2026-02-09_ATT 8 - Certified MND — City Council Meeting Agenda, February 9, 2026 (part 2 of 3)

MM-GEO-3: Prior to commencement of
demolition or excavation activities, the Qualified
Paleontologist shall attend a pre-grade/construction
meeting to conduct construction worker
paleontological resources sensitivity training for
construction personnel. The training session, shall
be carried out by the Qualified Paleontologist and
shall focus on how to identify paleontological
resources that may be encountered during
earthmoving activities and the procedures to be
followed in such an event. In the event construction
crews are phased, additional trainings shall be
conducted for new construction personnel.

Documentation shall be retained demonstrating that
construction personnel attended the training.

Condition of
Approval
Plan Check
Notes, Reports,
Surveys and
Field
Inspections
Prior to Grading
Permit and
Building Permit
and On-Going
during
Construction
Culver City
Building Safety
Division,
Building Safety
Inspector,
Public Works,
Engineering
and Planning
Division
MM-GEO-4: If a potential fossil is found, the
paleontological monitor shall be allowed to
temporarily divert or redirect grading and
excavation activities in the area of the exposed
fossil to fac ilitate evaluation of the discovery. An
appropriate buffer area (usually 50 feet) shall be
established around the find where construction
activities shall not be allowed to continue. Work
shall be allowed to continue outside of the buffer
area. At the Qual ified Paleontologist’s discretion,
and to reduce any construction delay, the grading
and excavation contractor shall assist in removing
rock/sediment samples for initial processing and
evaluation. If the fossil is determined to be
significant, the Qualifie d Paleontologist shall
implement a paleontological salvage program to
remove the resources from their location, following
the guidelines of the SVP (SVP, 2010). Any fossils
encountered and recovered shall be prepared to
the point of identification and cata logued before
they are submitted to their final repository. Any
fossils collected shall be curated at a public, non-
profit institution with a research interest in the
material and with retrievable storage, such as the
Natural History Museum of Los Angeles County, if
such an institution agrees to accept the fossils. If
Condition of
Approval
Plan Check
Notes, Reports,
Surveys and
Field
Inspections
Prior to Grading
Permit and
Building Permit
and On-Going
during
Construction
Culver City
Building Safety
Division,
Building Safety
Inspector,
Public Works,
Engineering
and Planning
Division
11469 Jefferson Boulevard
Project

April

2021

Attachment C
–

Miti
gation Monitoring
Program

C
-
10 MITIGATION MONITORING PROGRAM

P2019
-
0194
-
SPR
;
P2019
-
0194
-
CUP
; and
P2019
-
0194
-
AUP

Project Design Feature/
Mitigation Measure

Implementing
Action,
Condition or
Mechanism

Method of
Verification

Timing of
Verification

Responsible
Persons

no institution accepts the fossil collection, they
shall be donated to a local school in the area for
educational purposes. Accompanying notes,
maps, and photographs shall also be filed at the

repository and/or school.

If construction personnel discover any potential
fossils during construction while the
paleontological monitor is not present, regardless
of the depth of work or location, work at the
discovery location shall cease in a 50
-
foo
t radius
of the discovery until the Qualified Paleontologist
has assessed the discovery and recommended
and implemented appropriate treatment as
described earlier in this measure.

MM
-
GEO
-
5:

Prior to the release of the grading
bond,
the Qualified Paleontologist shall prepare a
report summarizing the results of the monitoring
and salvaging efforts, the methodology used in
these efforts, as well as a description of the fossils
collected and their significance. The report shall be
submit
ted by the Applicant to the City, the Natural
History Museum of Los Angeles County, and
representatives of other appropriate or concerned
agencies to signify the satisfactory completion of
the Project and required mitigation measures.

Condition of
Approva
l

Plan Check
Notes, Reports,
Surveys and
Field
Inspections

Prior to Grading
Permit and
Building Permit
and On
-
Going
during
Construction

Culver City
Building Safety
Division,
Building Safety
Inspector,
Public Works,
Engineering
and Planning
Division

HAZARDS AND HAZARDOUS MATERIALS

MM
-
HAZ
-
1:

The Applicant shall retain a qualified
environmental consultant to prepare a Soil
Management and Remediation Plan

(SMRP)

for review
and approval by the Culver City Building Safety
Division
,
Department of Toxic Substances Control
(
DTSC
)

and
Los Angeles

Regional Water Quality
Control Board

(

LARWQCB
)
, as necessary, prior to the
c
ommencement of excavation and grading activities.

The plan would include measures to remove and/or
treat/remediate the impacted soils and groundwater to a level determined

by the LARWQCB to be protective of
human health and the environment and compatible
with
commercial use, in compliance with all
acceptable per
applicable regulatory standards, under supervision of a certified environmental consultant licensed to oversee
such remediation.

The SMRP shall describe measures
for (i) excavation of soils, (ii)
characterization of soils
to determine whether they qualify as hazardous waste
under regulations such as 22 C.C.R. § 66262.11 or other regulations identified in the SMRP or otherwise

Condition of
Approval

Plan Check
Notes, Reports,
Surveys and
Field
Inspections

Prior to Grading
Permit and
Building Permit
and

On
-
Going
during
Construction

Culver City
Building Safety
Division;
Building Safety
Inspector;

Fire Prevention;

Fire Inspector;

Planning
Division

11469 Jefferson Boulevard
Project

April

2021

Attachment C
–

Miti
gation Monitoring
Program

C
-
11 MITIGATION MONITORING PROGRAM

P2019
-
0194
-
SPR
;
P2019
-
0194
-
CUP
; and
P2019
-
0194
-
AUP

Project Design Feature/
Mitigation Measure

Implementing
Action,
Condition or
Mechanism

Method of
Verification

Timing of
Verification

Responsible
Persons

identified by DTSC and/or LARWQCB, and (iii)
disposal of excavated soils
in compliance with all
applicable regulations. The SMRP shall also describe
measures for sampling, treatment and disposal of
groundwater generated during construct
ion as
discussed
in MM
-
HYD
-
1 . The SMRP shall also
provide measures for the evaluation of va
por intrusion
risk at the Project site, and if necessary, modification of the Project design and/or installation of a vapor
intrusion mitigation system consistent with the
procedures and performance standards set forth in
DTSC’s October 2011 Vapor Intrusio
n Mitigation
Advisory

or as otherwise determined applicable by
DTSC at the time of construction
.

Upon completion of
the Soil Management and Remediation Plan, the
Applicant shall contact the LARWQCB
and DTSC, as
necessary,

to obtain a closure letter that s
tates no further
soils testing or remediation is required on the Project Site
.

MM
-
HAZ
-
2 :

Prior to the issuance of any permit
for the demolition or alteration of the existing on
-
site
buildings, a comprehensive ACMs survey of
the buildings shall be performed. If no ACMs are
found, the Applicant shall provide a letter to the
Culver City Building Safety Division from a
qualified asbestos abatement consultant
indicating that no ACMs are pr
esent in the on
-
site
buildings. If ACMs are found to be present, they
shall be abated in compliance with the South
Coast Air Quality Management District's Rule
1403 as well as all other applicable State and
Federal rules and regulations
.

Condition of
Approval

Plan Check
Notes, Reports,
Surveys and
Field
Inspections

Prior to Grading
Permit and
Building Permit
and On
-
Going
during
Construction

Culver City
Building Safety
Division;
Building Safety
Inspector;

Fire Prevention;

Fire Inspector;

Planning
Divis
ion

HYDROLOGY AND WATER QUALITY

MM
-
HYD
-
1:

If dewatering activities occur on
-
site during future redevelopment, samples shall be
obtained from the water and analyzed for volatile
organic compounds (VOCs) and oxygenates to
ensure that they do not exceed
applicable
discharge requirements. Should the samples
exceed VOC, oxygenates or any other applicable
discharge requirement, a dewatering plan shall be
prepared by the Project applicant for submittal to
the Los Angeles Regional Water Quality Control
Board (
LARWQCB), Los Angeles C
ounty
,

and
other appropriate agencies determined
appropriate in consultation with the LARWQCB for
review and approval. The plan shall include but not

Condition of
Approval

Plan Check
Notes, Reports,
Surveys and
Field
Inspections

On
-
Going
During
Construction

Culver City
Planning, Public
Works, and
Building Safety
Division

11469 Jefferson Boulevard
Project

April

2021

Attachment C
–

Miti
gation Monitoring
Program

C
-
12 MITIGATION MONITORING PROGRAM

P2019
-
0194
-
SPR
;
P2019
-
0194
-
CUP
; and
P2019
-
0194
-
AUP

Project Design Feature/
Mitigation Measure

Implementing
Action,
Condition or
Mechanism

Method of
Verification

Timing of
Verification

Responsible
Persons

be limited to sampling of groundwater
generated
during construction

that may be contaminated; and
treatment and disposal of contaminated
groundwater
generated during construction

in
compliance with applicable regulatory
requirements. Written verification from the
LARWQCB of approval of a dewatering plan
completion shall be

submitted to the Culver City
Planning Division, Building Safety Division, and
Department of Public Works prior to issuance of
grading permit.

NOISE

PDF
-
NOI
-
1: Noise Reduction Measures

Consistent with Policy 2.A of the Noise Element,
the Project would install a temporary sound barrier
during construction that blocks

the line
-
of
-
sight
between the Project Site and the residential uses
to the west and northwest achieving a minimum 10
dBA reduction in noise.

Condition of
Approval

Plan Check and
Field
Inspections

On
-
Going
during
Construction

Culver City
Building
Safety
Division,
Building Safety
Inspector,
Public Works,
Engineering
and Planning
Division

PUBLIC SERVICES

MM
-
PS
-
1:

Construction Traffic Management
Plan
–

A Construction Traffic Management Plan
shall be developed by the Project contractor in
consultation with the Project’s traffic and/or civil
engineer and approved by Culver City’s Building
Official, Engineer and/or Planning Manager, as
applicable, prior to issuance of any Project
demolition, grading or excavation permit. The Final
Plan shall
also be reviewed and approved by Culver
City’s Fire and Police Departments. The Culver
City’s Building Official, City Engineer and/or
Planning Manager, as applicable reserve the right
to reject any engineer at any time and to require that
the Plan be prepa
red by a different engineer.

Prior to commencement of construction, the
contractor shall advise the Public Works Inspector
and Building Inspector (“Inspectors”) of the
construction schedule and shall meet with the
Inspectors. Also, biweekly construction
management meetings with City S
taff and other
surrounding developments that will potentially be
under construction at around the same time as the
Project shall be required, as determined
appropriate by City Staff, to ensure concurrent

Condition of
Approval

Plan Check
Notes, Reports,
Surveys and
Field
Inspections

Prior to
Demolition,
Grading and
Building
Permits and
On
-
Going
during
Construction

Culver City
Planning, Public
Works, Fire and
Police
Departments

11469 Jefferson Boulevard
Project

April

2021

Attachment C
–

Miti
gation Monitoring
Program

C
-
13 MITIGATION MONITORING PROGRAM

P2019
-
0194
-
SPR
;
P2019
-
0194
-
CUP
; and
P2019
-
0194
-
AUP

Project Design Feature/
Mitigation Measure

Implementing
Action,
Condition or
Mechanism

Method of
Verification

Timing of
Verification

Responsible
Persons

construction projects are managed in collaboration
w
ith one another.

The Construction Traffic Management Plan shall
identify, at a minimum, the following to the
satisfaction of the City
:



The name and telephone number of a
contact person who can be reached 24
hours a day regarding construction traffic
compla
ints or emergency situations.



An up
-
to
-
date list of local police, fire, and
emergency response organizations and
procedures for the continuous
coordination of construction activity,
potential delays, and any alerts related to
unanticipated road conditions
or delays,
with local police, fire, and emergency
response agencies. Coordination shall
include the assessment of any alternative
access routes that might be required
through the site, and maps showing
access to and within the site and to
adjacent propert
ies.



Procedures for the training and
certification of the flag persons.



The location, times, and estimated
duration of any roadway closures, traffic
detours, use of protective devices,
warning signs, and staging or queuing
areas.



The location and travel ro
utes of off
-
site
staging and parking locations.



The location of temporary power, portable
toilet and trash and materials storage
locations.



The timing and duration of all street and/or
lane closures and shall be made available
to the City in digital format

for posting on
the City's website and distribution via
email alerts on the City's "Gov Delivery"
system. The Plans shall be updated
weekly during the duration of Project
construction, as determined necessary by
the City Department of Public Works or
desig
nee determined appropriate by
Public Works.

11469 Jefferson Boulevard
Project

April

2021

Attachment C
–

Miti
gation Monitoring
Program

C
-
14 MITIGATION MONITORING PROGRAM

P2019
-
0194
-
SPR
;
P2019
-
0194
-
CUP
; and
P2019
-
0194
-
AUP

Project Design Feature/
Mitigation Measure

Implementing
Action,
Condition or
Mechanism

Method of
Verification

Timing of
Verification

Responsible
Persons



Prior to approval of the Plan, the applicant
shall conduct one (1) Community Meeting
pursuant to the notification requirements
of the City's Community Meeting
guidelines, to discuss and provide the
following info
rmation to the surrounding
community.

Construction schedule and hours.

Framework for construction phases.

Identify traffic diversion plan by phase
and activity.

Potential location of construction
parking and office trailers.

Truck hauling routes and mater
ial
deliveries (i.e. identify the potential
routes and restrictions. Discuss the
types and number of trucks
anticipated and for what construction
activity).

Emergency access plan.

Demolition plan.

Staging plan for the concrete pours,
material loading and r
emoval.

Crane location(s).

10)

Accessible applicant and contractor
contacts during construction activity
and during off hours (relevant email
address and phone numbers).

TRANSPORTATION

MM
-
TRANS
-
1:

The Project shall implement a
TDM Plan to encourage the use of non
-
auto
modes of transportation and reduce vehicle trips.

The TDM Plan shall be reviewed and approved by
the City’s Planning Division, Public
Works/Engineering, and Transportation Staff for
re
view prior to the issuance of the first building
permit for the Project. The TDM Plan shall include,
at a minimum, measures required by the CCMC.

In addition, as recommended by the Project’s
Traffic Study, the TDM Plan shall also include, but
not be limite
d to measures and strategies to
reduce vehicle trips via amenity Improvements

Condition of
Approval

Approval of
Plan

Prior to
issuance of
Building Permit

Culver City
Traffic
Engineering
,
Engineering/

Public Works
,
Transportation
Department
and
Planning
Division

11469 Jefferson Boulevard
Project

April

2021

Attachment C
–

Miti
gation Monitoring
Program

C
-
15 MITIGATION MONITORING PROGRAM

P2019
-
0194
-
SPR
;
P2019
-
0194
-
CUP
; and
P2019
-
0194
-
AUP

Project Design Feature/
Mitigation Measure

Implementing
Action,
Condition or
Mechanism

Method of
Verification

Timing of
Verification

Responsible
Persons

supporting alternative modes of transportation and
a trip reduction program
.

MM
-
TRANS
-
2 :

To enhance the traffic signal
system in the Project study area and in response
to the forecast significant Project impacts, the
Applicant shall contribute a fixed
-
fee financial
contribution toward funding traffic signal upgrades,
including installation of closed
-
circuit television
(CCTV) cameras at Intersection No. 3 (Jefferson
Boulevard & 1
-
405 Northbound Ramps). The
funding contr
ibutions toward Intersection No. 3
(Jefferson Boulevard & 1
-
405 Northbound Ramps)
shall be based on coordination with Culver City’s
Planning Division and Public Works/Engineering
Staff, as well as LADOT, as necessary. This, and
any other required financial

fair
-
share
contributions, must be guaranteed prior to the
issuance of the Project’s building permit and
completed prior to the issuance of the Project’s
certificate of occupancy. Temporary certificates of
occupancy may be granted in the events of any
dela
y through no fault of the applicant, provided
that, in each case, the applicant has demonstrated
reasonable efforts and due diligence to the
satisfaction of the Culver City’s Planning Division
and Public Works/Engineering Staff, as well as
LADOT, as necess
ary
.

Condition of
Approval

Plan Check
Notes and Field
Inspections

Prior to
issuance of
Building Permit;
installation prior
to issuance of
Certificate of
Occupancy

Culver City
Traffic
Engineering
,
Engineering/

Public Works
and Planning
Division

TRIBAL

CULTURAL RESOURCES

Refer to Mitigation Measure CUL
-
2, above

Condition of
Approval

Plan Check
Notes, Reports,
Surveys and
Field
Inspections

Prior to Grading
Permit and
Building Permit
and On
-
Going
during
Construction

Culver City
Building Safety

Division,
Building Safety
Inspector,
Public Works,
Engineering
and Planning
Division

D-1

ATTACHMENT D

RESPONSES TO COMMENTS
A. INTRODUCTION
Section 15074(b) of the California Environmental Quality Act (CEQA) Guidelines states that “ Prior to approving a project, the decision-making body of the lead agency shall consider the proposed negative declaration or mitigated negative declaration together with any comments received during the public review process.” This chapter provides responses to written comments on the Draft MND, inclusive of one agency letter and nine (9) public comment letters received during the public comment period.

Table D-1, Comments Received in Response to the Draft MND, provides a list of the comment letters received by the City.

Section B, Responses to Comments, below, presents the comment letters submitted during the public comment period for the Draft EIR. As indicated in Table D -1, the comment letters are organized by agencies (AG ) and individuals (IND). Each letter/correspondence is assigned a number and each comment that requires a response within a given letter/correspondence is also assigned a number. For example, the agency letter from the California Department of Transportation (Caltrans) is designated Letter No. AG 1. The first comment r eceived within Letter No. AG 1 is then labeled Comment No. AG 1-1. Each numbered comment is then followed by a corresponding numbered response, (i.e., Response to Comment No. AG 1-1). A copy of each comment letter is provided in Appendix A, Original Comment Letters, in this Final MND. T he focus o f the responses to comments is the disposition of significant environmental issues raised. Therefore, detailed responses are not provided to comments that do not relate to environmental issues. However, in some cas es, additional information has been added for reference and clarity.

11469 Jefferson Boulevard Project
April 2021
Attachment D – Responses to Comments

D-2

TABLE D-1

COMMENTS RECEIVED IN RESPONSE TO THE DRAFT MND
No. From Date Received
Project
Description
Aesthetics
Air Quality
Greenhouse
Gas Emissions
Hazards &
Hazardous
Materials
Land Use and
Planning
Noise and
Vibration
Traffic/Parking
Other CEQA
Other
Agencies
AG 1
Miya Edmonson, IGR/Ceqa Branch Chief
Department of Transportation
District 7 – Office of Regional Planning
100 S. Main Street, MS 16 Los Angeles, CA 90012
February 18, 2021 X X
Individuals
IND 1 Ramez Ethnasios & Samia Rafeedie: Segrell Way
residents January 27, 2021 X
IND 2
Jonah Breslau, He/him/his
Research Analyst
Los Angeles Alliance for a New Economy (LAANE)
February 4, 2021 X
IND 3 Jay Coury, President
Premier World Discovery February 4, 2021 X X
IND 4 Tieira Ryder February 5, 2021 X
IND 5
David Steinitz C/O F.I.R.E./L.T.D.
12035 W. Jefferson Blvd.

Los Angeles, CA. 90230-6219
February 9, 2021 X X
IND 6
Robin Turner
10650 Drakewood Ave.

Culver City, CA 90230
February 10, 2021 X X
IND 7
Jordan Sisson (on behalf of UNITE HERE Local 11)
801 South Grand Avenue, 11th Floor
Los Angeles, CA. 90017
February 11, 2021 X X X X
11469 Jefferson Boulevard Project
April 2021
Attachment D – Responses to Comments

D-3

No. From Date Received
Project
Description
Aesthetics
Air Quality
Greenhouse
Gas Emissions
Hazards &
Hazardous
Materials
Land Use and
Planning
Noise and
Vibration
Traffic/Parking
Other CEQA
Other
IND 8
Arthur L. Kassan, P.E.

Registered Traffic Engineer No. 152
5105 Cimarron Lane
Culver City, CA 90230
February 17, 2021 X X
IND 9
Brian Flynn (on behalf of the Supporters Alliance
for Environmental Responsibility (“SAFER”)
Lozeau Drury, LLP
1939 Harrison Street, Suite 150
Oakland, CA 94612
February 19, 2021 X X X X

11469 Jefferson Boulevard Project
April 2021
Attachment D – Responses to Comments

D-4

B. RESPONSES TO COMMENTS
Comment Letter No. AG 1
Miya Edmonson, IGR/Ceqa Branch Chief
Department of Transportation
District 7 – Office of Regional Planning
100 S. Main Street, MS 16 Los Angeles, CA 90012
Received February 18, 2021

Comment No. AG 1-1
Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the above referenced MND. The Project would redevelop a 33,813 square foot (SF) property located in the northwest corner of the Jefferson Boulevard and Slauson Avenue intersection in Culver City. The existing single-story commercial building and parking lot would be removed as part of the Project. The Project includes the development of a new, five-story, 175-room boutique hotel building with food and beverage amenities and a two level, below -grade parking garage. Specifically, the 111,000 SF building would provide a total of approximately 67,030 SF in 175 hotel rooms, 8,536 SF of back of -house uses, 14,783 SF of ho tel amenities, 630 SF of bicycle parking, 18,842 SF of circulation facilities, and 1,119 SF of loading area. In addition, 15,450 SF of open space area would be provided, as well as 56,300 SF of subterranean parking that would accommodate a minimum of 138 parking spaces. The City of Culver City is the Lead Agency under the California Environmental Quality Act (CEQA).

Response to Comment No. AG 1-1
This comment is a brief summary of the Project as set forth in the MND . As the comment does not raise any specific issues with respect to the content and adequacy of the Draft MND , no further response is warranted.

Comment No. AG 1-2
The project is located approximately 1,000 feet away from the State Route 90 and Interstate 405 interchange.

From reviewing the MND, Caltrans has the following comments. As mentioned in the document, Senate Bill 743 (2013) mandates that Vehicle Miles Traveled (VMT) be used as the primary metric in identifying transportation impacts of all future development projects under CEQA, starting July 1, 2020. Since this implementation deadline has passed, Caltrans has reviewed this project from a VMT rather than a Level of Service (LOS) perspective.

For information on determining transportation impacts in terms of VMT on the State Highway System, see the Technical Advisory on Evaluating Transportation Impacts in CEQA by the California Governor’s Office of Planning and Research (OPR), dated December 2018: http://opr.ca.gov/docs/20190122- 743_Technical_Advisory.pdf. The City can also refer to Caltrans’ updated Vehicle Miles Traveled- Focused Transportation Impact Study Guide (TISG), dated May 2020: https://dot.ca.gov/- /media/dot-media/programs/transportation-planning/documents/sb-743/2020-05-20-approved-vmt-focused- tisg- a11y.pdf. Caltrans’ new TISG is largely based on the OPR 2018 Technical Advisory. 11469 Jefferson Boulevard Project
April 2021
Attachment D – Responses to Comments

D-5

Response to Comment No. AG 1-2
This comment introduces comments by Caltrans and indicates that Caltrans has reviewed this project from a VMT rather than a Level of Service (LOS) perspective. Reference documents pertaining to VMT are included in this comment. As the comment does not raise any specific issues regarding the content or adequacy of the Draft MND, no further response is warranted.

Comment No. AG 1-3
Due to the release of these guides, Caltrans no longer refers to the following agreements mentioned in the MND:
the October 2013 Agreement Between the City of Los Angeles and Caltrans District 7 on Freeway Impact Analysis Procedures, and the December 2015 First Amendment to the Agreement between LADOT and Caltrans District 7 on Freeway Impact Analysis Procedures.

Response to Comment No. AG 1-3
This comment provides the perspective that Caltrans took i n reviewing the MND. Specific State and Caltrans documents are cited for reference regarding VMT, and Caltrans indicates that previous non -VMT related transportation analysis agreements are no longer recognized. As such, no further response is warranted.

Comment No. AG 1-4
Regarding VMT, the MND states “Given the Project’s proximity (approximately one block) to the Westfield‐ Culver City Transit Center, the City considers the Project site to be in a key TPA [Transit Priority Area]. Therefore, based on the key TPA screening threshold, the Project is presumed to have a less ‐than‐ significant VMT impact and no further VMT analysis is required. ” The OPR Technical Advisory states that a presumption of less ‐than‐ significant VMT impact may not apply if the project includes more parking for use by residents, customers, or employees of the project than required by the jurisdiction. Thus, in the final MND please confirm that the project will not include more parking than required. For example, please state the maximum rather than the minimum number of parking spaces that will be provided.

Response to Comment No. AG 1-4
The Project will not provide more parking than required by the City of Culver City, as described in the April 3, 2020 Parking Demand Analysis prepared for the Project and included as Appendix E to the October 19, 2020 Traffic Impact Study. Through standard application of City of Culver City Municipal Code off -street parking requirement rates, the Project would require 387 automobile parking spaces. However, in coordination with City Planning staff, an empirical parking utilization study of similar, nearby hotels was conducted to determine current hotel parking demand rates in light of recent demand shifts due to the rise in customer travel via transportation network companies (TNCs) such as Lyft and Uber. That study determined conservatively that the Project would generate, at most, an automobile parking demand of 138 parked vehicles. Therefore, the Project parking supply includes 138 automobile parking spaces.

Comment No. AG 1-5
In addition, encroachment permits are required for any work performed on or near Caltrans’ right of way. Such permits might be needed for the installation of closed-circuit television cameras at the Jefferson Boulevard & 1- 405 Northbound Ramps intersection. However, Caltrans’ Office of Permits will make the final determination on this. Also, the MND states that the project applicant will contribute a fixed-fee financial contribution toward funding 11469 Jefferson Boulevard Project
April 2021
Attachment D – Responses to Comments

D-6

these improvements. In the final MND, please clarify which entity will be asked to pay the balance of the needed funding.

Response to Comment No. AG 1-5
The City of Los Angeles Department of Transportation (LADOT) shares with Caltrans the operation and maintenance costs for the intersection of Jefferson Boulevard and the I -405 Freeway Northbound Ramps.

Therefore, both the City of Los Angeles and Caltrans will review the traffic signal plan for the proposed mitigation improvement (installation of a closed- circuit television camera for use by the City of Los Angeles Automated Traffic Surveillance and Control [ ATSAC] Division). The Project applicant will provide a fixed- fee financial contribution that will cover 100 percent of the improvement cost. Therefore, no public entity will be asked to pay for the installation of this improvement.

Comment No. AG 1-6
The following information is included for your consideration. The mission of Caltrans is to provide a safe, sustainable, integrated and efficient transportation system to enhance California’s economy and livability.

Furthermore, Caltrans encourages Lead Agencies to implement Transportation Demand Management (TDM) strategies that reduce VMT and Greenhouse Gas (GHG) emissions. Thus, Caltrans supports this project implementing a TDM plan. For specific TDM options to include in this plan, please refer to:
• The 2010 Quantifying Greenhouse Gas Mitigation Measures report by the California Air Pollution Control Officers Association (CAPCOA), available at http://www.capcoa.org/wp - content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf, or • Integrating Demand Management into the Transportation Planning Process: A Desk Reference (Chapter 8) by the Federal Highway Administration (FHWA), avail able at https://ops.fhwa.dot.gov/publications/fhwahop12035/index.htm.

Response to Comment No. AG 1-6
This comment provides background information on Caltrans and highlights their support for VMT and GHG reduction strategies to be considered by the City, as the Lead Agency, in their decision- making process. Also, the comment supports the Project implementing a TDM Plan. Consistent with this comment, the Project would be required to prepare a TDM Plan as required by Mitigation Measure MM-TRANS-1. As the comment does not raise any specific issues regarding the content or adequacy of the Draft MND, no further response is warranted.

Comment No. AG 1-7
Also, any transportation of heavy construction equipment and/or materials which requi res use of oversized- transport vehicles on State highways will need a Caltrans transportation permit. Caltrans supports the following measure: “Dirt hauling and construction material deliveries or removal would not be allowed during morning (7:00 AM – 9:00 AM) and afternoon (4:00 PM – 6:00 PM) peak traffic periods.” If construction traffic is expected to cause delays on any State facilities, please submit the Construction Management Plan detailing these delays for Caltrans’ review.

Response to Comment No. AG 1-7
The comment identifies Caltrans’ permit requirements for oversized construction vehicles and recommends that large-size trucks trips be limited to off -peak hours. Project contractors would obtain transportation permits for 11469 Jefferson Boulevard Project
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any oversized transport vehicles on State highways. Efforts would be made to limit oversized transport during off-peak hours (such as mid-day hours) to facilitate the movement of such vehicles and reduce effects on State highway traffic.

As the comment does not raise any specific issues regarding the content or adequacy of the Draft EIR, no further response is warranted.

Comment No. AG 1-8
If you have any questions about these comments, please contact Emily Gibson, the proj ect coordinator, at [email protected], and refer to GTS # 07-LA-2021-03483.

Response to Comment No. AG 1-8
The comment provides contact information and is noted.

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Comment Letter No. IND 1-1
Ramez Ethnasios & Samia Rafeedie: Segrell Way residents Received January 27, 2021

Comment No. IND 1-1
On behalf of my wife, Samia Rafeedie, I would like to submit these comments regarding the above entitled project. We are resident owners of a house on Segrell Way and have reviewed the Traffic Impact Study dated 10-19-2020.

We have concerns that without proper deterrents in place that traffic will increase and cars will freely park in front of our house. We do not want to wait for such a time in the future when this will occur to start the process with the city, wait for whatever studies to be done, then get whatever measures in place.

Thinking about the amount of parking spots the hotel will have, the 120 full and part time employees, and guests, one would surely guess that a number of these persons will seek to park in the adjacent street for a variety of reasons. For employees, there may be limits in the parking spaces and for guests they may not want to pay whatever nightly parking fees.

Response to Comment No. IND 1-1
A discussion of parking for the Project is provided on pages B-103 and B-104 of the Draft MND for informational purposes, as parking is not an issue subject to CEQA impact findings. Regardless, as discussed therein, the Project is expected to have a maximum parking demand of 138 parking spaces (inclusive of employees and all visitors), which would occur midday on a weekday. The project would provide at least 138 spaces to meet this peak demand. Furthermore, as discussed on page B-104 of the MND, at the request of the City and based on concerns from the community, the Proje ct will fund a study to identify potential neighborhood traffic intrusion measures. These measures may include peak -period turn restrictions at certain intersections to address the cut-through traffic concerns within the Sunkist Park neighborhood. City t raffic engineering staff indicated that there is a recognized cut -through traffic problem on southbound Segrell Way and Culver Park Drive, between Sawtelle Boulevard and Slauson Avenue, during the weekday PM peak period. As such, City staff indicated they would be supportive of traffic measures involving weekday PM peak -period left-turn restrictions for the southbound approaches of Segrell Way and Culver Park Drive at Slauson Avenue (and possibly right -turn restrictions for the eastbound approaches of Sawt elle Boulevard at Segrell Way and Culver Park Drive). The study would follow the Neighborhood Traffic Management Program (NTMP) process, as required for local street traffic intrusion improvements in the Sunkist Park neighborhood.

An additional Project feature may include assisting the Sunkist Park neighborhood with expanding the residential permit parking program to ensure that parking along Segrell Way and Culver Park Drive is available primarily (or exclusively) for residents/guests on those roadways. Within five years of Project occupancy, if the City determines there is an intrusion of Project parking on nearby residential streets, the Project or subsequent property owner shall be responsible to pay for a parking study to be performed by a consultant selected by the City. If the parking study determines that mitigations are needed such as the establishment of permit parking, the Project shall pay for such mitigations including the cost of signage and one year of residential parking permits to alleviate the intrusion of Project parking on those streets. 11469 Jefferson Boulevard Project
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Similarly, within five years after Project occupancy, if the City observes there is an intrusion of Project traffic onto nearby residential streets, the Project or subsequent property owner shall be responsible to conduct a NTMP with input from the community to study and pay for the implementation of any traffic calming measures that will minimize or eliminate Project traffic from using the nearby residential streets. The NTMP review, design, and construction would be carried out by consultants selected by the City.

Comment No. IND 1-2
Please expedite the process for:
-peak period turn restrictions at certain intersections as noted on page 86 of the traffic impact study, and -begin the process to expand the residential parking permit program on Segrell way.

Response to Comment No. IND 1-2
This comment requests expedited processes for assessing noted traffic restrictions and a parking permit program. This comment is noted; however, as this comment does not raise any specific issues with respect to the content or adequacy of the Draft MND, no further response is warranted.

Comment No. IND 1-3
Please feel free to contact me as needed and I would like an update about any mitigation of our traffic intrusion and parking concerns related to the hotel project in 11469 Jefferson Blvd.

Response to Comment No. IND 1-3
This conclusion comment is noted; however, as this comment does not raise any specific issues with respect to the content or adequacy of the Draft MND, no further response is warranted.

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Comment Letter No. IND 2
Jonah Breslau
He/him/his
Research Analyst
Los Angeles Alliance for a New Economy (LAANE)
Received February 4, 2021

Comment No. IND 2-1
My name is Jonah Breslau. I am a research analyst at LAANE (https://laane.org/). I was wondering if there will be a public hearing for the Jeff Hotel project at 11469 Jefferson Boulevard Project (P2019- 0194-SPR P2019- 0194-CUP P2019-0194-AUP). If so, when would it be?
Response to Comment No. IND 2-1
Public hearings will be conducted for the Project. The public hearings will include hearings with the City Planning Commission and City Council. Notices of the public hearings will be posted on the City of Culver’s website at https://www.culvercity.org/Public-Notices and specific meeting/agenda information will be posted at https://www.culvercity.org/City-Hall/Meetings-Agendas.

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Comment Letter No. IND 3
Jay Coury, President
Premier World Discovery
Received February 4, 2021

Comment No. IND 3-1
I reside at 11430 Segrell Way, CC and was wondering if there is a rendering of the project available see view? While I am in favor of the project, living where I do, I wonder if guests on top ﬂoor will get a view into my yard. I am excited that the project will bring attention to the alley which has become a causeway for speeding and once the two bars re-open on Jeﬀerson, the alley becomes something quite diﬀerent. Thank you in advance for your reply.

Response to Comment No. IND 3-1
Rendering of the Project are included in the Draft MND on pages A -16 to A-18 (see Figures A-12, A-13 and A- 14). Also, as discussed on page B-104 of the Draft MND, at the request of the City and based on concerns from the community, the Project will the Project will fund a study to identify potential neighborhood traffic intrusion measures. See Response to Comment No. IND 1-1 for additional details of this study. This study would address parking and traffic issues in the alley should they arise from the Project.

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Comment Letter No. IND 4
Tieira Ryder
Received February 5, 2021

Comment No. IND 4-1
Culver City and all of the Westside cities should be coordinating better to create more affordable housing for long term, working class residents, students, seniors, those living with disabilities and others! The video attached is not OK, the number of unhoused residents has increased by over 50% in the last 10 years in LA! Response to Comment No. IND 4-1
This comment asserts that Culver City and all of the Westside cities should be coordinating better to create more affordable housing. This comment is noted; however, as this comment does not raise any specific issues with respect to the content or adequacy of the Draft MND, no further response is warranted.

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Comment Letter No. IND 5
David Steinitz C/O F.I.R.E./L.T.D.
12035 W. Jefferson Blvd.

Los Angeles, CA. 90230-6219
Received February 9, 2021

Comment No. IND 5-1
I live closer to Barryman on Segrell Way and I do not have any real issues with this new project other that it setting a strong precedence for 5 story structures around my area.

Response to Comment No. IND 5-1
This comment indicates the Project would set a precedence for 5-story structures in the area. As discussed on pages B-59 and B-60 of the Draft MND, the Project’s building height would be consistent with the maximum 56- foot building height as allowed for in the City’s Zoning Code for a Commercial General (CG) zone, based on CCMC Section 17.220, Table 2-6. This comment is noted; however, as this comment does not raise any specific issues with respect to the content or adequacy of the Draft MND, no further response is warranted.

Comment No. IND 5-2
Also having lived in the neighborhood for a long time I do not believe the developer has seriously considered the 24 hour traﬃc noise from the elevated freeway. No one is going to want to sit on a roof deck when the ambient noise level is high and as far up the street as I am,
Response to Comment No. IND 5-2
This comment asserts Project visitors would not want to sit on the roof deck due to traffic noise. This comment does not raise any specific issues with respect to the content or adequacy of the Draft MND. However, it is acknowledged that measured ambient daytime noise levels (7 a.m. to 10 p.m.) at the property line along Slauson Avenue (Location R2) were at an average of 63 dBA. As shown in Table B-13, Noise and Land Use Compatibility Matrix – California, on page B-63 of the Draft MND, noise levels between 50-70 dBA are normally acceptable for business commercial uses, as well as for hotels (50-65 dBA). Thus, the roof deck is expected to be compatible with the ambient noise environment.

Comment No. IND 5-3
I am constantly cleaning up the black soot from the freeway and as close as they will be it will be a constant issue.

Response to Comment No. IND 5-3
This comment asserts cleaning up black soot from the freeway will be an issue for the Project. This comment is noted; however, as this comment does not raise any specific issues with respect to the content or adequacy of the Draft MND, no further response is warranted.
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Comment No. IND 5-4
I am a lighting consultant for the last 42 years with my own company and I have a number of these type of structures I am retained by to do their lighting and energy management designs and having city’s like Bellﬂower and Azusz as clients I see a lot of bad designs but even worse locations and this one only has a fair chance of survival what with all the other new hotels competing for the bed use.

I realize this may take more than another year to break ground and maybe the economic environment will make more sense but this project seems to be asking more than it can justify in ﬁnancial return and I for 1 would not like to see another large space like the Lowes building sitting empty or abandoned.

Just my concerned 2 cents.

As a side note I would love to see the power lines in the double wide alley converted to underground if there is ever a way to do it.

Response to Comment No. IND 5-4
This comment offers opinions on the Project’s long-term economic outlook. Also, the commente r indicates he would like to see the power lines in the double wide alley converted to underground. The power lines are not within the Project Site boundaries and are beyond the scope of the Project. As this comment does not raise any specific issues with respect to the content or adequacy of the Draft MND, no further response is warranted.

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Jefferson Boulevard Project

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–

Responses to Comments

D
-
15 Comment Letter No
. IND 6

Robin Turner

10650 Drakewood Ave.

Culver City, CA 90230

Received February 10, 2021

Comment No. IND

6 -
1 I would like to comment on the
11469 Je
ﬀerson Boulevard Project. The Project has been designed to be 5 stories in height. This clearly violates the Measure 1 Height Initiative maximum limit that was voted on by the voters of Culver City in 1988. There are no variances or conditions that

would allow this or any other building to be built
over the 56 feet limit. An elevator shaG is not allowed above the 56 foot limit. There are no variances allowed for that. 56 feet is 56 feet. Period! By building this Project, the City of Culver City will

be violating the law. In fact,
ANY NEW 5 STORY BUILDING OVER 56 FEET IN CULVER CITY IS IN DIRECT VIOLATION OF THE LAW!!!!!!!!!!

Response to
Comment No. IND

6 -
1 Michael Allen from the City of Culver City responded on February 10th to the above comment as f ollows, “
Thank
you for providing the below comment regarding the 11469 Je ﬀerson Blvd. Project. Based on our analysis, the
buil
ding is compliant with the 56'
height limitation, as well as the allowances for mechanical

equipment and the
elevator sha
ft
.
”

Se
e also Response to Comment No. IND 6
-
1 below.

Comment No. IND

6 -
2 In response to Michael Allen, Ms. Turner responded, “ Thank you for your comments. The 56 foot height limit
does allow for minor mechanical
equipment (roof HVAC equipment) but not for a full

doorway to get on the roof.

It is strictly allowed to have equipment such as a few feet allowance for elevator to hit the top ﬂoor but not for
roof access.
”

Response to Comment No. IND

6 -
2 T
he Culver City municipal code, S
ection 17.300.025.C.2b; allows for elevators, and mechanical penthouses and other mechanical rooms to exceed the building height (56' -
0" in CG Zone) by a maximum of 19'
-
6" (elevators)
and 13’
-
6”(all other mechanical equipment) respectively. Further, the ro
of level of the P
roject is accessible by
maintenance personnel only.

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Comment Letter No. IND 7
Jordan Sisson (on behalf of UNITE HERE Local 11)
801 South Grand Avenue, 11th Floor
Los Angeles, CA. 90017
Received February 11, 2021

Comment No. IND 7-1
On behalf of UNITE HERE Local 11 and its members (collectively “Local 11”), this Office provides the City of Culver City (“City”) the following comments 1 regarding the Initial Study/Mitigated Negative Declaration (“IS/MND”) for the above-referenced five-story, 175-room hotel development ( “Project”) located on a 33,813 square foot (“SF”) site located at the northwest corner of the intersection at Jefferson Boulevard and Slauson Avenue (“Site”).

In short, Local 11 finds that the IS/MND fails to adequately analyze Project impacts related to v ehicle miles traveled (“VMT”), construction noise, and exposure to hazards. As such, Local 11 urges the City to stay any action on any Project approvals until the issues identified below have been addressed in an adequate environmental review pursuant to the California Environmental Quality Act (“CEQA”). 1 Please note that pages cited herein are either to the page’s stated pagination (referenced herein as “p. ##”) or the page’s location in the referenced PDF document (referenced herein as “PDF p. ##”).

Response to Comment No. IND 7-1
This comment provides a brief summary of the Project and introduces comments related to VMT, construction noise, and hazards. Responses to these comments are provided below in Response to Comment Nos. IND 7- 2 to IND 7-6, below.

Comment No. IND 7-2

1. VMT ANALYSIS IS LACKING
Citing the VMT guidance provided by the Governor’s Office of Planning and Research (“OPR”), the IS/MND presumed the Project’s VMTs would be less than significant merely because the Site is near a transit priority area. (MND, p. B-105; IS/MND Traffic Study, pp. iv, 74-75.) However, OPR states explicitly that this “presumption would not apply, however, if project -specific or location- specific information indicates that the project will still generate significant levels of VMT.”
2 Project-specific information that indicates a significant VMT includes the following:
i. The Project would generate 1,463 trips per day compared to the exiting 376 trips per day (IS/MND, p. B- 92)—a net increase of 1,087 trips —which exceeds OPR’s small project screening threshold of 110 trips.3 So too, this increase would exceed the 250- trip screening threshold proposed under the City’s Draft Transportation Study Criteria Guidelines.4
2 OPR (Dec. 2018) Technical Advisory: On Evaluating Transportation Impacts In CEQA, pp. 13-14, https://opr.ca.gov/docs/20190122-743_Technical_Advisory.pdf. 3 Ibid. at p. 12.
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4 See City (May 2020) Draft Transportation Study Criteria and Guidelines, p. 4, https://culver- city.legistar.com/View.ashx?M=F&ID=8331543&GUID=B8DB9B35-E077-40E3-A0C3- AB70306081BF.

Response to Comment No. IND 7-2
The OPR Technical Advisory on Evaluating Transportation Impacts in CEQA (December 2018) provides guidance in the assessment of VMT, thresholds of significance, and mitigation measures. It is stated in both the Technical Advisory and within the CEQA Guidelines that these recommendations are not with the intent of enforcing, but instead to “provide advice and recommendations, which agencies and other entities may use at their discretion.” As the lead agency, the City of Culver City has the legal authority to use rational and reasonable methods in order to determine the scope and methodology of the required CEQA VMT analysis. As such, the VMT analysis was conducted according to the City’s Transportation Study Criteria and Guidelines, which were adopted by the City Council on July 13, 2020 and are the basis upon which all development projects are evaluated. Based on a review of the City’s CEQA VMT guidelines and with the utilization of the City’s VMT Tool, the Project does not require any further VMT analysis and is presumed to have a less -than-significant VMT impact based on its location within one-half mile of the Westfield-Culver City Transit Center.

The comment regarding transit priority area (TPA) guidelines is noted and will be forwarded to the decision- makers for consideration in future CEQA VMT guideline updates.

The 250 daily and 25 peak-hour vehicle trip thresholds for small projects contained in the City’s Transportation Study Criteria and Guidelines do not apply to the Project. For land use projects, the VMT screening thresholds for small projects are separate and distinct from the screening thresholds for projects within a key TPA.

Comment No. IND 7-3
ii. The IS/MND’s GHG Study shows the Project would generate 3.490 million annual VMTs as compared to the existing 0.636 million annual VMTs (GHG Study, PDF pp. 169, 224), which is more than a fivefold increase and exceeds OPR’s no net increase threshold for redevelopment projects. 5 5 OPR, supra fn. 2, p. 17.

Response to Comment No. IND 7-3
The OPR Technical Advisory on Evaluating Transportation Impacts in CEQA states that, for redevelopment projects that result in a net overall increase in VMT, the recommended screening and significance thresholds should be applied as part of the VMT analysis. The recommended screening thresholds include the presumption of a le ss-than-significant VMT impact for land use projects proposed within one- half mile of an existing major transit stop or an existing stop along a high- quality transit corridor. This screening threshold, as defined in the City of Culver City’s Transportation Study Criteria and Guidelines, was applied for the Project.

The comment about GHG emissions is noted and will be forwarded to the decision-makers for consideration in future CEQA VMT guideline updates.

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Comment No. IND 7-4
iii. No less than nine hotels/lodging are within 1.5 miles of the Project Site,6 suggesting the Site is hotel-rich and that the Project will not provide an alternative for hotel patrons that would otherwise be commuting from longer distances. Adding more hotels in a hotel -rich area wil l not further smart/mixed- use development.
6 Google Maps, https://www.google.com/maps/place/Mayumi/@33.9823269,- 118.4133479,14z/data=!4m17!1m8!2m7!1sHotels!3m5!1sHotels!2s33.9896,+-118.3973!4m2!1d 118.3973395!2d33.9895605!3m7!1s0x80c2ba021914d27f:0x2906349d35168b00!5m2!4m1!1i2!8m 2!3d33. 994924!4d-118.3942348.

Response to Comment No. IND 7-4
The Project complements the wide array of development that is occurring within the City, especially in Downtown and surrounding the Metro Ivy Station, along with areas to the south that include Playa Vista and Silicon Beach.

The site is centrally located to serve a multitude of nearby businesses that rely on the use of hotel accommodations. The boutique nature of the hotel and its location will likely position itself to generate more locally-serving trips. Additionally, considering VMT from a broader scale, it should be noted that the Project may shorten vehicle trips and reduce VMT by diverting trips from other established hotels . The Project will also be the only hotel use within one-quarter mile of the Westfield-Culver City Transit Center, making the site particularly attractive for employees and patrons to use alternative travel modes.

Comment No. IND 7-5
iv. The existing uses are local serving retail (e.g., restaurants, nails salon, dentist, golf, flowers, etc.) (IS/MND Remedial Action Plan [“RAP”], PDF p. 52 [Fig. 2]), which provide convenient access to nearby residents that do not need to use a vehicle to access these services. In contrast, the Project is a hotel development, which is regional in nature and displaces these local services. Hence, the Project may induce further VMTs by individuals no longer able to access these local services without entering their vehicles.

Response to Comment No. IND 7-5
The Project will include restaurant, lounge, and conference/meeting room uses that will be available to nearby residents. At the request of residents of the Sunkist Park neighborhood, a discount program will also be provided at the hotel restaurant for local neighbors. Therefore, the Project will maintain a level of local-serving commercial use.

Comment No. IND 7-6
v. The City acknowledges that hotels generate large amounts of visitors that may access the site via Uber/Lyft,
7 but the IS/MND fails to discuss how the Project would handle these ridesharing services.

Based on the above, the less than significant VMT impact presumption does not apply, and an actual VMT analysis is warranted here. The CEQA compliance must be re-done. 7 City, supra fn. 4, p. 7.
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Response to Comment No. IND 7-6
Per the City of Culver City’s Transportation Study Criteria and Guidelines, for land uses like hotels and theaters expected to generate large amounts of visitors, a project must provide on- site facilities with capacity to accommodate taxis and Transportation Network Companies (TNCs) like Lyft and Uber. The October 19, 2020 Traffic Impact Study for the Project provides a description of these on-site facilities, which include one of the two entry drive aisles from Slauson Avenue (the one closer to the hotel) dedicated for passenger drop-off and pick- up. With the dual entry lane c onfiguration, valet-assist parking, and the option to utilize the first subterranean parking level for drop- offs and pick -ups during high- demand periods (e.g., due to an event in the Project ’s meeting/conference room space), the on- site facilities will have the capacity to handle taxi and TNC demands without spillover onto Slauson Avenue.

As described in aggregate via Responses to Comments Nos. IND 7- 2 through IND 7- 6, the Project’s VMT analysis is sufficient, the Project’s VMT impact will be less -than-significant, and no further VMT analysis is warranted.

Comment No. IND 7-7

2. CONSTRUCTION NOISE/VIBRATION ANALYSIS IS INCOMPLETE
The IS/MND finds no construction noise impacts based on a time/place threshold. (IS/MND, pp. B -63, B-66.) However, this ignores that construction noise levels will reach up to 70 dBA compared to the 62 and 63 dBA (daytime Leq) ambient levels at sensitive receptors R1 and R2 (i.e., residences 50 feet from the site), respectively. (IS/MND, Tbls. B -14 & B-16.) This amounts to a seven to eight dBA -increase that would exceed the 5-dBA Leq threshold applied to the Project’s operational phase. (IS/MND, p. B-63.) Given construction is to last over 30- months (IS/MND, p. A -21), it is arbitrary to claim these noise levels are not significant t o those residents over such a long period.

Furthermore, these construction noise levels are likely underestimated for various reasons. First, the IS/MND’s Noise Study cites inconsistent construction equipment noise levels. (IS/MND Noise Study, PDF pp. 37, 234).

Second, the IS/MND does not discuss whether pile driving will be used, which can create noise levels up to 101 dBA at 50 feet and present a unique potential for vibration impacts. (Id.) Third, the IS/MND assumed a 10 -dBA reduction for “noise reduction features” like sound barriers “if construction noise is impacting nearby noise sensitive land uses,” as well as noise “abatement and acoustical design criteria” for new development. (IS/MND pp. B-67– B-68.) However, what are those specific features, what constitutes sufficient impact to warrant sound barriers, what criteria are going to be required? These unspecified mitigation measures also are not included in the proposed Mitigation Monitoring Reporting Program (“MMRP”). (IS/MND, Attachment C.) As such, these measures are illusory mitigation measures lacking performance standards that violate CEQA. 8 8 See e.g., Federation of Hillside & Canyon Ass’ns v. City of Los Angeles (2000) 83 Cal.App.th 1252, 1260; Sierra Club v. County of Fresno (2018) 6 Cal.5th 502, 522; Cleveland Nat’l Forest Found v. San Diego Ass’n of Gov’ts (2017) 17 Cal.App.5th 413, 433.

Response to Comment No. IND 7-7
The Project noise analysis provided in the Draft MND is not arbitrary as it provides a reasoned analysis based on applicable specific requirements in the City’s Noise Ordinance and Noise Element of the General Plan. As discussed on page B-62 of the Draft MND, Chapter 9.07 of the CCMC provides specific noise restrictions and exemptions for noise sources within the City, and states that construction activity shall be prohibited, except 11469 Jefferson Boulevard Project
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between the hours of 8:00 a.m. to 8:00 p.m., Monday through Friday, 9:00 a.m. to 7:00 p.m. on Saturdays, and 10:00 a.m. to 7:00 p.m. on Sundays per Culver City Municipal Code Section 9.07.035. Construction of the project would comply with these requirements to avoid the generation of excessive noise during nighttime hours. As discussed on page B-66 and as shown in Table B -16 of the Draft MND, the Project’s construction noise levels during the hours allowed by Chapter 9.07 of the CCMC were estimated to reach a maximum of 70 dBA L eq at the nearest off-site sensitive receptor location with a temporary sound barrier installation pursuant to Policy 2.A.

As shown in the Noise and Vibration Technical Report (November 2020), which was prepared to inform the findings in the Draft MND and was provided by the City alongside the Draft MND, a noise level of 70 dBA is less than other commonly experienced noise levels in urban environments, such as the Project Site, including idling city buses and lawn mowers (see Figure B -5 on page 207 of Appendix D of the Noise and Vibration Technical Report). While the noise and land use compatibility matrix as shown in Table 7 of the Noise and Vibration Technical Report is applicable to operational noise and not temporary or periodic construction noise, a noise level of up to 70 dBA is also within the conditionally acceptable category. Thus, the Project’s temporary and periodic construction noise level would not generate substantial noise uncharacteristic of an urban environment.

In addition, as discussed on page B-62 of the Draft MND, the City’s General Plan Noise Element includes Policy

2.A, which pertains to the use of temporary sound barrier installation at a construction site i f construction noise is impacting nearby noise sensitive land uses. As discussed on page B -64 and as shown in Figure B -1 in the Draft MND, existing one- and two-story single-family residences are located across the service alley to the north and west of the Project Site. As stated on page B-66 of the Draft MND, Project construction would occur within the allowable hours specified in CCMC 9.07. In addition, as stated on page B -67 of the Draft MND, given the proximity of noise- sensitive residential uses as fully described in the Draft MND, consistent with the City’s General Plan Noise Element Policy 2.A, the Project would include temporary sound barrier installation at the construction site and the analysis correctly accounts for this. The Applicant has had several community meetings to discuss the Project as required by the City and, as part of the community outreach, the Applicant has agreed to include a construction noise barrier to reduce the noise levels at the residences located northwest of the Project Site. The temporary sound barrier has been included as a project design feature (PDF) in this Final MND.

Refer to Attachment B , Explanation of Checklist Determinations , and Attachment C, Mitigation Monitoring Program, of the Final MND. Therefore, it is not an illusory measure and it will be enforceable. Therefore, based on compliance with the applicable provision of the City’s Noise Ordinance and Noise Element of the General Plan, and given the added clarification that the Project’s noise levels would not exceed other noise levels already experienced in urban environments, such as the Project Site, the Draft MND concludes that temporary construction noise impacts would be less than significant as supported by substantial evidence as clarified herein.

