City Council Meeting Agenda
December 5, 2022

PUBLIC CORRESPONDENCE
Crossings Campus – 8833 National Blvd and 8888 Venice Blvd

Via Email

November 8, 2022

Chair Nancy Barba
Vice Chair Ed Ogosta
Commissioner Jen Carter
Commissioner Stephen Jones
Commissioner Andrew Reilman
Planning Commission
City of Culver City
9770 Culver Boulevard
Culver City, CA 90232

Jeff Anderson, Planning Manager
Current Planning Division
City of Culver City
9770 Culver Boulevard
Culver City, CA 90232
[email protected]

Mr. Jeremy Green
City Clerk
City of Culver City
9770 Culver Boulevard
Culver City, CA 90232
[email protected]

Re: City of Culver City, Planning Commission Meeting of November 9, 2022, Public Hearing Item No. 1; Planning Commission Review of Resolution Recommending to the City Council Certification of the Environmental Impact Report (EIR) (P2021- 0272-EIR); Resolution Recommending to the City Council Approval of Zoning Map Amendment (P2022-0144-ZCMA) and Comprehensive Plan (P2022-0144-CP); Resolution Recommending City Council Approval of a Request for Extended Construction Hours (2022-P021) (File No. 23-538)

Dear Chair Barba, Honorable Planning Commissioners, and Mr. Anderson:

I am writing on behalf of Supporters Alliance for Environmental Responsibility (“SAFER”) regarding the Final Environmental Impact Report (“FEIR” or “EIR”) prepared for the Crossings Campus Project (Case No. P2022-0144-CP/ZCMA, P2021-0272-EIR), proposed by Applicant Culver Crossings Properties LLC (the “Applicant”), including all actions related or referring to the construction of two four- to five-story buildings that would provide a total of 536,000 square feet of new office floor area and a total of 1,216 vehicular parking spaces within two three-level subterranean garages under each proposed building, located at 8833 and 8825 National Boulevard and 8771 Washington Boulevard in the City of Culver City, and 8876, 8884, 8886 and 8888 Venice Boulevard, and 8827 and 8829 National Boulevard in the City of Los Angeles (SCH No. 2021110079) (the “Project”).

November 8, 2022
EIR for the Crossings Campus Project

After reviewing the EIR, we conclude that it fails as an informational document, fails to implement all feasible mitigation measures to reduce the Project’s adverse environmental impacts, and fails to support its statement of overriding considerations with substantial evidence.

SAFER therefore respectfully requests that you recommend that the City Council deny approval of the EIR, and instead, direct the City’s Planning Division staff to address these shortcomings in a revised environmental impact report (“REIR”), to be recirculated in accordance with the public review provisions of the California Environmental Quality Act (“CEQA”), Public Resources Code, section 21000 et. seq.

SAFER’s review of the EIR has been assisted by air quality experts Matt Hagemann, P.G., C.Hg. and Paul E. Rosenfeld, Ph.D., of the environmental consulting firm, Soil/Water/Air Protection Enterprise (“SWAPE”) (CV and comments attached as Exhibit A); and indoor air quality expert and Certified Industrial Hygienist, Francis “Bud” Offermann, PE, CIH (CV and comments attached as Exhibit B).

LEGAL STANDARD

CEQA requires that an agency analyze the potential environmental impacts of its proposed actions in an environmental impact report (“EIR”) (except in certain limited circumstances). (See, e.g. Pub. Res. Code § 21100). The EIR is the very heart of CEQA. (Dunn- Edwards v. BAAQMD (1992) 9 Cal.App.4th 644, 652). “The ‘foremost principle’ in interpreting CEQA is that the Legislature intended the act to be read so as to afford the fullest possible protection to the environment within the reasonable scope of the statutory language.” (Communities for a Better Environment v. Calif. Resources Agency (2002) 103 Cal. App. 4th 98, 109).

CEQA has two primary purposes. First, CEQA is designed to inform decision makers and the public about the potential, significant environmental effects of a project. (14 CCR § 15002(a)(1)). “Its purpose is to inform the public and its responsible officials of the environmental consequences of their decisions before they are made. Thus, the EIR ‘protects not only the environment but also informed self-government.’”

Second, CEQA requires public agencies to avoid or reduce environmental damage when “feasible” by requiring “environmentally superior” alternatives and all feasible mitigation measures. (14 CCR § 15002(a)(2) and (3); see also, Berkeley Jets, 91 Cal.App.4th at pp. 1344, 1354; Citizens of Goleta Valley, 52 Cal.3d at 564). The EIR serves to provide agencies and the public with information about the environmental impacts of a proposed project and to “identify ways that environmental damage can be avoided or significantly reduced.” (14 CCR §15002(a)(2)). If the project will have a significant effect on the environment, the agency may approve the project only if it finds that it has “eliminated or substantially lessened all significant effects on the environment where feasible” and that any unavoidable significant effects on the environment are “acceptable due to overriding concerns.” (PRC § 21081; 14 CCR § 15092(b)(2)(A) & (B)). The lead agency may deem a particular impact to be insignificant only if it produces rigorous analysis and concrete substantial evidence justifying the finding. (Kings County Farm Bureau v. City of Hanford (1990) 221 Cal.App.3d 692, 732).

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EIR for the Crossings Campus Project

While the courts review an EIR using an “abuse of discretion” standard, “the reviewing court is not to ‘uncritically rely on every study or analysis presented by a project proponent in support of its position. A ‘clearly inadequate or unsupported study is entitled to no judicial deference.’” (Berkeley Jets, 91 Cal. App. 4th at 1355). As the court stated in Berkeley Jets:

A prejudicial abuse of discretion occurs “if the failure to include relevant information precludes informed decisionmaking and informed public participation, thereby thwarting the statutory goals of the EIR process.” (San Joaquin Raptor/Wildlife Rescue Center v. County of Stanislaus (1994) 27 Cal.App.4th 713, 722; Galante Vineyards v. Monterey Peninsula Water Management Dist. (1997) 60 Cal. App. 4th 1109, 1117; County of Amador v. El Dorado County Water Agency (1999) 76 Cal. App. 4th 931, 946.)

More recently, the California Supreme Court has emphasized that:

When reviewing whether a discussion is sufficient to satisfy CEQA, a court must be satisfied that the EIR (1) includes sufficient detail to enable those who did not participate in its preparation to understand and to consider meaningfully the issues the proposed project raises [citation omitted], and (2) makes a reasonable effort to substantively connect a project's air quality impacts to likely health consequences.

(Sierra Club v. Cty. of Fresno (2018) 6 Cal.5th 502, 510).

“Whether or not the alleged inadequacy is the complete omission of a required discussion or a patently inadequate one-paragraph discussion devoid of analysis, the reviewing court must decide whether the EIR serves its purpose as an informational document.” (Id. at 516). Although an agency has discretion to decide the manner of discussing potentially significant effects in an EIR, “a reviewing court must determine whether the discussion of a potentially significant effect is sufficient or insufficient, i.e., whether the EIR comports with its intended function of including ‘detail sufficient to enable those who did not participate in its preparation to understand and to consider meaningfully the issues raised by the proposed project.’” (Id.). “The determination whether a discussion is sufficient is not solely a matter of discerning whether there is substantial evidence to support the agency’s factual conclusions.” (Id.). Whether a discussion of a potential impact is sufficient “presents a mixed question of law and fact. As such, it is generally subject to independent review. However, underlying factual determinations—including, for example, an agency’s decision as to which methodologies to employ for analyzing an environmental effect— may warrant deference.” (Id.) As the Court emphasized:

[W]hether a description of an environmental impact is insufficient because it lacks analysis or omits the magnitude of the impact is not a substantial evidence question. A conclusory discussion of an environmental impact that an EIR deems significant can be determined by a court to be inadequate as an informational document without reference to substantial evidence.

(Id. at 514.) We find that the EIR prepared for the Crossings Campus Project is inadequate for the reasons set forth below.

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EIR for the Crossings Campus Project

DISCUSSION

I. Substantial Evidence Shows that the Project Will Likely Have Significant Air Quality and Greenhouse Impacts.

Air quality experts Matt Hagemann, P.G., C.Hg. and Dr. Paul E. Rosenfeld, Ph.D. of the environmental consulting firm SWAPE reviewed the EIR and concluded that the Project will have significant air quality and greenhouse gas impacts. SWAPE’s comments and expert CVs are attached as Exhibit A.

a. The EIR Fails to Present Substantial Evidence Showing that the Project Will Have a Less Than Significant Air Quality Impact.

SWAPE reviewed the EIR’s CalEEMod output files – the underlying data files used to estimate a project’s air emissions – and found that “several model inputs were not consistent with [the] information disclosed in the DEIR.” (Ex. A., p. 2.) For instance, the FEIR failed to account for the number of proposed parking spaces when modeling the parking areas’ air quality impacts, including emissions of volatile organic compounds (“VOCs”) from architectural coatings and lighting infrastructure. (Id., pp. 3-4.)

Next, SWAPE found that the EIR presented unsubstantiated changes to the estimated timeframe for completion of various phases of Project construction. (Id., p. 6.) This is notable because the CalEEMod User Guide expressly “requires any changes to model defaults to be justified.” (Id., pp. 5-6.) SWAPE noted that while “the DEIR indicates the total construction duration, the DEIR fails to mention or justify the individual construction phase lengths.” (Id., p.

6.) In the absence of any justification, the EIR “fails to provide substantial evidence to support the revised individual construction phase lengths.” (Id.)

As SWAPE explains, “by disproportionately altering and extending some of the individual construction phase lengths without proper justification, the models assume there are a greater number of days to complete the construction activities required by the prolonged phases.” (Id.) “Therefore, the model may underestimate the peak daily emissions associated with some phases of construction and should not be relied upon to determine Project significance, as the potentially shorter phases may result in increased emissions.” (Id.)

This is clearly improper. An EIR must describe “the whole of an action” (14 Cal. Code of Regulations, § 15378) and cannot separate stages of a Project to obscure its true environmental impact. “Improper piecemealing occurs ‘when the purpose of the reviewed project is to be the first step toward future development’ or ‘when the reviewed project legally compels or practically presumes completion of another action.’” East Sacramento Partnerships for a Livable City v. City of Sacramento (2016) 5 Cal.App.5th 281, 293 (citing Banning Ranch Conservancy v.

City of Newport Beach (2012) 211 Cal.App.4th 1209, 1223). “There is no dispute that CEQA forbids ‘piecemeal’ review of the significant environmental impacts of a project.” Berkeley Keep Jets Over the Bay Com. v. Board of Port Cmrs. (2001) 91 Cal.App.4th 1344, 1358.

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EIR for the Crossings Campus Project

Next, the EIR obscures the Project’s adverse impacts by underestimating construction mobile-source emissions (Ex. A., p. 7.) Here, SWAPE notes, the EIR presents “unsubstantiated calculations” which diverge—without the necessary justification—from CalEEMod’s default values and improperly excludes “worker, vendor, and hauling trips from the emissions analysis.” (Id., p. 8.) Therefore, “the models may underestimate the Project’s mobile-source construction- related emissions and should not be relied upon to determine Project significance.” As such, the EIR lacks substantial evidence to show that the Project will have a less than significant air quality impact.

b. The EIR Fails to Present Substantial Evidence Showing that the Project Will Not Produce Significant Health Impacts.

The EIR fails to address potential health-related impacts resulting from the Project’s likely air emissions. This is problematic because operation of construction equipment during construction of the proposed Project, as well as daily truck trips during future operations, will release diesel particulate matter (“DPM”) emissions into the air, affecting local and regional air quality. DPM is a known human carcinogen which poses unique health risks to nearby sensitive receptors. Importantly, CEQA requires a quantified analysis to determine whether a Project’s toxic air contaminant (“TAC”) emissions—including DPM emissions —will have potentially adverse impacts on human health.

Current guidance by the Office of Environmental Health Hazard Assessment (“OEHHA”), the agency responsible for setting statewide standards to measure health risks under CEQA, recommends that a quantified Health Risk Assessment (“HRA”) be prepared to evaluate potential cancer risks for any short-term construction project lasting more than two months, and for the lifetime of any long-term project lasting more than six months. OEHHA guidance also recommends that an exposure duration of 30 years should be used to estimate the individual cancer risk affecting the maximally exposed individual resident (“MEIR”) near a proposed Project site. (Id., p. 10.) A project’s imposition of health risks upon impacted MEIRs is further evaluated according to the sensitive receptor’s age and pregnancy status. (Id., p. 14.)

Construction of the proposed Project is expected to last 35 months, and it is reasonable to assume, in the absence of any contrary assertion by the EIR, that future building operations will continue on the site for at least 30 years. Therefore, as SWAPE observes, “These recommendations reflect the most recent state health risk policies, and as such, a revised EIR should be prepared to include an analysis of health risk impacts posed to nearby sensitive receptors from Project-generated DPM emissions.” (Id., p. 10.)

Contrary to this established regulatory framework, however, the EIR failed to prepare a quantified HRA for the Project’s planned construction and operations. As such, the EIR fails to present substantial evidence showing that the Project will not have a significant health impact, despite known health risks that will directly result from the Project’s construction-related DPM emissions, its generation of hundreds of daily vehicle trips, and its projected TAC emissions that will impact local air quality during construction and future operations. (Id., pp. 9-10.) The EIR additionally “fails to compare the Project’s excess cancer risk” as it compares to the South Coast November 8, 2022
EIR for the Crossings Campus Project

Air Quality Management District’s (“SCAQMD”) established significance threshold of 10 per million. (Id., p. 11.)

c. Substantial Evidence Shows That the Project Will Likely Create a Significant Health Risk for Impacted Sensitive Receptors.

Provided that the EIR did not adequately assess the Project’s significant adverse health impacts, SWAPE developed a screening-level risk assessment using AERSCREEN, a modeling tool which is recommended by both OEHHA and the California Air Pollution Control Officers Association (“CAPCOA”) for the development of Level 2 Health Risk Screening Assessments (“Level 2 HRSA”). According to SWAPE, “A Level 2 HRSA utilizes a limited amount of site- specific information to generate maximum reasonable downwind concentrations of air contaminants to which nearby sensitive receptors may be exposed. If an unacceptable air quality hazard is determined to be possible using AERSCREEN, a more refined modeling approach is required prior to approval of the Project.” (Id., p. 11.)

Following the recommended methodology to model potential future health risks, SWAPE presented substantial evidence showing that Project construction and operations would result in excess cancer risks for pregnant individuals during their third trimester of pregnancy, as well as infants, children, and adults, when those individuals are maximally exposed to Project-related emissions or located approximately 100 meters from the Project site. (Id., pp. 11-14.) The resulting cancer risks to pregnant individuals, infants, children under age 16, and adults under age 30, would therefore be, respectively, 23.0, 556, 126, and 11.6 per million. (Id., p. 14.) The excess cancer risk over the course of a residential lifetime (30 years) is approximately 717 per million. (Id.)

Every single one of these risk levels—affecting sensitive receptors across all age groups—exceed s the SCAQMD’s established health risk significance threshold of 10 per million. Even so, SWAPE explains, its analysis is a “screening-level HRA, which is known to be conservative, and which may not fully capture the extent of a Project’s future health impacts.

Therefore, SWAPE concludes that the “screening-level HRA demonstrates that construction and operation of the Project could result in a potentially significant health risk impact,” and as such, “a revised EIR should be prepared to include a refined health risk analysis which adequately and accurately evaluates health risk impacts associated with both Project construction and operation.” (Id., p. 15.)

d. The EIR’s Unfounded Assertions That the Project’s Greenhouse Gas Impacts Will Be Less Than Significant Are Not Supported By Substantial Evidence.

SWAPE rejects the EIR’s unfounded assertions that the Project’s greenhouse gas (“GHG”) emissions will be less than significant. (Id., p. 16.) Specifically, SWAPE found that because the Project relied on mere compliance with regulatory plans and policies, but failed to “utilize a numeric threshold to quantitatively evaluate the Project’s GHG emissions,” it cannot accurately conclude “that the Project would result in a less-than-significant GHG impact.” (Id.) Therefore, the EIR’s conclusion is not supported by substantial evidence and should be considered invalid. Instead, a “revised EIR should be prepared, including an updated GHG November 8, 2022
EIR for the Crossings Campus Project

analysis and incorporating additional mitigation measures to reduce the Project’s GHG emissions to less-than-significant levels.” (Id., p. 17.)

Next, SWAPE observed that the EIR incorrectly asserted that the Project would be consistent with the California Air Resources Board’s (“CARB”) 2017 Climate Change Scoping Plan (“Scoping Plan”). (Id., p. 17.) This claim is unfounded, however, because the EIR failed to implement CARB’s performance-based standards for estimating emissions from daily per capita vehicle miles traveled (“VMT”) when estimating the Project’s GHG emissions. (Id, p. 18.) Therefore, the EIR’s claim that the Project would not conflict with the 2017 Scoping Plan is not supported by substantial evidence and should be disregarded. Here, again, SWAPE recommends that a “revised EIR should be prepared for the proposed Project to provide additional information and analysis to conclude less-than-significant GHG impacts.” (Id.)

Lastly, SWAPE found that the EIR failed to present substantial evidence in support of its assertion that the Project would comply with the Southern California Association of Governments’ (“SCAG”) recently adopted 2020 Regional Transportation Plans/Sustainable Communities Strategies (“RTP/SCS”). SCAG’s 2020 RTP/SCS adopted a CARB-mandated goal of decreasing VMT throughout the region by 19 percent before 2035, which in turn, SCAG concluded would require a further per capita emissions reduction to 18.8 pounds/day. (Id.) However, the EIR failed to evaluate whether the Project would achieve compliance with these emissions targets. Therefore, SWAPE writes, “the DEIR’s claim that the proposed Project would be consistent with SCAG’s RTP/SCS is unsupported.” (Id., p. 19.)

This oversight is further improper because CEQA requires that any proposed projects must comply with previously adopted local or regional plans or policies which were adopted to avoid or mitigate environmental effects. (Pocket Protectors v. Sacramento (2005) 124 Cal.App.4th 903.) Indeed, any inconsistencies between a proposed project and any applicable existing plans must be discussed in an EIR. A lead agency’s failure to address such conflicts, as is the case here, constitutes a per se significant impact under CEQA. (14 CCR § 15125(d); City of Long Beach v. Los Angeles Unif. School Dist. (2009) 176 Cal. App. 4th 889, 918; Georgetown Preservation Society v. County of El Dorado (2018) 30 Cal.App.5th 358.) This omission directly contradicts the EIR’s assertion that its GHG impacts will be less than significant and makes clear that further analysis and mitigation are required.

e. The Project’s Energy Analysis is Conclusory and Fails to Adopt All Feasible Mitigation Measures.

CEQA provides that all Projects must include mitigation measures “to reduce the wasteful, inefficient, and unnecessary consumption of energy.” (PRC § 21100(b)(3).) Energy conservation under CEQA is defined as the “wise and efficient use of energy.” (CEQA Guidelines, app. F, § I.) The “wise and efficient use of energy” is achieved by “(1) decreasing overall per capita energy consumption, (2) decreasing reliance on fossil fuels such as coal, natural gas and oil, and (3) increasing reliance on renewable energy resources.” (Id.)

Mere compliance with the California Building Energy Efficiency Standards (Cal. Code Regs., tit. 24, part 6 (“Title 24”) does not constitute an adequate analysis of energy. League to November 8, 2022
EIR for the Crossings Campus Project

Save Lake Tahoe, 75 Cal. App. 5th at 165; Ukiah Citizens for Safety First v. City of Ukiah (2016) 248 Cal. App. 4th 256, 264-65. Notably, in California Clean Energy v. City of Woodland, the court held unlawful an EIR’s energy analysis which relied solely upon compliance with Title 24 to conclude that energy impacts would be less than significant. California Clean Energy Committee v. City of Woodland (2014) 225 Cal. App. 4th 173, 209-13 (City of Woodland).

The courts have recently affirmed City of Woodland, explaining that even where “[an] EIR [has] determined the project’s impacts on energy resources would be less than significant,” a lead agency must still analyze implementation of all “renewable energy options that might have been available or appropriate for [a] project,” including to achieve 100 percent on-site renewable power generation. (League to Save Lake Tahoe Mountain Area Preservation Foundation v.

County of Placer (2022) 75 Cal.App.5th 63, 166-67.) Furthermore, the court explained, a lead agency’s failure to consider implementation of all feasible renewable energy proposals raised during the environmental review process constitutes a “prejudicial error.” (Id. at 168.)

The EIR makes much ado about the Project’s plans to achieve LEED Gold Certified Status and its compliance with state and local building energy codes. (See, for example, EIR, p. 5-26). What it fails to mention, however, is that compliance with these plans does not satisfy CEQA’s requirement to consider the use of all feasible renewable energy alternatives for the proposed Project.

For instance, rather than commit to the feasible installation of rooftop solar panels, the EIR equivocates in stating that the Applicant will “either” install a “solar photovoltaic system” or, in compliance with the Culver City Municipal Code, pay an optional “in-lieu fee in an amount equal to the cost of a solar photovoltaic system consistent with Section 117.2 Exceptions of the California Building Code.” (EIR, p. 4.6-29.) Elsewhere, however, the EIR states that “the Applicant will pay an in-lieu fee in an amount equal to the cost of a solar photovoltaic system.” (Id., p. 4.6-53 [emph. added].) These discrepancies make clear that there is no legally binding requirement within the EIR for the Applicant to install a solar power system, much less to supply the Project with 100-percent renewable energy.

In this regard, SWAPE writes, “[W]e emphasize the applicability of incorporating [a] solar power system into the Project design. Until the feasibility of incorporating on-site renewable energy production is considered, the Project should not be approved.” (Ex. A., p. 23.) The EIR violates CEQA due to its failure to consider implementation of all feasible renewable energy options. Therefore, the City should draft a REIR which includes the necessary renewable energy commitments and analysis required by CEQA.

f. Further Mitigation Measures Must be Implemented to Reduce the Project’s Significant Air Quality, Human Health, and Greenhouse Impacts.

Beyond its analysis of the EIR’s numerous analytical flaws, SWAPE proposed a comprehensive list of additional mitigation measures and analyses that may be feasibly implemented to reduce the Project’s significant air quality, human health, and greenhouse gas impacts (Id., pp. 19-23). These include, but are not limited to, the following:

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EIR for the Crossings Campus Project

• Require projects within 500 feet of residences, hospitals, or schools to use Tier 4 equipment for all engines above 50 horsepower (hp) unless the individual project can demonstrate that Tier 4 engines would not be required to mitigate emissions below significance thresholds.
• Consult the SCAG Environmental Justice Toolbox for potential measures to address impacts to low-income and/or minority communities. The measures provided above are also intended to be applied in low income and minority communities as applicable and feasible.
• Include updated air quality, health risk, and GHG analyses to ensure that the necessary mitigation measures are implemented to reduce emissions to below significance thresholds.

Therefore, a REIR should “demonstrate a commitment to the implementation of these measures prior to Project approval, to ensure that the Project’s significant emissions are reduced to the maximum extent possible.” (Id., p. 23.) Importantly, CEQA requires public agencies to avoid or reduce adverse environmental impacts when “feasible” by requiring “environmentally superior” alternatives and all feasible mitigation measures. (14 CCR § 15002(a)(2) and (3); see also, Berkeley Jets, 91 Cal.App.4th at pp. 1344, 1354; Citizens of Goleta V alley, 52 Cal.3d at 564). SAFER has presented substantial evidence that feasible mitigation measures exist to further reduce the Project’s adverse impacts. Therefore, a REIR must be developed to comply with CEQA by further analyzing the Project’s likely adverse impacts and considering implementation of each of these proposed measures.

II. Substantial Evidence Shows That the Project Will Likely Have Significant Adverse Indoor Air Quality and Health Impacts.

Certified Industrial Hygienist, Francis “Bud” Offermann, PE, CIH, has reviewed the EIR and all relevant documents regarding the Project’s indoor air emissions. Based on this review, Mr. Offermann concludes that the Project will likely expose future employees working at the Project to significant impacts related to indoor air quality, and in particular, emissions of the cancer-causing chemical formaldehyde. Mr. Offermann is a leading expert on indoor air quality and has published extensively on the topic. Mr. Offermann’s CV and expert comments are attached as Exhibit B.

A. Future Employees Will Face Elevated Cancer Risks from Indoor Formaldehyde Emissions.

Formaldehyde is a known human carcinogen and is listed by the State of California as a Toxic Air Contaminant (“TAC”). The South Coast Air Quality Management District (“SCAQMD”), the agency responsible for regulating air quality within the South Coast Air Basin—which includes the City of Huntington Beach—has established a cancer risk significance threshold from human exposure to carcinogenic TACs of 10 per million. (Ex. B., p. 2.)

