Agenda packet, first session — Glendale City Council, June 9, 2026 (part 2 of 8)

“Provide a safe and reliable transportation network that serves all people and respects the environment”

As a reminder, VMT is the standard transportation analysis metric in CEQA for land use projects after July 1, 2020, which is the statewide implementation date.

The construction phase of the proposed project is expected to generate approximately 76 two-way construction trips per day, with 4 AM peak hour trips and 34 PM peak hour trips during the most intense phase. To mitigate potential off -site impacts, we concur with recommendation that employee and truck arrivals in the morning should avoid or minimize activity during the 7 -9 AM peak period, and employee and truck departures in the afternoon should avoid or minimize activity during the 4-6 PM peak period.

The proposed project involves the construction of a bridge intended for use by bicyclists and pedestrians, aimed at improving and promoting pedestrian access. Only maintenance vehicles, which do not contribute to Vehicle Miles Traveled (VMT), will be allowed on the bridge. As such, the project is not expected to result in an increase in VMT or trigger the requirement for a VMT analysis. The project will support and enhance alternative means of transportation, designed to increase interjurisdictional pedes trian and bicycle access to LA River amenities, including the Glendale Narrows Riverwalk, Griffith Park, and the nearby LA Zoo. Consequently, the impacts are anticipated to be less than significant.

Any transportation of heavy construction equipment and/or materials that require the use of oversized transport vehicles on State highways will need a Caltrans transportation permit. Any large-size truck trips should be limited to off-peak commute periods for the construction phase and operation phase. Construction truck loads should be covered with a tarpaulin cover.

Storm water run -off is a sensitive issue for Los Angeles County. Please be mindful that projects should be designed to discharge clean run-off water.

If you have any questions, please feel free to contact Mr. Alan Lin, the project coordinator at (213) 269-1124 and refer to GTS # LA-2026-05003-MND.

Sincerely,

Anthony Higgins
Acting LDR Branch Chief

email: State Clearinghouse
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Attachment B
Francesca Smith Comment Letter dated February 16, 2026
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1 FRANCESCA SMITH
February 16, 2026
Mr. Dennis Joe, Principal Planner
City of Glendale, Community Development Department
Planning Division
633 East Broadway, Room 103
Glendale, CA 91206
via e-mail

RE: Comments on Glendale-Los Angeles Garden River Bridge Mitigated Negative Declaration

Dear Mr. Joe:

I am grateful for the opportunity to provide comments on the “Glendale-Los Angeles Garden River Bridge Mitigated Negative Declaration” (MND, January 2026) and its cultural resources technical report. My review of the MND and the “Cultural Resources Assessment for the Garden River Bridge Project” (technical report or tech report) dated March 28, 2025 prepared by BCR Consulting, LLC. reveals numerous fatal ﬂaws and shortcomings.

Among the issues in this case is the Lead Agency using a Mitigated Negative declaration when all potentially significant impacts from the proposed project have not been identified, avoided or mitigated to a less than significant level by project revisions or other requirements imposed on the project. Preparation of a MND by a lead agency is based on the premise that the construction and implementation of the proposed project would not cause a significant effect on the environment. The project’s expected impacts to least one other known historic resource, Griffith Park have not been analyzed. The proposed project impacts to the Los Angeles River were not adequately analyzed either. Other potential built environment resources, including electrical transmission towers and electrical transmission lines in the Area of Potential Effects/Project Area Limits were not evaluated for historic significance or analyzed, if warranted, for impacts that could be caused by the proposed project.

Another important complication is the use of a preliminary archaeological investigation prepared by archaeologists as the project technical report to address the identification of built environment resources with a wholly inadequate impacts analysis. The preparers of the technical report are unfortunately, not qualified to evaluate or analyze impacts to built environment historic resources. Archaeologists are trained to examine human history by excavating below ground and analyzing physical material, such as ruins, artifacts, and landscapes. Conversely, architectural historians evaluate design, construction methods, and cultural significance of existing usually “above ground” built environment resources, using written records and professional judgment to identify significant properties and to analyze expected effects of proposed projects.

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2 Phase 1 Cultural Resources Assessment
The technical report is described in the Management Summary on page ii as a Phase 1 Cultural Resources Assessment. A Phase I report is term-of-art which is limited to archaeological investigations. That report type is deﬁned
Phase I investigation consists of a combination of background research and fieldwork designed to identify resources and define site boundaries within a given project area or area of potential effect[s] (APE1). Phase I fieldwork consists of several methods including pedestrian survey, excavation of limited shovel test probes, or remote sensing. The use of specific field methods and techniques is dependent upon the type of ground cover present, the topographic setting, and the amount of observed disturbance in a given area (National Park Service. Cultural & Natural Resources, Cultural Resources “Cultural Resource Identification & Evaluation” at https://www.nps.gov/dscw/cr-identification-evaluation.htm accessed on January 21, 2016).

Archaeologists and architectural historians are entirely separate disciplines and are not interchangeable. The Secretary of the Interior's Standards and Guidelines for Archeology and Historic Preservation clearly define minimum “Professional Qualifications Standards” for History, Archeology [sic] and for Architectural History. I meet and exceed the qualifications standards for booth Architectural History and History. Let me know if anyone would like to review my qualifications. Page 7 of the Phase I, the “Personnel” section enumerates the qualifications of the technical report preparers. The iterated qualifications are ambiguous for the Project Manager, Principal Investigator and author of “the technical report and [California] Department of Park and Recreation (DPR) 523 forms for the current study” as well as for the Archaeological Crew Chief. The qualifications of the Consulting Staff Historian who assisted in preparation of the DPR form are not provided. Technical studies for the built environment are prepared by professionals who meet the Secretary of the Interior’s Professional Qualifications Standards for History, Architectural History or Historic Architecture, not by Archaeologists with the services of a Historian.

Identification of Historical Resources
Another related and significant error in the tech report is burying and not even addressing what the historical resources are in the project’s Area of Potential Effects (APE). The “Direct APE” on page 2 of the technical report and the Project Area Limits (PAL see Figures 1 and 2) are not defined. The following page contains “project work area limits” (Figure 1 on page 3) but neglects to identify where much of the work and ground-disturbing activities would be (see Outstanding Questions on pages 17-22). Worse yet, neither the referenced project Direct APE nor the PAL is defined in the document.

1 Area of Potential Eﬀects (APE): A term used and deﬁned in National Historic Preservation Act Section 106 regulations as the geographic area or areas within which an undertaking may cause changes in the character or use of cultural resources, if any resources exist there. This area always includes the actual site of an undertaking, but may also include other areas where the undertaking will cause changes in land use, traﬃc paĴerns, or other aspects that could aﬀect cultural resources, including visual, atmospheric, or audible changes (see “Deﬁnitions” at National Park Service. Home; Information; Deﬁnitions- A at hĴps://www.nps.gov/dscw/deﬁnitionsdc_a.htm#ape accessed on January 21, 2026).

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3 Figure 1: Project
Area Limits, Exhibit
C: “Detailed Project
Exhibit” in technical
report. Visible CAD
comment is
“proposed ADA
ramp.”

Figure 2: Project
Work Area Limits,
Figure 6 in MND.

The indirect APE or PAL for the project must be defined and surveyed as well. It should, at minimum, include all project-related potential staging and staff parking areas unless additional supplemental environmental review would be prepared after those staging and parking areas were identified.

An APE or PAL boundary must cover areas of direct physical impact (e.g., demolition, construction and implementation) as well as indirect impacts (e.g., noise, vibration, staging and parking areas, future related changes, alterations to setting and visual intrusions). There is no defined or delineated subterranean or vertical APE or PAL defined either, for a project that would include significant construction activities and result in permanent changes both beneath and far above finished grade.

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4 The technical report’s Significance Evaluation section is entirely superfluous and seems to struggle to make a finding regarding the Los Angeles River’s California Register eligibility.

There should be no question: the Los Angeles River Channel was determined eligible for the National Register in 2019. Because the linear resource was determined eligible (not “found” nor does it “appear to be eligible”), therefore the Los Angeles River Channel is automatically listed in the California Register in 2019. See Attachment A.

Without explanation, the technical report largely overlooks another historic resource, Griffith Park. Griffith Park was determined eligible for the National Register in 1994. It is also listed in the California Register and is Los Angeles Historic-Cultural Monument #942. The proposed project would be built largely within the identified boundaries of Griffith Park, including the 1897 survey boundaries of the historic property (in gray) and historical resource boundary in yellow dashed line (Figure 3 below).

Figure 3: Excerpted, annotated Griffith Park Historic Resources Map with proposed project area circled in red.

See 1897 Park Survey Boundary in gray. Source: https://friendsofgriffithpark.org/wp-content/uploads/2015/11/ GPboundarymap.pdf accessed on January 24, 2025.

PROPOSED

PROJECT
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5 No longer extant historical resources in the
proposed project area include
Griﬃth Park Aviation Park/Aerodrome (1912-
1939), National Guard Airport (1939-1946),
Glendale Grand Central Airport, locally
designated in 1977 (historic maps show runways
on the north side of the river until at least 1962);

Roger Young Village (1946-1954, south side of Los
Angeles River);
Grayson Steam-Electric Generating Station;
Grayson Power Plant Boiler Building after 1941
(determined National Register-eligible; listed in
California Register 2019; rescinded 2021; found
eligible for National and California Registers 2021;
demolished 2023, see Figures 4 (at left) and 5
(below).

Figure 4: Excerpt from 1953 USGS Burbank,
California quad map showing approximate
project area in red.

A Works Progress Administration
Map prepared with the Federal
Writers Project depicts the Griffith
Park in the late 1930s.

The proposed project area
contained far different uses than
are mentioned in the technical
report, including a Japanese
Cherry Grove, a Pecan Grove and
a National Guard Airport (Figure
4). None of those tree types are
proposed to be used for the
proposed project (see pages 9 and
17 of this letter under item [1]).

Figure 5: Excerpted Works Progress Administration map of “Griffith Park, Los Angeles City” prepared with the Federal Writers Project between in 1937. Library of Congress. HALS.

HALS NO. CA-105 at https://tile.loc.gov/storage-
services/master/pnp/habshaer/ca/ca4100/ca4161/data/ca4161da ta.pdf.

Another serious oversight is that Los Angeles Department of Water & Power 230kV electrical transmission lines with towers are extant in the proposed project APE or PAL (see Figure 6 and Photographs 3-6 in Appendix E of tech report). There are five separate lines, including the line on the south bank of the Los Angeles River. Those transmission lines and towers are not mentioned, evaluated for historic significance or analyzed for impacts that would be caused by the proposed project in the technical report (see Figure 6 on page 6).

A revised, corrected or addendum technical report prepared by both qualified archaeologists and built environment professionals must address this issue as well as other identified oversights in the March 2025 document. It should change the technical report’s conclusions and could well affect the type of environmental document used to clear the project.

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6 Figure 6: Annotated, excerpted
graphic map of project APE or
PAL (in red dashed lines) with
electrical transmission lines
overlaid in dashed black lines.

Base map is Open Street Map
Historic Aerials.com at
https://www.historicaerials.com/v
iewer accessed on January 27,
2026.

Interestingly, also without explanation, the technical report does contain a California Department of Parks & Recreation (DPR) series 523 update for the Los Angeles River Glendale Narrows. The unnecessary recordation is not an “intensive” evaluation (as cited in *P10. in Figure 7) and was prepared for the Glendale Narrows segment of the Los Angeles River.

As described and defined in the California Office of Historic Preservation-prepared Instructions for Recording Historical Resources “Appendix 6: Types of Survey Activities” Intensive surveys go beyond the systematic identification and description of historical resources to encompass the evaluation of those properties within a historic context.

Thus, in addition to the five categories of information needed for a reconnaissance report,2 the report documenting an intensive survey should also contain: 6. An evaluation of heritage resources identified during the survey as determined within a historic context using the National Register criteria (or CEQA criteria if appropriate). 7. Evidence that the evaluation was conducted or confirmed by an appropriately qualified professional (emphasis added 1995).

Because the preparers did not follow Instructions for Recording Historical Resources “Appendix 6:

Types of Survey Activities” by not evaluating the Los Angeles River for National or California Register eligibility and worse, overlooked the previous determination of eligibility for the Los Angeles River, the DPR form survey type is not “Intensive” as claimed, and worse yet, is unfortunately useless to the environmental clearance document.

2 1. Purpose of survey, 2. Deﬁnition of survey area, 3. Research design, 4. Methods, 5. Summary of results (California Oﬃce of Historic Preservation. Instructions for Recording Historical Resources “ Appendix 6:

Types of Survey Areas” 1995).

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7 Figure 6: DPR series
form 523A prepared
for the Phase 1. The
recorded resource
name is “Glendale
Narrows Segment of
the Los Angeles
River.”
In the header, under
Other Listings, the
from is blank.

In the location Map it
refers to a 1972 USGS
quad map that was
updated in 1994.

As mentioned, the DPR 523 forms dated January 15, 2022 prepared for the Phase 1 did not take into account or even reference the US Army Corps of Engineers’ 2019 determination of eligibility for the Los Angeles River Channel. The California Oﬃce of Historic Preservation Built Environment Resource Directory for Los Angeles County shows that the Los Angeles River Channel was determined eligible for listing in the National Register of Historic Places in 2011. That segment of the river is therefore also listed in the California Register (Status Code 2S2, see hĴps://ohp.parks.ca.gov/ ?page_id=30338 accessed on February 1, 2026).

Status Code 2S2 means “Individual property determined eligible for [the National Register] NR by a consensus through Section 106 process. Listed in the [California Register] CR.” (California Register Status Codes, February 8, 2023).

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8 In 2019, the US Army Corps of Engineers (COE)
Determined the Los Angeles River Channel… eligible for the National Register of Historic Places (NRHP) under criterion A at the local level of signiﬁcance for its signiﬁcant association with the development of a comprehensive ﬂood risk management program in the county and development of the metropolitan area. Further, the COE had determined the Channel is eligible under NRHP criterion C as the ﬁrst implementation of a fully concrete lined waterway engineered to address unique challenges in the locale and for its role as a prototype for ﬂood control channels in the region. The COE points out that the Channel maintains integrity of workmanship, materials, seĴing, feeling and association. The period of signiﬁcance is 1936-1960. The SHPO concurs. (emphasis added leĴer from California SHPO Julianne Polanco to COE re “Section 106 consultation for Los Angeles Channel[,] and Reach 2A repairs…” dated September 20, 2019, see AĴachment A).

For the record, both the Los Angeles River Channel and Griﬃth Park each retain the integrity of their original locations as well. A copy of the quoted Los Angeles River Channel determination of eligibility leĴer is AĴachment A.

Despite the referenced DPR forms prepared for the Phase 1 which provide no professional judgments regarding the established historic property and historical resource, the report nonetheless concludes that “the Los Angeles River Channel (including the Glendale Narrows/Reach 3 Segment) is eligible for California Register listing. As such it is recommended a historical resource under CEQA” (emphasis added, page 11).

This means that the technical report preparers and their reviewers were not aware that the 2019 determination of National Register eligibility for the Los Angeles River meant that the linear resource is also listed in the California Register. The Los Angeles River is therefore both a historic property for the purposes of Section 106 and a historical resource as deﬁned in CEQA.

In the History section on page 4, the American Period inexplicably ends in the late 19th century when the population of the City of Los Angeles was approximately 50,000 persons (1890). The head count roughly doubled to 102,000 by 1900, and entirely overlooks the boom years after the ﬁrst and second World Wars. The City of Glendale was notably not established until 1906. No context for Griﬃth Park’s establishment or for the occurrence of electrical transmission in the area is in the technical report.

Project Description
The Project Description for the Initial Study for this project is extremely vague. The Project Description section in an Initial Study is considered a “road map” providing information that characterizes a proposed project’s goals and objectives. Project descriptions must be the same in all supporting documents for a given project. They are intended to describe the project providing suﬃcient detail to set forth the baseline of information for use as a foundation in analyzing the speciﬁc components elsewhere in the document. The project description should describe the project’s related activities (e.g. construction and implementation), identify and discuss any jurisdictional issues relating to project commencement including acquisition of applicable permits, project duration, the proposed project’s speciﬁc location and a listing of related environmental review and consultation requirements mandated by federal, state or local EXHIBIT 2
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9 laws, regulations or policies (CCR Title 14, Section 15124). A project description must also include site, regional and vicinity maps to provide reviewers a sense of geographical location respecting the project site and its surroundings. It is noted that the Project Descriptions in the Initial Study, the MND and the technical report are entirely diﬀerent:

Cultural Resources Assessment for the Garden River Bridge Project/ Phase I Cultural Resources Assessment of the Garden River Bridge Project The project site is located in a non-sectioned portion of Township 1 North, Range 13 West, San Bernardino Baseline and Meridian, in the Cities of Los Angeles and Glendale. It is depicted on the United States Geological Survey (USGS) Burbank, California (1994) 7.5-minute topographic quadrangle... A detailed project exhibit is provided as Appendix C. The project site consists of areas in which impacts from a proposed project to potential historical resources could occur. The project includes construction of an approximately 350-foot long three-span curvilinear pedestrian/ bicycle bridge structure that spans the Los Angeles River with canopied seating areas. The bridge will be constructed using steel and concrete. It will be supported by two piers located in the river. Safety railings, trash cans, interpretive signs, pedestrian safety lighting, and other features will also be installed. The maximum height of the bents which will support the bridge from the ﬂoor of the channel will be 23 feet and six inches. The area of ground disturbance on the channel ﬂoor has been calculated at approximately 8,500 square feet.

Page 1 ends

On pages 3 and 4 of the MND, a far more comprehensive project description is provided, which would greatly have informed the technical report’s brief and insufficient analysis of impacts:

The City of Glendale as lead agency in cooperation with the City of LA, as responsible agency, proposes the construction of a three-span, curvilinear, landscaped bridge for use by pedestrians and bicyclists; see Figure 4 [not in this letter] for a visual of the proposed landscaping arrangement for the bridge, including locations of planting beds and tree canopies. [1]3 Tree species proposed to be part of the bridge’s landscape palette include western sycamore, valley oak, coast live oak, and tipu tree. Additional species included in the proposed planting mixes for the bridge include toyon, California sagebrush, California buckwheat, and star jasmine. The intent of this multi-community resource is to increase access to Glendale Narrows Riverwalk, and Griffith Park; to improve connections; and to increase the safety of paths used for pedestrians and cyclists. Dedicated access across the LA River at this key location would improve public safety and accessibility to important community resources by creating a connection between the Cities of Glendale and LA across the LA River for pedestrians and cyclists. [2] The proposed bridge would be concrete with two supporting piers in the LA River. [3] It would feature extensive landscaping on the approaches, as well as on the bridge itself, and is thus named the “Garden River Bridge.”[4] A number of raised planting beds on the bridge would create dedicated zones for bicycle and pedestrian circulation, shade structures, canopied seating areas, dispersed gathering spaces, and scenic views of the LA River. The proposed bridge would operate on the same schedule as the LA River Bike Path, which is generally open from 6am to 9pm. [5] Any gating for the bridge would be located at the proposed access ramp and stairs off of Zoo Drive.

The LA River is a U.S. Army Corps of Engineers (USACE) flood risk management facility, in which USACE holds primary authority over any proposed changes. In addition to USACE, several other stakeholder entities are within the proposed Project footprint. The City of LA owns, operates, and maintains the south side of the LA River, located within the southern portion of the proposed Project area; also within this area, Southern California Edison (SCE) holds a fifteen-foot easement along Zoo Drive and overhead facilities on Los Angeles Department of Water and Power (LADWP) poles. On the north bank of the LA River, parcels within the northern portion of

3 Red numerals in brackets are used to create the sequence of activities that should have been analyzed in preparing the project’s impacts analysis.

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10 the proposed Project limits are owned by the City, the City of LA, and the Los Angeles County Flood Control District (LACFCD). Furthermore, easements that cross the proposed Project area on the northern side are held by the City for utility purposes ( e.g., poles, sewers and related structures), and for the existing Riverwalk pedestrian/bike trail. [6] Table 1 below shows overall temporary and permanent impacts from the proposed Project.

Table 1 Comparison of Temporary and Permanent Impacts
Area of Impact Temporary Impacts Permanent Impacts
Total Project Area 2.94 acres 1.4 acres
[7] The Proposed Project would include overall temporary impacts of approximately 2.94 acres and approximately 1.4 acres of permanent impacts. Temporary impacts would include water diversion activities, excavation activities, and areas of access and staging. Permanent impacts would include the bridge, Riverwalk bike path reconstruction adjacent to the bridge, a new connection from the bridge to Zoo Drive, and the re-alignment of Zoo Drive… [8] The re-alignment of Zoo Drive would be to permit the construction of stairs and a ramp leading up to the LA River Bike Path and the proposed bridge. Trees between Zoo Drive and the LA River Bike Path would be removed and a new curb would be installed as part of proposed street improvements. [9] Additionally, a sidewalk would be installed to facilitate access from the bridge to the John Ferraro Athletic Fields to the south via a new raised crosswalk across Zoo Drive. These activities associated with the re-alignment of Zoo Drive would not result in the loss of parking as parking along this segment of Zoo Drive is not currently permitted, nor would realignment activities create parking along Zoo Drive.
[10] Construction is anticipated to begin in the Fall of 2025 and would last approximately 2.5 years, ending in the Spring of 2028. The proposed Project would occur in six (6) phases and shown and summarized below.
• Phase 0: Mobilization – The initial phase of the proposed Project would include requests for information, preparing and reviewing submittals, and procuring materials. • Phase 1: North Abutment and Approaches – [11] Approach work, bike path work, and abutment work.
• Phase 2: Bridge Substructure – [12] Construct piers within the LA River. • Phase 3: South Abutment and Approaches – [13] Construct the south abutment and connections to Zoo Drive; realign Zoo Drive.
• Phae 4 [sic]: Bridge Superstructure – [14] Construct the bridge superstructure using falsework within the LA River.
• Phase 5: Architectural Elements/Landscaping – [15] Construct the architectural elements (e.g., canopies, landscaping, etc.) on the bridge and approaches. [16] The bridge abutments would be constructed to be higher than the existing elevation of the channel walls and would not touch the levee walls. The abutments would be supported by deep foundations consisting of cast-in- drilled-hole concrete piles; the abutments would not be supported by the channel walls. [17] To address drainage from the bridge deck, pipes would be hung inside of the bridge and tie into existing drainage pipes or water treatment features on both sides of the LA River channel. [18] Activities associated with the realignment of Zoo Drive would include the removal of trees along the LA River Bike Path along Zoo Drive, within the southern portion of the proposed Project’s footprint in the City of LA. The tree removal would be required to accommodate grading and Zoo Drive realignment, and it is anticipated approximately 18 western sycamore trees would be removed, some of which fall under the jurisdiction of the City of LA’s Recreation and Parks Department (LARAP) and others under City of LA’s Bureau of Street Services (LABSS). Section 46.01 of the City of LA Municipal Code (LAMC) includes western sycamore trees as a protected tree species; therefore, the proposed tree removals within LABSS jurisdiction would require a Tree Removal Permit from the LABSS Urban Forestry Division. Removal of protected trees requires replacement at a 4:1 ratio with the same species of each species removed…
[19] The demolition and excavation phases of the proposed Project are expected to generate the most construction traffic and require the most equipment. In-river construction would occur EXHIBIT 2
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11 during the dry season (April through October) when flood flows are very unlikely, per USACE requirements. [20] The construction equipment used during different portions of the proposed Project would include work trucks, concrete trucks, cast-in-drilled-hole concrete pile drilling rigs, mobile cranes, and excavators. [21] The construction contractor would be required to lay down timber mats to protect the LA River bottom to prevent potential impacts to the LA River bottom during construction. [22] While variable, an average of 15 people would be on site daily for the duration of construction activities. [23] Construction access to the proposed Project site would be provided from Zoo Drive on the City of LA side of the proposed Project and from Flower Street on the Glendale side of the Project, with intermittent temporary lane closures and or reduced access. [24] Due to the lack of suitable access ramps within close proximity to the proposed Project site, the construction contractor may construct a temporary ramp from Zoo Drive down the sloped levee into the channel bottom. The temporary construction staging area would be located in the City of LA and City of Glendale at the southern and northern areas of the proposed Project; [25] specifically, one of the staging areas would be on the north side of Zoo Drive within the shoulder of the road. Additional staging would occur within the LA River northern bank and southern bank during construction of the bridge’s piers (MND pages 3-5).

While the referenced project description provides a large amount of specificity that is not addressed in the technical report, its incorporation and analysis with additional information that the Project Design Team could have provided would have greatly informed the analysis of impacts in the technical report.

Conclusions
In the “Recommendations” section, the technical report concluded without adequate explanation:

The Los Angeles River has been determined eligible for National Register listing and as such is a historical resource under CEQA. However, the proposed project will impact a tiny portion (approximately .06 percent) of the Glendale Narrows/Reach 3 segment of the Los Angeles River. Based on the small percentage of the segment that will be subject to direct impacts, BCR Consulting recommends that the proposed project will not result in a signiﬁcant adverse eﬀect to a historical resource under CEQA. Furthermore, the bridge abutments would be constructed to be higher than the existing elevation of the channel walls and would not touch the levee walls. Although the integrity of seĴing would be minimally impacted by the installation of the bridge, the seĴing of the Glendale Narrows/Reach 3 segment has already been impacted by development of the surrounding neighborhoods and by the Interstate 5 and State Route 134 freeway bridges that are visible from the proposed project site and were constructed after the period of signiﬁcance [identiﬁed as 1936-1960 in SHPO leĴer]. As such, the proposed project will not introduce any elements to the seĴing that are not already present, and the proposed project will not alter the ability of the Glendale Narrows/Reach 3 to contribute to a larger district. Based on these results, BCR Consulting recommends that the project as proposed will not result in signiﬁcant impacts to a historical resource (under CEQA). No mitigations are recommended for the current undertaking. No archaeological resources were identiﬁed during this assessment (emphases added, pages 11 and 12).

The assertion that proposed project would not cause a “signiﬁcant adverse eﬀect” to the Los Angeles River or to its Reach 3 was made without any demonstrable evidence or reasoning. The threshold for an impact on historical resource is not an “adverse eﬀect;” the correct language in CEQA is substantial adverse change which can cause a signiﬁcant eﬀect on the environment.

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12 In California Code of Regulations in Title 14, Section 15064.5 “Determining the Signiﬁcance of Impacts to Archaeological and Historical Resources, the law deﬁnes and clariﬁes:
(b) A project with an eﬀect that may cause a substantial adverse change in the signiﬁcance of an historical resource is a project that may have a signiﬁcant eﬀect on the environment. (1) Substantial adverse change in the signiﬁcance of an historical resource means physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the signiﬁcance of an historical resource would be materially impaired.
(2) The signiﬁcance of an historical resource is materially impaired when a project:
(A) Demolishes or materially alters in an adverse manner those physical characteristics of an historical resource that convey its historical signiﬁcance and that justify its inclusion in, or eligibility for, inclusion in the California Register of Historical Resources;
(B) Demolishes or materially alters in an adverse manner those physical characteristics that account for its inclusion in a local register of historical resources pursuant to section 5020.1(k) of the Public Resources Code or its identiﬁcation in an historical resources survey meeting the requirements of section 5024.1(g) of the Public Resources Code, unless the public agency reviewing the eﬀects of the project establishes by a preponderance of evidence that the resource is not historically or culturally signiﬁcant; or
(C) Demolishes or materially alters in an adverse manner those physical characteristics of a historical resource that convey its historical signiﬁcance and that justify its eligibility for inclusion in the California Register of Historical Resources as determined by a lead agency for purposes of CEQA . (3) Generally, a project that follows the Secretary of the Interior's Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings or the Secretary of the Interior's Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings (1995), Weeks and Grimmer, shall be considered as mitigated to a level of less than a signiﬁcant impact on the historical resource (emphasis added).

If the preparers of the technical report were qualiﬁed to identify and analyze impacts to built environment historic resources, partially by incorporating and applying the MND’s far more thorough Project Description, they would likely also have presented questions to the PDT, considered the responses and applied the appropriate CEQA impacts thresholds, they may well have arrived at a diﬀerent conclusion. This presents a substantial obstacle for the MND which unfortunately relies on the technical report’s inadequate identiﬁcation eﬀorts as well as its ﬂimsy conclusion.

The California State Historic Preservation Oﬃcer concluded in 2019 that for Section 106 [or CEQA] compliance on future undertakings [or projects] on the Los Angeles River Channel, the COE [or lead agency] will need to identify character-deﬁning features within the segment under consideration and assess whether the work will alter any of those features such that the segment will no longer be able to convey its signiﬁcance” (Julianne Polanco, California SHPO, leĴer to COE re “Section 106 consultation for Los Angeles Channel[,] and Reach 2A repairs…” dated September 20, 2019). That clear direction must be followed for the proposed project and any future projects in the Los Angeles River (see AĴachment A).

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13 If, as described on pages ii and 11, “the proposed Project would only impact a very small portion (approximately 0.6 percent) of the Glendale Narrows/Reach 3 section of the LA River, which, due to the small percentage subject to direct impacts, would not result in a signiﬁcant adverse eﬀect to a historical resource under CEQA.” That surprisingly brief analysis begs an important question that is not answered. What size is the Glendale Narrows/Reach 3 section of the Los Angeles River? How large is the entire Los Angeles River? Is it 100 acres or 1,000 acres in size? Is the consultant considering only the “temporary impact area” of nearly three acres (2.94) or the “permanent impact area” of 1.4 acres described in the MND? Strangely, as cited in the technical report on page 1, only 8,500 SF of the Los Angeles River channel ﬂoor would be “temporarily” used. It should be noted that 8,500 SF is just 0.1951331 of an acre, it is not 1.4 “direct impact acres” and certainly not the estimated “2.94 indirect impact acres” that are estimated and described in the MND. Why were these ﬁgures not cross-checked? Merely checking to see if numbers merely match is absolutely not an appropriate built environment impacts analysis under CEQA. My understanding of the project is that two bridge piers would be permanently located within the Los Angeles River channel, which is certainly not a temporary impact and is, far more importantly, not even analyzed.

The technical report asserts “the bridge abutments would be constructed to be higher than the existing elevation of the channel walls and would not touch the levee walls” (emphasis added). Would the new feature being built higher than the historical resource be preferable to the abutments being built lower than the levee walls? The description regarding “not ‘touching’ the levee walls” is in the MND project description. It is a physical description, not an analysis of historical resources impacts. No explanation for the statement or what it really means is provided.

According to The Secretary of the Interior’s Standards For the Treatment of Historic Properties With Guidelines For Preserving, Rehabilitating, Restoring & Reconstructing Historic Buildings In Guidelines For Rehabilitating Historic Buildings under New Exterior Additions and Related New Construction, under Rehabilitation as a treatment:

New additions should be designed and constructed so that the character-deﬁning features of the historic… [resource]4, its site, and seĴing are not negatively impacted.

Generally, a new addition should be subordinate to the historic… [resource]. A new addition [like a bridge] should be compatible, but diﬀerentiated enough so that it is not confused as historic or original to the … [resource]. The same guidance applies to new construction so that it does not negatively impact the historic character of the … [resource] or its site” (emphasis added, Anne E. Grimmer, 2017. page 79).

There are no detailed plans, no sections or elevations provided in the analysis for the proposed bridge abutments or for the new bridge Abutment types can vary from gravity walls to complex integrated systems, and gravity abutments, cantilever abutments, stub abutments, spill-through (or open) abutments, and integral abutments, all of which are designed to support the ends of a bridge, retain earth when necessary and to transfer loads, with selections depending on soils (where applicable), overall cost and a proposed bridge’s height. The insuﬃcient explanation in

4 In this quote, the word building is replaced by resource, because the Los Angeles River is a linear resource, not a building. It does not change the meaning, because the Standards are intended to be used for all types of historic properties.

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14 the tech report’s conclusion does not describe how much higher than the Los Angeles River levee walls are from grade, from the ﬂat part of the river, nor does it specify what type or size the thinly described bridge abutments are proposed to be. Worse yet, the idea that the abutments not “touching” the abutment walls alleviates the prospect of impacts to the historical resource is preposterous and demonstrates an essential issue with the preparers’ understanding of how to analyze impacts that may be caused by a given project to built environment historic resources.

The applicable thresholds are material impairment that would cause substantial adverse change. How high above grade would the proposed abutments be at the bases? How high above grade would the abutments be at the tops? Show a detailed plan and elevations. Would the design conform to the Secretary of the Interior’s Standards for Rehabilitation? Describe how.

How much soil is proposed to be excavated? To what depth would that soil be removed? If applicable, where would that soil be deposited? When will that analysis be prepared? These are usually important questions that are answered and analyzed in an archaeological technical report.

According to the CEQA Guidelines Section 15064.5(b), a project with an eﬀect that may cause a substantial adverse change in the signiﬁcance of a historic resource may have a signiﬁcant eﬀect on the environment. A substantial adverse change means physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings, resulting in material impairment of the historic resource (CEQA Guidelines Section 15064.5[b][1]).

The technical report further confuses immediate seĴing within and near the historical resource’s boundaries with its larger surrounding seĴing. SeĴing is deﬁned by the National Park Service as the physical environment of a historic property or a historical resource. Because location refers to the speciﬁc place where a resource was built or an event occurred, seĴing refers to the character of the place in which the property played its historical role. It involves how, not just where, the property is situated and its relationship to surrounding features and open space.

SeĴing can reﬂect the fundamental physical conditions under which a resource was built and the functions it was intended to serve. In addition, the way in which a resource is positioned in its environment can reﬂect the original designer or engineers’ concepts of nature and aesthetic preferences.

The technical report concludes that “Although the integrity of seĴing would be minimally impacted [not explained] by the installation of the bridge, the seĴing of the Glendale Narrows/Reach 3 segment has already been impacted by development of the surrounding neighborhoods and by the Interstate 5 and State Route 134 freeway bridges that are visible from the proposed project site and were constructed after the period of signiﬁcance.” The period of Signiﬁcance in the SHPO leĴer is 1936-1960 (AĴachment A). The preparers do not seem to have performed adequate research to justify that claim. The reader does not know how high the new bridge would be, how thick or deep the deck and girders or whatever its supporting elements would be, what its overall appearance would be and because of that, has no compelling reason to believe the conclusion.

The seĴing of the Los Angeles River and of any historical resource is both close-in (within and nearby the Los Angeles River Channel) as well as the linear property’s larger surroundings that EXHIBIT 2
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15 establish its larger atmosphere. On page 9 of the technical report, it states “The project site and surrounding area have been subject to severe disturbances related to reconﬁguration of Flower Street, construction of the channel, construction of the modern bike path and walkway, modern refuse dumping, the installation of transmission towers and streetlights, and by repeated ﬂooding.” While those described activities may equate to “severe disturbances” to the archaeologists who prepared the technical report, to a qualiﬁed architectural historian, the project area’s larger seĴing was described. The channelized Los Angeles River and Griﬃth Park are each historic resources. The electrical transmission lines and towers may wel1936 l be historically signiﬁcant as well. What was described was the environmental baseline, the time and conditions used as the point of comparison that would normally be used for determining the signiﬁcance of a given project’s environmental eﬀects.

On the north side of the river, the project area has been industrial since the turn of the early 20th century. The proposed project area, called “Flower Street District Annex” was not part of the City of Glendale until May of 1923 (Los Angeles, County of. “City of Glendale Annexations.” At hĴps://pw.lacounty.gov/sur/nas/SMPM_ AnnexationCityPDFs/Glendale.pdf accessed on February 2, 2023). Just three years later, San Fernando Road, roughly a block north of the proposed project became US Highway 6 in 1926. About a decade after that, US Highway 6 became US Highway 99, known as “the Mother Road, in 1934 (California, State of. State Highway Map. 1934). As Highway 99, the road was populated by scaĴered gas stations and primarily industrial uses in the project area, much like it still is.

Review of various sources shows that development of what is now State Route 134 freeway was ﬁrst considered in 1934, before the Los Angeles River was channelized, and before the identiﬁed 1936 period of signiﬁcance commenced (see AĴachment A) . The subject property section of the Los Angeles River was channelized in 1939, according to the technical report (page 10). In 1946, 750 Quonset huts were relocated to Griﬃth Park where the former National Guard Airport had been in the park. The area surrounding the Los Angeles River, like most of Los Angeles, was constantly changing.

In 1947, during the same decade that the river was channelized, the Regional Planning Commission established a “Master Plan of Metropolitan Los Angeles Freeways.” That Master Plan was adopted on August 4, 1947 and included part of the Ventura Freeway running east-to- west in Glendale in the approximate location of present-day State Route 134 (SR 134). In 1952, Grand Central Airport ceased operations because its limited landing strips could not accommodate large planes. The Interstate 5 bridge over the Los Angeles River was built in 1957.

Walt Disney recognized the potential in Grand Central’s location and large footprint. He purchased part of the property in 1961, the year that the identiﬁed period of signiﬁcance closed (AĴachment A). Between 1962 and ’65 the Colorado Street extension in Glendale, south of the proposed project area was a brief alternate stub route of the present-day Interstate 134. In 1963, the California Streets and Highways Code established Route 134 as being “from Route 101 near Riverside Drive easterly to Route 210 via the vicinity of Glendale” (California, State of. Streets and Highways Code - Division 1. State Highways, Chapter 2. The State Highway System, Article 3. The State Highway Routes. At
hĴps://leginfo.legislature.ca.gov/faces/codes_displaySection .xhtml?lawCode=SHC&sectionNum=434 last accessed on February 13, 2026). San Fernando EXHIBIT 2
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16 Road was re-signed as State Route 163 in the 1960s. In 1969, State Route 134 was rerouted oﬀ of Colorado Street in downtown Glendale north on to State Route 2 Verdugo Road to the “new” segment of the Ventura Freeway. By 1967, SR 134 reached Concord Drive in Glendale. Map review reveals that I-134 was completed in Glendale in 1971.

Sanborn Fire Insurance Co. Maps of Glendale, CA updated to October 1950 reveal that the larger seĴing of the Los Angeles River, particularly on the north (Glendale) side of the project area was much like it is now, developed by Glendale Central Aircraft Co., Grand Central Airport (built in 1930) runways and Cal-Aero Technical Institute (Sheet 222H, see also Figure 3 of this leĴer).

Sheet 0B in Figure 7 below reveals that Victory Truck Boulevard ran along the north bank of the Los Angeles River. The Grayson Steam-Electric Generating Station Boiler Building was completed after 1941 with various additions in the late 1940s through the 1970s.

Figure 8: Excerpted, annotated Sheet 0B from
Sanborn Fire Insurance Co. Maps of Glendale, CA,
dated October 1950.

Note that the regional airport was on the north
side of the Los Angeles River (in yellow) and that
the project area is circled in red. Flower Street
was not shown on the map, so it was added in
gray dashed lines. The Grayson Steam-Electric
Power Plant was located at approximately 1
o’clock, northeast of the proposed project. It was
demolished in 2023.

What this brief timeline reveals, is that the larger seĴing of the Los Angeles River in this area has been characterized by industrial and institutional uses since Glendale was established.

Furthermore, the environmental seĴing has been subject to nearly constant change from approximately the 1920s until between the 1940s, when the river was channelized and present day.

Absent any information regarding the proposed height of the abutments, bridge deck, railings, canopies and all other vertical features, it is impossible to make the conclusions in the technical report. The technical report describes the proposed bridge as concrete and steel materials, however the MND describes only steel, with no ﬁnishes speciﬁed. There is no agreement among these documents regarding the proposed project’s materials, and even less information regarding the designs. sizes or shapes of the bridge piers, the bridge deck, anti-scour features, connected deck items including railings, planting beds, trashcans, canopies, trees and other plants and the gates on the “Los Angeles” side. The PAL map in Figure 1 of this leĴer notes a “proposed plaza and stair area” that is not described in the tech report. It also depicts a lengthy ADA ramp conﬁgured in a loop on the southeast side of the proposed bridge.