The comment inappropriately references the 5 dBA greater than ambient threshold in relation to evaluating construction noise impacts. Page B-63 of the Draft MND states that the 5 dBA over ambient threshold applies to Project-related operational noise and does not apply to construction. Furthermore, while construction of the Project would last up to approximately 30 months, it is clear that the maximum construction noise levels at the noise sensitive receptor areas (i.e., 70 dBA L
eq at R1 and R2 and 63 dBA Leq at R3) would not occur during the entire construction duration. As shown in Table B-16 on page B-67 of the Draft MND, and in Table 9 on page 28 of the Noise and Vibration Technical Report, these maximum noise levels would be as sociated with the last phase of construction activity when overlapping building construction, paving, and architectural coating would occur. Furthermore, as stated on those same pages, construction noise levels represent the worst-case condition when noise generators are located closest to the receptors. During other phases of construction and when equipment would be located elsewhere on the Project Site further away from the sensitive receptor locations, noise levels would be substantially lower (i.e., reduced by a minimum of 6 dBA per doubling of distance away).

Therefore, construction noise impacts are appropriately characterized as temporary based on substantial evidence provided in the Draft MND and Noise and Vibration Technical Report. 11469 Jefferson Boulevard Project
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The comment is also incorrect regarding the alleged inconsistency of the construction equipment noise levels and potentially underestimated noise levels. The construction equipment noise levels provided in Table 8 on page 27 of the Noise and Vibration Technical Report (e .g., page 37 when numbered based on the portable document format [PDF] file; the reference to page 234 is unclear as it does not pertain to any relevant information in this comment but is assumed to be referencing the Federal Transit Administration Transit Noise and Vibration Impact Manual]) cited in the Noise Technical Report are not inconsistent with information provided in the analysis.

The construction equipment noise levels presented in Table 8 contains a footnote clearly stating FHWA’s Roadway Construction Noise Manual as the source of the referenced noise levels. The noise level information that the commenter appears to be referencing are from a different and wholly separate source altogether (i.e., the Federal Transit Administration Transit Noise and Vibration Impact Manual ), which are not used for the construction noise analysis. The Federal Transit Administration Transit Noise and Vibration Impact Manual is used for vibration analysis since the FHWA’s Roadway Construction Noise Manual and the Roadway Construction Noise Model do not evaluate vibration. Therefore, the noise levels are not inconsistent as the source of the data are clearly provided in Table 8.

As stated on page B -66 of the Draft MND and on page 26 of the Noise and Vibration Technical Report, pile driving would not be used for Project construction. Therefore, the noise and vibration levels described by the commenter would not occur and construction noise and vibration impacts were adequately addressed.

The 10-dBA reduction from an install ed noise barrier and implementation of noise abatement and acoustical design criteria are required under the Culver City General Plan Noise Element Policy 2.A and are not mitigation measures. Therefore, they are rightly excluded from the MMRP and are not subject to the performance standards as defined under CEQA. As stated above, the measure would be enforceable as a condition of approval.

Comment No. IND 7-8

3. HAZARDS ANALYSIS MUST BE UPDATED
The Site was formerly used as a gasoline/service station, currently contains constituents of concern, and is not fully remediated. (IS/MND, p. B -20, B -46; IS/MND RAP, pp. 2.1 -2.11.) The IS/MND proposes a future Soil Management and Remediation Plan (“SMRP”) to be prepared premised on a 2014 RAP that was prepared when no project was anticipated (IS/MND, pp. B-48, C-11) and where remedial activities were limited due to existing retail tenants at the site (IS/MND RAP, pp. 5.2 – 5.11.) Much has changed since then, including the now proposed removal of existing tenants – as well as the consideration of new guidance on vapor intrusion by the Water Board and its sister agency Department of Toxics Substance Control (“DTSC”). 9 For these reasons, the City should
have a revised RAP and detailed SMRP analyzed in a compliant CEQA document in hand before considering approval of the Project.
9 See Water Board (2020) Vapor Intrusion, https://www.waterboards.ca.gov/water_issues/programs/ site_cleanup_program/vapor_intrusion/; DTSC (2020) Vapor Intrusion, https://dtsc.ca.gov/vapor -intrusion/; CalEPA/Water Board/DTSC (Feb. 2020) Supplemental Guidance: Screening and Evaluating Vapor Intrusion, https://dtsc.ca.gov/wp-content/uploads/sites/31/2020/02/Public-Draft-Supplemental-VI-Guidance_2020- 02-

14.pdf.

Response to Comment No. IND 7-8
The comment is correct that the RAP cited in the Draft MND did not contemplate development of the Project currently being proposed. However, the analysis on pages B-48 to B-50 of the Draft MND is clear that under the Project, site remediation overseen by the LARQCB would occur following the abatement and demolition of existing on site improvements. This would include the excavation of hydrocarbon -impacted soils, and other 11469 Jefferson Boulevard Project
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D-22

groundwater management associated with remediation. During remediation activities, the site would be remediated to levels deemed acceptable by the LARWQCB for commercial use pursuant to all applicable regulatory standards. Based on the extent of contamination identified in the RAP, it is anticipated that approximately 1,000 cu bic yards of hydrocarbon- impacted soil would be exported from the site as part of remediation activities, which is less than 2% of the anticipated excavation. The Draft MND’s Mitigation Measure MM-HAZ-1 requires the Applicant to retain a qualified environmental consultant to prepare a Soil Management and Remediation Plan (SMRP) for review and approval by the Culver City Building Safety Division, DTSC and LARWQCB, as necessary, prior to the commencement of excavation and grading activities. Mitigation Measure MM-HAZ-1 has been modified to clarify that the SMRP would include a plan for (i) removal, characterization, and offsite disposal, and/or (ii) remediation of hydrocarbon impacted soils to a level determined by the LARWQCB to be acceptable for commercial use, in compliance with all applicable rules and regulations. The SMRP shall also include a plan for treatment and/or remediation of hydrocarbon impacted groundwater to a level determined acceptable for commercial use, in compliance with all applicable rules and regulations. including all applicable guidance on vapor intrusion from the LARWQCB and/or DTSC. The SMRP will be conducted under supervision of a certified environmental consultant licensed to oversee such remediation. This mitigation measure can reasonably be expected to avoid or reduce a potential significant impact from underlying hazardous materials and is enforceable by identifying the timing of the SMRP implementation and requirement to obtain a closure letter from the LARWQCB and DTSC (as necessary) that states no further soils testing or remediation is required on the Project Site. Effectively, with the SMRP requiring remediation to comply with all applicable regulatory standards and a closure letter from LARWQB and DTSC (as necessary) being required, these performance criteria would ensure that impacts from remediation of hazardous materials below the site are less than significant. Rather, by requiring remediation of subsurface contamination, this mitigation measure ensures a net benefit to the environment. The requirement for DTSC to review and approve the SMRP and issue a closure letter, in addition to the LARWQCB, has been added to Mitigation Measure HAZ-1 in this Final MND.

Comment No. IND 7-9

4. CODE-REQUIRED FINDINGS CANNOT BE MADE
The IS/MND specifies that only construction- related permits from the City, such as demolition, haul route, and building permits at issue. (IS/MND, pp. EC -2, A-22, B-60.) However, the Project’s case numbers (i.e., P2019- 0194-SPR, P2019-0194-CUP, P2019-0194-AUP) suggest that the Project requires City approval of Site Plan Review, Conditional Use Permit, and/or Administrative Use Permit. (IS/MND, pp. EC-1, C-1.) These types of discretionary approvals are subject to specific findings required under the Culver City Municipal Code (“CCMC” or “Code”). (CCMC §§ 17.530.020, 17.540.020.) The environmental and CEQA impacts and deficiencies discussed herein invalidate any public health/welfare findings (id.) — these impacts and deficiencies must be resolved if the City intends to make Code- required findings supported by substantial evidence.

Response to Comment No. IND 7-9
This comment asserts that approvals such as approval of Site Plan Review, Conditional Use Permit, and/or Administrative Use Permit were not addressed in the MND and that the environmental and CEQA impacts and deficiencies discussed herein invalidate any public health/welfare findings (id.). Page EC-2 has been corrected in this Final MND to list the potential for Site Plan Review, Conditional Use Permit, and/or Administrative Use Permit. Section XI, Land Use and Planning, in the Draft MND analyzed land use and planning impacts. On page B-60 of the Draft MND, it is stat ed that “other land use related approvals, programs, and/or or permits as 11469 Jefferson Boulevard Project
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part of the Project may include, but are not limited to, the following: demolition permits; grading, excavation, foundation, and building permits; and haul route permits.” The addition of other permits or actions such as Site Plan Review, Conditional Use Perm it, and/or Administrative Use Permit does not change the conclusion that, “None of these would conflict with an applicable land use plan (i.e., General Plan), policy or regulation of an agency with jurisdiction over the Project adopted for the purpose of avoiding or mitigating an environmental effect.” The Project’s physical and operational characteristics were fully evaluated in the Draft MND, to which the MND fully discloses the Project’s potential for physical impacts on the environment. Thus, t hese actions or permits do not substantively or materially change the impact analyses or conclusions in the MND. Furthermore, based on Response to Comment Nos . IND 7-2 to IND 7 -10, no substantive deficiencies have been identified herein that would invalidate any public health/welfare findings.

Comment No. IND 7-10
In closing, Local 11 urges the City to stay all action on the Project until the issues discussed herein are resolved in a recirculated MND or Environmental Impact Report, as required under CEQA. On behalf of Local 11, this Office requests, to the extent not already on the notice list, all notices of CEQA actions and any approvals, determinations, or public hearings to be held on the Project under state or local law requiring local agencies to mail such notices to any person who has filed a written request for them. (Pub. Res. Code §§ 21092.2, 21167(f) and Gov. Code § 65092 and CCMC § 17.630.010.A.d.) Please send notice by electronic and regular mail to:

Jordan R. Sisson, Esq., 801 S. Grand Avenue, 11th Fl., Los Angeles, CA 90017, [email protected].

Thank you for your consideration of these comments. We ask that this letter and any attachments are placed in the administrative record for the Project.

Response to Comment No. IND 7-11
Responses to all comments have been addressed in Response to Comment Nos. IND 7-1 to IND 7-10. Based on the responses therein, the Draft MND environmental analysis was sufficient to meet CEQA requirements and no substantive deficiencies were identified that require a recirculated MND or preparation of an Environmental Impact Report. The City will provide notices as required and applicable per the referenced regulatory requirements.

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D-24

Comment Letter No. IND 8
Arthur L. Kassan, P.E.

Registered Traffic Engineer No. 152
5105 Cimarron Lane
Culver City, CA 90230
Received February 17, 2021

Comment No. IND 8-1
Thank you for the opportunity to review the Traffic Impact Study For The Jeff Hotel Project Proposed At 11469 Jefferson Boulevard, Culver City prepared by Cr ain & Associates in October 2020. The study is part of the Mitigated Negative Declaration for the proposed project.

To introduce myself to you, I am a Registered Traffic Engineer in California with over 50 years of experience.

For many years, I performed the functions of the Culver City Traffic Engineer as a consultant to the City. I have been a resident of Culver City for 33 years.

I have comments on three issues addressed in the Crain report: 1) adequacy of the proposed on -site parking supply; 2) operation of the dual left-turn lane proposed for northbound Jefferson Boulevard at Slauson Avenue; and 3) truck maneuvering from and to the alley west of the hotel.

Response to Comment No. IND 8-1
This comment introduces the commenter and issues raised below. Re sponses to the referenced issues are provided below in Response to Comment Nos. IND 8-2 to IND 8-13.

Comment No. IND 8-2
On-Site Parking Supply
The following comments are based on information in Appendix E, Project Demand Parking Analysis, which consists of a letter dated April 3, 2020, to Michael Allen from Crain & Associates, plus the accompanying calculations upon which the letter text is based. The analysis in the Crain letter uses empirical data from three existing hotels in Culver City, near the s ubject site, to calculate estimates of the maximum potential parking demand for the Jeff Hotel.

For comparison, the letter also presents parking demand calculations based on the parking rates in the Culver City Municipal Code and in Urban Land Institute publications dealing with parking demands. There is great variance among the estimated parking demands using the rates from the three sources. After applying shared parking analysis methods, the estimates of maximum parking demands presented by Crain are:
138 spaces based on the rates derived from the local hotels; 299 spaces based on the Culver City Municipal Code rates; and 401 spaces based on the Urban Land Institute rates.

The derived-rate estimate is less than half the estimates using either of the other two sources. 11469 Jefferson Boulevard Project
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D-25

Response to Comment No. IND 8-2
This comment provides summary information from the April 3, 2020 Parking Demand Analysis prepared for the Project and included as Appendix E to the October 19, 2020 Traffic Impact Study. Therefore, no further response is warranted.

Comment No. IND 8-3
For the three local hotels studied by Crain, actual parking counts were conducted during the summer months of the years, 2018 and 2019. From those counts, peak parking usage rates (number of parked vehicles per guest room) were derived for each hotel, and the highest of the three rates was applied to the proposed number of guest rooms for the Jeff Hotel. The letter provides no information on the room occupancy rates at the study hotels during the parking counts . Were they at or near 100%? In addition to varying from month- to-month, as acknowledged in the letter, hotel occupancy rates vary from year -to-year based on numerous factors, such as the local economy and schedules of events in the area served. Were 2018 and 2019 high room-occupancy years for the hotels? If the study hotels operated at substantially below full occupancy during those years, the derived rates should be adjusted upward for that.

Response to Comment No. IND 8-3
Hotel room occupancy data were available for only one of the three local hotels surveyed as part of the hotel empirical parking utilization study -- the DoubleTree by Hilton Hotel at 6161 Centinela Avenue (the “DoubleTree”). However, the peak hourly parking demand ratio applied for the Project was conservatively determined based only on the DoubleTree parking demand data, given that it was shown to have the highest parking demands on a per room basis of the three surveyed hotels. Occupancy data provided for 2018 by DoubleTree staff show ed that June and July room occupancies were approximately 95.3 and 93.8 percent, respectively, while the hotel’s annual average occupancy was approximately 89.2 percent. The DoubleTree experienced its highest occupancy rate for the 2018 calendar year duri ng the month of June. Based on hospitality sector data provided by STR, hotels in Los Angeles County experienced an occupancy rate of approximately 79.7 percent during the first half of 2018, while those in the LAX/Inglewood/Culver City submarket were observed to be approximately 86.4 percent occupied. Compared with these average occupancy rates for local hotels, the occupancy rates experienced by the DoubleTree are considerably higher during June and July conditions. As such, the data collected represent well peak occupancy conditions and, therefore, are conservative and appropriate for use in determining the Project’s peak parking demands.

Comment No. IND 8-4
Do any of the three study hotels have a rooftop bar/lounge or similar facility comparable to that proposed for the Jeff Hotel? Such an amenity will attract non- guests to the hotel to meet guests or to enjoy the view. That will result in additional parking demand. If the hotel upon which the derived parking rate is based does not have a comparable amenity, the derived rate is too low to be applied to the Jeff Hotel analysis.

Response to Comment No. IND 8-4
As described in Response to Comment No. IND 8-3, the peak hourly parking demand ratio applied for the Project was based on data from only the DoubleTree location, given that it experienced the highest parking demands of the three surveyed hotels. The DoubleTree provides an on- site restaurant, bar/lounge, and outdoor pool area, which makes it substantially similar to the Project. In addition, the DoubleTree location provides approximately 15,969 square feet of meeting/conference space, which equates to approximately 42.6 square feet of 11469 Jefferson Boulevard Project
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D-26

meeting/conference space per guest room. The Project, with approximately 4,800 square feet of meeting/conference s pace and 175 guest rooms, will average approximately 27.4 square feet of meeting/conference space per guest room. Thus, when accounting for the added parking demands of meeting/conference space, the use of the DoubleTree parking data is conservative and appropriate for estimating the Project’s peak parking demands.

Comment No. IND 8-5
The parking facility that is proposed for the Jeff Hotel will consist of two subterranean levels beneath the building.

Once that facility is built, there will be no opportunity to expand it on or near the hotel site. Therefore, the original supply must be adequate to serve maximum hotel parking demands, or the unsatisfied overflow parking demand will have to be accommodated elsewhere, such as in the adjacent residential neighborhood or in the adjacent shopping center.

The above concerns result in significant statistical uncertainty that should lead to the prudent conclusion that a “safety factor” must be applied to the estimate of an adequate parking supply. Safety factors are commonly used in engineering analysis and design when there is the possibility that there could be unaccounted for variance in the data upon which the estimate is based and when the estimate is to be used to design a permanent structure that cannot be expanded. In this case, it would be reasonable to add a 15% safety factor, or 21 spaces, to the predicted maximum demand of 138 spaces, for a statistically safe total of 159 spaces.

Response to Comment No. IND 8-5
As described in Responses to Comment Nos. IND 8-3 and IND 8-4, the peak hourly parking demand ratio applied for the Project was determined conservatively. Instead of averaging peak parking demand ratios for the three surveyed hotel uses, data were only used from the DoubleTree location which experienced the highest parking demands of the surveyed hotels. The DoubleTree provides on- site amenities similar to the Project, along with substantially more expansive meeting/conference space, and therefore is appropriate for establishing the peak parking demands of the Project. In addition, the parking demand analysis does not account for the Project’s proximity to the Westfield-Culver City Transit Center, which is less than one-quarter mile away. As a hotel use closer to high -quality transit than any of the surveyed hotels, the Project’s automobile parking demands are expected to be even lower due to the attractiveness of alternative travel mode options. Accounting for all of these considerations, the predicted maximum automobile parking demand of 138 parking spaces already has a built-in safety factor.

Comment No. IND 8-6
There is nothing in the analysis to indicate whether there will be a fee charged for parking in the hotel facility.

Most hotels in the vicinity of the site, especially those with parking structures instead of surface lots, charge fees for parking, and the fees are usually substantial. That could be a disincentive for people to park at the hotel, especially those patronizing the restaurant or rooftop bar or those attending on- site meetings. They will be tempted to park in the neighborhood or at the adjacent shopping center, because their stays would be costly at the hotel parking structure. There should be an analysis of parking impacts on the nearby developments taking into consideration the effects of hotel parking fees.

Response to Comment No. IND 8-6
The Project will charge guests and patrons for parking in the subterranean parking facility. However, the parking fees for guests will be nominal so as not to incentivize off-site parking. There will also be a validation system for 11469
Jefferson Boulevard Project

April 2021

Attachment D
–

Responses to Comments

D
-
27 customers of the
Project’s commercial components that will reduce parking fees substantially for those patronizing these uses. As such, off
-
site parking impacts are not expected
for the
Project.

Still, as described in
the October 19, 2020 Traffic Impact Study, if the Cit
y determines there is an intrusion

of
Project parking on
nearby re
sidential streets, the
Project shall pay for a parking study to determine if mitigation measures are needed and pay for the cost of implementing those mitigation measures.

Comment No. IN
D 8
-
7 As stated in the Jeff Hotel description, the parking supply will include tandem spaces. However, no number or percentage of such spaces is specified. Will tandem spaces constitute a majority of the total spaces? “Valet -

assisted services”
are propose
d to assist with the tandem spaces. Will the valets be on duty at all times (7 days a week and 24 hours a day)? If not, when valets are not on duty, how many spaces will be effectively out of use, because self
-
parking guests will park in the outer tandem s
paces leaving the inner spaces inaccessible?

Response to Comment No. IND 8
-
7 The Project will provide
a minimum
of
138 automobile parking spaces across two levels of subterranean parking.

The 138 spaces will include 43 standard spaces, 90 tandem spaces, 4 AD A accessible spaces, and 1 ADA van
accessible space. Valets will
be available to assist Project guests and patrons with parking and retrieving their vehicles, 24 hours per day and 7 days per week, in order to ensure safe and efficient use of the tandem pa rking
spaces. Valet staffing will
be
monitored and adjusted, as needed, to ensure that the parking supply will meet anticipated demands. With the vast majority of hotel guests expected to book their rooms in advance and restaurant patrons allowed to make

reservations, the Project will be able to determine approximate traffic and parking demands in advance and adjust the number of valet staff accordingly.

Comment No. IND 8
-
8 The provision of valet
-
assisted services is an “operational measure”, not a stru ctural measure. An operational
measure is one that can be changed or discarded at any time by the operators of the hotel. The integrity of an operational measure depends on strict and frequent monitoring by the City. Does the City have the necessary person
nel to monitor hotel operations at various times throughout the week, such as between 10 p.m. and 6 a.m. on several days per week and on Saturdays and Sundays throughout the year? If strict and frequent monitoring cannot be
achieved by

the City, the relian
ce on the valet services is invalid.

Response to Comment No. IND 8
-
8 The

Project has no intent of changing or discarding the planned valet -
assist operation, as it is critical to the
hotel’s successful business. Therefore, as long as the hotel is operating , so will
its
24 -
hour valet services.

Further, the City h
as determined that the
Project
’s

parking demand analysis is adequa
te and, therefore, the
Project should not require ongoing monitoring as a condition of development .

Comment No. IND 8
-
9 The hotel wi
ll have a large labor force. Will employees be allowed to park on -
site at no cost? If not, where will
hotel employees park
–

in the neighborhood or the adjacent shopping center? What were the policies for employee parking at the three study hotels during t
he parking counts? There should be adjustments to the
derived parking rates to account for on
-
site employee parking if employees were not parked on
-
site at the existing
hotels. On
-
site employee parking is another operational measure that could be eliminate d by hotel management
quickly. Does the City have the capability to monitor employee parking frequently? If not, the impacts of potential 11469 Jefferson Boulevard Project
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D-28

off-site employee parking should be included in an analysis of parking impacts on the adjacent neighborhood and shopping center.

Response to Comment No. IND 8-9
The Project will employ approximately 80 full-time and 40 part-time employees. Employees will pay no fees to park on-site, which mirrors the pol icy of the DoubleTree location used to develop the Project’s peak parking demand. Therefore, no adjustment to the derived peak parking demand rate is needed. It should be noted that the Project will implement a TDM Plan designed to, among other things, r educe employee travel by personal automobile. Proposed TDM measures intended to increase the awareness and attractiveness of alternative travel mode options for employees include, but are not limited to, the following:
 A prominent display providing employees with current public transit route maps and schedules, rideshare materials, bicycle route and facility information, and a listing of all other resources available for employees not traveling by personal automobile;
 Preferential carpool/vanpool vehicle parking;
 Short-term and long-term bicycle parking;
 Bicycle tool and repair stand;
 Free on-site shared bicycles;
 Shower and changing room for employees who bike or walk;  Public-accessible parking for shared mobility devices (e.g., bikeshare and scooter share systems);  New and continuing employee orientation on the concept and goals of the TDM Plan;  Commuter carpool matching and bicycle group-ride matching services;  Transit pass discount program;
 On-site TDM coordinator;
 Marketing plan on available alternative mobility options;  Guaranteed ride home for employees who use alternative travel modes to commute; and  Financial incentive program for employees who use alternative travel modes (e.g. monthly subsidy for employees in vanpool program).

With the implementat ion of these TDM measures in place, a reduction in Project employee vehicle trips and automobile parking demand is expected. However, no reduction was assumed in the October 19, 2020 Traffic Impact Study in order to provide a more conservative parking analysis. As such, the Project is not expected to have off-site employee parking impacts. Further, the City has determined that the Project’s parking demand analysis is adequa te and, therefore, the Project should not require ongoing monitoring as a condition of development.

Comment No. IND 8-10
Operation of Dual Left-Turn Lane on Jefferson Boulevard 11469 Jefferson Boulevard Project
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In the plan shown in Appendix F of the Crain report, the vehicles using the two proposed northbound left -turn lanes will turn onto two lanes of westbound Slaus on Avenue. Those intersection exit lanes are proposed to be 11 feet and 12 feet wide, for a total of 23 feet from the curb to the center island of Slauson Avenue.

Response to Comment No. IND 8-10
This comment provides a brief description of the conceptual design changes proposed at the intersection of Jefferson Boulevard & Slauson Avenue to accommodate development of the Project, as shown in Appendix F to the October 19, 2020 Traffic Impact Study. Therefore, no further response is warranted.

Comment No. IND 8-11
Years of experience with the operations of dual left -turn lanes has led traffic engineers to recommend that the exit roadway for a dual left-turn movement be a minimum of 26 feet wide, with a more desirable width of 28 feet.

That is based on years of observations at existing dual left-turn lanes that the drivers in the inner lane (i.e., the lane closer to the centerline) tend to drift to their right away from the center island or the opposite direction vehicles during their turns, and the drivers in the outer lane compensate for that by drifting to their right, also.

The extra width in the curbside exit lane provides the outer lane driver with the room to complete the turn efficiently and safely. Without that extra width, outer lane drivers have been observed to hesitate to complete their turns until the adjacent inner lane vehicle has completed the turn ahead of them. That results in reduction of outer lane capacity plus the potential for side-swipe accidents with inner lane vehicles and rear-end accidents between outer lane vehicles. Adequate exit lane width must be provided for the proposed dual left -turn lanes if they are to be effective and safe. The striping plan for Slauson Avenue west of Jefferson must be modified to provide the additional exit lane width.

Response to Comment No. IND 8-11
The comment regarding the conceptual striping plan for the intersection of Jefferson Boulevard & Slauson Avenue (Appendix F to the October 19, 2020 Traffic Impact Study ) and the inadequate widths of the receivi ng lanes for the proposed northeastbound dual left -turn lanes has been noted. There was extensive coordination between City Department of Public Works/Mobility & Traffic Engineering staff and the Project team on the conceptual striping design of this intersection. First, the left receiving lane is approximately 16 feet wide at the start of the painted median island, meaning the total receiving width is approximately 28 feet at the intersection.

Avoidance of the island by drivers in the centerline-adjacent left-turn lane is not expected. It should be mentioned that the dual left-turn lanes will serve a residential area to the west of the Project Site on a Local Street with no transit service. Therefore, larger commercial and transit vehicles are not expected to utilize these lanes in high numbers. Further, since the plan is only conceptual at this time, modifications to the plan may occur prior to the final striping design. The Slauson Avenue eastbound left -turn lane width could be reduced from 11 feet to 10 feet and/or the eastbound through lane width could be reduced from 12 feet to 11 feet to provide another 1- 2 feet of width for the westbound receiving lanes. This would increase the westbound receiving width to 29- 30 feet at the intersection. Another consideration for providing more westbound receiving lane width would involve replacing the painted median island in front of the Project Site with a center median with Qwick Kurb and object markers on flexible barrier posts (paddles). This modification would reallocate the 5 feet of painted median island width, apportioning 2 feet for the center median with Qwick Kurb and paddles and 3 feet for the westbound receiving lanes. This would widen the two westbound receiving lanes to 26 feet past the Project driveway. Such plan modifications will be considered as the plan progresses from conceptual- to construction-level. 11469 Jefferson Boulevard Project
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Comment No. IND 8-12
As part of the dual left -turn plan, Crain recommends the elimination of all vehicle stopping (via red curb) along the north side of Slauson Avenue between the alley west of the project site and Culver Park Drive, a distance of one and one-half blocks, to provide the two proposed exit lanes. Seven existing curbside parking spaces would be eliminated in the adjacent residential neighborhood, and there is photographic evidence that those spaces were being used, until they were temporarily blocked by a construction project. There is no analysis of the impacts of that loss of curbside parking, nor are any measures to mitigate the loss of neighborhood parking proposed in the report. That will be a significant issue in the event of any overflow parking from the hotel, such as employees who may not be permitted to park within the hotel facility, hotel facility patrons who choose to park off-site, or hotel patron vehicles that are moved to street parking by the valets when the on-site facility is full.

Response to Comment No. IND 8-12
As outlined in Responses to Comments Nos. IND 8-3 through IND 8-9, the Project’s automobile parking supply is expected to accommodate the peak demands of all users. Overflow parking is not expected from the hotel.

Employees will be permitted to park within the subterranean parking facility. Hotel guests and patrons are unlikely to park off -site as p arking fees will be nominal and there will be a validation system for users of the hotel’s commercial components. Valet attendants will not move automobiles from the parking facility to neighboring roadways.

While there will be a loss of curbside parking along the north side of Slauson Avenue, west of the site-adjacent alley, the loss was determined in conjunction with City staff to be necessary in order for the intersection of Jefferson Boulevard & Slauson Avenue to operate safely and efficiently. Although an on-street parking analysis was not conducted, the Project has recognized the Sunkist Park neighborhood’s concerns about parking overflow. As described in the October 19, 2020 Traffic Impact Study, if the City determines there is an intrusion of Project parking on nearby residential streets, the Project shall pay for a parking study to determine if mitigation measures are needed and pay for the cost of implementing those mitigation measures.

Comment No. IND 8-13
Truck Turning From and To the Alley West of the Hotel Site Appendix G of the Crain report consists of diagrams illustrating the truck turning paths of a large truck:
a) backing into the hotel loading area from the northbound alley, and b) leaving the loading area to the northbound alley. As shown in the diagrams, the two maneuvers will each require the entire width of the alley, with the driver’s side of the truck virtually touching the western edge of the alley.

Response to Comment No. IND 8-13
This comment provides a brief description of the Project loading area truck turn analysis provided in Appendix G of the Project’s October 19, 2020 Traffic Impact Study. As the comment does not raise any specific issues regarding the content or adequacy of the Draft MND, no further response is warranted.

Comment No. IND 8-14
However, there is a large utility pole in the alley across from the northern part of the hotel site that is not shown in the Figure G diagrams. If that pole remains in place, the alley width available for the truck turn is reduced by 11469 Jefferson Boulevard Project
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three to four feet. The trucks could not make either of the maneuvers as illustrated. It is very expensive to move such a large utility pole. Will the hotel developers do so, or will they provide a more feasible truck turning plan? Response to Comment No. IND 8-14
The commenter raises concern that the Project loading area truck turn analysis illustrated truck maneuvers without sufficient consideration of the power poles that line the western edge of the north- south alley. This unnamed north-south alley forms the western boundary of the Project Site and serves as access to the ground floor loading dock and egress from the outer Project drive aisle and subterranean parking garage. There are power poles located on the western side of the north -south alley which were not shown in the Project loading area truck turn analysis included in Appendix G of the October 19, 2020 Traffic Impact Study . To confirm that the power poles will not interfere with truck access/egress to/from the loading dock, the topographic survey was overlaid on the Project Site plan and the existing utility poles were added to the truck turn analysis. Attached at end of this response letter, please find the revised Appendix G exhibit (Figure D-1) showing the truck turns and utility pole locations. As shown, trucks as large as a WB-50 design vehicle will be able to maneuver along the alley in both inbound and outbound directions without conflicting with any of the existing utility poles Comment No. IND 8-15
The three areas that I have addr essed should be of significant concern to the City officials and staff, if the proposed hotel is to have less -than-significant impacts on the bordering streets and the adjacent residential neighborhood. I would be pleased to discuss my comments with you and other members of the City staff. My telephone number is 310-558-0808 and my email address is [email protected].

Response to Comment No. IND 8-15
The three areas references in this comment are addressed above in Response to Comment Nos. IND 8-2 to IND 8-15. The comment also provides contact information and is noted.

C/L ALLEY
UP
DN
UP
DN
P08
1 P08
2 8' - 0"
13' - 0"
5' - 1 3/8"
7' - 6"

C/L ALLEY
UP
DN
UP
DN
UP
P08
1 P08
2 8' - 0"
13' - 0"
5' - 1 3/8"
7' - 6"

APPENDIX G
4/8/
20 21
FN: JeffersonHotelCulverCity\TruckTurn\TruckTurn20210408 NORTH
Fi
gure D-1

PROJECT LOADING AREA TRUCK TURN ANALYSIS
(WB-50 DESIGN VEHICLE)

INBOUND

OUTBOUND
WB-50

EXISTING

UTILITY

POLE LOCATION
LEGEND
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Comment Letter No. IND 9
Brian Flynn (on behalf of the Supporters Alliance for Environmental Responsibility (“SAFER”) Lozeau Drury, LLP
1939 Harrison Street, Suite 150
Oakland, CA 94612
Received February 19, 2021

Comment No. IND 9-1
I am writing on behalf of the Supporters Alliance for Environmental Responsibility (“SAFER”) regarding the Mitigated Negative Declaration (“MND”) prepared for the 11469 Jefferson Boulevard Project (“Project”) (P2019- 0194-SPR; P2019 -0194-CUP; P2019- 0194- AUP) in the City of Culver City (“City”). SAFER is a California nonprofit public benefit corporation whose purposes include contributing to the pres ervation and enhancement of the environment and advocating for programs, policies, and development projects that promote not only good jobs but also a healthy natural environment and working environment.

After reviewing the MND, it is clear that there is a “fair argument” that the Project may have unmitigated adverse environmental impacts. The written expert comments of Francis Offermann, Certified Industrial Hygienist, and SWAPE (attached hereto as Exhibit A and Exhibit B, respectively), as well as the com ments below, identify substantial evidence of a fair argument that the Project may have significant environmental impacts. Accordingly, an environmental impact report (“EIR”) is required to analyze these impacts and to propose all feasible mitigation measures to reduce those impacts. We urge the City to refrain from approving the MND, and instead to prepare an EIR for the Project prior to any Project approvals as required by CEQA.

Response to Comment No. IND 9-1
This comment introduces the commenter and provides background information on SAFER. The comment introduces the comments below and asserts that the Project may have unmitigated adverse environmental impacts which requires preparation of an EIR. Responses to specific comments on the Draft MND are provided below in Response to Comments Nos IND 9-4 to IND 9-32. As this comment does not raise any specific issues with respect to the content or adequacy of the Draft MND, no further response is warranted.

Comment No. IND 9-2
I. PROJECT BACKGROUND
The Project would redevelop a 33,813 square foot (sf) (0.78 -acre) property located in the northwest corner of the intersection at Jefferson Boulevard and Slauson Avenue. The existing single- story commercial (retail/restaurant) building and associated asphalt -paved surface parking lot would be removed as part of the Project.

The Project Site is currently improved with an approximately 13,000 sf main single- story, wood- framed commercial shopping center which includes both retail and restaurant uses. The remai nder of the site consists of an asphalt-paved surface parking lot and ornamental landscaped areas. Ingress/egress to the Project Site is available via a driveway from Jefferson Boulevard and a driveway from Slauson Avenue.

The Project includes the developm ent of a new, five -story, 175- room boutique hotel building with food and beverage amenities and a two level, below-grade parking garage. A pool and roof top bar would be located on the fifth floor. The 111,000 sf building would be up to 56 feet in height ( with the elevator shaft reaching 69 feet 11469 Jefferson Boulevard Project
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and 6 inches in height) and surrounded by landscaped areas located on site and within the public right of way.

Parking for the proposed uses would be provided on site within a subterranean parking structure that would accommodate a minimum of 138 parking spaces.

The Project Site is located at the south- end of the commercial corridor that runs along Jefferson Boulevard perpendicular to Interstate 405 (I-405) freeway within the Fox Hills area of Culver City. Downtown Los Angeles is approximately eight (8) miles east of the Project Site.

The Project Site is bounded by the intersection at Jefferson Boulevard and Slauson Avenue with commercial uses directly north of the Project Site and a public alley adjacent to the western Project boundary with residential uses just beyond the alley. Commercial uses are also located east and south of the Project Site across Jefferson Boulevard and Slauson Avenue. Both the I-405 and State Route 90 (SR-90) freeways are located less than 400 feet west and south of the Project Site.

Response to Comment No. IND 9-2
This comment provides an overview of the Project and its location. As this comment does not raise any specific issues with respect to the content or adequacy of the Draft MND, no further response is warranted.

Comment No. IND 9-3
As the California Supreme Court held, “[i]f no EIR has been prepared for a nonexempt project, but substantial evidence in the record supports a fair argument that the project may result in significant adverse impacts, the proper remedy is to order preparation of an EIR.” ( Communities for a Better Env’t v. South Coast Air Quality Mgmt. Dist. (2010) 48 Cal.4th 310, 319-320 (CBE v. SCAQMD) [citing No Oil, Inc. v. City of Los Angeles (1974) 13 Cal.3d 68, 75, 88; Brentwood Assn. for No Drilling, Inc. v. City of Los Angeles (1982) 134 Cal.App.3d 491, 504–505.].) “Significant environmental effect” is defined very broadly as “a substantial or potentially substantial adverse change in the environment.” (Pub. Res. Code [“PRC”] § 21068; see also 14 CCR § 15382.) An effect on the environment need not be “momentous” to meet the CEQA test for significance; it is enough that the impacts are “not trivial.” (No Oil, Inc., supra, 13 Cal.3d at 83.) “The ‘foremost principle’ in interpreting CEQA is that the Legislature intended the act to be read so as to afford the fullest possible protection to the environment within the reasonable scope of the statutory language.” ( Communities for a Better Env’t v. Cal. Res. Agency (2002) 103 Cal.App.4th 98, 109 (CBE v. CRA).)
The EIR is the very heart of CEQA. ( Bakersfield Citizens for Local Control v. City of Bakersfield (2004) 124 Cal.App.4th 1184, 1214 (Bakersfield Citizens); Pocket Protectors v. City of Sacramento (2004) 124 Cal.App.4th 903, 927.) The EIR is an “environmental ‘alarm bell’ whose purpose is to alert the public and its responsible officials to environmental changes before they have reached the ecological points of no return.” ( Bakersfield Citizens, supra, 124 Cal.App.4th at 1220.) The EIR also functions as a “document of accountability,” intended to “demonstrate to an apprehensive citizenry that the agency has, in fact, analyzed and considered the ecological implications of its action.” (Laurel Heights Improvements Assn. v. Regents of Univ. of Cal. (1988) 47 Cal.3d 376, 392.) The EIR process “protects not only the environment but also informed self -government.” (Pocket Protectors, supra, 124 Cal.App.4th at 927.)
An EIR is required if “there is substantial evidence, in light of the whole record before the lead agency, that the project may have a significant effect on the environment.” (PRC § 21080(d); see also Pocket Protectors, supra, 124 Cal.App.4th at 927.) In very limited circumstances, an agency may avoid preparing an EIR by issuing a negative declaration, a written statement briefly indicating that a project will have no significant impact thus requiring no EIR (14 Cal. Code Regs. § 15371), only if there is not even a “fair argument” that the project will have a significant environmental effect. (PRC, §§ 21100, 21064.) Since “[t]he adoption of a negative declaration 11469 Jefferson Boulevard Project
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. . . has a terminal effect on the environmental review process,” by allowing the agency “to dispense with the duty [to prepare an EIR],” negative declarations are allowed only in cases where “the proposed project will not affect the environment at all.” ( Citizens of Lake Murray v. San Diego (1989) 129 Cal.App.3d 436, 440.) A mitigated negative declaration is proper only if the project revisions would avoid or mitigate the potentially significant effects identified in the initial study “to a point where clearly no significant effect on the environment would occur, and…there is no substantial evidence in light of the whole record before the public agency that the project, as revised, may have a significant effect on the environment.” (PRC §§ 21064.5 and 21080(c)(2); Mejia v. City of Los Angeles (2005) 130 Cal.App.4th 322, 331.) In that context, “may” means a reasonable possibility of a significant effect on the environment. (PRC §§ 21082.2(a), 21100, 21151(a); Pocket Protectors, supra, 124 Cal.App.4th at 927; League for Protection of Oakland's etc. Historic Res. v. City of Oakland (1997) 52 Cal.App.4th 896, 904– 905.)
Under the “fair argument” standard, an EIR is required if any substantial evidence in the record indicates that a project may have an adverse environmental effect —even if contrary evidence exists to support the agency’s decision. (14 CCR § 15064(f)(1); Pocket Protectors, supra, 124 Cal.App.4th at 931; Stanislaus Audubon Society v. County of Stanislaus (1995) 33 Cal.App.4th 144, 150 -51; Quail Botanical Gardens Found., Inc. v. City of Encinitas (1994) 29 Cal.App.4th 1597, 1602.) The “fair argument” standard creates a “low threshold” favoring environmental review through an EIR rather than through issuance of negative declarations or notices of exemption from CEQA. (Pocket Protectors, supra, 124 Cal.App.4th at 928.) The “fair argument” standard is virtually the opposite of the typical deferential standard accorded to agencies.

As a leading CEQA treatise explains:

This ‘fair argument’ standard is very different from the standard normally followed by public agencies in making administrative determinations. Ordinarily, public agencies weigh the evidence in the record before them and reach a decision based on a preponderance of the evidence. [Citations]. The fair argument standard, by contrast, prevents the lead agency from weighing competing evidence to determine who has a better argument concerning the likelihood or extent of a potential environmental impact. The lead agency’s decision is thus largely legal rather than factual; it does not resolve conflicts in the evidence but determines only whether substantial evidence exists in the record to support the prescribed fair argument. (Kostka & Zishcke, Practice Under CEQA, §6.29, pp. 273-74.) The Courts have explained that “it is a question of law, not fact, whether a fair argument exists, and the courts owe no deference to the lead agency’s determination. Review is de novo, with a preference for resolving doubts in favor of environmental review.” (Pocket Protectors, supra, 124 Cal.App.4th at 928.)
Response to Comment No. IND 9-3
This comment provides background CEQA information, including information relevant to EIRs and the “fair argument” standard. This comment is noted; however, as this comment does not raise any specific issues with respect to the content or adequacy of the Draft MND, no further response is warranted.

Comment No. IND 9-4
III. DISCUSSION
A. Substantial Expert Evidence Establishes a Fair Argument that the Project’s Indoor Air Quality Will Have a Significant Impact on Human Health Due to Formaldehyde Emissions. 11469 Jefferson Boulevard Project
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The MND fails to address the significant health risks posed by the Project from formaldehyde, a toxic air contaminant (“TAC”). Certified Industrial Hygienist, Francis Offermann, PE, CIH, has conducted a review of the Project, the MND, and relevant documents regarding the Project’s indoor air emissions. Mr. Offermann is one of the world’s leading experts on indoor air quality, in particular emissions of formaldehyde, and has published extensively on the topic. As discussed below and set forth in Mr. Offermann’s comments, the Project’s emissions of formaldehyde to air will result in very significant cancer risks to future residents at the Project’s apartments.

Mr. Offermann’s expert opinion and calculation present a “fair argument” that the Project may have significant health risk impacts as a result of the se indoor air pollution emissions, which were not discussed, disclosed, or analyzed in the MND. These impacts must be addressed in n EIR. Mr. Offermann’s comment and curriculum vitae are attached as Exhibit A.

Formaldehyde is a known human carcinogen and l isted by the State as a TAC. SCAQMD has established a significance threshold of health risks for carcinogenic TACs of 10 in a million and a cumulative health risk threshold of 100 in a million. The MND fails to acknowledge the significant indoor air emissi ons that will result from the Project. Specifically, there is no discussion of impacts or health risks, no analysis, and no identification of mitigations for significant emissions of formaldehyde to air from the Project.

Mr. Offermann explains that many co mposite wood products typically used in home and apartment building construction contain formaldehyde-based glues which off -gas formaldehyde over a very long time period. He states, “The primary source of formaldehyde indoors is composite wood products manufactured with urea - formaldehyde resins, such as plywood, medium density fiberboard, and particle board. These materials are commonly used in residential, office, and retail building construction for flooring, cabinetry, baseboards, window shades, interior doors, and window and door trims.” (Ex. A, pp. 2-3.) Mr. Offermann states that future employees of the hotel 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. (Ex. A, p. 4.) This exceeds SCAQMD’s CEQA significance thresholds for airborne cancer risk of 10 per million. (Id.) Mr. Offermann concludes that these significant environmental impacts must be analyzed in an EIR and mitigation measures should be imposed to reduce the risk of formaldehyde exposure. (Ex. A, pp. 5, 10-12.) He prescribes a methodology for estimating the Project’s formaldehyde emissions in order to do a more project-specific health risk assessment. (Id., pp. 5 - 9.). Mr. Offermann also suggests several feasible mitigation measures, such as requiring the use of no-added-formaldehyde composite wood products, which are readily available. (Id., pp. 11-

13.) Mr. Offermann also suggests requiring air ventilation systems which would reduce formaldehyde levels. (Id.) Since the MND does not analyze this impact at all, none of these or other mitigation measures have been considered.

Response to Comment No. IND 9-4
The comment letter and supporting memorandum from Francis Offerman states that the MND fails to address significant health risks by the Project from formaldehyde. Mr. Offerman references his most recent research paper (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) as evidence that there is a “fair argument” for significant health risks resulting from poor indoor air quality by the Project. The research paper collected data from 70 homes about ventilation practices and indoor air quality and measured indoor air concentrations of formaldehyde emitted from composite wood products that might contain formaldehyde-based glues. According to the research paper, the study characterized 70 homes built between 2011 and 2017. In order to be part of the study, buildings also had to meet several other conditions. According to the research paper, to 11469 Jefferson Boulevard Project
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be included in the study, the building had to be a single-family detached structure, located in California, and built in 2011 or later. According to the research paper, the “built in 2011 or later” requirement was used as a proxy for single-family detached homes built to comply with the 2008 version of the California Title 24 standards.

First, Mr. Offerman incorrectly refers to the Project’s “future residents at the Project’s apartments.” The Project analyzed in this Draft MND is hotel development and contains no residential uses. Thus, the comment references an entirely different project unrelated to the Project analyzed in this Draft MND and no further response is required.

However, even when considering the comment, the building conditions in the research paper are highly dissimilar to the Project, as t he Project does not propose single- family detached structures. Furthermore, the building conditions in the research paper are also highly dissimilar to the Project because the research paper was seeking to study homes built to comply with the 2008 version of the California Title 24 standards, whereas the Project would be built to the most current 2019 California Title 24 standards and would meet the criteria for LEED Silver or equivalent certification level pursuant to PDF- AIR-3 described in the MND. The 2019 version of the Title 24 standards include new ventilation requirements that improve indoor air quality protecting residents from air pollution originating from outdoor and indoor sources . 1 The commenter fails to note that the research paper,
Ventilation and Indoor Air Quality in New California Homes with Gas Appliances and Mechanical Ventilation, discussed indoor air quality and the effect of fan sizing for ventilation with respect to Title 24. The research paper noted in its findings that the adopted fan sizing method in the 2019 version of the Title 24 includes requirements that ensures there is no structural bias towards higher pollutant exposure in homes using unbalanced ventilation systems, unlike the previous 2013 Title 24 standards, which could wor sen indoor air quality by 20 percent on average.
2 Further, while the study found many recently constructed homes (at the time of the field study) had ventilation equipment with more airflow capacity than the minimum requirements of Title 24 for when they were built and would meet the higher air flow requirements of the 2019 version of the Title 24 standards, the 2019 Title 24 requirements ensured the system consistently demonstrated lower indoor air quality exposures across various home types (e.g., homes w ith more air leakage, homes with more airtightness) than prior standards. 3 Therefore, while it is misleading to directly apply results from the research paper to the Project’s hotel uses, the research paper wholly acknowledges that California regulations have been effective in reducing formaldehyde concentrations in homes and states that “[c]omparisons of indoor formaldehyde…levels with those from a prior study of new homes in California (conducted in 2007-08) suggest that contaminant levels are lower in recently built (after 2008) homes. California’s regulation to limit formaldehyde emissions from composite wood products appears to have substantially lowered its emission rate and concentration in new homes.” 4 The research paper

1 CEC, News Release, May 9, 2018, https://www.energy.ca.gov/news/2018-05/energy-commission-adopts-standards-requiring-solar- systems-new-homes-first.
2 Chan, W., Kim, Y., Singer, B., and Walker I. 2019. Ventilation and Indoor Air Quality in New California Homes with Gas Appliances and Mechanical Ventilation. Lawrence Berkeley National Laboratory, Energy Technologies Area, LBNL- 2001200, DOI:

10.20357/B7QC7X.
3 Chan, W., Kim, Y., Singer, B., and Walker I. 2019. Ventilation and Indoor Air Quality in New California Homes with Gas Appliances and Mechanical Ventilation. Lawrence Berkeley National Laboratory, Energy Technologies Area, LBNL- 2001200, DOI:

10.20357/B7QC7X.
4 Chan, W., Kim, Y., Singer, B., and Walker I. 2019. Ventilation and Indoor Air Quality in New California Homes with Gas Appliances and Mechanical Ventilation. Lawrence Berkeley National Laboratory, Energy Technologies Area, LBNL- 2001200, DOI:

10.20357/B7QC7X.
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also states that “[indoor air quality] satisfaction was also similar in the newer homes as compared to homes built in years prior. These results indicate the success of standards.”5 The State of California’s own regulatory agency with authority over this issue, the California Air Resources Board (CARB), has stated that the control measures it has approved for reducing emissions, including formaldehyde, from composite wood products provide a level of control that protects health and safety. CARB makes this point by stating directly in its Frequently Asked Questions for Consumers on Reducing Emissions from Composite Wood Products that, from a public health standpoint, the CWP Regulation’s emission standards are set at low levels intended to protect public health. 6 The first emission s tandards (Phase 1) went into effect in 2009. The more stringent Phase 2 standards are now in effect for all composite wood panels and finished goods sold in California. Prior to the CWP Regulation, formaldehyde emissions were often ten to twenty -fold higher than the current allowable levels. The regulation also includes provisions for no -added formaldehyde and ultra -low emitting formaldehyde-based resins, to encourage the use of these lower -emitting resins in composite wood products.7
The Project would be required to comply with all applicable City, State, and Federal requirements pertaining to the use of indoor building materials. As the Project will include efficient heating, ventilation, and air conditioning (HVAC) systems pursuant to PDF-AIR-2 in the Draft MND, and as the Project will be built to the 2019 version of the Title 24 standards (the 2019 version of the Title 24 standards is the current version as of the date of this response letter), evidence demonstrates that compliance with applicable regulations will be effective in reducing indoor formaldehyde concentrations. Therefore, the research paper does not represent credible evidence that the Project would pose significant health risks to Project workers and temporary hotel guests from indoor air quality.

Moreover, the Appellant speculates that the Project could have an effect on the Project’s users, which is not considered to be an impact under CEQA and need not be analyzed in the Project’s MND. See, e.g., Parker Shattuck Neighbors v. Berkeley City Council (2013) 222 Cal.App.4th 768, 782 (Court concluded that alleged health risks to project residents and construction workers from contaminated soils did not constitute a fair argument of an impact to the environment under CEQA. “In general, CEQA does not regulate environmental changes that do not affect the public at large: “the question is whether a project [would] affect the environment of persons in general, not whether a project [would] affect particular persons.” [Citations omitted]). Furthermore, the calculations provided in the comment amount to speculation given that the underlying report is based on highly dissimilar uses compared to the Project and do not reflect the actual Project uses or compliance with current regulations and are thus unsupported by substantial evidence.

With regard to operational toxic air contaminant emissions, ESA has provided additional clarifying information regarding operational health risk impacts to the environment, which is provided in Appendix B of this Final MND.

As shown therein, health risk impacts to the environment would have a cancer risk of less than 10 in one million,

5 Chan, W., Kim, Y., Singer, B., and Walker I. 2019. Ventilation and Indoor Air Quality in New California Homes with Gas Appliances and Mechanical Ventilation. Lawrence Berkeley National Laboratory, Energy Technologies Area, LBNL- 2001200, DOI:

10.20357/B7QC7X.
6 California Air Resources Board, Frequently Asked Questions for Consumers, Reducing Formaldehyde Emissions from Composite Wood Products, https://ww3.arb.ca.gov/toxics/compwood/consumer_faq.pdf?_ga=2.32900281.682464648.1573169874- 1026610208.1565143819. Accessed November 2019.
7 California Air Resources Board, Frequently Ask ed Questions for Consumers, Reducing Formaldehyde Emissions from Composite Wood Products, https://ww3.arb.ca.gov/toxics/compwood/consumer_faq.pdf?_ga=2.32900281.682464648.1573169874- 1026610208.1565143819. Accessed November 2019.
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consistent with the findings already disclosed in the Draft MND (see pages B -14 and B-15 of the Draft MND), which would be a less than significant impact to the environment, as defined by CEQA and the SCAQMD.

Therefore, based on the above, the commenter does not present a fair argument that the project would result in significant indoor air quality impacts and the preparation of an EIR is not required. Nonetheless, this comment will be made available to the public and decision makers as information.

Comment No. IND 9-5
When a Project exceeds a duly adopted CEQA significance threshold, as here, this alone establishes substantial evidence that the project will have a significant adverse environmental impact. Indeed, in many instances, such air quality thresholds are the only criteria reviewed and treated as dispositive in evaluating the significance of a project’s air quality impacts. (See, e.g. Schenck v. County of Sonoma (2011) 198 Cal.App.4th 949, 960 [County applies Air District’s “published CEQA quantitative criteria” and “threshold level of cumulative significance”]; see also Communities for a Better Environment v. California Resources Agency (2002) 103 Cal.App.4th 98, 110-111 [“A ‘threshold of significance’ for a given environmental effect is simply that level at which the lead agency finds the effects of the project to be significant”].) The California Supreme Court made clear the substantial importance that an air district significance threshold plays in providing substantial evidence of a significant adverse impact. (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 advers e 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 Friends of Coll. of San Mateo Gardens v. San Mateo Cty. Cmty. Coll. Dist. (2016) 1 Cal.5th 937, 958 [emphasis added].) As a result, the City must prepare an EIR for the Project to address this impact and identify enforceable mitigation measures.

