WRITTEN PUBLIC COMMENTS RECEIVED — Beverly Hills City Council, June 3, 2025

WRITTEN PUBLIC

COMMENTS RECEIVED

Sincerely,
Jason Lewis
--
Jason Lewis
Lazer Properties, Inc.

From: Gail Gordon
To: City Clerk
Cc: Linda Lee Gordon; Roger & Linda Gordon; Gail Gordon Subject: E1
Date: Tuesday, June 3, 2025 1:04:29 PM
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Dear City Council
My family and I have owned property in Beverly Hill since the early 1960’s.

My brother and I attended the
Beverly Hills School system. So Beverly Hills is very important to us Not only as property owners but also as
former residents.

Agenda item E1 counters all that has made Beverly Hills great. These unnecessarily high buildings will forever change the foot print and elegance of our city.

These unusually high buildings take years to build. Not only are you impacting the environmental health of the city, you will be impacting the well being of the current residents particularly the health of their children. These particulates that will be created from the demolition of the buildings will become a breathing and immune system hazard.

I strongly oppose E1. Not only for the health and environmental hazards that will be created but for the exclusion of the voices of the residents of this brilliant city.

I trust you will do the right thing by voting against this problematic item E1.

Thank you in advance for your concerns of your constituents.

Sincerely
Gail Gordon, Chair, Housing Commission city of Santa Monica The Gordon Family
Gail, Roger and Linda
Sent from my iPhone=

From: Mitra Gidanian
To: City Clerk; Cindy Gordon
Subject: Permit to build a hotel
Date: Monday, June 2, 2025 3:06:39 PM
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Dear Mayor and City Council Members,
I am writing to strongly urge the city to prohibit the inclusion of hotels in any ministerial housing projects. Not only does current law appear to exclude hotels from eligibility under the builder’s remedy framework, but allowing hotels in such developments would significantly disrupt the character, safety, and livability of our residential neighborhoods. Introducing transient lodging into these projects is wholly inappropriate and inconsistent with the intent of housing legislation.

Additionally, I respectfully request that the City establish a clear and reasonable minimum unit size for all residential developments—no less than 500 square feet. This standard is essential to ensure that new housing is livable, dignified, and suitable for long-term occupancy, not merely a strategy to maximize developer yield at the community’s expense.

It is also deeply concerning that this critical meeting has been scheduled on a Jewish holiday, effectively excluding members of the Jewish community from participating in the public process. This not only undermines principles of inclusivity and equal access but also raises serious questions about the fairness and transparency of the City’s decision-making. Every resident deserves a meaningful opportunity to be heard, and this scheduling decision disregards that right.

Your leadership on these issues is essential. Please take action to protect our neighborhoods, promote equitable civic engagement, and ensure that new developments reflect the best interests of the entire community.

Sincerely,
Mitra Gidanian

from these future financial liabilities?
I strongly oppose Item E1, which would allow city staff to approve large development projects like the 26-story 8844 Burton Way tower without public hearings, architectural review, or environmental analysis. This process removes our community’s voice, threatens neighborhood character, and will worsen parking and congestion. Please protect Beverly Hills residents and require full public review for all major developments.

It is my hope that the city will find another way forward to balance development that is measured and responsible to all citizens including those who will dwell in these new developments. Given the city's improper management of complying with the state it would be the responsible and accountable thing to do. Development and change will be good for the city of Beverly Hills if it is responsibly managed and funded by all of us.

Sincerely,
Richard Goldstone
on behalf of Felice and Martin Goldstone
Richard Goldstone
The Gesher Group / CBRG Development
Real Estate Development & Investment
Rydal, PA 19046
From: Lainey Signer
To: [email protected]
Subject: Oppose item E 1 - Protect Our Neighborhood
Date: Tuesday, June 3, 2025 12:53:46 AM
Dear City Council,
I strongly oppose Item E1, which would allow city staff to approve large development projects like the 26-story 8844 Burton Way tower without public hearings, architectural review, or environmental analysis. This process removes our community’s voice, threatens neighborhood character, and will worsen parking and congestion. Please protect Beverly Hills residents and require full public review for all major developments.

Sincerely,
Helaine Signer
Beverly Hills, CA
Sent from my iPhone

P: (626) 314-3821
E: [email protected]
Mitchell M. Tsai
Law Firm
139 S. Hudson Ave., Suite 200
Pasadena, California 91101

VIA E-MAIL
June 2, 2025
City Council
City of Beverly Hills
Council Chamber
455 N. Rexford Drive
Beverly Hills, CA 90210
Ph: (310) 288-2288
Em: [email protected]
Cindy Gordon, AICP
Project Manager – Current Planning
City of Beverly Hills
455 N. Rexford Drive
Beverly Hills, CA 90210
Ph: (310) 285-1191
Em: [email protected]
RE: City Council Meeting, June 3, 2025 – Agenda Item No. E-1 Draft Ordinance for Alternative Ministerial Approval and Addendum to Housing Element Mitigated Negative Declaration Dear Mayor Nazarian, Honorable Councilmembers, Masa Alkire, and Cindy Gordon, On behalf of the Western States Regional Council of Carpenters (“Western Carpenters” or “WSRCC”), our firm is submitting these comments in connection with the City of Beverly Hills’ (“City”) June 3, 2025, City Council Meeting concerning the City’s proposed Draft Ordinance Amending the Beverly Hills Municipal Code to Establish an Alternative Ministerial Approval Housing Development Overlay Zone for Projects Subject to Government Code Section 65589.5, and Adopting an Addendum to the Mitigated Negative Declaration Prepared for the 2021-2029 City of Beverly Hills Housing Elements (“Ordinance”).

