ( 1995) 33 Cal.App.4th 144, 150; Brentwood Assn. for No Drilling, Inc. v. City of Los Angeles (1982) 134 Cal.App.3d 491; Friends of “ B” St., 106 Cal.App.3d 988; CEQA Guidelines, § 15064(f)(1).

2. Background Concerning Initial Studies, Negative Declarations and Mitigated Negative Declarations
CEQA and CEQA Guidelines are strict and unambiguous about when an MND may be used. A public agency must prepare an EIR whenever substantial evidence supports City of Anaheim – La Quinta Inn & Suites
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a “ fair argument” that a proposed project “ may have a significant effect on the environment.” Pub. Res. Code, §§ 21100, 21151; CEQA Guidelines, §§ 15002, subds. f)(1)-(2), 15063; No Oil, Inc., 13 Cal.3d at p. 75; Communities for a Better Environment v.

California Resources Agency ( 2002) 103 Cal.App.4th 98, 111-112. Essentially, should a lead agency be presented with a fair argument that a project may have a significant effect on the environment, the lead agency shall prepare an EIR even though it may also be presented with other substantial evidence that the project will not have a significant effect. CEQA Guidelines, §§ 15064, subds. (f)(1)-(2); see No Oil Inc., supra, 13 Cal.3d at p. 75 (internal citations and quotations omitted). Substantial evidence includes “ enough relevant information and reasonable inferences from this information that a fair argument can be made to support a conclusion, even though other conclusions might also be reached.” CEQA Guidelines, § 15384(a).

The fair argument standard is a “ low threshold” test for requiring the preparation of an EIR. No Oil Inc., supra, 13 Cal.3d at p. 84; County Sanitation Dist. No. 2 of Los Angeles County v. County of Kern (2005) 127 Cal.App.4th 1544, 1579. It “requires the preparation of an EIR where there is substantial evidence that any aspect of the project, either individually or cumulatively, may cause a significant effect on the environment, regardless of whether the overall effect of the project is adverse or beneficial[.]” County Sanitation, supra, 127 Cal.App.4th at p. 1580 (quoting CEQA Guidelines, § 15063(b)(1)).

A lead agency may adopt an MND only if “there is no substantial evidence that the project will have a significant effect on the environment.” CEQA Guidelines, § 15074( b).

Evidence supporting a fair argument of a significant environmental impact triggers preparation of an EIR regardless of whether the record contains contrary evidence.

League for Protection of Oakland’s Architectural and Historical Resources v. City of Oakland 1997) 52 Cal.App.4th 896, 904- 905. “ Where the question is the sufficiency of the evidence to support a fair argument, deference to the agency’s determination is not appropriate[.]” County Sanitation, 127 Cal.App.4th at 1579 (quoting Sierra Club v. County of Sonoma ( 1992) 6 Cal.App.4th 1307, 1317-1318).

Further, it is the duty of the lead agency, not the public, to conduct the proper environmental studies. “ The agency should not be allowed to hide behind its own failure to gather relevant data.” Sundstrom, 202 Cal.App.3d at p. 311. “ Deficiencies in the record may actually enlarge the scope of fair argument by lending a logical plausibility to a wider range of inferences.” Id; see also Gentry v. City of Murrieta (1995) City of Anaheim – La Quinta Inn & Suites
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36 Cal.App.4th 1359, 1382 (lack of study enlarges the scope of the fair argument which may be made based on the limited facts in the record).

Thus, refusal to complete recommended studies lowers the already low threshold to establish a fair argument. The court may not exercise its independent judgment on the omitted material by determining whether the ultimate decision of the lead agency would have been affected had the law been followed. Environmental Protection Information Center v. Cal. Dept. of Forestry (2008) 44 Cal.4th 459, 486 (internal citations and quotations omitted). The remedy for this deficiency would be for the trial court to issue a writ of mandate. Id.

Both the review for failure to follow CEQA’s procedures and the fair argument test are questions of law, thus, the de novo standard of review applies. Vineyard Area Citizens for Responsible Growth v. City of Rancho Cordova ( 2007) 40 Cal.4th 412, 435.

Whether the agency’ s record contains substantial evidence that would support a fair argument that the project may have a significant effect on the environment is treated as a question of law. Consolidated Irrigation Dist., 204 Cal.App.4th at p. 207; Kostka and Zischke, Practice Under the Environmental Quality Act (2017, 2d ed.) at § 6.76.

In an MND context, courts give no deference to the agency. Additionally, the agency or the court should not weigh expert testimony or decide on the credibility of such evidence— this is one of the EIR’s responsibilities. As stated in Pocket Protectors v. City of Sacramento:

Unlike the situation where an EIR has been prepared, neither the lead agency nor a court may “ weigh” conflicting substantial evidence to determine whether an EIR must be prepared in the first instance.

Guidelines section 15064, subdivision (f)(1) provides in pertinent part: if a lead agency is presented with a fair argument that a project may have a significant effect on the environment, the lead agency shall prepare an EIR even though it may also be presented with other substantial evidence that the project will not have a significant effect. Thus, as Claremont itself recognized, [ c]onsideration is not to be given contrary evidence supporting the preparation of a negative declaration.
2004) 124 Cal.App.4th 903, 935 (internal citations and quotations omitted).