Mr. Offermann explains that many composite wood products typically used in building materials and furnishings commonly found in offices, warehouses, residences, and hotels contain formaldehyde-based glues which off-gas formaldehyde over a very long period of time. He states November 8, 2022
EIR for the Crossings Campus Project

that “[t]he primary source of formaldehyde indoors is composite wood products manufactured with urea-formaldehyde resins, such as plywood, medium density fiberboard, and particleboard.

These materials are commonly used in building construction for flooring, cabinetry, baseboards, window shades, interior doors, and window and door trims.” (Id., pp. 2-3.)

Mr. Offermann concludes that future full-time employees working at the proposed Project will be exposed to a cancer risk from formaldehyde of approximately 17.7 per million, even assuming that all materials are compliant with the California Air Resources Board’s formaldehyde airborne toxics control measure. (Id., p. 4.) This risk level exceeds the SCAQMD’s CEQA significance threshold for airborne cancer risk of 10 per million.

The California Supreme Court has emphasized the importance of air district significance thresholds in providing substantial evidence of a significant adverse environmental impact under CEQA. (Communities for a Better Environment v. South Coast Air Quality Management Dist. (2010) 48 Cal.4th 310, 327 [“As the [South Coast Air Quality Management] District’s established significance threshold for NOx is 55 pounds per day, these estimates [of NOx emissions of 201 to 456 pounds per day] constitute substantial evidence supporting a fair argument for a significant adverse impact.”].) Since expert evidence demonstrates that the Project will exceed the SCAQMD’s CEQA significance threshold, there is substantial evidence that an “unstudied, potentially significant environmental effect[]” exists. (See San Mateo Gardens, supra, 1 Cal.5th at 958.)

The EIR’s failure to address the Project’s formaldehyde emissions is also contrary to the California Supreme Court’s decision in California Building Industry Ass’n v. Bay Area Air Quality Mgmt. Dist. (2015) 62 Cal.4th 369, 386 (“CBIA”). In that case, the Supreme Court held that potentially adverse impacts to future users and residents resulting from a Project’s environmental impacts must be addressed by the CEQA review process. The issue before the Court in CBIA was whether an air district could enact CEQA guidelines that advised lead agencies that they must analyze the impacts of existing environmental conditions that occurred near a project site.

The Supreme Court held that CEQA does not generally require lead agencies to consider the environment’s effects on a project (CBIA, 62 Cal.4th at 385-88). However, it ruled that agencies must still consider the extent to which a project may exacerbate existing environmental conditions at or near a project site, insofar as those conditions may affect the project’s future users or residents. (Id. at 388.) Specifically, the Supreme Court wrote, CEQA’s statutory language requires lead agencies to disclose and analyze “impacts on a project’s users or residents that arise from the project’s effects on the environment.” (Id. at 387 [emph. added].)

The Supreme Court’s reasoning in CBIA is well-grounded in CEQA’s statutory language.

CEQA expressly identifies a project’s effects on human beings as an effect that must be addressed as part of an environmental review. “Section 21083(b)(3)’s express language, for example, requires a finding of a ‘significant effect on the environment’ (§ 21083(b)) whenever the ‘environmental effects of a project will cause substantial adverse effects on human beings, either directly or indirectly.’” (CBIA, 62 Cal.4th at 386.) Likewise, “the Legislature has made clear—in declarations accompanying CEQA’s enactment —that public health and safety are of November 8, 2022
EIR for the Crossings Campus Project

great importance in the statutory scheme.” (Id. [citing e.g., §§ 21000, subds. (b), (c), (d), (g), 21001, subds. (b), (d)].) It goes without saying that future employees of the Project are human beings. It is therefore axiomatic that the health and safety of those workers is subject to CEQA’s environmental safeguards.

B. The EIR Must Be Revised to Analyze and Mitigate the Project’s Significant Adverse Indoor Air Quality and Health Impacts.

The City has a duty to investigate issues relating to a project’s potential environmental impacts. (See County Sanitation Dist. No. 2 v. County of Kern (2005) 127 Cal.App.4th 1544, 1597–98. [“[U]nder CEQA, the lead agency bears a burden to investigate potential environmental impacts.”].) The proposed Project will have significant impacts on health and air quality by emitting cancer-causing levels of formaldehyde into the air that will expose future employees working at the Project site to cancer risks potentially in excess of SCAQMD’s significance threshold of 10 per million.

The carcinogenic formaldehyde emissions which Mr. Offermann identified are not an existing environmental condition. To the contrary, those emissions will be caused by the Project and will result in adverse effects on the environment. If built without appropriate mitigation, the Project will slowly emit formaldehyde over long periods of time to levels that pose significant direct and cumulative health risks to Project residents. As noted above, the Supreme Court in CBIA expressly found that a Project’s environmental impacts, including those that affect a “project’s users and residents,” must be addressed by the CEQA review process. Therefore, an EIR must be prepared to identify existing levels of TAC emissions near the Project site – such as those resulting from heavy daily truck traffic along the neighboring I-10 freeway– and the impact that those will have on the health of future employees. Moreover, an EIR must evaluate the cumulative adverse health effects that will affect future employees as a result of the Project’s indoor formaldehyde emissions and existing off-site TAC emissions.

Mr. Offermann concludes that these significant impacts should be analyzed in an EIR and that additional mitigation measures should be imposed to reduce the significant health risks that will result from indoor formaldehyde emissions. (Id., pp. 12-14.) Mr. Offermann proposes various feasible mitigation measures to reduce these impacts, including by imposing a requirement that the Project applicant install air filters throughout the building and commit to using only composite wood materials that are made with CARB approved no-added formaldehyde (NAF) resins, or ultra-low emitting formaldehyde (ULEF) resins, for all of the buildings’ interior spaces.

Mr. Offermann’s observations constitute substantial evidence that the Project will produce potentially significant air quality and health impacts which the EIR has failed to address.

Therefore, the City must therefore prepare a REIR to fully evaluate and mitigate these impacts to the Project’s future employees.

III. The EIR Inaccurately Asserts that the Project’s “Significant” Noise Impacts are “Unavoidable,” Yet Fails to Adopt All Feasible Mitigation Measures.

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EIR for the Crossings Campus Project

The EIR concludes that the Project’s noise impact will be significant and unavoidable.

But this assertion is improper because the EIR also proposes a draft Planning Commission Resolution (“Resolution No. 2022-P021” or “Resolution”) which requests that the Applicant be allowed to conduct construction activities outside of the established hours for normally permitted construction activities pursuant to the Culver City Municipal Code (PC Resolution, p. 1.)

The Resolution correctly notes that Section 9.07.035 of the Culver City Municipal Code “allows an applicant to request extended construction activity of a specific nature, with a limited duration, in nonresidential zoning districts, on construction sites one (1) acre or greater in size, if the exception is determined to be in the public interest [emph. added].” However, it offers no explanation of how it meets the public interest justification. Instead, it merely states that the Project’s extended construction hours, if permitted, “would reduce overall construction time by 30 days, reducing the time period where impacts to the neighboring properties would occur.” (Id., p. 3.) No analysis is provided to support this assertion. In fact, the EIR concedes elsewhere that, “During these extended construction hours (i.e., 7:00 a.m. to 8:00 a.m. and 8:00 p.m. to 10:00 p.m.) noise levels could still nonetheless exceed the thresholds as shown in Table 4.10- 10, and for this reason, would be considered potentially significant impacts [emph. added].” (EIR, p. 4.10-38.)

Separately, the EIR states that, “with respect to on-site construction equipment noise, noise barriers have a technical limitation with regard to height. It is not feasible to install a construction noise barrier of sufficient height that would block the line-of-sight for all noise- sensitive receptor locations, such as upper floor areas of the sensitive residential units, due to technical limitations including barrier foundation needs and wind load capacities. As such, as shown in Table 4.10-15, noise levels at the upper floors of receptor locations at R1, R2 and R3 would exceed the significant noise impact threshold after implementation of the prescribed mitigation measures. Accordingly, these impacts would be significant and unavoidable.” (Id.,

4.10-55.)

While it appears that certain technical issues would indeed limit the Applicant’s ability to reduce noise impacts to sensitive receptors living on higher floors of the surrounding residential buildings, it remains unclear how the Planning Division staff concluded that the proposed allowance for extended construction hours would provide the most effective alternative to reducing the Project’s significant noise impacts over an expected minimum of 35 months of construction. CEQA requires such considerations to be disclosed and analyzed by an EIR.

Furthermore, the EIR repeatedly asserts that the Project would comply with the noise element of the City’s 1996 General Plan. (See, e.g., NOI-PDF-4 (Compliance with Noise Element), EIR, p. 2-20). However, upon further examination, it is evident that the EIR would in fact only comply with select provisions of the noise element. It is not apparent how these provisions were selected or whether the Project would comply with additional provisions of the noise element which the EIR did not analyze.

Additionally, it is unclear why the EIR limits its analysis to the 1996 noise element.

Although this remains the City’s current noise element, numerous additional studies and community engagement meetings have been held since 2020, as part of the ongoing drafting of November 8, 2022
EIR for the Crossings Campus Project

the City’s 2045 General Plan Update (“GPU”).1 For instance, a 2020 Environmental Background Report prepared for the GPU observes:

The noise measurements show that generally, noise levels in Culver City have increased since 1995. The increase in noise levels is likely attributed to an increase in traffic volumes associated with overall increases in jobs and population in Culver City and the surrounding cities. […] There has also been an increase in aircraft overflight to and from LAX, discussed in further detail below under sections titled Noise Sources and Planned Improvements.” (Environmental Background Study, p. 3-25.) Separately, the Study discusses the impact of construction noise throughout the City: “Although construction and maintenance activities may only occur from a few days to a couple of months for smaller projects, the noise levels from these activities and projects with longer-term construction can at times, be quite high and very annoying to surrounding residents.

(Id., p. 3-30.)

Therefore, it is clear that significant new information—beyond that which was used to prepare the 1996 noise element—exists to inform the City’s review of the Project’s significant noise impacts. A lead agency’s failure to address a Project’s conflicts with an existing general plan or policy, such as is the case here, constitutes a per se significant impact under CEQA. (14 CCR § 15125(d); City of Long Beach v. Los Angeles Unif. School Dist. (2009) 176 Cal. App. 4th 889, 918.) Furthermore, based on the above-referenced findings from the 2020 Environmental Background Report, it is clear that the Project’s significant noise impacts must further be analyzed and mitigated as cumulative impacts which exacerbate the existing baseline noise conditions at the Project site. Therefore, the City should prepare a REIR to further analyze and mitigate the Project’s significant noise impacts to the maximum feasible extent possible.

IV. The EIR Fails to Provide Substantial Evidence In Support Of the Statement of Overriding Considerations.

The EIR concludes that the Project will have significant, unmitigated air quality and noise impacts, and as required, provides a statement of overriding considerations. Under CEQA, when an agency approves a project with significant environmental impacts that will not be fully mitigated, it must adopt a “statement of overriding considerations,” finding that, because of the project’s overriding benefits, it is approving the project despite its adverse environmental impacts. (14 Cal. Code Regs. §15043; Pub. Res. Code §21081(b); Sierra Club v. Contra Costa County (1992) 10 Cal.App.4
th 1212, 1222). A statement of overriding considerations expresses the “larger, more general reasons for approving the project, such as the need to create new jobs, provide housing, generate taxes and the like.” (Concerned Citizens of South Central LA v. Los Angeles Unif. Sch. Dist. (1994) 24 Cal.App.4
th 826, 847.)

A statement of overriding considerations must be supported by substantial evidence in the

1 Additional information available at: https://www.pictureculvercity.com/#home-section November 8, 2022
EIR for the Crossings Campus Project

record. (14 Cal.Code Regs. §15093(b); Sierra Club v. Contra Costa Co. (1992) 10 Cal.App.4th 1212, 1223).) The agency must make “a fully informed and publicly disclosed” decision that “specifically identified expected benefits from the project outweigh the policy of reducing or avoiding significant environmental impacts of the project.” (15 Cal.Code Regs. §15043(b).) As with all findings, the agency must present an explanation to supply the logical steps between the ultimate finding and the facts in the record. (Topanga Assn. for a Scenic Community v. County of Los Angeles (1974) 11 Cal.3d 506, 515.) Key among the findings that the lead agency must make is that:

Specific economic, legal, social, technological, or other considerations, including the provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or alternatives identified in the environmental impact report[,] [and that those] benefits of the project outweigh the significant effects on the environment.

(Pub. Res. Code §21081(a)(3), (b) [emph. added].)

Thus, the City must make specific findings, supported by substantial evidence, concerning both the environmental impacts of the Project, and the economic benefits including “the provision of employment opportunities for highly trained workers.” Although the EIR presents a statement of overriding considerations, it fails to provide substantial evidence to support its conclusions.

First, it states the Project would “support environmental sustainability and reduce energy consumption and water demand through sustainable building design and building features,” to such an extent that these benefits would outweigh the Project’s likely adverse environmental impacts. (See, EIR, p. 6-4.) However, this statement does not withstand scrutiny. As detailed above, the Project fails to adopt feasible renewable energy alternatives, including rooftop solar panels that would reduce the building’s consumption of non-renewable fossil fuels.

Similarly, it states that the Project would “support City and regional goals and polices to reduce vehicle miles traveled (VMT) and associated greenhouse gas and regional pollutant emissions by increasing employee density in proximity to transit, including the Los Angeles County Metropolitan Transportation Authority (Metro) “E” Line and numerous bus routes.” However, as made clear above, the assertion that the Project will comply with the City’s existing commitment to reduce its GHG emissions and VMT impacts is not supported by substantial evidence.

Lastly, as discussed above, the statement fails to adequately disclose the extent of existing baseline noise conditions, nor does it consider the findings of recent technical studies prepared by the City’s own staff which show increasing cumulative noise impacts upon local residents. Therefore, a REIR should be prepared to further address these adverse impacts, and to include substantial evidence in support of any assertion that they are outweighed by the Project’s expected economic benefits.

V. CONCLUSION
November 8, 2022
EIR for the Crossings Campus Project

In conclusion, SAFER believes that the EIR fails as an informational document, fails to implement all feasible mitigation measures to reduce the Project’s adverse environmental impacts, and fails to support its statement of overriding considerations with substantial evidence.

In contrast, SAFER has presented substantial evidence of the EIR’s various shortcomings and its corresponding failure to adequately disclose or mitigate the Project’s likely significant adverse impacts. Therefore, we respectfully request that the Planning Commission recommend that the City Council deny approval of the EIR and instead direct City staff to prepare a REIR in accordance with CEQA’s public review provisions.

Sincerely,

Adam Frankel

LOZEAU DRURY LLP

EXHIBIT A

2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
[email protected]
Paul E. Rosenfeld, PhD
(310) 795-2335
[email protected]
November 4, 2022
Adam Frankel
Lozeau | Drury LLP
1939 Harrison Street, Suite 150
Oakland, CA 94618
Subject: Comments on the Crossings Campus Project (SCH No. 2021110079) Dear Mr. Frankel,
We have reviewed the October 2022 Final Environmental Impact Report (“FEIR”) and July 2022 Draft Environmental Impact Report (“DEIR”) for the Crossings Campus Project (“Project”) located in Culver City (“City”). The Project proposes the development of two buildings. Building 1 proposes to demolish 18,821-square-feet (“SF”) of existing buildings and construct 167,000-SF of office space and 478 parking spaces, while Building 2 proposes to demolish 86,226-SF of existing buildings and construct 369,000-SF of office space and 738 parking spaces, all on the 4.46-acre site.

Our review concludes that the DEIR fails to adequately evaluate the Project’s air quality, health risk, and greenhouse gas impacts. As a result, emissions and health risk impacts associated with construction and operation of the proposed Project are underestimated and inadequately addressed. A revised EIR should be prepared to adequately assess and mitigate the potential air quality, health risk, and greenhouse gas impacts that the project may have on the environment.

Air Quality
Failure to Implement All Feasible Mitigation to Reduce Emissions The DEIR’s air quality analysis relies upon an incorrect and unsubstantiated air model to determine the significance of the Project’s criteria air pollutant emissions, as discussed below. Despite the DEIR’s reliance upon a flawed air model, the Project’s criteria air pollutant emissions estimates indicate a significant air quality impact. Specifically, the DEIR estimates that the Project’s combined construction and operational NOX emissions would exceed the applicable SCAQMD threshold (see excerpt below) (p.

4.2-49, Table 4.2-10).

2 As such, the DEIR concludes that the impacts associated with Project construction and operation would be significant-and-unavoidable (p. 4.2-49). The DEIR states:
“[S]hort-term and temporary impacts related to regional NOX overlapping construction and operations emissions would be significant and unavoidable after implementation of feasible mitigation measures.” (p. 4.2-49).

However, while we agree that the Project’s criteria air pollutant emissions would result in a significant air quality impact, the DEIR’s conclusion that these impacts are “significant and unavoidable” is incorrect. According to CEQA Guidelines § 15096(g)(2):
“When an EIR has been prepared for a project, the Responsible Agency shall not approve the project as proposed if the agency finds any feasible alternative or feasible mitigation measures within its powers that would substantially lessen or avoid any significant effect the project would have on the environment.”
As demonstrated above , an impact can only be labeled as significant and unavoidable after all available, feasible mitigation is considered. Here, while the FEIR includes Mitigation Measure (“MM”) AQ-1, the DEIR and FEIR fail to implement all feasible mitigation (FEIR, p. 4-3, 4-4). Therefore, the DEIR and FEIR’s conclusion that the Project’s air quality impacts are significant-and-unavoidable is unsubstantiated. To reduce the Project’s air quality impacts to the maximum extent possible, additional feasible mitigation

3 measures should be incorporated, such as those suggested in the section of this letter titled “Feasible Mitigation Measures Available to Reduce Emissions.” Thus, the Project should not be approved until a revised EIR is prepared, incorporating all feasible mitigation to reduce emissions to less-than-significant levels.

Unsubstantiated Input Parameters Used to Estimate Project Emissions The DEIR’s air quality analysis relies on emissions calculated with the California Emissions Estimator Model (“CalEEMod”) Version 2020.4.0 (p. 4.9-29).1 CalEEMod provides recommended default values based on site-specific information, such as land use type, meteorological data, total lot acreage, project type and typical equipment associated with project type. If more specific project information is known, the user can change the default values and input project-specific values, but the California Environmental Quality Act (“CEQA”) requires that such changes be justified by substantial evidence.

Once all of the values are inputted into the model, the Project’s construction and operational emissions are calculated, and “output files” are generated. These output files disclose to the reader what parameters are utilized in calculating the Project’s air pollutant emissions and make known which default values are changed as well as provide justification for the values selected.

When reviewing the Project’s CalEEMod output files, provided in the Air Quality and Greenhouse Gas Emissions Calculations (“AQ & GHG Report”) as Appendix B to the DEIR, we found that several model inputs were not consistent with information disclosed in the DEIR. As a result, the Project’s construction and operational emissions are underestimated. A revised EIR should be prepared to include an updated air quality analysis that adequately evaluates the impacts that construction and operation of the Project will have on local and regional air quality.

Failure to Model Proposed Parking Land Use
According to the FEIR:
“Building 1 would be four stories, measuring up to 56 feet in height to the top of the roofline, with a three-level subterranean garage containing 478 vehicular parking spaces and 51 bicycle parking spaces. […] Building 2 would be four to five stories, measuring 56 feet to 75 feet in height to the top of the roof, with a three-level subterranean garage containing 738 vehicular parking spaces and 124 bicycle parking spaces.” (p. 1-2).

As such, the models should have included 478 and 738 parking spaces, respectively. However, review of the CalEEMod output files demonstrates that the “Culver Crossing B1” and “Culver Crossings B2” models fail to include any amount of parking (see excerpt below) (Appendix B, pp. 21, 56, 91, 131, 167, 203, 244, 281, 318, 355).

1 “CalEEMod Version 2020.4.0.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at: https://www.aqmd.gov/caleemod/download-model.
4 Culver Crossing B1

Culver Crossings B2

As demonstrated above, the models fail to include any of the respective 478 and 738 proposed parking spaces. These omissions present an issue, as the square footage of parking land uses is used for certain calculations such as determining the area to be painted and stripped (i.e., VOC emissions from architectural coatings) and area to include lighting (i.e., energy impacts). 2 Thus, by failing to include the proposed parking spaces, the models underestimate the Project’s construction-related and operational emissions and should not be relied upon to determine Project significance.

Unsubstantiated Changes to Individual Construction Phase Lengths Review of the CalEEMod output files demonstrates that the “Culver Crossing B1” and “Culver Crossings B2” models include several changes to the default individual construction phase lengths (see excerpt below) (Appendix B, pp. 22, 57, 92, 132, 168, 204, 245, 282, 319, 356). “Culver Crossing B1”

“Culver Crossings B2”

As a result of these changes, the models include the following construction schedules (see excerpts below) (Appendix B, pp. 27, 62, 97, 137, 173, 209, 252, 289, 326, 363):

2 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 2, 22.

5 Culver Crossing B1

Culver Crossings B2

As demonstrated above, the “Culver Crossing B1” model’s demolition phase increases by 25%, from the default value of 20 to 25 days; the site preparation phase increases by 1,300% from the default value of 2 to 28 days; the grading/excavation phase increases by 2,025%, from the default value of 4 to 85 days; the foundations/concrete pours phase decreases by 16%, from the default value of 200 to 168 days; the building construction phase increases by 55%, from the default value of 200 to 310 days; the paving phase increases by 1,000%, from the default value of 10 to 110 days; and the architectural coating phase increases by 1,170%, from the default value of 10 to 127 days. Furthermore, the “Culver Crossings B2” model’s demolition phase increases by 145%, from the default value of 20 to 49 days; the site preparation phase increases by 1,933%, from the default value of 3 to 61 days; the grading/excavation phase increases by 2,350% from the default value of 6 to 147 days; the foundations/concrete pour phase increases by 27%, from the default value of 220 to 280 days; the building construction phase increases by 24%, from the default value of 220 to 273; the paving phase increases by 570%, from the default value of 10 to 67; and the architectural coating phase increases by 87%, from the default value of 10 to 97 days. As previously mentioned, the CalEEMod User’s Guide requires any changes to model

6 defaults be justified.3 According to the “User Entered Comments & Non-Default Data” table, the justification provided for these changes is:
“Provided by client” (Appendix B, pp. 21, 56, 91, 131, 167, 203, 244, 281, 318, 355).

Regarding the Project’s anticipated construction duration, the DEIR states:
“Building 1 and Building 2 were separated assuming Building 1 begins in the first quarter of 2023 and is completed in the fourth quarter of 2024 and Building 2 begins in the third quarter of 2023 and ends in the fourth quarter of 2025” (p. 2-18).

Furthermore, the DEIR states:
“A preliminary Construction Management Plan is required as part of the entitlement processing phase of the Project. This plan would define the scope and scheduling of planned construction activities” (p. 2-17).

However, these changes remain unsupported. While the DEIR indicates the total construction duration, the DEIR fails to mention or justify the individual construction phase lengths. Futhermore, the above- mentioned Construction Management Plan also fails to mention or justify the individual construction phase lengths, as provided by the client. This is incorrect, as according to the CalEEMod User’s Guide:
“CalEEMod was also designed to allow the user to change the defaults to reflect site- or project- specific information, when available, provided that the information is supported by substantial evidence as required by CEQA.”
4 Here, as the DEIR only justifies the total construction duration of approximately 35 months, the DEIR fails to provide substantial evidence to support the revised individual construction phase lengths. As such, we cannot verify the changes.

These unsubstantiated changes present an issue, as the construction emissions are improperly spread out over a longer period of time for some phases, but not for others. According to the CalEEMod User’s Guide, each construction phase is associated with different emissions activities (see excerpt below). 5 3 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 1, 14.
4 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 13, 14.
5 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 32.
7 Thus, by disproportionately altering and extending some of the individual construction phase lengths without proper justification, the models assume there are a greater number of days to complete the construction activities required by the prolonged phases. As a result, there will be less construction activities required per day and, consequently, less pollutants emitted per day. Therefore, the model may underestimate the peak daily emissions associated with some phases of construction and should not be relied upon to determine Project significance, as the potentially shorter phases may result in increased emissions. As such, until the Construction Management Plan is updated to explicitly require the revised individual phase lengths, models should have proportionately altered all phase lengths to match the proposed total construction duration of 35 months.

Unsubstantiated Analysis of Construction Mobile-Source Emissions Review of the CalEEMod output files demonstrates that the “Culver Crossing B1” and “Culver Crossings B2” models fail to estimate the mobile-source emissions associated with Project construction (see excerpt below) (Appendix B, pp. 29, 64, 100, 140, 176, 212, 213).

As demonstrated above, the model fails to include any worker, vendor, or hauling trip numbers. As previously mentioned, the CalEEMod User’s Guide requires any changes to model defaults be justified.6

6 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 1, 14.

