1.84608e
+006
9.9500e0030.0905 0.0760 5.4000e0046.8800e0036.8800e0036.8800e0036.8800e0030.0000 98.5139 98.5139 1.8900e0031.8100e00399.0993 Regional
Shopping Center
91840 5.0000e0044.5000e0033.7800e0033.0000e0053.4000e0043.4000e0043.4000e0043.4000e0040.0000 4.9009 4.9009 9.0000e0059.0000e0054.9301 Total 0.1398 1.2312 0.7770 7.6200e0030.0966 0.0966 0.0966 0.0966 0.0000 1,383.426 8 1,383.426
8 0.0265 0.0254 1,391.647
8 Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Page 33 of 44 Date: 1/12/2021 2:26 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 176
ATTACHMENT 3
1053
5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
Apartments Low
Rise
106010 33.7770 1.3900e0032.9000e00433.8978
Apartments Mid
Rise
3.94697e
+006
1,257.587
9 0.0519 0.0107 1,262.086
9 General Office
Building
584550 186.2502 7.6900e0031.5900e003186.9165
High Turnover (Sit
Down Restaurant)
1.58904e
+006
506.3022 0.0209 4.3200e003508.1135
Hotel 550308 175.3399 7.2400e0031.5000e003175.9672
Quality
Restaurant
353120 112.5116 4.6500e0039.6000e004112.9141
Regional
Shopping Center
756000 240.8778 9.9400e0032.0600e003241.7395
Total 2,512.646
5 0.1037 0.0215 2,521.635
6 Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Page 34 of 44 Date: 1/12/2021 2:26 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 177
ATTACHMENT 3
1054
6.1 Mitigation Measures Area
6.0 Area Detail
5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
Apartments Low
Rise
106010 33.7770 1.3900e0032.9000e00433.8978
Apartments Mid
Rise
3.94697e
+006
1,257.587
9 0.0519 0.0107 1,262.086
9 General Office
Building
584550 186.2502 7.6900e0031.5900e003186.9165
High Turnover (Sit
Down Restaurant)
1.58904e
+006
506.3022 0.0209 4.3200e003508.1135
Hotel 550308 175.3399 7.2400e0031.5000e003175.9672
Quality
Restaurant
353120 112.5116 4.6500e0039.6000e004112.9141
Regional
Shopping Center
756000 240.8778 9.9400e0032.0600e003241.7395
Total 2,512.646
5 0.1037 0.0215 2,521.635
6 Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Page 35 of 44 Date: 1/12/2021 2:26 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 178
ATTACHMENT 3
1055
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 5.1437 0.2950 10.3804 1.6700e0030.0714 0.0714 0.0714 0.0714 0.0000 220.9670 220.9670 0.0201 3.7400e003222.5835 Unmitigated 5.1437 0.2950 10.3804 1.6700e0030.0714 0.0714 0.0714 0.0714 0.0000 220.9670 220.9670 0.0201 3.7400e003222.5835
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory tons/yr MT/yr
Architectural
Coating
0.4137 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products
4.3998 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Hearth 0.0206 0.1763 0.0750 1.1200e0030.0143 0.0143 0.0143 0.0143 0.0000 204.1166 204.1166 3.9100e0033.7400e003205.3295 Landscaping 0.3096 0.1187 10.3054 5.4000e0040.0572 0.0572 0.0572 0.0572 0.0000 16.8504 16.8504 0.0161 0.0000 17.2540 Total 5.1437 0.2950 10.3804 1.6600e0030.0714 0.0714 0.0714 0.0714 0.0000 220.9670 220.9670 0.0201 3.7400e003222.5835 Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Page 36 of 44 Date: 1/12/2021 2:26 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 179
ATTACHMENT 3
1056
7.1 Mitigation Measures Water
7.0 Water Detail
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory tons/yr MT/yr
Architectural
Coating
0.4137 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products
4.3998 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Hearth 0.0206 0.1763 0.0750 1.1200e0030.0143 0.0143 0.0143 0.0143 0.0000 204.1166 204.1166 3.9100e0033.7400e003205.3295 Landscaping 0.3096 0.1187 10.3054 5.4000e0040.0572 0.0572 0.0572 0.0572 0.0000 16.8504 16.8504 0.0161 0.0000 17.2540 Total 5.1437 0.2950 10.3804 1.6600e0030.0714 0.0714 0.0714 0.0714 0.0000 220.9670 220.9670 0.0201 3.7400e003222.5835 Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Page 37 of 44 Date: 1/12/2021 2:26 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 180
ATTACHMENT 3
1057
Total CO2 CH4 N2O CO2e
Category MT/yr
Mitigated 585.8052 3.0183 0.0755 683.7567
Unmitigated 585.8052 3.0183 0.0755 683.7567
CalEEMod Version: CalEEMod.2016.3.2 Page 38 of 44 Date: 1/12/2021 2:26 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 181
ATTACHMENT 3
1058
7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
Apartments Low
Rise
1.62885 /
1.02688
10.9095 0.0535 1.3400e00312.6471
Apartments Mid
Rise
63.5252 /
40.0485
425.4719 2.0867 0.0523 493.2363
General Office
Building
7.99802 /
4.90201
53.0719 0.2627 6.5900e00361.6019
High Turnover (Sit
Down Restaurant)
10.9272 /
0.697482
51.2702 0.3580 8.8200e00362.8482
Hotel 1.26834 /
0.140927
6.1633 0.0416 1.0300e0037.5079
Quality
Restaurant
2.42827 /
0.154996
11.3934 0.0796 1.9600e00313.9663
Regional
Shopping Center
4.14806 /
2.54236
27.5250 0.1363 3.4200e00331.9490
Total 585.8052 3.0183 0.0755 683.7567
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Page 39 of 44 Date: 1/12/2021 2:26 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 182
ATTACHMENT 3
1059
8.1 Mitigation Measures Waste
7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
Apartments Low
Rise
1.62885 /
1.02688
10.9095 0.0535 1.3400e00312.6471
Apartments Mid
Rise
63.5252 /
40.0485
425.4719 2.0867 0.0523 493.2363
General Office
Building
7.99802 /
4.90201
53.0719 0.2627 6.5900e00361.6019
High Turnover (Sit
Down Restaurant)
10.9272 /
0.697482
51.2702 0.3580 8.8200e00362.8482
Hotel 1.26834 /
0.140927
6.1633 0.0416 1.0300e0037.5079
Quality
Restaurant
2.42827 /
0.154996
11.3934 0.0796 1.9600e00313.9663
Regional
Shopping Center
4.14806 /
2.54236
27.5250 0.1363 3.4200e00331.9490
Total 585.8052 3.0183 0.0755 683.7567
Mitigated
8.0 Waste Detail
CalEEMod Version: CalEEMod.2016.3.2 Page 40 of 44 Date: 1/12/2021 2:26 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 183
ATTACHMENT 3
1060
Total CO2 CH4 N2O CO2e
MT/yr
Mitigated 207.8079 12.2811 0.0000 514.8354
Unmitigated 207.8079 12.2811 0.0000 514.8354
Category/Year
CalEEMod Version: CalEEMod.2016.3.2 Page 41 of 44 Date: 1/12/2021 2:26 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 184
ATTACHMENT 3
1061
8.2 Waste by Land Use
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
Apartments Low
Rise
11.5 2.3344 0.1380 0.0000 5.7834
Apartments Mid
Rise
448.5 91.0415 5.3804 0.0000 225.5513
General Office
Building
41.85 8.4952 0.5021 0.0000 21.0464
High Turnover (Sit
Down Restaurant)
428.4 86.9613 5.1393 0.0000 215.4430
Hotel 27.38 5.5579 0.3285 0.0000 13.7694
Quality
Restaurant
7.3 1.4818 0.0876 0.0000 3.6712
Regional
Shopping Center
58.8 11.9359 0.7054 0.0000 29.5706
Total 207.8079 12.2811 0.0000 514.8354
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Page 42 of 44 Date: 1/12/2021 2:26 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 185
ATTACHMENT 3
1062
8.2 Waste by Land Use
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
Apartments Low
Rise
11.5 2.3344 0.1380 0.0000 5.7834
Apartments Mid
Rise
448.5 91.0415 5.3804 0.0000 225.5513
General Office
Building
41.85 8.4952 0.5021 0.0000 21.0464
High Turnover (Sit
Down Restaurant)
428.4 86.9613 5.1393 0.0000 215.4430
Hotel 27.38 5.5579 0.3285 0.0000 13.7694
Quality
Restaurant
7.3 1.4818 0.0876 0.0000 3.6712
Regional
Shopping Center
58.8 11.9359 0.7054 0.0000 29.5706
Total 207.8079 12.2811 0.0000 514.8354
Mitigated
9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type
10.0 Stationary Equipment
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type CalEEMod Version: CalEEMod.2016.3.2 Page 43 of 44 Date: 1/12/2021 2:26 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 186
ATTACHMENT 3
1063
11.0 Vegetation
Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment
Equipment Type Number
CalEEMod Version: CalEEMod.2016.3.2 Page 44 of 44 Date: 1/12/2021 2:26 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 187
ATTACHMENT 3
1064
1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population General Office Building 45.00 1000sqft 1.03 45,000.00 0 High Turnover (Sit Down Restaurant) 36.00 1000sqft 0.83 36,000.00 0 Hotel 50.00 Room 1.67 72,600.00 0
Quality Restaurant 8.00 1000sqft 0.18 8,000.00 0
Apartments Low Rise 25.00 Dwelling Unit 1.56 25,000.00 72 Apartments Mid Rise 975.00 Dwelling Unit 25.66 975,000.00 2789 Regional Shopping Center 56.00 1000sqft 1.29 56,000.00 0
1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
9 Wind Speed (m/s) 2.2 Precipitation Freq (Days) 33
1.3 User Entered Comments & Non-Default Data
1.0 Project Characteristics
Utility Company Southern California Edison
Operational Year 2028
CO2 Intensity
(lb/MWhr)
702.44 CH4 Intensity 0.029
(lb/MWhr)
N2O Intensity 0.006
(lb/MWhr)
Village South Specific Plan (Proposed)
Los Angeles-South Coast County, Summer
CalEEMod Version: CalEEMod.2016.3.2 Page 1 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 188
ATTACHMENT 3
1065
Project Characteristics - Consistent with the DEIR's model.
Land Use - See SWAPE comment regarding residential and retail land uses.
Construction Phase - See SWAPE comment regarding individual construction phase lengths.
Demolition - Consistent with the DEIR's model. See SWAPE comment regarding demolition.
Vehicle Trips - Saturday trips consistent with the DEIR's model. See SWAPE comment regarding weekday and Sunday trips.
Woodstoves - Woodstoves and wood-burning fireplaces consistent with the DEIR's model. See SWAPE comment regarding gas fireplaces.
Energy Use -
Construction Off-road Equipment Mitigation - See SWAPE comment on construction-related mitigation.
Area Mitigation - See SWAPE comment regarding operational mitigation measures.
Water Mitigation - See SWAPE comment regarding operational mitigation measures.
Trips and VMT - Local hire provision
Table Name Column Name Default Value New Value
tblFireplaces FireplaceWoodMass 1,019.20 0.00
tblFireplaces FireplaceWoodMass 1,019.20 0.00
tblFireplaces NumberWood 1.25 0.00
tblFireplaces NumberWood 48.75 0.00
tblTripsAndVMT WorkerTripLength 14.70 10.00
tblTripsAndVMT WorkerTripLength 14.70 10.00
tblTripsAndVMT WorkerTripLength 14.70 10.00
tblTripsAndVMT WorkerTripLength 14.70 10.00
tblTripsAndVMT WorkerTripLength 14.70 10.00
tblTripsAndVMT WorkerTripLength 14.70 10.00
tblVehicleTrips ST_TR 7.16 6.17
tblVehicleTrips ST_TR 6.39 3.87
tblVehicleTrips ST_TR 2.46 1.39
tblVehicleTrips ST_TR 158.37 79.82
CalEEMod Version: CalEEMod.2016.3.2 Page 2 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 189
ATTACHMENT 3
1066
2.0 Emissions Summary
tblVehicleTrips ST_TR 8.19 3.75
tblVehicleTrips ST_TR 94.36 63.99
tblVehicleTrips ST_TR 49.97 10.74
tblVehicleTrips SU_TR 6.07 6.16
tblVehicleTrips SU_TR 5.86 4.18
tblVehicleTrips SU_TR 1.05 0.69
tblVehicleTrips SU_TR 131.84 78.27
tblVehicleTrips SU_TR 5.95 3.20
tblVehicleTrips SU_TR 72.16 57.65
tblVehicleTrips SU_TR 25.24 6.39
tblVehicleTrips WD_TR 6.59 5.83
tblVehicleTrips WD_TR 6.65 4.13
tblVehicleTrips WD_TR 11.03 6.41
tblVehicleTrips WD_TR 127.15 65.80
tblVehicleTrips WD_TR 8.17 3.84
tblVehicleTrips WD_TR 89.95 62.64
tblVehicleTrips WD_TR 42.70 9.43
tblWoodstoves NumberCatalytic 1.25 0.00
tblWoodstoves NumberCatalytic 48.75 0.00
tblWoodstoves NumberNoncatalytic 1.25 0.00
tblWoodstoves NumberNoncatalytic 48.75 0.00
tblWoodstoves WoodstoveDayYear 25.00 0.00
tblWoodstoves WoodstoveDayYear 25.00 0.00
tblWoodstoves WoodstoveWoodMass 999.60 0.00
tblWoodstoves WoodstoveWoodMass 999.60 0.00
CalEEMod Version: CalEEMod.2016.3.2 Page 3 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 190
ATTACHMENT 3
1067
2.1 Overall Construction (Maximum Daily Emission)
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2021 4.2561 46.4415 31.4494 0.0636 18.2032 2.0456 20.2488 9.9670 1.8820 11.8490 0.0000 6,163.416 6 6,163.416
6 1.9475 0.0000 6,212.103
9 2022 4.5441 38.8811 40.8776 0.1240 8.8255 1.6361 10.4616 3.6369 1.5052 5.1421 0.0000 12,493.44 03 12,493.44
03 1.9485 0.0000 12,518.57
07 2023 4.1534 25.7658 38.7457 0.1206 7.0088 0.7592 7.7679 1.8799 0.7136 2.5935 0.0000 12,150.48 90 12,150.48
90 0.9589 0.0000 12,174.46
15 2024 237.0219 9.5478 14.9642 0.0239 1.2171 0.4694 1.2875 0.3229 0.4319 0.4621 0.0000 2,313.180 8 2,313.180
8 0.7166 0.0000 2,331.095
6 Maximum 237.0219 46.4415 40.8776 0.1240 18.2032 2.0456 20.2488 9.9670 1.8820 11.8490 0.0000 12,493.44 03 12,493.44
03 1.9485 0.0000 12,518.57
07 Unmitigated Construction
CalEEMod Version: CalEEMod.2016.3.2 Page 4 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 191
ATTACHMENT 3
1068
2.1 Overall Construction (Maximum Daily Emission)
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2021 4.2561 46.4415 31.4494 0.0636 18.2032 2.0456 20.2488 9.9670 1.8820 11.8490 0.0000 6,163.416 6 6,163.416
6 1.9475 0.0000 6,212.103
9 2022 4.5441 38.8811 40.8776 0.1240 8.8255 1.6361 10.4616 3.6369 1.5052 5.1421 0.0000 12,493.44 03 12,493.44
03 1.9485 0.0000 12,518.57
07 2023 4.1534 25.7658 38.7457 0.1206 7.0088 0.7592 7.7679 1.8799 0.7136 2.5935 0.0000 12,150.48 90 12,150.48
90 0.9589 0.0000 12,174.46
15 2024 237.0219 9.5478 14.9642 0.0239 1.2171 0.4694 1.2875 0.3229 0.4319 0.4621 0.0000 2,313.180 8 2,313.180
8 0.7166 0.0000 2,331.095
5 Maximum 237.0219 46.4415 40.8776 0.1240 18.2032 2.0456 20.2488 9.9670 1.8820 11.8490 0.0000 12,493.44 03 12,493.44
03 1.9485 0.0000 12,518.57
07 Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CalEEMod Version: CalEEMod.2016.3.2 Page 5 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 192
ATTACHMENT 3
1069
2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 30.5020 15.0496 88.4430 0.0944 1.5974 1.5974 1.5974 1.5974 0.0000 18,148.59 50 18,148.59
50 0.4874 0.3300 18,259.11
92 Energy 0.7660 6.7462 4.2573 0.0418 0.5292 0.5292 0.5292 0.5292 8,355.983 2 8,355.983
2 0.1602 0.1532 8,405.638
7 Mobile 9.8489 45.4304 114.8495 0.4917 45.9592 0.3360 46.2951 12.2950 0.3119 12.6070 50,306.60 34 50,306.60
34 2.1807 50,361.12
08 Total 41.1168 67.2262 207.5497 0.6278 45.9592 2.4626 48.4217 12.2950 2.4385 14.7336 0.0000 76,811.18 16 76,811.18
16 2.8282 0.4832 77,025.87
86 Unmitigated Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 30.5020 15.0496 88.4430 0.0944 1.5974 1.5974 1.5974 1.5974 0.0000 18,148.59 50 18,148.59
50 0.4874 0.3300 18,259.11
92 Energy 0.7660 6.7462 4.2573 0.0418 0.5292 0.5292 0.5292 0.5292 8,355.983 2 8,355.983
2 0.1602 0.1532 8,405.638
7 Mobile 9.8489 45.4304 114.8495 0.4917 45.9592 0.3360 46.2951 12.2950 0.3119 12.6070 50,306.60 34 50,306.60
34 2.1807 50,361.12
08 Total 41.1168 67.2262 207.5497 0.6278 45.9592 2.4626 48.4217 12.2950 2.4385 14.7336 0.0000 76,811.18 16 76,811.18
16 2.8282 0.4832 77,025.87
86 Mitigated Operational
CalEEMod Version: CalEEMod.2016.3.2 Page 6 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 193
ATTACHMENT 3
1070
3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 9/1/2021 10/12/2021 5 30
2 Site Preparation Site Preparation 10/13/2021 11/9/2021 5 20 3 Grading Grading 11/10/2021 1/11/2022 5 45
4 Building Construction Building Construction 1/12/2022 12/12/2023 5 500 5 Paving Paving 12/13/2023 1/30/2024 5 35
6 Architectural Coating Architectural Coating 1/31/2024 3/19/2024 5 35 OffRoad Equipment
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Residential Indoor: 2,025,000; Residential Outdoor: 675,000; Non-Residential Indoor: 326,400; Non-Residential Outdoor: 108,800; Striped Parking Area: 0 (Architectural Coating ±sqft)
Acres of Grading (Site Preparation Phase): 0
Acres of Grading (Grading Phase): 112.5
Acres of Paving: 0
CalEEMod Version: CalEEMod.2016.3.2 Page 7 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 194
ATTACHMENT 3
1071
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Demolition Concrete/Industrial Saws 1 8.00 81 0.73
Demolition Excavators 3 8.00 158 0.38
Demolition Rubber Tired Dozers 2 8.00 247 0.40
Site Preparation Rubber Tired Dozers 3 8.00 247 0.40
Site Preparation Tractors/Loaders/Backhoes 4 8.00 97 0.37 Grading Excavators 2 8.00 158 0.38
Grading Graders 1 8.00 187 0.41
Grading Rubber Tired Dozers 1 8.00 247 0.40
Grading Scrapers 2 8.00 367 0.48
Grading Tractors/Loaders/Backhoes 2 8.00 97 0.37
Building Construction Cranes 1 7.00 231 0.29
Building Construction Forklifts 3 8.00 89 0.20
Building Construction Generator Sets 1 8.00 84 0.74
Building Construction Tractors/Loaders/Backhoes 3 7.00 97 0.37 Building Construction Welders 1 8.00 46 0.45
Paving Pavers 2 8.00 130 0.42
Paving Paving Equipment 2 8.00 132 0.36
Paving Rollers 2 8.00 80 0.38
Architectural Coating Air Compressors 1 6.00 78 0.48
Trips and VMT
CalEEMod Version: CalEEMod.2016.3.2 Page 8 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 195
ATTACHMENT 3
1072
3.2 Demolition - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 3.3074 0.0000 3.3074 0.5008 0.0000 0.5008 0.0000 0.0000 Off-Road 3.1651 31.4407 21.5650 0.0388 1.5513 1.5513 1.4411 1.4411 3,747.944 9 3,747.944
9 1.0549 3,774.317
4 Total 3.1651 31.4407 21.5650 0.0388 3.3074 1.5513 4.8588 0.5008 1.4411 1.9419 3,747.944 9 3,747.944
9 1.0549 3,774.317
4 Unmitigated Construction On-Site
3.1 Mitigation Measures Construction
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Demolition 6 15.00 0.00 458.00 10.00 6.90 20.00 LD_Mix HDT_Mix HHDT Site Preparation 7 18.00 0.00 0.00 10.00 6.90 20.00 LD_Mix HDT_Mix HHDT Grading 8 20.00 0.00 0.00 10.00 6.90 20.00 LD_Mix HDT_Mix HHDT Building Construction 9 801.00 143.00 0.00 10.00 6.90 20.00 LD_Mix HDT_Mix HHDT Paving 6 15.00 0.00 0.00 10.00 6.90 20.00 LD_Mix HDT_Mix HHDT Architectural Coating 1 160.00 0.00 0.00 10.00 6.90 20.00 LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod.2016.3.2 Page 9 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 196
ATTACHMENT 3
1073
3.2 Demolition - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.1273 4.0952 0.9602 0.0119 0.2669 0.0126 0.2795 0.0732 0.0120 0.0852 1,292.241 3 1,292.241
3 0.0877 1,294.433
7 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0487 0.0313 0.4282 1.1800e0030.1141 9.5000e0040.1151 0.0303 8.8000e0040.0311 117.2799 117.2799 3.5200e003117.3678 Total 0.1760 4.1265 1.3884 0.0131 0.3810 0.0135 0.3946 0.1034 0.0129 0.1163 1,409.521 2 1,409.521
2 0.0912 1,411.801
5 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 3.3074 0.0000 3.3074 0.5008 0.0000 0.5008 0.0000 0.0000 Off-Road 3.1651 31.4407 21.5650 0.0388 1.5513 1.5513 1.4411 1.4411 0.0000 3,747.944 9 3,747.944
9 1.0549 3,774.317
4 Total 3.1651 31.4407 21.5650 0.0388 3.3074 1.5513 4.8588 0.5008 1.4411 1.9419 0.0000 3,747.944 9 3,747.944
9 1.0549 3,774.317
4 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 10 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 197
ATTACHMENT 3
1074
3.2 Demolition - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.1273 4.0952 0.9602 0.0119 0.2669 0.0126 0.2795 0.0732 0.0120 0.0852 1,292.241 3 1,292.241
3 0.0877 1,294.433
7 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0487 0.0313 0.4282 1.1800e0030.1141 9.5000e0040.1151 0.0303 8.8000e0040.0311 117.2799 117.2799 3.5200e003117.3678 Total 0.1760 4.1265 1.3884 0.0131 0.3810 0.0135 0.3946 0.1034 0.0129 0.1163 1,409.521 2 1,409.521
2 0.0912 1,411.801
5 Mitigated Construction Off-Site
3.3 Site Preparation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 18.0663 0.0000 18.0663 9.9307 0.0000 9.9307 0.0000 0.0000 Off-Road 3.8882 40.4971 21.1543 0.0380 2.0445 2.0445 1.8809 1.8809 3,685.656 9 3,685.656
9 1.1920 3,715.457
3 Total 3.8882 40.4971 21.1543 0.0380 18.0663 2.0445 20.1107 9.9307 1.8809 11.8116 3,685.656 9 3,685.656
9 1.1920 3,715.457
3 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 11 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 198
ATTACHMENT 3
1075
3.3 Site Preparation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0584 0.0375 0.5139 1.4100e0030.1369 1.1400e0030.1381 0.0363 1.0500e0030.0374 140.7359 140.7359 4.2200e003140.8414 Total 0.0584 0.0375 0.5139 1.4100e0030.1369 1.1400e0030.1381 0.0363 1.0500e0030.0374 140.7359 140.7359 4.2200e003140.8414 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 18.0663 0.0000 18.0663 9.9307 0.0000 9.9307 0.0000 0.0000 Off-Road 3.8882 40.4971 21.1543 0.0380 2.0445 2.0445 1.8809 1.8809 0.0000 3,685.656 9 3,685.656
9 1.1920 3,715.457
3 Total 3.8882 40.4971 21.1543 0.0380 18.0663 2.0445 20.1107 9.9307 1.8809 11.8116 0.0000 3,685.656 9 3,685.656
9 1.1920 3,715.457
3 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 12 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 199
ATTACHMENT 3
1076
