Agenda packet, first session — Glendale City Council, August 12, 2025 (part 4 of 4)

The purpose of this document is to create a streamlined process for future analysis that is consistent with the CAAP in accordance with the above statutes. Future projects may utilize the CAAP to determine whether the project is consistent with its goals and policies and thereafter adopt mitigation strategies identified in the plan to address any potential significant impacts and confirm compliance. As discussed throughout this analysis, implementation of certain CAAP actions may require additional CEQA review once project specifications, such as site location, are identified and potential environmental impacts would be determined on a case-by-case basis.

Other Public Agencies
The City of Glendale has sole approval authority over the CAAP. There are no other public agencies whose approval is required.
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Draft Initial Study-Negative Declaration 49
Environmental Factors Potentially Affected
This project19 would potentially affect the environmental factors checked below, involving at least one impact that is “Potentially Significant” or “Less than Significant with Mitigation Incorporated” as indicated by the checklist on the following pages.
□ Aesthetics □ Agriculture and
Forestry Resources
□ Air Quality
□ Biological Resources □ Cultural Resources □ Energy
□ Geology and Soils □ Greenhouse Gas
Emissions
□ Hazards and Hazardous
Materials
□ Hydrology and Water
Quality
□ Land Use and Planning □ Mineral Resources
□ Noise □ Population/Housing □ Public Services
□ Recreation □ Transportation □ Tribal Cultural Resources □ Utilities/Service Systems □ Wildfire □ Mandatory Findings of Significance
Determination
Based on this initial evaluation:
■ I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.
□ I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions to the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.
□ I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.

19 Note that the CAAP is a plan; however, this language and the significance criteria questions language throughout this IS-ND are taken directly from CEQA Guidelines Appendix G, which refers to a “project” generally but is applicable to either a project or plan. 749 of 961

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50 □ I find that the proposed project MAY have a “potentially significant impact” or “less than significant with mitigation incorporated” impact on the environment, but at least one effect (1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and (2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed. □ I find that although the proposed project could have a significant effect on the environment, because all potential significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required.

Lead Agency Representative Signature Date

Lead Agency Representative Printed Name Title

David Jones
Sustainability Officer
March 15, 2025
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Environmental Checklist
1 Aesthetics

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
significant
Impact
No
Impact
Would the project:
a. Have a substantial adverse effect on a
scenic vista? □ □ ■ □
b. Substantially damage scenic resources,
including but not limited to, trees, rock
outcroppings, and historic buildings within
a State scenic highway? □ □ ■ □
c. In non-urbanized areas, substantially
degrade the existing visual character or
quality of public views of the site and its
surroundings? (Public views are those that
are experienced from a publicly accessible
vantage point). If the project is in an
urbanized area, would the project conflict
with applicable zoning and other
regulations governing scenic quality? □ □ ■ □
d. Create a new source of substantial light or
glare that would adversely affect daytime
or nighttime views in the area? □ □ ■ □
a. Would the project have a substantial adverse effect on a scenic vista? b. Would the project substantially damage scenic resources, including but not limited to, trees, rock outcroppings, and historic buildings within a State scenic highway? The City of Glendale’s General Plan, Open Space and Conservation Element identifies scenic resources within the City as the Verdugo Mountains, the San Rafael Hills, and the San Gabriel Mountains.20 Scenic vistas are primarily available from publicly accessible roadways including Interstate-5, Interstate-210, State Route (SR) 134 and SR-2.

There are no State-designated scenic highways that run through Glendale. The nearest designated State scenic highway to Glendale is SR-110 (i.e., Arroyo Seco Parkway connects Los Angeles and Pasadena), located approximately three miles southeast of Glendale, and is identified as a Federal Scenic Byway. Additionally, SR-210, which runs east to west through the northern portion of

20 Glendale, City of. 1993. Glendale General Plan: The Open Space and Conservation Plan. https://www.glendaleca.gov/home/showpublisheddocument/4565/635242151383400000 (accessed November 2024). 751 of 961

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52 Glendale, is eligible for designation as a State scenic highway. SR-2 is also eligible for designation within the unincorporated Los Angeles County community of La Crescenta-Montrose, just outside of the Glendale City limit, although within the Sphere of Influence.21 The City of Glendale is an urbanized City that is part of the greater Los Angeles metropolitan area.

While many of the major roadways that traverse Glendale offer views of nearby hills and ridgelines, with residential and commercial development in the foreground and middle ground, and long-range views toward the nearby mountains visible in the distance, the existing multi-story development and the mature landscape trees along the roadways already limit panoramic views of the natural landscape.

As a policy document, the CAAP would not result in direct impacts related to scenic highways.

However, implementation of some CAAP measures may promote infrastructure development and other physical changes through policies and programs. CAAP Measure SG-2 would establish three resilience centers within the City. CAAP Measure BLD-3 would require retrofitting of buildings in the City to be zero-carbon and resilient to extreme heat and wildfires. CAAP Measure MLS-1 would encourage increased residential densities along transit and commercial corridors in alignment with the Housing Element of the General Plan and State law mandate.22 Additionally, CAAP Measure MLS-1 would encourage increased active transportation modes. CAAP Measure MLS 2.14 and UE-3 encourage brush clearance along highways.

CAAP projects would generally be limited to the existing developed areas of the City and would be small-scale in nature. The CAAP itself will not create new residential development. The CAAP would be expected to support implementation of small-scale projects such as adding EV chargers, solar panels, and similar activities. Thus, the CAAP would promote infrastructure development and redevelopment that is complimentary to existing development and land uses. Though the implementation of the CAAP may result in future development, CAAP-related projects and actions, including those identified above, would be required to adhere to applicable City zoning and regulations, including the City’s applicable Design Guidelines and Objective Design Standards, which establish criteria for the aesthetic qualities of development in Glendale in order to preserve and enhance the desired character of existing neighborhoods.23 Compliance with the City’s Design Guidelines and Objective Design Standards, as applicable, would confirm that potential future infrastructure development and redevelopment related to the CAAP would be carefully integrated with the existing character of Glendale, minimizing potential aesthetic impacts. In addition, CAAP projects and actions would be reviewed for consistency with Glendale General Plan policies related to scenic resources prior to approval. As such, the CAAP would not result in adverse impacts related to scenic vistas or State scenic highways within the City. Therefore, the CAAP would result in less than significant impacts related to scenic vistas and scenic highways.

LESS THAN SIGNIFICANT IMPACT
c. Would the project in non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are

21 California Department of Transportation. 2024. California State Scenic Highway System Map. https://www.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e8057116f1aacaa (accessed October 2024). 22 Future Land Use Element amendments to the General Plan to further implement CAAP Measure MLS-1 would be considered as part of the environmental analysis completed at that time.
23 Glendale, City of. 2011. Comprehensive Design Guidelines. https://www.glendaleca.gov/home/showpublisheddocument/666/638531782517870000 (accessed November 2024). 752 of 961

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experienced from a publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality? Glendale is a primarily urbanized area with the following applicable visual character/quality policies in the Glendale General Plan Open Space and Conservation Element and Housing Element.

Open Space and Conservation Element
▪ Goal 2: Protect vital or sensitive open space areas including ridgelines, canyons, streams, geologic formations, watersheds and historic, cultural, aesthetic and ecologically significant areas from the negative impacts of development and urbanization. ▪ Goal 5: Preserve prominent ridgelines and slopes in order to protect Glendale's visual resources. ▪ Goal 7: Continue programs which enhance community design and protect environmental resource quality.24
Housing Element
▪ Goal 2: A City with high quality residential neighborhoods that are attractive and well designed. ▪ Policy 6.5: Require residential projects to preserve major ridgelines, secondary ridgelines, blue line streams, indigenous trees and other significant environmental features.25 In addition, the City has adopted Comprehensive Design Guidelines, which establish design review requirements to confirm that new development within Glendale is high-quality and complementary to the existing aesthetic character of the City.26 The City is also in the process of developing Objective Design Standards, which are anticipated to be adopted in 2025.

The CAAP would promote sustainable infrastructure development and redevelopment through measures and actions related to renewable energy, building energy use, transportation, water use, and solid waste. Implementation of some CAAP measures related to transportation, renewable energy, and residential density may result in physical changes that could impact the visual character of Glendale. Specifically, CAAP Measures BLD-1, BLD-4, and MLS-6 would encourage the addition of solar panels to rooftops and municipal properties to generate renewable energy in Glendale. CAAP Measure MLS-1 would encourage increased residential and mixed-use development along transit and commercial corridors, potentially resulting in increased building densities and heights along transit and commercial corridors in the City. CAAP Measures MLS-1, MLS-2, and MLS-3 would also encourage increased active transportation and public transit modes through new bicycle, pedestrian, and public transit facilities, such as, including but not limited to sidewalk improvements and bus stop shelter improvements throughout Glendale.

Increased residential and mixed-use densities along transit corridors, rooftop solar panels, and expanded active transportation and public transit facilities may slightly change the visual character of Glendale. However, future CAAP-related projects would be located and designed to be complimentary to existing land uses and would be required to adhere to the City zoning regulations,

24 Glendale, City of. 1993. General Plan Open Space and Conservation Element. https://www.glendaleca.gov/home/showpublisheddocument/4563/638532813084270000 (accessed November 2024). 25 Glendale, City of. 2023. General Plan Housing Element. https://www.glendaleca.gov/home/showpublisheddocument/70238/638140330782770000 (accessed November 2024). 26 Glendale, City of. 2011. Comprehensive Design Guidelines. https://www.glendaleca.gov/home/showpublisheddocument/666/638531782517870000 (accessed November 2024). 753 of 961

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54 General Plan policies, and Comprehensive Design Guidelines and Objective Design Standards, as applicable, that seek to preserve the character of Glendale and minimize aesthetic impacts. Future CAAP-related projects and actions would be reviewed for consistency with these policies prior to approval. Therefore, the CAAP would not conflict with applicable regulations governing scenic quality and impacts would be less than significant.

LESS THAN SIGNIFICANT IMPACT
d. Would the project create a new source of substantial light or glare that would adversely affect daytime or nighttime views in the area?
The CAAP would promote sustainable infrastructure development and redevelopment that is complimentary to existing land uses in the City. As a policy document, the CAAP would not directly result in impacts related to light and glare. CAAP Measure BLD-1 would promote installation of small-scale solar projects, such as rooftop solar panels, which could result in additional sources of glare in Glendale. However, solar panels are not subject to design review per the Glendale Municipal Code (GMC) Section 30.47.020 (G)(8). Additionally, Measure BLD-2, which includes an action related to amending the building code to require CALGreen Tier 2 Voluntary Standards Section A5.106.11.2 for cool roofs and Section A5.106.7.2 for cool walls, could result in additional sources of glare in Glendale.

Future installations of cool roofs in Glendale would be required to comply with Glendale Municipal Code (GMC), and all permitting conditions to limit aesthetic impacts. Future CAAP-related projects would also be reviewed for consistency with the CCR Title 24 roofing standards (CCR Title 24 Part 10), the Zoning Ordinance, and applicable Specific Plans and design guidelines, which includes a review of exterior lighting.27,28 Compliance with these regulations would minimize environmental impacts related to light and glare by implementing standard conditions of approval requiring the shielding of exterior lighting and limiting spillover lighting. Therefore, implementation of the CAAP would result in less than significant impacts related to light and glare.

LESS THAN SIGNIFICANT IMPACT
Cumulative Impacts
The cumulative projects scenario is the population, employment, and housing forecasts identified in the CAAP, based on demographic data contained in the SCAG RTP/SCS (refer to Table 6). Cumulative impacts related to scenic resources, visual character, and increased light and glare would generally be site-specific, and cumulative projects are not anticipated to contribute to cumulative aesthetic impacts with adherence to Glendale General Plan policies, the Zoning Ordinance, and applicable Specific Plans and design guidelines. Because of the developed nature of Glendale, future infrastructure projects under the CAAP, in combination with other cumulative projects that occur to accommodate Glendale’s anticipated population, employment, and housing growth, would not adversely impact the visual character of the Glendale community. In addition, future development in the City would be required to comply with the City’s Design Review process and be reviewed against applicable Glendale General Plan policies and the City’s design standards for design quality

27 California Energy Commission (CEC). 2022. 2022 Building Energy Efficiency Standards for Residential and Nonresidential Buildings. https://www.energy.ca.gov/sites/default/files/2022-12/CEC-400-2022-010_CMF.pdf (accessed November 2024). 28 Glendale, City of. 2011. Comprehensive Design Guidelines. https://www.glendaleca.gov/home/showpublisheddocument/666/638531782517870000 (accessed November 2024) 754 of 961

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Draft Initial Study-Negative Declaration 55
and compatibility with adjacent land uses. Therefore, implementation of the CAAP would result in a less than significant cumulative impact related to aesthetics. 755 of 961

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56 2 Agriculture and Forestry Resources

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
significant
Impact
No
Impact
Would the project:
a. Convert Prime Farmland, Unique Farmland,
or Farmland of Statewide Importance
(Farmland), as shown on maps prepared
pursuant to the Farmland Mapping and
Monitoring Program of the California
Resources Agency, to non-agricultural use? □ □ □ ■
b. Conflict with existing zoning for agricultural
use or a Williamson Act contract? □ □ □ ■
c. Conflict with existing zoning for, or cause
rezoning of, forest land (as defined in Public
Resources Code Section 12220(g));
timberland (as defined by Public Resources
Code Section 4526); or timberland zoned
Timberland Production (as defined by
Government Code Section 51104(g))? □ □ □ ■
d. Result in the loss of forest land or
conversion of forest land to non-forest use? □ □ □ ■
e. Involve other changes in the existing
environment which, due to their location or
nature, could result in conversion of
Farmland to non-agricultural use or
conversion of forest land to non-forest use? □ □ □ ■
a. Would the project convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? b. Would the project conflict with existing zoning for agricultural use or a Williamson Act contract? e.1. Would the project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use? Glendale is characterized primarily by urban and suburban development. The California Farmland Mapping and Monitoring Program classifies Glendale as Urban and Built-Up Land and Other Land.

There is no Prime Farmland, Unique Farmland, or Farmland of Statewide Importance in Glendale.29

29 California Department of Conservation. 2022. California Important Farmland Finder. https://maps.conservation.ca.gov/dlrp/ciff/ (accessed October 2024).
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Draft Initial Study-Negative Declaration 57
The CAAP would promote sustainable infrastructure development and redevelopment that is complimentary to existing land uses in the City. CAAP measures and actions would not involve projects or programs that would result in impacts related to conversion or loss of Farmland.

Therefore, the CAAP would not result in impacts related to degradation of agricultural resources or conversion of agricultural land to non-agriculture uses, nor would there be a conflict with existing zoning or Glendale General Plan land use designations.

NO IMPACT
c. Would the project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)); timberland (as defined by Public Resources Code Section 4526); or timberland zoned Timberland Production (as defined by Government Code Section 51104(g))?
d. Would the project result in the loss of forest land or conversion of forest land to non-forest use? e.2. Would the project involve other changes in the existing environment which, due to their location or nature, could result in conversion of forest land to non-forest use? Glendale contains open space areas such as the Verdugo Mountains Open Space Preserve in the northern portion of the City; the Deukmejian Wilderness Park at the northernmost City limits; San Rafael Hills in the east; and the City limits abut Griffith Park in the west. However, Glendale does not contain areas designated for forest land or Timberland Production. GMC Section 12.44, Indigenous Trees, establishes policies, regulations, and standards to protect indigenous oak, bay, and sycamore trees within Glendale.

The CAAP includes Measure UE-2 which encourages an increased tree canopy within the City. The CAAP does not include measures or actions that would conflict with City’s Tree Preservation regulations. Likewise, the CAAP does not include actions that would result in the loss of forest land or the conversion of forest land to non-forest use, nor would it conflict with or cause the rezoning of forest, timber land, or Timberland Production areas. Therefore, the CAAP would result in no impacts related to degradation of forestry resources or conversion of forest land to non-forest uses, nor would there be a conflict with existing zoning or General Plan land use designations.

NO IMPACT
Cumulative Impacts
The cumulative projects scenario is the population, employment, and housing forecasts identified in the CAAP, based on demographic data contained in the SCAG RTP/SCS (refer to Table 6). As the City’s population, employment, and housing grows and development intensifies in the future, CAAP Measure UE-2 would confirm that the urban forest is maintained and that additional trees are planted throughout the City. As discussed above, the CAAP would not include any measures or actions that would significantly impact agricultural or forest resources. In addition, the CAAP would not involve land use or zoning changes that could result in cumulative impacts related to conversion or loss of farmland or forest land. Therefore, implementation of the CAAP would result in no cumulative impact related to agricultural and forestry resources. 757 of 961

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58 3 Air Quality

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
significant
Impact
No
Impact
Would the project:
a. Conflict with or obstruct implementation of
the applicable air quality plan? □ □ □ ■
b. Result in a cumulatively considerable net
increase of any criteria pollutant for which
the project region is non-attainment under
an applicable federal or state ambient air
quality standard? □ □ ■ □
c. Expose sensitive receptors to substantial
pollutant concentrations? □ □ ■ □
d. Result in other emissions (such as those
leading to odors) adversely affecting a
substantial number of people? □ □ ■ □
a. Would the project conflict with or obstruct implementation of the applicable air quality plan? The Federal Clean Air Act (CAA) governs air quality in the United States and is administered by the United States Environmental Protection Agency (USEPA) at the Federal level. Air quality in California is also governed by regulations under the California CAA, which is administered by CARB at the State level. At the regional and local levels, local air districts typically administer the Federal and California CAA. As part of implementing the Federal and California CAA, the USEPA and CARB have established ambient air quality standards for major pollutants at thresholds intended to protect public health.

Glendale is located within the South Coast Air Basin (the Air Basin), which includes all of Orange County and the non-desert regions of Los Angeles County, Riverside County, and San Bernardino County. The Air Basin is under the jurisdiction of the South Coast Air Quality Management District (SCAQMD). As the local air quality management agency, SCAQMD is required to monitor air pollutant levels to confirm that State and Federal air quality standards are met and, if they are not met, to develop strategies to meet the standards. Depending on whether the standards are met or exceeded, the Air Basin is classified as being in “attainment” or “nonattainment.” Under State law, air districts are required to prepare a plan for air quality improvement for pollutants for which the district is in non-attainment. SCAQMD is in non-attainment for the State and Federal ozone standards and the State and Federal PM2.5 (particulate matter up to 2.5 microns in size) standards.

The SCAQMD Clean Air Plan (or 2022 Air Quality Management Plan [AQMP]) provides a blueprint for improving air quality and protecting public health, as well as reducing GHG emissions and the effects of climate change. The 2022 AQMP seeks to achieve multiple goals promoting reductions in criteria pollutant emissions, GHG emissions, and toxic risk, as well as efficiencies in energy use, transportation, and goods movement. A primary goal of the 2022 AQMP is to reduce pollutant concentrations below the National Ambient Air Quality Standards (NAAQS) through the 758 of 961

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Draft Initial Study-Negative Declaration 59
implementation of air pollutant emissions controls. The 2022 AQMP notes that the most effective way to reduce air pollution impacts is to reduce emissions from mobile sources, the principal contributor to air quality challenges in the Air Basin.30 A plan may be inconsistent with the 2022 AQMP if it would generate population, housing, or employment growth exceeding forecasts used in the development of the 2022 AQMP. The CAAP itself would not involve land use or zoning changes,31 and as addressed in Section 14, Population and Housing, would not generate additional housing, population, or jobs in Glendale. Rather, the CAAP would promote sustainable infrastructure development and redevelopment. Additionally, the recommended rezoning amendments in MLS-1.3 are being addressed as part of the Land Use Element Update. The CAAP measures and actions focus on decarbonization of buildings and sustainable development, increasing local renewable energy infrastructure, improving active transportation, zero emission vehicle and public transit infrastructure, and increasing the urban tree canopy. Implementation of CAAP measures, such as those aimed at reducing VMT, electrifying vehicles, and reducing natural gas use through building decarbonization, would have co-benefits to air quality within the Air Basin. These measures would help SCAQMD meet applicable air quality plan goals and would generally reduce air pollutant concentrations. Although the purpose and intended effect of the CAAP is to reduce GHG emissions generated in Glendale to help reduce the effects of climate change, many of its measures would also reduce criteria pollutant emissions.

CAAP Measures BLD-1, BLD-2, BLD-3, and BLD-4 involve increased energy efficiency and building decarbonization as part of residential, non-residential, and municipal land uses. In addition, CAAP Measures MLS-1, MLS-2, and MLS-3 seek to reduce VMT in the City by improving active transportation and public transit facilities. These energy- and transportation-related measures would reduce air pollutant emissions as well as GHG emissions. Therefore, the CAAP would be consistent with the 2022 AQMP and would have no impact related to a conflict with or obstruct the applicable air quality plan.

NO IMPACT
b. Would the project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or State ambient air quality standard (including releasing emissions that exceed quantitative thresholds for ozone precursors)?
The CAAP would not involve land use or zoning changes32 but would instead promote sustainable infrastructure development and redevelopment. As a policy document, the CAAP would not result in impacts related to criteria pollutants. However, future implementation of the some CAAP measures may promote construction activities that would temporarily generate criteria pollutants during the construction phase, as discussed below.

CAAP Measure BLD-1 would involve determining the feasibility of developing small-scale solar power and battery storage facilities, as well as electrical system improvements throughout the City to provide reliable renewable electricity sources. CAAP Measures BLD-3 and BLD-4 involve energy

30 SCAQMD. 2022. 2022 Air Quality Management Plan. https://www.aqmd.gov/docs/default-source/clean-air-plans/air-quality- management-plans/2022-air-quality-management-plan/final-2022-aqmp/final-2022-aqmp.pdf?sfvrsn=16 (accessed November 2024) 31 Future Land Use Element amendments to the General Plan to further implement CAAP Measure MLS-1 would be considered as part of the environmental analysis completed at that time.
32 Future Land Use Element amendments to the General Plan to further implement CAAP Measure MLS-1 would be considered as part of the environmental analysis completed at that time.
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60 efficiency and building decarbonization retrofits to existing residential, non-residential, and municipal buildings. In addition, CAAP Measures MLS-2 and MLS-3 seek to reduce VMT in the City by improving active transportation and public transit facilities, and Measures MLS-4 through MLS-6 recommend methods to facilitate a shift to EVs, zero-emission vehicles, and decarbonized off-road equipment by providing charging infrastructure. CAAP Measures UE-2 and UE-6 would increase tree canopy and replace non-functional turf within the City. CAAP Measure UE-5 would include methods to upgrade water and stormwater facilities for water conservation within the City. Future implementation of these measures would involve construction activities and the temporary generation of criteria pollutants.

Construction-related air quality impacts are generally associated with fugitive dust (PM10 and PM2.5) and exhaust emissions from heavy construction vehicles and soil hauling trucks, in addition to reactive organic gases that would be released during the drying phase upon application of architectural coatings. The CAAP does not require large-scale construction activities in its projections and any large-scale construction activities would require separate project-level environmental analysis and review. The project-level specifics of future CAAP implementation actions will need to be analyzed through the standard review process for new development or Capital Improvement Projects. CAAP projects or actions would also be subject to SCAQMD’s air quality regulations and best management practices, such as SCAQMD Rules 403 and 1113 for fugitive dust and reactive organic gases, and other applicable local, State, and Federal regulations.

Thus, the construction associated with implementation of the CAAP and compliance with regulatory requirements are anticipated to result in a less than significant impact related to criteria pollutants.

Air quality Impacts of each future implementing project will undergo individualized project-level CEQA review, as applicable. Potential environmental impacts would be determined on a case-by- case basis.

With respect to operational emissions, many of the CAAP actions would have the secondary benefit of reducing criteria pollutant emissions. As identified in the 2022 AQMP, reducing emissions from the transportation sector is a key component for meeting the air quality standards. CAAP measures such as Measures MLS-1 through MLS-6 that would reduce on- and off-road fossil fuel use and reduce VMT, result in a reduction of air pollutant emissions. Implementation of the CAAP would be beneficial by helping Glendale meet applicable air quality plan goals. Therefore, the CAAP would result in an overall less than significant impact related to criteria pollutant emissions.

LESS THAN SIGNIFICANT IMPACT
c. Would the project expose sensitive receptors to substantial pollutant concentrations? Implementation of the CAAP, as described under Response 3b., would promote infrastructure development and redevelopment that may result in temporary construction activities. Construction- related air quality impacts are generally associated with fugitive dust (PM10 and PM2.5) and exhaust emissions from heavy construction vehicles and soil hauling trucks, in addition to reactive organic gases that would be released during the drying phase upon application of architectural coatings.

However, the CAAP measures and actions do not include large-scale construction. While such construction-related emissions would be temporary, such construction related activities could result in emissions related impacts associated with construction.

While future projects could result in construction air quality impacts and exposure to sensitive receptors, CAAP projects or actions would be reviewed for consistency with SCAQMD air quality regulations, BMPs, and other applicable local, State, and Federal regulations through the standard development review process once specific project details and locations are known to assess project 760 of 961

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specific impacts and identify mitigation if required. No operational toxic air contaminant emissions are anticipated with approval of the CAAP. Implementation of the CAAP measures and actions would occur on a project-level basis and toxic air contaminant emissions would be analyzed on the individual project level basis. Therefore, the CAAP policies would have a less than significant impact related to exposure of sensitive receptors to toxic air contaminants because no specific development projects are included in the CAAP.

LESS THAN SIGNIFICANT IMPACT
d. Would the project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
The CARB 2005 Air Quality Land Use Handbook: A Community Health Perspective identifies land uses associated with odor complaints which include: sewage treatment plants, landfills, recycling facilities, waste transfer stations, petroleum refineries, biomass operations, auto body shops, coating operations, fiberglass manufacturing, foundries, rendering plants, and livestock operations.33
The CAAP includes Measures UE-1.7 and UE-1.8 which seek to increase organics diversion and the application of compost on appropriate lands, such as natural areas and parks. As such, implementation of the CAAP could result in minor odors related to organic waste diversion and compost application. It is anticipated that location of future compost application would be selected to be complimentary to existing development in the City and would be reviewed for site specific potential odor impacts to confirm that projects implemented in accordance with the CAAP would not adversely affect a substantial number of people. Therefore, the CAAP would not facilitate development that could create adverse odors because no specific development projects are included in the CAAP, and there would be less than significant impacts related to odors exposure.

LESS THAN SIGNIFICANT IMPACT
Cumulative Impacts
The cumulative projects scenario is the population, employment, and housing forecasts identified in the CAAP, based on demographic data contained in the SCAG RTP/SCS (refer to Table 6). Future CAAP-related projects, in combination with other cumulative projects that occur to accommodate Glendale’s anticipated population, employment, and housing growth, could result in air pollutant emissions that exceed applicable SCAQMD thresholds or be inconsistent with the 2022 AQMP.

However, implementation of the CAAP would have a less than significant contribution related to cumulative air quality impacts within the Air Basin and on sensitive receptors within Glendale, given that the CAAP would result in communitywide reduction of GHG emissions, energy use, single- occupancy vehicle travel, and associated air pollutant emissions. As such, implementation of the CAAP would not result in adverse impacts related to contribution of criteria pollutants to the air basin and exposure of sensitive receptors to toxic air contaminants and could result in co-benefits to air quality within the Air Basin for the reasons outlined in Response 3a above. Therefore, implementation of the CAAP would result in a less than significant cumulative impact related to air quality.

33 California Air Resources Control Board (CARB). 2005. Air Quality and Land Use Handbook: A Community Health Perspective. Available:
https://ww3.arb.ca.gov/ch/handbook.pdf (accessed October 2024). 761 of 961

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62 4 Biological Resources

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
significant
Impact
No
Impact
Would the project:
a. Have a substantial adverse effect, either
directly or through habitat modifications,
on any species identified as a candidate,
sensitive, or special status species in local
or regional plans, policies, or regulations, or
by the California Department of Fish and
Wildlife or U.S. Fish and Wildlife Service? □ □ ■ □
b. Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional
plans, policies, or regulations, or by the
California Department of Fish and Wildlife
or U.S. Fish and Wildlife Service? □ □ ■ □
c. Have a substantial adverse effect on state or
federally protected wetlands (including, but
not limited to, marsh, vernal pool, coastal,
etc.) through direct removal, filling,
hydrological interruption, or other means? □ □ ■ □
d. Interfere substantially with the movement
of any native resident or migratory fish or
wildlife species or with established native
resident or migratory wildlife corridors, or
impede the use of native wildlife nursery
sites? □ □ ■ □
e. Conflict with any local policies or
ordinances protecting biological resources,
such as a tree preservation policy or
ordinance? □ □ □ ■
f. Conflict with the provisions of an adopted
Habitat Conservation Plan, Natural
Community Conservation Plan, or other
approved local, regional, or State habitat
conservation plan? □ □ □ ■
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Draft Initial Study-Negative Declaration 63
a. Would the project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as candidate, sensitive, or special status in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service?
Glendale is a primarily urbanized community with both urban and suburban uses. Glendale contains open space areas such as the Verdugo Mountains Open Space Preserve in the northern portion of the City; the Deukmejian Wilderness Park at the northernmost City limits; San Rafael Hills in the east; and the City limits abut Griffith Park in the west. These areas could provide habitat for special- status species.
34 In addition, migratory and nesting birds protected by Sections 3503, 3503.5, and 3513 of the California Fish and Game Code (CFGC) and the Migratory Bird Treaty Act (MBTA) may utilize trees, landscaping, and structures throughout Glendale for nesting habitat. Special-status species are those plants and animals listed, proposed for listing, or candidates for listing as Threatened or Endangered by the United States Fish and Wildlife Service (USFWS) under the Federal Endangered Species Act. According to the USFWS Critical Habitat for Threatened & Endangered Species Map, there is no critical habitat within Glendale. The closest critical habitat to Glendale is north of the City limits and is identified as critical habitat for the Santa Ana sucker (Catostomus santaanae).35
The CAAP would not involve land use or zoning changes36 and would instead promote sustainable infrastructure development and redevelopment. CAAP measures and actions would generally apply to the urbanized areas of the City, with little application to parks, open spaces area, or the undeveloped portions of the City where sensitive habitat and related species may be present. The only CAAP measure which could affect the non-urbanized portions of Glendale is UE-3, which calls for vegetation management at the wildland urban interface zone and along roadways within the Very High Fire Hazard Severity Zone (VHFHSZ) to reduce wildfire risk (Action UE-3.6). The CAAP envisions vegetation management occurring through low-intensity grazing by cattle, horses, and/or goats, with monitoring occurring to protect native species and prevent invasive species growth, as described in CAAP Action UE-3.2. Vegetation management activities and future projects facilitated under the CAAP would be subject to the provisions of the various Federal and State natural resources regulations and their respective permitting processes for the protection of special status species and their habitat. In addition, CAAP Measure UE-2 calls for preservation of biodiversity and open space areas within the San Gabriel Mountains, Verdugo Mountains, and San Rafael Hills, as well as increased tree canopy throughout Glendale. Increased tree canopy and protected open space areas would provide additional habitat for special status species and migratory and nesting birds. As such, the CAAP would not have a substantial adverse effect on candidate, threatened, or endangered wildlife species either directly through individual take or indirectly through species habitat modification.

Implementation of some CAAP actions may promote infrastructure development within the urbanized portions of the City and could result in impacts to migratory and nesting birds protected under Sections 3503, 3503.5, and 3513 of the CFGC and under the MBTA through construction activities. CAAP Measures BLD-1, BLD-2, BLD-3, BLD-4 involve increased energy efficiency and

34 Glendale, City of. 1993. Glendale General Plan: The Open Space and Conservation Plan. https://www.glendaleca.gov/home/showpublisheddocument/4565/635242151383400000 (accessed November 2024). 35 United States Fish and Wildlife Service. 2022. Critical Habitat for Threatened & Endangered Species. https://ecos.fws.gov/ecp/report/table/critical-habitat.html (accessed November 2024) 36 Future Land Use Element amendments to the General Plan to further implement CAAP Measure MLS-1 would be considered as part of the environmental analysis completed at that time.
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64 building decarbonization as part of residential, non-residential, and municipal land uses. In addition, CAAP Measures MLS-1, MLS-2, and MLS-3 seek to reduce VMT in the City by improving active transportation and public transit facilities. CAAP Measure UE-2 would encourage an increased tree canopy within the City. CAAP Measure UE-5 would include upgrading water and stormwater facilities for water conservation within the City. These actions have the potential to disturb nesting habitat for protected birds and raptors. However, construction activities for future CAAP projects would be required to comply with the provisions of the MBTA and CFGC Sections 3503, 3503.5, and 3513 in order to avoid impacts to protected migratory and nesting birds and would be reviewed for consistency with City, State, and Federal policies related to protected species. As such, the CAAP would not have a substantial adverse effect on nesting and migratory birds. Therefore, the CAAP would result in an overall less than significant impact related to special-status wildlife species.

LESS THAN SIGNIFICANT IMPACT
b. Would the project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? c. Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
Riparian areas in Glendale primarily consist of Southern Oak Riparian habitat located in the northwestern portion of the City.37 There are also blue line streams and wetland areas in the undeveloped hillsides of the Verdugo Mountains, San Rafael Hills, and San Gabriel Mountains. In addition, the channelized Verdugo Wash runs through the urbanized area of the City just north of the Ventura Freeway.38
The CAAP would not involve land use or zoning changes39 but would instead promote and support sustainable infrastructure development and redevelopment within urbanized areas of the City. The CAAP measures would generally apply to the urbanized areas of the City, with little application to the open space areas of the Verdugo Mountains where riparian and wetland habitat is located.

Though future CAAP projects would be unlikely to occur in the vicinity of riparian or wetland areas, if development is proposed in areas identified as jurisdictional waters and/or wetlands, streambed/banks, or riparian vegetation, it would be subject to the permit requirements of the United States Army Corps of Engineers, Regional Water Quality Control Board, and California Department of Fish and Wildlife, pursuant to Section 404 and 401 of Clean Water Act, the Porter- Cologne Water Quality Control Act, and/or California Fish and Game Code Section 1600 et seq, as well as GMC 16.08.030 Blue Line Stream Preservation. The location and details of future CAAP projects would be reviewed for consistency with these regulations prior to approval. Therefore, the CAAP would not have a substantial adverse effect on riparian habitat, sensitive natural community, or wetlands, and impacts would be less than significant.

37 Glendale, City of. 1993. Glendale General Plan: The Open Space and Conservation Plan. https://www.glendaleca.gov/home/showpublisheddocument/4565/635242151383400000 (accessed November 2024). 38 United States Fish and Wildlife Service. 2024. National Wetlands Inventory Map. https://fwsprimary.wim.usgs.gov/wetlands/apps/wetlands-mapper/ (accessed November 2024). 39 Future Land Use Element amendments to the General Plan to further implement CAAP Measure MLS-1 would be considered as part of the environmental analysis completed at that time.
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Draft Initial Study-Negative Declaration 65

LESS THAN SIGNIFICANT IMPACT
d. Would the project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
The CAAP would not involve land use or zoning changes40 but would instead promote sustainable infrastructure development and redevelopment within urbanized portions of the City. The CAAP actions would generally apply to the urbanized areas of Glendale with little application to parks, open spaces, or other locations where wildlife corridors or native wildlife nursery sites may be present. Future CAAP projects would be required to adhere to City development regulations, the Glendale General Plan and the GMC, including GMC Chapter 12.44, Indigenous Trees, to retain urban forestry, and would be reviewed for consistency with applicable local, regional, and State regulations. In addition, CAAP Measure UE-2 calls for preservation of biodiversity and open space areas within the San Gabriel Mountains, Verdugo Mountains, and San Rafael Hills, as well as increased tree canopy throughout Glendale. This measure aligns with the Glendale General Plan Open Space and Conservation Element41 goals and would support the preservation of natural areas and urban landscape features that support migratory wildlife. Therefore, the CAAP would result in less than significant impacts related to interference with species movement or wildlife nursery use.

LESS THAN SIGNIFICANT IMPACT
e. Would the project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Glendale is a primarily urbanized community with parks and recreational spaces throughout the City. The Glendale General Plan Open Space and Conservation Element incorporates polices to protect biological resources such as plants, trees, wildlife habitats, and the species that utilize these habitats.42 In addition, GMC Chapter 12.44, Indigenous Trees, establishes the City’s tree preservation policy.

The CAAP would not involve land use or zoning changes43 but would promote sustainable infrastructure development and redevelopment within the urbanized portion of the City. The purpose and intended effect of the CAAP is to reduce GHG emissions generated in the City to help reduce the effects of climate change. The CAAP includes Measure UE-2 which calls for preservation of biodiversity and open space areas within the San Gabriel Mountains, Verdugo Mountains, and San Rafael Hills, as well as increased tree canopy throughout Glendale. Implementation of proposed CAAP actions would align with the General Plan Open Space and Conservation Element and would be beneficial by helping Glendale meet applicable local policies and ordinances for protecting biological resources, including the GMC Chapter 12.44, Indigenous Trees. As such, the CAAP would not conflict with or obstruct implementation of the applicable policies for preserving biological resources and would not affect the City’s ability to attain goals and policies that protect biological

40 Future Land Use Element amendments to the General Plan to further implement CAAP Measure MLS-1 would be considered as part of the environmental analysis completed at that time.
41 The City of Glendale’s Open Space and Conservation Element is currently being updated. 42 Glendale, City of. 1993. Open Space and Conservation Element: Implementation Plan. https://www.glendaleca.gov/home/showpublisheddocument/4567/638532813251870000 (accessed November 2024). 43 Future Land Use Element amendments to the General Plan to further implement CAAP Measure MLS-1 would be considered as part of the environmental analysis completed at that time.
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66 resources. Therefore, the CAAP would result in no impact related to consistency with local biological resources protection policies.

NO IMPACT
f. Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plan?
No portion of Glendale is currently subject to a Habitat Conservation Plan or Natural Community Conservation Plan.44 Therefore, the CAAP would have no impact related to consistency with an adopted habitat or natural community conservation plan.

Implementation of future CAAP-related projects, in combination with other cumulative projects that occur to accommodate Glendale’s anticipated population, employment, and housing growth, could result in impacts to biological resources during infrastructure and building construction. However, as described in Responses 4a. through 4f., above, infrastructure development or redevelopment resulting from implementation of the CAAP would be required to comply with applicable Glendale General Plan policies and State and Federal regulatory requirements regarding avoidance of special wildlife species and habitat. In addition, the CAAP would not result in new building construction and contains actions that prioritize the preservation of trees and improvements to existing habitat.

Therefore, implementation of the CAAP would result in a less than significant cumulative impact related to biological resources.

44 California Department of Fish and Wildlife (CDFW). 2024. Natural Community Conservation Plan Summaries. https://wildlife.ca.gov/Conservation/Planning/NCCP/Plans (accessed November 2024). 766 of 961

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Cultural Resources
Draft Initial Study-Negative Declaration 67
5 Cultural Resources

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
significant
Impact
No
Impact
Would the project:
a. Cause a substantial adverse change in the
significance of a historical resource
pursuant to §15064.5? □ □ ■ □
b. Cause a substantial adverse change in the
significance of an archaeological resource
pursuant to §15064.5? □ □ ■ □
c. Disturb any human remains, including
those interred outside of formal
cemeteries? □ □ ■ □
a. Would the project cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5?
The Glendale Register of Historic Resources identifies 150 historic properties listed as either Glendale Register, Historic District Contributor, California Landmark, or National Register.

The CAAP would not involve land use or zoning changes45 but would promote infrastructure development and redevelopment that would be complimentary to existing development. CAAP measures with the potential to affect historical resources include BLD-3 and BLD-4, which aim to decarbonize and fire-harden existing structures within Glendale, some of which may be historical resources. However, future retrofits to buildings would be required to comply with Glendale General Plan Historic Preservation Element goals and policies related to the preservation of historic resources, including Goal 1 which supports the preservation of historic resources in Glendale and Policy 1-6 which discourages the demolition of historic resources. Future CAAP-related projects would also be required to comply with GMC Chapter 15.20, Historic Preservation, which establishes requirements and procedures for projects that would affect resources that are historically or archaeologically significant in the cultural, architectural, archaeological, tribal, engineering, scientific, economic, agricultural, educational, social, political or military heritage of the City of Glendale.46 CAAP projects and actions would be reviewed for compliance with applicable local, regional, and State regulations regarding cultural resources, including the GMC and the Glendale General Plan Historic Preservation Element, to avoid adverse impacts related to historic resources.

Therefore, the CAAP would result in less than significant impacts related to historical resources.

LESS THAN SIGNIFICANT IMPACT

45 Future Land Use Element amendments to the General Plan to further implement CAAP Measure MLS-1 would be considered as part of the environmental analysis completed at that time.
46 Glendale, City of. 2024. Glendale Municipal Code Chapter 15.20, Historic Preservation. https://ecode360.com/43351129#43351141 (accessed November 2024).
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68 b. Would the project cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5?
There is a possibility for archaeological sites not previously recorded to be present in areas where future CAAP projects could occur. Future CAAP projects that would involve ground-disturbing activities, such as those related to carbon-free electricity and retrofits of existing buildings (BLD-1, BLD-3, and BLD-4), sustainable transportation infrastructure (MLS-2, MLS-3, MLS-4, and MLS-6), and urban trees, water efficiency, and green stormwater infrastructure (UE-2, UE-5, and UE-6), could result in construction that may expose previously undiscovered archaeological resources. Future CAAP projects would be located and designed strategically to reduce ground disturbance to the maximum extent possible. In addition, CAAP projects and actions would be reviewed for consistency with applicable local, regional, and State archeological regulations prior to final siting and construction, including GMC Chapter 15.20, Historic Preservation, and the General Plan Historic Preservation Element. Future CAAP projects would be required to implement BMPs if development would occur in an archaeologically sensitive area, consistent with Polices 1-4 and 1-5 of the General Plan Historic Preservation Element. These policies require archaeological surveys and/or monitoring to be conducted prior to the issuance of construction permits in archaeologically sensitive areas of the City and construction suspension when an archaeological site is discovered.47 As such, archeological resources would be protected prior to and/or upon discovery and, thus, impacts would be reduced to a minimal level. Therefore, the CAAP would result in less than significant impacts related to archaeological resources. For a discussion of impacts to archaeological resources of Tribal origin, refer to Section 18, Tribal Cultural Resources.