In cases where it is not clear whether there is substantial evidence of significant environmental impacts, CEQA requires erring on the side of a “ preference for City of Anaheim – La Quinta Inn & Suites
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resolving doubts in favor of environmental review.” Mejia v. City of Los Angeles ( 2005) 130 Cal.App.4th 322, 332 “ The foremost principle under CEQA is that the Legislature intended the act to be interpreted in such manner as to afford the fullest possible protection to the environment within the reasonable scope of the statutory language. Friends of Mammoth v. Board of Supervisors ( 1972) 8 Cal.3d 247, 259.

A. There is a Fair Argument that the Project Will Have a Significant Transportation Impact
There is a fair argument that the Project will have a significant transportation impact.

As a preliminary matter, the IS/ MND states that the “Project would generate 135 new AM peak hour trips, 101 new PM peak hour trips, and 1,317 new weekday daily trips Iteris 2022a).” IS/ MND, 5-20. Even further, given the Project’s proposed intensive use which will include a 67,715-square-foot, 120-room hotel, a 1,200-square-foot walkup and drive-thru fast-food restaurant, and associated parking to be constructed at the Project Site which is currently occupied by a vacant, 10,530-square-foot commercial building, this further suggests the Project will have a significant transportation impact.

In the IS/ MND’s Question B Transportation analysis of whether the project would conflict or be inconsistent with CEQA Guidelines section 15064. 3, subdivision ( b), the IS/ MND analyzes the Type 1: Transit Priority Area (“ TPA”) Screening threshold.

IS/ MND, supra, at p. 5-76. Per the Transportation analysis, The City Guidelines states that a presumption of less than significant impact would not apply if various factors are true, including if the Project has a Floor Area Ratio (“ FAR”) of less than 0.75.

Thus, the Transportation analysis concludes that “ the Proposed Project’ s FAR is 0.98, so the FAR exceeds 0.75.” Id. More recently, the FAR has been revised to 1.08.

However, the Project Applicant is seeking the City’ s approval of, among other things, a Conditional Use Permit (“ CUP”) to allow for a Floor Area Ratio (FAR) greater than permitted by the Zoning Code ( 1.08 proposed, 0.50 permitted). Meaning, at the time of the VMT-screening analysis was performed, a FAR greater than 0.50 was not permitted.

Relying upon a proposed FAR that must be approved via the CUP is insufficient to conclude that the Project can be screened out of the VMT analysis.

Based on the foregoing, the City should require that a VMT analysis be conducted that adequately assesses the Project’s potential transportation analysis, and the IS/ MND should be revised and recirculated accordingly.

B. There is a Fair Argument that the Project Will Have a Significant Waste City of Anaheim – La Quinta Inn & Suites
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Impact
There is a fair argument that the Project will have a significant waste impact. The IS/ MND calculates the solid waste generation rate for the project as 4 pounds per hotel room per day of hotel use, approximately 480 pounds of solid waste per day.

IS/ MND, 5-84. However, the rate calculation in the IS/ MND is flawed as it ignores the waste that would be generated by the Project’s fast-food restaurant. According to CalRecycle, fast-food restaurants generate waste at a rate of 17 pounds per employee per day.9 The inclusion of the fast-food waste rate would dramatically increase the estimated daily rate of waste produced by the project.

The City should require that the IS/ MND be revised and recirculated with an updated solid waste rate calculation and review of landfill capacity.

C. The Mitigation Monitoring and Reporting Program is Insufficient

1. Air Quality Impact
The IS/ MND notes that construction emissions were calculated with the incorporation of various construction rules such as SCAQMD Rule 403, Fugitive Dust. IS/ MND, 5-18. Yet, no project-level mitigation measures, such as those recommended by SCAG, the CARB, SCAQMD, and CAPCOA, are included in the Mitigation Monitoring and Reporting Program (“ MMRP”). Any assumptions made during the evaluation of the emissions must be incorporated into the MMRP. Without revision, the IS/ MND’s analysis of any potential air quality impacts is flawed.

Based on the foregoing, the City should revise the MMRP to include the mitigation measures used in the IS/ MND analysis, or revise and recirculate the IS/ MND with an accurate air quality impact analysis.

2. Rideshare Program
The IS/ MND also states that the developer intends to include rideshare and vanpooling opportunities for employees and patrons. IS/ MND, 5-75. However, the opportunities” are not explained in detail. Any such effect the programs may have on transportation have not been analyzed, nor is any monitoring proposed in the MMRP.

Indeed, the project fails to even establish how the “ opportunities” will satisfy the requirements established under Anaheim Municipal Code Chapter 14.60. 9 CalRecycle, Estimated Solid Waste Generation Rate (2013), available at https:// www2.calrecycle.ca.gov/ WasteCharacterization/ General/ Rates City of Anaheim – La Quinta Inn & Suites
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As such, the MMRP must be revised to establish a monitoring program for the proposed rideshare opportunities and compliance with Anaheim Municipal Code.