The Western States Regional Council of 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.

The Ordinance proposes allowing the City to ministerially approve properly submitted Builder’s Remedy projects that meet certain City-imposed conditions and requirements, such as the proposed 8844 Burton Way project, a 20-story 199-unit mixed use building proposed in the City. As part of this effort, the City is evaluating the potential impacts and benefits of implementing certain programs and policies pertaining to the ministerial processing of Builder’s Remedy applications for housing City of Beverly Hills – Draft Ordinance re Builder’s Remedy Ministerial Approval June 3, 2025

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developments within the City, such as reduced building height requirements, setback requirements, and limits on nature, scope, and use of outdoor common areas for such projects.

Individual members of the Western Carpenters live, work, and recreate in the City and surrounding communities and would be directly affected by the Ordinance.

The Western Carpenters expressly reserves the right to supplement these comments at or prior to hearings on the Ordinance, and at any later hearing and proceeding related to this Ordinance. 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.

I. REQUIRING DEVELOPERS’ COMMITMENT TO USE A LOCAL

WORKFORCE AND APPRENTICESHIP PROGRAMS IN
CONNECTION WITH BUILDER’S REMEDY PROJECTS WILL
BENEFIT THE CITY’S ECONOMIC DEVELOPMENT AND

OVERALL ENVIRONMENT
WSRCC submits that the City should adopt policies (e.g., a Labor Standard) requiring that any Builder’s Remedy projects subject to a ministerial approval process within the City be built using a local workers who have graduated from a Joint LaborManagement 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.

To that end, WSRCC respectfully requests that the City consider establishing, via the proposed Ordinance, a Labor Standard for any potential ministerial approval process whereby developers on Builder’s Remedy projects must also commit to the use of such local labor in conjunction with their pursuit of such ministerial or expedited approval for a proposed Builder’s Remedy project.

Indeed, at the January 28, 2025, City Council Study Session, Councilmember John A.

Mirisch indicated that development projects undergoing ministerial review should be required to utilize local workforces or even enter into labor agreements. As stated by Planning Commission staff, Councilmember Mirisch “expressed an interest in requiring such projects to utilize a local workforce and apprenticeship programs, and that each project would be required to enter into a project labor agreement.” (See City of Beverly Hills – Draft Ordinance re Builder’s Remedy Ministerial Approval June 3, 2025

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March 27, 2025, Planning Commission Report, p. 3). Similarly, WSRCC also recommends that the Ordinance be revised to require that development projects undergoing ministerial review utilize a local workforce or enter into labor agreements or, alternatively, that the City condition approval of such projects upon use of a local workforce or entering into labor agreements.

The community benefits of labor measures such as local hire requirements can be helpful to reduce environmental impacts and improve the positive economic impacts of the Ordinance. Local hire provisions requiring that a certain percentage of workers reside within 10 miles or less of a Builder’s Remedy 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.

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, municipal policies promoting and/or requiring the use of a local workforce 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 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.

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Air Quality Management District found that that the “[u]se of a local state-certified apprenticeship program” can result in air pollutant reductions.2

Moreover, 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
Further, 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 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 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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negotiating corporate participation in First Source as a condition of approval for development permits.

Additionally, in 2019, the City adopted the current version of its Sustainability Plan.

The Sustainability Plan notes that 38% of California’s greenhouse gas emissions are attributable to the transportation sector. (See City of Beverly Hills 2019 Sustainability Plan, p. 8.) The Plan also touts (1) minimizing GHG and other emissions from City facilities and operations, and (2) minimizing mobile source emissions from on- and off-road (construction) vehicles as the City’s top two policies in furthering the City’s Climate Change and Air Quality goals. (Id.) Further, the Plan states the policy of promoting alternative modes of transportation/travel, mass transit, and/or development of commute trip reduction plans within the City (including an emphasis on use of public transportation) in order to further its Land-Use, Transportation and Open Space, and Sustainable Local Economy goals. (2019 Sustainability Plan, pp. 11, 14, 27, 30.) Policies ensuring the use of local labor offer clear synergy and benefits with all of the foregoing goals of the Sustainability Plan. To this end, the City’s development and implementation of policies promoting local hire and utilization of apprenticeship programs on the numerous proposed Builder’s Remedy projects will demonstrably contribute to the City achieving its GHG, Energy, Transportation, and Land Use sustainability goals, and the goals of its forthcoming Climate Action & Adaptation Plan (“CAAP”) by reducing the overall VMT of the City’s workforce.

Relatedly, and based on the reasons outlined above, WSRCC proposes and recommends that the City incorporate local hire and apprenticeship program requirements on construction projects within the City in its forthcoming CAAP.

WSRCC urges the City to establish and implement policies and requirements for the use of local hire and prevailing wages on Builder’s Remedy projects subject to ministerial approval within the City in order to benefit the local area economically and to mitigate greenhouse gas emissions, improve air quality, and reduce transportation impacts.

WSRCC also recommends that the City exercise its lawful authority in requiring that approval of development projects under the Ordinance or issuance of permits thereof be conditional on the use of a local, skilled, and trained workforce as well as the payment of prevailing wages for workers. The Ordinance should accordingly be revised to clearly and expressly authorize the City to condition approval of City of Beverly Hills – Draft Ordinance re Builder’s Remedy Ministerial Approval June 3, 2025

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development projects undergoing ministerial review upon the use of a local workforce or other appropriate economic benefits.