LESS THAN SIGNIFICANT IMPACT
c. Would the project disturb any human remains, including those interred outside of formal cemeteries?
There is a possibility of encountering unknown buried human remains throughout the City where future CAAP projects involving ground disturbing activities could occur. CAAP projects and actions would be required to comply with California Health and Safety Code Section 7050.5 and California Public Resources Code Section 5097.98 regulations related to burial findings, including notification, assessment, and treatment of burial sites. Therefore, the CAAP would result in less than significant impacts related to human remains.

Additionally, there is a possibility of encountering buried archaeological deposits, and human remains throughout the City. Impacts to historic and archaeological resources and human remains are generally site-specific. Accordingly, potential impacts associated with cumulative developments would be addressed on a case-by-case basis. In addition, future projects in the City, including those

47 Glendale, City of. 1997. General Plan Historic Preservation Element. https://www.glendaleca.gov/home/showpublisheddocument/833/638533600745770000 (accessed November 2024). 768 of 961

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Cultural Resources
Draft Initial Study-Negative Declaration 69
associated with implementation of the CAAP, would be required to comply with the City’s policies and programs that require the identification and protection of sites and structures of architectural, historical, archaeological, and cultural significance in order to avoid impacts related to cultural resources. Therefore, implementation of the CAAP would result in less than significant cumulative impacts related to cultural resources.
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70 6 Energy

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
significant
Impact No Impact
Would the project:
a. Result in a potentially significant
environmental impact due to wasteful,
inefficient, or unnecessary consumption
of energy resources, during project
construction or operation? □ □ □ ■
b. Conflict with or obstruct a state or local
plan for renewable energy or energy
efficiency? □ □ □ ■
a. Would the project result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
California is one of the lowest per-capita energy users in the United States, ranked 49th in the nation, due to its energy efficiency programs and mild climate.48 California consumed 281,140 gigawatt-hours (GWh) of electricity in 2023 and 11,710 million therms of natural gas in 2022.49,50 The single largest end-use sector for energy consumption in California is transportation (42.6 percent), followed by industrial (22.5 percent), residential (17.6 percent) and commercial (17.4 percent).51 The City of Glendale has demonstrated its commitment to energy efficiency and renewable energy through many efforts, as described in the Glendale Sustainability and Greenhouse Gas Emissions Reductions Efforts section above. The City has adopted several plans, including the Glendale Water and Power Strategic Plan, in an effort to increase energy efficiency. Additionally, the City is also in the process of converting their streetlights to energy-efficient light-emitting diode (LED) lights and maintains a Green Business Program to help businesses implement sustainable practices and become certified as a Green Business.

The CAAP is a policy document containing climate action measures to reduce communitywide GHG emissions. The CAAP would increase renewable energy production and provide a transition to renewable energy use through Measure BLD-1. The CAAP would encourage energy efficiency in the City’s existing and new development through new policies and educational campaigns through CAAP Measures BLD-2, BLD-3, and BLD-4. Additionally, the CAAP attempts to reduce transportation-

48 United States Energy Information Administration (USEIA). 2023. California - Profile Overview. May 16, 2024. https://www.eia.gov/state/?sid=CA (accessed October 2024). 49 California Energy Commission (CEC). 2024. 2023 Total System Electric Generation. https://www.energy.ca.gov/data-reports/energy- almanac/california-electriCity-data/2023-total-system-electric-generation (accessed November 2024) 50 California Energy Commission (CEC). 2024. Gas Consumption by County. http://www.ecdms.energy.ca.gov/gasbycounty.aspx (accessed October 2024).
51 United States Energy Information Administration (USEIA). 2023. California - Profile Overview. May 16, 2024. https://www.eia.gov/state/?sid=CA (accessed October 2024). 770 of 961

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Energy
Draft Initial Study-Negative Declaration 71
related energy consumption by increasing active transportation and public transit use and reducing VMT through Measures MLS-1, MLS-2, and MLS-3.

Implementation of some CAAP measures would require small-scale construction. No large-scale construction is anticipated. Energy use for the construction of such projects would be temporary in nature, and construction equipment used would be typical of similar-sized construction projects in the region. In addition, construction contractors would be required to comply with the provisions of CCR Title 13 Sections 2449 and 2485, which would minimize unnecessary fuel consumption.

Construction equipment would be subject to the USEPA Construction Equipment Fuel Efficiency Standard, which would also minimize inefficient, wasteful, or unnecessary fuel consumption.

Furthermore, per applicable regulatory requirements such as CALGreen, future infrastructure projects would comply with construction waste management practices to divert a minimum of 65 percent of construction and demolition debris. These practices would result in efficient use of energy necessary to construct CAAP-related projects. Upon completion of construction of CAAP- related infrastructure development and redevelopment, non-renewable energy use would be reduced, renewable energy production and storage would be increased, and transportation fuel use would be decreased within the City.

The purpose and intended effect of the CAAP is to reduce GHG emissions generated within Glendale to minimize the effects of climate change, including those emissions generated by energy demand and supply. The CAAP would not result in the use of non-renewable resources in a wasteful or inefficient manner. Therefore, the CAAP would result in no impacts related to the wasteful, inefficient, or unnecessary consumption of energy.

NO IMPACT
b. Would the project conflict with or obstruct a State or local plan for renewable energy or energy efficiency?
Relevant plans and policies that aim to increase energy efficiency and the production of renewable energy include SB 1020, CALGreen (Title 24 Part 11), and the California Building Energy Efficiency Standards (Title 24 Part 6). SB 1020 supports the reduction of GHG emissions from the electricity sector by accelerating the State’s RPS Program and requires electricity providers to increase procurement from eligible renewable energy resources to 90 percent of total retail sales by 2035, 95 percent by 2040, and 100 percent by 2045. CALGreen (Title 24 Part 11) institutes mandatory minimum environmental performance standards for all ground-up new construction of non- residential and residential structures. In addition, the California Building Energy Efficiency Standards (Title 24 Part 6) establishes energy-efficiency standards for residential and non-residential buildings in order to reduce California’s energy demand. CCR Title 24 (Parts 6 and 11) is updated periodically to incorporate and consider new energy-efficiency technologies and methodologies as they become available. New construction and major renovations must demonstrate their compliance with the current Building Energy Efficiency Standards through submission and approval of a Title 24 Compliance Report to the local building permit review authority and the CEC.

GWP provides electricity service within Glendale. Glendale would continue to reduce its use of nonrenewable energy resources as the electricity generated by renewable resources provided by GWP continues to increase to comply with State requirements through SB 1020. The CAAP also includes measures and actions to reduce energy use and increase production of renewable energy, as discussed under Response 6a., and would therefore align with the overall intent of SB 1020. In addition, construction and operation associated with infrastructure projects stemming from the CAAP would be designed to comply with the energy efficiency standards of CALGreen and the 771 of 961

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72 California Building Energy Efficiency Standards. Future CAAP projects would be required to demonstrate compliance with the CALGreen and California Building Energy Efficiency by implementing sustainability and energy efficiency measures such as high-efficiency lighting and HVAC systems, low-flow water fixtures, dual-paned windows, and water efficient landscaping and irrigation systems. Compliance with these regulations would minimize potential conflicts with adopted energy conservation plans. As discussed under Response 6a., above, the CAAP would not result in the inefficient or wasteful use of energy; rather, the CAAP would support greater energy efficiency. These actions are consistent with the goals and policies established by SB 1020, CALGreen, and the California Building Energy Efficiency Standards. Thus, the CAAP would not conflict with adopted renewable energy or energy conservation plans and there would be no impact.

Implementation of the CAAP would result in reduced use of non-renewable energy resources across the community, in particular with requirements for retrofitted and new buildings and new infrastructure. Implementation of the CAAP would also increase the production of renewable energy within the City by incentivizing the addition of small-scale solar projects in new development and existing municipal facilities. Additionally, the CAAP includes measures to increase the use of active transportation and public transit and reduce VMT within the City, which would reduce transportation fuel use. As the City’s population grows and development intensifies in the future, actions contained within the CAAP would confirm that planned new development is constructed to strict energy efficiency standards and that VMT is reduced. As the CAAP would result in decreased non-renewable energy use within the City and would align with existing plans and policies related to renewable energy and energy efficiency, implementation of the CAAP would result in no cumulative impacts related to energy.

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Geology and Soils
Draft Initial Study-Negative Declaration 73
7 Geology and Soils

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
significant
Impact
No
Impact
Would the project:
a. Expose people or structures to potentially
substantial adverse effects, including the
risk of loss, injury, or death involving:

1. Rupture of a known earthquake fault,
as delineated on the most recent
Alquist-Priolo Earthquake Fault Zoning
Map issued by the State Geologist for
the area or based on other substantial
evidence of a known fault? □ □ □ ■

2. Strong seismic ground shaking? □ □ □ ■

3. Seismic-related ground failure,
including liquefaction? □ □ □ ■

4. Landslides? □ □ □ ■
b. Result in substantial soil erosion or the loss
of topsoil? □ □ ■ □
c. Be located on a geologic unit or soil that is
unstable, or that would become unstable as
a result of the project, and potentially
result in on- or off-site landslide, lateral
spreading, subsidence, liquefaction, or
collapse? □ □ □ ■
d. Be located on expansive soil, as defined in
Table 1-B of the Uniform Building Code
(1994), creating substantial direct or
indirect risks to life or property? □ □ □ ■
e. Have soils incapable of adequately
supporting the use of septic tanks or
alternative wastewater disposal systems
where sewers are not available for the
disposal of wastewater? □ □ □ ■
f. Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature? □ □ ■ □
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74 a. Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving:

1. Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault?

2. Strong seismic ground shaking?

3. Seismic-related ground failure, including liquefaction?

4. Landslides?
Glendale is located in a seismic hazard zone and the Raymond Fault Zone crosses the southern portion of the City, there are also several fault zones within the vicinity of the City that could cause seismic-related impacts. The Raymond Fault Zone, delineated on the Alquist-Priolo Earthquake Fault Zoning Map, traverses Glendale southwest to southeast.52 The perimeter of the City of Glendale and the surrounding area is identified as a liquefaction hazard area and the Verdugo Mountains, San Rafael Hills and San Gabriela Mountains within the City contain landslide hazard zones.53 Although Glendale is at risk of earthquake-induced ground shaking and associated hazards, the CAAP is a policy document containing measures and policies to reduce GHG emissions and vulnerability to climate change. The CAAP does not propose habitable development or policies that could result in exposure of people to potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, strong seismic ground shaking, seismic-related ground failure including liquefaction, or landslides. Implementation of some CAAP measures could result in small scale construction activities, such as the addition of bicycle lanes and pedestrian infrastructure to existing roadways and fire hardening of utility infrastructure. Future projects implemented under the CAAP would be required to adhere to State and local seismic safety regulations including the Alquist-Priolo Earthquake Fault Zoning Act, Seismic Safety Act, Seismic Hazards Mapping Act, Uniform Building Code (UBC), CBC, and the Glendale Building and Safety Code. The CBC and UBC regulate the design and construction of excavations, foundations, building frames, retaining walls, and other building elements to mitigate the effects of seismic hazards and adverse soil conditions. In addition, the CAAP includes actions, such as Actions UE-3.10 and UE-3.11, to reduce community vulnerability to landslides. Therefore, the CAAP would result in no impact related to seismic- and landslide-related hazards.

NO IMPACT
b. Would the project result in substantial soil erosion or the loss of topsoil? The CAAP would not involve land use or zoning changes54 but would promote sustainable infrastructure development and redevelopment. As a policy document, the CAAP would not directly require ground-disturbing activities. However, implementation of some measures in the CAAP, including Measures BLD-1, BLD-3, BLD-4, MLS-2 through MLS-4, MLS-6, UE-2, UE-5, and UE-6, could

52 California Department of Conservation. 2021. Earthquake Hazards Zone Application. https://maps.conservation.ca.gov/cgs/EQZApp/app/ (Accessed November 2024) 53 California Department of Conservation. 2021. Earthquake Hazards Zone Application. https://maps.conservation.ca.gov/cgs/EQZApp/app/ (Accessed November 2024) 54 Future Land Use Element amendments to the General Plan to further implement CAAP Measure MLS-1 would be considered as part of the environmental analysis completed at that time.
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Geology and Soils
Draft Initial Study-Negative Declaration 75
result in small-scale construction activities that could cause soil erosion or the loss of topsoil during ground disturbance.

CAAP projects and actions would be reviewed for consistency with the GMC and other local and State erosion and grading regulations prior to final siting and construction. The potential for CAAP project construction activities involving soil disturbance to result in increased erosion and sediment transport by stormwater to surface waters would be minimized through compliance with GMC Chapter 13.42, which includes erosion and sediment control standards, and/or the National Pollutant Discharge Elimination System (NPDES) Construction General Permit provided by the Regional Water Quality Control Board. These regulations require BMPs such as the covering of graded slopes and stockpiled materials, storm drain protection, and use of fiber rolls and silt fences to reduce erosion and topsoil loss from stormwater runoff. Compliance with these regulations would confirm that BMPs are implemented during construction and that soil erosion, and the loss of topsoil are minimized. Therefore, the CAAP would result in less than significant impacts related to soil erosion and loss of topsoil.

LESS THAN SIGNIFICANT IMPACT
c. Would the project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse?
d. Would the project be located on expansive soil, as defined in Table 1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property? According to the California Department of Conservation, the perimeter and area surrounding Glendale is within a liquefaction hazard area.55 Most of Glendale is characterized by low to no potential for landslides, with the exception of the San Rafael Hills, Verdugo Mountains and San Gabriel Mountains. Expansive soils are known to be present in the southern portion of the City.56 The General Plan Safety Element, GMC, Glendale Building & Safety Code, and CBC contain regulations for structural design and soil hazards in order to mitigate potential impacts related to unstable soils.

The CAAP is a policy document containing measures and policies to reduce GHG emissions and vulnerability to climate change. The CAAP does not propose habitable development or policies that could result in exposure of people or properties to risks related to unstable soils and expansive soils.

Implementation of some CAAP measures could result in small scale construction activities, such as the addition of bicycle lanes and pedestrian infrastructure to existing roadways and fire hardening of utility infrastructure. Future projects implemented under the CAAP would be required to adhere to State and local regulations including the UBC, CBC, and the Glendale Building and Safety Code.

The CBC and UBC regulate the design and construction of excavations, foundations, building frames, retaining walls, and other building elements to mitigate the effects of adverse soil conditions, including soils susceptible to liquefaction, expansion, lateral spreading, landslides, and subsidence.

In addition, the CAAP includes actions, such as Actions UE-3.10 and UE-3.11, to reduce community vulnerability to landslides. Therefore, the CAAP would result in no impacts related to unstable or expansive soils.

55 California Department of Conservation. 2021. Earthquake Hazards Zone Application. https://maps.conservation.ca.gov/cgs/EQZApp/app/ (accessed November 2024). 56 Glendale, City of. 2003. Technical Background Report to the Safety Element of the General Plan. https://www.glendaleca.gov/home/showpublisheddocument/4545/638533600714730000 (accessed November 2024). 775 of 961

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76 NO IMPACT
e. Would the project have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater?
The CAAP would not involve new development that would require the use of septic systems or alternative wastewater disposal systems. Therefore, no impact would occur related to soil capability to support alternative wastewater disposal systems.

NO IMPACT
f. Would the project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
The CAAP would not involve land use or zoning changes,57 but would instead promote sustainable development and redevelopment. As a policy document, the CAAP would not directly result in impacts related to paleontological resources or unique geologic features. CAAP measures that could involve future construction activities, such as the policies related to building electrification, water pipeline leak repairs, and active transportation, would involve work within existing, previously graded, and disturbed areas where the likelihood of encountering intact and previously undiscovered paleontological resources would be minimal. CAAP projects would also generally occur within the developed, urban areas of Glendale and would be located and designed strategically to reduce ground disturbance to the maximum extent possible. Nonetheless, there is a possibility that these small-scale construction projects may expose paleontological resources during ground disturbing activities. To reduce such risks, CAAP projects and actions would be reviewed for consistency with geotechnical and paleontological regulations prior to final siting and construction.

CAAP projects would be required to minimize impacts to paleontological resources in accordance with California Public Resources Code Section 5097.5, which prohibits the excavation and destruction of paleontological resources and implementation of measures to address such impacts.

Additionally, CAAP projects would be required to comply with Glendale General Plan Open Space and Conservation Element Policy 3, which states that paleontological structures and sites should be recognized and maintained. In addition, future CAAP projects would be located and designed strategically to reduce ground disturbance to the maximum extent possible. Through compliance with these existing regulations and policies, the CAAP would result in less than significant impacts related to paleontological resources and unique geologic features.

LESS THAN SIGNIFICANT IMPACT
Cumulative Impacts
The cumulative projects scenario is the population, employment, and housing forecasts identified in the CAAP, based on demographic data contained in the SCAG RTP/SCS (refer to Table 6). Future CAAP-related projects, in combination with other cumulative projects that occur to accommodate Glendale’s anticipated population, employment, and housing growth, could expose additional people and property to the seismic and geologic hazards that are present in the region. The magnitude of geologic hazards for individual projects, including those associated with implementation of the CAAP, would depend upon the location, type, and size of development and

57 Future Land Use Element amendments to the General Plan to further implement CAAP Measure MLS-1 would be considered as part of the environmental analysis completed at that time.
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Geology and Soils
Draft Initial Study-Negative Declaration 77
the specific hazards associated with individual sites. Specific geologic hazards associated with individual project sites would be limited to those sites without affecting other areas. Similarly, potential impacts to paleontological resources associated with each individual site would be limited to that site without affecting other areas, and impacts related to these resources would be minimized on a case-by-case basis. Compliance with existing regulations, including CBC requirements, City-issued permit requirements, the Glendale General Plan, the GMC, and Glendale Building & Safety Code, would minimize potential cumulative seismic and geologic impacts. Seismic and geologic hazards and paleontological resources impacts would be addressed on a case-by-case basis and would not result in cumulative impacts. Therefore, implementation of the CAAP would result in a less than significant cumulative impact related to geology and soils. 777 of 961

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78 8 Greenhouse Gas Emissions

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
significant
Impact
No
Impact
Would the project:
a. Generate greenhouse gas emissions, either
directly or indirectly, that may have a
significant impact on the environment? □ □ ■ □
b. Conflict with any applicable plan, policy, or
regulation adopted to reduce the emissions
of greenhouse gases? □ □ □ ■
a. Would the project generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment?
The greenhouse effect is a natural occurrence that helps regulate the temperature of the Earth. The majority of radiation from the sun hits Earth’s surface and warms it. The surface in turn radiates heat back towards the atmosphere, known as infrared radiation. Gases and clouds in the atmosphere trap and prevent some of this heat from escaping into space and re-radiate it in all directions. This process is essential to support life on Earth because it warms the planet by approximately 60 degrees Fahrenheit. Emissions from human activities since the beginning of the industrial revolution (approximately 270 years ago) have been adding to the natural greenhouse effect by resulting in increased gases in the atmosphere that trap heat and contribute to an average increase in Earth’s temperature. Global warming is the observed increase in the average temperature of the Earth’s surface, and climate change is the resultant change in wind patterns, precipitation, and storms over an extended period. GHGs produced by human activities include CO2, methane (CH4), nitrous oxide (N2O), hydrofluorocarbons, perfluorinated compound, and sulfur hexafluoride.58 Combustion of fossil fuels (e.g., gasoline, natural gas, and coal), deforestation, and decomposition of waste release carbon into the atmosphere that had been locked underground and stored in oil, gas, and other hydrocarbon deposits or in the biomass of surface vegetation.

Changes to the land surface also indirectly affect the atmosphere by changing the way in which Earth absorbs gases from the atmosphere. Potential impacts in California due to climate change include sea level rise, more extreme-heat days and high-ozone days, larger and more frequent forest fires, and more frequent and severe drought years.59 Although GHG emissions do not typically cause direct health impacts at a local level, GHG emissions can result in indirect health impacts by

58 The CAAP only considers emissions of CO2, CH4, and N2O, because these are the GHGs most relevant to local government policymaking.

These gases comprise a large majority of GHG emissions at the community level. The remaining gases are emitted primarily in private sector manufacturing and electricity transmission and are the subject of regulation at the State level. Therefore, these gases were omitted from the CAAP.
59 CARB and California Environmental Protection Agency (CalEPA). 2009. Environmental Health and Equity Impacts from Climate Change and Mitigation Policies in California: A Review of the Literature. https://www.researchgate.net/profile/Seth_Shonkoff/publication/237420289_ENVIRONMENTAL_HEALTH_AND_EQUITY_IMPACTS_FRO M_CLIMATE_CHANGE_AND_MITIGATION_POLICIES_IN_CALIFORNIA_A_REVIEW_OF_THE_LITERATURE/links/0deec533acf69321ea000000 .pdf?__cf_chl_tk=sKBnx7aC9B6w7d8jIi4kX_zYtLPNC9Yatzlz4orNSy4-1732073843-1.0.1.1- Jg14BqFCMQljjlzVHfWYoQzREXNBnraeLcLaNneIgCg (accessed November 2024). 778 of 961

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Greenhouse Gas Emissions
Draft Initial Study-Negative Declaration 79
contributing to climate change, which can have public health implications. The primary public health impacts of climate change include the following: 60
▪ Increased incidences of hospitalization and deaths due to more extreme heat events; ▪ Increased incidences of health impacts related to ground-level ozone pollution due to increased average temperatures that facilitate ozone formation;
▪ Increased incidences of respiratory illnesses from wildfire smoke due to increased incidences of wildfires;
▪ Increased vector-borne diseases due to the growing extent of warm climates; and ▪ Increased stress and mental trauma due to extreme events and disasters, economic disruptions, and residential displacement.

Glendale has completed a communitywide GHG emissions inventory for 2021, which is summarized in Table 2. The on-road transportation sector was the largest contributor to Glendale’s GHG emissions, followed by the building energy use sector. Table 5 summarizes the communitywide GHG emissions forecast under three scenarios: 1) BAU, 2) BAU projections with State measures, and 3) the City of Glendale target reduction path along with State measures. As shown therein, under the BAU scenario, communitywide GHG emissions are forecasted to increase to approximately 1,086,686 MT of CO2e by the year 2030, based on anticipated economic and population growth.

However, with implementation of State laws and programs, communitywide GHG emissions would decline to approximately 932,917 MT of CO2e by 2030.

Implementation of the CAAP alongside State laws and programs would reduce communitywide GHG emissions to approximately 718,702 MT of CO2e by 2030 and 187,110 MT of CO2e by 2045. The measures included in the CAAP combined with State-wide legislation and initiatives and regional transportation programs would enable the City to meet its emissions reduction target of 40 percent below 1990 levels by 2030 (a maximum total annual emissions of 809,740 MT of CO2e). The City needs to achieve a GHG emissions reduction from 2030 BAU levels of 276,946 MT of CO2e to meet the SB 32 target. The estimated GHG reductions from 2030 BAU levels that would be achieved by the CAAP along with State-wide legislation and initiatives total 367,984 MT of CO2e by 2030 and would exceed the SB 32 requirements. Because SB 32 is considered an interim target toward meeting the 2045 State goal of carbon neutrality, implementation of the CAAP would also be considered substantial progress toward meeting the State’s long-term 2045 goal. Avoiding interference with and making substantial progress toward these long-term State targets are important because these targets have been set at levels that achieve California’s fair share of international emissions reduction targets that will stabilize global climate change effects and help avoid the associated adverse environmental consequences.

The CAAP includes a list of 21 measures intended to reduce communitywide GHG emissions and improve adaptive capacity. Implementation of the CAAP would result in the reduction of communitywide and per capita operational GHG emissions, while only generating temporary GHG emissions during construction of infrastructure such as building energy and water efficiency upgrades. Additionally, the CAAP would serve as a pathway to reduce GHG emissions and introduce other beneficial environmental and sustainability effects. The CAAP would result in benefits such as a reduction in building energy consumption, vehicle miles traveled (and thus air pollution), and solid

60 California Natural Resources Agency. 2018. California’s Fourth Climate Change Assessment Statewide Summary Report. http://www.climateassessment.ca.gov/state/ (accessed November 2024). 779 of 961

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Glendale Climate Action & Adaptation Plan

80 waste generation. Therefore, the CAAP would result in less than significant impact related to generation of GHG emissions.

LESS THAN SIGNIFICANT IMPACT
b. Would the project conflict with any applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
Applicable plans, policies, and regulations adopted for the purpose of reducing GHG emissions are described in the Existing Sustainability Setting, above. The primary plan for reducing GHG emissions in California is CARB’s 2022 Climate Change Scoping Plan. The 2022 Climate Change Scoping Plan outlines a pathway to achieving the SB 32 goal of reducing GHG emissions 40 percent below 1990 levels by 2030 and the 2045 carbon neutrality goal established by AB 1279.

The CAAP is a policy-level document that establishes measures and actions to reduce GHG emissions within Glendale in an effort to comply with State regulations. As discussed under Response 8a. above, the CAAP includes measures that would reduce Glendale GHG emissions from forecasted BAU levels to approximately 718,702 MT of CO2e by 2030 and 187,110 MT of CO2e by 2045. The purpose of the CAAP is to meet Glendale’s proportionate fair share of the Statewide GHG emissions reduction target set by SB 32 and work toward the State’s longer-term target of carbon neutrality identified by the 2022 Scoping Plan and AB 1279.

The CAAP would not conflict with any applicable GHG reduction plans. Rather, the CAAP identifies how Glendale would achieve consistency with the Statewide GHG emissions reduction goals. The CAAP would serve as a pathway to reduce GHG emissions and introduce other beneficial environmental and sustainability effects. These benefits include reduction in building energy consumption, VMT (and thus air pollution), water use, and solid waste generation. Therefore, the CAAP would result in no impacts related to consistency with applicable GHG emissions reduction plans, policies, and regulations.

NO IMPACT
Cumulative Impacts
The cumulative projects scenario is the population, employment, and housing forecasts identified in the CAAP, based on demographic data contained in the SCAG RTP/SCS (refer to Table 6). Analyses of GHG emissions and climate change are cumulative in nature, as they affect the accumulation of GHG emissions in the atmosphere. The CAAP creates a GHG emissions reduction strategy (consistent with Section 15183.5 of the CEQA Guidelines) for Glendale. The CAAP also includes a series of actions that are intended to reduce GHG emissions by approximately 40 percent below 1990 levels by 2030, which provides substantial progress toward Glendale meeting State goals. As such, the CAAP would result in the reduction of GHG emissions rather than generating GHG emissions. Some GHG emissions would occur during future construction of CAAP-related infrastructure projects; however, these emissions would be temporary and minor in nature. Furthermore, the CAAP includes measures to reduce vulnerability to the effects of climate change in Glendale. Therefore, implementation of the CAAP would result in no cumulative impacts related to GHG emissions. 780 of 961

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Hazards and Hazardous Materials
Draft Initial Study-Negative Declaration 81
9 Hazards and Hazardous Materials

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
significant
Impact
No
Impact
Would the project:
a. Create a significant hazard to the public or
the environment through the routine
transport, use, or disposal of hazardous
materials? □ □ ■ □
b. Create a significant hazard to the public or
the environment through reasonably
foreseeable upset and accident conditions
involving the release of hazardous
materials into the environment? □ □ ■ □
c. Emit hazardous emissions or handle
hazardous or acutely hazardous materials,
substances, or waste within 0.25 mile of an
existing or proposed school? □ □ ■ □
d. Be located on a site that is included on a list
of hazardous material sites compiled
pursuant to Government Code Section
65962.5 and, as a result, would it create a
significant hazard to the public or the
environment? □ □ ■ □
e. For a project located in an airport land use
plan or, where such a plan has not been
adopted, within two miles of a public
airport or public use airport, would the
project result in a safety hazard or
excessive noise for people residing or
working in the project area? □ □ □ ■
f. Impair implementation of or physically
interfere with an adopted emergency
response plan or emergency evacuation
plan? □ □ □ ■
g. Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury,
or death involving wildland fires? □ □ □ ■
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Glendale Climate Action & Adaptation Plan

82 a. Would the project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? b. Would the project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
The CAAP is a policy document containing measures and actions to reduce GHG emissions. The CAAP does not involve identified site-specific development and, for the most part, it would not facilitate new development that would involve the routine use of hazardous materials.

Implementation of some of the CAAP actions, such as energy and water efficiency retrofits and active transportation improvements, would require construction activities. Construction would involve the temporary use of hazardous materials such as vehicle fuels and fluids that could be released should an accidental leak or spill occur. However, these types of materials are not considered acutely hazardous, and storage, handling, and disposal of these materials are regulated by the California Department of Toxic Substances Control, the USEPA, and the Occupational Safety and Health Administration. In addition, standard construction BMPs for the use and handling of such materials would reduce the potential for such conditions to occur. Any use of potentially hazardous materials during construction of CAAP projects would comply with all local, State, and Federal regulations regarding the handling of potentially hazardous materials, including Title 49 of the Code of Federal Regulations, Title 22, Division 4.5 of the CCR, and the NPDES permitting program. The risk of spills would cease after construction is completed. Therefore, construction activities related to CAAP actions would not be anticipated to create upset and accident conditions involving the release of hazardous materials.

Operation of the majority of project types envisioned under the CAAP would not involve the routine transport, use, or disposal of hazardous materials during operation. However, CAAP Measure BLD-1 emphasizes increasing local renewable energy production and storage within the City by encouraging developments to include small-scale solar systems and battery storage in their design.

Lithium-ion batteries, the typical battery technology used in battery storage systems, may pose a risk of upset and accidental release of hazardous chemicals contained within the batteries (e.g., in the event of a fire). Lithium-ion technology is a common battery storage medium and with low likelihood of failure, particularly for small-scale systems such as those envisioned in the CAAP.

Battery storage failure rates have been estimated to be between 1 in 10 million to 1 in 40 million cells, and improvements in the technology and safety systems has resulted in decreased incidents of battery fires.61
During normal operation, lithium-ion batteries do not represent a risk to off-site receptors, and safety standards applicable to energy storage facilities and safety certification tests established by independent bodies, such as Underwriters Laboratories, National Fire Protection Association (NFPA), and International Electrotechnical Commission would prevent the reasonable possibility of a substantial adverse effect on the environment related to the lithium-ion batteries. However, in the unlikely event of a fire, there is a risk of the accidental release of hazardous materials associated with renewable energy systems. Any future proposed renewable energy systems would, therefore, be carefully reviewed for appropriate locations, safety measures, and consistency with the Glendale General Plan, GMC, and applicable local, State, and Federal regulations. Thus, establishment of such production and storage facilities would be subject to site specific review and approval by the

61 American Clean Power. 2024. Claims vs. Facts: Energy Storage Safety. https://cleanpower.org/resources/claims-vs-facts-energy- storage-leading-on-safety/ (accessed February 2024).
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Hazards and Hazardous Materials
Draft Initial Study-Negative Declaration 83
Glendale Fire Department, Hazardous Materials Division, and Building Division and would be required to comply with all applicable safety standards. Therefore, the CAAP would result in a less than significant impact related to creating a significant hazard through the routine transport, use, or disposal of hazardous materials and reasonably foreseeable upset and accident conditions involving the release of hazardous materials.

LESS THAN SIGNIFICANT IMPACT
c. Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within 0.25 mile of an existing or proposed school? Glendale contains a variety of public and private schools citywide, including 21 public grade schools, five public middle schools and six public high schools in the Glendale Unified School District. (See https://gusd.net/schools)
The CAAP is a policy document containing measures to reduce GHG emissions and does not include site-specific proposals and development. As addressed under Responses a. and b., above, implementation of some CAAP policies and actions may require future construction activities, such as building energy efficiency retrofits, active transportation infrastructure enhancements, and the addition of new green stormwater infrastructure. In addition, the CAAP would encourage the placement of small scale solar and battery storage systems to increase the production and use of renewable energy in Glendale. Construction activities and new battery storage systems related to the CAAP could result in hazardous emissions or the handling of hazardous materials within 0.25 mile of an existing or proposed school. However, future CAAP projects and actions would be reviewed to confirm the appropriate location of projects in relation to existing development, including schools, in the City. Projects proposed under the CAAP would also be subject to State and Federal regulations that apply to the use, storage, transport, and disposal of hazardous materials.

Through compliance with these regulations, the CAAP would result in a less than significant impact related to handling of hazardous materials in proximity to schools.

LESS THAN SIGNIFICANT IMPACT
d. Would the project be located on a site included on a list of hazardous material sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
The California Department of Toxic Substances Control’s EnviroStor database includes nine potentially contaminated sites within Glendale that are listed as active or in need of evaluation.62 The State Water Resources Control Board’s GeoTracker database includes 14 sites within Glendale that are listed as open clean-up sites.63
The CAAP is a policy document containing measures and supporting actions to reduce GHG emissions and increase adaptive capacity. The CAAP does not include site-specific proposals and development; however, there is the possibility that CAAP measures could result in future construction activities on listed hazardous materials sites compiled pursuant to Government Code Section 65962.5. Construction activities on previously contaminated sites could expose construction

62 Department of Toxic Substances Control. 2024. EnviroStor. https://www.envirostor.dtsc.ca.gov/public/map/?myaddress=glendale (accessed November 2024).
63 State Water Resources Control Board. 2024. GeoTracker. https://geotracker.waterboards.ca.gov/map/?CMD=runreport&myaddress=glendale+ca# (accessed November 2024). 783 of 961

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Glendale Climate Action & Adaptation Plan

84 workers and the public to hazardous materials. However, future CAAP projects, once identified, would be reviewed for potential issues related to existing site contamination in accordance with Glendale General Plan Safety Element Update, and would be required to comply with applicable local, State, and Federal regulations related to hazardous materials sites, including Glendale Fire Department, California Department of Toxic Substances Control, Regional Water Quality Control Board, and Occupational Safety and Health Administration. Future CAAP projects would require site- specific development review by the City and, if required, cleanup of contamination on a project-by- project basis for projects that would be located in areas that may contain hazardous materials contaminants. Through compliance with these existing policies and regulations, the CAAP would result in a less than significant impact related to location on a listed hazardous materials site.

LESS THAN SIGNIFICANT IMPACT
e. For a project located in an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area? The Hollywood Burbank Airport is located within two miles of the City of Glendale, in the neighboring City of Burbank. The CAAP is a policy document that establishes new policies and measures to address GHG emissions and climate change impacts to the City. The CAAP does not propose new development or specific changes to land use and zoning64. Thus, implementation of the CAAP would not result in construction or operational impacts related to airport hazards.

Furthermore, the CAAP would not increase airport activity or result in additional habitable development or commercial development that could increase potential exposure of residents and employees to aircraft-related hazards. CAAP-related projects that could occur within the influence area zones of the Hollywood Burbank Airport would be subject to the policies of the Los Angeles County Airport Land Use Compatibility Plan.65 Therefore, the CAAP would result in no impacts related to risks associated with location proximate to a public airport.

NO IMPACT
f. Would the project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
The CAAP is a policy document intended to reduce GHG emissions. The proposed CAAP does not involve site-specific development, nor would it facilitate new development that would interfere with adopted emergency plans. Implementation of some CAAP measures may involve construction within the local right-of-way. Construction activities have the potential to require lane closures and may impact traffic and vehicle speeds on the affected roadways; however, these impacts would be temporary and safe access to roadways would be maintained throughout project construction in accordance with the requirements of GMC Section 12.08.130, Protection of Public Travel and Safety Requirements. Furthermore, future projects involving work in the public right-of-way would be required to coordinate with the City through the street use permits, encroachment permit review and construction permitting processes to confirm appropriate construction staging and adequate

64 Future Land Use Element amendments to the General Plan to further implement CAAP Measure MLS-1 would be considered as part of the environmental analysis completed at that time.
65 Los Angeles, County of. 2004. Los Angeles County Airport Land Use Plan. https://planning.lacounty.gov/wp- content/uploads/2022/10/Los-Angeles-County-Airport-Land-Use-Plan.pdf (accessed November 2024) 784 of 961

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Hazards and Hazardous Materials
Draft Initial Study-Negative Declaration 85
vehicular and pedestrian access on adjacent roadways and that emergency evacuation routes would not be substantially impacted. Additionally, the CAAP includes measures and actions, such as Measure SG-1 and Action MLS-2.23, to improve emergency response and evacuation within the City.

Additionally, the Safety Element Update, which was prepared in parallel with the CAAP, also includes policies and programs to improve emergency response and evacuation within the City.

Therefore, the CAAP would result in no impacts related to impairment or interference with implementation of an emergency response or evacuation plan.

NO IMPACT
g. Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires?
The CAAP does not propose specific development or new residential or commercial land uses that could be subject to wildland fire, nor would it result in other physical changes to the environment that could increase the risk of a wildland fire. The CAAP recognizes the risk that wildfires pose to Glendale and the likelihood of these risks to be exacerbated by climate change. As such, the CAAP includes measures and actions to reduce wildfire risks and community vulnerability to wildfire and post-wildfire hazards and improve the ability of the Fire Department and community to evacuate and respond to wildfire occurrences. These include CAAP Measures SG-1, SG-2, SG-5, BLD-1, BLD-3, BLD-4, MLS-2, UE-3, and UE-5. Additionally, the Safety Element Update, which was prepared in parallel with the CAAP, also includes policies and programs to reduce wildfire risks and community vulnerability to wildfire and post-wildfire hazards and improve the ability of the Fire Department and community to evacuate and respond to wildfire occurrences, such as Policies 4.1 – 4.9.

Therefore, the CAAP would result in no impact related to risks associated with exposure to wildland fires.

NO IMPACT
Cumulative Impacts
The cumulative projects scenario is the population, employment, and housing forecasts identified in the CAAP, based on demographic data contained in the SCAG RTP/SCS (refer to Table 6). Hazards and hazardous materials impacts are typically site-specific in nature. Future CAAP-related projects, in combination with other cumulative projects that occur to accommodate Glendale’s anticipated population, employment, and housing growth, are not anticipated to contribute to cumulative hazards and hazardous materials impacts with adherence to applicable Glendale General Plan policies and Federal, State, and local regulatory requirements related to the handling, storage, use, disposal, and cleanup of hazardous materials. Additionally, implementation of the CAAP would reduce Glendale’s vulnerability to wildfire hazards. Therefore, implementation of the CAAP would result in a less than significant cumulative impact related to hazards and hazardous materials. 785 of 961

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Glendale Climate Action & Adaptation Plan

86 10 Hydrology and Water Quality

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
significant
Impact
No
Impact
Would the project:
a. Violate any water quality standards or
waste discharge requirements or otherwise
substantially degrade surface or
groundwater quality? □ □ ■ □
b. Substantially decrease groundwater
supplies or interfere substantially with
groundwater recharge such that the
project may impede sustainable
groundwater management of the basin? □ □ □ ■
c. Substantially alter the existing drainage
pattern of the site or area, including
through the alteration of the course of a
stream or river or through the addition of
impervious surfaces, in a manner which
would: □ □ □ ■
(i) Result in substantial erosion or siltation
on- or off-site; □ □ □ ■
(ii) Substantially increase the rate or
amount of surface runoff in a manner
which would result in flooding on- or
off-site; □ □ □ ■
(iii) Create or contribute runoff water
which would exceed the capacity of
existing or planned stormwater
drainage systems or provide
substantial additional sources of
polluted runoff; or □ □ □ ■
(iv) Impede or redirect flood flows? □ □ □ ■
d. In flood hazard, tsunami, or seiche zones,
risk release of pollutants due to project
inundation? □ □ ■ □
e. Conflict with or obstruct implementation of
a water quality control plan or sustainable
groundwater management plan? □ □ □ ■
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Hydrology and Water Quality
Draft Initial Study-Negative Declaration 87
a. Would the project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality? The CAAP is a policy document containing actions intended to reduce GHG emissions within Glendale. CAAP Measures BLD-1, BLD-2, BLD-3, BLD-4 involve increased energy efficiency and building decarbonization as part of residential, non-residential, and municipal land uses. In addition, CAAP Measures MLS-1, MLS-2, and MLS-3 seek to reduce VMT in the City by improving active transportation and public transit facilities. CAAP Measure UE-2 would encourage an increased tree canopy within the City. CAAP Measure UE-5 would include upgrading water and stormwater facilities for water conservation within the City. These actions may result in small scale construction activities in the future that could result in temporary water quality impacts due to soil erosion and ground disturbance, as previously discussed under Response 7c. in Section 7, Geology and Soils.