Response to Comment No. IND 9-5
The comment references alleged expert evidence that demonstrates that the Project will exceed the SCAQMD’s CEQA significance threshold with respect to NO
X emissions of 201 to 456 pounds per day, which would exceed the SCAQMD established significance threshold for NOx of 55 pounds per day. The comment relies on incorrect information that substantially overestimates the Project’s NOX emissions. As shown on pages B-9 and B-10 and with supporting information provided in Appendix B , the Project would not exceed the SCAQMD established significance threshold for NOx of 100 pounds per day during construction and 55 pounds per day during operations. Therefore, the City is not required to prepare an EIR for the Project and no mitigation measures are required. This comment is further responded to in greater detail in Response to Comment No. 9-20.

Comment No. IND 9-6
The failure of the MND to address the Project’s formaldehyde emissions is 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 expressly holds that potential adverse impacts to future users and residents from pollution generated by a proposed project must be addressed under CEQA. At issue in CBIA was whether the Air District could enact CEQA guidelines that advised lead agencies that they must analyze the impacts of adjacent environmental conditions on a project. 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 800-01.) However, to the extent a project may exacerbate existing environmental conditions at or near a project site, those would still have to be considered pursuant to CEQA. (Id. at 801.) In so holding, the Court expressly held that 11469 Jefferson Boulevard Project
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CEQA’s statutory language required 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 800 [emphasis added].) The carcinogenic formaldehyde emissions identified by Mr. Offermann are not an existing environmental condition. Those emissions to the air will be from the Project. People will be residing in and using the Project once it is built and begins emitting formaldehyde. Once built, the Project will begin to emit formaldehyde at levels that pose significant direct and cumulative health risks. The Supreme Court in CBIA expressly finds that this type of air emission and health impact by the project on the environment and a “project’s users and residents” must be addressed in the CEQA process. The existing TAC sources near the Project site would have to be considered in evaluating the cumulative effect on future residents of both the Project’s TAC emi ssions as well as those existing off-site emissions.

The Supreme Court’s reasoning is well-grounded in CEQA’s statutory language. CEQA expressly includes a project’s effects on human beings as an effect on the environment that must be addressed in 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 800 [emphasis in original].) Likewise, “the Legislature has made clear —in declarations accompanying CEQA’s enactment — that public health and safety are of 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 the thousands of future residents at the Project are human beings and the health and safety of those residents must be subjected to CEQA’s safeguards.

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 office buildings will have significant impacts on air quality and health risks by emitting cancer-causing levels of formaldehyde into the air that will expose future residents to cancer risks potentially in excess of SCAQMD’s threshold of significance for cancer health risks of 10 in a million. Likewise, when combined with the risks posed by the nearby TAC sources, the health risks inside the project may exceed SCAQMD’s cumulative health risk threshold of 100 cancers in a million. Currently, outside of Mr. Offermann’s comments, the City does not have any idea what risks will be posed by formaldehyde emissions from the Project or the residences. As a result, the City must include an analysis and discussion in an EI R which discloses and analyzes the health risks that the Project’s formaldehyde emissions may have on future residents and identifies appropriate mitigation measures.

Response to Comment No. IND 9-6
The comment cites to a California Supreme Court opinion, California Building Industry Ass’n v. Bay Area Air Quality Mgmt. Dist. (2015) 62 Cal.4th 369, 386 (“CBIA”). However, the CBIA does not support the comment’s position that the City must analyze the impact of the Project’s formaldehyde emissions on the Project’s future residents and users – CBIA in fact supports the opposite conclusion.

As stated in the comment, the Supreme Court in CBIA held that “[A]gencies subject to CEQA generally are not required to analyze the impact of existing environmental conditions on a project’s future users or residents. But when a proposed project risks exacerbating those environmental hazards or conditions that already exist, an agency must analyze the potential impact of such hazards on future residents or users.” Id. at 377. In other words, a project’s environmental impact on the project’s future residents or users only need to be analyzed where some environmental hazards or conditions already exist, and could be exacerbated by the proposed project. The Court clarified that a project’s potentially significant exacerbating effects on existing environmental hazards are usually “effects that arise because the project brings development and people into the area affected.” Id. at 388. 11469 Jefferson Boulevard Project
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Here, the comment points to no existing environmental hazards or conditions that would be exacerbated by the Project’s alleged formaldehyde emissions. In fact, the comment acknowledges that “The carcinogenic formaldehyde emissions identified by Mr. Offermann are not an existing environmental condition. Those emissions to the air will be from the Project.” Therefore, the situation that the Supreme Court identified in CBIA, which requires the analysis of the project’s environmental impacts on its future residents and users, is not present here. The comment’s reliance on CBIA is thus misplaced and CBIA’s general rule should apply instead – CEQA does not require agencies to analyze the impact of existing environmental conditions on a project’s future users and residents.

Furthermore, operational air quality emissions , including operational emissions of VOCs (formaldehyde is a VOC), were found to be below SCAQMD significance thresholds (Table B -2 Maximum Regional Operational Emissions of Section III. Air Quality of the Draft MND). The Project would not result in significant operational emissions and would comply with
all applicable City, State, and Federal requirements pertaining to the use of indoor building materials. Please refer to Response to Comment No. IND 9-4.

Based on the above, the alleged health risks to Project users do not constitute a fair argument of an impact to the environment under CEQA.

Comment No. IND 9-7
B. The MND Relies on Unsubstantiated Input Parameters to Estimate Project Emissions and Thus Fails to Provide Substantial Evidence of the Project’s Air Quality Impacts.

Matt Hagemann, P.G., C.Hg., and Paul E. Rosenfeld, Ph.D., of the Soil/Water/Air Protection Enterprise (“SWAPE”) reviewed the air quality analysis in the MND. SWAPE’s comment letter and CVs are attached as Exhibit B and their findings are summarized below.

The MND for the Project relies on emissions calculated from the California Emissions Estimator Model Version CalEEMod.2016.3.2 (“CalEEMod”). This model relies on recommended default values based on site specific information related to a number of factors. The model is used to generate a project’s construction and operational emissions. SWAPE reviewed the Project’s CalEEMod output files and found that the values input into the model were inconsistent with information provided in the MND. This results in an underestimation of the Project’s emissions. As a result, the MND’s air quality analysis cannot be relied upon to determine the Project’s air quality impacts. Instead, the City must prepare an EIR to adequately evaluate the impacts that construction and operation of the Project will have on local and regional air quality.

Response to Comment No. IND 9-7
The CalEEMod model offers default data that can be used when site- specific information is not available, as discussed on Page 1 of the CalEEMod Users Guide.
8 Site-specific Project information was gathered and inputted into the CalEEMod model or other emissions tools and is consistent with the information provided in the MND.

The MND relies on EMFAC2017, which was approved by the U.S. Environmental Protection Agency (USEPA) in 2019. CalEEMod was used to calculate Project emissions from sources other than on- road mobile sources while EMFAC2017 was used to calculate emissions for on-road mobile sources.

8 California Air Pollution Control Officers Association, California Emissions Estimator Model, User’s Guide, Version 2016.3.2, November 2017, http://www.aqmd.gov/docs/default-source/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4. 11469 Jefferson Boulevard Project
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Therefore, the comment is inaccurate in the claim that the values inputted into CalEEMod were inconsistent with information provided in the MND as well as the claim that the Project’s emissions were underestimated. The specific claims are addressed in further detail below in Response to Comment Nos. IND 9-8 through 9-20.

Comment No. IND 9-8

1. The MND’s air quality model improperly reduced the default CO2 intensity factor.

SWAPE’s review of the Project’s CalEEMod output files found that the CO2 intensity factor was manually reduced by approximately 28%, from the default value of 702.44 pounds per megawatt hour (“lbs/MWh”) to 509.22 lbs/MWh. (Ex. B, p. 3.) The “User Entered Comments & Non-Default Data” section attempted to justify these changes by stating: “CO2e intensity factor was linearly projected for year 2022 anticipated RPS based on SB 100 target of 44% RPS by 12/31/2024 projected and from SCE contract with the CPUC to have 41.4% RPS by 2020” (MND, Appendix A, pp. 489, 539).

SWAPE found that the alteration to the CO2 intensity factor was unjustified for two reasons: “First, the IS/MND cannot simply interpolate its own CO2 intensity factor based on estimates of future increases in renewable energy use. Second, simply because the state has renewable energy goals for 2024 does not ensure that these goals will be achieved locally on the Project site or by the Project’s specific utility company. As a result, we cannot verify the revised CO2 intensity factor.” (Ex. B, p. 3.) SWAPE concluded that the unsubstantiated reduction to the default CO2 intensity factor may underestimate the Project’s GHG emissions and, therefore, cannot be relied upon to determine Project’s impacts. (Ex. B, p. 4.) Response to Comment No. IND 9-8
SWAPE’s comment that adjusting CO
2 intensity factors is unjustified is misleading and disingenuous. Changes to the default CO2 intensity factors in CalEEMod are appropriate and necessary to more accurately calculate the Project's GHG impacts. CalEEMod was designed with default assumptions, supported by substantial evidence to the extent available at the time of programming. However, 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. 9 The Project assumptions clearly express the
reasoning for modifying the default intensity factors based on regulatory mandates that utilities providers are required to achieve in accordance with the State of California Renewables Portfolio Standards (RPS). SWAPE appears to misleadingly characterize the RPS as State goals. This is factually incorrect. As discussed in detail on pages 19 and 20 of the Greenhouse Gas Technical Report (November 2020), which was prepared to inform the findings in the Draft MND and was provided by the City alongside the Draft MND, it is abundantly clear that the RPS sets legislative mandate and not voluntary goals. As stated on page 20 of the Greenhouse Gas Technical Report, “retail sellers and local publicly owned electric utilities to procure eligible renewable electricity for 44 percent of retail sales by December 31, 2024, 52 percent by December 31, 2027, and 60 percent by December 31, 2030.” California electricity utilities are obligated to meet the RPS under the supervision of the California Public Utilities Commission (CPUC) as required by State law. SWAPE’s comment seems to suggest that a utility would either ignore State law or reach the RPS only at the RPS target year. A linear projection of CO
2 intensity factor reductions is a reasonable approach assuming that a utility incrementally increases its renewable energy mix year-over-year. This is a reasonable assumption because utilities are required to submit an RPS compliance report annually to CPUC to ensure progress is being made towards the established target

9 CalEEMod was designed with default assumptions supported by substantial evidence to the extent available at the time of programming. However, 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. CalEEMod User's Guide, pp. 12-13.
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-
43 years and renewable energy percentages. Further, the analysis provided in the Draft MND is likely conservative given that the City of Culver City recently
transitioned to a new utility provider, Clean Power Alliance (CPA). CPA is the default utility provider to the City as of early 2019 and has three rate options for commercial and residential customers to choose from; lean power (36% renewable sources), cle an power (50% renewable sources), and
green power (100% renewable sources). Customers are automatically enrolled in the green power option unless they decide to opt to a different rate option or opt out and receive power from SCE. CPA is also subject to al l
RPS compliance enforced by CPUC. Given that CPA has rate options that offer a much higher renewable percentage (and therefore lower intensity factors) than SCE and that they are the default provider, it is reasonable to conclude that the prepared analysi
s is conservative and represents the worst
-
case scenario in which the
Project opts out of CPA and uses power provided by SCE.

Thus, the change to the default CO
2 intensity factor
is not unsubstantiated and does not underestimate the Project’s GHG emissio ns. The analysis can therefore be
relied upon to determine Project impacts.

Comment No. IND 9
-
9 2.

The MND’s air quality model underestimated the Project’s land use size for parking.

SWAPE’s review of the Project’s CalEEMod output files found that the air

model underestimated the proposed
parking space by 22,483 sf. (Ex. B, p. 4.) According to the MND, the Project proposes to provide 56,300 sf of subterranean parking but the air model includes
only 33,817 sf of parking space. (Id.) SWAPE concluded that the

model may therefore underestimate the Project’s construction -
related and operational emissions and cannot
be relied upon to determine Project significance. (Id.)

Response to Comment No. IND 9
-
9 The MND, page A
-
9, discusses that the Project will have
a min
imum of
138 parking spaces in two subterranean
levels, and it was estimated that these levels would utilize 56,300 square feet. The Air Quality Technical Report (November 2020)
, which was prepared to inform the findings in the Draft MND and was provided by

the City
alongside the Draft MND,

included CalEEMod outputs
that indicates that parking was m
odeled based on 199
spaces and
33,817

square feet. The inputs for the parking component were based on a proposed installation of an automated parking system. Howe
ver, in response to community input, the automated parking system was removed and replaced with a traditional valet serviced parking structure. The changes to the project construction program based on the removal of the automated parking system and replace ment with a traditional valet serviced
parking structure are captured in the construction schedule, construction equipment and vehicles, and construction workers utilized for the Draft MND (see also Response to Comment No. IND 9 -
15). Therefore, no
changes
to these emissions would result from a correction of the modeling for 138 parking spaces and 56,300 square feet.

A correction to the modeling for 138 parking spaces and 56,300 square feet would result in minor changes to fugitive VOC emissions (e.g., from
parking structure
architectural coating) and minor changes to electricity GHG emissions (e.g., from lighting and elevator electricity). This correction is summarized in Table D
-
2 ,
Revised
Emissions from Parking Structure Correction
, and calculation details

are provided in
Appendix
B

this Final
MND. The correction would result in maximum VOC and GHG emissions as follows:

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TABLE D-2

REVISED EMISSIONS FROM PARKING STRUCTURE CORRECTION
Project Phase Maximum VOC Emissions (pounds per day) Maximum GHG Emissions (MTCO2e per year) Draft MND Final MND Percent
Change
Draft MND Final MND Percent
Change
Construction 15.3 15.4 0.5% No Changes
Operations 6.00 6.04 0.6% 1,537 1,572 2.26%

Source: ESA, 2021

As shown in Table D-2, the change in emissions would be very minimal (less than 1 percent for VOC and less than 3 percent for GHG) and would not be substantial. This change would not in any way result in conflicts with applicable GHG reduction plans, policies, or regulations as the Project would still be compliant with applicable energy efficiency standards. No new impacts or substantially greater impacts would occur. Therefore, the Project’s construction-related and operational emissions can be relied upon to determine Project significance and no new analysis is required.

Comment No. IND 9-10

3. The MND’s air quality model failed to model all proposed land uses.

SWAPE’s review of the Project’s CalEEMod output files found that the air model failed to model the Project’s 3,313 sf of restaurant space and 700 sf of fitness space. (Ex. B, pp. 4-5.) SWAPE found that the model failed to distinguish between the Project’s hotel land use and restaurant/fitness land use (Id. at p. 5.) SWAPE explained that “CalEEMod includes 63 different land use types that are each assigned a distinctive set of energy usage emission factors” and that “each land use type includes a specific trip rate that CalEEMod uses to calculate mobile-source emissions.” (Id.) SWAPE concluded that the model may therefore underestimate the Project’s construction-related and operational emissions and cannot not be relied upon to determine Project impacts. (Id. at pp. 5-6.)
Response to Comment No. IND 9-10
SWAPE incorrectly concluded that the model may underestimate the Project’s construction- related and operational emissions. The Project CalEEMod emissions modeling did not exclude any land uses or emissions sources from the analysis and was correct in using the hotel land use subtype. Table 1 on page 24 of the CalEEMod User’s Guide provides descriptions of the various land use subtypes available. The description for the hotel land use subtype reads, “Hotels are places of lodging that provide sleeping accommo dations and supporting facilities such as restaurants; cocktail lounges; meeting and banquet rooms or convention facilities; limited recreational facilities and other retail and service shops.” 10 The land use description clearly includes any
supporting facilities (e.g. restaurants, bars, lounges, and recreational facilities) that are commonly found in a hotel. Therefore, the Project’s emissions do include restaurant/fitness land uses as part of the hotel land use subtype and emissions were accounted for correctly. Additionally, the Project conservatively modeled a total of

10 CAPCOA, CalEEMod User’s Guide, 2017. Page 24. Available: http://www.aqmd.gov/docs/default -source/caleemod/01_user-39-s- guide2016-3-2_15november2017.pdf?sfvrsn=4
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122,000 square feet instead of the 111,111 square feet listed in MND, Table A-1, to conservatively calculate construction-related and operational emissions.

Comment No. IND 9-11

4. The MND’s air quality model made unsubstantiated changes to individual construction phase lengths.

SWAPE’s review of the Project’s CalEEMod output files found that the air model made unsubstantiated changes to individual construction phase lengths. (Ex. B, p. 6.) The specific changes made were:
• the demolition phase was increased by approximately 430%, from the default of 10 to 53 days; • the grading phase was increased by approximately 3,650%, from the default of 2 to 75 days; • the building construction phases were collectively increased by approximately 84%, from the cumulative default value of 300 to 553 days;
• the paving phase was increased by approximately 120%, from the default value of 5 to 11 days; and • the architectural coating phase was increased by 1,440%, from the default value of 5 to 77 days. (Id.)

According to the “User Entered Comments and Non- Default Data” table, the justification provided for these changes is: “see construction assumptions” (MND, Appendix A, pp. 82, 115). However, as noted by SWAPE, the MND and associated documents provide no “construction assumptions,” as purported by the “User Entered Comments and Non-Default Data” table. (Ex. B, p. 7.)
Additionally, for the changes to construction- related inputs, the MND’s Air Quality Techni cal Report (“AQ Technical Report”) explained that “[t]he input values used in this analysis were adjusted to be Project -specific based on equipment types and the construction schedule” and that “[d]etailed construction equipment lists, construction scheduling, and emissions calculations are provided in Appendix A.” (AQ Technical Report, pp. 41-

42.)
However, as noted by SWAPE, Appendix A of the AQ Technical Report does not include fail a detailed construction schedule, as purported by the AQ Technical Report. (Ex. B, p. 7.) Response to Comment No. IND 9-11
SWAPE maintains that the manual changes to the construction schedule in the CalEEMod are unsubstantiated.

This is untrue. Changes to the default construction schedule in CalEEMod are appropriate and neces sary to more accurately calculate the Project's emissions. CalEEMod was designed with default assumptions, supported by substantial evidence to the extent available at the time of programming. However, 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. 11 The Project's construction schedule was prepared in consultation with the Applicant and their construction consultant and applied in the air quality modeling as provided in Appendix A-1 of the Air Quality Technical Report (November 2020), which was prepared to inform the findings in the Draft MND and was provided by the City

11 CalEEMod was designed with default assumptions supported by substantial evidence to the extent available at the time of programming. However, 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. Cal EEMod User's Guide, pp. 12-13.
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-
46 alongside the
Draft MND
.

The Air Quality Technical Report
anticipates that construction would occur with some
potential overlap
of

the construction
activities
.

The
potential overlap
of

the construction
activities was assumed
in order to estimate maximum emissions that could occur in a day to provide a conservative impact analysis.

Notably,

the comment provides no evidence whatsoever that
the construction schedule is unreasonable or
inappropriate.

We
also note that CalEEMod is designed to allow the user to change the defaults to reflect site or project -
specific
information, when available, provided that information is supported by substantial evidence. (CalEEMod User's Guide, p.12
-
13) The CalEEMod ins
tructions state on page 17: "[t]o indicate when construction of the project will begin, the user will need to insert a date in the Start of Construction field. The date when construction will start triggers a rolling calendar that starts with the constru ction start date and follows by various construction phases that will be populated with default date ranges in the Construction screen." In this case, the default date ranges for the subphases were changed based on the project
-
specific information as prov
ided by the Applicant

and
noted in Section 1.3 in the CalEEMod
output files (
Appendix A
-
1 of

the
Air Quality Technical Report)
. Thus,
construction schedules as inputted into CalEEMod are
appropriately adjusted to be Project
-
specific
.

Based on the above,
t
he detailed construction schedule inputted into CalEEMod was a reasonable forecast of anticipated construction period and SWAPE offers no evidence whatsoever to the contrary. The construction subphases for each phase were accounted for in the construction

assumptions and maximum daily Project
emissions were not underestimated in this regard.

Comment No. IND 9
-
12 Lastly, regarding the construction schedule, the AQ Technical Report states,

“This analysis assumes construction of the Project is estimated to re quire up to 26 months, starting as early as
the second quarter of 2020.” (AQ Technical Report, p. 42.) However, as noted by SWAPE, the AQ Technical Report only indicates that the total construction period is estimated as 26 months but says nothing about th e
individual construction phase lengths. (Ex. B, p. 7.)

SWAPE concluded that the MND may underestimate the Project’s construction -
related emissions because of
unsubstantiated changes to the default individual construction phase lengths and, therefore, cann ot be relied
upon to determine Project impacts. (Ex. B, p. 8.)

Response to Comment No. IND 9
-
12 As discussed above in Response to Comment No. IND 9
-
11,
the Project's construction schedule was prepared
in consultation with the Applicant and
their

constructi
on consultant and applied in the air quality modeling
as
provided
in Appendix A
-
1 of

the
Air Quality Technical Report (November 2020)
, which was prepared to inform
the findings in the Draft MND and was provided by the City alongside the Draft MND .

The Air

Quality Technical
Report
anticipates that construction would occur with some potential overlap of

the construction
activities
.

The
potential overlap
of

the construction
activities was assumed in order to estimate maximum emissions that could occur in a da
y to provide a conservative impact analysis.

Notably,

the comment provides no evidence whatsoever
that
the construction schedule is unreasonable or inappropriate.

As such, the changes to the construction
schedule were substantiated and emissions can be rel
ied upon to determine Project impacts.

Comment No. IND 9
-
13 5.

The MND’s air quality model improperly altered the number of construction days per week without justification.

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SWAPE’s review of the Project’s CalEEMod output files found that the Project’s number of construction days per week was manually changed from the CalEEMod default. (Ex. B, p. 8.) SWAPE found that the “User Entered Comments & Non-Default Data” table (located in Appendix A of the MND) states “see construction assumptions” (MND, Appendix A, pp. 82, 115). However, the MND and associated documents fail to provide any “construction assumptions” pertaining to the number of days a week for construction (Id.) As such, SWAPE concludes that the MND may underestimate the Project’s construction-related emissions and should not be relied upon to determine Project’s impacts. (Ex. B, p. 9.)
Response to Comment No. IND 9-13
Similar to the above Response to Comment No.’s IND 9-11 and IND 9-12, SWAPE maintains that the manual changes to the construction schedule in CalEEMod are unsubstantiated. Again, SWAPE acknowledges that the construction assumptions provided in the MND reflect the changes manually inputted into CalEEMod and contend that they cannot trust that the construction schedule is correct. Once again, this is untrue. The Project's construction schedule, as applied in the air quality modeling in Appendix A-1 of the Air Quality Technical Report (November 2020), was prepared in consultation with the Applicant and their construction consultant. SWAPE does not claim nor provide any evidence that the assumption itself is inaccurate or inappropriate. Thus, the maximum daily Project emissions were not underestimated in this regard.

Comment No. IND 9-14

6. The MND’s air quality model made unsubstantiated changes to off-road equipment unit amounts and usage hours.

SWAPE’s review of the Project’s CalEEMod output files found that the Project’s off-road equipment unit amounts and usage hours were manually changed from the CalEEMod defaults. (Ex. B, p. 9.) According to the “User Entered Comments and Non- Default Data” table, the justification provided for these changes is: “see construction assumptions” (MND, Appendix A, pp. 82, 115). However, as noted by SWAPE, the MND and associated documents provide no “construction assumptions,” as purported by the “User Entered Comments and Non-Default Data” table. (Ex. B, p. 10.)
Furthermore, for the changes to construction- related inputs, the MND’s Air Quality Technical Report (“AQ Technical Report”) explained that “[t]he input values used in this analysis were adjusted to be Project -specific based on equipment types and the construction schedule” and that “[d]etailed construction equipment lists, construction scheduling, and emissions calculations are provided in Appendix A.” (AQ Technical Report, pp. 41-

42.)
However, as noted by SWAPE, Appendix A of the AQ Technical Report does not include fail a detailed construction schedule, as purported by the AQ Technical Report. (Ex. B, p. 10.) SWAPE conc luded that the MND may underestimate the Project’s emissions because of unsubstantiated changes to the Project’s off-road construction equipment unit amounts and usage hours and, therefore, cannot be relied upon to determine Project impacts. (Ex. B, p. 8.) Response to Comment No. IND 9-14
SWAPE contends that several manual changes to the defaults for off-road construction equipment unit amounts and usage hours in the models used to determine the air quality impacts associated with the construction were unsubstantiated. That is incorrect. The model defaults referenced in the comment were modified to incorporate 11469 Jefferson Boulevard Project
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Project-specific information for off-road equipment and usage hours that conservatively would result in maximum daily construction emissions. These default modifications were necessary to accurately calculate the Project's construction air quality impacts. The changes to the off-road construction equipment units and hours are shown in the CalEEMod runs under sections 1.3 and 3.0.

SWAPE’s assertion that it cannot rely on the project-specific information for off-road equipment and usage hours is incorrect. The Project's off -road equipment and usage hours for the Project were prepared in consultation with the Applicant and their construction consultant. It reasonably anticipates that phase construction would occur over a 26-month period with some potential overlap in the construction of certain phases. In accordance with the CalEEMod User's Guide (page 32), Project -specific off-road equipment that would be used during construction activities and daily usage hours were used based on information from the Applicant and their construction consultant as documented in Appendix A -1. As it is acceptable to change the default inputs for project specific details, CalEEMod is an adequate representation of Project emissions and thus the analysis appropriately evaluated the Project’s local and regional air quality impacts. SWAPE fails to present any reason or evidence that the project information is unreasonable or i nappropriate. For these reasons, the manual changes to off -road equipment unit amounts and usage were substantiated and maximum daily Project emissions were not underestimated in this regard.

Comment No. IND 9-15

7. The MND’s air quality model failed to model all required material export.

SWAPE’s review of the Project’s CalEEMod output files found that the MND’s air model underestimated the amount of required material export by 12,524 cubic yards (cy). (Ex. B, p. 10. According to the AQ Technical Report, “[t]he Project would export approximately 43,836 cubic yards of soil during grading and excavation activities” (AQ Technical Report, p. 42.) However, as SWAPE notes, the model included only 31,312 cy of material export rather than 43,836 cy. (Ex. B, p. 10.) SWAPE concluded that the MND may underestimate the Project’s emissions by failing to model all the required material export and, therefore, cannot be relied upon to determine Project impacts. (Ex. B, p. 10.)
Response to Comment No. IND 9-15
SWAPE’s assertion that the MND incorrectly modeled the appropriate amount of export material is incorrect.

CalEEMod converts material export amounts to haul trips (CalEEMod Users Guide, page 33) for emissions calculations. As discussed above, EMFAC2017 was used to calc ulate on-road emissions in the Air Quality Technical Report (November 2020), which was prepared to inform the findings in the Draft MND and was provided by the City alongside the Draft MND. EMFAC2017 was approved by the U.S. Environmental Protection Agency (USEPA) in 2019. Thus, the material export values seen in the CalEEMod output files were not used for on-road haul truck emissions calculations. The above-referenced 43,836 cubic yards was indeed used to model on-road haul truck emissions from material export in the file titled “Construction Mobile Emissions (2019-1127)- AQ” provided in Appendix A-1 of the Air Quality Technical Report (hauling emissions start on page 132/590 of the PDF). Therefore, the appropriate amount of export material was modeled, P roject emissions were not underreported, and the emissions can be relied upon for determining Project impacts. Additional clarification regarding the excavation quantity of 43,836 cubic yards in the construction emissions modeling has been provided in Appendix B of this Final MND.

Comment No. IND 9-16

8. The MND’s air quality model made unsubstantiated reductions to hauling, worker, and vendor trip numbers. 11469 Jefferson Boulevard Project
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SWAPE’s review of the Project’s CalEEMod output files found that the MND’s air model made unsubstantiated reductions to hauling, worker, and vendor trip numbers. (Ex. B, p. 10.) Specifically, the hauling, worker, and vendor trip numbers were reduced to zero. (Id. at p. 11.) SWAPE found that the MND and associated documents failed to provide a source or any calculations explaining how the trip numbers were derived. (Ex. B, p. 11- 12.) By failing to provide this information, the MND fails to provide substantial evidence to justify the modifications to the CalEEMod defaults. (Id. at 12.) SWAPE also found that the MND and associated documents failed to provide the total on -road construction-related emissions for hauling, vendor, and worker trips, or demonstrate how the on-road construction-related emissions were summed with the construction-related emissions estimated in CalEEMod. (Id.) SWAPE concluded that the MND may underestimate the Project’s emissions by including unsubstantiated changes to the default hauling, vendor, and worker construction trips, and, therefore, cannot be relied upon to determine Project impacts. (Ex. B, p. 10.)
Response to Comment No. IND 9-16
As discussed above, on -road emissions were calculated outside of CalEEMod. EMFAC2017 was used to calculate emissions for on -road mobile sources in the Air Quality Technical Report (November 2020) .

EMFAC2017 was approved by the USEPA in 2019. CalEEMod was used to calculate Project emissions from sources other than on-road mobile sources. Thus, the trip number values seen in the CalEEMod output files were zeroed out because emissions associated with on-road vehicles were performed outside of CalEEMod in order to utilize the more conservative EMFAC2017 emission factors. Again, the claim by SWAPE the Project emissions were underreported and are unreliable is incorrect.

The worker, vendor and hauling trips were indeed included and used to calculate Project construction emissions, as seen in file titled “Construction Mobile Emissions (2019-1127)-AQ” provided in Appendix A-1 of the Air Quality Technical Report (November 2020) (starting on page 132/590 of the PDF). Therefore, the Draft MND does not underestimate the Project’s emissions based on the Project’s hauling, vendor, and worker construction trips, and the Draft MND can be relied upon to determine Project impacts.

Comment No. IND 9-17

9. The MND’s air quality model made unsubstantiated changes to the Project’s operational vehicle fleet mix.

SWAPE’s review of the Project’s CalEEMod output files found that the MND’s air model made several changes to the default operational vehicle fleet mix percentages. (Ex. B, 13.) However, no justification for the modifications was given and the MND and associated documents do not mention any revised operational vehicle fleet mix percentages. (Id. at 14.)
SWAPE concluded that the model may underestimate the Project’s mobile-source operational emissions and cannot be relied upon to determine Project significance. (Id.) Response to Comment No. IND 9-17
As outlined in the CalEEMod output files, the Project operational fleet mix percentages were changed based on values obtained from the Project traffic study. Trip percentages were adjusted to account for 25% pass-by trips in the traffic study. Additionally, the appropriate emission factors from the updated USEPA approved EMFAC2017 database were manually changed in CalEEMod to replace the model’s use of the EMFAC2014 emission factors. It was appropriate to update these values in order to prepare an analysis using the updated 11469 Jefferson Boulevard Project
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EMFAC2017 emission factors. Therefore, the changes made to the Project’s operational vehicle fleet mi x are based on substantial evidence and do not underestimate the Project’s operational mobile-source emissions and these emissions can be relied upon to determine Project significance.

Comment No. IND 9-18

10. The MND’s air quality model made unsubstantiated changes to operational vehicle emission factors.

SWAPE’s review of the Project’s CalEEMod output files found that the MND’s air model made several changes to the default operational vehicle emission factors. (Ex. B, 15.) According to the “User Entered Comments and Non-Default Data” table, the justification provided for these changes is: “Updated to EMFAC2017 EFs” (MND, Appendix A, pp. 489, 539). As explained by SWAPE, EMFAC refers to an entire database, not a specific set of vehicle emission factors. (Ex. B, p. 15.) The MND did not specify which input parameters were used to obtain the vehicle emission factors nor provide the revised vehicle emission factors themselves. (Id.) Because the vehicle emission factors are used to calculate the Proj ect’s operational emissions associated with on- road vehicles, the model may underestimate the Project’s mobile- source operational emissions by including several unsubstantiated changes to the default operational vehicle emission factors and, therefore, cannot be relied upon to determine Project significance. (Id.)
Response to Comment No. IND 9-18
Similar to the above comment, the CalEEMod emissions factors were changed based on values obtained from the EMFAC2017 database using the same assumptions CalEEMod would otherwise use from the EMFAC2014 database (like the same calendar and model year(s), region, vehicle types, aggregated speeds, etc.) . It was appropriate to update these values in order to prepare an air quality analysis using the updated USEPA approved EMFAC2017 emission factors. Therefore, the changes made to the Project’s operational vehicle fleet mix are based on substantial evidence and do not underestimate the Project’s operational mobile-source emissions and these emissions can be relied upon to determine Project significance.

Comment No. IND 9-19

11. The MND’s air quality model improperly included construction-related mitigation measures.

SWAPE’s review of the Project’s CalEEMod output files found that the MND assumed that the Project will implement construction-related mitigation measures, including a 15 miles per hour (mph) vehicle speed. (Ex. B, p. 15.) However, as explained by SWAPE, with the exception of Tier 4 Final engines, the “User Entered Comments & Non- Default Data” fails to justify t he inclusion of the other construction- related mitigation measures. (Id. at p. 16.)
For the 15 mph speed limit, SWAPE noted that although the MND claimed that the Project would comply with SCAQMD regulations for controlling fugitive dust pursuant to SCAQMD Rule 403, SCAQMD Rule 403 does not require a 15 mph speed limit. (Ex. B, p. 16.) Pursuant to SCAQMD Rule 403, the Project may either water unpaved roads 3 times per day, water unpaved roads 1 time per day and limit vehicle speeds to 15 mph, or apply a chemical stabilizer. (Id. at p. 17.) Therefore, SCAQMD Rule 403 does not explicitly require any of the measures included in the CalEEMod model. (Id.)
SWAPE concluded that the MND may underestimate the Project’s emissions by including several construction- related mitigation measures without properly committing to their implementation and enforcement, and, therefore, cannot be relied upon to determine Project impacts. (Ex. B, p. 17.) 11469 Jefferson Boulevard Project
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Response to Comment No. IND 9-19
As discussed in Section 2.3 of the Air Quality Technical Report (November 2020), SCAQMD Rule 403 requires restrictions on visible fugitive dust and PM10 emissions with specific requirements in Subpart d of Rule 403, which includes prohibiting dust that remains visible in the atmosphere beyond the property line of the emission source or prohibiting dust emission that exceeds 20 percent opacity if the dust emission is the result of movement of a motorized vehicle. Further as stated in Subpart d of Rule 403, “No person shall conduct active operations without utilizing the applicable best available control measures included in Table 1 of this Rule to minimize fugitive dust emissions from each fugitive dust source type within the active operation.” SCAQMD Rule 403 does not state that only one measure can be applied. On the contrary, projects may implement several of the best available control measures to meet requirements of the Rule.

CalEEMod incorporates industry standard best available control measures to quantify reductions in fugitive dust emissions based on several best available control measure listed in Rule 403, which includes a 15 miles per hour speed limit on unpaved roads and application of water on disturbed areas and unpaved roads three times per day or application of a non-toxic chemical stabilizer. These control measures are not mitigation measures as stated by SWAPE, but rather best management practice techniques implemented to quantify and meet the regulatory requirements under Subpart d of Rule 403. Excluding fugitive dust control measures from the Project’s modeling analysis means the Project would be non-compliant with Rule 403. Therefore, the Air Quality Technical Report and Draft MND appropriately considers industry standard best available control measures and does not underreport Project emissions. The emissions analysis can be relied upon to determine Project impacts.

Comment No. IND 9-20
C. Substantial Expert Evidence Establishes a Fair Argument That the Project Will Have Significant Emissions of ROG/VOC and NOx.

In an effort to accurately determine the Project’s construction and operational emissions, SWAPE prepared an updated CalEEMod model that includes more site-specific information and correct input parameters, as provided by the MND. (Ex. B, p. 17.) SWAPE’s model included all proposed land use types and sizes as described by the MND; corrected the amount of material export; omitted the unsubstantiated changes to the individual construction phase lengths, off -road construction equipment unit amounts and usage hours, construction tri p numbers, operational vehicle emission factors, and operational vehicle fleet mix percentages; and excluded the unsubstantiated construction-related mitigation measures. (Id.) SWAPE’s updated model found that the ROG/VOC and NOx emissions associated with Project construction exceed the 75- and 100-pounds per day (“lbs/day”) thresholds set by the SCAQMD, respectively. (Ex. B, p. 17.) SWAPE’s updated model demonstrates that when the Project’s construction and operational emissions are estimated based on site -specific information provided in the MND, the Project would result in a potentially significant air quality impact that was not previously identified or addressed in the MND. As such, the City must prepare an EIR to include an updated air pollution model to properly estimate the Project’s construction and operational emissions and incorporate mitigation to reduce these emissions to a less than significant level.

Response to Comment No. IND 9-20
SWAPE claims that regional construction- related and operational air quality emissions for the Project are significant based on its new CalEEMod modeling. Above, SWAPE claimed that several inputs to the CalEEMod modeling were incorrect. Response to Comment Nos. IND 9 -8 through 9 -19 provide specific responses 11469 Jefferson Boulevard Project
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explaining that the manual inputs for the air quality analysis were appropriate and why SWAPE’s conclusions are incorrect.

Based on review of the comments related to the emissions analysis presented in the Air Quality Technical Report (November 2020) and the Draft MND, SWAPE’s misunderstanding and misapplication of CalEEMod and the Project-specific analysis renders their comment as without credibility and merit. SWAPE’s use of default values for the construction schedule and off-road equipment are not representative of the Project nor the emissions that would be anticipated for the Project . Furthermore, no required or conditioned emission control measures were applied to SWAPE’s model, which is an inappropriate misrepresentation of Project emissions. For these reasons, SWAPE’s analysis misleads the public and decision makers as to the Project’s emissions impacts.

As discussed in Responses to Comment Nos. IND 9-8 through 9-19, the emissions analysis presented in the Air Quality Technical Report and the Draft MND adequately and conservatively represent the Project emissions and can relied upon for a determination of Project impacts.

Comment No. IND 9-21
D. The MND Fails to Adequately Evaluate Health Risks from Diesel Particulate Matter Emissions Based on based on a quantified construction health risk assessment (“HRA”) and a localized significance (“LST”) analysis, the MND concluded that the Project would have a less - than-significant health risk impact. (Ex. B, p.

18.) However, SWAPE’s review of the MND found that M ND’s evaluation of the Project’s potential health risk impacts and the less-than- significant impact conclusion were improper. (Id.) Response to Comment No. IND 9-21
SWAPE is incorrect in their assessment that the less -than-significant impact conclusions of the HRA and LST analysis were improper. Refer to Response to Comment Nos. IND 9-23 through IND 9-29 for responses to the specific comments raised.

Comment No. IND 9-22
First, SWAPE notes that, as discussed above, the MND’s HRA relied on a flawed air model and therefore underestimated PM10 emissions. (Ex. B, p. 18.) By using an inaccurate PM10 value, the HRA underestimated the diesel particulate matter (“DPM”) concentration to calculate the cancer risk associated with Project construction. (Id. at p. 19.) Therefore, the MND underestimated the Project’s construction -related cancer risk and cannot be relied upon to determine Project impacts. (Id.) Response to Comment No. IND 9-22
As detailed in Response to Comment Nos. IND 9-8 through 9-20, SWAPE is incorrect in their assessment that the MND underestimated PM10 emissions. As detailed above, the MND incorporated the appropriate emission factors, construction schedule, off-road equipment amounts and usage hours, etc. to produce PM10 and DPM emission impacts from the Project. Therefore, the assertion that emissions presented in the Air Quality Technical Report (November 2020) and in the Draft MND cannot be relied upon to determine the Project’s health risk impacts is also incorrect. The Air Quality Technical Report and the Draft MND do not underestimate the Project’s construction-related cancer risk from diesel particulate matter (DPM) emissions and the Draft MND can be relied upon to determine Project impacts. Refer to Response to Comment Nos. IND 9 -23 through IN D 9 -29 for responses to the specific health risk comments raised.
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Comment No. IND 9-23
Second, SWAPE disputes the MND’s conclusion that operational health risks would be less -than-significant because the Project would not “generate a substantial number of daily truck trips.” (Ex. B, p. 19.) However, the MND stated that Project operation would generate 1,463 new daily vehicle trips, which, according to SWAPE, would result in additional exhaust emissions and continue to expose nearby sensitive receptors to DP M emissions. (Id.) The MND makes no effort to connect the Project’s operational TAC emissions to the potential health risks posed to nearby receptors, and, therefore, should not conclude that the Project’s operational health risk impact would be less than significant. (Id.)
Response to Comment No. IND 9-23
Here SWAPE provides a misleading comment by not differentiating the vehicle trips associated with the operation of the Project and diesel -fueled vehicle trips. Of the 1,463 new vehicle trips generated per day, only approximately 4.3 percent would be diesel-fueled while the vast majority will be light duty passenger vehicles.

The operational mobile source exhaust PM10 emissions are from a combination of primarily gasoline- fueled vehicles, such as passenger vehicles and light-duty pick-up trucks, and a smaller number of diesel-fueled trucks, as provided in the vehicle fleet percentages in the CARB on- road EMFAC model. It is highly inappropriate and factually incorrect to analyze non- diesel fuel exhaust PM10 emissions as DPM. This results in substantially overestimated and, therefore, unrealistically high health risk impacts.

To provide additional clarifying information that the Project would not result in a significant TAC impact, ESA has prepared an operational Project HRA (provided in Appendix B of this Final MND), which demonstrates that the cancer (0.4 in one million) and non-cancer (HI of 0.0001) health risks associated with the Project's TAC emissions from operational DPM emissions are well below the sig nificance thresholds. Thus, as stated in the MND, the Project’s operational health risk impact would be less than significant.

Comment No. IND 9-24
Third, SWAPE found that the MND’s omission of a quantified operational HRA is inconsistent with the most recent guidance published by the Office of Environmental Health Hazard Assessment (“OEHHA”). (Ex. B, p. 19.) OEHHA recommends that exposure from projects lasting more than 6 months be evaluated for the duration of the project and recommends that an exposur e duration of 30 years be used to estimate individual cancer risk. (Id.) SWAPE concluded that the MND should include an operational HRA to evaluate health risk impacts with a 30-year exposure duration. (Id.)
Response to Comment No. IND 9-24
The SCAQMD has clarified that the OEHHA Guidance Manual does not include CEQA significance thresholds applicable to construction activities, nor to the operation of non- stationary source projects such as this Project.

SCAQMD staff is still evaluating how to implement the OEHHA Guidance Manual under CEQA. The SCAQMD has stated that it "currently does not have guidance on construction Health Risk Assessments." 12 To date, the
SCAQMD has not conducted public workshops nor developed any policy relating to the applicability of the revised

12 South Coast Air Quality Management District, Final Environmental Assessment for: Proposed Amended Rule 307.1 – Alternative Fees for Air Toxics Emissions Inventory; Proposed Amended Rule 1401 – New Source Review of Toxic Ai r Contaminants; Proposed Amended Rule 1402 – Control of Toxic Air Contaminants from Existing Sources; SCAQMD Public Notification Procedures for Facilities Under the Air Toxics " Hot Spots " Information and Assessment Act (AB 2588) and Rule 1402; and, SCAQMD Guidelines for Participating in the Rule 1402 Voluntary Risk, page 2-23, September 2016. The SCAQMD only applies the revised OEHHA Guidelines for operational impacts at stationary industrial source facilities that are in the AB 2588 Air Toxics Hot Spots pr ogram, which does not apply to the Project.
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2015 OEHHA Guidance Manual for projects prepared by other public/lead agencies subject to CEQA or for mixed-use residential and commercial projects. SCAQMD’s Mobile Source Toxics Analysis states that it will serve as an interim technical guidance for estimating potential DPM impacts from the following activities: 1) truck idling and movement (such as, but not limited to, truck stops, warehouse/distribution centers, or transit centers), 2) ship hoteling at ports, and 3) train idling. The Projec t is a hotel and will not be a truck stop, warehouse/distribution center or transit center. The number of large trucks visiting the site will be limited as the Project is a hotel and will be associated primarily with light -duty passenger vehicles. Theref ore, operational health risks would be less than significant.

Nevertheless, to provide additional clarifying information that the Project would not result in a significant TAC impact, ESA has prepared an operational Project HRA (provided in Appendix B of t his Final MND), which demonstrates that the cancer (0.4 in one million) and non-cancer (HI of 0.0001) health risks associated with the Project's TAC emissions from operational DPM emissions are well below the significance thresholds. Thus, as stated in the MND, the Project’s operational health risk impact would be less than significant.

Comment No. IND 9-25
Fourth, SWAPE found that the MND failed to evaluate the cumulative lifetime cancer risk to nearby, existing receptors as a result of Project construction and operation together. (Ex. B, p. 19.) SWAPE concluded that, per OEHHA Guidance, the Project’s combined construction and operational cancer risks must be quantified and compared to the SCAQMD threshold 10 in one million. (Id.) Response to Comment No. IND 9-25
This comment is addressed in Response to Comment Nos. IND 9-23 and 9-24.

Furthermore, the results of the Project’s quantitative construction and operational HRA demonstrate that the combined worst-case construction (9.2 in one million per Table 10 of the Air Quality Technical Report (November 2020) and Table B-5 of the Draft MND) plus the 30-year operational (0.4 in one million) cancer risks associated with the Project's TAC emissions from DPM emissions would be approximately 9.6 in one million, whi ch would be below the significance threshold of 10 in one million. Thus, the MND significance determination of less than significant operational cancer risk is correct and further substantiated by this clarifying information, the details of which are provided in Appendix B of this Final MND.

Comment No. IND 9-26
Lastly, SWAPE found that the MND improperly concluded that the Project’s PM2.5 and PM10 emissions would not exceed LSTs. (Ex. B, p. 20.) SWAPE’s review of the CalEEMod output files demonstrates that the PM10 and PM2.5 emissions associated with Project construction exceed the 1- and 2-lbs/day LSTs set by the SCAQMD, respectively. (Id.) Therefore, the MND’s claim that emissions associated with Project construction would not exceed the applicable SCAQMD LSTs is incorrect and cannot be relied upon.

Response to Comment No. IND 9-26
SWAPE is incorrect in their assessment that the MND underestimated emissions, including those of PM10 and PM2.5. The comment inaccurately refers to “1 - and 2- lbs/day LSTs set by the SCAQMD” for construction.

Consistent with the SCAQMD Localized Significance Thresholds (LSTs), Table 8 of the Air Quality Technical Report (November 2020) shows the appropriate construction LSTs for the Project, which are 4 pounds per day for PM10 and 3 pounds per day for PM2.5. As a result, t he assertion that the emissions presented in the Air Quality Technical Report (November 2020) cannot be relied upon for comparison to SCAQMD LSTs is also 11469 Jefferson Boulevard Project
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incorrect. The Air Quality Technical Report and the Draft M ND do not underestimate the Project’s localized emissions and localized impacts and the Draft MND can be relied upon to determine Project impacts.

Comment No. IND 9-27
E. Substantial Expert Evidence Establishes a Fair Argument that the Project May Have a Significant Impact on Human Health from Diesel Particulate Matter
SWAPE prepared a screening -level HRA to evaluate potential impacts from the construction and operation of the Project. (Ex. B, p. 21.) SWAPE used AERSCREEN, the leading screening-level air quality dispersion model. (Id.) SWAPE used a sensitive receptor distance of 25 meters and analyzed impacts to individuals at different stages of life based on OEHHA and SCAQMD guidance. (Ex. B, pp. 22-13.) SWAPE found that the excess cancer risk for adults, children, and infants, at the closest sensitive receptor located approximately 25 meters away, over the course of Project construction and operation, are approximately 16, 150, and 17 in one million, respectively. (Ex. B, p. 23.) SWAPE found that the excess cancer risk over the course of a residential lifetime is approximately 180 in one million. (Id.) These values appreciably exceed the SCAQMD’s threshold of 10 in one million.

SWAPE’s HRA constitutes a “fair argument” that the Project will have significant impacts on human health. As such, the City must prepare an EIR to properly evaluate the Project’s health risk impact.

Response to Comment No. IND 9-27
SWAPE erroneously contends that the MND’s health risk assessment was improper. SWAPE goes a step further by preparing a simple screening-level HRA, which not surprisingly estimates cancer-risk values that far exceed the various thresholds for a significant TAC impact. SWAPE acknowledges that “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.” (Exhibit B, page 21), which is exactly what was prov ided in the Air Quality Technical Report (November 2020).

This screening-level HRA lacks any semblance of credibility for a number of reasons. To start with, SWAPE's simple screening-level HRA relied upon AERSCREEN, which is a screening -level air quality dispersion model.

This screening-level HRA indicates a screening risk of 16 in one million without age sensitivity factors and 180 in one million with age sensitivity factors. These risk values are immediately suspect as misleading and unreasonable because they are substantially higher than typical risk values for industrial source projects and are therefore an entirely unexpected result for a hotel development project, which would have significantly lower DPM emissions than an industrial source project.

For example, an HRA was conducted for the Phillips 66 Wilmington refinery facility in the City of Wilmington, California, which generates TAC emissions from oil refinery operations and associated industrial processes and determined a 30-year residential risk at nearby residential receptors located adjacent to the east of the facility of

33.8 in one million. The Phillips 66 Wilmington facility analysis included age sensitivity factors. Unlike the Phillips 66 Wilmington facility, which generates long- term ongoing emissions from its continuous industrial operations, construction of the Project would not generate DPM emissions on an ongoing and continuous basis over a lifetime (70- year) or a residential exposure duration (30 years). Operation of the Project woul d generate a relatively small amount of ongoing operational DPM emissions from a minimal number of diesel-fueled vehicles (e.g., delivery trucks), as compared to an industrial oil refinery facility that has numerous heavy -duty industrial- sized equipment and industrial processes. Thus, the unexpectedly high results reported in SWAPE's screening- 11469 Jefferson Boulevard Project
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level HRA do not appear to be credible whatsoever and mislead the public and decision-makers as to the human health risks associated with the Project's DPM emissions.

In addition, upon further examination of the data, the screening- level HRA has several significant flaws that account for the misleading and incorrect analysis and explain the unrealistically high results. The first flaw is that SWAPE used incorrect and non- representative construction emissions to determine health risk impacts (discussed above related to their “updated” model in Comment 9-20).

The second flaw is that SWAPE assumed the Project's "operational activities will generate approximately 45 pounds of diesel particulate matter ("DPM") per year (Exhibit B, page 21). SWAPE calculated this value by multiplying the total daily exhaust PM10 emissions by 365 days per year. The total exhaust PM10 includes all area, energy, and mobile source exhaust PM10 emissions in the CalEEMod operational output files. This is not a valid assumption. SWAPE incorrectly assumed the 45 pounds of exhaust PM10 emissions were the result of diesel fuel combustion. In fact, only a small portion of these operational emissions are DPM. In reality, most of the area and energy exhaust PM10 emissions are the result of gasoline- fueled landscaping equipment and natural gas combustion for building heating and cooking. Similarly, the operational mobile source exhaust PM10 emissions are from a combination of primarily gasoline- fueled vehicles, such as passenger vehicles and light - duty pick-up trucks, and a smaller number of diesel -fueled trucks. These details were provided in the vehicle fleet percentages in the CARB on- road vehicle emissions factor (EMFAC) model, as well as further detailed in the operational HRA attached in response to the comments above. It is highly inappropriate and factually incorrect to analyze non- diesel fuel exhaust PM10 emissions as diesel particulate matter. Thi s results in substantially overestimated and, therefore, unrealistically high health risk impacts.

The third flaw is that SWAPE's screening-level HRA modeled all of the DPM emissions from mobile sources as if the emissions were occurring at a single locat ion. This was also improper because mobile sources, by their very nature, do not generate emissions at a single location but rather along the entire vehicle trip, which would disperse the emissions along regional roadways and not concentrate the emissions at a single location. The trip lengths vary between 5.9 and 16.6 miles and therefore all the vehicle emissions would not emit from a single point. When conducting HRAs, dispersion of pollutants is a critical and important consideration because health risk impacts are a direct result of TAC concentrations. The screening operational HRA incorrectly assumed that all mobile source emissions would occur at a single location, which results in concentrations at sensitive receptors that are artificially elevated to highly unreasonable levels (like that of a hotel having higher risk than a large refinery).

In addition, it is worthwhile to note the technical limitations in the model SWAPE used. As stated above, SWAPE "relied upon AERSCREEN which is a screening level air quality dispersion model". AERSCREEN assumes calm wind conditions at all times and a stable atmosphere (i.e., no atmospheric mixing) and does not have the capability to incorporate locally measured wind speed and wind direction data. Thus, AERSCREEN does not account for the dispersion of pollutants that occurs from wind. This is a significant limitation because wind directed away from sensitive receptor locations relative to a source of emissions would disperse pollutants away from sensitive receptors and thereby reduce the impact of TAC emissions on those receptors. Because the AERSCREEN model fails to account for local wind speed and wind direction, its application results in artificially elevated pollutant concentrations at sensitive receptors and, therefore, artificially elevated health risk levels. The wind rose presented in the operational HRA files provided in Appendix B of this Final MND shows that the highest wind speeds occur in directions away from the nearby sensitive receptors, thus produc ing lesser impacts than those produced by AERSCREEN.

For all of these reasons, SWAPE's health risk results are highly misleading and inaccurate and lack credibility.

In other words, SWAPE's conclusions are not supported by any credible evidence, much less substantial 11469 Jefferson Boulevard Project
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evidence. Even SWAPE acknowledged the serious limitations in its screening -level study, stating (actually, understating) that "[o]ur analysis represents a screening-level HRA, which is known to be conservative and tends to err on the side of health protection." Thus, the MND accurately evaluated the Project’s health risks to sensitive receptors during construction and operation and the preparation of an EIR is not required.