Eﬀects to the seĴings of properties eligible under Criteria A and 1, C and 3 like the Los Angeles River and Griﬃth Park must not only allow historic resources to retain their essential physical features, but those features must be clearly visible enough to suﬃciently convey their signiﬁcance. This means that even if a historical resource is physically intact, its integrity may become questionable if its signiﬁcant features would be concealed beneath new features, under EXHIBIT 2
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17 modern added construction like the proposed bridge. Will the new bridge be a truss, an arch, have open or closed spandrels, metal built-up girders, metal rigid frame, suspension, cantilever or another type of bridge not listed? Most bridge types have diﬀerent features, which can result in very diﬀerent appearances and impacts to historic resources. Without this information, including renderings and elevations, no conclusions can be made regarding physical (direct), atmospheric, visual or future expected impacts.

There are numerous outstanding issues described in the MND project description were not analyzed and must be addressed in a revised or addendum technical report that would be prepared by qualiﬁed built environment professionals.

Outstanding Questions for Analysis of Built Environment Impacts Detained review of the MND project description reveals some of those unanswered questions.

Statements below from the MND have responses that must be addressed immediately following the text:
[1] Tree species to be part of the bridge’s landscape palette include western sycamore, valley oak, coast live oak, and tipu tree. Additional species included in the proposed planting mixes for the bridge include toyon, California sagebrush, California buckwheat, and star jasmine...

Response (or R): What types of trees and other plantings exist in the baseline conditions? Griffith Park’s landscaping is among the historical resource’s most important features. The park’s more than 4,200-acre area contains natural features, with acres of undeveloped, open space and numerous designed landscapes. It is strongly recommended that the future revised built environment analysis use the ICF Jones & Stokes-prepared “Landscape Elements of Griffith Park” in prepared in 2008. The report identified and illustrated the character-defining features of the natural and designed landscape components of Griffith Park with related context for their establishment and development. Character-defining features in the project section of the Los Angeles River must be identified in the revised technical report to ensure than none are destroyed or altered such that the significance of the larger resource would be impaired. That assessment will be a crucial component of the future impacts analysis.

The Secretary of the Interior's Standards for the Treatment of Historic Properties with Guidelines for the Treatment of Cultural Landscapes prepared by the National Park Service as part of their Cultural Landscape Guidance Documents for Cultural Resource Stewardship and Partnerships in 1996, applies directly to this project, and directs:

Guidance for the Rehabilitation treatment begins with recommendations to identify those landscape features and materials that are important to the landscape's historic character and therefore must be retained. Therefore, guidance on identifying, retaining and preserving character-defining features is always given first. An overall evaluation of the existing conditions should always be made at this phase. The character of a cultural landscape is defined by its spatial organization and land patterns; features such as topography, vegetation, circulation and materials (emphasis added, 1996).

Will the proposed trees and planting materials be compatible with the existing landscape? Would Japanese Cherry or Walnut trees be planted, as historically existed in Griffith Park in the project area in 1937 (see Figure 5 on page 5)? How many of each tree are proposed to be removed or planted? What size boxes or specimens would be planted? Will the trees require supplemental irrigation? For how long a duration? Whose responsibility would that be? EXHIBIT 2
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18 [2] The proposed bridge would be concrete with two supporting piers in the LA River.

R: The technical report states that the bridge would be steel and concrete (page 1). The MND describes it as being concrete. Would the bridge materials be both steel and concrete? What would the walking surface or deck material of the bridge and abutments be? What are the proposed railings’ materials, colors and finishes? Would the railings have jump protection designed as part of the project? If so, would the jump protection be physical barriers like high- tensile stainless steel mesh, inward-curved fencing or under-deck netting? What are the proposed designs, materials and finishes for the piers and their bases? What color(s) would the concrete and/or steel be? What would the finishes be? Would the concrete match the existing Los Angeles River concrete? Would that concrete matching be undertaken before or after cleaning the concrete using the gentlest means possible in keeping with the Standards for Rehabilitation? Who would perform those reviews? It certainly sounds like additional mitigation would be necessary. Why was none of this coordinated? Would the bridge pier base configurations, in plan, be circular, rectangular, oblong or chamfered? Would they have tapered (sharp) or rounded (oval) noses? Are the shapes depicted in the few figures containing renderings? How high and long would the pier bases be? What shapes and designs would be the bridge piers and pier caps be? These issues must be addressed in a revised or addendum built environment technical report. [3] It would feature extensive landscaping on the approaches, as well as on the bridge itself, and is thus named the “Garden River Bridge.”
R: See responses regarding item 1.
[4] A number of raised planting beds on the bridge would create dedicated zones for bicycle and pedestrian circulation, shade structures, canopied seating areas, dispersed gathering spaces, and scenic views of the LA River. The proposed bridge would operate on the same schedule as the LA River Bike Path, which is generally open from 6am to 9pm.

R: See responses regarding items 1 and 2.
[5] Any gating for the bridge would be located at the proposed access ramp and stairs off of Zoo Drive.

R: Show exactly where the proposed gates are proposed, with proposed posts and gate heights, their widths, proposed materials and finishes for analysis in the future technical report that would address impacts to built environment resources.
[6] Table 1 below shows overall temporary and permanent impacts from the proposed Project.

Table 1 Comparison of Temporary and Permanent Impacts
Area of Impact Temporary Impacts Permanent Impacts
Total Project Area 2.94 acres 1.4 acres
R: Was the archaeologist consultant considering only the “temporary impact area” of nearly three acres (2.94) or the “permanent impact area” of 1.4 acres in Table 1 above? Would that include the large timber mats to protect the river and the two proposed construction ramps (see page 22)?
As described in the technical report on page 1, only 8,500 SF of the Los Angeles River “on the channel floor” would be temporarily used. That leaves the rest of the project being built using floating sky-hooks. 8,500 SF is just 0.1951331 of an acre, not 1.4 direct impact acres and certainly not the estimated 2.94 indirect impact acres estimated in the MND.

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19 This highlights the vast difference in the technical report preparers and the generalists’ thought processes and fundamental understanding of the proposed project.

The actual impacts of the proposed project must be far more carefully analyzed by the qualified professionals in the appropriate fields in a future built environment technical report. These outstanding questions should have been identified and corrected by city staff reviewers, Ruth Villalobos & Associates, Inc. and BCR Consulting?
[7] The Proposed Project would include overall temporary impacts of approximately 2.94 acres and approximately 1.4 acres of permanent impacts. Temporary impacts would include water diversion activities, excavation activities, and areas of access and staging. Permanent impacts would include the bridge, Riverwalk bike path reconstruction adjacent to the bridge, a new connection from the bridge to Zoo Drive, and the re-alignment of Zoo Drive; see Figure… R: See response to item 6. All of the described “temporary impact” areas must be included in the proposed project’s revised APE or PAL.
[8] The re-alignment of Zoo Drive would be to permit the construction of stairs and a ramp leading up to the LA River Bike Path and the proposed bridge. Trees between Zoo Drive and the LA River Bike Path would be removed and a new curb would be installed as part of proposed street improvements.

R: How many lineal feet and what width of Zoo Drive is proposed to be realigned? What would be that component’s maximum depth of disturbance and how would that realignment impact Griffith Park? The technical report does not address “stairs and a ramp,” although both are noted in the Project Area Limits map in Figure 1 of this letter and in the MND.

Once those project components have been designed, including materials and railings, with depths of disturbances considered, the expected impacts of those features must be far more carefully analyzed by the qualified professionals in the appropriate fields in a future built environment technical report.

How many and what species of trees “between Zoo Drive and the LA River Bike Path would be removed” for the proposed project. Where would the replacements be planted and what species would the replacement trees be? What is the basis for the identification of the new trees? What box sizes would the new trees be? How would they be irrigated and for how long? What and where would the proposed new curb be? What is there now? How long and tall would it be? Once those project components have been designed, including materials, finishes and railings, the expected impacts of those features must be far more carefully analyzed by the qualified professionals in the appropriate fields in a future built environment technical report. [9] Athletic Fields to the south via a new raised crosswalk across Zoo Drive. These activities associated with the re-alignment of Zoo Drive would not result in the loss of parking as parking along this segment of Zoo Drive is not currently permitted, nor would realignment activities create parking along Zoo Drive.

R: If a raised crosswalk is proposed “across Zoo Drive,” it should be depicted on plans and elevations in any future built environment technical report. How long and wide would the raised crosswalk be? What would the proposed materials be? How deep would the proposed ground disturbance be (if any is necessary)? How high would the proposed raised crosswalk be at the highest points from finished grade? Where would the required ramps be? How many lineal feet long and how wide would the proposed ramps be? EXHIBIT 2
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20 Once those project components have been designed, including materials, finishes and other features, the expected impacts of those features must be far more carefully analyzed by the qualified professionals in the appropriate fields in a future built environment technical report. [10] Construction is anticipated to begin in the Fall of 2025 and would last approximately 2.5 years, ending in the Spring of 2028. The proposed Project would occur in six (6) phases… and shown and summarized below…
R: The undated MND incredulously states for the proposed project that “Construction is anticipated to begin in the Fall of 2025 and would last approximately 2.5 years, ending in the Spring of 2028” (emphasis added, page 9). It is now winter of 2026 and environmental review for the proposed project has not been completed.

The project website states that construction will commence in June 2030 (see Glendale-Los Angeles Garden River Bridge Project (Glendale Narrows Riverwalk, Phase III). All such references must be coordinated in future recirculated documents. • Phase 1: North Abutment and Approaches – [11] Approach work, bike path work, and abutment work.

R: Fully describe the proposed approach work (including its length, width, maximum depth of disturbance, including necessary backfill and locations of drains), bike path work (same), and type of abutment work (including its type, length, width, maximum depth of disturbance, including necessary backfill and locations of drains, including the expected maximum depth and widths of disturbance). If soil or other material would be removed, provide that figure and provide the location where the soil would be taken.
• Phase 2: Bridge Substructure – [12] Construct piers permanently in within [sic] the LA River.

R: Fully describe the proposed pier types, their caps or headers, their lengths, widths, maximum depths of disturbance, any columns or shafts, their types, styles and shapes of footings and or piles. If the proposed CIDH piles would be “wet,” would they be placed under slurry? Would temporary casing used to control groundwater? Are inspection pipes proposed (where and how many)? How large would the inspection pipes be (height below grade, circumference and diameter for the wet method? What is the proposed appearance of the piers and anti-scour bases? How tall, with the bridge piers, abutments, deck, railings and other features be above the levee walls? Will plans be reviewed for conformance with The Secretary of the Interior’s Standards for Rehabilitation at 30, 60 and 90 percent completion by a qualified Historic Architect or Architectural Historian? It may well be too late according to the current schedule. Will the concrete be matched to the color and finish of the existing Los Angeles River in the project area? Would that original concrete be cleaned using the “gentlest means possible” before matching? (see SOIS Standards for Rehabilitation). If soil or concrete would be removed, provide the location where that material would be deposited. • Phase 3: South Abutment and Approaches – [13] Construct the south abutment and connections to Zoo Drive; realign Zoo Drive.

R: Same responses as items 9 and 11. Show how and where Zoo Drive would be realigned, including dimensions, materials and depths of disturbance. • Phae 4 [sic]: Bridge Superstructure – [14] Construct the bridge superstructure using falsework within the LA River.

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21 R: Describe the proposed work more fully. How long is it expected to take, how many members of construction team in river, debris removal methods, proposed hours of construction, etc. • Phase 5: Architectural Elements/Landscaping – [15] Construct the architectural elements (e.g., canopies, landscaping, etc.) on the bridge and approaches.

R: Describe the expected duration of the construction activity with construction hours (e.g., 7:00 AM to 5PM), as well as identifying proposed temporary and permanent materials with their heights above the bridge deck and the concrete bottom as well as the channel of the Los Angeles River.
[16] The bridge abutments would be constructed to be higher than the existing elevation of the channel walls and would not touch the levee walls. The abutments would be supported by deep foundations consisting of cast-in-drilled-hole concrete piles; the abutments would not be supported by the channel walls.

R: See responses to items 11 and 12.
[17] To address drainage from the bridge deck, pipes would be hung inside of the bridge and tie into existing drainage pipes or water treatment features on both sides of the LA River channel.

R: Describe the proposed work more fully. Show on a plan where and how the pipes are proposed. Describe proposed materials, estimate the number of pipes, their maximum diameters, lengths, finishes and whether they would be in chases, concealed beneath the deck or clearly visible.
[18] Activities associated with the realignment of Zoo Drive would include the removal of trees along the LA River Bike Path along Zoo Drive, within the southern portion of the proposed Project’s footprint in the City of LA. The tree removal would be required to accommodate grading and Zoo Drive realignment, and it is anticipated approximately 18 western sycamore trees would be removed, some of which fall under the jurisdiction of the City of LA’s Recreation and Parks Department (LARAP) and others under City of LA’s Bureau of Street Services (LABSS). Section 46.01 of the City of LA Municipal Code (LAMC) includes western sycamore trees as a protected tree species; therefore, the proposed tree removals within LABSS jurisdiction would require a Tree Removal Permit from the LABSS Urban Forestry Division.

Removal of protected trees requires replacement at a 4:1 ratio with the same species of each species removed…
R: What other types of trees and other plantings exist in the baseline conditions? Griffith Park’s landscaping is among the historical resource’s most important features. The park’s more than 4,200-acre land area contains natural features, with acres of undeveloped, open space and numerous designed landscapes. It is strongly recommended that the future revised built environment analysis use the ICF Jones & Stokes-prepared “Landscape Elements of Griffith Park” in prepared in 2008. The report identified and illustrated the character-defining features of the natural and designed landscape components of Griffith Park with related context for their establishment and development. Character-defining features in the project section of the Los Angeles River must be identified in the revised technical report to ensure than none are destroyed or altered such that the significance of the larger resource would be impaired. That assessment will be a crucial component of the impacts analysis.

Apply The Secretary of the Interior's Standards for the Treatment of Historic Properties with Guidelines for the Treatment of Cultural Landscapes which directs:

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22 Guidance for the Rehabilitation treatment begins with recommendations to identify those landscape features and materials that are important to the landscape's historic character and therefore must be retained. Therefore, guidance on identifying, retaining and preserving character-defining features is always given first. An overall evaluation of the existing conditions should always be made at this phase. The character of a cultural landscape is defined by its spatial organization and land patterns; features such as topography, vegetation, circulation and materials (emphasis added, 1996).

Will the proposed trees and planting materials be compatible with the existing landscape? Will the replacement trees require supplemental irrigation? For how long a duration? Whose responsibility would that be?
[19] The demolition and excavation phases of the proposed Project are expected to generate the most construction traffic and require the most equipment. In-river construction would occur during the dry season (April through October) when flood flows are very unlikely, per USACE requirements.

R: Describe the proposed work more fully. Is any demolition proposed to any character- defining features of the identified historic resources. What are those character-defining features? If so, why?
Show on a plan exactly where the proposed demolition and grading would occur, and how much material in cubic yards would be proposed to be removed. How many trucks are expected per day? Identify haul routes and the duration of the activities [20] The construction equipment used during different portions of the where Project would include work trucks, concrete trucks, cast-in-drilled-hole concrete pile drilling rigs, mobile cranes, and excavators.

R: Describe the proposed work more fully. Include more complete information and consider the full heights of the vehicles and equipment in the revised description of the vertical and subterranean APE or PAL in the supplemental technical report. [21] The construction contractor would be required to lay down timber mats to protect the LA River bottom to prevent potential impacts to the LA River bottom during construction.

R: Describe the proposed work more fully including the sizes and location of the timber mats on plans. Include more complete information and consider the duration of their use. [22] While variable, an average of 15 people would be on site daily for the duration of construction activities.

R: Describe that use of personnel more fully. Where would that parking be located? Where would construction trailers be placed? Show all potential locations on plans and include those areas in the revised Area of Potential Effects or Project Area Limits map. Describe how any parking limits would be enforced?
[23] Construction access to the proposed Project site would be provided from Zoo Drive on the City of LA side of the proposed Project and from Flower Street on the Glendale side of the Project, with intermittent temporary lane closures and or reduced access .

R: Show all potential access locations on plans and include those areas with the intermittent temporary lane closures and reduced access in the revised APE or PAL map. [24] Due to the lack of suitable access ramps within close proximity to the proposed Project site, the construction contractor may construct a temporary ramp from Zoo Drive down the sloped levee into the EXHIBIT 2
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23 channel bottom. The temporary construction staging area would be located in the City of LA and City of Glendale at the southern and northern areas of the proposed Project; R: Show all potential access ramps, including their lengths, widths and materials on plans and include those areas in the revised APE or PAL map.
[25] specifically, one of the staging areas would be on the north side of Zoo Drive within the shoulder of the road. Additional staging would occur within the LA River northern bank and southern bank during construction of the bridge’s piers (emphasis added, MND pages 3-5).

R: Show all potential and additional staging areas on plans and include all staging areas in the revised APE or PAL map.

Closing
The MND states:
the results of the Cultural Resources Assessment conclude that the proposed Project would only impact a very small portion (approximately 0.6 percent) of the Glendale Narrows/Reach 3 section of the LA River, which, due to the small percentage subject to direct impacts, would not result in a signiﬁcant adverse eﬀect to a historical resource under CEQA. Additionally, the bridge abutments would be constructed to be higher than the existing elevation of the channel walls and would not touch the levee walls.

While the integrity of the seĴing would be minimally impacted by the installation of the bridge, the seĴing of the Glendale Narrows/Reach 3 segment has already been impacted by subsequent development of the surrounding neighborhoods and by the Interstate 5 and State Route 134 freeway bridges over the LA River, which are visible from the proposed Project site and were constructed after the period of signiﬁcance. Thus, the proposed Project would not introduce elements (e.g., bridges over the LA River) to the seĴing not already present, nor would the proposes project alter the ability of the Glendale Narrows/Reach 3 to contribute to a larger district (page 25).

That analysis and the conclusion in the technical report lack suﬃcient detail as described in this leĴer to prove the that no impacts would occur. The character-deﬁning features of the Los Angles River and Griﬃth Park were not identiﬁed or analyzed for project-related impacts. We do not know whether the ﬁve electrical transmission lines and their four towers are historically signiﬁcant or whether these resources would be impacted, if they are historic resources, by the proposed project. The delineation and deﬁnition of the APE or PAL must include all additional areas where the project could cause impacts (including parking, construction trailers, etc.) and must be supplemented and reconsidered.

The Project Design Team and specialists preparing each of the project technical reports must share, collaborate and work from the same baselines and identical project information. Clearly, they did not collaborate adequately for this project, which leaves the cultural resources technical report relying on and using old and mistaken information.

More importantly, if no impacts are expected to occur as a result of the proposed project as described in the technical report, then why are these areas deﬁned in the MND as “impact areas?” The consultant does not explain the diﬀerence between indirect and direct impacts.

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24 This list of unanswered questions, along with the weak identiﬁcation of historical resources are each crucial problems with the technical report and necessitate preparation of a revised Built Environment technical report, which may cause revisions to the umbrella clearance document.

If these questions are revisited by qualiﬁed professionals in the proper ﬁelds, preparation of an Environmental Impact Report may be necessary. In this leĴer I have provided “substantial evidence” which includes “facts, reasonable assumptions predicated upon facts, and expert opinion supported by facts.” Inaccurate information and unsubstantiated opinion are not substantial evidence (Public Resources Code Section 21082.2 (c); CEQA Guidelines Section 15384). Based on this review, the technical report must be revised by qualiﬁed built environment professionals, taking these comments and other related comments into account.

I sincerely appreciate the opportunity to comment on this important project. Please ensure that this leĴer is included in the proposed project’s Administrative Record. Kindly add me to the mailing and e-mail lists for any future, related environmental review documents.

Sincerely,
Francesca Smith
Francesca Smith

aĴachment

cc: Suzie Abajian, PhD, City Clerk
Historic Preservation Commission
Daniel Hernandez, Director, Public Works

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EXHIBIT 2
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EXHIBIT 2
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Attachment C
BCR Consulting Response to Comments Letter dated March
28, 2026
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1 March 28, 2026

Dennis Joe
Principal Planner
City of Glendale
633 East Broadway, Room 103
Glendale, California 91206

Subject: Response to Comments on Glendale- Los Angeles Garden River Bridge Mitigated Negative Declaration

Dear Mr. Joe:

BCR Consulting LLC (BCR Consulting) is presenting the following response to Comments on Glendale-Los Angeles Garden River Bridge Mitigated Negative Declaration submitted by Francesca Smith on February 18, 2026. Responses focus on Ms. Smith’s comments to the Cultural Resources River Bridge dated March 28, 2025.

Comment A: Phase I Cultural Resources Assessment (page 2) The reviewer states that a Phase I report is a “ term of art ” limited to archaeological investigations. She then quotes the National Park Service (NPS) definition of a Phase I study. It is not clear why she uses the NPS definition as the NPS is a federal agency that is not involved in the current study. Also, as a federal agency NPS projects would follow federal statutes, not the California Environmental Quality Act (CEQA) under which the subject study has been completed. (Admittedly, the NPS was influential in developing cultural resource rules and these have influenced CEQA, but again, NPS and its regulations do not apply to the current project .) Different agencies use different terms for cultural resources assessments /inventories, evaluations , and data recovery reports -some use "Phases", others use "Classes", and there are many agencies that accept building or built environment evaluations as part of a Phase I survey. "Phase I" can also refer to environmental remediation projects. So "Phase" can be confusing and we usually don't use it. But use of the term does not indicate a shortcoming, or that report is only used for archaeology. Even so, since the term has caused confusion for this reviewer, all references to “Phase I” have been deleted.

Comment B: Phase I Cultural Resources Assessment (page 2) The reviewer explains the difference between archaeologists and architectural historians and questions the author’s qualifications . Since qualifications are not in the report (which she states) she cannot know what they are. The author exceeds the Secretary of the Interior Professional Qualification Standards for Archaeology, Architectural History, and History and has successfully assessed and evaluated dozens of similar resources for projects being completed pursuant to CEQA and to Section 106 of the National Historic Preservation Act (NHPA). Appendix A has been added to the report to include resumes of everyone that worked on the report, emphasizing qualifications.

Comment C: Identification of Historical Resources (pages 2-4) Under "Identification of Historical Resources" the reviewer states that the Area of Potential Effect (APE), Direct APE, and Project Area Limits (PAL) are not defined. APE and Direct EXHIBIT 2
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2 APE are federal terms that are defined under Section 106 of the NHPA, which she states in the footnote on page 2 of her comment letter . As stated above, this report was not completed pursuant to Section 106 of the NHPA, and as such this statute and its rules and terms do not apply here. Use of t hese terms in a CEQA context would be misleading and is not recommended. The reviewer notes that the term “Direct APE” (a federal term usually reserved for specific Programmatic Agreements) was used in a callout in Figure 1 (page 2).

Given the references to CEQA in the report (there are 19), it seems implausible that the reviewer would think the report was intended to meet an unstated regulation (i.e. Section 106 of the NHPA ), but it appears to have caused confusion. We regret the errant use of “Direct APE” in Figure 1 and have replaced it with “Project Location”, which is appropriate for CEQA.

The reviewer references Figures 1 and 2, and claims that “project work area limits” is in Figure 1 on page 3. Since this term is not used in the cultural resources report and the figures do not match with the figures in the report, the reviewer has apparently switched to a critique of the Initial Study/Mitigated Negative Declaration (IS/MND). She also uses the abbreviation “PAL” and states that the PAL is not defined in the document. "Project Area Limits" is a specific term most widely used in cultural resource management by the California Department of Transportation ( Caltrans). Although this can be a useful term in a general planning context, it can cause confusion in a cultural resources context as it is a narrowly defined Caltrans term. As with incorrect use of federal terms, the use of “Project Area Limits” or “PAL” in this context would be misleading and is not recommended. Since the term has caused confusion, it may be better to replace “Project Area Limits” in the IS/MND with “Project Work Area Limits”, if appropriate. No change has been made to the cultural report in reference to this comment.

The reviewer goes on to state that staging and parking areas should be identified and that indirect impacts (noise, vibration, staging, and alterations to setting, etc.) should be addressed (page 3 of the comment letter). We received information that staging and parking would all be confined within the project site (depicted in our Figure 1). Since this did not change the project area, we did not think it needed to be mentioned but a sentence has been added to the report address that on page 1 of Cultural Resources Assessment.

Potential for impacts to the setting are addressed on page 11 of the Cultural Resources Assessment. Specifically, the previous development of Interstate 5 and State Route 134 freeway bridges, the reconfiguration of Flower S treet, construction of a modern bike path and walkways, and installation of transmission towers and streetlights, have completely altered the visual setting from when the channel was constructed. Furthermore, the area is highly urbanized and there is lots of noise and vibration, so I don't believe these impacts will be significant. Finally, we do not recommend adjustments to a project boundary to depict construction workers parking on a street with legal street parking, any more than it should be changed to include the streets that they drive on during their commutes.

On page 4 the reviewer states that the evaluation is superfluous and struggles to make a finding regarding eligibility. This is not accurate. We exhausted all available resources and references and made a clear recommendation for eligibility, which the reviewer apparently agrees with. She states that "Because the linear resource is determined eligible (not "found" nor does it "appear to be eligible"), therefore the Los Angeles River Channel is automatically listed in the California Register." Under CEQA there is no regulatory difference between eligibility and listing, so this is not a consequential comment. We would be happy to cite other reports (even if they were not filed at the South Central Coastal Information Center, as EXHIBIT 2
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3 required) to support eligibility, but the things mentioned here would not change our recommendations. Besides, we do state that the L.A. River was determined eligible by the U.S. Army Corps of Engineers (page 10 of the Cultural Resources Assessment ), citing Thompson et al. 2022. The 2019 study by the Army Corps has been referenced in several other documents, and we requested it from the Army Corps of Engineers . We never received it and were told that it was not going to be made available. Furthermore, neither the reviewer nor SHPO (in the concurrence letter cited on page 8) cite the report directly so we do not even have direct evidence that this report exists . And finally, CEQA requires that “if the survey is five or more years old at the time of its nomination for inclusion in the California Register, the survey is updated to identify historical resources that have become eligible or ineligible due to changed circumstances…” (Public Resources Code §5024.1). As such, the 2022 citation is preferred over the 2019 study.

Regarding the project site's connection with Griffith Park, we do not think it is relevant. When we did our research, we used the map from the 1994 National Register Eligibility evaluation, and the project is clearly outside of the park boundaries, separated by Interstate 5 and State Route 134. The reviewer does provide a figure with lots of different boundaries that show the project within an approximate 1897 park survey boundary, and an approximate City of Los Angeles Park Boundary, but it also shows that the project site is outside of boundaries that depict historically sensitive resource areas, and other things (page 4 of the comments).

She also mentions “N o longer extant resources in the proposed project area” (page 5 comments). As the reviewer does not explain why she mentions these resources, and they no longer exist, this is not addressed.

She goes on to cite another "serious oversight" that transmission lines are within the project APE or PAL (page 5 of the comments). As indicated above, the terms "APE" and "PAL" are not relevant to this project, but we can still consider potential for indirect impacts. There are transmission lines that go overhead, but these have not been evaluated in the project area so eligibility was not indicated in our research and the towers are outside the impact area so direct impacts will not be a factor (which is why we have not recorded them). The project will not impact the alignments directly , and indirect impacts to transmission alignments are not likely to be consequential. Transmission alignments are made to withstand significant indirect impacts (like vibration and noise) and they occupy extensive linear alignments within all kinds of settings. And (as indicated above), the visual setting of this neighborhood has changed many times over the years and the proposed project would represent another change that is not substantially different from the previous changes. I think most reviewers understand this context, which is why it has not previously come up during any of the previous comments. No change to the report is necessary to address this comment.

Page 6 ends

and that it is recorded without explanation. Page 7 of the report explains that the project site is occupied by the Glendale Narrows/Reach 3 segment of the Los Angeles River. Citations are provided that substantiate terms. No response to this comment is warranted.

Page 6 ends

Historical Resources by not evaluating the Los Angeles River for National or California Register Eligibility. Again, it is not clear why she cites National Register eligibility since this is a CEQA report for which federal rules d o not apply. Furthermore, California Register eligibility evaluation is provided clearly on pages 10 and 11 of the assessment, including the statement that “the Los Angeles River Channel (including the Glendale Narrows/Reach 3 EXHIBIT 2
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4 Segment) is eligible for California Register Listing” (page 10). No change to the report is necessary based on this comment. Page 6 of the comments indicates that the evaluation is not intensive because it lacks evaluation within a historic context. Context is provided on page 4-7 of the Cultural Resources Assessment, and evaluation is provided on pages 10-

11. No change to the report is necessary based on this comment.

The bottom of Page 7 and page 8 before “Project Description” contain several repetitions, rewording, and emphasis of previous comments. No change to the report is necessary based on this comment.

Comment C: Project Description (page 8)

Page 8 ends

to the cultural resources assessment is necessary based on this comment. Page 9 indicates that the Project Description in the IS/MND and the technical report (which presumably means the Cultural Resources Assessment) are entirely different. Unless the Project Description in the Cultural Resources Assessment is inaccurate (not indicated), there is no need to provide the level of detail from the IS/MND Project Description. No change has been made to address this comment.

Page 11 ends

points out that “significant adverse effect” is not correct and that “substantial adverse change which can cause a significant effect on the environment” is the correct CEQA verbiage. Elsewhere she prefers federal language so this is a confusing comment.

Nevertheless, the CEQA language is correct and the verbiage has been corrected as indicated on page ii of the assessment Management Summary and page 11 under Recommendations. The reviewer incorrectly assumes that the preparers are unqualified on page 12; this comment has already been addressed. She also cites CCR Title 14 Section 15064.5 “Determining the Significance of Impacts to Archaeological and Historical Resources” which explain when a historical resource’s significance is materially impaired. It is not clear why she cites this; the statute has been applied to the analysis and cited in the assessment. On page 12 of the comment letter, the reviewer claims to cite a California State Historic Preservation Officer concurrence letter to state that character -defining features within any projects at the Los Angeles River must be identified to assess whether project impacts will affect significance. As indicated above, we requested the report referenced (but not cited) and we have not received it. Therefore, it cannot be cited in our report.

Furthermore, the study may be outdated by CEQA standards due to age (as indicated above), and our reference to the 2022 citation is adequate. However, since we do not have a description of character-defining features, we have addressed all of the features that could be impacted by the project under Recommendations on page 12 of the Cultural Resources Assessment. Since all features have been addressed, no change is necessary to address this comment.

Page 13 ends

River segment and how these things were calculated. The cultural resources report states that the segment in question is 7.4 miles long, and that impacts will occur within approximately .06 percent of the resource. The size of the segment was calculated using square feet of the 7.4 mile segment at a maximum width of 354 feet (approximately 13,831,488), minus the maximum square feet of area that the proposed project overlaps with the channel (97,800). The math gives us approximately .07 percent, but this is an overestimation because not all of the channel area that is intersected by the bridge will be EXHIBIT 2
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5 impacted. We have therefore rounded down to .06 percent (the actual impacts are certainly smaller) of a resource that is virtually unvaried within its 7.4 miles. This calculation and reasoning are inexact but are designed to overstate impacts, as stated. The method was developed by the U.S. Bureau of Reclamation for an eligible river channel and this method has been used and approved for numerous similar projects in southern California. It has never been challenged in my experience. No changes to the report are made based on this comment.

Comments on page 13 question why the assessment states that bridge abutments would not touch levee walls (page 12 of the assessment, under Recommendations). This statement clearly demonstrates that installations will not impact features (including character-defining features) of the resource. She goes on to cite the U.S. Secretary of the Interior standards for rehabilitations, emphasizing that “a new addition should be subordinate to the historic.” We have demonstrated that a tiny (.06 percent -probably less) of the resource will be impacted. This demonstrates consistency with this comment. This was all apparently clear to the many previous reviewers and no changes to the report are necessary based on this comment.

Page 13 ends

where it would be deposited, and the reviewer asks when that analysis would be prepared. It is not clear what she means by “analysis”. Due to the high level of disturbance and the complete lack of archaeological sites recorded in the area (zero within a mile), answering these soil questions would not constitute archaeological analysis. There are no indications of archaeological sensitivity, but given the level of disturbance, discovery of buried cultural resources is possible. Therefore, we have recommended robust measures to address potential archaeological discoveries on pages 12 and 13 of the assessment, under Recommendations. No change to the assessment is necessary based on this comment.

On page 14 of the comment letter, the reviewer states that the assessment confuses immediate setting within and near the resource’s boundaries with its larger surrounding setting, and goes on to provide a federal definition of setting (but does not provide a citation). Again, it is not clear why she is presenting federal verbiage for a CEQA report. She goes on to re -state that the “channelized Los Angeles River and Griffith Park are each historic resources. The electrical transmission lines and towers may wel…l… be historically significant as well.” The status of the L.A. River and Griffith Park are not in question, and the reason for this statement are not clear. Potential for indirect impacts to transmission alignments and Griffith Park have been addressed above and do not merit another response.

On pages 15 and 16 of the comment letter, the reviewer presents additional neighborhood details which she summarizes to state that the “area surrounding the Los Angeles River, like most of Los Angeles, was constantly changing” (page 15 and restated on page 16). We have not reviewed the additional neighborhood details provided, but if they are accurate the cultural resources report is in agreement with this statement. Page 7 of the assessment states that “the historic setting has been affected by the modern construction of athletic fields to the south, construction of Interstates 5 and 134 to the south, paved bicycle and walking paths, and the reconfiguration of Flower Street.” The additional details provided in the comments emphasize this statement. It’s not clear if the reviewer would like this information added to the report, but since it agrees with the report, we do not believe any EXHIBIT 2
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6 change to this effect would be substantive. No change has been made to address this information.

The last paragraph on page 16 of the comment letter states that effects to eligible properties must allow resources to retain essential physical features and that they must be sufficiently visible to convey significance. The reviewer goes on to ask for new information that would help address the visibility issue. As indicated above, the assessment has demonstrated that all features that are present in the .06 percent of the resource that could potentially be partially obscured are visible within 99.94 percent of the resource. The U.S. Bureau of Reclamation (a federal agency) and many local agencies (for CEQA) accept that this level of impact would not constitute “a significant adverse effect”, or “ a substantial adverse change which can cause a significant effect on the environment”. No change has been made to address this comment.

From page 17 to 24, t he reviewer provides comments to the IS/MND, which was not prepared by BCR Consulting. We have not addressed these comments but will be available to answer related questions, and to make sure the cultural resources assessment remains consistent with this document.

Please contact me by phone at 909/525- 7078 or e -mail at [email protected] with any further questions.

Sincerely,

BCR Consulting LLC

David Brunzell, Principal

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GLENDALE-LOS ANGELES GARDEN RIVER BRIDGE
MMR
P-1
GLENDALE – LOS ANGELES GARDEN RIVER BRIDGE PROJECT
Mitigation Monitoring and Reporting Program
California Public Resources Code Section 21081.6 and Section 15097 of the California Environmental Quality Act (CEQA) Guidelines require public agencies to establish monitoring and reporting programs for projects approved by a public agency whenever approv al involves the adoption of either a mitigated negative declaration or specified environmental findings related to environmental impact reports.

This is the Mitigation Monitoring and Reporting Program (MMRP) for the Glendale -Los Angeles Garden River Bridge. The intent of the MMRP is to ensure the successful implementation of the mitigation measures identified in the Initial Study Checklist.

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J ANUARY 2026

GLENDALE-LOS ANGELES GARDEN RIVER BRIDGE
MMRP-2

Construction, Operation, and Maintenance Best
Management Practices (BMPs) and
Mitigation Measures
Action Required/
Monitoring Method
Implementation
Timing
Responsible
Monitoring
Party/Agency
Compliance Verification
Initial Date Comments
Construction, Operation, and Maintenance BMPs
BMP-1: Pre-Construction Nesting Bird Survey
Construction activities including the removal of
western sycamore trees along Zoo Drive should be
conducted outside avian nesting season pursuant
to the Migratory Bird Treaty Act. The general avian
nesting season for passerines is from February 1 st
to September 15 th but can vary based on
migratory patterns, species, weather patterns,
etc. If the nesting season cannot be avoided, a
qualiﬁed biologist shall conduct a nesting bird
survey, including suitable habitat within a 500 -
foot radius, within three days prior to any
disturbance of the site, including tr ee removal
activities. If active nests are identiﬁed, the
biologist will establish suitable buﬀers around the
nests, and the buﬀer areas shall be avoided until
the nests are no longer occupied and the juvenile
birds can survive independently from the nests
Submittal of pre -
construction nesting
bird survey report to
the City by a Qualified
Biologist.

Prior to the
issuance of
grading permits
for construction
that would start
any time
between
February 1
st and
September 15th.

Community
Development
Department

Construction
Manager/
Qualified Biologist

BMP 2: Pre-Construction Clearance Survey
Prior to the start of any ground -disturbing
activities, a qualified biologist shall conduct a pre-
construction survey of the Project site within two
hours before the start of work to determine
presence of the California legless lizard. If
individuals are d etected during the survey or
encountered during construction, the individual
shall be allowed to move out of harm’s way on its
own, or if necessary, may be relocated by a
qualified biologist to suitable upstream habitat
within the LA River.

Submittal of pre -
construction clearance
survey report for
California legless lizard
to the City by a
Qualified Biologist.

Prior to the start
of any ground-
disturbing
activities.

Community
Development
Department

Construction
Manager/
Qualified Biologist

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J ANUARY 2026

GLENDALE-LOS ANGELES GARDEN RIVER BRIDGE
MMRP-3

BMP-3: Bat Roost and Emergence Survey
Prior to the start of construction activities
including the removal of western sycamore trees
along Zoo Drive, a pre-construction survey for bat
roosts shall be conducted by performing a
daytime pedestrian survey to inspect potential
habitat within 100 feet of the Project’s work area
limits for indications of bat use (e.g., occupancy,
guano staining, smells, or sounds) followed by a
dusk emergence survey. The surveys shall be
conducted by a qualified bat biologist. If it is
determined habitat within the survey area is being
used, or is likely to be used as a bat roost, and may
be affected by construction activities, then
specific measures will be developed and
implemented to minimize potential impacts to the
roost. Such measures may include minimizing
construction activities near the roost during the
bat maternity season (May 1st through August
15th) or other measures developed by the
qualified biologist in coordination with the
California Department of Fish and Wildlife
(CDFW).

Submittal of Bat Roost
and Emergence Survey
report to the City by a
qualified biologist.

Prior to the
issuance of any
construction
activities.

Community
Development
Department

Construction
Manager/
Qualified Biologist

BMP-4: Workers Environmental Awareness Program
Prior to Project implementation, a Workers
Environmental Awareness Program (WEAP) shall
be prepared and presented to construction crews
regarding the potential for nesting birds and other
special-status species to occur on site during
construction activiti es. The WEAP training shall
concentrate on the proper identification of
sensitive resources while in the field, suggested
Provide the sign in /
attendance sheet to
the City demonstrating
the WEAP was
conducted by a
Qualified Biologist and
that all construction
workers attended.