IV. CONCLUSION
Based on the foregoing, the City should reject the Planning Commission’s recommendation and require an Environmental Impact Report for the Project since there is a fair argument that the Project will result in significant environmental impacts.

Sincerely,
Grace Holbrook, Esq.

Attorneys for Western States
Regional Council of Carpenters
Attached:

March 8, 2021 SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and Considerations for Greenhouse Gas Modeling (Exhibit A); Air Quality and GHG Expert Paul Rosenfeld CV (Exhibit B); and Air Quality and GHG Expert Matt Hagemann CV (Exhibit C).

EXHIBIT A
1 2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C. Hg.
949) 887- 9013
mhagemann@swape. com
Paul E. Rosenfeld, PhD
310) 795- 2335
prosenfeld@swape. com
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.” 1CalEEMod quantifies construction- related emissions associated with land use projects resulting from off-road construction equipment; on-road mobile equipment associated with workers, vendors, and hauling; fugitive dust associated with grading, demolition, truck loading, and on-road vehicles traveling along paved and unpaved roads; and architectural coating activities; and paving. 2
The number, length, and vehicle class of worker trips are utilized by CalEEMod to calculate emissions associated with the on-road vehicle trips required to transport workers to and from the Project site during construction. 3 1 “ California Emissions Estimator Model.” CAPCOA, 2017, available at: http:// www. aqmd. gov/ caleemod/ home. 2 “ California Emissions Estimator Model.” CAPCOA, 2017, available at: http:// www. aqmd. gov/ caleemod/ home. 3 “ CalEEMod User’ s Guide.” CAPCOA, November 2017, available at: http:// www. aqmd. gov/ docs/ defaultsource/ caleemod/ 01_user- 39-s-guide2016- 3-2_15november2017. pdf?sfvrsn= 4, p. 34. 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 = Average Daily Trip Rate i * Average Overall Trip Length i) n Where:
n = Number of land uses being modeled.” 5
Furthermore, to calculate the on-road emissions associated with worker trips, CalEEMod utilizes the following equation ( see excerpt below):

Emissionspollutant = VMT * EFrunning, pollutant
Where:

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

Default Worker Trip Parameters and Potential Local Hire Requirements As previously discussed, the number, length, and vehicle class of worker trips are utilized by CalEEMod to calculate emissions associated with the on-road vehicle trips required to transport workers to and from the Project site during construction. 7In order to understand how local hire requirements and associated worker trip length reductions impact GHG emissions calculations, it is important to consider the CalEEMod default worker trip parameters. CalEEMod provides recommended default values based on site- specific information, such as land use type, meteorological data, total lot acreage, project type and typical equipment associated with project type. If more specific project information is known, the user can change the default values and input projectspecific values, but the California Environmental Quality Act (“ CEQA”) requires that such changes be justified by substantial evidence. 8The default number of construction- related worker trips is calculated by multiplying the 4 “ Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http:// www. aqmd. gov/ docs/ defaultsource/ caleemod/ 02_appendix- a2016- 3-2.pdf?sfvrsn= 6, p. 14-15. 5 “ Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http:// www. aqmd. gov/ docs/ defaultsource/ caleemod/ 02_appendix- a2016- 3-2.pdf?sfvrsn= 6, p. 23. 6 “ Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http:// www. aqmd. gov/ docs/ defaultsource/ caleemod/ 02_appendix- a2016- 3-2.pdf?sfvrsn= 6, p. 15. 7 “ CalEEMod User’ s Guide.” CAPCOA, November 2017, available at: http:// www. aqmd. gov/ docs/ defaultsource/ caleemod/ 01_user- 39-s-guide2016- 3-2_15november2017. pdf?sfvrsn= 4, p. 34. 8 CalEEMod User Guide, available at: http:// www. caleemod. com/, p. 1, 9. 3 number of pieces of equipment for all phases by 1.25, with the exception of worker trips required for the building construction and architectural coating phases. 9Furthermore, the worker trip vehicle class is a 50/ 25/ 25 percent mix of light duty autos, light duty truck class 1 and light duty truck class 2, respectively.” 10 Finally, the default worker trip length is consistent with the length of the operational home-to-work vehicle trips.11 The operational home- to-work vehicle trip lengths are:

B]ased on the location and urbanization selected on the project characteristic screen. These values were supplied by the air districts or use a default average for the state. Each district ( or county) also assigns trip lengths for urban and rural settings” ( emphasis added). 12 Thus, the default worker trip length is based on the location and urbanization level selected by the User when modeling emissions. The below table shows the CalEEMod default rural and urban worker trip lengths by air basin (see excerpt below and Attachment A).13
Worker Trip Length by Air Basin
Air Basin Rural ( miles) Urban ( miles)
Great Basin Valleys 16.8 10.8
Lake County 16.8 10.8
Lake Tahoe 16.8 10.8
Mojave Desert 16.8 10.8
Mountain Counties 16.8 10.8
North Central Coast 17.1 12.3
North Coast 16.8 10.8
Northeast Plateau 16.8 10.8
Sacramento Valley 16.8 10.8
Salton Sea 14.6 11
San Diego 16.8 10.8
San Francisco Bay Area 10.8 10.8
San Joaquin Valley 16.8 10.8
South Central Coast 16.8 10.8
South Coast 19.8 14.7
Average 16.47 11.17
Minimum 10.80 10.80
Maximum 19.80 14.70
Range 9.00 3.90
9 “ CalEEMod User’ s Guide.” CAPCOA, November 2017, available at: http:// www. aqmd. gov/ docs/ defaultsource/ caleemod/ 01_user- 39-s-guide2016- 3-2_15november2017. pdf?sfvrsn= 4, p. 34. 10 “ Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at:
http:// www. aqmd. gov/ docs/ default- source/ caleemod/ 02_ appendix- a2016- 3-2.pdf?sfvrsn= 6, p. 15. 11 “ Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at:
http:// www. aqmd. gov/ docs/ default- source/ caleemod/ 02_ appendix- a2016- 3-2.pdf?sfvrsn= 6, p. 14. 12 “ Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at:
http:// www. aqmd. gov/ docs/ default- source/ caleemod/ 02_appendix- a2016- 3-2.pdf?sfvrsn= 6, p. 21. 13 “ Appendix D Default Data Tables.” CAPCOA, October 2017, available at: http:// www. aqmd. gov/ docs/ defaultsource/ caleemod/ 05_appendix- d2016- 3-2.pdf?sfvrsn= 4, p. D-84 – D-86. 4 As demonstrated above, default rural worker trip lengths for air basins in California vary from 10.8- to 19.8- miles, with an average of 16.47 miles. Furthermore, default urban worker trip lengths vary from 10.8- to 14.7- miles, with an average of 11.17 miles. Thus, while default worker trip lengths vary by location, default urban worker trip lengths tend to be shorter in length. Based on these trends evident in the CalEEMod default worker trip lengths, we can reasonably assume that the efficacy of a local hire requirement is especially dependent upon the urbanization of the project site, as well as the project location.

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

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

This serves as an example of the potential impacts of local hire requirements on estimated project-level GHG emissions, though it does not indicate that local hire requirements would result in reduced construction- related GHG emission for all projects. As previously described, the significance of a local hire requirement depends on the worker trip length enforced and the default worker trip length for the project’ s urbanization level and location.
14 “ Appendix D Default Data Tables.” CAPCOA, October 2017, available at: http:// www. aqmd. gov/ docs/ defaultsource/ caleemod/ 05_appendix- d2016- 3-2.pdf?sfvrsn= 4, p. D-85. 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) 2.2 Precipitation Freq (Days) 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 029CH4 Intensity 0.
lb/MWhr)
006N2O Intensity 0.
lb/MWhr)
Village South Specific Plan ( Proposed)
Los Angeles- South Coast County, Annual
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 1 of 44 Date: 1/6/2021 1:52 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
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2.0 Emissions Summary
tblVehicleTrips SU_TR 5.95 3.20
tblVehicleTrips SU_TR 72.16 57.65
tblVehicleTrips SU_TR 25.24 6.39
tblVehicleTrips WD_TR 6.59 5.83
tblVehicleTrips WD_TR 6.65 4.13
tblVehicleTrips WD_TR 11.03 6.41
tblVehicleTrips WD_TR 127.15 65.80
tblVehicleTrips WD_TR 8.17 3.84
tblVehicleTrips WD_TR 89.95 62.64
tblVehicleTrips WD_TR 42.70 9.43
tblWoodstoves NumberCatalytic 1.25 0.00
tblWoodstoves NumberCatalytic 48.75 0.00
tblWoodstoves NumberNoncatalytic 1.25 0.00
tblWoodstoves NumberNoncatalytic 48.75 0.00
tblWoodstoves WoodstoveDayYear 25.00 0.00
tblWoodstoves WoodstoveDayYear 25.00 0.00
tblWoodstoves WoodstoveWoodMass 999.60 0.00
tblWoodstoves WoodstoveWoodMass 999.60 0.00
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 3 of 44 Date: 1/6/2021 1:52 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 2.4000e0030.4169 0.0817 0.4986 0.1795 0.0754 0.2549 0.0000 213.1969 213.1969 0.0601 0.0000 214.6993 2022 0.6904 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721.682 6 1,721.682
6 0.1294 0.0000 1,724.918
7 2023 0.6148 3.3649 5.6747 0.0178 1.1963 0.0996 1.2959 0.3203 0.0935 0.4138 0.0000 1,627.529 5 1,627.529
5 0.1185 0.0000 1,630.492
5 2024 4.1619 0.1335 0.2810 5.9000e0040.0325 6.4700e0030.0390 8.6300e0036.0400e0030.0147 0.0000 52.9078 52.9078 8.0200e0030.0000 53.1082 Maximum 4.1619 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721.682 6 1,721.682
6 0.1294 0.0000 1,724.918
7 Unmitigated Construction
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 4 of 44 Date: 1/6/2021 1:52 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 2.4000e0030.4169 0.0817 0.4986 0.1795 0.0754 0.2549 0.0000 213.1967 213.1967 0.0601 0.0000 214.6991 2022 0.6904 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721.682 3 1,721.682
3 0.1294 0.0000 1,724.918
3 2023 0.6148 3.3648 5.6747 0.0178 1.1963 0.0996 1.2959 0.3203 0.0935 0.4138 0.0000 1,627.529 1 1,627.529
1 0.1185 0.0000 1,630.492
1 2024 4.1619 0.1335 0.2810 5.9000e0040.0325 6.4700e0030.0390 8.6300e0036.0400e0030.0147 0.0000 52.9077 52.9077 8.0200e0030.0000 53.1082 Maximum 4.1619 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721.682 3 1,721.682
3 0.1294 0.0000 1,724.918
3 Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