Comment No. IND 9-28
E. The MND Fails to Adequately Assess Greenhouse Gas Impacts SWAPE concluded that the MND failed to adequately analyze the Project’s greenhouse gas (“GHG”) impacts. (Ex. B, p. 24.) Although the MND calculated the Project’s annual GHG emissions as 1,537 metric tons of carbon dioxide equivalents per year (“MT CO2e/yr”), the MND failed to compare the Project’s emissions to any objective threshold. (Id. at pp. 24, 27.) Furthermore, the MND’s calculation for 1,537 MT CO2e/yr was based on an inaccurate air model, as discussed above, and likely underestimated. (Id. at p. 26.) However, assuming that the Project’s 1,537 MT CO2e/yr is accurate, the Project exceeds the proper threshold of 2.6 MT CO2e/SP/year. (Id. at pp. 27-28.) SWAPE concluded that the exceedance of this threshold results in a significant GHG impac t not previously identified or addressed by the MND. (Id. at p. 28.) Therefore, an EIR must be prepared and mitigation must be implemented where necessary. SWAPE provided several mitigation measures that could be implemented to mitigate the Project’s significant GHG impact. (Id. at pp. 32-39.) Response to Comment No. IND 9-28
The Draft MND included a quantified analysis of GHG emissions. As discussed in Response to Comment Nos.

IND 9-9 through IND 9- 20, the air modeling emissions are sufficiently analyzed. As shown in Table D -2 in Response to Comment No. IND 9- 9, the change in the Project’s emissions from the correction to the parking structure square footage would be very minimal (less than a 3 percent change in annual GHG emissions), would not be substantial and would not in any way result in conflicts with GHG reduction plans, policies, or regulations.

No new impacts or substantially greater impacts would occur. Therefore, the Project’s construction-related and operational emissions can be relied upon to determine Project significance and no new analysis is required.

Regarding the significance threshold, as stated in the Draft MND (refer to pages B -33 through B-36), “the City has not yet adopted a numerical significance threshold for assessing impacts related to GHG emissions and has not formally adopted a local plan for reducing GHG emission. When no guidance exists under CEQA, the lead agency may look to and assess general compliance with comparable regulatory schemes. 13”. Pursuant to
Section 15064.4(a) of the CEQA Guidelines, the lead agency has the discretion, with respect to a project's GHG emissions, to (1) quantify GHG emissions and/ or (2) rely on a quantitative analysis or performance- based standards. Section 15064.4(b)(3) of the CEQA Guidelines further provides that, in determining whether a project's GHG impact is significant, the lead agency should consider "[t]he extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of greenhouse gas emissions," as well as "a project's consistency with the State's long-term climate goals or strategies." SWAPE engages in the pretense that a quantitative analysis is required.

13 See Protect Historic Amador Waterways v. Amador Water Agency (2004) 116 Cal. App. 4th 1099, 1107 [“‘[A] lead agency’s use of existing environmental standards in determining the significance of a project’s envir onmental impacts is an effective means of promoting consistency in significance determinations and integrating CEQA environmental review activities with other environmental program planning and resolution.”’”]. Lead agencies can, and often do, use regulatory agencies’ performance standards. A project’s compliance with these standards usually is presumed to provide an adequate level of protection for environmental resources. See, e.g., Cadiz Land Co. v. Rail Cycle (2000) 83 Cal.App.4th 74, 99 (upholding use of regulatory agency performance standard). 11469 Jefferson Boulevard Project
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The Draft MND includes, an 8-page analysis which demonstrates that the Project would be consistent with the applicable plans, policies and regulations adopted by the State and the City for the purpose of reducing GHG emissions, including the emissions reduction measures discussed within CARB’s Climate Change Scoping Plan, SCAG’s 2020-2045 RTP/SCS, and City of Culver City polices established for the purpose of increasing energy efficiency and reducing GHG emissions for new developments and the City’s Green Building Code. The Draft MND therefore concluded that the Project would not conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of GHGs and the Project's GHG impact would be less than significant (see pages B-39 through B-47 of the Draft MND). Since the Project’s GHG impact is less than significant, no mitigation measures are required and an EIR is not required.

Comment No. IND 9-29
Additionally, the MND relied upon the Project’s consistency with the CARB’s Scoping Plan, SCAG’s RTP/SCS, the City’s energy efficiency policies, and the City’s Green Building Code in order to conclude that the Project would have a less-than-significant GHG impact. (Ex. B, p. 25.) However, these regulatory plans do not meet the criteria for an officially adopt ed GHG reduction program, commonly referred to as a Climate Action Plan (“CAP”), for use as a threshold of significance for GHG emissions. (Ex. B, p. 26.) As CEQA Guideline section 15064.4(b)(3) makes clear, a qualified CAP “must be adopted by the relevant public agency through a public review process,” and, as explained by CEQA Guideline section 15183.5(b)(1), the CAP should include:
(1) Inventory: Quantify GHG emissions, both existing and projected over a specified time period, resulting from activities (e.g., projects) within a defined geographic area (e.g., lead agency jurisdiction); (2) Establish GHG Reduction Goal: Establish a level, based on substantial evidence, below which the contribution to GHG emissions from activities covered by the plan would not be cumulatively considerable; (3) Analyze Project Types: Identify and analyze the GHG emissions resulting from specific actions or categories of actions anticipated within the geographic area; (4) Craft Performance Based Mitigation Measures: Specify measures or a group of measures, including performance standards, that substantial evidence demonstrates, if implemented on a project -by-project basis, would collectively achieve the specified emissions level; (5) Monitoring: Establish a mechanism to monit or the CAP progress toward achieving said level and to require amendment if the plan is not achieving specified levels; and Here, the MND fails to demonstrate that the CARB’s Scoping Plan, SCAG’s RTP/SCS, the City’s energy efficiency policies, and the City’s Green Building Code include the above- listed requirements to be considered a qualified CAP for the City. Furthermore, the MND failed to consider performance -based standards under CARB’s Scoping Plan (Ex. B, pp. 28-30) and SCAG’s RTP/SCS (id. at pp. 30-32). As such, the MND leaves an analytical gap and fails to demonstrate that compliance with said plans can be used for project-level significance determination. (Ex. B, p. 27.)
Response to Comment No. IND 9-29
SWAPE erroneously conflates a GHG reduction plan with a Climate Action Plan. As discussed in the Draft MND and Greenhouse Gas Technical Report (November 2020), per CEQA Guidelines Section 15064(h)(3), a project’s incremental contribution to a cumulative impact can be found not cumulatively considerable if the project will 11469 Jefferson Boulevard Project
April 2021
Attachment D – Responses to Comments

D-59

comply with an approved plan or mitigation program that provides specific requirements that will avoid or substantially lessen the cumulative problem within the geographic area of the project. 14 To qualify, such a plan or program must be specified in law or adopted by the public agency with jurisdiction over the affected resources through a public review process to implement, interpret, or make specific the law enforced or administered by the public agency.15 Examples of such programs i nclude a “water quality control plan, air quality attainment or maintenance plan, integrated waste management plan, habitat conservation plan, natural community conservation plan, [and] plans or regulations for the reduction of greenhouse gas emissions.”16 Therefore, CEQA Guidelines Section 15064(h)(3) allows a lead agency to make a finding of non -significance for GHG emissions if a project complies with the California Cap- and-Trade Program or other regulatory schemes to reduce GHG emissions. While a qualified CAP is considered a GHG reduction plan that can be used to determine project significance, it is by no means the only type of GHG reduction plan that can be used. As stated in response No. IND 9-28 above, the City has not adopted a numeric threshold and has not developed a qualified CAP. In the absence of both, the lead agency may assess general compliance with comparable regulatory schemes. The Project would be consistent with the applicable plans, policies and regulations adopted by the State and the C ity for the purpose of reducing GHG emissions, including the emissions reduction measures discussed within CARB’s Climate Change Scoping Plan, SCAG’s 2020-2045 RTP/SCS, and City of Culver City polices established for the purpose of increasing energy effici ency and reducing GHG emissions for new developments and the City’s Green Building Code. Therefore, the analysis in the Draft MND and supporting Greenhouse Gas Technical Report , which was prepared to inform the findings in the Draft MND and was provided by the City alongside the Draft MND are consistent with the State CEQA Guidelines and no further analysis or response is warranted.

Comment No. IND 9-30
F. The MND’s Mitigation for Hazards and Hazardous Materials is Inadequate.

In order to mitigate the Project’s significant impacts related to hazardous materials, the MND required MM-HAZ-

1. MM-HAZ-1 requires a qualified environmental consultant to prepare a Soil Management and Remediation Plan and “[u]pon completion of the Soil Management and Remediation Plan, the Applicant shall contact the LARWQCB to obtain a closure letter that states no further soils testing or remediation is required on the Project Site.” (MND, p. B-50.) However, the MND fails to disclose that MND the recent status of the site in Geotrac ker, which concludes there are two impediments to closure: (1) free product in groundwater; and (2) threat for vapor intrusion. (Ex. B, p. 2.) Without disclosing and accounting for these impediments to closure, the MND fails to provide substantial evidence that MM-HAZ-1 would reduce the Project’s impacts to a less-than-significant level.

Response to Comment No. IND 9-30
This comment asserts that the MND fails to disclose the Project’s status on Geotracker which concludes there are two impediments to closure: (1) free product in groundwater; and (2) threat for vapor intrusion. Contrary to the comment, page B -51 of the MND states “ the Project Site is identified on the list of Open Active Leaking Underground Storage Tank Sites from the State Water Board’s GeoTracker database.” Further, page B-49 of the MND indicates that, “Because of the contaminated soils, groundwater and potentially vapors to occur beneath the Project Site, project implementation could result in a potentially significant impact or hazard to the public or

14 14 CCR § 15064(h)(3).
15 Ibid.
16 Ibid. (emphasis added).
11469 Jefferson Boulevard Project
April 2021
Attachment D – Responses to Comments

D-60

the environment during excavation activities. ” Thus, potential groundwater impacts and vapor intrusion are identified within the impact analysis for hazardous materials.

The analysis on pages B-48 to B-50 of the Draft MND is clear that under the Project, site remediation overseen by the RWQCB would occur following the abatement and demolition of existing on improvements. This would include the excavation of hydrocarbon -impacted soils, and other groundwater management associated with remediation. During remediation activities, the site would be remediated to levels deemed acceptable for commercial use pursuant to all applicable regulatory standards. Based on the extent of contamination identified in the RAP, it is anticipated that approximately 1,000 cubic yards of hydrocarbon-impacted soil would be exported from the site as part of remediation activities, which is less than 2% of the anticipated excavation. The Draft MND’s Mitigation Measure MM-HAZ-1 requires the Applicant to retain a qualified environmental consultant to prepare a Soil Management and Remediation Plan (SMRP) for review and approval by the Culver City Building Safety Division, DTSC and LARWQCB, as necessary, prior to the commencement of excavation and grading activities. Mitigation Measure MM-HAZ-1 has been modified to clarify that the SMRP would include a plan for (i) removal, characterization, and offsite disposal, and/or (ii) remediation of hydrocarbon impacted soils to a level determined by the LARWQCB to be acceptable for commercial use, in compliance with all applicable rules and regulations. The SMRP would also include a plan for treatment and/or remediation of hydrocarbon impacted groundwater to a level determined acceptable for commercial use, in compliance with all applicable rules and regulations, including any relevant guidance on vapor intrusion from the LARWQCB and/ or DTSC. The SMRP will be conducted under supervision of a certified environmental consultant licensed to oversee such remediation.

This mitigation measure can reasonably be expected to avoid or reduce a potential significant impact from underlying hazardous materials and is enforceable by identifying the timing of the SMR P implementation and requirement to obtain a closure letter from the LARWQCB and DTSC (as necessary) that states no further soils testing or remediation is required on the Project Site. Effectively, with the SMRP requiring remediation to comply with all applicable regulatory standards and a closure letter from LARWQB and DTSC (as necessary) being required, these performance criteria would ensure that impacts from remediation of hazardous materials below the site are less than significant. Rather, by requiring remediation of subsurface contamination, this mitigation measure ensures a net benefit to the environment. The requirement for DTSC to review and approve the SMRP and issue a closure letter, in addition to the LARWQCB, has been added to Mitigation Measure HAZ- 1 in this Final MND.

Comment No. IND 9-31
SWAPE also noted tha t MND failed to disclose contamination on the Project site because the extent of contamination is not known. (Ex. B, p. 2.) As a result, the MND failed to identify impacts of remediation because:
“(1) an informed estimate of the amount of soil to be excavated has not been made, therefore construction impacts for excavation and truck trips for proper disposal have not been estimated; and (2) magnitude of groundwater plume and vapor intrusion impacts have not been determined – these will result in impacts including construction and operation emissions associated with groundwater investigations, well drilling, and groundwater pumping and treatment system installation and operation.” (Id.) Without disclosing and accounting for the extent of contamination and the impacts of remediation, the MND fails to provide substantial evidence Project’s impacts related to hazards and hazardous materials are less-than-significant.

Response to Comment No. IND 9-31
The Comment asserts that “the extent of contamination is not known.” Contrary to the comment, the RAP concluded that adsorbed-phase and dissolved- phase hydrocarbon impacts are “considered to be adequately delineated.” (RAP, section 3.) Based on the technical studies to date, including the previous site assessments outlined in Section 2.5 of the RAP, and as discussed in Response to Comment IND-9-30 and as stated on page 11469 Jefferson Boulevard Project
April 2021
Attachment D – Responses to Comments

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B-48 of the MND, it is anticipated that approximately 1,000 cubic yards of hydrocarbon- impacted soil would be exported from the site as part of remediation activities, which is less than 2% of the total anticipated excavation.

The extent of these daily truck trips would be well within the number of daily trips analyzed as part of grading/excavation activities for the Project on a peak day, which estimated up to 59 trucks (118 truck trips) in a day. These trips have also been assumed as part of the Project’s overall extent of excavation, which is over 48,000 cubic yards of soil (including the estimated 1,000 cubic yards of impacted soil) . Thus, maximum daily emissions associated with haul trucks as a result of remediation activities would be subsumed within the maximum daily emissions during typical Project construction excavation activities. Further, the heavy -duty equipment used for the remediation activities would be similar to or less than the total horsepower rating for the equipment already analyzed during the grading/excavation activities for the Project, which included a concrete/industrial saw, excavator, rubber -tired dozer, and two tracto rs/loaders/backhoes. Therefore, the emissions analysis fully accounts for the remediation activities.

Comment No. IND 9-32
IV. CONCLUSION
For the foregoing reasons, the MND for the Project should be withdrawn, an EIR should be prepared, and the draft EIR should be circulated for public review and comment in accordance with CEQA. Thank you for considering these comments.

Response to Comment No. IND 9-32
Responses to all comments have been addressed in Response to Comment Nos. IND 9-1 to IND 9-32. Based on the responses therein, the Draft MND environmental analysis was sufficient to meet CEQA requirements and no substantive deficiencies were identified that require preparation of an Environmental Impact Report.

Appendix A

Original C
o
mment
Letters

“
Provide a safe, sustainable, integrated and efficient transportation system to enhance California’s economy and livability”
STATE OF CALIFORNIA------- CALIFORNIA STATE TRANSPORTATION AGENCY Gavin Newsom, Governor

DEPARTMENT OF TRANSPORTATION
DISTRICT 7 – Office of Regional Planning
100 S. MAIN STREET, MS 16
LOS ANGELES, CA 90012
PHONE (213) 897-0475
FAX (213) 897-1337
TTY 711
www.dot.ca.gov
Making Conservation
a California Way of Life.

Febr
uary 18, 2021
Li
sa Edwards
City of Culver City
9770 Culver Boulevard
Culver City, CA 90232
RE
: 11469 Jefferson Boulevard Project –
Mitigated Negative Declaration (MND)
SCH # 2021010247
GTS # 07-LA-2021-03483
Vic. LA-90/PM: 2.748
D
ear Lisa Edwards:

T
hank you for including the California Department of Transportation (Caltrans) in the environmental review process for the above referenced MND. The Project would redevelop a 33,813 square foot (SF) property located in the northwest corner of the Jefferson Boulevard and Slauson Avenue intersection in Culver City. The existing single-story commercial building and parking lot would be removed as part of the Project.

The Project includes the development of a new, five-story, 175-room boutique hotel building with food and beverage amenities and a two level, below -grade parking garage. Specifically, the 111,000 SF building would provide a total of approximately 67,030 SF in 175 hotel rooms, 8,536 SF of back of -house uses, 14,783 SF of hotel amenities, 630 SF of bicycle parking, 18,842 SF of circulation facilities, and 1,119 SF of loading area. In addition, 15,450 SF of open space area would be provided, as well as 56,300 SF of subterranean parking that would accommodate a minimum of 138 parking spaces. The City of Culver City is the Lead Agency under the California Environmental Quality Act (CEQA).

T
he project is located approximately 1,000 feet away from the State Route 90 and Interstate 405 interchange. From reviewing the MND, Caltrans has the following comments . As mentioned in the document, Senate Bill 743 (2013) mandates that Vehicle Miles Traveled ( VMT) be used as the primary metric in identifying transportation impacts of all future development projects under CEQA, starting July 1, 2020. Since this implementation deadline has passed, Caltrans has reviewed this project from a VMT rather than a Level of Service (LOS) perspective.

For
information on determining transportation impacts in terms of VMT on the State Highway System, see the Technical Advisory on Evaluating Transportation Impacts in CEQA by the California Governor’s Office of Planning and Research (OPR), dated December 2018: http://opr.ca.gov/docs/20190122- 743_Technical_Advisory.pdf. The City can also refer to Caltrans’ updated Vehicle Miles Traveled-Focused Transportation Impact Study Guide (TISG), dated May 2020: https://dot.ca.gov/-/media/dot- media/programs/transportation-planning/documents/sb-743/2020-05-20-approved-vmt-focused-tisg- a11y.pdf. Caltrans’ new TISG is largely based on the OPR 2018 Technical Advisory.

D
ue to the release of these guides, Caltrans no longer refers to the following agreements mentioned in the MND: the October 2013 Agreement Between the City of Los Angeles and Caltrans District 7 on Freeway Impact Analysis Procedures , and the December 2015 First Amendment to the Agreement

Lisa Edwards
February 18, 2021

Page 2 of 2 ends

“
Provide a safe, sustainable, integrated and efficient transportation system to enhance California’s economy and livability”
between LADOT and Caltrans District 7 on Freeway Impact Analysis Procedures.

Regar
ding VMT, the MND states “Given the Project’s proximity (approximately one block) to the Westfield‐ Culver City Transit Center, the City considers the Project site to be in a key TPA [Transit Priority Area].

Therefore, based on the key TPA screening threshold, the Project is presumed to have a less ‐than‐ significant VMT impact and no further VMT analysis is required.” The OPR Technical Advisory states that a presumption of less‐than‐significant VMT impact may not apply if the project includes more parking for use by residents, customers, or employees of the project than required by the jurisdiction. Thus, in the final MND please confirm that the project will not include more parking than required. For example, please state the maximum rather than the minimum number of parking spaces that will be provided.

I
n addition, encroachment permits are required for any work performed on or near Caltrans’ right of way.

Such permits might be needed for the installation of closed- circuit television cameras at the Jefferson Boulevard & 1-405 Northbound Ramps intersection. However, Caltrans’ Office of Permits will make the final determination on this. Also, the MND states that the project applicant will contribute a fixed- fee financial contribution toward funding these improvements. In the final MND, please clarify which entity will be asked to pay the balance of the needed funding.

T
he following information is included for your consideration. The mission of Caltrans is to provide a safe, sustainable, integrated and efficient transportation system to enhance California’s economy and livability.

Furthermore, Caltrans encourages Lead Agencies to implement Transportation Demand Management (TDM) strategies that reduce VMT and Greenhouse Gas (GHG) emissions. Thus, Caltrans supports this project implementing a TDM plan. For specific TDM options to include in this plan, please refer to:
• The 2010 Quantifying Greenhouse Gas Mitigation Measures report by the California Air Pollution Control Officers Association (CAPCOA), available at http://www.capcoa.org/wp- content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf, or • Integrating Demand Management into the Transportation Planning Process: A Desk Reference (Chapter 8) by the Federal Highway Administration (FHWA), available at https://ops.fhwa.dot.gov/publications/fhwahop12035/index.htm .

Also, any transportation of heavy construction equipment and/or materials which requires use of oversized-transport vehicles on State highways will need a Caltrans transportation permit.

Caltrans supports the following measure: “Dirt hauling and construction material deliveries or removal would not be allowed during morning (7:00 AM – 9:00 AM) and afternoon (4:00 PM – 6:00 PM) peak traffic periods.” If construction traffic is expected to cause delays on any State fac ilities, please submit the Construction Management Plan detailing these delays for Caltrans’ review.

If you have any questions about t hese comments, please contact Emily Gibson, the project coordinator, at [email protected], and refer to GTS # 07-LA-2021-03483.

Sincerely,
M

IYA EDMONSON
IGR/CEQA Branch Chief
cc: Scott Morgan, State Clearinghouse

2/22/2021 Mail - Edwards, Lisa - Outlook
https://outlook.office365.com/mail/deeplink?popoutv2=1&version=20210215002.03 1/1 Re: 11469 Jefferson Blvd project
Samia Rafeedie <[email protected]>
Tue 2/9/2021 10:20 AM
To: Edwards, Lisa <[email protected]>
Thanks Lisa! Appreciate that,Samia.

Sent from my iPhone
On Feb 9, 2021, at 10:15 AM, Edwards, Lisa <[email protected]> wrote:

Hi Ramez,
Thank you for your input. I will forward your concerns to our environmental team for incorporaon into the MND.

From: Ramez Ethnasios <[email protected]> Sent: Wednesday, January 27, 2021 9:41 AM To: Edwards, Lisa <[email protected]> Cc: Samia Rafeedie <[email protected]> Subject: 11469 Jeﬀerson Blvd project Dear Lisa Edwards, On behalf of my wife, Samia Rafeedie, I would like to submit these comments regarding the above entitled project.

We are resident owners of a house on Segrell Way and have reviewed the Traffic Impact Study dated 10-19-2020.

I have concerns regarding the traffic intrusion and parking mitigation measures. It appears there are not any current actions planned formitigating potential disruptions in our street and parking situation on Segrell Way. We have concerns that without proper deterrents in placethat traffic will increase and cars will freely park in front of our house. We do not want to wait for such a time in the future when this willoccur to start the process with the city, wait for whatever studies to be done, then get whatever measures in place.

Thinking about the amount of parking spots the hotel will have, the 120 full and part time employees, and guests, one would surely guessthat a number of these persons will seek to park in the adjacent street for a variety of reasons. For employees, there may be limits in theparking spaces and for guests they may not want to pay whatever nightly parking fees.

Please expedite the process for: -peak period turn restrictions at certain intersections as noted on page 86 of the traffic impact study, and -begin the process to expand the residential parking permit program on Segrell way.

Please feel free to contact me as needed and I would like an update about any mitigation of our traffic intrusion and parking concerns relatedto the hotel project in 11469 Jefferson Blvd. Ramez Ethnasios 818-231-6601 And Samia Rafeedie Segrell Way residents

The City of Culver City keeps a copy of all E-mails sent and received for a minimum of 2 years. All retained E-mails will be treated as a Public Record per the California Public Records Act, and may be subject to disclosure pursuant to the terms, and subject to the exemptions, of that Act. 2/22/2021 Mail - Edwards, Lisa - Outlook
https://outlook.office365.com/mail/deeplink?popoutv2=1&version=20210215002.03 1/1 Re: Jeff Hotel: Public Hearing?
Jonah Breslau <[email protected]>
Fri 2/19/2021 9:39 AM
To: Edwards, Lisa <[email protected]>
Thank you for the update!
Take care,Jonah
On Wed, Feb 17, 2021 at 6:23 PM Edwards, Lisa <[email protected]> wrote: Hi Jonah, My apologies for the delay. We were sll coordinang with the applicant regarding a tentave Planning Commission hearing date. As of late, thisproject is scheduled to be heard at the March 10th meeng.

From: Jonah Breslau <[email protected]> Sent: Thursday, February 4, 2021 1:46 PM To: Edwards, Lisa <[email protected]> Subject: Jeﬀ Hotel: Public Hearing? Hi Ms. Edwards, My name is Jonah Breslau. I am a research analyst at LAANE (https://laane.org/). I was wondering if there will be a public hearing for the Jeff Hotelproject at 11469 Jefferson Boulevard Project (P2019-0194-SPR P2019-0194-CUP P2019-0194-AUP). If so, when would it be? Thank you,Jonah Breslau -- Jonah BreslauHe/him/hisResearch AnalystLos Angeles Alliance for a New Economy (LAANE)[email protected]:773 603 5174

The City of Culver City keeps a copy of all E-mails sent and received for a minimum of 2 years. All retained E-mails will be treated as a Public Record per the California Public Records Act, and may be subject to disclosure pursuant to the terms, and subject to the exemptions, of that Act. 2/22/2021 Mail - Edwards, Lisa - Outlook
https://outlook.office365.com/mail/deeplink?popoutv2=1&version=20210215002.03 1/1 RE: The Jeff Hotel project
Jay Coury <[email protected]>
Tue 2/9/2021 10:52 AM
To: Edwards, Lisa <[email protected]>
Thank you Lisa Jay CouryPresidentPremier World Discovery From: Edwards, Lisa <[email protected]> Sent: Tuesday, February 9, 2021 10:23 AM To: Jay Coury <[email protected]> Subject: Re: The Jeﬀ Hotel project Hi Jay, Thank you for your input. I will forward your concerns to our environmental team for incorporaon into the MND. I will contact the developer to see if we can electronically send a rendering of the project for you.

From: Jay Coury <[email protected]> Sent: Thursday, February 4, 2021 12:30 PM To: Edwards, Lisa <[email protected]> Subject: The Jeﬀ Hotel project Hello Ms. EdwardsI reside at 11430 Segrell Way, CC and was wondering if there is a rendering of the project available see view? While I am in favor of the project, living where I do, Iwonder if guests on top ﬂoor will get a view into my yard. I am excited that the project will bring aenon to the alley which has become a causeway for speeding andonce the two bars re-open on Jeﬀerson, the alley becomes something quite diﬀerent. Thank you in advance for your reply. Jay CouryPresidentPremier World Discovery

The City of Culver City keeps a copy of all E-mails sent and received for a minimum of 2 years. All retained E-mails will be treated as a Public Record per the California Public RecordsAct, and may be subject to disclosure pursuant to the terms, and subject to the exemptions, of that Act. 2/22/2021 Mail - Edwards, Lisa - Outlook
https://outlook.office365.com/mail/deeplink?popoutv2=1&version=20210215002.03 1/1 Re: Culver City needs more affordable housing!!!!!!!
Edwards, Lisa <[email protected]>
Tue 2/9/2021 10:41 AM
To: DiaryofTieira Ryder <[email protected]>
Hi Tieira,
Thank you for your input. I will forward your concerns to our environmental team for incorporaon into the MND.

From: DiaryofTieira Ryder <[email protected]> Sent: Friday, February 5, 2021 12:20 PM To: Edwards, Lisa <[email protected]> Subject: Culver City needs more aﬀordable housing!!!!!!! Culver City and all of the Westside cities should be coordinating better to create more affordable housing for long term, working class residents, students,seniors, those living with disabilities and others! The video attached is not OK, the number of unhoused residents has increased by over 50% in the last 10years in LA! Best, Tieira
2/22/2021 Mail - Edwards, Lisa - Outlook
https://outlook.office365.com/mail/deeplink?popoutv2=1&version=20210215002.03 1/1 Re: New Proposed Project At 11469 Jefferson Blvd. From David@FIRE. 1-21-21 Edwards, Lisa <[email protected]>
Tue 2/9/2021 10:14 AM
To: David Steinitz <[email protected]>
Hi David,
Thank you for your input. I will forward your concerns to our environmental team for incorporaon into the MND.

From: David Steinitz <david@ﬁreltd.com> Sent: Thursday, January 21, 2021 11:29 AM To: Edwards, Lisa <[email protected]> Subject: New Proposed Project At 11469 Jeﬀerson Blvd. From David@FIRE. 1-21-21 Dear Ms. EdwardsI live closer to Barryman on Segrell Way and I do not have any real issues with this new project other that it seng a strong precedence for 5 story structures aroundmy area.Also having lived in the neighborhood for a long me I do not believe the developer has seriously considered the 24 hour traﬃc noise from the elevated freeway. Noone is going to want to sit on a roof deck when the ambient noise level is high and as far up the street as I am , I am constantly cleaning up the black soot from thefreeway and as close as they will be it will be a constant issue. I am a lighng consultant for the last 42 years with my own company and I have a number of these typeof structures I am retained by to do their lighng and energy management designs and having city’s like Bellﬂower and Azusz as clients I see a lot of bad designs buteven worse locaons and this one only has a fair chance of survival what with all the other new hotels compeng for the bed use.I realize this may take more than another year to break ground and maybe the economic environment will make more sense but this project seems to be asking morethan it can jusfy in ﬁnancial return and I for 1 would not like to see another large space like the Lowes building sing empty or abandoned.Just my concerned 2 cents.As a side note I would love to see the power lines in the double wide alley converted to underground if there is ever a way to do it.Your concerned cizen, David Steinitz C/OF.I.R.E./L.T.D.12035 W. Jefferson Blvd.Los Angeles, CA. 90230-6219Ph 424.835.4769Fx 424.835.4765www.FIRELTD.comServing all your lightingneeds for over 41 years. 2/22/2021 Mail - Edwards, Lisa - Outlook
https://outlook.office365.com/mail/deeplink?popoutv2=1&version=20210215002.03 1/1 RE: 11469 Jefferson Boulevard Project
[email protected] <[email protected]>
Wed 2/10/2021 6:11 PM
To: Allen, Michael <[email protected]>Cc: Edwards, Lisa <[email protected]> Hi Michael,Thank you for your comments. The 56 foot height limit does allow for minor mechanical equipment (roof HVAC equipment) but not for a full doorway to get on theroof. It is strictly allowed to have equipment such as a few feet allowance for elevator to hit the top ﬂoor but not for roof access. Thank you,Robin From: Allen, Michael <[email protected]> Sent: Wednesday, February 10, 2021 5:23 PM To: [email protected] Cc: Edwards, Lisa <[email protected]> Subject: Re: 11469 Jeﬀerson Boulevard Project Good aernoon Ms. Turner, Thank you for providing the below comment regarding the 11469 Jeﬀerson Blvd. Project. Based on our analysis, the building is compliant with the 56'height limitaon, as well as the allowances for mechanical equipment and the elevator sha. We will connue to evaluate this as we work through the currently available MND, and project analysis as we prepare for any upcoming public hearings. Best, Michael Allen, AICPPlanning ManagerCity of Culver City, Current Planning Division9770 Culver BoulevardCulver City, CA 90232Ph: 310.253.5727 From: [email protected] Date: February 10, 2021 at 5:12:05 PM EST To: "Edwards, Lisa" <[email protected]> Subject: 11469 Jeﬀerson Boulevard Project Good Aernoon Ms. Edwards,I would like to comment on the 11469 Jeﬀerson Boulevard Project. The Project has been designed to be 5 stories in height. This clearly violates theMeasure 1 Height Iniave maximum limit that was voted on by the voters of Culver City in 1988. There are no variances or condions that would allowthis or any other building to be built over the 56 feet limit. An elevator sha is not allowed above the 56 foot limit. There are no variances allowed forthat. 56 feet is 56 feet. Period! By building this Project, the City of Culver City will be violang the law. In fact, ANY NEW 5 STORY BUILDING OVER 56 FEETIN CULVER CITY IS IN DIRECT VIOLATION OF THE LAW!!!!!!!!!!Thank you,Robin Turner10650 Drakewood Ave.Culver City,CA 90230(424) 248-3316 o(310) 915-4536 c

February 11, 2021

VIA EMAIL:

Lisa Edwards, Contract Planner
City of Culver City Current Planning Division
9770 Culver Boulevard
Culver City, CA 90232
[email protected]

RE: 11469 JEFFERSON BOULEVARD PROJECT IS/MND COMMENTS

Dear Ms. Edwards:

On behalf of UNITE HERE Local 11 and its members (collectively “Local 11”), this Office provides the City of Culver City (“City”) the following comments1 regarding the Initial Study/Mitigated Negative Declaration (“IS/MND”) for the above-referenced five-story, 175-room hotel development (“Project”) located on a 33,813 square foot (“SF”) site located at the northwest corner of the intersection at Jefferson Boulevard and Slauson Avenue (“Site”).

1. VMT ANALYSIS IS LACKING

Citing the VMT guidance provided by the Governor’s Office of Planning and Research (“OPR”), the IS/MND presumed the Project’s VMTs would be less than significant merely because the Site is near a transit priority area. (MND, p. B-105; IS/MND Traffic Study, pp. iv, 74-75.) However, OPR states explicitly that this “presumption would not apply, however, if project-specific or location-specific information indicates that the project will still generate significant levels of VMT.”2 Project-specific information that indicates a significant VMT includes the following:

1 Please note that pages cited herein are either to the page’s stated pagination (referenced herein as “ p. ##”) or the page’s location in the referenced PDF document (referenced herein as “ PDF p. ##”). 2 OPR (Dec. 2018) Technical Advisory: On Evaluating Transportation Impacts In CEQA, pp. 13 -14, https://opr.ca.gov/docs/20190122-743_Technical_Advisory.pdf. 11469 Jefferson Boulevard Project: MND Comments
February 11, 2021

Page 2 of 4 ends

i. The Project would generate 1,463 trips per day compared to the exiting 376 trips per day (IS/MND, p. B-92)—a net increase of 1,087 trips—which exceeds OPR’s small project screening threshold of 110 trips.3 So too, this increase would exceed the 250-trip screening threshold proposed under the City’s Draft Transportation Study Criteria Guidelines.4 ii. The IS/MND’s GHG Study shows the Project would generate 3.490 million annual VMTs as compared to the existing 0.636 million annual VMTs (GHG Study, PDF pp. 169, 224), which is more than a fivefold increase and exceeds OPR’s no net increase threshold for redevelopment projects.5
iii. No less than nine hotels/lodging are within 1.5 miles of the Project Site,6 suggesting the Site is hotel-rich and that the Project will not provide an alternative for hotel patrons that would otherwise be commuting from longer distances. Adding more hotels in a hotel-rich area will not further smart/mixed-use development.
iv. The existing uses are local serving retail (e.g., restaurants, nails salon, dentist, golf, flowers, etc.) (IS/MND Remedial Action Plan [“RAP”], PDF p. 52 [Fig. 2]), which provide convenient access to nearby residents that do not need to use a vehicle to access these services. In contrast, the Project is a hotel development, which is regional in nature and displaces these local services. Hence, the Project may induce further VMTs by individuals no longer able to access these local services without entering their vehicles. v. The City acknowledges that hotels generate large amounts of visitors that may access the site via Uber/Lyft,7 but the IS/MND fails to discuss how the Project would handle these ridesharing services.

Based on the above, the less than significant VMT impact presumption does not apply, and an actual VMT analysis is warranted here. The CEQA compliance must be re-done.

2. CONSTRUCTION NOISE/VIBRATION ANALYSIS IS INCOMPLETE

The IS/MND finds no construction noise impacts based on a time/place threshold. (IS/MND, pp. B-63, B-66.) However, this ignores that construction noise levels will reach up to 70 dBA compared to the 62 and 63 dBA (daytime Leq) ambient levels at sensitive receptors R1 and R2 (i.e., residences 50 feet from the site), respectively. (IS/MND, Tbls. B-14 & B-16.) This amounts to a seven to eight dBA-increase that would exceed the 5-dBA Leq threshold applied to the Project’s operational phase. (IS/MND, p. B-63.) Given construction is to last over 30-months (IS/MND, p. A-21), it is arbitrary to claim these noise levels are not significant to those residents over such a long period.

3 Ibid. at p. 12.
4 See City (May 2020) Draft Transportation Study Criteria and Guidelines, p. 4, https://culver- city.legistar.com/View.ashx?M=F&ID=8331543&GUID=B8DB9B35-E077-40E3-A0C3-AB70306081BF. 5 OPR, supra fn. 2, p. 17.
6 Google Maps, https://www.google.com/maps/place/Mayumi/@33.9823269, - 118.4133479,14z/data=!4m17!1m8!2m7!1sHotels!3m5!1sHotels!2s33.9896,+ -118.3973!4m2!1d- 118.3973395!2d33.9895605!3m7!1s0x80c2ba021914d27f:0x2906349d35168b00!5m2!4m1!1i2!8m2!3d33. 994924!4d-118.3942348.
7 City, supra fn. 4, p. 7.
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Furthermore, these construction noise levels are likely underestimated for various reasons.

First, the IS/MND’s Noise Study cites inconsistent construction equipment noise levels. (IS/MND Noise Study, PDF pp. 37, 234). Second, the IS/MND does not discuss whether pile driving will be used, which can create noise levels up to 101 dBA at 50 feet and present a unique potential for vibration impacts. (Id.) Third, the IS/MND assumed a 10-dBA reduction for “noise reduction features” like sound barriers “if construction noise is impacting nearby noise sensitive land uses,” as well as noise “abatement and acoustical design criteria” for new development. (IS/MND pp. B-67 – B-68.) However, what are those specific features, what constitutes sufficient impact to warrant sound barriers, what criteria are going to be required? These unspecified mitigation measures also are not included in the proposed Mitigation Monitoring Reporting Program (“MMRP”). (IS/MND, Attachment C.) As such, these measures are illusory mitigation measures lacking performance standards that violate CEQA.8

3. HAZARDS ANALYSIS MUST BE UPDATED

The Site was formerly used as a gasoline/service station, currently contains constituents of concern, and is not fully remediated. (IS/MND, p. B-20, B-46; IS/MND RAP, pp. 2.1-2.11.) The IS/MND proposes a future Soil Management and Remediation Plan (“SMRP”) to be prepared premised on a 2014 RAP that was prepared when no project was anticipated (IS/MND, pp. B-48, C- 11) and where remedial activities were limited due to existing retail tenants at the site (IS/MND RAP, pp. 5.2 – 5.11.) Much has changed since then, including the now proposed removal of existing tenants – as well as the consideration of new guidance on vapor intrusion by the Water Board and its sister agency Department of Toxics Substance Control (“DTSC”).9 For these reasons, the City should have a revised RAP and detailed SMRP analyzed in a compliant CEQA document in hand before considering approval of the Project.

4. CODE-REQUIRED FINDINGS CANNOT BE MADE

The IS/MND specifies that only construction-related permits from the City, such as demolition, haul route, and building permits at issue. (IS/MND, pp. EC-2, A-22, B-60.) However, the Project’s case numbers (i.e., P2019-0194-SPR, P2019-0194-CUP, P2019-0194-AUP) suggest that the Project requires City approval of Site Plan Review, Conditional Use Permit, and/or Administrative Use Permit. (IS/MND, pp. EC-1, C-1.)

These types of discretionary approvals are subject to specific findings required under the Culver City Municipal Code (“CCMC” or “Code”). (CCMC §§ 17.530.020, 17.540.020.) The environmental and CEQA impacts and deficiencies discussed herein invalidate any public health/welfare findings (id.)—these impacts and deficiencies must be resolved if the City intends to make Code-required findings supported by substantial evidence.

8 See e.g., Federation of Hillside & Canyon Ass’ns v. City of Los Angeles (2000) 83 Cal.App.th 1252, 1260; Sierra Club v. County of Fresno (2018) 6 Cal.5th 502, 522; Cleveland Nat’l Forest Found v. San Diego Ass’n of Gov’ts (2017) 17 Cal.App.5th 413, 433.
9 See Water Board (2020) Vapor Intrusion, https://www.waterboards.ca.gov/water_issues/programs/ site_cleanup_program/vapor_intrusion/; DTSC (2020) Vapor Intrusion, https://dtsc.ca.gov/vapor-intrusion/; CalEPA/Water Board/DTSC (Feb. 2020) Supplemental Guidance: Screening and Evaluating Vapor Intrusion, https://dtsc.ca.gov/wp-content/uploads/sites/31/2020/02/Public-Draft-Supplemental-VI-Guidance_2020- 02-14.pdf.
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In closing, Local 11 urges the City to stay all action on the Project until the issues discussed herein are resolved in a recirculated MND or Environmental Impact Report, as required under CEQA. On behalf of Local 11, this Office requests, to the extent not already on the notice list, all notices of CEQA actions and any approvals, determinations, or public hearings to be held on the Project under state or local law requiring local agencies to mail such notices to any person who has filed a written request for them. (Pub. Res. Code §§ 21092.2, 21167(f) and Gov. Code § 65092 and CCMC § 17.630.010.A.d.) Please send notice by electronic and regular mail to: Jordan R. Sisson, Esq., 801 S. Grand Avenue, 11th Fl., Los Angeles, CA 90017, [email protected].

Thank you for your consideration of these comments. We ask that this letter and any attachments are placed in the administrative record for the Project.

Sincerely,

Jordan R. Sisson
Attorney for Local 11
5105 Cimarron Lane
Culver City, CA 90230

February 17, 2021

Ms. Lisa Edwards, Contract Planner
City of Culver City Current Planning Division
9770 Culver Boulevard
Culver City, CA 90232

Subject: Traffic Impact Study
Jeff Hotel
11469 Jefferson Boulevard

Dear Ms. Edwards:

Thank you for the opportunity to review the Traffic Impact Study For The Jeff Hotel Project Proposed At 11469 Jefferson Boulevard, Culver City prepared by Crain & Associates in October 2020. The study is part of the Mitigated Negative Declaration for the proposed project.

To introduce myself to you, I am a Registered Traffic Engineer in California with over 50 years of experience.

For many years, I performed the functions of the Culver City Traffic Engineer as a consultant to the City. I have been a resident of Culver City for 33 years.

I have comments on three issues addressed in the Crain report: 1) adequacy of the proposed on-site parking supply; 2) operation of the dual left-turn lane proposed for northbound Jefferson Boulevard at Slauson Avenue; and 3) truck maneuvering from and to the alley west of the hotel.

On-Site Parking Supply

The following comments are based on information in Appendix E, Project Demand Parking Analysis, which consists of a letter dated April 3, 2020, to Michael Allen from Crain & Associates, plus the accompanying calculations upon which the letter text is based. The analysis in the Crain letter uses empirical data from three existing hotels in Culver City, near the subject site, to calculate estimates of the maximum potential parking demand for the Jeff Hotel.

The derived-rate estimate is less than half the estimates using either of the other two sources.

For the three local hotels studied by Crain, actual parking counts were conducted during the summer months of the years, 2018 and 2019. From those counts, peak parking usage rates (number of parked vehicles per guest room) were derived for each hotel, and the highest of the three rates was applied to the proposed number of guest rooms for the Jeff Hotel. The letter provides no information on the room occupancy rates at the study hotels during the parking counts. Were they at or near 100%? In addition to varying from month-to-month, as acknowledged in the letter, hotel occupancy rates vary from year-to-year based on numerous factors, such as the local economy and schedules of events in the area served. Were 2018 and 2019 high room-occupancy years for the hotels? If the study hotels operated at substantially below full occupancy during those years, the derived rates should be adjusted upward for that.

Do any of the three study hotels have a rooftop bar/lounge or similar facility comparable to that proposed for the Jeff Hotel? Such an amenity will attract non-guests to the hotel to meet guests or to enjoy the view. That will result in additional parking demand. If the hotel upon which the derived parking rate is based does not have a comparable amenity, the derived rate is too low to be applied to the Jeff Hotel analysis.

The parking facility that is proposed for the Jeff Hotel will consist of two subterranean levels beneath the building. Once that facility is built, there will be no opportunity to expand it on or near the hotel site. Therefore, the original supply must be adequate to serve maximum hotel parking demands, or the unsatisfied overflow parking demand will have to be accommodated elsewhere, such as in the adjacent residential neighborhood or in the adjacent shopping center.

There is nothing in the analysis to indicate whether there will be a fee charged for parking in the hotel facility.

Most hotels in the vicinity of the site, especially those with parking structures instead of surface lots, charge fees for parking, and the fees are usually substantial. That could be a disincentive for people to park at the hotel, especially those patronizing the restaurant or rooftop bar or those attending on-site meetings. They will be tempted to park in the neighborhood or at the adjacent shopping center, because their stays would be costly at the hotel parking structure. There should be an analysis of parking impacts on the nearby developments taking into consideration the effects of hotel parking fees.

As stated in the Jeff Hotel description, the parking supply will include tandem spaces. However, no number or percentage of such spaces is specified. Will tandem spaces constitute a majority of the total spaces? “Valet- assisted services” are proposed to assist with the tandem spaces. Will the valets be on duty at all times (7 days a week and 24 hours a day)? If not, when valets are not on duty, how many spaces will be effectively out of use, because self-parking guests will park in the outer tandem spaces leaving the inner spaces inaccessible?

The provision of valet-assisted services is an “operational measure”, not a structural measure. An operational measure is one that can be changed or discarded at any time by the operators of the hotel. The integrity of an operational measure depends on strict and frequent monitoring by the City. Does the City have the necessary personnel to monitor hotel operations at various times throughout the week, such as between 10 p.m. and 6 a.m. on several days per week and on Saturdays and Sundays throughout the year? If strict and frequent monitoring cannot be achieved by the City, the reliance on the valet services is invalid.

The hotel will have a large labor force. Will employees be allowed to park on-site at no cost? If not, where will hotel employees park – in the neighborhood or the adjacent shopping center? What were the policies for employee parking at the three study hotels during the parking counts? There should be adjustments to the derived parking rates to account for on-site employee parking if employees were not parked on-site at the existing hotels. On-site employee parking is another operational measure that could be eliminated by hotel management quickly. Does the City have the capability to monitor employee parking frequently? If not, the impacts of potential off-site employee parking should be included in an analysis of parking impacts on the adjacent neighborhood and shopping center.

Operation of Dual Left-Turn Lane on Jefferson Boulevard

In the plan shown in Appendix F of the Crain report, the vehicles using the two proposed northbound left-turn lanes will turn onto two lanes of westbound Slauson Avenue. Those intersection exit lanes are proposed to be 11 feet and 12 feet wide, for a total of 23 feet from the curb to the center island of Slauson Avenue.

Years of experience with the operations of dual left-turn lanes has led traffic engineers to recommend that the exit roadway for a dual left-turn movement be a minimum of 26 feet wide, with a more desirable width of 28 feet. That is based on years of observations at existing dual left-turn lanes that the drivers in the inner lane (i.e., the lane closer to the centerline) tend to drift to their right away from the center island or the opposite direction vehicles during their turns, and the drivers in the outer lane compensate for that by drifting to their right, also.

The extra width in the curbside exit lane provides the outer lane driver with the room to complete the turn efficiently and safely. Without that extra width, outer lane drivers have been observed to hesitate to complete their turns until the adjacent inner lane vehicle has completed the turn ahead of them. That results in reduction of outer lane capacity plus the potential for side-swipe accidents with inner lane vehicles and rear-end accidents between outer lane vehicles. Adequate exit lane width must be provided for the proposed dual left-turn lanes if they are to be effective and safe. The striping plan for Slauson Avenue west of Jefferson must be modified to provide the additional exit lane width.

As part of the dual left-turn plan, Crain recommends the elimination of all vehicle stopping (via red curb) along the north side of Slauson Avenue between the alley west of the project site and Culver Park Drive, a distance of one and one-half blocks, to provide the two proposed exit lanes. Seven existing curbside parking spaces would be eliminated in the adjacent residential neighborhood, and there is photographic evidence that those spaces were being used, until they were temporarily blocked by a construction project. There is no analysis of the impacts of that loss of curbside parking, nor are any measures to mitigate the loss of neighborhood parking proposed in the report. That will be a significant issue in the event of any overflow parking from the hotel, such as employees who may not be permitted to park within the hotel facility, hotel facility patrons who choose to park off-site, or hotel patron vehicles that are moved to street parking by the valets when the on-site facility is full.

Truck Turning From and To the Alley West of the Hotel Site

Appendix G of the Crain report consists of diagrams illustrating the truck turning paths of a large truck:
a) backing into the hotel loading area from the northbound alley, and b) leaving the loading area to the northbound alley. As shown in the diagrams, the two maneuvers will each require the entire width of the alley, with the driver’s side of the truck virtually touching the western edge of the alley.

However, there is a large utility pole in the alley across from the northern part of the hotel site that is not shown in the Figure G diagrams. If that pole remains in place, the alley width available for the truck turn is reduced by three to four feet. The trucks could not make either of the maneuvers as illustrated. It is very expensive to move such a large utility pole. Will the hotel developers do so, or will they provide a more feasible truck turning plan?

The three areas that I have addressed should be of significant concern to the City officials and staff, if the proposed hotel is to have less-than-significant impacts on the bordering streets and the adjacent residential neighborhood. I would be pleased to discuss my comments with you and other members of the City staff. My telephone number is 310-558-0808 and my email address is [email protected].

Very truly yours,

Original signed by Arthur L. Kassan, P.E.

Arthur L. Kassan, P.E.