8 According to the “User Entered Comments & Non-Default Data” table, the justification provided for these changes is:
“Calculated using EMFAC 2021 outside of CalEEMod.” (Appendix B, pp. pp. 21, 56, 91, 132, 168, 204).

Furthermore, the AQ & GHG Report provides the following worker, vendor, and hauling trip assumptions (Appendix B, pp. 3):

However, these justifications remain insufficient as the AQ & GHG Report fails to provide a source for or the above the worker, vendor, and hauling trip numbers or provide the specific calculations to demonstrate how the mobile-source construction emissions were estimated outside of CalEEMod. As such, we cannot verify the specific values. This is incorrect, as according to the CalEEMod User’s Guide:
“CalEEMod was also designed to allow the user to change the defaults to reflect site- or project- specific information, when available, provided that the information is supported by substantial evidence as required by CEQA.” 7
Here, as the AQ & GHG Report fails to provide substantial evidence to support the mobile-source construction emissions estimates, we cannot verify the analysis.

These unsubstantiated calculations present an issue, as CalEEMod uses the mobile-source construction emissions to estimate the construction-related emissions associated with on-road vehicles.8 By omitting worker, vendor, and hauling trips from the emissions analysis, the models may underestimate the

7 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 13, 14.
8 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 35.

9 Project’s mobile-source construction-related emissions and should not be relied upon to determine Project significance.

Diesel Particulate Matter Emissions Inadequately Evaluated The DEIR concludes that the Project would have a less-than-significant health risk impact without conducting a quantified construction or operational health risk analysis (“HRA”). Regarding the health risk impacts associated with the Project construction, the DEIR states:
“Temporary TAC emissions associated with DPM emissions from heavy construction equipment would occur during the construction phase of the Project. According to OEHHA and the SCAQMD Health Risk Assessment Guidance for Analyzing Cancer Risks from Mobile Source Diesel Idling Emissions for CEQA Air Quality Analysis,67 health effects from TACs are described in terms of individual cancer risk based on a lifetime (i.e., 70-year) resident exposure duration. Given the temporary construction schedule (approximately 35 months), the Project would not result in a long-term (i.e., lifetime or 70-year) exposure as a result of Project construction. Additionally, SCAQMD’s CEQA guidance does not require a health risk assessment for short-term construction emissions. It is, therefore, not necessary to quantitatively evaluate long-term cancer impacts from construction activities, which occur over a relatively short duration” (p. 4.2-54).

As demonstrated above, the DEIR states that the Project would result in a less-than-significant construction-related health risk impact because the short-term construction duration would not result in significant toxic air contaminants (“TAC”) emissions. Furthermore, regarding the health risk impacts associated with the Project operation, the DEIR states:
“The SCAQMD recommends that operational health risk assessments be conducted for substantial sources of operational DPM (e.g., truck stops and warehouse distribution facilities that generate more than 100 trucks per day or more than 40 trucks with operating transport refrigeration units) and has provided guidance for analyzing mobile source diesel emissions.68 The Project would not include any truck stop or warehouse distribution uses, and, as such, operations would generate only minor amounts of diesel emissions from mobile sources, such as delivery trucks and occasional maintenance. Furthermore, Project trucks would be required to comply with the applicable provisions of 13 CCR, Section 2025 (Truck and Bus regulation) to minimize and reduce PM10, PM2.5, and NOX emissions from existing diesel trucks. Therefore, Project operation would not be considered a substantial source of DPM” (p. 4.2-55).

As demonstrated above, the DEIR states that Project operation would not result in significant DPM emissions because the proposed Project would not generate more than 100 daily truck trips and would comply with applicable regulations for diesel trucks. However, the DEIR’s evaluation of the Project’s potential health risk impacts, as well as the subsequent less-than-significant impact conclusion, is incorrect for three reasons.

First, by failing to prepare a quantified construction and operational HRA, the Project is inconsistent with CEQA’s requirement to make “a reasonable effort to substantively connect a project’s air quality impacts 10 to likely health consequences.” 9 This poses a problem, as according to the DEIR, construction of the Project would produce DPM emissions through the exhaust stacks of construction equipment over a duration of approximately 35 months (p. 4.2-64). Furthermore, operation of the Project is anticipated to generate a net increase of 412 daily vehicle trips, which would produce additional exhaust emissions and continue to expose nearby, existing sensitive receptors to DPM emissions (Appendix M, pp. 60, Table 8). However, the DEIR fails to evaluate the TAC emissions associated with Project construction and operation or indicate the concentrations at which such pollutants would trigger adverse health effects.

Thus, without making a reasonable effort to connect the Project’s TAC emissions to the potential health risks posed to nearby receptors, the DEIR is inconsistent with CEQA’s requirement to correlate Project- generated emissions with potential adverse impacts on human health.

Second, the Office of Environmental Health Hazard Assessment (“OEHHA”), the organization responsible for providing guidance on conducting HRAs in California, released its most recent Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments in February 2015. This guidance document describes the types of projects that warrant the preparation of an HRA. Specifically, OEHHA recommends that all short-term projects lasting at least 2 months assess cancer risks.10 Furthermore, according to OEHHA:
“Exposure from projects lasting more than 6 months should be evaluated for the duration of the project. In all cases, for assessing risk to residential receptors, the exposure should be assumed to start in the third trimester to allow for the use of the ASFs (OEHHA, 2009).”11 Thus, as the Project’s anticipated construction duration exceeds the 2-month and 6-month requirements set forth by OEHHA, construction of the Project meets the threshold warranting a quantified HRA under OEHHA guidance and should be evaluated for the entire 35-month construction period. Furthermore, OEHHA recommends that an exposure duration of 30 years should be used to estimate the individual cancer risk at the maximally exposed individual resident (“MEIR”).12 While the DEIR fails to provide the expected lifetime of the proposed Project, we can reasonably assume that the Project would operate for at least 30 years, if not more. Therefore, operation of the Project also exceeds the 2-month and 6-month requirements set forth by OEHHA and should be evaluated for the entire 30- year residential exposure duration, as indicated by OEHHA guidance. These recommendations reflect the most recent state health risk policies, and as such, a revised EIR should be prepared to include an analysis of health risk impacts posed to nearby sensitive receptors from Project-generated DPM emissions.

9 “Sierra Club v. County of Fresno.” Supreme Court of California, December 2018, available at:
https://ceqaportal.org/decisions/1907/Sierra%20Club%20v.%20County%20of%20Fresno.pdf. 10 “Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 8-18. 11 “Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 8-18. 12 “Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 2-4. 11 Third, by claiming a less-than-significant impact without conducting a quantified construction or operational HRA for nearby, existing sensitive receptors, the DEIR fails to compare the Project’s excess cancer risk to the SCAQMD’s specific numeric threshold of 10 in one million.13 Thus, in accordance with the most relevant guidance, an assessment of the health risk posed to nearby, existing receptors as a result of Project construction and operation should be conducted.

Screening-Level Analysis Demonstrates Potentially Significant Health Risk Impact In order to conduct our screening-level risk assessment we relied upon AERSCREEN, which is a screening level air quality dispersion model.14 As discussed above, the model replaced SCREEN3, and AERSCREEN is included in the OEHHA and the California Air Pollution Control Officers Associated (“CAPCOA”) guidance as the appropriate air dispersion model for Level 2 health risk screening assessments (“HRSAs”).15, 16 A Level 2 HRSA utilizes a limited amount of site-specific information to generate maximum reasonable downwind concentrations of air contaminants to which nearby sensitive receptors may be exposed. If an unacceptable air quality hazard is determined to be possible using AERSCREEN, a more refined modeling approach is required prior to approval of the Project.

We prepared a preliminary HRA of the Project’s construction and operational health risk impact to residential sensitive receptors using the annual PM
10 exhaust estimates from the DEIR’s CalEEMod
output files. Consistent with recommendations set forth by OEHHA, we assumed residential exposure begins during the third trimester stage of life.17 The DEIR’s CalEEMod model indicates that construction activities will generate approximately 1,767 pounds of DPM over the 1,038-day construction period.18 The AERSCREEN model relies on a continuous average emission rate to simulate maximum downward concentrations from point, area, and volume emission sources. To account for the variability in equipment usage and truck trips over Project construction, we calculated an average DPM emission rate by the following equation:

𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅 �𝑔𝑔𝑔𝑔𝑅𝑅𝐸𝐸𝐸𝐸
𝐸𝐸 𝑅𝑅 𝑠𝑠 𝐸𝐸𝐸𝐸𝑠𝑠� = 1766.6 𝑙𝑙𝑙𝑙 𝐸𝐸
1038 𝑠𝑠 𝑅𝑅𝑑𝑑 𝐸𝐸 × 453.6 𝑔𝑔𝑔𝑔𝑅𝑅𝐸𝐸𝐸𝐸
𝑙𝑙 𝑙𝑙 𝐸𝐸 × 1 𝑠𝑠 𝑅𝑅 𝑑𝑑
24 ℎ𝐸𝐸 𝑜𝑜𝑔𝑔 𝐸𝐸 × 1 ℎ𝐸𝐸 𝑜𝑜𝑔𝑔
3,600 𝐸𝐸 𝑅𝑅 𝑠𝑠 𝐸𝐸𝐸𝐸 𝑠𝑠 𝐸𝐸 = 𝟎𝟎. 𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎 𝒈𝒈/𝒔𝒔
Using this equation, we estimated a construction emission rate of 0.00894 grams per second (“g/s”).

Subtracting the 1,038-day construction period from the total residential duration of 30 years, we assumed that after Project construction, the sensitive receptor would be exposed to the Project’s operational DPM for an additional 27.16 years. The DEIR’s operational CalEEMod emissions indicate that

13 “South Coast AQMD Air Quality Significance Thresholds.” SCAQMD, April 2019, available at:
http://www.aqmd.gov/docs/default-source/ceqa/handbook/scaqmd-air-quality-significance-thresholds.pdf. 14 “AERSCREEN Released as the EPA Recommended Screening Model,” U.S. EPA, April 2011, available at:
http://www.epa.gov/ttn/scram/guidance/clarification/20110411_AERSCREEN_Release_Memo.pdf 15 “Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf. 16 “Health Risk Assessments for Proposed Land Use Projects.” CAPCOA, July 2009, available at:
http://www.capcoa.org/wp-content/uploads/2012/03/CAPCOA_HRA_LU_Guidelines_8-6-09.pdf. 17 “Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 8-18. 18 See Attachment A for health risk calculations.
12 operational activities will generate approximately 106 net pounds of DPM per year throughout operation. Applying the same equation used to estimate the construction DPM rate, we estimated the following emission rate for Project operation:

𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅 �𝑔𝑔𝑔𝑔𝑅𝑅𝐸𝐸𝐸𝐸
𝐸𝐸 𝑅𝑅 𝑠𝑠 𝐸𝐸𝐸𝐸 𝑠𝑠� = 105.5 𝑙𝑙𝑙𝑙 𝐸𝐸
365 𝑠𝑠 𝑅𝑅𝑑𝑑 𝐸𝐸 × 453.6 𝑔𝑔𝑔𝑔𝑅𝑅 𝐸𝐸𝐸𝐸
𝑙𝑙 𝑙𝑙 𝐸𝐸 × 1 𝑠𝑠 𝑅𝑅 𝑑𝑑
24 ℎ𝐸𝐸𝑜𝑜𝑔𝑔 𝐸𝐸 × 1 ℎ𝐸𝐸 𝑜𝑜𝑔𝑔
3,600 𝐸𝐸 𝑅𝑅 𝑠𝑠 𝐸𝐸𝐸𝐸 𝑠𝑠 𝐸𝐸= 𝟎𝟎. 𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎 𝒈𝒈/𝒔𝒔

Using this equation, we estimated an operational emission rate of 0.00152 g/s. Construction and operation were simulated as a 4.46-acre rectangular area source in AERSCREEN, with approximate dimensions of 190- by 95-meters. A release height of three meters was selected to represent the height of stacks of operational equipment and other heavy-duty vehicles, and an initial vertical dimension of one and a half meters was used to simulate instantaneous plume dispersion upon release. An urban meteorological setting was selected with model-default inputs for wind speed and direction distribution.

The population of Culver City was obtained from U.S. 2020 Census data. 19 The AERSCREEN model generates maximum reasonable estimates of single-hour DPM concentrations from the Project Site. The United States Environmental Protection Agency (“U.S. EPA”) suggests that the annualized average concentration of an air pollutant be estimated by multiplying the single-hour concentration by 10% in screening procedures.20 According to the DEIR the nearest sensitive receptors are residential uses located approximately 100 feet, or 30 meters from the Project site (p. 4.2-22).

However, review of the AERSCREEN output files demonstrates that the MEIR is located approximately 100 meters from the Project site. Thus, the single-hour concentration estimated by AERSCREEN for Project construction is approximately 16.94 µg/m3 DPM at approximately 100 meters downwind.

Multiplying this single-hour concentration by 10%, we get an annualized average concentration of 1.694 µg/m3 for Project construction at the MEIR. For Project operation, the single-hour concentration estimated by AERSCREEN is 2.876 µg/m3 DPM at approximately 100 meters downwind. Multiplying this single-hour concentration by 10%, we get an annualized average concentration of 0.2876 µg/m3 for Project operation at the MEIR.

We calculated the excess cancer risk to the MEIR using applicable HRA methodologies prescribed by OEHHA, as recommended by SCAQMD.21 Specifically, guidance from OEHHA and the CARB recommends the use of a standard point estimate approach, including high-point estimate (i.e. 95th percentile) breathing rates and age sensitivity factors (“ASF”) in order to account for the increased sensitivity to carcinogens during early-in-life exposure and accurately assess risk for susceptible subpopulations such as children. The residential exposure parameters, such as the daily breathing rates (“BR/BW”), exposure

19 “Culver City.” U.S. Census Bureau, 2020, available at: https://datacommons.org/place/geoId/0617568. 20 “Screening Procedures for Estimating the Air Quality Impact of Stationary Sources Revised.” U.S. EPA, October 1992, available at: http://www.epa.gov/ttn/scram/guidance/guide/EPA-454R-92-019_OCR.pdf. 21 “AB 2588 and Rule 1402 Supplemental Guidelines.” SCAQMD, October 2020, available at:
http://www.aqmd.gov/docs/default-source/planning/risk-assessment/ab-2588-supplemental- guidelines.pdf?sfvrsn=19, p. 2.
13 duration (“ED”), age sensitivity factors (“ASF”), fraction of time at home (“FAH”), and exposure frequency (“EF”) utilized for the various age groups in our screening-level HRA are as follows:

Exposure Assumptions for Residential Individual Cancer Risk Age Group
Breathing
Rate
(L/kg-day)22
Age
Sensitivity
Factor23
Exposure
Duration
(years)
Fraction of
Time at
Home24
Exposure
Frequency
(days/year)25
Exposure
Time
(hours/day)
3rd Trimester 361 10 0.25 1 350 24
Infant (0 - 2) 1090 10 2 1 350 24
Child (2 - 16) 572 3 14 1 350 24
Adult (16 - 30) 261 1 14 0.73 350 24
For the inhalation pathway, the procedure requires the incorporation of several discrete variates to effectively quantify dose for each age group.

Once determined, contaminant dose is multiplied by the
cancer potency factor (“CPF”) in units of inverse dose expressed in milligrams per kilogram per day (mg/kg/day-1) to derive the cancer risk estimate. Therefore, to assess exposures, we utilized the following dose algorithm:

𝐷𝐷𝐸𝐸𝐸𝐸
𝑅𝑅𝐴𝐴𝐴𝐴𝐴𝐴,𝑝𝑝𝑝𝑝𝑝𝑝 𝑎𝑎𝑎𝑎𝑝𝑝 𝑎𝑎 𝑝𝑝 𝑔𝑔𝑔𝑔𝑝𝑝= 𝐶𝐶𝑎𝑎𝑎𝑎𝑝𝑝× 𝐸𝐸𝐸𝐸 × �𝐵𝐵 𝑅𝑅 𝐵𝐵𝐵𝐵� × 𝐴𝐴 × 𝐶𝐶 𝐸𝐸
where:

DoseAIR = dose by inhalation (mg/kg/day), per age group Cair = concentration of contaminant in air (μg/m3)
EF = exposure frequency (number of days/365 days)
BR/BW = daily breathing rate normalized to body weight (L/kg/day) A = inhalation absorption factor (default = 1)
CF = conversion factor (1x10-6, μg to mg, L to m3)

22 “Supplemental Guidelines for Preparing Risk Assessments for the Air Toxics ‘Hot Spots’ Information and Assessment Act.” SCAQMD, October 2020, available at: http://www.aqmd.gov/docs/default-source/planning/risk- assessment/ab-2588-supplemental-guidelines.pdf?sfvrsn=19, p. 19; see also “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at:
https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf. 23 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 8-5 Table 8.3. 24 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 5-24. 25 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 5-24. 14 To calculate the overall cancer risk, we used the following equation for each appropriate age group:

𝐶𝐶
𝑅𝑅𝐸𝐸𝑠𝑠𝑅𝑅𝑔𝑔 𝑅𝑅𝐸𝐸𝐸𝐸𝑅𝑅𝐴𝐴𝐴𝐴𝐴𝐴= 𝐷𝐷𝐸𝐸𝐸𝐸 𝑅𝑅 𝐴𝐴𝐴𝐴𝐴𝐴 × 𝐶𝐶𝐶𝐶 𝐸𝐸 × 𝐴𝐴𝐴𝐴 𝐸𝐸 × 𝐸𝐸𝐴𝐴 𝐹𝐹 × 𝐸𝐸 𝐷𝐷 𝐴𝐴𝐴𝐴
where:

DoseAIR = dose by inhalation (mg/kg/day), per age group CPF = cancer potency factor, chemical-specific (mg/kg/day)-1 ASF = age sensitivity factor, per age group
FAH = fraction of time at home, per age group (for residential receptors only) ED = exposure duration (years)
AT = averaging time period over which exposure duration is averaged (always 70 years) Consistent with the 1038-day construction schedule, the annualized average concentration for construction was used for the entire third trimester of pregnancy (0.25 years), infantile stage of life (0 – 2 years), and the first 0.59 years of the child stage of life (2 – 16 years). The annualized average concentration for operation was used for the remainder of the 30-year exposure period, which makes up the latter 13.41 years of the child stage of life, as well as the entire adult (16 – 30 years) stage of life.

The results of our calculations are shown in the table below.

The Maximally Exposed Individual at an Existing Residential Receptor Age Group Emissions Source Duration (years) Concentration (ug/m3) Cancer Risk
3rd Trimester Construction 0.25 1.6940 2.30E-05
Infant (0 - 2) Construction 2 1.6940 5.56E-04
Construction 0.59 1.6940 2.60E-05
Operation 13.41 0.2876 9.97E-05
Child (2 - 16) Total 14 1.26E-04
Adult (16 - 30) Operation 14 0.2876 1.16E-05
Lifetime 30 7.17E-04
As demonstrated in the table above, the excess cancer risks for the 3rd trimester of pregnancy, infants, children, and adults at the MEIR located approximately 100 meters away, over the course of Project construction and operation, are approximately 23.0, 556, 126, and 11.6 in one million, respectively. The excess cancer risk over the course of a residential lifetime (30 years) is approximately 717 in one million.

The 3
rd trimester, infant, child, adult, and lifetime cancer risks exceed the SCAQMD threshold of 10 in 15 one million, thus resulting in a potentially significant impact not previously addressed or identified by the DEIR.

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

EPA, 1992).

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

The exposure assessor or risk manager can then determine whether the results of the screening- level assessment warrant further evaluation through refinements of the input data and exposure assumptions or by using more advanced models.” As demonstrated above, screening-level analyses warrant further evaluation in a refined modeling approach. Thus, as our screening-level HRA demonstrates that construction and operation of the Project could result in a potentially significant health risk impact, a revised EIR should be prepared to include a refined health risk analysis which adequately and accurately evaluates health risk impacts associated with both Project construction and operation.

Greenhouse Gas
Failure to Adequately Evaluate Greenhouse Gas Impacts
The DEIR estimates that the proposed Project would generate net annual greenhouse gas (“GHG”) emissions of 7,218- and 9,023-metric tons of carbon dioxide equivalents per year (“MT CO 2e/year”),
with and without GHG reduction measures (p. 4.6-65, Table 4.6-11). 16 However, the DEIR does not elect to utilize a numeric threshold to quantitatively evaluate the Project’s GHG emissions. Rather, the DEIR states:
“In the absence of any adopted, quantitative threshold, the Project would not have a significant effect on the environment if the Project is found to be consistent with the applicable regulatory plans and policies to reduce GHG emissions, including the emissions reduction measures discussed within CARB’s Climate Change Scoping Plan, 2020–2045 RTP/SCS, and City of Culver City’s and City of Los Angeles’s plans, programs, and policies including Culver City’s Green Building Program, City of Los Angeles’s Green New Deal/Sustainable City pLAn, and City of Los Angeles’s Green Building Program (as discussed in subsection, Local) established for the purpose of increasing energy efficiency and reducing GHG emissions for new developments” (p. 4.6-36 –

4.6-37).

As such, the DEIR’s analysis relies upon the applicable regulatory plans and policies to conclude that the Project would result in a less-than-significant GHG impact. However, the DEIR’s analysis, as well as the subsequent less-than-significant impact conclusion, is incorrect for two reasons.

17 (1) The DEIR fails to identify a potentially significant GHG impact; (2) The DEIR fails to consider the performance-based standards under CARB’s Scoping Plan; and (3) The DEIR fails to consider the performance-based standards under SCAG’s RTP/SCS. 1) Failure to Identify a Potentially Significant GHG Impact In an effort to quantitatively evaluate the Project’s GHG emissions, we compared the Project’s GHG emissions, as estimated by the DEIR, to the SCAQMD interim bright-line threshold of 3,000 MT CO2e/year for the year 2020.26 The guidance that provided the 3,000 MT CO2e/year threshold, SCAQMD’s 2008 Interim CEQA GHG Significance Threshold for Stationary Sources, Rules, and Plans report, was developed when the Global Warming Solutions Act of 2006, commonly known as “AB 32”, was the governing statute for GHG reductions and required California to reduce GHG emissions to 1990 levels by 2020.27
As previously stated, DEIR estimates that the proposed Project would generate net annual GHG emissions of 7,218-MT CO2e/year, with GHG reduction measures (p. 4.6-65, Table 4.6-11). When applying this threshold, the Project’s air models indicate a potentially significant GHG impact (see table below).