II. THE CITY SHOULD ESTABLISH TRAINING REQUIREMENTS

FOR CONSTRUCTION ACTIVITIES TO PREVENT COMMUNITY
SPREAD OF COVID-19 AND OTHER INFECTIOUS DISEASES
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, as part of the development and implementation of policies concerning ministerial approval of Builder’s Remedy projects, the City adopt and incorporate additional requirements to mitigate public health risks from the Project’s construction activities. Western Carpenters requests that the City establish requirements for safe on-site construction work practices, as well as training and certification for any construction workers on development projects within the City.

In particular, based upon Western Carpenters’ experience with safe construction site work practices, Western Carpenters recommends that the City develop and establish certain requirements for construction site design, testing procedures, and planning while construction activities are being conducted, including the following:

Construction Site Design:
• Project sites 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.
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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• The perimeter fence directly adjacent to project 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 project sites directing workers through temperature screening.
• Hand washing stations will be provided throughout
construction sites.

Testing Procedures:
• Non-contact devices shall be used for temperature
screening.
• 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 to the Project Site 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] of the Project Site 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.

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

Planning
• Require the development of an Infectious Disease
Preparedness and Response Plan for all applicable projects 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. WSRCC recommends and proposes that the City develop and implement policies requiring that all construction workers undergo COVID-19 Training and Certification before being allowed to conduct construction activities at project sites within the City.

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 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.

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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.

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

WSRCC submits that the City should develop policies that incorporate requirements that Builder’s Remedy projects within the City that are eligible for ministerial approval be subject to the foregoing public health risk mitigation protocols and be built using a workforce trained in ICRA protocols.

III. THE CITY SHOULD REQUIRE THAT PROJECTS APPROVED

PURSUANT TO THE ORDINANCE IMPLEMENT THE

MITIGATION MEASURES OUTLINED IN THE HOUSING

ELEMENT MND
The Housing Element Mitigated Negative Declaration (“MND”) to which the Ordinance proposes an Addendum presently identifies and outlines various mitigation measures intended to reduce the environmental impacts associated with the 2021-2029 Beverly Hills Housing Element Update. Specifically, the MND includes a “Mitigation Monitoring and Reporting Program” that identifies various mitigation measures relating to environmental media such as biological resources and cultural resources.

WSRCC believes it is imperative that any development projects approved pursuant to the Ordinance also be required to comply with the same mitigation measures outlined in the Housing Element MND. CEQA requires that, when an agency tiers off of prior environmental analysis, the previous mitigation measures be extended to the subsequent projects. PRC §§ 21068.5-21081.6(a)(1); CEQA Guidelines § 15152.

Symmetry between the mitigation measures outlined in the MND and those required for development projects ministerially approved pursuant to the proposed Ordinance will help ensure that any potential environmental impacts are adequately mitigated as contemplated by the original MND. This symmetry will also ensure that the original intent and purpose of the MND mitigation measures are not undermined. If compliance with the MND’s original mitigation measures is not required, development 7 For details concerning Western Carpenters’ ICRA training program, see https://icrahealthcare.com/.

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projects approved pursuant to the Ordinance would be able to circumvent the City’s original environmental determinations regarding the Housing Element and generally run afoul of CEQA’s purpose and requirements.

CEQA Guidelines generally require that mitigation measures be legally enforceable on a project applicant. As such, these mitigation measures may be appropriately included as “conditions of approval” for a development project. Indeed, the original “Mitigation Monitoring and Reporting Program” acknowledges that “mitigation measures may be included as conditions of approval for the project.” Therefore, the City should exercise this authority to require that any existing mitigation measures currently outlined in the MND are enforceable as to any development projects to be approved under the Ordinance. For instance, the City may require that any subsequent approval of development projects under the Ordinance be conditional upon the explicit compliance or implementation of mitigation measures outlined in the MND. The City should also consider revising the Ordinance such that the approval of applicable development projects would be expressly conditioned upon the projects’ compliance with mitigation measures, including those identified in the MND. Lastly, the City should also incorporate additional mitigation measures in the Ordinance that may not exist in the MND but that the City reasonably believes will help mitigate a development project’s potential environmental impacts based on analysis and input from City staff and the public.

IV. THE CITY SHOULD REQUIRE AN ENVIRONMENTAL IMPACT

REPORT OR SUBSEQUENT MND BE PREPARED FOR THE

ORDINANCE
The City should require that an Environmental Impact Report (EIR) or Subsequent MND be prepared for the Ordinance based on the discrepancy between development projects contemplated by the Ordinance and those accounted for in the Housing Element. Specifically, there appears to be an anomaly between the potential development projects that the Ordinance identifies versus those accounted for in the City’s most recent Housing Element. For example, many of the development projects listed in the proposed “Addendum to Housing Element MND” do not appear, and are therefore not accounted for, in the City’s operative Housing Element. It is further unclear whether the development projects being contemplated by the Ordinance satisfy or achieve the same commitments or metrics articulated in the Housing Element, including, for example, as to affordable housing units.

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Addendums to a previously certified EIR or MND are allowed under CEQA for “minor technical changes or additions” or based upon a finding that there are no substantial changes to the project, its circumstances, or new information of substantial importance. CEQA Guidelines §§ 15162, 15164.

As the City has acknowledged, the CEQA Guidelines Section 15162 generally provides that no subsequent MND or Environmental Impact Report shall be prepared for the a project unless, on the basis of substantial evidence in the light of the whole record, one or more of the following is determined: (1) Substantial changes are proposed in the project that will require major revisions of the previous MND due to the involvement of new, significant environmental effects or a substantial increase in the severity of previously identified significant effects; (2) Substantial changes occur with respect to the circumstances under which the project is undertaken which will require major revisions of the previous MND due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or (3) New information of substantial importance identifies one or more significant effects not discussed in the previous MND, significant effects previously examined will be substantially more severe than shown in the previous MND, mitigation measures or alternatives previously found not to be feasible or not analyzed in the MND would be feasible and would substantially reduce one or more significant effects but the project proponents decline to adopt the measure or alternative. 14 C.C.R. Section 15162.