CAAP projects and actions would be reviewed for consistency with local and State regulations, including the NPDES permitting program that requires implementation of Stormwater Pollution Prevention Plans (SWPPPs), as applicable, and the GMC Chapter 13.42, Stormwater and Urban Runoff Pollution Prevention, that includes erosion and sediment control standards. These regulations require BMPs to reduce water quality impacts from construction activities. Compliance with the GMC Chapter 13.42 and/or NPDES permitting program would confirm that BMPs are implemented during construction to minimize potential impacts to surface and groundwater quality.

Additionally, CAAP Measures UE-2, UE-5, and UE-6 would increase green stormwater infrastructure, stormwater capture and groundwater recharge, the planting of urban trees, and development of new greenspaces. These measures would increase permeable surfaces throughout the City and improve water infiltration, water quality, and stormwater management. As such, the CAAP would result in less than significant impacts related to surface or groundwater water quality in Glendale.

LESS THAN SIGNIFICANT IMPACT
b. Would the project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
The CAAP would not result in new land uses, such as increased residential or commercial development, which would contribute to an increase in demand for groundwater. CAAP Measure UE-5 seeks to decrease community water use by promoting water efficiency retrofits, sustainable landscaping, increased recycled and greywater water use, and efficient landscaping irrigation. In addition, CAAP Measures UE-2, UE-5, and UE-6 would increase green stormwater infrastructure, stormwater capture and groundwater recharge, the planting of urban trees, and development of new greenspaces. These measures would increase permeable surfaces throughout the City and improve water infiltration and groundwater recharge. These measures would aid in maintaining groundwater supplies. Therefore, the CAAP would result in no impact related to the impedance of sustainable groundwater management.

NO IMPACT
c. Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
▪ Result in substantial erosion or siltation on- or off-site? 787 of 961

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88 ▪ Substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site?
▪ Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff? ▪ Impede or redirect flood flows?
Implementation of several CAAP measures may promote infrastructure development and small- scale construction activities within Glendale, such as measures related to active transportation, building retrofits, and water infrastructure improvements. Implementation of these CAAP actions would primarily occur within previously developed areas and would not result in substantial alterations to Glendale’s existing drainage patterns and amount of impervious surface. Construction of future CAAP projects could result in erosion, as discussed in Section 7, Geology and Soils.

However, impacts to drainage patterns, erosion, runoff, and water quality during construction of CAAP-related projects would be minimized through the implementation of BMPs as required by the GMC Chapter 13.42 and/or NPDES Construction General Permit program.

In addition, CAAP projects would be developed in accordance with the Glendale General Plan Open Space and Conservation Element, which includes Goal 6 and Objectives 6.2 through 6.6 for the protection and preservation of streams, watersheds, drainage, and groundwater within Glendale.

The CAAP includes Measures UE-2, UE-5, and UE-6, which would increase green stormwater infrastructure, stormwater capture and groundwater recharge, the planting of urban trees, and development of new greenspaces. These measures would improve drainage and water quality in Glendale and reduce surface water runoff and the potential for flooding during extreme rain events.

These measures are consistent with Goal 6 of the General Plan Open Space and Conservation Element. Therefore, the CAAP would result in no impact related to the alteration of existing drainage patterns.

NO IMPACT
d. Would the project result in flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
Glendale is located approximately 15 miles east of the Pacific Ocean. As such, the City is not within a coastal zone, or near a large body of water, where there would be risk of seiche. The City is identified as outside of the tsunami hazard area and is not located within a 100-year or 500-year floodplain.
6667
As described under Response 10c., CAAP projects would not impede or redirect flood flows. Rather, the CAAP includes Measures UE-2, UE-5, and UE-6 to improve stormwater management within the City. Additionally, as discussed under Responses 9a. and b. in Section 9, Hazards and Hazardous Materials, CAAP projects would generally not involve the regular use or storage of hazardous materials with the exception of renewable energy systems that include the storage of lithium-ion batteries. Future CAAP projects, such as renewable energy systems, would be reviewed for compliance with the applicable local and State regulations related to flooding and hazardous

66 California Department of Conservation. 2022. California Tsunami Maps: Los Angeles County. https://maps.conservation.ca.gov/cgs/informationwarehouse/ts_evacuation/ (accessed November 2024) 67 Federal Emergency Management Agency. 2008. Flood Map Service Center: Map 06037C1375F. Effective September 26. 2008. https://msc.fema.gov/portal/search?AddressQuery=Glendale%2C%20CA (accessed November 2024). 788 of 961

Environmental Checklist
Hydrology and Water Quality
Draft Initial Study-Negative Declaration 89
materials use and storage, including CBC standards. Therefore, the CAAP would result in less than significant impacts related to flooding and inundation resulting in release of pollutants.

LESS THAN SIGNIFICANT IMPACT
e. Would the project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
The CAAP measures would not include activities that would result in the extraction of groundwater.

Rather, the CAAP encourages reduced water consumption, expanded pervious surfaces, and increased groundwater recharge within Glendale, as discussed under Response 10a. The CAAP would not interfere with or obstruct implementation of water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality. Therefore, the CAAP would result in no impacts related to consistency with a water quality control plan or sustainable groundwater management plan.

NO IMPACT
Cumulative Impacts
The cumulative projects scenario is the population, employment, and housing forecasts identified in the CAAP, based on demographic data contained in the SCAG RTP/SCS (refer to Table 6). Future CAAP-related projects, in combination with other cumulative projects that occur to accommodate Glendale’s anticipated population, employment, and housing growth, are not anticipated to contribute to cumulative hydrology and water quality impacts with adherence to applicable Glendale General Plan policies and local, State, and Federal regulatory requirements including the GMC and NPDES. Implementation of the CAAP would not contribute to an increase in growth and development in Glendale but could result in small-scale infrastructure development and building retrofit projects, including energy and water efficiency upgrades and fire hardening. As such, implementation of the CAAP and other cumulative projects could have incremental impacts related to hydrology and water quality, such as erosion and sedimentation due to construction activities.

However, the CAAP’s contribution to such impacts would be minor and temporary, and the CAAP would have the long-term effect of reducing water use, improving sustainable stormwater management, and increasing groundwater recharge. Therefore, implementation of the CAAP would result in a less than significant cumulative impact related to hydrology and water quality. 789 of 961

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90 11 Land Use and Planning

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
significant
Impact
No
Impact
Would the project:
a. Physically divide an established
community? □ □ □ ■
b. Cause a significant environmental impact
due to a conflict with any land use plan,
policy, or regulation adopted for the
purpose of avoiding or mitigating an
environmental effect? □ □ □ ■
a. Would the project physically divide an established community? The CAAP is a policy document containing measures to reduce GHG emissions and vulnerability to the effects of climate change and does not include actions that would divide an established community. CAAP Measures MLS-2 and MLS-3 facilitate the installation of active transportation infrastructure and amenities, improved public transit connectivity, and enhanced safety for pedestrians and bicyclists. Such actions would help to increase connectivity within Glendale.

Therefore, the CAAP would result in no impact related to the division of an established community.

NO IMPACT
b. Would the project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
The CAAP is a policy document containing measures that are consistent with the Glendale General Plan and that are designed to reduce adverse environmental impacts associated with climate change. Nonetheless, implementing the CAAP could require some modification of existing policies, including developing and implementing new programs, and projects, or modifying existing ones. For example, CAAP Measure BLD-1 may result in the eventual adoption of a building electrification ordinance, Measure MLS-1 may result in changes to the GMC to encourage transit-oriented development, and Measure MLS-5 may result in the adoption of new ordinances for decarbonization of off-road equipment fleets. To implement these policies and measures, the GMC and other applicable City policies may need to be amended to reflect new or modified requirements. However, where modifications of existing policies are implemented, the CAAP measures would result in greater avoidance or reduction of environmental effects. Therefore, the CAAP would result in no impact related to consistency with current land use plans or policies adopted for the purpose of avoiding or mitigating an environmental effect.

NO IMPACT
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Land Use and Planning
Draft Initial Study-Negative Declaration 91
Cumulative Impacts
The cumulative projects scenario is the population, employment, and housing forecasts identified in the CAAP, based on demographic data contained in the SCAG RTP/SCS (refer to Table 6). The CAAP would establish measures and actions to reduce GHG emissions within Glendale and reduce vulnerability to the effects of climate change. The CAAP does not propose specific development and, on its own, would not require land use or zoning changes to implement CAAP measures or incorporate them into future projects. The CAAP is a policy document containing measures that are consistent with the Glendale General Plan and other existing policy documents. Nonetheless, implementation of the CAAP, in combination with other cumulative projects that occur to accommodate Glendale’s anticipated population, employment, and housing growth, may require some modification of existing land use policies, including amending the General Plan and developing and implementing new programs, and projects, or modifying existing ones. The proposed policy changes in the CAAP would be consistent with the intent of the goals and policies already established within the General Plan and GMC and would not cumulatively contribute to the division of communities or conflict with land use policies related to environmental protection. Cumulative projects, including those implemented under the CAAP, would be required to adhere to City development regulations and Glendale General Plan policies to retain land use character and minimize environmental impacts. Therefore, implementation of the CAAP would result in no cumulative impact related to land use.
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92 12 Mineral Resources

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
significant
Impact
No
Impact
Would the project:
a. Result in the loss of availability of a known
mineral resource that would be of value to
the region and the residents of the state? □ □ □ ■
b. Result in the loss of availability of a locally
important mineral resource recovery site
delineated on a local general plan, specific
plan, or other land use plan? □ □ □ ■
a. Would the project result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
b. Would the project result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan? There are no mapped mineral resource zones in Glendale of statewide or regional significance. In addition, no areas in the City are designated as mineral resource extraction areas by the State and no mineral extraction operations occur within the City.68 Furthermore, the CAAP would not facilitate additional urban growth or infrastructure development projects within the City that could result in the loss of availability of known mineral resources. Therefore, the CAAP would result in no impact related to mineral resources.

NO IMPACT
Cumulative Impacts
The cumulative projects scenario is the population, employment, and housing forecasts identified in the CAAP, based on demographic data contained in the SCAG RTP/SCS (refer to Table 6). As discussed above, Glendale does not contain areas of mineral resource extraction. Therefore, the CAAP, in combination with other cumulative projects that occur to accommodate Glendale’s anticipated population, employment, and housing growth, is not anticipated to contribute to cumulative impacts to mineral resources. Thus, implementation of the CAAP would result in no cumulative impact related to mineral resources.

68 Glendale, City of. 1993. Glendale General Plan: Open Space and Conservation Element. https://www.glendaleca.gov/home/showpublisheddocument/4565/635242151383400000 (accessed November 2024). 792 of 961

Environmental Checklist
Noise
Draft Initial Study-Negative Declaration 93
13 Noise

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
significant
Impact
No
Impact
Would the project result in:
a. Generation of a substantial temporary or
permanent increase in ambient noise levels
in the vicinity of the project in excess of
standards established in the local general
plan or noise ordinance, or applicable
standards of other agencies? □ □ ■ □
b. Generation of excessive groundborne
vibration or groundborne noise levels? □ □ ■ □
c. For a project located within the vicinity of a
private airstrip or an airport land use plan
or, where such a plan has not been
adopted, within two miles of a public
airport or public use airport, would the
project expose people residing or working
in the project area to excessive noise
levels? □ □ ■ □
a. Would the project result in exposure of persons to or generation of noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?
Sound is a vibratory disturbance created by a moving or vibrating source, which is capable of being detected by the hearing organs. Noise is defined as sound that is loud, unpleasant, unexpected, or undesired and may therefore be classified as a more specific group of sounds. The effects of noise on people can include general annoyance, interference with speech communication, sleep disturbance, and, in the extreme, hearing impairment. Environmental noise levels typically fluctuate over time, and different types of noise descriptors are used to account for this variability. Noise level measurements include intensity, frequency, and duration, as well as time of occurrence. Noise level (or volume) is generally measured in decibels (dB) using the A-weighted sound pressure level (dBA). Because of the way the human ear works, a sound must be about 10 dBA greater than the reference sound to be judged as twice as loud. In general, a 3 dBA change in community noise levels is noticeable, while 1-2 dBA changes generally are not perceived.69 Quiet suburban areas typically have noise levels in the range of 40-50 dBA, while arterial streets are in the 50-60+ dBA range.

69 Caltrans. 2013. Technical Noise Supplement to the Traffic Noise Analysis Protocol. (CT-HWANP-RT-13-069.25.2). https://dot.ca.gov/- /media/dot-media/programs/environmental-analysis/documents/env/tens-sep2013-a11y.pdf (accessed November 2024). 793 of 961

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94 Normal conversational levels are in the 60-65 dBA range, and ambient noise levels greater than 65 dBA can interrupt conversations.70
Noise levels typically attenuate (or drop off) at a rate of 6 dBA per doubling of distance from point sources (such as construction equipment). Noise from lightly traveled roads typically attenuates at a rate of about 4.5 dBA per doubling of distance. Noise from heavily traveled roads typically attenuates at about 3 dBA per doubling of distance, while noise from a point source typically attenuates at about 6 dBA per doubling of distance. Noise levels may also be reduced by the introduction of intervening structures. For example, a single row of buildings between the receptor and the noise source reduces the noise level by about 5 dBA, while a solid wall or berm that breaks the line-of-sight reduces noise levels by 5 to 10 dBA.71 GMC Chapter 8.36, Noise Control, establishes noise standards within the City. Construction noise is regulated by GMC Section 8.36.060, Construction on Buildings, Structures, and Projects, which prohibits construction within a residential zone, or within a radius of five hundred feet therefrom, between the hours of 7:00 p.m. and 7:00 a.m. Monday through Saturday, on Sundays, and on holidays.

The CAAP is a policy document that supports the reduction of GHG emissions and reduced vulnerability to the effects of climate change within Glendale. Some of the CAAP measures would support small-scale construction projects that could result in temporary noise, such as measures related to building decarbonization, active transportation infrastructure, water infrastructure improvements, and green stormwater infrastructure. However, CAAP projects would be reviewed for consistency with the noise standards established in the GMC, and construction activities would be required to comply with the construction hour limitations established by GMC Section 8.26.060.

Therefore, the CAAP would not result in significant construction noise related impacts.

The CAAP does not include future projects that would result in substantial operational noise. Rather, the CAAP encompasses a suite of GHG-reduction opportunities that affect the transportation sector and its associated noise. For example, CAAP Measures MLS-1 through MLS-4 and MLS-6 encourage adoption of electric and zero-emission vehicles, which are quieter than gas-powered alternatives, and facilitate improvements to bicycle and public transit facilities to increase active transportation and decrease VMT. These measures would reduce VMT and traffic-related noise in Glendale.

Additionally, CAAP Measure MLS-5 would phase out fossil fuel powered off-road equipment, such as lawnmowers, leaf blowers, and chainsaws, which would reduce community noise levels from these sources. Therefore, the CAAP would not generate excessive operational noise levels and would result in a less than significant impact related to noise exposure.

LESS THAN SIGNIFICANT IMPACT

70 Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment Manual. https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/transit-noise-and-vibration-impact-assessment- manual-fta-report-no-0123_0.pdf (accessed November 2024). 71 Federal Highway Administration (FHWA). 2011. Highway Traffic Noise: Analysis and Abatement Guidance. https://www.fhwa.dot.gov/environment/noise/regulations_and_guidance/analysis_and_abatement_guidance/revguidance.pdf (accessed November 2024).

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Noise
Draft Initial Study-Negative Declaration 95
b. Would the project result in exposure of persons to or generation of excessive groundborne vibration or groundborne noise levels?
While people have varying sensitivities to vibrations at different frequencies, in general they are most sensitive to low-frequency vibration. Vibration in buildings, such as from nearby construction activities, may cause windows, items on shelves, and pictures on walls to rattle. Vibration of building components can also take the form of an audible low-frequency rumbling noise, referred to as groundborne noise.72 Although groundborne vibration is sometimes noticeable in outdoor environments, it is almost never annoying to people who are outdoors. The primary concern from vibration is that it can be intrusive and annoying to building occupants and vibration-sensitive land uses.

Vibration amplitudes are usually expressed in Peak Particle Velocity (PPV) or Root Mean Square (RMS) vibration velocity. The PPV and RMS velocity are normally described in inches per second (in/sec). PPV is defined as the maximum instantaneous positive or negative peak of a vibration signal. PPV is often used in the monitoring of blasting vibration because it is related to the stresses that are experienced by buildings.73 Vibration significance ranges from approximately 50 vibration decibels (VdB), which is the typical background vibration-velocity level, to 100 VdB, the general threshold where minor damage can occur in fragile buildings. The general human response to different levels of groundborne vibration velocity levels is described in Table 7.74 Table 7 Human Response to Different Levels of Groundborne Vibration Vibration Velocity Level Human Reaction
65 VdB Approximate threshold of perception for many people 75 VdB Approximate dividing line between barely perceptible and distinctly perceptible. Many people find that transportation-related vibration at this level is unacceptable. 85 VdB Vibration acceptable only if there are an infrequent number of events per day VdB = vibration decibels
Source: Federal Transit Administration 2018
GMC Section 8.36.210, Vibration, prohibits operation of devices that create a vibration which is above the vibration perception threshold of an individual at or beyond the property boundary of the source if on private property or at one hundred fifty feet from the source if on a public space or public right-of-way.

The CAAP is a policy document that supports the reduction of GHG emissions and reduced vulnerability to the effects of climate change within Glendale. Some of the CAAP measures would support small-scale construction projects that could result in a temporary, minor increase in groundborne vibration, such as measures related to building decarbonization, active transportation infrastructure, water infrastructure improvements, and green stormwater infrastructure. However, CAAP projects would be reviewed for consistency with the noise and vibration standards established in GMC Chapter 8.36 to confirm that temporary construction impacts related to groundborne vibration would be minimized. There are no measures in the CAAP which would result in operational

72 Caltrans. 2020. Transportation and Construction Vibration Guidance Manual (CT-HWANP-RT-13-069.25.3). https://dot.ca.gov/- /media/dot-media/programs/environmental-analysis/documents/env/tcvgm-apr2020-a11y.pdf (accessed November 2024). 73 FHWA. 2006. FHWA Highway Construction Noise Handbook. (FHWAHEP-06-015; DOT-VNTSC-FHWA-06-02). https://www.fhwa.dot.gov/Environment/noise/construction_noise/handbook/handbook00.cfm (accessed November 2024). 74 FTA. 2018. Transit Noise and Vibration Impact Assessment Manual. https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research- innovation/118131/transit-noise-and-vibration-impact-assessment-manual-fta-report-no-0123_0.pdf (accessed November 2024). 795 of 961

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96 sources of groundborne vibration Therefore, the CAAP would result in a less than significant related to groundborne vibration.

LESS THAN SIGNIFICANT IMPACT
c. For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? The Hollywood Burbank Airport is located within two miles of the City of Glendale, in the neighboring City of Burbank. The CAAP is a policy document that would not increase airport activity or result in additional habitable development or commercial development that could increase potential exposure of residents and employees to excessive noise levels. CAAP-related projects that could occur within the influence area zones of the Hollywood Burbank Airport would be subject to the policies and noise reduction requirements of the Los Angeles County Airport Land Use Compatibility Plan.75 Therefore, the CAAP would result in a less than significant impact related to aviation-related noise exposure.

LESS THAN SIGNIFICANT IMPACT
Cumulative Impacts
The cumulative projects scenario is the population, employment, and housing forecasts identified in the CAAP, based on demographic data contained in the SCAG RTP/SCS (refer to Table 6). CAAP- related projects, in combination with other cumulative projects that occur to accommodate Glendale’s anticipated population, employment, and housing growth, would support construction that may result in a temporary increase in noise and groundborne vibration levels. However, cumulative projects, including future CAAP projects, would be subject to review by the City for compliance with the GMC and would be required to comply with applicable local, State, and Federal regulations governing construction noise and vibration. Additionally, the CAAP encompasses a suite of GHG-reduction opportunities that would decrease traffic and traffic-related noise. As such, implementation of the CAAP would not generate permanent, excessive noise or groundborne vibration levels. Therefore, the CAAP would result in a less than significant cumulative impact related to noise.

75 Los Angeles, County of. 2004. Los Angeles County Airport Land Use Plan. https://planning.lacounty.gov/wp- content/uploads/2022/10/Los-Angeles-County-Airport-Land-Use-Plan.pdf (accessed November 2024) 796 of 961

Environmental Checklist
Population and Housing
Draft Initial Study-Negative Declaration 97
14 Population and Housing

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
significant
Impact
No
Impact
Would the project:
a. Induce substantial unplanned population
growth in an area, either directly (for
example, by proposing new homes and
businesses) or indirectly (for example,
through extension of roads or other
infrastructure)? □ □ □ ■
b. Displace substantial numbers of existing
people or housing, necessitating the
construction of replacement housing
elsewhere? □ □ □ ■
a. Would the project induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
b. Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
The CAAP does not include measures or actions that would result in new housing or jobs or that would displace existing residents or housing. In addition, the CAAP does not propose new infrastructure, such as roadways or utilities, which could indirectly lead to new population growth or development. The CAAP would not directly increase the population, indirectly induce additional unplanned population growth, or displace people or housing. Therefore, the CAAP would result in no impact related to population and housing.

NO IMPACT
Cumulative Impacts
The cumulative projects scenario is the population, employment, and housing forecasts identified in the CAAP, based on demographic data contained in the SCAG RTP/SCS (refer to Table 6). The CAAP would establish measures and actions to reduce GHG emissions within Glendale and reduce vulnerability to the effects of climate change. The CAAP does not propose specific development and, on its own, would not require land use or zoning changes to implement CAAP measures or incorporate them into future projects. Future CAAP-related projects, in combination with other cumulative projects that occur to accommodate Glendale’s anticipated population, employment, and housing growth, are not anticipated to displace people or housing nor induce substantial unplanned population growth within Glendale. Specifically, the CAAP would not contribute to person or housing displacement in Glendale nor result in population growth beyond that already 797 of 961

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98 assumed and planned for in the RTP/SCS. Therefore, the CAAP would result in no cumulative impact related to population and housing.
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Environmental Checklist
Public Services
Draft Initial Study-Negative Declaration 99
15 Public Services

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
significant
Impact
No
Impact
a. Would the project result in substantial
adverse physical impacts associated with
the provision of new or physically altered
governmental facilities, or the need for
new or physically altered governmental
facilities, the construction of which could
cause significant environmental impacts, in
order to maintain acceptable service ratios,
response times or other performance
objectives for any of the public services:

1. Fire protection? □ □ □ ■

2. Police protection? □ □ □ ■

3. Schools? □ □ □ ■

4. Parks? □ □ □ ■

5. Other public facilities? □ □ □ ■
a. Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
▪ Fire protection?
▪ Police protection?
▪ Schools?
▪ Parks?
▪ Other public facilities?
Implementation of the CAAP would not result in increases in population or new employment opportunities that could induce population growth, as further discussed in Section 14, Population and Housing. As such, the CAAP would not require the construction of new or physically altered governmental facilities to serve additional residents, the construction of which could cause significant environmental impacts. CAAP Measures SG-1, SG-2, and SG-5 would improve the community’s awareness and response to climate-related extreme weather events, provide resilience centers to assist with emergency response and serve as a community resource, and increase the capacity of Glendale to withstand climate shocks and stresses. Additionally, CAAP Measures BLD-1, BLD-3, BLD-4, MLS-2, UE-3, UE-5, and UE-6 contain actions to reduce vulnerability 799 of 961

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100
to wildfire and post-wildfire landslides, improve the ability of the Fire Department to respond to fire events, and provide battery backup power to critical public facilities. The CAAP would therefore reduce the burden on local public services related to natural disasters and climate change. As such, the CAAP would result in no impact related to public services.

NO IMPACT
Cumulative Impacts
The cumulative projects scenario is the population, employment, households, and service population forecasts identified in the CAAP, based on demographic data contained in the SCAG RTP/SCS (refer to Table 6). As further addressed in Section 14, Population and Housing, future CAAP- related projects, in combination with other cumulative projects that occur to accommodate Glendale’s anticipated population, employment, and housing growth, would not result in population growth beyond that already assumed and planned for in the City. Therefore, implementation of the CAAP would not result in substantial cumulative need to expand public services facilities. Rather, the CAAP includes measures and actions to improve community resilience, enhance critical public facilities, and reduce the potential impacts of climate change in the City, thereby reducing the burden on local public services related to climate change-induced disasters. Therefore, the CAAP would result in a no cumulative impact related to public services. 800 of 961

Environmental Checklist
Recreation
Draft Initial Study-Negative Declaration 101
16 Recreation

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
significant
Impact
No
Impact
Would the project:
a. Increase the use of existing neighborhood
and regional parks or other recreational
facilities such that substantial physical
deterioration of the facility would occur or
be accelerated? □ □ □ ■
b. Include recreational facilities or require the
construction or expansion of recreational
facilities which might have an adverse
physical effect on the environment? □ □ □ ■
a. Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
b. Would the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? Glendale is a primarily urbanized community with 47 parks and recreational amenities incorporated throughout the City.76 Glendale also contains over 5,000 acres of natural open space in the Verdugo Mountains, San Gabriel Mountains, and San Rafael Hills with hiking and/or multi-use trails, as shown in Map 3-2 of the General Plan Open Space and Conservation Element.77, 78 The General Plan Recreation Element and Open Space and Conservation Element incorporate goals and policies related to open space/recreational resources in the City.79, 80 The CAAP is a policy document containing measures and actions that are consistent with and complementary to the General Plan Open Space and Conservation and Recreation Element policies, which are being updated to align with current policies and new standards to address accessibility and resilience. For example, CAAP Measure UE-2 seeks to increase greenspace, trees, and parklets within Glendale, while Measures MLS-2 and MLS-3 include actions to increase the accessibility of parks for bicyclists and public transit users. Additionally, as described in Section 14, Population and Housing, the CAAP would not result in substantial population growth. As such, implementation of

76 Glendale, City of. 2016. Map of Glendale Parks.
https://www.glendaleca.gov/home/showpublisheddocument/50/636117201427130000 (accessed November 2024). 77 Glendale, City of. 1993. General Plan Open Space and Conservation Element. https://www.glendaleca.gov/home/showpublisheddocument/4563/638532813084270000 (accessed November 2024). 78 Glendale, City of. 2024. Trails and Open Space Program Welcome Page. https://www.glendaleca.gov/government/departments/community-services-parks/trails-and-open-space (accessed November 2024). 79 Glendale, City of. 1996. General Plan Recreation Element. https://www.glendaleca.gov/home/showpublisheddocument/37401/636312436409300000 (accessed November 2024). 80 Glendale, City of. 1993. General Plan Open Space and Conservation Element. https://www.glendaleca.gov/home/showpublisheddocument/4563/638532813084270000 (accessed November 2024). 801 of 961

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the CAAP would not result in a substantial physical deterioration of parks or other recreational facilities or result in the need to expand recreational facilities. Rather, as a co-benefit, the CAAP would improve access to parks and recreational facilities and increase greenspaces within Glendale.

Therefore, the CAAP would result in no impact related to the need for construction of new or altered recreational facilities.

NO IMPACT
Cumulative Impacts
The cumulative projects scenario is the population, employment, households, and service population forecasts identified in the CAAP, based on demographic data contained in the SCAG RTP/SCS (refer to Table 6). As further addressed in Section 14, Population and Housing, future CAAP- related projects, in combination with other cumulative projects that occur to accommodate Glendale’s anticipated population, employment, and housing growth, would not result in population growth beyond that already assumed and planned for in the City. Therefore, implementation of the CAAP would not result in increased demand for parks or substantial cumulative physical deterioration of parks or other recreational facilities or result in the cumulative need to expand recreational facilities. In addition, the CAAP includes measures to increase greenspace, trees, and parklets within the community, as well as improve access to these resources for bicyclists and public transit users, which aligns with the General Plan Open Space and Conservation and Recreation Elements goals. Therefore, implementation of the CAAP would result in no cumulative impact related to recreation.
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17 Transportation

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
significant
Impact
No
Impact
Would the project:
a. Conflict with a program, plan, ordinance or
policy addressing the circulation system,
including transit, roadway, bicycle and
pedestrian facilities? □ □ □ ■
b. Conflict or be inconsistent with CEQA
Guidelines section 15064.3, subdivision
(b)? □ □ □ ■
c. Substantially increase hazards due to a
geometric design feature (e.g., sharp
curves or dangerous intersections) or
incompatible use (e.g., farm equipment)? □ □ ■ □
d. Result in inadequate emergency access? □ □ ■ □
a. Would the project conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? The City has adopted several plans and policies addressing the circulation system, including the General Plan Circulation Element, Bicycle Transportation Plan, Citywide Pedestrian Plan (Parts 1 and 2), and the Glendale Safe and Healthy Streets Plan. The General Plan Circulation Element, which establishes the overarching vision for the circulation system in Glendale, includes the following goals:
▪ Goal 1: Preservation and enhancement of the quality of life in Glendale's unique communities. ▪ Goal 2: Minimization of congestion, air pollution, and noise associated with motor vehicles. ▪ Goal 3: Reasonable access to services and goods in Glendale by a variety of transportation modes.
▪ Goal 4: Functional and safe streetscapes that are aesthetically pleasing for both pedestrians and vehicular travel.
▪ Goal 5: Land use which can be supported within the capacity constraints of existing and realistic future infrastructure.81
The Bicycle Transportation Plan, Citywide Pedestrian Plan (Parts 1 and 2), and Glendale Safe and Healthy Streets Plan build upon the General Plan Circulation Element goals to reduce dependence

81 Glendale, City of. 1998. General Plan Circulation Element. https://www.glendaleca.gov/home/showpublisheddocument/4497/638654712105630000 (accessed November 2024). 803 of 961

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on automobiles and create vibrant neighborhoods by making the City a safer and more convenient place to bike, walk, and use alternate modes of transportation.82, 83, 84, 85 The CAAP contains measures and actions that are consistent with the General Plan Circulation Element, Bicycle Transportation Plan, Citywide Pedestrian Plan (Parts 1 and 2), and Glendale Safe and Healthy Streets Plan. CAAP Measure MLS-1 would support land use patterns and parking strategies to reduce vehicle use and VMT, with associated benefits to air quality, GHG emissions, and the environment. CAAP Measure MLS-2 seeks to increase active transportation by implementing improvements to the bicycle and pedestrian infrastructure and safety in Glendale. For example, CAAP Action MLS-2.6 specifically directs the City to pursue funding and implement programs identified in the Bicycle Transportation Plan, Circulation Element, and Safe and Healthy Streets Plan. Additionally, CAAP Measure MLS-3 contains actions to enhance the public transit system. These CAAP measures would advance active transportation and public transit within Glendale and decrease VMT and associated air pollutants and GHG emissions. These CAAP measures would be consistent with Glendale’s existing policies and goals related to improving multi-modal facilities, reducing VMT and single-occupancy vehicles, encouraging active transportation, and reducing vehicle congestion within the City. Therefore, the CAAP would result in no impact related to consistency with plans addressing the transportation circulation system.

NO IMPACT
b. Would the project conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b)?
CEQA Guidelines Section 15064.3 establishes VMT as the most appropriate measure of assessing transportation impacts for the purposes of CEQA. The City adopted their Transportation Impact Analysis Guidelines in 2020, which establishes locally appropriate VMT thresholds and analysis requirements consistent with CEQA Guidelines Section 15064.3, subdivision (b). Section 2.3 of the Transportation Impact Analysis Guidelines establish the criteria for analyzing VMT impacts from plan-level projects and documents and specifies that a significant impact would occur if a plan would:
▪ Generate total VMT per service population in the horizon year plus project scenario that exceeds the total VMT per service population under existing conditions; or ▪ Generate total VMT per service population in the horizon year plus project scenario that exceeds the total VMT per service population under the horizon year no project/previous plan scenario. 86

82 Glendale, City of. 2012. Bicycle Transportation Plan. https://www.glendaleca.gov/home/showpublisheddocument/16789/635416466425100000 (accessed November 2024). 83 Glendale, City of. Glendale Citywide Pedestrian Plan Part 1. https://www.glendaleca.gov/home/showpublisheddocument/67588/637932141006000000 (accessed November 2024). 84 Glendale, City of. 2021. Glendale Citywide Pedestrian Plan Part 2. https://www.glendaleca.gov/home/showpublisheddocument/67590/637932141021770000 (accessed November 2024). 85 Glendale, City of. 2011. Safe and Healthy Streets Plan. https://www.glendaleca.gov/home/showpublisheddocument/14128/635343731643200000 (accessed November 2024). 86 Glendale, City of. 2020. Transportation Impact Analysis Guidelines. https://www.glendaleplan.com/_files/ugd/81c7a2_469b63477a8844388ff25df39e0167bc.pdf (accessed November 2024). 804 of 961

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The CAAP includes measures and actions that seek to reduce single-occupancy vehicle use and VMT within the City, consistent with CEQA Guidelines section 15064.3, subdivision (b). The CAAP would accomplish VMT reductions through Measures MLS-1, MLS-2, and MLS-3, described above under Response 17a. These measures would support land use patterns and parking strategies to reduce vehicle use and VMT, increase active transportation by implementing improvements to bicycle and pedestrian infrastructure, and enhancing the public transit system. Therefore, the CAAP would result in no impact related to consistency with plans addressing the transportation circulation system and CEQA Guidelines Section 15064.3, subdivision (b).

NO IMPACT
c. Would the project substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible use (e.g., farm equipment)? d. Would the project result in inadequate emergency access? The CAAP would not involve new land uses or changes to the roadway system that would increase hazards due to design changes or incompatible uses. Implementation of CAAP measures and actions related to active transportation and public transit, including the actions under Measures MLS-2 and MLS-3, may involve construction within the local right-of-way. Construction activities have the potential to require lane closures and may impact traffic and vehicle speeds on the affected roadways; however, these impacts would be temporary and access to roadways would generally be maintained throughout project construction. Furthermore, future projects involving work in the public right-of-way would be required to coordinate with the City through the encroachment permit process to confirm appropriate construction staging and adequate vehicular and pedestrian access on adjacent roadways. Coordination with the City would confirm that significant impacts to the circulation system design, including safety impacts and emergency access, would not occur. As such, construction of future CAAP-related projects would not create transportation design hazards or result in inadequate emergency access. Furthermore, the CAAP would facilitate increased active transportation and public transit use and decreased VMT within Glendale, which in turn would reduce potential transportation hazards and congestion conditions that can hinder emergency response. Therefore, the CAAP would result in a less than significant impact related to transportation hazards and emergency access.

LESS THAN SIGNIFICANT IMPACT
Cumulative Impacts
The cumulative projects scenario is the population, employment, households, and service population forecasts identified in the CAAP, based on demographic data contained in the SCAG RTP/SCS (refer to Table 6). Cumulative projects that occur to accommodate Glendale’s anticipated population, employment, and housing growth could result in increases in VMT or changes affecting traffic design safety and emergency access. However, the CAAP is a policy document containing measures and actions that are consistent with the General Plan Circulation Element and other applicable transportation policies and does not propose new development that would increase VMT, result in design hazards, or affect emergency access. Rather, the CAAP measures and actions would promote alternative modes of transportation and reduction of VMT throughout Glendale.

Implementation of the CAAP would guide future development within Glendale and confirm that future projects within the City are planned and designed to limit VMT and improve multi-modal access. Therefore, the CAAP would result in no cumulative impacts related to transportation. 805 of 961

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18 Tribal Cultural Resources

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
significant
Impact
No
Impact
Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
a. Listed or eligible for listing in the California
Register of Historical Resources, or in a
local register of historical resources as
defined in Public Resources Code section
5020.1(k), or □ □ ■ □
b. A resource determined by the lead agency,
in its discretion and supported by
substantial evidence, to be significant
pursuant to criteria set forth in subdivision
(c) of Public Resources Code Section
2024.1. In applying the criteria set forth in
subdivision (c) of Public Resources Code
Section 5024.1, the lead agency shall
consider the significant of the resource to a
California Native American tribe? □ □ ■ □
a. Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in a Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe and that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code § 5020.1 (k)? b. Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in a Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe and that is a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 2024.1. In applying the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1, the lead agency shall consider the significant of the resource to a California Native American tribe?
On August 29, 2024, fourteen Native American Heritage Commission (NAHC)- and City-identified local Native American tribal representatives from nine Native American Tribal groups were formally notified that the City initiated environmental review of the CAAP and were invited to consult on the 806 of 961

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plan under Senate Bill (SB) 18 and/or Assembly Bill (AB) 52. Follow up phone calls were also conducted on October 4 and 8, 2024 to solicit Tribal input. The Native American Tribal groups that were notified for the plans include the following:
▪ Fernandeño Tataviam Band of Mission Indians (AB 52 and SB 18 consultation) ▪ Gabrieleño Band of Mission Indians - Kizh Nation (SB 18 consultation) ▪ Gabrieleno/Tongva San Gabriel Band of Mission Indians (SB 18 consultation) ▪ Gabrielino Tongva Indians of California Tribal Council (SB 18 consultation) ▪ Gabrielino/Tongva Nation (SB 18 consultation)
▪ Gabrielino-Tongva Tribe (AB 52 and SB 18 consultation) ▪ San Fernando Band of Mission Indians (SB 18 consultation) ▪ Santa Rosa Band of Cahuilla Indians (SB 18 consultation) ▪ Soboba Band of Luiseño Indians (AB 52 and SB 18 consultation) On September 3, 2024, the Santa Rosa Band of Cahuilla Indians responded indicated that they defer any comments on the CAAP to the Soboba Band of Luiseño Indians. On September 11, 2024, a representative from the Gabrieleño Band of Mission Indians - Kizh Nation responded stating that they agree with the General Plan Amendment, but request consultation for all future projects within the City. On October 4, 2024, representatives from the Soboba Band of Luiseño Indians responded indicating that they have no concerns regarding the CAAP and GPSE Update. On October 8, 2024, the Fernandeño Tataviam Band of Mission Indians responded that they were not requesting consultation on the CAAP and GPSE Update. No other responses were received during the 30-day AB 52 and 90-day SB 18 consultation period.

The CAAP would not directly result in land use or zoning changes87 that would increase development within the City but would instead promote sustainable development within the urbanized areas of the City. As a policy document, the CAAP would also not directly entail ground disturbing activities; however, implementation of various CAAP measures and actions related to carbon-free electricity, existing building decarbonization, active transportation facilities, tree planting, recycled water, and green stormwater infrastructure would include construction activities in the future which would be analyzed on a project-level basis prior to approval. These include Measures BLD-1, BLD-3, BLD-4, MLS-2, MLS-3, UE-2, UE-5, and UE-6.

Future solar and battery storage projects and electrical transmission upgrades implemented as part of CAAP Measure BLD-1 would involve construction activities and ground disturbance. In addition, building decarbonization retrofits encouraged by CAAP Measures BLD-3 and BLD-4 may change the physical environment through the need for upgraded service and electrical panels, branch circuit upgrades, and installation of condensate drains to facilitate the installation of electric heat pumps for water and space heating. Improvements to bicycle, pedestrian, and public transit facilities associated with CAAP Measures MLS-2 and MLS-3 would primarily impact previously disturbed areas within existing roadways and the public rights-of-way. However, the physical changes these installations and enhancements would entail are dependent on the location of construction for new bike lanes, sidewalks, and public transit facilities, which in some cases may include minor temporary excavation and would be analyzed on a project-level basis. CAAP Measure UE-2 would increase urban trees within the community, which could result in ground disturbance related to planting new

87 Future Land Use Element amendments to the General Plan to further implement CAAP Measure MLS-1 would be considered as part of the environmental analysis completed at that time.
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trees. Additionally, CAAP Measures UE-5 and UE-6 would increase recycled water and green stormwater infrastructure in the City, with associated construction activities to develop this sustainable infrastructure.

Implementation of these CAAP measures could impact unknown tribal cultural resources during construction that involves below-grade activities in previously undisturbed soils. However, future CAAP-related projects would be located and designed strategically to reduce ground disturbance to the maximum extent possible. Furthermore, CAAP Action SG-4.3 explicitly requires that future CAAP-related projects consult with local Tribes in their scoping, development, adoption, and implementation, going beyond the requirements of AB 52 and SB 18. Future CAAP-related projects and actions would be reviewed for consistency with applicable local and State tribal cultural and archaeological regulations prior to final siting and construction, such as AB 52, SB 18, the General Plan Historic Preservation Element, and GMC Chapter 15.20, Historic Preservation. In particular, future CAAP projects would be required to implement BMPs in accordance with General Plan Historic Preservation Element Policies 1-4 and 1-5. These policies require archaeological surveys and/or monitoring to be conducted prior to the issuance of construction permits for individual projects in archaeologically sensitive areas of the City and construction suspension when cultural resources are discovered.88 As such, local Tribes would be consulted prior to implementation of future CAAP projects in accordance with CAAP Action SG-4.3 and tribal cultural resources would be protected prior to and/or upon discovery in accordance with General Plan Historic Preservation Element Policies 1-4 and 1-5. Thus, the CAAP would result in a less than significant impact related to tribal cultural resources.

LESS THAN SIGNIFICANT IMPACT
Cumulative Impacts
The cumulative projects scenario is the population, employment, households, and service population forecasts identified in the CAAP, based on demographic data contained in the SCAG RTP/SCS (refer to Table 6). Future CAAP-related projects, in combination with other cumulative projects that occur to accommodate Glendale’s anticipated population, employment, and housing growth, could increase the potential for adverse effects to unknown tribal cultural resources in the City. However, impacts to tribal cultural resources are site-specific; accordingly, as required under applicable laws and regulations, potential impacts associated with cumulative developments would be addressed on a project-level case-by-case basis as cumulative project details and locations become known. Future CAAP projects and other cumulative projects would be required to comply with the General Plan Historic Preservation Element requirements for cultural resources surveys in archaeological sensitive areas and the halting of construction and proper treatment of any resources discovered during ground disturbance. Therefore, the CAAP would result in a less than significant cumulative impact related to tribal cultural resources.