3.3 Site Preparation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0584 0.0375 0.5139 1.4100e0030.1369 1.1400e0030.1381 0.0363 1.0500e0030.0374 140.7359 140.7359 4.2200e003140.8414 Total 0.0584 0.0375 0.5139 1.4100e0030.1369 1.1400e0030.1381 0.0363 1.0500e0030.0374 140.7359 140.7359 4.2200e003140.8414 Mitigated Construction Off-Site
3.4 Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 8.6733 0.0000 8.6733 3.5965 0.0000 3.5965 0.0000 0.0000 Off-Road 4.1912 46.3998 30.8785 0.0620 1.9853 1.9853 1.8265 1.8265 6,007.043 4 6,007.043
4 1.9428 6,055.613
4 Total 4.1912 46.3998 30.8785 0.0620 8.6733 1.9853 10.6587 3.5965 1.8265 5.4230 6,007.043 4 6,007.043
4 1.9428 6,055.613
4 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 13 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 200
ATTACHMENT 3
1077
3.4 Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0649 0.0417 0.5710 1.5700e0030.1521 1.2700e0030.1534 0.0404 1.1700e0030.0415 156.3732 156.3732 4.6900e003156.4904 Total 0.0649 0.0417 0.5710 1.5700e0030.1521 1.2700e0030.1534 0.0404 1.1700e0030.0415 156.3732 156.3732 4.6900e003156.4904 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 8.6733 0.0000 8.6733 3.5965 0.0000 3.5965 0.0000 0.0000 Off-Road 4.1912 46.3998 30.8785 0.0620 1.9853 1.9853 1.8265 1.8265 0.0000 6,007.043 4 6,007.043
4 1.9428 6,055.613
4 Total 4.1912 46.3998 30.8785 0.0620 8.6733 1.9853 10.6587 3.5965 1.8265 5.4230 0.0000 6,007.043 4 6,007.043
4 1.9428 6,055.613
4 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 14 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 201
ATTACHMENT 3
1078
3.4 Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0649 0.0417 0.5710 1.5700e0030.1521 1.2700e0030.1534 0.0404 1.1700e0030.0415 156.3732 156.3732 4.6900e003156.4904 Total 0.0649 0.0417 0.5710 1.5700e0030.1521 1.2700e0030.1534 0.0404 1.1700e0030.0415 156.3732 156.3732 4.6900e003156.4904 Mitigated Construction Off-Site
3.4 Grading - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 8.6733 0.0000 8.6733 3.5965 0.0000 3.5965 0.0000 0.0000 Off-Road 3.6248 38.8435 29.0415 0.0621 1.6349 1.6349 1.5041 1.5041 6,011.410 5 6,011.410
5 1.9442 6,060.015
8 Total 3.6248 38.8435 29.0415 0.0621 8.6733 1.6349 10.3082 3.5965 1.5041 5.1006 6,011.410 5 6,011.410
5 1.9442 6,060.015
8 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 15 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 202
ATTACHMENT 3
1079
3.4 Grading - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0607 0.0376 0.5263 1.5100e0030.1521 1.2300e0030.1534 0.0404 1.1300e0030.0415 150.8754 150.8754 4.2400e003150.9813 Total 0.0607 0.0376 0.5263 1.5100e0030.1521 1.2300e0030.1534 0.0404 1.1300e0030.0415 150.8754 150.8754 4.2400e003150.9813 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 8.6733 0.0000 8.6733 3.5965 0.0000 3.5965 0.0000 0.0000 Off-Road 3.6248 38.8435 29.0415 0.0621 1.6349 1.6349 1.5041 1.5041 0.0000 6,011.410 5 6,011.410
5 1.9442 6,060.015
8 Total 3.6248 38.8435 29.0415 0.0621 8.6733 1.6349 10.3082 3.5965 1.5041 5.1006 0.0000 6,011.410 5 6,011.410
5 1.9442 6,060.015
8 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 16 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 203
ATTACHMENT 3
1080
3.4 Grading - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0607 0.0376 0.5263 1.5100e0030.1521 1.2300e0030.1534 0.0404 1.1300e0030.0415 150.8754 150.8754 4.2400e003150.9813 Total 0.0607 0.0376 0.5263 1.5100e0030.1521 1.2300e0030.1534 0.0404 1.1300e0030.0415 150.8754 150.8754 4.2400e003150.9813 Mitigated Construction Off-Site
3.5 Building Construction - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 1.7062 15.6156 16.3634 0.0269 0.8090 0.8090 0.7612 0.7612 2,554.333 6 2,554.333
6 0.6120 2,569.632
2 Total 1.7062 15.6156 16.3634 0.0269 0.8090 0.8090 0.7612 0.7612 2,554.333 6 2,554.333
6 0.6120 2,569.632
2 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 17 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 204
ATTACHMENT 3
1081
3.5 Building Construction - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.4079 13.2032 3.4341 0.0364 0.9155 0.0248 0.9404 0.2636 0.0237 0.2873 3,896.548 2 3,896.548
2 0.2236 3,902.138
4 Worker 2.4299 1.5074 21.0801 0.0607 6.0932 0.0493 6.1425 1.6163 0.0454 1.6617 6,042.558 5 6,042.558
5 0.1697 6,046.800
0 Total 2.8378 14.7106 24.5142 0.0971 7.0087 0.0741 7.0828 1.8799 0.0691 1.9490 9,939.106 7 9,939.106
7 0.3933 9,948.938
4 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 1.7062 15.6156 16.3634 0.0269 0.8090 0.8090 0.7612 0.7612 0.0000 2,554.333 6 2,554.333
6 0.6120 2,569.632
2 Total 1.7062 15.6156 16.3634 0.0269 0.8090 0.8090 0.7612 0.7612 0.0000 2,554.333 6 2,554.333
6 0.6120 2,569.632
2 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 18 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 205
ATTACHMENT 3
1082
3.5 Building Construction - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.4079 13.2032 3.4341 0.0364 0.9155 0.0248 0.9404 0.2636 0.0237 0.2873 3,896.548 2 3,896.548
2 0.2236 3,902.138
4 Worker 2.4299 1.5074 21.0801 0.0607 6.0932 0.0493 6.1425 1.6163 0.0454 1.6617 6,042.558 5 6,042.558
5 0.1697 6,046.800
0 Total 2.8378 14.7106 24.5142 0.0971 7.0087 0.0741 7.0828 1.8799 0.0691 1.9490 9,939.106 7 9,939.106
7 0.3933 9,948.938
4 Mitigated Construction Off-Site
3.5 Building Construction - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 1.5728 14.3849 16.2440 0.0269 0.6997 0.6997 0.6584 0.6584 2,555.209 9 2,555.209
9 0.6079 2,570.406
1 Total 1.5728 14.3849 16.2440 0.0269 0.6997 0.6997 0.6584 0.6584 2,555.209 9 2,555.209
9 0.6079 2,570.406
1 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 19 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 206
ATTACHMENT 3
1083
3.5 Building Construction - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.3027 10.0181 3.1014 0.0352 0.9156 0.0116 0.9271 0.2636 0.0111 0.2747 3,773.876 2 3,773.876
2 0.1982 3,778.830
0 Worker 2.2780 1.3628 19.4002 0.0584 6.0932 0.0479 6.1411 1.6163 0.0441 1.6604 5,821.402 8 5,821.402
8 0.1529 5,825.225
4 Total 2.5807 11.3809 22.5017 0.0936 7.0088 0.0595 7.0682 1.8799 0.0552 1.9350 9,595.279 0 9,595.279
0 0.3511 9,604.055
4 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 1.5728 14.3849 16.2440 0.0269 0.6997 0.6997 0.6584 0.6584 0.0000 2,555.209 9 2,555.209
9 0.6079 2,570.406
1 Total 1.5728 14.3849 16.2440 0.0269 0.6997 0.6997 0.6584 0.6584 0.0000 2,555.209 9 2,555.209
9 0.6079 2,570.406
1 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 20 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 207
ATTACHMENT 3
1084
3.5 Building Construction - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.3027 10.0181 3.1014 0.0352 0.9156 0.0116 0.9271 0.2636 0.0111 0.2747 3,773.876 2 3,773.876
2 0.1982 3,778.830
0 Worker 2.2780 1.3628 19.4002 0.0584 6.0932 0.0479 6.1411 1.6163 0.0441 1.6604 5,821.402 8 5,821.402
8 0.1529 5,825.225
4 Total 2.5807 11.3809 22.5017 0.0936 7.0088 0.0595 7.0682 1.8799 0.0552 1.9350 9,595.279 0 9,595.279
0 0.3511 9,604.055
4 Mitigated Construction Off-Site
3.6 Paving - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 1.0327 10.1917 14.5842 0.0228 0.5102 0.5102 0.4694 0.4694 2,207.584 1 2,207.584
1 0.7140 2,225.433
6 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 1.0327 10.1917 14.5842 0.0228 0.5102 0.5102 0.4694 0.4694 2,207.584 1 2,207.584
1 0.7140 2,225.433
6 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 21 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 208
ATTACHMENT 3
1085
3.6 Paving - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0427 0.0255 0.3633 1.0900e0030.1141 9.0000e0040.1150 0.0303 8.3000e0040.0311 109.0150 109.0150 2.8600e003109.0866 Total 0.0427 0.0255 0.3633 1.0900e0030.1141 9.0000e0040.1150 0.0303 8.3000e0040.0311 109.0150 109.0150 2.8600e003109.0866 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 1.0327 10.1917 14.5842 0.0228 0.5102 0.5102 0.4694 0.4694 0.0000 2,207.584 1 2,207.584
1 0.7140 2,225.433
6 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 1.0327 10.1917 14.5842 0.0228 0.5102 0.5102 0.4694 0.4694 0.0000 2,207.584 1 2,207.584
1 0.7140 2,225.433
6 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 22 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 209
ATTACHMENT 3
1086
3.6 Paving - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0427 0.0255 0.3633 1.0900e0030.1141 9.0000e0040.1150 0.0303 8.3000e0040.0311 109.0150 109.0150 2.8600e003109.0866 Total 0.0427 0.0255 0.3633 1.0900e0030.1141 9.0000e0040.1150 0.0303 8.3000e0040.0311 109.0150 109.0150 2.8600e003109.0866 Mitigated Construction Off-Site
3.6 Paving - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.9882 9.5246 14.6258 0.0228 0.4685 0.4685 0.4310 0.4310 2,207.547 2 2,207.547
2 0.7140 2,225.396
3 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.9882 9.5246 14.6258 0.0228 0.4685 0.4685 0.4310 0.4310 2,207.547 2 2,207.547
2 0.7140 2,225.396
3 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 23 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 210
ATTACHMENT 3
1087
3.6 Paving - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0403 0.0233 0.3384 1.0600e0030.1141 8.8000e0040.1150 0.0303 8.1000e0040.0311 105.6336 105.6336 2.6300e003105.6992 Total 0.0403 0.0233 0.3384 1.0600e0030.1141 8.8000e0040.1150 0.0303 8.1000e0040.0311 105.6336 105.6336 2.6300e003105.6992 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.9882 9.5246 14.6258 0.0228 0.4685 0.4685 0.4310 0.4310 0.0000 2,207.547 2 2,207.547
2 0.7140 2,225.396
3 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.9882 9.5246 14.6258 0.0228 0.4685 0.4685 0.4310 0.4310 0.0000 2,207.547 2 2,207.547
2 0.7140 2,225.396
3 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 24 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 211
ATTACHMENT 3
1088
3.6 Paving - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0403 0.0233 0.3384 1.0600e0030.1141 8.8000e0040.1150 0.0303 8.1000e0040.0311 105.6336 105.6336 2.6300e003105.6992 Total 0.0403 0.0233 0.3384 1.0600e0030.1141 8.8000e0040.1150 0.0303 8.1000e0040.0311 105.6336 105.6336 2.6300e003105.6992 Mitigated Construction Off-Site
3.7 Architectural Coating - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Archit. Coating 236.4115 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.1808 1.2188 1.8101 2.9700e0030.0609 0.0609 0.0609 0.0609 281.4481 281.4481 0.0159 281.8443 Total 236.5923 1.2188 1.8101 2.9700e0030.0609 0.0609 0.0609 0.0609 281.4481 281.4481 0.0159 281.8443 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 25 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 212
ATTACHMENT 3
1089
3.7 Architectural Coating - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.4296 0.2481 3.6098 0.0113 1.2171 9.4300e0031.2266 0.3229 8.6800e0030.3315 1,126.758 3 1,126.758
3 0.0280 1,127.458
3 Total 0.4296 0.2481 3.6098 0.0113 1.2171 9.4300e0031.2266 0.3229 8.6800e0030.3315 1,126.758 3 1,126.758
3 0.0280 1,127.458
3 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Archit. Coating 236.4115 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.1808 1.2188 1.8101 2.9700e0030.0609 0.0609 0.0609 0.0609 0.0000 281.4481 281.4481 0.0159 281.8443 Total 236.5923 1.2188 1.8101 2.9700e0030.0609 0.0609 0.0609 0.0609 0.0000 281.4481 281.4481 0.0159 281.8443 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 26 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 213
ATTACHMENT 3
1090
4.0 Operational Detail - Mobile
4.1 Mitigation Measures Mobile
3.7 Architectural Coating - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.4296 0.2481 3.6098 0.0113 1.2171 9.4300e0031.2266 0.3229 8.6800e0030.3315 1,126.758 3 1,126.758
3 0.0280 1,127.458
3 Total 0.4296 0.2481 3.6098 0.0113 1.2171 9.4300e0031.2266 0.3229 8.6800e0030.3315 1,126.758 3 1,126.758
3 0.0280 1,127.458
3 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 27 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 214
ATTACHMENT 3
1091
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 9.8489 45.4304 114.8495 0.4917 45.9592 0.3360 46.2951 12.2950 0.3119 12.6070 50,306.60 34 50,306.60
34 2.1807 50,361.12
08 Unmitigated 9.8489 45.4304 114.8495 0.4917 45.9592 0.3360 46.2951 12.2950 0.3119 12.6070 50,306.60 34 50,306.60
34 2.1807 50,361.12
08 4.2 Trip Summary Information
4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Apartments Low Rise 145.75 154.25 154.00 506,227 506,227 Apartments Mid Rise 4,026.75 3,773.25 4075.50 13,660,065 13,660,065 General Office Building 288.45 62.55 31.05 706,812 706,812 High Turnover (Sit Down Restaurant) 2,368.80 2,873.52 2817.72 3,413,937 3,413,937 Hotel 192.00 187.50 160.00 445,703 445,703
Quality Restaurant 501.12 511.92 461.20 707,488 707,488 Regional Shopping Center 528.08 601.44 357.84 1,112,221 1,112,221 Total 8,050.95 8,164.43 8,057.31 20,552,452 20,552,452
CalEEMod Version: CalEEMod.2016.3.2 Page 28 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 215
ATTACHMENT 3
1092
Miles Trip % Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by Apartments Low Rise 14.70 5.90 8.70 40.20 19.20 40.60 86 11 3 Apartments Mid Rise 14.70 5.90 8.70 40.20 19.20 40.60 86 11 3 General Office Building 16.60 8.40 6.90 33.00 48.00 19.00 77 19 4 High Turnover (Sit Down
Restaurant)
16.60 8.40 6.90 8.50 72.50 19.00 37 20 43
Hotel 16.60 8.40 6.90 19.40 61.60 19.00 58 38 4
Quality Restaurant 16.60 8.40 6.90 12.00 69.00 19.00 38 18 44 Regional Shopping Center 16.60 8.40 6.90 16.30 64.70 19.00 54 35 11
5.0 Energy Detail
5.1 Mitigation Measures Energy
4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH Apartments Low Rise 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Apartments Mid Rise 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 General Office Building 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 High Turnover (Sit Down
Restaurant)
0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Hotel 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Quality Restaurant 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Regional Shopping Center 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Historical Energy Use: N
CalEEMod Version: CalEEMod.2016.3.2 Page 29 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 216
ATTACHMENT 3
1093
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
NaturalGas
Mitigated
0.7660 6.7462 4.2573 0.0418 0.5292 0.5292 0.5292 0.5292 8,355.983 2 8,355.983
2 0.1602 0.1532 8,405.638
7 NaturalGas
Unmitigated
0.7660 6.7462 4.2573 0.0418 0.5292 0.5292 0.5292 0.5292 8,355.983 2 8,355.983
2 0.1602 0.1532 8,405.638
7 CalEEMod Version: CalEEMod.2016.3.2 Page 30 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 217
ATTACHMENT 3
1094
5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Apartments Low
Rise
1119.16 0.0121 0.1031 0.0439 6.6000e0048.3400e0038.3400e0038.3400e0038.3400e003131.6662 131.6662 2.5200e0032.4100e003132.4486 Apartments Mid
Rise
35784.3 0.3859 3.2978 1.4033 0.0211 0.2666 0.2666 0.2666 0.2666 4,209.916 4 4,209.916
4 0.0807 0.0772 4,234.933
9 General Office
Building
1283.42 0.0138 0.1258 0.1057 7.5000e0049.5600e0039.5600e0039.5600e0039.5600e003150.9911 150.9911 2.8900e0032.7700e003151.8884 High Turnover (Sit
Down Restaurant)
22759.9 0.2455 2.2314 1.8743 0.0134 0.1696 0.1696 0.1696 0.1696 2,677.634 2 2,677.634
2 0.0513 0.0491 2,693.546
0 Hotel 4769.72 0.0514 0.4676 0.3928 2.8100e0030.0355 0.0355 0.0355 0.0355 561.1436 561.1436 0.0108 0.0103 564.4782 Quality
Restaurant
5057.75 0.0545 0.4959 0.4165 2.9800e0030.0377 0.0377 0.0377 0.0377 595.0298 595.0298 0.0114 0.0109 598.5658 Regional
Shopping Center
251.616 2.7100e0030.0247 0.0207 1.5000e0041.8700e0031.8700e0031.8700e0031.8700e00329.6019 29.6019 5.7000e0045.4000e00429.7778 Total 0.7660 6.7463 4.2573 0.0418 0.5292 0.5292 0.5292 0.5292 8,355.983 2 8,355.983
2 0.1602 0.1532 8,405.638
7 Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Page 31 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 218
ATTACHMENT 3
1095
6.1 Mitigation Measures Area
6.0 Area Detail
5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Apartments Low
Rise
1.11916 0.0121 0.1031 0.0439 6.6000e0048.3400e0038.3400e0038.3400e0038.3400e003131.6662 131.6662 2.5200e0032.4100e003132.4486 Apartments Mid
Rise
35.7843 0.3859 3.2978 1.4033 0.0211 0.2666 0.2666 0.2666 0.2666 4,209.916 4 4,209.916
4 0.0807 0.0772 4,234.933
9 General Office
Building
1.28342 0.0138 0.1258 0.1057 7.5000e0049.5600e0039.5600e0039.5600e0039.5600e003150.9911 150.9911 2.8900e0032.7700e003151.8884 High Turnover (Sit
Down Restaurant)
22.7599 0.2455 2.2314 1.8743 0.0134 0.1696 0.1696 0.1696 0.1696 2,677.634 2 2,677.634
2 0.0513 0.0491 2,693.546
0 Hotel 4.76972 0.0514 0.4676 0.3928 2.8100e0030.0355 0.0355 0.0355 0.0355 561.1436 561.1436 0.0108 0.0103 564.4782 Quality
Restaurant
5.05775 0.0545 0.4959 0.4165 2.9800e0030.0377 0.0377 0.0377 0.0377 595.0298 595.0298 0.0114 0.0109 598.5658 Regional
Shopping Center
0.251616 2.7100e0030.0247 0.0207 1.5000e0041.8700e0031.8700e0031.8700e0031.8700e00329.6019 29.6019 5.7000e0045.4000e00429.7778 Total 0.7660 6.7463 4.2573 0.0418 0.5292 0.5292 0.5292 0.5292 8,355.983 2 8,355.983
2 0.1602 0.1532 8,405.638
7 Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Page 32 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 219
ATTACHMENT 3
1096
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 30.5020 15.0496 88.4430 0.0944 1.5974 1.5974 1.5974 1.5974 0.0000 18,148.59 50 18,148.59
50 0.4874 0.3300 18,259.11
92 Unmitigated 30.5020 15.0496 88.4430 0.0944 1.5974 1.5974 1.5974 1.5974 0.0000 18,148.59 50 18,148.59
50 0.4874 0.3300 18,259.11
92 6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
2.2670 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
24.1085 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Hearth 1.6500 14.1000 6.0000 0.0900 1.1400 1.1400 1.1400 1.1400 0.0000 18,000.00 00 18,000.00
00 0.3450 0.3300 18,106.96
50 Landscaping 2.4766 0.9496 82.4430 4.3600e0030.4574 0.4574 0.4574 0.4574 148.5950 148.5950 0.1424 152.1542 Total 30.5020 15.0496 88.4430 0.0944 1.5974 1.5974 1.5974 1.5974 0.0000 18,148.59 50 18,148.59
50 0.4874 0.3300 18,259.11
92 Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Page 33 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 220
ATTACHMENT 3
1097
8.1 Mitigation Measures Waste
7.1 Mitigation Measures Water
7.0 Water Detail
8.0 Waste Detail
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
2.2670 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
24.1085 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Hearth 1.6500 14.1000 6.0000 0.0900 1.1400 1.1400 1.1400 1.1400 0.0000 18,000.00 00 18,000.00
00 0.3450 0.3300 18,106.96
50 Landscaping 2.4766 0.9496 82.4430 4.3600e0030.4574 0.4574 0.4574 0.4574 148.5950 148.5950 0.1424 152.1542 Total 30.5020 15.0496 88.4430 0.0944 1.5974 1.5974 1.5974 1.5974 0.0000 18,148.59 50 18,148.59
50 0.4874 0.3300 18,259.11
92 Mitigated
9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type
10.0 Stationary Equipment
CalEEMod Version: CalEEMod.2016.3.2 Page 34 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 221
ATTACHMENT 3
1098
11.0 Vegetation
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment
Equipment Type Number
CalEEMod Version: CalEEMod.2016.3.2 Page 35 of 35 Date: 1/12/2021 2:29 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 222
ATTACHMENT 3
1099
1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population General Office Building 45.00 1000sqft 1.03 45,000.00 0 High Turnover (Sit Down Restaurant) 36.00 1000sqft 0.83 36,000.00 0 Hotel 50.00 Room 1.67 72,600.00 0
Quality Restaurant 8.00 1000sqft 0.18 8,000.00 0
Apartments Low Rise 25.00 Dwelling Unit 1.56 25,000.00 72 Apartments Mid Rise 975.00 Dwelling Unit 25.66 975,000.00 2789 Regional Shopping Center 56.00 1000sqft 1.29 56,000.00 0
1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
9 Wind Speed (m/s) 2.2 Precipitation Freq (Days) 33
1.3 User Entered Comments & Non-Default Data
1.0 Project Characteristics
Utility Company Southern California Edison
Operational Year 2028
CO2 Intensity
(lb/MWhr)
702.44 CH4 Intensity 0.029
(lb/MWhr)
N2O Intensity 0.006
(lb/MWhr)
Village South Specific Plan (Proposed)
Los Angeles-South Coast County, Winter
CalEEMod Version: CalEEMod.2016.3.2 Page 1 of 35 Date: 1/12/2021 2:30 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Winter 223
ATTACHMENT 3
1100
Project Characteristics - Consistent with the DEIR's model.