The discrepancy between development projects contemplated by the Ordinance and those accounted for in the City’s Housing Element arguably satisfies several of these criteria, although only one is needed to trigger further environment review. For instance, the additional projects contemplated by the Ordinance and Addendum to Housing Element MND may represent “substantial changes” to the “project” that was evaluated by the original MND because it did not even consider some of these later or more recent projects.

Further, these additional projects may also present “new information of substantial importance” because their individual environmental impacts, as well as their aggregate impacts, were not thoroughly evaluated by the original MND. Indeed, in assessing the Ordinance’s potential for “new, significant environmental effects or a substantial increase in the severity of previously identified significant effects,” the March 12, 2024, Addendum to MND indicated as follows:

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The Amendments do not propose or contemplate specific development projects. Although goals and policies in the plan may result in future actions that could have environmental effects, there is not any information available to allow for meaningful environmental analysis at this time. Environmental review of any implementing actions and projects would occur at the time when project details are known.

See March 12, 2024, Addendum to Mitigated Negative Declaration, p. 15.

Fast-forwarding to the April 29, 2025 Addendum to MND prepared by the City in connection with the Ordinance, which identifies and contemplates “specific development projects” (see April 29, 2025 Addendum to MND, p. 1), the City has still failed to conduct any analysis of the potential environmental effects of those projects.

Rather, the City has only provided substantive analysis in its most recent Addendum to the Housing Element MND of the Ordinance’s consistency with the Housing Element’s policies and programs. Thus, City’s overall approach to environmental review of the Housing Element and the Ordinance has arrived at an apparent paradox:
on the one hand the City claimed it was infeasible to previously study the environmental effects of projects contemplated under the Housing Element due to a lack of specifics regarding such projects; and on the other hand, now that the City has received specific details concerning the assorted projects subject to the City’s Housing Element and potentially the proposed Ordinance, the environmental effects of the specific projects still cannot analyzed and evaluated because the proposed Ordinance, by its very nature, would exempt the specific projects from CEQA environmental review.

The prior environmental review documentation associated with the City’s operative Housing Element makes clear that the City had planned and intended for detailed environmental review for specific housing development projects to be prepared.

Because the proposed Ordinance would effectively circumvent that prior documented intention and foreclose any future pathway for meaningful environmental review of the specific projects subject to it, CEQA requires that such environmental review occur now, prior to any approval of the Ordinance by the City, based on, among other things, the “new information of substantial importance” implicated by the Ordinance.

To that end, the proposed Ordinance includes various specific requirements that would apply to the fourteen (14) eligible, pending Builder’s Remedy development projects, and the application of those specific requirements to the defined scope of applicable development projects could now feasibly be evaluated for their City of Beverly Hills – Draft Ordinance re Builder’s Remedy Ministerial Approval June 3, 2025

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environmental impacts relative to the previous analysis set forth concerning the City’s Housing Element. The performance of such analysis would further permit and ensure that any additional necessary mitigation measures could then be incorporated into the Ordinance. However, the nature and scope of the required additional mitigation cannot be ascertained until the City conducts an adequate and CEQA-compliant review of the impacts of the proposed Ordinance. Simply put, further and more detailed environmental review of the proposed Ordinance and its associated impacts is now warranted under CEQA prior to any enactment of it by the City.

Moreover, the City’s legislative body and the public is entitled to a full opportunity to assess the adequacy of the environmental review performed in connection with the Ordinance, along with any associated environmental mitigation measures that are proposed as a result. As it stands, the City’s decisionmakers and the public have been denied of essential right under CEQA with respect to the proposed Ordinance and its potential impacts.

Lastly, the potential cumulative impacts of the development projects subject to the Ordinance in relation to one another have not yet been evaluated even though environmental impacts may be potentially significant and may represent “substantial changes… to the circumstances under which the project is undertaken.” In light of the discrepancy between projects contemplated by the Ordinance and those accounted for in the Housing Element, the City should require the preparation of an EIR or Subsequent MND in compliance with CEQA Guidelines Section 15162.

Further environmental review will help reveal and disclose the potential environmental impacts of the proposed projects to the public and allow for an adequate mitigation of those impacts to be incorporated, all in accordance with the mandates of CEQA.

V. CONCLUSION
For the foregoing reasons, WSRCC urges the City to implement policies in the proposed Ordinance that establish local hire and apprenticeship construction workforce requirements and public health risk mitigation protocols for any Builder’s Remedy projects within the City that are deemed eligible for ministerial approval.

WSRCC also submits that CEQA requires that the City exercise its authority to condition approval of projects under the Ordinance on the implementation of mitigation measures, including those identified in the original MND for the City’s current Housing Element and any others deemed appropriate, as well as require the City of Beverly Hills – Draft Ordinance re Builder’s Remedy Ministerial Approval June 3, 2025

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preparation of an EIR or Subsequent MND for the Ordinance to allow for adequate and complete environmental review of its potential impacts.

WSRCC appreciates the opportunity to provide comments and input regarding this important matter, and thanks the Council for its consideration of the concerns and proposals set forth herein. If the City should have any questions or concerns, please do not hesitate to contact this office.