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

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

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CalEEMod Version: CalEEMod. 2016.3.2 PMPage 7 of 44 Date: 1/6/2021 1:52 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 PMPage 8 of 44 Date: 1/6/2021 1:52 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 PMPage 9 of 44 Date: 1/6/2021 1:52 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 7.5100e0030.0000 7.5100e0030.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0475 0.4716 0.3235 5.8000e0040.0233 0.0233 0.0216 0.0216 0.0000 51.0012 51.0012 0.0144 0.0000 51.3601 Total 0.0475 0.4716 0.3235 5.8000e0040.0496 0.0233 0.0729 7.5100e0030.0216 0.0291 0.0000 51.0012 51.0012 0.0144 0.0000 51.3601 Unmitigated Construction On-Site

3.1 Mitigation Measures Construction
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Demolition 6 15.00 0.00 458.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Site Preparation 7 18.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Grading 8 20.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Building Construction 9 801.00 143.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Paving 6 15.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Architectural Coating 1 160.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod. 2016.3.2 PMPage 10 of 44 Date: 1/6/2021 1:52 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 1.9300e0030.0634 0.0148 1.8000e0043.9400e0031.9000e0044.1300e0031.0800e0031.8000e0041.2600e0030.0000 17.4566 17.4566 1.2100e0030.0000 17.4869 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 9.7000e0047.5000e0048.5100e0032.0000e0052.4700e0032.0000e0052.4900e0036.5000e0042.0000e0056.7000e0040.0000 2.2251 2.2251 7.0000e0050.0000 2.2267 Total 2.9000e0030.0641 0.0233 2.0000e0046.4100e0032.1000e0046.6200e0031.7300e0032.0000e0041.9300e0030.0000 19.6816 19.6816 1.2800e0030.0000 19.7136 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0496 0.0000 0.0496 7.5100e0030.0000 7.5100e0030.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0475 0.4716 0.3235 5.8000e0040.0233 0.0233 0.0216 0.0216 0.0000 51.0011 51.0011 0.0144 0.0000 51.3600 Total 0.0475 0.4716 0.3235 5.8000e0040.0496 0.0233 0.0729 7.5100e0030.0216 0.0291 0.0000 51.0011 51.0011 0.0144 0.0000 51.3600 Mitigated Construction On-Site
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 11 of 44 Date: 1/6/2021 1:52 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 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 7.7000e0046.0000e0046.8100e0032.0000e0051.9700e0032.0000e0051.9900e0035.2000e0041.0000e0055.4000e0040.0000 1.7801 1.7801 5.0000e0050.0000 1.7814 Total 7.7000e0046.0000e0046.8100e0032.0000e0051.9700e0032.0000e0051.9900e0035.2000e0041.0000e0055.4000e0040.0000 1.7801 1.7801 5.0000e0050.0000 1.7814 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.1807 0.0000 0.1807 0.0993 0.0000 0.0993 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0389 0.4050 0.2115 3.8000e0040.0204 0.0204 0.0188 0.0188 0.0000 33.4357 33.4357 0.0108 0.0000 33.7060 Total 0.0389 0.4050 0.2115 3.8000e0040.1807 0.0204 0.2011 0.0993 0.0188 0.1181 0.0000 33.4357 33.4357 0.0108 0.0000 33.7060 Mitigated Construction On-Site
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 13 of 44 Date: 1/6/2021 1:52 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
Fugitive Dust 0.1741 0.0000 0.1741 0.0693 0.0000 0.0693 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0796 0.8816 0.5867 1.1800e0030.0377 0.0377 0.0347 0.0347 0.0000 103.5405 103.5405 0.0335 0.0000 104.3776 Total 0.0796 0.8816 0.5867 1.1800e0030.1741 0.0377 0.2118 0.0693 0.0347 0.1040 0.0000 103.5405 103.5405 0.0335 0.0000 104.3776 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 14 of 44 Date: 1/6/2021 1:52 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 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 1.6400e0031.2700e0030.0144 4.0000e0054.1600e0033.0000e0054.2000e0031.1100e0033.0000e0051.1400e0030.0000 3.7579 3.7579 1.1000e0040.0000 3.7607 Total 1.6400e0031.2700e0030.0144 4.0000e0054.1600e0033.0000e0054.2000e0031.1100e0033.0000e0051.1400e0030.0000 3.7579 3.7579 1.1000e0040.0000 3.7607 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.1741 0.0000 0.1741 0.0693 0.0000 0.0693 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0796 0.8816 0.5867 1.1800e0030.0377 0.0377 0.0347 0.0347 0.0000 103.5403 103.5403 0.0335 0.0000 104.3775 Total 0.0796 0.8816 0.5867 1.1800e0030.1741 0.0377 0.2118 0.0693 0.0347 0.1040 0.0000 103.5403 103.5403 0.0335 0.0000 104.3775 Mitigated Construction On-Site