Prior to the start
of construction
activities and
throughout
construction on
an as needed
basis as new
construction
Community
Development
Department

Construction
Manager/
Qualified Biologist

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J ANUARY 2026

GLENDALE-LOS ANGELES GARDEN RIVER BRIDGE
MMRP-4

Construction, Operation, and Maintenance Best
Management Practices (BMPs) and
Mitigation Measures
Action Required/
Monitoring Method
Implementation
Timing
Responsible
Monitoring
Party/Agency
Compliance Verification
Initial Date Comments
strategies in avoiding impacts to sensitive
resources, and proper reporting methods for field
crews if sensitive resources are observed during
construction activities.
workers come to
the site
BMP-5: Construction Noise
Construction noise best management practices
(BMPs) shall be implemented to protect sensitive
receptors (park users) and sound sensitive special-
status species roosting and/or nesting in the LA
River channel and adjacent habitat during
construction (includ ing excavation, pier
construction, etc.). Such BMPs shall include
requiring construction activities to be conducted
in accordance with the applicable local noise
regulations and standards and implementation of
noise reduction techniques during construction
activities, such as locating stationary construction
noise sources as far from adjacent noise-sensitive
receptors as possible. A temporary mobile noise
barriers shall be installed along the Project
boundary where construction activity is currently
active that is made of sound blanket, plywood or
other solid material capable of reducing on -site
construction noise levels by at least 9 dBA when
measured from the outside of the barrier. In
addition, all applicable equipment shall be fitted
with proper/improved mufflers which will provide
a reduction in construction noise levels by 6 dBA.
(Can be combined BMP-7 as applicable).

Install temporary
mobile noise barrier
along Project
boundary where
construction is
currently active.

Pre-construction &
construction
compliance monitoring
memo prepared by
qualified biologist to
submit to the City.

Prior to start of
construction
activities and
maintained
during
construction.

Community
Development
Department

Construction
Manager/
Qualified Biologist

BMP-6: Operational Lighting
Night lighting can disrupt the circadian rhythms of
many wildlife species; therefore, if night lighting is
required at Project entry points, low-level lighting
Use only low -level
lighting if necessary at
entry points.

Prior to start of
construction
activities and
Community
Development
Department

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J ANUARY 2026

GLENDALE-LOS ANGELES GARDEN RIVER BRIDGE
MMRP-5

Pre-construction &
construction
compliance monitoring
memo prepared by
qualified biologist to
submit to the City.
maintained
during
construction.

Construction
Manager/
Qualified Biologist
BMP-7: Access Routes and Work Area
The Project shall establish and delineate work
areas and access routes, within areas and routes
within jurisdictional features, to minimize impacts
to sensitive resources to the greatest extent
feasible.

Delineate work areas
and access routes
within jurisdictional
features.

Pre-construction
compliance monitoring
memo prepared by
qualified biologist to
submit to the City.

Prior to start of
construction
activities and
maintained
during
construction.

Community
Development
Department

Construction
Manager/
Qualified Biologist

BMP-8
Perimeter construction fencing shall be installed
at a minimum height of 6 feet around
construction areas to provide security to
pedestrians and screen views of staging and
construction areas.

Install 6-foot
perimeter
construction fencing.

Pre-construction
compliance monitoring
memo prepared by
qualified biologist to
submit to the City.

Prior to start of
construction
activities and
maintained
during
construction.

Community
Development
Department

Construction
Manager/
Qualified Biologist

BMP-9
All 75 horsepower or greater diesel -powered
equipment shall be powered by CARB -certified
Tier 4 Interim engines, except where the
Construction manager
to submit construction
equipment log to City
confirming use of or
Prior to start of
construction
activities and
maintained
Community
Development
Department

EXHIBIT 3
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J ANUARY 2026

GLENDALE-LOS ANGELES GARDEN RIVER BRIDGE
MMRP-6

Construction
Manager
Cultural Resources
MM CR-1:

Archaeological Worker Environmental
Awareness Program (WEAP). Prior to the start of
construction, the Qualified Archaeologist or
archaeological monitor shall conduct training for
construction personnel regarding the appearance
of archaeological resources and the procedures
for notifying archaeological staff should
archaeological resources be discovered by
construction staff. In the event of an
archaeological resource discovery by construction
personnel, all work in the immediate vicinity of the
find shall cease and a Qualified Archaeologist shall
be contacted to evaluate the find before restarting
work in the area. If it is determined that the
archaeological resource(s) is(are) scientifically
significant, the archaeological monitor shall
complete the Archaeological Assessment.

Archaeological Assessment. If a possible
archaeological resource is uncovered during
earthwork or construction, all work shall cease
within a minimum distance of 50 feet from the find
until a Qualified Archaeologist has been retained
to evaluate the find in accordance with National
Register and California Register criteria. The
Qualified Archaeologist may adjust this avoidance
area, ensuring appropriate temporary protection
measures of the find are taken while also
Provide the sign in /
attendance sheet to
the City demonstrating
the WEAP was
conducted by a
Qualified
Archaeologist and that
all construction
workers attended.

Qualified
Archaeologist’s
assessment report
submitted to City

Prior to the start
of construction
activities and
throughout
construction on
an as needed
basis as new
construction
workers come to
the site

A report that
describes the
resources(s) and
its disposition,
as well as the
assessment
methodology,
shall be
prepared by the
Community
Development
Department

Construction
Manager/
Qualified
Archaeologist

Community
Development
Department

Construction
Manager/
Qualified
Archaeologist

EXHIBIT 3
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J ANUARY 2026

GLENDALE-LOS ANGELES GARDEN RIVER BRIDGE
MMRP-7

Consistent with Public Resources Code Section
21083.2, the handling, treatment, preservation,
and recordation of unique archaeological
resources should occur as follows:
• The find should be preserved in place or
left in an undisturbed state unless the
project would damage the resource.
• When preserving in place or leaving in an
undisturbed state is not possible,
excavation and recovery of the find for
scientific study should occur unless
testing or studies already completed
have adequately recovered the
scientifically consequential information
from and about the resource, and this
Qualified
Archaeologist
within 60 days
of assessing the
find and in
accordance with
current
professional
standards.

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Ground disturbance activities in the area where
resource(s) were found may recommence once
the identified resources are properly assessed and
processed by a Qualified Archaeologist. A report
that describes the resources(s) and its disposition,
as well as t he assessment methodology, shall be
prepared by the Qualified Archaeologist within 60
days of assessing the find and in accordance with
current professional standards. If appropriate, the
report should also contain the Qualified
Archaeologist’s recommendat ions for the
preservation, conservation, and curation of the
resource at a suitable repository, such as the
Natural History Museum of Los Angeles County,
which shall be implemented. The Qualified
Archaeologist shall submit the report to the City of
Glendale and the SCCIC at the California State
University, Fullerton. The report shall include all
state and local requirements and shall be
formatted and completed in accordance with the
California Historic Resources Inventory System
(CHRIS) document submittals standards.

Tribal Cultural Resources
MM TCR-1: Retain a Native American Monitor listed on the Native American Heritage Commission contact list from the Kizh Nation Prior to Commencement of Ground-Disturbing Activities
A. The lead agency shall retain a Native American
Monitor from the Native American Heritage
Commission (NAHC) contact list, selected by the
Lead Agency in consultation with the consulting
tribes a qualified Kizh Nation representative to
City to retain a copy of
executed Native
American monitoring
agreement.

Prior to start of
construction
activities

Community
Development
Department

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B. A copy of the executed monitoring agreement
shall be retained by the lead agency prior to
commencement of any ground-disturbing activity,
or the issuance of any permit necessary to
commence a ground-disturbing activity.

C. The monitor will complete daily monitoring logs
that will provide descriptions of the relevant
ground-disturbing activities, the type of
construction activities performed, locations of
ground-disturbing activities, soil types, cultural -
related materials, and any other facts, conditions,
materials, or discoveries of significance to the
Native American
monitoring logs
Maintain
throughout
construction
duration
Construction
Manager/
Native American
Monitor
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Construction, Operation, and Maintenance Best
Management Practices (BMPs) and
Mitigation Measures
Action Required/
Monitoring Method
Implementation
Timing
Responsible
Monitoring
Party/Agency
Compliance Verification
Initial Date Comments
consulting tribes. Monitor logs will identify and
describe any discovered TCRs, including but not
limited to, Native American cultural and historical
artifacts, remains, places of significance, etc.,
(collectively, tribal cultural resources, or “TCR”),
as well as any discovered Native American
(ancestral) human remains and burial goods.

Copies of monitor logs will be provided to the lead
agency and maintained as part of the project
record upon written request to the consulting
tribes, subject to applicable confidentiality
requirements under CEQA and the California
Public Resources Code.

D. On -site tribal monitoring shall conclude upon
the latter of the following: (1) written
confirmation to the Kizh Nation and other
consulting tribes who have requested separate
site monitoring, from a designated point of
contact for the lead agency that all ground-
disturbing activities and phases that may involve
ground-disturbing activities on the project site or
in connection with the project are complete; or (2)
a determination by the Lead Agency, informed by
consultation with the Kizh Nation and other the
consulting tribes, as applicable, and written
notification to the Kizh Nation and other
consulting tribes , as applicable, that no future,
planned construction activity and/or
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MM TCR-2: Unanticipated Discovery of Tribal Cultural Resource Objects (Non-Funerary/Non-Ceremonial) A. Upon discovery of any TCRs, all construction
activities in the immediate vicinity of the
discovery (within a 60-foot buffer) shall cease and
shall not resume until the discovered TCR has
been fully assessed by the tribal monitor and/or a
qualified archaeol ogist meeting Secretary of
Interior standards (retained by lead agency).

Work on the portions of the project site outside of
the buffered area may continue during this
assessment period. The TCR shall be retained by
the archaeologist until the end of th e project
whereby the lead agency shall, in good faith,
consult with the Kizh Nation and other consulting
tribes, as applicable, that requested consultation
for the project on the disposition and treatment
(which may include reinternment to an area
where there will be no future ground
disturbances) of any TCR(s) encountered during
all ground disturbing activities.

Submittal of
Monitoring Report to
City
Throughout
construction
duration
Community
Development
Department

Construction
Manager/
Native American
Monitor and Qualified
Archaeologist

MM TCR-3: Unanticipated Discovery of Human Remains and Associated Funerary or Ceremonial Objects A. Native American human remains are defined in
California Public Resources Code (PRC) Section
5097.98 (d)(1) as an inhumation or cremation, and
in any state of decomposition or skeletal
completeness. Funerary objects, called associated
Monitoring, data
recovery, determining
the significance of the
finds, and
implementing
Throughout
construction
duration
Community
Development
Department

County Coroner/

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B. Human remains and grave/burial goods shall be
treated alike per California Public Resources Code
section 5097.98(d)(1) and (2).

C. If Native American human remains and/or
grave goods are discovered or recognized on the
project site, then PRC Section 5097.9 as well as
California Health and Safety Code Section 7050.5
shall be followed. If human remains or funerary
objects are encount ered, work within the
immediate vicinity (within 100 -foot buffer of the
find) shall cease and the County Coroner shall be
contacted without delay. No photographs may be
taken. If the County Coroner determines that the
remains are Native American, the Coron er will
contact the California Native American Heritage
Commission (NAHC), in accordance with
subdivision (c) of Section 7050.5 of the California
Health and Safety Code. If the relevant agencies
conclude that avoidance of the site is not feasible,
an alter native plan must be developed that
outlines specific steps and a timeline for resuming
construction activities. Monitoring, data recovery,
determining the significance of the finds, and
implementing avoidance measures (if necessary)
avoidance measures (if
necessary) must be
carried out promptly,
by the City

Native American
Monitor and Qualified
Archaeologist
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D. Preservation in place (avoidance with 100 foot
boundary/buffer) is the preferred manner of
treatment for discovered human remains and/or
burial goods.

E. Any discovery of human remains/burial goods
shall be kept confidential to prevent further
disturbance.

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D
ATE: May 19, 2025
TO: Juan Villalobos, Ruth Villalobos & Associates, Inc.

FROM: Haseeb Qureshi
Ali Dadabhoy
JOB NO: 14238-06 AQ, GHG & EA Assessment

GLENDALE-LOS ANGELES GARDEN RIVER BRIDGE AIR QUALITY ,

GREENHOUSE GAS & ENERGY ASSESSMENT
Juan Villalobos,
Urban Crossroads, Inc. is pleased to provide the following Air Quality (AQ), Greenhouse Gas (GHG) & Energy Assessment (EA) for the Glendale -Los Angeles Garden River Bridge (Project), which is generally located north of N. Zoo Drive, in the City of Los Angeles, and south of the intersection of Flower Street and Fairmont Avenue in in the City of Glendale. The proposed residential Project site is located within a commercial area with the nearest existing single-family residential homes approximately 1,360 feet to the northeast. The John Ferraro Athletic Fields, Los Angeles Zoo, and other community resources within Los Angeles are located south of the Project site.

PROJECT OVERVIEW
The City of Glendale as lead agency in cooperation with the City of LA, as responsible agency, proposes the construction of a three-span, curvilinear, landscaped bridge for use by pedestrians and bicyclists, as shown in Exhibit 1. The intent of this multi-community resource is to increase access to Glendale Narrows Riverwalk, and Griffith Park; to improve connections; and to increase the safety of paths used for pedestrians and cyclists. Dedicated access across the Los Angeles River at this key location would improve public safety and accessibility to important community resources by creating a connection between the Cities of Glendale and Los Angeles across the Los Angeles River for pedestrians and cyclists.

The proposed bridge would be concrete with two supporting piers in the Los Angeles River. It would feature extensive landscaping on the approaches, as well as on the bridge itself, and is thus named the “Garden River Bridge.” A number of raised planting beds on the bridge would create dedicated zones for bicycle and pedestrian circulation, shade structures, canopied seating areas, dispersed gathering spaces, and scenic views of the Los Angeles River.

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The City of Los Angeles owns, operates, and maintains the south side of the Los Angeles River, located within the southern portion of the proposed Project area; also within this area, Southern California Edison (SCE) holds a fifteen-foot easement along Zoo Drive and overhead facilities on Los Angeles Department of Water and Power (LADWP) poles. On the north bank of the Los Angeles River, parcels within the northern portion of the proposed Project limits are owned by the City of Glendale, the City of Los Angeles, and the Los Angeles County Flood Control District (LACFCD). Furthermore, easements that cross the proposed Project area on the northern side are held by the City of Glendale for utility purposes (e.g., poles, sewers and related structures), and for the existing Riverwalk pedestrian/bike trail.

The proposed Project would include overall temporary impacts of approximately 2.94 acres and approximately 1.4 acres of permanent impacts. Temporary impacts would include water diversion activities, excavation activities, and areas of access and staging. P ermanent impacts would include the bridge, Riverwalk bike path reconstruction adjacent to the bridge, a new connection from the bridge to Zoo Drive, and the realignment of Zoo Drive; see Exhibit 2. The realignment of Zoo Drive would be to permit the construction of stairs and a ramp leading up to the LA River Bike Path and the proposed bridge. Trees between Zoo Drive and the Los Angeles River Bike Path would be removed, and a new curb would be installed as part of proposed street improvements. Additionally, a sidewalk would be installed to facilitate access from the bridge to the John Ferraro Athletic Fields to the south via a new raised crosswalk across Zoo Drive.

Construction is anticipated to begin in the Fall of 2025 and would last approximately 2.5 years, ending in the Spring of 2028. The proposed Project would occur in six (6) phases, and shown and summarized below.
• Phase 0: Mobilization – The initial phase of the proposed Project would include requests for information, preparing and reviewing submittals, and procuring materials. • Phase 1: North Abutment and Approaches – Approach work, bike path work, and abutment work. • Phase 2: Bridge Substructure – Construct bents within the LA River. • Phase 3: South Abutment and Approaches – Construct the south abutment and connections to Zoo Drive; realign Zoo Drive.
• Phae 4: Bridge Superstructure – Construct the bridge superstructure using falsework within the LA River.
• Phase 5: Architectural Elements/Landscaping – Construct the architectural elements (e.g., canopies, landscaping, etc.) on the bridge and approaches.

The bridge abutments would be constructed to be higher than the existing elevation of the channel walls and would not touch the levee walls. The abutments would be supported by deep foundations consisting of cast -in-drilled-hole concrete piles; the abutments would not be supported by the channel walls. In order to address drainage from the bridge deck, pipes would be hung inside of the bridge and tie into existing drainage pipes or water treatment features on both sides of the Los Angeles River channel. Activities associated with the realignment of Zoo Drive would include the removal of trees along the Los Angeles River Bike Path along Zoo Drive, within the southern portion of the proposed Project’s footprint in the City of LA.

The demolition and excavation phases of the proposed Project are expected to generate the most construction traffic and require the most equipment. In-river construction would occur during EXHIBIT 4
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the dry season (April through October) when flood flows are very unlikely. The construction equipment used during different portions of the proposed Project would include work trucks, concrete trucks, cast-in-drilled-hole concrete pile drilling rigs, mobile cranes, and excavators. The construction contractor would be required to lay down timber mats to protect the Los Angeles River bottom and prevent potential impacts to the Los Angeles River bottom during construction.

While variable, an average of 15 peop le would be on site daily for the duration of construction activities. Construction access to the proposed Project site would be provided from Zoo Drive on the City of Los Angeles side of the proposed Project and from Flower Street on the Glendale side of the Project, with intermittent temporary lane closures and or reduced access. Due to the lack of suitable access ramps within close proximity to the proposed Project site, the cons truction contractor may construct a temporary ramp from Zoo Drive down the sloped levee into the channel bottom. The temporary construction staging area would be located in the City of Los Angeles and the City of Glendale at the southern and northern areas of the proposed Project; specifically, one of the staging areas would be on the north side of Zoo Drive within the shoulder of the road. Additional staging would occur within the Los Angeles River's northern bank and southern bank during construction of the bridge’s piers. Any rights of entry and/or temporary easements would be negotiated as part of the final design phase prior to the start of construction. The existing pedestrian and bike path use on the Riverwalk and the Los Angeles River Bike Path would require temporary intermittent detours during construction activities. The City of Glendale would be responsible for the construction of the proposed Project. The cities of Glendale and Los Angeles are currently negotiating an agreement to address shared ownership, operation, and maintenance of the proposed Project.

SUMMARY OF FINDINGS
Results of the assessment indicate that the Project would result in a less than significant impact with respect to air quality, greenhouse gas and energy and no mitigation is required.

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EXHIBIT 1: PROJECT SITE

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PROJECT AIR QUALITY IMPACTS

REGULATORY BACKGROUND

FEDERAL REGULATIONS
The EPA is responsible for setting and enforcing the national ambient air quality standards (NAAQS) for O 3, CO, NO X, SO2, PM10, and lead (Pb) (1). The EPA has jurisdiction over emissions sources that are under the authority of the federal government including aircraft, locomotives, and emissions sources outside state waters (Outer Continental Shelf). The EPA also establishes emission standards for vehicles sold in states other than California. Automobiles sold in California must meet the stricter emission requirements of CARB.

The Federal Clean Air Act (CAA) was first enacted in 1955 and has been amended numerous times in subsequent years (1963, 1965, 1967, 1970, 1977, and 1990). The CAA establishes the federal air quality standards, the NAAQS, and specifies future dates for achieving compliance (2). The CAA also mandates that each state submit and implement state implementation plans (SIPs) for local areas not meeting these standards. These plans must include pollution control measures that demonstrate how the standards will be met.

The 1990 amendments to the CAA that identify specific emission reduction goals for areas not meeting the NAAQS require a demonstration of reasonable further progress toward attainment and incorporate additional sanctions for failure to attain or to meet in terim milestones. The sections of the CAA most directly applicable to the development of the Project site include Title I (Non-Attainment Provisions) and Title II (Mobile Source Provisions) (3) (4). Title I provisions were established with the goal of attaining the NAAQS for the following criteria pollutants O 3, NO2, SO2,
PM10, CO, PM2.5, and Pb. The NAAQS were amended in July 1997 to include an additional standard for O3 and to adopt a NAAQS for PM2.5.

Mobile source emissions are regulated in accordance with Title II provisions. These provisions require the use of cleaner burning gasoline and other cleaner burning fuels such as methanol and natural gas. Automobile manufacturers are also required to reduce tailpipe emissions of hydrocarbons and NO
X. NOX is a collective term that includes all forms of NOX which are emitted as byproducts of the combustion process.

CALIFORNIA REGULATIONS
CARB
The CARB, which became part of the California EPA (CalEPA) in 1991, is responsible for ensuring implementation of the California Clean Air Act (AB 2595), responding to the federal CAA, and for regulating emissions from consumer products and motor vehicles. AB 2595 mandates achievement of the maximum degree of emissions reductions possible from vehicular and other mobile sources in order to attain the state ambient air quality standards by the earliest practical date. The CARB established the California ambient air quality standards (CAAQS) for all pollutants for which the federal government has NAAQS and, in addition, establishes standards for SO 4,
visibility, hydrogen sulfide (H2S), and vinyl chloride (C2H3Cl). However, at this time, H2S and C2H3Cl EXHIBIT 4
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are not measured at any monitoring stations in the SCAB because they are not considered to be a regional air quality problem. Generally, the CAAQS are more stringent than the NAAQS (5) (6).

Local air quality management districts, such as the SCAQMD, regulate air emissions from stationary sources such as commercial and industrial facilities. All air pollution control districts have been formally designated as attainment or non-attainment for each CAAQS.

Serious non-attainment areas are required to prepare Air Quality Management Plans (AQMP) that include specified emission reduction strategies in an effort to meet clean air goals. These plans are required to include:
• Application of Best Available Retrofit Control Technology to existing sources; • Developing control programs for area sources (e.g., architectural coatings and solvents) and indirect sources (e.g., motor vehicle use generated by residential and commercial development);
• A District permitting system designed to allow no net increase in emissions from any new or modified permitted sources of emissions;
• Implementing reasonably available transportation control measures and assuring a substantial reduction in growth rate of vehicle trips and miles traveled; • Significant use of low emissions vehicles by fleet operators; • Sufficient control strategies to achieve a 5% or more annual reduction in emissions or 15% or more in a period of three years for ROGs, NO
X, CO and PM10. However, air basins
may use an alternative emission reduction strategy that achieves a reduction of less than 5% per year under certain circumstances.

AQMP
Currently, the NAAQS and CAAQS are exceeded in most parts of the SCAB. In response, the SCAQMD has adopted a series of AQMP to meet the state and federal ambient air quality standards (7). AQMPs are updated regularly in order to more effectively reduce emissions, accommodate growth, and to minimize any negative fiscal impacts of air pollution control on the economy.

APPLICABLE REGULATORY REQUIREMENTS
SCAQMD Rules that are currently applicable during construction activity for this Project include but are not limited to Rule 403 (Fugitive Dust) and Rule 1113 (Architectural Coatings) (8) (9).

SCAQMD Rule 403
This rule is intended to reduce the amount of particulate matter entrained in the ambient air as a result of anthropogenic (human- made) fugitive dust sources by requiring actions to prevent and reduce fugitive dust emissions. Rule 403 applies to any activity or human -made condition capable of generating fugitive dust and requires best available control measures to be applied to earth moving and grading activities. This rule is intended to reduce PM 10 emissions from any
transportation, handling, construction, or storage activity that has the potential to generate fugitive dust. PM
10 suppression techniques are summarized below.

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• Portions of a construction site to remain inactive longer than a period of three months will be seeded and watered until grass cover is grown or otherwise stabilized. • All on-site roads will be paved as soon as feasible or watered periodically or chemically stabilized.
• All material transported off-site will be either sufficiently watered or securely covered to prevent excessive amounts of dust.
• The area disturbed by clearing, grading, earthmoving, or excavation operations will be minimized at all times.
• Where vehicles leave a construction site and enter adjacent public streets, the streets will be swept daily or washed down at the end of the workday to remove soil tracked onto the paved surface.

METHODOLOGY
In May 2022, the California Air Pollution Control Officers Association (CAPCOA) in conjunction with other California air districts, including the South Coast Air Quality Management District (SCAQMD), released the latest version of the CalEEMod Version 2022.1. The purpose of this model is to calculate construction-source and operational-source criteria pollutant (VOCs, NO

X, SOX, CO,
PM10, and PM2.5) and GHG emissions from direct and indirect sources; and quantify applicable air quality and GHG reductions achieved from mitigation measures (11). Accordingly, the latest version of CalEEMod has been used for this Project to determine construction and operational air quality and greenhouse gas emissions.

Standards of Significance
The criteria used to determine the significance of potential Project-related air quality impacts are taken from the California Environmental Quality Act Guidelines ( CEQA Guidelines ) (14 CCR §§15000, et seq.). Based on these thresholds, a project would result in a significant impact related to air quality if it would (10):
• Threshold 1: Conflict with or obstruct implementation of the applicable air quality plan. • Threshold 2: Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in non -attainment under an applicable federal or state ambient air quality standard.
• Threshold 3: Expose sensitive receptors to substantial pollutant concentrations. • Threshold 4 : Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.

CITY OF LOS ANGELES CALIFORNIA ENVIRONMENTAL QUALITY ACT THRESHOLDS GUIDE The L.A. CEQA Thresholds Guide (2006) describes significance thresholds to be used in air quality analyses and outlines methodologies for determining significance. It refers to the SCAQMD CEQA Air Quality Analysis Handbook (1993) for appropriate thresholds . Although SCAQMD has not published an updated Handbook, various supplements have been published that provide updated methodologies for analyzing air quality impacts as well as thresholds of significance.

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These current SCAQMD methodologies and significance thresholds were utilized in this analysis as presented below.

AIR QUALITY REGIONAL EMISSIONS THRESHOLDS
The SCAQMD has developed regional significance thresholds for criteria pollutants, as summarized at Table 1 (12). The SCAQMD’s CEQA Air Quality Significance Thresholds ( March 2023) indicate that any projects in the South Coast Air Basin (SCAB) with daily emissions that exceed any of the indicated thresholds should be considered as having an individually and cumulatively significant air quality impact.

TABLE 1: MAXIMUM DAILY REGIONAL EMISSIONS THRESHOLDS
Pollutant Construction Operations
NOX 100 lbs/day 55 lbs/day
VOC 75 lbs/day 55 lbs/day
PM10 150 lbs/day 150 lbs/day
PM2.5 55 lbs/day 55 lbs/day
SOX 150 lbs/day 150 lbs/day
CO 550 lbs/day 550 lbs/day
lbs/day – Pounds Per Day

AIR QUALITY LOCALIZED EMISSIONS THRESHOLDS
For this Project, the appropriate Source Receptor Area ( SRA) for the Localized Significant Thresholds (LST) analysis is the SCAQMD East San Fernando Valley monitoring station (SRA 7).

LSTs apply to CO, NO 2, PM10, and PM2.5. The SCAQMD produced look -up tables for pr ojects less than or equal to 5 acres in size . T he SCAQMD’s screening look- up tables are utilized in determining localized impacts. The proposed project is located on approximately 2.94 acres and it should be noted that since the look-up tables identify thresholds at only 1 acre, 2 acres, and 5 acres, linear regression has been utilized to determine localized significance thresholds.

Consistent with SCAQMD guidance, the thresholds presented in Table 2 were calculated by interpolating the threshold values for the Project’s disturbed acreage.

TABLE 2: MAXIMUM DAILY LOCALIZED EMISSIONS THRESHOLDS
Source
Emissions (lbs/day)
VOC NOX PM10 PM2.5
Construction 132 lbs/day 989 lbs/day 122 lbs/day 57 lbs/day 1Source of localized significance threshold (LSTs) is provided on page 9.

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REGIONAL CONSTRUCTION EMISSIONS SUMMARY
Construction activities associated with the Project would result in emissions of VOCs, NO X, SOX, CO, PM10, and PM2.5. Construction related emissions are expected from the following construction activities:
• Phase 1: North Abutment & Approaches
• Phase 2: Bridge Substructure (Bent Construction)
• Phase 3: South Abutment & Approaches
• Phase 4: Bridge Superstructure
• Phase 5: Architectural Elements / Landscaping

ON-ROAD TRIPS
Construction generates on-road vehicle emissions from vehicle usage for workers and vendors commuting to and from the site. It should be noted that the CalEEMod defaults for worker trips have been adjusted based on information provided by the Project applicant. Vendor trips are based on CalEEMod defaults.

CONSTRUCTION DURATION
Per Project applicant provided data, construction of Project is expected to commence in January 2026 and would last through March 2028. The construction schedule utilized in the analysis represents a “worst -case” analysis scenario should construction occur any time after the respective dates since emission factors for construction decrease as time passes and the analysis year increases due to emission regulations becoming more stringent 1. The duration of construction activity and associated equipment represents a reasonable approximation of the expected construction fleet as required per CEQA Guidelines (13).

CONSTRUCTION EQUIPMENT
The CalEEMod default construction equipment associated with the proposed Project has been adjusted based on information provided by the Project applicant . Consistent with industry standards and typical construction practices, each piece of equipment will operate up to a total of eight (8) hours per day, or more than two -thirds of the period during which construction activities are allowed pursuant to the code.

REGIONAL CONSTRUCTION EMISSIONS SUMMARY
The estimated maximum daily construction emissions without mitigation are summarized on Table 3. Detailed construction model outputs are presented in Attachment A. Under the assumed

1 As shown in the CalEEMod User’s Guide Version 2022, Appendix G “Table G-11. Statewide Average Annual Offroad Equipment Emission Factors” as the analysis year increases, emission factors for the same equipment pieces decrease due to the natural turnover of older equipment being replaced by newer less polluting equipment and new regulatory requirements.

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scenarios, emissions resulting from the Project construction will not exceed thresholds established by the SCAQMD for emissions of any criteria pollutant and no mitigation is required.

TABLE 3: OVERALL REGIONAL CONSTRUCTION EMISSIONS SUMMARY Source
Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Summer
2026 2.86 20.50 27.80 0.07 1.50 0.84
2027 2.72 16.50 21.60 0.07 1.40 0.75
Winter
2026 1.39 9.55 13.50 0.03 0.78 0.37
2027 1.37 9.21 13.50 0.03 0.62 0.39
2028 1.21 8.33 10.00 0.03 0.59 0.36
Maximum Daily Emissions 2.86 20.50 27.80 0.07 1.50 0.84 SCAQMD Regional Threshold 75 100 550 150 150 55
Threshold Exceeded? NO NO NO NO NO NO
1PM10 and PM2.5 source emissions reflect 3x daily watering per SCAQMD Rule 403 for fugitive dust.

REGIONAL OPERATIONAL EMISSIONS
Operational activities associated with Projects would result in emissions of CO, VOCs, NO X, SOX, PM10, and PM2.5. As this Project involves the construction of 350-foot long, three-span curvilinear bridge structure and associated improvements , heating and consumer products would not be used. Additionally, any other sources including mobile and energy sources would not contribute a substantial amount of emissions capable of exceeding SCAQMD thresholds.

Sensitive Receptor Locations
Some people are especially sensitive to air pollution and are given special consideration when evaluating air quality impacts from projects. These groups of people include children, the elderly, and individuals with pre-existing respiratory or cardiovascular illness. Structures that house these persons or places where they gather are defined as “sensitive receptors”. These structures typically include uses such as residences, hotels, and hospitals where an individual can remain for 24 hours. Consistent with the LST Methodology, the nearest land use where an individual could remain for 24 hours to the Project site has been used to determine construction and operational air quality impacts for emissions of PM
10 and PM2.5, since PM10 and PM2.5 thresholds
are based on a 24-hour averaging time.

Receptors in the Project study area are described below. All distances are measured from the Project site boundary to the outdoor living areas (e.g., backyards) or at the building façade, whichever is closer to the Project site. Receptors in the Project study area are shown on Exhibit 2 under the Localized Construction Emissions section later in the report.

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• Receptor R1 represents the John Ferraro Athletic Fields south along Zoo Drive, approximately 318 feet west of the Project site at the play structure nearest to the Project site.
• Receptor R2 represents the existing residence located at 810 Pelanconi Avenue , approximately 1,238 feet northeast of the Project site. • Receptor R3 represents an outdoor seating area of an office structure located at 1000 Flower Street, approximately 422 feet northwest of the Project site. • Receptor R4 represents the John Ferraro Athletic Field soccer field, approximately 13 feet south of the Project site.
• Receptor R5 represents the John Ferraro Athletic Field soccer field, approximately 101 feet southwest of the Project site.
• Receptor R6 represents the Los Angeles Zoo south along Zoo Drive, approximately 1,454 feet south of the Project site.
• Receptor R7 represents the Los Angeles Children Zoo south along Zoo Drive , approximately 2,215 feet southwest of the Project site.

SENSITIVE RECEPTORS
The analysis uses the methodology included in the SCAQMD Final Localized Significance Threshold Methodology (LST Methodology) (14). The SCAQMD has established that impacts to air quality are significant if there is a potential to contribute or cause localized exceedances of the federal and/or state ambient air quality standards (NAAQS/CAAQS). Collectively, these are referred to as Localized Significance Thresholds (LSTs). The SCAQMD established LSTs in response to the SCAQMD Governing Board’s Environmental Justice Initiative I-4

2. LSTs represent the maximum
emissions from a project that will not cause or contribute to an exceedance of the most stringent applicable federal or state ambient air quality standard at the sensitive receptor. The SCAQMD states that lead agencies can use the LSTs as another indicator of significance in its air quality impact analyses. It should be noted that SCAQMD also states that projects that are statutorily or categorically exempt under CEQA would not be subject to LST analyses. Projects exempt from CEQA also include infill projects that meet the H&S Code provisions. The proposed Project is anticipated to be Categorically Exempt under CEQA and as such while LST analysis is not required for this Project, LST analysis is presented to further underscore that there are in fact no significant impacts associated with the Project.

The SCAQMD recommends that the nearest sensitive receptor be considered when determining the Project’s potential to cause an individual or cumulatively significant impact. The nearest land use where an individual could remain for 24 hours to the Project site has been used to determine

2 The purpose of SCAQMD’s Environmental Justice program is to ensure that everyone has the right to equal protection from air pollution and fair access to the decision-making process that works to improve the quality of air within their communities. Further, the SCAQMD defines Environmental Justice as “…equitable environmental policymaking and enforcement to protect the health of all residents, regardless of age, culture, ethnicity, gender, race, socioeconomic status, or geographic location, from the health effects of air pollution.” EXHIBIT 4
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localized construction impacts for emissions of PM 10 and PM2.5 (since PM10 and PM2.5 thresholds are based on a 24 -hour averaging time). The nearest receptor used for evaluation of localized impacts of PM10 and PM2.5 is location R2 represented by the existing residence at 810 Pelanconi Ave, approximately 1,238 feet (377 meters) northeast of the Project site. As such, for evaluation of localized PM10 and PM2.5, a 377-meter distance will be used. Receptors in the Project study area shown on Exhibit 2.

As previously stated, and consistent with LST Methodology, the nearest industrial/commercial use to the Project site is used to determine construction air impacts for emissions of NOX and CO as the averaging periods for these pollutants are shorter (8 hours or less) and it is reasonable to assume that an individual could be present at these sites for periods of one to 8 hours. The nearest receptor used for evaluation of localized impacts of NO X and CO is location R 4
represented by the John Ferraro Athletic Fields , approximately 13 feet (4 meters) south of the Project site.

It should be noted that the LST Methodology explicitly states that “It is possible that a project may have receptors closer than 25 meters. Projects with boundaries located closer than 25 meters to the nearest receptor should use the LSTs for receptors located at 25 meters (14).” As such, for evaluation of localized NO
x and CO, a 25-meter distance will be used.

Additionally, receptors at locations R6 and R7, which represent potential impacts to patrons of the Los Angeles Zoo have been considered in this analysis. Given that both locations R 6 and R7 are located further away from the Project’s construction activities than locations R1 , R2, R3, R4, and R5 any potential impacts at locations R6 or R7 would be less than what is already disclosed in this report for impacts that may occur at locations R1, R2, R3, R4, and R5.

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EXHIBIT 2: SENSITIVE RECEPTOR LOCATIONS

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LOCALIZED CONSTRUCTION EMISSIONS
Table 4 identifies the localized impacts at the nearest receptor location in the vicinity of the Project. Outputs from the model runs for construction LSTs are provided in Attachment A. For analytical purposes, emissions associated with peak site preparation and grading activities are considered for purposes of LSTs since these phases represents the maximum localized emissions that would occur. Any other construction phases of development that overlap would result in lesser emissions and consequently lesser impact s than what is disclosed herein. As shown in Table 4, emissions resulting from the construction will not exceed the numerical thresholds of significance established by the SCAQMD for any criteria pollutant . Thus, a less than significant impact would occur for localized Project-related construction-source emissions and no mitigation is required.

TABLE 4: PROJECT LOCALIZED CONSTRUCTION IMPACTS
On-Site Emissions
Emissions (lbs/day)
NOX CO PM10 PM2.5
Phase 1: North Abutment & Approaches
Maximum Daily Emissions 7.94 10.40 0.26 0.24
SCAQMD Localized Threshold 132 989 122 57
Threshold Exceeded? NO NO NO NO
Phase 2: Bridge Substructure (Bent Construction)
Maximum Daily Emissions 20.20 23.90 0.71 0.65
SCAQMD Localized Threshold 132 989 122 57
Threshold Exceeded? NO NO NO NO
Phase 3: South Abutment & Approaches
Maximum Daily Emissions 9.46 12.40 0.33 0.31
SCAQMD Localized Threshold 132 989 122 57
Threshold Exceeded? NO NO NO NO

PROJECT GREENHOUSE GAS ANALYSIS
As this Project involves the construction of 350-foot long, three-span curvilinear bridge structure and associated improvements, heating and consumer products would not be used. Additionally, any other sources including mobile and energy sources would not result in any substantive new long-term GHG emissions sources. The estimated GHG emissions for the Project land use are summarized on Table 5 . The estimated GHG emission include emissions from Carbon Dioxide (CO2), Methane (CH 4), Nitrous Oxide (N 2O), and Refrigerants (R). As shown on Table 5 , the proposed Project would generate a total of approximately 46.97 MTCO2e/yr.

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TABLE 5: TOTAL PROJECT GHG EMISSIONS
Year
Emission (MT/yr)
CO2 CH4 N2O Refrigerants Total CO2e
Annual construction-related emissions
amortized over 30 years 46.77 2.00E-03 6.67E-04 6.33E-03 46.97 Total CO2e (All Sources) 46.97
A numerical threshold for determining the significance of GHG emissions in the SCAB has not been e stablished by the SCAQMD for projects where it is not the lead agency. As an interim threshold based on guidance provided in the CAPCOA CEQA and Climate Change handbook, the City has opted to use a non- zero threshold approach based on Approach 2 of the h andbook.

Threshold 2.5 (Unit-Based Thresh olds Based on Market Ca pture) e stablishes a numerical threshold based on capture of approximately 90% of emissions from future development. The latest threshold developed by SCAQMD using this method is 3,000 MTCO2e/yr for all projects (15).

The Project would result in approximately 46.97 MTCO2e/yr; the proposed Project would not exceed the SCAQMD’s numeric threshold of 3,000 MTCO2e/yr. Thus, the Project would result in a less than significant impact with respect to GHG emissions.

PROJECT ENERGY ANALYSIS
Vehicle fuel efficiencies for light-duty-auto vehicles (LDA), light-duty-trucks (LDT1), and light-duty- trucks (LDT2) were estimated using information generated within the 2021 version of the EMFAC developed by the California Air Resources Board (CARB). EMF AC2021 is a mathematical model that was developed to calculate emission rates, fuel consumption, and VMT from motor vehicles that operate on highways, freeways, and local roads in California and is commonly used by CARB to project changes in future emissions from on-road mobile sources (9). EMFAC2021 was run for the LDA, LDT1, and LDT2 vehicle class within the California Los Angeles South-Coast sub-area for the 202 6 calendar year. It should be noted that using the static year 202 6 is considered conservative for estimating fuel consumption as it does not account for fuel efficiency improvements each year. Data from EMFAC2021 is shown in Attachment B.

CONSTRUCTION ENERGY DEMANDS

CONSTRUCTION EQUIPMENT ELECTRICITY USAGE ESTIMATES
The 2024 National Construction Estimator identifies a typical power cost per 1,000 sf of construction per month of $2. 66, which was used to calculate the Project’s total construction power cost (16).