88 Glendale, City of. 1997. General Plan Historic Preservation Element. https://www.glendaleca.gov/home/showpublisheddocument/833/638533600745770000 (accessed November 2024). 808 of 961

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19 Utilities and Service Systems

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
significant
Impact
No
Impact
Would the project:
a. Require or result in the relocation or
construction of new or expanded water,
wastewater treatment or storm water
drainage, electric power, natural gas, or
telecommunications facilities, the
construction or relocation of which could
cause significant environmental effects? □ □ ■ □
b. Have sufficient water supplies available to
serve the project and reasonably
foreseeable future development during
normal, dry and multiple dry years? □ □ □ ■
c. Result in a determination by the
wastewater treatment provider which
serves or may serve the project that it has
adequate capacity to serve the project’s
projected demand in addition to the
provider’s existing commitments? □ □ □ ■
d. Generate solid waste in excess of State or
local standards, or in excess of the capacity
of local infrastructure, or otherwise impair
the attainment of solid waste reduction
goals? □ □ □ ■
e. Comply with federal, State, and local
management and reduction statutes and
regulations related to solid waste? □ □ □ ■
a. Would the project require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
The CAAP is a policy document aimed at reducing solid waste production and energy and water consumption, amongst other issues, and the related GHG emissions throughout Glendale and does not include site-specific infrastructure designs or project proposals. Implementation of the CAAP would not result in an increase in population and housing, nor would it facilitate growth beyond that anticipated by SCAG population forecasts. As such, implementation of the CAAP would not create new utility demand due to increased growth in the City. However, projects resulting from 809 of 961

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implementation of the CAAP could include redevelopment and/or restructuring of electricity and natural gas power facilities and infrastructure, as well as new local renewable energy generation and storage and recycled water and green stormwater infrastructure projects. Potential impacts related to these measures are discussed further below.

Water Supply Facilities/Infrastructure
GWP is the primary retail water supplier for development within the City. According to the GWP Urban Water Management Plan (UWMP), GWP obtains 60-70 percent of its municipal water supply from Metropolitan Water District (MWD), which supplies water predominantly from the Colorado River Aqueduct and the State Water Project. The remainder of the water supply is from local groundwater wells and recycled water produced at the Los Angeles-Glendale Water Reclamation Plant (LAGWRP).89 The City’s distribution system includes over 380 miles of pipelines, 16 wells, 28 tanks and reservoirs, 28 pump stations, and six pressuring reducing stations.90 CAAP Measure UE-5 seeks to decrease community water use by promoting water efficiency retrofits, sustainable landscaping, increased recycled and greywater water use, and efficient landscaping irrigation. In addition, CAAP Measures UE-2, UE-5, and UE-691 when implemented on a project level basis would increase green stormwater infrastructure, stormwater capture and groundwater recharge, the planting of urban trees, and development of new greenspaces. These measures would increase permeable surfaces throughout the City and improve water infiltration and groundwater recharge. As part of these measures, repairs to leaking water pipelines, new recycled water lines, and leakage detective systems may be implemented throughout Glendale.

However, the CAAP would not result in new land uses, such as increased residential or commercial development, which would contribute to an increase in water use compared to existing conditions or that would require relocation or construction of new water infrastructure. Therefore, the CAAP would result in a less than significant impact related to the need for construction or expansion of water supply facilities and infrastructure.

Wastewater Treatment Facilities/Infrastructure
The City of Glendale collects and treats wastewater generated within Glendale. The City’s sewer system consists of approximately 360 miles of pipes and one lift station. Sewage treatment for collected wastewater is provided by either the LAGWRP or the Hyperion Water Reclamation Plant.92 The LAGWRP has a treatment capacity of 20 million gallons per day (mgd) and currently treats

89 Glendale, City of. 2020. 2020 Urban Water Management Plan. https://www.glendaleca.gov/home/showpublisheddocument/62412/638562960022130000 (accessed November 2024). 90 Glendale, City of. 2023. Glendale Water and Power 2022-2023 Annual Report. https://www.glendaleca.gov/home/showpublisheddocument/73790/638416244855630000 (accessed November 2024). 91 Implementation of certain actions may require additional CEQA review once project specifications, such as site location, are identified and potential environmental impacts would be determined on a case-by-case basis. 92 Glendale, City of. 2018. South Glendale Community Plan Program Environmental Impact Report. https://www.glendaleca.gov/home/showpublisheddocument/45607/638481693518000000 (accessed November 2024). 810 of 961

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approximately 20 mgd on average.93 The Hyperion Water Reclamation Plant has a treatment capacity of 450 mgd and treats an average of 275 mgd.94 The CAAP would not result in new land uses that would generate sanitary wastewater or otherwise contribute to an increase in wastewater treatment requirements. Rather, the CAAP includes Action UE-5.9 which would expand GWP programs to provide low-flow fixtures, such as toilets, sinks, and showerheads to residents, thereby decreasing the amount of wastewater generated. As such, the CAAP would not require relocation or construction of new wastewater treatment and conveyance infrastructure, and no impact related to construction or expansion of wastewater treatment facilities and infrastructure would occur.

Stormwater Drainage Facilities/Infrastructure
The City maintains a system of storm drains, gutters, and ditches to convey stormwater generated during rain events. As discussed in Section 10, Hydrology and Water Quality, implementation of CAAP measures related to building decarbonization and energy and water efficiency upgrades, renewable energy production and storage, active and public transportation, green stormwater infrastructure, and urban trees would involve construction activities. Construction of projects implemented in accordance with the CAAP could result in erosion and potential changes to drainage patterns, affecting stormwater drainage infrastructure. However, as described in Section 7, Geology and Soils, and Section 10, Hydrology and Water Quality, CAAP projects would be required to comply with local, State, and Federal requirements during construction that would control stormwater runoff, erosion, and potential impacts to the stormwater drainage system. In addition, CAAP Measures UE-2, UE-5, and UE-6 would increase green stormwater infrastructure, stormwater capture and groundwater recharge, the planting of urban trees, and development of new greenspaces. These measures would increase permeable surfaces throughout the City and improve water infiltration and stormwater management. Therefore, the CAAP would result in less than significant impacts related to stormwater drainage.

Electric Power Facilities/Infrastructure
Electric power service in the City is provided by GWP, with a peak load of 349 megawatts (MW) in 2024.95 According to GWP’s Integrated Resources Plan (IRP), GWP anticipates peak loads to increase over the next 20 years with the electrification of buildings and EVs.96 CAAP Measures BLD-2, BLD-3, and BLD-4 promote decarbonization of new and existing buildings, energy efficiency retrofits of existing buildings, and energy efficient buildings for future development. In addition, CAAP Measures MLS-4, MLS-5, and MLS-6 encourage adoption of EVs and zero-emission vehicles, decarbonizing off-road vehicles and off-road equipment to electric power, and converting the municipal fleet to zero-emission vehicles. These CAAP measures would result in increased electricity demand within Glendale, as anticipated by the IRP. Analysis of the impacts of CAAP recommended

93 City of Los Angeles Environment and Sanitation. 2024. Los Angeles-Glendale Water Reclamation Plant. https://sanitation.laCity.gov/san/faces/home/portal/s-lsh-wwd/s-lsh-wwd-cw/s-lsh-wwd-cw-p/s-lsh-wwd-cw-p-lagwrp?_adf.ctrl- state=bas4k0tci_1&_afrLoop=560208968658679&_afrWindowMode=0&_afrWindowId=null#!%40%40%3F_afrWindowId%3Dnull%26_afr Loop%3D560208968658679%26_afrWindowMode%3D0%26_adf.ctrl-state%3Dbas4k0tci_5 (accessed November 2024). 94 City of Los Angeles Environment and Sanitation. 2024. Treatment Process. https://sanitation.laCity.gov/san/faces/wcnav_externalId/s- lsh-wwd-cw-p-hwrp-tp?_adf.ctrl-state=bas4k0tci_290&_afrLoop=562229808088201#! (accessed November 2024). 95 Cardenas, I. February 18, 2025. Peak Load Data [Email]. 96 Glendale, City of. 2024. 2024 Integrated Resources Plan. https://www.glendaleca.gov/government/departments/glendale-water-and- power/reports-plans/integrated-resource-plan (accessed November 2024). 811 of 961

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specific electric power facilities/infrastructure projects would be undertaken on a project-level basis.

CAAP Measure BLD-1 supports installation of small-scale renewable energy systems and battery storage to provide renewable electricity within the City, which would help to offset some of the increased demand associated with decarbonization of buildings and electrification of vehicles and offroad equipment. In addition, CAAP Measure BLD-1 includes actions to increase the purchase of renewable energy, improve transmission capacity, and enhance grid resilience, thereby preparing Glendale for increased electricity use. Additionally, GWP, through the IRP process, already has anticipated and planned for increased electricity use, and is projected to have adequate resources through 2045 to accommodate electricity needs in Glendale.97 The CAAP would serve as a pathway to reduce GHG emissions, including emissions related to energy consumption, and other beneficial environmental and sustainability effects. These benefits include a reduction in overall energy consumption and an increase in renewable energy production. Therefore, the CAAP would result in a less than significant impact related to construction, expansion, or relocation of electric power facilities and infrastructure.

Natural Gas Power Facilities/Infrastructure
Southern California Gas Company (SoCalGas) provides natural gas services to Glendale. The CAAP would not involve new land uses that require new or additional natural gas service, resulting in the need for construction of new or expanded natural gas facilities. CAAP Measures BLD-2, BLD-3, and BLD-4 promote decarbonization of new and existing buildings, energy efficiency retrofits of existing buildings, and energy efficient buildings for future development, resulting in reduced natural gas consumption within the City. Therefore, the CAAP would result in no impact related to construction, expansion, or relocation of natural gas facilities and infrastructure.

Telecommunications Facilities/Infrastructure
The City is served by existing telecommunications companies such as Frontier, AT&T, and Verizon.

The CAAP would not involve new land uses or development that would require new telecommunications infrastructure, but the CAAP may result in minor modifications to existing telecommunications facilities and infrastructure. Specifically, CAAP Action SG-1.5 supports improvements in the redundancy of emergency evacuation communication systems, including telecommunication towers, by installing back-up power at critical facilities. The addition of backup power for telecommunications towers would involve minor construction activities and would not result in the relocation or expansion of such facilities. Therefore, the CAAP would result in a less than significant impact related to the need for construction or expansion of telecommunication facilities and infrastructure.

LESS THAN SIGNIFICANT IMPACT
b. Would the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years? The City addresses issues of water supply in the UWMP, which is a long-range planning document used to assess current and projected water usage, water supply planning, and conservation and recycling efforts. According to the 2020 UWMP, the City has analyzed three different hydrological

97 Glendale, City of. 2024. 2024 Integrated Resources Plan. https://www.glendaleca.gov/government/departments/glendale-water-and- power/reports-plans/integrated-resource-plan (accessed November 2024). 812 of 961

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conditions to determine the reliability of water supplies: average/normal water year, single dry water year, and five consecutive dry years. The UWMP indicates that water supplies under all three hydrological conditions will be sufficient to meet demand through 2045. In addition, the UWMP includes a Water Shortage Contingency Plan to guide local actions if a water supply shortage were to occur.98
The CAAP is a policy-level document that does not include site-specific infrastructure designs or project proposals, nor does it grant entitlements for development that would have the potential to increase water demand. Rather the CAAP contains measures and actions to reduce water use, such as Measure UE-5, which would reduce water demand by promoting water efficiency retrofits, sustainable landscaping, increased recycled and greywater use, and efficient landscaping irrigation.

In addition, CAAP Measures UE-2, UE-5, and UE-6 would increase green stormwater infrastructure, stormwater capture and groundwater recharge, the planting of urban trees, and development of new greenspaces. These measures would increase permeable surfaces throughout the City and improve water infiltration and groundwater recharge. Thus, the CAAP would result in no impact related to water supply.

NO IMPACT
c. Would the project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
As described above under Response 19a., wastewater treatment for the City is provided by a combination of the LAGWRP, which is operating at capacity, and the Hyperion Water Reclamation Plant, which has surplus capacity compared to the currently daily average wastewater flows.

The CAAP would not result in new land uses that would generate sanitary wastewater or otherwise contribute to an increase in wastewater treatment requirements. Rather, the CAAP includes Action UE-5.9 which would expand GWP programs to provide low-flow fixtures, such as toilets, sinks, and showerheads to residents, thereby decreasing the amount of wastewater generated. As such, the CAAP would have no impact related to wastewater treatment.

NO IMPACT
d. Would the project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
e. Would the project comply with federal, State, and local management and reduction statutes and regulations related to solid waste?
The City provides solid waste services for single-family and multi-family residential properties with two to four units. Multi-family properties with five or more units and commercial businesses are serviced by one of the four franchised haulers, which include Southland Disposal Company, Athens Services, Waste Resources, and NASA Services.99 Solid waste services in the City include recycling, organic waste recycling, and trash. Municipal solid waste generated in Glendale is primarily disposed

98 Glendale, City of. 2020. Urban Water Management Plan. https://www.glendaleca.gov/home/showpublisheddocument/62412/638562960022130000 (accessed November 2024). 99 Glendale, City of. 2024. Who is My Hauler?. https://www.glendaleca.gov/government/departments/public-works/integrated-waste- management/who-is-my-hauler (accessed November 2024).
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of at the Scholl Canyon Landfill in Glendale.100 Scholl Canyon Landfill has a maximum permitted throughput of 3,400 tons of solid waste per day and has a remaining capacity of 9,900,000 cubic yards.101
The CAAP focuses on sustainable infrastructure development and does not include land use or other policy changes that would result in increased residential, commercial, or other development that would increase solid waste generation within the City. CAAP Measure UE-6 seeks to reduce solid waste production within the City by reducing consumption, increasing landfill diversion rates, and implementing climate smart food and purchasing programs. This CAAP measure aligns with Federal, State, and local regulations aimed at reducing solid waste disposal and increasing organic waste and recyclables diversion, such as SB 1383. Additionally, because the CAAP is a policy document that would not facilitate population growth, it would not generate solid waste in excess of State or local standards or local landfill capacity. Therefore, the CAAP would result in no impact related to solid waste.

NO IMPACT
Cumulative Impacts
The cumulative projects scenario is the population, employment, households, and service population forecasts identified in the CAAP, based on demographic data contained in the SCAG RTP/SCS (refer to Table 6). Cumulative projects that occur to accommodate Glendale’s anticipated population, employment, and housing growth could result in increases in population and additional use of, or need for, utilities and service systems. However, implementation of the CAAP would not contribute to increases in population or induce additional population growth that would require additional use of existing City utilities or service systems. Rather, implementation of the CAAP would result in overall reduced energy and water consumption and solid waste and wastewater production. Therefore, implementation of the CAAP would result in a less than significant cumulative impact related to utilities and service systems.

100 Glendale, City of. 2018. South Glendale Community Plan Program Environmental Impact Report. https://www.glendaleca.gov/home/showpublisheddocument/45607/638481693518000000 (accessed November 2024). 101 CalRecycle. 2024. SWIS Facility/Site Activity Details: Scholl Canyon Landfill. https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/3531?siteID=1000 (accessed November 2024). 814 of 961

Environmental Checklist
Tribal Cultural Resources
Draft Initial Study-Negative Declaration 115
20 Wildfire

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
significant
Impact No Impact
If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:
a. Substantially impair an adopted
emergency response plan or emergency
evacuation plan? □ □ □ ■
b. Due to slope, prevailing winds, and other
factors, exacerbate wildfire risks and
thereby expose project occupants to
pollutant concentrations from a wildfire
or the uncontrolled spread of a wildfire? □ □ □ ■
c. Require the installation or maintenance
of associated infrastructure (such as
roads, fuel breaks, emergency water
sources, power lines or other utilities)
that may exacerbate fire risk or that may
result in temporary or ongoing impacts
to the environment? □ □ □ ■
d. Expose people or structures to significant
risks, including downslopes or
downstream flooding or landslides, as a
result of runoff, post-fire slope instability,
or drainage changes? □ □ □ ■
a. If located in or near State responsibility areas or lands classified as very high fire hazard severity zones, would the project substantially impair an adopted emergency response plan or emergency evacuation plan?
b. If located in or near State responsibility areas or lands classified as very high fire hazard severity zones, would the project due to slope, prevailing winds, and other factors, exacerbate wildfire risks and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
c. If located in or near State responsibility areas or lands classified as very high fire hazard severity zones, would the project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment? 815 of 961

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d. If located in or near State responsibility areas or lands classified as very high fire hazard severity zones, would the project expose people or structures to significant risks, including downslopes or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?
The CAAP recognizes the risk that wildfires pose to Glendale and the likelihood of these risks to be exacerbated by climate change. As such, the CAAP includes measures and actions to reduce wildfire risks and community vulnerability to wildfire and post-wildfire hazards and improve the ability of the fire department and community to evacuate and respond to wildfire occurrences. These include CAAP Measures SG-1, SG-2, SG-5, BLD-1, BLD-3, BLD-4, MLS-2, UE-3, and UE-5. Measures SG-1, SG-2, and SG-5 would improve evacuation messaging and community awareness and provide resilience centers to assist during wildfire and other climate-hazard related events. Measure BLD-1 would implement increased vegetation clearance requirements for electrical infrastructure within fire hazard severity zones to reduce wildfire risk. Measures BLD-3 and BLD-4 would result in retrofits and requirements for new buildings within fire hazard zones to reduce vulnerability to wildfires.

Measure MLS-2 would result in improved emergency evacuation. Measure UE-3 would reduce the risk of wildfire through prescribed burns, brush clearance, and building hardening. Measure UE-5 would increase Glendale’s water system resilience and improve the City’s ability to respond to fire events. Additionally, the Safety Element Update, which was prepared concurrently with the CAAP, also includes policies and programs to reduce wildfire risks and community vulnerability to wildfire and post-wildfire hazards, and to improve the Fire Department and community ability to evacuate and respond to wildfire occurrences, such as Policies 4.1 – 4.9. Thus, the CAAP would result in no impact related to wildfire.

NO IMPACT
Cumulative Impacts
The cumulative projects scenario is the population, employment, households, and service population forecasts identified in the CAAP, based on demographic data contained in the SCAG RTP/SCS (refer to Table 6). Cumulative development anticipated to occur in Glendale could result in cumulative impacts related to wildfire if new development is added in areas of wildfire risk or downwind or downslope of such areas. However, implementation of the CAAP would have a less- than-significant contribution related to potential cumulative wildfire impacts, given that it does not include new habitable development that could be at risk from wildfire, nor does it grant entitlements for development that would have the potential to cause wildfire. Rather, the CAAP includes measures and actions that would reduce wildfire risk and post-wildfire hazards. As such, implementation of the CAAP would result in no cumulative impact related to wildfire. 816 of 961

Environmental Checklist
Mandatory Findings of Significance
Draft Initial Study-Negative Declaration 117
21 Mandatory Findings of Significance

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
significant
Impact
No
Impact
Does the project:
a. Have the potential to substantially degrade
the quality of the environment,
substantially reduce the habitat of a fish or
wildlife species, cause a fish or wildlife
population to drop below self-sustaining
levels, threaten to eliminate a plant or
animal community, substantially reduce
the number or restrict the range of a rare
or endangered plant or animal or eliminate
important examples of the major periods
of California history or prehistory? □ □ ■ □
b. Have impacts that are individually limited,
but cumulatively considerable?
(“Cumulatively considerable” means that
the incremental effects of a project are
considerable when viewed in connection
with the effects of past projects, the effects
of other current projects, and the effects of
probable future projects)? □ □ ■ □
c. Have environmental effects which will
cause substantial adverse effects on
human beings, either directly or indirectly? □ □ ■ □
a. Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? The intent of the CAAP is to reduce GHG emissions and community vulnerability to the impacts of climate change through implementation of measures and actions related to energy use, water consumption, transportation, solid waste, stormwater, vegetation management, and community education and outreach. The CAAP measures encourage residents, businesses, and municipal operations to reduce energy and water use, vehicle fuel consumption, VMT, and solid waste generation and the associated GHG emissions, as well as implement measures to adapt to and prepare for climate change-related hazards. The CAAP would not facilitate development that would degrade the quality of the environment (as addressed throughout this document), eliminate or threaten wildlife habitats or protected species (as addressed in Section 4, Biological Resources), or 817 of 961

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eliminate important examples of the major periods of California history or prehistory (as addressed in Section 5, Cultural Resources). Therefore, the CAAP would result in a less than significant impact.

LESS THAN SIGNIFICANT IMPACT
b. Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)?
As discussed throughout the respective cumulative impacts discussions within this document, the CAAP would not result in significant cumulative impacts. Rather, implementation of the CAAP would produce benefits related to GHG emissions, air quality, the transportation system, energy use, utility demands, wildfire and other climate hazard risks, and community resiliency. As addressed in each individual impact section above, the CAAP would result in an overall less than significant cumulative impact related to all CEQA topics addressed within this document.

LESS THAN SIGNIFICANT IMPACT
c. Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly?
In general, impacts to human beings are associated with air quality, GHG emissions and climate change, hazards and hazardous materials, noise, transportation, and wildfire impacts. As detailed in the preceding sections, the CAAP would not result, either directly or indirectly, in substantial adverse effects related to air quality, GHG emissions, hazards, noise, transportation, or wildfire. As discussed in more detail in Section 3, Air Quality, Section 13, Noise, and Section , the CAAP could cause temporary construction impacts related to transportation, air quality, and noise that could, in turn, affect human beings but would not result in substantial adverse effects. As discussed throughout, implementation of certain CAAP actions may require additional CEQA review once project specifications, such as site location, are identified and potential environmental impacts and impacts to human beings would be determined on a case-by-case basis. As discussed throughout this document, the CAAP would serve as a pathway to reduce operational GHG emissions and would result in other positive environmental and sustainability effects. These benefits include reduction in building energy and water consumption, VMT and traffic noise, and solid waste generation, as well as improved air quality and resiliency to the effects of climate change and natural disasters.

Therefore, the CAAP would result in a less than significant impact related to potential for adverse effects on human beings.

LESS THAN SIGNIFICANT IMPACT

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References
Draft Initial Study-Negative Declaration 119
Preparers
Rincon prepared this CAAP Initial Study under contract to the City of Glendale. Persons involved in data gathering, environmental impact analysis, quality review, graphics preparation, and document formatting include the following.

RINCON CONSULTANTS, INC.

Matt Maddox, Principal (Principal-in-Charge)
Kelsey Bennett, Director
Emily Marino, Senior Environmental Planner (Project Manager) Leslie Slayday, Senior Environmental Planner
Gina Gerlich, Graphics Specialist
Debra Jane Seltzer, Publishing Specialist
Yaritza Ramirez, Publishing Specialist
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Appendix A
Sources, Health Effects, and Typical Controls Associated with Criteria Pollutants

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Sources, Health Effects, and Typical Controls Associated with Criteria Pollutants

Draft Initial Study-Negative Declaration A-1
Sources, Health Effects, and Typical Controls Associated with Criteria Pollutants Pollutant Sources Health Effects Typical Controls
Ozone (O3) Formed when reactive organic
gases (ROG) and nitrogen
oxides react in the presence of
sunlight. ROG sources include
any source that burns fuels
(e.g., gasoline, natural gas,
wood, oil); solvents;
petroleum processing and
storage.

Breathing difficulties, lung
tissue damage, vegetation
damage, damage to rubber
and some plastics.

Reduce motor vehicle reactive
organic gas (ROG) and
nitrogen oxide (NOX) emissions
through emission standards,
reformulated fuels,
inspections programs, and
reduced vehicle use. Limit
ROG emissions from
commercial operations,
gasoline refueling facilities,
and consumer products. Limit
ROG and NOX emissions from
industrial sources such as
power plants and
manufacturing facilities.

Carbon monoxide
(CO)
Any source that burns fuel
such as automobiles, trucks,
heavy construction and
farming equipment, residential
heating.

Chest pain in heart patients,
headaches, reduced mental
alertness.

Control motor vehicle and
industrial emissions. Use
oxygenated gasoline during
winter months. Conserve
energy.

Nitrogen dioxide
(NO2)
See Carbon Monoxide. Lung irritation and damage.

Reacts in the atmosphere to
form ozone and acid rain.

Control motor vehicle and
industrial combustion
emissions. Conserve energy.

Sulfur dioxide
(SO2)
Coal or oil burning power
plants and industries,
refineries, diesel engines.

Increases lung disease and
breathing problems for
asthmatics. Reacts in the
atmosphere to form acid rain.

Reduce use of high sulfur fuels
(e.g., use low sulfur
reformulated diesel or natural
gas). Conserve energy.

Respirable
particulate matter
(PM10)
Road dust, windblown dust,
agriculture and construction,
fireplaces. Also formed from
other pollutants (NOX, SOX,
organics).

Increased respiratory disease,
lung damage, cancer,
premature death, reduced
visibility, surface soiling.

Control dust sources,
industrial particulate
emissions, woodburning
stoves and fireplaces. Reduce
secondary pollutants which
react to form PM10. Conserve
energy.

Fine particulate
matter (PM2.5)
Fuel combustion in motor
vehicles, equipment, and
industrial sources; residential
and agricultural burning. Also
formed from reaction of other
pollutants (NOX, SOX, organics,
and NH3).

Increases respiratory disease,
lung damage, cancer, and
premature death, reduced
visibility, surface soiling.

Particles can aggravate heart
diseases such as congestive
heart failure and coronary
artery disease.

Reduce combustion emissions
from motor vehicles,
equipment, industries, and
agricultural and residential
burning. Precursor controls,
like those for ozone, reduce
fine particle formation in the
atmosphere.

Lead Metal smelters, resource
recovery, leaded gasoline,
deterioration of lead paint.

Learning disabilities, brain and
kidney damage. Control metal
smelters.

No lead in gasoline or paint.

Sulfur Dioxide
(SO2)
Coal or oil burning power
plants and industries,
refineries, diesel engines.

Increases lung disease and
breathing problems for
asthmatics. Reacts in the
atmosphere to form acid rain.

Reduce use of high sulfur fuels
(e.g., use low sulfur
reformulated diesel or natural
gas). Conserve energy.

Sulfates Produced by reaction in the air
of SO2, (see SO2 sources), a
component of acid rain.

Breathing difficulties,
aggravates asthma, reduced
visibility.

See SO2
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Pollutant Sources Health Effects Typical Controls
Hydrogen Sulfide Geothermal power plants,
petroleum production and
refining, sewer gas.

Nuisance odor (rotten egg
smell), headache and
breathing difficulties (higher
concentrations).

Control emissions from
geothermal power plants,
petroleum production and
refining, sewers, and sewage
treatment plants.

Visibility Reducing
Particulates
See PM2.5 Reduced visibility (e.g.,
obscures mountains and other
scenery), reduced airport
safety.

See PM2.5
Vinyl Chloride Exhaust gases from factories
that manufacture or process
vinyl chloride (construction,
packaging, and transportation
industries).

Central nervous system effects
(e.g., dizziness, drowsiness,
headaches), kidney irritation,
liver damage, liver cancer.

Control emissions from plants
that manufacture or process
vinyl chloride, installation of
monitoring systems.

Toxic Air
Contaminant
(TAC)
Combustion engines
(stationary and mobile), diesel
combustion, storage and use
of TAC-containing substances
(i.e., gasoline, lead smelting,
etc.)
Depends on TAC, but may
include cancer, mutagenic
and/or teratogenic effects,
other acute or chronic health
effects.

Toxic Best Available Control
Technologies (T-BACT), limit
emissions from known
sources.

Source: Compiled by Rincon Consultants, Inc. in November 2024

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Appendix B
Description of Greenhouse Gases of California Concern

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Description of Greenhouse Gases of California Concern

Draft Initial Study-Negative Declaration B-i
Description of Greenhouse Gases of California Concern
Greenhouse Gas
Physical Description and
Properties
Global Warming
Potential
(100 years)
Atmospheric
Residence
Lifetime
(years) Sources
Carbon dioxide
(CO2)
Odorless, colorless, natural gas. 1 50–200 Burning coal, oil, natural gas, and wood; decomposition of
dead organic matter;
respiration of bacteria, plants,
animals, and fungus; oceanic
evaporation; volcanic
outgassing; cement
production; land use changes
Methane
(CH4)
Flammable gas and is the main
component of natural gas.
28 12 Geological deposits (natural
gas fields) extraction; landfills;
fermentation of manure; and
decay of organic matter
Nitrous oxide
(N2O)
Nitrous oxide (laughing gas) is a
colorless GHG.
298 114 Microbial processes in soil and
water; fuel combustion;
industrial processes
Chloro-fluoro-
carbons
(CFCs)
Nontoxic, nonflammable,
insoluble, and chemically
unreactive in the troposphere
(level of air at the Earth’s
surface); formed synthetically by
replacing all hydrogen atoms in
methane or ethane with
chlorine and/or fluorine atoms.
3,800–8,100 45–640 Refrigerants; aerosol
propellants; cleaning solvents
Hydro-fluoro-
carbons
(HFCs)
Synthetic human-made
chemicals used as a substitute
for CFCs and contain carbon,
chlorine, and at least one
hydrogen atom.
140 to 11,700 1–50,000 Automobile air conditioners;
refrigerants
Per-fluoro-
carbons (PFCs)
Stable molecular structures and
only break down by ultraviolet
rays about 60 kilometers above
Earth’s surface.
6,500 to 9,200 10,000–50,000 Primary aluminum production; semiconductor manufacturing
Sulfur
hexafluoride
(SF6)
Human-made, inorganic,
odorless, colorless, and
nontoxic, nonflammable gas.
22,800 3,200 Electrical power transmission
equipment insulation;
magnesium industry,
semiconductor manufacturing;
a tracer gas
Nitrogen
trifluoride
(NF3)
Inorganic, is used as a
replacement for PFCs, and is a
powerful oxidizing agent.
17,200 740 Electronics manufacture for
semiconductors and liquid
crystal displays
Source: Compiled by Rincon Consultants, Inc. in November 2024

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9b
25-88294

CITY OF GLENDALE, CALIFORNIA

REPORT TO THE CITY COUNCIL

AGENDA ITEM
Report: Ordinance amending Glendale Municipal Code section 10.24.020 to lower the posted speed limits on 21 roadway segments.

1. Ordinance amending Section 10.24.020 of the Glendale Municipal Code relating to prima facie speed limits on non-local city streets.

COUNCIL ACTION
Item Type: Action Item
Approved for August 12, 2025 calendar

EXECUTIVE SUMMARY
This report and the accompanying ordinance are presented for City Council consideration to lower the posted speed limits on 21 of 29 studied roadway segments based on findings from 2025 Engineering and Traffic Surveys (E&TS). The revised E&TS data indicate that certain street segments in Glendale now support a prima facie speed limit reduction. An amendment to Glendale Municipal Code section 10.24.020 is required to legally establish and enforce these new speed limits. Recent changes in state law (Assembly Bill 43) provide additional flexibility and policy support for these reductions by allowing local authorities to set safer speed limits where justified. Adoption of this ordinance will align the posted speeds with prevailing safe speeds in accordance with state law and engineering criteria.

RECOMMENDATION
That the City Council introduce and thereafter adopt an ordinance reflecting the following changes to Glendale Municipal Code section 10.24.020 relating to prima facie speed limits on non-local City streets, as shown in Exhibit A.

Eight other street segments were evaluated through an E&TS, with no changes made to the speed limit due to findings supporting the existing speed limit. 825 of 961

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ANALYSIS
Speed limits are set according to the guidelines of the California Manual on Uniform Traffic Control Devices (CA-MUTCD) and the California Vehicle Code (CVC). These guidelines specify that the posted speed limit should normally be established at the nearest 5 MPH increment to the measured 85th-percentile speed of free-flowing traffic.

The 85th-percentile speed is the speed at or below which 85% of vehicles are observed to travel under free-flow conditions. This metric typically lies about one standard deviation above the average speed and is commonly used as a threshold to define the upper limit of reasonable and prudent driving behavior. In cases where the speed limit should be rounded up to the nearest 5 MPH increment, a local authority may decide instead to round this value down to the lower 5 MPH increment. Additionally, if after completing an E&TS, a local authority finds that the speed limit is still more than is reasonable or safe, the local authority may determine and declare a prima facie speed limit that has been reduced an additional 5 MPH for either of the following reasons:

The portion of highway has been designated as a safety corridor; or The portion of highway is adjacent to any land or facility that generates high concentrations of bicyclists or pedestrians, especially those from vulnerable groups such as children, seniors, persons with disabilities, and the unhoused.

Exhibit B provides an example of a typical Engineering and Traffic Survey.

2025 E&TS Results and Implementation
The Public Works Department recently completed a new cycle of E&TSs for Glendale’s arterial and collector streets. There are a total of 95 street segments in the City of Glendale that require periodic E&TS updates for speed enforcement purposes. In the current ordinance, 83 street segments determine speed limits above 25 MPH and 12 street segments determine speed limits of 25 MPH. However, three 25 MPH street segments were inadvertently shown in the list of 83 street segments above 25 MPH; therefore, these street segments should be moved to the list of 25 MPH streets segments.

The three street segments are:

Chevy Chase Drive from Leith Road and Charing Cross Road – 25 mph Concord Street from Doran Street to Glenoaks Boulevard – 25 mph Lowell Avenue from Foothill Boulevard to Santa Carlotta Street – 25 mph

In 2025, 29 segments had surveys that expired or are due to expire and were re- surveyed to remain in compliance with the CVC and CA-MUTCD standards. Speed limits on eight street segments remain unchanged; however, 21 roadway segments qualify for speed limit reductions under the recent AB 43 amendments to the CVC. For these segments, the updated E&TSs support lowering the speed limits from the previously posted values.
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The 21 and 8 segments are shown, respectively, in the tables below.

Street From To Existing
Prima
Facie
Speed
Limit
Proposed
Prima
Facie
Speed
Limit

1. Boston Ave Foothill Blvd Markridge Rd 30 25

2. Brand Blvd Glenoaks Blvd Kenneth Rd 30 25

3. Central Ave San Fernando Rd Colorado St 35 30
*4. Chevy Chase Dr Glenoaks Blvd Leith Rd 30 25

5. Dunsmore Ave Foothill Blvd Markridge Rd 30 25

6. Flower St Air Way Allen Ave 30 25

7. Glendale Ave San Fernando Rd Chevy Chase Dr 30 25

8. Glendale Ave Colorado St Monterey Rd 30 25

9. Glenoaks Blvd Pacific Ave Brand Blvd 40 35

10. Glenoaks Blvd Avonoak Terrace Chevy Chase Dr 30 25
*11. Honolulu Ave La Crescenta Ave Orangedale Ave 35 30

12. Honolulu Ave Orangedale Ave Verdugo Rd 25 15

13. Lowell Ave 210 Freeway Foothill Blvd 30 25

14. Mountain St Verdugo Rd 2 Fwy 35 30

15. San Fernando Rd Spazier Ave Grandview Ave 35 30

16. San Fernando Rd Grandview Ave Goodwin Ave 35 30

17. Santa Carlotta St Lowell Ave Maryland Ave 30 25
*18. Verdugo Blvd Verdugo Rd East City Limit 35 30
*19. Verdugo Rd Chevy Chase Dr Glendale Ave 35 30
*20. Victory Blvd West City Limit East City Limit 35 30 *21. Western Ave South City Limit Lake St 30 25

*Location 4 proposed prima facie speed limit changed from 30 to 25 after supplemental staff review of the E&TS.

*Location 11 limits changed from Honolulu Ave between Las Palmas Ave & La Crescenta Ave to Honolulu Ave between La Crescenta Ave & Orangedale Ave.

*Location 18 limits changed from Verdugo Blvd between Verdugo Rd & Easterly City Limit to Verdugo Rd & East City Limit.

*Location 19 provides a correction for the street name of Glendale Avenue. Currently, the Glendale Municipal Code incorrectly identifies Glendale Avenue as Glendale Boulevard. 827 of 961

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*Location 20 limits changed from Victory Blvd between Westerly City Limit & Southerly City Limit to Victory Blvd between West City Limit & East City Limit

*Location 21 limits changed from Western Ave between Southerly City Limit & Lake St to South City Limit & Lake St.

Street From To Existing
Prima
Facie
Speed
Limit
Proposed
Prima
Facie
Speed
Limit

1. Brand Blvd Colorado St Broadway 25 25
*2. Camino San Rafael Calle Canta North City Limits 40 40 *3. Fern Ln Verdugo Rd East City Limits 30 30

4. Glenoaks Blvd Rossmoyne Ave Glendale Ave 25 25

5. Glenoaks Blvd Glendale Ave Avonoak Terrace 25 25

6. Glenwood Rd Grandview Ave School St 25 25

7. Grandview Ave Flower St Glenoaks Blvd 25 25

8. Pacific Ave Glenoaks Blvd Stocker St 25 25

*Location 2 provides a correction for the street name of Calle Canta. Currently, the Glendale Municipal Code incorrectly identifies Calle Canta as Calle Canto.

*Location 3 limits changed from Fern Lane between Verdugo Rd & Easterly City Limit to Verdugo Rd & East City Limit.

To legally enforce the new speed limits on the 21 segments using radar or lidar, the City must amend its ordinance to reflect the updated survey results. The roadway segments proposed for speed limit reductions are listed in the first table above. Exhibit A also incorporates corrections for the three 25 MPH street segments listed above.

Another component of the E&TS is the three-year reported collision rates. Actual collision rates are compared to expected rates when assessing whether to adjust or retain speed limits. The expected rates are based on statewide averages, while actual rates are calculated using collision counts, average daily traffic (ADT), and segment lengths. A summary of both expected and actual collision rates for all 29 segments is listed in Exhibit C.

With the proposed amendments to the ordinance, there are 69 street segments determined to have speed limits above 25 MPH, 25 streets with speed limits of 25 MPH, and one street segment with a speed limit of 15 MPH.

The City will install updated speed limit signs to provide drivers with speed information that reflects current roadway conditions and implement traffic signal timing modifications to accommodate the changes in speed limits.
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There will be a one-time estimated cost of $75,000 to replace existing speed limit signs ($25,000) and modify traffic signal timing parameters ($50,000) at traffic signal intersection along the affected street segments.

STAKEHOLDERS/OUTREACH
The Transportation and Parking Commission (TPC) had a public meeting on June 23, 2025, to discuss the proposed posted speed limit changes. There was no public opposition and the TPC unanimously passed a motion recommending the City Council to adopt an ordinance amending Glendale Municipal Code Section 10.24.020 as shown in Exhibit A.

The Public Works Department has coordinated with the Glendale Police Department – Traffic Bureau regarding the proposed posted speed limit changes.

FISCAL IMPACT
The one-time estimated cost to replace existing speed limit signs and modify traffic signal timing parameters will cost $75,000, which was included as a part of the FY 2025-26 budget. No new appropriation is being requested at this time.

Existing Appropriation
Amount Account String Funding Source
$50,000 43110-1010-PWD-7516 General Fund
$25,000 45350-1010-PWD-7517 General Fund

ENVIRONMENTAL REVIEW (CEQA/NEPA)
The activity under consideration is not a “project” within the meaning of CEQA. Pursuant to CEQA Guidelines section 15378(b)(2), the term “project” does not include continuing administrative or maintenance activities, including general policy or procedure making (except as applied to specific instances not germane to this Ordinance). Even if it is a “project,” this activity is categorically exempt pursuant to CEQA Guidelines section 15301, in that it consists of the operation, maintenance, or minor alteration of existing public facilities or topographical features, namely, existing streets, involving negligible or no expansion of former use. In any event, it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment; thus, it is exempt from CEQA pursuant to CEQA Guidelines section 15061(b)(3).

CAMPAIGN DISCLOSURE
This item is exempt from campaign disclosure requirements.

ALTERNATIVES TO STAFF RECOMMENDATION
Alternative 1: Do not introduce and adopt the ordinance amending Glendale Municipal Code related to prima facie speed limits on non-local City Streets. No change would be made to the posted speed limits, which are not supported 829 of 961

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by the latest E&TS; thus, the City would forgo the potential safety benefits of the proposed reductions. Enforcement of the speed limits would also be challenging given they are not supported by the E&TS.

Alternative 2: The City Council may consider any other alternative not proposed by staff.

ADMINISTRATIVE ACTION
Submitted by:

Daniel Hernandez, Director of Public Works
Prepared by:

Carlos Cortez, Civil Engineering Assistant
Pastor Casanova, T.E., Principal Traffic Engineer
Arek Harmandayan, T.E., Senior Traffic Engineer
Approved by:

Roubik R. Golanian, P.E., City Manager

EXHIBITS/ATTACHMENTS
Exhibit A – 10.24.020 Prima Facie Speed Limits on Non-Local City Streets Exhibit B – Typical Engineering and Traffic Survey Example Exhibit C – Collision Rates
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4 ORDINANCE NO. _______

AN ORDINANCE OF THE COUNCIL OF THE CITY OF GLENDALE, CALIFORNIA, AMENDING SECTION 10.24.020 OF THE GLENDALE MUNICIPAL CODE, 1995,

RELATING TO PRIMA FACIE SPEED LIMITS ON NON-LOCAL CITY STREETS WHEREAS, Title 10 of the Glendale Municipal Code, 1995, provides standards for vehicle and traffic regulation within the City of Glendale; and WHEREAS, such standards include prima facie speed limits on non-local city streets under section 10.24.020; and
WHEREAS, based upon the California Vehicle Code and California Manual on Uniform Traffic Control Devices, the prima face speed limits on certain street segments within the City of Glendale are eligible for revision due to recent Engineering and Traffic Surveys; and
WHEREAS, the revisions in this Ordinance are consistent therewith and in the best interest of the City of Glendale.