DEIR Greenhouse Gas Emissions
Annual Emissions with GHG Reduction Measures
(MT CO2e/year) 7,218
SCAQMD Interim Threshold (MT CO2e/year) 3,000
Exceeds? Yes
As demonstrated above, the Project’s estimated annual GHG emissions with GHG reduction measures exceed the SCAQMD interim threshold of 3,000 MT CO
2e/year, thus resulting in a significant impact not
previously addressed or mitigated in the DEIR. As a result, the DEIR’s less-than-significant GHG impact conclusion should not be relied upon. A revised EIR should be prepared, including an updated GHG analysis and incorporating additional mitigation measures to reduce the Project’s GHG emissions to less- than-significant levels.
2) Failure to Consider Performance-based Standards Under CARB’s 2017 Scoping Plan As previously discussed, the DEIR concludes that the Project would be consistent with CARB’s 2017 Climate Change Scoping Plan (p. 4.6-36 – 4.6-37). However, this is incorrect, as the DEIR fails to consider performance-based measures proposed by CARB.
i. Passenger & Light Duty VMT Per Capita Benchmarks per SB 375

26 “Minutes for the GHG CEQA Significance Threshold Stakeholder Working Group #15.” SCAQMD, September 2010, available at: http://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa- significance-thresholds/year-2008-2009/ghg-meeting-15/ghg-meeting-15-minutes.pdf, p. 2. 27 “HEALTH & SAFETY CODE 38550,” available at:
https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=HSC&sectionNum=38550. 18 In reaching the State’s long-term GHG emission reduction goals, CARB’s 2017 Scoping Plan explicitly cites to SB 375 and the VMT reductions anticipated under the implementation of Sustainable Community Strategies.28 CARB has identified the population and daily VMT from passenger autos and light-duty vehicles at the state and county level for each year between 2010 to 2050 under a “baseline scenario” that includes “current projections of VMT included in the existing Regional Transportation Plans/Sustainable Communities Strategies (RTP/SCSs) adopted by the State’s 18 Metropolitan Planning Organizations (MPOs) pursuant to SB 375 as of 2015.”
29 By dividing the projected daily VMT by the
population, we calculated the daily VMT per capita for each year at the state and county level for 2010 (baseline year), 2026 (Project operational year), and 2030 (target year under SB 32) (see table below). 2017 Scoping Plan Daily VMT Per Capita
Los Angeles County State
Year Population LDV VMT Baseline VMT Per Capita Population LDV VMT Baseline VMT Per Capita 2010 9,838,771 216,979,221.64 22.05 37,335,085 836,463,980.46 22.40 2026 10,581,976 217,309,804.92 20.54 42,655,695 935,625,476.00 21.93 2030 10,868,614 215,539,586.12 19.83 43,939,250 957,178,153.19 21.78 As the DEIR fails to evaluate the Project’s consistency with the CARB 2017 Scoping Plan performance- based daily VMT per capita projections, the DEIR’s claim that the proposed Project would not conflict with the CARB 2017 Scoping Plan is unsupported. A revised EIR should be prepared for the proposed Project to provide additional information and analysis to conclude less-than-significant GHG impacts. 3) Failure to Consider Performance-based Standards under SCAG’s RTP/SCS As previously discussed, the DEIR concludes that the Project would be consistent with SCAG’s RTP/SCS (p. 4.6-36 – 4.6-37). However, the DEIR fails to consider whether or not the Project meets any of the specific performance-based goals underlying SCAG’s RTP/SCS and SB 375, such as: i) per capita GHG emission targets, or ii) daily vehicles miles traveled (“VMT”) per capita benchmarks. i. SB 375 Per Capita GHG Emission Goals
SB 375 was signed into law in September 2008 to enhance the state’s ability to reach AB 32 goals by directing CARB to develop regional 2020 and 2035 GHG emission reduction targets for passenger vehicles (autos and light-duty trucks). In March 2018, CARB adopted updated regional targets requiring a 19 percent decrease in VMT for the SCAG region by 2035. This goal is reflected in SCAG’s 2020 RTP/SCS

28 “California’s 2017 Climate Change Scoping Plan.” CARB, November 2017, available at:
https://ww3.arb.ca.gov/cc/scopingplan/scoping_plan_2017.pdf, p. 25, 98, 101-103. 29 “Supporting Calculations for 2017 Scoping Plan-Identified VMT Reductions,” California Air Resources Board (CARB), January 2019, available at: https://ww2.arb.ca.gov/resources/documents/carb-2017-scoping-plan- identified-vmt-reductions-and-relationship-state-climate; s ee also:
https://ww2.arb.ca.gov/sites/default/files/2019-01/sp_mss_vmt_calculations_jan19_0.xlsx. 19 Program Environmental Impact Report (“PEIR”), in which the 2020 RTP/SCS PEIR updates the per capita emissions to 18.8 lbs/day in 2035 (see excerpt below). 30

As the DEIR fails to evaluate the Project’s consistency with the SCAG’s per capita emissions, the DEIR’s claim that the proposed Project would be consistent with SCAG’s RTP/SCS is unsupported. A full CEQA analysis should be prepared for the proposed Project to provide additional information and analysis to conclude less-than-significant GHG impacts.
ii. SB 375 RTP/SCS Daily VMT Per Capita Target
Under the SCAG’s 2020 RTP/SCS, daily VMT per capita in the SCAG region should decrease from 23.2 VMT in 2016 to 20.7 VMT by 2045.31 Daily VMT per capita in Los Angeles County should decrease from

22.2 to 19.2 VMT during that same period.32 Here, however, the DEIR fails to consider any of the above- mentioned performance-based VMT targets. As the DEIR fails to evaluate the Project’s consistency with the SCAG’s performance-based daily VMT per capita projections, the DEIR’s claim that the proposed Project would be consistent with SCAG’s RTP/SCS is unsupported. A revised EIR should be prepared for the proposed Project to provide additional information and analysis to conclude less-than-significant GHG impacts.

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

30 “Connect SoCal Certified Final Program Environmental Impact Report.” SCAG, May 2020, available at:
https://scag.ca.gov/sites/main/files/file-attachments/fpeir_connectsocal_complete.pdf?1607981618, p. 3.8-74. 31 “Connect SoCal.” SCAG, September 2020, available at: https://scag.ca.gov/sites/main/files/file- attachments/0903fconnectsocal-plan_0.pdf?1606001176, pp. 138. 32 “Connect SoCal.” SCAG, September 2020, available at: https://scag.ca.gov/sites/main/files/file- attachments/0903fconnectsocal-plan_0.pdf?1606001176, pp. 138.

20 Therefore, to reduce the Project’s emissions, we recommend consideration of SCAG’s 2020 RTP/SCS PEIR’s Air Quality Project Level Mitigation Measures (“PMM-AQ-1”) and Greenhouse Gas Project Level Mitigation Measures (“PMM-GHG-1”), as described below: 33 SCAG RTP/SCS 2020-2045
Air Quality Project Level Mitigation Measures – PMM-AQ-1:

In accordance with provisions of sections 15091(a)(2) and 15126.4(a)(1)(B) of the State CEQA Guidelines, a Lead Agency for a project can and should consider mitigation measures to reduce substantial adverse effects related to violating air quality standards. Such measures may include the following or other comparable measures identified by the Lead Agency:
f) Minimize unnecessary vehicular and machinery activities. j) Require contractors to assemble a comprehensive inventory list (i.e., make, model, engine year, horsepower, emission rates) of all heavy-duty off-road (portable and mobile) equipment (50 horsepower and greater) that could be used an aggregate of 40 or more hours for the construction project. Prepare a plan for approval by the applicable air district demonstrating achievement of the applicable percent reduction for a CARB-approved fleet.
k) Ensure that all construction equipment is properly tuned and maintained. l) Minimize idling time to 5 minutes— saves fuel and reduces emissions. n) Utilize existing power sources (e.g., power poles) or clean fuel generators rather than temporary power generators.
p) As appropriate require that portable engines and portable engine-driven equipment units used at the project work site, with the exception of on-road and off-road motor vehicles, obtain CARB Portable Equipment Registration with the state or a local district permit. Arrange appropriate consultations with the CARB or the District to determine registration and permitting requirements prior to equipment operation at the site. q) Require projects within 500 feet of residences, hospitals, or schools to use Tier 4 equipment for all engines above 50 horsepower (hp) unless the individual project can demonstrate that Tier 4 engines would not be required to mitigate emissions below significance thresholds. bb) The following criteria related to diesel emissions shall be implemented on by individual project sponsors as appropriate and feasible:
- Diesel nonroad vehicles on site for more than 10 total days shall have either (1) engines that meet EPA on road emissions standards or (2) emission control technology verified by EPA or CARB to reduce PM emissions by a minimum of 85%
- Diesel generators on site for more than 10 total days shall be equipped with emission control technology verified by EPA or CARB to reduce PM emissions by a minimum of 85%. - Nonroad diesel engines on site shall be Tier 2 or higher. - Diesel nonroad construction equipment on site for more than 10 total days shall have either (1) engines meeting EPA Tier 4 nonroad emissions standards or (2) emission control technology verified by EPA or CARB for use with nonroad engines to reduce PM emissions by a minimum of 85% for engines for 50 hp and greater and by a minimum of 20% for engines less than 50 hp.

33 “4.0 Mitigation Measures.” Connect SoCal Program Environmental Impact Report Addendum #1, September 2020, available at: https://scag.ca.gov/sites/main/files/file- attachments/fpeir_connectsocal_addendum_4_mitigationmeasures.pdf?1606004420, p. 4.0-2 – 4 .0-10; 4.0-19 –

4.0-23; See also: “Certified Final Connect SoCal Program Environmental Impact Report.” Southern California Association of Governments (SCAG), May 2020, available at: https://scag.ca.gov/peir. 21 - Emission control technology shall be operated, maintained, and serviced as recommended by the emission control technology manufacturer.
- Diesel vehicles, construction equipment, and generators on site shall be fueled with ultra-low sulfur diesel fuel (ULSD) or a biodiesel blend approved by the original engine manufacturer with sulfur content of 15 ppm or less.
- The construction contractor shall maintain a list of all diesel vehicles, construction equipment, and generators to be used on site. The list shall include the following:
i. Contractor and subcontractor name and address, plus contact person responsible for the vehicles or equipment.
ii. Equipment type, equipment manufacturer, equipment serial number, engine manufacturer, engine model year, engine certification (Tier rating), horsepower, engine serial number, and expected fuel usage and hours of operation.
iii. For the emission control technology installed: technology type, serial number, make, model, manufacturer, EPA/CARB verification number/level, and installation date and hour-meter reading on installation date.
- The contractor shall establish generator sites and truck-staging zones for vehicles waiting to load or unload material on site. Such zones shall be located where diesel emissions have the least impact on abutters, the general public, and especially sensitive receptors such as hospitals, schools, daycare facilities, elderly housing, and convalescent facilities. - The contractor shall maintain a monthly report that, for each on road diesel vehicle, nonroad construction equipment, or generator onsite, includes:
i. Hour-meter readings on arrival on-site, the first and last day of every month, and on off-site date.
ii. Any problems with the equipment or emission controls. iii. Certified copies of fuel deliveries for the time period that identify:

1. Source of supply

2. Quantity of fuel

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

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

Furthermore, as it is policy of the State that eligible renewable energy resources and zero-carbon resources supply 100% of retail sales of electricity to California end-use customers by December 31, 2045, we emphasize the applicability of incorporating solar power system into the Project design. Until the feasibility of incorporating on-site renewable energy production is considered, the Project should not be approved.

A revised EIR should be prepared to include all feasible mitigation measures, as well as include updated air quality, health risk, and GHG analyses to ensure that the necessary mitigation measures are implemented to reduce emissions to below thresholds. The updated EIR should also demonstrate a commitment to the implementation of these measures prior to Project approval, to ensure that the Project’s significant emissions are reduced to the maximum extent possible. 24 Disclaimer
SWAPE has received limited discovery regarding this project. Additional information may become available in the future; thus, we retain the right to revise or amend this report when additional information becomes available. Our professional services have been performed using that degree of care and skill ordinarily exercised, under similar circumstances, by reputable environmental consultants practicing in this or similar localities at the time of service. No other warranty, expressed or implied, is made as to the scope of work, work methodologies and protocols, site conditions, analytical testing results, and findings presented. This report reflects efforts which were limited to information that was reasonably accessible at the time of the work, and may contain informational gaps, inconsistencies, or otherwise be incomplete due to the unavailability or uncertainty of information obtained or provided by third parties.

Sincerely,

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

Paul E. Rosenfeld, Ph.D.

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

Annual Emissions (tons/year) 0.289 Annual Emissions (tons/year) 0.05275 Daily Emissions (lbs/day) 1.583561644 Daily Emissions (lbs/day) 0.289041096 Construction Duration (days) 319 Total DPM (lbs) 105.5
Total DPM (lbs) 505.1561644 Emission Rate (g/s) 0.001517466 Total DPM (g) 229138.8362 Release Height (meters) 3
Start Date 2/16/2023 Total Acreage 4.46
End Date 1/1/2024 Max Horizontal (meters) 189.99
Construction Days 319 Min Horizontal (meters) 95.00
Initial Vertical Dimension (meters) 1.5
Annual Emissions (tons/year) 0.4395 Setting Urban
Daily Emissions (lbs/day) 2.408219178 Population 39,970 Construction Duration (days) 366
Total DPM (lbs) 881.4082192
Total DPM (g) 399806.7682
Start Date 1/1/2024
End Date 1/1/2025
Construction Days 366
Annual Emissions (tons/year) 0.1965
Daily Emissions (lbs/day) 1.076712329
Construction Duration (days) 353
Total DPM (lbs) 380.0794521
Total DPM (g) 172404.0395
Start Date 1/1/2025
End Date 12/20/2025
Construction Days 353
Total DPM (lbs) 1766.643836
Total DPM (g) 801349.6438
Emission Rate (g/s) 0.008935337
Release Height (meters) 3
Total Acreage 4.46
Max Horizontal (meters) 189.99
Min Horizontal (meters) 95.00
Initial Vertical Dimension (meters) 1.5
Setting Urban
Population 39,970
Start Date 2/16/2023
End Date 12/20/2025
Total Construction Days 1038
Total Years of Construction 2.84
Total Years of Operation 27.16
2025
2024
Operation
2023
Total
Emission Rate
Construction
Attachment A
AERSCREEN 21112 / AERMOD 21112 10/27/22
17:14:32
TITLE: Crossings Campus, Construction
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ******************************  AREA PARAMETERS  **************************** ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ SOURCE EMISSION RATE: 0.894E ‐02 g/s 0.709E‐01 lb/hr
AREA EMISSION RATE: 0.495E‐06 g/(s‐m2) 0.393E ‐05 lb/(hr‐m2) AREA HEIGHT: 3.00 meters 9.84 feet
AREA SOURCE LONG SIDE: 189.99 meters 623.33 feet
AREA SOURCE SHORT SIDE: 95.00 meters 311.68 feet
INITIAL VERTICAL DIMENSION: 1.50  meters 4.92 feet
RURAL OR URBAN: URBAN
POPULATION: 39970
INITIAL PROBE DISTANCE = 5000. meters 16404. feet
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ***********************  BUILDING DOWNWASH PARAMETERS  ********************** ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ BUILDING DOWNWASH NOT USED FOR NON‐POINT SOURCES
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ **************************  FLOW SECTOR ANALYSIS  *************************** 25 meter receptor spacing: 1. meters ‐ 5000. meters
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ MAXIMUM  IMPACT  RECEPTOR
Zo SURFACE    1‐HR CONC  RADIAL  DIST   TEMPORAL
SECTOR    ROUGHNESS  (ug/m3)    (deg)   (m)    PERIOD
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
1*       1.000     16.94      20   100.0     WIN
* =  worst case diagonal
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ Attachment B
**********************  MAKEMET METEOROLOGY PARAMETERS  ********************* ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ MIN/MAX TEMPERATURE:    250.0 / 310.0 (K)
MINIMUM WIND SPEED:       0.5 m/s
ANEMOMETER HEIGHT:     10.000 meters
SURFACE CHARACTERISTICS INPUT: AERMET SEASONAL TABLES
DOMINANT SURFACE PROFILE: Urban
DOMINANT CLIMATE TYPE:    Average Moisture
DOMINANT SEASON:          Winter
ALBEDO:                  0.35
BOWEN RATIO:             1.50
ROUGHNESS LENGTH:       1.000 (meters)
SURFACE FRICTION VELOCITY (U*) NOT ADUSTED
METEOROLOGY CONDITIONS USED TO PREDICT OVERALL MAXIMUM IMPACT ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐ YR MO DY JDY HR
‐‐ ‐‐ ‐‐ ‐‐‐ ‐‐
10 01 10  10 01
H0     U*     W*  DT/DZ ZICNV ZIMCH  M‐O LEN    Z0  BOWEN ALBEDO  REF WS ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐  ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐1.30  0.043 ‐9.000  0.020 ‐999.   21.      6.0 1.000   1.50   0.35    0.50 HT
REF TA     HT
‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐

10.0   310.0    2.0
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ************************ AERSCREEN AUTOMATED DISTANCES ********************** OVERALL MAXIMUM CONCENTRATIONS BY DISTANCE
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ MAXIMUM                             MAXIMUM
DIST     1‐HR CONC                  DIST     1‐HR CONC
(m)      (ug/m3)                    (m)      (ug/m3)
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐               ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐

1.00     12.81                   2525.00    0.2170

25.00     14.19                   2550.00    0.2141

50.00     15.35                   2575.00    0.2113

75.00     16.33                   2600.00    0.2085
100.00     16.94                   2625.00    0.2058
125.00     11.97                   2650.00    0.2031
150.00     9.052                   2675.00    0.2005
175.00     7.487                   2700.00    0.1980
200.00     6.336                   2725.00    0.1955
225.00     5.460                   2750.00    0.1931
250.00     4.769                   2775.00    0.1907
275.00     4.218                   2800.00    0.1884
300.00     3.768                   2825.00    0.1861
325.00     3.392                   2850.00    0.1839
350.00     3.080                   2875.00    0.1817
375.00     2.812                   2900.00    0.1796
400.00     2.583                   2925.00    0.1775
425.00     2.383                   2950.00    0.1754
450.00     2.211                   2975.00    0.1734
475.00     2.057                   3000.00    0.1714
500.00     1.921                   3025.00    0.1695
525.00     1.800                   3050.00    0.1676
550.00     1.693                   3075.00    0.1657
575.00     1.596                   3100.00    0.1639
600.00     1.507                   3125.00    0.1621
625.00     1.427                   3150.00    0.1603
650.00     1.354                   3175.00    0.1586
675.00     1.287                   3200.00    0.1569
700.00     1.226                   3225.00    0.1553
725.00     1.170                   3250.00    0.1536
750.00     1.117                   3275.00    0.1520
775.00     1.069                   3300.00    0.1505
800.00     1.024                   3325.00    0.1489
825.00    0.9829                   3350.00    0.1474
850.00    0.9444                   3375.00    0.1459
875.00    0.9082                   3400.00    0.1444
900.00    0.8743                   3425.00    0.1430
925.00    0.8427                   3450.00    0.1416
950.00    0.8130                   3475.00    0.1402
975.00    0.7849                   3500.00    0.1388
1000.00    0.7583                   3525.00    0.1375
1025.00    0.7333                   3550.00    0.1361
1050.00    0.7097                   3575.00    0.1348
1075.00    0.6875                   3600.00    0.1336
1100.00    0.6664                   3625.00    0.1323
1125.00    0.6464                   3650.00    0.1311
1150.00    0.6274                   3675.00    0.1299
1175.00    0.6094                   3700.00    0.1287
1200.00    0.5923                   3725.00    0.1275
1225.00    0.5761                   3750.00    0.1263
1250.00    0.5606                   3775.00    0.1252
1275.00    0.5458                   3800.00    0.1240
1300.00    0.5317                   3825.00    0.1229
1325.00    0.5182                   3850.00    0.1218
1350.00    0.5052                   3875.00    0.1208
1375.00    0.4928                   3900.00    0.1197
1400.00    0.4809                   3925.00    0.1187
1425.00    0.4695                   3950.00    0.1176
1450.00    0.4585                   3975.00    0.1166
1475.00    0.4480                   4000.00    0.1156
1500.00    0.4378                   4025.00    0.1147
1525.00    0.4281                   4050.00    0.1137
1550.00    0.4187                   4075.00    0.1127
1575.00    0.4097                   4100.00    0.1118
1600.00    0.4010                   4125.00    0.1109
1625.00    0.3927                   4150.00    0.1100
1650.00    0.3846                   4175.00    0.1091
1675.00    0.3768                   4200.00    0.1082
1700.00    0.3693                   4225.00    0.1073
1725.00    0.3620                   4250.00    0.1064
1750.00    0.3550                   4275.00    0.1056
1775.00    0.3517                   4300.00    0.1047
1800.00    0.3450                   4325.00    0.1039
1825.00    0.3386                   4350.00    0.1031
1850.00    0.3323                   4375.00    0.1023
1875.00    0.3262                   4400.00    0.1015
1900.00    0.3204                   4425.00    0.1007
1925.00    0.3147                   4450.00    0.9995E‐01 1950.00    0.3092                   4475.00    0.9918E‐01 1975.00    0.3038                   4500.00    0.9843E‐01 2000.00    0.2986                   4525.00    0.9769E‐01 2025.00    0.2936                   4550.00    0.9695E‐01 2050.00    0.2887                   4575.00    0.9623E‐01 2075.00    0.2840                   4600.00    0.9552E‐01 2100.00    0.2793                   4625.00    0.9481E‐01 2125.00    0.2748                   4650.00    0.9411E‐01 2150.00    0.2705                   4675.00    0.9343E‐01 2175.00    0.2662                   4700.00    0.9275E‐01 2200.00    0.2621                   4725.00    0.9208E‐01 2225.00    0.2581                   4750.00    0.9141E‐01 2250.00    0.2541                   4775.00    0.9076E‐01 2275.00    0.2503                   4800.00    0.9011E‐01 2300.00    0.2466                   4825.00    0.8948E‐01 2325.00    0.2430                   4850.00    0.8885E‐01 2350.00    0.2395                   4875.00    0.8822E‐01 2375.00    0.2360                   4900.00    0.8761E‐01 2400.00    0.2327                   4924.99    0.8700E‐01 2425.00    0.2294                   4950.00    0.8640E‐01 2450.00    0.2262                   4975.00    0.8581E‐01 2475.00    0.2231                   5000.00    0.8522E‐01 2500.00    0.2200
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ **********************  AERSCREEN MAXIMUM IMPACT SUMMARY  ********************* ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 3‐hour, 8‐hour, and 24‐hour scaled
concentrations are equal to the 1‐hour concentration as referenced in SCREENING PROCEDURES FOR ESTIMATING THE AIR QUALITY
IMPACT OF STATIONARY SOURCES, REVISED (Section 4.5.4)
Report number EPA‐454/R‐92‐019
http://www.epa.gov/scram001/guidance_permit.htm
under Screening Guidance
MAXIMUM      SCALED      SCALED      SCALED      SCALED 1‐HOUR      3‐HOUR      8‐HOUR     24‐HOUR      ANNUAL
CALCULATION          CONC        CONC        CONC        CONC        CONC PROCEDURE         (ug/m3)     (ug/m3)     (ug/m3)     (ug/m3)     (ug/m3) ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐    ‐‐‐‐‐‐‐‐‐‐  ‐‐‐‐‐‐‐‐‐‐  ‐‐‐‐‐‐‐‐‐‐  ‐‐‐‐‐‐‐ ‐‐‐  ‐‐‐‐‐‐‐‐‐‐ FLAT TERRAIN        16.97       16.97       16.97       16.97         N/A DISTANCE FROM SOURCE        101.00 meters
IMPACT AT THE
AMBIENT BOUNDARY    12.81       12.81       12.81       12.81         N/A DISTANCE FROM SOURCE          1.00 meters
AERSCREEN 21112 / AERMOD 21112                                      10/27/22 17:16:32
TITLE: Crossings Campus, Operation
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ******************************  AREA PARAMETERS  **************************** ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ SOURCE EMISSION RATE:         0.152E‐02 g/s             0.120E‐01 lb/hr AREA EMISSION RATE:           0.841E‐07 g/(s‐m2)        0.667E‐06 lb/(hr‐m2) AREA HEIGHT:                       3.00 meters               9.84 feet AREA SOURCE LONG SIDE:           189.99 meters             623.33 feet AREA SOURCE SHORT SIDE:           95.00 meters             311.68 feet INITIAL VERTICAL DIMENSION:        1.50 meters               4.92 feet RURAL OR URBAN:                   URBAN
POPULATION:                       39970
INITIAL PROBE DISTANCE =          5000. meters             16404. feet ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ***********************  BUILDING DOWNWASH PARAMETERS  ********************** ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ BUILDING DOWNWASH NOT USED FOR NON‐POINT SOURCES
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ **************************  FLOW SECTOR ANALYSIS  *************************** 25 meter receptor spacing: 1. meters ‐ 5000. meters
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ MAXIMUM  IMPACT  RECEPTOR
Zo        SURFACE   1‐HR CONC  RADIAL  DIST   TEMPORAL
SECTOR    ROUGHNESS  (ug/m3)    (deg)   (m)    PERIOD
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
1*       1.000     2.876      20   100.0     WIN
* = worst case diagonal
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ **********************  MAKEMET METEOROLOGY PARAMETERS  ********************* ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ MIN/MAX TEMPERATURE:    250.0 / 310.0 (K)
MINIMUM WIND SPEED:       0.5 m/s
ANEMOMETER HEIGHT:     10.000 meters
SURFACE CHARACTERISTICS INPUT: AERMET SEASONAL TABLES
DOMINANT SURFACE PROFILE: Urban
DOMINANT CLIMATE TYPE:    Average Moisture
DOMINANT SEASON:          Winter
ALBEDO:                  0.35
BOWEN RATIO:             1.50
ROUGHNESS LENGTH:       1.000 (meters)
SURFACE FRICTION VELOCITY (U*) NOT ADUSTED
METEOROLOGY CONDITIONS USED TO PREDICT OVERALL MAXIMUM IMPACT ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐ YR MO DY JDY HR
‐‐ ‐‐ ‐‐ ‐‐‐ ‐‐
10 01 10  10 01
H0     U*     W*  DT/DZ ZICNV ZIMCH  M‐O LEN    Z0  BOWEN ALBEDO  REF WS ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐  ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐1.30  0.043 ‐9.000  0.020 ‐999.   21.      6.0 1.000   1.50   0.35    0.50 HT
REF TA     HT
‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐

10.0   310.0    2.0
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ************************ AERSCREEN AUTOMATED DISTANCES ********************** OVERALL MAXIMUM CONCENTRATIONS BY DISTANCE
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ MAXIMUM                             MAXIMUM
DIST     1‐HR CONC                  DIST     1‐HR CONC
(m)      (ug/m3)                    (m)      (ug/m3)
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐               ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐

1.00     2.175                   2525.00    0.3685E‐01

25.00     2.409                   2550.00    0.3636E‐01

50.00     2.607                   2575.00    0.3588E‐01

75.00     2.773                   2600.00    0.3540E‐01 100.00     2.876                   2625.00    0.3494E‐01 125.00     2.033                   2650.00    0.3449E‐01 150.00     1.537                   2675.00    0.3405E‐01 175.00     1.271                   2700.00    0.3362E‐01 200.00     1.076                   2725.00    0.3320E‐01 225.00    0.9271                   2750.00    0.3279E‐01 250.00    0.8097                   2775.00    0.3238E‐01 275.00    0.7162                   2800.00    0.3199E‐01 300.00    0.6398                   2825.00    0.3160E‐01 325.00    0.5760                   2850.00    0.3122E‐01 350.00    0.5229                   2875.00    0.3085E‐01 375.00    0.4774                   2900.00    0.3049E‐01 400.00    0.4385                   2925.00    0.3013E‐01 425.00    0.4047                   2950.00    0.2978E‐01 450.00    0.3754                   2975.00    0.2944E‐01 475.00    0.3494                   3000.00    0.2911E‐01 500.00    0.3262                   3025.00    0.2878E‐01 525.00    0.3057                   3050.00    0.2846E‐01 550.00    0.2874                   3075.00    0.2814E‐01 575.00    0.2709                   3100.00    0.2783E‐01 600.00    0.2559                   3125.00    0.2753E‐01 625.00    0.2423                   3150.00    0.2723E‐01 650.00    0.2298                   3175.00    0.2693E‐01 675.00    0.2185                   3200.00    0.2665E‐01 700.00    0.2082                   3225.00    0.2636E‐01 725.00    0.1986                   3250.00    0.2609E‐01 750.00    0.1897                   3275.00    0.2581E‐01 775.00    0.1815                   3300.00    0.2555E‐01 800.00    0.1739                   3325.00    0.2529E‐01 825.00    0.1669                   3350.00    0.2503E‐01 850.00    0.1604                   3375.00    0.2477E‐01 875.00    0.1542                   3400.00    0.2452E‐01 900.00    0.1485                   3425.00    0.2428E‐01 925.00    0.1431                   3450.00    0.2404E‐01 950.00    0.1380                   3475.00    0.2380E‐01 975.00    0.1333                   3500.00    0.2357E‐01 1000.00    0.1288                   3525.00    0.2334E‐01 1025.00    0.1245                   3550.00    0.2312E‐01 1050.00    0.1205                   3575.00    0.2290E‐01 1075.00    0.1167                   3600.00    0.2268E‐01 1100.00    0.1132                   3625.00    0.2247E‐01 1125.00    0.1098                   3650.00    0.2226E‐01 1150.00    0.1065                   3675.00    0.2205E‐01 1175.00    0.1035                   3700.00    0.2185E‐01 1200.00    0.1006                   3725.00    0.2165E‐01 1225.00    0.9782E‐01               3750.00    0.2145E‐01 1250.00    0.9519E‐01               3775.00    0.2125E‐01 1275.00    0.9268E‐01               3800.00    0.2106E‐01 1300.00    0.9028E‐01               3825.00    0.2087E‐01 1325.00    0.8799E‐01               3849.99    0.2069E‐01 1350.00    0.8579E‐01               3875.00    0.2051E‐01 1375.00    0.8368E‐01               3900.00    0.2033E‐01 1400.00    0.8166E‐01               3925.00    0.2015E‐01 1425.00    0.7973E‐01               3950.00    0.1998E‐01 1450.00    0.7786E‐01               3975.00    0.1980E‐01 1475.00    0.7607E‐01               4000.00    0.1964E‐01 1500.00    0.7434E‐01               4025.00    0.1947E‐01 1525.00    0.7269E‐01               4050.00    0.1930E‐01 1550.00    0.7110E‐01               4075.00    0.1914E‐01 1575.00    0.6957E‐01               4100.00    0.1898E‐01 1600.00    0.6809E‐01               4125.00    0.1883E‐01 1625.00    0.6667E‐01               4150.00    0.1867E‐01 1650.00    0.6530E‐01               4175.00    0.1852E‐01 1675.00    0.6398E‐01               4200.00    0.1837E‐01 1700.00    0.6271E‐01               4225.00    0.1822E‐01 1725.00    0.6148E‐01               4250.00    0.1807E‐01 1750.00    0.6028E‐01               4275.00    0.1793E‐01 1775.00    0.5972E‐01               4300.00    0.1779E‐01 1800.00    0.5858E‐01               4325.00    0.1765E‐01 1825.00    0.5749E‐01               4350.00    0.1751E‐01 1850.00    0.5643E‐01               4375.00    0.1737E‐01 1875.00    0.5540E‐01               4400.00    0.1724E‐01 1900.00    0.5440E‐01               4425.00    0.1710E‐01 1925.00    0.5344E‐01               4450.00    0.1697E‐01 1950.00    0.5250E‐01               4475.00    0.1684E‐01 1975.00    0.5159E‐01               4500.00    0.1671E‐01 2000.00    0.5071E‐01               4525.00    0.1659E‐01 2025.00    0.4985E‐01               4550.00    0.1646E‐01 2050.00    0.4902E‐01               4575.00    0.1634E‐01 2075.00    0.4822E‐01               4600.00    0.1622E‐01 2100.00    0.4743E‐01               4625.00    0.1610E‐01 2125.00    0.4667E‐01               4650.00    0.1598E‐01 2150.00    0.4593E‐01               4675.00    0.1586E‐01 2175.00    0.4521E‐01               4700.00    0.1575E‐01 2200.00    0.4450E‐01               4725.00    0.1563E‐01 2225.00    0.4382E‐01               4750.00    0.1552E‐01 2250.00    0.4316E‐01               4775.00    0.1541E‐01 2275.00    0.4251E‐01               4800.00    0.1530E‐01 2300.00    0.4188E‐01               4825.00    0.1519E‐01 2325.00    0.4126E‐01               4850.00    0.1509E‐01 2350.00    0.4066E‐01               4875.00    0.1498E‐01 2375.00    0.4008E‐01               4900.00    0.1488E‐01 2400.00    0.3951E‐01               4925.00    0.1477E‐01 2425.00    0.3895E‐01               4950.00    0.1467E‐01 2450.00    0.3841E‐01               4975.00    0.1457E‐01 2475.00    0.3788E‐01               5000.00    0.1447E‐01 2500.00    0.3736E‐01
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ **********************  AERSCREEN MAXIMUM IMPACT SUMMARY  ********************* ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 3‐hour, 8‐hour, and 24‐hour scaled
concentrations are equal to the 1‐hour concentration as referenced in SCREENING PROCEDURES FOR ESTIMATING THE AIR QUALITY
IMPACT OF STATIONARY SOURCES, REVISED (Section 4.5.4)
Report number EPA‐454/R‐92‐019
http://www.epa.gov/scram001/guidance_permit.htm
under Screening Guidance
MAXIMUM      SCALED      SCALED      SCALED      SCALED 1‐HOUR      3‐HOUR      8‐HOUR     24‐HOUR      ANNUAL
CALCULATION          CONC        CONC        CONC        CONC        CONC PROCEDURE         (ug/m3)     (ug/m3)     (ug/m3)     (ug/m3)     (ug/m3) ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐    ‐‐‐‐‐‐‐‐‐‐  ‐‐‐‐‐‐‐‐‐‐  ‐‐‐‐‐‐‐‐‐‐  ‐‐‐‐‐‐‐ ‐‐‐  ‐‐‐‐‐‐‐‐‐‐ FLAT TERRAIN        2.881       2.881       2.881       2.881         N/A DISTANCE FROM SOURCE        101.00 meters
IMPACT AT THE
AMBIENT BOUNDARY    2.175       2.175       2.175       2.175         N/A DISTANCE FROM SOURCE          1.00 meters
2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G
, C.Hg.
(949) 887-9013
[email protected]
Matthew F. Hagemann, P.G., C.Hg., QSD, QSP
Geologic and Hydrogeologic Ch
aracterization
Investigation and Remediation Strategies
Litigation Support and Testifying Expert
Industrial Stormwater Compliance
CEQA Review
Education:

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

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

Professional Certifications:

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

Matt has 30 years of experience in environmental policy, contaminant assessment and remediation, stormwater compliance, and CEQA review. He spent nine years with the U.S. EPA in the RCRA and Superfund programs and served as EPA’s Senior Science Policy Advisor in the Western Regional Office where he identified emerging threats to groundwater from perchlorate and MTBE. While with EPA, Matt also served as a Senior Hydrogeologist in the oversight of the assessment of seven major military facilities undergoing base closure. He led numerous enforcement actions under provisions of the Resource Conservation and Recovery Act (RCRA) and directed efforts to improve hydrogeologic characterization and water quality monitoring. For the past 15 years, as a founding partner with SWAPE, Matt has developed extensive client relationships and has managed complex projects that include consultation as an expert witness and a regulatory specialist, and a manager of projects ranging from industrial stormwater compliance to CEQA review of impacts from hazardous waste, air quality and greenhouse gas emissions.

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

Senior Regulatory and Litigation Support Analyst:

With SWAPE, Matt’s responsibilities have included:
• Lead analyst and testifying expert in the review of over 300 environmental impact reports and negative declarations since 2003 under CEQA that identify significant issues with regard to hazardous waste, water resources, water quality, air quality, greenhouse gas emissions, and geologic hazards. Make recommendations for additional mitigation measures to lead agencies at the local and county level to include additional characterization of health risks and implementation of protective measures to reduce worker exposure to hazards from toxins and Valley Fever.
• Stormwater analysis, sampling and best management practice evaluation at more than 100 industrial facilities.
• Expert witness on numerous cases including, for example, perfluorooctanoic acid (PFOA) contamination of groundwater, MTBE litigation, air toxins at hazards at a school, CERCLA compliance in assessment and remediation, and industrial stormwater contamination. • Technical assistance and litigation support for vapor intrusion concerns. • Lead analyst and testifying expert in the review of environmental issues in license applications for l arge 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 C alifornia drinking water wells.
• Manager and designated expert for litigation support under provisions of Proposition 65 in the review of r eleases of gasoline to sources drinking water at major refineries and hundreds of gas stations t hroughout California.

With Komex H2O Science Inc., Matt’s duties included the following:
• Senior author of a report on the extent of perchlorate contamination that was used in testimony by t he former U.S. EPA Administrator and General Counsel. • Senior researcher in the development of a comprehensive, electronically interactive chronology of M TBE use, research, and regulation.
• Senior researcher in the development of a comprehensive, electronically interactive chronology of p erchlorate use, research, and regulation.
• Senior researcher in a study that estimates nationwide costs for MTBE remediation and drinking water tr eatment, results of which were published in newspapers nationwide and in testimony against p rovisions 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 C alifornia and New York.
3 • Expert witness testimony in a case of oil production‐related contamination in Mississippi. • Lead author for a multi‐volume remedial investigation report for an operating school in Los Angeles that met strict regulatory requirements and rigorous deadlines. • Development of strategic approaches for cleanup of contaminated sites in consultation with clients and regulators.

Executive Director:

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

Hydrogeology:

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

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

As a hydrogeologist with the EPA Groundwater Protection Section, Matt worked with provisions of the Safe Drinking Water Act and NEPA to prevent drinking water contamination. Specific activities included the following:
• Received an EPA Bronze Medal for his contribution to the development of national guidance for the protection of drinking water.
• Managed the Sole Source Aquifer Program and protected the drinking water of two communities through designation under the Safe Drinking Water Act. He prepared geologic reports, conducted 4 public hearings, and responded to public comments from residents who were very concerned about the impact of designation.
• Reviewed a number of Environmental Impact Statements for planned major developments, including large hazardous and solid waste disposal facilities, mine reclamation, and water transfer.

Matt served as a hydrogeologist with the RCRA Hazardous Waste program. Duties were as follows:
• Supervised the hydrogeologic investigation of hazardous waste sites to determine compliance with Subtitle C requirements.
• Reviewed and wrote 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 5 principles into the policy‐making process.
• Established national protocol for the peer review of scientific documents.

Geology:

With the U.S. Forest Service, Matt led investigations to determine hillslope stability of areas proposed for timber harvest in the central Oregon Coast Range. Specific activities were as follows:
• Mapped geology in the field, and used aerial photographic interpretation and mathematical models to d etermine 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 M edford, 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 ge ology, oceanography (lab and lecture), hydrogeology, and groundwater contamination.
• Served as a committee member for graduate and undergraduate students. • Taught courses in environmental geology and oceanography at the College of Marin.

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

Invited Testimony, Reports, Papers and Presentations:

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

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

EPA Region 9, San Francisco, California.

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

Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in Nevada and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Las Vegas, NV (served on conference organizing committee).
6 Hagemann, M.F., 2004. Invited testimony to a California Senate committee hearing on air toxins at schools in Southern California, Los Angeles.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Unpublished report.

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

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

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

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

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

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

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

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

Hagemann, M.F., 1994. Groundwater Ch ar ac te r i z a t i o n and Cl ean up a t Closing Military Bases in California. Proceedings, California Groundwater Resources Association Meeting.

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

Hagemann, M.F., 1993. U.S. EPA Policy on the Technical Impracticability of the Cleanup of DNAPL‐ contaminated Groundwater. California Groundwater Resources Association Meeting. 8 Hagemann, M.F., 1992. Dense Nonaqueous Phase Liquid Contamination of Groundwater: An Ounce of Prevention... Proceedings, Association of Engineering Geologists Annual Meeting, v. 35.

Other Experience:

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

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

Mobil: (310) 795-2335
Office: (310) 452-5555
Fax: (310) 452-5550
Email: [email protected]
Paul E. Rosenfeld, Ph.D. Page 1 of 10 October 2021
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 oil spills, landfills, boilers and incinerators, process stacks, storage tanks, confined animal feeding operations, industrial, military and agricultural sources, unconventional oil drilling operations, and locomotive and construction engines. His project experience ranges from monitoring and modeling of pollution sources to evaluating impacts of pollution on workers at industrial facilities and residents in surrounding communities. Dr. Rosenfeld has also successfully modeled exposure to contaminants distributed by water systems and via vapor intrusion.

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

Attachment D
Paul E. Rosenfeld, Ph.D. Page 2 of 10 October 2021
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 October 2021

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 October 2021

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

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

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

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

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

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

Presentations:

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

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

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

Urban Environmental Pollution. Lecture conducted from Boston, MA.

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

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

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

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

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

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

Paul E. Rosenfeld, Ph.D. Page 5 of 10 October 2021

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.

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

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

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

Lecture conducted from Phoenix Arizona.

Paul E. Rosenfeld, Ph.D. Page 6 of 10 October 2021

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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.

Paul E. Rosenfeld, Ph.D. Page 7 of 10 October 2021

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

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

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

Teaching Experience:

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

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

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

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

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

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

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

Academic Grants Awarded:

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

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

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

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

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

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

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

Paul E. Rosenfeld, Ph.D. Page 8 of 10 October 2021

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

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

Deposition and/or Trial Testimony:

In the 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, 5-14-2021
Trial, October 8-4-2021

In the Circuit Court of Cook County Illinois
Joseph Rafferty, Plaintiff vs. Consolidated Rail Corporation and National Railroad Passenger Corporation d/b/a AMTRAK,
Case No.: No. 18-L-6845
Rosenfeld Deposition, 6-28-2021

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

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

Case Number CV20127-094749
Rosenfeld Deposition: 5-7-2021

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

Case Number 1:17-cv-000508
Rosenfeld Deposition: 3-25-2021

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

Case No. 1720288
Rosenfeld Deposition 2-23-2021

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

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

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

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

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

Paul E. Rosenfeld, Ph.D. Page 9 of 10 October 2021

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

In The Superior Court of the State of California, For The County of Los Angeles Warrn Gilbert and Penny Gilber, Plaintiff vs. BMW of North America LLC Case No.: LC102019 (c/w BC582154)
Rosenfeld Deposition, 8-16-2017, Trail 8-28-2018

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

Paul E. Rosenfeld, Ph.D. Page 10 of 10 October 2021

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 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 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 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 for the Middle District of Alabama, Northern Division James K. Benefield, et al., Plaintiffs, vs. International Paper Company, Defendant.

Civil Action Number 2:09-cv-232-WHA-TFM
Rosenfeld Deposition: July 2010, June 2011

In the Circuit Court of Jefferson County Alabama
Jaeanette Moss Anthony, et al., Plaintiffs, vs. Drummond Company Inc., et al., Defendants Civil Action No. CV 2008-2076
Rosenfeld Deposition: September 2010

In the United States District Court, Western District Lafayette Division Ackle et al., Plaintiffs, vs. Citgo Petroleum Corporation, et al., Defendants.

Case Number 2:07CV1052
Rosenfeld Deposition: July 2009
EXHIBIT B

INDOOR ENVIRONMENTAL ENGINEERING
1448 Pine Street, Suite 103 San Francisco, California 94109 Telephone: (415) 567-7700
E-mail: [email protected]
http://www.iee-sf.com

Date: November 1, 2022

To: Adam Frankel
Lozeau | Drury LLP
1939 Harrison Street, Suite 150
Oakland, California 94612

From: Francis J. Offermann PE CIH

Subject: Indoor Air Quality: Crossings Campus, Culver City, CA (IEE File Reference: P-4648)

Pages: 18

Indoor Air Quality Impacts
Indoor air quality (IAQ) directly impacts the comfort and health of building occupants, and the achievement of acceptable IAQ in newly constructed and renovated buildings is a well-recognized design objective. For example, IAQ is addressed by major high- performance building rating systems and building codes (California Building Standards Commission, 2014; USGBC, 2014). Indoor air quality in homes is part icularly important because occupants, on average, spend approximately ninety percent of their time indoors with the majority of this time spent at home (EPA, 2011). Some segments of the population that are most susceptible to the effects of poor IAQ, such as the very young and the elderly, occupy their homes almost continuously. Additionally, an increasing number of adults are working from home at least some of the time during the workweek.

Indoor air quality also is a serious concern for workers in hotels, offices and other business establishments.

The concentrations of many air pollutants often are elevated in homes and other buildings relative to outdoor air because many of the materials and products used indoors contain and release a variety of pollutants to air (Hodgson et al., 2002; Offermann and Hodgson, 2 of 18
2011). With respect to indoor air contaminants for which inhalation is the primary route of exposure, the critical design and construction parameters are the provision of adequate ventilation and the reduction of indoor sources of the contaminants.

Indoor Formaldehyde Concentrations Impact . In the California New Home Study (CNHS) of 108 new homes in California (Offermann, 2009), 25 air contaminants were measured, and formaldehyde was identified as the indoor air contaminant with the highest cancer risk as determined by the California Proposition 65 Safe Harbor Levels (OEHHA, 2017a), No Significant Risk Levels (NSRL) for carcinogens. The NSRL is the daily intake level calculated to result in one excess case of cancer in an exposed population of 100,000 (i.e., ten in one million cancer risk) and for formaldehyde is 40 µg/day. The NSRL concentration of formaldehyde that represents a daily dose of 40 µg is 2 µg/m 3, assuming a continuous 24- hour exposure, a t otal daily inhaled air volume of 20 m 3, and 100% absorption by the respiratory system. All of the CNHS homes exceeded this NSRL concentration of 2 µg/m 3. The median indoor formaldehyde concentration was 36 µg/m 3, and ranged from 4.8 to 136 µg/m 3, which corresponds to a median exceedance of the 2 µg/m3 NSRL concentration of 18 and a range of 2.3 to 68.

Therefore, the cancer risk of a resident living in a California home with the median indoor formaldehyde concentration of 36 µg/m
3, is 180 per million as a result of formaldehyde
alone. The CEQA significance threshold for airborne cancer risk is 10 per million, as established by the South Coast Air Quality Management District (SCAQMD, 2015).

Besides being a human carcinogen, formaldehyde is also a potent eye and respiratory irritant. In the CNHS, many homes exceeded the non- cancer reference exposure levels (RELs) prescribed by California Office of Environmental Health Hazard Assessment (OEHHA, 2017b). The percentage of homes exceeding the RELs ranged from 98% for the Chronic REL of 9 µg/m
3 to 28% for the Acute REL of 55 µg/m3.

The primary source of formaldehyde indoors is composite wood products manufactured with urea -formaldehyde resins, such as plywood, medium density fiberboard, and 3 of 18
particleboard. These materials are commonly used in building construction for flooring, cabinetry, baseboards, window shades, interior doors, and window and door trims.

In January 2009, the California Air Resources Board (CARB) adopted an airborne toxics control measu re (ATCM) to reduce formaldehyde emissions from composite wood products, including hardwood plywood, particleboard, medium density fiberboard, and also furniture and other finished products made with these wood products (California Air Resources Board 2009). While this formaldehyde ATCM has resulted in reduced emissions from composite wood products sold in California, they do not preclude that homes built with composite wood products meeting the CARB ATCM will have indoor formaldehyde concentrations below cancer and non-cancer exposure guidelines.

A follow up study to the California New Home Study (CNHS) was conducted in 2016- 2018 (Singer et. al., 2019), and found that the median indoor formaldehyde in new homes built after 2009 with CARB Phase 2 Formaldehyde ATCM materials had lower indoor formaldehyde concentrations, with a median indoor concentrations of 22.4 µg/m 3 (18.2
ppb) as compared to a median of 36 µg/m 3 found in the 2007 CNHS. Unlike in the CNHS study where formaldehyde concentrations were measured with pumped DNPH samplers, the formaldehyde concentrations in the HENGH study were measured with passive samplers, which were estimat ed to under -measure the true indoor formaldehyde concentrations by approximately 7.5%. Applying this correction to the HENGH indoor formaldehyde concentrations results in a median indoor concentration of 24.1 µg/m 3, which is 33% lower than the 36 µg/m3 found in the 2007 CNHS.

Thus, while new homes built after the 2009 CARB formaldehyde ATCM have a 33% lower median indoor formaldehyde concentration and cancer risk, the median lifetime cancer risk is still 120 per million for homes built with CARB compliant composite wood products. This median lifetime cancer risk is more than 12 times the OEHHA 10 in a million cancer risk threshold (OEHHA, 2017a).

With respect to the Crossings Campus Project, Culver City, CA , the buildings consist of commercial spaces.
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The employees of the commercial spaces are expected to experience significant indoor exposures (e.g., 40 hours per week, 50 weeks per year). These exposures for employees are anticipated to result in significan t cancer risks resulting from exposures to formaldehyde released by the building materials and furnishing commonly found in offices, warehouses, residences and hotels.

Because the commercial spaces will be constructed with CARB Phase 2 Formaldehyde ATCM materials, and be ventilated with the minimum code required amount of outdoor air, the indoor formaldehyde concentrations are likely similar to those concentrations observed in residences built with CARB Phase 2 Formaldehyde ATCM materials, which is a median of 24.1 µg/m
3 (Singer et. al., 2020)

Assuming that the employees of commercial spaces work 8 hours per day and inhale 20 m
3 of air per day, the formaldehyde dose per work-day at the offices is 161 µg/day.

Assuming that these employees work 5 days per week and 50 weeks per year for 45 years (start at age 20 and retire at age 65) the average 70-year lifetime formaldehyde daily dose is 70.9 µg/day.

This is 1.77 times the NSRL (OEHHA, 2017a) of 40 µg/day and represents a cancer r isk of 17.7 per million, which exceeds the CEQA cancer risk of 10 per million. This impact should be analyzed in an environmental impact report (“EIR”), and the agency should impose all feasible mitigation measures to reduce this impact. Several feasible mitigation measures are discussed below and these and other measures should be analyzed in an EIR.

In addition, we note that the average outdoor air concentration of formaldehyde in California is 3 ppb, or 3.7 µg/m
3, (California Air Resources Board, 2004), and thus
represents an average pre- existing background airborne cancer risk of 1.85 per million.

Thus, the indoor air formaldehyde exposures describe above exacerbate this pre- existing risk resulting from outdoor air formaldehyde exposures.

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Appendix A, Indoor Formaldehyde Concentrations and the CARB Formaldehyde ATCM, provides analyses that show utilization of CARB Phase 2 Formaldehyde ATCM materials will not ensure acceptable cancer risks with respect to formaldehyde emissions from composite wood products.

Even composite wood products manufactured with CARB certified ultra low emitting formaldehyde (ULEF) resins do not insure that the indoor air will have concentrations of formaldehyde the meet the OEHHA cancer risks that substantially exceed 10 p er million.

The permissible emission rates for ULEF composite wood products are only 11-15% lower than the CARB Phase 2 emission rates. O nly use of composite wood products made with no- added formaldehyde resins (NAF), such as resins made from soy, polyvinyl acetate, or methylene diisocyanate can insure that the OEHHA cancer risk of 10 per million is met.