Based on Table 6, the total power cost of the on-site electricity usage during the construction of the Project is estimated to be approximately $8,857.09. As shown on Table 7, the total electricity usage from on-site Project construction related activities is estimated to be approximately 63,265 kWh.

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TABLE 6: PROJECT CONSTRUCTION POWER COST
Land Use
Power Cost
(per 1,000 SF of
building per
month of
construction)
Total
Building
Size
(1,000 SF)
Construction
Duration
(months)
Project
Construction
Power Cost
Bridge/Overpass Construction $2.66 128.067 26 $8,857.09 TOTAL PROJECT CONSTRUCTION POWER COST $8,857.09
TABLE 7: PROJECT CONSTRUCTION ELECTRICITY USAGE
Land Use Cost per kWh1 Project Construction
Electricity Usage (kWh)
Bridge/Overpass Construction $0.16 63,265
TOTAL PROJECT CONSTRUCTION ELECTRICITY USAGE (kWh) 63,265 1Assumes the Project will be under the GS-1 General Service Rate under Southern California Edison

CONSTRUCTION EQUIPMENT FUEL ESTIMATES
As presented in Table 8 , Project construction activities would consume an estimated 130,082 gallons of diesel fuel. Project construction would represent a “single ‐event” diesel fuel demand and would not require on ‐going or permanent commitment of diesel fuel resources for this purpose.

CONSTRUCTION WORKER FUEL ESTIMATES
With respect to estimated VMT, the construction worker trips would generate an estimated 404,040 VMT. Based on CalEEMod methodology, it is assumed that 50% of all vendor trips are from LDA, 25% are from LDT1, and 25% are from LDT2. Data regarding Project related construction worker trips were based on CalEEMod defaults for the land use type and projec t location which are also utilized within the air quality assessment and CalEEMod outputs contained herein.
.

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TABLE 8: PROJECT CONSTRUCTION EQUIPMENT FUEL CONSUMPTIONS ESTIMATES Activity/Duration Duration
(Days) Equipment HP Rating Quantity Usage Hours Load Factor HP-hrs/day Total Fuel
Consumption
(gal. diesel
fuel)
Phase 1 97
Bore/Drill Rigs 83 1 8 0.5 332 1,741
Excavators 36 2 8 0.38 219 1,148
Off-Highway Trucks 376 2 8 0.38 2,286 11,986
Phase 2 85
Bore/Drill Rigs 83 2 8 0.5 664 3,051
Excavators 36 4 8 0.38 438 2,011
Cranes 367 2 8 0.29 1,703 7,824
Off-Highway Trucks 376 3 8 0.38 3,429 15,755
Phase 3 155
Bore/Drill Rigs 83 1 8 0.5 332 2,782
Excavators 36 2 8 0.38 219 1,834
Off-Highway Trucks 376 2 8 0.38 2,286 19,154
Pavers 81 1 8 0.42 272 2,280
Phase 4 119
Cranes 367 2 8 0.29 1,703 10,954
Off-Highway Trucks 376 4 8 0.38 4,572 29,410
Phase 5 131
Cranes 367 2 8 0.29 1,703 12,058
Off-Highway Trucks 376 1 8 0.38 1,143 8,094
CONSTRUCTION FUEL DEMAND (GALLONS DIESEL FUEL) 130,082
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As shown on Table 9, it is estimated that 14,313 gallons of fuel will be consumed related to construction worker trips during full construction of the proposed Project. Project construction worker trips would represent a “single ‐event” gasoline fuel demand and would not require on ‐ going or permanent commitment of fuel resources for this purpose.

TABLE 9: CONSTRUCTION WORKER FUEL CONSUMPTION ESTIMATES Year Construction Activity Duration
(Days)
Worker
Trips/Day
Trip
Length
(miles)
VMT
Average
Vehicle Fuel
Economy

Estimated
Fuel
Consumption

2026
LDA
Phase 1 97 20 18.5 35,890 33.12 1,084
Phase 2 85 30 18.5 47,175 33.12 1,425
Phase 3 79 10 18.5 14,615 33.12 441
LDT1
Phase 1 97 10 18.5 17,945 24.62 729
Phase 2 85 15 18.5 23,588 24.62 958
Phase 3 79 5 18.5 7,308 24.62 297
LDT2
Phase 1 97 10 18.5 17,945 24.57 730
Phase 2 85 15 18.5 23,588 24.57 960
Phase 3 79 5 18.5 7,308 24.57 297
2026
LDA
Phase 3 76 10 18.5 14,060 33.12 425
Phase 4 119 30 18.5 66,045 33.12 1,994
Phase 5 66 10 18.5 12,210 33.12 369
LDT1
Phase 3 76 5 18.5 7,030 24.62 286
Phase 4 119 15 18.5 33,023 24.62 1,341
Phase 5 66 5 18.5 6,105 24.62 248
LDT2
Phase 3 76 5 18.5 7,030 24.57 286
Phase 4 119 15 18.5 33,023 24.57 1,344
Phase 5 66 5 18.5 6,105 24.57 248
2026
LDA
Phase 5 65 10 18.5 12,025 33.12 363
LDT1
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Year Construction Activity Duration
(Days)
Worker
Trips/Day
Trip
Length
(miles)
VMT
Average
Vehicle Fuel
Economy

Estimated
Fuel
Consumption
Phase 5 65 5 18.5 6,013 24.62 244
LDT2
Phase 5 65 5 18.5 6,013 24.57 245
TOTAL CONSTRUCTION WORKER FUEL CONSUMPTION 14,313

CONSTRUCTION VENDOR/HAULING FUEL ESTIMATES
With respect to estimated VMT, the construction vendor trips would generate an estimated 1,734 VMT. It is assumed that 50% of all vendor trips are from medium- heavy duty trucks (MHDT) and 50% of vendor trips are from heavy- heavy duty trucks (HHDT ). As shown on Table 10, it is estimated that 244 gallons of fuel will be consumed related to construction vendor trips (medium duty trucks) during full construction of the Project. Project construction vendor trips would represent a “single‐ event” diesel fuel dema nd and would not require on‐ going or permanent commitment of diesel fuel resources for this purpose.

TABLE 10: CONSTRUCTION VENDOR FUEL CONSUMPTION ESTIMATES (TRUCKS) Year Construction Activity Duration
(Days)
Worker
Trips/Day
Trip
Length
(miles)
VMT
Average
Vehicle Fuel
Economy

Estimated
Fuel
Consumption

2026
MHDT
Phase 2 85 1 10.2 867 8.49 102
HHDT (Vendor)
Phase 2 85 1 10.2 867 6.12 142
TOTAL CONSTRUCTION WORKER FUEL CONSUMPTION 244

CONSTRUCTION ENERGY DEMANDS SUMMARY
Construction equipment use of fuel would not be atypical for the type of construction proposed because there are no aspects of the Project’s proposed construction process that are unusual or energy-intensive, and Project construction equipment would confor m to the applicable CARB emissions standards, acting to promote equipment fuel efficiencies.

CCR Title 13, Title 13, Motor Vehicles, section 2449(d)(3) Idling, limits idling times of construction vehicles to no more than 5 minutes, thereby precluding unnecessary and wasteful consumption of fuel due to unproductive idling of construction equipment. Best Available Control Measures (BACMs) inform construction equipment operators of this requirement.

With regard to construction worker trips, the 2023 IEPR released by the CEC has shown that fuel efficiencies are getting better within on and off -road vehicle engines due to more stringent government requirements. As supported by the preceding discussions, Project construction energy consumption would not be considered inefficient, wasteful, or otherwise unnecessary.

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OPERATIONAL ENERGY DEMANDS SUMMARY
The Project does not propose a trip-generating land use. For these reasons, operational-related energy consumption would not result in a significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources. Therefore, the operational impact related to vehicle fuel consumption would be less than significant.

AIR QUALITY, GREENHOUSE GAS & ENERGY CONCLUSION
Results of the assessment indicate that the Project is not anticipated to result in a significant impact during construction and operations activities with air quality, greenhouse gas and energy and no mitigation is required.

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REFERENCES

1. United States Environmental Protection Agency. National Ambient Air Quality Standards (NAAQS). [Online] 1990. https://www.epa.gov/environmental-topics/air-topics.

2. Environmental Protection Agency. Air Pollution and the Clean Air Act. [Online] http://www.epa.gov/air/caa/.

3. 1990 Clean Air Act Amendment Summary: Title I. [Online] https://www.epa.gov/clean- air-act-overview/1990-clean-air-act-amendment-summary-title-i.

4. United States Environmental Protection Agency. 1990 Clean Air Act Amendment Summary: Title II. [Online] https://www.epa.gov/clean -air-act-overview/1990- clean-air-act-amendment-summary-title-ii.

5. Air Resources Board. California Ambient Air Quality Standards (CAAQS). [Online] 2009. [Cited: April 16, 2018.] http://www.arb.ca.gov/research/aaqs/caaqs/caaqs.htm.

6. Environmental Protection Agency. National Ambient Air Quality Standards (NAAQS). [Online] 1990. https://www.epa.gov/environmental-topics/air-topics.

7. Southern California Association of Governments. 2016- 2040 Regional Transportation Plan/Sustainable Communities Strategy. [Online] April 2016. http://scagrtpscs.net/Documents/2016/final/f2016RTPSCS.pdf.

8. South Coast Air Quality Management District. RULE 403. FUGITIVE DUST. [Online] https://www.aqmd.gov/docs/default-source/rule-book/rule-iv/rule- 403.pdf?sfvrsn=4.

9. —. RULE 1113. Architectural Coatings. [Online] http://www.aqmd.gov/docs/default - source/rule-book/reg-xi/r1113.pdf.

10. California Air Pollution Control Officers Association (CAPCOA). California Emissions Estimator Model (CalEEMod). [Online] May 2022. www.caleemod.com.

11. State of California. 2020 CEQA California Environmental Quality Act. 2020.

12. South Coast Air Quality Management District (SCAQMD). SCAQMD Air Quality Significance Thresholds. [Online] https://www.aqmd.gov/docs/default - source/ceqa/handbook/south-coast-aqmd-air-quality-significance- thresholds.pdf.

13. State of California. 2020 CEQA California Environmental Quality Act. 2020.

14. South Coast Air Quality Management District. Localized Significance Thresholds Methodology. s.l. : South Coast Air Quality Managment District, 2003.

15. —. Interim CEQA GHG Threshold for Stationary Sources, Rules and Plans. [Online] December 5, 2008. http://www.aqmd.gov/docs/default-
source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa-significance- thresholds/ghgboardsynopsis.pdf.

16. Pray, Richard. 2024 National Construction Estimator. Carlsbad : Craftsman Book Company, 2024.

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17. California Department of Transportation. EMFAC Software. [Online] http://www.dot.ca.gov/hq/env/air/pages/emfac.htm.

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ATTACHMENT A

CALEEMOD CONSTRUCTION EMISSIONS MODEL OUTPUTS

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Table of Contents

1. Basic Project Information

1.1. Basic Project Information

1.2. Land Use Types

1.3. User-Selected Emission Reduction Measures by Emissions Sector

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds

2.2. Construction Emissions by Y ear, Unmitigated

3. Construction Emissions Details

3.1. Linear, Grubbing & Land Clearing (2026) - Unmitigated

3.3. Linear, Grading & Excavation (2026) - Unmitigated

3.5. Linear, Drainage, Utilities, & Sub-Grade (2026) - Unmitigated

3.7. Linear, Drainage, Utilities, & Sub-Grade (2027) - Unmitigated

3.9. Linear, Drainage, Utilities, & Sub-Grade (2027) - Unmitigated

3.11. Linear, Drainage, Utilities, & Sub-Grade (2027) - Unmitigated EXHIBIT 4
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3.13. Linear, Drainage, Utilities, & Sub-Grade (2028) - Unmitigated

4. Operations Emissions Details

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated

5. Activity Data

5.1. Construction Schedule

5.2. Off-Road Equipment

5.2.1. Unmitigated

5.3. Construction Vehicles

5.3.1. Unmitigated

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies

5.5. Architectural Coatings

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities
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5.6.2. Construction Earthmoving Control Strategies

5.7. Construction Paving

5.8. Construction Electricity Consumption and Emissions Factors

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated

5.18.2. Sequestration

5.18.2.1. Unmitigated

6. Climate Risk Detailed Report

6.1. Climate Risk Summary

6.2. Initial Climate Risk Scores

6.3. Adjusted Climate Risk Scores

6.4. Climate Risk Reduction Measures

7. Health and Equity Details

7.1. CalEnviroScreen 4.0 Scores
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7.2. Healthy Places Index Scores

7.3. Overall Health & Equity Scores

7.4. Health & Equity Measures

7.5. Evaluation Scorecard

7.6. Health & Equity Custom Measures

8. User Changes to Default Data
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1. Basic Project Information

1.1. Basic Project Information
Data Field Value
Project Name 14238-Garden River Bridge
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 2.50
Precipitation (days) 20.2
Location 34.155999, -118.28119
County Los Angeles-South Coast
City Los Angeles
Air District South Coast AQMD
Air Basin South Coast
TAZ 3974
EDFZ 17
Electric Utility Los Angeles Department of Water & Power Gas Utility Southern California Gas

1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq ft)
Special Landscape
Area
(sq ft)
Population Description
Bridge/Overpass
Constr
uction

0.06 Mile 2.94 0.00 — — — —
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1.3. User-Selected Emission Reduction Measures by Emissions Sector No measures selected

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 3.39 2.86 20.5 27.8 0.07 0.71 0.79 1.50 0.65 0.19 0.84 — 8,160 8,160 0.33 0.09 2.83 8,199 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 1.64 1.39 9.55 13.5 0.03 0.36 0.52 0.78 0.33 0.12 0.39 — 3,907 3,907 0.16 0.05 0.05 3,923 Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 1.66 1.40 8.98 12.6 0.03 0.33 0.37 0.68 0.30 0.09 0.39 — 4,087 4,087 0.16 0.04 0.58 4,104 Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 0.30 0.25 1.64 2.31 0.01 0.06 0.07 0.12 0.06 0.02 0.07 — 677 677 0.03 0.01 0.10 679

2.2. Construction Emissions by Y ear, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Y ear TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily -
Summer
(Max)
— — — — — — — — — — — — — — — — — —
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2026 3.39 2.86 20.5 27.8 0.07 0.71 0.79 1.50 0.65 0.19 0.84 — 8,160 8,160 0.33 0.09 2.83 8,199 2027 3.23 2.72 16.5 21.6 0.07 0.61 0.78 1.40 0.56 0.18 0.75 — 8,110 8,110 0.33 0.09 2.48 8,147 Daily -
Winter
(Max)
— — — — — — — — — — — — — — — — — —
2026 1.64 1.39 9.55 13.5 0.03 0.33 0.52 0.78 0.31 0.12 0.37 — 3,907 3,907 0.16 0.05 0.05 3,923 2027 1.63 1.37 9.21 13.5 0.03 0.36 0.26 0.62 0.33 0.06 0.39 — 3,901 3,901 0.15 0.04 0.02 3,916 2028 1.44 1.21 8.33 10.0 0.03 0.33 0.26 0.59 0.30 0.06 0.36 — 3,563 3,563 0.14 0.04 0.02 3,577 Average
Daily
— — — — — — — — — — — — — — — — — —
2026 1.55 1.31 8.98 12.6 0.03 0.30 0.37 0.68 0.28 0.09 0.37 — 3,752 3,752 0.15 0.04 0.58 3,769 2027 1.66 1.40 8.94 11.5 0.03 0.33 0.35 0.68 0.30 0.08 0.39 — 4,087 4,087 0.16 0.04 0.49 4,104 2028 0.26 0.22 1.48 1.79 0.01 0.06 0.05 0.10 0.05 0.01 0.06 — 635 635 0.02 0.01 0.06 638 Annual — — — — — — — — — — — — — — — — — —
2026 0.28 0.24 1.64 2.31 0.01 0.06 0.07 0.12 0.05 0.02 0.07 — 621 621 0.03 0.01 0.10 624 2027 0.30 0.25 1.63 2.11 0.01 0.06 0.06 0.12 0.06 0.02 0.07 — 677 677 0.03 0.01 0.08 679 2028 0.05 0.04 0.27 0.33 < 0.005 0.01 0.01 0.02 0.01 < 0.005 0.01 — 105 105 < 0.005 < 0.005 0.01 106

3. Construction Emissions Details

3.1. Linear, Grubbing & Land Clearing (2026) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

1.39 1.17 7.94 10.4 0.03 0.26 — 0.26 0.24 — 0.24 — 3,335 3,335 0.14 0.03 — 3,346 EXHIBIT 4
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Dust
F
rom
Material
Movement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

1.39 1.17 7.94 10.4 0.03 0.26 — 0.26 0.24 — 0.24 — 3,335 3,335 0.14 0.03 — 3,346 Dust
F
rom
Material
Movement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.37 0.31 2.11 2.75 0.01 0.07 — 0.07 0.06 — 0.06 — 886 886 0.04 0.01 — 889 Dust
F
rom
Material
Movement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.07 0.06 0.39 0.50 < 0.005 0.01 — 0.01 0.01 — 0.01 — 147 147 0.01 < 0.005 — 147 Dust
F
rom
Material
Movement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 EXHIBIT 4
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Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.17 0.15 0.16 2.58 0.00 0.00 0.03 0.03 0.00 0.00 0.00 — 542 542 0.02 0.02 1.83 550 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.17 0.15 0.17 2.20 0.00 0.00 0.03 0.03 0.00 0.00 0.00 — 514 514 0.02 0.02 0.05 520 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.04 0.04 0.05 0.61 0.00 0.00 0.01 0.01 0.00 0.00 0.00 — 139 139 0.01 0.01 0.21 140 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.01 0.11 0.00 0.00 < 0.005 < 0.005 0.00 0.00 0.00 — 22.9 22.9 < 0.005 < 0.005 0.03 23.2 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.3. Linear, Grading & Excavation (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
EXHIBIT 4
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Off-Road
Equipment

3.14 2.64 20.2 23.9 0.07 0.71 — 0.71 0.65 — 0.65 — 7,316 7,316 0.30 0.06 — 7,341 Dust
F
rom
Material
Movement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.73 0.61 4.71 5.56 0.02 0.16 — 0.16 0.15 — 0.15 — 1,704 1,704 0.07 0.01 — 1,710 Dust
F
rom
Material
Movement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.13 0.11 0.86 1.02 < 0.005 0.03 — 0.03 0.03 — 0.03 — 282 282 0.01 < 0.005 — 283 Dust
F
rom
Material
Movement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.25 0.22 0.23 3.88 0.00 0.00 0.05 0.05 0.00 0.00 0.00 — 813 813 0.03 0.03 2.75 825 EXHIBIT 4
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Vendor < 0.005 < 0.005 0.03 0.02 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 31.2 31.2 < 0.005 < 0.005 0.08 32.6 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.06 0.05 0.07 0.81 0.00 0.00 0.01 0.01 0.00 0.00 0.00 — 182 182 0.01 0.01 0.28 185 Vendor < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 7.26 7.26 < 0.005 < 0.005 0.01 7.59 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.01 0.15 0.00 0.00 < 0.005 < 0.005 0.00 0.00 0.00 — 30.2 30.2 < 0.005 < 0.005 0.05 30.6 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.20 1.20 < 0.005 < 0.005 < 0.005 1.26 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.5. Linear, Drainage, Utilities, & Sub-Grade (2026) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

1.56 1.31 9.46 12.4 0.03 0.33 — 0.33 0.31 — 0.31 — 3,650 3,650 0.15 0.03 — 3,663 Dust
F
rom
Material
Movement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 EXHIBIT 4
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——————————————————Daily,
Winter
(Max)
Off-Road
Equipment

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.33 0.28 2.02 2.65 0.01 0.07 — 0.07 0.07 — 0.07 — 779 779 0.03 0.01 — 781 Dust
F
rom
Material
Movement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.06 0.05 0.37 0.48 < 0.005 0.01 — 0.01 0.01 — 0.01 — 129 129 0.01 < 0.005 — 129 Dust
F
rom
Material
Movement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.08 0.07 0.08 1.29 0.00 0.00 0.02 0.02 0.00 0.00 0.00 — 271 271 0.01 0.01 0.92 275 EXHIBIT 4
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Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.08 0.07 0.09 1.10 0.00 0.00 0.02 0.02 0.00 0.00 0.00 — 257 257 0.01 0.01 0.02 260 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.02 0.02 0.02 0.25 0.00 0.00 < 0.005 < 0.005 0.00 0.00 0.00 — 55.6 55.6 < 0.005 < 0.005 0.08 56.4 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.04 0.00 0.00 < 0.005 < 0.005 0.00 0.00 0.00 — 9.21 9.21 < 0.005 < 0.005 0.01 9.33 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.7. Linear, Drainage, Utilities, & Sub-Grade (2027) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

1.55 1.30 9.12 12.4 0.03 0.31 — 0.31 0.29 — 0.29 — 3,649 3,649 0.15 0.03 — 3,661 EXHIBIT 4
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———————0.000.00—0.000.00——————Dust
F
rom
Material
Movement
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

1.55 1.30 9.12 12.4 0.03 0.31 — 0.31 0.29 — 0.29 — 3,649 3,649 0.15 0.03 — 3,661 Dust
F
rom
Material
Movement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.32 0.27 1.89 2.58 0.01 0.06 — 0.06 0.06 — 0.06 — 757 757 0.03 0.01 — 759 Dust
F
rom
Material
Movement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.06 0.05 0.35 0.47 < 0.005 0.01 — 0.01 0.01 — 0.01 — 125 125 0.01 < 0.005 — 126 Dust
F
rom
Material
Movement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 EXHIBIT 4
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Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.08 0.07 0.07 1.20 0.00 0.00 0.02 0.02 0.00 0.00 0.00 — 266 266 0.01 0.01 0.83 270 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.08 0.07 0.09 1.02 0.00 0.00 0.02 0.02 0.00 0.00 0.00 — 252 252 < 0.005 0.01 0.02 255 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.02 0.01 0.02 0.22 0.00 0.00 < 0.005 < 0.005 0.00 0.00 0.00 — 53.0 53.0 < 0.005 < 0.005 0.07 53.7 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.04 0.00 0.00 < 0.005 < 0.005 0.00 0.00 0.00 — 8.78 8.78 < 0.005 < 0.005 0.01 8.89 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.9. Linear, Drainage, Utilities, & Sub-Grade (2027) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
EXHIBIT 4
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Off-Road
Equipment

2.99 2.51 16.3 18.0 0.07 0.61 — 0.61 0.56 — 0.56 — 7,313 7,313 0.30 0.06 — 7,338 Dust
F
rom
Material
Movement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
tr
uck

0.97 0.82 5.31 5.87 0.02 0.20 — 0.20 0.18 — 0.18 — 2,384 2,384 0.10 0.02 — 2,392 Dust
F
rom
Material
Movement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.18 0.15 0.97 1.07 < 0.005 0.04 — 0.04 0.03 — 0.03 — 395 395 0.02 < 0.005 — 396 Dust
F
rom
Material
Movement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.24 0.21 0.21 3.60 0.00 0.00 0.05 0.05 0.00 0.00 0.00 — 797 797 0.03 0.03 2.48 809 EXHIBIT 4
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Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.08 0.07 0.08 1.05 0.00 0.00 0.02 0.02 0.00 0.00 0.00 — 250 250 < 0.005 0.01 0.35 253 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.02 0.19 0.00 0.00 < 0.005 < 0.005 0.00 0.00 0.00 — 41.4 41.4 < 0.005 < 0.005 0.06 41.9 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.11. Linear, Drainage, Utilities, & Sub-Grade (2027) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

1.40 1.18 8.99 9.08 0.03 0.36 — 0.36 0.33 — 0.33 — 3,313 3,313 0.13 0.03 — 3,325 Dust
F
rom
Material
Movement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
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Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.25 0.21 1.62 1.64 0.01 0.06 — 0.06 0.06 — 0.06 — 597 597 0.02 < 0.005 — 599 Dust
F
rom
Material
Movement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.05 0.04 0.30 0.30 < 0.005 0.01 — 0.01 0.01 — 0.01 — 98.8 98.8 < 0.005 < 0.005 — 99.1 Dust
F
rom
Material
Movement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
tr
uck

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Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.04 0.00 0.00 < 0.005 < 0.005 0.00 0.00 0.00 — 7.62 7.62 < 0.005 < 0.005 0.01 7.72 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.13. Linear, Drainage, Utilities, & Sub-Grade (2028) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

1.36 1.14 8.25 9.06 0.03 0.33 — 0.33 0.30 — 0.30 — 3,315 3,315 0.13 0.03 — 3,326 Dust
F
rom
Material
Movement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.24 0.20 1.47 1.61 0.01 0.06 — 0.06 0.05 — 0.05 — 590 590 0.02 < 0.005 — 592 EXHIBIT 4
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———————0.000.00—0.000.00——————Dust
F
rom
Material
Movement
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.04 0.04 0.27 0.29 < 0.005 0.01 — 0.01 0.01 — 0.01 — 97.7 97.7 < 0.005 < 0.005 — 98.1 Dust
F
rom
Material
Movement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.08 0.07 0.08 0.96 0.00 0.00 0.02 0.02 0.00 0.00 0.00 — 247 247 < 0.005 0.01 0.02 250 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.01 0.18 0.00 0.00 < 0.005 < 0.005 0.00 0.00 0.00 — 44.7 44.7 < 0.005 < 0.005 0.06 45.3 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.03 0.00 0.00 < 0.005 < 0.005 0.00 0.00 0.00 — 7.40 7.40 < 0.005 < 0.005 0.01 7.50 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 EXHIBIT 4
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Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

4. Operations Emissions Details

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetatio
n
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

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——————————————————Daily,
Winter
(Max)
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
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——————————————————Remove
d
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —

5. Activity Data

5.1. Construction Schedule
Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description Phase 1: North Abutment &
Approaches
Linear, Grubbing & Land
Clear
ing
1/1/2026 5/15/2026 5.00 97.0 —
Phase 2: Bridge
Substr
ucture (Bent
Construction)
Linear, Grading &
Exca
vation
5/18/2026 9/11/2026 5.00 85.0 —
Phase 3: South Abutment &
Approaches
Linear, Drainage, Utilities, &
Sub-Gr
ade
9/14/2026 4/16/2027 5.00 155 —
Phase 4: Bridge
Superstr
ucture
Linear, Drainage, Utilities, &
Sub-Gr
ade
4/17/2027 9/30/2027 5.00 119 —
Phase 5: Architectural
Elements /
Landscaping
Linear, Drainage, Utilities, &
Sub-Gr
ade
10/1/2027 3/31/2028 5.00 131 —
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5.2. Off-Road Equipment

5.2.1. Unmitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Phase 1: North
Ab
utment &
Approaches
Bore/Drill Rigs Diesel Average 1.00 8.00 83.0 0.50
Phase 1: North
Ab
utment &
Approaches
Excavators Diesel Average 2.00 8.00 36.0 0.38
Phase 1: North
Ab
utment &
Approaches
Off-Highway Trucks Diesel Average 2.00 8.00 376 0.38
Phase 2: Bridge
Substr
ucture (Bent
Construction)
Bore/Drill Rigs Diesel Average 2.00 8.00 83.0 0.50
Phase 2: Bridge
Substr
ucture (Bent
Construction)
Excavators Diesel Average 4.00 8.00 36.0 0.38
Phase 2: Bridge
Substr
ucture (Bent
Construction)
Cranes Diesel Average 2.00 8.00 367 0.29
Phase 2: Bridge
Substr
ucture (Bent
Construction)
Off-Highway Trucks Diesel Average 3.00 8.00 376 0.38
Phase 3: South
Ab
utment &
Approaches
Bore/Drill Rigs Diesel Average 1.00 8.00 83.0 0.50
Phase 3: South
Ab
utment &
Approaches
Excavators Diesel Average 2.00 8.00 36.0 0.38
Phase 3: South
Ab
utment &
Approaches
Off-Highway Trucks Diesel Average 2.00 8.00 376 0.38
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0.4281.08.001.00AverageDieselPaversPhase 3: South
Abutment &
Approaches
Phase 4: Bridge
Superstr
ucture
Cranes Diesel Average 2.00 8.00 367 0.29
Phase 4: Bridge
Superstr
ucture
Off-Highway Trucks Diesel Average 4.00 8.00 376 0.38
Phase 5: Architectural
Elements /
Landscaping
Cranes Diesel Average 2.00 8.00 367 0.29
Phase 5: Architectural
Elements /
Landscaping
Off-Highway Trucks Diesel Average 1.00 8.00 376 0.38

5.3. Construction Vehicles

5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Phase 1: North Abutment &
Approaches
— — — —
Phase 1: North Abutment &
Approaches
Worker 40.0 18.5 LDA,LDT1,LDT2
Phase 1: North Abutment &
Approaches
Vendor — 10.2 HHDT,MHDT
Phase 1: North Abutment &
Approaches
Hauling 0.00 20.0 HHDT
Phase 1: North Abutment &
Approaches
Onsite truck — — HHDT
Phase 2: Bridge Substructure (Bent
Constr
uction)
— — — —
Phase 2: Bridge Substructure (Bent
Constr
uction)
Worker 60.0 18.5 LDA,LDT1,LDT2
Phase 2: Bridge Substructure (Bent
Constr
uction)
Vendor 1.00 10.2 HHDT,MHDT
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HHDT20.00.00HaulingPhase 2: Bridge Substructure (Bent
Construction)
Phase 2: Bridge Substructure (Bent
Constr
uction)
Onsite truck — — HHDT
Phase 3: South Abutment &
Approaches
— — — —
Phase 3: South Abutment &
Approaches
Worker 20.0 18.5 LDA,LDT1,LDT2
Phase 3: South Abutment &
Approaches
Vendor — 10.2 HHDT,MHDT
Phase 3: South Abutment &
Approaches
Hauling 0.00 20.0 HHDT
Phase 3: South Abutment &
Approaches
Onsite truck — — HHDT
Phase 4: Bridge Superstructure — — — —
Phase 4: Bridge Superstructure Worker 60.0 18.5 LDA,LDT1,LDT2 Phase 4: Bridge Superstructure Vendor — 10.2 HHDT,MHDT
Phase 4: Bridge Superstructure Hauling 0.00 20.0 HHDT
Phase 4: Bridge Superstructure Onsite truck — — HHDT
Phase 5: Architectural Elements /
Landscaping
— — — —
Phase 5: Architectural Elements /
Landscaping
Worker 20.0 18.5 LDA,LDT1,LDT2
Phase 5: Architectural Elements /
Landscaping
Vendor — 10.2 HHDT,MHDT
Phase 5: Architectural Elements /
Landscaping
Hauling 0.00 20.0 HHDT
Phase 5: Architectural Elements /
Landscaping
Onsite truck — — HHDT

5.4. Vehicles
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5.4.1. Construction Vehicle Control Strategies
Non-applicable. No control strategies activated by user.

5.5. Architectural Coatings
Phase Name Residential Interior Area Coated
(sq
ft)
Residential Exterior Area Coated
(sq
ft)
Non-Residential Interior Area
Coated
(sq ft)
Non-Residential Exterior Area
Coated
(sq ft)
Parking Area Coated (sq ft)

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (cy) Material Exported (cy) Acres Graded (acres) Material Demolished (sq. ft.) Acres Paved (acres) Phase 1: North Abutment &
Approaches
— — 2.94 0.00 —
Phase 2: Bridge Substructure
(Bent
Construction)
— — 2.94 0.00 —
Phase 3: South Abutment &
Approaches
— — 2.94 0.00 —
Phase 4: Bridge Superstructure — — 2.94 0.00 —
Phase 5: Architectural
Elements /
Landscaping
— — 2.94 0.00 —

5.6.2. Construction Earthmoving Control Strategies
Non-applicable. No control strategies activated by user.

5.7. Construction Paving
Land Use Area Paved (acres) % Asphalt
Bridge/Overpass Construction 2.00 100%

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kWh per Y ear and Emission Factor (lb/MWh)
Y ear kWh per Y ear CO2 CH4 N2O
2026 0.00 690 0.05 0.01
2027 0.00 690 0.05 0.01
2028 0.00 690 0.05 0.01

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres

5.18.2. Sequestration

5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)

6. Climate Risk Detailed Report

6.1. Climate Risk Summary
Cal-Adapt midcentury 2040–2059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 which assumes GHG emissions
will continue to rise strongly through 2050 and then plateau around 2100.

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Climate Hazard Result for Project Location Unit
Temperature and Extreme Heat 11.7 annual days of extreme heat Extreme Precipitation 6.75 annual days with precipitation above 20 mm Sea Level Rise 0.00 meters of inundation depth
Wildfire 0.00 annual hectares burned
Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed histor
ical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall if received over a full da
y or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider different increments
of sea level rise coupled with extreme storm events. Users may select from four model simulations to view the range in potential inundation depth for the grid cell. The four simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature possibilities (MIROC5). Each grid cell is 50 meters (m) by 50 m, or about 164 feet (ft) by 164 ft.

Wildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider historical data of climate, v
egetation, population density, and large (> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. The four simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

6.2. Initial Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat 1 0 0 N/A
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise 1 0 0 N/A
Wildfire 1 0 0 N/A
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation 0 0 0 N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest e
xposure.

The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the g
reatest ability to adapt.

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The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reduction measures.

6.3. Adjusted Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat 1 1 1 2
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise 1 1 1 2
Wildfire 1 1 1 2
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation 1 1 1 2
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest e
xposure.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reduction measures.

6.4. Climate Risk Reduction Measures

7. Health and Equity Details

7.1. CalEnviroScreen 4.0 Scores
The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.

Indicator Result for Project Census Tract
Exposure Indicators —
AQ-Ozone 69.6
AQ-PM 65.9
AQ-DPM 47.5
Drinking Water 92.5
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Lead Risk Housing —
Pesticides 0.00
Toxic Releases 70.0
Traffic 99.5
Effect Indicators —
CleanUp Sites 94.3
Groundwater 36.9
Haz Waste Facilities/Generators 47.6
Impaired Water Bodies 77.3
Solid Waste 89.9
Sensitive Population —
Asthma 8.92
Cardio-vascular 23.8
Low Birth Weights —
Socioeconomic Factor Indicators —
Education —
Housing —
Linguistic —
Poverty —
Unemployment —

7.2. Healthy Places Index Scores
The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.

Indicator Result for Project Census Tract
Economic —
Above Poverty —
Employed —
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Median HI —
Education —
Bachelor's or higher —
High school enrollment —
Preschool enrollment —
Transportation —
Auto Access —
Active commuting —
Social —
2-parent households —
Voting —
Neighborhood —
Alcohol availability —
Park access —
Retail density —
Supermarket access —
Tree canopy —
Housing —
Homeownership —
Housing habitability —
Low-inc homeowner severe housing cost burden —
Low-inc renter severe housing cost burden —
Uncrowded housing —
Health Outcomes —
Insured adults —
Arthritis 0.0
Asthma ER Admissions 87.3
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High Blood Pressure 0.0
Cancer (excluding skin) 0.0
Asthma 0.0
Coronary Heart Disease 0.0
Chronic Obstructive Pulmonary Disease 0.0
Diagnosed Diabetes 0.0
Life Expectancy at Birth 0.0
Cognitively Disabled 99.8
Physically Disabled 99.8
Heart Attack ER Admissions 79.0
Mental Health Not Good 0.0
Chronic Kidney Disease 0.0
Obesity 0.0
Pedestrian Injuries 0.0
Physical Health Not Good 0.0
Stroke 0.0
Health Risk Behaviors —
Binge Drinking 0.0
Current Smoker 0.0
No Leisure Time for Physical Activity 0.0
Climate Change Exposures —
Wildfire Risk 100.0
SLR Inundation Area 0.0
Children 99.4
Elderly 99.8
English Speaking 0.0
Foreign-born 0.0
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Outdoor Workers 98.2
Climate Change Adaptive Capacity —
Impervious Surface Cover 97.9
Traffic Density 0.0
Traffic Access 23.0
Other Indices —
Hardship 0.0
Other Decision Support —
2016 Voting 0.0

7.3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a) —
Healthy Places Index Score for Project Location (b) —
Project Located in a Designated Disadvantaged Community (Senate Bill 535) Y es Project Located in a Low-Income Community (Assembly Bill 1550) No Project Located in a Community Air Protection Program Community (Assembly Bill 617) No a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.

7.4. Health & Equity Measures
No Health & Equity Measures selected.

7.5. Evaluation Scorecard
Health & Equity Evaluation Scorecard not completed.

7.6. Health & Equity Custom Measures
No Health & Equity Custom Measures created.

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8. User Changes to Default Data
Screen Justification
Construction: Construction Phases Taken from site plan
Construction: Off-Road Equipment Construction equipment provided by Project applicant Standard
8-hour working day
Off-Highway Trucks represent "Concrete Trucks"
Construction: Dust From Material Movement Emissions accounted only for grading Construction: Trips and VMT Client provided vendor trips per phase.