NOW, THEREFORE, BE IT ORDAINED BY THE COUNCIL OF THE CITY OF GLENDALE:

SECTION 1. The above recitals are true and correct.

SECTION 2. Section 10.24.020 of the Glendale Municipal Code, 1995, is hereby amended to read as follows:

10.24.020 Prima facie speed limits on non-local city streets.

A. It is determined that upon the basis of an engineering and traffic survey that a speed limit greater than 25 miles per hour would facilitate the orderly movement of vehicular traffic and would be reasonable and safe upon the following non-local city streets, other than state highways, which streets would otherwise be subject to a prima facie speed limit permitted by state law of 25 miles per hour and maximum speed limit of 65 miles per hour. Upon the erection of appropriate signs giving notice thereof on streets or parts of streets, the prima facie speed limits shall be as set forth herein. This section does not apply to any 25 mile per hour prima facie limit which is applicable when passing a school building or the grounds thereof or when passing a senior center or other facility primarily used by senior citizens.

Street From To
Prima Facie
Speed Limit

1. Arden Ave. Pacific Ave. Central Ave. 30

2. Broadway. San Fernando Rd. Central Ave. 35
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4 Street From To
Prima Facie
Speed Limit

3. Broadway. Central Ave. Glendale Ave. 30

4. Broadway. Glendale Ave. Wilson Ave. 30

5. Camino San Rafael. Foxkirk Rd. Calle Canta 30

6. Camino San Rafael. Calle Canta North City Limit 40

7. Canada Blvd. Verdugo Rd. Menlo Dr. 35

8. Central Ave. San Fernando Rd. Colorado St. 30

9. Central Ave. Colorado St. Glenoaks Blvd. 35

10. Central Ave. Glenoaks Blvd. Loraine St. 30

11. Central Ave. Loraine St. Kenneth Rd. 30

12. Chevy Chase Dr. West City Limits Glendale Ave. 35

13. Chevy Chase Dr. Glendale Ave. Acacia Ave. 35

14. Chevy Chase Dr. Acacia Ave. Glenoaks Blvd. 30

15. Colorado St. Westerly City Limit Glendale Ave. 35

16. Colorado St. Glendale Ave. East City Limit 35

17. Columbus Ave. Colorado St. Broadway 35

18. Concord St. Doran St. Glenoaks Blvd. 30

19. Fern Lane. Verdugo Rd. East City Limit 30

20. Foothill Blvd. Lowell Ave. Pennsylvania Ave. 40

21. Glendale Ave. Chevy Chase Dr. Colorado St. 30

22. Glendale Ave. Monterey Rd. Verdugo Rd. 35

23. Glenoaks Blvd. Alameda Ave. Highland Ave. 40

24. Glenoaks Blvd. Highland Ave. Pacific Ave. 40

25. Glenoaks Blvd. Pacific Ave. Brand Blvd. 35

26. Glenoaks Blvd. Brand Blvd. Geneva St. 35

27. Glenoaks Blvd. Chevy Chase Dr. Scholl Dr. 30

28. Glenoaks Blvd. Scholl Dr. Sleepy Hollow Dr. 30

29. Harvey Dr. Broadway Chevy Chase Dr. 35

30. Highland Ave. San Fernando Rd. Glenoaks Blvd. 30

31. Highland Ave. Glenoaks Blvd. Glenwood Rd. 30

32. Honolulu Ave. La Crescenta Ave. Orangedale Ave. 30

33. Honolulu Ave. La Crescenta Ave. Pennsylvania Ave. 35

34. Honolulu Ave. Pennsylvania Ave. Boston Ave. 35
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4 Street From To
Prima Facie
Speed Limit

35. Honolulu Ave. Boston Ave. Lowell Ave. 35

36. La Crescenta Ave. Verdugo Rd. Shirlyjean St. 40

37. La Crescenta Ave. Shirlyjean St. Montrose Ave. 40

38. Los Feliz Rd. Westerly City Limit Glendale Ave. 35

39. Montrose Ave. Raymond Ave. Ramsdell Ave. 30

40. Mountain St. Verdugo Rd. 2 Fwy 30

41. New York Ave. Foothill Blvd. Santa Carlotta St. 30

42. Ocean View Blvd. Verdugo Rd. North City Limit 30

43. Pacific Ave. San Fernando Rd. Colorado St. 30

44. Pacific Ave. Colorado St. Glenoaks Blvd. 30

45. Pennsylvania Ave. Honolulu Ave. 210 Fwy 35

46. Pennsylvania Ave. 210 Fwy Foothill Blvd. 35

47. Pennsylvania Ave. Foothill Blvd. Markridge Rd. 35

48. Riverside Dr. Westerly City Limit Southerly City Limit 35

49. Royal Blvd. Mountain Ave. Arboles Dr. 30

50. San Fernando Rd. Spazier Ave. Grandview Ave. 30

51. San Fernando Rd. Grandview Ave. Goodwin Ave. 30

52. San Fernando Rd. Goodwin Ave. Rosslyn St. 35

53. Sonora Ave. Garden St. Lake St. 35

54. Sonora Ave. Lake St. San Fernando Rd. 35

55. Verdugo Blvd. Verdugo Rd. East City Limit 30

56. Verdugo Rd. Glendale Ave. Mountain St. 40

57. Verdugo Rd. Mountain St. Canada Blvd. 40

58. Verdugo Rd. Canada Blvd. (South) Menlo Dr. 35

59. Verdugo Rd. Menlo Dr. La Crescenta Ave. 40

60. Verdugo Rd. La Crescenta Ave. Honolulu Ave. 35

61. Verdugo Rd. Hilda Ave. Colorado St. 35

62. Verdugo Rd. Colorado St. Chevy Chase Dr. 35

63. Verdugo Rd. Chevy Chase Dr. Glendale Ave. 30

64. Victory Blvd. West City Limit East City Limit 30

65. Western Ave. Lake St. Glenoaks Blvd. 35

66. Wilson Ave. Central Ave. Glendale Ave. 30
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4 Street From To
Prima Facie
Speed Limit

67. Wilson Ave. Glendale Ave. Broadway 30

68. Fairmont Ave. Concord St. 134 FWY Ramps 30

69. Fairmont Ave. Flower St. 134 FWY Ramps 35
B. The prima facie speed limits for the following non-local city streets are hereby continued at 25 miles per hour.

Street From To
Prima Facie
Speed Limit

1. Boston Ave. Foothill Blvd. Markridge Rd. 25

2. Brand Blvd. Southerly City Limit Colorado St. 25

3. Brand Blvd. Colorado St. Broadway 25

4. Brand Blvd. Broadway Milford St. 25

5. Brand Blvd. Milford St. Glenoaks Blvd. 25

6. Brand Blvd. Glenoaks Blvd. Kenneth Rd. 25

7. Chevy Chase Dr. Glenoaks Blvd. Leith Rd. 25

8. Chevy Chase Dr. Leith Rd. Charing Cross Rd. 25

9. Concord St. Broadway Doran St. 25

10. Dunsmore Ave. Foothill Blvd. Markridge Rd. 25

11. Flower St. Air Way Allen Ave. 25

12. Glendale Ave. San Fernando Rd. Chevy Chase Dr. 25

13. Glendale Ave. Colorado St. Monterey Rd. 25

14. Glenoaks Blvd. Rossmoyne Ave. Glendale Ave. 25

15. Glenoaks Blvd. Glendale Ave. Avonoak Terrace 25

16. Glenoaks Blvd. Avonoak Terrace Chevy Chase Dr. 25

17. Glenwood Rd. Grandview Ave. School St. 25

18. Grandview Ave. Flower St. Glenoaks Blvd. 25

19. Lowell Ave. 210 Freeway Foothill Blvd. 25

20. Lowell Ave. Foothill Blvd. Santa Carlotta St. 25

21. Pacific Ave. Glenoaks Blvd. Stocker St. 25

22. Pacific Ave. Stocker St. Kenneth Rd. 25

23. Santa Carlotta St. Lowell Ave. Maryland Ave. 25

24. Western Ave. South City Limit Lake St. 25
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4 Street From To
Prima Facie
Speed Limit

25. Maginn Dr. Pacific Ave. Maginn Pl. 25
C. The prima facie speed limits for the following non-local city streets are hereby determined to be 15 miles per hour.

Street From To
Prima Facie
Speed Limit

1. Honolulu Ave. Orangedale Ave. Verdugo Rd. 15
SECTION 3. Compliance with California Environmental Quality Act. The City Council finds and determines that this Ordinance is not subject to the California Environmental Quality Act (“CEQA”) because it is not a “project” within the meaning of CEQA. Pursuant to section 15378, subdivision (b)(2), of Division 6 of Title 14 of the California Code of Regulations (the “CEQA Guidelines”), the term “project” does not include continuing administrative or maintenance activities, including general policy or procedure making (except as applied to specific instances not germane to this Ordinance).

Even if it is a “project,” the City Council finds and determines that this Ordinance is categorically exempt from CEQA pursuant to CEQA Guidelines section 15301 in that it consists of the operation, maintenance, or minor alteration of existing public facilities or topographical features, namely, existing streets, involving negligible or no expansion of existing or former use. Moreover, the City Council finds and determines with certainty that there is no possibility that the activity in question may have a significant effect on the environment; thus, it is exempt from CEQA pursuant to CEQA Guidelines section 15061, subdivision (b)(3).

SECTION 4. Severability. This Ordinance is adopted under the authority of the Charter of the City of Glendale and state law. If any section, subsection, clause or phrase is declared invalid or otherwise void by a court of competent jurisdiction, it shall not affect any remaining provisions hereof. In this regard, the City Council finds and declares that it would have adopted this measure notwithstanding any partial invalidity hereof.

SECTION 5. Effective Date. This Ordinance shall take effect and be in force thirty (30) days after the date of its passage.

Passed and adopted by the Council of the City of Glendale on the _____ day of _______________, 2025.
____________________________
Mayor
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4 ATTEST:
_________________________
City Clerk
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4 STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES ) SS.

CITY OF GLENDALE )
I, Suzie Abajian Ph.D., City Clerk of the City of Glendale, certify that the foregoing Ordinance No. ___________ was passed by a majority vote of the Council of the City of Glendale, California, at a regular meeting held on the _____ day of _____________, 2025, and that the same was passed by the followed vote.

Ayes:

Noes:

Absent:

Abstain:
______________________________
City Clerk
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EXHIBIT B
Street From To Jurisdiction
Findings
Roadway Conditions
Street Classification:

Roadway Separation: Double yellow centerline Dashed centerline Two-way left-turn lane Raised median Other: ______________
Alignment:

Grade:

Adjacent Land Use:

Parking Restrictions:

Parking Activity:

Development Type:

Prior Speed Limit:

Speed Survey Information
Direction (NB/EB): Direction (SB/WB):
85th % Speed (MPH): 85th % Speed (MPH):

Date of Speed Survey: Date of Speed Survey:

Time of Speed Survey: Time of Speed Survey:

Location of Survey: Location of Survey:

Sample Size (Count): Sample Size (Count):

Pace Speed (MPH): Pace Speed (MPH):
0 MPH
0 MPHRounded 85th Percentile Speed both directions:

No Parking (anytime)
Parking Type:

Stop Signs
Street Lighting
Traffic Signals
Roadside Features: Sidewalks
Level
Notable horizontal curves
Rolling/Variable
Notable vertical curves
Steep grades present
Parking Lanes/Shoulder
Curb and Gutter Bike Lanes
Guardrail/Barriers
Other: _____________
No Stopping (anytime) Time-limited
Street sweeping hours None/Unrestricted Other: _____________ City of Glendale - Engineering and Traffic Survey
Average 85th Percentile Speed both directions:

Segment Length (Miles):Street Width (ft.):

Number of Lanes (Total):

Glendale
Residential Commercial Industrial
School Zone Park or Recreation
Recommended Posted Speed Limit
## MPH
## MPH
Other: _____________
Predominantly straight
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EXHIBIT B
Collision History / Traffic Volumes
Average Daily Traffic (ADT):
vehicles per day (VPD)
Actual Collision Rate:
#DIV/0! collisions per million vehicle-miles (C/MVM)
*Expected Collision Rate:
collisions per million vehicle-miles (C/MVM)
Special Considerations
Land or Facilities that Generate High Concentrations of Bicyclists and Pedestrians: Yes No Vulnerable Pedestrian Groups: Yes No
Conditions Not Readily Apparent to Drivers: Yes No Speed Reductions
Comments:

Approved by: Prepared by:

Signature: Date:

Date:

Notes
Senior Centers
Shared Use Paths Other: _________________________________ Residence District CVC 515 Designated Safety Corridor School Zone Transit Hubs Commercial Districts
Park or Recreation
Children Persons with Disabilities Other: _____________ #/#/2021 to #/#/2024
Numerous Driveways Mid-block Crossings Limited Sight Distances Other: _____________ CVC 22358.6 (a) CVC 22358.6 (b)
CVC 22358.6 (c) CVC 22358.7
Seniors
CVC 22358.8
Collision Reporting Period:

Number of Reported Collisions:
###
Civil or Traffic Engineer
CVC 22358.9
*Expected collision rates are obtained from
State averages.
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Exhibit C: Collision Rates

SEGMENTS WITH CHANGES TO THE SPEED LIMIT
Street From To
Expected
Collision
Rates*
Actual
Collision
Rates*

1. Boston Ave Foothill Blvd Markridge Rd 1.07 0.34

2. Brand Blvd Glenoaks Blvd Kenneth Rd 0.99 1.83

3. Central Ave San Fernando Rd Colorado St 1.33 1.96

4. Chevy Chase Dr Glenoaks Blvd Leith Rd 1.07 1.44

5. Dunsmore Ave Foothill Blvd Markridge Rd 1.07 0.00

6. Flower St Air Way Allen Ave 1.33 0.75

7. Glendale Ave San Fernando Rd Chevy Chase Dr 1.33 1.53

8. Glendale Ave Colorado St Monterey Rd 1.33 1.71

9. Glenoaks Blvd Pacific Ave Brand Blvd 0.99 1.12

10. Glenoaks Blvd Avonoak Terrace Chevy Chase Dr 1.07 1.62

11. Honolulu Ave La Crescenta Ave Orangedale Ave 1.33 1.76

12. Honolulu Ave Orangedale Ave Verdugo Rd 1.07 1.51

13. Lowell Ave 210 Freeway Foothill Blvd 1.07 0.66

14. Mountain St Verdugo Rd 2 Fwy 1.33 1.48

15. San Fernando Rd Spazier Ave Grandview Ave 1.33 1.65

16. San Fernando Rd Grandview Ave Goodwin Ave 0.99 1.30

17. Santa Carlotta St Lowell Ave Maryland Ave 1.07 0.47

18. Verdugo Blvd Verdugo Rd East City Limit 1.33 0.97

19. Verdugo Rd Chevy Chase Dr Glendale Ave 1.33 1.51

20. Victory Blvd West City Limit East City Limit 1.33 1.13

21. Western Ave South City Limit Lake St 1.07 0.98
* Collisions per million vehicle-miles (C/MVM)
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SEGMENTS WITH NO CHANGES TO THE SPEED LIMIT
Street From To
Expected
Collision
Rates*
Actual
Collision
Rates*

1. Brand Blvd Colorado St Broadway 0.99 1.54

2. Camino San Rafael Calle Canta North City Limits 1.07 0.00

3. Fern Ln Verdugo Rd East City Limits 1.07 0.38

4. Glenoaks Blvd Rossmoyne Ave Glendale Ave 1.07 0.38

5. Glenoaks Blvd Glendale Ave Avonoak Terrace 1.07 1.35

6. Glenwood Rd Grandview Ave School St 1.07 1.29

7. Grandview Ave Flower St Glenoaks Blvd 1.33 3.05

8. Pacific Ave Glenoaks Blvd Stocker St 1.07 1.27
*Collisions per million vehicle-miles (C/MVM)
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CITY OF GLENDALE, CALIFORNIA

REPORT TO THE CITY COUNCIL

AGENDA ITEM
Report: Residential Air Conditioner to Heat Pump Replacement (AC2HP) Reach Code.

1. Motion directing staff to prepare and return to introduce a reach code for existing single-family buildings that would require installation of a heat pump as the primary heating source, or other energy conservation improvements, in cases where an existing air conditioning system is altered or replaced, or where an air conditioning system is added.

COUNCIL ACTION
Item Type: Action Item
Approved for August 12, 2025 calendar

EXECUTIVE SUMMARY
The City of Glendale has developed and implemented a series of “Reach Codes” designed to advance building electrification, photovoltaic (PV) deployment, and electric vehicle (EV) infrastructure. These codes go beyond minimum state requirements and aim to reduce greenhouse gas (GHG) emissions, improve public health, and modernize building systems.

In 2022, Glendale adopted Reach Codes requiring all-electric construction for new buildings, including ADUs, with limited exemptions; PV systems for new non-residential and multifamily buildings; and EV charging infrastructure for a range of new residential and non-residential construction.

However, due to a 2023 federal court decision striking down Berkeley’s natural gas ban for violating the federal Energy Policy and Conservation Act (EPCA), Glendale suspended enforcement of the all-electric new construction requirement in June 2024 while continuing to enforce PV and EV provisions. In April 2025, the City Council directed staff to evaluate a new reach code referred to as the Air Conditioner to Heat Pump (AC2HP) Reach Code applicable to existing single-family homes. 842 of 961

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This proposed reach code specifies that when an air conditioning (AC) system is replaced or added, the homeowner must either:

1. Install a heat pump as the primary heating source; or

2. Implement alternative energy conservation upgrades, such as improved insulation, air sealing, and duct sealing.

The proposed reach code would not preclude mixed-fuel residential construction in violation of federal law.

Legal and Timing Considerations
Due to the passage of AB 130 in June 2025, commencing on September 30, 2025, AB 130 limits cities and counties from adopting local amendments (such as this reach code) to the residential building code through 2031, except under certain limited conditions. In light of these limitations, cities seeking to implement reach codes have the option of amending the existing 2022 Building Standards Code to add the new reach code before September 30, 2025, and later include the reach code in the 2025 Building Standards Code being adopted later this year based on the reach code being “substantially equivalent” to prior changes that were “in effect” as of September 30, 2025.

The second option is to include the proposed reach code in the 2025 Building Standards Code adoption process scheduled to occur before the end of 2025. The second option requires the City to show that the proposed changes are: i) “necessary to implement a local code amendment that is adopted to align with a general plan approved on or before June 10, 2025”, ii) that “permits mixed fuel residential construction consistent with federal law”, e.g. compliance with the federal Energy Policy and Conservation Act, and iii) incentivizes “all-electric construction as part of an adopted greenhouse gas emissions reduction strategy”.

Since AB 130 is new law, both these options are based on our current understanding of AB 130, but are untested. With respect to Option 1 (amending the 2022 Building Standards Code), there is time to introduce and adopt the reach code by August 26, 2025; however, if the reach code is scheduled for adoption after August 30, 2025, it would need to be adopted on an urgency basis in order to be effective before September 30, 2025.
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RECOMMENDATION
The City Council direct staff to prepare and introduce a reach code for existing single- family homes that would require installation of a heat pump as the primary heating source, or other energy conservation improvements, in cases where an existing air conditioning system is altered or replaced, or where an air conditioning system is added.

ANALYSIS
In 2022, the City hired Rincon Consultants to develop building electrification, photovoltaic (PV), and electric vehicle (EV) charging Reach Codes, which were adopted through a local amendment to the 2022 California Building and Energy Code.

The reach codes required the following:

1. Building Electrification: All new construction (including standalone accessory dwelling units (ADUs)) must be all-electric with limited exemptions and subject to an infeasibility waiver.

2. PV Infrastructure: Require non-residential and multifamily PV systems to be installed on all new buildings to offset 100 percent of projected electricity use or cover at least 50 percent of rooftop space and include an infeasibility waiver for projects unable to meet the requirement due to shading or other technical constraints.

3. EV Charging Infrastructure: Require EV charging infrastructure for new single- and multifamily dwellings, townhouses with attached private garages, multifamily dwellings with residential parking facilities, and new non-residential construction, with limited exceptions and subject to an infeasibility waiver.

At the November 1, 2022, City Council meeting, the ordinance was introduced with modifications to specific definitions and the EV infeasibility waiver process. The City Council subsequently adopted the Reach Code ordinance on November 15, 2022.

In 2019, the California Restaurant Association (CRA) sued the City of Berkeley over its ordinance banning the use of fuel gas piping in new buildings. A three-judge panel of the 9th Circuit Federal Appeals Court struck down Berkeley's ordinance in April 2023, agreeing with the CRA that the city overstepped the federal Energy and Policy Conservation Act when it passed the ban in 2019.

In 2024, the 9th Circuit declined to reconsider the decision rejecting the Berkeley, California, natural gas ban. As a result, several Cities that had natural gas bans or ordinances for new construction either halted the enforcement of the ordinance, considered alternatives, or continued with enforcement. 844 of 961

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In response to the 9th Circuit's decision, on June 4, 2024, the City Council directed staff to suspend enforcement of those portions of Ordinance No. 5999 that require all newly constructed buildings in Glendale to be "All-Electric." All other provisions of Ordinance No. 5999, including but not limited to those pertaining to photovoltaic requirements and EV charging, as well as all requirements in the California Building Code and/or the California Energy Code regarding electric readiness, continue to be enforced.

In April 2025, the City Council requested that staff prepare a report on the potential for adopting a reach code that requires installation of either a heat pump as the primary heating source or make other energy conservation improvements for existing single- family buildings in which an existing air conditioning system is altered or replaced, or where an air conditioning system is added.

State Law Requirements
The California Building Standards Code (CBSC), also known as Title 24 of the California Code of Regulations, is a comprehensive set of regulations that govern building design and construction in California (“Title 24”). It encompasses various parts that address different aspects, including building, residential, electrical, mechanical, plumbing, energy, fire, and green building standards. The CBSC is periodically updated, with the 2025 edition published on July 1, 2025, and effective January 1, 2026.

The code proposed by the State, or the base code, includes several provisions related to energy efficiency and electrification readiness for new single-family residential construction that will take effect regardless of any action by the City. These include:
Heat pumps for space conditioning and water heating
Solar requirements;
Battery readiness;
Electric vehicle (EV) charging readiness;
Pre-wiring for electric appliances when installing gas; and Higher minimum energy performance scores.

The California Health and Safety Code enables local jurisdictions to modify the base code and adopt different or more restrictive requirements with the caveat that the local modifications must be substantially equivalent to, or more stringent than, the building standards published in the CBSC; the local jurisdiction is required to make findings that such changes are reasonably necessary because of local geological, climatic or topographic conditions; and adopt a determination that the amendments will be cost- effective.
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Newly adopted State legislation (AB 130) and Critical Timing Impacting Adoption of Local Reach Code Amendments to the Residential Building Code On June 30, 2025, the Legislature adopted, and the Governor signed into law, Assembly Bill (AB) 130 (formerly AB 306); AB 130 became immediately effective.

Among other things, AB 130 restricts local jurisdictions from adopting local amendments to the residential building code for the next two code cycles, between October 1, 2025, and June 1, 2031, subject to six (6) limited exceptions, including changes related to home hardening and health safety, or where the changes are “substantially equivalent” to changes previously adopted that “were in effect” as of September 30, 2025, or where there is consistency with certain general plan policies.

The City Attorney's Office has reviewed the various implications of AB 130, including on how the City may proceed with adopting an AC2HP reach code. As indicated above, the City may as part of the 2025 Building Standards Code adopt a reach code that encourages the use of a heat pump or dual-fuel system, which includes a heat pump combined with a furnace, when an air conditioner is replaced or installed in existing single-family homes if the proposed local changes are “substantially equivalent to changes or modification that were previously filed [with the California Building Standards Commission] by the governing body of the city or county and were in effect as of September 30, 2025” (Emphasis added).(AB 130, Section 29, amending Health & Safety Code §17958(b)(1)). However, to meet the “substantially equivalent” standard, the City would first need to amend the existing 2022 Building Standards Code as follows:

Option 1: Amend the existing 2022 Building Standards Code to add the reach code so that it “will be in effect” before September 30, 2025. Then, when the City adopts the 2025 Building Standards Code later this year, the City can use an AB 130, exception (Health & Safety Code section 17958(b)(1)) to adopt the reach code as part of the 2025 Building Standards Code (Energy Code component) with a finding that “substantially equivalent” to the one in effect before September 30, 2025. (Exception No. 1)
Option 2: Adopt the 2025 Building Standards Code (or at least the Energy Code component) using the AB 130 exception (Health & Safety Code section 17958(b)(5)) that allows for changes or modifications that “are necessary to implement a local code amendment that is adopted to align with a general plan approved on or before June 10, 2025, and that permits mixed-fuel residential construction consistent with federal law while also incentivizing all-electric construction as part of an adopted greenhouse gas emissions reduction strategy.” (Exception No. 5) 846 of 961

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It is important to note that the reach code would be submitted simultaneously to both the CEC and CBSC. The reach code could not be enforced until CEC and CBSC approval is obtained. Typically, the California Energy Commission (CEC) would review and approve proposed amendments before they are submitted to the CBSC for review and approval. However, there is no statutory requirement that local energy standards must be first filed with and approved by the CEC, and there are no statutory regulations that appear to preclude filing the proposed local changes with the CEC and CBSC at the same time. Importantly, CBSC “approval” is not required in order for the CEC approved local changes to become effective, but the CBSC approval is required before the local jurisdiction can enforce the new local standards.

The AC2HP Reach Code Could Comply with two of the AB 130 Exceptions A “belt and suspenders” approach would be to amend the 2022 Building Standards Code to include the new reach code and “readopt” the reach codes as part of the 2025 Building Standards Code based on the “substantially equivalent” finding (Exception No. 1 discussed above), and also make findings in conjunction with the 2025 Building Standards Code adoption that the changes qualify for each of the three components of Exception No. 5 as follows:

1. The reach code will align with a general plan approved on or before June 10, 2025. The City adopted the current Safety Element of the General Plan on April 1, 2025. The 2025 Safety Element, Policy 5-2: Building Resilience, specifically states that the City shall amend the building code to increase the resiliency of existing and new buildings, thereby protecting residents from the impacts of extreme heat and poor air quality. The 2025 Safety Element, Program 5-2.3, specifies that the City shall consider amending the building code to require all newly installed HVAC units for existing buildings to have two-way air conditioning unit capability to provide heating and cooling by the next CBC update cycle. Adopting an AC2HP reach code is consistent with the 2025 General Plan Safety Element; it can help Glendale achieve its climate goals, improve public health, and modernize infrastructure.

2. The reach code is consistent with EPCA because it “permits mixed-fuel residential construction”. In other words, compliance with the AC2HP reach code does not preclude a residential property owner from using natural gas, which was the issue in the Berkeley case.

3. The reach code will incentivize all-electric construction as part of an adopted greenhouse gas emissions reduction strategy. The City adopted the Greener Glendale Plan in 2012. The Greener Glendale Plan has strategies to reduce GHGs which include reduction in citywide energy consumption by facilitating permitting and construction of alternative building structures, materials and site 847 of 961

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location; retrofitting existing development for increased energy and water efficiency, and promoting and supporting use of renewable energy. The AC2HP reach code are consistent with these strategies because they can reduce greenhouse gas emissions by replacing fossil fuel-based heating systems with electric heat pumps. Staff has reviewed studies that show AC2HP upgrades increase efficiency and are cost-effective over the system's lifecycle, especially when factoring in utility incentives and future energy savings. Electrification also reduces fire hazards associated with gas lines and appliances, enhancing community resilience.

How AC2HP works: Basic Principle
A two-way heat pump operates on the principle of the refrigeration cycle, utilizing a compressor, expansion valve, refrigerant, and two heat exchangers (one located indoors and one outdoors). It operates in two modes:

Cooling Mode (like an air conditioner)

1.Indoor Air is Warm: Warm indoor air is blown over the indoor coil, where the refrigerant absorbs heat.

2.Refrigerant is Compressed: The refrigerant is then compressed, raising its temperature and pressure.

3.Heat is Released Outside: The hot refrigerant travels to the outdoor coil, where it releases heat into the outdoor air.

4.Cooled Air Returned Indoors: The refrigerant cools down, flows back indoors, and the cycle repeats.

Result: Heat is removed from the inside and expelled outdoors, cooling a home.

Heating Mode (reverse operation). A reversing valve flips the direction of refrigerant flow.

1.Outdoor Air is Cool. Even in cold air, there's thermal energy. The refrigerant in the outdoor coil absorbs this heat.

2.Refrigerant is Compressed: The refrigerant is compressed, causing a significant increase in its temperature.

3.Heat is Released Indoors: The hot refrigerant flows to the indoor coil, releasing its heat to warm your home.

4.Cycle Repeats: Cooled refrigerant flows back outside to pick up more heat.

Result: Heat is extracted from outdoor air and transferred indoors, heating a home. 848 of 961

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Key Components
Compressor: Pressurizes the refrigerant to move heat.
Reversing Valve: Switches the direction of refrigerant flow between heating and cooling modes.
Expansion Valve: Reduces refrigerant pressure before it enters the evaporator coil.
Coils: Act as evaporators or condensers depending on the mode.

Diagram 1: Heat Pump Process
Ordinance Pathways
The ordinance structure is based on the voluntary requirements adopted in 2025 Title 24, Part 11, California Green Building Standards Code (CALGreen), Section A4.204.1.1 for heat pump space conditioning alterations in single-family homes (California Energy Commission, 2025). The heat pump path requires the heat pump as the primary heat source, with backup heating allowable, either provided by electric resistance or natural gas. In cases where the existing furnace remains, the heat pump is installed alongside the existing furnace, with integrated controls that allow the furnace to provide backup heating. In alignment with the 2025 Energy Code requirements, the heat pump must be sized to meet the heating load at the design heating temperature without requiring backup heat. The proposed ordinance provides alternative pathways for residents who prefer to replace their air conditioner with similar equipment, combined with additional efficiency measures, rather than migrating to a heat pump system.

The proposed ordinance applies to existing single-family homes and triggers when:

1. An existing A/C system is altered or replaced, or

2. A new air conditioning (A/C) system is installed where none previously existed. 849 of 961

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Projects meeting these criteria must either:

1. Install a heat pump system as the primary source of space heating, OR

2. Implement a set of alternative energy conservation measures, such as:
a. Sealing ductwork to limit air leakage
b. Establish Airflow requirements
c. Improving ceiling insulation (e.g., to R-49)
d. Performing refrigerant charge verification
e. Air sealing the building envelope
f. Installing energy-efficient fan systems and thermostats Exceptions are provided for circumstances such as:
Insufficient electrical panel capacity to support heat pump installation Oversized heating load that cannot be reasonably met with a heat pump Existing hazards such as asbestos or knob-and-tube wiring AC Pathways for Heat Pump Replacements
Figure 1 illustrates two AC pathways: one with an existing duct system and another with a new duct system, alongside the heat pump pathways. The figure presents the proposed efficiency upgrade measures that would be part of a reach code (solid blue) along with the relevant requirements from Title 24, Part 6 that are triggered as part of equipment replacements (white or gradient blue). A reach code that establishes requirements when an air conditioner is replaced or a new one is installed could allow for either a heat pump to be installed or an AC, as long as the performance measures listed below are met.

Diagram 2: Heat Pump Pathways
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Costs
The California Codes and Standards (C&S) Reach Codes program, also known as the Local Energy Codes program, provides technical support to local governments considering adopting a local ordinance (reach code) intended to support meeting local and/or statewide energy efficiency and greenhouse gas (GHG) reduction goals. The program facilitates adoption and implementation of the code when requested by local jurisdictions by providing resources such as cost-effectiveness studies, model language, sample findings, and other supporting documentation.

These studies aim to ensure that the requirements do not result in buildings consuming more energy than permitted by the State's minimum standards. The analysis includes scenarios of compliance packages, options, and cost-effectiveness for all California climate zones. It evaluates building prototypes to assess the cost-effectiveness of proposed changes to Title 24 requirements. Staff have provided the Local Energy Codes team with the GWP residential electric rates, L-1-A Standard Service Rates, to undertake a cost-effectiveness study.

Cost Effective Study Results
The study (exhibit 1) analyzes the cost-effectiveness of heat pump space heater measure upgrades in existing single-family buildings that exceed the minimum state requirements under the 2025 Building Energy Efficiency Standards. 851 of 961

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The Local Energy Codes Team assessed the incremental costs and savings of the packages over the lifecycle of 30-years. Incremental costs represent the equipment, installation, replacement, and maintenance costs of the proposed measure relative to the 2025 Energy Code minimum requirements or standard industry practices. The following scenarios were evaluated.

1.Dual Fuel Heat Pump (DFHP Existing Furnace): Replace existing ducted AC with an electric heat pump and install controls to operate the heat pump as the primary space conditioning source and to use the existing gas furnace (78 AFUE) for backup heat when heating demands cannot be met by the heat pump. In this report, dual fuel heat pumps were modeled to disable furnace operation above an outdoor temperature of 35°F in compliance with Energy Code Section 150.0(h)7, which requires this lockout for any heat pump with supplemental heating.

2.HPSH: Replace existing ducted AC and natural gas furnace with an electric heat pump and air handler. Minimum federal efficiency.

3.High Efficiency HPSH: Replace existing ducted AC and natural gas furnace with an electric heat pump and air handler. Higher efficiency.

The primary objective of the evaluation is to identify cost-effective energy upgrade measures at the time of air conditioner replacement in single family buildings, to support the design of local ordinances requiring upgrades, which may be triggered by different events, such as at the time of a significant remodel or at burnout of mechanical equipment. Table 10 shows the analysis results for Climate Zone 9 for the standard rate L-1-A rate.

Results Summary
This analysis evaluated the feasibility and cost-effectiveness of heat pump upgrades at time of air conditioner replacement in GWP territory for homes built before 2010. The Statewide Reach Codes Team used both On-Bill and LSC-based LCC approaches to evaluate cost-effectiveness and quantify the energy cost savings associated with 852 of 961

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energy efficiency measures compared to the incremental costs associated with the measures.

Conclusions and Discussion:
The heat pump installation alongside the existing furnace (DFHP Existing Furnace) was found to be cost-effective under the high gas escalation and LSC cost-effective in all vintages.
The complete heat pump system installation (heat pump and air handler – HPSH) was found to be cost-effective under the high gas escalation and LSC cost-effective in all vintages.
The complete heat pump system installation with high efficiency heat pump was found to be cost-effective under the high gas escalation in the pre-1978 vintage and LSC cost-effective in all vintages, with exception to the 1992-2010 vintage. Under the modest gas escalation scenario, only the DFHP Existing Furnace in the 1978-1991 and 1992-2010 vintages were found to be cost-effective. Challenges to On-Bill cost-effectiveness include higher first costs and higher first- year utility costs due to higher electricity tariffs relative to gas tariffs. However, On-Bill cost-effectiveness improves under GWP rates compared to SCE rates, primarily because GWP electricity rates are lower.

Estimated Greenhouse Gas Emissions Impacts
Assumptions: CA grid average emissions (0.25 kg CO₂/kWh), natural gas (5.3 kg CO₂/therm), usage based on average SFH demand.

Table 6: GHG Emissions Comparison
System Type Annual CO₂ Emissions 15-Year Total
Heat Pump (ASHP) 800 – 1,200 kg 12,000 – 18,000 kg
Gas Furnace + AC 2,000 – 3,200 kg 30,000 – 48,000 kg
Incentives available across the U.S., combining federal, and utility programs inclide:

Federal Incentives (2025) Inflation Reduction Act – High-Efficiency Electric Home Rebate Program. The Inflation Reduction Act (IRA) heat pump incentives are still available in 2025, though some parts are being phased out or reassessed Federal Tax Credit: Up to $2,000 for qualifying heat pump systems oMust meet ENERGY STAR Most Efficient certification
oAvailable through December 31, 2025
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GWP Incentives. Below are current electrification rebates provided by GWP.

However, GWP are reviewing the rebates and will be providing information to the City Council in the future.
Heat Pump Mini-Split or Central Heat Pump AC: $500/Unit (up to $2,500 total) Timeline and next steps
Staff are seeking the City Council’s authorization to prepare and introduce AC2HP reach code language and submit applications to the CEC and CBSC, based on amendment to the 2022 Building Code.

Staff recommend utilizing the model language prepared by the Local Energy Codes program (Exhibit 2). To meet the September 30, 2025, code effectiveness date, the reach code ordinance could be adopted on a non-urgency basis before September 1, 2025 (Introduced August 19 and Adopted on August 26, becoming “effective” on September 26, 2025), or depending on the timing, could be presented for adoption in September on an urgency basis.

Staff reviewed other California Geen Building Standards voluntary measures. However, at this time staff have not undertaken studies to determine the feasibility of mandating the voluntary measures outlined in the table.

Occupancy Event Topic Proposed Changes
Single
Family
New Performance
margins
Higher performance margins
(0.18 to 2.7, depending upon
climate zone)
All New Outdoor
lighting
standards
Downlit and shielded
Multi
Family/Non
Residential
Addition
&
Alteration
Pools and
spas
Heat pump (gas back up
allowed) or gas with 60%
solar thermal/recovered
energy fraction.

STAKEHOLDERS/OUTREACH
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Staff presented draft reach code language to the August 7, 2025, Sustainability Commission meeting and received recommendations and direction from the Commission.

Staff provided a copy of the reach code model language to the Community Development Building Official and the GWP Clean Energy Officer in June 2025.

FISCAL IMPACT
There is no fiscal impact associated with this report.

ENVIRONMENTAL REVIEW (CEQA/NEPA)
This item is not subject to CEQA as it is not a project approval.

CAMPAIGN DISCLOSURE
This item is exempt from campaign disclosure requirements.

ALTERNATIVES TO STAFF RECOMMENDATION

1. The City Council may recommend staff to not prepare an AC2HP reach code until after the AB130 6-year restrictions expire.

2. The City Council may consider any alternates not presented by staff.

ADMINISTRATIVE ACTION
Submitted by:

John Takhtalian, Assistant City Manager
Prepared by:

David Jones, Sustainability Officer
Approved by:

Roubik R. Golanian, P.E., City Manager

EXHIBITS/ATTACHMENTS

1. Custom Cost Effectiveness Analysis: City of Glendale Ac to Heat Pump Replacement.

2. Model Reach Code Language.
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c:\pgcompilerservicerelease\temp\glendale\meetingid_10583\packet\pdf\59123\15117\1.docx

M O T I O N
Moved by Council Member _______________________, seconded by Council Member _______________________, that the City Council hereby directs staff to prepare and return to introduce a reach code ordinance for existing single-family buildings that would require installation of a heat pump as the primary heating source, or other energy conservation improvements, in cases where an existing air conditioning system is altered or replaced, or where an air conditioning system is added.

Vote as follows:

Ayes:

Noes:

Absent:

Abstain:
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2025 CODE CYCLE:

Custom Cost
Effectiveness Analysis:

City of Glendale
Single Family AC to Heat
Pump Replacement
Prepared by:

Frontier Energy, Inc.

Misti Bruceri & Associates, LLC

Prepared for:

Kelly Cunningham, Codes and
Standards Program, Pacific Gas
and Electric

Revision: 1.0
Last modified: 2025/07/22

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Table 1. Summary of Revisions
Date Description Reference (page or section)
7/22/2025 Original Release N/A

Legal Notice
This report was prepared by
Pacific Gas and Electric Company
and funded by the California utility
customers under the auspices of
the California Public Utilities
Commission.

Copyright 2025, Pacific Gas and
Electric Company. All rights
reserved, except that this
document may be used, copied,
and distributed without
modification.

Neither PG&E nor any of its
employees makes any warranty,
express or implied; or assumes
any legal liability or responsibility
for the accuracy, completeness or
usefulness of any data,
information, method, product,
policy or process disclosed in this
document; or represents that its
use will not infringe any privately-
owned rights including, but not
limited to, patents, trademarks or
copyrights.