Registered Traffic Engineer No. 152

February 19, 2021 Via E-Mail Lisa Edwards, Contract Planner City of Culver City Current Planning Division 9770 Culver Boulevard Culver City, CA 90232 [email protected]

Re: 11469 Jefferson Boulevard Project MND P2019-0194-SPR; P2019-0194-CUP; P2019-0194-AUP Dear Ms. Edwards and the Current Planning Division of Culver City: I am writing on behalf of the Supporters Alliance for Environmental Responsibility (“SAFER”) regarding the Mitigated Negative Declaration (“MND”) prepared for the 11469 Jefferson Boulevard Project (“Project”) (P2019-0194-SPR; P2019-0194-CUP; P2019-0194-AUP) in the City of Culver City (“City”). SAFER is a California nonprofit public benefit corporation whose purposes include contributing to the preservation and enhancement of the environment and advocating for programs, policies, and development projects that promote not only good jobs but also a healthy natural environment and working environment. After reviewing the MND, it is clear that there is a “fair argument” that the Project may have unmitigated adverse environmental impacts. The written expert comments of Francis Offermann, Certified Industrial Hygienist, and SWAPE (attached hereto as Exhibit A and Exhibit B, respectively), as well as the comments below, identify substantial evidence of a fair argument that the Project may have significant environmental impacts. Accordingly, an environmental impact report (“EIR”) is required to analyze these impacts and to propose all feasible mitigation measures to reduce those impacts. We urge the City to refrain from approving the MND, and instead to prepare an EIR for the Project prior to any Project approvals as required by CEQA. I. PROJECT BACKGROUND The Project would redevelop a 33,813 square foot (sf) (0.78-acre) property located in the northwest corner of the intersection at Jefferson Boulevard and Slauson Avenue. The existing single- story commercial (retail/restaurant) building and associated asphalt-paved surface parking lot would be removed as part of the Project. 11469 Jefferson Boulevard Project MND February 19, 2021 Page 2 of 15 The Project Site is currently improved with an approximately 13,000 sf main single-story, wood-framed commercial shopping center which includes both retail and restaurant uses. The remainder of the site consists of an asphalt-paved surface parking lot and ornamental landscaped areas. Ingress/egress to the Project Site is available via a driveway from Jefferson Boulevard and a driveway from Slauson Avenue. The Project includes the development of a new, five-story, 175-room boutique hotel building with food and beverage amenities and a two level, below-grade parking garage. A pool and roof top bar would be located on the fifth floor. The 111,000 sf building would be up to 56 feet in height (with the elevator shaft reaching 69 feet and 6 inches in height) and surrounded by landscaped areas located on site and within the public right of way. Parking for the proposed uses would be provided on site within a subterranean parking structure that would accommodate a minimum of 138 parking spaces. The Project Site is located at the south-end of the commercial corridor that runs along Jefferson Boulevard perpendicular to Interstate 405 (I-405) freeway within the Fox Hills area of Culver City. Downtown Los Angeles is approximately eight (8) miles east of the Project Site. The Project Site is bounded by the intersection at Jefferson Boulevard and Slauson Avenue with commercial uses directly north of the Project Site and a public alley adjacent to the western Project boundary with residential uses just beyond the alley. Commercial uses are also located east and south of the Project Site across Jefferson Boulevard and Slauson Avenue. Both the I-405 and State Route 90 (SR-90) freeways are located less than 400 feet west and south of the Project Site. II. LEGAL STANDARD As the California Supreme Court held, “[i]f no EIR has been prepared for a nonexempt project, but substantial evidence in the record supports a fair argument that the project may result in significant adverse impacts, the proper remedy is to order preparation of an EIR.” (Communities for a Better Env’t v. South Coast Air Quality Mgmt. Dist. (2010) 48 Cal.4th 310, 319-320 (CBE v. SCAQMD) [citing No Oil, Inc. v. City of Los Angeles (1974) 13 Cal.3d 68, 75, 88; Brentwood Assn. for No Drilling, Inc. v. City of Los Angeles (1982) 134 Cal.App.3d 491, 504–505.].) “Significant environmental effect” is defined very broadly as “a substantial or potentially substantial adverse change in the environment.” (Pub. Res. Code [“PRC”] § 21068; see also 14 CCR § 15382.) An effect on the environment need not be “momentous” to meet the CEQA test for significance; it is enough that the impacts are “not trivial.” (No Oil, Inc., supra, 13 Cal.3d at 83.) “The ‘foremost principle’ in interpreting CEQA is that the Legislature intended the act to be read so as to afford the fullest possible protection to the environment within the reasonable scope of the statutory language.” (Communities for a Better Env’t v. Cal. Res. Agency (2002) 103 Cal.App.4th 98, 109 (CBE v. CRA).) The EIR is the very heart of CEQA. (Bakersfield Citizens for Local Control v. City of Bakersfield (2004) 124 Cal.App.4th 1184, 1214 (Bakersfield Citizens); Pocket Protectors v. City of Sacramento (2004) 124 Cal.App.4th 903, 927.) The EIR is an “environmental ‘alarm bell’ whose purpose is to alert the public and its responsible officials to environmental changes before 11469 Jefferson Boulevard Project MND February 19, 2021 Page 3 of 15 they have reached the ecological points of no return.” (Bakersfield Citizens, supra, 124 Cal.App.4th at 1220.) The EIR also functions as a “document of accountability,” intended to “demonstrate to an apprehensive citizenry that the agency has, in fact, analyzed and considered the ecological implications of its action.” (Laurel Heights Improvements Assn. v. Regents of Univ. of Cal. (1988) 47 Cal.3d 376, 392.) The EIR process “protects not only the environment but also informed self-government.” (Pocket Protectors, supra, 124 Cal.App.4th at 927.) An EIR is required if “there is substantial evidence, in light of the whole record before the lead agency, that the project may have a significant effect on the environment.” (PRC § 21080(d); see also Pocket Protectors, supra, 124 Cal.App.4th at 927.) In very limited circumstances, an agency may avoid preparing an EIR by issuing a negative declaration, a written statement briefly indicating that a project will have no significant impact thus requiring no EIR (14 Cal. Code Regs. § 15371), only if there is not even a “fair argument” that the project will have a significant environmental effect. (PRC, §§ 21100, 21064.) Since “[t]he adoption of a negative declaration . . . has a terminal effect on the environmental review process,” by allowing the agency “to dispense with the duty [to prepare an EIR],” negative declarations are allowed only in cases where “the proposed project will not affect the environment at all.” (Citizens of Lake Murray v. San Diego (1989) 129 Cal.App.3d 436, 440.) A mitigated negative declaration is proper only if the project revisions would avoid or mitigate the potentially significant effects identified in the initial study “to a point where clearly no significant effect on the environment would occur, and…there is no substantial evidence in light of the whole record before the public agency that the project, as revised, may have a significant effect on the environment.” (PRC §§ 21064.5 and 21080(c)(2); Mejia v. City of Los Angeles (2005) 130 Cal.App.4th 322, 331.) In that context, “may” means a reasonable possibility of a significant effect on the environment. (PRC §§ 21082.2(a), 21100, 21151(a); Pocket Protectors, supra, 124 Cal.App.4th at 927; League for Protection of Oakland's etc. Historic Res. v. City of Oakland (1997) 52 Cal.App.4th 896, 904–905.) Under the “fair argument” standard, an EIR is required if any substantial evidence in the record indicates that a project may have an adverse environmental effect—even if contrary evidence exists to support the agency’s decision. (14 CCR § 15064(f)(1); Pocket Protectors, supra, 124 Cal.App.4th at 931; Stanislaus Audubon Society v. County of Stanislaus (1995) 33 Cal.App.4th 144, 150-51; Quail Botanical Gardens Found., Inc. v. City of Encinitas (1994) 29 Cal.App.4th 1597, 1602.) The “fair argument” standard creates a “low threshold” favoring environmental review through an EIR rather than through issuance of negative declarations or notices of exemption from CEQA. (Pocket Protectors, supra, 124 Cal.App.4th at 928.) The “fair argument” standard is virtually the opposite of the typical deferential standard accorded to agencies. As a leading CEQA treatise explains: This ‘fair argument’ standard is very different from the standard normally followed by public agencies in making administrative determinations. Ordinarily, public agencies weigh the evidence in the record before them and reach a decision based on a preponderance of the evidence. [Citations]. The fair argument standard, by contrast, prevents the lead agency from weighing competing 11469 Jefferson Boulevard Project MND February 19, 2021 Page 4 of 15 evidence to determine who has a better argument concerning the likelihood or extent of a potential environmental impact. The lead agency’s decision is thus largely legal rather than factual; it does not resolve conflicts in the evidence but determines only whether substantial evidence exists in the record to support the prescribed fair argument. (Kostka & Zishcke, Practice Under CEQA, §6.29, pp. 273-74.) The Courts have explained that “it is a question of law, not fact, whether a fair argument exists, and the courts owe no deference to the lead agency’s determination. Review is de novo, with a preference for resolving doubts in favor of environmental review.” (Pocket Protectors, supra, 124 Cal.App.4th at 928.) III. DISCUSSION A. Substantial Expert Evidence Establishes a Fair Argument that the Project’s Indoor Air Quality Will Have a Significant Impact on Human Health Due to Formaldehyde Emissions. The MND fails to address the significant health risks posed by the Project from formaldehyde, a toxic air contaminant (“TAC”). Certified Industrial Hygienist, Francis Offermann, PE, CIH, has conducted a review of the Project, the MND, and relevant documents regarding the Project’s indoor air emissions. Mr. Offermann is one of the world’s leading experts on indoor air quality, in particular emissions of formaldehyde, and has published extensively on the topic. As discussed below and set forth in Mr. Offermann’s comments, the Project’s emissions of formaldehyde to air will result in very significant cancer risks to future residents at the Project’s apartments. Mr. Offermann’s expert opinion and calculation present a “fair argument” that the Project may have significant health risk impacts as a result of these indoor air pollution emissions, which were not discussed, disclosed, or analyzed in the MND. These impacts must be addressed in n EIR. Mr. Offermann’s comment and curriculum vitae are attached as Exhibit A. Formaldehyde is a known human carcinogen and listed by the State as a TAC. SCAQMD has established a significance threshold of health risks for carcinogenic TACs of 10 in a million and a cumulative health risk threshold of 100 in a million. The MND fails to acknowledge the significant indoor air emissions that will result from the Project. Specifically, there is no discussion of impacts or health risks, no analysis, and no identification of mitigations for significant emissions of formaldehyde to air from the Project. Mr. Offermann explains that many composite wood products typically used in home and apartment building construction contain formaldehyde-based glues which off-gas formaldehyde over a very long time period. He states, “The primary source of formaldehyde indoors is composite wood products manufactured with urea-formaldehyde resins, such as plywood, medium density fiberboard, and particle board. These materials are commonly used in residential, office, and retail building construction for flooring, cabinetry, baseboards, window shades, interior doors, and window and door trims.” (Ex. A, pp. 2-3.) 11469 Jefferson Boulevard Project MND February 19, 2021 Page 5 of 15 Mr. Offermann states that future employees of the hotel 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. (Ex. A, p. 4.) This exceeds SCAQMD’s CEQA significance thresholds for airborne cancer risk of 10 per million. (Id.) Mr. Offermann concludes that these significant environmental impacts must be analyzed in an EIR and mitigation measures should be imposed to reduce the risk of formaldehyde exposure. (Ex. A, pp. 5, 10-12.) He prescribes a methodology for estimating the Project’s formaldehyde emissions in order to do a more project-specific health risk assessment. (Id., pp. 5-9.). Mr. Offermann also suggests several feasible mitigation measures, such as requiring the use of no-added-formaldehyde composite wood products, which are readily available. (Id., pp. 11-13.) Mr. Offermann also suggests requiring air ventilation systems which would reduce formaldehyde levels. (Id.) Since the MND does not analyze this impact at all, none of these or other mitigation measures have been considered. When a Project exceeds a duly adopted CEQA significance threshold, as here, this alone establishes substantial evidence that the project will have a significant adverse environmental impact. Indeed, in many instances, such air quality thresholds are the only criteria reviewed and treated as dispositive in evaluating the significance of a project’s air quality impacts. (See, e.g. Schenck v. County of Sonoma (2011) 198 Cal.App.4th 949, 960 [County applies Air District’s “published CEQA quantitative criteria” and “threshold level of cumulative significance”]; see also Communities for a Better Environment v. California Resources Agency (2002) 103 Cal.App.4th 98, 110-111 [“A ‘threshold of significance’ for a given environmental effect is simply that level at which the lead agency finds the effects of the project to be significant”].) The California Supreme Court made clear the substantial importance that an air district significance threshold plays in providing substantial evidence of a significant adverse impact. (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 Friends of Coll. of San Mateo Gardens v. San Mateo Cty. Cmty. Coll. Dist. (2016) 1 Cal.5th 937, 958 [emphasis added].) As a result, the City must prepare an EIR for the Project to address this impact and identify enforceable mitigation measures. The failure of the MND to address the Project’s formaldehyde emissions is 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 expressly holds that potential adverse impacts to future users and residents from pollution generated by a proposed project must be addressed under CEQA. At issue in CBIA was whether the Air District could enact CEQA guidelines that advised lead agencies that they must analyze the impacts of adjacent environmental conditions on a project. The Supreme Court held that CEQA does not generally require lead agencies to consider the environment’s effects on a 11469 Jefferson Boulevard Project MND February 19, 2021 Page 6 of 15 project. (CBIA, 62 Cal.4th at 800-01.) However, to the extent a project may exacerbate existing environmental conditions at or near a project site, those would still have to be considered pursuant to CEQA. (Id. at 801.) In so holding, the Court expressly held that CEQA’s statutory language required 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 800 [emphasis added].) The carcinogenic formaldehyde emissions identified by Mr. Offermann are not an existing environmental condition. Those emissions to the air will be from the Project. People will be residing in and using the Project once it is built and begins emitting formaldehyde. Once built, the Project will begin to emit formaldehyde at levels that pose significant direct and cumulative health risks. The Supreme Court in CBIA expressly finds that this type of air emission and health impact by the project on the environment and a “project’s users and residents” must be addressed in the CEQA process. The existing TAC sources near the Project site would have to be considered in evaluating the cumulative effect on future residents of both the Project’s TAC emissions as well as those existing off-site emissions. The Supreme Court’s reasoning is well-grounded in CEQA’s statutory language. CEQA expressly includes a project’s effects on human beings as an effect on the environment that must be addressed in 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 800 [emphasis in original].) Likewise, “the Legislature has made clear—in declarations accompanying CEQA’s enactment—that public health and safety are of 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 the thousands of future residents at the Project are human beings and the health and safety of those residents must be subjected to CEQA’s safeguards. 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 office buildings will have significant impacts on air quality and health risks by emitting cancer-causing levels of formaldehyde into the air that will expose future residents to cancer risks potentially in excess of SCAQMD’s threshold of significance for cancer health risks of 10 in a million. Likewise, when combined with the risks posed by the nearby TAC sources, the health risks inside the project may exceed SCAQMD’s cumulative health risk threshold of 100 cancers in a million. Currently, outside of Mr. Offermann’s comments, the City does not have any idea what risks will be posed by formaldehyde emissions from the Project or the residences. As a result, the City must include an analysis and discussion in an EIR which discloses and analyzes the health risks that the Project’s formaldehyde emissions may have on future residents and identifies appropriate mitigation measures. 11469 Jefferson Boulevard Project MND February 19, 2021 Page 7 of 15 B. The MND Relies on Unsubstantiated Input Parameters to Estimate Project Emissions and Thus Fails to Provide Substantial Evidence of the Project’s Air Quality Impacts. Matt Hagemann, P.G., C.Hg., and Paul E. Rosenfeld, Ph.D., of the Soil/Water/Air Protection Enterprise (“SWAPE”) reviewed the air quality analysis in the MND. SWAPE’s comment letter and CVs are attached as Exhibit B and their findings are summarized below. The MND for the Project relies on emissions calculated from the California Emissions Estimator Model Version CalEEMod.2016.3.2 (“CalEEMod”). This model relies on recommended default values based on site specific information related to a number of factors. The model is used to generate a project’s construction and operational emissions. SWAPE reviewed the Project’s CalEEMod output files and found that the values input into the model were inconsistent with information provided in the MND. This results in an underestimation of the Project’s emissions. As a result, the MND’s air quality analysis cannot be relied upon to determine the Project’s air quality impacts. Instead, the City must prepare an EIR to adequately evaluate the impacts that construction and operation of the Project will have on local and regional air quality. 1. The MND’s air quality model improperly reduced the default CO2 intensity factor. SWAPE’s review of the Project’s CalEEMod output files found that the CO2 intensity factor was manually reduced by approximately 28%, from the default value of 702.44 pounds per megawatt hour (“lbs/MWh”) to 509.22 lbs/MWh. (Ex. B, p. 3.) The “User Entered Comments & Non-Default Data” section attempted to justify these changes by stating: “CO2e intensity factor was linearly projected for year 2022 anticipated RPS based on SB 100 target of 44% RPS by 12/31/2024 projected and from SCE contract with the CPUC to have 41.4% RPS by 2020” (MND, Appendix A, pp. 489, 539). SWAPE found that the alteration to the CO2 intensity factor was unjustified for two reasons: “First, the IS/MND cannot simply interpolate its own CO2 intensity factor based on estimates of future increases in renewable energy use. Second, simply because the state has renewable energy goals for 2024 does not ensure that these goals will be achieved locally on the Project site or by the Project’s specific utility company. As a result, we cannot verify the revised CO2 intensity factor.” (Ex. B, p. 3.) SWAPE concluded that the unsubstantiated reduction to the default CO2 intensity factor may underestimate the Project’s GHG emissions and, therefore, cannot be relied upon to determine Project’s impacts. (Ex. B, p. 4.) 2. The MND’s air quality model underestimated the Project’s land use size for parking. SWAPE’s review of the Project’s CalEEMod output files found that the air model underestimated the proposed parking space by 22,483 sf. (Ex. B, p. 4.) According to the MND, the Project proposes to provide 56,300 sf of subterranean parking but the air model includes only 11469 Jefferson Boulevard Project MND February 19, 2021 Page 8 of 15 33,817 sf of parking space. (Id.) SWAPE concluded that the model may therefore underestimate the Project’s construction-related and operational emissions and cannot be relied upon to determine Project significance. (Id.) 3. The MND’s air quality model failed to model all proposed land uses. SWAPE’s review of the Project’s CalEEMod output files found that the air model failed to model the Project’s 3,313 sf of restaurant space and 700 sf of fitness space. (Ex. B, pp. 4-5.) SWAPE found that the model failed to distinguish between the Project’s hotel land use and restaurant/fitness land use (Id. at p. 5.) SWAPE explained that “CalEEMod includes 63 different land use types that are each assigned a distinctive set of energy usage emission factors” and that “each land use type includes a specific trip rate that CalEEMod uses to calculate mobile-source emissions.” (Id.) SWAPE concluded that the model may therefore underestimate the Project’s construction-related and operational emissions and cannot not be relied upon to determine Project impacts. (Id. at pp. 5-6.) 4. The MND’s air quality model made unsubstantiated changes to individual construction phase lengths. SWAPE’s review of the Project’s CalEEMod output files found that the air model made unsubstantiated changes to individual construction phase lengths. (Ex. B, p. 6.) The specific changes made were: • the demolition phase was increased by approximately 430%, from the default of 10 to 53 days; • the grading phase was increased by approximately 3,650%, from the default of 2 to 75 days; • the building construction phases were collectively increased by approximately 84%, from the cumulative default value of 300 to 553 days; • the paving phase was increased by approximately 120%, from the default value of 5 to 11 days; and • the architectural coating phase was increased by 1,440%, from the default value of 5 to 77 days. (Id.) According to the “User Entered Comments and Non-Default Data” table, the justification provided for these changes is: “see construction assumptions” (MND, Appendix A, pp. 82, 115). However, as noted by SWAPE, the MND and associated documents provide no “construction assumptions,” as purported by the “User Entered Comments and Non-Default Data” table. (Ex. B, p. 7.) Additionally, for the changes to construction-related inputs, the MND’s Air Quality Technical Report (“AQ Technical Report”) explained that “[t]he input values used in this analysis were adjusted to be Project-specific based on equipment types and the construction schedule” and that “[d]etailed construction equipment lists, construction scheduling, and emissions calculations are provided in Appendix A.” (AQ Technical Report, pp. 41-42.) 11469 Jefferson Boulevard Project MND February 19, 2021 Page 9 of 15 However, as noted by SWAPE, Appendix A of the AQ Technical Report does not include fail a detailed construction schedule, as purported by the AQ Technical Report. (Ex. B, p. 7.) Lastly, regarding the construction schedule, the AQ Technical Report states, “This analysis assumes construction of the Project is estimated to require up to 26 months, starting as early as the second quarter of 2020.” (AQ Technical Report, p. 42.) However, as noted by SWAPE, the AQ Technical Report only indicates that the total construction period is estimated as 26 months but says nothing about the individual construction phase lengths. (Ex. B, p. 7.) SWAPE concluded that the MND may underestimate the Project’s construction-related emissions because of unsubstantiated changes to the default individual construction phase lengths and, therefore, cannot be relied upon to determine Project impacts. (Ex. B, p. 8.) 5. The MND’s air quality model improperly altered the number of construction days per week without justification. SWAPE’s review of the Project’s CalEEMod output files found that the Project’s number of construction days per week was manually changed from the CalEEMod default. (Ex. B, p. 8.) SWAPE found that the “User Entered Comments & Non-Default Data” table (located in Appendix A of the MND) states “see construction assumptions” (MND, Appendix A, pp. 82, 115). However, the MND and associated documents fail to provide any “construction assumptions” pertaining to the number of days a week for construction (Id.) As such, SWAPE concludes that the MND may underestimate the Project’s construction-related emissions and should not be relied upon to determine Project’s impacts. (Ex. B, p. 9.) 6. The MND’s air quality model made unsubstantiated changes to off-road equipment unit amounts and usage hours. SWAPE’s review of the Project’s CalEEMod output files found that the Project’s off-road equipment unit amounts and usage hours were manually changed from the CalEEMod defaults. (Ex. B, p. 9.) According to the “User Entered Comments and Non-Default Data” table, the justification provided for these changes is: “see construction assumptions” (MND, Appendix A, pp. 82, 115). However, as noted by SWAPE, the MND and associated documents provide no “construction assumptions,” as purported by the “User Entered Comments and Non-Default Data” table. (Ex. B, p. 10.) Furthermore, for the changes to construction-related inputs, the MND’s Air Quality Technical Report (“AQ Technical Report”) explained that “[t]he input values used in this analysis were adjusted to be Project-specific based on equipment types and the construction schedule” and that “[d]etailed construction equipment lists, construction scheduling, and emissions calculations are provided in Appendix A.” (AQ Technical Report, pp. 41-42.) 11469 Jefferson Boulevard Project MND February 19, 2021 Page 10 of 15 However, as noted by SWAPE, Appendix A of the AQ Technical Report does not include fail a detailed construction schedule, as purported by the AQ Technical Report. (Ex. B, p. 10.) SWAPE concluded that the MND may underestimate the Project’s emissions because of unsubstantiated changes to the Project’s off-road construction equipment unit amounts and usage hours and, therefore, cannot be relied upon to determine Project impacts. (Ex. B, p. 8.) 7. The MND’s air quality model failed to model all required material export. SWAPE’s review of the Project’s CalEEMod output files found that the MND’s air model underestimated the amount of required material export by 12,524 cubic yards (cy). (Ex. B, p. 10. According to the AQ Technical Report, “[t]he Project would export approximately 43,836 cubic yards of soil during grading and excavation activities” (AQ Technical Report, p. 42.) However, as SWAPE notes, the model included only 31,312 cy of material export rather than 43,836 cy. (Ex. B, p. 10.) SWAPE concluded that the MND may underestimate the Project’s emissions by failing to model all the required material export and, therefore, cannot be relied upon to determine Project impacts. (Ex. B, p. 10.) 8. The MND’s air quality model made unsubstantiated reductions to hauling, worker, and vendor trip numbers. SWAPE’s review of the Project’s CalEEMod output files found that the MND’s air model made unsubstantiated reductions to hauling, worker, and vendor trip numbers. (Ex. B, p. 10.) Specifically, the hauling, worker, and vendor trip numbers were reduced to zero. (Id. at p. 11.) SWAPE found that the MND and associated documents failed to provide a source or any calculations explaining how the trip numbers were derived. (Ex. B, p. 11-12.) By failing to provide this information, the MND fails to provide substantial evidence to justify the modifications to the CalEEMod defaults. (Id. at 12.) SWAPE also found that the MND and associated documents failed to provide the total on-road construction-related emissions for hauling, vendor, and worker trips, or demonstrate how the on-road construction-related emissions were summed with the construction-related emissions estimated in CalEEMod. (Id.) SWAPE concluded that the MND may underestimate the Project’s emissions by including unsubstantiated changes to the default hauling, vendor, and worker construction trips, and, therefore, cannot be relied upon to determine Project impacts. (Ex. B, p. 10.) 9. The MND’s air quality model made unsubstantiated changes to the Project’s operational vehicle fleet mix. SWAPE’s review of the Project’s CalEEMod output files found that the MND’s air model made several changes to the default operational vehicle fleet mix percentages. (Ex. B, 13.) However, no justification for the modifications was given and the MND and associated documents do not mention any revised operational vehicle fleet mix percentages. (Id. at 14.) 11469 Jefferson Boulevard Project MND February 19, 2021 Page 11 of 15 SWAPE concluded that the model may underestimate the Project’s mobile-source operational emissions and cannot be relied upon to determine Project significance. (Id.) 10. The MND’s air quality model made unsubstantiated changes to operational vehicle emission factors. SWAPE’s review of the Project’s CalEEMod output files found that the MND’s air model made several changes to the default operational vehicle emission factors. (Ex. B, 15.) According to the “User Entered Comments and Non-Default Data” table, the justification provided for these changes is: “Updated to EMFAC2017 EFs” (MND, Appendix A, pp. 489, 539). As explained by SWAPE, EMFAC refers to an entire database, not a specific set of vehicle emission factors. (Ex. B, p. 15.) The MND did not specify which input parameters were used to obtain the vehicle emission factors nor provide the revised vehicle emission factors themselves. (Id.) Because the vehicle emission factors are used to calculate the Project’s operational emissions associated with on-road vehicles, the model may underestimate the Project’s mobile-source operational emissions by including several unsubstantiated changes to the default operational vehicle emission factors and, therefore, cannot be relied upon to determine Project significance. (Id.) 11. The MND’s air quality model improperly included construction-related mitigation measures. SWAPE’s review of the Project’s CalEEMod output files found that the MND assumed that the Project will implement construction-related mitigation measures, including a 15 miles per hour (mph) vehicle speed. (Ex. B, p. 15.) However, as explained by SWAPE, with the exception of Tier 4 Final engines, the “User Entered Comments & Non-Default Data” fails to justify the inclusion of the other construction- related mitigation measures. (Id. at p. 16.) For the 15 mph speed limit, SWAPE noted that although the MND claimed that the Project would comply with SCAQMD regulations for controlling fugitive dust pursuant to SCAQMD Rule 403, SCAQMD Rule 403 does not require a 15 mph speed limit. (Ex. B, p. 16.) Pursuant to SCAQMD Rule 403, the Project may either water unpaved roads 3 times per day, water unpaved roads 1 time per day and limit vehicle speeds to 15 mph, or apply a chemical stabilizer. (Id. at p. 17.) Therefore, SCAQMD Rule 403 does not explicitly require any of the measures included in the CalEEMod model. (Id.) SWAPE concluded that the MND may underestimate the Project’s emissions by including several construction-related mitigation measures without properly committing to their implementation and enforcement, and, therefore, cannot be relied upon to determine Project impacts. (Ex. B, p. 17.) C. Substantial Expert Evidence Establishes a Fair Argument That the Project Will Have Significant Emissions of ROG/VOC and NOx. In an effort to accurately determine the proposed Project’s construction and operational 11469 Jefferson Boulevard Project MND February 19, 2021 Page 12 of 15 emissions, SWAPE prepared an updated CalEEMod model that includes more site-specific information and correct input parameters, as provided by the MND. (Ex. B, p. 17.) SWAPE’s model included all proposed land use types and sizes as described by the MND; corrected the amount of material export; omitted the unsubstantiated changes to the individual construction phase lengths, off-road construction equipment unit amounts and usage hours, construction trip numbers, operational vehicle emission factors, and operational vehicle fleet mix percentages; and excluded the unsubstantiated construction-related mitigation measures. (Id.) SWAPE’s updated model found that the ROG/VOC and NOx emissions associated with Project construction exceed the 75- and 100-pounds per day (“lbs/day”) thresholds set by the SCAQMD, respectively. (Ex. B, p. 17.) SWAPE’s updated model demonstrates that when the Project’s construction and operational emissions are estimated based on site-specific information provided in the MND, the Project would result in a potentially significant air quality impact that was not previously identified or addressed in the MND. As such, the City must prepare an EIR to include an updated air pollution model to properly estimate the Project’s construction and operational emissions and incorporate mitigation to reduce these emissions to a less than significant level. D. The MND Fails to Adequately Evaluate Health Risks from Diesel Particulate Matter Emissions Based on based on a quantified construction health risk assessment (“HRA”) and a localized significance (“LST”) analysis, the MND concluded that the Project would have a less-than-significant health risk impact. (Ex. B, p. 18.) However, SWAPE’s review of the MND found that MND’s evaluation of the Project’s potential health risk impacts and the less-than-significant impact conclusion were improper. (Id.) First, SWAPE notes that, as discussed above, the MND’s HRA relied on a flawed air model and therefore underestimated PM10 emissions. (Ex. B, p. 18.) By using an inaccurate PM10 value, the HRA underestimated the diesel particulate matter (“DPM”) concentration to calculate the cancer risk associated with Project construction. (Id. at p. 19.) Therefore, the MND underestimated the Project’s construction-related cancer risk and cannot be relied upon to determine Project impacts. (Id.) Second, SWAPE disputes the MND’s conclusion that operational health risks would be less-than-significant because the Project would not “generate a substantial number of daily truck trips.” (Ex. B, p. 19.) However, the MND stated that Project operation would generate 1,463 new daily vehicle trips, which, according to SWAPE, would result in additional exhaust emissions and continue to expose nearby sensitive receptors to DPM emissions. (Id.) The MND makes no effort to connect the Project’s operational TAC emissions to the potential health risks posed to nearby receptors, and, therefore, should not conclude that the Project’s operational health risk impact would be less than significant. (Id.) Third, SWAPE found that the MND’s omission of a quantified operational HRA is 11469 Jefferson Boulevard Project MND February 19, 2021 Page 13 of 15 inconsistent with the most recent guidance published by the Office of Environmental Health Hazard Assessment (“OEHHA”). (Ex. B, p. 19.) OEHHA recommends that exposure from projects lasting more than 6 months be evaluated for the duration of the project and recommends that an exposure duration of 30 years be used to estimate individual cancer risk. (Id.) SWAPE concluded that the MND should include an operational HRA to evaluate health risk impacts with a 30-year exposure duration. (Id.) Fourth, SWAPE found that the MND failed to evaluate the cumulative lifetime cancer risk to nearby, existing receptors as a result of Project construction and operation together. (Ex. B, p. 19.) SWAPE concluded that, per OEHHA Guidance, the Project’s combined construction and operational cancer risks must be quantified and compared to the SCAQMD threshold 10 in one million. (Id.) Lastly, SWAPE found that the MND improperly concluded that the Project’s PM2.5 and PM10 emissions would not exceed LSTs. (Ex. B, p. 20.) SWAPE’s review of the CalEEMod output files demonstrates that the PM10 and PM2.5 emissions associated with Project construction exceed the 1- and 2-lbs/day LSTs set by the SCAQMD, respectively. (Id.) Therefore, the MND’s claim that emissions associated with Project construction would not exceed the applicable SCAQMD LSTs is incorrect and cannot be relied upon. E. Substantial Expert Evidence Establishes a Fair Argument that the Project May Have a Significant Impact on Human Health from Diesel Particulate Matter SWAPE prepared a screening-level HRA to evaluate potential impacts from the construction and operation of the Project. (Ex. B, p. 21.) SWAPE used AERSCREEN, the leading screening-level air quality dispersion model. (Id.) SWAPE used a sensitive receptor distance of 25 meters and analyzed impacts to individuals at different stages of life based on OEHHA and SCAQMD guidance. (Ex. B, pp. 22-13.) SWAPE found that the excess cancer risk for adults, children, and infants, at the closest sensitive receptor located approximately 25 meters away, over the course of Project construction and operation, are approximately 16, 150, and 17 in one million, respectively. (Ex. B, p. 23.) SWAPE found that the excess cancer risk over the course of a residential lifetime is approximately 180 in one million. (Id.) These values appreciably exceed the SCAQMD’s threshold of 10 in one million. SWAPE’s HRA constitutes a “fair argument” that the Project will have significant impacts on human health. As such, the City must prepare an EIR to properly evaluate the Project’s health risk impact. E. The MND Fails to Adequately Assess Greenhouse Gas Impacts SWAPE concluded that the MND failed to adequately analyze the Project’s greenhouse gas (“GHG”) impacts. (Ex. B, p. 24.) Although the MND calculated the Project’s annual GHG 11469 Jefferson Boulevard Project MND February 19, 2021 Page 14 of 15 emissions as 1,537 metric tons of carbon dioxide equivalents per year (“MT CO2e/yr”), the MND failed to compare the Project’s emissions to any objective threshold. (Id. at pp. 24, 27.) Furthermore, the MND’s calculation for 1,537 MT CO2e/yr was based on an inaccurate air model, as discussed above, and likely underestimated. (Id. at p. 26.) However, assuming that the Project’s 1,537 MT CO2e/yr is accurate, the Project exceeds the proper threshold of 2.6 MT CO2e/SP/year. (Id. at pp. 27-28.) SWAPE concluded that the exceedance of this threshold resuls in a significant GHG impact not previously identified or addressed by the MND. (Id. at p. 28.) Therefore, an EIR must be prepared and mitigation must be implemented where necessary. SWAPE provided several mitigation measures that could be implemented to mitigate the Project’s significant GHG impact. (Id. at pp. 32-39.) Additionally, the MND relied upon the Project’s consistency with the CARB’s Scoping Plan, SCAG’s RTP/SCS, the City’s energy efficiency policies, and the City’s Green Building Code in order to conclude that the Project would have a less-than-significant GHG impact. (Ex. B, p. 25.) However, these regulatory plans do not meet the criteria for an officially adopted GHG reduction program, commonly referred to as a Climate Action Plan (“CAP”), for use as a threshold of significance for GHG emissions. (Ex. B, p. 26.) As CEQA Guideline section 15064.4(b)(3) makes clear, a qualified CAP “must be adopted by the relevant public agency through a public review process,” and, as explained by CEQA Guideline section 15183.5(b)(1), the CAP should include: (1) Inventory: Quantify GHG emissions, both existing and projected over a specified time period, resulting from activities (e.g., projects) within a defined geographic area (e.g., lead agency jurisdiction); (2) Establish GHG Reduction Goal: Establish a level, based on substantial evidence, below which the contribution to GHG emissions from activities covered by the plan would not be cumulatively considerable; (3) Analyze Project Types: Identify and analyze the GHG emissions resulting from specific actions or categories of actions anticipated within the geographic area; (4) Craft Performance Based Mitigation Measures: Specify measures or a group of measures, including performance standards, that substantial evidence demonstrates, if implemented on a project-by-project basis, would collectively achieve the specified emissions level; (5) Monitoring: Establish a mechanism to monitor the CAP progress toward achieving said level and to require amendment if the plan is not achieving specified levels; and Here, the MND fails to demonstrate that the CARB’s Scoping Plan, SCAG’s RTP/SCS, the City’s energy efficiency policies, and the City’s Green Building Code include the above-listed requirements to be considered a qualified CAP for the City. Furthermore, the MND failed to consider performance-based standards under CARB’s Scoping Plan (Ex. B, pp. 28-30) and SCAG’s RTP/SCS (id. at pp. 30-32). As such, the MND leaves an analytical gap and fails to demonstrate that compliance with said plans can be used for project-level significance determination. (Ex. B, p. 27.) 11469 Jefferson Boulevard Project MND February 19, 2021 Page 15 of 15 F. The MND’s Mitigation for Hazards and Hazardous Materials is Inadequate. In order to mitigate the Project’s significant impacts related to hazardous materials, the MND required MM-HAZ-1. MM-HAZ-1 requires a qualified environmental consultant to prepare a Soil Management and Remediation Plan and “[u]pon completion of the Soil Management and Remediation Plan, the Applicant shall contact the LARWQCB to obtain a closure letter that states no further soils testing or remediation is required on the Project Site.” (MND, p. B-50.) However, the MND fails to disclose that MND the recent status of the site in Geotracker, which concludes there are two impediments to closure: (1) free product in groundwater; and (2) threat for vapor intrusion. (Ex. B, p. 2.) Without disclosing and accounting for these impediments to closure, the MND fails to provide substantial evidence that MM-HAZ-1 would reduce the Project’s impacts to a less-than-significant level. SWAPE also noted that MND failed to disclose contamination on the Project site because the extent of contamination is not known. (Ex. B, p. 2.) As a result, the MND failed to identify impacts of remediation because: “(1) an informed estimate of the amount of soil to be excavated has not been made, therefore construction impacts for excavation and truck trips for proper disposal have not been estimated; and (2) magnitude of groundwater plume and vapor intrusion impacts have not been determined – these will result in impacts including construction and operation emissions associated with groundwater investigations, well drilling, and groundwater pumping and treatment system installation and operation.” (Id.) Without disclosing and accounting for the extent of contamination and the impacts of remediation, the MND fails to provide substantial evidence Project’s impacts related to hazards and hazardous materials are less-than-significant. IV. CONCLUSION For the foregoing reasons, the MND for the Project should be withdrawn, an EIR should be prepared, and the draft EIR should be circulated for public review and comment in accordance with CEQA. Thank you for considering these comments. Sincerely, Brian Flynn Lozeau | Drury LLP

EXHIBIT A
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: February 9, 2021 To: Brian Flynn Lozeau | Drury LLP 1939 Harrison Street, Suite 150 Oakland, California 94612 From: Francis J. Offermann PE CIH Subject: Indoor Air Quality: 11469 Jefferson Boulevard-Culver City, CA (IEE File Reference: P-4424) Pages: 19 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 particularly 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 19
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/m3, assuming a continuous 24-hour exposure, a total daily inhaled air volume of 20 m3, and 100% absorption by the respiratory system. All of the CNHS homes exceeded this NSRL concentration of 2 µg/m3. The median indoor formaldehyde concentration was 36 µg/m3, and ranged from 4.8 to 136 µg/m3, 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/m3, 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/m3 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 19
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 measure (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/m3 (18.2 ppb) as compared to a median of 36 µg/m3 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 estimated 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/m3, 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 11469 Jefferson Boulevard Project, Culver City, CA, the building consists of a hotel. 4 of 19
The employees of the hotel 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 significant cancer risks resulting from exposures to formaldehyde released by the building materials and furnishing commonly found in offices, warehouses, residences and hotels. Because the hotel 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/m3 (Singer et. al., 2020) Assuming that the employees of hotel work 8 hours per day and inhale 20 m3 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 risk 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. 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. 5 of 19
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 per million. The permissible emission rates for ULEF composite wood 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. 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 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. 6 of 19

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., m2 of material/m2 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/m2-h) and the area (m2) 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 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. 7 of 19
CDPH, BIFMA, and other chemical emission rate testing programs, typically certify that a material or furnishing does not create 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/m2-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/m2-h, but not the actual measured specific emission rate, which may be 3, 18, or 30 µg/m2-h. These area-specific emission rates determined from the product 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. 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. 8 of 19

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. For each IAQ Zone, calculate the indoor formaldehyde concentration (µg/m3) 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. !!"= #!"!#$$"# (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 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 9 of 19
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 Formaldehyde Emissions Assessment) to insure that the materials selected achieve acceptable cancer risks from material off gassing of formaldehyde. 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 10 of 19
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. The 11469 Jefferson Boulevard Project, Culver City, CA is close to roads with moderate to high traffic (e.g., Jefferson Boulevard, S. Lausen Avenue, San Diego Freeway, Sepulevada Boulevard, I-90 etc.. As a result of the outdoor vehicle traffic noise, the Project site is likely to be a sound impacted site. According to the Proposed Mitigated Negative Declaration - 11469 Jefferson Boulevard Project, Culver City, CA. (City of Culver City, 2021) the future traffic noise levels with Project range from from 63.6 to 670.2 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. PM2.5 Outdoor Concentrations Impact. An additional impact of the nearby motor vehicle traffic associated with this project, are the outdoor concentrations of PM2.5. According to the Proposed Mitigated Negative Declaration - 11469 Jefferson Boulevard Project, Culver City, CA. (City of Culver City, 2021), the Project is located in South Coast Air Basin, which is a State and Federal non-attainment area for PM2.5. 11 of 19
An air quality analyses should to be conducted to determine the concentrations of PM2.5 in the outdoor and indoor air that people inhale each day. This air quality analyses needs to consider the cumulative impacts of the project related emissions, existing and projected future emissions from local PM2.5 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 PM2.5 exceedence concentration of 12 µg/m3, 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 PM2.5 particles is less than the California and National PM2.5 annual and 24-hour standards. It is my experience that based on the projected high traffic noise levels, the annual average concentration of PM2.5 will exceed the California and National PM2.5 annual and 24-hour standards and warrant installation of high efficiency air filters (i.e. MERV 13 or higher) in 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 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, such as resins made from soy, polyvinyl acetate, or methylene diisocyanate can insure that the OEHHA cancer risk of 10 per million is met. 12 of 19
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/ft2 of floor area. Following installation of the system conduct 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. PM2.5 Outdoor Air Concentration Mitigation. Install air filtration with sufficient PM2.5 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 PM2.5 annual and 24-hour 13 of 19
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 Resources 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. 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. 14 of 19
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, Richmond, CA. https://www.cdph.ca.gov/Programs/CCDPHP/ DEODC/EHLB/IAQ/Pages/VOC.aspx. City of Culver City. 2021. Proposed Mitigated Negative Declaration - 11469 Jefferson Boulevard Project, Culver City, CA. 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. 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 OEHHA - Office of Environmental Health Hazard Assessment. 2017b. All OEHHA Acute, 8-hour and Chronic Reference Exposure Levels. Available at: http://oehha.ca.gov/air/allrels.html 15 of 19
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 (12th 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 16 of 19
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 regulation - 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 California homes, the median indoor formaldehyde concentration was of 22.4 µg/m3 (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 ft2), 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 19
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 mechanical 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 ft2 (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 19
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 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 per million. The permissible emission rates for ULEF composite wood 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.

EXHIBIT B

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]
February 17, 2021

Brian Flynn
Lozeau | Drury LLP
1939 Harrison Street, Suite 150
Oakland, CA 94612

Subject: Comments on 11469 Jefferson Boulevard Project (SCH No. 2021010247) Dear Mr. Flynn,
We have reviewed the January 2021 Initial Study/Mitigated Negative Declaration (“IS/MND”) for the 11469 Jefferson Boulevard Project (“Project”) located in the City of Culver City (“City”). The Project proposes to demolish the existing 13,000-SF shopping center and construct a 111,000-SF hotel, including 175-rooms, food and drink amenities, a rooftop bar, and pool, as well as 138 parking spaces in a 56,300- SF subterranean garage, on the 0.78-acre site.

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

Hazards and Hazardous Materials
In MM HAZ-1, the IS/MND presumes closure will be granted, stating:
“MM-HAZ-1: The Applicant shall retain a qualified environmental consultant to prepare a Soil Management and Remediation Plan for review and approval by the Culver City Building Safety Division and LARWQCB, as necessary, prior to the commencement of excavation and grading activities. The plan would include measures to remove and/or treat/remediate the impacted soils and groundwater to a level determined acceptable per applicable regulatory standards,

2 under supervision of a certified environmental consultant licensed to oversee such remediation.

Upon completion of the Soil Management and Remediation Plan, the Applicant shall contact the LARWQCB to obtain a closure letter that states no further soils testing or remediation is required on the Project Site.”
The IS/MND does not disclose the recent status of the site in Geotracker, pasted below, which concludes there are two impediments to closure: (1) free product in groundwater; and (2) threat for vapor intrusion.

This IS/MND cites plans to remediate by development, stating:
“[T]he Project would include subterranean parking, which by its nature would involve excavation of soils for the proposed 2-level parking structure. Therefore, with the Project, direct excavation and removal of contaminated soils and groundwater can occur in a manner that was not previously contemplated in the RAP.”
The IS/MND fails to disclose contamination because the extent of contamination is not known.

Additionally, not knowing the extent of contamination, the IS/MND fails to identify impacts of remediation because: (1) an informed estimate of the amount of soil to be excavated has not been made, therefore construction impacts for excavation and truck trips for proper disposal have not been estimated; and (2) magnitude of groundwater plume and vapor intrusion impacts have not been determined – these will result in impacts including construction and operation emissions associated with groundwater investigations, well drilling, and groundwater pumping and treatment system installation and operation.

Air Quality
Unsubstantiated Input Parameters Used to Estimate Project Emissions The IS/MND’s air quality analysis relies on emissions calculated with CalEEMod.2016.3.2 (p. B-36).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.

1 CAPCOA (November 2017) CalEEMod User’s Guide, http://www.aqmd.gov/docs/default- source/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4. 3 When reviewing the Project’s CalEEMod output files, provided in The Jeff Hotel Project Air Quality Emissions Worksheets (“AQ Emissions Worksheets”) as Appendix A to the IS/MND, we found that several model inputs were not consistent with information disclosed in the IS/MND. As a result, the Project’s construction and operational emissions are underestimated. As a result, a Project-specific EIR should be prepared to include an updated air quality analysis that adequately evaluates the impacts that construction and operation of the Project will have on local and regional air quality.

Unsubstantiated Reduction to the Default CO2 Intensity Factor Review of the CalEEMod output files demonstrates that the “11469 Jefferson – Operations” includes a manual reduction to the default CO2 intensity factor (see excerpt below) (Appendix A, pp. 491, 541).

As you can see in the excerpt below, the CO2 intensity factor was manually reduced by approximately 28%, from the default value of 702.44 pounds per megawatt hour (“lbs/MWh”) to 509.22 lbs/MWh. As previously mentioned, the CalEEMod User’s Guide requires any changes to model defaults be justified.2 According to the “User Entered Comments and Non-Default Data” table, the justification provided for this change is:
“CO2e intensity factor was linearly projected for year 2022 anticipated RPS based on SB 100 target of 44% RPS by 12/31/2024 projected and from SCE contract with the CPUC to have 41.4% RPS by 2020” (Appendix A, pp. 489, 539).

Furthermore, regarding the revised CO2 intensity factor, the IS/MND states:
“Since the Project’s first operational year was conservatively modeled for Year 2022 (would be less energy used for future years), the default CO2 intensity factor in CalEEMod for SCE was linearly adjusted from 2020 to account for 42.4 percent renewable energy for 2022 based on the required renewables from year 2024 under SB 100. For 2012, SCE had 20.6 percent renewables and this was used to back calculate a CO2 intensity factor where SCE had zero percent renewable. This value was then adjusted to reflect a CO2 intensity factor with 42.4 percent renewables” (p. B-37).

However, these justifications are insufficient for two reasons. First, the IS/MND cannot simply interpolate its own CO2 intensity factor based on estimates of future increases in renewable energy use.

Second, simply because the state has renewable energy goals for 2024 does not ensure that these goals will be achieved locally on the Project site or by the Project’s specific utility company. As a result, we cannnot verify the revised CO2 intensity factor.

2 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 2, 9

4 This unsubstantiated reduction presents an issue, as CalEEMod uses the CO2 intensity factor to calculate the Project’s greenhouse gas (“GHG”) emissions associated with electricity use.3 Thus, by including an unsubstantiated reduction to the default CO2 intensity factor, the model may underestimate the Project’s GHG emissions and should not be relied upon to determine Project significance.

Use of an Underestimated Parking Land Use Size
According to the IS/MND, the Project proposes to provide “56,300 SF of subterranean parking” (p. A-4).

However, review of the CalEEMod output files demonstrates that the “11469 Jefferson – Construction” and “11469 Jefferson – Operations” models include only 33,817-SF of parking space (See excerpts below) (Appendix A, pp. 81, 114, 489, 539).
“11469 Jefferson – Construction”

“11469 Jefferson – Operation”

As you can see in the excerpt above, the proposed parking space is underestimated by 22,483-SF.4 This underestimation presents an issue, as the land use size feature is used throughout CalEEMod to determine default variable and emission factors that go into the model’s calculations. The square footage of a land use is used for certain calculations such as determining the wall space to be painted (i.e., VOC emissions from architectural coatings) and volume that is heated or cooled (i.e., energy impacts).5 Thus, by underestimating the size of the proposed parking land use, the models underestimate the Project’s construction-related and operational emissions and should not be relied upon to determine Project significance.

Failure to Model All Proposed Land Uses
According to the IS/MND, the Project proposes to construct 3,313-SF6 of restaurant space and 700-SF of fitness space (see excerpt below) (p. A-9).

3 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.caleemod.com/, p. 17. 4 Calculated: 56,300-SF – 33,817-SF = 22,483-SF.
5 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 28. 6 Calculated: 2,900-SF “Restaurant” + 413-SF “Rooftop Bar” = 3,313-SF total restaurant space.

5 As such, the models should have included 3,313- and 700-SF of restaurant and fitness space, respectively. However, review of the CalEEMod output files demonstrates that the “11469 Jefferson – Construction” and “11469 Jefferson – Operations” models fail to include the proposed restaurant and fitness land uses (see excerpt below) (Appendix A, pp. 81, 114, 489, 539).

As you can see in the excerpt above, the models fail to distinguish between the hotel land use and the restaurant and fitness land uses. This inconsistency presents an issue, as CalEEMod includes 63 different land use types that are each assigned a distinctive set of energy usage emission factors.7 Furthermore, each land use type includes a specific trip rate that CalEEMod uses to calculate mobile-source emissions.8 Thus, by failing to include all proposed land use types, the models may underestimate the

7 “CalEEMod User’s Guide, Appendix D.” CAPCOA, September 2016, available at:
http://www.aqmd.gov/docs/default-source/caleemod/upgrades/2016.3/05_appendix-d2016-3-1.pdf?sfvrsn=2. 8 CalEEMod User’s Guide, available at: http://www.aqmd.gov/docs/default- source/caleemod/upgrades/2016.3/01_user-39-s-guide2016-3-1.pdf?sfvrsn=2, p. 14.

6 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 “11469 Jefferson – Construction” model includes several changes to the default individual construction phase lengths (see excerpt below) (Appendix A, pp. 83, 116).

As a result of these changes, the model includes a construction schedule as follows (see excerpt below) (Appendix A, pp. 89, 122):

As you can see in the excerpts above, the demolition phase was increased by approximately 430%, from the default of 10 to 53 days; the grading phase was increased by approximately 3,650%, from the default of 2 to 75 days; the building construction phases were collectively increased by approximately 84%, from the cumulative default value of 300 to 553 days; the paving phase was increased by approximately 120%, from the default value of 5 to 11 days; and the architectural coating phase was increased by 1,440%, from the default value of 5 to 77 days.

As previously mentioned, the CalEEMod User’s Guide requires any changes to model defaults be justified.9 According to the “User Entered Comments and Non-Default Data” table, the justification provided for these changes is: “see construction assumptions” (Appendix A, pp. 82, 115). Furthermore,

9 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 2, 9

7 regarding the Project’s construction-related CalEEMod input values, the Air Quality Technical Report (“AQ Technical Report”) states:
“The input values used in this analysis were adjusted to be Project-specific based on equipment types and the construction schedule. These values were then applied to the construction phasing assumptions used in the criteria pollutant analysis to generate criteria pollutant emissions values for each construction activity. Detailed construction equipment lists, construction scheduling, and emissions calculations are provided in Appendix A” (see emphasis) (p. 41-42).

Furthermore, regarding the construction schedule, the AQ Technical Report states:
“This analysis assumes construction of the Project is estimated to require up to 26 months, starting as early as the second quarter of 2020” (p. 42).

However, these justifications are insufficient for two reasons.

First, review of the IS/MND and associated documents demonstrates that no construction assumptions are provided, as purported by the “User Entered Comments and Non-Default Data” table. Furthermore, review of Appendix A demonstrates that the AQ Emissions Worksheets fail to include a detailed construction schedule, as purported by the AQ Technical Report. As such, the revised individual construction phase lengths are unsubstantiated.

Second, while the AQ Technical Report indicates that the total construction period is estimated to require 26 months, the AQ Technical Report fails to provide the individual construction phase lengths (p. 42). As such, we cannot verify the revised individual construction phase lengths.

These unsubstantiated changes present an issue, as they improperly spread out construction emissions over a longer period of time than is anticipated for the Project. According to the CalEEMod User’s Guide, each construction phase is associated with different emissions activities (see excerpt below).10

10 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 31. 8 As such, by disproportionately altering individual construction phase lengths without proper justification, the model’s calculations are altered and underestimate emissions. Thus, by including unsubstantiated changes to the default individual construction phase lengths, the model may underestimate the Project’s construction-related emissions and should not be relied upon to determine Project significance.

Unsubstantiated Change to Number of Construction Days per Week Review of the CalEEMod output files demonstrates that the “11469 Jefferson – Construction” model includes several changes to the default number of construction days per week (see excerpt below) (Appendix A, pp. 83, 116).

As you can see in the excerpt above, the model assumes that construction activities would occur 6 days per week, rather than the default of 5 days per week. As previously mentioned, the CalEEMod User’s Guide requires any changes to model defaults be justified.11 According to the “User Entered Comments and Non-Default Data” table, the justification provided for these changes is: “see construction assumptions” (Appendix A, pp. 82, 115). However, as discussed above, the IS/MND and associated documents fail to include any construction assumptions. Furthermore, the IS/MND and associated documents fail to mention or justify the revised number of construction days per week whatsoever.

This presents an issue, as increasing the number of construction days per week spreads out construction emissions over a longer period of time than is anticipated for the Project. Thus, by including an

11 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 2, 9

9 unsubstantiated increase to the default number of construction days per week, the model may underestimate the Project’s construction-related emissions and should not be relied upon to determine Project significance.

Unsubstantiated Changes to Off-Road Equipment Unit Amounts and Usage Hours Review of the CalEEMod output files demonstrates that the “11469 Jefferson – Construction” model includes several changes to the default off-road equipment unit amounts and usage hours (see excerpt below) (Appendix A, pp. 84, 117).

As you can see in the excerpt above, the default off-road construction equipment unit amounts and usage hours were manually altered in the model. As previously mentioned, the CalEEMod User’s Guide requires any changes to model defaults be justified.12 According to the “User Entered Comments and Non-Default Data” table, the justification provided for these changes is: “see construction assumptions” (Appendix A, pp. 82, 115). Furthermore, regarding the Project’s construction-related CalEEMod input values, the AQ Technical Report states:
“The input values used in this analysis were adjusted to be Project-specific based on equipment types and the construction schedule. These values were then applied to the construction phasing assumptions used in the criteria pollutant analysis to generate criteria pollutant emissions values for each construction activity. Detailed construction equipment lists, construction scheduling, and emissions calculations are provided in Appendix A” (see emphasis) (p. 41-42).

12 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 2, 9

10 However, as previously discussed, review of the IS/MND and associated documents demonstrates that no construction assumptions are provided, as purported by the “User Entered Comments and Non- Default Data” table. Furthermore, review of Appendix A demonstrates that the AQ Emissions Worksheets fail to include detailed construction equipment lists, as purported by the AQ Technical Report. As such, we cannot verify the revised off-road construction equipment unit amounts and usage hours. Thus, by including unsubstantiated changes to the Project’s off-road construction equipment unit amounts and usage hours, the model may underestimate the Project’s construction-related emissions and should not be relied upon to determine Project significance.

Failure to Model All Required Material Export
According to the AQ Technical Report, “[t]he Project would export approximately 43,836 cubic yards of soil during grading and excavation activities” (p. 42). As such, the model should have included 43,836 cubic yards (“cy”) of material export. However, review of the CalEEMod output files demonstrates that the “11469 Jefferson – Construction” model includes only 31,312 cy of material export (see excerpt below) (Appendix A, pp. 83, 116).

As you can see in the excerpt above, the amount of required material export is underestimated by 12,524 cy.13 Thus, the amount of material export included in the model is underestimated and inconsistent with the information provided in the AQ Technical Report. This underestimation presents an issue, as CalEEMod uses the total amount of material export to calculate emissions produced from material movement, including truck loading, unloading, and additional hauling truck trips.14 Thus, by failing to model all the required material export, the model underestimates the Project’s construction- related emissions and should not be relied upon to determine Project significance.

Unsubstantiated Reductions to Hauling, Worker, and Vendor Trip Numbers Review of the CalEEMod output files demonstrates that the “11469 Jefferson – Construction” model includes several manual reductions to the default number of hauling, vendor, and worker trips required for construction (see excerpt below) (Appendix A, pp. 84-85, 117-118).

13 Calculated: 43,836 cy – 31,312 cy = 12,524 cy.
14 CalEEMod User’s Guide, available at: http://www.aqmd.gov/docs/default- source/caleemod/upgrades/2016.3/01_user-39-s-guide2016-3-1.pdf?sfvrsn=2, p. 3, 26.

11 As you can see in the excerpt above, the hauling, vendor, and worker trip numbers were manually reduced to zero. As previously mentioned, the CalEEMod User’s Guide requires any changes to model defaults be justified.15 According to the “User Entered Comments and Non-Default Data” table, the justification provided for these changes is: “construction mobile emissions calculated outside CalEEMod” (Appendix A, pp. 82, 115). Furthermore, the AQ Emissions Worksheets provide the input values utilized for the Project’s on-road construction-related emissions calculations (see excerpt below) (Appendix A, pp. 147).

However, the IS/MND’s analysis of the Project’s on-road construction-related emissions is incorrect for two reasons.

First, the AQ Emissions Worksheets fails to provide a source or calculations explaining how the worker and hauling trip numbers were derived. Specifically, while the IS/MND provides the total number of hauling and worker trips required for Project construction, the document fails to provide the daily

15 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 2, 9

12 hauling and vendor trip numbers (p. B-24). Furthermore, the IS/MND fails to provide the total or daily number of worker trips. This is incorrect, because the hauling, vendor, and worker trip numbers relied upon by the Project’s on-road construction-related emissions calculations are different than the CalEEMod default values. 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” (emphasis added).16
As you can see in the excerpt, the any changes to default values should be supported by substantial evidence. As the Project fails to provide substantial evidence to support the hauling, vendor, and worker trip numbers relied upon by the Project’s on-road construction-related emissions calculations, we cannot verify the revised values. Thus, despite the fact that the AQ Emissions Worksheets include an analysis of the Project’s on-road construction-related emissions outside of CalEEMod, the IS/MND should still justify the hauling, vendor, and worker trip numbers utilized.