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14238-06 AQ, GHG & EA Assessment

ATTACHMENT B

CALEEMOD OPERATIONAL EMISSIONS MODEL OUTPUTS

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14238 - Garden River Bridge (Operations) Detailed Report Table of Contents

1. Basic Project Information

1.1. Basic Project Information

1.2. Land Use Types

1.3. User-Selected Emission Reduction Measures by Emissions Sector

2. Emissions Summary

2.4. Operations Emissions Compared Against Thresholds

2.5. Operations Emissions by Sector, Unmitigated

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated

4.2.3. Natural Gas Emissions By Land Use - Unmitigated

4.3. Area Emissions by Source
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4.3.1. Unmitigated

4.4. Water Emissions by Land Use

4.4.1. Unmitigated

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated

4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated

4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated EXHIBIT 4
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5. Activity Data

5.9. Operational Mobile Sources

5.9.1. Unmitigated

5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated

5.10.2. Architectural Coatings

5.10.3. Landscape Equipment

5.11. Operational Energy Consumption

5.11.1. Unmitigated

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated

5.13. Operational Waste Generation

5.13.1. Unmitigated

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated

5.15. Operational Off-Road Equipment
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5.15.1. Unmitigated

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps

5.16.2. Process Boilers

5.17. User Defined

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated

5.18.2. Sequestration

5.18.2.1. Unmitigated

6. Climate Risk Detailed Report

6.1. Climate Risk Summary

6.2. Initial Climate Risk Scores

6.3. Adjusted Climate Risk Scores

6.4. Climate Risk Reduction Measures
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7. Health and Equity Details

7.1. CalEnviroScreen 4.0 Scores

7.2. Healthy Places Index Scores

7.3. Overall Health & Equity Scores

7.4. Health & Equity Measures

7.5. Evaluation Scorecard

7.6. Health & Equity Custom Measures

8. User Changes to Default Data
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1. Basic Project Information

1.1. Basic Project Information
Data Field Value
Project Name 14238 - Garden River Bridge (Operations)
Operational Y ear 2028
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 2.50
Precipitation (days) 20.2
Location 34.155999, -118.28119
County Los Angeles-South Coast
City Los Angeles
Air District South Coast AQMD
Air Basin South Coast
TAZ 3974
EDFZ 17
Electric Utility Los Angeles Department of Water & Power Gas Utility Southern California Gas
App Version 2022.1.1.23

1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq ft)
Special Landscape
Area
(sq ft)
Population Description
User Defined
Recreational

1.00 User Defined Unit 0.00 0.00 0.00 — — —
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1.3. User-Selected Emission Reduction Measures by Emissions Sector No measures selected

2. Emissions Summary

2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 0.12 0.10 0.09 1.19 < 0.005 < 0.005 0.31 0.31 < 0.005 0.08 0.08 0.00 327 327 0.01 0.01 0.91 331 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 0.11 0.10 0.10 1.07 < 0.005 < 0.005 0.31 0.31 < 0.005 0.08 0.08 0.00 313 313 0.01 0.01 0.02 317 Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 0.11 0.10 0.11 1.10 < 0.005 < 0.005 0.30 0.31 < 0.005 0.08 0.08 0.00 317 317 0.01 0.01 0.40 321 Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 0.02 0.02 0.02 0.20 < 0.005 < 0.005 0.06 0.06 < 0.005 0.01 0.01 0.00 52.5 52.5 < 0.005 < 0.005 0.07 53.2

2.5. Operations Emissions by Sector, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
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Mobile 0.12 0.10 0.09 1.19 < 0.005 < 0.005 0.31 0.31 < 0.005 0.08 0.08 — 327 327 0.01 0.01 0.91 331 Area 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Energy 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Water — — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00 Waste — — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00 Total 0.12 0.10 0.09 1.19 < 0.005 < 0.005 0.31 0.31 < 0.005 0.08 0.08 0.00 327 327 0.01 0.01 0.91 331 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 0.11 0.10 0.10 1.07 < 0.005 < 0.005 0.31 0.31 < 0.005 0.08 0.08 — 313 313 0.01 0.01 0.02 317 Area — 0.00 — — — — — — — — — — — — — — — —
Energy 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Water — — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00 Waste — — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00 Total 0.11 0.10 0.10 1.07 < 0.005 < 0.005 0.31 0.31 < 0.005 0.08 0.08 0.00 313 313 0.01 0.01 0.02 317 Average
Daily
— — — — — — — — — — — — — — — — — —
Mobile 0.11 0.10 0.11 1.10 < 0.005 < 0.005 0.30 0.31 < 0.005 0.08 0.08 — 317 317 0.01 0.01 0.40 321 Area 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Energy 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Water — — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00 Waste — — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00 Total 0.11 0.10 0.11 1.10 < 0.005 < 0.005 0.30 0.31 < 0.005 0.08 0.08 0.00 317 317 0.01 0.01 0.40 321 Annual — — — — — — — — — — — — — — — — — —
Mobile 0.02 0.02 0.02 0.20 < 0.005 < 0.005 0.06 0.06 < 0.005 0.01 0.01 — 52.5 52.5 < 0.005 < 0.005 0.07 53.2 Area 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Energy 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Water — — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00 Waste — — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00 EXHIBIT 4
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Total 0.02 0.02 0.02 0.20 < 0.005 < 0.005 0.06 0.06 < 0.005 0.01 0.01 0.00 52.5 52.5 < 0.005 < 0.005 0.07 53.2

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
User
Defined
Recreational

0.12 0.10 0.09 1.19 < 0.005 < 0.005 0.31 0.31 < 0.005 0.08 0.08 — 327 327 0.01 0.01 0.91 331 Total 0.12 0.10 0.09 1.19 < 0.005 < 0.005 0.31 0.31 < 0.005 0.08 0.08 — 327 327 0.01 0.01 0.91 331 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
User
Defined
Recreational

0.11 0.10 0.10 1.07 < 0.005 < 0.005 0.31 0.31 < 0.005 0.08 0.08 — 313 313 0.01 0.01 0.02 317 Total 0.11 0.10 0.10 1.07 < 0.005 < 0.005 0.31 0.31 < 0.005 0.08 0.08 — 313 313 0.01 0.01 0.02 317 Annual — — — — — — — — — — — — — — — — — —
User
Defined
Recreational

0.02 0.02 0.02 0.20 < 0.005 < 0.005 0.06 0.06 < 0.005 0.01 0.01 — 52.5 52.5 < 0.005 < 0.005 0.07 53.2 Total 0.02 0.02 0.02 0.20 < 0.005 < 0.005 0.06 0.06 < 0.005 0.01 0.01 — 52.5 52.5 < 0.005 < 0.005 0.07 53.2

4.2. Energy
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4.2.1. Electricity Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
User
Defined
Recreational
— — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
User
Defined
Recreational
— — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00 Annual — — — — — — — — — — — — — — — — — —
User
Defined
Recreational
— — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00

4.2.3. Natural Gas Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
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0.00—0.000.000.000.00—0.00—0.000.00—0.000.000.000.000.000.00User Defined
Recreational
Total 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
User
Defined
Recreational

0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Total 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Annual — — — — — — — — — — — — — — — — — —
User
Defined
Recreational

0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Total 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00

4.3. Area Emissions by Source

4.3.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Source TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Consum
er
Products
— 0.00 — — — — — — — — — — — — — — — —
Architect
ur
al
Coatings
— 0.00 — — — — — — — — — — — — — — — —
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0.00—0.000.000.000.00—0.00—0.000.00—0.000.000.000.000.000.00Landsca pe
Equipme
Total 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Consum
er
Products
— 0.00 — — — — — — — — — — — — — — — —
Architect
ur
al
Coatings
— 0.00 — — — — — — — — — — — — — — — —
Total — 0.00 — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Consum
er
Products
— 0.00 — — — — — — — — — — — — — — — —
Architect
ur
al
Coatings
— 0.00 — — — — — — — — — — — — — — — —
Landsca
pe
Equipme
nt

0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Total 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00

4.4. Water Emissions by Land Use

4.4.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e EXHIBIT 4
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Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
User
Defined
Recreational
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
User
Defined
Recreational
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00 Annual — — — — — — — — — — — — — — — — — —
User
Defined
Recreational
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
User
Defined
Recreational
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00 EXHIBIT 4
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Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
User
Defined
Recreational
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00 Annual — — — — — — — — — — — — — — — — — —
User
Defined
Recreational
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.7. Offroad Emissions By Equipment Type
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4.7.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme
nt
T
ype
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme
nt
T
ype
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
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Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme
nt
T
ype
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10. Soil Carbon Accumulation By Vegetation Type

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Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

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Sequest — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
EXHIBIT 4
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5. Activity Data

5.9. Operational Mobile Sources

5.9.1. Unmitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Y ear VMT/Weekday VMT/Saturday VMT/Sunday VMT/Y ear User Defined
Recreational

29.0 29.0 29.0 10,585 435 435 435 158,775

5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated

5.10.2. Architectural Coatings
Residential Interior Area Coated (sq ft) Residential Exterior Area Coated (sq ft) Non-Residential Interior Area Coated (sq
ft)
Non-Residential Exterior Area Coated
(sq
ft)
Parking Area Coated (sq ft)
0 0.00 0.00 0.00 —

5.10.3. Landscape Equipment
Season Unit Value
Snow Days day/yr 0.00
Summer Days day/yr 250

5.11. Operational Energy Consumption

5.11.1. Unmitigated
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Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr) CO2 CH4 N2O Natural Gas (kBTU/yr) User Defined Recreational 0.00 690 0.0489 0.0069 0.00

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated
Land Use Indoor Water (gal/year) Outdoor Water (gal/year) User Defined Recreational 0.00 0.00

5.13. Operational Waste Generation

5.13.1. Unmitigated
Land Use Waste (ton/year) Cogeneration (kWh/year)
User Defined Recreational 0.00 —

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated
Land Use Type Equipment Type Refrigerant GWP Quantity (kg) Operations Leak Rate Service Leak Rate Times Serviced

5.15. Operational Off-Road Equipment

5.15.1. Unmitigated
Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor

5.16. Stationary Sources
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5.16.1. Emergency Generators and Fire Pumps
Equipment Type Fuel Type Number per Day Hours per Day Hours per Y ear Horsepower Load Factor

5.16.2. Process Boilers
Equipment Type Fuel Type Number Boiler Rating (MMBtu/hr) Daily Heat Input (MMBtu/day) Annual Heat Input (MMBtu/yr)

5.17. User Defined
Equipment Type Fuel Type

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres

5.18.2. Sequestration

5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year) EXHIBIT 4
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6. Climate Risk Detailed Report

Climate Hazard Result for Project Location Unit
Temperature and Extreme Heat 11.7 annual days of extreme heat Extreme Precipitation 6.75 annual days with precipitation above 20 mm Sea Level Rise — meters of inundation depth
Wildfire 0.00 annual hectares burned
Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed histor
ical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (Radke et al., 2017, CEC-500-2017-008), and consider in
undation location and depth for the San Francisco Bay, the Sacramento-San Joaquin River Delta and California coast resulting different increments of sea level rise coupled with extreme storm events.

Users may select from four scenarios to view the range in potential inundation depth for the grid cell. The four scenarios are: No rise, 0.5 meter, 1.0 meter, 1.41 meters Wildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider historical data of climate, v
egetation, population density, and large (> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. The four simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

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Air Quality Degradation 0 0 0 N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest e
xposure.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reduction measures.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reduction measures.

6.4. Climate Risk Reduction Measures

7. Health and Equity Details

7.1. CalEnviroScreen 4.0 Scores
The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.

Indicator Result for Project Census Tract
Exposure Indicators —
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AQ-Ozone 69.6
AQ-PM 65.9
AQ-DPM 47.5
Drinking Water 92.5
Lead Risk Housing —
Pesticides 0.00
Toxic Releases 70.0
Traffic 99.5
Effect Indicators —
CleanUp Sites 94.3
Groundwater 36.9
Haz Waste Facilities/Generators 47.6
Impaired Water Bodies 77.3
Solid Waste 89.9
Sensitive Population —
Asthma 8.92
Cardio-vascular 23.8
Low Birth Weights —
Socioeconomic Factor Indicators —
Education —
Housing —
Linguistic —
Poverty —
Unemployment —

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Indicator Result for Project Census Tract
Economic —
Above Poverty —
Employed —
Median HI —
Education —
Bachelor's or higher —
High school enrollment —
Preschool enrollment —
Transportation —
Auto Access —
Active commuting —
Social —
2-parent households —
Voting —
Neighborhood —
Alcohol availability —
Park access —
Retail density —
Supermarket access —
Tree canopy —
Housing —
Homeownership —
Housing habitability —
Low-inc homeowner severe housing cost burden —
Low-inc renter severe housing cost burden —
Uncrowded housing —
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Health Outcomes —
Insured adults —
Arthritis 0.0
Asthma ER Admissions 87.3
High Blood Pressure 0.0
Cancer (excluding skin) 0.0
Asthma 0.0
Coronary Heart Disease 0.0
Chronic Obstructive Pulmonary Disease 0.0
Diagnosed Diabetes 0.0
Life Expectancy at Birth 0.0
Cognitively Disabled 99.8
Physically Disabled 99.8
Heart Attack ER Admissions 79.0
Mental Health Not Good 0.0
Chronic Kidney Disease 0.0
Obesity 0.0
Pedestrian Injuries 0.0
Physical Health Not Good 0.0
Stroke 0.0
Health Risk Behaviors —
Binge Drinking 0.0
Current Smoker 0.0
No Leisure Time for Physical Activity 0.0
Climate Change Exposures —
Wildfire Risk 100.0
SLR Inundation Area 0.0
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Children 99.4
Elderly 99.8
English Speaking 0.0
Foreign-born 0.0
Outdoor Workers 98.2
Climate Change Adaptive Capacity —
Impervious Surface Cover 97.9
Traffic Density 0.0
Traffic Access 23.0
Other Indices —
Hardship 0.0
Other Decision Support —
2016 Voting 0.0

7.4. Health & Equity Measures
No Health & Equity Measures selected.

7.5. Evaluation Scorecard
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Health & Equity Evaluation Scorecard not completed.

7.6. Health & Equity Custom Measures
No Health & Equity Custom Measures created.

8. User Changes to Default Data
Screen Justification
Operations: Vehicle Data Per client data, the Project will include 29 daily trips and a 15 mile trip length.

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14238-06 AQ, GHG & EA Assessment

ATTACHMENT C
EMFAC2021
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Source: EMFAC2021 (v1.0.2) Emissions Inventory
Region Type: Sub-Area
Region: Los Angeles (SC)
Calendar Year: 2026
Season: Annual
Vehicle Classification: EMFAC2007 Categories
Units: miles/day for CVMT and EVMT, trips/day for Trips, kWh/day for Energy Consumption, tons/day for Emissions, 1000 gallons/day for Fuel Consumption Region
endar Yehicle Catego Model Year Speed Fuel Population Total VMT el_Consumption (1000 g Fuel_Consumption (gal) Total Fuel VMT Total VMT Miles per Gallon Vehicle Class Los Angeles (SC) 2026 HHDT Aggregate Aggregate Gasoline 31.71483174 2530.344681 0.595008255 595.008255 1164069.716 2530.344681 7277084.666 6.25 HHDT Los Angeles (SC) 2026 HHDT Aggregate Aggregate Diesel 55277.3799 6819808.694 1098.590287 1098590.287 6819808.694 Los Angeles (SC) 2026 HHDT Aggregate Aggregate Electricity 610.8824182 66680.90118 0 0 66680.90118 Los Angeles (SC) 2026 HHDT Aggregate Aggregate Natural Gas 6222.084708 388064.7258 64.88442099 64884.42099 388064.7258 Los Angeles (SC) 2026 LDA Aggregate Aggregate Gasoline 3219652.786 125598332.2 4156.999113 4156999.113 4242481.146 125598332.2 140494683.9 33.12 LDA Los Angeles (SC) 2026 LDA Aggregate Aggregate Diesel 7348.716503 212062.0866 5.149764542 5149.764542 212062.0866 Los Angeles (SC) 2026 LDA Aggregate Aggregate Electricity 209865.581 10019447.29 0 0 10019447.29 Los Angeles (SC) 2026 LDA Aggregate Aggregate Plug-in Hybrid 103430.6361 4664842.379 80.33226876 80332.26876 4664842.379 Los Angeles (SC) 2026 LDT1 Aggregate Aggregate Gasoline 303121.7183 10988219.26 436.9194811 436919.4811 437683.1643 10988219.26 11090768.71 25.34 LDT1 Los Angeles (SC) 2026 LDT1 Aggregate Aggregate Diesel 88.7979738 1718.50539 0.074204054 74.20405391 1718.50539 Los Angeles (SC) 2026 LDT1 Aggregate Aggregate Electricity 1265.851297 56656.04808 0 0 56656.04808 Los Angeles (SC) 2026 LDT1 Aggregate Aggregate Plug-in Hybrid 890.9485459 44174.8973 0.689479092 689.4790918 44174.8973 Los Angeles (SC) 2026 LDT2 Aggregate Aggregate Gasoline 1632990.627 66847121.76 2677.276355 2677276.355 2698876.906 66847121.76 68582011.91 25.41 LDT2 Los Angeles (SC) 2026 LDT2 Aggregate Aggregate Diesel 5437.834714 230831.6694 7.025538956 7025.538956 230831.6694 Los Angeles (SC) 2026 LDT2 Aggregate Aggregate Electricity 17319.28615 613691.4866 0 0 613691.4866 Los Angeles (SC) 2026 LDT2 Aggregate Aggregate Plug-in Hybrid 18786.14155 890366.9989 14.57501217 14575.01217 890366.9989 Los Angeles (SC) 2026 LHDT1 Aggregate Aggregate Gasoline 123929.2199 4960391.725 351.17062 351170.62 481998.3017 4960391.725 7842646.775 16.27 LHDT1 Los Angeles (SC) 2026 LHDT1 Aggregate Aggregate Diesel 61552.22012 2704306.099 130.8276817 130827.6817 2704306.099 Los Angeles (SC) 2026 LHDT1 Aggregate Aggregate Electricity 2671.099104 177948.9511 0 0 126318.5559 177948.9511 1956182.403 15.49 LHDT2 Los Angeles (SC) 2026 LHDT2 Aggregate Aggregate Gasoline 18802.30269 702537.4457 57.21721911 57217.21911 702537.4457 Los Angeles (SC) 2026 LHDT2 Aggregate Aggregate Diesel 28207.89186 1209848.539 69.10133677 69101.33677 24235.05076 1209848.539 1005181.469 41.48 MCY Los Angeles (SC) 2026 LHDT2 Aggregate Aggregate Electricity 691.3171043 43796.419 0 0 1829186.939 43796.419 38233993.02 20.90 MDV Los Angeles (SC) 2026 MCY Aggregate Aggregate Gasoline 153887.3138 1005181.469 24.23505076 24235.05076 1005181.469 Los Angeles (SC) 2026 MDV Aggregate Aggregate Gasoline 964398.5458 36646219.44 1803.349906 1803349.906 36646219.44 Los Angeles (SC) 2026 MDV Aggregate Aggregate Diesel 11199.92317 428851.9709 17.49813003 17498.13003 428851.9709 Los Angeles (SC) 2026 MDV Aggregate Aggregate Electricity 18645.2319 659895.0843 0 0 36235.25834 659895.0843 206291.2031 5.69 MH Los Angeles (SC) 2026 MDV Aggregate Aggregate Plug-in Hybrid 11391.54804 499026.5259 8.338902977 8338.902977 499026.5259 Los Angeles (SC) 2026 MH Aggregate Aggregate Gasoline 14307.03368 146047.5722 30.18050526 30180.50526 432346.7032 146047.5722 3398646.229 7.86 MHDT Los Angeles (SC) 2026 MH Aggregate Aggregate Diesel 5685.026918 60243.63088 6.054753085 6054.753085 60243.63088 Los Angeles (SC) 2026 MHDT Aggregate Aggregate Gasoline 14018.64483 760040.5963 144.2836857 144283.6857 760040.5963 Los Angeles (SC) 2026 MHDT Aggregate Aggregate Diesel 61381.38023 2536950.689 282.4978542 282497.8542 2536950.689 Los Angeles (SC) 2026 MHDT Aggregate Aggregate Electricity 1016.757423 56341.7981 0 0 51620.84435 56341.7981 320927.8184 6.22 OBUS Los Angeles (SC) 2026 MHDT Aggregate Aggregate Natural Gas 983.1551606 45313.1448 5.565163339 5565.163339 45313.1448 Los Angeles (SC) 2026 OBUS Aggregate Aggregate Gasoline 3466.029388 130669.0411 25.46693943 25466.93943 130669.0411 Los Angeles (SC) 2026 OBUS Aggregate Aggregate Diesel 2204.359751 167083.6645 23.79556615 23795.56615 20245.30514 167083.6645 133175.7822 6.58 SBUS Los Angeles (SC) 2026 OBUS Aggregate Aggregate Electricity 32.17174938 2316.377191 0 0 2316.377191 Los Angeles (SC) 2026 OBUS Aggregate Aggregate Natural Gas 358.9603738 20858.73557 2.358338765 2358.338765 20858.73557 Los Angeles (SC) 2026 SBUS Aggregate Aggregate Gasoline 1439.394428 63136.50277 6.985775097 6985.775097 63136.50277 Los Angeles (SC) 2026 SBUS Aggregate Aggregate Diesel 1484.919634 29449.64017 4.00274451 4002.74451 138225.3819 29449.64017 455208.2004 3.29 UBUS Los Angeles (SC) 2026 SBUS Aggregate Aggregate Electricity 43.7276656 1385.007139 0 0 1385.007139 Los Angeles (SC) 2026 SBUS Aggregate Aggregate Natural Gas 1619.758995 39204.63215 9.256785533 9256.785533 39204.63215 Los Angeles (SC) 2026 UBUS Aggregate Aggregate Gasoline 435.2433216 30711.79502 6.645484972 6645.484972 30711.79502 Los Angeles (SC) 2026 UBUS Aggregate Aggregate Diesel 6.30137858 935.3704801 0.161043189 161.0431889 935.3704801 Los Angeles (SC) 2026 UBUS Aggregate Aggregate Electricity 172.837956 17147.4887 0 0 17147.4887 Los Angeles (SC) 2026 UBUS Aggregate Aggregate Natural Gas 3794.807103 406413.5462 131.4188537 131418.8537 406413.5462 EXHIBIT 4
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The Garden River Bridge at the Los Angeles River
Cities of Glendale and Los Angeles, Los Angeles County, California Bi
ological Resources Assessment
Prepared for:

City of Glendale
Public Works Engineering Division
613 E. Broadway
Glendale, CA 91206
Prepared by:

Ruth Villalobos & Associates, Inc.
3602 Inland Empire Blvd, Ste C310
Ontario, CA 91764
Contact: Miranda Villalobos
909.245.1129 Office
909.241.7433 Mobile
February 2023
Updated: October, 2025
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CONTENTS

1.0 Introduction...........................................................................................................................1

1.1 Project Location .................................................................................................................1

1.2 Project Description ............................................................................................................4

2.0 Methods ................................................................................................................................5

2.1 Biological Resources Assessment ......................................................................................5

2.2 Jurisdictional Delineation ..................................................................................................6

3.0 Regulatory Framework ..........................................................................................................6

3.1 Federal Regulations ...........................................................................................................6 Clean Water Act (33 U.S.C. 1344 et seq.) ..................................................................................6 Federal Endangered Species Act ...............................................................................................7 Migratory Bird Treaty Act .........................................................................................................7 Fish and Wildlife Coordination Act of 1958, as amended, (16 U.S.C. 661 et seq.) ...................7 National Environmental Policy Act of 1969, as amended, (42 U.S.C. 4321 et seq.) .................7

3.2 State Regulations ...............................................................................................................7 California Endangered Species Act............................................................................................7 California Native Plant Society ..................................................................................................8 California Fish and Game Code .................................................................................................8 Regional Water Quality Control B oar d .....................................................................................8 Calif
ornia Department of Fish and Wild life ..............................................................................8

3.3 Local Regu lations ...............................................................................................................9 County of Los Angeles Oak Tree Preservation Ordinance ........................................................9 City of Los Angeles Tree Preservation Ordinance .....................................................................9 City of Glendale Indigenous Tree Ordinance ............................................................................9

4.0 Existing Conditions ................................................................................................................9

4.1 Surrounding Land Use Types .............................................................................................9

4.2 Topography And Soils ........................................................................................................9

5.0 Results ................................................................................................................................ 12 Site Conditions ........................................................................................................................... 12 Vegetation and Land Use Types ................................................................................................ 12 Wildlife....................................................................................................................................... 15 Wildlife Movement and Connectivity ........................................................................................ 15 EXHIBIT 5
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Federal and State Jurisdictional Resources ............................................................................... 15 Special-Status Species ............................................................................................................... 16 Protected Trees ......................................................................................................................... 17 Nesting Birds.............................................................................................................................. 17 Habitats of Concern ................................................................................................................... 17 Delineation Results Summary ................................................................................................... 19

6.0 Conclusions......................................................................................................................... 22 Impacts on Nesting Birds ........................................................................................................... 22 Impacts on Bat Species .............................................................................................................. 22 Impacts on Protected Trees ...................................................................................................... 22 Impacts on Jurisdictional Waters .............................................................................................. 22

7.0 References ...................................................................................................................... 26

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LIST OF FIGURES
Figure 1 – Regional Vicinity Map
Figure 2 – Site Vicinity Map
Figure 3 – Soils Map
Figure 4 – Vegetation/Land Use Types Map
Figure 5 – Critical Habitat Map
Figure 6 – USACE/RWQCB Jurisdictional Map
Figure 7 – CDFW Jurisdictional Map
Figure 8 – Western Sycamore Tree Removal Area
Figure 9 – USACE/RWQCB Jurisdictional Impacts Map
Figure 10 – CDFW Jurisdictional Impacts Map

LIST OF TABLES
Table 1 – Summary of Vegetation/Land Use Types within Project Area Work Limits Table 2 – Summary of Jurisdictional Areas

LIST OF ATTACHMENTS
Attachment 1 – Flora/Fauna Compendium
Attachment 2 – Special-Status Species Table
Attachment 3 – Site Photographs
Attachment 4 – Jurisdictional Delineation Report
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LIST OF ACRONYMS/ABBREVIATIONS

APN Assessor’s Parcel Number
AMSL Above Mean Sea Level
CDFW California Department of Fish and Wildlife
CNDDB California Natural Diversity Database
CWA Clean Water Act
EFH Essential Fish Habitat
ESA Endangered Species Act
Ft. Feet
GIS Geographical Information System
MSL mean sea level
OHWM Ordinary High Water Mark
RVA Ruth Villalobos & Associates, Inc.

RWQCB Regional Water Quality Control Board
SEA Significant Ecological Area
SCE Southern California Edison
TNW Traditionally Navigable Water
USACE United States Army Corps of Engineers
USDA United States Department of Agriculture
USFWS United States Fish and Wildlife Service
USGS United States Geological Survey
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1 1.0 INTRODUCTION
Ruth Villalobos & Associates, Inc. (RVA) conducted a biological resources assessment for the proposed Garden River Bridge Project (Project) located within the Cities of Glendale and Los Angeles, Los Angeles County, California. A literature/database review was conducted and included a review of state and federal databases of sensitive species known to occur in the area.

The field review included a pedestrian survey by biologists of established study area, which included the 2.94-acre Project site, the site’s overlapping 3.80-acre work area limits, and a 500 - foot survey buffer . A habitat assessment was conducted for sensitive and general plant communities, as well as birds and other sensitive animal species. RVA also determined any federal or state jurisdictional features within the proposed project boundaries, and the extent of disturbance to waters and riparian vegetation. This report of findings includes study area baseline information, a description of the habitats found on site, regulatory requirements, and recommendations for avoidance, minimization, and mitigation measures, where applicable.

1.1 PROJECT LOCATION
The proposed Project would span the LA River at approximately LA River Mile 31, latitude

34.1563
o and longitude - 118.2823o, within Township 1 North, Range 13 West. The proposed Project would extend from the City of Glendale on the north side of the LA River to the City of Los Angeles on the south. The bridge and associated connections to the existing bicycle/pedestrian trails along the LA River would be constructed w ithin Assessor’s Parcel Numbers (APN) 5593-001-900, 5593-002-917, 5593-002-916, 5593-002-270, 5627-020-907, and 5627-020-908. Located just north of where Interstate Highway 5 intersects with State Highway 134, the proposed bridge would serve as a point of connection across the LA River from the corner of Flower Street and Fairmont Avenue on the north side of the LA River (City of Glendale), to North Zoo Drive in Griffith Park on the south side of the LA River (City of Los Angeles) (see Figure 1 – Regional Vicinity Map and Figure 2 – Site Vicinity Map).

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2 EXHIBIT 5
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GLENDALE GARDEN RIVER BRIDGE PROJECT
Site Vicini
ty Map
Figure 2
USGS The National Map: National Boundaries Dataset, 3DEP Elevation Program, Geographic Names Information System, National Hydrography Dataset, National Land Cover Database, National S
tructures Dataset, and
National Transportation Dataset; USGS Global Ecosystems; U.S. Census Bureau TIGER/Line data; USFS Road data; Natural Earth Data; U.S. Department of State HIU; NOAA National Centers for Environmental Information. Data refreshed October 3, 2025.

Legend
Project Work Area Limits
0 0.2 0.4
Miles
¯
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4 1.2 P ROJECT DESCRIPTION
The City of Glendale, in partnership with the City of LA, proposes the construction of a three - span, curvilinear, landscaped bridge for use by pedestrians, bicyclists, and maintenance vehicles.

The intent of this multi-community resource is to increase access t o Glendale Narrows Riverwalk, and Griffith Park; to improve connections; and to increase the safety of paths used for pedestrians and cyclists. Dedicated ac cess ac ross the LA River at this key location would improve public safety and accessibility to important community resources by creating a connectio n between Glendale and Los Angeles across the LA River for pedestrians and cyclists.

The proposed bridge would be concrete with two supporting piers in the Los Angeles River. It would feature extensive landscaping on the approaches, as well as on the bridge itself, and is thus named the “Garden River Bridge.” A number of raised and in-ground planting beds would create dedicated zones for bicycle and pedestrian circulation, shade structures, canopied seating areas, dispersed gathering spaces, and scenic views of the LA River.

The LA River is a U.S. Army Corps of Engineers (USACE)-built flood risk management facility, in which the USACE holds primary authority over any proposed changes. The City of LA owns, operates, and maintains the south side of the LA River, located within t he southern portion of the proposed Project area; als o within this area, a fifteen -foot easement is held by Southern C
alifornia Edison (SCE). The LA River channel limits are owned, operated, and managed by the City of LA; the City of Glendale would enter into an operations a nd management agreement for the proposed Project. On the north bank of the LA River, parcels within the northern portion of the proposed Project limits are owned by the City of LA, the City o f Glendale, and the Los Angeles County Flood C o ntrol District (LACFCD). Furthermore, easements that cross the proposed Project area on the northern side are held by the City of Glendale for poles, sewers and structures, and the Riverwalk pedestrian/bike trail.

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5 2.0 METHODS

2.1 BIOLOGICAL RESOURCES ASSESSMENT
Prior to the on-site field assessment, biologists established a study area, which included the 2.94- acre Project site, the site’s overlapping 3.80 -acre work area limits, and a 500 -foot survey buffer (herein collectively referred to as the study area). The study area was reviewed to determine whether the Project’s work area limits or the general vicinity support special status or otherwise sensitive species and/or their habitat, and to address the potential effects associated with the proposed Project on those resources. The species and habitats addressed in this document are based on a literature and database review and field investigation.

Prior to conducting the site survey, species and habitat information was gathered and reviewed for the Burbank, California USGS quadrangle to determine which species and/or habitats would be expected to occur within the survey area. The following resources were reviewed:
• California Natural Diversity Database (CNDDB);
• U.S. Fish and Wildlife Service (USFWS) Species Occurrence Database; • USFWS mapping of designated critical habitat;
• California Native Plant Society Electronic Inventory (CNPSEI) database; • Calflora Database; and
• LA County Significant Ecological Area (SEA) mapping tool On December 20, 2022, RVA biologists Miranda Villalobos and Justinne Manahan visited the study area to conduct a field assessment and to document sensitive biological resources. Survey methods included walking the entire study area while conducting a thorough examination of the surrounding area. Areas inaccessible by foot were examined using binoculars. The field assessment consisted of observing and recording plant and animal species in a field notebook. A complete list of plant species and wildlife species observed can be found in Attachment 1, Flora/Fauna Compendium, of this report. On October 20, 2025, an updated desktop analysis was conducted to identify any newly listed species not previously recorded in the area and to verify current environmental conditions. The review included the CNDDB , the U.S. Fish and Wildlife Service (USFWS) Occurrence Database, and recent Google Earth imagery.

Vegetation communities within the study area were mapped according to Holland (1986) when possible, while plant species were identified using The Jepson Manual: Vascular Plants of California (2012) and U.C. Berkeley’s “Jepson eFlora” online database (2023). The study area does not meet the parameters of any natural vegetation classification system. Wildlife species were identified by sight, call, and/or tracks when present.

The field assessment was conducted between 9:00 am and 11:30 am, the temperature was 64 degrees Fahrenheit with mostly sunny skies, 2 -mile-per-hour winds from the southwest, and

54.1% humidity. A shallow sheet of water with moderate siltation was present within the LA River, with an approximate wetted depth of up to 12 inches.

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6 2.2 JURISDICTIONAL DELINEATION
On December 20, 2022, RVA biologists Miranda Villalobos and Justinne Manahan also conducted a jurisdictional delineation to evaluate the study area for the limits of jurisdictional waters of the U.S. regulated by the USACE and the Regional Water Quality Control Board (RWQCB), and streambed and associated riparian habitat as regulated by California Department of Fish and Wildlife (CDFW). The jurisdictional delineation was based on the methods outlined in the Wetland Delineation Manual (Environmental Laborato ry 1987), the Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region (USACE 2008a), and A Field Guide to the Identification of the Ordinary High-Water Mark (OHWM) in the Arid West Region of the Western United States (USACE 2008b). The following relevant literature and materials were also reviewed prior to conducting the delineation:
• Historical aerial photographs of the study area contours to determine the potential locations of jurisdictional waters or wetlands;
• USGS topographic map (Figure 2 – Site Vicinity Map) to determine the presence of any “blue line” drainages or other mapped water features;
• United States Department of Agriculture (USDA) soil mapping data; and • United States Fish and Wildlife Service (USFWS) National Wetlands Inventory (NWI) maps to identify areas mapped as wetland features.

Channel widths within the LA River were measured according to a discernable OHWM to determine waters of the U.S. The RWQCB jurisdictional follows guidance from Section 401 of the Clean Water Act and typically follows the same jurisdictional areas as USACE. Widths of the streambed and bank were also measured to determine waters of the State by delineating the top of bank measurement.

3.0 REGULATORY FRAMEWORK

3.1 FEDERAL REGULATIONS
CLEAN WATER ACT (33 U.S.C. 1344 ET SEQ.)
Section 404 of the Clean Water Act regulates the discharge of dredged or fill material into waters of the United States, including wetlands. The USEPA promulgated Section 404(b)(1) guidelines (40 CFR Part 230); however, the USACE Regulatory Program evaluates and issues permits fo r proposed discharges into waters of the United States. Section 401 of the Clean Water Act requires that applicants for federal permits or licenses provide certification from the state that any discharges will comply with state -established water quality standard requirements.

Applicants/Requestors must obtain a Section 401 certification or waiver for the proposed action before the USACE can authorize a permit under Section 408 and Section 404. EC 1165-2-220 specifies that the USACE will coordinate internally to ensure that the Section 404 permit and the Section 408 Permissions are consistent.

RIVER AND HARBORS ACT (33 U.S.C. 403)
Section 10 of the River and Harbors Act regulates the construction of structures in or over any navigable Waters of the U.S. ( WoUS) or outside the defined limits of navigable WoUS if the EXHIBIT 5
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7 structure or work affects the course, location, or condition of the water body. The law regulates disposal of dredged or fill materials, dredging, excavation, filling, modification and recanalizatio n of WoUS and pertains to the smallest to the largest of construction undertakings including without limitation any aerial or subaqueous power transmission lines, aids to navigation, artificial canal, bank protection (e.g., riprap, revetment, bulkhead), boat ramp, boom breakwater, dolphin, groin, intake or outfall pipes, jetty, mooring structures such as pilings, permanently moored floating vessel, riprap, revetment, tunnel, weir, wharf. This section applies to all construction whether permanent, semi-permanent, or temporary.

Section 14 of the Rivers and Harbors Act of 1899, as amended, and codified in 33 U.S.C 408 (Section 408) provides that the Secretary of the Army may, upon the recommendation of the USACE Chief of Engineers, grant permission to other entities for the permanent or temporary alteration or use of any USACE Civil Works project. This requires a determination by the Secretary that the requested alteration would not be injurious to the public interest and would not impair the usefulness of the USACE project. The purpose of the Section 408 review is to ensure that the Congressionally - authorized purpose and benefits of the Civil Works project are protected and maintained (e.g., flood risk management, navigation, coastal storm damage reduction) and to ensure that what is being proposed is not injurious to the public interest.

EDERAL ENDANGERED SPECIES ACT
The federal Endangered Species Act (ESA) was enacted in 1973 to conserve threatened and endangered species and their ecosystems. Actions that jeopardize endangered or threatened species and their habitats upon which they rely are considered “take” under the ESA. Take of a federally listed threatened or endangered species is prohibited without a special permit. The ESA allows for take of a threatened or endangered species incidental to development activities once a habitat conservation plan (HCP) has been prepared to the satisfaction of the U.S. Fish and Wildlife Service (USFWS) and an incidental take permit has been issued. The ESA also allows for the take of threatened or endangered species after Section 7(a)(2) consultation with the USFWS has deemed that development of the federal action associated with activities will not jeopardize the continued existence of the species.

IGRATORY BIRD TREATY ACT
The Migratory Bird Treaty Act (MBTA) was enacted in 1918 to protect native migratory birds or any part, nest, or egg of such bird unless allowed by another regulation adopted in accordance with the act. Enforced in the U.S. by the USFWS, the MBTA makes it unlawful to take, possess, buy, sell, purchase, or barter any migratory bird listed in the Code of Federal Regulations, Title 50, Chapter 10, including feathers or other parts, nests, eggs, or products, except as allowed by implementing regulations (Code F ed. Regs., Title 50, Ch. 21). Disturbance that causes nest abandonment and/or loss of reproductive effort (e.g., killing or abandonment of eggs or young) may be considered “take” and is potentially punishable by fines and/or imprisonment.

F
ISH AND WILDLIFE COORDINATION ACT OF 1958, AS AMENDED, (16 U.S.C. 661 ET SEQ.) The FWCA requires that federal agencies consult with the USFWS and the head of the agency exercising administration over the wildlife resources of the particular state, “whenever the EXHIBIT 5
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8 waters of any stream or other body of water are proposed or authorized to be impounded, diverted, the channel deepened, or the stream or other body of water otherwise controlled or modified for any purpose whatever” (16 U.S.C. 662).

N
ATIONAL ENVIRONMENTAL POLICY ACT OF 1969, AS AMENDED, (42 U.S.C. 4321 ET SEQ.) NEPA requires federal agencies to assess the environmental effects of their proposed actions prior to decision making. This biological assessment has been prepared following the 2020 CEQ NEPA Regulations (40 CFR 1500- 1508) and the USACE ER 200-2- 2 (33 CFR 230) and satisfies the NEPA requirement.

3.2 STATE REGULATIONS

CALIFORNIA ENDANGERED SPECIES ACT
The CESA, like the Federal ESA, contains a process for the listing of species and regulatin g potential impacts to listed species. State threatened and endangered species include both plants and wildlife but do not include invertebrates. The designation “rare” applies only to Californ ia native plants. State threatened and endangered plant species are regulated largely under the Native Plant Preservation Act in conjunction with the CESA.

State threatened and
endangered animal species are legally protected against take. The CESA authorizes CDFW to enter into a memorandum of agreement for take or listed species to issue an incidental take permit for a state-listed threatened and endangered species only if specific criteria are met.

ALIFORNIA NATIVE PLANT SOCIETY
The California Native Plant Society (CNPS) is a private organization that monitors and protects sensitive plant species. The CNPS compiles and maintains a list of rare, threatened, o r endangered plant species that often serves as a basis for designation or a species as threatened or endangered by CDFW.

ALIFORNIA FISH AND GAME CODE
The California Fish and Game Code (CFGC) provides protection from take for a variety of species, referred to as fully protected species. Take is defined in Section 86 as “hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture, or kill.” Section 5050 lists protected amphibians and reptiles. Section 3315 prohibits take of fully protected fish species. Eggs and nests of all birds are protected under Section 3503, nesting birds (including raptors and passerines) under Sections 3503.5 and 3513, birds of prey under Section 3503.5, and fully protected birds under Section 3511. Migratory non-game birds are protected under Section 3800. Mammals are protected under Section 4700.

EGIONAL WATER QUALITY CONTROL BOARD
The Regional Water Quality Control Board (RWQCB) regulates activities pursuant to Section 401(a)(1) of the CWA. Section 401 of the CWA specifies that certification from the State is required for any applicant requesting a federal license or permit including a Section 404 permit.

Through the Porter Cologne Water Quality Control Act, the Regional Board asserts jurisdiction over Waters of the State of California which is generally the same as WoUS but may also include waters not in federal jurisdiction. The State Wetland Definition and Procedures for Discharges of EXHIBIT 5
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9 Dredged or Fill Material to Waters of the State was adopted in April 2020 and put into effect statewide on May 28, 2020 (State Water Resources Control Board, 2020).

CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE
The CDFW regulates water resources under Section 1600 -1616 of the California Fish and Game Code. Section 1602 states: “An entity may not substantially divert or obstruct the natural flow of, or substantially change or use any material from the bed, channel, or bank of, any river, stream, or lake, or deposit or dispose of debris, waste, or other material containing crumbled, flaked, o r ground pavement where it may pass into any river, stream, or lake (CDFW, 2015).” CDFW jurisdiction includes ephemeral, intermittent, and perennial watercourses (including dry washes) and lakes characterized by the presence of (1) definable bed and banks and (2) existing fish or wildlife resources. Furthermore, CDFW jurisdiction often extends to habitats adjacent to watercourses, such as oak woodlands in canyon bottoms or willow woodlands that support hydrologic functions within the riparian system. CDFW jurisdiction typically does not include features without a discernible bed and bank, such as swales, vernal pools, or wet meadows.