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Acronym List
B/C – Lifecycle Benefit-to-
Cost Ratio
CBSC – California Building
Standards Commission
CBECC – California
Building Energy Code
Compliance
CZ – California Climate
Zone
GHG – Greenhouse Gas
GWP – Glendale Water and
Power
IOU – Investor-Owned
Utility
LCC – Lifecycle Cost
LSC – Long-Term
Systemwide Cost
NPV – Net Present Value
PG&E – Pacific Gas and
Electric Company
POU – Publicly Owned
Utility
PV – Solar Photovoltaic
SoCalGas – Southern
California Gas Company
TDV – Time Dependent
Valuation
Title 24 – Title 24, Part 6
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Table of Contents
1 Introduction .................................................................................................................. 3 2 Methodology and Assumptions .................................................................................. 5

2.1 Reach Codes ........................................................................................................ 5

2.1.1 Benefits ............................................................................................................ 5

2.1.2 Costs ................................................................................................................ 5

2.1.3 Lifecycle Cost Assuming Zero-NOx Standards for Space Heating After 2030 ... 8

2.1.4 Metrics .............................................................................................................. 9

2.1.5 Utility Rates .....................................................................................................10

2.2 Greenhouse Gas Emissions ................................................................................ 11 3 Prototype Designs and Measure Packages ............................................................. 12

3.1 Prototype Characteristics .....................................................................................12

3.2 Measure Details ...................................................................................................15 4 Results ........................................................................................................................ 16

4.1 Zero-NOx Scenario Results .................................................................................17 5 Summary .................................................................................................................... 18 6 References ................................................................................................................. 20 7 Appendices ................................................................................................................ 22

7.1 Map of California Climate Zones ..........................................................................22

7.2 Utility Rate Schedules ..........................................................................................23

7.2.1 Glendale Water and Power ..............................................................................23

7.2.2 Southern California Gas ...................................................................................24

7.2.3 Fuel Escalation Rates ......................................................................................25

List of Tables
Table 1. Summary of Revisions ............................................................................................ 1 Table 2. Lifecycle Incremental Cost Breakdown for a 4-Ton DFHP Existing Furnace ............ 7 Table 3. Lifecycle Incremental Cost Breakdown for 4-Ton HPSH ......................................... 7 Table 4. HVAC Measure Cost Assumptions – 4-Ton Electric Replacements ......................... 8 Table 5. SCAQMD Rule 1111 Proposed Manufacturer Compliance Targets ......................... 8 Table 6. Lifecycle Incremental Cost Breakdown for 4-Ton System DFHP Existing Furnace with no Gas Furnaces after 2030 ......................................................................................... 9 Table 7. Residential (Single Family and Detached ADU) Utility Tariffs in City of Glendale ..10 860 of 961

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Table 8. Residential Prototype Characteristics ....................................................................12 Table 9. Efficiency Characteristics for Three Vintage Cases ................................................14 Table 10. Heat Pump Single Family Cost-Effectiveness Summary ......................................16 Table 11. DFHP Existing Furnace On-Bill NPV and 2025 LSC Cost-effectiveness High Gas Escalation (Zero-NOx Rule) ................................................................................................17 Table 12. SoCalGas Monthly Gas Rate ($/therm) ................................................................24 Table 13: Real Utility Rate Escalation Rate Assumptions, CPUC En Banc and 2022 TDV Basis ...................................................................................................................................26 Table 14: Real Utility Rate Escalation Rate Assumptions, 2025 LSC Basis .........................27

List of Figures
Figure 1. Map of California climate zones. ..........................................................................22

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1 Introduction
The California Codes and Standards (C&S) Reach Codes program provides technical support to local governments considering adopting a local ordinance (reach code) intended to support meeting local and/or statewide energy efficiency and greenhouse gas reduction goals. The program facilitates adoption and implementation of the code when requested by local jurisdictions by providing resources such as cost-effectiveness studies, model language, sample findings, and other supporting documentation.

The California Building Energy Efficiency Standards Title 24, Part 6 (Title 24) (CEC, 2025) is maintained and updated every three years by two state agencies: the California Energy Commission (the Energy Commission) and the Building Standards Commission (BSC). In addition to enforcing the code, local jurisdictions have the authority to adopt local energy efficiency ordinances—or reach codes—that exceed the minimum standards defined by Title 24 (as established by Public Resources Code Section 25402.1(h)2 and Section 10-106 of the Building Energy Efficiency Standards). Local jurisdictions must demonstrate that the requirements of the proposed ordinance are cost-effective and do not result in buildings consuming more energy than is permitted by Title 24. In addition, the jurisdiction must obtain approval from the Energy Commission and file the ordinance with the BSC for the ordinance to be legally enforceable.

This report is an addendum to the Single Family Air Conditioner Replacements (AC to HP) Cost-effectiveness Report (Statewide Reach Codes Team, 2025) modified to accurately represent local conditions for the City of Glendale, California with service territory in California Climate Zone 9. The study analyzes the cost-effectiveness of heat pump space heater measure upgrades in existing single family buildings that exceed the minimum state requirements under the 2025 Building Energy Efficiency Standards. Local jurisdictions in California may consider adopting local energy ordinances to achieve energy savings beyond what will be accomplished by enforcing building efficiency requirements that apply statewide. This report was developed in coordination with the California Statewide Investor- Owned Utilities (IOUs) Codes and Standards Program, key consultants, and engaged cities—collectively known as the Statewide Reach Codes Team.

The methodology, prototype characteristics, and measure packages are retained from the main study referenced above except for the energy costs are calculated using local Glendale Water and Power (GWP) utility rates. Measure packages include upgrades in existing single family buildings that meet or exceed the minimum state requirements. A 1,665 square foot single family home prototype with an attached garage was evaluated in this study.

Local jurisdictions may also adopt ordinances that amend different Parts of the California Building Standards Code or may elect to amend other state or municipal codes. The decision regarding which code to amend will determine the specific requirements that must be followed for an ordinance to be legally enforceable. Although a cost-effectiveness study is only required to amend Part 6 of the CA Building Code, it is important to understand the 862 of 961

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economic impacts of any policy decision. This study documents the estimated costs, benefits, energy impacts and greenhouse gas emission reductions that may result from implementing an ordinance based on the results to help residents, local leadership, and other stakeholders make informed policy decisions.

Model ordinance language and other resources are posted on the C&S Reach Codes Program website at LocalEnergyCodes.com. Local jurisdictions that are considering adopting an ordinance may contact the program for further technical support at [email protected].
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2 Methodology and Assumptions

2.1 Reach Codes
This section describes the approach to calculating cost-effectiveness including benefits, costs, metrics, and utility rate selection.

2.1.1 Benefits
This analysis used two different metrics to assess the cost-effectiveness of the proposed upgrades. Both methodologies require estimating and quantifying the incremental costs and energy savings associated with each energy efficiency measure. The main difference between the methodologies is the way they value energy impacts:
• On-Bill: Customer-based lifecycle cost approach that values energy based upon estimated site energy usage and customer on-bill savings using electricity and natural gas utility rate schedules over a 30-year duration, accounting for a three percent discount rate and energy cost inflation per Appendix 0. • Long-term Systemwide Cost (LSC): Formerly known as Time Dependent Valuation (TDV) energy cost savings, LSC reflects the Energy Commission’s current LCC methodology, which is intended to capture the total value or cost of energy use over 30 years. This method accounts for the hourly cost of marginal generation, transmission and distribution, fuel, capacity, losses, and cap-and-trade-based CO2 emissions (California Energy Commission, 2023). This is the methodology used by the Energy Commission in evaluating cost-effectiveness for efficiency measures in the 2025 Energy Code.

The Reach Codes Team performed energy simulations using the 2025 research version of the Residential California Building Energy Code Compliance software (CBECC).

2.1.2 Costs
The Reach Codes Team assessed the incremental costs and savings of the packages over the lifecycle of 30-years. Incremental costs represent the equipment, installation, replacement, and maintenance costs of the proposed measure relative to the 2025 Energy Code minimum requirements or standard industry practices.

In February 2024, the TECH Clean California statewide program completed an incremental cost study from cost data collected from 64 contractor participants (Opinion Dynamics, 2024). This report directly uses the TECH costs for all the scenarios for which there was TECH cost data available. These costs were supplemented with measure costs the Reach Codes Team obtained from a contractor survey conducted in the summer of 2023. Additional details on the contractor cost survey are available in the prior existing building statewide study (Statewide Reach Codes Team, 2025). The following summarizes key assumptions in this costing approach.
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• Average statewide costs from the TECH Study were used, no regional specific costs were applied.
• The TECH study provided cost for a minimum efficiency 60,000 Btu/h gas furnace.

However, beginning in 2028, newly installed residential gas furnaces must comply with updated federal efficiency standards requiring a minimum of 95% AFUE1.

Because the TECH study did not include cost estimates for a 95% AFUE condensing furnace, an adjustment was made using data from the statewide contractor cost survey. For systems requiring larger furnace capacities, cost estimates were derived as follows:
o 100,000 Btu/h furnaces (serving systems 4 tons and larger): The same method was applied using the corresponding cost differential for 100,000 Btu/h units.
• At the time of replacement for a furnace when it fails, the statewide study assumed a fan motor replacement. The TECH costs did not include this option. A $1,200 incremental cost was added to the TECH cost.
• At time of replacement for high efficiency heat pump, the sum of the TECH cost for standard efficiency heat pump and the incremental cost difference from the statewide study for high efficiency and standard efficiency heat pump was applied.

Over the 30-year analysis period, certain changes are assumed when the equipment is replaced that impact both lifetime costs and energy use. Table 2 and Table 3 present the lifetime scenario for the DFHP Existing Furnace and HPSH measures, respectively. The analysis assumed a 20-year effective useful lifetime (EUL) for a furnace, a 15-year EUL for an air conditioner, and a 15-year EUL for a heat pump. Lifetimes are based on the Database for Energy Efficient Resources (DEER) (California Public Utilities Commission, 2021b). The existing furnace is assumed to be halfway through its EUL at the beginning of the analysis period. After 10 years when the furnace reaches the end of its life and needs to be replaced, it will be subject to new federal efficiency standards for residential gas furnaces that go into effect in 2028 requiring 95 AFUE

1. Five years later the air conditioner reaches the end of its life and is replaced with a new air conditioner.

For the DFHP upgrade case, after 10 years when the furnace fails it’s expected that the furnace is abandoned in place since the heat pump serves primary heating and was sized to provide the full design heating load. In this case it is assumed that the fan motor is replaced with a new aftermarket unit and operates another five years until the heat pump fails and is replaced with a new heat pump and air handler. Table 2 and Table 3 presents the lifecycle incremental cost breakdown for a 4-ton system. The heat pump is sized based on the heating and cooling load, and the 4-ton system is used for Climate Zone 9. These surveys reflect the cost to the customer and include equipment, labor, permit fees, and required HERS testing.

1 https://www.energy.gov/articles/doe-finalizes-energy-efficiency-standards-residential-furnaces-save-americans- 15-
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Table 2. Lifecycle Incremental Cost Breakdown for a 4-Ton DFHP Existing Furnace Calendar
Year
Baseline
AC
Baseline
Future
Cost
Baseline
Present
Value Cost
Heat Pump
Heat Pump
Future
Cost
Heat Pump
Present
Value Cost
2026 AC fails,
install new
AC, keep
existing
furnace
$10,431 $10,431 AC fails,
install new
HP , keep
existing
furnace
$12,347 $12,347
2036 Furnace
fails, install
new 95AFUE
furnace
$7,879 $5,863 Furnace
fails, replace
fan motor
$1,200 $893
2041 AC fails,
install new
AC
$10,431 $6,695 HP fails,
install new
HP and air
handler
$14,529 $9,326
Total $22,989 $22,566
Incremental Cost -$424
Table 3. Lifecycle Incremental Cost Breakdown for 4-Ton HPSH Calendar
Year
Baseline
AC
Baseline
Future
Cost
Baseline
Present
Value Cost
Heat Pump
Heat Pump
Future
Cost
Heat Pump
Present
Value Cost
2026 AC fails,
install new
AC & furnace
$13,808 $13,808 AC fails,
install new

HP & AHU
$14,529 $14,529
2041 AC fails,
install new
AC
$10,431 $6,695 HP fails,
install new

HP & AHU
$13,529 $8,684
2046 Furnace
fails, install
new 95AFUE
furnace
$7,879 $4,363
- - -
2056 Remaining
useful life for
furnace
-
-$1,623
- - -
Total $23,243 $23,213
Incremental Cost -$30

Table 4 presents estimated first and lifetime costs for the baseline and heat pump scenarios for 4-ton equipment. Costs include all material and installation labor including providing new 240 V electrical service to the air handler location for all new air handler installations and decommissioning of the furnace for the cases where the furnace is removed. DFHP costs incorporate controls installation and commissioning to ensure the heat pump and the furnace communicate properly and don’t operate at the same time. Future replacement 866 of 961

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costs do not include any initial costs associated with 240V electrical service or furnace decommissioning.

Table 4. HVAC Measure Cost Assumptions – 4-Ton Electric Replacements Measure Case
AC +
Evaporator
Coil
Gas
Furnace
/AC
DFHP Existing
Furnace HPSH
High
Efficiency
HPSH
Base Case - - AC +
Evaporator Coil
Gas
Furnace
/AC
Gas
Furnace
/AC
First Cost $10,431 $13,808 $12,347 $14,529 $17,506
Replacement Cost
(Future Value) $18,310 $18,310 $15,729 $13,529 $16,506
Replacement Cost
(Present Value) $12,558 $11,058 $10,219 $8,684 $10,594
Remaining Value at
Year 30 $0 -$1,623 $0 $0 $0
Total Lifecycle Cost $22,989 $23,243 $22,566 $23,213 $28,100 Incremental Cost - - -$424 -$30 $4,857

2.1.3 Lifecycle Cost Assuming Zero-NOx Standards for Space Heating After 2030
The California Air Resource Board proposed a strategy for reducing emissions in their 2022 Scoping Plan for Achieving Carbon Neutrality that includes a zero-emission standard for space and water heaters sold in California that would go into effect in 2030 (California Air Resources Board, 2022). The South Coast Air Quality Management District (SCAQMD) proposed Rule 1111 for the Reduction of NOx Emissions from Natural Gas-Fired Furnaces.

This rule applies to furnaces less than 175,000 Btu/hr and sets compliance goals for manufacturers with the proposed dates in Table 5. The sale of gas furnaces above the compliance target will incur a mitigation fee (SCAQMD, 2025).

Table 5. SCAQMD Rule 1111 Proposed Manufacturer Compliance Targets Target Dates 2027-2028 2029-2032 2033-2035 2036 and after NOx Emitting Units (e.g. gas) 70% 50% 25% 10%
Zero-Emission Units 30% 50% 75% 90%

The Bay Area Air Quality Management District (BAAD) adopted Rule 9-4 that similarly requires zero NOx standards for space heating systems sold in the Bay Area.

Implementation for residential furnaces will begin January 2029 (BAAD, 2025).

The BAAD Rule 9-4 has been adopted, but both the California Air Resources Board and SCAQMD Rule 1111 are proposed rules that have not yet been adopted, but given the implications these rulings would have on the 30-year cost-effectiveness if gas furnaces were 867 of 961

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very limited or no longer available in 2030, a sensitivity analysis for this scenario is included in this study for the DFHP Existing Furnace scenario. The other heat pump measures would also be impacted by this ruling; however, for simplicity the team selected one measure to give a sense of the impact on the results. The costs in Table 6 reflect the DFHP Existing Furnace scenario where gas furnaces are not available in 2030. This 30-year lifecycle analysis assumes that in 10 years when the furnace reaches the end of its useful life and needs to be replaced, it will be subjected to the SCAQMD Rule 1111 or California Air Resources Board proposal and will be replaced with a heat pump.

Table 6. Lifecycle Incremental Cost Breakdown for 4-Ton System DFHP Existing Furnace with no Gas Furnaces after 2030
Calendar
Year
Baseline AC
Replacement
Schedule
Baseline
Future
Cost
Baseline
Present
Value
Cost
Heat Pump
Heat
Pump
Future
Cost
Heat
Pump
Present
Value
Cost
2026
AC fails, install new
AC, keep existing
furnace
$10,431 $10,431
AC fails, install new
HP , keep existing
furnace
$12,347 $12,347
2036 Furnace fails, install
new HP $14,529 $10,811 Furnace fails,
replace fan motor $1,200 $893
2041 - - - HP fails, install new
HP and air handler $14,529 $9,326
2051 HP fails, install new
HP $13,529 $6,462 - - -
2056 Remaining useful
life for HP - -$4,459 - - -
Total $23,245 $22,566
Incremental Cost -$679

2.1.4 Metrics
Cost-effectiveness is presented using net present value (NPV) and benefit-to-cost (B/C) ratio metrics.
• NPV: The Reach Codes Team uses net savings (NPV benefits minus NPV costs) as the cost-effectiveness metric. If the net savings of a measure or package is positive, it is considered cost effective. Negative net savings represent net costs to the consumer. A measure that has negative energy cost benefits (energy cost increase) can still be cost effective if the costs to implement the measure are even more negative (i.e., construction and maintenance cost savings). • B/C Ratio: Ratio of the present value of all benefits to the present value of all costs over 30 years (NPV benefits divided by NPV costs). The criteria for cost- effectiveness is a B/C greater than 1.0. A value of one indicates the savings over the 868 of 961

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life of the measure are equivalent to the incremental cost of that measure. A value greater than one represents a positive return on investment.

Improving the energy performance of a building often requires an initial investment. In most cases the benefit is represented by annual on-bill utility or LSC savings, and the cost by incremental first cost and replacement costs. However, some packages result in initial construction cost savings (negative incremental cost), and either energy cost savings (positive benefits), or increased energy costs (negative benefits). In cases where both construction costs and energy-related savings are negative, the construction cost savings are treated as the benefit while the increased energy costs are the cost. In cases where a measure or package is cost-effective immediately (i.e., upfront construction cost savings and lifetime energy cost savings), B/C ratio cost-effectiveness is represented by “>1”.

Because of these situations, NPV savings are also reported, which, in these cases, are positive values.

2.1.5 Utility Rates
In coordination with the City of Glendale, the Reach Codes Team determined appropriate tariffs for each package, summarized in Table 7, based on the annual load profile of the prototype and the corresponding package, and the most prevalent rate for each building type.

For a more detailed breakdown of the rates selected refer to Section 7.2 Utility Rate Schedules.

Table 7. Residential (Single Family and Detached ADU)
Utility Tariffs in City of Glendale
Electric / Gas Utility Electricity Natural Gas
GWP / SoCalGas L-1-A GR

Utility rates are assumed to escalate over time according to the two scenarios described below.
1) Modest Gas Escalation: The first scenario is based on assumptions from the CPUC 2021 En Banc hearings on utility costs through 2030 (California Public Utilities Commission, 2021a). Escalation rates throughout the remainder of the 30-year evaluation period are based on the escalation rate assumptions within the 2022 TDV factors.
2) High Gas Escalation: A second set of escalation rates were also evaluated to demonstrate the impact that utility cost changes have on cost-effectiveness over time. This set was based on those used within the 2025 LSC factors (LSC replaces TDV in the 2025 code cycle) which assumed steep increases in gas rates in the latter half of the analysis period.
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See Section 7.2.3 and the statewide 2022 Single Family Retrofit Cost-effectiveness Study (Statewide Reach Codes Team, 2025) for details.

2.2 Greenhouse Gas Emissions
The analysis uses the greenhouse gas (GHG) emissions estimates built-in to CBECC-Res.

There are 8760 hourly multipliers accounting for time dependent energy use and carbon emissions based on source emissions, including renewable portfolio standard projections.

Natural gas fugitive emissions, which are shown to be substantial, are not included. 870 of 961

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3 Prototype Designs and Measure
Packages

3.1 Prototype Characteristics
The Energy Commission defines building prototypes which it uses to evaluate the cost- effectiveness of proposed changes to Title 24 requirements. Average home size has steadily increased over time, and the Energy Commission single family new construction prototypes are larger than many existing single family homes across California. For this analysis, a 1,665 square foot prototype was evaluated. Table 8 describes the basic characteristics of the single family prototype. Additions are not evaluated in this analysis as they are already addressed in Section 150.2 of Title 24, Part 6. The CEC has proposed significant changes to the 2025 Energy Code that would remove the allowance of gas space heating and water heating equipment for additions and instead require additions to follow the same space heating and water heating equipment requirements as new construction (California Energy Commission, 2025).

Table 8. Residential Prototype Characteristics

Three building vintages were evaluated to determine sensitivity of existing building performance on cost-effectiveness of upgrades. For example, it is widely recognized that adding attic insulation in an older home with no insulation is cost-effective, however, newer homes will likely have existing attic insulation reducing the cost-effectiveness of an incremental addition of insulation. The building characteristics for each vintage were determined based on either prescriptive requirements from Title 24 that were in effect or standard construction practice during that time period. Homes built under 2001 Title 24 are subject to prescriptive envelope code requirements very similar to homes built under the 2005 code cycle, which was in effect until January 1, 2010.

Table 9 summarizes the assumptions for each of the three vintages. Additionally, the analysis assumed the following features when modeling the prototype buildings. Efficiencies were defined by year of the most recent equipment replacement based on standard equipment lifetimes.
• Individual space conditioning and water heating systems, one per single family building.
• Split-system air conditioner with natural gas furnace.

Specification
Existing Conditioned Floor Area 1,665 ft2
Num. of Stories 1
Num. of Bedrooms 3
Window-to-Floor Area Ratio 13%
Attached Garage 2-car garage
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o Scenarios with an existing natural gas wall furnace without AC were also evaluated.
• Small storage natural gas water heater.
o Scenarios with an existing electric resistance storage water heater were also evaluated.
• Gas cooktop, oven, and clothes dryer.

The methodology applied in the analysis begins with a design that matches the specifications as described in Table 9 for each of the three vintages. Prospective energy efficiency measures were modeled to determine the projected energy performance and utility cost impacts relative to the baseline vintage.

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Table 9. Efficiency Characteristics for Three Vintage Cases Building Component Efficiency
Feature
Vintage Case
Pre-1978 1978-1991 1992-2010
Envelope
Exterior Walls 2x4, 16-inch on center wood frame,
R-0a
2x4 16 inch on center wood frame,
R-11
2x4 16 inch on center wood frame,
R-13
Foundation Type & Insulation Uninsulated slab (CZ 2-15) Raised floor, R-0 (CZ 1 & 16)
Uninsulated slab (CZ 2-15)
Raised floor, R-0 (CZ 1 & 16)
Uninsulated slab (CZ 2-15)
Raised floor, R-19 (CZ 1 & 16)
Ceiling Insulation & Attic Type
Vented attic, R-5 @ ceiling level for CZ
6 & 7,
Vented attic, R-11 @ ceiling level
(all other CZs)
Vented attic, R-19 @ ceiling level Vented attic, R-30 @ ceiling level Roofing Material & Color Asphalt shingles, dark
(0.10 reflectance, 0.85 emittance)
Asphalt shingles, dark
(0.10 reflectance, 0.85 emittance)
Asphalt shingles, dark
(0.10 reflectance, 0.85 emittance)
Radiant Barrier No No No
Window Type: U-factor/SHGCb Metal, single pane: 1.16/0.76 Metal, dual pane: 0.79/0.70 Vinyl, dual pane Low-E: 0.55/0.40 House Infiltration at 50 Pascals 15 ACH50 10 ACH50 7 ACH50 HVAC Equipment
Heating Efficiency 78 AFUE (assumes 2 replacements) 78 AFUE (assumes 1 replacement) 78 AFUE Cooling Efficiency 10 SEER (assumes 2 replacements) 10 SEER (assumes 1 replacement) 13 SEER, 11 EER Duct Location & Details Attic, R-2.1, 30% leakage at 25 Pa Attic, R-2.1, 25% leakage at 25 Pa Attic, R-4.2, 15% leakage at 25 Pa Whole Building Mechanical
Ventilation None None None
Water Heating Equipment
Water Heater Efficiency 0.575 Energy Factor (assumes 2
replacements)

0.575 Energy Factor (assumes 1
replacement) 0.575 Energy Factor
Water Heater Type 40-gallon gas storage 40-gallon gas storage 40-gallon gas storage Pipe Insulation None None None
Hot Water Fixtures Standard, non-low flow Standard, non-low flow Standard, non-low flow a Pre-1978 wall modeled with R-5 cavity insulation to better align wall system performance with monitored field data and not overestimate energy use. b Window type selections were made based on conversations with window industry expert, Ken Nittler. If a technology was enterin g the market during the time period (e.g., Low-E during 1992-2010 or dual-pane during 1978-1991) that technology was included in the analysis. This provides a conservative assumption for overall building performance and additional measures may be cost -effective for buildings with lower performing windows, for example buildings with metal single pane windows in the 1978-1991 vintage.

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3.2 Measure Details
The following heat pump space heater (HPSH) measures were evaluated as described below. All included HERS verified refrigerant charge, 10% duct sealing, and 300 CFM/ton airflow, aligned with the proposed code requirements for the 2025 Title 24 code.
1) Dual Fuel Heat Pump (DFHP Existing Furnace): Replace existing ducted AC with an electric heat pump and install controls to operate the heat pump as the primary space conditioning source and to use the existing gas furnace (78 AFUE) for backup heat when heating demands cannot be met by the heat pump. In this report, dual fuel heat pumps were modeled to disable furnace operation above an outdoor temperature of 35°F in compliance with Energy Code Section 150.0(h)7, which requires this lockout for any heat pump with supplemental heating. A minimum federal efficiency (14.3 SEER2, 11.7 EER2, 7.5 HSPF2) heat pump was evaluated. Savings are compared to a new AC (14.3 SEER2, 11.7 EER2) alongside the existing furnace (78 AFUE). A new evaporator coil is assumed to be installed with the AC system.
2) HPSH: Replace existing ducted AC and natural gas furnace with an electric heat pump and air handler. Minimum federal efficiency (14.3 SEER2, 11.7 EER2, 7.5 HSPF2) heat pumps were evaluated. Savings are compared to a new ducted natural gas furnace and AC (14.3 SEER2, 11.7 EER2, 80 AFUE).
3) High Efficiency HPSH: Replace existing ducted AC and natural gas furnace with an electric heat pump and air handler. Higher efficiency (17 SEER2, 12.48 EER2, 9.5 HSPF2) heat pumps were evaluated. Savings are compared to a new ducted natural gas furnace and AC (14.3 SEER2, 11.7 EER2, 80 AFUE).

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4 Results
The primary objective of the evaluation is to identify cost-effective energy upgrade measures at the time of air conditioner replacement in single family buildings, to support the design of local ordinances requiring upgrades, which may be triggered by different events, such as at the time of a significant remodel or at burnout of mechanical equipment. Table 10 shows the analysis results for Climate Zone 9 for the standard rate L-1-A rate.

Table 10. Heat Pump Single Family Cost-Effectiveness Summary Vintage
Year Case
Annual
Elec
Savings
(kWh)
Annual
Gas
Savings
(therms)
Average
Annual
GHG
Reductions
(metric
tons)
Utility Cost Savings Incremental Cost On-Bill Cost-Effectiveness 2025 LSC Cost-
Effectiveness
First
Year
Lifecycle
(2025$)
First
Year
Lifecycle
(2025$)
Modest Gas
Escalation
High Gas
Escalation
B/C
Ratio NPV B/C
Ratio NPV B/C
Ratio NPV

Pre 1978
DFHP Existing Furnace (738) 95 0.40 ($66) ($429) $1,916 ($424) 0.99 ($6) >1 $2,949 >1 $4,387 HPSH (Std Efficiency) (879) 99 0.40 ($101) ($1,173) $721 ($30) 0.03 ($1,143) >1 $1,909 >1 $4,415 HPSH (High Efficiency) (478) 99 0.44 $43 $2,018 $3,698 $4,857 0.42 ($2,839) 1.07 $345 1.49 $2,358 1978-
1991
DFHP Existing Furnace (499) 65 0.27 ($44) ($285) $1,916 ($424) 1.49 $139 >1 $2,141 >1 $3,127 HPSH (Std Efficiency) (599) 68 0.27 ($69) ($810) $721 ($30) 0.04 ($780) >1 $1,289 >1 $3,022 HPSH (High Efficiency) (300) 68 0.30 $35 $1,505 $3,698 $4,857 0.31 ($3,352) 0.76 ($1,187) 1.05 $232 1992-
2010
DFHP Existing Furnace (410) 54 0.23 ($36) ($218) $1,916 ($424) 1.94 $206 >1 $1,860 >1 $2,749 HPSH (Std Efficiency) (490) 56 0.23 ($56) ($642) $721 ($30) 0.05 ($612) >1 $1,096 >1 $2,589 HPSH (High Efficiency) (282) 56 0.25 $11 $856 $3,698 $4,857 0.18 ($4,001) 0.54 ($2,231) 0.85 ($750) 875 of 961

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4.1 Zero-NOx Scenario Results
This section presents cost-effectiveness results for the DFHP Existing Furnace under the scenario where proposed air quality district zero-NOx rules go into effect over the next 10 years. In the base case, at time of replacement of the gas furnace at year 10 a heat pump is installed. The energy profile between the base case and the heat pump upgrade case are subsequently identical for the remaining 20 years of the 30-year analysis period. As a result, energy and cost savings only persist for the first 10 years.

Table 11 shows the On-Bill NPV cost-effectiveness results and the LSC cost-effectiveness results for all three vintages. 2025 LSC savings were calculated using individual year multipliers for the first 10 years, 2026 through 2035.

Table 11. DFHP Existing Furnace On-Bill NPV and 2025 LSC Cost-effectiveness High Gas Escalation (Zero-NOx Rule)
Vintage Year
NPV
On-Bill 2025 LSC

Pre 1978 $400 $608
1978-1991 $492 $424
1992-2010 $532 $372
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5 Summary
This analysis evaluated the feasibility and cost-effectiveness of heat pump upgrades at time of air conditioner replacement in GWP territory for homes built before 2010. The Statewide Reach Codes Team used both On-Bill and LSC-based LCC approaches to evaluate cost- effectiveness and quantify the energy cost savings associated with energy efficiency measures compared to the incremental costs associated with the measures.

Conclusions and Discussion:
• The heat pump installation alongside the existing furnace (DFHP Existing Furnace) was found to be cost-effective under the high gas escalation and LSC cost-effective in all vintages.
• The complete heat pump system installation (heat pump and air handler – HPSH) was found to be cost-effective under the high gas escalation and LSC cost-effective in all vintages.
• The complete heat pump system installation with high efficiency heat pump was found to be cost-effective under the high gas escalation in the pre-1978 vintage and LSC cost-effective in all vintages, with exception to the 1992-2010 vintage. • Under the modest gas escalation scenario, only the DFHP Existing Furnace in the 1978-1991 and 1992-2010 vintages were found to be cost-effective. • Challenges to On-Bill cost-effectiveness include higher first costs and higher first- year utility costs due to higher electricity tariffs relative to gas tariffs. However, On- Bill cost-effectiveness improves under GWP rates compared to SCE rates, primarily because GWP electricity rates are lower.
• Given the adopted Bay Area Air Quality Management District Zero NOx rule, and the proposed California Air Resource Board or South Coast Air Quality Management District (SCAQMD) Zero-NOx rules, and gas furnaces may not be available to be installed after 2030. A sensitivity analysis was performed for the Zero NOx scenario using the high gas escalation rate scenario and found that cost-effectiveness decreases in all DFHP cases. Utility cost impacts are experienced over the first 10- year period, during which gas rate escalation is lower and electricity rate escalation higher. As a result, this scenario has higher lifetime increases in utility cost. Even though lifetime incremental costs are lower, the combined impact is a lower net present value.
• While not evaluated in this report, the 2022 Single Family Retrofit Cost-effectiveness Study (Statewide Reach Codes Team, 2025) shows it is beneficial to combine a heat pump space conditioning system with photovoltaics (PV) because the additional electricity required by the heat pump can be met by the PV system and result in reduced utility bills.
• In this study the dual fuel heat pump is evaluated with an existing furnace, however the homeowner could choose to replace the existing furnace with a new furnace at this time as well. This measure (DFHP New Furnace) was evaluated in the 2022 877 of 961

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Single Family Retrofit Cost-effectiveness Study (Statewide Reach Codes Team, 2025) but found to be less cost-effective than the DFHP Existing Furnace case.

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6 References
BAAD. (2025, May 7). Rules 9-4 and 9-6 Building Appliances. Retrieved from Bay Area Air District: https://www.baaqmd.gov/en/rules-and-compliance/rule- development/building-appliances
California Air Resources Board. (2022, August 12). 2022 State Strategy for the State Implementation Plan (2022 State SIP Strategy). Retrieved from California Air Resources Board Web site: https://ww2.arb.ca.gov/sites/default/files/2022- 11/Proposed_2022_State_SIP_Strategy.pdf
California Energy Commission. (2023). 2025 Energy code Hourly Factors. Retrieved from https://www.energy.ca.gov/files/2025-energy-code-hourly-factors California Energy Commission. (2025). Final Express Terms for the Proposed Revisions to 2025 Title 24, Parts 1 and 6. Retrieved from
https://efiling.energy.ca.gov/GetDocument.aspx?tn=261222&DocumentContentId=97 581
California Public Utilities Commission. (2021a). Utility Costs and Affordability of the Grid of the Future: An Evaluation of Electric Costs, Rates, and Equity Issues Pursuant to P.U. Code Section 913.1. Retrieved from https://www.cpuc.ca.gov/-/media/cpuc- website/divisions/office-of-governmental-affairs-division/reports/2021/senate-bill-695- report-2021-and-en-banc-whitepaper_final_04302021.pdf
California Public Utilities Commission. (2021b). Database for Energy-Efficient resources (DEER2021 Update). Retrieved April 13, 2021, from
http://www.deeresources.com/index.php/deer-versions/deer2021 Heinemeier, K. (2025). Residential HVAC Performance. Retrieved from https://title24stakeholders.com/wp-content/uploads/2025/03/Residential-HVAC- Performance.pdf
Opinion Dynamics. (2024). TECH Clean California: Incremental Cost Study. Final Phase I Findings. Retrieved from
https://techcleanca.com/documents/4258/TECH_Cost_Study_- _FINAL_Phase_I_Findings_2.12.24_2.pdf
SCAQMD. (2025, February 21). Space and Water Heating Building Appliances. Retrieved from South Coast AQMD: https://www.aqmd.gov/docs/default- source/Agendas/ssc/ssc-agenda-2-21-2025.pdf
Statewide Reach Codes Team. (2024, September). 2022 Cost-Effectiveness Study: Single Family New Construction. Retrieved from
https://localenergycodes.com/download/1240/file_path/fieldList/2022%20Single%20 Family%20NewCon%20Cost-eff%20Study.docx
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Statewide Reach Codes Team. (2025). Single Family Air Conditioner Replacements (AC to HP) Cost-effectiveness Report. Retrieved from
https://localenergycodes.com/download/2034/file_path/fieldList/2025%20Single%20 Family%20AC%20to%20HP%20Cost-eff%20Study.pdf
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7 Appendices

7.1 Map of California Climate Zones
Climate zone geographical boundaries are depicted in Figure . The map in Figure 1 along with a zip-code search directory is available at:
https://ww2.energy.ca.gov/maps/renewable/building_climate_zones.html Figure 1. Map of California climate zones.

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7.2 Utility Rate Schedules
The Reach Codes Team used City of Glendale electricity and SoCalGas gas tariffs detailed below to determine the On-Bill savings for each package.

7.2.1 Glendale Water and Power
Following shows the City of Glendale electricity tariffs applied in this study. The L-1-A rate was applied to all packages.

L-1-A Standard Service Rate

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7.2.2 Southern California Gas
The SoCalGas monthly gas rate in $/therm applied in this analysis is shown in Table 12. The gas rates were developed based on the latest available gas rate for May 2025 and a curve to reflect how natural gas prices fluctuate with seasonal supply and demand. The seasonal curve was estimated from SoCalGas’s monthly residential tariffs between 2015 and 2024. 12-month curves were created from monthly gas rates for each of the ten years. The ten annual curves were then averaged to arrive at an average normalized annual curve. Long- term historical natural gas rate data was only available for SoCalGas’ procurement charges.

The baseline and excess transmission charges were found to be consistent over the course of a year and applied for the entire year based on May 2025 rates. The costs presented in Table 12 were then derived by establishing the baseline and excess rates from the May 2025 tariff as a reference point and then using the normalized curve to estimate the cost for the remaining months relative to the May rates.

Table 12. SoCalGas Monthly Gas Rate ($/therm)
Month
Total Charge
Baseline Excess
January $1.57 $2.06
February $1.40 $1.88
March $1.34 $1.82
April $1.28 $1.76
May $1.29 $1.77
June $1.32 $1.81
July $1.34 $1.82
August $1.38 $1.86
September $1.34 $1.83
October $1.33 $1.82
November $1.37 $1.86
December $1.43 $1.91
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7.2.3 Fuel Escalation Rates
The average annual escalation rates in Table 13 present the moderate gas escalation scenario used in this study. The electricity and natural gas rates are based on assumptions from the CPUC 2021 En Banc hearings on utility costs through 2030 (California Public Utilities Commission, 2021a). Escalation rates throughout the remainder of the 30-year evaluation period are based on the escalation rate assumptions within the 2022 TDV factors. No data was available to estimate electricity escalation rates for Glendale, therefore electricity escalation rates for SCE and statewide natural gas escalation rates were applied.

Table 14 presents the high gas escalation scenario escalation rates used in this analysis.

Rates were applied for the same 30-year period and are based on the escalation rate assumptions within the 2025 LSC factors from 2026 through 2055. These rates were developed for electricity use statewide (not utility-specific) and assume steep increases in gas rates in the latter half of the analysis period. Data was not available for the year 2026 and so the CPUC En Banc assumptions were applied for those years using the average rate across the three IOUs for statewide electricity escalation.

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Table 13: Real Utility Rate Escalation Rate Assumptions, CPUC En Banc and 2022 TDV Basis

Year
Statewide Natural
Gas Average Rate
(%/year, real)
SCE Electric
Average Rate
(%/year, real)
2026 4.6% 1.6%
2027 4.6% 1.6%
2028 4.6% 1.6%
2029 4.6% 1.6%
2030 4.6% 1.6%
2031 2.0% 0.6%
2032 2.4% 0.6%
2033 2.1% 0.6%
2034 1.9% 0.6%
2035 1.9% 0.6%
2036 1.8% 0.6%
2037 1.7% 0.6%
2038 1.6% 0.6%
2039 2.1% 0.6%
2040 1.6% 0.6%
2041 2.2% 0.6%
2042 2.2% 0.6%
2043 2.3% 0.6%
2044 2.4% 0.6%
2045 2.5% 0.6%
2046 1.5% 0.6%
2047 1.3% 0.6%
2048 1.6% 0.6%
2049 1.3% 0.6%
2050 1.5% 0.6%
2051 1.8% 0.6%
2052 1.8% 0.6%
2053 1.8% 0.6%
2054 1.8% 0.6%
2055 1.8% 0.6%
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Table 14: Real Utility Rate Escalation Rate Assumptions, 2025 LSC Basis

Year
Statewide Natural
Gas Residential
Average Rate
(%/year, real)
Statewide
Electricity
Residential
Average Rate
(%/year, real)
2026 4.6% 2.1%
2027 4.2% 0.6%
2028 3.2% 1.9%
2029 3.6% 1.6%
2030 6.6% 1.3%
2031 6.7% 1.0%
2032 7.7% 1.2%
2033 8.2% 1.1%
2034 8.2% 1.1%
2035 8.2% 0.9%
2036 8.2% 1.1%
2037 8.2% 1.1%
2038 8.2% 1.0%
2039 8.2% 1.1%
2040 8.2% 1.1%
2041 8.2% 1.1%
2042 8.2% 1.1%
2043 8.2% 1.1%
2044 8.2% 1.1%
2045 8.2% 1.1%
2046 8.2% 1.1%
2047 3.1% 1.1%
2048 -0.5% 1.1%
2049 -0.6% 1.1%
2050 -0.5% 1.1%
2051 -0.6% 1.1%
2052 -0.6% 1.1%
2053 -0.6% 1.1%
2054 -0.6% 1.1%
2055 -0.6% 1.1%
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Revision: 1.0
Last modified: 2025/07/22

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Please Note:

This template is intended for educational purposes only, without any express or implied warranty of any kind, including warranties of accuracy, completeness, or fitness for any particular purpose. You agree that your use of the template is without any recourse whatsoever to PG&E, SCE, SDG&E, or their affiliates. The template is a draft, and anyone using this document should seek the advice of an attorney to develop appropriate ordinance language to meet its jurisdiction’s specific needs, as state and local laws may differ.

This document is the product of a collaborative effort, incorporating input and feedback from several entities and experts based on their collective experiences.

Please contact the Codes and Standards Reach Codes Team at [email protected] for additional information.

This program is funded by California utility customers and administered by Pacific Gas and Electric Company, San Diego Gas & Electric Company (SDG&E®), and Southern California Edison Company under the auspices of the California Public Utilities Commission and in support of the California Energy Commission. 888 of 961

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Model Ordinance Language for Air Conditioning
Alterations, Replacements and Installations in
Existing Single-Family Buildings
Table of Contents
Changes from Prior Versions........................................................................................1 Scope...............................................................................................................................1 Introduction.....................................................................................................................1 Additional Resources.....................................................................................................2 Model Ordinance.............................................................................................................3 Findings....................................................................................................................................................3 Sample Amendments ...............................................................................................................................4 Other Sample Ordinance Sections...........................................................................................................8 889 of 961

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Changes from Prior Versions
This is the original version of the model language.

Scope
Existing single-family buildings in which an existing air conditioning system is altered or replaced or where an air conditioning system is added, must either install a heat pump as the primary heating source or make other energy conservation improvements.

Introduction
This model ordinance language supports a reach code requiring that a project in a single-family home involving replacement or alteration of an existing air conditioning system or installation of a new air conditioning system in an existing home must either include a heat pump space heater as the primary heating system or install other energy conservation measures. The ordinance is based on the 2025 California Green Building Standards Code (CALGreen) Section A4.204 and includes references to the 2025 California Energy Code and appendices.

Amendments to the State Code appear in strikeouts (deletions) and underlines (additions). Such amendments require that the governing body of the local jurisdiction make express findings, including a CEQA determination, and cite the authorities used to adopt the ordinance. Refer to the Guide for Local Amendments to Building Standards for more information. In addition to the requirements specified in the Guide, the California Energy Commission requires that the findings include a statement to the effect that the local governmental agency’s governing body has, at a public meeting, adopted its determination that the standards are cost-effective.