Sincerely,
______________________
Jeremy Herwitt
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
[email protected]
Paul E. Rosenfeld, PhD
(310) 795-2335
[email protected]
March 8, 2021
Mitchell M. Tsai
155 South El Molino, Suite 104
Pasadena, CA 91101
Subject: Local Hire Requirements and Considerations for Greenhouse Gas Modeling Dear Mr. Tsai,
Soil Water Air Protection Enterprise (“SWAPE”) is pleased to provide the following draft technical report explaining the significance of worker trips required for construction of land use development projects with respect to the estimation of greenhouse gas (“GHG”) emissions. The report will also discuss the potential for local hire requirements to reduce the length of worker trips, and consequently, reduced or mitigate the potential GHG impacts.

Worker Trips and Greenhouse Gas Calculations
The California Emissions Estimator Model (“CalEEMod”) is a “statewide land use emissions computer model designed to provide a uniform platform for government agencies, land use planners, and environmental professionals to quantify potential criteria pollutant and greenhouse gas (GHG) emissions associated with both construction and operations from a variety of land use projects.”1 CalEEMod quantifies construction-related emissions associated with land use projects resulting from off-road construction equipment; on-road mobile equipment associated with workers, vendors, and hauling; fugitive dust associated with grading, demolition, truck loading, and on-road vehicles traveling along paved and unpaved roads; and architectural coating activities; and paving.2
The number, length, and vehicle class of worker trips are utilized by CalEEMod to calculate emissions associated with the on-road vehicle trips required to transport workers to and from the Project site during construction.3 1 “California Emissions Estimator Model.” CAPCOA, 2017, available at: http://www.aqmd.gov/caleemod/home. 2 “California Emissions Estimator Model.” CAPCOA, 2017, available at: http://www.aqmd.gov/caleemod/home. 3 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/01 user-39-s-guide2016-3-2 15november2017.pdf?sfvrsn=4, p. 34. 2 Specifically, the number and length of vehicle trips is utilized to estimate the vehicle miles travelled (“VMT”) associated with construction. Then, utilizing vehicle-class specific EMFAC 2014 emission factors, CalEEMod calculates the vehicle exhaust, evaporative, and dust emissions resulting from construction-related VMT, including personal vehicles for worker commuting.4
Specifically, in order to calculate VMT, CalEEMod multiplies the average daily trip rate by the average overall trip length (see excerpt below):
“VMTd = Σ(Average Daily Trip Rate i * Average Overall Trip Length i) n Where:
n = Number of land uses being modeled.”5
Furthermore, to calculate the on-road emissions associated with worker trips, CalEEMod utilizes the following equation (see excerpt below):
“Emissionspollutant = VMT * EFrunning,pollutant
Where:

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

Default Worker Trip Parameters and Potential Local Hire Requirements As previously discussed, the number, length, and vehicle class of worker trips are utilized by CalEEMod to calculate emissions associated with the on-road vehicle trips required to transport workers to and from the Project site during construction.7In order to understand how local hire requirements and associated worker trip length reductions impact GHG emissions calculations, it is important to consider the CalEEMod default worker trip parameters. CalEEMod provides recommended default values based on site-specific information, such as land use type, meteorological data, total lot acreage, project type and typical equipment associated with project type. If more specific project information is known, the user can change the default values and input projectspecific values, but the California Environmental Quality Act (“CEQA”) requires that such changes be justified by substantial evidence.8 The default number of construction-related worker trips is calculated by multiplying the 4 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/02 appendix-a2016-3-2.pdf?sfvrsn=6, p. 14-15. 5 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/02 appendix-a2016-3-2.pdf?sfvrsn=6, p. 23. 6 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/02 appendix-a2016-3-2.pdf?sfvrsn=6, p. 15. 7 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/01 user-39-s-guide2016-3-2 15november2017.pdf?sfvrsn=4, p. 34. 8 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 1, 9.

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

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

11.0 Vegetation
Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment
Equipment Type Number
CalEEMod Version: CalEEMod.2016.3.2 Page 44 of 44 Date: 1/12/2021 2:26 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

11.0 Vegetation
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment
Equipment Type Number
CalEEMod Version: CalEEMod.2016.3.2 Page 35 of 35 Date: 1/12/2021 2:30 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Winter Total Construction GHG Emissions (MT CO2e) 3,623
Amortized (MT CO2e/year) 120.77
Total Construction GHG Emissions (MT CO2e) 3,024
Amortized (MT CO2e/year) 100.80
% Decrease in Construction-related GHG Emissions 17%
Local Hire Provision Net Change
With Local Hire Provision
Without Local Hire Provision
Attachment C

EXHIBIT B

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

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

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

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

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

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

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

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

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

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

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

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

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

Procedia Environmental Sciences. 113–125.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Paul E. Rosenfeld, Ph.D. Page 4 of 10 June 2019
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., Sutherland, A; Hesse, R.; Zapata, A. (October 3-6, 2013). Air dispersion modeling of volatile organic emissions from multiple natural gas wells in Decatur, TX. 44th Western Regional Meeting, American Chemical Society. Lecture conducted from Santa Clara, CA.

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

Urban Environmental Pollution. Lecture conducted from Boston, MA.

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

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

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

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

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

Rosenfeld, P. E. (October 15-18, 2007). The Repeated Trespass of Tritium-Contaminated Water Into A Surrounding Community Form Repeated Waste Spills From A Nuclear Power Plant. The 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 10 June 2019
Rosenfeld, P. E. (October 15-18, 2007). Somerville Community Exposure To Contaminants From Wood Treatment Facility Emissions. The 23rd Annual International Conferences on Soils Sediment and Water. Lecture conducted from University of Massachusetts, Amherst MA.

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

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

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

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

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

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

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

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

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

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

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

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

Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.