Land Use - See SWAPE comment regarding residential and retail land uses.
Construction Phase - See SWAPE comment regarding individual construction phase lengths.
Demolition - Consistent with the DEIR's model. See SWAPE comment regarding demolition.
Vehicle Trips - Saturday trips consistent with the DEIR's model. See SWAPE comment regarding weekday and Sunday trips.
Woodstoves - Woodstoves and wood-burning fireplaces consistent with the DEIR's model. See SWAPE comment regarding gas fireplaces.
Energy Use -
Construction Off-road Equipment Mitigation - See SWAPE comment on construction-related mitigation.
Area Mitigation - See SWAPE comment regarding operational mitigation measures.
Water Mitigation - See SWAPE comment regarding operational mitigation measures.
Trips and VMT - Local hire provision
Table Name Column Name Default Value New Value
tblFireplaces FireplaceWoodMass 1,019.20 0.00
tblFireplaces FireplaceWoodMass 1,019.20 0.00
tblFireplaces NumberWood 1.25 0.00
tblFireplaces NumberWood 48.75 0.00
tblTripsAndVMT WorkerTripLength 14.70 10.00
tblTripsAndVMT WorkerTripLength 14.70 10.00
tblTripsAndVMT WorkerTripLength 14.70 10.00
tblTripsAndVMT WorkerTripLength 14.70 10.00
tblTripsAndVMT WorkerTripLength 14.70 10.00
tblTripsAndVMT WorkerTripLength 14.70 10.00
tblVehicleTrips ST_TR 7.16 6.17
tblVehicleTrips ST_TR 6.39 3.87
tblVehicleTrips ST_TR 2.46 1.39
tblVehicleTrips ST_TR 158.37 79.82
CalEEMod Version: CalEEMod.2016.3.2 Page 2 of 35 Date: 1/12/2021 2:30 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Winter 224
ATTACHMENT 3
1101
2.0 Emissions Summary
tblVehicleTrips ST_TR 8.19 3.75
tblVehicleTrips ST_TR 94.36 63.99
tblVehicleTrips ST_TR 49.97 10.74
tblVehicleTrips SU_TR 6.07 6.16
tblVehicleTrips SU_TR 5.86 4.18
tblVehicleTrips SU_TR 1.05 0.69
tblVehicleTrips SU_TR 131.84 78.27
tblVehicleTrips SU_TR 5.95 3.20
tblVehicleTrips SU_TR 72.16 57.65
tblVehicleTrips SU_TR 25.24 6.39
tblVehicleTrips WD_TR 6.59 5.83
tblVehicleTrips WD_TR 6.65 4.13
tblVehicleTrips WD_TR 11.03 6.41
tblVehicleTrips WD_TR 127.15 65.80
tblVehicleTrips WD_TR 8.17 3.84
tblVehicleTrips WD_TR 89.95 62.64
tblVehicleTrips WD_TR 42.70 9.43
tblWoodstoves NumberCatalytic 1.25 0.00
tblWoodstoves NumberCatalytic 48.75 0.00
tblWoodstoves NumberNoncatalytic 1.25 0.00
tblWoodstoves NumberNoncatalytic 48.75 0.00
tblWoodstoves WoodstoveDayYear 25.00 0.00
tblWoodstoves WoodstoveDayYear 25.00 0.00
tblWoodstoves WoodstoveWoodMass 999.60 0.00
tblWoodstoves WoodstoveWoodMass 999.60 0.00
CalEEMod Version: CalEEMod.2016.3.2 Page 3 of 35 Date: 1/12/2021 2:30 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Winter 225
ATTACHMENT 3
1102
2.1 Overall Construction (Maximum Daily Emission)
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2021 4.2621 46.4460 31.4068 0.0635 18.2032 2.0456 20.2488 9.9670 1.8820 11.8490 0.0000 6,154.337 7 6,154.337
7 1.9472 0.0000 6,203.018
6 2022 4.7966 38.8851 39.6338 0.1195 8.8255 1.6361 10.4616 3.6369 1.5052 5.1421 0.0000 12,035.34 40 12,035.34
40 1.9482 0.0000 12,060.60
13 2023 4.3939 25.8648 37.5031 0.1162 7.0088 0.7598 7.7685 1.8799 0.7142 2.5940 0.0000 11,710.40 80 11,710.40
80 0.9617 0.0000 11,734.44
97 2024 237.0656 9.5503 14.9372 0.0238 1.2171 0.4694 1.2875 0.3229 0.4319 0.4621 0.0000 2,307.051 7 2,307.051
7 0.7164 0.0000 2,324.962
7 Maximum 237.0656 46.4460 39.6338 0.1195 18.2032 2.0456 20.2488 9.9670 1.8820 11.8490 0.0000 12,035.34 40 12,035.34
40 1.9482 0.0000 12,060.60
13 Unmitigated Construction
CalEEMod Version: CalEEMod.2016.3.2 Page 4 of 35 Date: 1/12/2021 2:30 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Winter 226
ATTACHMENT 3
1103
2.1 Overall Construction (Maximum Daily Emission)
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2021 4.2621 46.4460 31.4068 0.0635 18.2032 2.0456 20.2488 9.9670 1.8820 11.8490 0.0000 6,154.337 7 6,154.337
7 1.9472 0.0000 6,203.018
6 2022 4.7966 38.8851 39.6338 0.1195 8.8255 1.6361 10.4616 3.6369 1.5052 5.1421 0.0000 12,035.34 40 12,035.34
40 1.9482 0.0000 12,060.60
13 2023 4.3939 25.8648 37.5031 0.1162 7.0088 0.7598 7.7685 1.8799 0.7142 2.5940 0.0000 11,710.40 80 11,710.40
80 0.9617 0.0000 11,734.44
97 2024 237.0656 9.5503 14.9372 0.0238 1.2171 0.4694 1.2875 0.3229 0.4319 0.4621 0.0000 2,307.051 7 2,307.051
7 0.7164 0.0000 2,324.962
7 Maximum 237.0656 46.4460 39.6338 0.1195 18.2032 2.0456 20.2488 9.9670 1.8820 11.8490 0.0000 12,035.34 40 12,035.34
40 1.9482 0.0000 12,060.60
13 Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CalEEMod Version: CalEEMod.2016.3.2 Page 5 of 35 Date: 1/12/2021 2:30 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Winter 227
ATTACHMENT 3
1104
2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 30.5020 15.0496 88.4430 0.0944 1.5974 1.5974 1.5974 1.5974 0.0000 18,148.59 50 18,148.59
50 0.4874 0.3300 18,259.11
92 Energy 0.7660 6.7462 4.2573 0.0418 0.5292 0.5292 0.5292 0.5292 8,355.983 2 8,355.983
2 0.1602 0.1532 8,405.638
7 Mobile 9.5233 45.9914 110.0422 0.4681 45.9592 0.3373 46.2965 12.2950 0.3132 12.6083 47,917.80 05 47,917.80
05 2.1953 47,972.68
39 Total 40.7912 67.7872 202.7424 0.6043 45.9592 2.4640 48.4231 12.2950 2.4399 14.7349 0.0000 74,422.37 87 74,422.37
87 2.8429 0.4832 74,637.44
17 Unmitigated Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 30.5020 15.0496 88.4430 0.0944 1.5974 1.5974 1.5974 1.5974 0.0000 18,148.59 50 18,148.59
50 0.4874 0.3300 18,259.11
92 Energy 0.7660 6.7462 4.2573 0.0418 0.5292 0.5292 0.5292 0.5292 8,355.983 2 8,355.983
2 0.1602 0.1532 8,405.638
7 Mobile 9.5233 45.9914 110.0422 0.4681 45.9592 0.3373 46.2965 12.2950 0.3132 12.6083 47,917.80 05 47,917.80
05 2.1953 47,972.68
39 Total 40.7912 67.7872 202.7424 0.6043 45.9592 2.4640 48.4231 12.2950 2.4399 14.7349 0.0000 74,422.37 87 74,422.37
87 2.8429 0.4832 74,637.44
17 Mitigated Operational
CalEEMod Version: CalEEMod.2016.3.2 Page 6 of 35 Date: 1/12/2021 2:30 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Winter 228
ATTACHMENT 3
1105
3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 9/1/2021 10/12/2021 5 30
2 Site Preparation Site Preparation 10/13/2021 11/9/2021 5 20 3 Grading Grading 11/10/2021 1/11/2022 5 45
4 Building Construction Building Construction 1/12/2022 12/12/2023 5 500 5 Paving Paving 12/13/2023 1/30/2024 5 35
6 Architectural Coating Architectural Coating 1/31/2024 3/19/2024 5 35 OffRoad Equipment
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Residential Indoor: 2,025,000; Residential Outdoor: 675,000; Non-Residential Indoor: 326,400; Non-Residential Outdoor: 108,800; Striped Parking Area: 0 (Architectural Coating ±sqft)
Acres of Grading (Site Preparation Phase): 0
Acres of Grading (Grading Phase): 112.5
Acres of Paving: 0
CalEEMod Version: CalEEMod.2016.3.2 Page 7 of 35 Date: 1/12/2021 2:30 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Winter 229
ATTACHMENT 3
1106
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Demolition Concrete/Industrial Saws 1 8.00 81 0.73
Demolition Excavators 3 8.00 158 0.38
Demolition Rubber Tired Dozers 2 8.00 247 0.40
Site Preparation Rubber Tired Dozers 3 8.00 247 0.40
Site Preparation Tractors/Loaders/Backhoes 4 8.00 97 0.37 Grading Excavators 2 8.00 158 0.38
Grading Graders 1 8.00 187 0.41
Grading Rubber Tired Dozers 1 8.00 247 0.40
Grading Scrapers 2 8.00 367 0.48
Grading Tractors/Loaders/Backhoes 2 8.00 97 0.37
Building Construction Cranes 1 7.00 231 0.29
Building Construction Forklifts 3 8.00 89 0.20
Building Construction Generator Sets 1 8.00 84 0.74
Building Construction Tractors/Loaders/Backhoes 3 7.00 97 0.37 Building Construction Welders 1 8.00 46 0.45
Paving Pavers 2 8.00 130 0.42
Paving Paving Equipment 2 8.00 132 0.36
Paving Rollers 2 8.00 80 0.38
Architectural Coating Air Compressors 1 6.00 78 0.48
Trips and VMT
CalEEMod Version: CalEEMod.2016.3.2 Page 8 of 35 Date: 1/12/2021 2:30 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Winter 230
ATTACHMENT 3
1107
3.2 Demolition - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 3.3074 0.0000 3.3074 0.5008 0.0000 0.5008 0.0000 0.0000 Off-Road 3.1651 31.4407 21.5650 0.0388 1.5513 1.5513 1.4411 1.4411 3,747.944 9 3,747.944
9 1.0549 3,774.317
4 Total 3.1651 31.4407 21.5650 0.0388 3.3074 1.5513 4.8588 0.5008 1.4411 1.9419 3,747.944 9 3,747.944
9 1.0549 3,774.317
4 Unmitigated Construction On-Site
3.1 Mitigation Measures Construction
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Demolition 6 15.00 0.00 458.00 10.00 6.90 20.00 LD_Mix HDT_Mix HHDT Site Preparation 7 18.00 0.00 0.00 10.00 6.90 20.00 LD_Mix HDT_Mix HHDT Grading 8 20.00 0.00 0.00 10.00 6.90 20.00 LD_Mix HDT_Mix HHDT Building Construction 9 801.00 143.00 0.00 10.00 6.90 20.00 LD_Mix HDT_Mix HHDT Paving 6 15.00 0.00 0.00 10.00 6.90 20.00 LD_Mix HDT_Mix HHDT Architectural Coating 1 160.00 0.00 0.00 10.00 6.90 20.00 LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod.2016.3.2 Page 9 of 35 Date: 1/12/2021 2:30 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Winter 231
ATTACHMENT 3
1108
3.2 Demolition - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.1304 4.1454 1.0182 0.0117 0.2669 0.0128 0.2797 0.0732 0.0122 0.0854 1,269.855 5 1,269.855
5 0.0908 1,272.125
2 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0532 0.0346 0.3963 1.1100e0030.1141 9.5000e0040.1151 0.0303 8.8000e0040.0311 110.4707 110.4707 3.3300e003110.5539 Total 0.1835 4.1800 1.4144 0.0128 0.3810 0.0137 0.3948 0.1034 0.0131 0.1165 1,380.326 2 1,380.326
2 0.0941 1,382.679
1 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 3.3074 0.0000 3.3074 0.5008 0.0000 0.5008 0.0000 0.0000 Off-Road 3.1651 31.4407 21.5650 0.0388 1.5513 1.5513 1.4411 1.4411 0.0000 3,747.944 9 3,747.944
9 1.0549 3,774.317
4 Total 3.1651 31.4407 21.5650 0.0388 3.3074 1.5513 4.8588 0.5008 1.4411 1.9419 0.0000 3,747.944 9 3,747.944
9 1.0549 3,774.317
4 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 10 of 35 Date: 1/12/2021 2:30 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Winter 232
ATTACHMENT 3
1109
3.2 Demolition - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.1304 4.1454 1.0182 0.0117 0.2669 0.0128 0.2797 0.0732 0.0122 0.0854 1,269.855 5 1,269.855
5 0.0908 1,272.125
2 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0532 0.0346 0.3963 1.1100e0030.1141 9.5000e0040.1151 0.0303 8.8000e0040.0311 110.4707 110.4707 3.3300e003110.5539 Total 0.1835 4.1800 1.4144 0.0128 0.3810 0.0137 0.3948 0.1034 0.0131 0.1165 1,380.326 2 1,380.326
2 0.0941 1,382.679
1 Mitigated Construction Off-Site
3.3 Site Preparation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 18.0663 0.0000 18.0663 9.9307 0.0000 9.9307 0.0000 0.0000 Off-Road 3.8882 40.4971 21.1543 0.0380 2.0445 2.0445 1.8809 1.8809 3,685.656 9 3,685.656
9 1.1920 3,715.457
3 Total 3.8882 40.4971 21.1543 0.0380 18.0663 2.0445 20.1107 9.9307 1.8809 11.8116 3,685.656 9 3,685.656
9 1.1920 3,715.457
3 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 11 of 35 Date: 1/12/2021 2:30 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Winter 233
ATTACHMENT 3
1110
3.3 Site Preparation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0638 0.0415 0.4755 1.3300e0030.1369 1.1400e0030.1381 0.0363 1.0500e0030.0374 132.5649 132.5649 3.9900e003132.6646 Total 0.0638 0.0415 0.4755 1.3300e0030.1369 1.1400e0030.1381 0.0363 1.0500e0030.0374 132.5649 132.5649 3.9900e003132.6646 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 18.0663 0.0000 18.0663 9.9307 0.0000 9.9307 0.0000 0.0000 Off-Road 3.8882 40.4971 21.1543 0.0380 2.0445 2.0445 1.8809 1.8809 0.0000 3,685.656 9 3,685.656
9 1.1920 3,715.457
3 Total 3.8882 40.4971 21.1543 0.0380 18.0663 2.0445 20.1107 9.9307 1.8809 11.8116 0.0000 3,685.656 9 3,685.656
9 1.1920 3,715.457
3 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 12 of 35 Date: 1/12/2021 2:30 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Winter 234
ATTACHMENT 3
1111
3.3 Site Preparation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0638 0.0415 0.4755 1.3300e0030.1369 1.1400e0030.1381 0.0363 1.0500e0030.0374 132.5649 132.5649 3.9900e003132.6646 Total 0.0638 0.0415 0.4755 1.3300e0030.1369 1.1400e0030.1381 0.0363 1.0500e0030.0374 132.5649 132.5649 3.9900e003132.6646 Mitigated Construction Off-Site
3.4 Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 8.6733 0.0000 8.6733 3.5965 0.0000 3.5965 0.0000 0.0000 Off-Road 4.1912 46.3998 30.8785 0.0620 1.9853 1.9853 1.8265 1.8265 6,007.043 4 6,007.043
4 1.9428 6,055.613
4 Total 4.1912 46.3998 30.8785 0.0620 8.6733 1.9853 10.6587 3.5965 1.8265 5.4230 6,007.043 4 6,007.043
4 1.9428 6,055.613
4 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 13 of 35 Date: 1/12/2021 2:30 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Winter 235
ATTACHMENT 3
1112
3.4 Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0709 0.0462 0.5284 1.4800e0030.1521 1.2700e0030.1534 0.0404 1.1700e0030.0415 147.2943 147.2943 4.4300e003147.4051 Total 0.0709 0.0462 0.5284 1.4800e0030.1521 1.2700e0030.1534 0.0404 1.1700e0030.0415 147.2943 147.2943 4.4300e003147.4051 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 8.6733 0.0000 8.6733 3.5965 0.0000 3.5965 0.0000 0.0000 Off-Road 4.1912 46.3998 30.8785 0.0620 1.9853 1.9853 1.8265 1.8265 0.0000 6,007.043 4 6,007.043
4 1.9428 6,055.613
4 Total 4.1912 46.3998 30.8785 0.0620 8.6733 1.9853 10.6587 3.5965 1.8265 5.4230 0.0000 6,007.043 4 6,007.043
4 1.9428 6,055.613
4 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 14 of 35 Date: 1/12/2021 2:30 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Winter 236
ATTACHMENT 3
1113
3.4 Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0709 0.0462 0.5284 1.4800e0030.1521 1.2700e0030.1534 0.0404 1.1700e0030.0415 147.2943 147.2943 4.4300e003147.4051 Total 0.0709 0.0462 0.5284 1.4800e0030.1521 1.2700e0030.1534 0.0404 1.1700e0030.0415 147.2943 147.2943 4.4300e003147.4051 Mitigated Construction Off-Site
3.4 Grading - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 8.6733 0.0000 8.6733 3.5965 0.0000 3.5965 0.0000 0.0000 Off-Road 3.6248 38.8435 29.0415 0.0621 1.6349 1.6349 1.5041 1.5041 6,011.410 5 6,011.410
5 1.9442 6,060.015
8 Total 3.6248 38.8435 29.0415 0.0621 8.6733 1.6349 10.3082 3.5965 1.5041 5.1006 6,011.410 5 6,011.410
5 1.9442 6,060.015
8 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 15 of 35 Date: 1/12/2021 2:30 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Winter 237
ATTACHMENT 3
1114
3.4 Grading - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0665 0.0416 0.4861 1.4300e0030.1521 1.2300e0030.1534 0.0404 1.1300e0030.0415 142.1207 142.1207 4.0000e003142.2207 Total 0.0665 0.0416 0.4861 1.4300e0030.1521 1.2300e0030.1534 0.0404 1.1300e0030.0415 142.1207 142.1207 4.0000e003142.2207 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 8.6733 0.0000 8.6733 3.5965 0.0000 3.5965 0.0000 0.0000 Off-Road 3.6248 38.8435 29.0415 0.0621 1.6349 1.6349 1.5041 1.5041 0.0000 6,011.410 5 6,011.410
5 1.9442 6,060.015
8 Total 3.6248 38.8435 29.0415 0.0621 8.6733 1.6349 10.3082 3.5965 1.5041 5.1006 0.0000 6,011.410 5 6,011.410
5 1.9442 6,060.015
8 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 16 of 35 Date: 1/12/2021 2:30 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Winter 238
ATTACHMENT 3
1115
3.4 Grading - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0665 0.0416 0.4861 1.4300e0030.1521 1.2300e0030.1534 0.0404 1.1300e0030.0415 142.1207 142.1207 4.0000e003142.2207 Total 0.0665 0.0416 0.4861 1.4300e0030.1521 1.2300e0030.1534 0.0404 1.1300e0030.0415 142.1207 142.1207 4.0000e003142.2207 Mitigated Construction Off-Site
3.5 Building Construction - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 1.7062 15.6156 16.3634 0.0269 0.8090 0.8090 0.7612 0.7612 2,554.333 6 2,554.333
6 0.6120 2,569.632
2 Total 1.7062 15.6156 16.3634 0.0269 0.8090 0.8090 0.7612 0.7612 2,554.333 6 2,554.333
6 0.6120 2,569.632
2 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 17 of 35 Date: 1/12/2021 2:30 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Winter 239
ATTACHMENT 3
1116
3.5 Building Construction - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.4284 13.1673 3.8005 0.0354 0.9155 0.0256 0.9412 0.2636 0.0245 0.2881 3,789.075 0 3,789.075
0 0.2381 3,795.028
3 Worker 2.6620 1.6677 19.4699 0.0571 6.0932 0.0493 6.1425 1.6163 0.0454 1.6617 5,691.935 4 5,691.935
4 0.1602 5,695.940
8 Total 3.0904 14.8350 23.2704 0.0926 7.0087 0.0749 7.0836 1.8799 0.0699 1.9498 9,481.010 4 9,481.010
4 0.3984 9,490.969
1 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 1.7062 15.6156 16.3634 0.0269 0.8090 0.8090 0.7612 0.7612 0.0000 2,554.333 6 2,554.333
6 0.6120 2,569.632
2 Total 1.7062 15.6156 16.3634 0.0269 0.8090 0.8090 0.7612 0.7612 0.0000 2,554.333 6 2,554.333
6 0.6120 2,569.632
2 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 18 of 35 Date: 1/12/2021 2:30 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Winter 240
ATTACHMENT 3
1117
3.5 Building Construction - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.4284 13.1673 3.8005 0.0354 0.9155 0.0256 0.9412 0.2636 0.0245 0.2881 3,789.075 0 3,789.075
0 0.2381 3,795.028
3 Worker 2.6620 1.6677 19.4699 0.0571 6.0932 0.0493 6.1425 1.6163 0.0454 1.6617 5,691.935 4 5,691.935
4 0.1602 5,695.940
8 Total 3.0904 14.8350 23.2704 0.0926 7.0087 0.0749 7.0836 1.8799 0.0699 1.9498 9,481.010 4 9,481.010
4 0.3984 9,490.969
1 Mitigated Construction Off-Site
3.5 Building Construction - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 1.5728 14.3849 16.2440 0.0269 0.6997 0.6997 0.6584 0.6584 2,555.209 9 2,555.209
9 0.6079 2,570.406
1 Total 1.5728 14.3849 16.2440 0.0269 0.6997 0.6997 0.6584 0.6584 2,555.209 9 2,555.209
9 0.6079 2,570.406
1 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 19 of 35 Date: 1/12/2021 2:30 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Winter 241
ATTACHMENT 3
1118
3.5 Building Construction - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.3183 9.9726 3.3771 0.0343 0.9156 0.0122 0.9277 0.2636 0.0116 0.2752 3,671.400 7 3,671.400
7 0.2096 3,676.641
7 Worker 2.5029 1.5073 17.8820 0.0550 6.0932 0.0479 6.1411 1.6163 0.0441 1.6604 5,483.797 4 5,483.797
4 0.1442 5,487.402
0 Total 2.8211 11.4799 21.2591 0.0893 7.0088 0.0601 7.0688 1.8799 0.0557 1.9356 9,155.198 1 9,155.198
1 0.3538 9,164.043
7 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 1.5728 14.3849 16.2440 0.0269 0.6997 0.6997 0.6584 0.6584 0.0000 2,555.209 9 2,555.209
9 0.6079 2,570.406
1 Total 1.5728 14.3849 16.2440 0.0269 0.6997 0.6997 0.6584 0.6584 0.0000 2,555.209 9 2,555.209
9 0.6079 2,570.406
1 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 20 of 35 Date: 1/12/2021 2:30 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Winter 242
ATTACHMENT 3
1119
3.5 Building Construction - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.3183 9.9726 3.3771 0.0343 0.9156 0.0122 0.9277 0.2636 0.0116 0.2752 3,671.400 7 3,671.400
7 0.2096 3,676.641
7 Worker 2.5029 1.5073 17.8820 0.0550 6.0932 0.0479 6.1411 1.6163 0.0441 1.6604 5,483.797 4 5,483.797
4 0.1442 5,487.402
0 Total 2.8211 11.4799 21.2591 0.0893 7.0088 0.0601 7.0688 1.8799 0.0557 1.9356 9,155.198 1 9,155.198
1 0.3538 9,164.043
7 Mitigated Construction Off-Site
3.6 Paving - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 1.0327 10.1917 14.5842 0.0228 0.5102 0.5102 0.4694 0.4694 2,207.584 1 2,207.584
1 0.7140 2,225.433
6 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 1.0327 10.1917 14.5842 0.0228 0.5102 0.5102 0.4694 0.4694 2,207.584 1 2,207.584
1 0.7140 2,225.433
6 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 21 of 35 Date: 1/12/2021 2:30 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Winter 243
ATTACHMENT 3
1120
3.6 Paving - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0469 0.0282 0.3349 1.0300e0030.1141 9.0000e0040.1150 0.0303 8.3000e0040.0311 102.6928 102.6928 2.7000e003102.7603 Total 0.0469 0.0282 0.3349 1.0300e0030.1141 9.0000e0040.1150 0.0303 8.3000e0040.0311 102.6928 102.6928 2.7000e003102.7603 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 1.0327 10.1917 14.5842 0.0228 0.5102 0.5102 0.4694 0.4694 0.0000 2,207.584 1 2,207.584