The following describes a method that should be used, prior to construction in the environmental review under CEQA, for determining whether the indoor concentrations resulting from the formaldehyde emissions of specific building materials/furnishings selected exceed cancer and non -cancer guidelines. Such a design analyses can be used to identify those materials/furnishings prior to the completion of the City’s CEQA review and project approval, that have formaldehyde emission rates that contribute to indoor concentrations that exceed cancer and non -cancer guidelines, so that alternative lower emitting materials/furnishings may be selected and/or higher minimum outdoor air ventilation rates can be increased to achieve acceptable indoor concentrations and incorporated as mitigation measures for this project.

Pre-Construction Building Material/Furnishing Formaldehyde Emissions Assessment

This formaldehyde emissions assessment should be used in the environmental review under CEQA to assess the indoor formaldehyde concentrations from the proposed loading of building materials/furnishings, the area -specific formaldehyde emission rate data for building materials/furnishings, and the design minimum outdoor air ventilation rates. This assessment allows the applicant (and the City) to determine , before the 6 of 18
conclusion of the environmental review process and the building materials/furnishings are specified, purchased, and installed , if the total chemical emissions will exceed cancer and non- cancer guidelines, and if so, allow for changes in the selection of specific material/furnishings and/or the design minimum outdoor air ventilations rates such that cancer and non-cancer guidelines are not exceeded.

1.) Define Indoor Air Quality Zones . Divide the building into separate indoor air quality zones, (IAQ Zones). IAQ Zones are defined as areas of well -mixed air. Thus, each ventilation system with recirculating air is considered a single zone, and each room or group of rooms where air is not recirculated (e.g. 100% outdoor air) is considered a separate zone. For IAQ Zones with the same construction material/furnishings and design minimum outdoor air ventilation rates. (e.g. hotel rooms, apartments, condominiums, etc.) the formaldehyde emission rates need only be assessed for a single IAQ Zone of that type.

2.) Calculate Material/Furnishing Loading. For each IAQ Zone, determine the building material and furnishing loadings (e.g., m 2 of material/m 2 floor area, units of furnishings/m2 floor area) from an inventory of all potential indoor formaldehyde sources, including flooring, ceiling tiles, furnishings, finishes, insulation, sealants, adhesives, and any products constructed with composite wood products containing urea - formaldehyde resins (e.g., plywood, medium density fiberboard, particleboard).

3.) Calculate the Formaldehyde Emission Rate . For each building material, calculate the formaldehyde emission rate (µg/h) from the product of the area -specific formaldehyde emission rate (µg/m 2-h) and the area (m 2) of material in the IAQ Zone, and from each furnishing (e.g. chairs, desks, etc.) from the unit -specific formaldehyde emission rate (µg/unit-h) and the number of units in the IAQ Zone.

NOTE: As a result of the high- performance building rating systems and building codes (California Building Standards Commission, 2014; USGBC, 2014), most manufacturers of building materials furnishings sold in the United States conduct chemical emission rate tests using the California Department of Health “Standard Method for the Testing and Evaluation of Volatile Organic Chemical Emissions for Indoor Sources Using 7 of 18
Environmental Chambers ,” (CDPH, 2017), or other equivalent chemical emission rate testing methods. Most manufacturers of building furnishings sold in the United States conduct chemical emission rate tests using ANSI/BIFMA M7.1 Standard Test Method for Determining VOC Emissions (BIFMA, 2018), or other equivalent chemical emission rate testing methods.

CDPH, BIFMA, and other chemical emission rate testing programs, typically certify that a material or furnishing does not c reate indoor chemical concentrations in excess of the maximum concentrations permitted by their certification. For instance, the CDPH emission rate testing requires that the measured emission rates when input into an office, school, or residential model do not exceed one -half of the OEHHA Chronic Exposure Guidelines (OEHHA, 2017b) for the 35 specific VOCs, including formaldehyde, listed in Table 4-1 of the CDPH test method (CDPH, 2017). These certifications themselves do not provide the actual area -specific formaldehyde emission rate (i.e., µg/m 2-h) of the
product, but rather provide data that the formaldehyde emission rates do not exceed the maximum rate allowed for the certification. Thus, for example, the data for a certification of a specific type of flooring may be used to calculate that the area- specific emission rate of formaldehyde is less than 31 µg/m 2-h, but not the actual measured specific emission rate, which may be 3, 18, or 30 µg/m 2-h. These area -specific emission rates determined from the pr oduct certifications of CDPH, BIFA, and other certification programs can be used as an initial estimate of the formaldehyde emission rate.

If the actual area- specific emission rates of a building material or furnishing is needed (i.e. the initial emission rates estimates from the product certifications are higher than desired), then that data can be acquired by requesting from the manufacturer the complete chemical emission rate test report. For instance if the complete CDPH emission test report is requested for a CDHP certified product, that report will provide the actual area- specific emission rates for not only the 35 specific VOCs, including formaldehyde, listed in Table 4 -1 of the CDPH test method (CDPH, 2017), but also all of the cancer and reproductive/developmental chemicals listed in the California Proposition 65 Safe Harbor Levels (OEHHA, 2017a), all of the toxic air contaminants (TACs) in the California Air Resources Board Toxic Air Contamination List (CARB, 2011), and the 10 chemicals with the greatest emission rates.
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Alternatively, a sample of the building material or furnishing can be submitted to a chemical emission rate testing laboratory, such as Berkeley Analytical Laboratory (https://berkeleyanalytical.com), to measure the formaldehyde emission rate.

4.) Calculate the Total Formaldehyde Emission Rate. For each IAQ Zone, calculate the total formaldehyde emission rate (i.e. µg/h) from the individual formaldehyde emission rates from each of the building material/furnishings as determined in Step 3.

5.) Calculate the Indoor Formaldehyde Concentration. Fo r each IAQ Zone, calculate the indoor formaldehyde concentration (µg/m 3) from Equation 1 by dividing the total formaldehyde emission rates (i.e. µg/h) as determined in Step 4, by the design minimum outdoor air ventilation rate (m3/h) for the IAQ Zone.

𝐶𝐶𝑖𝑖𝑖𝑖=
𝐸𝐸𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡𝑡
𝑄𝑄𝑡𝑡𝑡𝑡
(Equation 1)

where:

Cin = indoor formaldehyde concentration (µg/m3)
Etotal = total formaldehyde emission rate (µg/h) into the IAQ Zone.

Qoa = design minimum outdoor air ventilation rate to the IAQ Zone (m3/h)

The above Equation 1 is based upon mass balance theory, and is referenced in Section

3.10.2 “Calculation of Estimated Building Concentrations” of the California Department of Health “Standard Method for the Testing and Evaluation of Volatile Organic Chemical Emissions for Indoor Sources Using Environmental Chambers”, (CDPH, 2017).

6.) Calculate the Indoor Exposure Cancer and Non- Cancer Health Risks . For each IAQ Zone, calculate the cancer and non -cancer health risks from the indoor formaldehyde concentrations determined in Step 5 and as described in the OEHHA Air Toxics Hot Spots Program Risk Assessment Guidelines; Guidance Manual for Preparation of Health Risk Assessments (OEHHA, 2015).

7.) Mitigate Indoor Formaldehyde Exposures of exceeding the CEQA Cancer and/or 9 of 18
Non-Cancer Health Risks . In each IAQ Zone, provide mitigation for any formaldehyde exposure risk as determined in Step 6, that exceeds the CEQA cancer risk of 10 per million or the CEQA non-cancer Hazard Quotient of 1.0.

Provide the source and/or ventilation mitigation required in all IAQ Zones to reduce the health risks of the chemical exposures below the CEQA cancer and non -cancer health risks.

Source mitigation for formaldehyde may include:

1.) reducing the amount materials and/or furnishings that emit formaldehyde

2.) substituting a different material with a lower area -specific emission rate of formaldehyde

Ventilation mitigation for formaldehyde emitted from building materials and/or furnishings may include:

1.) increasing the design minimum outdoor air ventilation rate to the IAQ Zone.

NOTE: Mitigating the formaldehyde emissions through use of less material/furnishings, or use of lower emitting materials/furnishings, is the preferred mitigation option, as mitigation with increased outdoor air ventilation increases initial and operating costs associated with the heating/cooling systems.

Further, we are not asking that the builder “speculate” on what and how much composite materials be used, but rather at the design stage to select composite wood materials based on the formaldehyde emission rates that manufacturers routinely conduct using the California Department of Health “Standard Method for the Testing and Evaluation of Volatile Organic Chemical Emissions for Indoor Sources Using Environmental Chambers,” (CDPH, 2017), and use the procedure described earlier above (i.e. Pre- Construction Building Material/Furnishing Formal dehyde Emissions Assessment) to insure that the materials selected achieve acceptable cancer risks from material off gassing of formaldehyde.

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Outdoor Air Ventilation Impact . Another important finding of the CNHS, was that the outdoor air ventilation rates in the homes were very low. Outdoor air ventilation is a very important factor influencing the indoor concentrations of air contaminants, as it is the primary removal mechanism of all indoor air generated contaminants. Lower outdoor air exchange rates cause indoor generated air contaminants to accumulate to higher indoor air concentrations. Many homeowners rarely open their windows or doors for ventilation as a result of their concerns for security/safety, noise, dust, and odor concerns (Price, 2007). In the CNHS field study, 32% of the homes did not use their windows during the 24‐ hour Test Day, and 15% of the homes did not use their windows during the entire preceding week. Most of the homes with no window usage were homes in the winter field session.

Thus, a substantial percentage of homeowners never open their windows, especially in the winter season. The median 24‐ hour measurement was 0.26 air changes per hour (ach) , with a range of 0.09 ach to 5.3 ach. A total of 67% of the homes had outdoor air exchange rates below the minimum California Building Code (2001) requirement of 0.35 ach. Thus, the relatively tight envelope construction, combined with the fact that many people never open their windows for ventilation, results in homes with low outdoor air exchange rates and higher indoor air contaminant concentrations.

According to the Draft Environmental Report – Crossings Campus, Culver City, CA (ESA, 2022), the Project is close to roads with moderate to high traffic (e.g., I- 10, Venice Boulevard, National Boulevard, Washington Boulevard, etc.) . As a result t he Project site is a sound impacted site.

The Draft Environmental Report – Crossings Campus, Culver City, CA (ESA, 2022) states in Table 4.10-13 that the future 2026 noise levels with the Projec t range from 55.6 to 72.2 dBA CNEL.

As a result of the high outdoor noise levels, the current project will require a mechanical supply of outdoor air ventilation to allow for a habitable interior environment with closed windows and doors. Such a ventilation system would allow windows and doors to be kept closed at the occupant’s discretion to control exterior noise within building interiors.

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PM2.5 Outdoor Concentrations Impact . An additional impact of the nearby motor vehicle traffic associated with this project, are the outdoor concentrations of PM 2.5.

According to the Draft Environmental Report – Crossings Campus, Culver City, CA (ESA, 2022) , the Project is located in the South Coast Air Basin, which is a State and Federal non-attainment area for PM2.5.

An air quality analyses should to be conducted to determine the concentrations of PM 2.5 in the outdoor and indoor air that people inhale each day. This air quality analys es needs to consider the cumulative impacts of the project related emissions, existing and projected future emissions from local PM 2.5 sources (e.g. stationary sources, motor vehicles, and airport traffic) upon the outdoor air concentrations at the Project site. If the outdoor concentrations are determined to exceed the California and National annual average PM 2.5 exceedence concentration of 12 µg/m 3, or the National 24- hour average exceedence concentration of 35 µg/m3, then the buildings need to have a mechanical supply of outdoor air that has air filtration with sufficient removal efficiency, such that the indoor concentrations of outdoor PM

2.5 particles is less than the California and National PM 2.5 annual and 24-hour standards.

It is my experience that based on the projected high traffic noise levels, the annual average concentration of PM

2.5 will exceed the California and National PM 2.5 annual and 24-hour standards and warrant installation of high efficiency air filters (i.e. MERV 13 or higher) i n all mechanically supplied outdoor air ventilation systems.

Indoor Air Quality Impact Mitigation Measures

The following are recommended mitigation measures to minimize the impacts upon indoor quality:

Indoor Formaldehyde Concentrations Mitigation. Use only composite wood materials (e.g. hardwood plywood, medium density fiberboard, particleboard) for all interior finish systems that are made with CARB approved no- added formaldehyde (NAF) resins (CARB, 2009). CARB Phase 2 certified composite wood products, or ultra -low emitting 12 of 18
formaldehyde (ULEF) resins, do not insure indoor formaldehyde concentrations that are below the CEQA cancer risk of 10 per million. Only composite wood products manufactured with CARB approved no- added formaldehyde (NAF) resins, s uch as resins made from soy, polyvinyl acetate, or methylene diisocyanate can insure that the OEHHA cancer risk of 10 per million is met.

Alternatively, conduct the previously described Pre -Construction Building Material/Furnishing Chemical Emissions Assessment, to determine that the combination of formaldehyde emissions from building materials and furnishings do not create indoor formaldehyde concentrations that exceed the CEQA cancer and non-cancer health risks.

It is important to note that we are not asking that the builder “speculate” on what and how much composite materials be used, but rather at the design stage to select composite wood materials based on the formaldehyde emission rates that manufacturers routinely conduct using the California Department of Health “Standard Method for the Testing and Evaluation of Volatile Organic Chemical Emissions for Indoor Sources Using Environmental Chambers”, (CDPH, 2017), and use the procedure described above (i.e.

Pre-Construction Building Material/Furnishing Formaldehyde Emissions Assessment) to insure that the materials selected achieve acceptable cancer risks from material off gassing of formaldehyde.

Outdoor Air Ventilation Mitigation . Provide each habitable room with a continuous mechanical supply of outdoor air that meets or exceeds the California 2016 Building Energy Efficiency Standards (California Energy Commission, 2015) requirements of the greater of 15 cfm/occupant or 0.15 cfm/ft
2 of floor area. Following installation of the
system co nduct testing and balancing to insure that required amount of outdoor air is entering each habitable room and provide a written report documenting the outdoor airflow rates. Do not use exhaust only mechanical outdoor air systems, use only balanced outdoor air supply and exhaust systems or outdoor air supply only systems. Provide a manual for the occupants or maintenance personnel, that describes the purpose of the mechanical outdoor air system and the operation and maintenance requirements of the system.
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PM2.5 Outdoor Air Concentration Mitigation. Install air filtration with sufficient PM 2.5 removal efficiency (e.g. MERV 13 or higher) to filter the outdoor air entering the mechanical outdoor air supply systems, such that the indoor concentrations of outdoor PM2.5 particles are less than the California and National PM 2.5 annual and 24-hour standards. Install the air filters in the system such that they are accessible for replacement by the occupants or maintenance personnel. Include in the mechanical outdoor air ventilation system manual instructions on how to replace the air filters and the estimated frequency of replacement.

References

BIFA. 2018. BIFMA Product Safety and Performance Standards and Guidelines. www.bifma.org/page/standardsoverview

California Air Resources Board. 2009. Airborne Toxic Control Measure to Reduce Formaldehyde Emissions from Composite Wood Products. California Environmental Protection Agency, Sacramento, CA.
https://www.arb.ca.gov/regact/2007/compwood07/fro-final.pdf

California Air Resour ces Board . 2011. Toxic Air Contaminant Identification List.

California Environmental Protection Agency, Sacramento, CA. https://www.arb.ca.gov/toxics/id/taclist.htm

California Building Code. 2001. California Code of Regulations, Title 24, Part 2 Volume 1, Appendix Chapter 12, Interior Environment, Division 1, Ventilation, Section 1207:
2001 California Building Code, California Building Standards Commission. Sacramento, CA.

California Building Standards Commission (2014). 2013 California Green Building Standards Code. California Code of Regulations, Title 24, Part 11. California Building Standards Commission, Sacramento, CA http://www.bsc.ca.gov/Home/CALGreen.aspx.

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California Energy Commission, PIER Program. CEC -500-2007-033. Final Report, ARB Contract 03-326. Available at: www.arb.ca.gov/research/apr/past/03-326.pdf.

California Energy Commission, 2015. 2016 Building Energy Efficiency Standards for Residential and Nonresidential Buildings, California Code of Regulations, Title 24, Part 6. http://www.energy.ca.gov/2015publications/CEC-400-2015-037/CEC-400-2015-037- CMF.pdf

CDPH. 2017. Standard Method for the Testing and Evaluation of Volatile Organic Chemical Emissions for Indoor Sources Using Environmental Chambers, Version 1.1.

California Department of Public Health, Rich mond, CA.
https://www.cdph.ca.gov/Programs/CCDPHP/ DEODC/EHLB/IAQ/Pages/VOC.aspx.

EPA. 2011. Exposure Factors Handbook: 2011 Edition, Chapter 16 – Activity Factors.

Report EPA/600/R -09/052F, September 2011. U.S. Environmental Protection Agency, Washington, D.C.

ESA. 2022. Draft Environmental Report – Crossings Campus, Culver City, CA.

Hodgson, A. T., D. Beal, J.E.R. McIlvaine. 2002. Sources of formaldehyde, other aldehydes and terpenes in a new manufactured house. Indoor Air 12: 235–242.

OEHHA (Office of Environmental Health Hazard Assessment). 2015. Air Toxics Hot Spots Program Risk Assessment Guidelines; Guidance Manual for Preparation of Health Risk Assessments.

OEHHA (Office of Environmental Health Hazard Assessment). 2017a. Proposition 65 Safe Harbor Levels. No Significant Risk Levels for Carcinogens and Maximum Allowable Dose Levels for Chemicals Causing Reproductive Toxicity. Available at:
http://www.oehha.ca.gov/prop65/pdf/safeharbor081513.pdf

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OEHHA - Office of Environme ntal Health Hazard Assessment. 2017b. All OEHHA Acute, 8 -hour and Chronic Reference Exposure Levels. Available at:
http://oehha.ca.gov/air/allrels.html

Offermann, F. J. 2009. Ventilation and Indoor Air Quality in New Homes. California Air Resources Board and California Energy Commission, PIER Energy‐ Related Environmental Research Program. Collaborative Report. CEC -500-2009-085. https://www.arb.ca.gov/research/apr/past/04-310.pdf

Offermann, F. J. and A. T. Hodgson. 2011. Emission Rates of Volatile Organic Compounds in New Homes. Proceedings Indoor Air 2011 (12 th International Conference on Indoor Air Quality and Climate 2011), June 5-10, 2011, Austin, TX.

Singer, B.C, Chan, W.R, Kim, Y., Offermann, F.J., and Walker I.S. 2020. Indoor Air Quality in California Homes with Code-Required Mechanical Ventilation. Indoor Air, Vol 30, Issue 5, 885-899.

South Coast Air Quality Management District (SCAQMD). 2015. California Environmental Quality Act Air Quality Handbook. South Coast Air Quality Management District, Diamond Bar, CA,
http://www.aqmd.gov/home/rules-compliance/ceqa/air-
quality-analysis-handbook

USGBC. 2014. LEED BD+C Homes v4. U.S. Green Building Council, Washington, D.C. http://www.usgbc.org/credits/homes/v4

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APPENDIX A

INDOOR FORMALDEHYDE CONCENTRATIONS

AND THE

CARB FORMALDEHYDE ATCM

With respect to formaldehyde emissions from composite wood products, the CARB ATCM regulations of formaldehyde emissions from composite wood products, do not assure healthful indoor air quality. The following is the stated purpose of the CARB ATCM regulati on - The purpose of this airborne toxic control measure is to “reduce formaldehyde emissions from composite wood products, and finished goods that contain composite wood products, that are sold, offered for sale, supplied, used, or manufactured for sale in California”. In other words, the CARB ATCM regulations do not “assure healthful indoor air quality” , but rather “ reduce formaldehyde emissions from composite wood products”.

Just how much protection do the CARB ATCM regulations provide building occupants from the formaldehyde emissions generated by composite wood products? Definitely some, but certainly the regulations do not “ assure healthful indoor air quality” when CARB Phase 2 products are utilized . As shown in the Chan 2019 study of new Cali fornia homes, the median indoor formaldehyde concentration was of 22.4 µg/m 3 (18.2 ppb), which corresponds to a cancer risk of 112 per million for occupants with continuous exposure, which is more than 11 times the CEQA cancer risk of 10 per million.

Another way of looking at how much protection the CARB ATCM regulations provide building occupants from the formaldehyde emissions generated by composite wood products is to calculate the maximum number of square feet of composite wood product that can be in a residence without exceeding the CEQA cancer risk of 10 per million for occupants with continuous occupancy.

For this calculation I utilized the floor area (2,272 ft 2), the ceiling height (8.5 ft), and the
number of bedrooms (4) as defined in Appendix B ( New Single -Family Residence Scenario) of the Standard Method for the Testing and Evaluation of Volatile Organic Chemical Emissions for Indoor Sources Using Environmental Chambers, Version 1.1, 2017, California 17 of 18
Department of Public Health, Richmond, CA. https://www.cdph.ca.gov/Programs/CCDPHP/ DEODC/EHLB/IAQ/Pages/VOC.aspx.

For the outdoor air ventilation rate I used the 2019 Title 24 code required mechanic al ventilation rate (ASHRAE 62.2) of 106 cfm (180 m3/h) calculated for this model residence.

For the composite wood formaldehyde emission rates I used the CARB ATCM Phase 2 rates.

The calculated maximum number of square feet of composite wood product that can be in a residence, without exceeding the CEQA cancer risk of 10 per million for occupants with continuous occupancy are as follows for the different types of regulated composite wood products.

Medium Density Fiberboard (MDF) – 15 ft
2 (0.7% of the floor area), or
Particle Board – 30 ft2 (1.3% of the floor area), or
Hardwood Plywood – 54 ft2 (2.4% of the floor area), or
Thin MDF – 46 ft2 (2.0 % of the floor area).

For offices and hotels the calculated maximum amount of composite wood product (% of floor area) that can be used without exceeding the CEQA cancer risk of 10 per million for occupants, assuming 8 hours/day occupancy, and the California Mechanical Code minimum outdoor air ventilation rates are as follows for the different types of regulated composite wood products.

Medium Density Fiberboard (MDF) – 3.6 % (offices) and 4.6% (hotel rooms), or Particle Board – 7.2 % (offices) and 9.4% (hotel rooms), or Hardwood Plywood – 13 % (offices) and 17% (hotel rooms), or Thin MDF – 11 % (offices) and 14 % (hotel rooms)

Clearly the CARB ATCM does not regulate the formaldehyde emissions from composite wood products such that the potentially large areas of these products, such as for flooring, baseboards, interior doors, window and door trims, and kitchen and bathroom cabinetry, 18 of 18
could be used without causing indoor formaldehyde concentrations that result in CEQA cancer risks that substantially exceed 10 per million for occupants with continuous occupancy.

Even composite wood products manufactured with CARB c ertified ultra low emitting formaldehyde (ULEF) resins do not insure that the indoor air will have concentrations of formaldehyde the meet the OEHHA cancer risks that substantially exceed 10 per million.

The permissible emission rates for ULEF composite wo od products are only 11- 15% lower than the CARB Phase 2 emission rates. Only use of composite wood products made with no- added formaldehyde resins (NAF), such as resins made from soy, polyvinyl acetate, or methylene diisocyanate can insure that the OEHHA cancer risk of 10 per million is met.

If CARB Phase 2 compliant or ULEF composite wood products are utilized in construction, then the resulting indoor formaldehyde concentrations should be determined in the design phase using the specific amounts of each type of composite wood product, the specific formaldehyde emission rates, and the volume and outdoor air ventilation rates of the indoor spaces, and all feasible mitigation measures employed to reduce this impact (e.g. use less formaldehyde containing composite wood products and/or incorporate mechanical systems capable of higher outdoor air ventilation rates). See the procedure described earlier (i.e. Pre -Construction Building Material/Furnishing Formaldehyde Emissions Assessment) to insure that the materials selected achieve acceptable cancer risks from material off gassing of formaldehyde.

Alternatively, and perhaps a simpler approach, is to use only composite wood products (e.g. hardwood plywood, medium density fiberboard, particleboard) for all interior finish systems that are made with CARB approved no-added formaldehyde (NAF) resins.