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

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

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

Lecture conducted from Phoenix Arizona.

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

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

Paul E. Rosenfeld, Ph.D. Page 6 of 10 June 2019
Paul Rosenfeld, Ph.D. (April 7, 2004). A National Damage Assessment Model For PCE and Dry Cleaners.

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

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

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

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

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

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

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

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

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

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

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

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.

Paul E. Rosenfeld, Ph.D. Page 7 of 10 June 2019
Rosenfeld, P.E, C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur Emissions Following Biosolids Incorporation With High-Carbon Wood-Ash. Water Environment Federation 12th Annual Residuals and Biosolids Management Conference Proceedings. Lecture conducted from Bellevue Washington.

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.

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

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

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

Case No.: 3:15-CV-00106 consolidated with 3:15-CV-00237 Rosenfeld Deposition. 5-9-2019
In The Superior Court of the State of California In And For The County Of Los Angeles – Santa Monica Carole-Taddeo-Bates et al., vs. Ifran Khan et al., Defendants Case No.: No. BC615636
Rosenfeld Deposition, 1-26-2019
In The Superior Court of the State of California In And For The County Of Los Angeles – Santa Monica The San Gabriel Valley Council of Governments et al. vs El Adobe Apts. Inc. et al., Defendants Case No.: No. BC646857
Rosenfeld Deposition, 10-6-2018; Trial 3-7-19

In United States District Court For The District of Colorado Bells et al. Plaintiff vs. The 3M Company et al., Defendants Case: No 1:16-cv-02531-RBJ
Rosenfeld Deposition, 3-15-2018 and 4-3-2018
In The District Court Of Regan County, Texas, 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., Plaintiffs vs. Chevron Corporation, et al., Defendants Cause No C12-01481
Rosenfeld Deposition, 11-20-2017
In The Circuit Court Of The Twentieth Judicial Circuit, St Clair County, Illinois Martha Custer et al., Plaintiff vs. Cerro Flow Products, Inc., Defendants Case No.: No. 0i9-L-2295
Rosenfeld Deposition, 8-23-2017

In The Superior Court of the State of California, For The County of Los Angeles Warrn Gilbert and Penny Gilber, Plaintiff vs. BMW of North America LLC Case No.: LC102019 (c/w BC582154)
Rosenfeld Deposition, 8-16-2017, Trail 8-28-2018
In the Northern District Court of Mississippi, Greenville Division Brenda J. Cooper, et al., Plaintiffs, vs. Meritor Inc., et al., Defendants Case Number: 4:16-cv-52-DMB-JVM
Rosenfeld Deposition: July 2017
Paul E. Rosenfeld, Ph.D. Page 9 of 10 June 2019
In The Superior Court of the State of Washington, County of Snohomish Michael Davis and Julie Davis et al., Plaintiff vs. Cedar Grove Composting Inc., Defendants Case No.: No. 13-2-03987-5
Rosenfeld Deposition, February 2017
Trial, March 2017
In The Superior Court of the State of California, County of Alameda Charles Spain., Plaintiff vs. Thermo Fisher Scientific, et al., Defendants Case No.: RG14711115
Rosenfeld Deposition, September 2015
In The Iowa District Court In And For Poweshiek County
Russell D. Winburn, et al., Plaintiffs vs. Doug Hoksbergen, et al., Defendants Case No.: LALA002187
Rosenfeld Deposition, August 2015
In The Iowa District Court For Wapello County
Jerry Dovico, et al., Plaintiffs vs. Valley View Sine LLC, et al., Defendants Law No,: LALA105144 - Division A
Rosenfeld Deposition, August 2015
In The Iowa District Court For Wapello County
Doug Pauls, et al.,, et al., Plaintiffs vs. Richard Warren, et al., Defendants Law No,: LALA105144 - Division A
Rosenfeld Deposition, August 2015
In The Circuit Court of Ohio County, West Virginia
Robert Andrews, et al. v. Antero, et al.

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

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

Case No. 5:12-cv-01152-C
Rosenfeld Deposition: July 2014
Paul E. Rosenfeld, Ph.D. Page 10 of 10 June 2019
In the County Court of Dallas County Texas
Lisa Parr et al, Plaintiff, vs. Aruba et al, Defendant.

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

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

EXHIBIT C
1640 5th St.., Suite 204 Santa
Santa Monica, California 90401
Tel: (949) 887‐9013
Email: [email protected]
Matthew F. Hagemann, P.G., C.Hg., QSD, QSP
Geologic and Hydrogeologic Characterization
Industrial Stormwater Compliance
Investigation and Remediation Strategies
Litigation Support and Testifying Expert
CEQA Review
Education:

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

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

Professional Certifications:

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

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

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

Positions Matt has held include:
• Founding Partner, Soil/Water/Air Protection Enterprise (SWAPE) (2003 – present); • Geology Instructor, Golden West College, 2010 – 2014; • Senior Environmental Analyst, Komex H2O Science, Inc. (2000 ‐‐ 2003); • Executive Director, Orange Coast Watch (2001 – 2004); • Senior Science Policy Advisor and Hydrogeologist, U.S. Environmental Protection Agency (1989– 1998);
• Hydrogeologist, National Park Service, Water Resources Division (1998 – 2000); • Adjunct Faculty Member, San Francisco State University, Department of Geosciences (1993 – 1998);
• Instructor, College of Marin, Department of Science (1990 – 1995); • Geologist, U.S. Forest Service (1986 – 1998); and
• Geologist, Dames & Moore (1984 – 1986).

