VIA EMAIL
October 15, 2025
Ara Najarian, Mayor Dennis Joe, Senior Planner
Ardy Kassakhian, Councilmember Community Development Department Dan Brotman, Councilmember City of Glendale
Elen Asatryan, Councilmember 633 E. Broadway, Room 103 Vartan Gharpetian, Councilmember Glendale, CA 91206
Glendale City Council [email protected]
613 E. Broadway
Glendale, CA 91206 Bradley Calvert, Director
[email protected] Community Development Department [email protected] City of Glendale
[email protected] 633 E. Broadway, Room 103 [email protected] Glendale, CA 91206
[email protected] [email protected]
[email protected]
Dr. Suzie Abajian, City Clerk
Glendale City Clerk’s Office
613 E. Broadway, Unit 110
Glendale, CA 91206
[email protected]
Re: Required Use of Skilled and Trained Labor and Prevailing Wages under AB 130 for the Central Avenue Mixed-Use Project (Stage II Design Review Case No. PDR 2212056)
Dear Mayor Najarian, Honorable Members of the Glendale City Council, Dr. Abajian, Mr. Joe, and Mr. Calvert:
I am writing on behalf of Supporters Alliance for Environmental Responsibility (“SAFER”) and its members living or working in the City of Glendale (“City”) regarding the Central Avenue Mixed-Use Project (Case No. PDR-003195-2024) (“Project”), proposed by Anthony Ditteaux of Maple Multi-Family Land CA, LP (“Applicant”). The Project involves the construction of a new eight-story, 95-foot-tall, 655,418-square-foot, mixed-use development on a
4.57-acre site located at 236 North Central Avenue, 212 West California Avenue, and 201 West California Avenue, in downtown Glendale, California. The Project is scheduled to be heard at the City Council meeting on October 21, 2025 at 6pm.
Letter Re: Required Use of Skilled and Trained Labor and Prevailing Wages under AB 130 Central Avenue Mixed-Use Project
October 15, 2025
Through the recently-enacted Assembly Bill 130 (“AB 130”), the Applicant has sought to exempt the Project from environmental review under the California Environmental Quality Act (“CEQA”). AB 130 establishes a new statutory exemption from CEQA for qualifying infill housing projects. (See AB 130 § 59; Pub. Res. Code § 21080.66 [“PRC”].) As discussed below, AB 130 specifies construction labor standards for certain types of projects, including buildings taller than 85 feet, such as the proposed Project here. Therefore, under AB 130, SAFER respectfully requests that the City Council require the Applicant to: (1) employ a skilled and trained construction workforce; and (2) pay its construction workforce prevailing wages.
DISCUSSION
AB 130 states that the labor standards of Government Code § 65913.4(a)(8) [“Gov.
Code”] apply to buildings over 85 feet in height for any housing development project that otherwise qualifies for a CEQA exemption under AB 130. (PRC § 21080.66(d)(2); AB 130 § 59(d)(2).) Here, the Project will be 95 feet tall, thereby triggering the labor standards of Gov.
Code § 65913.4(a)(8).
I. The Applicant must employ a skilled and trained construction workforce to build the Project.
Gov. Code § 65913.4(a)(8)(F)(i) states, inter alia, that the developer for any project over 85 feet tall shall enter construction contracts with prime contractors only if the contract contains an enforceable commitment that the prime contractor and subcontractors at every tier will use a skilled and trained workforce, as defined in Public Contract Code § 2601(d), to perform work on the project that falls within an apprenticeable occupation, as defined in PCC § 2601(a), in the building and construction trades. (Gov. Code § 65913.4(a)(8)(F)(i)(I).)
Public Contract Code § 2601(d) [“PCC”] defines a “skilled and trained workforce” as a workforce that meets the following conditions, among others:
(1) All workers performing work in an apprenticeable occupation in the building and construction trades are either skilled journeypersons or apprentices registered in an apprenticeship program approved by the chief.
(2)(A) For work performed on or after January 1, 2017, at least 30 percent of the skilled journeypersons employed to perform work on the contract or project by every contractor and each of its subcontractors at every tier are graduates of an apprenticeship program for the applicable occupation. This requirement shall not apply to work performed in the occupation of teamster. . . .