Francis (Bud) J. Offermann III PE, CIH Indoor Environmental Engineering 1448 Pine Street, Suite 103, San Francisco, CA 94109 Phone: 415-567-7700 Email: [email protected] http://www.iee-sf.com Education M.S. Mechanical Engineering (1985) Stanford University, Stanford, CA. Graduate Studies in Air Pollution Monitoring and Control (1980) University of California, Berkeley, CA. B.S. in Mechanical Engineering (1976) Rensselaer Polytechnic Institute, Troy, N.Y. Professional Experience President: Indoor Environmental Engineering, San Francisco, CA. December, 1981 - present. Direct team of environmental scientists, chemists, and mechanical engineers in conducting State and Federal research regarding indoor air quality instrumentation development, building air quality field studies, ventilation and air cleaning performance measurements, and chemical emission rate testing. Provide design side input to architects regarding selection of building materials and ventilation system components to ensure a high quality indoor environment. Direct Indoor Air Quality Consulting Team for the winning design proposal for the new State of Washington Ecology Department building. Develop a full-scale ventilation test facility for measuring the performance of air diffusers; ASHRAE 129, Air Change Effectiveness, and ASHRAE 113, Air Diffusion Performance Index. Develop a chemical emission rate testing laboratory for measuring the chemical emissions from building materials, furnishings, and equipment. Principle Investigator of the California New Homes Study (2005-2007). Measured ventilation and indoor air quality in 108 new single family detached homes in northern and southern California. Develop and teach IAQ professional development workshops to building owners, managers, hygienists, and engineers. 2 Air Pollution Engineer: Earth Metrics Inc., Burlingame, CA, October, 1985 to March, 1987. Responsible for development of an air pollution laboratory including installation a forced choice olfactometer, tracer gas electron capture chromatograph, and associated calibration facilities. Field team leader for studies of fugitive odor emissions from sewage treatment plants, entrainment of fume hood exhausts into computer chip fabrication rooms, and indoor air quality investigations. Staff Scientist: Building Ventilation and Indoor Air Quality Program, Energy and Environment Division, Lawrence Berkeley Laboratory, Berkeley, CA. January, 1980 to August, 1984. Deputy project leader for the Control Techniques group; responsible for laboratory and field studies aimed at evaluating the performance of indoor air pollutant control strategies (i.e. ventilation, filtration, precipitation, absorption, adsorption, and source control). Coordinated field and laboratory studies of air-to-air heat exchangers including evaluation of thermal performance, ventilation efficiency, cross-stream contaminant transfer, and the effects of freezing/defrosting. Developed an in situ test protocol for evaluating the performance of air cleaning systems and introduced the concept of effective cleaning rate (ECR) also known as the Clean Air Delivery Rate (CADR). Coordinated laboratory studies of portable and ducted air cleaning systems and their effect on indoor concentrations of respirable particles and radon progeny. Co-designed an automated instrument system for measuring residential ventilation rates and radon concentrations. Designed hardware and software for a multi-channel automated data acquisition system used to evaluate the performance of air-to-air heat transfer equipment. Assistant Chief Engineer: Alta Bates Hospital, Berkeley, CA, October, 1979 to January, 1980. Responsible for energy management projects involving installation of power factor correction capacitors on large inductive electrical devices and installation of steam meters on physical plant steam lines. Member of Local 39, International Union of Operating Engineers. Manufacturing Engineer: American Precision Industries, Buffalo, NY, October, 1977 to October, 1979. 3 Responsible for reorganizing the manufacturing procedures regarding production of shell and tube heat exchangers. Designed customized automatic assembly, welding, and testing equipment. Designed a large paint spray booth. Prepared economic studies justifying new equipment purchases. Safety Director. Project Engineer: Arcata Graphics, Buffalo, N.Y. June, 1976 to October, 1977. Responsible for the design and installation of a bulk ink storage and distribution system and high speed automatic counting and marking equipment. Also coordinated material handling studies which led to the purchase and installation of new equipment. PROFESSIONAL ORGANIZATION MEMBERSHIP American Society of Heating, Refrigeration and Air Conditioning Engineers (ASHRAE) • Chairman of SPC-145P, Standards Project Committee - Test Method for Assessing the Performance of Gas Phase Air Cleaning Equipment (1991-1992) • Member SPC-129P, Standards Project Committee - Test Method for Ventilation Effectiveness (1986-97) - Member of Drafting Committee • Member Environmental Health Committee (1992-1994, 1997-2001, 2007-2010) - Chairman of EHC Research Subcommittee - Member of Man Made Mineral Fiber Position Paper Subcommittee - Member of the IAQ Position Paper Committee - Member of the Legionella Position Paper Committee - Member of the Limiting Indoor Mold and Dampness in Buildings Position Paper Committee • Member SSPC-62, Standing Standards Project Committee - Ventilation for Acceptable Indoor Air Quality (1992 to 2000) - Chairman of Source Control and Air Cleaning Subcommittee • Chairman of TC-4.10, Indoor Environmental Modeling (1988-92) - Member of Research Subcommittee • Chairman of TC-2.3, Gaseous Air Contaminants and Control Equipment (1989-92) - Member of Research Subcommittee American Society for Testing and Materials (ASTM) • D-22 Sampling and Analysis of Atmospheres - Member of Indoor Air Quality Subcommittee • E-06 Performance of Building Constructions American Board of Industrial Hygiene (ABIH) American Conference of Governmental Industrial Hygienists (ACGIH) • Bioaerosols Committee (2007-2013) 4 American Industrial Hygiene Association (AIHA) Cal-OSHA Indoor Air Quality Advisory Committee International Society of Indoor Air Quality and Climate (ISIAQ) • Co-Chairman of Task Force on HVAC Hygiene U. S. Green Building Council (USGBC) - Member of the IEQ Technical Advisory Group (2007-2009) - Member of the IAQ Performance Testing Work Group (2010-2012) Western Construction Consultants (WESTCON) PROFESSIONAL CREDENTIALS Licensed Professional Engineer - Mechanical Engineering Certified Industrial Hygienist - American Board of Industrial Hygienists SCIENTIFIC MEETINGS AND SYMPOSIA Biological Contamination, Diagnosis, and Mitigation, Indoor Air’90, Toronto, Canada, August, 1990. Models for Predicting Air Quality, Indoor Air’90, Toronto, Canada, August, 1990. Microbes in Building Materials and Systems, Indoor Air ’93, Helsinki, Finland, July, 1993. Microorganisms in Indoor Air Assessment and Evaluation of Health Effects and Probable Causes, Walnut Creek, CA, February 27, 1997. Controlling Microbial Moisture Problems in Buildings, Walnut Creek, CA, February 27, 1997. Scientific Advisory Committee, Roomvent 98, 6th International Conference on Air Distribution in Rooms, KTH, Stockholm, Sweden, June 14-17, 1998. Moisture and Mould, Indoor Air ’99, Edinburgh, Scotland, August, 1999. Ventilation Modeling and Simulation, Indoor Air ’99, Edinburgh, Scotland, August, 1999. Microbial Growth in Materials, Healthy Buildings 2000, Espoo, Finland, August, 2000. 5 Co-Chair, Bioaerosols X- Exposures in Residences, Indoor Air 2002, Monterey, CA, July 2002. Healthy Indoor Environments, Anaheim, CA, April 2003. Chair, Environmental Tobacco Smoke in Multi-Family Homes, Indoor Air 2008, Copenhagen, Denmark, July 2008. Co-Chair, ISIAQ Task Force Workshop; HVAC Hygiene, Indoor Air 2002, Monterey, CA, July 2002. Chair, ETS in Multi-Family Housing: Exposures, Controls, and Legalities Forum, Healthy Buildings 2009, Syracuse, CA, September 14, 2009. Chair, Energy Conservation and IAQ in Residences Workshop, Indoor Air 2011, Austin, TX, June 6, 2011. Chair, Electronic Cigarettes: Chemical Emissions and Exposures Colloquium, Indoor Air 2016, Ghent, Belgium, July 4, 2016. SPECIAL CONSULTATION Provide consultation to the American Home Appliance Manufacturers on the development of a standard for testing portable air cleaners, AHAM Standard AC-1. Served as an expert witness and special consultant for the U.S. Federal Trade Commission regarding the performance claims found in advertisements of portable air cleaners and residential furnace filters. Conducted a forensic investigation for a San Mateo, CA pro se defendant, regarding an alleged homicide where the victim was kidnapped in a steamer trunk. Determined the air exchange rate in the steamer trunk and how long the person could survive. Conducted in situ measurement of human exposure to toluene fumes released during nailpolish application for a plaintiffs attorney pursuing a California Proposition 65 product labeling case. June, 1993. Conducted a forensic in situ investigation for the Butte County, CA Sheriff’s Department of the emissions of a portable heater used in the bedroom of two twin one year old girls who suffered simultaneous crib death. Consult with OSHA on the 1995 proposed new regulation regarding indoor air quality and environmental tobacco smoke. 6 Consult with EPA on the proposed Building Alliance program and with OSHA on the proposed new OSHA IAQ regulation. Johnson Controls Audit/Certification Expert Review; Milwaukee, WI. May 28-29, 1997. Winner of the nationally published 1999 Request for Proposals by the State of Washington to conduct a comprehensive indoor air quality investigation of the Washington State Department of Ecology building in Lacey, WA. Selected by the State of California Attorney General’s Office in August, 2000 to conduct a comprehensive indoor air quality investigation of the Tulare County Court House. Lawrence Berkeley Laboratory IAQ Experts Workshop: “Cause and Prevention of Sick Building Problems in Offices: The Experience of Indoor Environmental Quality Investigators”, Berkeley, California, May 26-27, 2004. Provide consultation and chemical emission rate testing to the State of California Attorney General’s Office in 2013-2015 regarding the chemical emissions from e-cigarettes. PEER-REVIEWED PUBLICATIONS : F.J.Offermann, C.D.Hollowell, and G.D.Roseme, "Low-Infiltration Housing in Rochester, New York: A Study of Air Exchange Rates and Indoor Air Quality," Environment International, 8, pp. 435-445, 1982. W.W.Nazaroff, F.J.Offermann, and A.W.Robb, "Automated System for Measuring Air Exchange Rate and Radon Concentration in Houses," Health Physics, 45, pp. 525-537, 1983. F.J.Offermann, W.J.Fisk, D.T.Grimsrud, B.Pedersen, and K.L.Revzan, "Ventilation Efficiencies of Wall- or Window-Mounted Residential Air-to-Air Heat Exchangers," ASHRAE Annual Transactions, 89-2B, pp 507-527, 1983. W.J.Fisk, K.M.Archer, R.E Chant, D. Hekmat, F.J.Offermann, and B.Pedersen, "Onset of Freezing in Residential Air-to-Air Heat Exchangers," ASHRAE Annual Transactions, 91-1B, 1984. W.J.Fisk, K.M.Archer, R.E Chant, D. Hekmat, F.J.Offermann, and B.Pedersen, "Performance of Residential Air-to-Air Heat Exchangers During Operation with Freezing and Periodic Defrosts," ASHRAE Annual Transactions, 91-1B, 1984. F.J.Offermann, R.G.Sextro, W.J.Fisk, D.T.Grimsrud, W.W.Nazaroff, A.V.Nero, and K.L.Revzan, "Control of Respirable Particles with Portable Air Cleaners," Atmospheric Environment, Vol. 19, pp.1761-1771, 1985. 7 R.G.Sextro, F.J.Offermann, W.W.Nazaroff, A.V.Nero, K.L.Revzan, and J.Yater, "Evaluation of Indoor Control Devices and Their Effects on Radon Progeny Concentrations," Atmospheric Environment, 12, pp. 429-438, 1986. W.J. Fisk, R.K.Spencer, F.J.Offermann, R.K.Spencer, B.Pedersen, R.Sextro, "Indoor Air Quality Control Techniques," Noyes Data Corporation, Park Ridge, New Jersey, (1987). F.J.Offermann, "Ventilation Effectiveness and ADPI Measurements of a Forced Air Heating System," ASHRAE Transactions , Volume 94, Part 1, pp 694-704, 1988. F.J.Offermann and D. Int-Hout "Ventilation Effectiveness Measurements of Three Supply/Return Air Configurations," Environment International , Volume 15, pp 585-592 1989. F.J. Offermann, S.A. Loiselle, M.C. Quinlan, and M.S. Rogers, "A Study of Diesel Fume Entrainment in an Office Building," IAQ '89, The Human Equation: Health and Comfort, pp 179-183, ASHRAE, Atlanta, GA, 1989. R.G.Sextro and F.J.Offermann, "Reduction of Residential Indoor Particle and Radon Progeny Concentrations with Ducted Air Cleaning Systems," submitted to Indoor Air, 1990. S.A.Loiselle, A.T.Hodgson, and F.J.Offermann, "Development of An Indoor Air Sampler for Polycyclic Aromatic Compounds", Indoor Air , Vol 2, pp 191-210, 1991. F.J.Offermann, S.A.Loiselle, A.T.Hodgson, L.A. Gundel, and J.M. Daisey, "A Pilot Study to Measure Indoor Concentrations and Emission Rates of Polycyclic Aromatic Compounds", Indoor Air , Vol 4, pp 497-512, 1991. F.J. Offermann, S. A. Loiselle, R.G. Sextro, "Performance Comparisons of Six Different Air Cleaners Installed in a Residential Forced Air Ventilation System," IAQ'91, Healthy Buildings, pp 342-350, ASHRAE, Atlanta, GA (1991). F.J. Offermann, J. Daisey, A. Hodgson, L. Gundell, and S. Loiselle, "Indoor Concentrations and Emission Rates of Polycyclic Aromatic Compounds", Indoor Air, Vol 4, pp 497-512 (1992). F.J. Offermann, S. A. Loiselle, R.G. Sextro, "Performance of Air Cleaners Installed in a Residential Forced Air System," ASHRAE Journal, pp 51-57, July, 1992. F.J. Offermann and S. A. Loiselle, "Performance of an Air-Cleaning System in an Archival Book Storage Facility," IAQ'92, ASHRAE, Atlanta, GA, 1992. S.B. Hayward, K.S. Liu, L.E. Alevantis, K. Shah, S. Loiselle, F.J. Offermann, Y.L. Chang, L. Webber, “Effectiveness of Ventilation and Other Controls in Reducing Exposure to ETS in Office Buildings,” Indoor Air ’93, Helsinki, Finland, July 4-8, 1993. 8 F.J. Offermann, S. A. Loiselle, G. Ander, H. Lau, "Indoor Contaminant Emission Rates Before and After a Building Bake-out," IAQ'93, Operating and Maintaining Buildings for Health, Comfort, and Productivity, pp 157-163, ASHRAE, Atlanta, GA, 1993. L.E. Alevantis, Hayward, S.B., Shah, S.B., Loiselle, S., and Offermann, F.J. "Tracer Gas Techniques for Determination of the Effectiveness of Pollutant Removal From Local Sources," IAQ '93, Operating and Maintaining Buildings for Health, Comfort, and Productivity, pp 119-129, ASHRAE, Atlanta, GA, 1993. L.E. Alevantis, Liu, L.E., Hayward, S.B., Offermann, F.J., Shah, S.B., Leiserson, K. Tsao, E., and Huang, Y., "Effectiveness of Ventilation in 23 Designated Smoking Areas in California Buildings," IAQ '94, Engineering Indoor Environments, pp 167-181, ASHRAE, Atlanta, GA, 1994. L.E. Alevantis, Offermann, F.J., Loiselle, S., and Macher, J.M., “Pressure and Ventilation Requirements of Hospital Isolation Rooms for Tuberculosis (TB) Patients: Existing Guidelines in the United States and a Method for Measuring Room Leakage”, Ventilation and Indoor air quality in Hospitals, M. Maroni, editor, Kluwer Academic publishers, Netherlands, 1996. F.J. Offermann, M. A. Waz, A.T. Hodgson, and H.M. Ammann, "Chemical Emissions from a Hospital Operating Room Air Filter," IAQ'96, Paths to Better Building Environments, pp 95-99, ASHRAE, Atlanta, GA, 1996. F.J. Offermann, "Professional Malpractice and the Sick Building Investigator," IAQ'96, Paths to Better Building Environments, pp 132-136, ASHRAE, Atlanta, GA, 1996. F.J. Offermann, “Standard Method of Measuring Air Change Effectiveness,” Indoor Air, Vol 1, pp.206-211, 1999. F. J. Offermann, A. T. Hodgson, and J. P. Robertson, “Contaminant Emission Rates from PVC Backed Carpet Tiles on Damp Concrete”, Healthy Buildings 2000, Espoo, Finland, August 2000. K.S. Liu, L.E. Alevantis, and F.J. Offermann, “A Survey of Environmental Tobacco Smoke Controls in California Office Buildings”, Indoor Air, Vol 11, pp. 26-34, 2001. F.J. Offermann, R. Colfer, P. Radzinski, and J. Robertson, “Exposure to Environmental Tobacco Smoke in an Automobile”, Indoor Air 2002, Monterey, California, July 2002. F. J. Offermann, J.P. Robertson, and T. Webster, “The Impact of Tracer Gas Mixing on Airflow Rate Measurements in Large Commercial Fan Systems”, Indoor Air 2002, Monterey, California, July 2002. M. J. Mendell, T. Brennan, L. Hathon, J.D. Odom, F.J.Offermann, B.H. Turk, K.M. Wallingford, R.C. Diamond, W.J. Fisk, “Causes and prevention of Symptom Complaints 9 in Office Buildings: Distilling the Experience of Indoor Environmental Investigators”, submitted to Indoor Air 2005, Beijing, China, September 4-9, 2005. F.J. Offermann, “Ventilation and IAQ in New Homes With and Without Mechanical Outdoor Air Systems”, Healthy Buildings 2009, Syracuse, CA, September 14, 2009. F.J. Offermann, “ASHRAE 62.2 Intermittent Residential Ventilation: What’s It Good For, Intermittently Poor IAQ”, IAQVEC 2010, Syracuse, CA, April 21, 2010. F.J. Offermann and A.T. Hodgson, “Emission Rates of Volatile Organic Compounds in New Homes”, Indoor Air 2011, Austin, TX, June, 2011. P. Jenkins, R. Johnson, T. Phillips, and F. Offermann, “Chemical Concentrations in New California Homes and Garages”, Indoor Air 2011, Austin, TX, June, 2011. W. J. Mills, B. J. Grigg, F. J. Offermann, B. E. Gustin, and N. E. Spingarm, “Toluene and Methyl Ethyl Ketone Exposure from a Commercially Available Contact Adhesive”, Journal of Occupational and Environmental Hygiene, 9:D95-D102 May, 2012. F. J. Offermann, R. Maddalena, J. C. Offermann, B. C. Singer, and H, Wilhelm, “The Impact of Ventilation on the Emission Rates of Volatile Organic Compounds in Residences”, HB 2012, Brisbane, AU, July, 2012. F. J. Offermann, A. T. Hodgson, P. L. Jenkins, R. D. Johnson, and T. J. Phillips, “Attached Garages as a Source of Volatile Organic Compounds in New Homes”, HB 2012, Brisbane, CA, July, 2012. R. Maddalena, N. Li, F. Offermann, and B. Singer, “Maximizing Information from Residential Measurements of Volatile Organic Compounds”, HB 2012, Brisbane, AU, July, 2012. W. Chen, A. Persily, A. Hodgson, F. Offermann, D. Poppendieck, and K. Kumagai, “Area-Specific Airflow Rates for Evaluating the Impacts of VOC emissions in U.S. Single-Family Homes”, Building and Environment, Vol. 71, 204-211, February, 2014. F. J. Offermann, A. Eagan A. C. Offermann, and L. J. Radonovich, “Infectious Disease Aerosol Exposures With and Without Surge Control Ventilation System Modifications”, Indoor Air 2014, Hong Kong, July, 2014. F. J. Offermann, “Chemical Emissions from E-Cigarettes: Direct and Indirect Passive Exposures”, Building and Environment, Vol. 93, Part 1, 101-105, November, 2015. F. J. Offermann, “Formaldehyde Emission Rates From Lumber Liquidators Laminate Flooring Manufactured in China”, Indoor Air 2016, Belgium, Ghent, July, 2016. F. J. Offermann, “Formaldehyde and Acetaldehyde Emission Rates for E-Cigarettes”, Indoor Air 2016, Belgium, Ghent, July, 2016. 10 OTHER REPORTS: W.J.Fisk, P.G.Cleary, and F.J.Offermann, "Energy Saving Ventilation with Residential Heat Exchangers," a Lawrence Berkeley Laboratory brochure distributed by the Bonneville Power Administration, 1981. F.J.Offermann, J.R.Girman, and C.D.Hollowell, "Midway House Tightening Project: A Study of Indoor Air Quality," Lawrence Berkeley Laboratory, Berkeley, CA, Report LBL-12777, 1981. F.J.Offermann, J.B.Dickinson, W.J.Fisk, D.T.Grimsrud, C.D.Hollowell, D.L.Krinkle, and G.D.Roseme, "Residential Air-Leakage and Indoor Air Quality in Rochester, New York," Lawrence Berkeley Laboratory, Berkeley, CA, Report LBL-13100, 1982. F.J.Offermann, W.J.Fisk, B.Pedersen, and K.L.Revzan, Residential Air-to-Air Heat Exchangers: A Study of the Ventilation Efficiencies of Wall- or Window- Mounted Units," Lawrence Berkeley Laboratory, Berkeley, CA, Report LBL-14358, 1982. F.J.Offermann, W.J.Fisk, W.W.Nazaroff, and R.G.Sextro, "A Review of Portable Air Cleaners for Controlling Indoor Concentrations of Particulates and Radon Progeny," An interim report for the Bonneville Power Administration, 1983. W.J.Fisk, K.M.Archer, R.E.Chant, D.Hekmat, F.J.Offermann, and B.S. Pedersen, "Freezing in Residential Air-to-Air Heat Exchangers: An Experimental Study," Lawrence Berkeley Laboratory, Berkeley, CA, Report LBL-16783, 1983. R.G.Sextro, W.W.Nazaroff, F.J.Offermann, and K.L.Revzan, "Measurements of Indoor Aerosol Properties and Their Effect on Radon Progeny," Proceedings of the American Association of Aerosol Research Annual Meeting, April, 1983. F.J.Offermann, R.G.Sextro, W.J.Fisk, W.W. Nazaroff, A.V.Nero, K.L.Revzan, and J.Yater, "Control of Respirable Particles and Radon Progeny with Portable Air Cleaners," Lawrence Berkeley Laboratory, Berkeley, CA, Report LBL-16659, 1984. W.J.Fisk, R.K.Spencer, D.T.Grimsrud, F.J.Offermann, B.Pedersen, and R.G.Sextro, "Indoor Air Quality Control Techniques: A Critical Review," Lawrence Berkeley Laboratory, Berkeley, CA, Report LBL-16493, 1984. F.J.Offermann, J.R.Girman, and R.G.Sextro, "Controlling Indoor Air Pollution from Tobacco Smoke: Models and Measurements,", Indoor Air, Proceedings of the 3rd International Conference on Indoor Air Quality and Climate, Vol 1, pp 257-264, Swedish Council for Building Research, Stockholm (1984), Lawrence Berkeley Laboratory, Berkeley, CA, Report LBL-17603, 1984. 11 R.Otto, J.Girman, F.Offermann, and R.Sextro,"A New Method for the Collection and Comparison of Respirable Particles in the Indoor Environment," Lawrence Berkeley Laboratory, Berkeley, CA, Special Director Fund's Study, 1984. A.T.Hodgson and F.J.Offermann, "Examination of a Sick Office Building," Lawrence Berkeley Laboratory, Berkeley, CA, an informal field study, 1984. R.G.Sextro, F.J.Offermann, W.W.Nazaroff, and A.V.Nero, "Effects of Aerosol Concentrations on Radon Progeny," Aerosols, Science, & Technology, and Industrial Applications of Airborne Particles, editors B.Y.H.Liu, D.Y.H.Pui, and H.J.Fissan, p525, Elsevier, 1984. K.Sexton, S.Hayward, F.Offermann, R.Sextro, and L.Weber, "Characterization of Particulate and Organic Emissions from Major Indoor Sources, Proceedings of the Third International Conference on Indoor Air Quality and Climate, Stockholm, Sweden, August 20-24, 1984. F.J.Offermann, "Tracer Gas Measurements of Laboratory Fume Entrainment at a Semi-Conductor Manufacturing Plant," an Indoor Environmental Engineering R&D Report, 1986. F.J.Offermann, "Tracer Gas Measurements of Ventilation Rates in a Large Office Building," an Indoor Environmental Engineering R&D Report, 1986. F.J.Offermann, "Measurements of Volatile Organic Compounds in a New Large Office Building with Adhesive Fastened Carpeting," an Indoor Environmental Engineering R&D Report, 1986. F.J.Offermann, "Designing and Operating Healthy Buildings", an Indoor Environmental Engineering R&D Report, 1986. F.J.Offermann, "Measurements and Mitigation of Indoor Spray-Applicated Pesticides", an Indoor Environmental Engineering R&D Report, 1988. F.J.Offermann and S. Loiselle, "Measurements and Mitigation of Indoor Mold Contamination in a Residence", an Indoor Environmental Engineering R&D Report, 1989. F.J.Offermann and S. Loiselle, "Performance Measurements of an Air Cleaning System in a Large Archival Library Storage Facility", an Indoor Environmental Engineering R&D Report, 1989. F.J. Offermann, J.M. Daisey, L.A. Gundel, and A.T. Hodgson, S. A. Loiselle, "Sampling, Analysis, and Data Validation of Indoor Concentrations of Polycyclic Aromatic Hydrocarbons", Final Report, Contract No. A732-106, California Air Resources Board, March, 1990. 12 L.A. Gundel, J.M. Daisey, and F.J. Offermann, "A Sampling and Analytical Method for Gas Phase Polycyclic Aromatic Hydrocarbons", Proceedings of the 5th International Conference on Indoor Air Quality and Climate, Indoor Air '90, July 29-August 1990. A.T. Hodgson, J.M. Daisey, and F.J. Offermann "Development of an Indoor Sampling and Analytical Method for Particulate Polycyclic Aromatic Hydrocarbons", Proceedings of the 5th International Conference on Indoor Air Quality and Climate, Indoor Air '90, July 29-August, 1990. F.J. Offermann, J.O. Sateri, “Tracer Gas Measurements in Large Multi-Room Buildings”, Indoor Air ’93, Helsinki, Finland, July 4-8, 1993. F.J.Offermann, M. T. O’Flaherty, and M. A. Waz “Validation of ASHRAE 129 - Standard Method of Measuring Air Change Effectiveness”, Final Report of ASHRAE Research Project 891, December 8, 1997. S.E. Guffey, F.J. Offermann et. al., “Proceedings of the Workshop on Ventilation Engineering Controls for Environmental Tobacco smoke in the Hospitality Industry”, U.S. Department of Labor Occupational Safety and Health Administration and ACGIH, 1998. F.J. Offermann, R.J. Fiskum, D. Kosar, and D. Mudaari, “A Practical Guide to Ventilation Practices & Systems for Existing Buildings”, Heating/Piping/Air Conditioning Engineering supplement to April/May 1999 issue. F.J. Offermann, P. Pasanen, “Workshop 18: Criteria for Cleaning of Air Handling Systems”, Healthy Buildings 2000, Espoo, Finland, August 2000. F.J. Offermann, Session Summaries: Building Investigations, and Design & Construction, Healthy Buildings 2000, Espoo, Finland, August 2000. F.J. Offermann, “The IAQ Top 10”, Engineered Systems, November, 2008. L. Kincaid and F.J. Offermann, “Unintended Consequences: Formaldehyde Exposures in Green Homes, AIHA Synergist, February, 2010. F.J. Offermann, “ IAQ in Air Tight Homes”, ASHRAE Journal, November, 2010. F.J. Offermann, “The Hazards of E-Cigarettes”, ASHRAE Journal, June, 2014. PRESENTATIONS : "Low-Infiltration Housing in Rochester, New York: A Study of Air Exchange Rates and Indoor Air Quality," Presented at the International Symposium on Indoor Air Pollution, Health and Energy Conservation, Amherst, MA, October 13-16,1981. 13 "Ventilation Efficiencies of Wall- or Window-Mounted Residential Air-to-Air Heat Exchangers," Presented at the American Society of Heating, Refrigeration, and Air Conditioning Engineers Summer Meeting, Washington, DC, June, 1983. "Controlling Indoor Air Pollution from Tobacco Smoke: Models and Measurements," Presented at the Third International Conference on Indoor Air Quality and Climate, Stockholm, Sweden, August 20-24, 1984. "Indoor Air Pollution: An Emerging Environmental Problem", Presented to the Association of Environmental Professionals, Bar Area/Coastal Region 1, Berkeley, CA, May 29, 1986. "Ventilation Measurement Techniques," Presented at the Workshop on Sampling and Analytical Techniques, Georgia Institute of Technology, Atlanta, Georgia, September 26, 1986 and September 25, 1987. "Buildings That Make You Sick: Indoor Air Pollution", Presented to the Sacramento Association of Professional Energy Managers, Sacramento, CA, November 18, 1986. "Ventilation Effectiveness and Indoor Air Quality", Presented to the American Society of Heating, Refrigeration, and Air Conditioning Engineers Northern Nevada Chapter, Reno, NV, February 18, 1987, Golden Gate Chapter, San Francisco, CA, October 1, 1987, and the San Jose Chapter, San Jose, CA, June 9, 1987. "Tracer Gas Techniques for Studying Ventilation," Presented at the Indoor Air Quality Symposium, Georgia Tech Research Institute, Atlanta, GA, September 22-24, 1987. "Indoor Air Quality Control: What Works, What Doesn't," Presented to the Sacramento Association of Professional Energy Managers, Sacramento, CA, November 17, 1987. "Ventilation Effectiveness and ADPI Measurements of a Forced Air Heating System," Presented at the American Society of Heating, Refrigeration, and Air Conditioning Engineers Winter Meeting, Dallas, Texas, January 31, 1988. "Indoor Air Quality, Ventilation, and Energy in Commercial Buildings", Presented at the Building Owners &Managers Association of Sacramento, Sacramento, CA, July 21, 1988. "Controlling Indoor Air Quality: The New ASHRAE Ventilation Standards and How to Evaluate Indoor Air Quality", Presented at a conference "Improving Energy Efficiency and Indoor Air Quality in Commercial Buildings," National Energy Management Institute, Reno, Nevada, November 4, 1988. "A Study of Diesel Fume Entrainment Into an Office Building," Presented at Indoor Air '89: The Human Equation: Health and Comfort, American Society of Heating, Refrigeration, and Air Conditioning Engineers, San Diego, CA, April 17-20, 1989. 14 "Indoor Air Quality in Commercial Office Buildings," Presented at the Renewable Energy Technologies Symposium and International Exposition, Santa Clara, CA June 20, 1989. "Building Ventilation and Indoor Air Quality", Presented to the San Joaquin Chapter of the American Society of Heating, Refrigeration, and Air Conditioning Engineers, September 7, 1989. "How to Meet New Ventilation Standards: Indoor Air Quality and Energy Efficiency," a workshop presented by the Association of Energy Engineers; Chicago, IL, March 20-21, 1989; Atlanta, GA, May 25-26, 1989; San Francisco, CA, October 19-20, 1989; Orlando, FL, December 11-12, 1989; Houston, TX, January 29-30, 1990; Washington D.C., February 26-27, 1990; Anchorage, Alaska, March 23, 1990; Las Vegas, NV, April 23-24, 1990; Atlantic City, NJ, September 27-28, 1991; Anaheim, CA, November 19-20, 1991; Orlando, FL, February 28 - March 1, 1991; Washington, DC, March 20-21, 1991; Chicago, IL, May 16-17, 1991; Lake Tahoe, NV, August 15-16, 1991; Atlantic City, NJ, November 18-19, 1991; San Jose, CA, March 23-24, 1992. "Indoor Air Quality," a seminar presented by the Anchorage, Alaska Chapter of the American Society of Heating, Refrigeration, and Air Conditioning Engineers, March 23, 1990. "Ventilation and Indoor Air Quality", Presented at the 1990 HVAC & Building Systems Congress, Santa, Clara, CA, March 29, 1990. "Ventilation Standards for Office Buildings", Presented to the South Bay Property Managers Association, Santa Clara, May 9, 1990. "Indoor Air Quality", Presented at the Responsive Energy Technologies Symposium & International Exposition (RETSIE), Santa Clara, CA, June 20, 1990. "Indoor Air Quality - Management and Control Strategies", Presented at the Association of Energy Engineers, San Francisco Bay Area Chapter Meeting, Berkeley, CA, September 25, 1990. "Diagnosing Indoor Air Contaminant and Odor Problems", Presented at the ASHRAE Annual Meeting, New York City, NY, January 23, 1991. "Diagnosing and Treating the Sick Building Syndrome", Presented at the Energy 2001, Oklahoma, OK, March 19, 1991. "Diagnosing and Mitigating Indoor Air Quality Problems" a workshop presented by the Association of Energy Engineers, Chicago, IL, October 29-30, 1990; New York, NY, January 24-25, 1991; Anaheim, April 25-26, 1991; Boston, MA, June 10-11, 1991; Atlanta, GA, October 24-25, 1991; Chicago, IL, October 3-4, 1991; Las Vegas, NV, December 16-17, 1991; Anaheim, CA, January 30-31, 1992; Atlanta, GA, March 5-6, 1992; Washington, DC, May 7-8, 1992; Chicago, IL, August 19-20, 1992; Las Vegas, 15 NV, October 1-2, 1992; New York City, NY, October 26-27, 1992, Las Vegas, NV, March 18-19, 1993; Lake Tahoe, CA, July 14-15, 1994; Las Vegas, NV, April 3-4, 1995; Lake Tahoe, CA, July 11-12, 1996; Miami, Fl, December 9-10, 1996. "Sick Building Syndrome and the Ventilation Engineer", Presented to the San Jose Engineers Club, May, 21, 1991. "Duct Cleaning: Who Needs It ? How Is It Done ? What Are The Costs ?" What Are the Risks ?, Moderator of Forum at the ASHRAE Annual Meeting, Indianapolis ID, June 23, 1991. "Operating Healthy Buildings", Association of Plant Engineers, Oakland, CA, November 14, 1991. "Duct Cleaning Perspectives", Moderator of Seminar at the ASHRAE Semi-Annual Meeting, Indianapolis, IN, June 24, 1991. "Duct Cleaning: The Role of the Environmental Hygienist," ASHRAE Annual Meeting, Anaheim, CA, January 29, 1992. "Emerging IAQ Issues", Fifth National Conference on Indoor Air Pollution, University of Tulsa, Tulsa, OK, April 13-14, 1992. "International Symposium on Room Air Convection and Ventilation Effectiveness", Member of Scientific Advisory Board, University of Tokyo, July 22-24, 1992. "Guidelines for Contaminant Control During Construction and Renovation Projects in Office Buildings," Seminar paper at the ASHRAE Annual Meeting, Chicago, IL, January 26, 1993. "Outside Air Economizers: IAQ Friend or Foe", Moderator of Forum at the ASHRAE Annual Meeting, Chicago, IL, January 26, 1993. "Orientation to Indoor Air Quality," an EPA two and one half day comprehensive indoor air quality introductory workshop for public officials and building property managers; Sacramento, September 28-30, 1992; San Francisco, February 23-24, 1993; Los Angeles, March 16-18, 1993; Burbank, June 23, 1993; Hawaii, August 24-25, 1993; Las Vegas, August 30, 1993; San Diego, September 13-14, 1993; Phoenix, October 18-19, 1993; Reno, November 14-16, 1995; Fullerton, December 3-4, 1996; Fresno, May 13-14, 1997. "Building Air Quality: A Guide for Building Owners and Facility Managers," an EPA one half day indoor air quality introductory workshop for building owners and facility managers. Presented throughout Region IX 1993-1995. “Techniques for Airborne Disease Control”, EPRI Healthcare Initiative Symposium; San Francisco, CA; June 7, 1994. 16 “Diagnosing and Mitigating Indoor Air Quality Problems”, CIHC Conference; San Francisco, September 29, 1994. ”Indoor Air Quality: Tools for Schools,” an EPA one day air quality management workshop for school officials, teachers, and maintenance personnel; San Francisco, October 18-20, 1994; Cerritos, December 5, 1996; Fresno, February 26, 1997; San Jose, March 27, 1997; Riverside, March 5, 1997; San Diego, March 6, 1997; Fullerton, November 13, 1997; Santa Rosa, February 1998; Cerritos, February 26, 1998; Santa Rosa, March 2, 1998. ASHRAE 62 Standard “Ventilation for Acceptable IAQ”, ASCR Convention; San Francisco, CA, March 16, 1995. “New Developments in Indoor Air Quality: Protocol for Diagnosing IAQ Problems”, AIHA-NC; March 25, 1995. "Experimental Validation of ASHRAE SPC 129, Standard Method of Measuring Air Change Effectiveness", 16th AIVC Conference, Palm Springs, USA, September 19-22, 1995. “Diagnostic Protocols for Building IAQ Assessment”, American Society of Safety Engineers Seminar: ‘Indoor Air Quality – The Next Door’; San Jose Chapter, September 27, 1995; Oakland Chapter, 9, 1997. “Diagnostic Protocols for Building IAQ Assessment”, Local 39; Oakland, CA, October 3, 1995. “Diagnostic Protocols for Solving IAQ Problems”, CSU-PPD Conference; October 24, 1995. “Demonstrating Compliance with ASHRAE 62-1989 Ventilation Requirements”, AIHA; October 25, 1995. “IAQ Diagnostics: Hands on Assessment of Building Ventilation and Pollutant Transport”, EPA Region IX; Phoenix, AZ, March 12, 1996; San Francisco, CA, April 9, 1996; Burbank, CA, April 12, 1996. “Experimental Validation of ASHRAE 129P: Standard Method of Measuring Air Change Effectiveness”, Room Vent ‘96 / International Symposium on Room Air Convection and Ventilation Effectiveness"; Yokohama, Japan, July 16-19, 1996. “IAQ Diagnostic Methodologies and RFP Development”, CCEHSA 1996 Annual Conference, Humboldt State University, Arcata, CA, August 2, 1996. “The Practical Side of Indoor Air Quality Assessments”, California Industrial Hygiene Conference ‘96, San Diego, CA, September 2, 1996. 17 “ASHRAE Standard 62: Improving Indoor Environments”, Pacific Gas and Electric Energy Center, San Francisco, CA, October 29, 1996. “Operating and Maintaining Healthy Buildings”, April 3-4, 1996, San Jose, CA; July 30, 1997, Monterey, CA. “IAQ Primer”, Local 39, April 16, 1997; Amdahl Corporation, June 9, 1997; State Compensation Insurance Fund’s Safety & Health Services Department, November 21, 1996. “Tracer Gas Techniques for Measuring Building Air Flow Rates”, ASHRAE, Philadelphia, PA, January 26, 1997. “How to Diagnose and Mitigate Indoor Air Quality Problems”; Women in Waste; March 19, 1997. “Environmental Engineer: What Is It?”, Monte Vista High School Career Day; April 10, 1997. “Indoor Environment Controls: What’s Hot and What’s Not”, Shaklee Corporation; San Francisco, CA, July 15, 1997. “Measurement of Ventilation System Performance Parameters in the US EPA BASE Study”, Healthy Buildings/IAQ’97, Washington, DC, September 29, 1997. “Operations and Maintenance for Healthy and Comfortable Indoor Environments”, PASMA; October 7, 1997. “Designing for Healthy and Comfortable Indoor Environments”, Construction Specification Institute, Santa Rosa, CA, November 6, 1997. “Ventilation System Design for Good IAQ”, University of Tulsa 10th Annual Conference, San Francisco, CA, February 25, 1998. “The Building Shell”, Tools For Building Green Conference and Trade Show, Alameda County Waste Management Authority and Recycling Board, Oakland, CA, February 28, 1998. “Identifying Fungal Contamination Problems In Buildings”, The City of Oakland Municipal Employees, Oakland, CA, March 26, 1998. “Managing Indoor Air Quality in Schools: Staying Out of Trouble”, CASBO, Sacramento, CA, April 20, 1998. “Indoor Air Quality”, CSOOC Spring Conference, Visalia, CA, April 30, 1998. “Particulate and Gas Phase Air Filtration”, ACGIH/OSHA, Ft. Mitchell, KY, June 1998. 18 “Building Air Quality Facts and Myths”, The City of Oakland / Alameda County Safety Seminar, Oakland, CA, June 12, 1998. “Building Engineering and Moisture”, Building Contamination Workshop, University of California Berkeley, Continuing Education in Engineering and Environmental Management, San Francisco, CA, October 21-22, 1999. “Identifying and Mitigating Mold Contamination in Buildings”, Western Construction Consultants Association, Oakland, CA, March 15, 2000; AIG Construction Defect Seminar, Walnut Creek, CA, May 2, 2001; City of Oakland Public Works Agency, Oakland, CA, July 24, 2001; Executive Council of Homeowners, Alamo, CA, August 3, 2001. “Using the EPA BASE Study for IAQ Investigation / Communication”, Joint Professional Symposium 2000, American Industrial Hygiene Association, Orange County & Southern California Sections, Long Beach, October 19, 2000. “Ventilation,” Indoor Air Quality: Risk Reduction in the 21st Century Symposium, sponsored by the California Environmental Protection Agency/Air Resources Board, Sacramento, CA, May 3-4, 2000. “Workshop 18: Criteria for Cleaning of Air Handling Systems”, Healthy Buildings 2000, Espoo, Finland, August 2000. “Closing Session Summary: ‘Building Investigations’ and ‘Building Design & Construction’, Healthy Buildings 2000, Espoo, Finland, August 2000. “Managing Building Air Quality and Energy Efficiency, Meeting the Standard of Care”, BOMA, MidAtlantic Environmental Hygiene Resource Center, Seattle, WA, May 23rd, 2000; San Antonio, TX, September 26-27, 2000. “Diagnostics & Mitigation in Sick Buildings: When Good Buildings Go Bad,” University of California Berkeley, September 18, 2001. “Mold Contamination: Recognition and What To Do and Not Do”, Redwood Empire Remodelers Association; Santa Rosa, CA, April 16, 2002. “Investigative Tools of the IAQ Trade”, Healthy Indoor Environments 2002; Austin, TX; April 22, 2002. “Finding Hidden Mold: Case Studies in IAQ Investigations”, AIHA Northern California Professionals Symposium; Oakland, CA, May 8, 2002. “Assessing and Mitigating Fungal Contamination in Buildings”, Cal/OSHA Training; Oakland, CA, February 14, 2003 and West Covina, CA, February 20-21, 2003. 19 “Use of External Containments During Fungal Mitigation”, Invited Speaker, ACGIH Mold Remediation Symposium, Orlando, FL, November 3-5, 2003. Building Operator Certification (BOC), 106-IAQ Training Workshops, Northwest Energy Efficiency Council; Stockton, CA, December 3, 2003; San Francisco, CA, December 9, 2003; Irvine, CA, January 13, 2004; San Diego, January 14, 2004; Irwindale, CA, January 27, 2004; Downey, CA, January 28, 2004; Santa Monica, CA, March 16, 2004; Ontario, CA, March 17, 2004; Ontario, CA, November 9, 2004, San Diego, CA, November 10, 2004; San Francisco, CA, November 17, 2004; San Jose, CA, November 18, 2004; Sacramento, CA, March 15, 2005. “Mold Remediation: The National QUEST for Uniformity Symposium”, Invited Speaker, Orlando, Florida, November 3-5, 2003. “Mold and Moisture Control”, Indoor Air Quality workshop for The Collaborative for High Performance Schools (CHPS), San Francisco, December 11, 2003. “Advanced Perspectives In Mold Prevention & Control Symposium”, Invited Speaker, Las Vegas, Nevada, November 7-9, 2004. “Building Sciences: Understanding and Controlling Moisture in Buildings”, American Industrial Hygiene Association, San Francisco, CA, February 14-16, 2005. “Indoor Air Quality Diagnostics and Healthy Building Design”, University of California Berkeley, Berkeley, CA, March 2, 2005. “Improving IAQ = Reduced Tenant Complaints”, Northern California Facilities Exposition, Santa Clara, CA, September 27, 2007. “Defining Safe Building Air”, Criteria for Safe Air and Water in Buildings, ASHRAE Winter Meeting, Chicago, IL, January 27, 2008. “Update on USGBC LEED and Air Filtration”, Invited Speaker, NAFA 2008 Convention, San Francisco, CA, September 19, 2008. “Ventilation and Indoor air Quality in New California Homes”, National Center of Healthy Housing, October 20, 2008. “Indoor Air Quality in New Homes”, California Energy and Air Quality Conference, October 29, 2008. “Mechanical Outdoor air Ventilation Systems and IAQ in New Homes”, ACI Home Performance Conference, Kansas City, MO, April 29, 2009. “Ventilation and IAQ in New Homes with and without Mechanical Outdoor Air Systems”, Healthy Buildings 2009, Syracuse, CA, September 14, 2009. 20 “Ten Ways to Improve Your Air Quality”, Northern California Facilities Exposition, Santa Clara, CA, September 30, 2009. “New Developments in Ventilation and Indoor Air Quality in Residential Buildings”, Westcon meeting, Alameda, CA, March 17, 2010. “Intermittent Residential Mechanical Outdoor Air Ventilation Systems and IAQ”, ASHRAE SSPC 62.2 Meeting, Austin, TX, April 19, 2010. “Measured IAQ in Homes”, ACI Home Performance Conference, Austin, TX, April 21, 2010. “Respiration: IEQ and Ventilation”, AIHce 2010, How IH Can LEED in Green buildings, Denver, CO, May 23, 2010. “IAQ Considerations for Net Zero Energy Buildings (NZEB)”, Northern California Facilities Exposition, Santa Clara, CA, September 22, 2010. “Energy Conservation and Health in Buildings”, Berkeley High SchoolGreen Career Week, Berkeley, CA, April 12, 2011. “What Pollutants are Really There ?”, ACI Home Performance Conference, San Francisco, CA, March 30, 2011. “Energy Conservation and Health in Residences Workshop”, Indoor Air 2011, Austin, TX, June 6, 2011. “Assessing IAQ and Improving Health in Residences”, US EPA Weatherization Plus Health, September 7, 2011. “Ventilation: What a Long Strange Trip It’s Been”, Westcon, May 21, 2014. “Chemical Emissions from E-Cigarettes: Direct and Indirect Passive Exposures”, Indoor Air 2014, Hong Kong, July, 2014. “Infectious Disease Aerosol Exposures With and Without Surge Control Ventilation System Modifications”, Indoor Air 2014, Hong Kong, July, 2014. “Chemical Emissions from E-Cigarettes”, IMF Health and Welfare Fair, Washington, DC, February 18, 2015. “Chemical Emissions and Health Hazards Associated with E-Cigarettes”, Roswell Park Cancer Institute, Buffalo, NY, August 15, 2014. “Formaldehyde Indoor Concentrations, Material Emission Rates, and the CARB ATCM”, Harris Martin’s Lumber Liquidators Flooring Litigation Conference, WQ Minneapolis Hotel, May 27, 2015. 21 “Chemical Emissions from E-Cigarettes: Direct and Indirect Passive Exposure”, FDA Public Workshop: Electronic Cigarettes and the Public Health, Hyattsville, MD June 2, 2015. “Creating Healthy Homes, Schools, and Workplaces”, Chautauqua Institution, Athenaeum Hotel, August 24, 2015. “Diagnosing IAQ Problems and Designing Healthy Buildings”, University of California Berkeley, Berkeley, CA, October 6, 2015. “Diagnosing Ventilation and IAQ Problems in Commercial Buildings”, BEST Center Annual Institute, Lawrence Berkeley National Laboratory, January 6, 2016. “A Review of Studies of Ventilation and Indoor Air Quality in New Homes and Impacts of Environmental Factors on Formaldehyde Emission Rates From Composite Wood Products”, AIHce2016, May, 21-26, 2016. “Admissibility of Scientific Testimony”, Science in the Court, Proposition 65 Clearinghouse Annual Conference, Oakland, CA, September 15, 2016. “Indoor Air Quality and Ventilation”, ASHRAE Redwood Empire, Napa, CA, December 1, 2016.