1 0.7140 2,225.433
6 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 1.0327 10.1917 14.5842 0.0228 0.5102 0.5102 0.4694 0.4694 0.0000 2,207.584 1 2,207.584
1 0.7140 2,225.433
6 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 22 of 35 Date: 1/12/2021 2:30 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Winter 244
ATTACHMENT 3
1121
3.6 Paving - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0469 0.0282 0.3349 1.0300e0030.1141 9.0000e0040.1150 0.0303 8.3000e0040.0311 102.6928 102.6928 2.7000e003102.7603 Total 0.0469 0.0282 0.3349 1.0300e0030.1141 9.0000e0040.1150 0.0303 8.3000e0040.0311 102.6928 102.6928 2.7000e003102.7603 Mitigated Construction Off-Site
3.6 Paving - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.9882 9.5246 14.6258 0.0228 0.4685 0.4685 0.4310 0.4310 2,207.547 2 2,207.547
2 0.7140 2,225.396
3 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.9882 9.5246 14.6258 0.0228 0.4685 0.4685 0.4310 0.4310 2,207.547 2 2,207.547
2 0.7140 2,225.396
3 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 23 of 35 Date: 1/12/2021 2:30 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Winter 245
ATTACHMENT 3
1122
3.6 Paving - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0444 0.0257 0.3114 1.0000e0030.1141 8.8000e0040.1150 0.0303 8.1000e0040.0311 99.5045 99.5045 2.4700e00399.5663 Total 0.0444 0.0257 0.3114 1.0000e0030.1141 8.8000e0040.1150 0.0303 8.1000e0040.0311 99.5045 99.5045 2.4700e00399.5663 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.9882 9.5246 14.6258 0.0228 0.4685 0.4685 0.4310 0.4310 0.0000 2,207.547 2 2,207.547
2 0.7140 2,225.396
3 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.9882 9.5246 14.6258 0.0228 0.4685 0.4685 0.4310 0.4310 0.0000 2,207.547 2 2,207.547
2 0.7140 2,225.396
3 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 24 of 35 Date: 1/12/2021 2:30 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Winter 246
ATTACHMENT 3
1123
3.6 Paving - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0444 0.0257 0.3114 1.0000e0030.1141 8.8000e0040.1150 0.0303 8.1000e0040.0311 99.5045 99.5045 2.4700e00399.5663 Total 0.0444 0.0257 0.3114 1.0000e0030.1141 8.8000e0040.1150 0.0303 8.1000e0040.0311 99.5045 99.5045 2.4700e00399.5663 Mitigated Construction Off-Site
3.7 Architectural Coating - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Archit. Coating 236.4115 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.1808 1.2188 1.8101 2.9700e0030.0609 0.0609 0.0609 0.0609 281.4481 281.4481 0.0159 281.8443 Total 236.5923 1.2188 1.8101 2.9700e0030.0609 0.0609 0.0609 0.0609 281.4481 281.4481 0.0159 281.8443 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 25 of 35 Date: 1/12/2021 2:30 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Winter 247
ATTACHMENT 3
1124
3.7 Architectural Coating - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.4734 0.2743 3.3220 0.0107 1.2171 9.4300e0031.2266 0.3229 8.6800e0030.3315 1,061.381 8 1,061.381
8 0.0264 1,062.041
0 Total 0.4734 0.2743 3.3220 0.0107 1.2171 9.4300e0031.2266 0.3229 8.6800e0030.3315 1,061.381 8 1,061.381
8 0.0264 1,062.041
0 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Archit. Coating 236.4115 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.1808 1.2188 1.8101 2.9700e0030.0609 0.0609 0.0609 0.0609 0.0000 281.4481 281.4481 0.0159 281.8443 Total 236.5923 1.2188 1.8101 2.9700e0030.0609 0.0609 0.0609 0.0609 0.0000 281.4481 281.4481 0.0159 281.8443 Mitigated Construction On-Site
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1125
4.0 Operational Detail - Mobile
4.1 Mitigation Measures Mobile
3.7 Architectural Coating - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.4734 0.2743 3.3220 0.0107 1.2171 9.4300e0031.2266 0.3229 8.6800e0030.3315 1,061.381 8 1,061.381
8 0.0264 1,062.041
0 Total 0.4734 0.2743 3.3220 0.0107 1.2171 9.4300e0031.2266 0.3229 8.6800e0030.3315 1,061.381 8 1,061.381
8 0.0264 1,062.041
0 Mitigated Construction Off-Site
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1126
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 9.5233 45.9914 110.0422 0.4681 45.9592 0.3373 46.2965 12.2950 0.3132 12.6083 47,917.80 05 47,917.80
05 2.1953 47,972.68
39 Unmitigated 9.5233 45.9914 110.0422 0.4681 45.9592 0.3373 46.2965 12.2950 0.3132 12.6083 47,917.80 05 47,917.80
05 2.1953 47,972.68
39 4.2 Trip Summary Information
4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Apartments Low Rise 145.75 154.25 154.00 506,227 506,227 Apartments Mid Rise 4,026.75 3,773.25 4075.50 13,660,065 13,660,065 General Office Building 288.45 62.55 31.05 706,812 706,812 High Turnover (Sit Down Restaurant) 2,368.80 2,873.52 2817.72 3,413,937 3,413,937 Hotel 192.00 187.50 160.00 445,703 445,703
Quality Restaurant 501.12 511.92 461.20 707,488 707,488 Regional Shopping Center 528.08 601.44 357.84 1,112,221 1,112,221 Total 8,050.95 8,164.43 8,057.31 20,552,452 20,552,452
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ATTACHMENT 3
1127
Miles Trip % Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by Apartments Low Rise 14.70 5.90 8.70 40.20 19.20 40.60 86 11 3 Apartments Mid Rise 14.70 5.90 8.70 40.20 19.20 40.60 86 11 3 General Office Building 16.60 8.40 6.90 33.00 48.00 19.00 77 19 4 High Turnover (Sit Down
Restaurant)
16.60 8.40 6.90 8.50 72.50 19.00 37 20 43
Hotel 16.60 8.40 6.90 19.40 61.60 19.00 58 38 4
Quality Restaurant 16.60 8.40 6.90 12.00 69.00 19.00 38 18 44 Regional Shopping Center 16.60 8.40 6.90 16.30 64.70 19.00 54 35 11
5.0 Energy Detail
5.1 Mitigation Measures Energy
4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH Apartments Low Rise 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Apartments Mid Rise 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 General Office Building 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 High Turnover (Sit Down
Restaurant)
0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Hotel 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Quality Restaurant 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Regional Shopping Center 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Historical Energy Use: N
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ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
NaturalGas
Mitigated
0.7660 6.7462 4.2573 0.0418 0.5292 0.5292 0.5292 0.5292 8,355.983 2 8,355.983
2 0.1602 0.1532 8,405.638
7 NaturalGas
Unmitigated
0.7660 6.7462 4.2573 0.0418 0.5292 0.5292 0.5292 0.5292 8,355.983 2 8,355.983
2 0.1602 0.1532 8,405.638
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5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Apartments Low
Rise
1119.16 0.0121 0.1031 0.0439 6.6000e0048.3400e0038.3400e0038.3400e0038.3400e003131.6662 131.6662 2.5200e0032.4100e003132.4486 Apartments Mid
Rise
35784.3 0.3859 3.2978 1.4033 0.0211 0.2666 0.2666 0.2666 0.2666 4,209.916 4 4,209.916
4 0.0807 0.0772 4,234.933
9 General Office
Building
1283.42 0.0138 0.1258 0.1057 7.5000e0049.5600e0039.5600e0039.5600e0039.5600e003150.9911 150.9911 2.8900e0032.7700e003151.8884 High Turnover (Sit
Down Restaurant)
22759.9 0.2455 2.2314 1.8743 0.0134 0.1696 0.1696 0.1696 0.1696 2,677.634 2 2,677.634
2 0.0513 0.0491 2,693.546
0 Hotel 4769.72 0.0514 0.4676 0.3928 2.8100e0030.0355 0.0355 0.0355 0.0355 561.1436 561.1436 0.0108 0.0103 564.4782 Quality
Restaurant
5057.75 0.0545 0.4959 0.4165 2.9800e0030.0377 0.0377 0.0377 0.0377 595.0298 595.0298 0.0114 0.0109 598.5658 Regional
Shopping Center
251.616 2.7100e0030.0247 0.0207 1.5000e0041.8700e0031.8700e0031.8700e0031.8700e00329.6019 29.6019 5.7000e0045.4000e00429.7778 Total 0.7660 6.7463 4.2573 0.0418 0.5292 0.5292 0.5292 0.5292 8,355.983 2 8,355.983
2 0.1602 0.1532 8,405.638
7 Unmitigated
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6.1 Mitigation Measures Area
6.0 Area Detail
5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Apartments Low
Rise
1.11916 0.0121 0.1031 0.0439 6.6000e0048.3400e0038.3400e0038.3400e0038.3400e003131.6662 131.6662 2.5200e0032.4100e003132.4486 Apartments Mid
Rise
35.7843 0.3859 3.2978 1.4033 0.0211 0.2666 0.2666 0.2666 0.2666 4,209.916 4 4,209.916
4 0.0807 0.0772 4,234.933
9 General Office
Building
1.28342 0.0138 0.1258 0.1057 7.5000e0049.5600e0039.5600e0039.5600e0039.5600e003150.9911 150.9911 2.8900e0032.7700e003151.8884 High Turnover (Sit
Down Restaurant)
22.7599 0.2455 2.2314 1.8743 0.0134 0.1696 0.1696 0.1696 0.1696 2,677.634 2 2,677.634
2 0.0513 0.0491 2,693.546
0 Hotel 4.76972 0.0514 0.4676 0.3928 2.8100e0030.0355 0.0355 0.0355 0.0355 561.1436 561.1436 0.0108 0.0103 564.4782 Quality
Restaurant
5.05775 0.0545 0.4959 0.4165 2.9800e0030.0377 0.0377 0.0377 0.0377 595.0298 595.0298 0.0114 0.0109 598.5658 Regional
Shopping Center
0.251616 2.7100e0030.0247 0.0207 1.5000e0041.8700e0031.8700e0031.8700e0031.8700e00329.6019 29.6019 5.7000e0045.4000e00429.7778 Total 0.7660 6.7463 4.2573 0.0418 0.5292 0.5292 0.5292 0.5292 8,355.983 2 8,355.983
2 0.1602 0.1532 8,405.638
7 Mitigated
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1131
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 30.5020 15.0496 88.4430 0.0944 1.5974 1.5974 1.5974 1.5974 0.0000 18,148.59 50 18,148.59
50 0.4874 0.3300 18,259.11
92 Unmitigated 30.5020 15.0496 88.4430 0.0944 1.5974 1.5974 1.5974 1.5974 0.0000 18,148.59 50 18,148.59
50 0.4874 0.3300 18,259.11
92 6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
2.2670 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
24.1085 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Hearth 1.6500 14.1000 6.0000 0.0900 1.1400 1.1400 1.1400 1.1400 0.0000 18,000.00 00 18,000.00
00 0.3450 0.3300 18,106.96
50 Landscaping 2.4766 0.9496 82.4430 4.3600e0030.4574 0.4574 0.4574 0.4574 148.5950 148.5950 0.1424 152.1542 Total 30.5020 15.0496 88.4430 0.0944 1.5974 1.5974 1.5974 1.5974 0.0000 18,148.59 50 18,148.59
50 0.4874 0.3300 18,259.11
92 Unmitigated
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8.1 Mitigation Measures Waste
7.1 Mitigation Measures Water
7.0 Water Detail
8.0 Waste Detail
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
2.2670 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
24.1085 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Hearth 1.6500 14.1000 6.0000 0.0900 1.1400 1.1400 1.1400 1.1400 0.0000 18,000.00 00 18,000.00
00 0.3450 0.3300 18,106.96
50 Landscaping 2.4766 0.9496 82.4430 4.3600e0030.4574 0.4574 0.4574 0.4574 148.5950 148.5950 0.1424 152.1542 Total 30.5020 15.0496 88.4430 0.0944 1.5974 1.5974 1.5974 1.5974 0.0000 18,148.59 50 18,148.59
50 0.4874 0.3300 18,259.11
92 Mitigated
9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type
10.0 Stationary Equipment
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11.0 Vegetation
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment
Equipment Type Number
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Total Construction GHG Emissions (MT CO2e) 3,623
Amortized (MT CO2e/year) 120.77
Total Construction GHG Emissions (MT CO2e) 3,024
Amortized (MT CO2e/year) 100.80
% Decrease in Construction-related GHG Emissions 17%
Local Hire Provision Net Change
With Local Hire Provision
Without Local Hire Provision
Attachment C
258
ATTACHMENT 3
1135
EXHIBIT B
259
ATTACHMENT 3
1136
SOIL WATER AIR PROTECTION ENTERPRISE
2656 29th Street, Suite 201
Santa Monica, California 90405
Attn: Paul Rosenfeld, Ph.D.
Mobil: (310) 795-2335
Office: (310) 452-5555
Fax: (310) 452-5550
Email: [email protected]
Paul E. Rosenfeld, Ph.D. Page 1 of 10 June 2019
Paul Rosenfeld, Ph.D. Chemical Fate and Transport & Air Dispersion Modeling Principal Environmental Chemist Risk Assessment & Remediation Specialist Education
Ph.D. Soil Chemistry, University of Washington, 1999. Dissertation on volatile organic compound filtration.
M.S. Environmental Science, U.C. Berkeley, 1995. Thesis on organic waste economics.
B.A. Environmental Studies, U.C. Santa Barbara, 1991. Thesis on wastewater treatment.
Professional Experience
Dr. Rosenfeld has over 25 years’ experience conducting environmental investigations and risk assessments for evaluating impacts to human health, property, and ecological receptors. His expertise focuses on the fate and transport of environmental contaminants, human health risk, exposure assessment, and ecological restoration. Dr.
Rosenfeld has evaluated and modeled emissions from unconventional oil drilling operations, oil spills, landfills, boilers and incinerators, process stacks, storage tanks, confined animal feeding operations, and many other industrial and agricultural sources. His project experience ranges from monitoring and modeling of pollution sources to evaluating impacts of pollution on workers at industrial facilities and residents in surrounding communities.
Dr. Rosenfeld has investigated and designed remediation programs and risk assessments for contaminated sites containing lead, heavy metals, mold, bacteria, particulate matter, petroleum hydrocarbons, chlorinated solvents, pesticides, radioactive waste, dioxins and furans, semi- and volatile organic compounds, PCBs, PAHs, perchlorate, asbestos, per- and poly-fluoroalkyl substances (PFOA/PFOS), unusual polymers, fuel oxygenates (MTBE), among other pollutants. Dr. Rosenfeld also has experience evaluating greenhouse gas emissions from various projects and is an expert on the assessment of odors from industrial and agricultural sites, as well as the evaluation of odor nuisance impacts and technologies for abatement of odorous emissions. As a principal scientist at SWAPE, Dr. Rosenfeld directs air dispersion modeling and exposure assessments. He has served as an expert witness and testified about pollution sources causing nuisance and/or personal injury at dozens of sites and has testified as an expert witness on more than ten cases involving exposure to air contaminants from industrial sources. 260
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Professional History:
Soil Water Air Protection Enterprise (SWAPE); 2003 to present; Principal and Founding Partner UCLA School of Public Health; 2007 to 2011; Lecturer (Assistant Researcher) UCLA School of Public Health; 2003 to 2006; Adjunct Professor UCLA Environmental Science and Engineering Program; 2002-2004; Doctoral Intern Coordinator UCLA Institute of the Environment, 2001-2002; Research Associate Komex H2O Science, 2001 to 2003; Senior Remediation Scientist National Groundwater Association, 2002-2004; Lecturer
San Diego State University, 1999-2001; Adjunct Professor Anteon Corp., San Diego, 2000-2001; Remediation Project Manager Ogden (now Amec), San Diego, 2000-2000; Remediation Project Manager Bechtel, San Diego, California, 1999 – 2000; Risk Assessor King County, Seattle, 1996 – 1999; Scientist
James River Corp., Washington, 1995-96; Scientist
Big Creek Lumber, Davenport, California, 1995; Scientist Plumas Corp., California and USFS, Tahoe 1993-1995; Scientist Peace Corps and World Wildlife Fund, St. Kitts, West Indies, 1991-1993; Scientist Publications:
Remy, L.L., Clay T., Byers, V., Rosenfeld P. E. (2019) Hospital, Health, and Community Burden After Oil Refinery Fires, Richmond, California 2007 and 2012. Environmental Health. 18:48 Simons, R.A., Seo, Y. Rosenfeld, P., (2015) Modeling the Effect of Refinery Emission On Residential Property Value. Journal of Real Estate Research. 27(3):321-342
Chen, J. A, Zapata A. R., Sutherland A. J., Molmen, D.R., Chow, B. S., Wu, L. E., Rosenfeld, P. E., Hesse, R. C., (2012) Sulfur Dioxide and Volatile Organic Compound Exposure To A Community In Texas City Texas Evaluated Using Aermod and Empirical Data. American Journal of Environmental Science, 8(6), 622-632.
Rosenfeld, P.E. & Feng, L. (2011). The Risks of Hazardous Waste. Amsterdam: Elsevier Publishing.
Cheremisinoff, N.P., & Rosenfeld, P.E. (2011). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Agrochemical Industry, Amsterdam: Elsevier Publishing.
Gonzalez, J., Feng, L., Sutherland, A., Waller, C., Sok, H., Hesse, R., Rosenfeld, P. (2010). PCBs and Dioxins/Furans in Attic Dust Collected Near Former PCB Production and Secondary Copper Facilities in Sauget, IL.
Procedia Environmental Sciences. 113–125.
Feng, L., Wu, C., Tam, L., Sutherland, A.J., Clark, J.J., Rosenfeld, P.E. (2010). Dioxin and Furan Blood Lipid and Attic Dust Concentrations in Populations Living Near Four Wood Treatment Facilities in the United States. Journal of Environmental Health. 73(6), 34-46.
Cheremisinoff, N.P., & Rosenfeld, P.E. (2010). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Wood and Paper Industries. Amsterdam: Elsevier Publishing.
Cheremisinoff, N.P., & Rosenfeld, P.E. (2009). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Petroleum Industry. Amsterdam: Elsevier Publishing.
Wu, C., Tam, L., Clark, J., Rosenfeld, P. (2009). Dioxin and furan blood lipid concentrations in populations living near four wood treatment facilities in the United States. WIT Transactions on Ecology and the Environment, Air Pollution, 123 (17), 319-327.
261
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Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). A Statistical Analysis Of Attic Dust And Blood Lipid Concentrations Of Tetrachloro-p-Dibenzodioxin (TCDD) Toxicity Equivalency Quotients (TEQ) In Two Populations Near Wood Treatment Facilities. Organohalogen Compounds, 70, 002252-002255.
Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). Methods For Collect Samples For Assessing Dioxins And Other Environmental Contaminants In Attic Dust: A Review. Organohalogen Compounds, 70, 000527- 000530.
Hensley, A.R. A. Scott, J. J. J. Clark, Rosenfeld, P.E. (2007). Attic Dust and Human Blood Samples Collected near a Former Wood Treatment Facility. Environmental Research. 105, 194-197.
Rosenfeld, P.E., J. J. J. Clark, A. R. Hensley, M. Suffet. (2007). The Use of an Odor Wheel Classification for Evaluation of Human Health Risk Criteria for Compost Facilities. Water Science & Technology 55(5), 345-357.
Rosenfeld, P. E., M. Suffet. (2007). The Anatomy Of Odour Wheels For Odours Of Drinking Water, Wastewater, Compost And The Urban Environment. Water Science & Technology 55(5), 335-344.
Sullivan, P. J. Clark, J.J.J., Agardy, F. J., Rosenfeld, P.E. (2007). Toxic Legacy, Synthetic Toxins in the Food, Water, and Air in American Cities. Boston Massachusetts: Elsevier Publishing Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash. Water Science and Technology. 49(9),171-178.
Rosenfeld P. E., J.J. Clark, I.H. (Mel) Suffet (2004). The Value of An Odor-Quality-Wheel Classification Scheme For The Urban Environment. Water Environment Federation’s Technical Exhibition and Conference (WEFTEC) 2004. New Orleans, October 2-6, 2004.
Rosenfeld, P.E., and Suffet, I.H. (2004). Understanding Odorants Associated With Compost, Biomass Facilities, and the Land Application of Biosolids. Water Science and Technology. 49(9), 193-199.
Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash, Water Science and Technology, 49( 9), 171-178.
Rosenfeld, P. E., Grey, M. A., Sellew, P. (2004). Measurement of Biosolids Odor and Odorant Emissions from Windrows, Static Pile and Biofilter. Water Environment Research. 76(4), 310-315.
Rosenfeld, P.E., Grey, M and Suffet, M. (2002). Compost Demonstration Project, Sacramento California Using High-Carbon Wood Ash to Control Odor at a Green Materials Composting Facility. Integrated Waste Management Board Public Affairs Office, Publications Clearinghouse (MS–6), Sacramento, CA Publication #442-02-008.
Rosenfeld, P.E., and C.L. Henry. (2001). Characterization of odor emissions from three different biosolids. Water Soil and Air Pollution. 127(1-4), 173-191.
Rosenfeld, P.E., and Henry C. L., (2000). Wood ash control of odor emissions from biosolids application. Journal of Environmental Quality. 29, 1662-1668.