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 15 of 44 Date: 1/6/2021 1:52 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
Fugitive Dust 0.0807 0.0000 0.0807 0.0180 0.0000 0.0180 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0127 0.1360 0.1017 2.2000e0045.7200e0035.7200e0035.2600e0035.2600e0030.0000 19.0871 19.0871 6.1700e0030.0000 19.2414 Total 0.0127 0.1360 0.1017 2.2000e0040.0807 5.7200e0030.0865 0.0180 5.2600e0030.0233 0.0000 19.0871 19.0871 6.1700e0030.0000 19.2414 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 16 of 44 Date: 1/6/2021 1:52 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 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 2.8000e0042.1000e0042.4400e0031.0000e0057.7000e0041.0000e0057.7000e0042.0000e0041.0000e0052.1000e0040.0000 0.6679 0.6679 2.0000e0050.0000 0.6684 Total 2.8000e0042.1000e0042.4400e0031.0000e0057.7000e0041.0000e0057.7000e0042.0000e0041.0000e0052.1000e0040.0000 0.6679 0.6679 2.0000e0050.0000 0.6684 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0807 0.0000 0.0807 0.0180 0.0000 0.0180 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0127 0.1360 0.1017 2.2000e0045.7200e0035.7200e0035.2600e0035.2600e0030.0000 19.0871 19.0871 6.1700e0030.0000 19.2414 Total 0.0127 0.1360 0.1017 2.2000e0040.0807 5.7200e0030.0865 0.0180 5.2600e0030.0233 0.0000 19.0871 19.0871 6.1700e0030.0000 19.2414 Mitigated Construction On-Site
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 17 of 44 Date: 1/6/2021 1:52 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
Off-Road 0.2158 1.9754 2.0700 3.4100e0030.1023 0.1023 0.0963 0.0963 0.0000 293.1324 293.1324 0.0702 0.0000 294.8881 Total 0.2158 1.9754 2.0700 3.4100e0030.1023 0.1023 0.0963 0.0963 0.0000 293.1324 293.1324 0.0702 0.0000 294.8881 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 18 of 44 Date: 1/6/2021 1:52 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 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0527 1.6961 0.4580 4.5500e0030.1140 3.1800e0030.1171 0.0329 3.0400e0030.0359 0.0000 441.9835 441.9835 0.0264 0.0000 442.6435 Worker 0.4088 0.3066 3.5305 0.0107 1.1103 8.8700e0031.1192 0.2949 8.1700e0030.3031 0.0000 966.8117 966.8117 0.0266 0.0000 967.4773 Total 0.4616 2.0027 3.9885 0.0152 1.2243 0.0121 1.2363 0.3278 0.0112 0.3390 0.0000 1,408.795 2 1,408.795
2 0.0530 0.0000 1,410.120
8 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.2158 1.9754 2.0700 3.4100e0030.1023 0.1023 0.0963 0.0963 0.0000 293.1321 293.1321 0.0702 0.0000 294.8877 Total 0.2158 1.9754 2.0700 3.4100e0030.1023 0.1023 0.0963 0.0963 0.0000 293.1321 293.1321 0.0702 0.0000 294.8877 Mitigated Construction On-Site
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 19 of 44 Date: 1/6/2021 1:52 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
Off-Road 0.1942 1.7765 2.0061 3.3300e0030.0864 0.0864 0.0813 0.0813 0.0000 286.2789 286.2789 0.0681 0.0000 287.9814 Total 0.1942 1.7765 2.0061 3.3300e0030.0864 0.0864 0.0813 0.0813 0.0000 286.2789 286.2789 0.0681 0.0000 287.9814 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 20 of 44 Date: 1/6/2021 1:52 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 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0382 1.2511 0.4011 4.3000e0030.1113 1.4600e0030.1127 0.0321 1.4000e0030.0335 0.0000 417.9930 417.9930 0.0228 0.0000 418.5624 Worker 0.3753 0.2708 3.1696 0.0101 1.0840 8.4100e0031.0924 0.2879 7.7400e0030.2957 0.0000 909.3439 909.3439 0.0234 0.0000 909.9291 Total 0.4135 1.5218 3.5707 0.0144 1.1953 9.8700e0031.2051 0.3200 9.1400e0030.3292 0.0000 1,327.336 9 1,327.336
9 0.0462 0.0000 1,328.491
6 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.1942 1.7765 2.0061 3.3300e0030.0864 0.0864 0.0813 0.0813 0.0000 286.2785 286.2785 0.0681 0.0000 287.9811 Total 0.1942 1.7765 2.0061 3.3300e0030.0864 0.0864 0.0813 0.0813 0.0000 286.2785 286.2785 0.0681 0.0000 287.9811 Mitigated Construction On-Site