VIA EMAIL ONLY

November 9, 2022

Chair Nancy Barba
Vice Chair Ed Ogosta
Commissioner Jen Carter
Commissioner Stephen Jones
Commissioner Andrew Reilman
Planning Commission
City of Culver City
9770 Culver Boulevard
Culver City, CA 90232

Jeff Anderson, Planning Manager
Current Planning Division
City of Culver City
9770 Culver Boulevard
Culver City, CA 90232
[email protected]

Mr. Jeremy Green
City Clerk
City of Culver City
9770 Culver Boulevard
Culver City, CA 90232
[email protected]

Re: Notice of Withdrawal of Comment Letter; Environmental Impact Report for the Crossings Campus Project (P2021-0272-EIR); (P2022-0144-ZCMA); (P2022-0144- CP); (Planning Commission Resolution No. 2022-P021); (Culver City File No. 23- 538); (SCH No. 2021110079)

Dear Chair Barba, Honorable Planning Commissioners, and Mr. Anderson:

On November 8, 2022, Supporters Alliance for Environmental Responsibility (“SAFER”) submitted a comment letter to the City of Culver City (“City”) Current Planning Division, expressing its concerns regarding various inadequacies of the Environmental Impact Report (“EIR”), and related approvals prepared for the Crossings Campus Project (“Project”).

SAFER is pleased to announce that it has reached an agreement with the Applicant, Culver Crossings Properties LLC (“Applicant”), who sought approvals from the City for the Project. Pursuant to the agreement, the Applicant has agreed to implement additional measures which resolve many of SAFER’s environmental concerns. SAFER accordingly withdraws its prior comment letter and has no further objection to the Project.

November 9, 2022
Withdrawal of Comment Letter

Sincerely,

Adam Frankel
Lozeau Drury LLP