Rosenfeld, P.E., C.L. Henry and D. Bennett. (2001). Wastewater dewatering polymer affect on biosolids odor emissions and microbial activity. Water Environment Research. 73(4), 363-367.
Rosenfeld, P.E., and C.L. Henry. (2001). Activated Carbon and Wood Ash Sorption of Wastewater, Compost, and Biosolids Odorants. Water Environment Research, 73, 388-393.
Rosenfeld, P.E., and Henry C. L., (2001). High carbon wood ash effect on biosolids microbial activity and odor.
Water Environment Research. 131(1-4), 247-262.
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Chollack, T. and P. Rosenfeld. (1998). Compost Amendment Handbook For Landscaping. Prepared for and distributed by the City of Redmond, Washington State.
Rosenfeld, P. E. (1992). The Mount Liamuiga Crater Trail. Heritage Magazine of St. Kitts, 3(2).
Rosenfeld, P. E. (1993). High School Biogas Project to Prevent Deforestation On St. Kitts. Biomass Users Network, 7(1).
Rosenfeld, P. E. (1998). Characterization, Quantification, and Control of Odor Emissions From Biosolids Application To Forest Soil. Doctoral Thesis. University of Washington College of Forest Resources.
Rosenfeld, P. E. (1994). Potential Utilization of Small Diameter Trees on Sierra County Public Land. Masters thesis reprinted by the Sierra County Economic Council. Sierra County, California.
Rosenfeld, P. E. (1991). How to Build a Small Rural Anaerobic Digester & Uses Of Biogas In The First And Third World. Bachelors Thesis. University of California.
Presentations:
Rosenfeld, P.E., Sutherland, A; Hesse, R.; Zapata, A. (October 3-6, 2013). Air dispersion modeling of volatile organic emissions from multiple natural gas wells in Decatur, TX. 44th Western Regional Meeting, American Chemical Society. Lecture conducted from Santa Clara, CA.
Sok, H.L.; Waller, C.C.; Feng, L.; Gonzalez, J.; Sutherland, A.J.; Wisdom-Stack, T.; Sahai, R.K.; Hesse, R.C.; Rosenfeld, P.E. (June 20-23, 2010). Atrazine: A Persistent Pesticide in Urban Drinking Water.
Urban Environmental Pollution. Lecture conducted from Boston, MA.
Feng, L.; Gonzalez, J.; Sok, H.L.; Sutherland, A.J.; Waller, C.C.; Wisdom-Stack, T.; Sahai, R.K.; La, M.; Hesse, R.C.; Rosenfeld, P.E. (June 20-23, 2010). Bringing Environmental Justice to East St. Louis, Illinois. Urban Environmental Pollution. Lecture conducted from Boston, MA.
Rosenfeld, P.E. (April 19-23, 2009). Perfluoroctanoic Acid (PFOA) and Perfluoroactane Sulfonate (PFOS) Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the United States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting, Lecture conducted from Tuscon, AZ.
Rosenfeld, P.E. (April 19-23, 2009). Cost to Filter Atrazine Contamination from Drinking Water in the United States” Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the United States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting. Lecture conducted from Tuscon, AZ.
Wu, C., Tam, L., Clark, J., Rosenfeld, P. (20-22 July, 2009). Dioxin and furan blood lipid concentrations in populations living near four wood treatment facilities in the United States. Brebbia, C.A. and Popov, V., eds., Air Pollution XVII: Proceedings of the Seventeenth International Conference on Modeling, Monitoring and Management of Air Pollution. Lecture conducted from Tallinn, Estonia.
Rosenfeld, P. E. (October 15-18, 2007). Moss Point Community Exposure To Contaminants From A Releasing Facility. The 23rd Annual International Conferences on Soils Sediment and Water. Platform lecture conducted from University of Massachusetts, Amherst MA.
Rosenfeld, P. E. (October 15-18, 2007). The Repeated Trespass of Tritium-Contaminated Water Into A Surrounding Community Form Repeated Waste Spills From A Nuclear Power Plant. The 23rd Annual International Conferences on Soils Sediment and Water. Platform lecture conducted from University of Massachusetts, Amherst MA.
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Rosenfeld, P. E. (October 15-18, 2007). Somerville Community Exposure To Contaminants From Wood Treatment Facility Emissions. The 23rd Annual International Conferences on Soils Sediment and Water. Lecture conducted from University of Massachusetts, Amherst MA.
Rosenfeld P. E. (March 2007). Production, Chemical Properties, Toxicology, & Treatment Case Studies of 1,2,3- Trichloropropane (TCP). The Association for Environmental Health and Sciences (AEHS) Annual Meeting. Lecture conducted from San Diego, CA.
Rosenfeld P. E. (March 2007). Blood and Attic Sampling for Dioxin/Furan, PAH, and Metal Exposure in Florala, Alabama. The AEHS Annual Meeting. Lecture conducted from San Diego, CA.
Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (August 21 – 25, 2006). Dioxin Containing Attic Dust And Human Blood Samples Collected Near A Former Wood Treatment Facility. The 26th International Symposium on Halogenated Persistent Organic Pollutants – DIOXIN2006. Lecture conducted from Radisson SAS Scandinavia Hotel in Oslo Norway.
Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (November 4-8, 2006). Dioxin Containing Attic Dust And Human Blood Samples Collected Near A Former Wood Treatment Facility. APHA 134 Annual Meeting & Exposition. Lecture conducted from Boston Massachusetts.
Paul Rosenfeld Ph.D. (October 24-25, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.
Mealey’s C8/PFOA. Science, Risk & Litigation Conference. Lecture conducted from The Rittenhouse Hotel, Philadelphia, PA.
Paul Rosenfeld Ph.D. (September 19, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human Ingestion, Toxicology and Remediation PEMA Emerging Contaminant Conference. Lecture conducted from Hilton Hotel, Irvine California.
Paul Rosenfeld Ph.D. (September 19, 2005). Fate, Transport, Toxicity, And Persistence of 1,2,3-TCP. PEMA Emerging Contaminant Conference. Lecture conducted from Hilton Hotel in Irvine, California.
Paul Rosenfeld Ph.D. (September 26-27, 2005). Fate, Transport and Persistence of PDBEs. Mealey’s Groundwater Conference. Lecture conducted from Ritz Carlton Hotel, Marina Del Ray, California.
Paul Rosenfeld Ph.D. (June 7-8, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.
International Society of Environmental Forensics: Focus On Emerging Contaminants. Lecture conducted from Sheraton Oceanfront Hotel, Virginia Beach, Virginia.
Paul Rosenfeld Ph.D. (July 21-22, 2005). Fate Transport, Persistence and Toxicology of PFOA and Related Perfluorochemicals. 2005 National Groundwater Association Ground Water And Environmental Law Conference.
Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.
Paul Rosenfeld Ph.D. (July 21-22, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human Ingestion, Toxicology and Remediation. 2005 National Groundwater Association Ground Water and Environmental Law Conference. Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.
Paul Rosenfeld, Ph.D. and James Clark Ph.D. and Rob Hesse R.G. (May 5-6, 2004). Tert-butyl Alcohol Liability and Toxicology, A National Problem and Unquantified Liability. National Groundwater Association. Environmental Law Conference. Lecture conducted from Congress Plaza Hotel, Chicago Illinois.
Paul Rosenfeld, Ph.D. (March 2004). Perchlorate Toxicology. Meeting of the American Groundwater Trust.
Lecture conducted from Phoenix Arizona.
Hagemann, M.F., Paul Rosenfeld, Ph.D. and Rob Hesse (2004). Perchlorate Contamination of the Colorado River.
Meeting of tribal representatives. Lecture conducted from Parker, AZ. 264
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Paul Rosenfeld, Ph.D. (April 7, 2004). A National Damage Assessment Model For PCE and Dry Cleaners.
Drycleaner Symposium. California Ground Water Association. Lecture conducted from Radison Hotel, Sacramento, California.
Rosenfeld, P. E., Grey, M., (June 2003) Two stage biofilter for biosolids composting odor control. Seventh International In Situ And On Site Bioremediation Symposium Battelle Conference Orlando, FL.
Paul Rosenfeld, Ph.D. and James Clark Ph.D. (February 20-21, 2003) Understanding Historical Use, Chemical Properties, Toxicity and Regulatory Guidance of 1,4 Dioxane. National Groundwater Association. Southwest Focus Conference. Water Supply and Emerging Contaminants.. Lecture conducted from Hyatt Regency Phoenix Arizona.
Paul Rosenfeld, Ph.D. (February 6-7, 2003). Underground Storage Tank Litigation and Remediation. California CUPA Forum. Lecture conducted from Marriott Hotel, Anaheim California.
Paul Rosenfeld, Ph.D. (October 23, 2002) Underground Storage Tank Litigation and Remediation. EPA Underground Storage Tank Roundtable. Lecture conducted from Sacramento California.
Rosenfeld, P.E. and Suffet, M. (October 7- 10, 2002). Understanding Odor from Compost, Wastewater and Industrial Processes. Sixth Annual Symposium On Off Flavors in the Aquatic Environment. International Water Association. Lecture conducted from Barcelona Spain.
Rosenfeld, P.E. and Suffet, M. (October 7- 10, 2002). Using High Carbon Wood Ash to Control Compost Odor.
Sixth Annual Symposium On Off Flavors in the Aquatic Environment. International Water Association. Lecture conducted from Barcelona Spain.
Rosenfeld, P.E. and Grey, M. A. (September 22-24, 2002). Biocycle Composting For Coastal Sage Restoration.
Northwest Biosolids Management Association. Lecture conducted from Vancouver Washington..
Rosenfeld, P.E. and Grey, M. A. (November 11-14, 2002). Using High-Carbon Wood Ash to Control Odor at a Green Materials Composting Facility. Soil Science Society Annual Conference. Lecture conducted from Indianapolis, Maryland.
Rosenfeld. P.E. (September 16, 2000). Two stage biofilter for biosolids composting odor control. Water Environment Federation. Lecture conducted from Anaheim California.
Rosenfeld. P.E. (October 16, 2000). Wood ash and biofilter control of compost odor. Biofest. Lecture conducted from Ocean Shores, California.
Rosenfeld, P.E. (2000). Bioremediation Using Organic Soil Amendments. California Resource Recovery Association. Lecture conducted from Sacramento California.
Rosenfeld, P.E., C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur Emissions Following Biosolids Incorporation With High-Carbon Wood-Ash. Water Environment Federation 12th Annual Residuals and Biosolids Management Conference Proceedings. Lecture conducted from Bellevue Washington.
Rosenfeld, P.E., and C.L. Henry. (1999). An evaluation of ash incorporation with biosolids for odor reduction. Soil Science Society of America. Lecture conducted from Salt Lake City Utah.
Rosenfeld, P.E., C.L. Henry, R. Harrison. (1998). Comparison of Microbial Activity and Odor Emissions from Three Different Biosolids Applied to Forest Soil. Brown and Caldwell. Lecture conducted from Seattle Washington.
Rosenfeld, P.E., C.L. Henry. (1998). Characterization, Quantification, and Control of Odor Emissions from Biosolids Application To Forest Soil. Biofest. Lecture conducted from Lake Chelan, Washington. 265
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Rosenfeld, P.E, C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur Emissions Following Biosolids Incorporation With High-Carbon Wood-Ash. Water Environment Federation 12th Annual Residuals and Biosolids Management Conference Proceedings. Lecture conducted from Bellevue Washington.
Rosenfeld, P.E., C.L. Henry, R. B. Harrison, and R. Dills. (1997). Comparison of Odor Emissions From Three Different Biosolids Applied to Forest Soil. Soil Science Society of America. Lecture conducted from Anaheim California.
Teaching Experience:
UCLA Department of Environmental Health (Summer 2003 through 20010) Taught Environmental Health Science 100 to students, including undergrad, medical doctors, public health professionals and nurses. Course focused on the health effects of environmental contaminants.
National Ground Water Association, Successful Remediation Technologies. Custom Course in Sante Fe, New Mexico. May 21, 2002. Focused on fate and transport of fuel contaminants associated with underground storage tanks.
National Ground Water Association; Successful Remediation Technologies Course in Chicago Illinois. April 1, 2002. Focused on fate and transport of contaminants associated with Superfund and RCRA sites.
California Integrated Waste Management Board, April and May, 2001. Alternative Landfill Caps Seminar in San Diego, Ventura, and San Francisco. Focused on both prescriptive and innovative landfill cover design.
UCLA Department of Environmental Engineering, February 5, 2002. Seminar on Successful Remediation Technologies focusing on Groundwater Remediation.
University Of Washington, Soil Science Program, Teaching Assistant for several courses including: Soil Chemistry, Organic Soil Amendments, and Soil Stability.
U.C. Berkeley, Environmental Science Program Teaching Assistant for Environmental Science 10.
Academic Grants Awarded:
California Integrated Waste Management Board. $41,000 grant awarded to UCLA Institute of the Environment.
Goal: To investigate effect of high carbon wood ash on volatile organic emissions from compost. 2001.
Synagro Technologies, Corona California: $10,000 grant awarded to San Diego State University.
Goal: investigate effect of biosolids for restoration and remediation of degraded coastal sage soils. 2000.
King County, Department of Research and Technology, Washington State. $100,000 grant awarded to University of Washington: Goal: To investigate odor emissions from biosolids application and the effect of polymers and ash on VOC emissions. 1998.
Northwest Biosolids Management Association, Washington State. $20,000 grant awarded to investigate effect of polymers and ash on VOC emissions from biosolids. 1997.
James River Corporation, Oregon: $10,000 grant was awarded to investigate the success of genetically engineered Poplar trees with resistance to round-up. 1996.
United State Forest Service, Tahoe National Forest: $15,000 grant was awarded to investigating fire ecology of the Tahoe National Forest. 1995.
Kellogg Foundation, Washington D.C. $500 grant was awarded to construct a large anaerobic digester on St. Kitts in West Indies. 1993
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Deposition and/or Trial Testimony:
In the United States District Court For The District of New Jersey Duarte et al, Plaintiffs, vs. United States Metals Refining Company et. al. Defendant.
Case No.: 2:17-cv-01624-ES-SCM
Rosenfeld Deposition. 6-7-2019
In the United States District Court of Southern District of Texas Galveston Division M/T Carla Maersk, Plaintiffs, vs. Conti 168., Schiffahrts-GMBH & Co. Bulker KG MS “Conti Perdido” Defendant.
Case No.: 3:15-CV-00106 consolidated with 3:15-CV-00237 Rosenfeld Deposition. 5-9-2019
In The Superior Court of the State of California In And For The County Of Los Angeles – Santa Monica Carole-Taddeo-Bates et al., vs. Ifran Khan et al., Defendants Case No.: No. BC615636
Rosenfeld Deposition, 1-26-2019
In The Superior Court of the State of California In And For The County Of Los Angeles – Santa Monica The San Gabriel Valley Council of Governments et al. vs El Adobe Apts. Inc. et al., Defendants Case No.: No. BC646857
Rosenfeld Deposition, 10-6-2018; Trial 3-7-19
In United States District Court For The District of Colorado Bells et al. Plaintiff vs. The 3M Company et al., Defendants Case: No 1:16-cv-02531-RBJ
Rosenfeld Deposition, 3-15-2018 and 4-3-2018
In The District Court Of Regan County, Texas, 112th Judicial District Phillip Bales et al., Plaintiff vs. Dow Agrosciences, LLC, et al., Defendants Cause No 1923
Rosenfeld Deposition, 11-17-2017
In The Superior Court of the State of California In And For The County Of Contra Costa Simons et al., Plaintiffs vs. Chevron Corporation, et al., Defendants Cause No C12-01481
Rosenfeld Deposition, 11-20-2017
In The Circuit Court Of The Twentieth Judicial Circuit, St Clair County, Illinois Martha Custer et al., Plaintiff vs. Cerro Flow Products, Inc., Defendants Case No.: No. 0i9-L-2295
Rosenfeld Deposition, 8-23-2017
In The Superior Court of the State of California, For The County of Los Angeles Warrn Gilbert and Penny Gilber, Plaintiff vs. BMW of North America LLC Case No.: LC102019 (c/w BC582154)
Rosenfeld Deposition, 8-16-2017, Trail 8-28-2018
In the Northern District Court of Mississippi, Greenville Division Brenda J. Cooper, et al., Plaintiffs, vs. Meritor Inc., et al., Defendants Case Number: 4:16-cv-52-DMB-JVM
Rosenfeld Deposition: July 2017
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In The Superior Court of the State of Washington, County of Snohomish Michael Davis and Julie Davis et al., Plaintiff vs. Cedar Grove Composting Inc., Defendants Case No.: No. 13-2-03987-5
Rosenfeld Deposition, February 2017
Trial, March 2017
In The Superior Court of the State of California, County of Alameda Charles Spain., Plaintiff vs. Thermo Fisher Scientific, et al., Defendants Case No.: RG14711115
Rosenfeld Deposition, September 2015
In The Iowa District Court In And For Poweshiek County
Russell D. Winburn, et al., Plaintiffs vs. Doug Hoksbergen, et al., Defendants Case No.: LALA002187
Rosenfeld Deposition, August 2015
In The Iowa District Court For Wapello County
Jerry Dovico, et al., Plaintiffs vs. Valley View Sine LLC, et al., Defendants Law No,: LALA105144 - Division A
Rosenfeld Deposition, August 2015
In The Iowa District Court For Wapello County
Doug Pauls, et al.,, et al., Plaintiffs vs. Richard Warren, et al., Defendants Law No,: LALA105144 - Division A
Rosenfeld Deposition, August 2015
In The Circuit Court of Ohio County, West Virginia
Robert Andrews, et al. v. Antero, et al.
Civil Action N0. 14-C-30000
Rosenfeld Deposition, June 2015
In The Third Judicial District County of Dona Ana, New Mexico Betty Gonzalez, et al. Plaintiffs vs. Del Oro Dairy, Del Oro Real Estate LLC, Jerry Settles and Deward DeRuyter, Defendants
Rosenfeld Deposition: July 2015
In The Iowa District Court For Muscatine County
Laurie Freeman et. al. Plaintiffs vs. Grain Processing Corporation, Defendant Case No 4980
Rosenfeld Deposition: May 2015
In the Circuit Court of the 17th Judicial Circuit, in and For Broward County, Florida Walter Hinton, et. al. Plaintiff, vs. City of Fort Lauderdale, Florida, a Municipality, Defendant.
Case Number CACE07030358 (26)
Rosenfeld Deposition: December 2014
In the United States District Court Western District of Oklahoma Tommy McCarty, et al., Plaintiffs, v. Oklahoma City Landfill, LLC d/b/a Southeast Oklahoma City Landfill, et al. Defendants.
Case No. 5:12-cv-01152-C
Rosenfeld Deposition: July 2014
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In the County Court of Dallas County Texas
Lisa Parr et al, Plaintiff, vs. Aruba et al, Defendant.
Case Number cc-11-01650-E
Rosenfeld Deposition: March and September 2013
Rosenfeld Trial: April 2014
In the Court of Common Pleas of Tuscarawas County Ohio
John Michael Abicht, et al., Plaintiffs, vs. Republic Services, Inc., et al., Defendants Case Number: 2008 CT 10 0741 (Cons. w/ 2009 CV 10 0987) Rosenfeld Deposition: October 2012
In the United States District Court of Southern District of Texas Galveston Division Kyle Cannon, Eugene Donovan, Genaro Ramirez, Carol Sassler, and Harvey Walton, each Individually and on behalf of those similarly situated, Plaintiffs, vs. BP Products North America, Inc., Defendant.
Case 3:10-cv-00622
Rosenfeld Deposition: February 2012
Rosenfeld Trial: April 2013
In the Circuit Court of Baltimore County Maryland
Philip E. Cvach, II et al., Plaintiffs vs. Two Farms, Inc. d/b/a Royal Farms, Defendants Case Number: 03-C-12-012487 OT
Rosenfeld Deposition: September 2013
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EXHIBIT C
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1640 5th St.., Suite 204 Santa
Santa Monica, California 90401
Tel: (949) 887‐9013
Email: [email protected]
Matthew F. Hagemann, P.G., C.Hg., QSD, QSP
Geologic and Hydrogeologic Characterization
Industrial Stormwater Compliance
Investigation and Remediation Strategies
Litigation Support and Testifying Expert
CEQA Review
Education:
M.S. Degree, Geology, California State University Los Angeles, Los Angeles, CA, 1984.
B.A. Degree, Geology, Humboldt State University, Arcata, CA, 1982.
Professional Certifications:
California Professional Geologist
California Certified Hydrogeologist
Qualified SWPPP Developer and Practitioner
Professional Experience:
Matt has 25 years of experience in environmental policy, assessment and remediation. He spent nine years with the U.S. EPA in the RCRA and Superfund programs and served as EPA’s Senior Science Policy Advisor in the Western Regional Office where he identified emerging threats to groundwater from perchlorate and MTBE. While with EPA, Matt also served as a Senior Hydrogeologist in the oversight of the assessment of seven major military facilities undergoing base closure. He led numerous enforcement actions under provisions of the Resource Conservation and Recovery Act (RCRA) while also working with permit holders to improve hydrogeologic characterization and water quality monitoring.
Matt has worked closely with U.S. EPA legal counsel and the technical staff of several states in the application and enforcement of RCRA, Safe Drinking Water Act and Clean Water Act regulations. Matt has trained the technical staff in the States of California, Hawaii, Nevada, Arizona and the Territory of Guam in the conduct of investigations, groundwater fundamentals, and sampling techniques.
Positions Matt has held include:
• Founding Partner, Soil/Water/Air Protection Enterprise (SWAPE) (2003 – present); • Geology Instructor, Golden West College, 2010 – 2014; • Senior Environmental Analyst, Komex H2O Science, Inc. (2000 ‐‐ 2003); 271
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• Executive Director, Orange Coast Watch (2001 – 2004); • Senior Science Policy Advisor and Hydrogeologist, U.S. Environmental Protection Agency (1989– 1998);
• Hydrogeologist, National Park Service, Water Resources Division (1998 – 2000); • Adjunct Faculty Member, San Francisco State University, Department of Geosciences (1993 – 1998);
• Instructor, College of Marin, Department of Science (1990 – 1995); • Geologist, U.S. Forest Service (1986 – 1998); and
• Geologist, Dames & Moore (1984 – 1986).
Senior Regulatory and Litigation Support Analyst:
With SWAPE, Matt’s responsibilities have included:
• Lead analyst and testifying expert in the review of over 100 environmental impact reports since 2003 under CEQA that identify significant issues with regard to hazardous waste, water resources, water quality, air quality, Valley Fever, greenhouse gas emissions, and geologic hazards. Make recommendations for additional mitigation measures to lead agencies at the local and county level to include additional characterization of health risks and implementation of protective measures to reduce worker exposure to hazards from toxins and Valley Fever.
• Stormwater analysis, sampling and best management practice evaluation at industrial facilities. • Manager of a project to provide technical assistance to a community adjacent to a former Naval shipyard under a grant from the U.S. EPA.
• Technical assistance and litigation support for vapor intrusion concerns. • Lead analyst and testifying expert in the review of environmental issues in license applications for large solar power plants before the California Energy Commission. • Manager of a project to evaluate numerous formerly used military sites in the western U.S. • Manager of a comprehensive evaluation of potential sources of perchlorate contamination in Southern California drinking water wells.
• Manager and designated expert for litigation support under provisions of Proposition 65 in the review of releases of gasoline to sources drinking water at major refineries and hundreds of gas stations throughout California.
• Expert witness on two cases involving MTBE litigation. • Expert witness and litigation support on the impact of air toxins and hazards at a school. • Expert witness in litigation at a former plywood plant.