This initial version of the model reach code amends the California Green Building Standards Code (Title 24, Part 11) and, by reference, the California Energy Code (Title 24, Part 6).

However, jurisdictions should consider amending the Energy Code directly to better align the requirements with the CALGreen scope as revised. Contact the Local Energy Codes program for assistance with drafting the requirements in the Energy Code. Amendments to the Energy Code must be approved by the California Energy Commission (CEC). All amendments to the Building Code must be filed with the California Building Standards Commission.

Jurisdictions may wish to modify elements of the ordinance, such as those marked with the text “[Optional]”. When modifying the language, ensure all references are maintained and that the ordinance still meets the State requirements.

The headings, footnotes and instructions (in blue) are for staff reference and should be removed from the final ordinance.

The draft ordinance text is provided as an example only. Jurisdictions should be aware that there have been legal challenges to policies that prohibit the installation of gas appliances, and while this policy is quite different, there is a risk that it could also be challenged; consultation 890 of 961

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with the city/county attorney is recommended. Ensure all ordinance materials are reviewed and verified by relevant jurisdiction staff and the city/county attorney.

Additional Resources
 Local Ordinance Basics
 Local Energy Codes Options and Opportunities
 Single Family Residential Retrofit Cost Effectiveness Report Single Family AC to Heat Pump Cost Effectiveness Report (forthcoming) State Submittal Guidance (update forthcoming)
Application Checklist (forthcoming)
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Model Ordinance
ORDINANCE AMENDING THE [CITY/COUNTY OF JURISDICTION] BUILDING CODE TO REQUIRE

ENERGY CONSERVATION MEASURES FOR AIR CONDITIONER ALTERATIONS, REPLACEMENTS

AND INSTALLATIONS IN EXISTING SINGLE-FAMILY BUILDINGS

DELETE ALL BLUE TEXT
Findings
Amendments to the State Building Code require jurisdictions to make certain express findings; additional findings are required to support amendments to the State Energy Code. Refer to Guide for Local Amendments of Building Standards 2022 for more information. Required findings include:
A declaration of the authorities granted by the State to the jurisdiction to amend the code, which include:
oHealth and Safety Code sections 17958.7 and 18941.5
oPublic Resources Code Section 25402.1(h)(2)
oSection 10-106 of the Building Energy Efficiency Standards A determination that the amendments are reasonably necessary to address local climatic, geological, or topographical conditions
A determination that the proposed standards are cost-effective and a reference to the supporting analysis
A declaration that the jurisdiction has at a public meeting, adopted its determination that the standards are cost-effective
A determination that the proposed standards are more stringent than the State Energy Code and that they will require buildings to be designed to consume less energy than permitted by the State Energy Code
Any findings, determinations, declarations, or reports, including any negative declaration or environmental impact report, required pursuant to the California Environmental Quality Act
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Sample Amendments
Chapter [cite local code section] of the [local jurisdiction municipal/county code], adoption of the 2025 California Green Building Standards Code, Title 24, Part 11, is hereby amended to add the following section as mandatory.

A4.204.1 Energy Efficiency. Alterations to existing residential buildings shall comply with Sections A4.204.1.1 and A4.204.1.2.

A4.204.1.1 Altered Space-Conditioning System Serving Existing Single-Family Dwelling Units – Mechanical Cooling. When a space-conditioning system serving an existing single-family dwelling unit is altered in climate zones 1 through 14 and 16 by installation or replacement of an air conditioner, the altered system shall comply with either a or b below in addition to the requirements for installation specified by Title 24, Part 6, Sections 150.2(b)1E and 150.2(b)1F:
a. A heat pump shall be the primary heating source and sized according to the system selection requirements specified by Title 24, Part 6 of Section 150.0(h)5. Supplemental heating may be provided by an existing gas furnace or existing electric resistance heating as specified in Title 24, Part 6, Sections 150.0(h)7 and 150.0(i); or b. An air conditioner shall meet the following all the requirements in either subsection I or II below:

I. Systems with Existing Duct Distribution Systems:

I. R-8 duct insulation for ducts located in unconditioned space; and A. II. The duct system measured air leakage shall be equal to or less than 510 percent of the system air handler airflow as confirmed through field verification and diagnostic testing, per the requirements in Title 24, Part 6, Reference Residential Appendix Section RA3.1.4.3.1; and
Exception 1 to A4.204.1.1bIA. If it is not possible to meet the duct sealing requirements, all accessible leaks shall be sealed and verified through a visual inspection and a smoke test by a certified ECC-Rater utilizing the methods specified in Reference Residential Appendix Section RA3.1.4.3.5.

Exception 2 to A4.204.1.1bIA: Existing duct systems, constructed, insulated or sealed with asbestos.

B. III. Demonstrate, in every control mode, airflow greater than or equal to 400 300 CFM per ton of nominal cooling capacity through the return grilles, and an air- handling unit fan efficacy less than or equal to 0.45 W/CFM. The airflow rate and fan efficacy requirements in this section shall be confirmed through field verification and diagnostic testing, following the procedures outlined in Title 24, Part 6, Reference Residential Appendix RA3.3; and
Exception 1 to A4.204.1.1bIB: Systems unable to comply with the minimum airflow rate and system efficacy requirements shall demonstrate compliance by satisfying all of the following:
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1. Following the procedures in Section RA3.3.3.1.5;

2. Installing a system thermostat that conforms to the specifications in Section 110.12;

3. For standard ducted systems (without zoning dampers), meet the applicable minimum total return filter grille nominal area requirements in Table 150.0-B or 150.0-C as confirmed by field verification and diagnostic testing in accordance with the procedures in Reference Residential Appendix Sections RA3.1.4.4 and RA3.1.4.5. The design clean-filter pressure drop requirements specified by Section 150.0(m)12D for the system air filter(s) shall conform to the requirements given in Tables 150.0-B and 150.0-C.

Exception 2 to Section A4.204.1.1bIB: Multispeed compressor systems or variable speed compressor systems shall verify air flow (cfm/ton) and fan efficacy (Watt/cfm) for system operation at the maximum compressor speed and the maximum air handler fan speed.

Exception 3 to Section A4.204.1.1bIB: Gas furnace air-handling units manufactured prior to July 3, 2019 shall comply with a fan efficacy value less than or equal to 0.58 W/cfm as confirmed by field verification and diagnostic testing in accordance with the procedures given in Reference Residential Appendix RA3.3.

C. IV. In all climate zones, refrigerant charge verification requirements shall meet the requirements in Title 24, Part 6 Section 150.2(b)1Fiib, including the minimum airflow rate specified in Section 150.2(b)1Fiia; and
D. V. Vented attics shall have insulation installed to achieve a U-factor of 0.020 or insulation installed at the ceiling level shall result in an insulated thermal resistance of R-49 or greater for the insulation alone; luminaires not rated for insulation contact must be replaced or retrofitted with a fireproof cover that allows for insulation to be installed directly over the cover; and Exception 1 to Section A4.204.1.1(b)ID: Dwelling units with at least R-38 existing insulation installed at the ceiling level.

Exception 2 to Section A4.204.1.1(b)ID: Dwelling units where the alteration would directly cause the disturbance of asbestos unless the alteration is made in conjunction with asbestos abatement.

Exception 3 to Section A4.204.1.1(b)ID: Dwelling units with knob and tube wiring located in the vented attic.

Exception 4 to Section A4.204.1.1(b)ID: Where the accessible space in the attic is not large enough to accommodate the required R-value, the entire accessible space shall be filled with insulation provided such installation does not violate Section 806.3 of Title 24, Part 2.5.

E. VI. Air seal all accessible areas of the ceiling plane between the attic and the conditioned space including all joints, penetrations and other openings that are 894 of 961

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potential sources of air leakage by caulking, gasketing, weather-stripping or otherwise sealing to limit infiltration and exfiltration.

Exception 1 to Section A4.204.1.1bIE: Dwelling units with at least R-38 existing insulation installed at the ceiling level.

Exception 2 to Section A4.204.1.1 bIE: Dwelling units where the alteration would directly cause the disturbance of asbestos unless the alteration is made in conjunction with asbestos abatement.

Exception 3 to Section A4.204.1.1bIE: Dwelling units with atmospherically vented space heating or water heating combustion appliances located inside the pressure boundary of the dwelling unit.

II. Entirely New or Complete Replacement Duct Systems:

A. I. R-8 duct insulation shall be installed for all new ducts located in unconditioned space; and
B. II. The total duct system measured air leakage shall be equal to or less than 5 percent of the system air handler airflow as confirmed through field verification and diagnostic testing, per the requirements in Title 24, Part 6, Reference Residential Appendix Section RA3.1.4.3.1; and
C. III. Demonstrate, in every control mode, airflow greater than or equal to 400350 CFM per ton of nominal cooling capacity through the return grilles, and an air- handling unit fan efficacy less than or equal to 0.35 W/CFM. The airflow rate and fan efficacy requirements in this section shall be confirmed through field verification and diagnostic testing, following the procedures outlined in Title 24, Part 6, Reference Residential Appendix RA3.3; and
D. IV. In all climate zones, refrigerant charge verification requirements shall meet the requirements in Title 24, Part 6 Section 150.2(b)1Fiib; and E. V. In Climate Zones 1-4, 6, and 8-16 if the air handler and ducts are located within a vented attic, vVented attics shall have insulation installed to achieve a U-factor of 0.020 or insulation installed at the ceiling level shall result in an insulated thermal resistance of R-49 or greater for the insulation alone; luminaires not rated for insulation contact must be replaced or retrofitted with a fireproof cover that allows for insulation to be installed directly over the cover; and Exception 1 to Section A4.204.1.1bIIE: In Climate Zones 1, 3, and 6, dwelling units with at least R-19 existing insulation installed at the ceiling level.

Exception 2 to Section A4.204.1.1bIIE: Dwelling units where the alteration would directly cause the disturbance of asbestos unless the alteration is made in conjunction with asbestos abatement.
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Exception 3 to Section A4.204.1.1bIIE: Dwelling units with knob and tube wiring located in the vented attic.

Exception 4 to Section A4.204.1.1bIIE: Where the accessible space in the attic is not large enough to accommodate the required R-value, the entire accessible space shall be filled with insulation provided such installation does not violate Section 806.3 of Title 24, Part 2.5.

F. VI. In Climate Zones 2, 4, and 8-16, aAir seal all accessible areas of the ceiling plane between the attic and the conditioned space including all joints, penetrations and other openings that are potential sources of air leakage by caulking, gasketing, weather-stripping or otherwise sealing to limit infiltration and exfiltration.

Exception 1 to Section A4.204.1.1bIIF: Dwelling units with at least R-19 existing insulation installed at the ceiling level.

Exception 2 to Section A4.204.1.1bIIF: Dwelling units where the alteration would directly cause the disturbance of asbestos unless the alteration is made in conjunction with asbestos abatement.

Exception 3 to Section A4.204.1.1bIIF: Dwelling units with atmospherically vented space heating or water heating combustion appliances located inside the pressure boundary of the dwelling unit.

Exception 1 to Section A4.204.1.1: Where the capacity of the existing main electrical service panel is insufficient to supply the electrical capacity of a heat pump and where the existing main electrical service panel is sufficient to supply a new or replacement air conditioner, as calculated according to the requirements of California Electrical Code Article 220.83 or Article 220.87. Documentation of electrical load calculations in accordance with Article 220 must be submitted to the enforcement agency prior to permitting for both the heat pump and proposed air conditioner.

Exception 2 to Section A4.204.1.1: Where the required capacity of a heat pump to meet the system selection requirements of Section 150.0(h)5 is greater than or equal to 12,000 Btu/h more than the greater of the required capacity of an air conditioner to meet the design cooling load OR the capacity of the existing air conditioner. Documentation of heating and cooling load calculations in accordance with 150.0(h) must be submitted to the enforcement agency prior to permitting for both the heat pump and proposed air conditioner. 896 of 961

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Other Sample Ordinance Sections
Section 2: CEQA
This ordinance is exempt from CEQA under 15061(b)(3) on the grounds that these standards are more stringent than the State energy standards, there are no reasonably foreseeable adverse impacts and there is no possibility that the activity in question may have a significant effect on the environment.

Section 3: Severability
If any word, phrase, sentence part, section, subsection or other portion of this amendment or any application thereof to any person or circumstance is declared void, unconstitutional, or invalid for any reason, then such word, phrase, sentence, part, section, subsection, or other portion, or the prescribed application thereof, shall be severable, and the remaining provisions of this amendment, and all applications thereof, not having been declared void, unconstitutional or invalid, shall remain in full force and effect.  The [name of governing body] hereby declares that it would have passed this amendment and each section, subsection sentence, clause and phrase of this amendment, irrespective of the fact that any one or more sections, subsection, sentences, clauses or phrases is declared invalid or unconstitutional.

Section 4: Violations
Violation of the requirements of this Chapter shall be considered an infraction of the [jurisdiction Municipal/County Code], punishable by all the sanctions prescribed in [cite local reference to infractions].

Section 5: Effective Date
This ordinance shall become effective as of [DATE], upon approval of the California Energy Commission or upon the date the California Building Standards Commission (CBSC) accepts the ordinance for filing, whichever is later.
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9d
25-87656

CITY OF GLENDALE, CALIFORNIA

REPORT TO THE CITY COUNCIL

AGENDA ITEM
Report: Ordinance Amending Glendale Municipal Code provisions regarding meetings, powers and duties of the Commission on the Status of Women

1. Introduction of Ordinance Amending Sections 2.38.090 and 2.38.140 of the Glendale Municipal Code, 1995 – Relating to the Commission on the Status of Women.

COUNCIL ACTION
Item Type: Action Item
Approved for August 19, 2025 calendar

EXECUTIVE SUMMARY
During its March 18, 2025, Council recommended certain changes to the frequency of meetings of the Commission on the Status of Women and their powers and duties. This report provides those amendments by changing the frequency of meetings from quarterly to monthly. It further amends the provisions pertaining to the Commission’s powers and responsibilities, to include regular programming based on policy recommendations of the Commission’s Report on the Status of Women and Girls and the City’s Workforce Demographics Report, engaging in community partnerships and fundraising.

RECOMMENDATION
Introduce and adopt the Ordinance as directed by City Council.

ANALYSIS

BACKGROUND
The Commission on the Status of Women (CSW) was originally established in 2003 to serve as an advisory body to the City Council, providing recommendations on policies, programs, and services that address the needs of women in Glendale.

Per Glendale Municipal Code (“GMC”) Section 2.38.140, the powers and duties of the Commission were established as follows:
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be to assess and evaluate the needs and issues of women in the City in order to inform and advise the City Council, City departments and divisions, and other community agencies and organizations of those needs and issues; recommend programs or legislation to the City Council to promote and ensure equal rights and opportunities to and for women in the City; to promote education on issues regarding matters involving the needs of women and to prepare and disseminate such information; provide outreach information and education that empowers women to achieve self-sufficiency and self-esteem; maintain an active liaison with groups, organizations, agencies and individuals in regard to issues related to women; perform other duties as may be imposed upon the Commission by the City Council by ordinance or resolution."
Since its inception, the CSW has undergone multiple modifications, including changes to its composition, meeting frequency, and overall function. The Council has directed the restoration of CSW’s programmatic function and an increase in the frequency of its regular meetings. To that end, the City Attorney has prepared a draft ordinance for the Council’s consideration. The draft Ordinance increases the regular meeting schedule from quarterly to monthly, and modifies the CSW’s powers and duties, as follows:

The powers and duties of the commission on the status of women shall be to assess and evaluate the needs and issues of women in the city in order to inform and advise the city council, city departments and divisions, and other community agencies and organizations of those needs and issues; recommend and organize programs or legislation to the city council to promote and ensure equal rights and opportunities to and for women in the city based on the Report on the Status of Women and Girls prepared from time to time at the behest of the commission and the City’s Workforce Demographics Report; to promote education on issues regarding matters involving the needs of women and to prepare and disseminate such information; provide outreach information and education that empowers women to achieve self-sufficiency and self-esteem; engage and maintain an active liaison with groups, organizations, agencies and individuals in regard to issues related to women; explore and engage in fundraising activities; perform other duties as may be imposed upon the commission by the city council by ordinance or resolution.

STAKEHOLDERS/OUTREACH
N/A

FISCAL IMPACT
There is no direct fiscal impact associated with adoption of the proposed ordinance.

The existing position headcount will be transferred from the City Clerk’s departmental to the City Manager’s Office within the General Fund in order to accommodate the 899 of 961

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increased meeting frequency and programmatic functions for the CSW.

ENVIRONMENTAL REVIEW (CEQA/NEPA)
The ordinance implementing changes to the CSW is exempt from environmental review under the California Environmental Quality Act ("CEQA") pursuant to Title 14 of the California Code of Regulations ("CEQA Guidelines"). The proposed ordinance is not a “project” for CEQA purposes as it involves only organizational and administrative activities of government. CEQA Guidelines Sec. 15378(b)(5). It is further exempt since it can be seen with certainty that there is no possibility that the activity may have a significant effect on the environment per CEQA Guidelines Section 15061(b)(3).

CAMPAIGN DISCLOSURE
This item is exempt from campaign disclosure requirements.

ALTERNATIVES TO STAFF RECOMMENDATION

1. The Council could choose not to introduce or adopt the ordinance.

2. City Council may elect to consider any other alternative not proposed by staff.

ADMINISTRATIVE ACTION
Submitted by:

Michael J. Garcia, City Attorney
Prepared by:

Lucy Varpetian, Principal Assistant City Attorney
Approved by:

Roubik R. Golanian, P.E., City Manager

EXHIBITS/ATTACHMENTS
Click or tap here to enter text.
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ORDINANCE NO. ____________

AN ORDINANCE OF THE COUNCIL OF THE CITY OF GLENDALE,
CALIFORNIA AMENDING SECTIONS 2.38.090 and 2.38.140 OF
THE GLENDALE MUNICIPAL CODE, 1995, PERTAINING TO THE

FREQUENCY OF MEETINGS AND POWERS AND DUTIES

OF THE COMMISSION ON THE STATUS OF WOMEN
BE IT ORDAINED BY THE COUNCIL OF THE CITY OF GLENDALE, CALIFORNIA:

SECTION 1. Section 2.38.090 of the Glendale Municipal Code, 1995, is amended to read as follows:
§ 2.38.090 Meetings.

A. The commission shall meet at least once quarterly a month at such time and place as the commission may fix by resolution, consistent with the dates and times available for televising the meetings.

B. Special meetings of the commission may be called at any time by the chairperson, or three voting members thereof by written notice served upon each member as required by the Ralph M. Brown Act.

C. All meetings of the commission shall be open to the public and held in compliance with the provisions of the Ralph M. Brown Act. The commission on the status of women shall keep a record of minutes of all its proceedings and actions which shall be available for public inspection.

SECTION 2. Section 2.38.140 of the Glendale Municipal Code, 1995, is amended to read as follows:
§ 2.38.140 Powers and duties—Generally.

The powers and duties of the commission on the status of women shall be to assess and evaluate the needs and issues of women in the city in order to inform and advise the city council, city departments and divisions, and other community agencies and organizations of those needs and issues; recommend and organize programs or legislation to the city council to promote and ensure equal rights and opportunities to and for women in the city based on the Report on the Status of Women and Girls prepared from time to time at the behest of the commission and the City’s Workforce Demographics Report; to promote education on issues regarding matters involving the needs of women and to prepare and disseminate such information; provide outreach information and education that empowers women to achieve self- sufficiency and self-esteem; engage and maintain an active liaison with groups, organizations, agencies and individuals in regard to issues related to women; explore and engage in fundraising activities; perform other duties as may be imposed upon the commission by the city council by ordinance or resolution.
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Adopted by the Council of the City of Glendale on the _____ day of , 2025. _________________________________
Mayor
ATTEST:
______________________________
City Clerk

STATE OF CALIFORNIA )
) SS.

COUNTY OF LOS ANGELES )
I, Suzie Abajian, Ph.D., City Clerk of the City of Glendale, hereby certify that the foregoing Ordinance No. ______ was adopted by the Council of the City of Glendale, California, at a regular meeting held on the _____ day of _______________, 2025, and that the same was adopted by the following vote:

Ayes:

Noes:

Absent:

Abstain:

______________________________
City Clerk
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10a

CITY OF GLENDALE, CALIFORNIA

REPORT TO THE CITY COUNCIL

AGENDA ITEM
Report: Professional Services Agreement with Architectural Resources Group for preparation of a Historic District Survey for the proposed Verdugo Woodlands historic district.

1. Motion authorizing the City Manager or his designee to execute a Professional Services Agreement with Architectural Resources Group for a historic district survey for the proposed Verdugo Woodlands historic district for a not-to-exceed contract amount of $91,760.

2. Resolution of appropriation in the amount of $91,760 for the Verdugo Woodlands historic district survey.

3. Motion requiring the applicants to circulate a petition within the proposed Verdugo Woodlands historic district obtaining the support of the owners of more than 25% of the properties in the proposed district.

COUNCIL ACTION
Item Type: Hearing
Approved for August 12, 2025 calendar

EXECUTIVE SUMMARY
The preparation of a historic district survey is a required step in the Glendale district designation process. On August 15, 2024, the Historic Preservation Commission reviewed an application for a proposed Verdugo Woodlands historic district. After considering public testimony and sitting in on the community forum held just before the hearing, the Commission found that the application contained sufficient information to suggest the proposed area may meet the City’s thresholds and criteria for district designation. This vote moved the application forward to the next step in the designation process, which is conducting a historic district survey.

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Councilmembers whose families own property in the proposed Verdugo Woodlands district or within 500 feet of its boundary, consideration of the survey funding was pulled out for separate consideration, which is the subject of tonight’s hearing. Since City Council previously authorized a contract with Architectural Resources Group (ARG) to conduct the East-West Glendale Historic Context and Survey, there will still be efficiencies in including the Verdugo Woodlands district survey with the larger survey since the consulting team will already be researching and conducting field survey in the area and is already familiar with the history of its development.

RECOMMENDATION
City Council authorize a Professional Services Agreement with Architectural Resources Group to conduct a historic district survey for the proposed Verdugo Woodlands historic district and approve a Resolution of Appropriation for $91,760.

ANALYSIS
Background
The proposed district consists of the portion of the Verdugo Woodlands neighborhood located to the west of Canada Boulevard, which serves as the eastern boundary. The south side of San Gabriel Avenue is suggested as the northern boundary and Verdugo Park is included at the south. The west boundary is irregular but generally conforms to the areas of relatively early development at the lower elevations of the Verdugo Mountains. The proposed district will surround the Niodrara Drive Historic District, which was designated in 2016. The proposal includes 788 properties, but includes the previously designated Niodrara Drive Historic District, containing thirty-two homes. For this reason, the exact number of properties is uncertain pending a decision by the City about whether Niodrara Drive will remain a standalone district or if it will be subsumed into a new, larger district.

The area features a number of early residences, including the Catalina Verdugo Adobe (GR No. 1, c. 1860) and the 1912 home of the Verdugo Woodland’s initial developer, John Pirtle. Several Craftsman-style homes from the 1910s and 1920s remain, but much of the area’s development reflects the Revival styles popular in the 1920s and 1930s, along with the Minimal Traditional style that came to prominence in the years prior to World War II. Numerous Ranch and Modern style properties were built on undeveloped lots in the 1940s and 1950s, with the neighborhood being largely built about by the mid-1960s. True to its name, the area is notable for the number of mature trees on both private and public property, including the many oaks and sycamores that dominate its streetscapes.

The district application was reviewed by HPC on August 15, 2024. This is the first proposed district to be reviewed under the streamlined designation process approved by City Council in 2023. The Commission made a preliminary finding that the proposed district appears likely to meet the thresholds and criteria requirements established in the Historic Preservation Ordinance (GMC 30.25) and voted to authorize staff to begin the process for retaining a historic preservation consulting firm to conduct a survey of the area. This decision also shifted the proposed area’s status from “proposed district” to “pending district,” meaning that design review authority shifted from DRB and the 904 of 961

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Citywide Design Guidelines to HPC and the Historic District Design Guidelines.

At the hearing and the preceding community forum, speakers and callers expressed a variety of opinions about designating a district, ranging from strong support to strong opposition. Under the streamlined designation process, the Commission chose not to invoke the option to require a petition requiring the owners of over 25% of the properties in the area to request that the City conduct the survey. At the present hearing, Council has the same option if it desires to better gauge the level of support before deciding whether to authorize the survey.

Historic District Survey
Historic district surveys are different than historic resource surveys. Their focus is on determining the overall character of a specific area and identifying the properties that contribute to that character and those that do not. District surveys also assess a proposed district against the set of thresholds and criteria established in the Glendale Municipal Code. Until a survey is completed, it is unknown whether the proposed district will qualify for designation or if its proposed boundary will be found appropriate.

Because the Verdugo Woodlands neighborhood is in the East-West Glendale study area, staff asked the preferred bidder for that project to provide a supplemental bid for conducting the Verdugo Woodlands historic district survey.

ARG proposes to produce the Verdugo Woodlands survey for $91,760. This fee works out to about $114 per property for the approximately 750 houses within the proposed boundary. The per property cost is in keeping with those for other recent district surveys.

Councilmember Participation
Mayor Najarian and Councilmembers Brotman and Gharpetian own property in or within 500 feet of the proposed historic district. As such, they generally have a conflict of interest under the Political Reform Act and the regulations of the Fair Political Practices Commission (“FPPC”). Under FPPC regulations, it is reasonably foreseeable that decisions on the proposed historic district will have material financial effects on their real property. The City sought advice from the FPPC on this issue. In its advice letter (Exhibit 6), the FPPC confirmed the conflicts.

Notwithstanding these conflicts, the FPPC also opined that its regulations permit the City to invoke the “legally required participation” exception to select councilmembers to be selected at random to form a quorum with respect to the decisions necessary to act on the proposed historic district. No more conflicted councilmembers may participate in decisions than are necessary to lawfully take action on the item. For purposes of the decision on authorizing a survey and approving an appropriation, that quorum is three councilmembers. Thus, one of the three conflicted councilmembers will be selected at random to form a quorum with the other two councilmembers and participate in the decision whether to authorize the survey and appropriate the funds. That councilmember will then participate in any future decisions on the proposed district. 905 of 961

410a
6 1
9 3
Additional councilmembers may be selected at random for future decisions, if any, where a supermajority is required to take action, e.g. the four-vote supermajority necessary to adopt the historic district.

STAKEHOLDERS/OUTREACH
Outreach for proposed historic districts is built into the Glendale Municipal Code. The first required community forum and HPC hearing for the pending Verdugo Woodlands historic district was held on August 15, 2024. Notice of this meeting was mailed to owners and residents of properties inside the proposed boundary and within a 500-foot radius. A notice indicating the outcome of the HPC meeting was subsequently mailed to the same group. This notice explained that the Commission’s vote led to the change of the area within the proposed boundary to the status of “pending historic district” and shifted the design review authority for projects proposed during the period the district remains under consideration.

FISCAL IMPACT
The cost for the Verdugo Woodlands Historic District Survey is $91,760, which was not included as a part of the FY 25-26 budget. Staff is requesting an appropriation of $91,760 from the General Fund balance. The appropriation request is outlined below:

Requesting Appropriation
Amount From (Account
String)
To (Account String) Funding Source
$91,760 25300-1010-000 43110-1010-CDD-
2502-P0000
General Fund

ENVIRONMENTAL REVIEW (CEQA/NEPA)
The project is exempt from CEQA as a Class 8 “Actions by Regulatory Agencies for Protection of the Environment” exemption pursuant to Section 15308 of the State CEQA Guidelines because historic contexts and surveys provide information and guidance that will help protect the city’s historic built environment.

CAMPAIGN DISCLOSURE
The names and business addresses of the members of the board of directors, the chairperson, CEO, COO, CFO, Subcontractors and any person or entity with more than 10% interest in the company proposed for contract in this report are attached in Exhibit #1, in accordance with the City Campaign Finance Ordinance No. 5744.

ALTERNATIVES TO STAFF RECOMMENDATION

1. Do not authorize a Professional Services Agreement with Architectural Resources Group for preparation of the Verdugo Woodlands historic resource survey and adopt a Resolution of Appropriation for $91,760.

2. Direct historic district proponents to circulate a petition requesting that City Council authorize completion of a historic district survey.

3. Any other alternative not proposed by staff.
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510a
6 1
9 3

ADMINISTRATIVE ACTION
Submitted by:

Bradley Calvert, Director of Community Development
Prepared by:

Jay Platt, Principal Planner
Approved by:

Roubik R. Golanian, P.E., City Manager

EXHIBITS/ATTACHMENTS
Exhibit 1: ARG Revised Fee for Verdugo Woodlands Survey Exhibit 2: Verdugo Woodlands Historic District Application Exhibit 3: Map of Proposed District
Exhibit 4: Streamlined District Designation Process Flow Chart Exhibit 5: Campaign Disclosure Form
Exhibit 6: FPPC Advice Letter dated December 23, 2024
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MOTION
Moved by Council Member ____________________________, seconded by Council Member ___________________________, that the City Manager, or designee, is hereby authorized to execute a professional services agreement with Architectural Resources Group for a historic district survey for the proposed Verdugo Woodlands historic district, in an amount not to exceed $91,760, as outlined in the August 12, 2025, staff report from the Director of Community Development. Said agreement shall be subject to approval as to form by the City Attorney.

Vote as follows:

Ayes:

Noes:

Absent:

Abstain:
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RESOLUTION
NO

RESOLUTION
OF
THE

COUNCIL
OF
THE
CITY
OF

GLENDALE
MAKING
AN

APPROPRIATION
BE
IT

RESOLVED
BY
THE

COUNCIL
OF
THE
CITY
OF
GLENDALE:

SECTION
1:

That
the
sum
of
$91,760
is
hereby
appropriated
and/or
transferred
from
the
following
accounts
to
the
following
accounts:

ACCOUNTS

DESCRIPTION
FROM
TO
25300-1010-000
Undesignated
Fund
Balance,
General
Fund
$91,760
43110-1010-CDD-2502-
Contractual
Services,
General
Fund,
Community
$91,760
P0000
Development
Department,
Urban
Design
&
Mobility
To
appropriate
funding
for
a
PSA
with
Architectural
Resources
Group
for
preparation
of
the
Verdugo
Woodlands
historic
district
survey.

SECTION
2:

The
Director
of
Finance
is
authorized
to
make
such
other
revisions,
individual
appropriation
line-items,
changes
in
summaries,
fund
totals,
grand
totals,
and
other
portions
of
the
budget
document
as
necessary
to
reflect
and
implement
the
changes
specified
in
this
resolution.

SECTION
3:

The
City
Clerk
shall
certify
to
the
adoption
of
this
Resolution.

Adopted
this
day
of
________________,
2025.

Mayor
ATTEST:

CITY
OF

GLENDALE
DATE
8/4/2025
(T)

APPROVED
AS
TO

FINANCIAL
City
Clerk

PROVISION
FOR
$

91.760
STATE
OF

CALIFORNIA)
1—
COUNTY
OF
LOS

ANGELES)
SS
_____________________________
CITY
OF

GLENDALE)
Director
of
Finance
I,Suzie
Abajian,
City
Clerk
of
the
City
of
Glendale,
do
hereby
certify
that
the
foregoing
Resolution
No.
was
adopted
by
the
Council
of
the
City
of
Glendale,
California,
at
aregular
meeting
held
on
the__________
day
of
________________,
2025,
and
that
the
same
was
adopted
by
the
following
vote:

Ayes:Noes:Absent:Abstain:

City
Clerk
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M O T I O N
Moved by Council Member _________________________, seconded by Council Member ___________________________, that, with respect to the Report to Council dated August 12, 2025 regarding the proposed Verdugo Woodland Historic District, the Council finds pursuant to Section 30.25.030(C)(2) of the Glendale Municipal Code that there is reason to require further public input to indicate the level of support for establishing a historic district overlay zone and requires the applicant to circulate a petition and obtain the signatures of owners of more than 25% of the properties within the proposed historic district prior to the City’s preparation and execution of the historic district survey contract with Architectural Resources Group.

Vote as follows:

Ayes:

Noes:

Absent:

Abstain:
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Fee Proposal: Verdugo Woodlands Historic District Survey PIC PM/Sr Hist Hist Intern Total Cost

1. Meetings and Project Administration
Participate in ongoing meetings and correspondence with City staff, as needed, for the duration of the project. 2 8 10 $1,920

2. Background Review and Historic Context
Review background materials obtained during the kickoff meeting; conduct additional primary and secondary source research as necessary. Confirm district boundary identified in the nomination.
8 16 16 40 $4,760
Prepare a historic context statement and eligibility standards specific to the proposed historic district, for inclusion in the survey report. 48 16 64 $10,880

3. Field Survey
Conduct field survey of the proposed historic district using a custom mobile documentation app (Fulcrum); data will include a list of architectural features, visible alterations, and three (3) high‐res photos of each property.
136 136 272 $44,880
Draft DPR 523a and 523d forms; organize and name photos per City of Glendale conventions; generate property spreadsheet. 40 20 20 80 $11,200
Produce GIS maps for inclusion in the survey report. 8 8 $1,240

4. Historic Resources Report (Draft)
Prepare draft Historic Resources Report with the following sections: project description and methodology, historic context, physical character, evaluation of eligibility, and DPR forms.

Submit for City review and comment.
4 40 24 68 $11,760

5. Meetings
Attend two (2) public meetings, including one (1) public meeting and one (1) Historic Preservation Commission meeting; present draft Historic Resources Report and survey findings. 4 4 $700

6. Historic Resources Report (Final)
Revise draft deliverables based on City and community feedback; submit final Historic Resources Report and DPR forms. 2 8 10 $1,920
Total Hours 8 292 220 36 556 $89,260
Hourly Rates $260 $175 $155 $55
Subtotal (per person) $2,080 $51,100 $34,100 $1,980
Subtotal Labor $89,260
Reimbursable allowance (estimated) $2,500
TOTAL NOT‐TO‐EXCEED FEE $91,760
1 /1
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Supporting Materials

Proposed Selvas de Verdugo Historic District

April 1, 2022
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Selvas de Verdugo Application

2 Figure 1. Map of boundaries of proposed Selvas de Verdugo Historic District. (Exclusions include the small commercial district and multi-family properties from 2425 Cañada Blvd. to 1654 Don Carlos Ave., 1400 - 1444 Hillside Drive, a tract resubdivided and developed in 1968, and an extension of San Luis Rey through Via Saldivar.)
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Selvas de Verdugo Application

3 Historic District Context Statement
Development History

The Verdugos, John Pirtle, and the Verdugo Canyon Land Company

The proposed Selvas de Verdugo historic district comprises a significant portion of the 3,300 acres allotted to Catalina Verdugo, the daughter of the original Mexican owner of the vast Rancho San Rafael, and her nephew Teodoro in the Great Partition of 1871. The proposed district includes the Catalina Verdugo adobe (built by Teodoro, 2211 Bonita Drive), a neighborhood landmark and important material reminder of the area’s rich Spanish and Mexican history. Another landmark on the property was the now deceased Oak of Peace, significant as the site of negotiations in 1847 that ultimately led to the end of the Mexican-American War.1

Efforts to develop the Verdugos’ property followed Teodoro’s death in 1904, and in 1906 the Forest Grove Land Company came into possession of Tract 250. There were plans to subdivide the land for residences; these failed, likely due to the lack of frequent, reliable public transportation. The local press at the time noted broken promises to build an electric railway from Los Angeles. Until 1910, the only public transportation adjacent to the property was the Salt Lake Railway, which served it infrequently. 2 In 1909 Tract 250 was acquired by the Verdugo Canyon Land Company, whose President John A. Pirtle had been involved with the Forest Grove Land Company. The boundaries of the renamed “Verdugo Canyon Tract” extended from the fork at Verdugo Road and Cañada Blvd. (south) to Glorietta Avenue (north), and from the foothills (west) to Verdugo Road (east). It included Verdugo Park, a favorite regional picnicking spot since at least the 1890s, which remained informal open space until the City of Glendale began acquiring land there for an official park in 1944 (see figure 2).3

Development of the tract was facilitated by the extension of the Glendale-Eagle Rock Railway line (a private line, opened in 1909) into the Verdugo Canyon in July 1910.

Pirtle provided the necessary right-of-way and subscribed $20,000 to guarantee its construction. To accommodate the railway tracks, Pirtle laid out Cañada Blvd. in a straight line, in contrast with the winding curves of nearby Verdugo Cañon Road (later renamed Verdugo Road).
4 1 Details of the history of the Verdugos’ property ownership and sales are found in “A Historical and Architectural Assessment of the Verdugo Adobe,” Glendale, California, prepared by Chambers Group, Inc. (August 1993), 5, Glendale Public Library, Special Collections (hereafter GPL-SC), Verdugo Adobe/Verdugo Family binder. For the Selvas de Verdugo historic district application, the applicants are indebted to the research of Architectural Resources Group on the Niodrara Drive Historic District historic context statement and Catherine Jurca for the Niodrara Drive Historic District application. 2 “The Verdugo Ranch,” Glendale News, October 2, 1909, GPL-SC, Verdugo Woodlands folders. See also “Verdugo Park to Be Cut Up,” Los Angeles Times, August 28, 1906, proquest. 3 See E. Caswell Perry and Carroll W. Parcher, Glendale Area History, 2nd ed. (Glendale, CA, 1981), 22, 167.
4 See “Road to Verdugo Park,” Glendale News, April 22, 1910; and “Extended to Verdugo Park,” Glendale News, July 8, 1910, GPL-SC, Verdugo Woodlands folders.
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Selvas de Verdugo Application

4 Pirtle’s name dominated Verdugo Canyon Tract advertising. He was called “the moving spirit” of the project, and he aimed for a high-class clientele. (figure 3).5 He worked hard

Figure 3. Postcard advertising the Verdugo
Canyon Tract, with John Pirtle’s name,
1910. Glendale Public Library, Special
Collections, Panoramas, Mountains,
Canyons binder.

to ensure that the subdivision preserved the area’s remarkable natural features. He hired noted San Francisco horticulturalist John McLaren, “the father of Golden Gate Park,” to

5 “Transformation of Big Ranch,” Los Angeles Times, September 28, 1909, proquest.

Figure 2. Members of the
Concordia Club, Los Angeles,
picnicking in Verdugo Park,
1908. Los Angeles Public
Library Photo Collection.
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Selvas de Verdugo Application

5 lay out the streets in keeping with the natural contours of the land and to ensure that no coast live oaks or sycamores would have to be removed.6

An ad in the Los Angeles Times described lots “one-half acre to three acres, rolling grounds, live oaks, sycamore trees, running water and parks.” 7 In May 1910 the
company advertised the creation of “the most beautiful and artistic illustrated booklet of its kind ever published in Los Angeles” (figures 4 and 5).8 This expensive brochure likewise touted “large villa lots, trees, running water” but primarily told its story in pictures, including photographs of Verdugo Park, a wonderful asset to potential homeowners. Pirtle’s brochure also included a photo of the lot on which he proposed to build a house, which he did in 1912 (2101 Cañada Blvd.), the oldest house within the proposed district.9

Figure 4. “Lover’s Bridge” in Verdugo Park.
“Verdugo Canyon Tract,” pamphlet, n.d.
(circa 1910), Huntington Library.

6 See ibid.
7 Ad for Verdugo Canyon Tract, Los Angeles Time, October 27, 1909, proquest. 8 Ad for Verdugo Canyon Tract, Los Angeles Times, May 12, 1910, proquest. 9 “Verdugo Canyon Tract,” n.d. (circa 1910), Huntington Library.

Figure 5. Future homesite of
developer John Pirtle.
“Verdugo Canyon Tract.”

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Selvas de Verdugo Application

6 The Verdugo Canyon Tract focused on development on the west side of Cañada, and the layout of streets closely resembles the present configuration. Ten east-west streets from Colina Drive to Glorietta Avenue (“Avenue F”), along with the north-south streets of Niodrara Drive, Bonita Drive, and Cañada, were mapped and over 200 lots created. By contrast, the east side of Cañada was divided as six giant lots with a single street— Opechee—running east-west.

Despite Pirtle’s ambitions, only a few houses were built in the 1910s. Nonetheless, the Verdugo Canyon territory, including Pirtle’s subdivision, was annexed to Glendale in 1912, only the second area to join the city following its incorporation in 1906. The annexation enabled the city to exert control over important water rights linked to the abundant natural streams.
10 Frederick Pennington Newport and Selvas de Verdugo

The pace of development picked up with the involvement of Frederick Pennington (F. P.) Newport, whose eponymous company purchased and re-subdivided much of the Verdugo Canyon Tract beginning in 1917. Newport re-named the area Selvas de Verdugo, later anglicized to Verdugo Woodlands, a name that eventually described a much larger area than that owned by Newport, extending as far as the 2 freeway (some properties on the far eastern edge of which were demolished to make way for it). Newport formally “opened” Selvas de Verdugo in June 1917, with a fiesta in Verdugo Park featuring Spanish music and dancing as well as lectures on California history by Charles F.

Lummis and former State Senator Reginaldo Francisco del Valle. 11 The Selvas de Verdugo tract was expansive and irregular, its boundaries shaped by prior land sales; from the west side of Cañada it included not only streets platted in 1909 but also several new streets that extended up into the foothills, as well as the highly picturesque Hermosita Drive, which curves north along the base of the hills. Selvas de Verdugo expanded through the mid-1920s; in 1922 it was extended north from Glorietta to Santa Maria Avenue, and again in 1924 to the south side of San Gabriel Avenue.