Senior Regulatory and Litigation Support Analyst:

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

With Komex H2O Science Inc., Matt’s duties included the following:
• Senior author of a report on the extent of perchlorate contamination that was used in testimony by the former U.S. EPA Administrator and General Counsel. • Senior researcher in the 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.
2 • 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. 3 • 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 public hearings, and responded to public comments from residents who were very concerned about the impact of designation.
4 • Reviewed a number of Environmental Impact Statements for planned major developments, including large hazardous and solid waste disposal facilities, mine reclamation, and water transfer.

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

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

With the National Park Service, Matt directed service‐wide investigations of contaminant sources to prevent degradation of water quality, including the following tasks:
• Applied pertinent laws and regulations including CERCLA, RCRA, NEPA, NRDA, and the Clean Water Act to control military, mining, and landfill contaminants. • Conducted watershed‐scale investigations of contaminants at parks, including Yellowstone and Olympic National Park.
• Identified high‐levels of perchlorate in soil adjacent to a national park in New Mexico and advised park superintendent on appropriate response actions under CERCLA. • Served as a Park Service representative on the Interagency Perchlorate Steering Committee, a national workgroup.
• Developed a program to conduct environmental compliance audits of all National Parks while serving on a national workgroup.
• Co‐authored two papers on the potential for water contamination from the operation of personal watercraft and snowmobiles, these papers serving as the basis for the development of nation‐ wide policy on the use of these vehicles in National Parks. • Contributed to the Federal 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 EPAʹs scientific and engineering staff. • Earned an EPA Bronze Medal for representing the region’s 300 scientists and engineers in negotiations with the Administrator and senior management to better integrate scientific principles into the policy‐making process.
• Established national protocol for the peer review of scientific documents. 5 Geology:

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

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

Teaching:

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

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

Invited Testimony, Reports, Papers and Presentations:

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

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

EPA Region 9, San Francisco, California.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Unpublished report.

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

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

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

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

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

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

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

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

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

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

Hagemann, M.F., 1993. U.S. EPA Policy on the Technical Impracticability of the Cleanup of DNAPL‐ contaminated Groundwater. California Groundwater Resources Association Meeting. 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 examination, 2009‐ 2011.
9 email contains confidential information. If you are not the person to whom this message is addressed, be aware that any use, reproduction, or distribution of this message is strictly prohibited. If you received this in error, please contact the sender and immediately delete this email and any attachments.

From: Cindy Gordon
To: City Clerk
Subject: Fw: Building corner of Maple and Wishire
Date: Tuesday, June 3, 2025 5:37:55 PM
For tonight's E1 item.

CINDY GORDON, AICP
Project Manger - Current Planning | City of Beverly Hills | 310.285.1191 NOTE: Planning applications and project resubmittals are currently accepted via email. However, planning applications and project resubmittals are not considered received by the City until such submittal is acknowledged by a Planning Division staff member. If you have questions regarding the status of your planning application, please call 310-285-1000 and ask to speak to a planner. If you have questions about the status of your project resubmittal, please reach out to your assigned planner directly.

From: Gity J < >
Sent: Tuesday, June 3, 2025 5:35 PM
To: Cindy Gordon <[email protected]>
Subject: Building corner of Maple and Wishire
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To whom it may concern
We all think that this is a very wrong area to build a hotel or a building as this is family neighborhood and the very important point is that from Maple drive you can only do right turn which is next to Rexford drive and will make this area unlivable anymore.

We all are against this projects .

Hope you can stop this projects
Thank you
Javaheri family
Sent from my iPhone=

I am not an architect or city planner so I don't have a clue what a PA is, but after reading this it does not appear to provide an acceptable solution for tenants. Rather it provides opportunity for greedy developers.
--
Arlene Zeichner

Unlike community-serving retail, like a café or grocery store, hotels don't make the project more livable for the residents of the housing and are more likely to be incompatible rather than complementary to the residential uses. The City should maintain its ability to oversee the development of hotels in Beverly Hills.

Regan Lara

From: WebCBH MAYORANDCITYCOUNCIL
To: City Clerk
Subject: FW: OPPOSE ITEM 1
Date: Tuesday, June 3, 2025 9:58:47 AM
Public comment received
-----Original Message-----
From: Saul Leonard
Sent: Monday, June 2, 2025 10:33 PM
To: WebCBH MAYORANDCITYCOUNCIL <[email protected]> Subject: OPPOSE ITEM 1
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I oppose item E1. Ministerial approvals silence our community and threaten our neighborhood with projects like the 26 story 8844 Burton Way.

Saul F Leonard

purports to address a handful of the most egregious high-rise proposals, it ignores others entirely. Most concerning, it strips the community of any opportunity for input and eliminates all environmental oversight.

We already know the Olympic/Beverly intersection is nearing failure from a traffic perspective. Without proper environmental review, how will mitigation measures be identified or enforced? How can we consider approving such impactful projects without comprehensive traffic studies? Furthermore, the proposal makes no meaningful attempt to address the broader implications for our city’s infrastructure and character—zoning, water supply, waste management, green space, school capacity, public safety services, utilities, fire access, or construction-related impacts like noise. These issues demand case-by-case consideration, not blanket approval.

The proposal seems to greenlight some projects largely as submitted. Why not require a uniform height reduction—say, 30%—across the board? Why aren't detailed circulation and traffic studies mandated? Why are we, as a city, seemingly throwing up our hands?
Have we fully explored our legal options? What rights does the State have to compel approval while bypassing long-standing environmental review processes? These are serious questions that deserve answers.