With Komex H2O Science Inc., Matt’s duties included the following:
• Senior author of a report on the extent of perchlorate contamination that was used in testimony by the former U.S. EPA Administrator and General Counsel. • Senior researcher in the development of a comprehensive, electronically interactive chronology of MTBE use, research, and regulation.
• Senior researcher in the development of a comprehensive, electronically interactive chronology of perchlorate use, research, and regulation.
• Senior researcher in a study that estimates nationwide costs for MTBE remediation and drinking water treatment, results of which were published in newspapers nationwide and in testimony against provisions of an energy bill that would limit liability for oil companies. • Research to support litigation to restore drinking water supplies that have been contaminated by MTBE in California and New York.
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• Expert witness testimony in a case of oil production‐related contamination in Mississippi. • Lead author for a multi‐volume remedial investigation report for an operating school in Los Angeles that met strict regulatory requirements and rigorous deadlines. 273
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• Development of strategic approaches for cleanup of contaminated sites in consultation with clients and regulators.
Executive Director:
As Executive Director with Orange Coast Watch, Matt led efforts to restore water quality at Orange County beaches from multiple sources of contamination including urban runoff and the discharge of wastewater. In reporting to a Board of Directors that included representatives from leading Orange County universities and businesses, Matt prepared issue papers in the areas of treatment and disinfection of wastewater and control of the discharge of grease to sewer systems. Matt actively participated in the development of countywide water quality permits for the control of urban runoff and permits for the discharge of wastewater. Matt worked with other nonprofits to protect and restore water quality, including Surfrider, Natural Resources Defense Council and Orange County CoastKeeper as well as with business institutions including the Orange County Business Council.
Hydrogeology:
As a Senior Hydrogeologist with the U.S. Environmental Protection Agency, Matt led investigations to characterize and cleanup closing military bases, including Mare Island Naval Shipyard, Hunters Point Naval Shipyard, Treasure Island Naval Station, Alameda Naval Station, Moffett Field, Mather Army Airfield, and Sacramento Army Depot. Specific activities were as follows:
• Led efforts to model groundwater flow and contaminant transport, ensured adequacy of monitoring networks, and assessed cleanup alternatives for contaminated sediment, soil, and groundwater.
• Initiated a regional program for evaluation of groundwater sampling practices and laboratory analysis at military bases.
• Identified emerging issues, wrote technical guidance, and assisted in policy and regulation development through work on four national U.S. EPA workgroups, including the Superfund Groundwater Technical Forum and the Federal Facilities Forum.
At the request of the State of Hawaii, Matt developed a methodology to determine the vulnerability of groundwater to contamination on the islands of Maui and Oahu. He used analytical models and a GIS to show zones of vulnerability, and the results were adopted and published by the State of Hawaii and County of Maui.
As a hydrogeologist with the EPA Groundwater Protection Section, Matt worked with provisions of the Safe Drinking Water Act and NEPA to prevent drinking water contamination. Specific activities included the following:
• Received an EPA Bronze Medal for his contribution to the development of national guidance for the protection of drinking water.
• Managed the Sole Source Aquifer Program and protected the drinking water of two communities through designation under the Safe Drinking Water Act. He prepared geologic reports, conducted public hearings, and responded to public comments from residents who were very concerned about the impact of designation.
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• Reviewed a number of Environmental Impact Statements for planned major developments, including large hazardous and solid waste disposal facilities, mine reclamation, and water transfer.
Matt served as a hydrogeologist with the RCRA Hazardous Waste program. Duties were as follows:
• Supervised the hydrogeologic investigation of hazardous waste sites to determine compliance with Subtitle C requirements.
• Reviewed and wrote ʺpart Bʺ permits for the disposal of hazardous waste. • Conducted RCRA Corrective Action investigations of waste sites and led inspections that formed the basis for significant enforcement actions that were developed in close coordination with U.S.
EPA legal counsel.
• Wrote contract specifications and supervised contractor’s investigations of waste sites.
With the National Park Service, Matt directed service‐wide investigations of contaminant sources to prevent degradation of water quality, including the following tasks:
• Applied pertinent laws and regulations including CERCLA, RCRA, NEPA, NRDA, and the Clean Water Act to control military, mining, and landfill contaminants. • Conducted watershed‐scale investigations of contaminants at parks, including Yellowstone and Olympic National Park.
• Identified high‐levels of perchlorate in soil adjacent to a national park in New Mexico and advised park superintendent on appropriate response actions under CERCLA. • Served as a Park Service representative on the Interagency Perchlorate Steering Committee, a national workgroup.
• Developed a program to conduct environmental compliance audits of all National Parks while serving on a national workgroup.
• Co‐authored two papers on the potential for water contamination from the operation of personal watercraft and snowmobiles, these papers serving as the basis for the development of nation‐ wide policy on the use of these vehicles in National Parks. • Contributed to the Federal Multi‐Agency Source Water Agreement under the Clean Water Action Plan.
Policy:
Served senior management as the Senior Science Policy Advisor with the U.S. Environmental Protection Agency, Region 9. Activities included the following:
• Advised the Regional Administrator and senior management on emerging issues such as the potential for the gasoline additive MTBE and ammonium perchlorate to contaminate drinking water supplies.
• Shaped EPA’s national response to these threats by serving on workgroups and by contributing to guidance, including the Office of Research and Development publication, Oxygenates in Water: Critical Information and Research Needs.
• Improved the technical training of EPAʹs scientific and engineering staff. • Earned an EPA Bronze Medal for representing the region’s 300 scientists and engineers in negotiations with the Administrator and senior management to better integrate scientific principles into the policy‐making process.
• Established national protocol for the peer review of scientific documents. 275
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Geology:
With the U.S. Forest Service, Matt led investigations to determine hillslope stability of areas proposed for timber harvest in the central Oregon Coast Range. Specific activities were as follows:
• Mapped geology in the field, and used aerial photographic interpretation and mathematical models to determine slope stability.
• Coordinated his research with community members who were concerned with natural resource protection.
• Characterized the geology of an aquifer that serves as the sole source of drinking water for the city of Medford, Oregon.
As a consultant with Dames and Moore, Matt led geologic investigations of two contaminated sites (later listed on the Superfund NPL) in the Portland, Oregon, area and a large hazardous waste site in eastern Oregon. Duties included the following:
• Supervised year‐long effort for soil and groundwater sampling. • Conducted aquifer tests.
• Investigated active faults beneath sites proposed for hazardous waste disposal.
Teaching:
From 1990 to 1998, Matt taught at least one course per semester at the community college and university levels:
• At San Francisco State University, held an adjunct faculty position and taught courses in environmental geology, oceanography (lab and lecture), hydrogeology, and groundwater contamination.
• Served as a committee member for graduate and undergraduate students. • Taught courses in environmental geology and oceanography at the College of Marin.
Matt taught physical geology (lecture and lab and introductory geology at Golden West College in Huntington Beach, California from 2010 to 2014.
Invited Testimony, Reports, Papers and Presentations:
Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Presentation to the Public Environmental Law Conference, Eugene, Oregon.
Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Invited presentation to U.S.
EPA Region 9, San Francisco, California.
Hagemann, M.F., 2005. Use of Electronic Databases in Environmental Regulation, Policy Making and Public Participation. Brownfields 2005, Denver, Coloradao.
Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in Nevada and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Las Vegas, NV (served on conference organizing committee).
Hagemann, M.F., 2004. Invited testimony to a California Senate committee hearing on air toxins at schools in Southern California, Los Angeles.
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Brown, A., Farrow, J., Gray, A. and Hagemann, M., 2004. An Estimate of Costs to Address MTBE Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells.
Presentation to the Ground Water and Environmental Law Conference, National Groundwater Association.
Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in Arizona and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Phoenix, AZ (served on conference organizing committee).
Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in the Southwestern U.S. Invited presentation to a special committee meeting of the National Academy of Sciences, Irvine, CA.
Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a tribal EPA meeting, Pechanga, CA.
Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a meeting of tribal repesentatives, Parker, AZ.
Hagemann, M.F., 2003. Impact of Perchlorate on the Colorado River and Associated Drinking Water Supplies. Invited presentation to the Inter‐Tribal Meeting, Torres Martinez Tribe.
Hagemann, M.F., 2003. The Emergence of Perchlorate as a Widespread Drinking Water Contaminant.
Invited presentation to the U.S. EPA Region 9.
Hagemann, M.F., 2003. A Deductive Approach to the Assessment of Perchlorate Contamination. Invited presentation to the California Assembly Natural Resources Committee.
Hagemann, M.F., 2003. Perchlorate: A Cold War Legacy in Drinking Water. Presentation to a meeting of the National Groundwater Association.
Hagemann, M.F., 2002. From Tank to Tap: A Chronology of MTBE in Groundwater. Presentation to a meeting of the National Groundwater Association.
Hagemann, M.F., 2002. A Chronology of MTBE in Groundwater and an Estimate of Costs to Address Impacts to Groundwater. Presentation to the annual meeting of the Society of Environmental Journalists.
Hagemann, M.F., 2002. An Estimate of the Cost to Address MTBE Contamination in Groundwater (and Who Will Pay). Presentation to a meeting of the National Groundwater Association.
Hagemann, M.F., 2002. An Estimate of Costs to Address MTBE Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells. Presentation to a meeting of the U.S. EPA and State Underground Storage Tank Program managers.
Hagemann, M.F., 2001. From Tank to Tap: A Chronology of MTBE in Groundwater. Unpublished report.
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Hagemann, M.F., 2001. Estimated Cleanup Cost for MTBE in Groundwater Used as Drinking Water.
Unpublished report.
Hagemann, M.F., 2001. Estimated Costs to Address MTBE Releases from Leaking Underground Storage Tanks. Unpublished report.
Hagemann, M.F., and VanMouwerik, M., 1999. Potential Water Quality Concerns Related to Snowmobile Usage. Water Resources Division, National Park Service, Technical Report.
VanMouwerik, M. and Hagemann, M.F. 1999, Water Quality Concerns Related to Personal Watercraft Usage. Water Resources Division, National Park Service, Technical Report.
Hagemann, M.F., 1999, Is Dilution the Solution to Pollution in National Parks? The George Wright Society Biannual Meeting, Asheville, North Carolina.
Hagemann, M.F., 1997, The Potential for MTBE to Contaminate Groundwater. U.S. EPA Superfund Groundwater Technical Forum Annual Meeting, Las Vegas, Nevada.
Hagemann, M.F., and Gill, M., 1996, Impediments to Intrinsic Remediation, Moffett Field Naval Air Station, Conference on Intrinsic Remediation of Chlorinated Hydrocarbons, Salt Lake City.
Hagemann, M.F., Fukunaga, G.L., 1996, The Vulnerability of Groundwater to Anthropogenic Contaminants on the Island of Maui, Hawaii. Hawaii Water Works Association Annual Meeting, Maui, October 1996.
Hagemann, M. F., Fukanaga, G. L., 1996, Ranking Groundwater Vulnerability in Central Oahu, Hawaii. Proceedings, Geographic Information Systems in Environmental Resources Management, Air and Waste Management Association Publication VIP‐61.
Hagemann, M.F., 1994. Groundwater Characterization and Cleanup a t Closing Military Bases in California. Proceedings, California Groundwater Resources Association Meeting.
Hagemann, M.F. and Sabol, M.A., 1993. Role of the U.S. EPA in the High Plains States Groundwater Recharge Demonstration Program. Proceedings, Sixth Biennial Symposium on the Artificial Recharge of Groundwater.
Hagemann, M.F., 1993. U.S. EPA Policy on the Technical Impracticability of the Cleanup of DNAPL‐ contaminated Groundwater. California Groundwater Resources Association Meeting. 278
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Hagemann, M.F., 1992. Dense Nonaqueous Phase Liquid Contamination of Groundwater: An Ounce of Prevention... Proceedings, Association of Engineering Geologists Annual Meeting, v. 35.
Other Experience:
Selected as subject matter expert for the California Professional Geologist licensing examination, 2009‐ 2011.
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1 Shawn Smallwood, PhD
3108 Finch Street
Davis, CA 95616
Ashley Vera, Senior Planner
City of Livermore
Community Development Department
1052 S. Livermore Avenue
Livermore, CA 94550 12 December 2023
RE: SMP 38, SMP 39. SMP 40
Dear Ms. Vera,
I write to comment on potential impacts to biological resources that could result from the proposed SMP 38, SMP 39. SMP 40 Project, which I understand would add 1,514,275 square feet of floor space in eight speculative industrial buildings up to 55 feet tall on 217.04 acres located on APNs) 904-1-7-21; 904-1-2-12; 904-1-7-32; 904-3-1-4; 904-10-2-2, -3, -5, -7, and -8 west of Isabel Avenue, north of Stanley Boulevard, south of West Jack London Boulevard, and east of El Charro Road. I comment on the analyses of impacts to biological resources in the DEIR and in Monk & Associates (2021).
My qualifications for preparing expert comments are the following. I hold a Ph.D. degree in Ecology from University of California at Davis, where I also worked as a postgraduate researcher in the Department of Agronomy and Range Sciences. My research has been on animal density and distribution, habitat selection, wildlife interactions with the anthrosphere, and conservation of rare and endangered species. I authored many papers on these and other topics. I served as Chair of the Conservation Affairs Committee for The Wildlife Society – Western Section. I am a member of The Wildlife Society and Raptor Research Foundation, and I’ve lectured part-time at California State University, Sacramento. I was Associate Editor of wildlife biology’s premier scientific journal, The Journal of Wildlife Management, as well as of Biological Conservation, and I was on the Editorial Board of Environmental Management. I have performed wildlife surveys in California for thirty-seven years. My CV is attached.
SITE VISIT
I visited the SMP 40 for 2.22 hours from 14:43 to 16:35 hours on 28 November 2023, and SMP 38 and SMP 39 for 2.83 hours from 06:45 to 09:35 hours on 29 November 2023. At SMP 40, I surveyed from a cul-du-sac on the north edge of the site. At SMP 38 and SMP 39, I walked the northern perimeters, stopping to scan for wildlife with use of binoculars. I recorded all species of vertebrate wildlife I detected, including those whose members flew over the sites or were seen nearby, off the sites. Animals of uncertain species identity were either omitted or, if possible, recorded to the Genus or higher taxonomic level.
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2 Conditions were mostly cloudy still with temperatures of 62-55° F on the 28th and 46- 50° F on the 29th. The sites have been previously disked, and at the time of the surveys they were covered by annual grasses and ruderal vegetation (Photos 1―2).
Photos 1‒2. Views of SMP 40 (top) and SMP 39 with a flock of Canada goose (bottom), 28-29 November 2023.
I detected 46 species of vertebrate wildlife at or adjacent to the project site, including 10 species with special status (Table 1). I saw Botta’s pocket gopher (Photo 3) and California ground squirrel (Photo 4), both species of which are ecological keystone species. I saw loggerhead shrike (Photo 5), Cooper’s hawk and American kestrel (Photos 6 and 7), western meadowlark (Photo 8), house finch and killdeer (Photos 9 and 10), black phoebe and white-crowned sparrow (Photos 11 and 12), mourning dove (Photo 13), Say’s phoebe and yellow-rumped warbler (Photos 14 and 15), savannah sparrow (Photo 16), and lesser goldfinch and bushtit (Photos 17 and 18), among the other species listed in Table 1. Many of the species actively foraged on the site, including coyote, Cooper’s hawk, red-tailed hawk, horned lark, Canada goose and Aleutian cackling goose, killdeer, western meadowlark, house finch and others. I observed Some species in high abundance, including western meadowlark and mourning dove. California ground squirrels occupied all three sites, but were particularly abundant on SMP 40. 281
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3 Table 1. Species of wildlife I observed during 5.05 hours of survey on 28-29 November 2023.
Common name Species name Status1 Notes SMP Just
38 39 40 offsite
Sierran treefrog Pseudacris regilla Calling X X
Cackling goose Branta hutchinsii TWL Foraging X X X
Canada goose Branta canadensis Foraging X X X
Mallard Anas platyrhynchos Flyover X X X X
Mourning dove Zenaida macroura Many X X X X
Killdeer Charadrius vociferus Foraging X X X
Short-billed gull Larus brachyrhynchus Flyover X
Ring-billed gull Larus delawarensis Flyover X X X
California gull Larus californicus BCC, TWL Flyover X X X Herring gull Larus argentatus Flyover X
Glaucous-winged gull Larus glaucescens Flyover X X
Double-crested cormorant Nannopterum auritum TWL Flyover X X Great blue heron Ardea herodias Flyover X X
Turkey vulture Cathartes aura BOP Foraging X X
Northern harrier Circus cyaneus BCC, SSC3, BOP SMP 39 X Cooper’s hawk Accipiter cooperii TWL, BOP Perched at airport, foraged project site
X X
Red-tailed hawk Buteo jamaicensis BOP X X X X
Hairy woodpecker Dryobates villosus Flyover X X
Northern flicker Colaptes auratus SMP 40 X
American kestrel Falco sparverius BOP X X X
Black phoebe Sayornis nigricans X X X X
Say’s phoebe Sayornis saya SMP 39 X
Loggerhead shrike Lanius ludovicianus SSC2 SMP 39 X
California scrub-jay Aphelocoma californica X X
American crow Corvus brachyrhynchos X X X X
Common raven Corvus corax X X X X
California horned lark Eremophila alpestris actia TWL Foraging X Violet-green swallow Tachycineta thalassina SMP 40 X X
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4 Common name Species name Status1 Notes SMP Just
38 39 40 offsite
Bushtit Psaltriparus minimus Just offsite X
Northern mockingbird Mimus polyglottos X X X
European starling Sturnus vulgaris Non-native X X X X
American pipit Anthus rubescens Foraging X
House finch Haemorphous mexicanus X X X
Lesser goldfinch Spinus psaltria Just offsite X
Lawrence’s goldfinch Spinus lawrencei BCC SMP 40 X
White-crowned sparrow Zonotrichia leucophrys X X X
Savannah sparrow Passerculus sandwichensis SMP 38, SMP 39 X Lincoln’s sparrow Melospiza lincolnii SMP 38 X X
California towhee Melozone crissalis X X
Western meadowlark Sturnella neglecta Many X X X X
Red-winged blackbird Agelaius phoeniceus X
Brown-headed cowbird Molothrus ater X
Yellow-rumped warbler Setophaga coronata X X X X
Desert cottontail Sylvilagus audubonii SMP 38 X
California ground squirrel Otospermophilus beecheyi Many X X X X Coyote Canis latrans SMP 39 X
Botta’s pocket gopher Thomomys bottae Burrows X X
1 Listed as FT or FE = federal threatened or endangered, CT or CE = California threatened or endangered, CFP = California Fully Protected (CFG Code 3511), SSC = California Species of Special Concern, BCC = U.S. Fish and Wildlife Service Bird of Conservation Concern, TWL = Taxa to Watch List (Shuford and Gardali 2008), and BOP = Birds of Prey (California Fish and Game Code 3503.5).
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5 Photo 3. Botta’s pocket gopher mounds on the project site, 29 November 2023.
Photo 4. California ground squirrels on the SMP 40 portion of the project site, 28 November 2023.
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6 Photo 5.
Loggerhead
shrike on the
SMP 39 portion
of the project
site, 29
November
2023.
Photos 6 and 7. Cooper’s hawk (L) and American kestrel (R) at the project site, 29 November 2023.
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7 Photo 8. One of many western meadowlarks foraging on the SMP 39 portion of the project site, 29 November 2023.
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8 Photos 9 and 10. House finches (top) and one of many killdeer (bottom) on the project site, 28-29 November 2023.
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9 Photos 11 and 12. Black phoebe (L) and white-crowned sparrow (R) on the project site, 28-29 November 2023.
Photo 13. One of
many mourning
doves foraging on
the SMP 39
portion of the
project site, 29
November 2023.
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10 Photos 14 and 15. Say’s phoebe (top) and yellow-rumped warbler (bottom) on the project site, 28-29 November 2023.
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11 Photo 16. Savannah sparrow on the SMP 39 portion of the project site, 29 November 2023.
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12 Photos 17 and 18. Lesser goldfinch (L) and bushtit (R) just off the project site, 29 November 2023.
I fit nonlinear regression models to the cumulative numbers of vertebrate species I detected with time into my surveys to predict the number of species that I would have detected with a longer survey or perhaps with additional biologists available to assist.
The models are logistic growth models which reach asymptotes that correspond with the maximum numbers of vertebrate wildlife species that could have been detected during each survey. In this case, the models predict 46 and 118 species of vertebrate wildlife were available to be detected on the evening of the 28th and the morning of the 29th, respectively, the difference likely due to the onset of darkness during the evening survey of the 28th. Compared to models fit to data I collected from 18 other sites in the region between 2019 and 2023, the data from this project site exceeds the upper bound of the 95% confidence interval of the rate of accumulated species detections with time into the survey (Figure 1). Importantly, however, the species I detected on November 28-29 composed only a fraction of the species that would occur at the project site over the period of a year or longer. This is because many species are seasonal in their occurrence. 291
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13 Figure 1. Actual
and predicted
relationships
between the
number of
vertebrate
wildlife species
detected and the
elapsed survey
time based on
visual-scan
surveys on 28-29
November 2023.
Note that the
relationships
would differ if the
surveys were
based on another
method or during
another season.
At least a year’s worth of surveys would be needed to more accurately report the number of vertebrate species that occur at the project site, but I only have Noriko’s one survey.
However, by use of an analytical bridge, a modeling effort applied to a large, robust data set from a research site can predict the number of vertebrate wildlife species that likely make use of the site over the longer term. As part of my research, I completed a much larger survey effort across 167 km2 of annual grasslands of the Altamont Pass Wind Resource Area, where from 2015 through 2019 I performed 721 1-hour visual-scan surveys, or 721 hours of surveys, at 46 stations. I used binoculars and otherwise the methods were the same as the methods I and other consulting biologists use for surveys at proposed project sites. At each of the 46 survey stations, I tallied new species detected with each sequential survey at that station, and then related the cumulative species detected to the hours (number of surveys, as each survey lasted 1 hour) used to accumulate my counts of species detected. I used combined quadratic and simplex methods of estimation in Statistica to estimate least-squares, best-fit nonlinear models of the number of cumulative species detected regressed on hours of survey (number of surveys) at the station: 𝑅̂ =
1 1⁄𝑎+𝑏×(𝐻𝑜𝑢𝑟𝑠)
𝑐
, where 𝑅̂ represented cumulative species
0 50 100 150 200 250 300
Minutes into survey
0 5
10 15
20 25
30 35
40 45
Cumulative number of wildlife species detected
Actual species count, 28th
Model prediction
r
2 = 0.99, loss = 19.2
Model prediction
r
2 = 0.99, loss = 28.0
Actual species count, 29th
95% CI, surveys at 53
nearby sites, 2018-2023 292
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14 richness detected. The coefficients of determination, r 2, of the models ranged 0.88 to
1.00, with a mean of 0.97 (95% CI: 0.96, 0.98); or in other words, the models were excellent fits to the data.
I projected the predictions of each model to thousands of hours to find predicted asymptotes of wildlife species richness. The mean model-predicted asymptote of species richness was 57 after 11,857 hours of visual-scan surveys among the 46 stations of my research site. I also averaged model predictions of species richness at each incremental increase of number of surveys, i.e., number of hours (Figure 2). On average I would have detected 17.5 species over my first 5.05 hours of surveys at my research site in the Altamont Pass (5.05 hours to match the 5.05 hours I surveyed at the project site), which composed 30.7% of the predicted total number of species I would detect with a much larger survey effort at the research site. Given the example illustrated in Figure 2, the 46 species I detected after my 5.05 hours of survey at the project site likely represented
30.7% of the species to be detected after many more visual-scan surveys over another year or longer. With many more repeat surveys through the year, I would likely detect 46 0.307 ⁄ = 150 species of vertebrate wildlife at the site. Assuming my ratio of specialstatus to non-special-status species was to hold through the detections of all 150 predicted species, then continued surveys would eventually detect 33 special-status species of vertebrate wildlife.