Second, while the AQ Emissions Worksheets provides the analysis of the Project’s on-road construction- related emissions, the IS/MND and associated documents fail to provide the total on-road construction- related emissions associated with hauling, vendor, and worker trips, or demonstrate how the on-road construction-related emissions were summed with the construction-related emissions estimated in CalEEMod (see excerpt below) (p. B-9, Table B-1).

16 CalEEMod Model 2013.2.2 User’s Guide, available at: http://www.aqmd.gov/docs/default- source/caleemod/usersguideSept2016.pdf?sfvrsn=6, p. 12.

13 As you can see in the excerpt above, the IS/MND fails to indicate how the on-road construction-related emissions estimated outside of CalEEMod were included in the maximum daily construction emissions.

Absent an explanation of how the on-road construction-related emissions were summed with the construction-related emissions estimated by CalEEMod, we cannot verify the analysis included in the AQ Emissions Worksheet.

These unsubstantiated changes present an issue, as CalEEMod uses hauling, vendor, and worker trips to calculate the Project’s construction-related emissions associated with on-road vehicles.17 Thus, by including unsubstantiated changes to the default hauling, vendor, and worker construction trips, the model may underestimate the Project’s mobile-source construction-related emissions and should not be relied upon to determine Project significance.

Unsubstantiated Changes to Operational Vehicle Fleet Mix Review of the CalEEMod output files demonstrates that the “11469 Jefferson – Operations” model includes several changes to the default operational vehicle fleet mix percentages (see excerpt below) (Appendix A, pp. 490, 540).

17 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 34. 14 As you can see in the excerpt above, the operational vehicle fleet mix percentages were altered in the model. As previously mentioned, the CalEEMod User’s Guide requires any changes to model defaults be justified.18 However, no justification was provided in the “User Entered Comments and Non-Default Data” table. Furthermore, the IS/MND and associated documents fail to mention or justify the revised operational vehicle fleet mix percentages whatsoever. As a result, we cannot verify the revised percentages included in the model.

These unsubstantiated changes present an issue, as operational vehicle fleet mix percentages are used by CalEEMod to calculate the Project’s operational emissions associated with on-road vehicles.19 Thus, by including unsubstantiated changes to the default operational vehicle fleet mix percentages, the model may underestimate the Project’s mobile-source operational emissions and should not be relied upon to determine Project significance.

18 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 2, 9 19 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 2, 9

15 Unsubstantiated Changes to Operational Vehicle Emission Factors Review of the CalEEMod output files demonstrates that the “11469 Jefferson – Operations” model includes several changes to the default operational vehicle emission factors (Appendix A, pp. 491-534, 541-584). As previously mentioned, the CalEEMod User’s Guide requires any changes to model defaults be justified.20 According to the “User Entered Comments and Non-Default Data” table, the justification provided for these changes is: “Updated to EMFAC2017 EFs” (Appendix A, pp. 489, 539). Furthermore, the IS/MND states:
“CalEEMod was used to estimate mobile source emissions where emissions factors from CARB’s updated version of the on-road vehicle emissions factor (EMFAC) model were input into CalEEMod to calculate mobile GHG emissions. The most recent version is EMFAC2017, which ‘represents CARB's current understanding of motor vehicle travel activities and their associated emission levels’” (p. B-37).

However, this justification is insufficient, as EMFAC refers to an entire database, not a specific set of vehicle emission factors.21 Thus, the IS/MND and associated documents should have specified which input parameters were used to obtain the vehicle emission factors inputted in the model, or provided the revised vehicle emission factors themselves. Absent the specific input parameters, we cannot verify the altered vehicle emission factors, and the changes may be incorrect. These unsubstantiated changes present an issue, as CalEEMod uses vehicle emission factors to calculate the Project’s operational emissions associated with on-road vehicles.22 Thus, by including several unsubstantiated changes to the default operational vehicle emission factors, the model may underestimate the Project’s mobile-source operational emissions and should not be relied upon to determine Project significance.

Incorrect Application of Construction-Related Mitigation Measures Review of the CalEEMod output files demonstrates that the “11469 Jefferson – Construction” model includes the following construction-related mitigation measures (see excerpt below) (Appendix A, pp. 89, 124):

Furthermore, the model includes a 15 miles per hour (“MPH”) vehicle speed (see excerpt below) (Appendix A, pp. 82, 115).

20 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 2, 9 21 “EMFAC2017 Web Database.” CARB, available at: https://arb.ca.gov/emfac/2017/. 22 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 35.

16 As previously mentioned, the CalEEMod User’s Guide requires any changes to model defaults be justified.23 According to the “User Entered Comments and Non-Default Data” table, the justification provided for the inclusion of construction-related mitigation measures is: “All Diesel equipment>50 HP would meet Tier 4 Final engine standards” (Appendix A, pp. 82, 115). Furthermore, the IS/MND states:
“The Project would also comply with SCAQMD regulations for controlling fugitive dust pursuant to SCAQMD Rule 403” (p. B-6).

However, these justifications are insufficient for four reasons.

First, the justification provided in the “User Entered Comments & Non-Default Data” table only applies to the inclusion of Tier 4 Final mitigation, thus failing to address the above-mentioned construction- related mitigation measures.

Second, this measure is not included in the Project’s Mitigation Monitoring Program, provided as Attachment C to the IS/MND. As a result, we cannot verify that the measure would be implemented, monitored, and enforced on the Project site.

Third, simply because the IS/MND states that the Project would comply with SCAQMD Rule 403 does not justify the inclusion of the above-mentioned construction-related mitigation measures in the model.

According to the Association of Environmental Professionals (“AEP”) CEQA Portal Topic Paper on mitigation measures:
“By definition, mitigation measures are not part of the original project design. Rather, mitigation measures are actions taken by the lead agency to reduce impacts to the environment resulting from the original project design. Mitigation measures are identified by the lead agency after the project has undergone environmental review and are above-and-beyond existing laws, regulations, and requirements that would reduce environmental impacts” (emphasis added).24 As you can see in the excerpt above, mitigation measures “are not part of the original project design” and are intended to go “above-and-beyond” existing regulatory requirements. As such, the inclusion of these measures, based on the Project’s compliance with SCAQMD Rule 403, is unsubstantiated.

Fourth, according to SCAQMD Rule 403, Projects can either water unpaved roads 3 times per day, water unpaved roads 1 time per day and limit vehicle speeds to 15 mph or apply a chemical stabilizer (see excerpt below).25

23 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 2, 9 24 “CEQA Portal Topic Paper Mitigation Measures.” AEP, February 2020, available at:
https://ceqaportal.org/tp/CEQA%20Mitigation%202020.pdf, p. 5. 25 “RULE 403. FUGITIVE DUST.” SCAQMD, June 2005, available at: http://www.aqmd.gov/docs/default-source/rule- book/rule-iv/rule-403.pdf, p. 403-21, Table 2.

17 As you can see in the above excerpt, to simply comply with SCAQMD Rule 403, the Project may either water unpaved roads 3 times per day, water unpaved roads 1 time per day and limit vehicle speeds to 15 mph, or apply a chemical stabilizer. Thus, none of the measures included in the CalEEMod model are explicitly required by SCAQMD Rule 403, and we cannot verify their inclusion in the model. By including several construction-related mitigation measures without properly committing to their implementation, the model may underestimate the Project’s construction-related emissions and should not be relied upon to determine Project significance.

Updated Analysis Indicates a Potentially Significant Air Quality Impact In an effort to more accurately estimate the Project’s construction-related and operational emissions, we prepared updated CalEEMod models, using the Project-specific information provided by the IS/MND.

In our updated models, we included all proposed land use types and sizes as described by the IS/MND; corrected the amount of material export; omitted the unsubstantiated changes to the individual construction phase lengths, off-road construction equipment unit amounts and usage hours, construction trip numbers, operational vehicle emission factors, and operational vehicle fleet mix percentages; and excluded the unsubstantiated construction-related mitigation measures. Our updated analysis estimates that the ROG/VOC and NOX emissions associated with Project construction exceed the 75- and 100-pounds per day (“lbs/day”) thresholds set by the SCAQMD, respectively (see table below).26
Construction Model ROG/VOC NOX
SWAPE 229.42 755.85
IS/MND 15.00 47.00
% Increase 1429% 1508%
SCAQMD Regional Threshold (lbs/day) 75 100
Threshold Exceeded? Yes Yes
As demonstrated above, when modeled correctly, the Project’s construction-related ROG/VOC and NOx emissions increase by approximately 1,429% and 1,508%, respectively, and exceed the applicable

26 “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.

18 SCAQMD significance thresholds. Thus, our model demonstrates that the Project would result in a potentially significant air quality impact that was not previously identified or addressed in the IS/MND.

As a result, an EIR should be prepared to adequately assess and mitigate the potential air quality impacts that the Project may have on the surrounding environment.

Diesel Particulate Matter Health Risk Emissions Inadequately Evaluated The IS/MND concludes that the proposed Project would have a less-than-significant health risk impact based on a quantified construction health risk assessment (“HRA”), as well as a localized significance (“LST”) analysis (p. B-14 – B-15). Specifically, the IS/MND estimates that the Project’s construction- related cancer risk would be 9.2 in one million, which would not exceed the SCAQMD threshold of 10 in one million (see excerpt below) (p. B -14, Table B-5).

Regarding the potential health risk impacts associated with Project operation, the IS/MND states:
“The Project is not anticipated to generate a substantial number of daily truck trips. Under existing conditions, trucks currently make deliveries from the service alley to the northwest of the Project Site. With implementation of the Project, delivery truck loading and unloading would be moved to the interior of the Project Site in dedicated loading areas, creating greater separation between trucks and off-site sensitive receptors. Furthermore, typical sources of hazardous TACs include industrial manufacturing processes and automotive repair facilities. The Project would not include any of these potential sources, although minimal emissions may result from the use of consumer products (e.g., aerosol sprays). Based on this, the Project is not expected to release substantial amounts of TACs. Therefore, based on the limited activity of TAC sources and TAC concentrations at off-site sensitive receptors relative to existing conditions, the Project would not warrant the need for a health risk assessment associated with on-site activities, and potential TAC impacts would be less than significant” (p. B-15).

However, the IS/MND’s evaluation of the Project’s potential health risk impacts, as well as the subsequent less-than-significant impact conclusion, is incorrect for five reasons.

First, the IS/MND’s construction HRA is incorrect, as it relies upon an exhaust PM10 estimate from a flawed air model (Appendix A, p. 44). As previously discussed, when we reviewed the Project's CalEEMod output files, provided in the AQ Emissions Worksheets as Appendix A to the IS/MND, we found that several of the values inputted into the model are not consistent with information disclosed in

19 the IS/MND and associated documents. As a result, the construction HRA utilizes an underestimated diesel particulate matter (“DPM”) concentration to calculate the cancer risk associated with Project construction. As such, the IS/MND underestimates the Project’s construction-related cancer risk and should not be relied upon to determine Project significance.

Second, the IS/MND’s claims that the Project’s operational toxic air contaminant (“TAC”) emissions would be less than significant impact, because the Project would result in “greater separation between trucks and off-site sensitive receptors and would not “generate a substantial number of daily truck trips” or include common sources of TACs any of these potential sources are unsupported. Rather, according to the IS/MND, Project operation would generate 1,463 new daily vehicle trips, which would result in additional exhaust emissions and continue to expose nearby sensitive receptors to DPM emissions (p. B- 92). Without making a reasonable effort to connect the Project’s operational TAC emissions to the potential health risks posed to nearby receptors, the IS/MND should not conclude that the Project’s operational health risk impact would be less than significant.

Third, the omission of a quantified operational HRA is inconsistent with the most recent guidance published by the Office of Environmental Health Hazard Assessment (“OEHHA”). The OEHHA document recommends that exposure from projects lasting more than 6 months be evaluated for the duration of the project and recommends that an exposure duration of 30 years be used to estimate individual cancer risk for the maximally exposed individual resident (“MEIR”).27 Even though we were not provided with the expected lifetime of the Project, we can reasonably assume that the Project will operate for at least 30 years, if not more. Therefore, we recommend that health risk impacts from Project operation also be evaluated, as a 30-year exposure duration vastly exceeds the 6-month requirement set forth by OEHHA. These recommendations reflect the most recent state health risk policies, and as such, we recommend that an updated assessment of health risk impacts posed to nearby sensitive receptors from Project operation be included in an EIR for the Project Fourth, while the IS/MND includes a construction HRA, the IS/MND fails to evaluate the cumulative lifetime cancer risk to nearby, existing receptors as a result of Project construction and operation together. According to OEHHA guidance, as referenced by the AQ Technical Report, “the excess cancer risk is calculated separately for each age grouping and then summed to yield cancer risk at the receptor location” (p. 16).28 Here, however, the IS/MND fails to conduct a construction-related and operational HRA, as well as sum each age bin to evaluate the total cancer risk over the course of Project construction and operation. This is incorrect and, thus, an EIR should be prepared, quantifying the Project’s construction and operational cancer risks and summing them to compare to the SCAQMD threshold 10 in one million.29

27 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: http://oehha.ca.gov/air/hot_spots/2015/2015GuidanceManual.pdf, p. 8-6, 8-15 28 “Guidance Manual for preparation of Health Risk Assessments.” OEHHA, February 2015, available at:
https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf p. 8-4 29 “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. 20 Fifth, the IS/MND concludes that the Project’s construction-related criteria air pollutant emissions would not exceed the applicable SCAQMD Localized Significance Thresholds (“LSTs”) (see excerpt below) (p. B- 12).

However, this is incorrect. Review of the CalEEMod output files demonstrates that the PM10 and PM2.5 emissions associated with Project construction exceed the 1- and 2-lbs/day LSTs set by the SCAQMD, respectively (see excerpt below) (Appendix A, pp. 86, 119).

21 As you can see in the excerpt above, the Project’s estimated construction-related PM10 and PM2.5 emissions are 2.4122- and 1.3351-lbs/day, respectively. Thus, the Project’s estimated construction- related PM10 and PM2.5 emissions exceed the applicable LST thresholds set by the SCAQMD. As such, the IS/MND’s claim that emissions associated with Project construction would not exceed the applicable SCAQMD LSTs is incorrect, and the subsequent less-than-significant health risk impact conclusion should not be relied upon.

Screening-Level Assessment Indicates a Potentially Significant Health Risk Impact In an effort to demonstrate the potential health risk posed by the construction and operation of the Project to nearby, existing sensitive receptors, we prepared a simple screening-level operational HRA.

The results of our assessment, as described below, demonstrate that the proposed Project would have a potentially significant impact.

In order to conduct our screening-level risk assessment we relied upon AERSCREEN, which is a screening level air quality dispersion model.30 The model replaced SCREEN3, and AERSCREEN is included in the OEHHA31 and the California Air Pollution Control Officers Associated (CAPCOA)32 guidance as the appropriate air dispersion model for Level 2 health risk screening assessments (“HRSAs”). 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 health-related impact to sensitive receptors using the annual PM10 exhaust estimates from the IS/MND’s annual CalEEMod output files. Consistent with recommendations set forth by OEHHA, we used a residential exposure duration of 30 years, starting from the 3rd trimester stage of life. Subtracting the 726-day construction period from the total residential duration of 30 years, we assumed that after Project construction, the sensitive receptor would be exposed to the Project’s operational DPM for an additional 28 years, approximately.

The IS/MND’s annual CalEEMod output file indicates that operational activities will generate approximately 45 pounds of DPM per year over approximately 28 years of operation. 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 operation, we calculated an average DPM emission rate by the following equation.

𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅 �𝑔𝑔𝑔𝑔𝑅𝑅𝐸𝐸𝐸𝐸
𝐸𝐸𝑅𝑅𝑠𝑠𝐸𝐸𝐸𝐸𝑠𝑠� = 45.2 𝑙𝑙𝑙𝑙𝐸𝐸
365 𝑠𝑠𝑅𝑅𝑑𝑑𝐸𝐸 × 453.6 𝑔𝑔𝑔𝑔𝑅𝑅𝐸𝐸𝐸𝐸
𝑙𝑙𝑙𝑙𝐸𝐸 × 1 𝑠𝑠𝑅𝑅𝑑𝑑
24 ℎ𝐸𝐸𝑜𝑜𝑔𝑔𝐸𝐸 × 1 ℎ𝐸𝐸𝑜𝑜𝑔𝑔
3,600 𝐸𝐸𝑅𝑅𝑠𝑠𝐸𝐸𝐸𝐸𝑠𝑠𝐸𝐸= 𝟎𝟎. 𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎 𝒈𝒈/𝒔𝒔

30 U.S. EPA (April 2011) AERSCREEN Released as the EPA Recommended Screening Model, http://www.epa.gov/ttn/scram/guidance/clarification/20110411_AERSCREEN_Release_Memo.pdf 31 Supra, fn 20.
32 CAPCOA (July 2009) Health Risk Assessments for Proposed Land Use Projects, http://www.capcoa.org/wp- content/uploads/2012/03/CAPCOA_HRA_LU_Guidelines_8-6-09.pdf. 22 Using this equation, we estimated an operational emission rate of 0.00065 g/s. Operation was simulated as a 0.78-acre rectangular area source in AERSCREEN, with dimensions of 77 meters by 41 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 AERSCREEN model generates maximum reasonable estimates of single-hour DPM concentrations from the Project Site. EPA guidance suggests that in screening procedures, the annualized average concentration of an air pollutant to be estimated by multiplying the single-hour concentration by 10%.33 According to the IS/MND, the closest residential receptors are located 25 meters north and west of the Project site (p. B-12). As such, we utilized the single-hour concentrations at 25 meters from the Project site. Thus, for Project operation, the single-hour concentration at the MEIR estimated by AERSCREEN is approximately 4.006 µg/m3 DPM at approximately 25 meters downwind. Multiplying this single-hour concentration by 10%, we get an annualized average concentration of 0.4006 µg/m3 for Project operation at the MEIR.

We calculated the excess cancer risk to the MEIR using applicable HRA methodologies prescribed by OEHHA. Consistent with the construction period of 726 days inputted into the IS/MND’s CalEEMod model, the annualized average concentration for Project operation was used for the remaining 0.26 years of the infantile stage of life (0 – 2 years), the entire the child stage of life (2 - 16 years), and adult stage of life (16 – 30 years).

Consistent with OEHHA, as recommended by SCAQMD, BAAQMD, and SJVAPCD guidance, and referenced by the AQ Technical Report, we used Age Sensitivity Factors (“ASFs”) to account for the heightened susceptibility of young children to the carcinogenic toxicity of air pollution (p. 16).34, 35, 36, 37 According to this guidance, the quantified cancer risk should be multiplied by a factor of ten during the third trimester of pregnancy and during the first two years of life (infant) as well as multiplied by a factor of three during the child stage of life (2 – 16 years). Furthermore, in accordance with the guidance set

33 U.S. EPA (October 1992) Screening Procedures for Estimating the Air Quality Impact of Stationary Sources Revised, http://www.epa.gov/ttn/scram/guidance/guide/EPA-454R-92-019_OCR.pdf. 34 “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. 35 “Draft Environmental Impact Report (DEIR) for the Proposed The Exchange (SCH No. 2018071058).” SCAQMD, March 2019, available at: http://www.aqmd.gov/docs/default-source/ceqa/comment- letters/2019/march/RVC190115-03.pdf?sfvrsn=8, p. 4.
36 “California Environmental Quality Act Air Quality Guidelines.” BAAQMD, May 2017, available at:
http://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en, p. 56; see also “Recommended Methods for Screening and Modeling Local Risks and Hazards.” BAAQMD, May 2011, available at:
http://www.baaqmd.gov/~/media/Files/Planning%20and%20Research/CEQA/BAAQMD%20Modeli ng%20Approac h.ashx, p. 65, 86.
37 “Update to District’s Risk Management Policy to Address OEHHA’s Revised Risk Assessment Guidance Document.” SJVAPCD, May 2015, available at: https://www.valleyair.org/busind/pto/staff-report-5-28-15.pdf, p. 8, 20, 24.
23 forth by OEHHA, we used the 95th percentile breathing rates for infants.38 Finally, according to SCAQMD guidance, we used a Fraction of Time At Home (“FAH”) Value of 1 for the 3rd trimester and infant receptors.39 We used a cancer potency factor of 1.1 (mg/kg-day)-1 and an averaging time of 25,550 days.

The results of our calculations are shown below.

The Maximum Exposed Individual at an Existing Residential Receptor (MEIR) Activity Duration
(years)
Concentration
(ug/m3)
Breathing
Rate (L/kg-
day)
ASF Cancer Risk
with ASFs*
Construction 0.25 N/A 361 10 N/A
3rd Trimester
Duration 0.25
3rd
Trimester
Exposure
N/A
Construction 1.74 N/A 1090 10 N/A
Operation 0.26 0.4006 1090 10 1.7E-05
Infant Exposure
Duration 2.00 Infant
Exposure 1.7E-05
Operation 14.00 0.4006 572 3 1.5E-04
Child Exposure
Duration 14.00 Child
Exposure 1.5E-04
Operation 14.00 0.4006 261 1 1.6E-05
Adult Exposure
Duration 14.00 Adult
Exposure 1.6E-05
Lifetime Exposure
Duration 30.00 Lifetime
Exposure 1.8E-04
As demonstrated in the table above, the excess cancer risk to adults, children, and infants at the MEIR located approximately 25 meters away, over the course of Project operation, are approximately 16, 150 and 17 in one million, respectively. The estimated excess cancer risk over the course of a residential lifetime (30 years), as a result of Project operation alone, is approximately 180 in one million. When summing the Project’s estimated operational cancer risk, with the IS/MND’s estimated construction- related cancer risk of 9.2 in one million, we calculated a lifetime construction and operational cancer risk of 189.2 in one million.40 The infant, child, adult, and lifetime cancer risks exceed the SCAQMD threshold

38 “Supplemental Guidelines for Preparing Risk Assessments for the Air Toxics ‘Hot Spots’ Information a nd Assessment Act,” July 2018, available at: http://www.aqmd.gov/docs/default-source/planning/risk- assessment/ab2588supplementalguidelines.pdf, p. 16.
“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 39 “Risk Assessment Procedures for Rules 1401, 1401.1, and 212.” SCAQMD, August 2017, available at:
http://www.aqmd.gov/docs/default-source/rule-book/Proposed- Rules/1401/riskassessmentprocedures_2017_080717.pdf, p. 7. 40 Calculated: 180 in one million + 9.2 in one million = 189.2 in one million. 24 of 10 in one million, thus resulting in a potentially significant impact not previously addressed or identified by the IS/MND.

An agency must include an analysis of health risks that connects the Project’s air emissions with the health risk posed by those emissions. 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 construction and operational HRA shown above is to demonstrate the link between the proposed Project’s emissions and the potential health risk. Our screening-level HRA demonstrates that construction and operation of the Project could result in a potentially significant health risk impact, when correct exposure assumptions and up-to-date, applicable guidance are used. Therefore, since our screening-level construction HRA indicates a potentially significant impact, an EIR should include a reasonable effort to connect the Project’s air quality emissions and the potential health risks posed to nearby receptors. Thus, an EIR should include a quantified air pollution model as well as an updated, quantified refined health risk assessment 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 IS/MND estimates that the Project would generate net annual greenhouse gas (“GHG”) emissions of 1,537 metric tons of carbon dioxide equivalents per year (“MT CO2e/year”) (p. B-39, Table B-9). 25 However, the IS/MND fails to compare the Project’s estimated GHG emissions to any quantitative threshold, stating:
“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, SCAG’s 2020-2045 RTP/SCS, and City of Culver City polices established for the purpose of increasing energy efficiency and reducing GHG emissions for new developments and the City’s Green Building Code” (p. B-35).

As demonstrated above, the IS/MND relies upon the Project’s consistency with the CARB’s Scoping Plan, SCAG’s RTP/SCS, the City’s energy efficiency policies, and the City’s Green Building Code in order to conclude that the Project would have a less-than-significant GHG impact. However, the IS/MND’s GHG analysis, as well as the subsequent less-than-significant impact conclusion, is incorrect for six reasons.

26 (1) The IS/MND’s quantitative GHG analysis relies upon an incorrect and unsubstantiated air model; (2) CARB’s 2017 Scoping Plan, SCAG’s 2020-2045 RTP/SCS, and the City’s energy efficiency policies should not be relied upon to determine Project significance; (3) The IS/MND fails to consider a quantitative GHG threshold; (4) The IS/MND fails to identify a potentially significant GHG impact; (5) The IS/MND fails to consider the performance-based standards under CARB’s Scoping Plan; and (6) The IS/MND fails to consider the performance-based standards under SCAG’s RTP/SCS. 1) Incorrect and Unsubstantiated Quantitative Analysis of Emissions As previously stated, the IS/MND estimates that the Project would generate net annual GHG emissions of 1,537 MT CO2e/year (p. B-39, Table B-9). However, the IS/MND’s quantitative GHG analysis is unsubstantiated, as it relies upon a flawed air model. As previously discussed, when we reviewed the Project's CalEEMod output files, provided in AQ Emissions Worksheets as Appendix A to the IS/MND, we found that several of the values inputted into the model are not consistent with information disclosed in the IS/MND. As a result, the model underestimates the Project’s emissions, and the IS/MND’s quantitative GHG analysis should not be relied upon to determine Project significance. A Project-specific EIR should be prepared that adequately assesses the potential GHG impacts that construction and operation of the proposed Project may have on the surrounding environment. 2) Incorrect Reliance on CARB’s 2017 Scoping Plan, SCAG’s 2020-2045 RTP/SCS, and the Sustainable City pLAn/L.A.’s Green New Deal
As previously discussed, the IS/MND relies upon the Project’s consistency with CARB’s 2017 Scoping Plan, SCAG’s 2020-2045 RTP/SCS, and the City’s energy efficiency policies in order to conclude that the Project’s GHG impact would be less than significant. However, these plans and policies do not qualify as adequate GHG reduction plans or CAPs under CEQA. CEQA Guidelines § 15064.4(b)(3) and § 15183(b) allow a lead agency to consider a project’s consistency with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions. When read in conjunction, CEQA Guidelines § 15064.4(b)(3) and § 15183.5(b)(1) make clear that qualified GHG reduction plans or CAPs should include the following features:
(1) Inventory: Quantify GHG emissions, both existing and projected over a specified time period, resulting from activities (e.g., projects) within a defined geographic area (e.g., lead agency jurisdiction);
(2) Establish GHG Reduction Goal: Establish a level, based on sub stantial evidence, below which the contribution to GHG emissions from activities covered by the plan would not be cumulatively considerable;
(3) Analyze Project Types: Identify and analyze the GHG emissions resulting from specific actions or categories of actions anticipated within the geographic area; (4) Craft Performance Based Mitigation Measures : Specify measures or a group of measures, including performance standards, that substantial evidence demonstrates, if implemented on a project-by-project basis, would collectively achieve the specified emissions level; (5) Monitoring: Establish a mechanism to monitor the CAP progress toward achieving said level and to require amendment if the plan is not achieving specified levels . 27 Collectively, the above-listed features tie qualitative measures to quantitative results, which in turn become binding via proper monitoring and enforcement by the jurisdiction—all resulting in real GHG reductions for the jurisdiction as a whole, and substantial evidence demonstrating that a project’s incremental contribution is not cumulatively considerable. Here, however, the IS/MND fails to demonstrate that these plans and policies include the above-listed requirements to be considered qualified GHG Reduction Plans or CAPs for the City. As such, the IS/MND leaves an analytical gap showing that compliance with said plans and policies can be used for a project-level significance determination. Thus, the IS/MND’s GHG significance determination regarding CARB’s 2017 Scoping Plan, SCAG’s 2020-2045 RTP/SCS, and the City’s energy efficiency policies should not be relied upon. 3) Failure to Apply a Quantitative GHG Threshold
As previously stated, the IS/MND estimates that the Project would generate net annual GHG emissions of 1,537 MT CO2e/year (p. B-39, Table B-9). However, the IS/MND fails to apply a quantitative GHG threshold to evaluate the Project’s emissions, instead incorrectly relying upon the Project’s consistency with CARB’s 2017 Scoping Plan, SCAG’s 2020-2045 RTP/SCS, and the City’s energy efficiency policies, as described above. Since the IS/MND should not rely upon the Project’s consistency with these plans and policies to determine Project significance, we recommend that the Project apply the AEP’s “2030 Land Use Efficiency Threshold” of 2.6 metric tons of CO2 equivalents per service population per year (“MT CO2e/SP/year”).41 In support of this threshold for projects with a horizon year beyond 2020, AEP’s guidance states:
“Once the state has a full plan for 2030 (which is expected in 2017), and then a project with a horizon between 2021 and 2030 should be evaluated based on a threshold using the 2030 target. A more conservative approach would be to apply a 2030 threshold based on SB 32 for any project with a horizon between 2021 and 2030 regardless of the status of the Scoping Plan Update” (emphasis added).42
As the California Air Resources Board (“CARB”) adopted California’s 2017 Climate Change Scoping Plan in November of 2017, the proposed Project “should be evaluated based on a threshold using the 2030 target,” according to the relevant guidance referenced above. We recommend that an updated EIR be prepared, including an updated air model and comparing the Project’s estimated GHG emissions to the AEP’s “2030 Land Use Efficiency Threshold” of 2.6 MT CO2e/SP/year. 4) Incorrect and Unsubstantiated Quantitative Analysis of Emissions The IS/MND’s incorrect and unsubstantiated air model indicates a potentially significant GHG impact, when applying the “2030 Land Use Efficiency Threshold” of 2.6 MT CO2e/SP/year. As previously stated, the IS/MND estimates that the Project would generate net annual GHG emissions of 1,537 MT

41 “Beyond Newhall and 2020: A Field Guide to New CEQA Greenhouse Gas Thresholds and Climate Action Plan Targets for California.” Association of Environmental Professionals (AEP), October 2016, available at:
https://califaep.org/docs/AEP-2016_Final_White_Paper.pdf, p. 40. 42 “Beyond Newhall and 2020: A Field Guide to New CEQA Greenhouse Gas Thresholds and Clim ate Action Plan Targets for California.” Association of Environmental Professionals (AEP), October 2016, available at:
https://califaep.org/docs/AEP-2016_Final_White_Paper.pdf, p. 40. 28 CO2e/year (p. B-39, Table B-9). Furthermore, according to CAPCOA’s CEQA & Climate Change report, service population is defined as “the sum of the number of residents and the number of jobs supported by the project.”43 The IS/MND estimates that the Project would employ approximately 130 people upon buildout (p. B-76). As the Project does not include any residential land uses, we estimate a service population of 130 people.44 Dividing the Project’s GHG emissions, as estimated by the IS/MND, by a service population value of 130 people, we find that the Project would emit approximately 11.8 MT CO2e/SP/year (see table below).45
IS/MND Service Population Efficiency
Project Phase Proposed Project (MT
CO2e/year)
Total 1,537
Service Population 130
Service Population Efficiency 11.8
Threshold 2.6
Exceed? Yes
As demonstrated above, when we compare the Project’s per service population GHG emissions to the AEP’s “2030 Land Use Efficiency Threshold” of 2.6 MT CO2e/SP/year, we find that the Project would result in a significant GHG impact not previously identified or addressed by the IS/MND. Therefore, an EIR should be prepared and recirculated for the Project, and mitigation should be implemented where necessary.
5) Failure to Consider Performance-based Standards Under CARB’s 2017 Scoping Plan As previously discussed, the IS/MND relies upon the Project’s consistency with CARB’s 2017 Scoping Plan to determine Project GHG significance. However, this is incorrect, as the IS/MND fails to consider performance-based measures proposed by CARB.
i. Passenger & Light Duty VMT Per Capita Benchmarks per SB 375 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.46 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

43 CAPCOA (Jan. 2008) CEQA & Climate Change, p. 71-72, http://www.capcoa.org/wp- content/uploads/2012/03/CAPCOA-White-Paper.pdf.
44 Calculated: 130 employees + 0 residents = 130 service population. 45 Calculated: (1,537 MT CO2e/year) / (130 service population) = (11.8 MT CO2e/SP/year). 46 “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 Organizations (MPOs) pursuant to SB 375 as of 2015.”47 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), 2022 (Project operational year), and 2030 (target years under SB 32) (see table below and Attachment B).
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 2022 10,534,881 220,487,425.77 20.93 41,321,565 916,010,145.57 22.17 2030 10,868,614 215,539,586.12 19.83 43,939,250 957,178,153.19 21.78 The below table compares the 2017 Scoping Plan daily VMT per capita values against the daily VMT per capita values for the Project based on the IS/MND’s modeling (see table below and Attachment B).

Daily VMT Per Capita from Passenger & Light-Duty Trucks, Exceedances under 2017 Scoping Plan Performance-Based SB 375 Benchmarks Sources Project
IS/MND Modeling
Annual VMT from Auto & Light-Duty Vehicles 3,207,802
Daily VMT from Auto & Light-Duty Vehicles 8,788
Service Population 130
Daily VMT Per Capita 67.60
2017 Scoping Plan Benchmarks, Statewide

22.40 VMT (2010 Baseline) Exceed? Yes

22.17 VMT (2022 Projected) Exceed? Yes

21.78 VMT (2030 Projected) Exceed? Yes
2017 Scoping Plan Benchmarks, Los Angeles County Specific

22.05 VMT (2010 Baseline) Exceed? Yes

20.93 VMT (2022 Projected) Exceed? Yes

19.83 VMT (2030 Projected) Exceed? Yes
As shown above, the IS/MND’s modeling shows that the Project exceeds the CARB 2017 Scoping Plan projections for 2010, 2022, and 2030. Because the exceeds the CARB 2017 Scoping Plan performance- based daily VMT per capita projections, the Project conflicts with the CARB 2017 Scoping Plan and SB 375. As such, the IS/MND’s claim that the proposed Project would not conflict with the CARB 2017

47 “Supporting Calculations for 2017 Scoping Plan-Identified VMT Reductions,” Excel Sheet “Readme.” CARB, January 2019, available at: https://ww2.arb.ca.gov/sites/default/files/2019- 01/sp_mss_vmt_calculations_jan19_0.xlsx.
30 Scoping Plan is incorrect and unsubstantiated. A Project-specific EIR should be prepared for the proposed Project to provide additional information and analysis to conclude less than significant GHG impacts.
6) Failure to Consider Performance-based Standards under SCAG’s RTP/SCS Here, as discussed above, the IS/MND concludes that the Project would be consistent with SCAG’s RTP/SCS. However, the IS/MND 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 Program Environmental Impact Report (“PEIR”),48 in which the 2020 RTP/SCS PEIR updates the per capita emissions to 21.3 lbs/day in 2020 and 18.8 lbs/day in 2035 (see excerpt below). 49

In order to evaluate consistency with this SB 375 objective and SCAG’s RTP/SCS performance-based goals, SWAPE calculated the Project’s per-capita CO2 emissions from passenger and light duty vehicles (calculations attached hereto as Attachment B). First, total annual GHG mobile emissions were multiplied by the percentage of auto and light-duty truck fleet mix, then converted into total pounds per

48 “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. 49 “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 day, then divided by the estimated service population of 130. The below table shows the per capita emissions for the Project based on the IS/MND’s modeling (see table below and Attachment B).

CO2e Per Capita Emissions from Passenger & Light-Duty Trucks, Exceedances under RTP/SCS Performance-Based SB 375 Goals Sources
Project
IS/MND Modeling
Annual Mobile Emissions (MT CO2e/year) 1,222.85
Passenger & Light-Duty Fleet Mix (%) 91.89%
Daily CO2e Emissions (lbs/day) 6,787.00
Service Population 130
Per Capita Emissions (lbs/day) 52.21

21.3 lbs/day/SP (2020 Goal) Exceeded? Yes

18.8 lbs/day/SP (2035 Goal) Exceeded? Yes
As shown in the above table, when utilizing the IS/MND’s modeling, the Project would result in 52.21 pounds per day per service population (“lbs/day/SP”) emissions. This exceeds both SCAG’s 2020 and 2035 targets of 21.3- and 18.8-lbs/day/SP, respectively, indicating that the Project is inconsistent with SB 375 and SCAG’s RTP/SCS.
i. 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 2045.50 Daily VMT per capita in Los Angeles County should decrease from

22.2 to 19.2 VMT during that same period.51
Here, however, the IS/MND fails to consider any of the abovementioned performance-based VMT targets. In order to evaluate consistency with the RTP/SCS’s performance-based VMT reduction targets, SWAPE calculated the Project’s VMT from passenger and light duty vehicles (calculations attached hereto as Attachment B). First, annual VMTs from passenger automobile and light-duty vehicle were calculated based on the CalEEMod default fleet mix, converted into daily VMT, and divided by the estimated service population of 130. The below table shows the daily VMT per capita for the Project based on the IS/MND’s modeling (see table below and Attachment B).

50 “Connect SoCal.” SCAG, September 2020, available at: https://scag.ca.gov/sites/main/files/file- attachments/0903fconnectsocal-plan_0.pdf?1606001176, pp. 138. 51 “Connect SoCal.” SCAG, September 2020, available at: https://scag.ca.gov/sites/main/files/file- attachments/0903fconnectsocal-plan_0.pdf?1606001176, pp. 138. 32 Daily VMT Per Capita from Passenger & Light-Duty Trucks, Exceedances under RTP/SCS Performance-Based SB 375 Target Sources
Project
IS/MND
Modeling
Annual VMT from Auto & Light-Duty Vehicles 3,207,802
Daily VMT from Auto & Light-Duty Vehicles 8,788
Service Population 130
Daily VMT Per Capita 67.60
2020 RTP/SCS Benchmarks, SCAG-Wide

23.2 VMT (2016 Baseline) Exceed? Yes

20.7 VMT (2045 Target) Exceed? Yes
2020 RTP/SCS Benchmarks, Los Angeles County

22.2 VMT (2016 Baseline) Exceed? Yes

19.2 VMT (2045 Target) Exceed? Yes
As shown in the above table, based on a service population of 130, the Project would result in 67.6 daily VMT per capita from passenger auto and light-duty truck vehicles. This exceeds all SCAG-wide and Los Angeles County specific benchmarks and targets under SCAG’s 2020 RTP/SCS. Thus, based on the IS/MND’s modeling, the Project would exceed the 2016 baseline and 2045 target VMT per capita values for both Los Angeles County and the SCAG region as a whole, indicating that the Project conflicts with the SCAG’s RTP/SCS and SB 375.

Feasible Mitigation Measures Available to Reduce Emissions Our analysis demonstrates that the Project’s air quality, health risk, and GHG emissions may result in significant impacts and should be mitigated further. In an effort to reduce the Project’s emissions, we identified several mitigation measures that are applicable to the proposed Project. Feasible mitigation measures can be found in CAPCOA’s Quantifying Greenhouse Gas Mitigation Measures.52 Therefore, to reduce the Project’s emissions, consideration of the following measures should be made:

CAPCOA’s Quantifying Greenhouse Gas Mitigation Measures53 Measures – Energy
Building Energy Use
Install Programmable Thermostat Timers
Install Energy Efficient Appliances

52 http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf 53 “Quantifying Greenhouse Gas Mitigation Measures.” California Air Pollution Control Officers Association (CAPCOA), August 2010, available at: http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA- Quantification-Report-9-14-Final.pdf, p.
33 Install Energy Efficient Boilers
Lighting
Install Higher Efficacy Public Street and Area Lighting Limit Outdoor Lighting Requirements
Replace Traffic Lights with LED Traffic Lights
Alternative Energy Generation
Establish Onsite Renewable or Carbon-Neutral Energy Systems Utilize a Combined Heat and Power System
Measures – Transportation
Land Use/Location
Increase Density
Increase Location Efficiency
Increase Diversity of Urban and Suburban Developments (Mixed Use) Orient Project Toward Non-Auto Corridor
Neighborhood/Site Enhancements
Provide Traffic Calming Measures, such as:
• Marked crosswalks
• Count-down signal timers
• Curb extensions
• Speed tables
• Raised crosswalks
• Raised intersections
• Median islands
• Tight corner radii
• Roundabouts or mini-circles
• On-street parking
• Planter strips with trees
• Chicanes/chokers
Implement a Neighborhood Electric Vehicle (NEV) Network.

Create Urban Non-Motorized Zones
Provide Electric Vehicle Parking
Dedicate Land for Bike Trails
Parking Policy/Pricing
Limit Parking Supply through:
• Elimination (or reduction) of minimum parking requirements • Creation of maximum parking requirements
• Provision of shared parking
Unbundle Parking Costs from Property Cost
Implement Market Price Public Parking (On-Street)
34 Require Residential Area Parking Permits
Commute Trip Reduction Programs
Implement Commute Trip Reduction (CTR) Program – Voluntary • Carpooling encouragement
• Ride-matching assistance
• Preferential carpool parking
• Flexible work schedules for carpools
• Half time transportation coordinator
• Vanpool assistance
• Bicycle end-trip facilities (parking, showers and lockers) • New employee orientation of trip reduction and alternative mode options • Event promotions and publications
• Flexible work schedule for employees
• Transit subsidies
• Parking cash-out or priced parking
• Shuttles
• Emergency ride home
Implement Commute Trip Reduction (CTR) Program – Required Implementation/Monitoring • Established performance standards (e.g. trip reduction requirements) • Required implementation
• Regular monitoring and reporting
Provide Ride-Sharing Programs
• Designate a certain percentage of parking spaces for ride sharing vehicles • Designating adequate passenger loading and unloading and waiting areas for ride-sharing vehicles • Providing a web site or messaging board for coordinating rides • Permanent transportation management association membership and funding requirement.

Implement Subsidized or Discounted Transit Program
Provide Ent of Trip Facilities, including:
• Showers
• Secure bicycle lockers
• Changing spaces
Encourage Telecommuting and Alternative Work Schedules, such as:
• Staggered starting times
• Flexible schedules
• Compressed work weeks
Implement Commute Trip Reduction Marketing, such as:
• New employee orientation of trip reduction and alternative mode options • Event promotions
• Publications
Implement Preferential Parking Permit Program
Implement Car-Sharing Program
Implement School Pool Program
35 Provide Employer-Sponsored Vanpool/Shuttle
Implement Bike-Sharing Programs
Implement School Bus Program
Price Workplace Parking, such as:
• Explicitly charging for parking for its employees;
• Implementing above market rate pricing;
• Validating parking only for invited guests;
• Not providing employee parking and transportation allowances; and • Educating employees about available alternatives.

Implement Employee Parking “Cash-Out”
Transit System Improvements
Transit System Improvements, including:
• Grade-separated right-of-way, including bus only lanes (for buses, emergency vehicles, and sometimes taxis), and other Transit Priority measures. Some systems use guideways which automatically steer the bus on portions of the route.
• Frequent, high-capacity service
• High-quality vehicles that are easy to board, quiet, clean, and comfortable to ride. • Pre-paid fare collection to minimize boarding delays. • Integrated fare systems, allowing free or discounted transfers between routes and modes. • Convenient user information and marketing programs.
• High quality bus stations with Transit Oriented Development in nearby areas. • Modal integration, with BRT service coordinated with walking and cycling facilities, taxi services, intercity bus, rail transit, and other transportation services.

Implement Transit Access Improvements, such as:
• Sidewalk/crosswalk safety enhancements
• Bus shelter improvements
Increase Transit Service Frequency/Speed
Provide Bike Parking Near Transit
Provide Local Shuttles
Road Pricing/Management
Implement Area or Cordon Pricing
Improve Traffic Flow, such as:
• Signalization improvements to reduce delay;
• Incident management to increase response time to breakdowns and collisions; • Intelligent Transportation Systems (ITS) to provide real-time information regarding road conditions and directions; and
• Speed management to reduce high free-flow speeds.

Required Project Contributions to Transportation Infrastructure Improvement Projects Install Park-and-Ride Lots
Vehicles
Utilize Alternative Fueled Vehicles, such as:
36 • Biodiesel (B20)
• Liquefied Natural Gas (LNG)
• Compressed Natural Gas (CNG)
Utilize Electric or Hybrid Vehicles
Measures – Water
Water Supply
Use Reclaimed Water
Use Gray Water
Use Locally Sourced Water Supply
Water Use
Adopt a Water Conservation strategy
Design Water-Efficient Landscapes (see California Department of Water Resources Model Water Efficient Landscape Ordinance), such as:
• Reducing lawn sizes;
• Planting vegetation with minimal water needs, such as native species; • Choosing vegetation appropriate for the climate of the project site; • Choosing complimentary plants with similar water needs or which can provide each other with shade and/or water.

Use Water-Efficient Landscape Irrigation Systems (“Smart” irrigation control systems) Reduce Turf in Landscapes and Lawns
Plant Native or Drought-Resistant Trees and Vegetation
Measures – Area Landscaping
Landscaping Equipment
Prohibit Gas Powered Landscape Equipment
Implement Lawnmower Exchange Program
Electric Yard Equipment Compatibility
Measures – Vegetation
Vegetation
Urban Tree Planting
Create New Vegetated Open Space
Measures – Construction
Construction
Use Alternative Fuels for Construction Equipment
Urban Tree Planting
Use Electric and Hybrid Construction Equipment
Limit Construction Equipment Idling Beyond Regulation Requirements Institute a Heavy-Duty Off-Road Vehicle Plan, including:
• Construction vehicle inventory tracking system;
37 • Requiring hour meters on equipment;
• Document the serial number, horsepower, manufacture age, fuel, etc. of all onsite equipment; and
• Daily logging of the operating hours of the equipment.

Implement a Construction Vehicle Inventory Tracking System Measures – Miscellaneous
Miscellaneous
Establish a Carbon Sequestration Project, such as:
• Geologic sequestration or carbon capture and storage techniques, in which CO2 from point sources is captured and injected underground;
• Terrestrial sequestration in which ecosystems are established or preserved to serve as CO2 sinks; • Novel techniques involving advanced chemical or biological pathways; or • Technologies yet to be discovered.

Establish Off-Site Mitigation
Use Local and Sustainable Building Materials
Require best Management Practices in Agriculture and Animal Operations Require Environmentally Responsible Purchasing, such as:
• Purchasing products with sustainable packaging;
• Purchasing post-consumer recycled copier paper, paper towels, and stationary; • Purchasing and stocking communal kitchens with reusable dishes and utensils; • Choosing sustainable cleaning supplies;
• Leasing equipment from manufacturers who will recycle the components at their end of life; • Choosing ENERGY STAR appliances and Water Sense-certified water fixtures; • Choosing electronic appliances with built in sleep-mode timers; • Purchasing ‘green power’ (e.g. electricity generated from renewable or hydropower) from the utility; and
• Choosing locally-made and distributed products.

Furthermore, in an effort to reduce the Project’s emissions, we identified several mitigation measures that are applicable to the proposed Project from NEDC’s Diesel Emission Controls in Construction Projects.54 Therefore, to reduce the Project’s emissions, consideration of the following measures should be made:

NEDC’s Diesel Emission Controls in Construction Projects55 Measures – Diesel Emission Control Technology

54 “Diesel Emission Controls in Construction Projects.” Northeast Diesel Collaborative (NEDC), December 2010, available at: https://www.epa.gov/sites/production/files/2015-09/documents/nedc-model-contract- sepcification.pdf.
55 “Diesel Emission Controls in Construction Projects.” Northeast Diesel Collaborati ve (NEDC), December 2010, available at: https://www.epa.gov/sites/production/files/2015-09/documents/nedc-model-contract- sepcification.pdf.
38 a. Diesel Onroad Vehicles
All diesel nonroad vehicles on site for more than 10 total days must have either (1) engines that meet EPA onroad emissions standards or (2) emission control technology verified by EPA or CARB to reduce PM emissions by a minimum of 85%.
b. Diesel Generators
All diesel generators on site for more than 10 total days must be equipped with emission control technology verified by EPA or CARB to reduce PM emissions by a minimum of 85%. c. Upon confirming that the diesel vehicle, construction equipment, or generator has either an engine meeting Tier 4 non road emission standards or emission control technology, as specified above, installed and functioning, the developer will issue a compliance sticker. All diesel vehicles, construction equipment, and generators on site shall display the compliance sticker in a visible, external location as designated by the developer.
d. Emission control technology shall be operated, maintained, and serviced as recommended by the emission control technology manufacturer.

Measures – Additional Diesel Requirements
a. Construction shall not proceed until the contractor submits a certified 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.
b. If the contractor subsequently needs to bring on site equipment not on the list, the contractor shall submit written notification within 24 hours that attests the equipment complies with all contract conditions and provide information.
c. All diesel equipment shall comply with all pertinent local, state, and federal regulations relative to exhaust emission controls and safety.
d. 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.

Reporting
a. For each onroad diesel vehicle, nonroad construction equipment, or generator, the contractor shall submit to the developer’s representative a report prior to bringing said equipment on site that includes:
i. Equipment type, equipment manufacturer, equipment serial number, engine manufacturer, engine model year, engine certification (Tier rating), horsepower, and engine serial number. ii. The type of emission control technology installed, serial number, make, model, manufacturer, and EPA/CARB verification number/level.
iii. The Certification Statement signed and printed on the contractor’s letterhead. b. The contractor shall submit to the developer’s representative a monthly report that, for each onroad 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:
39 1.Source of supply

2. Quantity of fuel

3.Quality of fuel, including sulfur content (percent by weight) 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. An EIR should be prepared to include all feasible mitigation measures, as well as include an updated health risk and GHG analysis to ensure that the necessary mitigation measures are implemented to reduce emissions to below thresholds. The EIR should also demonstrate a commitment to the implementation of these measures prior to Project approval, to ensure that the Project’s significant emissions are reduced to the maximum extent possible.

Disclaimer
SWAPE has received limited discovery regarding this project. Additional information may become available in the future; thus, we retain the right to revise or amend this report when additional information becomes available. Our professional services have been performed using that degree of care and skill ordinarily exercised, under similar circumstances, by reputable environmental consultants 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:

Attachment B:

SWAPE HRA Calculations
SWAPE GHG and VMT Calculations
Attachment C:

Attachment D:

SWAPE Project CalEEMod Modeling
SWAPE Project AERSCREEN Modeling
Attachment E: Paul Rosenfeld CV
Attachment F: Matt Hagemann CV

Annual Emissions (tons/year) 0.0226
Daily Emissions (lbs/day) 0.123835616
Emission Rate (g/s) 0.000650137
Release Height (meters) 3
Initial Vertical Dimension (meters) 1.5
Max Horizontal (meters) 77.0
Min Horizontal (meters) 41.0
Total Acreage 0.780111
Setting Urban
Population 39,169
Total DPM (lbs) 45.2
Total Pounds of DPM
Operation
Emission Rate
Attachment A
Activity Duration
(years)
Concentration
(ug/m3)
Breathing
Rate (L/kg-day) ASF Cancer Risk
with ASFs*
Construction 0.25 N/A 361 10 N/A
3rd Trimester
Duration 0.25 3rd Trimester
Exposure N/A
Construction 1.74 N/A 1090 10 N/A
Operation 0.26 0.4006 1090 10 1.7E-05
Infant Exposure
Duration 2.00 Infant
Exposure 1.7E-05
Operation 14.00 0.4006 572 3 1.5E-04
Child Exposure
Duration 14.00 Child
Exposure 1.5E-04
Operation 14.00 0.4006 261 1 1.6E-05
Adult Exposure
Duration 14.00 Adult
Exposure 1.6E-05
Lifetime Exposure
Duration 30.00 Lifetime
Exposure 1.8E-04
The Maximum Exposed Individual at an Existing Residential Receptor (MEIR) Line (L) Value Unit
1 3,490,968 Project Total VMT

2 1,222.85 Mobile Emissions (MT CO2e/year)
(CalEEMod Output, Tbl. 2.2, Mitigated Operational).
3 3,490,968 Project Total VMT (see L1)
4 91.89%Passenger and Light-Duty VMT Fleet Mix
5 3,207,802 VMT from Passenger & Light-Duty Vehicles**** [Calc: (L3*L4)]
6 1,123.66 Passenger and Light Duty Vehicle Emissions (MT CO2e/year) [Calc: (L2*L4)]
7 6,787.00 Passenger and Light-Duty Vehicle Emissions (Total lbs CO2e/day) [Calc: (L6 converted into lbs) / (365 days)]
8 130Service Population [0 residents + 130 long-term jobs] 9 52.21 Per Service Population Emissions (lbs CO2e/day/SP) [Calc: (L7/L8)]
10 3,207,802 VMT from Passenger & Light-Duty Vehicles**** (see L5) 11 8,788 Daily VMT from Passenger & Light-Duty Vehicles [Calc: (L10/365)]
12 130Service Population [0 residents + 130 long-term jobs] 13 67.60 Daily VMT Per Capita
[(Calc: L11/L12)]
Total Emissions From Passenger and Light Duty Vehicles
GHG CALCULATIONS: IS/MND Modeling
Project Total VMT
Daily VMT Per Capita From Passenger and Light Duty Vehicles Attachment
Project
IS/MND Modeling
Annual Mobile Emissions (MT CO2e/year) 1,222.85
Passenger & Light-Duty Fleet Mix (%) 91.89%
Daily CO2e Emissions (lbs/day) 6,787.00
Service Population 130
Per Capita Emissions (lbs/day) 52.21

21.3 lbs/day/SP (2020 Goal) Exceeded? Yes

18.8 lbs/day/SP (2035 Goal) Exceeded? Yes
Sources
CO2e Per Capita Emissions from Passenger & Light-Duty Trucks, Exceedances under RTP/SCS Performance-Based SB 375 Goals Project
IS/MND Modeling
3,207,802
8,788
130

67.60 Yes
Yes
Yes
Yes
41 19.2 VMT (2045 Target) Exceed?

23.2 VMT (2016 Baseline) Exceed?

20.7 VMT (2045 Target) Exceed?

22.2 VMT (2016 Baseline) Exceed?
2020 RTP/SCS Benchmarks, SCAG-Wide
2020 RTP/SCS Benchmarks, Los Angeles County
Service Population
Daily VMT Per Capita
Daily VMT Per Capita from Passenger & Light-Duty Trucks, Exceedances under RTP/SCS Performance-Based SB 375 Target Annual VMT from Auto & Light-Duty Vehicles
Sources
Daily VMT from Auto & Light-Duty Vehicles
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 2022 10,534,881 220,487,425.77 20.93 41,321,565 916,010,145.57 22.17 2030 10,868,614 215,539,586.12 19.83 43,939,250 957,178,153.19 21.78 2017 Scoping Plan Daily VMT Per Capita
Los Angeles County State
Project
IS/MND Modeling
Annual VMT from Auto & Light-Duty Vehicles 3,207,802
Daily VMT from Auto & Light-Duty Vehicles 8,788
Service Population 130
Daily VMT Per Capita 67.60

22.40 VMT (2010 Baseline) Exceed? Yes

22.17 VMT (2022 Projected) Exceed? Yes

21.78 VMT (2030 Projected) Exceed? Yes

22.05 VMT (2010 Baseline) Exceed? Yes

20.93 VMT (2022 Projected) Exceed? Yes

19.83 VMT (2030 Projected) Exceed? Yes
Sources
Daily VMT Per Capita from Passenger & Light-Duty Trucks, Exceedances under 2017 Scoping Plan Performance-Based SB 375 Benchmarks 2017 Scoping Plan Benchmarks, Los Angeles County Specific 2017 Scoping Plan Benchmarks, Statewide

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population Enclosed Parking with Elevator 138.00 Space 0.28 56,300.00 0 Health Club 0.70 1000sqft 0.02 700.00 0
Hotel 175.00 Room 0.50 117,987.00 0
Quality Restaurant 3.31 1000sqft 0.08 3,313.00 0

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
11 Wind Speed (m/s) Precipitation Freq (Days)2.2 31

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company Southern California Edison
2022Operational Year
CO2 Intensity
(lb/MWhr)
702.44 0.029CH4 Intensity
(lb/MWhr)

0.006N2O Intensity
(lb/MWhr)
11469 Jefferson - Operations
South Coast AQMD Air District, Annual
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 1 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual Attachment C
Project Characteristics - See SWAPE comment regarding CO2 intensity factor.