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 21 of 44 Date: 1/6/2021 1:52 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
Off-Road 6.7100e0030.0663 0.0948 1.5000e0043.3200e0033.3200e0033.0500e0033.0500e0030.0000 13.0175 13.0175 4.2100e0030.0000 13.1227 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 6.7100e0030.0663 0.0948 1.5000e0043.3200e0033.3200e0033.0500e0033.0500e0030.0000 13.0175 13.0175 4.2100e0030.0000 13.1227 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 22 of 44 Date: 1/6/2021 1:52 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 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 3.7000e0042.7000e0043.1200e0031.0000e0051.0700e0031.0000e0051.0800e0032.8000e0041.0000e0052.9000e0040.0000 0.8963 0.8963 2.0000e0050.0000 0.8968 Total 3.7000e0042.7000e0043.1200e0031.0000e0051.0700e0031.0000e0051.0800e0032.8000e0041.0000e0052.9000e0040.0000 0.8963 0.8963 2.0000e0050.0000 0.8968 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 6.7100e0030.0663 0.0948 1.5000e0043.3200e0033.3200e0033.0500e0033.0500e0030.0000 13.0175 13.0175 4.2100e0030.0000 13.1227 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 6.7100e0030.0663 0.0948 1.5000e0043.3200e0033.3200e0033.0500e0033.0500e0030.0000 13.0175 13.0175 4.2100e0030.0000 13.1227 Mitigated Construction On-Site
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 23 of 44 Date: 1/6/2021 1:52 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
Off-Road 0.0109 0.1048 0.1609 2.5000e0045.1500e0035.1500e0034.7400e0034.7400e0030.0000 22.0292 22.0292 7.1200e0030.0000 22.2073 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0109 0.1048 0.1609 2.5000e0045.1500e0035.1500e0034.7400e0034.7400e0030.0000 22.0292 22.0292 7.1200e0030.0000 22.2073 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 24 of 44 Date: 1/6/2021 1:52 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 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 5.9000e0044.1000e0044.9200e0032.0000e0051.8100e0031.0000e0051.8200e0034.8000e0041.0000e0054.9000e0040.0000 1.4697 1.4697 4.0000e0050.0000 1.4706 Total 5.9000e0044.1000e0044.9200e0032.0000e0051.8100e0031.0000e0051.8200e0034.8000e0041.0000e0054.9000e0040.0000 1.4697 1.4697 4.0000e0050.0000 1.4706 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0109 0.1048 0.1609 2.5000e0045.1500e0035.1500e0034.7400e0034.7400e0030.0000 22.0292 22.0292 7.1200e0030.0000 22.2073 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0109 0.1048 0.1609 2.5000e0045.1500e0035.1500e0034.7400e0034.7400e0030.0000 22.0292 22.0292 7.1200e0030.0000 22.2073 Mitigated Construction On-Site
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 25 of 44 Date: 1/6/2021 1:52 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 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0101 6.9900e0030.0835 2.8000e0040.0307 2.3000e0040.0309 8.1500e0032.2000e0048.3700e0030.0000 24.9407 24.9407 6.1000e0040.0000 24.9558 Total 0.0101 6.9900e0030.0835 2.8000e0040.0307 2.3000e0040.0309 8.1500e0032.2000e0048.3700e0030.0000 24.9407 24.9407 6.1000e0040.0000 24.9558 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Archit. Coating 4.1372 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 3.1600e0030.0213 0.0317 5.0000e0051.0700e0031.0700e0031.0700e0031.0700e0030.0000 4.4682 4.4682 2.5000e0040.0000 4.4745 Total 4.1404 0.0213 0.0317 5.0000e0051.0700e0031.0700e0031.0700e0031.0700e0030.0000 4.4682 4.4682 2.5000e0040.0000 4.4745 Mitigated Construction On-Site
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 27 of 44 Date: 1/6/2021 1:52 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 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0101 6.9900e0030.0835 2.8000e0040.0307 2.3000e0040.0309 8.1500e0032.2000e0048.3700e0030.0000 24.9407 24.9407 6.1000e0040.0000 24.9558 Total 0.0101 6.9900e0030.0835 2.8000e0040.0307 2.3000e0040.0309 8.1500e0032.2000e0048.3700e0030.0000 24.9407 24.9407 6.1000e0040.0000 24.9558 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 28 of 44 Date: 1/6/2021 1:52 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 PMPage 29 of 44 Date: 1/6/2021 1:52 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 PMPage 30 of 44 Date: 1/6/2021 1:52 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 0.0000 0.0000 0.0000 2,512.646
5 2,512.646
5 0.1037 0.0215 2,521.635
6 Electricity
Unmitigated