Figure 2. Mean (95% CI)
predicted wildlife species
richness, 𝑅̂, as a nonlinear
function of hour-long
survey increments across
46 visual-scan survey
stations across the
Altamont Pass Wind
Resource Area, Alameda
and Contra Costa
Counties, 2015‒2019. Note
that the location of the
study is largely irrelevant
to the utility of the graph
to the interpretation of
survey outcomes at the
project site. It is the
pattern in the data that is
relevant, because the
pattern is typical of the
pattern seen elsewhere.
Because my prediction of 150 species of vertebrate wildlife, including 33 special-status species of vertebrate wildlife, is derived from daytime visual-scan surveys, and would detect few nocturnal mammals such as bats, the true number of species composing the wildlife community of the site must be larger. My reconnaissance surveys should serve 0 20 40 60 80 100
0 10
20 30
40 50
Cumulative number of surveys (hours)
(95% CI)
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15 only as a starting point toward characterization of the site’s wildlife community, but they certainly cannot alone inform of the inventory of species that use the site. More surveys are needed than my two survey to inventory use of the project site by wildlife.
Nevertheless, the large number of species I predict at the project site is indicative of a relatively species-rich wildlife community that warrants a serious survey effort.
EXISTING ENVIRNMENTAL SETTING
The first step in analysis of potential project impacts to biological resources is to accurately characterize the existing environmental setting, including the biological species that use the site, their relative abundances, how they use the site, key ecological relationships, and known and ongoing threats to those species with special status. A reasonably accurate characterization of the environmental setting can provide the basis for determining whether the site holds habitat value to wildlife, as well as a baseline against which to analyze potential project impacts. For these reasons, characterization of the environmental setting, including the project site’s regional setting, is one of CEQA’s essential analytical steps. Methods to achieve this first step typically include (1) surveys of the site for biological resources, and (2) reviews of literature, databases and local experts for documented occurrences of special-status species. In the case of the proposed project, these needed steps have been inadequate.
Environmental Setting informed by Field Surveys
To CEQA’s primary objective to disclose potential environmental impacts of a proposed project, the analysis should be informed of which biological species are known to occur at the proposed project site, which special-status species are likely to occur, as well as the limitations of the survey effort directed to the site. Analysts need this information to characterize the environmental setting as a basis for opining on, or predicting, potential project impacts to biological resources.
Herein I discuss several types of surveys, which are common to environmental review, but which are often misunderstood and misapplied. A reconnaissance survey, also often referred to as a general biological survey, is intended to (1) detect as many of the species as feasible during the time of the survey, (2) search for and map the locations of approximate boundaries of wetlands and coarse representations of vegetation cover, and (3) assess the likelihood of occurrences of special-status species. The latter objective is often referred to as habitat assessment. CDFW (2018) provides guidelines for reconnaissance surveys directed toward plant species, but there are no guidelines for reconnaissance-level wildlife surveys, other than the expected use of sound scientific methodology. A protocol-level survey is a survey guided by a written protocol, usually by a resource agency or professional group of biologists. Such surveys can be for various objectives, but in environmental review they are usually intended for detection surveys. Detection surveys are formulated by experts on a particular species to, at reasonable cost, give survey personnel the best chance at detecting members of a species if the species is indeed present. The additional purpose of detection surveys is to support absence determinations when the protocol was followed but the species was nevertheless not detected. Absence determinations made for special-status species are 294
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16 supportable only if the results of detection surveys were negative, or when the site is outside the species’ geographic range or clearly does not provide habitat.
Preconstruction surveys are take-avoidance surveys intended to be completed after reconnaissance surveys and detection surveys and just prior to construction grounddisturbance activities such as clearing and grubbing or grading. For some species, protocols for preconstruction surveys are included in mitigation guidelines. The preconstruction survey is a mitigation measure, and therefore not to be confused with other types of surveys. This type of survey will be discussed in the Mitigation section near the end of my comments.
Monk & Associates (2021) performed a reconnaissance survey of the SMP 39 project site on 5 November 2021 “to record biological resources and to assess the likelihood of resource agency regulated areas occurring on the project site,” and “searching all habitats on the site and recording all plant and wildlife species observed,” and “examination of the site to determine if there could be potential areas within the project site that would be regulated as waters of the United States and/or State.” Monk & Associates (2023) performed two reconnaissance surveys of the SMP 40 project site on 10 June 2019 and 10 September 2021. The objectives of the surveys at SMP 40 were essentially the same as those for the survey of SMP 39. In all three of these surveys, Monk & Associates recorded all the species observed. A wetland delineation was alco completed at SMP 40.
For none of the above surveys was there reporting of what time the surveys began, or how long the surveys lasted. No checklist is shared of habitat elements that the biologists might have used during their survey to later crosscheck against documented habitats of each special-status species. No explanation is provided of whether or how animal behavior data or other evidence contributed to the biologist’s assessment of the site for its importance to animal movement. It is therefore difficult to assess survey outcomes relative to survey effort and methods.
Monk & Associates (2021) detected 14 species of vertebrate wildlife on SMP 39, and Monk & Associates (2023) detected 22 species of vertebrate wildlife on SMP 40. In comparison, and even though I was unable to access either of the project sites, I detected 34 species in only 1.83 hours at SMP 39, and 29 species in only 2.22 hours at SMP 40. I also detected twice the number of special-status species at SMP 39 and 1.5 times the number of special-status species at SMP 40. Based on my surveys of the project sites, the existing environmental setting of each appears substantially different from the setting characterized by Monk & Associates (2021, 2023). Considering the differences between what Monk & Associates and what I found, I suggest that Monk & Associates must have either been distracted by other too many survey objectives, or lacked the skill needed to perform the surveys. The results of the Monk and Associates (2021, 2023) surveys have been misinterpreted in the reports, resulting in inaccurate characterizations of the existing environmental settings of SMP 39 and SMP 40.
Combining my survey results with those of Monk & Associates (2021, 2023), 38 species of vertebrate wildlife have been detected at SMP 39, and 44 species have been detected 295
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17 at SMP 40. These combined results increase the documented number of species at SMP 39 by nearly 3-fold and they double the number of species at SMP 40. In other words, the combined survey outcomes support my modeling predictions of much larger numbers of species of wildlife making use of the project sites than can be demonstrated by one or two reconnaissance surveys. My modeling predicts at least 150 species of vertebrate wildlife make use of the two sites, and this prediction was based solely on diurnal visual-scan surveys, and not on live-trapping for small mammals and nocturnal surveys for nocturnally active animals. The wildlife communities of SMP 39 and SMP 40 are much richer than portrayed in the DEIR.
The DEIR (page 4.3-25) reports that “western burrowing owls have not been observed within SMP 39 or SMP 40.” This is factually incorrect, as CNDDB includes a record of burrowing owl occurrence on SMP 39 (Monk & Associates 2023: Figure 4). Even if this reporting was correct, it would still qualify as pseudoscientific. The appropriate surveys for detecting burrowing owls are detailed in the survey guidelines of CDFW (2012). Lack of detections of burrowing owls during reconnaissance surveys would be meaningful only after completion of many reconnaissance surveys at the appropriate time of year and by qualified biologists. Considering that ground squirrels occur in abundance on SMP 39 and SMP 40, and considering that one of California’s most significant populations of burrowing owls occurs within the nearby Altamont Pass (Smallwood et al. 2013), and considering that the appropriate detection surveys have not been completed at SMP 39 and SMP 40, it would be prudent to assume that burrowing owls occur on the project sites.
Regarding tricolored blackbird, the DEIR (page 4.3-26) reports that “the species has not been observed near SMP 39 in nearly 40 years.” This is factually incorrect, as eBird includes a 2003 record of tricolored blackbird occurrence only 300 m north of SMP 39.
The DEIR also reports that tricolored blackbird would not occur on SMP 9 because “aquatic habitat does not exist within SMP 39.” But this is also factually incorrect. I have many times recorded tricolored blackbird occurrences on grasslands of the Altamont Pass far from bodies of water (Photos 19 and 20). Grassland environments is where tricolored blackbirds do most of their foraging in Alameda County, and it is where they sometimes nest within the Altamont Pass (Photo 20).
The DEIR reports that loggerhead shrikes do not occur on SMP 39. But again, the DEIR is factually inaccurate. I observed a loggerhead shrike on SMP 39 (Photo 21), which as it turned out, was near where a loggerhead shrike sighting was also reported to eBird in 2018. Loggerhead shrike does occur on SMP 39, as well as on SMP 40.
The DEIR reports that SMP 39 and SMP 40 contains potential habitat of raptors.
However, the word “potential” insinuates uncertainty remains on the question of whether the sites provide raptor habitat. Of course, they do. Those portions of the environment used by raptors are considered raptor habitat. Between my surveys and those of Monk & Associates, and including CNDDB and eBird records, the following raptors have been seen on SMP 39 and SMP 40: turkey vulture, northern harrier, whitetailed kite, red-tailed hawk, ferruginous hawk, Cooper’s hawk, American kestrel, merlin, 296
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18 and burrowing owl. There should be no ambiguity around the question of whether raptor habitat occurs on SMP 39 and SMP 40; raptor habitat is present.
Photos 19 and 20. Top, tricolored blackbirds forage on grassland far from aquatic environments, and bottom, they breed on rapeseed and thistle in the Altamont Pass Wind Resource Area.
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19 Photo 21.
Loggerhead
shrike on the
SMP 39 portion
of the project
site, 29
November
2023.
Reconnaissance surveys for wildlife are not designed to detect special-status species.
Special-status species can be detected during such surveys, as has been the case for 10 special-status species at the project site, but these surveys are not formulated to detect them, nor are there minimum standards to be met in these surveys to support absence determinations. For the latter purpose, protocol-level detection surveys have been formulated by species experts. Monk & Associates (2021, 2023) did not perform any detection surveys. Based on Monk & Associates (2021, 2023), the DEIR’s characterization of the existing environmental setting is therefore incomplete and inaccurate.
The same is true for special-status species of plants. According to the DEIR (page 4.3- 25), “special-status plants have not been observed during several surveys of the project sites conducted during various months over the years.” However, this reporting is misleading, because only one of the several surveys was conducted during the plant blooming season. Monk and Associates (2021, 2023) did not meet the minimum standards of CDFW’s (2018) plant survey guidelines.
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20 Environmental Setting informed by Desktop Review
The purpose of literature and database review and of consulting with local experts is to inform the field survey, and to augment interpretation of its outcome. Analysts need this information to identify which species are known to have occurred at or near the project site, and to identify which other special-status species could conceivably occur at the site due to geographic range overlap and migration flight paths.
Monk & Associates (2021) did not reportedly review eBird (https://eBird.org) or iNaturalist (https://www.inaturalist.org) for documented occurrence records at or near the project site. Instead, Monk & Associates (2021, 2023) queried the California Natural Diversity Data Base (CNDDB) for documented occurrences of special-status species within the three miles of the project sites. By taking this approach, Monk & Associates (2021, 2023) and the DEIR screen out many special-status species from further consideration in the characterization of the wildlife community as part of the existing environmental setting. CNDDB is not designed to support absence determinations or to screen out species from characterization of a site’s wildlife community. As noted by CNDDB, “The CNDDB is a positive sighting database. It does not predict where something may be found. We map occurrences only where we have documentation that the species was found at the site. There are many areas of the state where no surveys have been conducted and therefore there is nothing on the map. That does not mean that there are no special status species present.” Monk & Associates (2021, 2023) and the DEIR misuse CNDDB.
According to Monk & Associates (2021:6), “No special-status animal records have ever been mapped on the project site.” The word “ever” adds emphasis to the finding.
However, by implication, Monk & Associates (2021) misrepresents CNDDB as a database with uniform representation of California properties, which is far from the case. CNDDB relies entirely on volunteer reporting from biologists who were allowed access to whatever properties they report from. Many properties have never been surveyed by biologists. Many properties have been surveyed, but the survey outcomes never reported to CNDDB. Many properties have been surveyed multiple times, but not all survey outcomes reported to CNDDB. Furthermore, CNDDB is interested only in the findings of special-status species, which means that species more recently assigned special status will have been reported many fewer times to CNDDB than were species assigned special status since the inception of CNDDB. The lack of many CNDDB records for species recently assigned special status had nothing to do with whether the species’ geographic ranges overlapped the project site, but rather more to do with the brief time for records to have accumulated since the species were assigned special status. And because negative findings are not reported to CNDDB, CNDDB cannot provide the basis for estimating occurrence likelihoods, either.
In my assessment based on database reviews and site visits, 128 special-status species of wildlife are known to occur near enough to the site (SMP 38, SMP 39, SMP 40) to warrant analysis of occurrence potential (Table 2). Of these 128 species, 19 (15%) were recorded on the project site, and another 35 (27%) species have been documented within 1.5 miles of the site (‘Very close’), another 13 (10%) within 1.5 and 4 miles 299
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21 (‘Nearby’), and another 57 (45%) within 4 to 30 miles (‘In region’). More than half (52%) of the species in Table 2 have been reportedly seen within 4 miles of the project site. The site therefore supports multiple special-status species of wildlife and carries the potential for supporting many more special-status species of wildlife based on proximity of recorded occurrences. The site is far richer in special-status species than is characterized in the DEIR.
Whereas Monk & Associates (2021, 2023) reportedly queried CNDDB for occurrence records within three miles of the project sites, the DEIR analyzes the occurrence likelihoods of only 6 (<5%) of the species in Table 2. That only 6 special-status species were identified from occurrence records within 3 miles strains credulity. As noted above, using eBird and iNaturalist, I found records of 54 special-status species of wildlife within only 1.5 miles of the project sites, and 67 within 4 miles of the sites.
Of the 6 species included in Monk & Associates (2021, 2023) analyses of occurrence likelihoods, the DEIR concludes that 4 have no chance of occurrence, 1 has low to no chance, and 1 has low to moderate chance of occurrence. Except for species whose habitat is compellingly absent from the site, absence determinations are inappropriate based on the evidence gathered by Monk & Associates (2021, 2023). Absence determinations are supportable only after species-specific protocol-level detection surveys have been completed to the standards of the protocols, and the species were nevertheless not detected. No such surveys have been completed. It is inappropriate to conclude that a species is absent simply by looking at a site, and it is especially inappropriate to do so for 125 species of wildlife. Important findings of Monk & Associates (2021, 2023) and the DEIR are not supportable.
Of the special-status species that Monk & Associates (2021, 2023)) claims to be absent from one or both of the project sites, two – burrowing owl and loggerhead shrike – have been seen where they were reported to be absent. Occurrence records of another 2 supposedly absent special-status species have been reported within only 1.5 miles of the site, and another has been reported within 1.5 and 4 miles of the project site. Important findings of Monk & Associates (2021, 2023) and the DEIR are not supportable.
Of the 122 special-status species in Table 2, but which the DEIR does not analyze for occurrence potential, some are unlikely to occur, whereas many are likely to occur. With ground squirrels known to be present on SMP 39 and SMP 40, there is reason to expect the occurrences of American badger, ferruginous hawk, bald eagle and golden eagle. I regularly observed these species in the Altamont Pass Wind Resource Areas while I performed various studies there from 1999 through 2019. Golden eagles, I continue to record both in the Altamont Pass and over and on the project sites (Figure 3). Of the 45 golden eagles that Douglas Bell captured and fit with GPS telemetry backpacks since 2013, 11 have flown to or perched in the areas of the project sites (Figure 3). 300
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22 Figure 3. GPS telemetry positions (N = 3,478) of 11 golden eagles from 2014 through 2023, each distinct color-symbol combination representative of one golden eagle.
Many of the positions are on SMP 38, SMP 39, and SMP 40. Many of the positions are of flying golden eagles, and some are of perched golden eagles.
Considering the inaccuracies of the DEIR’s characterization of the existing environmental setting, the reasonable course of action would be to withdraw the current draft EUIR and prepare a new one to appropriately characterize the existing environmental setting. The public needs to understand the nature of the sensitive biological assets that exist on the project sites.
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23 Table 2. Occurrence likelihoods of special-status bird species at or near the proposed project site, according to eBird/iNaturalist records (https://eBird.org, https://www.inaturalist.org) and on-site survey findings, where ‘Very close’ indicates within 1.5 miles of the site, “nearby” indicates within 1.5 and 4 miles, and “in region” indicates within 4 and 30 miles, and ‘in range’ means the species’ geographic range overlaps the site. Entries in bold font indicate those species I detected during my reconnaissance surveys.
Common name Species name Status1
DEIR occurrence
potential
Data base
records,
Site visits
Longhorn fairy shrimp Branchinecta longiantenna FE In region Vernal pool fairy shrimp Branchinecta lynchi FT In region Vernal pool tadpole shrimp Lepidurus packardi FE In region Monarch Danaus plexippus FC Very close
Crotch’s bumble bee Bombus crotchii CCE In region
California tiger salamander Ambystoma californiense FT, CT, WL None Nearby Foothill yellow-legged frog Rana boylii CT, SSC In region California red-legged frog Rana draytonii FT, SSC None Nearby Western pond turtle Emys marmorata SSC None Very close
Blainville’s horned lizard Phrynosoma blainvillii SSC In region Northern California legless lizard Anniella pulchra SSC In region California glossy snake Arizona elegans occidentalis SSC In region San Joaquin coachwhip Masticophis flagellum ruddocki SSC In region Alameda whipsnake Coluber lateralis euryxanthus FT, CT In region Brant Branta bernicla SSC2 In region
Cackling goose (Aleutian) Branta hutchinsii leucopareia WL On site Redhead Aythya americana SSC2 Very close
Harlequin duck Histrionicus histrionicus SSC2 In region Barrow’s goldeneye Bucephala islandica SSC Very close
Western grebe Aechmophorus occidentalis BCC Very close
Clark’s grebe Aechmophorus clarkii BCC Very close
Western yellow-billed cuckoo Coccyzus americanus occidentalis FT, CE, BCC In region Black swift Cypseloides niger SSC3, BCC In region
Vaux’s swift Chaetura vauxi SSC2, BCC Very close
Costa’s hummingbird Calypte costae BCC In region
Rufous hummingbird Selasphorus rufus BCC Very close
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24 Common name Species name Status1
DEIR occurrence
potential
Data base
records,
Site visits
Allen’s hummingbird Selasphorus sasin BCC Very close
Ridgway’s rail (San Francisco
Bay)
Rallus obsoletus obsoletus In region
Yellow rail In region
Lesser sandhill crane Antigone canadensis canadensis SSC3 In region Greater sandhill crane Antigone canadensis tabida CT, FP In region American avocet4 Recurvirostra americana BCC Very close Mountain plover Charadrius montanus SSC2, BCC In region Snowy plover Charadrius nivosus BCC In region
Western snowy plover Charadrius nivosus nivosus FT, SSC, BCC In region Whimbrel4 Numenius phaeopus BCC In region
Long-billed curlew Numenius americanus WL Very close
Marbled godwit Limosa fedoa BCC Very close
Red knot (Pacific) Calidris canutus BCC Very close
Short-billed dowitcher Limnodromus griseus BCC Nearby
Willet Tringa semipalmata BCC Very close
Laughing gull Leucophaeus atricilla WL In region
Heermann’s gull Larus heermanni BCC In region
Western gull Larus occidentalis BCC Very close
California gull Larus californicus BCC, WL On site
California least tern Sternula antillarum browni FE, CE, FP In region Black tern Chlidonias niger SSC2, BCC In region
Elegant tern Thalasseus elegans BCC, WL Nearby
Black skimmer Rynchops niger BCC, SSC3 In region
Common loon Gavia immer SSC Very close
Brandt’s cormorant Urile penicillatus BCC Nearby
Double-crested cormorant Phalacrocorax auritus WL On site American white pelican Pelacanus erythrorhynchos SSC1, BCC Very close California brown pelican Pelecanus occidentalis californicus FP In region Least bittern Ixobrychus exilis SSC2 In region
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25 Common name Species name Status
1 DEIRoccurrence
potential
Data base
records,
Site visits
White-faced ibis Plegadis chihi WL Nearby
Turkey vulture Cathartes aura BOP On site
Osprey Pandion haliaetus WL, BOP Very close
White-tailed kite Elanus luecurus CFP, BOP On site
Golden eagle Aquila chrysaetos BGEPA, CFP,
BOP, WL
On site
Northern harrier Circus cyaneus BCC, SSC3, BOP On site
Sharp-shinned hawk Accipiter striatus WL, BOP Very close Cooper’s hawk Accipiter cooperii WL, BOP On site
American goshawk Accipiter atricapillus SSC2, BOP In region Bald eagle Haliaeetus leucocephalus CE, BGEPA Very close Red-shouldered hawk Buteo lineatus BOP Very close
Swainson’s hawk Buteo swainsoni CT, BOP Very close
Red-tailed hawk Buteo jamaicensis BOP On site
Ferruginous hawk Buteo regalis WL, BOP On site
Rough-legged hawk Buteo lagopus BOP Nearby
Barn owl Tyto alba BOP Very close
Western screech-owl Megascops kennicotti BOP Very close Great horned owl Bubo virginianus BOP Very close
Burrowing owl Athene cunicularia BCC, SSC2, BOP Not likely On site Long-eared owl Asio otus BCC, SSC3, BOP In region
Short-eared owl Asia flammeus BCC, SSC3, BOP In region
Lewis’s woodpecker Melanerpes lewis BCC Very close
Nuttall’s woodpecker Picoides nuttallii BCC On site
American kestrel Falco sparverius BOP On site
Merlin Falco columbarius WL, BOP On site
Peregrine falcon Falco peregrinus BOP Very close
Prairie falcon Falco mexicanus WL, BOP Very close
Olive-sided flycatcher Contopus cooperi BCC, SSC2 Very close Willow flycatcher Empidonax trailii CE Very close
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26 Common name Species name Status1
DEIR occurrence
potential
Data base
records,
Site visits
Vermilion flycatcher Pyrocephalus rubinus SSC2 Nearby
Loggerhead shrike Lanius ludovicianus SSC2 Low to moderate On site Yellow-billed magpie Pica nuttalli BCC Very close
Oak titmouse Baeolophus inornatus BCC On site
California horned lark Eremophila alpestris actia WL On site Bank swallow Riparia riparia CT In region
Purple martin Progne subis SSC2 In region
Wrentit Chamaea fasciata BCC Very close
California thrasher Toxostoma redivivum BCC Very close
Cassin’s finch Haemorhous cassinii BCC In region
Lawrence’s goldfinch Spinus lawrencei BCC On site
Grasshopper sparrow Ammodramus savannarum SSC2 Nearby
Alameda song sparrow Melospiza melodia pusillula BCC, SSC2 In region Black-chinned sparrow Spizella atrogularis BCC In region Gray-headed junco Junco hyemalis caniceps WL In region
Bell’s sparrow Amphispiza b. belli WL In region
Yellow-breasted chat Icteria virens SSC3 Nearby
Yellow-headed blackbird Xanthocephalus xanthocephalus SSC3 Nearby Bullock’s oriole Icterus bullockii BCC On site
Tricolored blackbird Agelaius tricolor CT, BCC, SSC1 Low to none Very close Lucy’s warbler Leiothlypis luciae SSC3, BCC In region
Virginia’s warbler Leiothlypis virginiae WL, BCC In region Yellow warbler Setophaga petechia SSC2 Very close
Summer tanager Piranga rubra SSC1 In region
Pallid bat Antrozous pallidus SSC, WBWG:H In region
Townsend’s big-eared bat Corynorhinus townsendii SSC, WBWG:H In region Canyon bat Parastrellus hesperus WBWG:L In region
Big brown bat Episticus fuscus WBWG:L In region
Silver-haired bat Lasionycteris noctivagans WBWG:M In region Western red bat Lasiurus blossevillii SSC, WBWG:H In region 305
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27 Common name Species name Status1
DEIR occurrence
potential
Data base
records,
Site visits
Hoary bat Lasiurus cinereus WBWG:M In region
Western small-footed myotis Myotis cililabrum WBWG:M In range Miller’s myotis Myotis evotis WBWG:M In region
Little brown myotis Myotis lucifugus WBWG:M In region
Fringed myotis Myotis thysanodes WBWG:H In range
Long-legged myotis Myotis volans WBWG:H In range
Yuma myotis Myotis yumanensis WBWG:LM In region
California myotis Myotis californicus WBWG:L In region
Western mastiff bat Eumops perotis SSC, WBWG:H In range Mexican free-tailed bat Tadarida brasiliensis WBWG:L In region San Francisco dusky-footed
woodrat
Neotoma fuscipes annectens SSC In region
Ringtail Bassariscus astutus CFP In region
American badger Taxidea taxus SSC Nearby
Mountain lion Puma concolor CCT Nearby
1 Listed as FC, FT or FE = federal candidate, threatened or endangered, BCC = U.S. Fish and Wildlife Service Bird of Conservation Concern, CCT, CCE, CT or CE = California Candidate threatened or endangered, or California threatened or endangered, CFP = California Fully Protected (California Fish and Game Code 3511), SSC = California Species of Special Concern, SSC1, SSC2 and SSC3 = Bird Species of Special Concern priorities 1, 2 and 3, respectively (Shuford and Gardali 2008), WL = Taxa to Watch List (Shuford and Gardali 2008), and BOP = Birds of Prey (CFG Code 3503.5), and WBWG = Western Bat Working Group with priority rankings, of low (L), moderate (M), and high (H).