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10 3.3 LOCAL REGULATIONS
The Project spans both City of Los Angeles and Los Angeles County jurisdictions and is subject to the requirements set forth in the following ordinances:

COUNTY OF LOS ANGELES OAK TREE PRESERVATION ORDINANCE
County Ordinance No 22.56.2060 defines protected trees are any species of the oak tree genus which is 8 inches or more in diameter; multi-trunked oaks are measured by a combined diameter of twelve inches or more of the two larger trunks.

CITY OF LOS ANGELES TREE PRESERVATION ORDINANCE
Ordinance No. 186,873 (Chapter IV, Article 6 of the Los Angeles Municipal Code) protects trees and shrubs (including coast live oak, western sycamore, Southern California black walnut, California bay laurel, Mexican elderberry, and toyon) with trunk diameters (measured at 4.5 feet above grade) of 4 inches or greater. City ROW trees are “protected” at any size or species under the Department of Recreation Urban Forestry Program.

ITY OF GLENDALE INDIGENOUS TREE ORDINANCE
Since 1982, native trees growing within the City of Glendale limits have been under the protections established in the Indigenous Tree Ordinance. The ordinance protects indigenous trees by requiring an indigenous tree permit for work that is performed on a protected tree or through the review of site plans when construction is proposed near protected trees. The City of Glendale’s list of protected trees consists of the following species:
• Coast live oak (Quercus agrifolia)
• Mesa oak (Quercus engelmannii )
• California (western) sycamore (Platanus racemosa)
• Valley oak (Quercus lobata)
• Scrub oak (Quercus berberidifolia )
• California bay (Umbellularia californica)
Protected trees additionally include any city-owned or park tree.

4.0 EXISTING CONDITIONS

4.1 SURROUNDING LAND USE TYPES
The study area encompasses approximately 10 acres within portions of the City of Los Angeles and City of Glendale where the cities each border a side of the Los Angeles River channel, as well as a portion of the Los Angeles River channel. Land use types occurring in the vicinity of the Project site include industrial uses to the north, within the City of Glendale, and open space (Griffith Park area) to the south, within the City of Los Angeles.

4.2 TOPOGRAPHY AND SOILS
Topography is relatively flat along the concrete -lined bottom of the Los Angeles River channel, the Glendale Narrows Riverwalk/trail to the north, and the Los Angeles River Bike Path and North Zoo Drive to the south.

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12 The site’s elevational profile varies from north to south, with the elevation at approximately 450 feet (ft.) above mean sea level (AMSL) at the top of the channel at the Glendale Narrows Riverwalk/trail to the north, approximately 433 ft. AMSL along the bottom of the channel, and at approximately 456 ft. AMSL at the top of the channel at the Los Angeles River Bike Path to the south.

Figure 3 – Soils Map, provides an overview of soil types within the study area . A review of the United States Department of Agriculture’s (USDA) Web Soil Survey indicates that Project’s work area limits include:
• 1001: Urban land-Metz-Pico complex; 0 to 2 percent slopes • 1264: Xeropsamments, frequently flooded; 0 to 2 percent slopes • 1012: Urban land-Tujunga-Typic Xerothents, sandy substratum complex; 0 to 2 percent slopes.

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GLENDALE GARDEN RIVER BRIDGE PROJECT
S
oils Map
Figure 3
Flowe
r St
Flower St
Fairmont Ave
Zoo Dr
Griffith Park
Ferraro Fields
Zoo Dr
Playground
Esri Community Maps Contributors, County of Los Angeles, California State P
arks, © OpenStreetMap, Microsoft, Esri, TomTom, Garmin, SafeGraph, GeoTechnologies, Inc, METI/NASA, USGS, Bureau of Land Management, EPA, NPS, US Census Bureau, USDA, USFWS, Microsoft, Vantor
Legend
Project Work Area Limits
1001: Urban land-Metz-Pico complex, 0 to 2
percent slopes.
1012: Urban land-Tujunga-Typic Xerorthents,
sandy substratum complex, 0 to 2 percent
slopes.
1264: Xeropsamments, frequently flooded, 0 to
2 percent slopes.
0 240 480
Feet
¯
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13 5.0 RESULTS

SITE CONDITIONS
The study area is located within urban areas within the cities of Glendale to the north and Los Angeles to the south, within Los Angeles County. On-site land uses are considered disturbed and naturally occurring habitats have been eliminated due to channelization and development along the Lost Angeles River channel. The study area is within a concrete -lined portion of the channel and is bordered by pavement trails and roads (the Glendale Narrows Riverwalk, Flower Street, and Fairmont Street to the north; the Los Angeles River Bike Path and North Zoo Drive to the south) on both sides of the channel.

Within the study area, the Los Angeles River is confined by a half-trapezoidal (to the south), half- vertical concrete wall (to the north) channel. During the site visit, a moderately shallow level o f water was present (about 12 to 20 inches) with minimal deposition and some algae growth present.

VEGETATION AND LAND USE TYPES
Vegetation present in and around the study area is relatively sparse and reflects ornamental plantings (e.g., trees and shrubs along walkways and within planters) or occurrences of herbaceous weedy species. Five overall vegetation types/land use types were identified during the biological assessment: developed, developed – concrete-lined channel, open water (concrete-lined channel), native/landscaped, and western sycam ore (see Figure 4 – Vegetation/Land Use Types Map and Table 2 – Summary of Vegetation/Land Use Types within the Project Area Work Limits).

Developed
The study area is surrounded by paved and/or concreted developed areas, such as adjacent sidewalks/walkways, roads, and the paved walking/bike trails. These developed areas do not contain or support vegetation.

Developed – Concrete-Lined Channel
The portion of the Los Angeles River channel in which the proposed Project would be constructed is concrete-lined and concrete-bottomed; as such, minimal to no vegetation is present within the concrete-lined portions of the channel. The minimal vegetation present consists of weedy herbaceous species growing out of some concrete cracks and weep holes along the surface and bottom of the trapezoidal/sloped side of the channel. Among the species observed were: spotted spurge ( Euphorbia maculata), pond water -starwort ( Callitriche stagnalis), rosilla ( Helenium puberulum), and big -flowered blumea ( Blumea megacephala). Observed not as often were instances of mulefat (Baccharis salicifolia) emerging from some of the weep holes.

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Open Water (Concrete-Lined Channel)
The low-flow portion of the concrete-lined, concrete-bottomed Los Angeles River channel is inundated with enough water to cover the surface of the channel bottom. Any vegetation observed was very minimal and consisted of algal growth.

Native/Landscaped
Native/landscaped vegetation consists of various native and non- native plantings in and around the study area within planters along the Glendale Narrows Riverwalk to the north (the majority of the vegetation being outside the Project’s northern site boundary). Species within these planters include: desertbroom (Baccharis sarathroides), African sumac (Searsia lancea), cheeseweed ( Malva parviflora), tumbleweed ( Kali tragus sp. tragus), and coyote brush (Baccharis pilularis). A few early -stage coast live oak trees ( Quercus agrifolia) were also observed within these planter areas.

Park Landscaped
The area ju st south of Zoo Drive and just north of the Griffith Park soccer field contains a scattering of trees including western sycamore ( Platanus racemosa) and coast live oak (Quercus agrifolia) in addition to some bare/sparsely vegetated unpaved areas.

Western Sycamore
A line of western sycamore (Platanus racemosa) trees is present within the southern portion of the proposed Project’s work area limits. These trees are bordered on one side by the paved Los Angeles River Bike Path and by the paved North Zoo Drive road on the other. No other vegetation was observed growing under or around these trees.

Table 1 – Summary of Vegetation/Land Use Types within the Project Work Area Limits Vegetation Type/Land Use Type Approximate Acreage
Developed 1.72
Developed – Concrete-Lined Channel 1.04
Open Water (Concrete-Lined Channel) 2.79
Native/Landscaped* 0.03
Park Landsacped 1.15
Landscaped Western Sycamore 0.55
*As noted, the majority of the native/landscaped vegetation type is located outside of proposed Project boundaries, along the Glendale Narrows Riverwalk.

Upstream of the Project (more than 1,000 ft. outside of the Project work area limits), there is a soft-bottomed portion of the Los Angeles River channel that supports vegetation within the wetted portion of the channel. Vegetation in this area primarily consists of California bulrush (Schoenoplectus californicus) and some willow trees ( Salix sp.). This area is located far outside of the Project’s work area limits and would not be impacted by Project activities.

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GLENDALE GARDEN RIVER BRIDGE PROJECT
Figure 4
V
egetation/Land Use Types Map
Flowe r St
Fairmon
t Ave
Zoo Dr
Griffith Park
Ferraro Fields
Zoo Dr
Esri Community Maps Contributors, County of Los Angeles, California State Parks, © OpenStreetMap, Microsoft, Esri, T
omTom, Garmin, SafeGraph, GeoTechnologies, Inc, METI/NASA, USGS, Bureau of Land Management, EPA, NPS, US Census Bureau, USDA, USFWS, Microsoft, Vantor Legend
Project Work Area Limits
Developed
Developed - Concrete-
Lined Channel
Open Water (Concrete-
Lined Channel)
Native/Landscaped
Park Landscaping
Western Sycamore
(Platanus racemosa)
0 225 450
Feet
¯
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16 WILDLIFE
Due to urbanization and minimal habitat within the study area, very few wildlife species were observed. This may also have been due to cooler winter temperatures at the time of the site assessment. Wildlife species observed during the site survey included: rock dove (Columba livia), American crow (Corvus brachyrhynchos), black -necked stilt ( Himantopus mexicanus), mourning dove (Zenaida macroura), and black phoebe (Sayornis nigricans).

Additionally, within the soft -bottomed, vegetated portion of the channel, located upstream of the Project site, American wigeon ( Mareca americana) and American coot ( Fulica americana) were observed.

WILDLIFE MOVEMENT AND CONNECTIVITY
Native habitat patches, wildlife corridors, linkages, and Local Connectivity Areas exist within the landscape in and around the Los Angeles River. A wildlife corridor is a strip of habitat that connects two otherwise separated larger habitat areas. Connecting isolated habitats helps to reduce population isolation, increases the species’ range, and allows for greater survival of the population. The combination of the Los Angeles River channel and the adjacent highways and development has effectively created a blockage to the wildlife movement that would have historically occurred between the Santa Monica Mountains to the west and Verdugo Mountains and San Gabriel Mountains to the east. Bats and birds are less restricted by development, thoug h human occupation may discourage passage. Ground dwelling animals that occur in the vicinity of the Los Angeles River migrate into the study area via the available, though limited, pathways.

These pathways can be composed of narrow riparian strips, but more often are provided by culverts, paved pathways along the Los Angeles River, and concrete tunnels beneath highways.

Despite the man-made nature of these pathways, wildlife are known to utilize them. Althoug h the riverbed is highly developed, it likely provides at least some connectivity for species moving or migrating through the region, particularly for aerial species such as bats and birds. Outside of the river channel, various areas contain habitats that support species movement, migration , stopover, overwintering, and breeding, such as trees and vegetation in local parks, greenbelts, and landscaping. Developed features within the study area, such as culverts, tunnels, and bridges additionally provide breeding and/or nesting habitat for both bird and bat species within and outside of the Los Angeles River.

The Los Angeles River may serve as a wildlife corridor that allows animals to migrate between larger native habitat patch areas.

FEDERAL AND STATE JURISDICTIONAL RESOURCES
The study area contains one drainage feature, the Los Angeles River, a concrete -lined flood control channel, a portion of which is located within the Project site. The Los Angeles River is a blue-line perennial stream that is designated as a Traditional Navigable Water (TNW) for its entire length and flows for approximately 51 miles until it releases flows into the Pacific Ocean. Flows observed within the channel during the time of survey were primarily from recent winter rain and urban runoff. No additional jurisdictional resources are within the study area boundaries.

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The segment of the channelized Los Angeles River exhibits physical evidence of an OHWM; observed staining of the concrete side slopes indicate the OHWM is approximately 12 inches above the toe of the slope. Widths of the LA River within the Project work area limits average approximately 241.78 feet. USACE and RWQCB jurisdiction associated with the LA River within the Project work area limits totaled approximately 2.80 acres (508.74 linear feet) (Figure 6 – U SACE/RWQCB Jurisdictional Map).

CDFW jurisdiction associated with the Los Angeles River within the Project work area limi ts extends top of the channel, bank to bank. Due to the lack of soils and vegetation within the conc
rete channel, there is no associated riparian habitat present in this portion of the Los Angeles River. Bank to bank widths within CDFW jurisdiction was approximately 308.57 fe et. CDFW jurisdiction totaled approximately 3.84 acres (641.63 linear feet) of unvegetated streambed within the Project work area limits (Figure 7 – C DFW Jurisdictional Map).

SPEC

IAL-STATUS SPECIES
A list of special- status species with the potential to be in the study area was obtained using th e California Natural Diversity Database (CNDDB), the California Native Plant Society (CNPS), and U.S
. Fish and Wildlife Se rvice (USFWS) Species Occurrence Database. Habitat assessments fo r all listed species within the Burbank quadrangle were evaluated in Attachment 2, Special- Status Species Table.

Based on the habitat requirements for specific species, soil types, and disturbed nature of the study area, it was determined the study area has less than reasonable potential to provide suit
able habitat for the special-status plant s pecies identified in the CNDDB query and for most spe
cial-status wildlife species.

Special-Status Plant Communities
The CNDDB identifies areas of southern coast live oak riparian forest approximately 1 m ile southwest of the Project site, within Griffith Park. Project activities will not extend into Griffith Park and will not alter conditions within the study area that could adversely affect the southern coast like oak riparian forest within Griffith Park.

Special-Status Plant Species
No special-status plants were detected within the survey area. As discussed, the proposed Project would be constructed within a concrete -lined, developed portion of the Los Angeles River channel. Due to the concrete -lined nature of the channel and surrounding urbanization, th e proposed Project would not support the special -status plant species identified in the CNDDB query of the Burbank quadrangle.

Special-Status Wildlife Species
One special-status avian species, t he American p eregrine f alcon (Falco peregrinus anatum), has the potential t o o ccur within the P roject area. While t he American p eregrine f alcon ha s been Federally delisted due to population recovery, i t continues to be recognized as a Fully P rotected sp
ecies in C alifornia. American peregrine falcon ad apts well to ur ban environments, often using 17 EXHIBIT 5
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18 tall buildings, bridges, and other man-made structures as nesting sites. Although the Project site itself does not contain s uitable nesting habitat, it provides potential foraging habitat for the falcon g
iven the presence of prey species such as fish, pigeons, and small mammals associated with the LA River.

One reptile species, the California legless lizard (A nniella spp.), has a moderate potential to occur within or near the Project site. California legless lizard is a species of spec ial concern. T his species has been documented upstream in riparian habitat located offsite within the Glendale Narrows rip
arian habitat directly upstream. While the Project site is concrete-lined and lacks the vegetative cover and loose, sandy soils preferred by this species for burrowing, occasional individuals may occur as they forage beyond their typical habitat boundaries.

Four special-status bat species were identified in the CNDDB query to have moderate potential to utilize the study area to some extent – pallid bat ( A ntrozous pallidus), western mastiff bat (Eumops perotis californicus), hoary bat ( Lasiurus cinereus), and western yellow bat ( Lasiurus xanthinus). All four of these bat species are designated as species of special concern. The s tudy area p rovides potentially suitable foraging an d/or roosting habitat for bat species as s ome bat spe
cies are known to forage and roost along the Los Angeles River channel. Developed features within the study area, such as culverts, tunnels, and bridges provide breeding and/or nesting habitat for special status bat species within the study area.

PROTECTED TREES
The Project would be subject to both county and city tree ordinances. As discussed, there are western sycamore trees along the Los Angeles River Bike Path and North Zoo Drive, within the southern footprint of the Project’s work area limits , and some early stage coast live oak t rees in the planter areas along the Glendale Narrows Riverwalk within the northern footprint of the w or k area limits. The construction of an ADA access ramp and plaza area between the Zoo Drive crosswalk and the bridge will require the removal of approximately eighteen (18) western Sycamore trees located between Zoo Drive and the LA River Bike Path.

NESTING BIRDS
Developed and undeveloped portions of the study area contain suitable nesting habitat for a variety of avian species. The trees along the Los Angeles River Bike Path and the shrubs along the Glendale Narrows Riverwalk c ontain suitable habitat within the Pr oject’s work area limits. The flowing water in this portion of the Los Angeles River provides important foraging sites for many birds.

HABITATS OF CONCERN
Habitats of concern along the LA River include s ensitive natural communities, EFH, and USFWS critical habitat.

Sensitive natural communities: There are no sensitive natural communities documented within the study area . The CNDDB identifies areas of southern coast live oak riparian forest approximately 1 mile southwest of the study area , within Griffith Park. The Project would not involve encroaching into these areas and would not impact these areas.

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19 Habitat Conservation Plans: There are no habitat conservation plans for the Project site o r surrounding area.

EFH: As the LA River is a concrete -bottom channel at this location with no associated riparian habitat, the study area is not an EFH.

USFWS critical habitat: There is no designated USFWS critical habitat within the study area or the vicinity. The nearest critical habitat is approximately 8.1 miles to the northwest and north fo r Santa Ana sucker (Catostomus santaanae; see Figure 5 – Critical Habitat Map) .

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21 DELINEATION RESULTS SUMMARY
Within the study area, there is one feature subject to the jurisdiction of the USACE, RWQCB, and CDFW. The Los Angeles River within the Project area does not meet the wetland criteria for USACE or RWQCB jurisdictional wetlands. Please refer to the following table, Figure 6 – USACE/RWQCB Jurisdictional Map, and Figure 7 – CDFW Jurisdictional Map for a detailed summary of the federal and state jurisdictional areas.

Table 2 – Summary of Jurisdictional Areas
Jurisdictional
Feature
USACE
Jurisdiction
(acres)
RWQCB
Jurisdiction
(acres)
CDFW
Jurisdiction
(acres)
Length
(linear
feet)
Latitude/
Longitude
Class of
Aquatic
Resource
LA River 2.80 2.80 3.84 ~650 34.156321°/
-
118.282288°
Non-
Section
10- non
wetland
Total 2.80 2.80 3.84 ~650 n/a n/a
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GLENDALE GARDEN RIVER BRIDGE PROJECT
Figure 6
USACE and R
WQCB Jurisdiction
Fairmo nt
Ave
Zoo Dr
Zoo Dr
Esri Community Maps Contributors, County of Los Angeles, California State Parks, © OpenStreetMap, Microsoft, Esri, T
omTom, Garmin, SafeGraph, GeoTechnologies, Inc, METI/NASA, USGS, Bureau of Land Management, EPA, NPS, US Census Bureau, USDA, USFWS, Microsoft, Vantor EXHIBIT 5
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GLENDALE GARDEN RIVER BRIDGE PROJECT
Figure 7
CDFW Jurisdiction
Flower St
Fairmon t Ave
Zoo Dr
Zoo Dr
Esri Community Maps Contributors, County of Los Angeles, California State Parks, © OpenStreetMap, Microsoft, Esri, T
omTom, Garmin, SafeGraph, GeoTechnologies, Inc, METI/NASA, USGS, Bureau of Land Management, EPA, NPS, US Census Bureau, USDA, USFWS, Microsoft, Vantor Legend
Project Work Area Limits
CDFW Jurisdiction within Project
Site
CDFW Jurisdiction outside
Project Site
0 130 260
Feet
¯
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25 6.0 CONCLUSIONS

IMPACTS ON NESTING BIRDS
The study area contains suitable nesting habitat within the surrounding trees and shrubs along the Glendale Narrows Riverwalk and the Los Angeles River Bike Path. As these areas of trees and shrubs within the study area contain potential nesting habitat, construction activities should be conducted outside avian nesting season pursuant to the Migratory Bird Treaty Act. The general avian nesting season for passerines is from February 1 st to September 15 th but can vary based on migratory patterns, species, weather patterns, etc. If avoidance of the nesting season is not feasible, the following Mitigation Measure is recommended:

MM-BIO-1 Pr
e-Construction Nesting Bird Survey
If construction activities such as earthwork, clearing, grubbing, etc. cannot feasibly be conducted outside the general nesting bird season for migratory birds (February 1 st to September 15 th), a qualified biologist shall conduct a nesting bird survey, including suitable habitat within a 500-foot radius, within three days prior to any disturbance of the site. If active nests are identified, the biologist shall establish suitable buffers around the nests, and the buffer areas shall be avoided until the nests are no longer occupied and the juvenile birds can survive independently from the nests.

IMPACTS ON REPTILE SPECIES
Given the close proximity of known occurrences of California leg less lizard within the upstream riparian habitat within Glendale Narrows , there is a potential for this species to occur within the Project site . Although the site lacks their prefer red habitat due to the concrete -lined nature , individuals may occasionally disperse into or forage within the area. If present during construction activities, th is species could be adversely affected by ground dist urbance and e quipment movement. To avoid and minim ize potential impacts to California leg less lizard , the following Mitigation Measure is recommended:

MM-BIO-2
Pre-Construction Clearance Survey
Prior to the start of any g round-disturbing act ivities, a qualified biologist shall cond uct a pre - construction survey of the Project site within two hours before the start of work to determine presence of the Cali fornia legless lizard . If individuals are detected during the survey or encountered during construction, the individual shall be allowed to move out of harm’s way on its own, or if necessary, may be relocated by a qualified biologist to suitable upstream habitat within the LA River.

IMPACTS ON BAT SPECIES
The study area contains potentially suitable foraging and/or roosting habitat for bat species. Bats are known to forage and/or roost along the Los Angeles River channel where concrete -lined portions of the channel (e.g., bridges, channel outlets, etc.) provide habitat via cracks and crevices and where open water provides foraging habitat. The proposed project activities would not alter conditions within the project site with respect to suitability of habitat for bat foraging or roosting.

Nonetheless, because the study area contains suitable bat foraging and/or roosting habitat, the following Mitigation Measure is recommended:

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26 MM-BIO-3 Bat Roost and Emergence Survey
A pre-construction survey for bat roosts shall be conducted by performing a daytime pedestrian survey to inspect potential habitat within 100 feet of the Project’s work area limits for indications of bat use (e.g. occupancy, guano staining, smells, or sounds) and a dusk emer gence survey. The survey shall be conducted by a qualified bat biologist. If it is determined habitat within the survey area is being used, or likely to be us ed as a bat roost, and may be affected by constructio n activities, then specific measures will be developed and implemented to minimize potential impacts on the roost. Such measures may include minimizing construction activities near the roost during maternity season (May 1st through August 15th) or other measures developed by the qualified biologist in coordination with CDFW.

IMPACTS

ON PROTECTED TREES
The Project ’s work area limits include County and City protected trees including western Sycamore and coast live oak trees. The construction of an ADA access ramp and plaza area between the Zoo Drive crosswalk and the bridge will require the removal of approximately 18 western Sycamore trees. Please
see Figure 8- Western Sycamore Tree Removal Area.

DISTU
RBANCE OR R emoval of any protected trees within the work area limits will require a Tr ee Remo
val Permit from the City of Los Angeles Bureau of Street Services Urban Forestry Division. If protected trees cannot be transplanted and relocated within the study area , they must be replaced at a 4:1 ratio.

IMPACTS ON JURISDICTIONAL WATERS
USACE Jurisdictional Impacts
Non-wetland waters of the U. S. subject to USACE jurisdiction within the Project area work limits total approximately 1.85 acres. Of this, a total of 1.00 acre of temporary impacts would occur to USACE jurisdiction resulting from water diversion activities and th e excavation for two bridge pier foundations. Additionally, a total of 0.03 acre of permanent impacts to US ACE jurisdiction would occur from the construction of the two bridge piers. Please see Figure 9 – USACE & RWQCB Jurisdictional Impacts Map for a visual overview of these impacts.

RWQCB
Jurisdictional Impacts
Non-wetland waters of the State subject to RWQCB jurisdiction within the Project area work limits total approximately 1.85 acres. Of this, a total of 1.00 acre of temporary impacts would occur to RWQCB jurisdiction resulting from water diversion activities and the excavation for two bridge pier foundations. Additionally, a total of 0.03 acre of permanent imp acts to RWQCB juris diction would occur from the construction of the two bridge piers. Please see Figure 9 – USACE & RWQCB Jurisdictional Impacts Map for a visual overview of these impacts.

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27 CDFW Jurisdictional Impacts
Waters of the State in the form of unvegetated streambed subject to CDFW jurisdiction within the Project area work limits total approximately 2.31 acres. Of this, a total of 1.03 acre of temporary impacts would occur to CDFW jurisdiction resulting from water diversion activities, excavation activities for two bridge piers, and to excavate areas to install the bridge abutment and retaining wall. Additionally, a total of 0.04 acre of permanent impacts to CDFW jurisdiction would occur from the construction of the two bridge piers and from the abutment for the bridge on the south side of the channel. Please see Figure 10 – CDFW Jurisdictional Impacts Map fo r a visual overview of these impacts.

Addressing Jurisdictional Impacts
Based on the results of the Jurisdictional Delineation, the Los Angeles River is a blue-line stream jurisdictional under waters of the U.S. and falls under USACE, RWQCB, and CDFW jurisdiction. As the Project would include both temporary and permanent impacts within jurisdictional waters and a TNW, the Project would need to obtain a regulatory Section 10/404 Nationwide Permit, RWQCB Section 401 Water Quality Certification, and CDFW Section 1602 Streambed Alteration Agreement approvals prior to development of the site.

Other recommendations related to reducing impacts during construction:

MM BIO-4 Environmental Training
A W orker E nvironmental Awareness Program (WEAP) s hall be presented to all employees, representatives, agents, contractors, and subcontractors concentrating on the proper identification of s ensitive resources w hile in t he field, suggested s trategies in avoi ding im pact t o s ensitive resources, and proper reporting methods for field crews if sensitive resources are observed dur ing construction activities.

MM BIO-5 Access Routes and Work Area
The P roject shall establish an d delineate work areas and ac ce ss r outes, within ar eas an d r outes within jurisdictional features, to m inimize im pacts to sensitive resources t o the g reatest e xtent feasible.

Recommended Best Management Pr actices (BMPs) related to Operations and Maintenance:

1. To av
oid light spillover into the Los Angeles River habitat, any proposed lighting fixtures on the bridge structure shall incorporate internal baffles, or similar, to direct the light towards the ground and shall have a zero side-angle cut-off to the horizon.

2. Construction activities should be limited to daylight hours.

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GLENDALE GARDEN RIVER BRIDGE PROJECT
Figure 8
W
estern Sycamore Tree Removal Area
Flower St
Fairm ont Ave
Zoo Dr
Zoo Dr
Esri Community Maps Contributors, County of Los Angeles, California State Parks, © OpenStreetMap, Microsoft, Esri, T
omTom, Garmin, SafeGraph, GeoTechnologies, Inc, METI/NASA, USGS, Bureau of Land Management, EPA, NPS, US Census Bureau, USDA, USFWS, Microsoft, Vantor Legend
Project Work Area Limits
Western Sycamore
Removal
Area (~18 trees)
Proposed Bridge
Proposed Plaza, Staris, &
ADA
Ramp Areas
0 170 340
Feet
¯
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29 EXHIBIT 5
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30 EXHIBIT 5
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31 7.0 REFERENCES
California Department of Fish and Wildlife, 1994. Field Guide to Lake and Streambed Alteration Agreements Section 1600-1607 California Fish and Wildlife Code.

Caltrans and CDFW, California Essential Habitat Connectivity Project: A Strategy for Conserving a Connected California, 2010
Environmental Conservation Online System (ECOS): USFWS Critical Habitat for Threatened and Endangered Species
Guerra, Roberto. "An Inventory of Loss on the Los Angeles River." High Country News, 25 June 2018, https://www.hcn.org/issues/50-11/photos-an-inventory-of-loss-on-the-los - angeles-river
Holland, Robert F. “Preliminary Descriptions of the Terrestrial Natural Communities of California.” October 1986.

Jepson Manual: Vascular Plants of California, Second Edition. January 2012.

Natural Resources Conservation Service, April 2022. Hydric Soils List of California . (http://soils.usda.gov/use/hydric/)
Spencer, W.D., P. Beier, K. Penrod, K. Winters, C. Paulman, H. Rustigian-Romsos, J. Strittholt, M.

Parisi, and A. Pettler. 2010. California Essential Habitat Connectivity Project: A Strategy for Conserving a Connected California. Prepared for California Department of Transportation, California Department of Fish and Game, and Federal Highways Administration.

U.C. Berkeley. “The Jepson Herbarium: Jepson eFlora.” 2022.

U.S. Army Corps of Engineers, Los Angeles District. "Los Angeles River." U.S. Army Corps of Engineers, n.d., https://www.spl.usace.army.mil/Missions/Asset-Management/Los- Angeles-
River/#:~:text=Three%20frogs%20may%20occur%20in%20the%20Glendale,(Sceloporus% 20occidentalis)%2C%20and%20side%2Dblotched%20lizard%20(Uta%20stansburiana) U.S. Army Corps of Engineers, 2007. Practices for Documenting Jurisdiction under Section 404 of the CWA, Regional Guidance Letter 07 -01.

U.S. Army Corps of Engineers, 2008. A Field Guide to the Identification of the Ordinary High Water Mark in the Arid West Region of the Western United States.

U.S. Army Corps of Engineers, 2001. Minimum Standards for Acceptance of Preliminary Wetland Delineations.

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32 U.S. Department of Agriculture, Natural Resources Conservation Service, Web Soil Survey. (http://websoilsurvey.nrcs.usda.gov/app/)
U.S. Fish and Wildlife Service, Department of Habitat and Resource Conservation, Wetland Geodatabase. (http://wetlandsfws.er.usgs.gov/NWI/index.html) EXHIBIT 5
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33 Attachment 1 – Flora/Fauna Compendium
This list documents plant and animal species observed during the habitat assessment on December 2 0 , 2022. Other species may have been overlooked or undetectable due to their activity patterns or growing season.

Common Name Scientific Name
Flora: Coast live oak
Western sycamore
Tumbleweed
Coyote bush
Desert broom
African sumac
Cheeseweed
Spotted spurge
Pond water-starwort
Rosilla
Big-flowered blumea
Mulefat
California bulrush
Willow sp.

Quercus agrifolia
Platanus racemose
Kali tragus subsp. tragus
Baccharis pilularis
Baccharis sarothroides
Searsia lancea
Malva parviflora
Euphorbia maculata
Callitriche stagnalis
Helenium puberulum
Blumea megacephal a
Baccharis salicifolia
Schoenoplectus californicus
Salix sp.

Fauna: Mourning dove
Rock dove
Black phoebe
Black-necked stilt
American wigeon
American coot
Zenaida macroura
Columba livia
Sayornis nigricans
Himantopus mexicanus
Mareca americana
Fulica americana
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34 Attachment 2 – Special-Status Species Table

Scientific Name
Common Name Federal/State Listing Global Rank/
State Rank
CA Rare
Plant
Rank
Habitats Observed
On Site? Potential to Occur
Reptiles
Actinemys pallida
southwestern pond turtle Proposed Threatened/None G2/SN R N/A Streams, ponds, lakes, wetlands
with terrestrial habitat nearby for
nesting
No
No suitable habitat
occurs on site. Species
is considered ABSENT.

Anniella spp.

California legless lizard None/None G3G4/ S 3S4 N/A
Sparsely vegetated areas of
coastal dune, valley -foothill,
chaparral, and coastal scrub
habitats
No
Species documented to
occur directly upstream
from Project site in the
native riparian habitat.

Species has a

MODERATE POTENTIAL
TO OCCUR.

Anniella stebbinsi
Southern California legless
lizard
None/None G3/S3 N/A
Broadleaved upland forest,
Chaparral, Coastal dunes, Coastal
scrub
No
No suitable habitat
occurs on site. Species
is considered ABSENT.

Arizona elegans
occidentalis
California glossy snake
None/None G5T2/ S2 N/A
Desert habitats, chaparral,
sagebrush, valley -foothill
hardwood, pine-juniper, annual
grass
No
No suitable habitat
occurs on site. Species
is considered ABSENT.

Phrynosoma blainvillii
Phrynosoma blainvillii
coast horned lizard

None/None G4/S4 N /A Deserts, chapparal, grassland,
often near ant hills No
No suitable habitat
occurs on site. Species
is considered ABSENT.

Amphibians

Phrynosoma blainvillii
western spadefoot

Proposed Threatened/None G2G3/S 3S4 N/A
Grassland, chaparral , scrub, oak
woodlands , sandy, gravelly washes
and small seasonal streams.

Treeless habitats preferred where
there is ponding
No
No suitable habitat
occurs on site. Species
is considered ABSENT.

Mammals
Antrozous pallidus
pallid bat None/None G4/S3 N /A
Chaparral, Coastal scrub, Desert
wash, Great Basin grassland,
Great Basin scrub, Mojavean
desert scrub, Riparian woodland,
Sonoran desert scrub, Upper
No
No suitable habitat
occurs on site. Species
is considered ABSENT.

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35 Scientific Name
Common Name Federal/State Listing Global Rank/
State Rank
CA Rare
Plant
Rank
Habitats Observed
On Site? Potential to Occur
montane coniferous forest, Valley &
foothill grassland
Eumops perotis
californicus
western mastiff bat
None/None G4G5T4/S3S4 N/A
Chaparral, Cismontane woodland,
Coastal scrub, Valley & foothill
grassland
No
No suitable habitat
occurs on site. Species
is considered ABSENT.

Lasionycteris noctivagans
silver-haired bat None/None G4/S3S4 N/A Conifer ous, mixed coniferous and deciduous forest, old growth forests No
No suitable habitat
occurs on site. Species
is considered ABSENT.

Lasiurus cinereus
hoary bat None/None G3G4/S 4 N/A
Broadleaved upland forest,
Cismontane woodland, Lower
montane coniferous forest, North
coast coniferous forest
No
No suitable habitat
occurs on site. Species
is considered ABSENT.

Lasiurus xanthinus
western yellow bat None/None G4G5/S 3 N/A Desert wash No No suitable habitat
occurs on site. Species
is considered ABSENT.

Neotoma lepida intermedia
San Diego desert woodrat None/None G5T3T 4/S3S4 N/A Coastal scrub No No suitable habitat
occurs on site. Species
is considered ABSENT.

Nyctinomops macrotis
big free-tailed bat None/None G5/S3 N /A
Rugged, rocky habitats in arid
landscapes; desert shrub,
woodlands, and evergreen forests
No
No suitable habitat
occurs on site. Species
is considered ABSENT.

Taxidea taxus
American badger None/None G5/S3 N /A
Alkali marsh, Alkali playa, Alpine,
Alpine dwarf scrub, Bog & fen,
Brackish marsh, Broadleaved
upland forest, Chaparral,
Chenopod scrub, Cismontane
woodland, Closed-cone coniferous
forest, Coastal bluff scrub, Coastal
dunes, Coastal prairie, Coastal
scrub, Desert dunes, Desert wash,
Freshwater marsh, Great Basin
grassland, Great Basin scrub,
Interior dunes, Ione formation,
Joshua tree woodland, Limestone,
Lower montane coniferous forest,
Marsh & swamp, Meadow & seep,
Mojavean desert scrub, Montane
dwarf scrub, North coast coniferous
forest, Oldgrowth, Pavement plain,
No
No suitable habitat
occurs on site.

Species is considered
ABSENT.

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36 Scientific Name
Common Name Federal/State Listing Global Rank/
State Rank
CA Rare
Plant
Rank
Habitats Observed
On Site? Potential to Occur
Redwood, Riparian forest, Riparian
scrub, Riparian woodland, Salt
marsh, Sonoran desert scrub,
Sonoran thorn woodland,
Ultramafic, Upper montane
coniferous forest, Upper Sonoran
scrub, Valley & foothill grassland
Plants/Vegetation
Atriplex parishii
Parish's brittlescale None/None G1G2/ S1 1B.1
Alkali playa, Chenopod scrub,
Meadow & seep, Vernal pool,
Wetland
No
No suitable habitat
occurs on site. Species
is considered ABSENT.

Berberis nevinii
Nevin's barberry Endangered/Endangered G1/S1 1 B.1 Chaparral, Cismontane woodland, Coastal scrub, Riparian scrub No
No suitable habitat
occurs on site. Species
is considered ABSENT.

Calochortus clavatus var.
gracilis
slender mariposa-lily
None/None G4T2T3/ S2S3 1B.2 Chaparral, Coastal scrub, Valley & foothill grassland No
No suitable habitat
occurs on site. Species
is considered ABSENT.

Calochortus plummerae
Plummer's mariposa-lily None/None G4/S4 4 .2
Chaparral, Cismontane woodland,
Coastal scrub, Lower montane
coniferous forest, Valley & foothill
grassland
No
No suitable habitat
occurs on site. Species
is considered ABSENT.

Calystegia felix
lucky morning-glory None/None G1Q/S1 1 B.2
Meadows, Seep, riparian scrub ,
associated with wetlands and
marshes
No
This species is
considered extirpated
from Los Angeles
County.

Centromadia parryi ssp.
australis
southern tarplant
None/None G3T2/S2 1B.1
Wetlands, salt-marsh, vernal pools,
valley grassland and freshwater
wetlands
No
No suitable habitat
occurs on site. Species
is considered ABSENT.

Chorizanthe parryi var.
fernandina
San Fernando Valley
spineflower
None/Endangered G3T1/S1 1B.1 Coastal scrub, Valley & foothill grassland No
No suitable habitat
occurs on site. Species
is considered ABSENT.

Dodecahema
leptoceras
slender- horned
spineflower
Endangered/Endangered G1/S1 1B.1 Chaparral, Cismontane woodland, Coastal scrub No
No suitable habitat
occurs on site. Species
is considered ABSENT.

Dudleya multicaulis
many- stemmed dudleya None/None G2/S2 1 B.2 Chaparral, Coastal scrub, Valley & foothill grassland No
No suitable habitat
occurs on site. Species
is considered ABSENT.

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37 Scientific Name
Common Name Federal/State Listing Global Rank/
State Rank
CA Rare
Plant
Rank
Habitats Observed
On Site? Potential to Occur
Horkelia cuneata var.
puberula
mesa horkelia
None/None G4T1/S1 1B.1 Chaparral, Cismontane woodland, Coastal scrub No
No suitable habitat
occurs on site. Species
is considered ABSENT.

Malacothamnus davidsonii
Davidson's bush-mallow None/None GNR/S2 1B .2 Chaparral, Cismontane woodland, Coastal scrub, Riparian woodland No
No suitable habitat
occurs on site. Species
is considered ABSENT.

Pseudognaphalium
leucocephalum
white rabbit- tobacco
None/None G4/S2 2 B.2 Chaparral, Cismontane woodland,
Coastal scrub, Riparian woodland No
No suitable habitat
occurs on site.

Species is considered
ABSENT.

Quercus Dumosa
Nuttall's scrub oak None/None G3/S3 1 B.1 Chapparal, sandy soils along the coast No
No suitable habitat
occurs on site.

Species is considered
ABSENT.

Ribes divaricatum var.
parishii
Parish's gooseberry
None/None G5TX/S X 1A Riparian, Coastal Sage Scrub,
Wetland No
No suitable habitat
occurs on site.

Species is considered
ABSENT.

Symphyotrichum
defoliatum
San Bernardino aster
None/None G2/S2 1B.2
freshwatermarsh, Freshwater
Wetlands, Coastal Sage Scrub,
Southern Oak Woodland
No This species is
considered extirpated.

Symphyotrichum greatae
Greata's aster None/None G2/S2 1 B.3 Chaparral, canyons No No suitable habitat
occurs on site.

Species is considered
ABSENT.

Insects
Bombus crotchii
Crotch bumble bee None/None G2/S1 S2 N/A Grasslands and shrublands , coastal sage scrub No
No suitable habitat
occurs on site. Species
is considered ABSENT.