Land Use - See SWAPE comment regarding parking and failure to model all proposed land uses.

Vehicle Trips - Consistent with the IS/MND's model.

Vehicle Emission Factors - See SWAPE comment regarding operational vehicle emission factors.

Vehicle Emission Factors -
Vehicle Emission Factors -
Energy Mitigation - Consistent with the IS/MND's model.

Waste Mitigation -

2.0 Emissions Summary
Table Name Column Name Default Value New Value
tblLandUse LandUseSquareFeet 55,200.00 56,300.00
tblLandUse LandUseSquareFeet 254,100.00 117,987.00
tblLandUse LandUseSquareFeet 3,310.00 3,313.00
tblLandUse LotAcreage 1.24 0.28
tblLandUse LotAcreage 5.83 0.50
tblVehicleTrips ST_TR 20.87 0.00
tblVehicleTrips ST_TR 8.19 8.36
tblVehicleTrips ST_TR 94.36 0.00
tblVehicleTrips SU_TR 26.73 0.00
tblVehicleTrips SU_TR 5.95 8.36
tblVehicleTrips SU_TR 72.16 0.00
tblVehicleTrips WD_TR 32.93 0.00
tblVehicleTrips WD_TR 8.17 8.36
tblVehicleTrips WD_TR 89.95 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 2 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual

2.1 Overall Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2021 0.6399 0.6196 0.6034 1.4600e-
003

0.0529 0.0267 0.0796 0.0144 0.0247 0.0391 0.0000 132.3248132.3248 0.0215 0.0000 132.8611 Maximum 0.6399 0.6196 0.6034 1.4600e-
003

0.0529 0.0267 0.0796 0.0144 0.0247 0.0391 0.0000 132.3248132.3248 0.0215 0.0000 132.8611 Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2021 0.6399 0.6196 0.6034 1.4600e-
003

0.0529 0.0267 0.0796 0.0144 0.0247 0.0391 0.0000 132.3247132.3247 0.0215 0.0000 132.8610 Maximum 0.6399 0.6196 0.6034 1.4600e-
003

0.0529 0.0267 0.0796 0.0144 0.0247 0.0391 0.0000 132.3247132.3247 0.0215 0.0000 132.8610 Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio-CO2Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 3 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual

2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Area 0.5022 4.0000e-
005

4.0500e-
003

0.0000 1.0000e-
005

1.0000e-
005

0.0000 7.8700e-
003

7.8700e-
003

2.0000e-
005

0.0000 8.3900e-
003
Energy 0.0195 0.1768 0.1485 1.0600e-
003

0.0134 0.0134 0.0134 0.0134 0.0000 631.6018631.6018 0.0218 7.2800e- 003
634.3165
Mobile 0.3735 2.0366 4.4176 0.0162 1.3265 0.0130 1.3395 0.3555 0.0121 0.3676 0.0000 1,498.530 2 1,498.530
2 0.0753 0.0000 1,500.413
1 Waste 0.0000 0.0000 0.0000 0.0000 20.8715 0.0000 20.8715 1.2335 0.0000 51.7083 Water 0.0000 0.0000 0.0000 0.0000 1.7402 24.8200 26.5603 0.1798 4.4300e- 003

32.3752
Total 0.8951 2.2134 4.5701 0.0173 1.3265 0.0264 1.3529 0.3555 0.0256 0.3810 22.61182,154.959 8 2,177.571
6 1.5104 0.0117 2,218.821
4 Unmitigated Operational
Quarter Start Date End Date Maximum Unmitigated ROG + NOX (tons/quarter) Maximum Mitigated ROG + NOX (tons/quarter) 1 2-9-2021 5-8-2021 0.3619 0.3619
2 5-9-2021 8-8-2021 0.8914 0.8914
Highest 0.8914 0.8914
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 4 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual

4.0500e-
003

0.0000 1.0000e-
005

1.0000e-
005

0.0000 7.8700e-
003

7.8700e-
003

2.0000e-
005

0.0000 8.3900e-
003
Energy 0.0195 0.1768 0.1485 1.0600e-
003

0.0134 0.0134 0.0134 0.0134 0.0000 631.6018631.6018 0.0218 7.2800e- 003
634.3165
Mobile 0.3735 2.0366 4.4176 0.0162 1.3265 0.0130 1.3395 0.3555 0.0121 0.3676 0.0000 1,498.530 2 1,498.530
2 0.0753 0.0000 1,500.413
1 Waste 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Water 0.0000 0.0000 0.0000 0.0000 1.7402 24.8200 26.5603 0.1798 4.4300e- 003

32.3752
Total 0.8951 2.2134 4.5701 0.0173 1.3265 0.0264 1.3529 0.3555 0.0256 0.3810 1.7402 2,154.959 8 2,156.700
0 0.2769 0.0117 2,167.113
1 Mitigated Operational

3.0 Construction Detail
Construction Phase
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio-CO2Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 92.30 0.00 0.96 81.67 0.00 2.33 CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 5 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 2/9/2021 2/22/2021 5 10
2 Site Preparation Site Preparation 2/23/2021 2/23/2021 5 1 3 Grading Grading 2/24/2021 2/25/2021 5 2
4 Building Construction Building Construction 2/26/2021 7/15/2021 5 100 5 Paving Paving 7/16/2021 7/22/2021 5 5
6 Architectural Coating Architectural Coating 7/23/2021 7/29/2021 5 5 OffRoad Equipment
Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 183,000; Non-Residential Outdoor: 61,000; Striped Parking Area: 3,378 (Architectural Coating – sqft)
Acres of Grading (Site Preparation Phase): 0.5
Acres of Grading (Grading Phase): 0
Acres of Paving: 0.28
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 6 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Demolition Concrete/Industrial Saws 1 8.00 81 0.73
Demolition Rubber Tired Dozers 1 1.00 247 0.40
Demolition Tractors/Loaders/Backhoes 2 6.00 97 0.37
Site Preparation Graders 1 8.00 187 0.41
Site Preparation Tractors/Loaders/Backhoes 1 8.00 97 0.37 Grading Concrete/Industrial Saws 1 8.00 81 0.73
Grading Rubber Tired Dozers 1 1.00 247 0.40
Grading Tractors/Loaders/Backhoes 2 6.00 97 0.37
Building Construction Cranes 1 4.00 231 0.29
Building Construction Forklifts 2 6.00 89 0.20
Building Construction Tractors/Loaders/Backhoes 2 8.00 97 0.37 Paving Cement and Mortar Mixers 4 6.00 9 0.56
Paving Pavers 1 7.00 130 0.42
Paving Rollers 1 7.00 80 0.38
Paving Tractors/Loaders/Backhoes 1 7.00 97 0.37
Architectural Coating Air Compressors 1 6.00 78 0.48
Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Demolition 4 10.00 0.00 0.00 14.70 6.90 20.00LD_Mix HDT_Mix HHDT Site Preparation 2 5.00 0.00 0.00 14.70 6.90 20.00LD_Mix HDT_Mix HHDT Grading 4 10.00 0.00 0.00 14.70 6.90 20.00LD_Mix HDT_Mix HHDT Building Construction 5 75.00 29.00 0.00 14.70 6.90 20.00LD_Mix HDT_Mix HHDT Paving 7 18.00 0.00 0.00 14.70 6.90 20.00LD_Mix HDT_Mix HHDT Architectural Coating 1 15.00 0.00 0.00 14.70 6.90 20.00LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 7 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual

3.2 Demolition - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 3.9800e-
003

0.0363 0.0379 6.0000e-
005

2.0400e-
003

1.9400e-
003

0.0000 5.2047 5.2047 9.7000e-
004

0.0000 5.2289
Total 3.9800e-
003

0.0363 0.0379 6.0000e-
005

2.0400e-
003

1.9400e-
003

0.0000 5.2047 5.2047 9.7000e-
004

0.0000 5.2289
Unmitigated Construction On-Site

3.1 Mitigation Measures Construction
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 8 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual

3.2 Demolition - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 2.1000e-
004

1.5000e-
004

1.7400e-
003

1.0000e-
005

5.5000e-
004

0.0000 5.5000e-
004

1.5000e-
004

0.0000 1.5000e-
004

0.0000 0.4778 0.4778 1.0000e-
005

0.0000 0.4782
Total 2.1000e-
004

1.5000e-
004

1.7400e-
003

1.0000e-
005

5.5000e-
004

0.0000 5.5000e-
004

1.5000e-
004

0.0000 1.5000e-
004

0.0000 0.4778 0.4778 1.0000e-
005

0.0000 0.4782
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 3.9800e-
003

0.0363 0.0379 6.0000e-
005

2.0400e-
003

1.9400e-
003

0.0000 5.2047 5.2047 9.7000e-
004

0.0000 5.2289
Total 3.9800e-
003

0.0363 0.0379 6.0000e-
005

2.0400e-
003

1.9400e-
003

0.0000 5.2047 5.2047 9.7000e-
004

0.0000 5.2289
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 9 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual

1.5000e-
004

1.7400e-
003

1.0000e-
005

5.5000e-
004

0.0000 5.5000e-
004

1.5000e-
004

0.0000 1.5000e-
004

0.0000 0.4778 0.4778 1.0000e-
005

0.0000 0.4782
Total 2.1000e-
004

1.5000e-
004

1.7400e-
003

1.0000e-
005

5.5000e-
004

0.0000 5.5000e-
004

1.5000e-
004

0.0000 1.5000e-
004

0.0000 0.4778 0.4778 1.0000e-
005

0.0000 0.4782
Mitigated Construction Off-Site

0.0000 2.7000e-
004

3.0000e-
005

0.0000 3.0000e-
005

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 3.2000e-
004

3.9100e-
003

2.0100e-
003

0.0000 1.5000e-
004

1.5000e-
004

1.4000e-
004

0.0000 0.4276 0.4276 1.4000e-
004

0.0000 0.4310
Total 3.2000e-
004

3.9100e-
003

2.0100e-
003

0.0000 2.7000e-
004

1.5000e-
004

4.2000e-
004

3.0000e-
005

1.4000e-
004

1.7000e-
004

0.0000 0.4276 0.4276 1.4000e-
004

0.0000 0.4310
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 10 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual

3.3 Site Preparation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 1.0000e-
005

1.0000e-
005

9.0000e-
005

0.0000 3.0000e-
005

1.0000e-
005

0.0000 1.0000e-
005

0.0000 0.0239 0.0239 0.0000 0.0000 0.0239
Total 1.0000e-
005

1.0000e-
005

9.0000e-
005

0.0000 3.0000e-
005

1.0000e-
005

0.0000 1.0000e-
005

0.0000 0.0239 0.0239 0.0000 0.0000 0.0239
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 2.7000e-
004

0.0000 2.7000e-
004

3.0000e-
005

0.0000 3.0000e-
005

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 3.2000e-
004

3.9100e-
003

2.0100e-
003

0.0000 1.5000e-
004

1.5000e-
004

1.4000e-
004

0.0000 0.4276 0.4276 1.4000e-
004

0.0000 0.4310
Total 3.2000e-
004

3.9100e-
003

2.0100e-
003

0.0000 2.7000e-
004

1.5000e-
004

4.2000e-
004

3.0000e-
005

1.4000e-
004

1.7000e-
004

0.0000 0.4276 0.4276 1.4000e-
004

0.0000 0.4310
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 11 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual

1.0000e-
005

9.0000e-
005

0.0000 3.0000e-
005

1.0000e-
005

0.0000 1.0000e-
005

0.0000 0.0239 0.0239 0.0000 0.0000 0.0239
Total 1.0000e-
005

1.0000e-
005

9.0000e-
005

0.0000 3.0000e-
005

1.0000e-
005

0.0000 1.0000e-
005

0.0000 0.0239 0.0239 0.0000 0.0000 0.0239
Mitigated Construction Off-Site

3.4 Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 7.5000e-
004

0.0000 7.5000e-
004

4.1000e-
004

0.0000 4.1000e-
004

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 8.0000e-
004

7.2500e-
003

7.5700e-
003

1.0000e-
005

4.1000e-
004

3.9000e-
004

0.0000 1.0409 1.0409 1.9000e-
004

0.0000 1.0458
Total 8.0000e-
004

7.2500e-
003

7.5700e-
003

1.0000e-
005

7.5000e-
004

4.1000e-
004

1.1600e-
003

4.1000e-
004

3.9000e-
004

8.0000e-
004

0.0000 1.0409 1.0409 1.9000e-
004

0.0000 1.0458
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 12 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual

3.4 Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 4.0000e-
005

3.0000e-
005

3.5000e-
004

0.0000 1.1000e-
004

3.0000e-
005

0.0000 3.0000e-
005

0.0000 0.0956 0.0956 0.0000 0.0000 0.0956
Total 4.0000e-
005

3.0000e-
005

3.5000e-
004

0.0000 1.1000e-
004

3.0000e-
005

0.0000 3.0000e-
005

0.0000 0.0956 0.0956 0.0000 0.0000 0.0956
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 7.5000e-
004

0.0000 7.5000e-
004

4.1000e-
004

0.0000 4.1000e-
004

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 8.0000e-
004

7.2500e-
003

7.5700e-
003

1.0000e-
005

4.1000e-
004

3.9000e-
004

0.0000 1.0409 1.0409 1.9000e-
004

0.0000 1.0458
Total 8.0000e-
004

7.2500e-
003

7.5700e-
003

1.0000e-
005

7.5000e-
004

4.1000e-
004

1.1600e-
003

4.1000e-
004

3.9000e-
004

8.0000e-
004

0.0000 1.0409 1.0409 1.9000e-
004

0.0000 1.0458
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 13 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual

3.0000e-
005

3.5000e-
004

0.0000 1.1000e-
004

3.0000e-
005

0.0000 3.0000e-
005

0.0000 0.0956 0.0956 0.0000 0.0000 0.0956
Total 4.0000e-
005

3.0000e-
005

3.5000e-
004

0.0000 1.1000e-
004

3.0000e-
005

0.0000 3.0000e-
005

0.0000 0.0956 0.0956 0.0000 0.0000 0.0956
Mitigated Construction Off-Site

3.5 Building Construction - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0388 0.3993 0.3632 5.7000e-
004

0.0224 0.0224 0.0206 0.0206 0.0000 50.0410 50.0410 0.0162 0.0000 50.4456 Total 0.0388 0.3993 0.3632 5.7000e-
004

0.0224 0.0224 0.0206 0.0206 0.0000 50.0410 50.0410 0.0162 0.0000 50.4456 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 14 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual

0.1403 0.0348 3.7000e-
004

9.1400e-
003

2.8000e-
004

9.4200e-
003

2.6400e-
003

2.7000e-
004

2.9100e-
003

0.0000 35.4012 35.4012 2.2400e-
003

0.0000 35.4572
Worker 0.0156 0.0116 0.1307 4.0000e-
004

0.0411 3.1000e-
004

0.0415 0.0109 2.8000e-
004

0.0112 0.0000 35.8373 35.8373 9.6000e-
004

0.0000 35.8613
Total 0.0198 0.1519 0.1655 7.7000e-
004

0.0503 5.9000e-
004

0.0509 0.0136 5.5000e-
004

0.0141 0.0000 71.2385 71.2385 3.2000e-
003

0.0000 71.3185
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0388 0.3993 0.3632 5.7000e-
004

0.0224 0.0224 0.0206 0.0206 0.0000 50.0410 50.0410 0.0162 0.0000 50.4456 Total 0.0388 0.3993 0.3632 5.7000e-
004

0.0224 0.0224 0.0206 0.0206 0.0000 50.0410 50.0410 0.0162 0.0000 50.4456 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 15 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual

0.1403 0.0348 3.7000e-
004

9.1400e-
003

2.8000e-
004

9.4200e-
003

2.6400e-
003

2.7000e-
004

2.9100e-
003

0.0000 35.4012 35.4012 2.2400e-
003

0.0000 35.4572
Worker 0.0156 0.0116 0.1307 4.0000e-
004

0.0411 3.1000e-
004

0.0415 0.0109 2.8000e-
004

0.0112 0.0000 35.8373 35.8373 9.6000e-
004

0.0000 35.8613
Total 0.0198 0.1519 0.1655 7.7000e-
004

0.0503 5.9000e-
004

0.0509 0.0136 5.5000e-
004

0.0141 0.0000 71.2385 71.2385 3.2000e-
003

0.0000 71.3185
Mitigated Construction Off-Site

3.6 Paving - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 1.8000e-
003

0.0168 0.0177 3.0000e-
005

8.8000e-
004

8.2000e-
004

0.0000 2.3481 2.3481 6.8000e-
004

0.0000 2.3652
Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 1.8000e-
003

0.0168 0.0177 3.0000e-
005

8.8000e-
004

8.2000e-
004

0.0000 2.3481 2.3481 6.8000e-
004

0.0000 2.3652
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 16 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual

3.6 Paving - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 1.9000e-
004

1.4000e-
004

1.5700e-
003

0.0000 4.9000e-
004

0.0000 5.0000e-
004

1.3000e-
004

0.0000 1.3000e-
004

0.0000 0.4301 0.4301 1.0000e-
005

0.0000 0.4303
Total 1.9000e-
004

1.4000e-
004

1.5700e-
003

0.0000 4.9000e-
004

0.0000 5.0000e-
004

1.3000e-
004

0.0000 1.3000e-
004

0.0000 0.4301 0.4301 1.0000e-
005

0.0000 0.4303
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 1.8000e-
003

0.0168 0.0177 3.0000e-
005

8.8000e-
004

8.2000e-
004

0.0000 2.3481 2.3481 6.8000e-
004

0.0000 2.3652
Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 1.8000e-
003

0.0168 0.0177 3.0000e-
005

8.8000e-
004

8.2000e-
004

0.0000 2.3481 2.3481 6.8000e-
004

0.0000 2.3652
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 17 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual

1.4000e-
004

1.5700e-
003

0.0000 4.9000e-
004

0.0000 5.0000e-
004

1.3000e-
004

0.0000 1.3000e-
004

0.0000 0.4301 0.4301 1.0000e-
005

0.0000 0.4303
Total 1.9000e-
004

1.4000e-
004

1.5700e-
003

0.0000 4.9000e-
004

0.0000 5.0000e-
004

1.3000e-
004

0.0000 1.3000e-
004

0.0000 0.4301 0.4301 1.0000e-
005

0.0000 0.4303
Mitigated Construction Off-Site

3.8200e-
003

4.5400e-
003

1.0000e-
005

2.4000e-
004

0.0000 0.6383 0.6383 4.0000e-
005

0.0000 0.6394
Total 0.5739 3.8200e-
003

4.5400e-
003

1.0000e-
005

2.4000e-
004

0.0000 0.6383 0.6383 4.0000e-
005

0.0000 0.6394
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 18 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual

3.7 Architectural Coating - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 1.6000e-
004

1.2000e-
004

1.3100e-
003

0.0000 4.1000e-
004

1.1000e-
004

0.0000 1.1000e-
004

0.0000 0.3584 0.3584 1.0000e-
005

0.0000 0.3586
Total 1.6000e-
004

1.2000e-
004

1.3100e-
003

0.0000 4.1000e-
004

1.1000e-
004

0.0000 1.1000e-
004

0.0000 0.3584 0.3584 1.0000e-
005

0.0000 0.3586
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Archit. Coating 0.5733 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 5.5000e-
004

3.8200e-
003

4.5400e-
003

1.0000e-
005

2.4000e-
004

0.0000 0.6383 0.6383 4.0000e-
005

0.0000 0.6394
Total 0.5739 3.8200e-
003

4.5400e-
003

1.0000e-
005

2.4000e-
004

0.0000 0.6383 0.6383 4.0000e-
005

0.0000 0.6394
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 19 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual

4.0 Operational Detail - Mobile

4.1 Mitigation Measures Mobile

1.2000e-
004

1.3100e-
003

0.0000 4.1000e-
004

1.1000e-
004

0.0000 1.1000e-
004

0.0000 0.3584 0.3584 1.0000e-
005

0.0000 0.3586
Total 1.6000e-
004

1.2000e-
004

1.3100e-
003

0.0000 4.1000e-
004

1.1000e-
004

0.0000 1.1000e-
004

0.0000 0.3584 0.3584 1.0000e-
005

0.0000 0.3586
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 20 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 0.3735 2.0366 4.4176 0.0162 1.3265 0.0130 1.3395 0.3555 0.0121 0.3676 0.0000 1,498.530 2 1,498.530
2 0.0753 0.0000 1,500.413
1 Unmitigated 0.3735 2.0366 4.4176 0.0162 1.3265 0.0130 1.3395 0.3555 0.0121 0.3676 0.0000 1,498.530 2 1,498.530
2 0.0753 0.0000 1,500.413
1 4.2 Trip Summary Information

4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Enclosed Parking with Elevator 0.00 0.00 0.00
Health Club 0.00 0.00 0.00
Hotel 1,463.00 1,463.00 1463.00 3,490,968 3,490,968
Quality Restaurant 0.00 0.00 0.00
Total 1,463.00 1,463.00 1,463.00 3,490,968 3,490,968
Miles Trip % Trip Purpose %
Land Use H-W or C-WH-S or C-CH-O or C-NWH-W or C-WH-S or C-CH-O or C-NW Primary Diverted Pass-by Enclosed Parking with Elevator 16.60 8.40 6.90 0.00 0.00 0.00 0 0 0 Health Club 16.60 8.40 6.90 16.90 64.10 19.00 52 39 9
Hotel 16.60 8.40 6.90 19.40 61.60 19.00 58 38 4
Quality Restaurant 16.60 8.40 6.90 12.00 69.00 19.00 38 18 44

4.4 Fleet Mix
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 21 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual

5.0 Energy Detail
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Electricity
Mitigated

0.0000 0.0000 0.0000 0.0000 0.0000 439.1449439.1449 0.0181 3.7500e- 003
440.7159
Electricity
Unmitigated

0.0000 0.0000 0.0000 0.0000 0.0000 439.1449439.1449 0.0181 3.7500e- 003
440.7159
NaturalGas
Mitigated

0.0195 0.1768 0.1485 1.0600e-
003

0.0134 0.0134 0.0134 0.0134 0.0000 192.4569192.45693.6900e- 003

3.5300e-
003
193.6006
NaturalGas
Unmitigated

0.0195 0.1768 0.1485 1.0600e-
003

0.0134 0.0134 0.0134 0.0134 0.0000 192.4569192.45693.6900e- 003

3.5300e-
003
193.6006

5.1 Mitigation Measures Energy
Kilowatt Hours of Renewable Electricity Generated
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH Enclosed Parking with Elevator 0.5495590.0428930.2015640.1185330.0155690.0058460.0213940.0342550.0020990.0018280.0048550.0007090.000896 Health Club 0.5495590.0428930.2015640.1185330.0155690.0058460.0213940.0342550.0020990.0018280.0048550.0007090.000896 Hotel 0.5495590.0428930.2015640.1185330.0155690.0058460.0213940.0342550.0020990.0018280.0048550.0007090.000896 Quality Restaurant 0.5495590.0428930.2015640.1185330.0155690.0058460.0213940.0342550.0020990.0018280.0048550.0007090.000896 Historical Energy Use: N
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 22 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual

5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Land Use kBTU/yr tons/yr MT/yr
Enclosed Parking
with Elevator
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Health Club 12670 7.0000e-
005

6.2000e-
004

5.2000e-
004

0.0000 5.0000e-
005

5.0000e-
005

0.0000 0.6761 0.6761 1.0000e-
005

1.0000e-
005

0.6801
Hotel 2.82933e
+006

0.0153 0.1387 0.1165 8.3000e-
004

0.0105 0.0105 0.0105 0.0105 0.0000 150.9837150.98372.8900e- 003

2.7700e-
003
151.8810
Quality
Restaurant
764508 4.1200e-
003

0.0375 0.0315 2.2000e-
004

2.8500e-
003

0.0000 40.7971 40.7971 7.8000e-
004

7.5000e-
004

41.0395
Total 0.0195 0.1768 0.1485 1.0500e-
003

0.0134 0.0134 0.0134 0.0134 0.0000 192.4569192.45693.6800e- 003

3.5300e-
003
193.6006
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 23 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual

6.2000e-
004

5.2000e-
004

0.0000 5.0000e-
005

5.0000e-
005

0.0000 0.6761 0.6761 1.0000e-
005

1.0000e-
005

0.6801
Hotel 2.82933e
+006

0.0153 0.1387 0.1165 8.3000e-
004

0.0105 0.0105 0.0105 0.0105 0.0000 150.9837150.98372.8900e- 003

2.7700e-
003
151.8810
Quality
Restaurant
764508 4.1200e-
003

0.0375 0.0315 2.2000e-
004

2.8500e-
003

0.0000 40.7971 40.7971 7.8000e-
004

7.5000e-
004

41.0395
Total 0.0195 0.1768 0.1485 1.0500e-
003

0.0134 0.0134 0.0134 0.0134 0.0000 192.4569192.45693.6800e- 003

3.5300e-
003
193.6006
Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 24 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual

5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
Enclosed Parking
with Elevator
329918 105.11894.3400e-
003

9.0000e-
004
105.4950
Health Club 7770 2.4757 1.0000e-
004

2.0000e-
005

2.4846
Hotel 894341 284.9564 0.0118 2.4300e-
003
285.9758
Quality
Restaurant
146236 46.5939 1.9200e-
003

4.0000e-
004

46.7606
Total 439.1449 0.0181 3.7500e-
003
440.7159
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 25 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual

6.1 Mitigation Measures Area

6.0 Area Detail

5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
Enclosed Parking
with Elevator
329918 105.11894.3400e-
003

9.0000e-
004
105.4950
Health Club 7770 2.4757 1.0000e-
004

2.0000e-
005

2.4846
Hotel 894341 284.9564 0.0118 2.4300e-
003
285.9758
Quality
Restaurant
146236 46.5939 1.9200e-
003

4.0000e-
004

46.7606
Total 439.1449 0.0181 3.7500e-
003
440.7159
Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 26 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 0.5022 4.0000e-
005

4.0500e-
003

0.0000 1.0000e-
005

1.0000e-
005

0.0000 7.8700e-
003

7.8700e-
003

2.0000e-
005

0.0000 8.3900e-
003
Unmitigated 0.5022 4.0000e-
005

4.0500e-
003

0.0000 1.0000e-
005

1.0000e-
005

0.0000 7.8700e-
003

7.8700e-
003

2.0000e-
005

0.0000 8.3900e-
003

6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
SubCategory tons/yr MT/yr
Architectural
Coating

0.0573 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

0.4445 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Landscaping 3.8000e-
004

4.0000e-
005

4.0500e-
003

0.0000 1.0000e-
005

1.0000e-
005

0.0000 7.8700e-
003

7.8700e-
003

2.0000e-
005

0.0000 8.3900e-
003
Total 0.5022 4.0000e-
005

4.0500e-
003

0.0000 1.0000e-
005

1.0000e-
005

0.0000 7.8700e-
003

7.8700e-
003

2.0000e-
005

0.0000 8.3900e-
003
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 27 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual

7.1 Mitigation Measures Water

7.0 Water Detail

0.0573 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

0.4445 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Landscaping 3.8000e-
004

4.0000e-
005

4.0500e-
003

0.0000 1.0000e-
005

1.0000e-
005

0.0000 7.8700e-
003

7.8700e-
003

2.0000e-
005

0.0000 8.3900e-
003
Total 0.5022 4.0000e-
005

4.0500e-
003

0.0000 1.0000e-
005

1.0000e-
005

0.0000 7.8700e-
003

7.8700e-
003

2.0000e-
005

0.0000 8.3900e-
003
Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 28 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual Total CO2 CH4 N2O CO2e
Category MT/yr
Mitigated 26.5603 0.1798 4.4300e-
003

32.3752
Unmitigated 26.5603 0.1798 4.4300e-
003

32.3752

7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
Enclosed Parking
with Elevator
0 / 0 0.0000 0.0000 0.0000 0.0000
Health Club 0.0414002
/

0.0253743

0.2747 1.3600e-
003

3.0000e-
005

0.3189
Hotel 4.43918 /

0.493243

21.5715 0.1455 3.5900e-
003

26.2778
Quality
Restaurant

1.0047 /

0.0641296

4.7140 0.0329 8.1000e-
004

5.7785
Total 26.5603 0.1798 4.4300e-
003

32.3752
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 29 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual

8.1 Mitigation Measures Waste
Institute Recycling and Composting Services

7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
Enclosed Parking
with Elevator
0 / 0 0.0000 0.0000 0.0000 0.0000
Health Club 0.0414002
/

0.0253743

0.2747 1.3600e-
003

3.0000e-
005

0.3189
Hotel 4.43918 /

0.493243

21.5715 0.1455 3.5900e-
003

26.2778
Quality
Restaurant

1.0047 /

0.0641296

4.7140 0.0329 8.1000e-
004

5.7785
Total 26.5603 0.1798 4.4300e-
003

32.3752
Mitigated

8.0 Waste Detail
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 30 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual Total CO2 CH4 N2O CO2e
MT/yr
Mitigated 0.0000 0.0000 0.0000 0.0000
Unmitigated 20.8715 1.2335 0.0000 51.7083
Category/Year

8.2 Waste by Land Use
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
Enclosed Parking
with Elevator
0 0.0000 0.0000 0.0000 0.0000
Health Club 3.99 0.8099 0.0479 0.0000 2.0066
Hotel 95.81 19.4486 1.1494 0.0000 48.1830
Quality
Restaurant

3.02 0.6130 0.0362 0.0000 1.5188
Total 20.8715 1.2335 0.0000 51.7083
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 31 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual

8.2 Waste by Land Use
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
Enclosed Parking
with Elevator

0.0000 0.0000 0.0000 0.0000
Health Club 0.0000 0.0000 0.0000 0.0000
Hotel 0.0000 0.0000 0.0000 0.0000
Quality
Restaurant

0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000
Mitigated

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

10.0 Stationary Equipment
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 32 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual

11.0 Vegetation
Equipment Type Number
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:01 AMPage 33 of 33 11469 Jefferson - Operations - South Coast AQMD Air District, Annual

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
11 Wind Speed (m/s) Precipitation Freq (Days)2.2 31

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company Southern California Edison
2022Operational Year
CO2 Intensity
(lb/MWhr)
702.44 0.029CH4 Intensity
(lb/MWhr)

0.006N2O Intensity
(lb/MWhr)
11469 Jefferson - Operations
South Coast AQMD Air District, Summer
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:05 AMPage 1 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Summer Project Characteristics - See SWAPE comment regarding CO2 intensity factor.

Land Use - See SWAPE comment regarding parking and failure to model all proposed land uses.

Vehicle Trips - Consistent with the IS/MND's model.

Vehicle Emission Factors - See SWAPE comment regarding operational vehicle emission factors.

Vehicle Emission Factors -
Vehicle Emission Factors -
Energy Mitigation - Consistent with the IS/MND's model.

Waste Mitigation -

2.0 Emissions Summary
Table Name Column Name Default Value New Value
tblLandUse LandUseSquareFeet 55,200.00 56,300.00
tblLandUse LandUseSquareFeet 254,100.00 117,987.00
tblLandUse LandUseSquareFeet 3,310.00 3,313.00
tblLandUse LotAcreage 1.24 0.28
tblLandUse LotAcreage 5.83 0.50
tblVehicleTrips ST_TR 20.87 0.00
tblVehicleTrips ST_TR 8.19 8.36
tblVehicleTrips ST_TR 94.36 0.00
tblVehicleTrips SU_TR 26.73 0.00
tblVehicleTrips SU_TR 5.95 8.36
tblVehicleTrips SU_TR 72.16 0.00
tblVehicleTrips WD_TR 32.93 0.00
tblVehicleTrips WD_TR 8.17 8.36
tblVehicleTrips WD_TR 89.95 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:05 AMPage 2 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Summer

2.1 Overall Construction (Maximum Daily Emission)
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2021 229.601610.9562 10.7455 0.0271 1.0239 0.4593 1.4832 0.4434 0.4227 0.8328 0.0000 2,723.839 8 2,723.839
8 0.4269 0.0000 2,734.513
0 Maximum 229.601610.9562 10.7455 0.0271 1.0239 0.4593 1.4832 0.4434 0.4227 0.8328 0.0000 2,723.839 8 2,723.839
8 0.4269 0.0000 2,734.513
0 Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2021 229.601610.9562 10.7455 0.0271 1.0239 0.4593 1.4832 0.4434 0.4227 0.8328 0.0000 2,723.839 8 2,723.839
8 0.4269 0.0000 2,734.513
0 Maximum 229.601610.9562 10.7455 0.0271 1.0239 0.4593 1.4832 0.4434 0.4227 0.8328 0.0000 2,723.839 8 2,723.839
8 0.4269 0.0000 2,734.513
0 Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio-CO2Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:05 AMPage 3 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Summer

2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 2.7527 3.0000e-
004

0.0324 0.0000 1.2000e-
004

1.2000e-
004

0.0694 0.0694 1.8000e-
004

0.0740
Energy 0.1066 0.9687 0.8137 5.8100e-
003

0.0736 0.0736 0.0736 0.0736 1,162.451
6 1,162.451
6 0.0223 0.0213 1,169.359
5 Mobile 2.2214 10.8617 25.2626 0.0927 7.4230 0.0712 7.4942 1.9861 0.0664 2.0525 9,444.500 9 9,444.500
9 0.4570 9,455.925
9 Total 5.0807 11.8307 26.1087 0.0985 7.4230 0.1449 7.5680 1.9861 0.1402 2.1263 10,607.02 19 10,607.02
19 0.4795 0.0213 10,625.35
93 Unmitigated Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 2.7527 3.0000e-
004

0.0324 0.0000 1.2000e-
004

1.2000e-
004

0.0694 0.0694 1.8000e-
004

0.0740
Energy 0.1066 0.9687 0.8137 5.8100e-
003

0.0736 0.0736 0.0736 0.0736 1,162.451
6 1,162.451
6 0.0223 0.0213 1,169.359
5 Mobile 2.2214 10.8617 25.2626 0.0927 7.4230 0.0712 7.4942 1.9861 0.0664 2.0525 9,444.500 9 9,444.500
9 0.4570 9,455.925
9 Total 5.0807 11.8307 26.1087 0.0985 7.4230 0.1449 7.5680 1.9861 0.1402 2.1263 10,607.02 19 10,607.02
19 0.4795 0.0213 10,625.35
93 Mitigated Operational
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:05 AMPage 4 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Summer

3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 2/9/2021 2/22/2021 5 10
2 Site Preparation Site Preparation 2/23/2021 2/23/2021 5 1 3 Grading Grading 2/24/2021 2/25/2021 5 2
4 Building Construction Building Construction 2/26/2021 7/15/2021 5 100 5 Paving Paving 7/16/2021 7/22/2021 5 5
6 Architectural Coating Architectural Coating 7/23/2021 7/29/2021 5 5 OffRoad Equipment
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio-CO2Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 183,000; Non-Residential Outdoor: 61,000; Striped Parking Area: 3,378 (Architectural Coating – sqft)
Acres of Grading (Site Preparation Phase): 0.5
Acres of Grading (Grading Phase): 0
Acres of Paving: 0.28
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:05 AMPage 5 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Summer Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Demolition Concrete/Industrial Saws 1 8.00 81 0.73
Demolition Rubber Tired Dozers 1 1.00 247 0.40
Demolition Tractors/Loaders/Backhoes 2 6.00 97 0.37
Site Preparation Graders 1 8.00 187 0.41
Site Preparation Tractors/Loaders/Backhoes 1 8.00 97 0.37 Grading Concrete/Industrial Saws 1 8.00 81 0.73
Grading Rubber Tired Dozers 1 1.00 247 0.40
Grading Tractors/Loaders/Backhoes 2 6.00 97 0.37
Building Construction Cranes 1 4.00 231 0.29
Building Construction Forklifts 2 6.00 89 0.20
Building Construction Tractors/Loaders/Backhoes 2 8.00 97 0.37 Paving Cement and Mortar Mixers 4 6.00 9 0.56
Paving Pavers 1 7.00 130 0.42
Paving Rollers 1 7.00 80 0.38
Paving Tractors/Loaders/Backhoes 1 7.00 97 0.37
Architectural Coating Air Compressors 1 6.00 78 0.48
Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Demolition 4 10.00 0.00 0.00 14.70 6.90 20.00LD_Mix HDT_Mix HHDT Site Preparation 2 5.00 0.00 0.00 14.70 6.90 20.00LD_Mix HDT_Mix HHDT Grading 4 10.00 0.00 0.00 14.70 6.90 20.00LD_Mix HDT_Mix HHDT Building Construction 5 75.00 29.00 0.00 14.70 6.90 20.00LD_Mix HDT_Mix HHDT Paving 7 18.00 0.00 0.00 14.70 6.90 20.00LD_Mix HDT_Mix HHDT Architectural Coating 1 15.00 0.00 0.00 14.70 6.90 20.00LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:05 AMPage 6 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Summer

3.2 Demolition - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.7965 7.2530 7.5691 0.0120 0.4073 0.4073 0.3886 0.3886 1,147.433 8 1,147.433
8 0.2138 1,152.779
7 Total 0.7965 7.2530 7.5691 0.0120 0.4073 0.4073 0.3886 0.3886 1,147.433 8 1,147.433
8 0.2138 1,152.779
7 Unmitigated Construction On-Site

3.1 Mitigation Measures Construction
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:05 AMPage 7 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Summer

3.2 Demolition - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0422 0.0274 0.3767 1.1100e-
003

0.1118 8.2000e-
004

0.1126 0.0296 7.6000e-
004

0.0304 110.7403110.74032.9800e-
003
110.8148
Total 0.0422 0.0274 0.3767 1.1100e-
003

0.1118 8.2000e-
004

0.1126 0.0296 7.6000e-
004

0.0304 110.7403110.74032.9800e-
003
110.8148
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.7965 7.2530 7.5691 0.0120 0.4073 0.4073 0.3886 0.3886 0.0000 1,147.433 8 1,147.433
8 0.2138 1,152.779
7 Total 0.7965 7.2530 7.5691 0.0120 0.4073 0.4073 0.3886 0.3886 0.0000 1,147.433 8 1,147.433
8 0.2138 1,152.779
7 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:05 AMPage 8 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Summer

0.1118 8.2000e-
004

0.1126 0.0296 7.6000e-
004

0.0304 110.7403110.74032.9800e-
003
110.8148
Total 0.0422 0.0274 0.3767 1.1100e-
003

0.1118 8.2000e-
004

0.1126 0.0296 7.6000e-
004

0.0304 110.7403110.74032.9800e-
003
110.8148
Mitigated Construction Off-Site

0.2995 0.2995 0.2755 0.2755 942.5842942.5842 0.3049 950.2055 Total 0.6403 7.8204 4.0274 9.7300e-
003

0.5303 0.2995 0.8297 0.0573 0.2755 0.3328 942.5842942.5842 0.3049 950.2055 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:05 AMPage 9 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Summer

3.3 Site Preparation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0211 0.0137 0.1884 5.6000e-
004

0.0559 4.1000e-
004

0.0563 0.0148 3.8000e-
004

0.0152 55.3702 55.3702 1.4900e-
003

55.4074
Total 0.0211 0.0137 0.1884 5.6000e-
004

0.0559 4.1000e-
004

0.0563 0.0148 3.8000e-
004

0.0152 55.3702 55.3702 1.4900e-
003

55.4074
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 0.5303 0.0000 0.5303 0.0573 0.0000 0.0573 0.0000 0.0000 Off-Road 0.6403 7.8204 4.0274 9.7300e-
003

0.2995 0.2995 0.2755 0.2755 0.0000 942.5842942.5842 0.3049 950.2055 Total 0.6403 7.8204 4.0274 9.7300e-
003

0.5303 0.2995 0.8297 0.0573 0.2755 0.3328 0.0000 942.5842942.5842 0.3049 950.2055 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:05 AMPage 10 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Summer

0.0559 4.1000e-
004

0.0563 0.0148 3.8000e-
004

0.0152 55.3702 55.3702 1.4900e-
003

55.4074
Total 0.0211 0.0137 0.1884 5.6000e-
004

0.0559 4.1000e-
004

0.0563 0.0148 3.8000e-
004

0.0152 55.3702 55.3702 1.4900e-
003

55.4074
Mitigated Construction Off-Site

3.4 Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 0.7528 0.0000 0.7528 0.4138 0.0000 0.4138 0.0000 0.0000 Off-Road 0.7965 7.2530 7.5691 0.0120 0.4073 0.4073 0.3886 0.3886 1,147.433 8 1,147.433
8 0.2138 1,152.779
7 Total 0.7965 7.2530 7.5691 0.0120 0.7528 0.4073 1.1601 0.4138 0.3886 0.8024 1,147.433 8 1,147.433
8 0.2138 1,152.779
7 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:05 AMPage 11 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Summer

3.4 Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0422 0.0274 0.3767 1.1100e-
003

0.1118 8.2000e-
004

0.1126 0.0296 7.6000e-
004

0.0304 110.7403110.74032.9800e-
003
110.8148
Total 0.0422 0.0274 0.3767 1.1100e-
003

0.1118 8.2000e-
004

0.1126 0.0296 7.6000e-
004

0.0304 110.7403110.74032.9800e-
003
110.8148
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 0.7528 0.0000 0.7528 0.4138 0.0000 0.4138 0.0000 0.0000 Off-Road 0.7965 7.2530 7.5691 0.0120 0.4073 0.4073 0.3886 0.3886 0.0000 1,147.433 8 1,147.433
8 0.2138 1,152.779
7 Total 0.7965 7.2530 7.5691 0.0120 0.7528 0.4073 1.1601 0.4138 0.3886 0.8024 0.0000 1,147.433 8 1,147.433
8 0.2138 1,152.779
7 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:05 AMPage 12 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Summer

0.1118 8.2000e-
004

0.1126 0.0296 7.6000e-
004

0.0304 110.7403110.74032.9800e-
003
110.8148
Total 0.0422 0.0274 0.3767 1.1100e-
003

0.1118 8.2000e-
004

0.1126 0.0296 7.6000e-
004

0.0304 110.7403110.74032.9800e-
003
110.8148
Mitigated Construction Off-Site

3.5 Building Construction - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.7750 7.9850 7.2637 0.0114 0.4475 0.4475 0.4117 0.4117 1,103.215 8 1,103.215
8 0.3568 1,112.135
8 Total 0.7750 7.9850 7.2637 0.0114 0.4475 0.4475 0.4117 0.4117 1,103.215 8 1,103.215
8 0.3568 1,112.135
8 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:05 AMPage 13 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Summer

3.5 Building Construction - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0807 2.7659 0.6564 7.4000e-
003

0.1856 5.5700e-
003

0.1912 0.0534 5.3300e-
003

0.0588 790.0716790.0716 0.0478 791.2664
Worker 0.3166 0.2053 2.8254 8.3400e-
003

0.8383 6.1700e-
003

0.8445 0.2223 5.6800e-
003

0.2280 830.5525830.5525 0.0223 831.1109
Total 0.3973 2.9712 3.4818 0.0157 1.0239 0.0117 1.0357 0.2758 0.0110 0.2868 1,620.624 0 1,620.624
0 0.0701 1,622.377
2 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.7750 7.9850 7.2637 0.0114 0.4475 0.4475 0.4117 0.4117 0.0000 1,103.215 8 1,103.215
8 0.3568 1,112.135
8 Total 0.7750 7.9850 7.2637 0.0114 0.4475 0.4475 0.4117 0.4117 0.0000 1,103.215 8 1,103.215
8 0.3568 1,112.135
8 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:05 AMPage 14 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Summer

3.5 Building Construction - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0807 2.7659 0.6564 7.4000e-
003

0.1856 5.5700e-
003

0.1912 0.0534 5.3300e-
003

0.0588 790.0716790.0716 0.0478 791.2664
Worker 0.3166 0.2053 2.8254 8.3400e-
003

0.8383 6.1700e-
003

0.8445 0.2223 5.6800e-
003

0.2280 830.5525830.5525 0.0223 831.1109
Total 0.3973 2.9712 3.4818 0.0157 1.0239 0.0117 1.0357 0.2758 0.0110 0.2868 1,620.624 0 1,620.624
0 0.0701 1,622.377
2 Mitigated Construction Off-Site

3.6 Paving - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.7214 6.7178 7.0899 0.0113 0.3534 0.3534 0.3286 0.3286 1,035.342 5 1,035.342
5 0.3016 1,042.881
8 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.7214 6.7178 7.0899 0.0113 0.3534 0.3534 0.3286 0.3286 1,035.342 5 1,035.342
5 0.3016 1,042.881
8 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:05 AMPage 15 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Summer

3.6 Paving - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0760 0.0493 0.6781 2.0000e-
003

0.2012 1.4800e-
003

0.2027 0.0534 1.3600e-
003

0.0547 199.3326199.33265.3600e-
003
199.4666
Total 0.0760 0.0493 0.6781 2.0000e-
003

0.2012 1.4800e-
003

0.2027 0.0534 1.3600e-
003

0.0547 199.3326199.33265.3600e-
003
199.4666
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.7214 6.7178 7.0899 0.0113 0.3534 0.3534 0.3286 0.3286 0.0000 1,035.342 5 1,035.342
5 0.3016 1,042.881
8 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.7214 6.7178 7.0899 0.0113 0.3534 0.3534 0.3286 0.3286 0.0000 1,035.342 5 1,035.342
5 0.3016 1,042.881
8 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:05 AMPage 16 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Summer

0.2012 1.4800e-
003

0.2027 0.0534 1.3600e-
003

0.0547 199.3326199.33265.3600e-
003
199.4666
Total 0.0760 0.0493 0.6781 2.0000e-
003

0.2012 1.4800e-
003

0.2027 0.0534 1.3600e-
003

0.0547 199.3326199.33265.3600e-
003
199.4666
Mitigated Construction Off-Site

0.0941 0.0941 0.0941 0.0941 281.4481281.4481 0.0193 281.9309 Total 229.5383 1.5268 1.8176 2.9700e-
003

0.0941 0.0941 0.0941 0.0941 281.4481281.4481 0.0193 281.9309 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:05 AMPage 17 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Summer

3.7 Architectural Coating - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0633 0.0411 0.5651 1.6700e-
003

0.1677 1.2300e-
003

0.1689 0.0445 1.1400e-
003

0.0456 166.1105166.11054.4700e-
003
166.2222
Total 0.0633 0.0411 0.5651 1.6700e-
003

0.1677 1.2300e-
003

0.1689 0.0445 1.1400e-
003

0.0456 166.1105166.11054.4700e-
003
166.2222
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Archit. Coating 229.3194 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.2189 1.5268 1.8176 2.9700e-
003

0.0941 0.0941 0.0941 0.0941 0.0000 281.4481281.4481 0.0193 281.9309 Total 229.5383 1.5268 1.8176 2.9700e-
003

0.0941 0.0941 0.0941 0.0941 0.0000 281.4481281.4481 0.0193 281.9309 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:05 AMPage 18 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Summer

4.0 Operational Detail - Mobile

4.1 Mitigation Measures Mobile

0.1677 1.2300e-
003

0.1689 0.0445 1.1400e-
003

0.0456 166.1105166.11054.4700e-
003
166.2222
Total 0.0633 0.0411 0.5651 1.6700e-
003

0.1677 1.2300e-
003

0.1689 0.0445 1.1400e-
003

0.0456 166.1105166.11054.4700e-
003
166.2222
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:05 AMPage 19 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Summer ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 2.2214 10.8617 25.2626 0.0927 7.4230 0.0712 7.4942 1.9861 0.0664 2.0525 9,444.500 9 9,444.500
9 0.4570 9,455.925
9 Unmitigated 2.2214 10.8617 25.2626 0.0927 7.4230 0.0712 7.4942 1.9861 0.0664 2.0525 9,444.500 9 9,444.500
9 0.4570 9,455.925
9 4.2 Trip Summary Information

4.4 Fleet Mix
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:05 AMPage 20 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Summer

5.0 Energy Detail
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
NaturalGas
Mitigated

0.1066 0.9687 0.8137 5.8100e-
003

0.0736 0.0736 0.0736 0.0736 1,162.451
6 1,162.451
6 0.0223 0.0213 1,169.359
5 NaturalGas
Unmitigated

0.1066 0.9687 0.8137 5.8100e-
003

0.0736 0.0736 0.0736 0.0736 1,162.451
6 1,162.451
6 0.0223 0.0213 1,169.359
5 5.1 Mitigation Measures Energy
Kilowatt Hours of Renewable Electricity Generated
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH Enclosed Parking with Elevator 0.5495590.0428930.2015640.1185330.0155690.0058460.0213940.0342550.0020990.0018280.0048550.0007090.000896 Health Club 0.5495590.0428930.2015640.1185330.0155690.0058460.0213940.0342550.0020990.0018280.0048550.0007090.000896 Hotel 0.5495590.0428930.2015640.1185330.0155690.0058460.0213940.0342550.0020990.0018280.0048550.0007090.000896 Quality Restaurant 0.5495590.0428930.2015640.1185330.0155690.0058460.0213940.0342550.0020990.0018280.0048550.0007090.000896 Historical Energy Use: N
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:05 AMPage 21 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Summer

5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Enclosed Parking
with Elevator
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Health Club 34.7123 3.7000e-
004

3.4000e-
003

2.8600e-
003

2.0000e-
005

2.6000e-
004

4.0838 4.0838 8.0000e-
005

7.0000e-
005

4.1081
Hotel 7751.58 0.0836 0.7600 0.6384 4.5600e-
003

0.0578 0.0578 0.0578 0.0578 911.9511911.9511 0.0175 0.0167 917.3704 Quality
Restaurant
2094.54 0.0226 0.2054 0.1725 1.2300e-
003

0.0156 0.0156 0.0156 0.0156 246.4167246.41674.7200e-
003

4.5200e-
003
247.8811
Total 0.1066 0.9687 0.8137 5.8100e-
003

0.0736 0.0736 0.0736 0.0736 1,162.451
6 1,162.451
6 0.0223 0.0213 1,169.359
5 Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:05 AMPage 22 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Summer

6.1 Mitigation Measures Area

6.0 Area Detail

5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Enclosed Parking
with Elevator
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Health Club 0.03471233.7000e-
004

3.4000e-
003

2.8600e-
003

2.0000e-
005

2.6000e-
004

4.0838 4.0838 8.0000e-
005

7.0000e-
005

4.1081
Hotel 7.75158 0.0836 0.7600 0.6384 4.5600e-
003

0.0578 0.0578 0.0578 0.0578 911.9511911.9511 0.0175 0.0167 917.3704 Quality
Restaurant

2.09454 0.0226 0.2054 0.1725 1.2300e-
003

0.0156 0.0156 0.0156 0.0156 246.4167246.41674.7200e-
003

4.5200e-
003
247.8811
Total 0.1066 0.9687 0.8137 5.8100e-
003

0.0736 0.0736 0.0736 0.0736 1,162.451
6 1,162.451
6 0.0223 0.0213 1,169.359
5 Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:05 AMPage 23 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Summer ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 2.7527 3.0000e-
004

0.0324 0.0000 1.2000e-
004

1.2000e-
004

0.0694 0.0694 1.8000e-
004

0.0740
Unmitigated 2.7527 3.0000e-
004

0.0324 0.0000 1.2000e-
004

1.2000e-
004

0.0694 0.0694 1.8000e-
004

0.0740

6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating

0.3141 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products

2.4355 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 3.0100e-
003

3.0000e-
004

0.0324 0.0000 1.2000e-
004

1.2000e-
004

0.0694 0.0694 1.8000e-
004

0.0740
Total 2.7527 3.0000e-
004

0.0324 0.0000 1.2000e-
004

1.2000e-
004

0.0694 0.0694 1.8000e-
004

0.0740
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:05 AMPage 24 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Summer

8.1 Mitigation Measures Waste
Institute Recycling and Composting Services

7.1 Mitigation Measures Water

7.0 Water Detail

8.0 Waste Detail

0.3141 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products

2.4355 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 3.0100e-
003

3.0000e-
004

0.0324 0.0000 1.2000e-
004

1.2000e-
004

0.0694 0.0694 1.8000e-
004

0.0740
Total 2.7527 3.0000e-
004

0.0324 0.0000 1.2000e-
004

1.2000e-
004

0.0694 0.0694 1.8000e-
004

0.0740
Mitigated

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

10.0 Stationary Equipment
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:05 AMPage 25 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Summer

11.0 Vegetation
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment
Equipment Type Number
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:05 AMPage 26 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Summer

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
11 Wind Speed (m/s) Precipitation Freq (Days)2.2 31

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company Southern California Edison
2022Operational Year
CO2 Intensity
(lb/MWhr)
702.44 0.029CH4 Intensity
(lb/MWhr)

0.006N2O Intensity
(lb/MWhr)
11469 Jefferson - Operations
South Coast AQMD Air District, Winter
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:06 AMPage 1 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Winter Project Characteristics - See SWAPE comment regarding CO2 intensity factor.