(2)(D) For work performed on or after January 1, 2020, at least 60 percent of the skilled journeypersons employed to perform work on the contract or project by every contractor and each of its subcontractors at every tier are graduates of an apprenticeship program for the applicable occupation, except that the requirements of subparagraph (A) shall Letter Re: Required Use of Skilled and Trained Labor and Prevailing Wages under AB 130 Central Avenue Mixed-Use Project
October 15, 2025
continue to apply to work performed in the following occupations: acoustical installer, bricklayer, carpenter, cement mason, drywall installer or lather, marble mason, finisher, or setter, modular furniture or systems installer, operating engineer, pile driver, plasterer, roofer or waterproofer, stone mason, surveyor, teamster, terrazzo worker or finisher, and tile layer, setter, or finisher.
(PCC § § 2601(d).) PCC § 2601(a) defines an “apprenticeable occupation” as an occupation for which the Chief of the Division of Apprenticeship Standards of the Department of Industrial Relations had approved an apprenticeship program pursuant to California Labor Code § 3075 [“CLC”] before 2014.
Here, because the Project building will be over 85 feet tall, the Applicant must use a skilled and trained workforce at every tier to perform work on the Project that falls within an apprenticeable occupation in the building and construction trades.
II. The Applicant must pay its construction workforce prevailing wages for the Project.
For any development that is not entirely a public work, Gov. Code § 65913.4(a)(8)(A) requires, inter alia, that all construction workers employed in the execution of the subject project be paid at least the general prevailing rate of per diem wages for the type of work and geographic area, as determined by the Director of Industrial Relations under CLC §§ 1733 and 1733.9.
However, apprentices registered in programs approved by the Chief of the Division of Apprenticeship Standards may be paid at least the applicable apprentice prevailing rate. (Gov.
Code § 65913.4(a)(8)(A)(i).) Additionally, the development proponent shall ensure that the prevailing wage requirement is included in all contracts for the performance of the work and shall also provide notice of all contracts for the performance of the work to the Department of Industrial Relations for the portions of the development that are not a public work. (Gov. Code § 65913.4(a)(8)(A)(ii).)
Here, because the Project is not a wholly public work and will be over 85 feet tall, the Applicant must pay all its construction workers prevailing wages.
CONCLUSION
For the reasons set forth above, the City Council must require the Applicant to use a skilled and trained construction workforce and pay its construction workforce prevailing wages, in compliance with the labor standards set forth in AB 130. Thank you for your consideration.
Sincerely,
Richard T. Drury
LOZEAU DRURY LLP
You don't often get email from [email protected]. Learn why this is important From: Hayley Uno <[email protected]>
Sent: Wednesday, October 15, 2025 11:40 AM
To: Joe, Dennis <[email protected]>; Calvert, Bradley <[email protected]>; Abajian, Suzie <[email protected]>; City Council <[email protected]>; Najarian, Ara <[email protected]>; Kassakhian, Ardashes <[email protected]>; Asatryan, Elen <[email protected]>; Gharpetian, Vartan <[email protected]>; Brotman, Daniel <[email protected]>
Cc: Richard Drury <[email protected]>; Rebecca Davis <[email protected]>; Chase Preciado <[email protected]>; Emy Lipkind <[email protected]>; Leslie Reider <[email protected]>
Subject: SAFER Comment Submission on the Central Avenue Mixed-Use Project (Stage II Design Review Case No. PDR 2212056)
CAUTION:
This email was delivered from the Internet. Do not click links, open attachments, or reply if you are unsure as to the sender.
Dear Mayor Najarian, Honorable Members of the Glendale City Council, Dr. Abajian, Mr. Joe, and Mr. Calvert,
On behalf of
Supporters Alliance for Environmental Responsibility (“SAFER”), please find attached comments regarding the application of Assembly Bill 130 to the Central Avenue Mixed-Use Project (Stage II Design Review Case No. PDR 2212056) ("Project"), located at
236
North Central Avenue, 201 West California Avenue, and 212 West California Avenue, in the City of Glendale. The Project is scheduled to be heard at the City Council meeting on October 21, 2025 at 6pm.
If you could please confirm receipt of this email and the attached comments, that would be greatly appreciated. Thank you for your time.
Best regards,
Hayley Uno
--
Hayley Uno
(she/her)
Lozeau Drury LLP
1939 Harrison Street, Suite 150
Oakland, CA 94612
Office: (510) 836-4200
Cell: (510) 400-7950
[email protected]