Bombus pensylvanicus
American bumble bee None/None G3G4/S 2 N/A
Farmlands, Open Fields No
No suitable habitat
occurs on site. Species
is considered ABSENT.

Woodland and Forests
California Walnut
Woodland
California Walnut
Woodland
None/None G2/S2.1 N/A Cismontane woodland No
No suitable habitat
occurs on site. Habitat
type is considered
ABSENT.

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38 Scientific Name
Common Name Federal/State Listing Global Rank/
State Rank
CA Rare
Plant
Rank
Habitats Observed
On Site? Potential to Occur
Southern Coast Live Oak
Riparian Forest
Southern Coast Live Oak
Riparian Forest
None/None G4/S4 N/A Riparian forest No
No suitable habitat
occurs on site. Habitat
type is considered
ABSENT.

Southern Cottonwood
Willow Riparian Forest
Southern Cottonwood
Willow Riparian Forest
None/None G3/S3.2 N/A Riparian forest No
No suitable habitat
occurs on site. Habitat
type is considered
ABSENT.

Southern Sycamore Alder
Riparian Woodland
Southern Sycamore Alder
Riparian Woodland
None/None G4/S4 N/A Riparian woodland No
No suitable habitat
occurs on site. Habitat
type is considered
ABSENT.

Birds
Aimophila ruficeps
canescens
southern California rufous-
crowned
None/None G5T3/S4 N/A Dry Hillsides, canyons No
No suitable habitat
occurs on site. Habitat
type is considered
ABSENT.

Athene cunicularia
burrowing owl None/Candidate Endangered G4/S 2 N/A
Coastal prairie, Coastal scrub,
Great Basin grassland, Great Basin
scrub, Mojavean desert scrub,
Sonoran desert scrub, Valley &
foothill grassland
No
No suitable habitat
occurs on site. Species
is considered ABSENT.

Coturnicops
noveboracensis
yellow rail
None/None G4/S2 N /A Wet Meadows and marshes with
shallow waters No
Site lacks fresh and
brackish sedge-filled
marshes this species
requires. Species is
considered Absent.

Empidonax traillii extimus
southwestern willow
flycatcher
Endangered/Endangered G5T2/S3 N/A Riparian woodland No
No suitable habitat
occurs on site. Species
is considered ABSENT.

American peregrine falcon Delisted/Delisted G4T4/ S3S4 N/A Variety, nest in other birds nests and
on indentation on a cliff side of
human made structures.

No
No suitable nesting
habitat occurs on site.

River provides suitable
foraging habitat.

Species has LOW

POTENTIAL TO OCCUR
ON SITE.

Polioptila californica
californica Threatened/None G4G5T3 Q/S2 N/A Coastal bluff scrub, Coastal scrub No No suitable habitat occurs on site.

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39 Scientific Name
Common Name Federal/State Listing Global Rank/
State Rank
CA Rare
Plant
Rank
Habitats Observed
On Site? Potential to Occur
coastal California
gnatcatcher
Species is considered
ABSENT.

Riparia riparia
bank swallow None/Threatened G5/S3 N/A R iparian, Coastal No Bank swallows are
extirpated from
southern California.

No suitable mud
banks exists for their
nesting habitat.

Species is considered
ABSENT.

Vireo bellii pusillus
least Bell's vireo Endangered/Endangered G5T2/S3 N/A Riparian forest, Riparian scrub, Riparian woodland No
No suitable habitat
occurs on site.

Species is considered
ABSENT.

Mollusks
Glyptostoma gabrielense
San Gabriel chestnut None/None G2/S3 N /A
Aquatic, Riparian canyons,
endemic to the San G abriel
Mountains near Pasadena,
requires moist rip arian canyons or
other areas with seasonal
moisture.

No
This species requires
moist, rocky hillsides
and is limited to an
“island” habitat in the
San Gabriel Mountains.

No habitat is found
onsite. Species is
considered ABSENT.

Gonidea angulate
western ridged mussel None/None G3/S1 S2 N/A Aquatic No The Los Angeles River
Channel may provide
suitable habitat for this
species. However, the
CNDDB considers this
species’ presence as
Extirpated. Species is
considered ABSENT.

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40 Attachment 3 – Site Photographs
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34 Attachment 3 – Site Photographs

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Attachment 4- Jurisdictional Delineation
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The Garden River Bridge at the Los Angeles River

City Glendale and City of Los Angeles, Los Angeles County, California

Jurisdictional Delineation Report

Prepared for:

City of Glendale
Public Works Engineering Division
613 E. Broadway
Glendale, CA 91206

Prepared by:

Ruth Villalobos & Associates, Inc.
3602 Inland Empire Blvd, Ste C310
Ontario, CA 91764
Contact: Miranda Villalobos
909.245.1129 Office
909.241.7433 Mobile

February 2023
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CONTENTS

1.0 Introduction ......................................................................................................................... 1

1.1 Project Location .............................................................................................................. 1

1.2 P roject Description ......................................................................................................... 4

2.0 Regulatory Background ........................................................................................................ 4

2.1 Applicable Aquatic Resource Protection Regulations..................................................... 4 Clean Water Act (33 U.S.C. 1344 et seq.) ................................................................................ 4 Porter-Cologne Water Quality Control Act.............................................................................. 5 California Fish and Game Code Section 1600-1602 ................................................................ 6

3.0 Methods ............................................................................................................................... 6

4.0 Results .................................................................................................................................. 7

4.1 Hydrology ........................................................................................................................ 7

4.2 Topography And Soils ..................................................................................................... 7

4.3 Site Conditions .............................................................................................................. 10

4.4 Vegetation/Land Use .................................................................................................... 10

4.5 Federal and State Jurisdictional Resources .................................................................. 13

6.0 Conclusion .......................................................................................................................... 17

7.0 References..................................................................................................................... 18

LIST OF FIGURES
Figure 1 – Regional Vicinity Map
Figure 2 – Site Vicinity Map
Figure 3 – HUC Map
Figure 4 – Soils Map
Figure 5 – Vegetation/Land Use Types Map
Figure 6 – USACE & RWQCB Jurisdiction Map
Figure 7 – CDFW Jurisdiction Map

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LIST OF TABLES
Table 1 – Summary of Jurisdictional Areas

ATTACHMENTS
Attachment 1 – Site Photographs
Attachment 2 – Arid West Ephemeral and Intermittent Streams OHWM Datasheet

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1 1.0 I NTRODUCTION
Ruth Villalobos & Associates, Inc. (RVA) conducted a jurisdictional delineation for the proposed Garden River Bridge Project (Project) in Los Angeles County, California. The delineation was performed to identify areas anticipated to be jurisdictional under the U.S. Army Corps of Engineers (USACE) pursuant to Section 404 of the Clean Water Act; the Regional Water Quality Control Board (RWQCB) pursuant to Section 401 of the Clean Water Act and the Porter-Cologne Act; and streambed and riparian habitats under California Department of Fish and Wildlife (CDFW) pursuant to California Fish and Game Code (Section 1602). This information is necessary to evaluate potential jurisdictional impacts and permit requirements associated with the Project and can be used by the agencies to assess Project conformance with State and Federal regulations.

1.1 P ROJECT LOCATION
The Project would span the LA River at approximately LA River Mile 31, latitude 34.1563 o and longitude -118.2823o. The proposed Project would extend from the City on the north side of the LA River to the City of Los Angles on the south side. The bridge and associated connections to the existing bicycle/pedestrian trails along the LA River would be constructed within Assessor’s Parcel Numbers (APN) 5593- 001-900, 5593-002-917, 5593- 002-916, 5593- 002-270, 5627- 020- 907, and 5627-020-908. The proposed Project is located within the U.S. Geological Survey (USGS)

7.5-minute Burbank quadrangle in Section 00, Township 1 North, Range 13 west. Located just north of where Interstate Highway 5 intersects with State Highway 134, the proposed bridge would serve as a point of connection across the LA River from the corner of Flower Street and Fairmont Avenue on the north side of the LA River (City of Glendale), to North Zoo Drive in Griffith Park on the south side of the LA River (City of Los Angeles) (see Figure 1 – Regional Vicinity Map and Figure 2 – Site Vicinity Map).

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GLENDALE GARDEN RIVER BRIDGE PROJECT
Si
te Vicinity Map
Figure 2
USGS The National Map: National Boundaries Dataset, 3DEP Elevation Program, Geographic Names Information S
ystem, National Hydrography
Dataset, National Land Cover Database, National Structures Dataset, and National Transportation Dataset; USGS Global Ecosystems; U.S. Census Bureau TIGER/Line data; USFS Road data; Natural Earth Data; U.S. Department of State HIU; NOAA National Centers for Environmental Information. Data refreshed October 3, 2025.

Legend
Project Work Area Limits
0 0.2 0.4
Miles
¯
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4 1.2 P ROJECT DESCRIPTION
The City of Glendale, in partnership with the City of LA, proposes the construction of a three- span, curvilinear, landscaped bridge for use by pedestrians, bicyclists, and maintenance vehicles.

The intent of this multi-community resource is to increase ac cess to Glendale Narrows Riverwalk, a
nd Griffith Park; to improve connections; and to increase the safety of paths used for pedestrians an d c yclists. Dedicated access across the LA River at this key location would improve public safety and accessibility t o important community resources by creating a connectio n between Glendale and Los Angeles across the LA River for pedestrians and cyclists.

The proposed bridge would be concrete with two supporting piers in the Los Angeles River. It would feature extensive landscaping on the approaches, as well as on the bridge itself, and is thus named the “Garden River Bridge.” A number of raised and in-ground planting beds would create dedicated zones for bicycle and pedestrian circulation, shade structures, canopied seating areas, dispersed gathering spaces, and scenic views of the LA River.

The LA River Channel is a U.S. Army C orps of Engineers (USACE)-built flood risk manageme nt facility, in which USACE holds primary authority over any proposed changes. The City of LA owns, operates, and maintains the south side of the LA River, located within the southern portion of the proposed Project area ; also within this area, a fifteen -fo ot easement is held by Souther n California Edison (SCE). The LA River channel limits are owned, operated, and managed by the City of LA; the City of Glendale would enter into an operations and management agreement for the proposed Project. On the north bank of the LA River, parcels within the northern portion of the proposed Project limits are owned by the City of LA, the City of Glendale, and the Los Angeles County Flood Control District (LACFCD). Furthermore, easements that cross the proposed Action ar
ea on the northern side are held by the City of Glendale for poles, sewers and structures, and the Riverwalk pedestrian/bike trail.

2.0 R EGULATORY BACKGROUND
Several regulations have been e stablished b y Federal, State, and local ag encies t o protect and conserve aquatic resources. The descriptions below provide a brief overview of agency re
gulations that may be applicable t o the Project. Regulatory a gencies make the final determination of whether a project requires authorization pursuant to these regulations.

2.1 A PPLICABLE AQUATIC RESOURCE PROTECTION REGULATIONS CLEAN WATER ACT (33 U.S.C. 1344 ET SEQ.)
Section 404 of the Clean Water Act regulates the discharge of dredged or fill material into waters of the United States, i ncluding wetlands. The U.S. E nvironmental Protection Agency ( USEPA) promulgated Section 404(b)(1) g uidelines (40 C FR P art 230); ho wever, the USACE R egulatory Program evaluates and issues permits for proposed discharges i nto waters of the United States.

Section 401 of the Clean Water Act requires that applicants for federal permits or licenses provide certification from the state that any discharges will comply with state-established water quality standard requirements. Applicants/Requestors must obtain a Section 401 certification or waiver EXHIBIT 5
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5 for the proposed action before USACE can authorize a permit under Section 408 and Section 404.

EC 1165-2-220 specifies that USACE will coordinate internally to ensure that the Section 404 permit and the Section 408 Permissions are consistent.

Waters of the U.S.

On December 30, 2022, the USEPA and USACE announced the final “Revised Definition of ‘Waters of the United States’” rule. On January 18, 2023, the rule was published in the Federal Register , with the rule going into effect on March 20, 2023. In this rule , consistent with the general framework of the 1986 regulations, the USEPA and USACE interpret the term “waters of the United States” to include (40 C.F.R. §120.2(a)(1)-(5):
• Traditional navigable waters , the territorial seas, and interstate waters (i.e., paragrap h (a)(1) waters)
• Impoundments of “waters of the United States” (i.e., paragraph (a)(2) impoundments) • “Tributaries” to traditional navigable waters, the territorial seas, interstate waters, or paragraph (a)(2) impoundments when tributaries meet either the relatively permanent standard or the significant nexus standard (i.e., jurisdictional tributaries) • Wetlands “adjacent ” t o paragraph (a)(1) waters; wetlands adjacent to and with a continuous surface connection to relatively permanent paragraph (a)(2) impoundments or jurisdictional tributaries when the jurisdictional tributaries meet the relatively permanent standard; and wetlands adjacent to paragraph (a)(2) impoundments or jurisdictional tributaries when the wetlands meet the significant nexus standard (i.e., jurisdictional adjacent wetlands)
• Intrastate lakes and ponds, streams or wetlands not identified in paragraphs (a)(1) through (4) that meet either the relatively permanent standard or the significant nexus standard (i.e., paragraph (a)(5) waters)
P

ORTER-COLOGNE WATER QUALITY CONTROL ACT
The Porter-Cologne Water Quality Control Act (Water Code Section 13000 et seq.) provides for statewide coordination of water quality regulations. The State Water Resources Control Board was established as the statewide authority and nine separate RWQCBs were developed to oversee water quality on a day -to-day basis. The RWQCB is the primary agency responsible for protecting water quality in California. As discussed above, the RWQCB regulates discharges to surface waters under the federal CWA. In addition, the RWQCB is responsible for administerin g the Porter-Cologne Water Quality Control Act
Pursuant to the Porter-Cologne Water Quality Control Act, the state is given authority to regulate waters of the state, which are defined as any surface water or groundwater, including salin e waters. As such, any person proposing to discharge waste into a water body that could affect its water quality must first file a Report of Waste Discharge if Section 404 is not required for the activity. “Waste” is partially defined as any waste substance associated with human habitation, including fill material discharged into water bodies .

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6 CALIFORNIA FISH AND GAME CODE SECTION 1600-1602
Pursuant to Division 2, Chapter 6, Section 1602 of the California Fish and Game Code (CFGC), CDFW regulates all diversions, obstructions, or changes to the natural flow or bed, channel or bank of any river, stream or lake that supports fish or wildlife. A Notification of Lake or Streambed Alteration must be submitted to CDFW for “any activity that may substantially divert or obstruct the natural flow or substantially change the bed, channel, or bank of any river, stream, or lake.” CDFW has jurisdiction over riparian habitats associated with watercourses and wetland habitats supported by a river, lake, or stream. Jurisdictional waters are delineated by the outer edge of riparian vegetation (i.e., drip line) or at the top of the bank of streams or lakes, whichever is wider. CDFW jurisdiction does not include tidal areas or isolated resources. CDFW reviews the proposed actions and, if necessary, submits (to the applicant) a proposal that includes measures to protect affected fish and wildlife resources. The final proposal that is mutually agreed upon by CDFW and applicant is the Lake or Streambed Alteration Agreement .

3.0 M ETHODS
Prior to the on-site delineation, RVA biologists conducted a review of the U.S. Fish and Wildlife Service (USFWS) National Wetlands Inventory (NWI) and geographic information systems (GIS) datasets of mapped California Blue Line Streams to assist in determining the potential locations of jurisdictional aquatic resources. Google Earth Pro aerial imagery was also utilized to assess current and historic presence or absence of flow in the Project area.

RVA biologists Miranda Villalobos and Justinne Manahan conducted the jurisdictional delineation field visit on December 20, 2022 from approximately 9:30am to 11:30am. Field conditions were sunny, cool, and breezy, with temperatures ranging from 40 degrees Fahrenheit (°F) to 55°F. The Project survey area included the proposed Project site work area limits, with an approximately 100-foot buffer.

Lateral limits of non -wetland waters of the U.S./State for USACE and RWQCB were identified using field indicators of an ordinary high water mark (OHWM) as described in A Field Guide to the Identification of the Ordinary High Water Mark (OHWM) in the Arid West Region of the Western United States (USACE 2008). For each feature exhibiting the potential presence of an OHWM, RVA biologists completed a 2010 Arid West Ephemeral and Intermittent Streams OHWM Datasheet following the guidance provided in the Updated Datasheet for the Identification of the Ordinary High Water Mark (OHWM) in the Arid West Region of the Western United States (USACE 2010).

CDFW potential jurisdictional boundaries were determined based on the presence of streambed and associated riparian habitat and/or wetland areas. Streambeds considered within CDFW jurisdiction were delineated based on the definition of streambed as "a body of water that flows at least periodically or intermittently through a bed or channel having banks and supporting fish or other aquatic life. This includes watercourses having a surface or subsurface flow that supports riparian vegetation" (Title 14, Section 1.72). Riparian habitat refers to vegetation and habitat EXHIBIT 5
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7 associated with a stream. The CDFW jurisdictional habitat includes all riparian shrub or tree canopy that may extend beyond the banks of a stream.

While conducting the delineation, potentially jurisdictional features were recorded using a hand- held Trimble Geo 7x Global Positioning System (GPS) unit. Site conditions and photographs were documented utilizing a photograph application that marked the photos with the approximate latitude and longitude coordinates where each photo was taken. Plants were identified and catalogued in field notebooks and photographed with approximate locations noted.

4.0 R ESULTS

4.1 H YDROLOGY
The Project site is located within Los Angeles Watershed (HUC 1807105) (see Figure 3). The Project site is located within the Los Angeles River just upstream of the confluence of the L os Angeles River and Verdugo Wash. The Los Angeles River is a blue -line perennial stream that is designated as a Traditionally Navigable Water (TNW) for its entire length and flows for approximately 51 miles until it releases flows into the Pacific Ocean. The Los Angeles River at the location of the project site flows in a west to east direction. Flows observed within the channel during the time of survey were primarily from recent winter rain and urban runoff .

4.2 T OPOGRAPHY AND SOILS
Topography is relatively flat along the concrete -lined bottom of the Los Angeles River channel, the Glendale Narrows Riverwalk/trail to the north, and the Los Angeles River Bike Path and North Zoo Drive to the south.

The site’s elevational profile varies from north to south, with the elevation at approximately 450 feet (ft.) above mean sea level (AMSL) at the top of the channel at the Glendale Narrows Riverwalk/trail to the north, approximately 433 ft. AMSL along the bottom of the channel, and at approximately 456 ft. AMSL at the top of the channel at the Los Angeles River Bike Path to the south.

Figure 4 – Soils Map, provides an overview of soil types within the Project site. A review of the United States Department of Agriculture’s (USDA) Web Soil Survey indicates that Project site soils include:
• 1001: Urban land-Metz-Pico complex; 0 to 2 percent slopes • 1264: Xeropsamments, frequently flooded; 0 to 2 percent slopes • 1012: Urban land-Tujunga-Typic Xerothents, sandy substratum complex; 0 to 2 percent slopes

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Soi
ls Map
Figure 4
Flower
St
Flower St
Fairmont Ave
Zoo Dr
Griffith Park
Ferraro Fields
Zoo Dr
Playground
Esri Community Maps Contributors, County of Los Angeles, California State Parks, © OpenS
treetMap, Microsoft, Esri, TomTom, Garmin, SafeGraph,
GeoTechnologies, Inc, METI/NASA, USGS, Bureau of Land Management, EPA, NPS, US Census Bureau, USDA, USFWS, Microsoft, Vantor
Legend
Project Work Area Limits
1001: Urban land-Metz-Pico complex, 0 to 2
percent slopes.
1012: Urban land-Tujunga-Typic Xerorthents,
sandy substratum complex, 0 to 2 percent
slopes.
1264: Xeropsamments, frequently flooded, 0 to
2 percent slopes.
0 240 480
Feet
¯
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10 4.3 S ITE CONDITIONS
The Project site is located within urban areas within the cities of Glendale to the north and Los Angeles to the south, within Los Angeles County. On-site land uses are considered disturbed and naturally occurring habitats have been eliminated due to channelization and development alon g the Los Angeles River channel. The Project site is within a concrete -lined portion of the channel and is bordered by pavement trails and roads (the Glendale Narrows Riverwalk and Fairmont Street to the north; the Los Angeles River Bike Path and North Zoo Drive to the south) on both sides of the channel.

Within the study area, the Los Angeles River is confined by a half-trapezoidal (to the south), half- vertical concrete wall (to the north) channel. During the site visit, a moderately shallow level of water was present (about 2 inches ) with minimal sediment deposition and some algae growth present.

4.4 V EGETATION/LAND USE
Vegetation present in and around the proposed Project site is relatively sparse and reflects ornamental plantings (e.g., trees and shrubs along walkways and within planters) or occurrences of herbaceous weedy species. Five overall vegetation types/land use types were identified during the biological assessment: developed, developed – concrete-lined channel, open water (concrete-lined channel), native/landscaped, and western sycamore (see Figure 4 – Vegetation/Land Use Types Map and Table 1 below).

Developed
The proposed Project area is surrounded by paved and/or concreted developed areas, such as adjacent sidewalks/walkways, roads, and the paved walking/bike trails. These developed areas do not contain or support vegetation.

Open Water (Concrete -Lined Channel)
The low-flow portion of the concrete -lined, concrete -bottomed Los Angeles River channel is inundated with enough water to cover the surface of the channel bottom. No vegetation was observed within the open water areas of the channel.

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GLENDALE GARDEN RIVER BRIDGE PROJECT
Figure 5
Vegetation/Land Use Types Map
Flower St
Fairmont
Ave
Zoo Dr
Griffith Park
Ferraro Fields
Zoo Dr
Esri Community Maps Contributors, County of Los Angeles, California State Parks, © OpenStreetMap, Microsoft, Esri, TomT
om, Garmin, SafeGraph, GeoTechnologies, Inc, METI/NASA, USGS, Bureau of Land Management, EPA, NPS, US Census Bureau, USDA, USFWS, Microsoft, Vantor Legend
Project Work Area Limits
Developed
Developed - Concrete-
Lined Channel
Open Water (Concrete-
Lined Channel)
Native/Landscaped
Park Landscaping
Western Sycamore
(Platanus racemosa)
0 225 450
Feet
¯
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13 4.5 F EDERAL AND STATE JURISDICTIONAL RESOURCES
The survey area contains one drainage feature, the Los Angeles River, a concrete- lined flood control channel , a portion of which is located within the Project site work area limits . As di
scussed, t he Los Angeles River is a blue -line perennial stream that is designated as a Trad
itionally Navigable Water ( TNW) for its entire length and flows for approximately 51 mil es until it releases flows into the Pacific Ocean. Flows observed within the channel during the time of survey were primarily from recent winter r ain a nd urban runoff . No additional jurisdictional res
ources are within the study area boundaries.

This segment of the channelized L os Angeles River within the Project area exhibits physical evid
ence of an OHWM ; observed staining of the concrete side slopes indicate the OHW M is approximately 12 inches above the toe of the slope. Widths of the LA River within the Project work area limits average approximately 241.78 feet. USACE and RWQCB jurisdiction associated with the LA River within the Project work area limits total approximate ly

2.80 a cres (approximately 508.74 linear feet ) (Figure 6 – USACE/RWQCB Jurisdictional Map).

CDFW jurisdiction associated with the L os Angeles River within the Project work area limi ts ex
tends top of the c hannel, bank to bank . Due to the lack of soils and vegetation within the concrete channel, there is no associated riparian habitat present in this portion of the Los Angeles River. Bank to bank widths within CDFW jurisdiction were approximately 308.57 feet. CDFW jurisdiction totaled approximately 3.84 acres (approximately 641.63 linear fee t) of unvegetated streambed (Figure 7 – CDFW Jurisdictional Map ).

No State or Federal jurisdictional wetlands were observed within Project work area limits or within close proximity to work area limits. The closest area of the Los Angeles River channel exhibiting potential wetland features is located more than 300 ft. upstream of the Project work area limits and would not be impacted by Project activities. As described, the segment of the Los Angeles River channel associated with the Project site is c oncrete-lined and features mini mal v
egetation. Due to the concrete - line d nature of this segment of the channel, there were no suitable areas in which digging a test pit for potential wetland features was possible.

Please refer to the following table, Figure 5 – USACE/RWQCB Jurisdictional Map, and Figure 6 – CDFW Jurisdictional Map for a detailed s ummary of the f ederal and s tate jurisdictional areas.

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14 Table 1: Summary of Jurisdictional Areas
Jurisdictional
Feature
USACE
Jurisdiction
(acres)
RWQCB
Jurisdiction
(acres)
CDFW
Jurisdiction
(acres)
Length
(linear
feet)
Latitude/
Longitude
Class of
Aquatic
Resource
LA River 2.80 2.80 3.84 ~650 34.156321°/ -
118.282288°
Non-
Section 10 -
non
wetland
Total 2.80 2.80 3.84 ~650 n/a n/a
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Figure 6
USACE and RWQCB Jurisdiction
Fairmo
nt Ave
Zoo Dr
Zoo Dr
Esri Community Maps Contributors, County of Los Angeles, California State Parks, © OpenStreetMap, Microsoft, Esri, TomT
om, Garmin, SafeGraph, GeoTechnologies, Inc, METI/NASA, USGS, Bureau of Land Management, EPA, NPS, US Census Bureau, USDA, USFWS, Microsoft, Vantor EXHIBIT 5
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17 6.0 C ONCLUSION
As the Project would include both temporary and permanent impacts within jurisdictional waters of the U.S. and waters of the State , the Project would need to obtain a regulatory Section 404 Nationwide Permit, RWQCB Section 401 Water Quality Certification, and CDFW Section 1602 Streambed Alteration Agreement approvals prior to development of the site.

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18 7.0 R EFERENCES
California Department of Fish and Wildlife, 1994. Field Guide to Lake and Streambed Alteration Agreements Section 1600-1607 California Fish and Wildlife Code.

Natural Resources Conservation Service, April 2022. Hydric Soils List of California . (http://soils.usda.gov/use/hydric/)
U.S. Army Corps of Engineers, 2007. Practices for Documenting Jurisdiction under Section 404 of the CWA, Regional Guidance Letter 07 -01.

U.S. Army Corps of Engineers, 2008. A Field Guide to the Identification of the Ordinary High Water Mark in the Arid West Region of the Western United States.

U.S. Arm Corps of Engineers, 2010. Updated Datasheet for the Identification of the Ordinary High Water Mark (OHWM) in the Arid West Region of the Western United States.

U.S. Army Corps of Engineers, 2001. Minimum Standards for Acceptance of Preliminary Wetland Delineations.

U.S. Department of Agriculture, Natural Resources Conservation Service, Web Soil Survey. (http://websoilsurvey.nrcs.usda.gov/app/)
U.S. Fish and Wildlife Service, Department of Habitat and Resource Conservation, Wetland Geodatabase. (http://wetlandsfws.er.usgs.gov/NWI/index.html) U.S. Geological Survey, 7.5 Minute Series Topographic Quadrangles, Burbank, California EXHIBIT 5
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19 Attachment 1 – Site Photographs
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21 Attachment 2 – Arid West Ephemeral and Intermittent Streams OHWM Datasheet

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C U L T U R A L R E S O U R C E S A S S E S S M E N T Garden River Bridge Project
Glendale and Los Angeles, Los Angeles County , California Prepared for:

Ruth Villalobos
Ruth Villalobos & Associates, Inc.
3602 Inland Empire Blvd., Suite C310
Ontario, Ca 91764
Prepared by:

David Brunzell, M.A., RPA
BCR Consulting LLC
Claremont, California 91711
With Contributions By: Nicholas Shepetuk, B.A.

Project No. RVA2205
Data Base Information:

Type of Study: Cultural Resources Assessment
Resources: Glendale Narrows/Reach 3 Section of the L.A. River; L.A. River Channel Keywords: Glendale Narrows, Reach 3, Los Angeles River Channel USGS Quadrangle: 7.5-minute Burbank, California (1994)
March 30, 2026
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MANAGEMENT SUMMARY
BCR Consulting LLC (BCR Consulting) is under contract to Ruth Villalobos & Associates, Inc. to conduct a Cultural Resources Assessment of the Garden River Bridge Project (project) in the Cities of Glendale and Los Angeles , Los Angeles County, California. The work is being performed pursuant to the California Environmental Quality Act (CEQA). A cultural resources recor ds search, additional research, field survey, Sacred Lands File Search with the Native American Heritage Commission (NAHC), and paleontological overview were conducted for the project . The records search revealed that 14 cultural resource studies have taken place resulting in 18 cultural resources identified within a half- mile radius of the project site. Of the 14 previous studies, one has assessed the project site for cultural resources and one cultural resource (the Glendale Narrows segment of the Los Angeles River designated P -19-190897) has been previously identified within its boundaries. A [Draft] Regional Historic Context for Flood -Control Activities within Los Angeles County and an Architectural Assessment of Select Reaches of the Los Angeles River Channel, Los Angeles County, California prepared by Thompson et al. in 2022 was not available during the records search, but was provided by the U.S. Army Corps of Engineers. The eligibility of the Los Angeles River channel as a whole, was described in the Thompson et al. 2022 study, and recommended to be a presumed historic District (P - 19-190897) eligible for listing in the National Register of Historic Places (National Register) under Criteria A and C. The individual reaches of the Los Angeles River District, including Reach 3 in which the Project will occur, though not found individually eligible, were presumed contributing elements of the Los Angeles River historic District as previously defined. As a cultural resource eligible for National Register listing, the Los Angeles River is also eligible for registration on the California Register of Historical Resources and is therefore a significant historical resource under California Environmental Quality Act (CEQA).

During the research and field survey, BCR Consulting archaeologists identified the historic- period Glendale Narrows segment of the Los Angeles River , which is roughly coterminous with Reach 3 (approximately 7.4 miles in length) of the Los Angeles River constructed between 1938 and 1939 . The Los Angeles River has been determined eligible for National Register listing and as such is eligible for the California Register of Historical Resources (California Register) and a historical resource under CEQA . However, the proposed project will impact a tiny portion (approximately .06 percent) of the Glendale Narrows/ Reach 3 segment of the Los Angeles River. Based on the small percentage of the segment that will be subject to direct impacts , BCR Consulting recommends that the proposed project , a pedestrian/bicycle bridge over the Glendale Narrows, will not result in a substantial adverse change to a historical resource which can cause a significant effect on the environment under CEQA. Furthermore, the bridge abutments would be constructed to be higher than the existing elevation of the channel walls and would not touch the levee walls. Although the integrity of setting would be minimally impacted by the installation of the bridge, the setting of the Glendale Narrows/ Reach 3 segment has already been impacted by subsequent development of the surrounding neighborhoods and by the Interstate 5 and State Route 134 freeway bridges over the Los Angeles River that are visible from the proposed project site and were constructed after the period of significance. As such, the proposed project will not introduce any elements (e.g., bridges over the river) to the setting that are not already present , and the proposed project will not alter the ability of the EXHIBIT 6
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Glendale Narrows/Reach 3 to contribute to a larger district . Based on these results, BCR Consulting recommends that the project as proposed will not result in a significant impact to a historical resource (under CEQA). No mitigations are recommended for the current undertaking. No archaeological resources were identified during this assessment.

Disturbances associated with the construction of the Reach 3 of the Los Angeles River , recent development of bike and walking paths, recent reconfiguration of Flower Street adjacent to the north end of the project site, and modern development of athletic fields adjacent to the south side of the project site have disrupted soil beyond depths at which buried cultural resources are likely. Also, no buried discoveries have occurred in the vicinity of the project site. As a result, the potential to encounter in -situ remains associated with significant archaeological materials during project-related excavation is low.

While the current study has not indicated sensitivity for unknown cultural resources within the project boundaries, ground disturbing activities always have the potential to reveal buried deposits not observed on the surface during previous surveys. Therefore, a list of recommendations is provided in the Recommendations section, based on the City of Los Angeles’ Best Management Practices for Inadvertent Discovery of Archaeological and Paleontological Resources.

Sacred Lands File search results with the NAHC were negative. The NAHC has recommended contacting tribes listed (Appendix D) for more information. The lead CEQA agency will initiate Assembly Bill (AB) 52 Native American Consultation for the project.

Therefore, the results of the consultation are not provided in this report. However, this report may be used during the consultation process, and BCR Consulting staff is available to answer questions and address concerns as necessary.

If human remains are encountered during the undertaking, State Health and Safety Code Section 7050.5 states that no further disturbance shall occur until the County Coroner has made a determination of origin and disposition pursuant to Public Resources Code Section 5097.98. The County Coroner must be notified of the find immediately. If the remains are determined to be prehistoric, the Coroner will notify the Native American Heritage Commission (NAHC), which will determine and notify a Most Likely Descendant (MLD).

With the permission of the landowner or his/her authorized representative, the MLD may inspect the site of the discovery. The MLD shall complete the inspection within 48 hours of notification by the NAHC.

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TABLE OF CONTENTS

MANAGEMENT SUMMARY ................................................................................................... ii INTRODUCTION ..................................................................................................................... 1 PROJECT LOCATION AND DESCRIPTION .................................................................... 1 NATURAL SETTING ............................................................................................................... 1 CULTURAL SETTING ............................................................................................................. 3 PREHISTORIC CONTEXT ............................................................................................... 3 ETHNOGRAPHY .............................................................................................................. 3 HISTORY .......................................................................................................................... 4 PERSONNEL .......................................................................................................................... 7 METHODS .............................................................................................................................. 7 RESEARCH ...................................................................................................................... 8 FIELD SURVEY ................................................................................................................ 8 RESULTS................................................................................................................................ 8 RESEARCH ...................................................................................................................... 8 FIELD SURVEY ................................................................................................................ 9 SIGNIFICANCE EVALUATIONS .......................................................................................... 10 SIGNIFICANCE CRITERIA ............................................................................................. 10 NATIONAL AND CALIFORNIA REGISTER EVALUATIONS .......................................... 10 RECOMMENDATIONS ......................................................................................................... 11 REFERENCES ...................................................................................................................... 16

FIGURES
1: Project Location Map ........................................................................................................ 2

TABLES
A: Cultural Resources and Reports Within One Half-Mile of the Project ............................... 9

APPENDICES
A: RECORDS SEARCH BIBLIOGRAPHY
B: DEPARTMENT OF PARK AND RECREATION 523 FORMS
C: DETAILED PROJECT EXHIBIT
D: NATIVE AMERICAN HERITAGE COMMISSION SACRED LANDS FILE SEARCH E: PROJECT PHOTOGRAPHS
F: RESUMES OF PROJECT PERSONNEL
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1 INTRODUCTION
BCR Consulting LLC (BCR Consulting) is under contract to Ruth Villalobos & Associates to complete a Cultural Resources Assessment of the Garden River Bridge Project (project) in the Cities of Los Angeles and Glendale, Los Angeles County, California . The work is being performed pursuant to the California Environmental Quality Act (CEQA).

PROJECT LOCATION AND DESCRIPTION
The project site is located in a non-sectioned portion of Township 1 North, Range 13 West, San Bernardino Baseline and Meridian, in the Cities of Los Angeles and Glendale . It is depicted on the United States Geological Survey (USGS) Burbank, California (1994) 7.5 - minute topographic quadrangle (Figure 1). A detailed project exhibit is provided as Appendix C. The project site consists of areas in which impacts from a proposed project to potential historical resources could occur. The project includes construction of an approximately 350- foot long three -span curvilinear pedestrian/bicycle bridge structure that spans the Los Angeles River with canopied seating areas. The bridge will be constructed using steel and concrete. It will be supported by two piers located in the river. Safety railings, trash cans, interpretive signs, pedestrian safety lighting, and other features will also be installed. The maximum height of the bents which will support the bridge from the floor of the channel will be 23 feet and six inches . The area of ground disturbance on the channel floor has been calculated at approximately 8,500 square feet. Staging and access will all take place within the project site boundaries depicted in Figure 1.

NATURAL SETTING
The local geologic region coincides with the physiographic area known as the Los Angeles Basin. It is characterized as a transverse -oriented lowland basin and coastal plain approximately 50 miles long and 20 miles wide. The basin originated as a deep marine trough during the Pliocene (7 -2 million years ago) that eventually filled with shallow water fossil bearing sediments. By the beginning of the Pleistocene (after 2 million years ago) uplifting created the series of plains and mesas along the coast that now characterize the area (Lambert 1994, Mendenhall 1905, Woodford et al. 1954). Local rainfall ranges from 5 to 15 inches annually (Jaeger and Smith 1971:36 -37). The project region comprises a portion of the Los Angeles River channel, which (locally channelized and paved) flows from west to east. Although much of the native vegetation has been locally removed, c haparral, coastal sage scrub, and riparian vegetation communities dominate regional flora. Key native plants include black sage, California brittlebush, California buckwheat, California sagebrush, deerweed, golden yarrow, laurel sumac, lemonadeberry, poison oak, purple sage, sticky monkeyflower, sugar bush, toyon, white sage, coastal century plant, coastal cholla, prickly - pear cactus, arroyo willow, and bulrush. These plants were utilized by local animal species, kangaroo rats, California horned lizard, orange -throated whiptail, horned lizard, brown - headed cowbird, California gnatcatcher, California quail, cactus wren, darkling beetle, harvester ant, and Palos Verdes blue butterfly (Williams et al. 2008:117,122). Peripheral species included deer, and various rodents, rabbits, and birds -many of which were utilized by prehistoric and historic inhabitants (see Lightfoot and Parrish 2009).

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3 CULTURAL SETTING
Prehistoric Context
The local prehistoric cultural setting has been organized into many chronological frameworks (see Warren and Crabtree 1986; Bettinger and Taylor 1974; Lanning 1963; Hunt 1960; Wallace 1958, 1962, 1978; Campbell and Campbell 1935), although there is no definitive sequence for the region. The difficulties in establishing cultural chronologies for Los Angeles County are a function of its enormous size and the small amount of archaeological excavations conducted there. Moreover, throughout prehistory many groups have occupied the area and their territories often overlap spatially and chronologically resulting in mixed artifact deposits. Due to dry climate and capricious geological processes, these artifacts rarely become integrated in -situ. Lacking a milieu hospitable to the preservation of cultural midden, local chronologies have relied upon temporally diagnostic artifacts, such as projectile points, or upon the presence/absence of other temporal indicators, such as groundstone. Such methods are instructive, but can be limited by prehistoric occupants’ concurrent use of different artifact styles, or by artifact re - use or re -sharpening, as well as researchers’ mistaken diagnosis, and other factors (see Flenniken 1985; Flenniken and Raymond 1986; Flenniken and Wilke 1989). Recognizing the shortcomings of comparative temporal indicators, this study recommends review of Warren and Crabree (1986), who have drawn upon this method to produce a commonly cited and relatively comprehensive chronology.

Ethnography
Although no previously recorded prehistoric sites have established a local prehistoric ethnographic affiliation, the project site vicinity is situated within traditional Gabrielino territory. The Gabrielino consisted of semi -nomadic hunter -gatherers who spoke a variation of the Takic language subfamily. The Gabrielino probably first encountered Europeans when Spanish explorers reached California's southern coast during the 15th and 16th centuries (Bean and Smith 1978; Kroeber 1925). The first documented encounter, however, occurred in 1769 when Gaspar de Portola's expedition crossed Gabrielino territory (Bean and Smith 1978). Other brief encounters took place over the years, and are documented in McCawley 1996 (citing numerous sources). The Gabrielino name has been attributed by association with the Spanish mission of San Gabriel, and refers to a subset of people sharing speech and customs with other Cupan speakers (such as the Juaneño/Luiseño/Ajachemem) from the greater Takic branch of the Uto -Aztecan language family (Bean and Smith 1978). Gabrielino villages occupied the watersheds of various rivers (locally including the Santa Ana) and intermittent streams. Chiefs were usually descended through the male line and often administered several villages.