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

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

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

1.30613e
007

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

8.30736e
006

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

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

1.84608e
006

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

1.30613e
007

8.30736e
006

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

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

1.84608e
006

9.9500e0030.0905 0.0760 5.4000e0046.8800e0036.8800e0036.8800e0036.8800e0030.0000 98.5139 98.5139 1.8900e0031.8100e00399.0993 Regional
Shopping Center
91840 5.0000e0044.5000e0033.7800e0033.0000e0053.4000e0043.4000e0043.4000e0043.4000e0040.0000 4.9009 4.9009 9.0000e0059.0000e0054.9301 Total 0.1398 1.2312 0.7770 7.6200e0030.0966 0.0966 0.0966 0.0966 0.0000 1,383.426 8 1,383.426
8 0.0265 0.0254 1,391.647
8 Mitigated
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 33 of 44 Date: 1/6/2021 1:52 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 1.3900e0032.9000e00433.8978
Apartments Mid
Rise

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

6.1 Mitigation Measures Area

6.0 Area Detail

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

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

1.58904e
006
506.3022 0.0209 4.3200e003508.1135
Hotel 550308 175.3399 7.2400e0031.5000e003175.9672
Quality
Restaurant
353120 112.5116 4.6500e0039.6000e004112.9141
Regional
Shopping Center
756000 240.8778 9.9400e0032.0600e003241.7395
Total 2,512.646
5 0.1037 0.0215 2,521.635
6 Mitigated
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 35 of 44 Date: 1/6/2021 1:52 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 1.6700e0030.0714 0.0714 0.0714 0.0714 0.0000 220.9670 220.9670 0.0201 3.7400e003222.5835 Unmitigated 5.1437 0.2950 10.3804 1.6700e0030.0714 0.0714 0.0714 0.0714 0.0000 220.9670 220.9670 0.0201 3.7400e003222.5835

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

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

7.1 Mitigation Measures Water

7.0 Water Detail

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

4.3998 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Hearth 0.0206 0.1763 0.0750 1.1200e0030.0143 0.0143 0.0143 0.0143 0.0000 204.1166 204.1166 3.9100e0033.7400e003205.3295 Landscaping 0.3096 0.1187 10.3054 5.4000e0040.0572 0.0572 0.0572 0.0572 0.0000 16.8504 16.8504 0.0161 0.0000 17.2540 Total 5.1437 0.2950 10.3804 1.6600e0030.0714 0.0714 0.0714 0.0714 0.0000 220.9670 220.9670 0.0201 3.7400e003222.5835 Mitigated
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 37 of 44 Date: 1/6/2021 1:52 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
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 38 of 44 Date: 1/6/2021 1:52 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 1.3400e00312.6471
Apartments Mid
Rise

63.5252 /

40.0485
425.4719 2.0867 0.0523 493.2363
General Office
Building

7.99802 /

4.90201

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

10.9272 /

0.697482

51.2702 0.3580 8.8200e00362.8482
Hotel 1.26834 /

0.140927

6.1633 0.0416 1.0300e0037.5079
Quality
Restaurant

2.42827 /

0.154996

11.3934 0.0796 1.9600e00313.9663
Regional
Shopping Center

4.14806 /

2.54236

27.5250 0.1363 3.4200e00331.9490
Total 585.8052 3.0183 0.0755 683.7567
Unmitigated
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 39 of 44 Date: 1/6/2021 1:52 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 1.3400e00312.6471
Apartments Mid
Rise

63.5252 /

40.0485
425.4719 2.0867 0.0523 493.2363
General Office
Building

7.99802 /

4.90201

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

10.9272 /

0.697482

51.2702 0.3580 8.8200e00362.8482
Hotel 1.26834 /

0.140927

6.1633 0.0416 1.0300e0037.5079
Quality
Restaurant

2.42827 /

0.154996

11.3934 0.0796 1.9600e00313.9663
Regional
Shopping Center

4.14806 /

2.54236

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

8.0 Waste Detail
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 40 of 44 Date: 1/6/2021 1:52 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
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 41 of 44 Date: 1/6/2021 1:52 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
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 42 of 44 Date: 1/6/2021 1:52 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 CalEEMod Version: CalEEMod. 2016.3.2 PMPage 43 of 44 Date: 1/6/2021 1:52 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
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 44 of 44 Date: 1/6/2021 1:52 Village South Specific Plan (Proposed) - Los Angeles- South Coast County, Annual

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

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company Southern California Edison
2028Operational Year
CO2 Intensity
lb/MWhr)
702.44 029CH4 Intensity 0.
lb/MWhr)
006N2O Intensity 0.
lb/MWhr)
Village South Specific Plan ( Proposed)
Los Angeles- South Coast County, Summer
CalEEMod Version: CalEEMod. 2016.3.2 PMPage 1 of 35 Date: 1/6/2021 1:54 Village South Specific Plan (Proposed) - Los Angeles- South Coast County, Summer Project Characteristics - Consistent with the DEIR' s model.