Land Use - See SWAPE comment regarding parking and failure to model all proposed land uses.

Vehicle Trips - Consistent with the IS/MND's model.

Vehicle Emission Factors - See SWAPE comment regarding operational vehicle emission factors.

Vehicle Emission Factors -
Vehicle Emission Factors -
Energy Mitigation - Consistent with the IS/MND's model.

Waste Mitigation -

2.0 Emissions Summary
Table Name Column Name Default Value New Value
tblLandUse LandUseSquareFeet 55,200.00 56,300.00
tblLandUse LandUseSquareFeet 254,100.00 117,987.00
tblLandUse LandUseSquareFeet 3,310.00 3,313.00
tblLandUse LotAcreage 1.24 0.28
tblLandUse LotAcreage 5.83 0.50
tblVehicleTrips ST_TR 20.87 0.00
tblVehicleTrips ST_TR 8.19 8.36
tblVehicleTrips ST_TR 94.36 0.00
tblVehicleTrips SU_TR 26.73 0.00
tblVehicleTrips SU_TR 5.95 8.36
tblVehicleTrips SU_TR 72.16 0.00
tblVehicleTrips WD_TR 32.93 0.00
tblVehicleTrips WD_TR 8.17 8.36
tblVehicleTrips WD_TR 89.95 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:06 AMPage 2 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Winter

2.1 Overall Construction (Maximum Daily Emission)
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2021 229.607510.9669 10.5372 0.0264 1.0239 0.4595 1.4834 0.4434 0.4229 0.8328 0.0000 2,647.162 2 2,647.162
2 0.4290 0.0000 2,657.886
0 Maximum 229.607510.9669 10.5372 0.0264 1.0239 0.4595 1.4834 0.4434 0.4229 0.8328 0.0000 2,647.162 2 2,647.162
2 0.4290 0.0000 2,657.886
0 Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2021 229.607510.9669 10.5372 0.0264 1.0239 0.4595 1.4834 0.4434 0.4229 0.8328 0.0000 2,647.162 2 2,647.162
2 0.4290 0.0000 2,657.886
0 Maximum 229.607510.9669 10.5372 0.0264 1.0239 0.4595 1.4834 0.4434 0.4229 0.8328 0.0000 2,647.162 2 2,647.162
2 0.4290 0.0000 2,657.886
0 Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio-CO2Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:06 AMPage 3 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Winter

0.0324 0.0000 1.2000e-
004

1.2000e-
004

0.0694 0.0694 1.8000e-
004

0.0740
Energy 0.1066 0.9687 0.8137 5.8100e-
003

0.0736 0.0736 0.0736 0.0736 1,162.451
6 1,162.451
6 0.0223 0.0213 1,169.359
5 Mobile 2.1043 10.9950 23.9828 0.0877 7.4230 0.0717 7.4948 1.9861 0.0669 2.0531 8,935.124 6 8,935.124
6 0.4611 8,946.652
7 Total 4.9635 11.9640 24.8289 0.0935 7.4230 0.1455 7.5685 1.9861 0.1407 2.1268 10,097.64 56 10,097.64
56 0.4836 0.0213 10,116.08
61 Unmitigated Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 2.7527 3.0000e-
004

0.0324 0.0000 1.2000e-
004

1.2000e-
004

0.0694 0.0694 1.8000e-
004

0.0740
Energy 0.1066 0.9687 0.8137 5.8100e-
003

0.0736 0.0736 0.0736 0.0736 1,162.451
6 1,162.451
6 0.0223 0.0213 1,169.359
5 Mobile 2.1043 10.9950 23.9828 0.0877 7.4230 0.0717 7.4948 1.9861 0.0669 2.0531 8,935.124 6 8,935.124
6 0.4611 8,946.652
7 Total 4.9635 11.9640 24.8289 0.0935 7.4230 0.1455 7.5685 1.9861 0.1407 2.1268 10,097.64 56 10,097.64
56 0.4836 0.0213 10,116.08
61 Mitigated Operational
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:06 AMPage 4 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Winter

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 183,000; Non-Residential Outdoor: 61,000; Striped Parking Area: 3,378 (Architectural Coating – sqft)
Acres of Grading (Site Preparation Phase): 0.5
Acres of Grading (Grading Phase): 0
Acres of Paving: 0.28
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:06 AMPage 5 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Winter Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Demolition Concrete/Industrial Saws 1 8.00 81 0.73
Demolition Rubber Tired Dozers 1 1.00 247 0.40
Demolition Tractors/Loaders/Backhoes 2 6.00 97 0.37
Site Preparation Graders 1 8.00 187 0.41
Site Preparation Tractors/Loaders/Backhoes 1 8.00 97 0.37 Grading Concrete/Industrial Saws 1 8.00 81 0.73
Grading Rubber Tired Dozers 1 1.00 247 0.40
Grading Tractors/Loaders/Backhoes 2 6.00 97 0.37
Building Construction Cranes 1 4.00 231 0.29
Building Construction Forklifts 2 6.00 89 0.20
Building Construction Tractors/Loaders/Backhoes 2 8.00 97 0.37 Paving Cement and Mortar Mixers 4 6.00 9 0.56
Paving Pavers 1 7.00 130 0.42
Paving Rollers 1 7.00 80 0.38
Paving Tractors/Loaders/Backhoes 1 7.00 97 0.37
Architectural Coating Air Compressors 1 6.00 78 0.48
Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Demolition 4 10.00 0.00 0.00 14.70 6.90 20.00LD_Mix HDT_Mix HHDT Site Preparation 2 5.00 0.00 0.00 14.70 6.90 20.00LD_Mix HDT_Mix HHDT Grading 4 10.00 0.00 0.00 14.70 6.90 20.00LD_Mix HDT_Mix HHDT Building Construction 5 75.00 29.00 0.00 14.70 6.90 20.00LD_Mix HDT_Mix HHDT Paving 7 18.00 0.00 0.00 14.70 6.90 20.00LD_Mix HDT_Mix HHDT Architectural Coating 1 15.00 0.00 0.00 14.70 6.90 20.00LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:06 AMPage 6 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Winter

3.1 Mitigation Measures Construction
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:06 AMPage 7 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Winter

0.1118 8.2000e-
004

0.1126 0.0296 7.6000e-
004

0.0304 103.5668103.56682.7800e-
003
103.6362
Total 0.0461 0.0300 0.3385 1.0400e-
003

0.1118 8.2000e-
004

0.1126 0.0296 7.6000e-
004

0.0304 103.5668103.56682.7800e-
003
103.6362
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.7965 7.2530 7.5691 0.0120 0.4073 0.4073 0.3886 0.3886 0.0000 1,147.433 8 1,147.433
8 0.2138 1,152.779
7 Total 0.7965 7.2530 7.5691 0.0120 0.4073 0.4073 0.3886 0.3886 0.0000 1,147.433 8 1,147.433
8 0.2138 1,152.779
7 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:06 AMPage 8 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Winter

0.1118 8.2000e-
004

0.1126 0.0296 7.6000e-
004

0.0304 103.5668103.56682.7800e-
003
103.6362
Total 0.0461 0.0300 0.3385 1.0400e-
003

0.1118 8.2000e-
004

0.1126 0.0296 7.6000e-
004

0.0304 103.5668103.56682.7800e-
003
103.6362
Mitigated Construction Off-Site

0.2995 0.2995 0.2755 0.2755 942.5842942.5842 0.3049 950.2055 Total 0.6403 7.8204 4.0274 9.7300e-
003

0.5303 0.2995 0.8297 0.0573 0.2755 0.3328 942.5842942.5842 0.3049 950.2055 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:06 AMPage 9 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Winter

0.0559 4.1000e-
004

0.0563 0.0148 3.8000e-
004

0.0152 51.7834 51.7834 1.3900e-
003

51.8181
Total 0.0231 0.0150 0.1693 5.2000e-
004

0.0559 4.1000e-
004

0.0563 0.0148 3.8000e-
004

0.0152 51.7834 51.7834 1.3900e-
003

51.8181
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 0.5303 0.0000 0.5303 0.0573 0.0000 0.0573 0.0000 0.0000 Off-Road 0.6403 7.8204 4.0274 9.7300e-
003

0.2995 0.2995 0.2755 0.2755 0.0000 942.5842942.5842 0.3049 950.2055 Total 0.6403 7.8204 4.0274 9.7300e-
003

0.5303 0.2995 0.8297 0.0573 0.2755 0.3328 0.0000 942.5842942.5842 0.3049 950.2055 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:06 AMPage 10 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Winter

0.0559 4.1000e-
004

0.0563 0.0148 3.8000e-
004

0.0152 51.7834 51.7834 1.3900e-
003

51.8181
Total 0.0231 0.0150 0.1693 5.2000e-
004

0.0559 4.1000e-
004

0.0563 0.0148 3.8000e-
004

0.0152 51.7834 51.7834 1.3900e-
003

51.8181
Mitigated Construction Off-Site

3.4 Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 0.7528 0.0000 0.7528 0.4138 0.0000 0.4138 0.0000 0.0000 Off-Road 0.7965 7.2530 7.5691 0.0120 0.4073 0.4073 0.3886 0.3886 1,147.433 8 1,147.433
8 0.2138 1,152.779
7 Total 0.7965 7.2530 7.5691 0.0120 0.7528 0.4073 1.1601 0.4138 0.3886 0.8024 1,147.433 8 1,147.433
8 0.2138 1,152.779
7 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:06 AMPage 11 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Winter

0.1118 8.2000e-
004

0.1126 0.0296 7.6000e-
004

0.0304 103.5668103.56682.7800e-
003
103.6362
Total 0.0461 0.0300 0.3385 1.0400e-
003

0.1118 8.2000e-
004

0.1126 0.0296 7.6000e-
004

0.0304 103.5668103.56682.7800e-
003
103.6362
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 0.7528 0.0000 0.7528 0.4138 0.0000 0.4138 0.0000 0.0000 Off-Road 0.7965 7.2530 7.5691 0.0120 0.4073 0.4073 0.3886 0.3886 0.0000 1,147.433 8 1,147.433
8 0.2138 1,152.779
7 Total 0.7965 7.2530 7.5691 0.0120 0.7528 0.4073 1.1601 0.4138 0.3886 0.8024 0.0000 1,147.433 8 1,147.433
8 0.2138 1,152.779
7 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:06 AMPage 12 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Winter

0.1118 8.2000e-
004

0.1126 0.0296 7.6000e-
004

0.0304 103.5668103.56682.7800e-
003
103.6362
Total 0.0461 0.0300 0.3385 1.0400e-
003

0.1118 8.2000e-
004

0.1126 0.0296 7.6000e-
004

0.0304 103.5668103.56682.7800e-
003
103.6362
Mitigated Construction Off-Site

3.5 Building Construction - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.7750 7.9850 7.2637 0.0114 0.4475 0.4475 0.4117 0.4117 1,103.215 8 1,103.215
8 0.3568 1,112.135
8 Total 0.7750 7.9850 7.2637 0.0114 0.4475 0.4475 0.4117 0.4117 1,103.215 8 1,103.215
8 0.3568 1,112.135
8 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:06 AMPage 13 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Winter

3.5 Building Construction - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0849 2.7571 0.7345 7.1900e-
003

0.1856 5.7500e-
003

0.1914 0.0534 5.5000e-
003

0.0589 767.1956767.1956 0.0513 768.4788
Worker 0.3459 0.2248 2.5391 7.7900e-
003

0.8383 6.1700e-
003

0.8445 0.2223 5.6800e-
003

0.2280 776.7509776.7509 0.0208 777.2713
Total 0.4308 2.9819 3.2735 0.0150 1.0239 0.0119 1.0358 0.2758 0.0112 0.2869 1,543.946 5 1,543.946
5 0.0722 1,545.750
2 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.7750 7.9850 7.2637 0.0114 0.4475 0.4475 0.4117 0.4117 0.0000 1,103.215 8 1,103.215
8 0.3568 1,112.135
8 Total 0.7750 7.9850 7.2637 0.0114 0.4475 0.4475 0.4117 0.4117 0.0000 1,103.215 8 1,103.215
8 0.3568 1,112.135
8 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:06 AMPage 14 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Winter

3.5 Building Construction - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0849 2.7571 0.7345 7.1900e-
003

0.1856 5.7500e-
003

0.1914 0.0534 5.5000e-
003

0.0589 767.1956767.1956 0.0513 768.4788
Worker 0.3459 0.2248 2.5391 7.7900e-
003

0.8383 6.1700e-
003

0.8445 0.2223 5.6800e-
003

0.2280 776.7509776.7509 0.0208 777.2713
Total 0.4308 2.9819 3.2735 0.0150 1.0239 0.0119 1.0358 0.2758 0.0112 0.2869 1,543.946 5 1,543.946
5 0.0722 1,545.750
2 Mitigated Construction Off-Site

3.6 Paving - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.7214 6.7178 7.0899 0.0113 0.3534 0.3534 0.3286 0.3286 1,035.342 5 1,035.342
5 0.3016 1,042.881
8 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.7214 6.7178 7.0899 0.0113 0.3534 0.3534 0.3286 0.3286 1,035.342 5 1,035.342
5 0.3016 1,042.881
8 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:06 AMPage 15 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Winter

0.2012 1.4800e-
003

0.2027 0.0534 1.3600e-
003

0.0547 186.4202186.42025.0000e-
003
186.5451
Total 0.0830 0.0539 0.6094 1.8700e-
003

0.2012 1.4800e-
003

0.2027 0.0534 1.3600e-
003

0.0547 186.4202186.42025.0000e-
003
186.5451
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.7214 6.7178 7.0899 0.0113 0.3534 0.3534 0.3286 0.3286 0.0000 1,035.342 5 1,035.342
5 0.3016 1,042.881
8 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.7214 6.7178 7.0899 0.0113 0.3534 0.3534 0.3286 0.3286 0.0000 1,035.342 5 1,035.342
5 0.3016 1,042.881
8 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:06 AMPage 16 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Winter

0.2012 1.4800e-
003

0.2027 0.0534 1.3600e-
003

0.0547 186.4202186.42025.0000e-
003
186.5451
Total 0.0830 0.0539 0.6094 1.8700e-
003

0.2012 1.4800e-
003

0.2027 0.0534 1.3600e-
003

0.0547 186.4202186.42025.0000e-
003
186.5451
Mitigated Construction Off-Site

0.0941 0.0941 0.0941 0.0941 281.4481281.4481 0.0193 281.9309 Total 229.5383 1.5268 1.8176 2.9700e-
003

0.0941 0.0941 0.0941 0.0941 281.4481281.4481 0.0193 281.9309 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:06 AMPage 17 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Winter

0.1677 1.2300e-
003

0.1689 0.0445 1.1400e-
003

0.0456 155.3502155.35024.1600e-
003
155.4543
Total 0.0692 0.0450 0.5078 1.5600e-
003

0.1677 1.2300e-
003

0.1689 0.0445 1.1400e-
003

0.0456 155.3502155.35024.1600e-
003
155.4543
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Archit. Coating 229.3194 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.2189 1.5268 1.8176 2.9700e-
003

0.0941 0.0941 0.0941 0.0941 0.0000 281.4481281.4481 0.0193 281.9309 Total 229.5383 1.5268 1.8176 2.9700e-
003

0.0941 0.0941 0.0941 0.0941 0.0000 281.4481281.4481 0.0193 281.9309 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:06 AMPage 18 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Winter

4.0 Operational Detail - Mobile

4.1 Mitigation Measures Mobile

0.1677 1.2300e-
003

0.1689 0.0445 1.1400e-
003

0.0456 155.3502155.35024.1600e-
003
155.4543
Total 0.0692 0.0450 0.5078 1.5600e-
003

0.1677 1.2300e-
003

0.1689 0.0445 1.1400e-
003

0.0456 155.3502155.35024.1600e-
003
155.4543
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:06 AMPage 19 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Winter ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 2.1043 10.9950 23.9828 0.0877 7.4230 0.0717 7.4948 1.9861 0.0669 2.0531 8,935.124 6 8,935.124
6 0.4611 8,946.652
7 Unmitigated 2.1043 10.9950 23.9828 0.0877 7.4230 0.0717 7.4948 1.9861 0.0669 2.0531 8,935.124 6 8,935.124
6 0.4611 8,946.652
7 4.2 Trip Summary Information

4.4 Fleet Mix
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:06 AMPage 20 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Winter

5.0 Energy Detail
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
NaturalGas
Mitigated

0.1066 0.9687 0.8137 5.8100e-
003

0.0736 0.0736 0.0736 0.0736 1,162.451
6 1,162.451
6 0.0223 0.0213 1,169.359
5 NaturalGas
Unmitigated

0.1066 0.9687 0.8137 5.8100e-
003

0.0736 0.0736 0.0736 0.0736 1,162.451
6 1,162.451
6 0.0223 0.0213 1,169.359
5 5.1 Mitigation Measures Energy
Kilowatt Hours of Renewable Electricity Generated
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH Enclosed Parking with Elevator 0.5495590.0428930.2015640.1185330.0155690.0058460.0213940.0342550.0020990.0018280.0048550.0007090.000896 Health Club 0.5495590.0428930.2015640.1185330.0155690.0058460.0213940.0342550.0020990.0018280.0048550.0007090.000896 Hotel 0.5495590.0428930.2015640.1185330.0155690.0058460.0213940.0342550.0020990.0018280.0048550.0007090.000896 Quality Restaurant 0.5495590.0428930.2015640.1185330.0155690.0058460.0213940.0342550.0020990.0018280.0048550.0007090.000896 Historical Energy Use: N
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:06 AMPage 21 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Winter

5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Enclosed Parking
with Elevator
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Health Club 34.7123 3.7000e-
004

3.4000e-
003

2.8600e-
003

2.0000e-
005

2.6000e-
004

4.0838 4.0838 8.0000e-
005

7.0000e-
005

4.1081
Hotel 7751.58 0.0836 0.7600 0.6384 4.5600e-
003

0.0578 0.0578 0.0578 0.0578 911.9511911.9511 0.0175 0.0167 917.3704 Quality
Restaurant
2094.54 0.0226 0.2054 0.1725 1.2300e-
003

0.0156 0.0156 0.0156 0.0156 246.4167246.41674.7200e-
003

4.5200e-
003
247.8811
Total 0.1066 0.9687 0.8137 5.8100e-
003

0.0736 0.0736 0.0736 0.0736 1,162.451
6 1,162.451
6 0.0223 0.0213 1,169.359
5 Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:06 AMPage 22 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Winter

6.1 Mitigation Measures Area

6.0 Area Detail

5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Enclosed Parking
with Elevator
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Health Club 0.03471233.7000e-
004

3.4000e-
003

2.8600e-
003

2.0000e-
005

2.6000e-
004

4.0838 4.0838 8.0000e-
005

7.0000e-
005

4.1081
Hotel 7.75158 0.0836 0.7600 0.6384 4.5600e-
003

0.0578 0.0578 0.0578 0.0578 911.9511911.9511 0.0175 0.0167 917.3704 Quality
Restaurant

2.09454 0.0226 0.2054 0.1725 1.2300e-
003

0.0156 0.0156 0.0156 0.0156 246.4167246.41674.7200e-
003

4.5200e-
003
247.8811
Total 0.1066 0.9687 0.8137 5.8100e-
003

0.0736 0.0736 0.0736 0.0736 1,162.451
6 1,162.451
6 0.0223 0.0213 1,169.359
5 Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:06 AMPage 23 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Winter ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 2.7527 3.0000e-
004

0.0324 0.0000 1.2000e-
004

1.2000e-
004

0.0694 0.0694 1.8000e-
004

0.0740
Unmitigated 2.7527 3.0000e-
004

0.0324 0.0000 1.2000e-
004

1.2000e-
004

0.0694 0.0694 1.8000e-
004

0.0740

0.3141 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products

2.4355 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 3.0100e-
003

3.0000e-
004

0.0324 0.0000 1.2000e-
004

1.2000e-
004

0.0694 0.0694 1.8000e-
004

0.0740
Total 2.7527 3.0000e-
004

0.0324 0.0000 1.2000e-
004

1.2000e-
004

0.0694 0.0694 1.8000e-
004

0.0740
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:06 AMPage 24 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Winter

8.1 Mitigation Measures Waste
Institute Recycling and Composting Services

7.1 Mitigation Measures Water

7.0 Water Detail

8.0 Waste Detail

0.3141 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products

2.4355 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 3.0100e-
003

3.0000e-
004

0.0324 0.0000 1.2000e-
004

1.2000e-
004

0.0694 0.0694 1.8000e-
004

0.0740
Total 2.7527 3.0000e-
004

0.0324 0.0000 1.2000e-
004

1.2000e-
004

0.0694 0.0694 1.8000e-
004

0.0740
Mitigated

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

10.0 Stationary Equipment
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:06 AMPage 25 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Winter

11.0 Vegetation
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment
Equipment Type Number
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/17/2021 10:06 AMPage 26 of 26 11469 Jefferson - Operations - South Coast AQMD Air District, Winter

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
11 Wind Speed (m/s) Precipitation Freq (Days)2.2 31

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company Southern California Edison
2022Operational Year
CO2 Intensity
(lb/MWhr)
702.44 0.029CH4 Intensity
(lb/MWhr)

0.006N2O Intensity
(lb/MWhr)
11469 Jefferson - Construction
South Coast AQMD Air District, Summer
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 1 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer Project Characteristics - Consistent with the IS/MND's model.

Land Use - See SWAPE comment regarding parking and failure to model all proposed land uses.

Construction Phase - See SWAPE comment regarding constructuion schedule and number of days per week, Off-road Equipment - See SWAPE comment regarding construction equipment unit amounts and usage hours.

Trips and VMT - See SWAPE comment regarding worker, vendor, and hauling trips.

Demolition -
Grading - See SWAPE comment regarding material export.

Construction Off-road Equipment Mitigation - Consistent with the DEIR's model.

CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 2 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer Table Name Column Name Default Value New Value
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 4.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 3.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 6.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 11.00 tblConstEquipMitigation Tier No Change Tier 4 Final
tblConstEquipMitigation Tier No Change Tier 4 Final
tblConstEquipMitigation Tier No Change Tier 4 Final
tblConstEquipMitigation Tier No Change Tier 4 Final
tblConstEquipMitigation Tier No Change Tier 4 Final
tblConstEquipMitigation Tier No Change Tier 4 Final
tblConstEquipMitigation Tier No Change Tier 4 Final
tblConstEquipMitigation Tier No Change Tier 4 Final
tblConstEquipMitigation Tier No Change Tier 4 Final
tblGrading MaterialExported 0.00 43,836.00
tblLandUse LandUseSquareFeet 55,200.00 56,300.00
tblLandUse LandUseSquareFeet 254,100.00 117,987.00
tblLandUse LandUseSquareFeet 3,310.00 3,313.00
tblLandUse LotAcreage 1.24 0.28
tblLandUse LotAcreage 5.83 0.50
tblTripsAndVMT HaulingTripNumber 0.00 5,044.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 3 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer

2.0 Emissions Summary

2.1 Overall Construction (Maximum Daily Emission)
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2020 21.7234753.5728156.4009 2.1378 51.2224 2.8718 54.0942 13.9401 2.7462 16.6862 0.0000 230,963.8 803
230,963.8
803

15.6343 0.0000 231,354.7
366
2021 229.601610.9562 10.7455 0.0271 1.0239 0.4593 1.4832 0.2758 0.4227 0.6985 0.0000 2,723.839 8 2,723.839
8 0.4269 0.0000 2,734.513
0 Maximum 229.6016753.5728156.4009 2.1378 51.2224 2.8718 54.0942 13.9401 2.7462 16.6862 0.0000 230,963.8 803
230,963.8
803

15.6343 0.0000 231,354.7
366
Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2020 20.9887746.2746156.6292 2.1378 51.2224 2.4223 53.6447 13.9401 2.3182 16.2582 0.0000 230,963.8 803
230,963.8
803

15.6343 0.0000 231,354.7
366
2021 229.4124 3.5764 11.2079 0.0271 1.0239 0.0304 1.0543 0.2758 0.0296 0.3054 0.0000 2,723.839 8 2,723.839
8 0.4269 0.0000 2,734.513
0 Maximum 229.4124746.2746156.6292 2.1378 51.2224 2.4223 53.6447 13.9401 2.3182 16.2582 0.0000 230,963.8 803
230,963.8
803

15.6343 0.0000 231,354.7
366
Mitigated Construction
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 4 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio-CO2Total CO2 CH4 N20 CO2e
Percent
Reduction

0.37 1.92 -0.41 0.00 0.00 26.37 1.58 0.00 25.91 4.72 0.00 0.00 0.00 0.00 0.00 0.00 CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 5 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer

0.0324 0.0000 1.2000e-
004

1.2000e-
004

0.0694 0.0694 1.8000e-
004

0.0740
Energy 0.1066 0.9687 0.8137 5.8100e-
003

0.0736 0.0736 0.0736 0.0736 1,162.451
6 1,162.451
6 0.0223 0.0213 1,169.359
5 Mobile 2.6194 12.6894 28.7558 0.1046 8.3224 0.0806 8.4030 2.2268 0.0751 2.3019 10,658.92 30 10,658.92
30 0.5222 10,671.97
71 Total 5.4787 13.6584 29.6019 0.1104 8.3224 0.1543 8.4767 2.2268 0.1489 2.3756 11,821.44 40 11,821.44
40 0.5446 0.0213 11,841.41
06 Unmitigated Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 2.7527 3.0000e-
004

0.0324 0.0000 1.2000e-
004

1.2000e-
004

0.0694 0.0694 1.8000e-
004

0.0740
Energy 0.1066 0.9687 0.8137 5.8100e-
003

0.0736 0.0736 0.0736 0.0736 1,162.451
6 1,162.451
6 0.0223 0.0213 1,169.359
5 Mobile 2.6194 12.6894 28.7558 0.1046 8.3224 0.0806 8.4030 2.2268 0.0751 2.3019 10,658.92 30 10,658.92
30 0.5222 10,671.97
71 Total 5.4787 13.6584 29.6019 0.1104 8.3224 0.1543 8.4767 2.2268 0.1489 2.3756 11,821.44 40 11,821.44
40 0.5446 0.0213 11,841.41
06 Mitigated Operational
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 6 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer

3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 5/4/2020 5/15/2020 5 10
2 Excavation Grading 5/16/2020 5/19/2020 5 2
3 Building Construction Building Construction 5/20/2020 10/6/2020 5 100 4 Foundation Building Construction 10/7/2020 2/23/2021 5 100 5 Continuous Concrete Pour Building Construction 2/24/2021 7/13/2021 5 100 6 Paving Paving 7/14/2021 7/20/2021 5 5
7 Architectural Coating Architectural Coating 7/21/2021 7/27/2021 5 5 OffRoad Equipment
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio-CO2Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 183,000; Non-Residential Outdoor: 61,000; Striped Parking Area: 3,378 (Architectural Coating – sqft)
Acres of Grading (Site Preparation Phase): 0
Acres of Grading (Grading Phase): 0
Acres of Paving: 0.28
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 7 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Demolition Concrete/Industrial Saws 1 8.00 81 0.73
Demolition Rubber Tired Dozers 1 1.00 247 0.40
Demolition Tractors/Loaders/Backhoes 2 6.00 97 0.37
Excavation Concrete/Industrial Saws 1 8.00 81 0.73
Excavation Rubber Tired Dozers 1 1.00 247 0.40
Excavation Tractors/Loaders/Backhoes 2 6.00 97 0.37
Building Construction Cranes 1 4.00 231 0.29
Building Construction Forklifts 2 6.00 89 0.20
Building Construction Tractors/Loaders/Backhoes 2 8.00 97 0.37 Foundation Cranes 1 4.00 231 0.29
Foundation Forklifts 2 6.00 89 0.20
Foundation Tractors/Loaders/Backhoes 2 8.00 97 0.37
Continuous Concrete Pour Cranes 1 4.00 231 0.29
Continuous Concrete Pour Forklifts 2 6.00 89 0.20
Continuous Concrete Pour Tractors/Loaders/Backhoes 2 8.00 97 0.37 Paving Cement and Mortar Mixers 4 6.00 9 0.56
Paving Pavers 1 7.00 130 0.42
Paving Rollers 1 7.00 80 0.38
Paving Tractors/Loaders/Backhoes 1 7.00 97 0.37
Architectural Coating Air Compressors 1 6.00 78 0.48
Trips and VMT
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 8 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer

3.2 Demolition - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 3.3468 0.0000 3.3468 0.5067 0.0000 0.5067 0.0000 0.0000 Off-Road 0.8674 7.8729 7.6226 0.0120 0.4672 0.4672 0.4457 0.4457 1,147.235 2 1,147.235
2 0.2169 1,152.657
8 Total 0.8674 7.8729 7.6226 0.0120 3.3468 0.4672 3.8140 0.5067 0.4457 0.9524 1,147.235 2 1,147.235
2 0.2169 1,152.657
8 Unmitigated Construction On-Site

3.1 Mitigation Measures Construction
Use Cleaner Engines for Construction Equipment
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Demolition 4 10.00 0.00 155.00 14.70 6.90 20.00LD_Mix HDT_Mix HHDT Excavation 4 10.00 0.00 5,480.00 14.70 6.90 20.00LD_Mix HDT_Mix HHDT Building Construction 5 75.00 29.00 5,044.00 14.70 6.90 20.00LD_Mix HDT_Mix HHDT Foundation 5 75.00 29.00 0.00 14.70 6.90 20.00LD_Mix HDT_Mix HHDT Continuous Concrete
Pour
5 75.00 29.00 0.00 14.70 6.90 20.00LD_Mix HDT_Mix HHDT
Paving 7 18.00 0.00 0.00 14.70 6.90 20.00LD_Mix HDT_Mix HHDT Architectural Coating 1 15.00 0.00 0.00 14.70 6.90 20.00LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 9 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer

3.2 Demolition - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.1177 4.2182 0.8393 0.0120 0.2709 0.0136 0.2845 0.0742 0.0130 0.0872 1,299.410 3 1,299.410
3 0.0872 1,301.590
2 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0452 0.0304 0.4088 1.1500e-
003

0.1118 8.5000e-
004

0.1126 0.0296 7.8000e-
004

0.0304 114.4418114.44183.2900e-
003
114.5240
Total 0.1630 4.2486 1.2481 0.0132 0.3826 0.0145 0.3971 0.1039 0.0138 0.1177 1,413.852 0 1,413.852
0 0.0905 1,416.114
2 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 3.3468 0.0000 3.3468 0.5067 0.0000 0.5067 0.0000 0.0000 Off-Road 0.1326 0.5747 7.8509 0.0120 0.0177 0.0177 0.0177 0.0177 0.0000 1,147.235 2 1,147.235
2 0.2169 1,152.657
8 Total 0.1326 0.5747 7.8509 0.0120 3.3468 0.0177 3.3645 0.5067 0.0177 0.5244 0.0000 1,147.235 2 1,147.235
2 0.2169 1,152.657
8 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 10 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer

0.1118 8.5000e-
004

0.1126 0.0296 7.8000e-
004

0.0304 114.4418114.44183.2900e-
003
114.5240
Total 0.1630 4.2486 1.2481 0.0132 0.3826 0.0145 0.3971 0.1039 0.0138 0.1177 1,413.852 0 1,413.852
0 0.0905 1,416.114
2 Mitigated Construction Off-Site

3.3 Excavation - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 3.2315 0.0000 3.2315 0.7891 0.0000 0.7891 0.0000 0.0000 Off-Road 0.8674 7.8729 7.6226 0.0120 0.4672 0.4672 0.4457 0.4457 1,147.235 2 1,147.235
2 0.2169 1,152.657
8 Total 0.8674 7.8729 7.6226 0.0120 3.2315 0.4672 3.6987 0.7891 0.4457 1.2348 1,147.235 2 1,147.235
2 0.2169 1,152.657
8 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 11 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer

3.3 Excavation - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 20.8108745.6695148.3695 2.1246 47.8792 2.4037 50.2829 13.1213 2.2997 15.4210 229,702.2 033
229,702.2
033

15.4141 230,087.5
548
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0452 0.0304 0.4088 1.1500e-
003

0.1118 8.5000e-
004

0.1126 0.0296 7.8000e-
004

0.0304 114.4418114.44183.2900e-
003
114.5240
Total 20.8560745.6999148.7783 2.1258 47.9910 2.4046 50.3955 13.1510 2.3005 15.4514 229,816.6 451
229,816.6
451

15.4174 230,202.0
788
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 3.2315 0.0000 3.2315 0.7891 0.0000 0.7891 0.0000 0.0000 Off-Road 0.1326 0.5747 7.8509 0.0120 0.0177 0.0177 0.0177 0.0177 0.0000 1,147.235 2 1,147.235
2 0.2169 1,152.657
8 Total 0.1326 0.5747 7.8509 0.0120 3.2315 0.0177 3.2491 0.7891 0.0177 0.8068 0.0000 1,147.235 2 1,147.235
2 0.2169 1,152.657
8 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 12 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer

15.4141 230,087.5
548
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0452 0.0304 0.4088 1.1500e-
003

0.1118 8.5000e-
004

0.1126 0.0296 7.8000e-
004

0.0304 114.4418114.44183.2900e-
003
114.5240
Total 20.8560745.6999148.7783 2.1258 47.9910 2.4046 50.3955 13.1510 2.3005 15.4514 229,816.6 451
229,816.6
451

15.4174 230,202.0
788
Mitigated Construction Off-Site

3.4 Building Construction - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.8617 8.8523 7.3875 0.0114 0.5224 0.5224 0.4806 0.4806 1,102.978 1 1,102.978
1 0.3567 1,111.896
2 Total 0.8617 8.8523 7.3875 0.0114 0.5224 0.5224 0.4806 0.4806 1,102.978 1 1,102.978
1 0.3567 1,111.896
2 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 13 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer

3.4 Building Construction - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.3831 13.7269 2.7313 0.0391 0.8814 0.0443 0.9257 0.2416 0.0423 0.2839 4,228.532 5 4,228.532
5 0.2838 4,235.626
4 Vendor 0.0952 3.0431 0.7246 7.4600e-
003

0.1856 0.0151 0.2007 0.0534 0.0144 0.0679 795.9005795.9005 0.0500 797.1498 Worker 0.3393 0.2281 3.0661 8.6200e-
003

0.8383 6.3600e-
003

0.8447 0.2223 5.8600e-
003

0.2282 858.3131858.3131 0.0247 858.9300
Total 0.8177 16.9981 6.5221 0.0552 1.9053 0.0657 1.9710 0.5173 0.0626 0.5799 5,882.746 1 5,882.746
1 0.3584 5,891.706
2 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.1397 0.6052 7.7261 0.0114 0.0186 0.0186 0.0186 0.0186 0.0000 1,102.978 1 1,102.978
1 0.3567 1,111.896
2 Total 0.1397 0.6052 7.7261 0.0114 0.0186 0.0186 0.0186 0.0186 0.0000 1,102.978 1 1,102.978
1 0.3567 1,111.896
2 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 14 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer

3.4 Building Construction - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.3831 13.7269 2.7313 0.0391 0.8814 0.0443 0.9257 0.2416 0.0423 0.2839 4,228.532 5 4,228.532
5 0.2838 4,235.626
4 Vendor 0.0952 3.0431 0.7246 7.4600e-
003

0.1856 0.0151 0.2007 0.0534 0.0144 0.0679 795.9005795.9005 0.0500 797.1498 Worker 0.3393 0.2281 3.0661 8.6200e-
003

0.8383 6.3600e-
003

0.8447 0.2223 5.8600e-
003

0.2282 858.3131858.3131 0.0247 858.9300
Total 0.8177 16.9981 6.5221 0.0552 1.9053 0.0657 1.9710 0.5173 0.0626 0.5799 5,882.746 1 5,882.746
1 0.3584 5,891.706
2 Mitigated Construction Off-Site

3.5 Foundation - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.8617 8.8523 7.3875 0.0114 0.5224 0.5224 0.4806 0.4806 1,102.978 1 1,102.978
1 0.3567 1,111.896
2 Total 0.8617 8.8523 7.3875 0.0114 0.5224 0.5224 0.4806 0.4806 1,102.978 1 1,102.978
1 0.3567 1,111.896
2 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 15 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer

3.5 Foundation - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0952 3.0431 0.7246 7.4600e-
003

0.1856 0.0151 0.2007 0.0534 0.0144 0.0679 795.9005795.9005 0.0500 797.1498 Worker 0.3393 0.2281 3.0661 8.6200e-
003

0.8383 6.3600e-
003

0.8447 0.2223 5.8600e-
003

0.2282 858.3131858.3131 0.0247 858.9300
Total 0.4346 3.2712 3.7908 0.0161 1.0239 0.0214 1.0454 0.2758 0.0203 0.2960 1,654.213 6 1,654.213
6 0.0747 1,656.079
8 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.1397 0.6052 7.7261 0.0114 0.0186 0.0186 0.0186 0.0186 0.0000 1,102.978 1 1,102.978
1 0.3567 1,111.896
2 Total 0.1397 0.6052 7.7261 0.0114 0.0186 0.0186 0.0186 0.0186 0.0000 1,102.978 1 1,102.978
1 0.3567 1,111.896
2 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 16 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer

0.1856 0.0151 0.2007 0.0534 0.0144 0.0679 795.9005795.9005 0.0500 797.1498 Worker 0.3393 0.2281 3.0661 8.6200e-
003

0.8383 6.3600e-
003

0.8447 0.2223 5.8600e-
003

0.2282 858.3131858.3131 0.0247 858.9300
Total 0.4346 3.2712 3.7908 0.0161 1.0239 0.0214 1.0454 0.2758 0.0203 0.2960 1,654.213 6 1,654.213
6 0.0747 1,656.079
8 Mitigated Construction Off-Site

3.5 Foundation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.7750 7.9850 7.2637 0.0114 0.4475 0.4475 0.4117 0.4117 1,103.215 8 1,103.215
8 0.3568 1,112.135
8 Total 0.7750 7.9850 7.2637 0.0114 0.4475 0.4475 0.4117 0.4117 1,103.215 8 1,103.215
8 0.3568 1,112.135
8 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 17 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer

3.5 Foundation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0807 2.7659 0.6564 7.4000e-
003

0.1856 5.5700e-
003

0.1912 0.0534 5.3300e-
003

0.0588 790.0716790.0716 0.0478 791.2664
Worker 0.3166 0.2053 2.8254 8.3400e-
003

0.8383 6.1700e-
003

0.8445 0.2223 5.6800e-
003

0.2280 830.5525830.5525 0.0223 831.1109
Total 0.3973 2.9712 3.4818 0.0157 1.0239 0.0117 1.0357 0.2758 0.0110 0.2868 1,620.624 0 1,620.624
0 0.0701 1,622.377
2 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.1397 0.6052 7.7261 0.0114 0.0186 0.0186 0.0186 0.0186 0.0000 1,103.215 8 1,103.215
8 0.3568 1,112.135
8 Total 0.1397 0.6052 7.7261 0.0114 0.0186 0.0186 0.0186 0.0186 0.0000 1,103.215 8 1,103.215
8 0.3568 1,112.135
8 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 18 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer

0.1856 5.5700e-
003

0.1912 0.0534 5.3300e-
003

0.0588 790.0716790.0716 0.0478 791.2664
Worker 0.3166 0.2053 2.8254 8.3400e-
003

0.8383 6.1700e-
003

0.8445 0.2223 5.6800e-
003

0.2280 830.5525830.5525 0.0223 831.1109
Total 0.3973 2.9712 3.4818 0.0157 1.0239 0.0117 1.0357 0.2758 0.0110 0.2868 1,620.624 0 1,620.624
0 0.0701 1,622.377
2 Mitigated Construction Off-Site

3.6 Continuous Concrete Pour - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.7750 7.9850 7.2637 0.0114 0.4475 0.4475 0.4117 0.4117 1,103.215 8 1,103.215
8 0.3568 1,112.135
8 Total 0.7750 7.9850 7.2637 0.0114 0.4475 0.4475 0.4117 0.4117 1,103.215 8 1,103.215
8 0.3568 1,112.135
8 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 19 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer

3.6 Continuous Concrete Pour - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0807 2.7659 0.6564 7.4000e-
003

0.1856 5.5700e-
003

0.1912 0.0534 5.3300e-
003

0.0588 790.0716790.0716 0.0478 791.2664
Worker 0.3166 0.2053 2.8254 8.3400e-
003

0.8383 6.1700e-
003

0.8445 0.2223 5.6800e-
003

0.2280 830.5525830.5525 0.0223 831.1109
Total 0.3973 2.9712 3.4818 0.0157 1.0239 0.0117 1.0357 0.2758 0.0110 0.2868 1,620.624 0 1,620.624
0 0.0701 1,622.377
2 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.1397 0.6052 7.7261 0.0114 0.0186 0.0186 0.0186 0.0186 0.0000 1,103.215 8 1,103.215
8 0.3568 1,112.135
8 Total 0.1397 0.6052 7.7261 0.0114 0.0186 0.0186 0.0186 0.0186 0.0000 1,103.215 8 1,103.215
8 0.3568 1,112.135
8 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 20 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer

3.6 Continuous Concrete Pour - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0807 2.7659 0.6564 7.4000e-
003

0.1856 5.5700e-
003

0.1912 0.0534 5.3300e-
003

0.0588 790.0716790.0716 0.0478 791.2664
Worker 0.3166 0.2053 2.8254 8.3400e-
003

0.8383 6.1700e-
003

0.8445 0.2223 5.6800e-
003

0.2280 830.5525830.5525 0.0223 831.1109
Total 0.3973 2.9712 3.4818 0.0157 1.0239 0.0117 1.0357 0.2758 0.0110 0.2868 1,620.624 0 1,620.624
0 0.0701 1,622.377
2 Mitigated Construction Off-Site

3.7 Paving - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.7214 6.7178 7.0899 0.0113 0.3534 0.3534 0.3286 0.3286 1,035.342 5 1,035.342
5 0.3016 1,042.881
8 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.7214 6.7178 7.0899 0.0113 0.3534 0.3534 0.3286 0.3286 1,035.342 5 1,035.342
5 0.3016 1,042.881
8 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 21 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer

3.7 Paving - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0760 0.0493 0.6781 2.0000e-
003

0.2012 1.4800e-
003

0.2027 0.0534 1.3600e-
003

0.0547 199.3326199.33265.3600e-
003
199.4666
Total 0.0760 0.0493 0.6781 2.0000e-
003

0.2012 1.4800e-
003

0.2027 0.0534 1.3600e-
003

0.0547 199.3326199.33265.3600e-
003
199.4666
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.1119 0.4851 6.9028 0.0113 0.0149 0.0149 0.0149 0.0149 0.0000 1,035.342 5 1,035.342
5 0.3016 1,042.881
8 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.1119 0.4851 6.9028 0.0113 0.0149 0.0149 0.0149 0.0149 0.0000 1,035.342 5 1,035.342
5 0.3016 1,042.881
8 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 22 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer

0.2012 1.4800e-
003

0.2027 0.0534 1.3600e-
003

0.0547 199.3326199.33265.3600e-
003
199.4666
Total 0.0760 0.0493 0.6781 2.0000e-
003

0.2012 1.4800e-
003

0.2027 0.0534 1.3600e-
003

0.0547 199.3326199.33265.3600e-
003
199.4666
Mitigated Construction Off-Site

0.0941 0.0941 0.0941 0.0941 281.4481281.4481 0.0193 281.9309 Total 229.5383 1.5268 1.8176 2.9700e-
003

0.0941 0.0941 0.0941 0.0941 281.4481281.4481 0.0193 281.9309 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 23 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer

3.8 Architectural Coating - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0633 0.0411 0.5651 1.6700e-
003

0.1677 1.2300e-
003

0.1689 0.0445 1.1400e-
003

0.0456 166.1105166.11054.4700e-
003
166.2222
Total 0.0633 0.0411 0.5651 1.6700e-
003

0.1677 1.2300e-
003

0.1689 0.0445 1.1400e-
003

3.9600e-
003

0.0000 281.4481281.4481 0.0193 281.9309
Total 229.3491 0.1288 1.8324 2.9700e-
003

3.9600e-
003

0.0000 281.4481281.4481 0.0193 281.9309
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 24 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer

4.0 Operational Detail - Mobile

4.1 Mitigation Measures Mobile

0.1677 1.2300e-
003

0.1689 0.0445 1.1400e-
003

0.0456 166.1105166.11054.4700e-
003
166.2222
Total 0.0633 0.0411 0.5651 1.6700e-
003

0.1677 1.2300e-
003

0.1689 0.0445 1.1400e-
003

0.0456 166.1105166.11054.4700e-
003
166.2222
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 25 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 2.6194 12.6894 28.7558 0.1046 8.3224 0.0806 8.4030 2.2268 0.0751 2.3019 10,658.92 30 10,658.92
30 0.5222 10,671.97
71 Unmitigated 2.6194 12.6894 28.7558 0.1046 8.3224 0.0806 8.4030 2.2268 0.0751 2.3019 10,658.92 30 10,658.92
30 0.5222 10,671.97
71 4.2 Trip Summary Information

4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Enclosed Parking with Elevator 0.00 0.00 0.00
Health Club 23.05 14.61 18.71 45,395 45,395
Hotel 1,429.75 1,433.25 1041.25 3,280,389 3,280,389
Quality Restaurant 297.73 312.33 238.85 414,857 414,857 Total 1,750.54 1,760.19 1,298.81 3,740,641 3,740,641
Miles Trip % Trip Purpose %
Land Use H-W or C-WH-S or C-CH-O or C-NWH-W or C-WH-S or C-CH-O or C-NW Primary Diverted Pass-by Enclosed Parking with Elevator 16.60 8.40 6.90 0.00 0.00 0.00 0 0 0 Health Club 16.60 8.40 6.90 16.90 64.10 19.00 52 39 9
Hotel 16.60 8.40 6.90 19.40 61.60 19.00 58 38 4
Quality Restaurant 16.60 8.40 6.90 12.00 69.00 19.00 38 18 44

4.4 Fleet Mix
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 26 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer

5.0 Energy Detail
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
NaturalGas
Mitigated

0.1066 0.9687 0.8137 5.8100e-
003

0.0736 0.0736 0.0736 0.0736 1,162.451
6 1,162.451
6 0.0223 0.0213 1,169.359
5 NaturalGas
Unmitigated

0.1066 0.9687 0.8137 5.8100e-
003

0.0736 0.0736 0.0736 0.0736 1,162.451
6 1,162.451
6 0.0223 0.0213 1,169.359
5 5.1 Mitigation Measures Energy
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH Enclosed Parking with Elevator 0.5495590.0428930.2015640.1185330.0155690.0058460.0213940.0342550.0020990.0018280.0048550.0007090.000896 Health Club 0.5495590.0428930.2015640.1185330.0155690.0058460.0213940.0342550.0020990.0018280.0048550.0007090.000896 Hotel 0.5495590.0428930.2015640.1185330.0155690.0058460.0213940.0342550.0020990.0018280.0048550.0007090.000896 Quality Restaurant 0.5495590.0428930.2015640.1185330.0155690.0058460.0213940.0342550.0020990.0018280.0048550.0007090.000896 Historical Energy Use: N
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 27 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer

5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Enclosed Parking
with Elevator
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Health Club 34.7123 3.7000e-
004

3.4000e-
003

2.8600e-
003

2.0000e-
005

2.6000e-
004

4.0838 4.0838 8.0000e-
005

7.0000e-
005

4.1081
Hotel 7751.58 0.0836 0.7600 0.6384 4.5600e-
003

0.0578 0.0578 0.0578 0.0578 911.9511911.9511 0.0175 0.0167 917.3704 Quality
Restaurant
2094.54 0.0226 0.2054 0.1725 1.2300e-
003

0.0156 0.0156 0.0156 0.0156 246.4167246.41674.7200e-
003

4.5200e-
003
247.8811
Total 0.1066 0.9687 0.8137 5.8100e-
003

0.0736 0.0736 0.0736 0.0736 1,162.451
6 1,162.451
6 0.0223 0.0213 1,169.359
5 Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 28 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer

6.1 Mitigation Measures Area

6.0 Area Detail

5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Enclosed Parking
with Elevator
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Health Club 0.03471233.7000e-
004

3.4000e-
003

2.8600e-
003

2.0000e-
005

2.6000e-
004

4.0838 4.0838 8.0000e-
005

7.0000e-
005

4.1081
Hotel 7.75158 0.0836 0.7600 0.6384 4.5600e-
003

0.0578 0.0578 0.0578 0.0578 911.9511911.9511 0.0175 0.0167 917.3704 Quality
Restaurant

2.09454 0.0226 0.2054 0.1725 1.2300e-
003

0.0156 0.0156 0.0156 0.0156 246.4167246.41674.7200e-
003

4.5200e-
003
247.8811
Total 0.1066 0.9687 0.8137 5.8100e-
003

0.0736 0.0736 0.0736 0.0736 1,162.451
6 1,162.451
6 0.0223 0.0213 1,169.359
5 Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 29 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2NBio- CO2Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 2.7527 3.0000e-
004

0.0324 0.0000 1.2000e-
004

1.2000e-
004

0.0694 0.0694 1.8000e-
004

0.0740
Unmitigated 2.7527 3.0000e-
004

0.0324 0.0000 1.2000e-
004

1.2000e-
004

0.0694 0.0694 1.8000e-
004

0.0740

0.3141 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products

2.4355 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 3.0100e-
003

3.0000e-
004

0.0324 0.0000 1.2000e-
004

1.2000e-
004

0.0694 0.0694 1.8000e-
004

0.0740
Total 2.7527 3.0000e-
004

0.0324 0.0000 1.2000e-
004

1.2000e-
004

0.0694 0.0694 1.8000e-
004

0.0740
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 30 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer

8.1 Mitigation Measures Waste

7.1 Mitigation Measures Water

7.0 Water Detail

8.0 Waste Detail

0.3141 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products

2.4355 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 3.0100e-
003

3.0000e-
004

0.0324 0.0000 1.2000e-
004

1.2000e-
004

0.0694 0.0694 1.8000e-
004

0.0740
Total 2.7527 3.0000e-
004

0.0324 0.0000 1.2000e-
004

1.2000e-
004

0.0694 0.0694 1.8000e-
004

0.0740
Mitigated

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

10.0 Stationary Equipment
Fire Pumps and Emergency Generators
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 31 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer

11.0 Vegetation
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment
Equipment Type Number
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:16 PMPage 32 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Summer

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
11 Wind Speed (m/s) Precipitation Freq (Days)2.2 31

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company Southern California Edison
2022Operational Year
CO2 Intensity
(lb/MWhr)
702.44 0.029CH4 Intensity
(lb/MWhr)

0.006N2O Intensity
(lb/MWhr)
11469 Jefferson - Construction
South Coast AQMD Air District, Winter
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:19 PMPage 1 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Winter Project Characteristics - Consistent with the IS/MND's model.

Land Use - See SWAPE comment regarding parking and failure to model all proposed land uses.

Trips and VMT - See SWAPE comment regarding worker, vendor, and hauling trips.

Demolition -
Grading - See SWAPE comment regarding material export.

Construction Off-road Equipment Mitigation - Consistent with the DEIR's model.

CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:19 PMPage 2 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Winter Table Name Column Name Default Value New Value
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 4.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 3.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 6.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 11.00 tblConstEquipMitigation Tier No Change Tier 4 Final
tblConstEquipMitigation Tier No Change Tier 4 Final
tblConstEquipMitigation Tier No Change Tier 4 Final
tblConstEquipMitigation Tier No Change Tier 4 Final
tblConstEquipMitigation Tier No Change Tier 4 Final
tblConstEquipMitigation Tier No Change Tier 4 Final
tblConstEquipMitigation Tier No Change Tier 4 Final
tblConstEquipMitigation Tier No Change Tier 4 Final
tblConstEquipMitigation Tier No Change Tier 4 Final
tblGrading MaterialExported 0.00 43,836.00
tblLandUse LandUseSquareFeet 55,200.00 56,300.00
tblLandUse LandUseSquareFeet 254,100.00 117,987.00
tblLandUse LandUseSquareFeet 3,310.00 3,313.00
tblLandUse LotAcreage 1.24 0.28
tblLandUse LotAcreage 5.83 0.50
tblTripsAndVMT HaulingTripNumber 0.00 5,044.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/16/2021 1:19 PMPage 3 of 32 11469 Jefferson - Construction - South Coast AQMD Air District, Winter

City Council Meeting AgendaFebruary 9, 2026

City Council Meeting Agenda
February 9, 2026