Newport also incrementally added property on the east side of Cañada Blvd., from the northern intersection of Cañada and Verdugo to the north side of El Rito. In addition, Newport owned and developed smaller tracts within the proposed historic district, including Fernbrook Place and other lots within the Niodrara Drive Historic District (designated 2016).

A brief biography of Newport in John Steven McGroarty’s Los Angeles from the Mountains to the Sea: With Selected Biography of Actors and Witnesses to the Period of Growth and Achievement (1921) specifically mentioned his “pioneering” development of “surpassingly beautiful home sites” in the “fertile foothill and valley lands in historic Verdugo Canyon.”
12 Like Pirtle, Newport emphasized the sylvan setting and touted

10 See “Vexatious Water Problem,” Los Angeles Times, October 19, 1912, proquest. 11 “Grand Spanish Fiesta Program is Announced,” Glendale News, June 7, 1917. GPL-SC, Verdugo Woodlands folders. Similar articles/promotions ran on June 8 and June 9 as well. 12 John Steven McGroarty, Los Angeles from the Mountains to the Sea: With Selected Biography of Actors and Witnesses to the Period of Growth and Achievement (Chicago: American Historical Society, 1921), 900.
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7 natural features: references to mature trees and flowing streams were ubiquitous in his advertisements. An ad in the Glendale Evening News from 1924, for example, refers simultaneously to its history as the “estate of the distinguished Verdugo family” and the area’s “early hacienda days,” while also claiming its affinities with “the Riviera, Switzerland, and the rustic lanes of the English countryside” (figure 6). Newport created an extravagant pamphlet of his own, which urged that “Verdugo Woodlands is like a

touch of old Switzerland,” with “[c]hattering brooks of sparkling mountain water—clear vistas of rugged mountains…laurel-covered foothills—great gnarled sycamores— evergreen live-oaks, clusters of alders.”13 Native oaks and sycamores are still prominent features of the proposed historic district.

Newport promised potential buyers a “high class” environment of single-family homes-- “Restrictions on the property protect it against the encroachment of commercial, tenement, apartment house, bungalow court” and other “undesirable feature[s]”--which could serve as a code for discouraging lower-income groups and racial minorities, who might find development conditions more difficult to satisfy. Despite these promises, Newport focused on smaller lots more scaled to 1920s suburban development, in contrast with the large “villa” properties favored by his predecessor. 14 13 “The Story of Verdugo Woodlands told in pictures,” n.d. (1920s), GPL-SC, Sparr Heights/Verdugo Woodlands binder.
14 “Restrictions Aid Tract’s Development,” Glendale Evening News, January 29, 1927, GPL-SC, Verdugo Woodlands folders.

Figure 6. Ad for “Verdugo Woodlands,”
Glendale Evening News, October 31,
1924, GPL-SC, Verdugo Woodlands
folders.
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Selvas de Verdugo Application

8 The proposed historic district had other developers, but Newport was by far the most prominent and active, bringing to fruition the vision for a sylvan suburban setting first formulated by John Pirtle. Newport remained the driving force until 1935, when the F. P.

Newport Company declared bankruptcy, one of many developer-victims of the Great Depression. The area was built out by the 1960s; later waves of development took place in areas beyond the proposed historic district boundaries, on streets that climbed higher into the foothills.

Relationship of District to Glendale Development Patterns, Events, and Persons.

Development Patterns

The neighborhood developed gradually at first and then steadily over decades, in keeping with patterns of development in other single-family neighborhoods in north Glendale.

Development was made possible with the opening of the Glendale-Eagle Rock Railway line in 1910, but it only truly flourished with the ascendance of the private automobile, which made the extension of sidewalk-less streets into the western foothills of Selvas de Verdugo desirable.

As in other older Glendale neighborhoods that developed over time, with contributions from architects and builders who gave their individual stamp to properties built one at a time, the style of architecture is eclectic rather than homogeneous. The Craftsman style is represented, while Period Revival and Minimal Traditional homes predominate among properties developed before World War II. During the post-war period undeveloped lots were filled in, typically with Ranch-style homes as well as with some fine examples of Mid-century Modern.

The proposed historic district “is united historically [and] aesthetically by plan or physical development” (GMC 30.25.015). The same themes that applied to the Niodrara Drive Historic District (designated 2016), apply to the larger Selvas de Verdugo historic district, which is unsurprising given the outsized influence of F. P. Newport on both.

Thus we propose the former be included within the larger historic district’s boundaries.

Niodrara Drive was designated primarily for its association with trends in residential development, subdivision design, and community planning, in particular those associated with a picturesque, sylvan ideal that sought to marry proximity to the city with a rejuvenating life in nature. Pirtle’s and Newport’s larger development activities were unique within Glendale in their consistent embrace of, and deference to, the natural environment, signaled by the initial hiring of San Franciscan horticulturalist John McLaren to lay out the streets so as to maximize natural features. This commitment is reflected in the river rock enclosures that protect trees in the middle of two streets, Niodrara Dr. and Selvas Place. While the landscaping along Niodrara is particularly striking, a similarly bucolic atmosphere pervades the rest of the proposed historic district.

The commitment to preserving and enhancing natural amenities, evoked accurately by the “Selvas/Woodlands” name, resulted in a cohesive streetscape characterized by curvilinear, intersecting streets that embrace the contours of the hillside terrain, use of native stone, mature trees with an emphasis on natives, a lack of sidewalks, and historic streetlamps.
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9 Not only is this area different in character from other neighborhoods in Glendale, but it is different from the east side of Cañada. The sliver of land between it and Verdugo Road is level. Streets are more linear and most dead-end at the Verdugo Wash, which forms a natural barrier. We believe that it would be possible in future to propose a second phase to the Selvas de Verdugo historic district from Cañada to the Wash. The development on the east side of Verdugo Road, only part of which is considered part of the Verdugo Woodlands, was not part of either the Verdugo Canyon or Selvas de Verdugo Tracts.

Events

The proposed historic district is the site of an important event in American history, the place, formerly memorialized by the Oak of Peace (figure 7), where the terms to end the Mexican-American War were negotiated in 1847, leading to the signing of the Treaty of Cahuenga. The former location of the oak is commemorated in the Catalina Verdugo Adobe park.

Persons

The proposed historic district is associated with several notable individuals who played an important role in the history and development of this area. Catalina and Teodoro Verdugo, daughter and grandson of the original Mexican owner Jose Verdugo, owned the land as part of the holdings allotted to them in the Great Partition of 1871 and resided in the adobe that gives the neighborhood and city park its name.

Developer John Pirtle was not only was president of the Verdugo Canyon Land Company, but as president of Glendale Consolidated Water Company he was a player in Glendale’s water wars, along with other such prominent figures as C. E. Thom and Figure 7. The Oak of Peace, n.d.

Los Angeles Public Library
Photo Collection.
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10 Erskine Ross.15 The water rights to the canyon had been divided up as carefully as the land in the Great Partition of 1871. This precious commodity, which enabled the development of Glendale by providing most water for domestic use, belonged proportionately to the various claimants based on the percentage of land they had been awarded.16 For decades much of Glendale’s water was thus controlled by a small number of prominent figures, with Glendale Consolidated controlling roughly 13 percent of the canyon’s water in 1912, according to the Los Angeles Times. 17 Pirtle was an original
resident of the Verdugo Canyon Tract as owner of a “villa lot” on Cañada, which originally spanned from Wabasso Way to Camulos. The property’s river rock wall and original house are extant.

F. P. Newport spurred development of Selvas de Verdugo/Verdugo Woodlands from 1917 until he lost his company to bankruptcy in 1935. He carried out Pirtle’s original vision for a residential development that married proximity to the city with all the amenities that a forested, water-rich natural environment afforded. He also helped to ensure the preservation of the historic Catalina Verdugo adobe.

Period of Significance

The suggested period of significance for the proposed historic district is 1909 – 1965.

This period aligns closely with the 1909 – 1962 period of significance for the Niodrara Drive Historic District. Apart from the adobe, which falls outside the period of significance, there are no buildings constructed before 1912; however, 1909 is appropriate as the date when the Verdugo Canyon Tract had been platted and open for inspection and when John McLaren made his notable contribution to the street plan and vision of this sylvan suburban neighborhood. There is still significant in-fill development into the mid-1960s. By 1966 there is a notable difference in the style of house, with a boxier massing that has more in common with development outside the proposed boundaries in 1968 and later than with the historic development within them.

Profile of Historic Resource Types

The Niodrara Drive Historic District, including its 32 properties and landscaping, is a historic resource within the boundaries of the proposed historic district.

Five properties in the proposed district are on the Glendale Register of Historic Resources. Several other properties are historically significant beyond their architectural merits. The list is by no means exhaustive, and further research will no doubt turn up other important properties.

15 See “The Verdugo Ranch,” Glendale News, October 2, 1909, GPL-SC, Verdugo Woodlands folders; “The Beautiful Verdugo Canyon,” Los Angeles Herald, April 17, 1910, California Digital Newspaper Collection; “Royal Boulevard Historic Resources Survey,” prepared by Historic Resources Group, City of Glendale, March 2008, 12; and “Vexatious Water Problem.” 16 John Calvin Sherer, History of Glendale and Vicinity (Glendale: Glendale History Publishing Company, 1922), 116. Sherer would know: he helped to organize the Verdugo Canyon Water Company and was president, secretary, and treasurer at various times as well as a stockholder. As such he was an internenor in an 1893 lawsuit over rights to the stream.
17 “Vexatious Water Problem,” Los Angeles Times, October 19, 1912, proquest. 923 of 961

Selvas de Verdugo Application

11 Catalina Verdugo Adobe, 2211 Bonita Drive

Built by Catalina’s nephew Teodoro (dates are variously cited as 1828 and 1860s or 1870s), the adobe is listed on the Glendale Register of Historic Resources (#1) and is listed on the National Register of Historic Places. Nearby was the Oak of Peace, also listed on the National Register, but the tree has since died of natural causes. The adobe— and plans for its preservation—was prominently mentioned in advertisements from both the Verdugo Canyon Land Co. and F. P. Newport.
18 The adobe falls outside the period of
significance. The adobe and its surroundings were purchased by the City of Glendale in 1989 and are now a city park.

Verdugo Park, 1621 Cañada Blvd.

Figure 9. Site Plan for Verdugo Park, Glendale, [1945], Ralph D. Cornell Papers, UCLA Library, Special Collections.

18 See, for example, “The Verdugo Ranch,” Glendale Evening News Real Estate, October 2, 1909, and “Beauties of Nature Are Carefully Preserved,” Glendale Evening News, October 31, 1924, p. 16, GPL-SC, Verdugo Woodlands folders.
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12 Verdugo Park was a major selling point for all iterations of development within the general Verdugo Woodlands area. It was never subdivided and remained informal open space before Glendale acquired it for a city park in 1944. The park was designed by celebrated landscape architect Ruth Shelhorn, working for Ralph Cornell. Shelhorn designed many important public landscaping projects in southern California including Disneyland and Bullocks Pasadena as well as other branches of the iconic department store.

Pirtle House, 2101 Cañada Blvd.

Side view of the 1912 Craftsman-influenced property built for John Pirtle, who created the initial subdivision as part of the Verdugo Canyon Land Company. Master architect and Glendale resident Alfred Priest designed the house. An octagonal roof-top dome is just visible through the foliage.

1616 Wabasso Way

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13 An outstanding example of Prairie Style/Foursquare architecture, neither of which is common in Glendale,1616 Wabasso Way was built in 1914 (corrected from 1912 in the Niodrara Dr. survey) by master architect and Glendale resident Alfred Priest. The house was used frequently to advertise Selvas de Verdugo. In addition, between 1924 – 1931 it was owned by the heavyweight boxing champion Jess Willard. It is a contributor to the Niodrara Dr. Historic District.

1360 San Luis Rey

This Mediterranean Revival was designed by master architect and Glendale resident Alfred Priest in 1924.

Dick House, 1639 Santa Barbara Ave.

This Spanish Colonial Revival residence was designed in 1926 by the famous, prolific theater architect S. Charles Lee, the year before he got his first theater commission, to 926 of 961

Selvas de Verdugo Application

14 design the Tower Theatre in downtown LA for H. L. Gumbiner. This property was recently listed on the Glendale Register.

Willard House, 2312 Blanchard St.

Willard House is number 113 on the Glendale Register and built in 1929. An English Revival with storybook elements, it was the residence of boxer Jess Willard after he moved from 1616 Wabasso Way.

Joy House, 1539 El Rito Ave.

Joy House is number 125 on the Glendale Register. It is one of a handful of Monterrey Colonial Revival properties in the Woodlands neighborhood, designed by noted architect Edward Mayberry in 1932.
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Selvas de Verdugo Application

15 Austin House, 1427 Andenes Dr.

Austin House is number 129 on the Glendale Register. It is an unusual Swiss chalet-style residence built in 1937.

Rodriguez House, 1845 Niodrara Dr.

Rodriguez House is number 24 on the Glendale Register. It is a modern wood frame, stucco, stone, and glass house designed by one of southern California’s most important and innovative architects, Rudolf Schindler, an Austrian émigré. It is located within the Niodrara Dr. Historic District and individually eligible for the National Register.

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Selvas de Verdugo Application

16 1900 Niodrara Dr.

This 1950 Rustic Ranch was designed by notable southern California architect, Robert Byrd, whose other works include the ranch house on actor Robert Taylor’s estate in Mandeville Canyon; a “tree house” on Laurel Canyon Blvd., where Frank Zappa lived; and the demolished Cielo House in Benedict Canyon, built for French actress Michele Morgan but best known as the house in which Sharon Tate and other victims of the Manson clan were murdered. Byrd, who was active from the 1930s through the 1960s, was known for working in an off-beat rustic style in which elements were combined somewhat higgeldly piggeldy: hence the nickname “Byrd House” for his works. It is a contributor to the Niodrara Dr. Historic District.

McKentley House, 2223 Bonita Dr.

This 1951 Mid-century Modern was designed in 1951 by noted architect Boyd Georgi.

Figure 20. McKentley House,
2223 Bonita Dr.

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17 Markwith House, 1350 Andenes Dr.

This 1965 Mid-century Modern was designed by the husband/wife, USC-trained, architecture team Denver and Marjorie Markwith for their family.

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Selvas de Verdugo Application

18 Architectural Styles within the Proposed District

The following photographs are by no means a comprehensive survey of architectural styles but rather are designed to serve as an introduction to the range of styles.

American Colonial Revival

1555 Hillside Dr.

1627 Don Carlos Ave.

2300 Blanchard Dr.

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Selvas de Verdugo Application

19 Craftsman

1601 Hillside Dr.

1601 Hillside Dr. can be seen on the north-east corner of Bonita and Hillside in this undated historic photo.

1643 Wabasso Way

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20 Dutch Colonial

1625 Opechee Way

1640 Santa Maria Ave.

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21 English Revival

1601 Wabasso

1638 Capistrano Ave.
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22 2401 Bonita Dr.
2407 Bonita Dr.
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23 Foursquare

1648 Del Valle Ave.

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24 French Revival

2301 Bonita Ave.

1347 San Luis Rey Dr.

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Selvas de Verdugo Application

25 Mediterranean Revival

1608 El Rito Ave.

1676 San Gabriel Ave.

2307 Blanchard Dr.

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Selvas de Verdugo Application

26 Mid-century Modern

1307 Opechee Way

1350 Capistrano Ave.

2400 Hermosita Ave.

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27 Minimal Traditional

1400 Andenes Dr.

1615 Ramona Ave.

1664 Santa Barbara Ave.

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Selvas de Verdugo Application

28 Mission Revival

2511 Hermosita Dr.

2207 Canada Blvd.

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Selvas de Verdugo Application

29 Monterey Colonial Revival

1383 Opechee Way

1658 San Gabriel Ave.

1602 Santa Rosa Ave.

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Selvas de Verdugo Application

30 Ranch

1326 Opechee Way

1604 Hillside Dr.

2900 Hermosita Dr.

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Selvas de Verdugo Application

31 Spanish Colonial Revival

1533 Opechee Way

2313 Andenes Dr.

2410 Hermosita Dr.

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Selvas de Verdugo Application

32 Storybook

1632 Don Carlos

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33 Tudor Revival

1614 Ramona Ave.

1626 Country Club Dr.

2411 Bonita Dr.

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34 Historic Streetlamps

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35 948 of 961

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Address Ranges

• 1344-1462 Andenes
• 2107-2128 Armour
• 2300-2324 Blanchard
• 1898-2411 Bonita
• 1501-1645 Camulos
• 1801-2421 Canada
• 2623-2967 Canada
• 1300-1661 Capistrano
• 1439; 1619; 1951 Colina
• 1600-2993 Country Club
• 1601-1661 Del Valle
• 1600-1661 Don Carlos
• 1400-1655 El Rito
• 1630-1647 Fernbrook
• 1602-1659 Glorietta
• 2301-2977 Hermosita
• 1309-1645 Hillside
• 1437-1515 La Vista
• 1800-2011 Niodrara
• 1300-1654 Opechee
• 1600-1651 Ramona
• 1606-1676 San Gabriel
• 1306-1370 San Luis Rey
• 1600-1681 Santa Barbara
• 1613-1681 Santa Maria
• 1602-2983 Santa Rosa
• 1345-1361 Selvas
• 2001-2023 Sierra
• 2211 Verdugo Court
• 1411-1643 Wabasso
• 1318-1630 Wabasso
• 2506; 2510; 2011 Weston
• Verdugo Park

Please note that this boundary is
the initial proposal made by the
applicants – it may change as the
process moves forward due to
community input or the findings of
the district survey.

Proposed Verdugo Woodlands Historic District Boundary

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Glendale Historic District Designation Process
Current Step for Proposed Verdugo Woodlands Historic District Public Input
Administrative

Optional Petition
Council or HPC may require
circulation of a petition to
show amount of support in
the neighborhood.

Optional Hearing
HPC may require another
hearing if the draft survey
needs substantial changes
that require more review.
. HPC/CC
discretion
Historic District Application
Planning Department Review and Recommendation
Community Forum and HPC Hearing
Review and discussion of district application and historic districts in general. HPC may authorize staff to move forward with process. Notice sent to owners/resident in proposed area and within 500-foot radius.

RFP/Bidder Recommendation by Staff
City Council Authorization of Funding and Contract
Planning Department/Consultant Completes Draft
Historic Resources Survey
Historic Preservation Commission
Review and Recommendation of Survey and
Community Forum
Notice and information sent to all owners and residents within proposed district

Petition
Proponents circulate petition requesting a historic district overlay zone
(requires 50+% homeowner support w/in 6 months to proceed – may begin before public meeting)

Planning Commission
Review and Final Recommendation
City Council Final Determination Current Step
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City of Glendale

DISCLOSURE - CAMPAIGN FINANCE ORDINANCE
The City Council adopted Ordinance No. 5744, “Campaign Finance Ordinance,” which became effective on September 9, 2011, and amended it with Ordinance No. 5768, which became effective on March 15, 2012 (“the Ordinance”). The Ordinance prohibits: (1) A contractor* (including a subcontractor**)― who has a contract with the City of Glendale (“City”), Economic Development Department (“EDD”), or the Housing Authority of the City of Glendale (“HA”) and that contract is subject to approval by the City Council, EDD, or HA― from making a contribution to a City Council member, EDD member, HA member, City Clerk, or City Treasurer; and (2) Council members, EDD members, and HA members from voting on matters concerning a contract with a person who has provided a campaign contribution.

The Ordinance applies to a contractor whose contract requires the City Council’s, EDD's, or HA’s approval. A contract with the City, EDD, or HA is known as a “City Contract.” The Ordinance also applies to a subcontractor who has a subcontract through a City Contract. The Ordinance excludes a competitively bid contract awarded to the lowest responsible bidder.

To assist members of the City Council, EDD, and HA before they vote on a matter regarding a City Contract, the Ordinance requires City staff to prepare this report which discloses certain information about: the contractor receiving the City Contract, and the subcontractor(s) working under the City Contract.

A contractor must provide the information listed below when: A subcontractor must provide the information listed below when:
•The City Contract has a total anticipated or actual value of $50,000 or more; or • The subcontract through a City Contract has a total anticipated or actual value of $25,000 or more; or
• A combination or series of City Contracts have a value of $50,000 or more. • A combination or series of subcontract s, for the same or different projects, have an aggregate value of $25,000 or
more. Information that must be disclosed: ● Name of the person, entity, or organization (i.e., the Contractor or Subcontractor) ● Name of the Chief Executive Officer/Pre
siden t
● Chief Operating Officer
● Chief Financial Officer
● Chairper
son
● All members of the Board of Directors
● All persons who own more than 10% of the perso
n, entity, or organi zation
● Name of any campaign committee owned or controll ed by the person, entity, or organization Please complete the following disclosure form:

Contractor(s)*:

Name Address
Full Name Title Business Address City State Zip
Chairperson
Chief Executive Officer / President
Chief Operating Officer
Chief Financial Officer
Board of Directors
More than 10% interest owner
*“Contractor” is the person, entity, or organization that is the party, or prospective party, to the contract with the City, EDD, or HA or any member of that person’s, entity’s, or organization’s Board of Direct ors, its Chairperson, Chief Executive Officer, Chief Financial Officer, Chief Operat ing Officer, any person with an ownership interest of more than ten percent (10%) in that person, entit y, or organization, and any campaign committee that is o wned or controlled by that person, entity, or organization. Above please disclose these persons’ name and business address.

Architectural Resources Group, Inc
Pier 9, The Embarcadero, #107, San Francisco, CA 94111
n/a
Naomi Miroglio
Pier 9, The Embarcadero, #107
San Francisco
CA
94111
n/a
n/a
Katie Horak, Naomi Miroglio, Lisa Yergovich
Pier 9, The Embarcadero, #107
San Francisco
CA
94111
Katie Horak, Naomi Miroglio, Debbie Cooper, Catherine Vieth, Lisa Yergovich, Maya Foty Pier 9, The Embarcadero, #107
San Francisco
CA
94111
contract
awarded to the lowest responsible bidder.
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Rev. 6/7/12 J:\FILES\DOCFILES\ORD\CAMPAIGN CONTRIBUTION\DISCLOSURE FORM – CONTRACTOR – 6-7-12.doc Subcontractor(s)**:

Name Address
Full Name Title Business Address City State Zip
Chairperson
Chief Executive Officer / President
Chief Operating Officer
Chief Financial Officer
Board of Directors
More than 10% interest owner
** “Subcontractor” is the person, entity, or organization that has entered into a contract for the performance of all or a portion of the work undertaken under an agreement with an architect, design professional, engineer, or gener al or prime contract, usually by a general or prime contrac tor. Subcontractor includes any member of that person’s, entity’s, or organization’s Board of Directors, its Chairperson, Chief Executive Officer, Chief Financ ial Officer, Chief Operating Officer, any person with an ownership interest of more than ten percent (10%) in that person, entity, or organization, and any campaign committee that is owned or controlled by that person, entity, or organization. Above please disclose these persons’ name and business address.

Campaign Committee owned or controlled by:

Title Business Address City State Zip

CERTIFICATION
On behalf of the above-named Contractor Subcontractor:
• I acknowledge that I have a continuing obligation to update this disclosure form if I substitute― or if I select additional ― archite cts, design professionals, contractors, or subcontractors within ten (10) days of the selection or change; and • I hereby certify that:
I have identified all persons for which the Ordinance requires disclos ure; The information in this disclosure form (and any attachment to this form) is true, accur ate, correct, and complete; and I have been legally authorized to submit this disclosure form.

In total, this disclosure form (including attachments) is pages.

Executed on: , 20 , at: , California.

Signature: Print Full Name:

Address:

Phone Number: E-mail Address:

Historic Resources Group, LLC
12 S Fair Oaks Ave, Suite 200, Pasadena, CA 91105-3816
n/a
-
-
-
-
n/a
-
-
-
-
n/a
-
-
-
-
n/a
-
-
-
-
n/a
-
-
-
-
Andrea Humberger, Christine Lazzaretto, Paul Travis
12 S Fair Oaks Ave, Suite 200
Pasadena
CA
91105-3816
2 August 14
24 360 E. 2nd Street, #225, Los Angeles
Katie Horak
360 E. 2nd Street, #225, Los Angeles, CA 90012
626-583-1401 x103
[email protected]
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STATE OF CALIFORNIA

FAIR POLITICAL PRACTICES COMMISSION
1102 Q Street • Suite 3050 • Sacramento, CA 95811
(916) 322-5660 • Fax (916) 322-0886
December 23, 2024
Michael J. Garcia
City Attorney
City of Glendale
613 E. Broadway, Suite 220
Glendale, California 91206-4394
Re: Your Request for Advice
Our File No. A-24-123
Dear Mr. Garcia:

This letter responds to your request for advice on behalf of City of Glendale City Councilmembers Dan Brotman, Ara Najarian, and Vartan Gharpetian regarding the conflict of interest provisions of the Political Reform Act (the “Act”). 1 Please note that we are only providing advice under the conflict of interest provisions of the Act and not under other general conflict of interest prohibitions such as common law conflict of interest or Section 1090.

Also note that we are not a finder of fact when rendering advice (In re Oglesby (1975) 1 FPPC Ops. 71), and any advice we provide assumes your facts are complete and accurate. If this is not the case or if the facts underlying these decisions should change, you should contact us for additional advice.

QUESTIONS

1. Do Councilmembers Brotman, Gharpetian, and Najarian have prohibited conflict of interests in making, participating in making or in any way using or attempting to use their positions to influence the decision to approve a contract with a consultant to prepare the Verdugo Woodlands Historic District survey, and participate in future governmental decisions pertaining to the approval of the district, considering their properties located in or within 500 feet of the proposed district?

2. If the councilmembers have a conflict of interest, can councilmembers be chosen at random to participate in the decisions under the rule and procedure for “legal required participation” as set forth in Regulation 18705?
1 The Political Reform Act is contained in Government Code Sections 81000 through 91014. All statutory references are to the Government Code, unless otherwise indicated. The regulations of the Fair Political Practices Commission are contained in Sections 18104 through 18998 of Title 2 of the California Code of Regulations. All regulatory references are to Title 2, Division 6 of the California Code of Regulations, unless otherwise indicated. 954 of 961

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Page No. 2

CONCLUSIONS

1. The facts provided do not establish clear and convincing evidence that the decisions will have no measurable impact on Councilmembers Brotman’s, Gharpetian’s, and Najarian’s real properties under the applicable regulations for property located within 500 feet and not explicitly involved in the decisions. Therefore, they have prohibitive financial interests and may not generally take part in the decision to approve a contract with a consultant to prepare the Verdugo Woodlands Historic District survey or participate in future governmental decisions pertaining to the approval of the district.

2. Although the Act prohibits Councilmembers Brotman, Gharpetian, and Najarian from taking part in the decisions, as explained bellow, the City may invoke the “legally required participation” exception to form a quorum of councilmembers with respect to the decisions, as specified in Regulation 18705.

FACTS AS PRESENTED BY REQUESTER
The City of Glendale was incorporated in 1906 and has several neighborhoods that retain architectural integrity that the City has deemed worthy of preserving. Thus, as outlined in the City’s Municipal Code, the City established a process to create historic district overlay zones to “protect the beauty of the city and improve the quality of its environment through identification, recognition, conservation, maintenance and enhancement of its historic and architectural resources within neighborhoods” and “to protect designated areas having historic and architectural significance against intrusion of alterations, additions, new structures and other designs that fail to protect such significance.” Notably, one of the other legislative purposes of historic districts in Glendale is to “stabilize and improve property values in such designated areas, thus strengthening the local economy.” The Glendale City Council is made up of five councilmembers who are elected from the City at large. The decision to select a consultant will require participation of a quorum of councilmembers, while future Council decisions pertaining to the formation of the District require approval of a four-fifths vote of the City Council.

Summary of Historic District Designation Process
The process to establish a historic district overlay zone is set forth in the Glendale Municipal Code (“GMC”). The process first requires that the owners of any three properties within the proposed district boundary (the “study area”) submit an application to the City’s Director of Community Development (“Director”). The application must include the proposed historic district overlay zone study area boundary, addresses of all properties to be included in the proposed historic district overlay zone, a written narrative describing the history and development of the area, and a statement describing why the proposed historic district overlay zone designation or modification meets the criteria for designation. Next, the Director must set a community forum and a public hearing before the City’s Historic Preservation Commission (“HPC”), the purpose of which is to inform residents and owners about the proposed historic district and historic districts in general, as well as answer questions; immediately following the community forum, the HPC must conduct the public hearing to make a preliminary determination whether the application contains sufficient information indicating the study area appears likely to meet the thresholds and criteria for purposes 955 of 961

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Page No. 3
of subsequently undergoing more detailed analysis. At the HPC’s hearing, the HPC may take one of the following three actions:

1. Preliminarily determine that the proposed historic district overlay zone appears to be eligible for designation or modification;

2. Determine the proposed historic district does not appear eligible for designation; or

3. Preliminarily determine that although the proposed historic district overlay zone appears eligible for designation or modification, additional evidence demonstrating public support for the application is warranted, in which case the HPC may require the applicant to circulate a petition requesting that the City Council authorize preparation of a historic district survey.

Upon the HPC’s determination that the proposed historic district overlay zone appears eligible for designation and the Director’s acceptance of any required petition, the proposed historic district overlay zone is deemed a “pending historic district overlay zone” until the application is approved or denied by the City Council or is withdrawn by the applicants. If deemed a “pending” district, design review authority for projects in the pending district is transferred from the City’s Design Review Board to the HPC and the City’s historic district design guidelines for design review replace any applicable general design review guidelines with respect to applications submitted subsequent to the date of the determination.

After the HPC’s preliminary determination, the Director must issue a request for proposals (“RFP”) to preservation consulting firms and prepare a ranked list of recommended consultants to be selected by the City Council. The chosen consultant completes a draft historic district survey, which the Director must set for review before the HPC.

At such hearing, the HPC may approve the draft historic district survey as presented or provide direction to the Director to make minor revisions. Once the HPC approves the final historic district survey, it issues its final recommendation to the City Council regarding the establishment of the historic district overlay zone and authorizes the project proponents to circulate a petition requesting a historic district overlay zone to affected property owners asking City Council to establish a historic district overlay zone.

If the petition satisfies the GMC’s requirements, the Director must prepare a report that details the appropriateness of the recommended boundary consistent with the historic district overlay zone designation criteria, and other necessary information. The Director must then forward the HPC’s recommendation and the report to the City’s Planning Commission for consideration of a zone change to create the specific historic district overlay zone. Following the Planning Commission’s recommendation, the City Council conducts a hearing regarding approval of the historic district overlay zone.

Limitations and Development Review for Properties Within a Historic District Overlay Zone An historic district overlay zone is an “overlay” to the underlying zoning applicable to each property within the historic district. The GMC and historic district guidelines place restrictions on what modifications, e.g., building alterations, can be made to properties in a designated or pending 956 of 961

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historic district. For example, major alterations for any structure that is a contributor2 or non- contributor3 to a designated historic district or in a pending historic district and that are visible from the street must be approved by either the HPC or the Director. Any such work must be consistent with the City’s Historic District Design Guidelines and the Secretary of the Interior’s Standards for Rehabilitation establish the framework for design review of portions of a historic resource that are visible from the public right-of-way. The City does not issue building permits for modifications until review under the California Environmental Quality Act and design review are completed.

The Director also has review authority over routine maintenance and repair of exterior portions of contributors and non-contributors visible from the public right-of-way that require a permit, to determine whether the proposed maintenance and repair exceed the thresholds and/or requirements for what is considered routine maintenance and repair. Even minor alterations to contributors or non-contributors to a historic district require design review and typically also require issuance of a permit. The Director is the review authority for the purpose of determining whether certain work that does not require a permit is nonetheless a minor alteration and, therefore, requires review because the alteration may have a significant impact on the character and appearance of a contributor or non-contributor. Such minor alternations include replacement of doors and garage doors within existing openings; removal of existing awnings, or installation of new awnings, that are fully supported by the wall; removal or installation of wall cladding, trim, shutters, or other decorative materials; installation or removal of decorative light fixtures at existing junction boxes; construction or removal of hardscape, fences, and walls; removal of any protected landscape feature; and includes any other work not requiring a permit and determined by the Director to require design review due to its potential to affect the historic character and appearance of the property. In addition, a demolition clearance and demolition permit is required prior to complete or partial demolition of contributors and non-contributors to designated historic districts and pending historic districts.

Verdugo Woodland Historic District Application
The application currently under consideration is for a proposed historic district consisting of the portion of the Verdugo Woodlands neighborhood The proposed district will incorporate the Niodrara Drive Historic District, which was designated in 2016. The proposal includes 788 properties, including the 32 homes in the Niodrara Drive Historic District. However, it is still uncertain whether Niodrara Drive will remain a standalone district or if it will be subsumed into a new, larger district.

The application was reviewed by the HPC on August 15, 2024. The HPC made a preliminary finding that the proposed district appears likely to meet the thresholds and criteria requirements and voted to authorize staff to begin the process of retaining a historic preservation 2 “Contributor” means a historic resource in a designated or pending historic district overlay zone that was built within the period of significance and retains enough historic integrity to contribute to the overall character and significance of the historic district overlay zone.

3 “Non-contributor” means a resource in a designated or pending historic district overlay zone that was either not built within the historic district overlay zone’s period of significance or was built within the period of significance but does not retain enough historic integrity to contribute to the overall character and significance of the historic district overlay zone.
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consulting firm to conduct a survey of the area. This determination means the area is now a “pending district” subject to design criteria and approval as stated above. A public hearing was noticed for September 17, 2024, for the City Council to award a contract for a historic district survey to the recommended consultant. However, this hearing was continued pending a determination regarding potential conflicts of interest.

Councilmembers’ Residential Real Property
 Councilmember Brotman owns a single-family residential property (his primary residence) that is within the Niodrara Drive Historic District. Even if the Niodrara Drive Historic District is removed from the current application, the property is still within 500 feet of the boundary of the proposed Verdugo Woodlands Historic District.  Councilmember Najarian owns a single-family residential property (his primary residence) that is not within the proposed district but within 500 feet of the proposed boundary.  Councilmember Gharpetian owns three single-family residential properties (one of which is his primary residence) that are not within the proposed district but within 500 feet of the proposed boundary. The other two properties are rental properties.

The number of properties that will be within the proposed District and within 500 feet of the proposed district is substantially below 15 percent or 25 percent of all residential real properties within the City.

ANALYSIS
Under Section 87100 of the Act, “[a] public official at any level of state or local government shall not make, participate in making or in any way attempt to use the official’s position to influence a governmental decision in which the official knows or has reason to know the official has a financial interest.” “A public official has a financial interest in a decision within the meaning of Section 87100 if it is reasonably foreseeable that the decision will have a material financial effect, distinguishable from its effect on the public generally, on the official, a member of the official’s immediate family,” or on certain specified economic interests. (Section 87103.) Among those specified economic interests are:
(a) Any business entity in which the public official has a direct or indirect investment worth two thousand dollars ($2,000) or more.
(b) Any real property in which the public official has a direct or indirect interest worth two thousand dollars ($2,000) or more.
(c) Any source of income, except gifts or loans by a commercial lending institution made in the regular course of business on terms available to the public without regard to official status, aggregating five hundred dollars ($500) or more in value provided or promised to, received by, the public official within 12 months prior to the time when the decision is made.
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(d) Any business entity in which the public official is a director, officer, partner, trustee, employee, or holds any position of management.
(Section 87103.)
Councilmembers Brotman, Najarian, and Gharpetian all have an economic interest in their real properties. In addition, Councilmember Gharpetian also has an interest in his property rental business as a business entity and source of income, and possible interest in his tenants as sources of income.4
Foreseeability and Materiality
Foreseeability standards vary depending on whether an interest is explicitly involved in a governmental decision. A financial effect is presumed to be reasonably foreseeable when it is explicitly involved in a decision. Financial interests that are explicitly involved include an interest that is a named party in, or subject of, a government decision. An interest in real property is the subject of the decision and explicitly involved in the decision anytime the decision affects the property as described in Regulation 18702.2(a)(1)-(6). (Regulation 18701(a).) Where an official’s economic interest is not explicitly involved in the governmental decision, the applicable standard for determining the foreseeability of a financial effect on the economic interest is found in Regulation 18701(b). That regulation provides, “[a] financial effect need not be likely to be considered reasonably foreseeable. In general, if the financial effect can be recognized as a realistic possibility and more than hypothetical or theoretical, it is reasonably foreseeable. If the financial result cannot be expected absent extraordinary circumstances not subject to the public official’s control, it is not reasonably foreseeable.” Pursuant to Regulations 18701(a) and 18702.2(a)(1), an interest in real property is explicitly involved in the decision and the effect of the decision on the interest is both foreseeable and material if the decision involves the adoption of or amendment to a development plan or criteria applying to the parcel.

Councilmembers Najarian’s and Gharpetian’s economic interests are not within the boundaries of the proposed district and therefor the properties are not explicitly involved in the decisions. It is unclear whether Councilmember Brotman’s property is explicitly involved in the decision. While the property may be incorporated into the proposed district, the property is already within the Niodrara Drive Historical District, which is already subject to historical designation restrictions, and may ultimately not be included within the proposed district. However, it is unnecessary to further consider whether the property is explicitly involved in the decision as Councilmember Brotman has a potentially disqualifying conflict of interest even to the extent the property is treated as not explicitly involved in the decisions.

Turning to the applicable standards for property not explicitly involved in the decision, the reasonably foreseeable financial effect of a governmental decision on a parcel of real property in 4 Considering the conclusion that Councilmember Gharpetian has a potentially disqualifying conflict of interest based upon his real property interest, it is unnecessary to further consider his interests in his rental business and tenants. 959 of 961

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which an official has a financial interest, other than a leasehold interest, is material whenever the governmental decision involves property located 500 feet or less from the property line of the parcel unless there is clear and convincing evidence that the decision will not have any measurable impact on the official’s property. (Regulation 18702.2(a)(7).) Based on the facts provided, the above-stated “clear and convincing evidence” standard is not met, and the councilmembers must recuse themselves from participation in the decision to approve a contract with a consultant to prepare the survey, and future governmental decisions pertaining to the approval of the historic district. As explained in detail above, the creation of a designated historic district is intended to “protect the beauty of the city and improve the quality of its environment through identification, recognition, conservation, maintenance and enhancement of its historic and architectural resources within neighborhoods” and “to protect designated areas having historic and architectural significance against intrusion of alterations, additions, new structures and other designs that fail to protect such significance.” Further, any remodeling in a historic district of a property which is visible from the public street or sidewalk immediately adjacent thereto is subject to design review. Even minor alterations to contributors or non- contributors to a historic district require design review and typically also require issuance of a permit. The creation of the historic district will protect the status quo of the entirety of the neighborhood, in part through the creation of review and permitting requirements that make nonconforming alterations difficult at best. As the Councilmembers’ properties are located within 500 feet of the proposed historic district and there is no clear and convincing evidence that decisions involving the proposed district would not have any measurable impact on the properties, the Councilmembers have a disqualifying financial interest in the decisions.

Legally Required Participation
Based on the facts provided, three of the City Council’s five members would be disqualified under the Act. Under Regulation 18705, “[a] public official who has a financial interest in a decision may establish that the official is legally required to make or to participate in the making of a governmental decision within the meaning of Section 87101 only if there exists no alternative source of decision consistent with the purposes and terms of the statute authorizing the decision.” (Regulation 18705(a).) Regulation 18705(c) requires the exception to be construed narrowly. The exception cannot be invoked to allow a financially interested official to participate in a decision if a quorum can be convened of other members of the agency who are not disqualified, and participation is required to be limited to the smallest number of officials with a disqualifying interest that are “legally required” to make the decision. (Regulation 18705(c)(2)-(3).) Because the City Council is made up of five councilmembers, at least three are necessary to form a quorum with respect to decisions regarding the selection of a consultant to prepare the survey, while four are necessary to form a quorum with respect to decisions pertaining to the formation of the district. Councilmembers Brotman, Gharpetian, and Najarian, as discussed above, would ordinarily all be prohibited from taking part in decisions these decisions. Accordingly, in order to establish a quorum of three councilmembers to approve the selection of a consultant, one otherwise disqualified councilmember may be “legally required” to participate as provided under Regulation 18705, while, in order to establish a four-fifth quorum for decisions pertaining to the formation of the district, one additional member may be selected to participate as provided under Regulation 18705.
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File No. A-24-123
Page No. 8
Accordingly, the City may use a random means of selection to select the necessary, otherwise disqualified, councilmembers to form the required quorums with respect to decisions relating to the selection of a consultant and the formation of the district. (See Regulation 18705(c)(3).) Once two councilmembers are selected, those councilmembers are selected for the duration of the proceedings and in all related matters until those councilmembers’ participation is no longer legally required, or the need for invoking the exception no longer exists. (Ibid.) The selected councilmembers will be required to state the existence of the potential conflict of interest as specified in Regulation 18705(b).

If you have other questions on this matter, please contact me at by email at [email protected].

Sincerely,
Dave Bainbridge
General Counsel
Zac hary W . No rto n
By: Zachary W. Norton
Senior Counsel, Legal Division
ZWN:aja
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Glendale City CouncilAugust 12, 2025

Glendale City Council
August 12, 2025