Gabrielino society was somewhat stratified and is thought to have contained three hierarchically ordered social classes which dictated ownership rights and social status and obligations (Bean and Smith 1978:540 -546). Plants utilized for food were heavily relied upon and included acorn -producing oaks, as well as seed -producing grasses and sage.

Animal protein was commonly derived from rabbits and deer in inland regions, while coastal populations supplemented their diets with fish, shellfish, and marine mammals (Boscana 1933, Heizer 1968, Johnston 1962, McCawley 1996). Dog, coyote, bear, tree squirrel, pigeon, dove, mud hen, eagle, buzzard, raven, lizards, frogs, and turtles were specifically not utilized as a food source (Kroeber 1925:652).

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4 History
Historic-era California is generally divided into three periods: the Spanish or Mission Period (1769 to 1821), the Mexican or Rancho Period (1821 to 1848), and the American Period (1848 to present).

Spanish Period. The first European to pass through the area is thought to be a Spaniard called Father Francisco Garces. Having become familiar with the area, Garces acted as a guide to Juan Bautista de Anza, who had been commissioned to lead a group across the desert from a Spanish outpost in Arizona to set up quarters at the Mission San Gabriel in 1771 near what today is Pasadena (Beck and Haase 1974). Garces was followed by Alta California Governor Pedro Fages, who briefly explored the region in 1772. Searching for San Diego Presidio deserters, Fages had traveled through Riverside to San Bernardino, crossed over the mountains into the Mojave Desert, and then journeyed westward to the San Joaquin Valley (Beck and Haase 1974).

Mexican Period. In 1821, Mexico overthrew Spanish rule and the missions began to decline. By 1833, the Mexican government passed the Secularization Act, and the missions, reorganized as parish churches, lost their vast land holdings, and released their neophytes (Beattie and Beattie 1974).

American Period . The American Period, 1848 –Present, began with the Treaty of Guadalupe Hidalgo. In 1850, California was accepted into the Union of the United States primarily due to the population increase created by the Gold Rush of 1849. The cattle industry reached its greatest prosperity during the first years of the American Period.

Mexican Period land grants had created large pastoral estates in California, and demand for beef during the Gold Rush led to a cattle boom that lasted from 1849 –1855. However, beginning about 1855, the demand for beef began to decline due to imports of sheep from New Mexico and cattle from the Mississippi and Missouri Valleys. When the beef market collapsed, many California ranchers lost their ranchos through foreclosure. A series of disastrous floods in 1861 –1862, followed by a significant drought further diminished the economic impact of local ranching. This decline combined with ubiquitous agricultural and real estate developments of the late 19 th century, set the stage for diversified economic pursuits that have continued to proliferate to this day (Beattie and Beattie 1974; Cleland 1941).

Water Resources in Southern California. Upon Spanish settlement of California in the eighteenth century, water was recognized as a vital resource and water rights were written into Spanish law. The first Spanish missionaries and settlers constructed a dam across the San Diego River, linking the resulting reservoir to the Mission San Diego de Alcala by way of a six -mile aqueduct and creating the first irrigation and domestic water system built in the west. Similarly, the Spanish in Los Angeles built a dam across the Los Angeles River in 1781 to serve their prospective pueblo.

Prior to the discovery of gold at Sutter’s Mill in 1848, settlements throughout the state consisted of scattered missions and ranches with most streams and rivers running uncontrolled. Simple irrigation systems were constructed for individual settlements. As thousands of eastern immigrants from around the world flocked to California during and EXHIBIT 6
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5 after the Gold Rush, water resources were more extensively deve loped. Miners built hundreds of miles of flumes to sluice gold in streams, creeks, and rivers. Gold became scarce by the 1860s, and many residents of the newly admitted state of California turned to farming which heightened the demand for water. In subsequent decades the expansion of local agriculture was accompanied by higher populations and a diversified economy.

The 1881 completion of the Southern Pacific Railroad and the 1885 completion of the Santa Fe Railroad connected the region from the Mexican border as far north as Ventura and as far inland as Arizona. This resulted in an influx of settlers and land speculators who began subdividing and developing local tracts (Brock et. al. 199 2:19). The 1887 passage of the Wright Irrigation Act allowed formation and management of irrigation districts financed and operated by localities throughout California, stimulating agricultural growth.

This measure assisted agricultural prospects in Southern California and incentivized settlement on the farms and homesteads that had already been platted. Groundwater was pumped through artesian wells , and open canals were commonly used to transport water as early as the 1860s. By 1880, concrete ditches and pipes were commonly used to divert water from major rivers, and by the 1890s they had become standard in southern California. By 1900, stream flow from major rivers such as the Los Angeles, San Gabriel, Santa Ana, and San Diego Rivers, and their respective tributaries (including the Rio Hondo), was fully utilized. The swell of southern California’s population into the twentieth century necessitated more creative means of meeting growing water demands (Carle 2004:227; California Department of Water Resources 2020 ; Davis 1998; Harding 1960:2, 109; San Diego County Water Authority 2020).

In the early 1900s , state and municipal officials began to develop public works projects to diminish problems related to water conservation and frequent floods. In 1901, the state of California divert ed water from the Colorado River to farmlands in the Imperial Valley.

Later, the California Development Company unintentionally diverted heavy flood waters from the west bank of the Colorado River into the Salton Basin, creating the present -day Salton Sea (Water Education Foundation 2017). In 1913 the Los Angeles Aqueduct was successfully completed to supply water to Los Angeles from the Owens Valley on the eastern slope of the Sierra Nevada Mountains. Los Angeles would acquire more water and land rights from the Owens Valley in the early 1920s , expanding capacity of the new aqueduct (Carle 2004:228; Los Angeles Department of Water and Power 2007).

The rivers and washes of the Los Angeles Basin lose elevation quickly in their relatively short route from the mountains to the Pacific Ocean, and are therefore naturally prone to overtopping their banks. There were eight serious floods in the Los Angeles basin between 1815 and 1879 and nine more between 1884 and 1938 (Starr 1996:320). After the 1914 flood, the Los Angeles County Flood Control District (LAFCD) was formed in response to public outcry for protection from floods, to develop water conservation systems, and to enhance water-based recreational opportunities throughout the county (LAPW 2019). In 1934, Congress authorized $70 million of flood control spending on the San Gabriel and Los Angeles rivers and local tributaries, which the U.S. Army Corps of Engineers would use to design, build, and improve flood control systems (Starr 1996:321).

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6 and contain the flow of downstream water (Suburban Emergency Management Project 2006).

In the aftermath of the Great Depression, President Franklin Delano Roosevelt’s New Deal job programs enabled further expansion of water infrastructure projects. The Boulder Dam (later renamed the Hoover Dam) was built between 1931 and 1935 along the Nevada - Arizona border. It was intended for flood control and irrigation measures, as well as to generate hydroelectric power for Southern California. The Metropolitan Water District of Southern California, formed in 1928 and servicing the Los Angeles area, constructed the Colorado River Aqueduct in 1941. The channel directs water from Lake Havasu at the Arizona-California border to Lake Mathews in Riverside. It was routed through four dams and five pumping plants on its 242 -mile course (History 2018; M etropolitan Water District 2016). The postwar years saw an immense economic boom as people flocked to California for its climate and robust job market. The increased population and commerce in urban centers such as Los Angeles and San Diego would not be sustained by existing water conveyance systems. Groundwater basins were being rapidly depleted for the irrigation of vast acreage needed to produce food for a growing population. A drought in the 1940s and 1950s forced the Metropolitan Water District to absorb agencies from Ventura, San Diego, San Bernardino, and Riverside Counties, expanding their conveyance district to 5,200 square miles. The San Diego Water Company, formed in 1944, began claiming a share of Colorado River water resources in the late 1940s, and oversaw an expansion of pipelines into the 1950s and 1960s. In 1951, conversations began regarding a State Water Project under the California Department of Water Resources. Construction for the project began in 1957, and construction of the California Aqueduct, the channel bringing Northern California water south, began in 1961. With the help of the Metropolitan Water District, the first State Water Project conveyances to Southern California were made in 1973 (C alifornia Department of Water Resources 2020; Water Education Foundation 2017).

Southern Californian water resources in recent decades have seen extensive conservation measures and expansion of existing infrastructure. In 1970, the passage of CEQA and the California Endangered Species Act opened the door to mitigating negative effects of development on water resources. That same year, groundwater from the Owens Valley and diversions from Mono Basin filled a second barrel of the Los Angeles Aqueduct. The Federal Clean Water Act passed in 1973, which protected state -designated wild and scenic rivers. In 1991, the West Coast’s first sea water desalination plant was opened on Catalina Island. A period of drought from 1987 to 1993 caused member agencies under the Metropolitan Water District to diversify its water supplies through the Integrated Water Resources Plan. Enough water was preserved through conservation policies, water recycling, and recovery that it could fill a new Colorado River Aqueduct. A coastal branch of the State Water Project began supplying Santa Barbara County with water from San Luis Obispo County in 1997. In 2000, Diamond Valley Lake near Hemet, the largest reservoir in Southern California, provided a six -month emergency water supply for prolonged droughts, with water being supplied by the Colorado River and the State Water Project. Southern California’s water resources continue to undergo efforts of conservation and expansion today to meet needs of growing cities and drought concerns (Carle EXHIBIT 6
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7 2004:233; Metropolitan Water District of Southern California 2016; Water Education Foundation 2017).

The project site occupies the Glendale Narrows /Reach 3 segment of the Los Angeles River, which was channelized between 1938 and 1939. Ground water precluded a paved riverbed, and the Glendale Narrows segment was the only part of the river that was originally constructed with concrete banks and a natural bottom. The segment has occupied the same alignment since construction, but has been subject to maintenance and repaving in areas. The historic setting has been affected by the modern construction of athletic fields to the south, construction of Interstates 5 and 134 to the south, paved bicycle and walking paths, and the reconfiguration of Flower Street to the north (Slawson 2013).

PERSONNEL
David Brunzell, M.A., RPA acted as the Project Manager and Principal Investigator , and provided project oversight. Mr. Brunzell meets the U.S. Secretary of the Interio r Standards for Archaeology and for Architectural History . Mr. Brunzell also completed the cultural resources records search at the South Central Coastal Information Center (SCCIC), and performed additional research through various archives and repositories, and authored the technical report and Department of Park and Recreation (DPR) 523 forms for the current study with contributions by BCR Consulting Archaeological Crew Chief Nicholas Shepetuk, B.A. BCR Consulting Staff Historian George Brentner, B.A., completed the field survey. Staff resumes are provided as Appendix F.

METHODS
This work was completed pursuant to CEQA, the Public Resources Code (PRC) Chapter

2.6, Section 21083.2, and California Code of Regulations (CCR) Title 14, Chapter 3, Article 5, Section 15064.5. The pedestrian cultural resources survey was intended to locate and document previously recorded or new cultural resources, including archaeological sites, features, isolates, and historic -period buildings and structures , that exceed 45 years in age within defined project boundaries. The project site was examined using 15 meter transect intervals. This study is intended to determine whether cultural resources are located within the project boundaries, whether any cultural resources are significant pursuant to the above -referenced regulations and standards, and to develop specific mitigation measures that will address potential impacts to existing or potential resources. Tasks pursued to achieve that end include:

• Cultural resources records search to review studies conducted and the resulting cultural resources recorded within a one half-mile radius of the project boundaries • Additional research through various local and regional resources • Systematic pedestrian survey of the entire project site • Evaluation of California Register eligibility for any cultural resources discovered • Development of recommendations and mitigation measures for cultural resources documented within the project boundaries, following CEQA guidelines • Completion of DPR 523 forms for any cultural resources identified EXHIBIT 6
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8 • Vertebrate paleontology resources report through Professional Paleontologists of the Western Science Center in Hemet, California.

Research
Records Search. An archaeological records search was conducted at the SCCIC on November 17, 2022. This included a review of all recorded historic and prehistoric cultural resources, as well as a review of known cultural resources, and survey and excavation reports generated from projects located within one -half mile of the project site. In addition, a review was conducted of the National Register of Historic Places (National Register), documents and inventories from the California Office of Historic Preservation including the lists of the California Register of Historical Resources (California Register), California Historical Landmarks, California Points of Historical Interest, and Listing of National Register Properties, as included in the Built Environment Resources Directory (BERD).

Additional Research. BCR Consulting performed additional research through the U.S.

Army Corps of Engineers, Los Angeles County Assessor’s Office, General Land Office records of the Bureau of Land Management, and various internet resources. Los Angeles and Glendale City resources reviewed included the Historical Places LA Historic Resources Inventory, the list of Los Angeles City Landmarks and Historic -Cultural Monuments, and the Glendale Register of Historic Resources.

Field Survey
An intensive -level cultural resources field survey of the project site was conducted on November 15 , 2022 . Due to the developed and paved nature of the project site, reconnaissance archaeological survey methods were utilized, during which the visible ground surface along the northern and southern banks of the Los Angeles River were carefully inspected for evidence of archaeological resources. The small portion of the Glendale Narrows Segment of the Los Angeles River channel was recorded on DPR 523 forms. Digital photographs were taken at various points within the project site. These included overviews as well as detail photographs of all cultural resources. Cultural resources were recorded per the California OHP Instructions for Recording Historical Resources in the field using:
• Detailed note taking for entry on DPR 523 Forms (see Appendix B) • Hand-held Garmin Global Positioning systems for mapping purposes • Digital photography of all cultural resources (see Appendix B and E).

RESULTS
Research
Records Search. Data from the SCCIC revealed that 14 cultural resource studies have taken place resulting in 18 cultural resources identified within a one half-mile radius of the project. Of the 14 previous studies, one has assessed the project site for cultural resources, and one cultural resource (the Glendale Narrows /Reach 3 segment of the Los Angeles River designated P -19-190897) has been identified within its boundaries. The Glendale Narrows segment is roughly coterminous with Reach 3 (approximately 7.4 miles in length) of the Los Angeles River constructed between 1938 and 1939 as identified in EXHIBIT 6
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9 Thompson et al. 2022. The records search results are summarized in Table A and bibliographic details are provided in Appendix A.

Table A. Cultural Resources and Reports Located Within One-Half Mile of Project USGS

7.5 Min
Quad
Cultural Resources Within One-Half Mile of Project Studies Within One- Half Mile of Project
Burbank,
California
(1994)
P-19-175297: Griffith Park (Adjacent S)
P-19-188087: Pomona Valley Creamery (0.25 Miles SE)
P-19-190312: San Fernando Road Bridge (0.25 Miles E)
P-19-190599: General Aircraft Co Bldg (0.25 Miles E)
P-19-190600: AirGas Inc. Building (0.3 Miles E)
P-19-190601: ICC Co. Building (0.3 Miles E)
P-19-190602: R.A. Fisher Co (0.3 Miles E)
P-19-190603: Milford St. Industrial Historic Dist (0.4 Miles E) P-19-190604: Historic SFR, 801 Milford St (0.4 Miles E) P-19-190605: Van Heuklyn & Handy Cabinet Co (0.4 Miles E) P-19-190606: Van Heuklyn & Handy Cabinet Co (0.4 Miles E) P-19-190607: Modern Refrigerator Works (0.4 Miles E)
P-19-190608: Beverly Dairies Addition (0.4 Miles E)
P-19-190609: Historic SFR, 862 Grange St (0.25 Miles E) P-19-190610: Historic SFR, 866 Grange St (0.25 Miles E) P-19-190611: Historic SFR, 870 Grange St (0.25 Miles E) P-19-190612: Historic SFR, 874 Grange St (0.25 Miles E) P-19-190897: Glendale Narrows Section of the Los Angeles River* LA-2210, 3554, 3950,
6006, 6722, 6738,
7259, 7263, 7840,
8255, 8303, 10767,
10768, 12120
*Within Project Area
Field Survey
During the field survey Mr. Brentner carefully inspected the project site and identified a portion of the Glendale Narrows section of the Los Angeles River . This resource is described below , and DPR 523 Forms are included in Appendix B. No other cultural resources (including prehistoric or historic archaeological or historic architectural resources) were identified during the field survey. The project site and surrounding area have been subject to severe disturbances related to reconfiguration of Flower Street, construction of the channel, construction of the modern bike path and walkway , modern refuse dumping, the installation of transmission towers and streetlights, and by repeated flooding. Sediments, where visible, consist of sandy silt and comprise recent alluvium.

Vegetation is limited to seasonal grasses and imported trees. The Interstate 5 Bridge over the Los Angeles River (constructed between 1954 and 1964) is visible from the project site approximately one half -mile to the west, and the State Route 134 Bridge over the Los Angeles River (constructed between 1964 and 1972) is visible from the project site approximately one-quarter mile to the southeast (United States Department of Agriculture 1972, 1964, 1954).

The Glendale Narrows. The Glendale Narrows (roughly coterminous with Reach 3 of the Los Angeles River as defined in Thompson 2022) is a seven -mile section of the Los Angeles River. It is the only portion of the river which lacks a concrete bottom, although it does have concrete lined banks. The bottom could not be paved due to excessive groundwater forces and is instead natural and lined with river cobbles, alluvium, and a variety of vegetation. A series of small river islands have formed from the accumulation of alluvial sediment. These islands are mainly on the west and south sides of the narrows, as EXHIBIT 6
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10 well as in its middle at certain points. Bike paths sit atop both banks of the channel in this segment. This portion of the Los Angeles River channel was originally constructed between 1938 and 1939 as a response to the flood of March 3, 1938 (Slawson 2013).

SIGNIFICANCE EVALUATIONS
During the field survey, the portion of the Glendale Narrows/Reach 3 section of the Los Angeles River Channel was identified. CEQA call s for the evaluation and recordation of historic and archaeological resources. The criteria for determining the significance of impacts to cultural resources are based on Section 15064.5 of the CEQA Guidelines and Guidelines for the Nomination of Properties to the California Register. Properties eligible for listing in the California Register and subject to review under CEQA are those meeting the criteria for listing in the California Register, or designation under a local ordinance.

Significance Criteria
California Register of Historical Resources. The California Register criteria are based on National Register criteria. For a property to be eligible for inclusion on the California Register, one or more of the following criteria must be met:

1. It is associated with the events that have made a significant contribution to the broad patterns of local or regional history, or the cultural heritage of California or the U.S.;

2. It is associated with the lives of persons important to local, California, or U.S. history;

3. It embodies the distinctive characteristics of a type, period, region, or method of construction, represents the work of a master, possesses high artistic values; and/or

4. It has yielded, or has the potential to yield, information important to the prehistory or history of the local area, California, or the nation.

In addition to meeting one or more of the above criteria, the California Register requires that sufficient time has passed since a resource’s period of significance to “obtain a scholarly perspective on the events or individuals associated with the resources.” (CCR 4852 [d][2]). The California Register also requires that a resource possess integrity. This is defined as the ability for the resource to convey its significance through seven aspects:
location, setting, design, materials, workmanship, feeling, and association.

California Register Evaluation
The Los Angeles River, of which the Glendale Narrows Segment and roughly coterminous Reach 3 (defined in Thompson et al. 2022) constitute a portion, has been determined eligible for listing in the National Register by the U.S. Army Corps of Engineers as a “presumed” historic district and is therefore also eligible for listing in the California Register (Thompson et al. 2022:4.15, citing Polanco 2019). Specifically,

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11 Under Criterion A [ and Criterion 1 of the California Register], the LAR [Los Angeles River] channel conveys a direct association with the LACDA [Los Angeles County Drainage Area] flood-control efforts undertaken by the USACE [U.S. Army Corps of Engineers] , which constitute a locally significant event that directly influenced the settlement and economic development of the City of Los Angeles and neighboring communities along the length of the LAR. The LAR channel as a whole also meets Criterion C [ and Criterion 3 of the California Register], given the scale and geographic extent of the channelization and the fact that it represents the first implementation of a fully concrete -lined river designed specifically to manage unique flood conditions. It embodies an engineered solution to the volatile flooding episodes common to the watershed and its tributaries, and it has served as a prototype for flood channels in the region (Thompson et al. 2022:4.15).

The Los Angeles River is not eligible for listing under Criterion 2 or 4 of the California Register. Criterion 2 is specifically intended to apply to properties that are associated with individuals whose specific contributions can be identified and documented. It is restricted to properties that illustrate (rather than commemorate) a person’s achievements. Although notable people have been instrumental in carrying out policies that set flood control projects in motion in California , research has failed to indicate any individuals whose contributions to the construction of the Los Angeles River itself can be associated with prescribed level of specificity. It is therefore not eligible for listing under Criterion 2.

Criterion 4 is most commonly associated with data potential archaeological sites. The flood control channel is a well understood property type. It has not and is not likely to yield information important in prehistory or history. Therefore the Los Angeles River is not eligible for listing under Criterion 4.

The U.S. Army Corps of Engineers has also found that the Los Angeles River channel retains integrity of workmanship, materials, setting, feeling, and association and that the period of significance spans the years from 1936 to 1960 (Thompson et al. 2022:4.16) .

However, the visual setting surrounding the project site has been impacted by development outside the period of significance, including construction of surrounding neighborhoods, the Interstate 5 and State Route 134 freeway bridges over the Los Angeles River, the reconfiguration of Flower Street, construction of the modern bike path and walkway, and by the installation of modern transmission towers and streetlights.

Based on these results, the Los Angeles River Channel (including the Glendale Narrows/Reach 3 Segment) is eligible for California Register listing. As such it is recommended a historical resource under CEQA.

RECOMMENDATIONS
During the research and field survey, BCR Consulting archaeologists identified the historic-period Glendale Narrows segment of the Los Angeles River, which is roughly coterminous with Reach 3 (approximately 7.4 miles in length) of the Los Angeles River constructed between 1938 and 1939. The Los Angeles River has been determined eligible for National Register listing and as such is a historical resource under CEQA. However, the proposed project will impact a tiny portion (approximately .06 percent) of the Glendale EXHIBIT 6
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12 Narrows/Reach 3 segment of the Los Angeles River. Based on the small percentage of the segment that will be subject to direct impacts , BCR Consulting recommends that the proposed project, a pedestrian/bicycle bridge over the Glendale Narrows, will not result in a substantial adverse change to a historical resource which can cause a significant effect on the environment under CEQA.

Furthermore, the bridge abutments would be constructed to be higher than the existing elevation of the channel walls and would not touch the levee walls. Although the integrity of setting would be minimally impacted by the installation of the bridge, the setting of the Glendale Narrows/Reach 3 segment has already been impacted by development of the surrounding neighborhoods and by the Interstate 5 and State Route 134 freeway bridges that are visible from the proposed project site and were constructed after the period of significance. As such, the proposed project will not introduce any elements to the setting that are not already present , and the proposed project will not alter the ability of the Glendale Narrows/Reach 3 to contribute to a larger district . Based on these results, BCR Consulting recommends that the project as proposed will not result in significant impacts to a historical resource (under CEQA). No mitigations are recommended for the current undertaking. No archaeological resources were identified during this assessment.

Disturbances associated with the construction of the Glendale Narrows segment/ Reach 3 of the Los Angeles River , recent development of bike and walking paths, recent reconfiguration of Flower Street adjacent to the north end of the project site, and modern development of athletic fields adjacent to the south side of the project site have disrupted soil beyond depths at which buried cultural resources are likely. Also, no buried discoveries have occurred in the vicinity of the project site. As a result, the potential to encounter in -situ remains associated with significant archaeological materials during project-related excavation is low.

While the current study has not indicated sensitivity for unknown cultural resources within the project boundaries, ground disturbing activities always have the potential to reveal buried deposits not observed on the surface during previous surveys. Therefore, a list of recommendations is provided below based on the City of Los Angeles’ Best Management Practices for Inadvertent Discovery of Archaeological and Paleontological Resources. This has been amended slightly where corrections were necessary, and to involve all participating agencies.

Archaeological Worker Environmental Awareness Program (WEAP) . Prior to the start of construction, the Qualified Archaeologist or archaeological monitor shall conduct training for construction personnel regarding the appearance of archaeological resources and the procedures for notifying archaeological staff should archaeological resources be discovered by construction staff. In the event of an archaeological resource discovery by construction personnel, all work in the immediate vicinity of the find shall cease and a Qualified Archaeologist shall be contacted to evaluate the find before restarting work in the area. If it is determined that the archaeological resource(s) is(are) scientifically significant, the archaeological monitor shall complete the Archaeological Assessment.

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13 Archaeological Assessment. If a possible archaeological resource is uncovered during earthwork or construction, all work shall cease within a minimum distance of 50 feet from the find until a Qualified Archaeologist has been retained to evaluate the find in accordance with National Register and California Register criteria. The Qualified Archaeologist may adjust this avoidance area, ensuring appropriate temporary protection measures of the find are taken while also considering ongoing construction needs in the surrounding area. Temporary staking and delineation of the avoidance area shall be installed around the find in order to avoid any disturbance from construction equipment.

Ground disturbance activities may continue unimpeded on other portions of the site outside the specified radius. Any potential archaeological resource or associated materials that are uncovered shall not be moved or collected by anyone other than an Archaeological Monitor or Qualified Archaeologist unless the materials have been determined to be non -unique archaeological resources, as defined in Public Resources Code Section 21083.1(h), by the Qualified Archaeologist. The Qualified Archaeologist shall determine if the resources are unique archeological resources as defined in Public Resources Code Section 21083.2(g). Consistent with Public Resources Code Section 21083.2, the handling, treatment, preservation, and recordation of unique archaeological resources should occur as follows:

• The find should be preserved in place or left in an undisturbed state unless the project would damage the resource.

• When preserving in place or leaving in an undisturbed state is not possible, excavation and recovery of the find for scientific study should occur unless testing or studies already completed have adequately recovered the scientifically consequential information from and about the resource, and this determination is documented by a Qualified Archaeologist.

Ground disturbance activities in the area where resource(s) were found may recommence once the identified resources are properly assessed and processed by a Qualified Archaeologist. A report that describes the resource(s) and its disposition, as well as the assessment methodology, shall be prepared by the Qualified Archaeologist according to current professional standards and maintained for at least five years after certificate of occupancy. If appropriate, the report should also contain the Qualified Archaeologist’s recommendations for the preservation, conservation, and curation of the resource at a suitable repository, such as the Natural History Museum of Los Angeles County, with which the City of Los Angeles must comply. Within 60 days following the completion of monitoring and all associated work, the archeologist shall submit the appropriate report to the Los Angeles Bureau of Engineering , representatives of other participating agencies, and to the SCCIC at California State University, Fullerton ; the report(s) shall include all state and local requirements. Reports submitted to the SCCIC shall be formatted and completed in accordance with the California Historic Resources Inventory System (CHRIS) document submittal standards.

Paleontological Worker Environmental Awareness Program (WEAP). Prior to the start of construction, the Qualified Paleontologist or Paleontological Monitor shall conduct training for construction personnel regarding the appearance of fossils and the procedures EXHIBIT 6
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14 for notifying paleontological staff should fossils be discovered by construction staff. In the event of a fossil discovery by construction personnel, all work in the immediate vicinity of the find shall cease and a Qualified Paleontologist shall be contacted to evaluate the find before restarting work in the area. If it is determined that the fossil(s) is(are) scientifically significant, the Paleontological Monitor shall complete the next two steps.

Treatment of Paleontological Resources. If a probable paleontological resource is uncovered during earthwork or construction, all work shall cease within a minimum distance of 50 feet from the find until a Qualified Paleontologist has been retained to evaluate the find in accordance with the Society of Vertebrate Paleontology’s Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources (2010). Temporary flagging shall be installed around the find to avoid any disturbance from construction equipment. Any paleontological materials that are uncovered shall not be moved or collected by anyone other than a Qualified Paleontologist or his/her designated representative such as a Paleontological Monitor. If cleared by the Qualified Paleontologist, Ground Disturbance Activities may continue unimpeded on other portions of the site. The found deposit(s) shall be treated in accordance with the Society of Vertebrate Paleontology’s Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources. In consultation with the City, Ground Disturbance Activities in the area where resource(s) were found may recommence once the identified resources are properly assessed and processed by the Qualified Paleontologist. A report that describes the resource and its disposition, as well as the assessment methodology, shall be prepared by the Qualified Paleontologist according to current professional standards and maintained for at least five years after certificate of occupancy. If appropriate, the report should also contain the Qualified Paleontologist’s recommendations for the preservation, conservation, and curation of the resource at a suitable repository, such as the Natural History Museum of Los Angeles County, with which the City must comply.

Treatment of Tribal Cultural Resources. If a possible tribal cultural resource is uncovered during earthwork or construction, all work shall cease within a minimum distance of 50 feet from the find until a Qualified Tribal Monitor or Archaeological Monitor has been retained to evaluate the find.

Following discovery, the Bureau of Engineering shall immediately contact all Native American tribes that have informed the City they are traditionally and culturally affiliated with the geographic area of the Project . If a Qualified Tribal Monitor or Archaeological Monitor determines, pursuant to Public Resources Code Section 21074(a)(2), that the object or artifact appears to be a potential tribal cultural resource, in its discretion and supported by substantial evidence, the City shall provide any affected tribe a reasonable period of time, not less than five business days, to conduct a site visit and make recommendations to the participating agencies, regarding the monitoring of future Ground Disturbance Activities and the treatment and disposition of any discovered tribal cultural resources. The City shall implement the tribe’s recommendations if the Qualified Tribal Monitor or Archaeological Monitor reasonably concludes such recommendations are reasonable and feasible.

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15 Consistent with Public Resources Code Section 21083.2, the handling, treatment, preservation, and recordation of tribal cultural resources should occur as follows:

• The find should be preserved in place or left in an undisturbed state unless the Project would damage the resource.

All collected artifacts and fieldwork notes, if not human remains or other mortuary objects, shall be offered to participating Tribes for reburial. If a suitable reburial location is not found, the items should be curated at the Natural History Museum of Los Angeles County or another appropriate curatorial facility for educational purposes. If cleared by the Qualified Tribal Monitor or Archaeological Monitor, ground disturbance activities may continue unimpeded on other portions of the site. Ground disturbance activities in the area where resource(s) were found may recommence once the identified resources are properly assessed and processed. A report that describes the resource and its disposition, as well as the assessment methodology shall be prepared by the Qualified Tribal Monitor or Archaeological Monitor, according to current professional standards. A copy of the report shall be submitted to Bureau of Engineering, representatives of other participating agencies, and the SCCIC at California State University, Fullerton. Participating agencies may review and approve any monitoring or mitigation plan prior to implementation.

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16 REFERENCES
Bean, Lowell John, and Charles Smith
1978 California, edited by R.F. Heizer. Handbook of North American Indians, Vol. 8, W.C. Sturtevant, general editor, Smithsonian Institution. Washington, D.C.

Beattie, George W., and Helen P. Beattie
1974 Heritage of the Valley: San Bernardino’s First Century. Biobooks: Oakland.

Beck, Warren A., and Ynez D. Haase
1974 Historical Atlas of California. Oklahoma City: University of Oklahoma Press.

Bettinger, Robert L., and R.E. Taylor
1974 Suggested Revisions in Archaeological Sequences of the Great Basin and Interior Southern California. Nevada Archaeological Survey Research Papers 3:1-26.

Boscana, Father Geronimo
1933 Chinigchinich: Alfred Robinson's Translation of Father Geronimo Boscana's Historic Account of the Belief, Usages, Customs and Extravagancies of the Indians of this Mission of San Juan Capistrano Called the Acagchemem Tribe.

Fine Arts Press, Santa Ana.

Brock, James, John F. Elliot, and Nina M. Harris
1992 A Cultural Resources Assessment of the Hansen Dam Flood Control Basin, City of Los Angeles, California. On File, South Central Coastal Information Center.

Fullerton, California.

California Department of Water Resources
2020 History of Water Development and the State Water Project. Electronic Document:
https://water.ca.gov/Programs/State-Water-Project/History. Accessed 9/8/20.

Campbell, E., and W. Campbell
1935 The Pinto Basin. Southwest Museum Papers 9:1-51.

Carle, David
2004 Introduction to Water in California. Berkley: University of California Press.

Cleland, Robert Glass
1941 The Cattle on a Thousand Hills—Southern California, 1850-80. San Marino, California: Huntington Library.

Flenniken, J.J.
1985 Stone Tool Reduction Techniques as Cultural Markers. Stone Tool Analysis:

Essays in Honor of Don E. Crabtree, edited by M.G. Plew, J.C. Woods, and M.G.

Pavesic. University of New Mexico Press, Albuquerque.

Flenniken, J.J. and A.W. Raymond
1986 Morphological Projectile Point Typology: Replication, Experimentation, and Technological Analysis. American Antiquity 51:603-614.

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17 Flenniken, J.J. and Philip J. Wilke
1989 Typology, Technology, and Chronology of Great Basin Dart Points. American Anthropologist 91:149-158.

Harding, S. T.
1960 Water in California. Palo Alto: N-P Publishers.

Heizer, Robert F.
1968 Introduction and Notes: The Indians of Los Angeles County: Hugo Reid's Letters of 1852, edited/annotated by Robert F. Heizer. Southwest Museum, Los Angeles.

Hunt, Alice P.
1960 The Archaeology of the Death Valley Salt Pan, California. University of Utah Anthropological Papers No. 47.

Jaeger, Edmund C., and Arthur C. Smith
1971 Introduction to the Natural History of Southern California. California Natural History Guides: 13. University of California Press. Los Angeles

Johnston, B.E.
1962 California's Gabrielino Indians. Southwest Museum, Los Angeles.

Kroeber, Alfred L.
1925 Handbook of the Indians of California. Bureau of American Ethnology Bulletin 78.

Washington D.C.: Smithsonian Institution. Reprinted in 1976, New York: Dover Publications.

Lanning, Edward P.
1963 The Archaeology of the Rose Spring Site (Iny-372). University of California Publications in American Archaeology and Ethnology 49(3):237-336.

Lambert, David
1994 The Field Guide to Prehistoric Life. Diagram Visual Information Limited. New York.

Lightfoot, Kent G., Otis Parrish
2009 California Indians and Their Environment, an Introduction. University of California Press, Berkeley.

McCawley, William
1996 The First Angelinos, The Gabrielino Indians of Los Angeles. Malki Museum Press/Ballena Press Cooperative Publication. Banning/Novato, California.

Mendenhall, W.C.
1905 Developments of Underground Waters in the Eastern Coastal Plain Regions of Southern California. USGS Water Supply Paper, Number 137.

Metropolitan Water District of Southern California
2016 “75 Years of Water Delivery.” Electronic Document: http://www.mwdh2o.com/ WhoWeAre/History/75years/. Accessed 9/8/20.

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18 San Diego County Water Authority
2020 History. Electronic Document: https://www.sdcwa.org/history. Accessed 9/8/20.

Slawson, Dana
2013 Department of Parks and Recreation DPR 523A Form for Resource Number P- 19-190897. On file at the SCCIC.

Starr, Kevin
1996 Endangered Dreams: The Great Depression in California. Oxford University Press, New York.

Suburban Emergency Management Project
2006 Los Angeles Basin’s 1938 Catastrophic Flood Event. Electronic Document:
https://web.archive.org/web/20090509054714/http://www.semp.us/publications/ biot_reader.php?BiotID=369. Accessed 11/8/2018.

Thompson, Scott, Burr Neely, Scott Kremkau, Patrick B. Stanton, and Kenneth M. Becker 2022 A [Draft] Regional Historic Context for Flood-Control Activities within Los Angeles County and an Architectural Assessment of Select Reaches of the Los Angeles River Channel, Los Angeles County, California. Provided by the U.S. Army Corps of Engineers.

United States Department of Agriculture
1972 Aerial Photographs of Los Angeles County. Electronic Document:
historicaerials.com. Accessed on Multiple Dates.

1964 Aerial Photographs of Los Angeles County. Electronic Document:
historicaerials.com. Accessed on Multiple Dates.

1954 Aerial Photographs of Los Angeles County. Electronic Document:
historicaerials.com. Accessed on Multiple Dates.

United States Geological Survey
1994 Burbank, California 7.5-minute topographic quadrangle map.

Wallace, William J.
1958 Archaeological Investigation in Death Valley National Monument. University of California Archaeological Survey Reports 42:7-22.

1962 Prehistoric Cultural Development in the Southern California Deserts. American Antiquity 28(2):172-180.

1978 The Southern Valley Yokuts, and The Northern Valley Yokuts. In Handbook of the North American Indians, Vol. 8, California, edited by W.L. d’Azevedo, pp. 448 - 470. W.C. Sturtevant, General Editor. Smithsonian Institution, Washington D.C.

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19 Warren, Claude N. and R.H. Crabtree
1986 The Prehistory of the Southwestern Great Basin. In Handbook of the North American Indians, Vol. 11, Great Basin, edited by W.L. d’Azevedo, pp.183 -193.

W.C. Sturtevant, General Editor. Smithsonian Institution, Washington D.C.

Water Education Foundation
2017 California Water Timeline. Electronic Document:
https://www.watereducation.org/aquapedia/california-water-timeline. Accessed 9/8/20.

Williams, Patricia, Leah Messinger, Sarah Johnson
2008 Habitats Alive! An Ecological Guide to California's Diverse Habitats. California Institute for Biodiversity, Claremont, California.

Woodford, A.O., J.E. Schuellhamer, J.E. Wooder, and R.F. Yerkes 1954 Geology of the Los Angeles Basin. In Geology of Southern California, Bulletin 170.

Division of Mines and Geology. San Francisco.

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APPENDIX A

RECORDS SEARCH BIBLIOGRAPHY

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Report List
Report No. Year Title AffiliationAuthor(s) ResourcesOther IDs RVA2205
LA-02210 1989 Archaeological Survey Report and
Assessment of the Riverdale Parcel, Griffith
Park Los Angeles, California
Frierman, Jay D.

LA-03554 1968 Ucas-304 Survey of Griffith Park, Los
Angeles County
UCAS,Department of
Recreation and Parks City
of Los Angeles
Leonard, Nelson N. III 19-175297
LA-03950 1998 Archaeological Assessment for Pacific Bell Mobile Services Telecommunications Facility
La 119-01, 604 Sonora Avenue, City of
Glendale, County of Los Angeles, California
LSA Associates, Inc.McLean, Deborah K.

LA-06006 2003 Cultural Resources Technical Report City of Glendale Water & Power Grayson Unit 9
Project
URS CorporationFarmer, T. Reid
LA-06722 2000 Historic Property Survey Report State Route 134/san Fernando Road Access and Safety
Improvement Program
PCR Services CorporationOstashay, Janet 19-190312, 19-190599, 19-190600, 19-190601, 19-190602, 19-190603,
19-190604, 19-190605, 19-190606,
19-190607, 19-190608, 19-190609,
19-190610, 19-190611, 19-190612
LA-06738 2001 Highway Project to Construct a New
Maintenance Station Under the Ventura
Freeway (134) in the City of Glendale, the
Doran Street Station at 943 W. Doran Street.

Caltrans District 7Sriro, Adam
LA-07259 2005 Cultural Resource Records Search and Site Visit for Sprint Facility Candidate La70xc132d
(aeroscopic) 5245 West San Fernando Road,
Los Angeles Los Angeles County, California
Michael Brandman
Associates
Bonner, Wayne H.

LA-07263 2002 Cultural Resource Assessment for Cingular Wireless Facility Vy183-01 City of Glendale,
California
Kyle ConsultingKyle, Carolyn E.

LA-07840 2001 Negative Archaeological Survey Report for the Beautification and Modernization Along
Route 134 From the 134/170 Separation to
Shoup Ave Uc, and Along Route 101 From
the 101/170 Separation to Concord Street Uc
Caltrans District 7Sylvia, Barbara
LA-08255 2006 Cultural Resources Final Report of Monitoring and Findings for the Qwest Network
Construction Project State of California:

Volumes I and Ii
SWCA Environmental
Consultants, Inc.

Arrington, Cindy and
Nancy Sikes

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Glendale City CouncilJune 9, 2026

Glendale City Council
June 9, 2026