Finally, I ask: is this truly a compromise? For developers, the overlay is a gift —an elimination of red tape. But for our community, removing CEQA and discretionary review is a dramatic and far-reaching shift. Even if some of these projects ultimately move forward, shouldn’t they at least be subject to focused Environmental Impact Reports (EIRs) and mitigation negotiations? A one-size-fits-all approach may look efficient on paper, but it overwhelmingly benefits developers while putting our city’s long-term health and identity at risk. Any genuine compromise must protect the integrity, livability, and character of this city—not erase them.

Thank you,
Kari Kramer

While we have many excellent City staff members who are dedicated to their responsibilities and the wellbeing of Beverly Hills, the leadership of our Community Development Department has been demonstrable in its decades of uniform and almost unconditional support for all forms of commercial and residential development, due in large part to the zealous pursuit of revenue generation enabled by project approval.

Even with State mandates, the City may still assert its discretion over Health & Safety Impacts, Objective Design Standards, CEQA Compliance, and Building Codes. Accordingly, since the members of the City Council are the sole elected representatives of our residents, voters and taxpayers, they - not staff, should directly exercise all allowable discretions, with the advice and consent of the People of Beverly Hills.

The Municipal League of Beverly Hills
by: Thomas White
Chairman, Board of Governors

parking demand, traffic, and demand for public safety resources such as police and fire services. Because hotel rooms are usually much smaller than dwelling units, some of these impacts are more concentrated in hotels than in typical residential development. Every hotel room has a toilet and a shower. Every guest needs transportation to arrive and depart, and many need parking. Most residential uses do not host large gatherings or provide the kind of services that require large numbers of employees; hotels do. Hotels involve all of these impacts without providing any permanent housing.

Don’t allow developers to use this ministerial process to get hotel projects approved.

Thank you!
Shirin Rafyzadeh

impacts are more concentrated in hotels than in typical residential development. Every hotel room has a toilet and a shower. Every guest needs transportation to arrive and depart, and many need parking. Most residential uses do not host large gatherings or provide the kind of services that require large numbers of employees; hotels do. Hotels involve all of these impacts without providing any permanent housing.

Don’t allow developers to use this ministerial process to get hotel projects approved.

Thank you!
Tamar Boglocishvili

From: Stephanie Morehouse
To: City Clerk
Subject: So Hamilton Dr building project
Date: Saturday, May 31, 2025 8:06:01 AM
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To the City Clerk,
The apartment complex, proposing to be built for So Hamilton drive, sounds less me an awful idea, and would effect a he quality of living for ALL surrounding residents. The scale that has been proposed, is unbelievable, so please consider this should you approve it.

Sincerely,
Stephanie Kline Morehouse,
Neighboring 90048

our surrounding neighborhoods.

Residential development will mean enhanced sales tax and business license revenue. More residents mean more local consumers.

Residential development will help revitalize our schools, which benefits the city in many ways. Schools are community hubs. More students mean more active parent involvement, more school events, and a stronger sense of intergenerational connection within Beverly Hills.

Residential development will enrich the lives of current Beverly Hills residents by bringing in new families and younger professionals.

Residential development will lead to increased foot traffic. Denser housing near commercial areas means more people walking to shops, cafes, and restaurants.

Denser housing can reduce overall vehicle miles traveled in Los Angeles.

I’m also unconvinced by the common NIMBY arguments against development.

1. Argument 1: “It’ll be a traffic nightmare.”
Much of Beverly Hills' traffic is "through traffic" – people commuting through our city to other destinations. New housing, especially if thoughtfully planned, can actually reduce regional traffic by allowing people to live closer to their jobs, schools, and amenities.

2. “It’ll be impossible to find parking.”
This is a classic red herring. Many modern residents, particularly younger professionals, own fewer cars or rely heavily on ride-sharing services and public transit.

3. “It will destroy the unique character and aesthetic appeal of Beverly Hills." Thoughtful, high-quality design and rigorous architectural review can ensure that new developments enhance, rather than detract from, our city's beauty.

Moreover, the "character" of a neighborhood also includes its vibrancy, its people, and its economic health. A stagnant, aging community that prices out its own children risks losing its true character far more than one that embraces carefully planned growth.

I also want to directly address the critical concerns regarding trust in governance and the implications of "Builders Remedy" projects.

I understand the frustration when development seems to proceed outside of clear, local control. However, it's crucial to recognize that "Builders Remedy" is a direct consequence of cities failing to meet their state-mandated housing targets.

My advocacy for more housing and denser housing is precisely about restoring and strengthening local control through proactive, responsible planning. By actively planning for and permitting the housing we need, Beverly Hills can avoid being subjected to these less desirable, state-imposed development scenarios.

In conclusion, supporting residential development in Beverly Hills is about our community charting its own path to ensure economic vitality and supporting our schools and to ensure Beverly Hills remains a beacon of prosperity and livability for generations to come.

Thank you for your time and attention to this important matter.

From: Shohreh Ashouri
To: City Clerk
Subject: Tuesdays City Hearing in regard to Builders remedy Date: Tuesday, June 3, 2025 9:40:17 AM
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Dear Mayor and City Council Members,
We are writing to you in regard to the inclusion of hotels in any ministerial housing projects.

This only a part of our displeasure with this plan:

We should not give an automatic City stamp to establishing these mini hotels in our city.

We all know what tiny hotel rooms are used for.

The city should not give hands to bringing an environment of crime in our city.

We are fighting even AirB&Bs for the same very reasons, and here we do this.

This kind of short-term thinking will damage the city for many years to come.

The City should not have any part in it, and in fact the City should fight it! Sincerely yours,
Eddy Ashouri

Beverly Hills City CouncilJune 3, 2025

Beverly Hills City Council
June 3, 2025