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28 POTENTIAL BIOLOGICAL IMPACTS
An impacts analysis should consider whether and how a proposed project would affect members of a species, larger demographic units of the species, the whole of a species, and ecological communities. The accuracy of this analysis depends on an accurate characterization of the existing environmental setting. In the case of the proposed project, the existing environmental setting has not been accurately characterized, and several important types of potential project impacts have been inadequately analyzed.
These types of impacts include habitat loss, interference with wildlife movement, and wildlife-automobile collision mortality.
HABITAT LOSS
Habitat loss results in a reduced productive capacity of affected wildlife species, but the DEIR offers no prediction of this lost capacity for any of the wildlife species potentially affected. In the case of birds, two methods exist for estimating the loss of productive capacity that would be caused by the project. One method would involve surveys to count the number of bird nests and chicks produced. The alternative method would be to infer productive capacity from estimates of total nest density elsewhere.
Because the project is located within an area that has undergone severe habitat fragmentation, the habitat that remains in fragmented patches probably no longer supports its original productive capacity of wildlife (Smallwood 2015, Smallwood and Smallwood 2023). However, several studies have estimated total avian nest density at locations that had likewise been highly fragmented. Two study sites in grassland/wetland/woodland complexes within agricultural matrices had total bird nesting densities of 32.8 and 35.8 nests per acre (Young 1948, Yahner 1982) for an average 34.3 nests per acre. Assuming total nest density at the project site is about a third of that of the above-cited study sites due to the annual disking of the project site’s interior areas, I predict SMP 38 (111.7 acres), SMP 39 (51.9 acres) and SMP 40 (41 acres) support 11.4 bird nests/acre/year. Based on this assumption, the combined projects, SMP 39 and SMP 40, on 92.9 acres would eliminate 1,059 nest sites, and assuming SMP 38 is also later developed, then the combined projects, SMP 38, SMP 39, and SMP 40, on 204.6 would eliminate 2,332 nest sites.
The loss of 1059 to 2,332 nest sites would easily qualify as a significant project impact that has not been quantitatively addressed in the DEIR. But the impact would not end with the immediate loss of nest sites as nest substrate is removed and foraging grounds graded in preparation for impervious surfaces. The reproductive capacity of the site would be lost. The average number of fledglings per nest in Young’s (1948) study was
2.9. Assuming Young’s (1948) study site typifies bird productivity, the project would prevent the production of 3,071 to 6,763 fledglings per year, depending on whether SMP 38 is developed. Assuming an average bird generation time of 5 years, the lost capacity of both breeders and annual fledgling production can be estimated from an equation in Smallwood (2022): {(nests/year × chicks/nest × number of years) + (2 adults/nest × nests/year) × (number of years ÷ years/generation)} ÷ (number of years) = 3,495 to 7,696 birds per year denied to California, depending on whether SMP 38 is developed. 307
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29 These losses of birds from California would be substantial, nearly equal to the annual loss of birds caused by wind turbine collision mortality in the nearby Altamont Pass Wind Resource Area (Adams Broadwell Joseph & Cardozo 8 January 2021 letter to Alameda County Planning Department regarding Comments on the Draft Subsequent Environmental Impact Report for the Mulqueeney Ranch Wind Repowering Project (SCH No. 2010082063), CUP Application No. PLN2019-00226). These losses would be highly significant.
INTERFERENCE WITH WILDLIFE MOVEMENT
One of CEQA’s principal concerns regarding potential project impacts is whether a proposed project would interfere with wildlife movement in the region. Unfortunately, the DEIR’s analysis of whether the project would interfere with wildlife movement in the region is flawed and misleading. According to the DEIR, “The project area does not fall within an Essential Habitat Connectivity area mapped by the CDFW.” However, at https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=18486, the California Essential Habitat Connectivity Project specifically points out that it is not: “A California Department of Fish and Game or US Fish and Wildlife Service response to potential impacts to a habitat or species from a project subject to the California Environmental Quality Act (CEQA),” nor “Fine scale, with every important piece of habitat identified” nor ““Essential”, meaning the only places of importance” nor “A solution by itself for how to provide necessary linkages for any given species of plant or animal... Linkage designs will vary depending on focal species chosen and the goal of providing connected habitat for a chosen species might be met several different ways” nor “The final word on connectivity for California.” With analytical grid cells of 2,000 acres, the spatial grain of the California Essential Habitat Connectivity Project is much too coarse for the conclusion the DEIR draws from it.
The next flaw in the DEIR is in the argument that SMP 39 is cut off from open areas by well-trafficked roads, the airport, the gravel quarries, and therefore cannot function as a wildlife movement corridor. The same argument is made for SMP 40. On this point, the DEIR merely speculates, and offers no supporting evidence to its assertion. Monk & Associates (2021, 2023) report no survey methodology designed to determine whether wildlife rely on the site for movement in the region. They implemented no sampling regime nor a program of observation to record wildlife movement patterns. They failed to quantitatively or qualitatively analyze movement patterns of observed wildlife. Based on what is reported, Monk & Associates (2021, 2023) did not record or measure wildlife movement in any way. The conclusions of the DEIR regarding wildlife movement on the project site are speculative and conclusory.
On the other hand, the coyote I saw on site got there somehow, and so did the ground squirrels and pocket gophers, and so did all of the birds I saw on and over SMP 39. I observed hundreds if not thousands of gulls of multiple species flying in both easterly and westerly directions across SMP 38, SMP 39, and SMP 40. I observed Canada geese and Aleutian cackling geese flying to and from the quarry ponds and the project sites to forage. I saw a Cooper’s hawk fly from the airport to SMP 39 to forage, crossing the welltrafficked road in about 2 seconds of flight time. Figure 3 illustrates that our telemetered 308
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30 golden eagles from the Altamont Pass make frequent visits to the project site. That thousands of our golden eagle telemetry positions appear in the project area is consistent with the pattern that my co-investigators and I have noticed about golden eagle movement across California and beyond to other states and border nations, and that is that golden eagles carefully select open spaces as parts of their travel routes. The project area is important to golden eagle movement in the region, just as it is important to the 10 special-status species I observed on the project site, and to the 19 special-status species so far documented on the project site. Th evidence is overwhelming that the project site is important to wildlife movement in the region. Losing the open space of this site would be devastating to many species of wildlife, including to golden eagle.
Furthermore, whether the site includes or is within a wildlife movement corridor is not the only consideration when it comes to the standard CEQA Checklist question of whether the project would interfere with wildlife movement in the region. The primary phrase of the CEQA standard goes to wildlife movement regardless of whether the movement is channeled by a corridor. In fact, a site such as the project site is critically important for wildlife movement because it composes an increasingly diminishing area of open space within a growing expanse of anthropogenic uses, forcing more species of volant wildlife to use the site for stopover and staging during migration, dispersal, and home range patrol (Warnock 2010, Taylor et al. 2011, Runge et al. 2014). The project, due to its elimination of at least 92.9 acres of open space, and more realistically 204.6 acres of open space, and due to its insertion of multiple new buildings into the aerospace currently used by birds, bats and butterflies. would cut wildlife off from one of the last remaining stopover and staging opportunities in the region, forcing volant wildlife to travel even farther between remaining stopover sites. This impact would be significant, and as the project is currently proposed, it would be unmitigated.
TRAFFIC IMPACTS TO WILDLIFE
Project-generated traffic would endanger wildlife that must, for various reasons, cross roads used by the project’s traffic to get to and from the project site (Photos 22―26), including along roads far from the project footprint. Vehicle collisions have accounted for the deaths of many thousands of amphibian, reptile, mammal, bird, and arthropod fauna, and the impacts have often been found to be significant at the population level (Forman et al. 2003). Across North America traffic impacts have taken devastating tolls on wildlife (Forman et al. 2003). In Canada, 3,562 birds were estimated killed per 100 km of road per year (Bishop and Brogan 2013), and the US estimate of avian mortality on roads is 2,200 to 8,405 deaths per 100 km per year, or 89 million to 340 million total per year (Loss et al. 2014). Local impacts can be more intense than nationally.
The nearest study of traffic-caused wildlife mortality was performed only 11 miles away, along a 2.5-mile stretch of Vasco Road in Contra Costa County, California. Fatality searches in this study found 1,275 carcasses of 49 species of mammals, birds, amphibians and reptiles over 15 months of searches (Mendelsohn et al. 2009). This fatality number needs to be adjusted for the proportion of fatalities that were not found due to scavenger removal and searcher error. This adjustment is typically made by placing carcasses for searchers to find (or not find) during their routine periodic fatality 309
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31 searches. This step was not taken at Vasco Road (Mendelsohn et al. 2009), but it was taken as part of another study I completed next to Vasco Road concurrent to the Mendelsohn et al. study (Brown et al. 2016). Brown et al.’s (2016) adjustment factors for carcass persistence resembled those of Santos et al. (2011), which were derived from carcasses placed along roads. Applying searcher detection rates from Brown et al. (2016), the adjusted total number of fatalities was estimated at 12,187 animals killed by traffic on the reach of road that was studied. This fatality number over 1.25 years and 2.5 miles of road translates to 3,900 wild animals per mile per year. In terms comparable to the national estimates, the estimates from the Mendelsohn et al. (2009) study would translate to 243,740 animals killed per 100 km of road per year, or 29 times that of Loss et al.’s (2014) upper bound estimate and 68 times the Canadian estimate. An analysis is needed of whether increased traffic generated by the project site would similarly result in local impacts on wildlife.
Photo 22. A Gambel’s quail dashes
across a road on 3 April 2021. Such
road crossings are usually successful,
but too often prove fatal to the animal.
Photo by Noriko Smallwood.
Photo 23. California ground squirrel
in the middle of an eastern Alameda
County road on 13 March 2014.
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32 Photo 24.
Western Pacific
rattlesnake on an
eastern Alameda
County road, 23
August 2011. Photo
by Shawn
Smallwood.
Photo 25. Mourning dove killed
by vehicle on a California road.
Photo by Noriko Smallwood, 21
June 2020.
Photo 26 Raccoon killed on Road 31 just east of
Highway 505 in Solano County. Photo taken on
10 November 2018.
For wildlife vulnerable to front-end collisions and crushing under tires, road mortality can be predicted from the study of Mendelsohn et al. (2009) as a basis, although it would be helpful to have the availability of more studies like that of Mendelsohn et al. (2009) at additional locations. My analysis of the Mendelsohn et al. (2009) data resulted in an estimated 3,900 animals killed per mile along a county road in Contra Costa County. Two percent of the estimated number of fatalities were birds, and the balance was composed of 34% mammals (many mice and pocket mice, but also ground squirrels, desert cottontails, striped skunks, American badgers, raccoons, and others),
52.3% amphibians (large numbers of California tiger salamanders and California redlegged frogs, but also Sierran treefrogs, western toads, arboreal salamanders, slender salamanders and others), and 11.7% reptiles (many western fence lizards, but also skinks, alligator lizards, and snakes of various species). VMT is useful for predicting wildlife mortality because I was able to quantify miles traveled along the studied reach of Vasco Road during the time period of the Mendelsohn et al. (2009), hence enabling a 311
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33 rate of fatalities per VMT that can be projected to other sites, assuming similar collision fatality rates.
From October 2016 through December 2019, I maintained my own database of wildlife mortality I encountered on Vasco Road between Marsh Creek Road and Livermore, which encompassed the wildlife mortality study site of Mendelsohn et al. (2009). Table 3 includes the wildlife I found as fatalities, and it compares my crudely calculated ratio of observed fatalities per mile. From Table 3, it is apparent that mortality along the reach of road studied by Mendelsohn et al. (2009) was relatively low compared to the rest of Vasco Road: 19.178
13.200 ⁄ = 5,667 fatalities per mile predicted for the 14.1 miles of Vasco Road that were not studies by Mendelsohn et al. (2009).
Table 3. Fatalities I found along Vasco Road from October 2016 though December 2019, and along 14.1 miles of road that was not studied by Mendelsohn et al. (2009) and 2.5 miles that were studied.
Common name Scientific name
Observed fatalities
Observed
fatalities/mile
14.1 miles
offsite
2.5- mile
study
site
14.1 miles
offsite
2.5-mile
study
site
Alligator lizard
Elgaria
multicarinata 1 0.068 0.000
American badger Taxidea taxus 3 2 0.205 0.800
American crow
Corvus
brachyrhynchos 2 0.137 0.000
Barn owl Tyto alba 21 2 1.438 0.800
Bird (Scrub-jay sized) 1 0.068 0.000
Blackbird Agelaius 2 0.137 0.000
Black-tailed jackrabbit Lepus californicus 2 0.137 0.000 Bobcat Felis rufus 2 0.137 0.000
Buffelhead Bucephala albeola 1 0.068 0.000
California kingsnake
Lampropeltis getula
californiae 1 0.000 0.400
Common poorwill
Phalaenoptilus
nuttallii 1 0.068 0.000
Coyote Canis latrans 29 2 1.986 0.800
Desert cottontail Sylvilagus audubonii 66 5 4.521 2.000 Gopher snake Pituophis c. catenifer 15 2 1.027 0.800
Ground squirrel
Otospermophilus
beecheyi 23 3 1.575 1.200
Gull Laridae 1 1 0.068 0.400
Helmeted guineefowl Numida meleagris 3 0.205 0.000
House cat Felis catus 1 0.068 0.000
Kangaroo rat Dipodomys 1 0.068 0.000
Large white bird 1 0.068 0.000
medium-sized bird 1 0.000 0.400
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34 Common name Scientific name
Observed fatalities
Observed
fatalities/mile
14.1 miles
offsite
2.5- mile
study
site
14.1 miles
offsite
2.5-mile
study
site
medium-sized mammal 2 0.137 0.000
Mule deer Odocoileus hemionus 5 0.342 0.000
Muskrat Ondatra zibethicus 1 0.068 0.000
Northern harrier Circus hudsonicus 1 0.068 0.000
Osprey Pandion haliaetus 1 0.068 0.000
Pocket gopher Thomomys bottae 1 0.068 0.000
Raccoon Procyon lotor 25 5 1.712 2.000
Western Pacific
rattlesnake
Crotalus oreganus
2 0.137 0.000
Red fox Vulpes vulpes 1 0.068 0.000
Red-tailed hawk Buteo jamaicensis 5 0.342 0.000
Red-winged blackbird Agelaius phoenecius 1 0.068 0.000
Rock pigeon Columba livea 1 0.068 0.000
Short-eared owl Asio flammeus 1 0.068 0.000
Snake 1 0.068 0.000
Striped skunk Mephitis mephitis 41 9 2.808 3.600
Turkey vulture Cathartes aura 1 0.068 0.000
Virginia opossum Didelphis virginiana 7 0.479 0.000
Western meadowlark Sturnella neglecta 1 0.068 0.000
Wild turkey Meleagris gallopavo 6 0.411 0.000
Total 280 33 19.178 13.200
Predicting project-generated traffic impacts to wildlife The DEIR predicts the project would generate 8,622,395 annual VMT. During the Mendelsohn et al. (2009) study, 19,500 cars traveled Vasco Road daily, so the vehicle miles that contributed to my estimate of non-volant fatalities was 19,500 cars and trucks × 2.5 miles × 365 days/year × 1.25 years = 22,242,187.5 vehicle miles per 12,187 wildlife fatalities, or 1,825 vehicle miles per fatality. This rate divided into the predicted annual VMT, above, would predict 4,725 vertebrate wildlife fatalities per year. My analysis of data in Table 3 suggests that the project-caused mortality along local roadways would be even higher.
Based on my analysis, the project-generated traffic would cause substantial, significant impacts to wildlife. The DEIR does not address this potential impact, let alone propose to mitigate it. Mitigation measures to improve wildlife safety along roads are available and are feasible, and they need exploration for their suitability with the proposed project. Given the predicted level of project-generated, traffic-caused mortality, and the lack of any proposed mitigation, it is my opinion that the proposed project would result in potentially significant adverse biological impacts. The DEIR should be withdrawn 313
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35 from circulation and revised to appropriately analyze the potential impacts of projectgenerated automobile traffic on wildlife.
CUMULATIVE IMPACTS
The DEIR attempts to minimalize the project’s contributions to cumulative impacts to biological resources by asserting that “ruderal herbaceous land is not considered sensitive wildlife habitat.” However, CEQA does not require that the habitat that would be lost to a project be labeled as sensitive; no such standard exists.
The DEIR presents a flawed analysis of cumulative impacts, including to biological resources. The DEIR asserts that it “sets forth mitigation measures to ensure all potential project-specific impacts that would occur to biological resources are reduced to a less-than-significant level.” And therefore, “the proposed project would not result in substantial adverse effects to biological resources protected by CEQA.” The DEIR contrives the false standard that a given project impact is cumulatively considerable only when it has not been fully mitigated at the project level. The DEIR implies that cumulative impacts are really residual impacts left over by inadequate mitigation of project impacts. This notion of residual impacts being the source of cumulative impacts is inconsistent with CEQA’s definition of cumulative effects. Individually mitigated projects do not negate the significance of cumulative impacts. If they did, then CEQA would not require a cumulative effects analysis. To summarize, the DEIR presents no cumulative effects analysis as defined in two ways by CEQA.
MITIGATION
Western Burrowing Owl
4.3-2(a) If project construction begins during the western burrowing owl nesting season (February 15 to August 31), a qualified biologist shall conduct targeted burrowing owl nest surveys within 14 days prior to construction activities using seven- to 20-foot transects. … The survey shall … follow CDFW guidelines outlined in the 2012 Staff Report on Burrowing Owl Mitigation.
The avian breeding season recognized by the CDFW is now 1 February through 15 September. The DEIR should be revised accordingly.
Whereas I concur that preconstruction, take-avoidance surveys should be completed, the DEIR falsely characterizes preconstruction surveys as detection surveys by insinuating that conducting preconstruction surveys without first having completed detection surveys would follow CDFW guidelines. Detection surveys are entirely different than preconstruction surveys, and are implemented to achieve a different set of objectives. Contrary to the DEIR’s implication, preconstruction surveys are not designed to detect burrowing owls with anywhere close to the same likelihood as are protocollevel detection surveys that are designed for this purpose. It would be very easy for a preconstruction survey to fail to detect burrowing owls that are in fact present.
Therefore, implementing a preconstruction survey as a surrogate for detection surveys would be reckless and would fail to meet the minimum standard of care for wildlife 314
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36 protection. In any case, preconstruction surveys need to be implemented after completion of detection surveys per CDFW (2012).
Tricolored Blackbird
4.3-2(c) Prior to any ground disturbance on SMP 40, a qualified biologist shall conduct a preconstruction survey in all accessible areas identified as supporting potential tricolored blackbird nesting habitat. The survey shall document the current, and to the extent possible, historical presence or absence of nesting colonies of tricolored blackbird. …
Whereas I concur that preconstruction, take-avoidance surveys should be completed, a detection survey is needed first to inform the readers of the DEIR of whether and where tricolored blackbirds occur on or near the project sites. A detection survey would likely also improve the efficacy of the preconstruction survey.
Nesting Birds and Raptors (Including Loggerhead Shrike)
4.3-2(d) If project construction begins during the nesting season (February 1 to August 31), a qualified biologist shall conduct a nesting bird survey within 7 days prior to construction activities. … If migratory birds are identified nesting on or within the zone of influence, … A qualified biologist shall establish a temporary protective nest buffer around the nest(s). The nest buffer shall be staked with orange construction fencing. The buffer must be of sufficient size to protect the nesting site from construction-related disturbance and shall be established by a qualified ornithologist or biologist with extensive experience working with nesting birds near and on construction sites.
Typically, adequate nesting buffers are 75 feet from the nest site or nest tree dripline for small birds and up to 300 feet for sensitive nesting birds that include several raptor species known in the region of the project site but that are not expected to occur on the project site. Upon completion of nesting surveys, if nesting birds are identified on or within a zone of influence of the project site, a qualified ornithologist/biologist that frequently works with nesting birds shall prescribe adequate nesting buffers to protect the nesting birds from harm while the project is constructed.
First, the avian breeding season recognized by the CDFW is now 1 February through 15 September. The DEIR should be revised accordingly.
Second, whereas I concur that preconstruction, take-avoidance surveys should be completed, in my experience the majority of bird nests would not be found by biologists assigned to the survey. For instance, I surveyed for grassland nesters as part of an intensive survey effort that I performed from March through mid-August 2023 on a Central Valley site. I surveyed the site 30 times. I found that the nests of grassland birds are the most difficult to locate. Cavity nesters can more effectively defend their nests against predators, whereas ground nesters are highly vulnerable to predation, and thus the most cryptic of nesters. Ground nesters, which include bird species that occur at the project site, are highly adept at concealing their nests both physically and behaviorally.
Based on my experience, it is highly likely that preconstruction survey would fail to find 315
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37 any of the nests of ground-nesting birds that truly occur on the project site. The DEIR’s implication that preconstruction survey would reduce potential impacts to nesting birds to less-than-significant is unsubstantiated by evidence in the DEIR.
The mitigation measure appears to be specifically directed toward loggerhead shrike, presumably because this special-status species was detected during a reconnaissance survey of SMP 40. Finding the nests of loggerhead shrikes is particularly difficult, as this species is expert at deceiving observers as to the whereabouts of their nests (Smallwood and Smallwood 2021). To adequately survey for nest sites of loggerhead shrike, many surveys are needed, and the survey methods need to include long sessions of visualscans, preferably from blinds such as automobiles. Observers would need to be experienced in bird behavior, and capable of tracking the movements of individual loggerhead shrikes. A preconstruction survey for loggerhead shrike nest would be ineffective by having inexperienced biologists walk back and forth along transects.
Third, the mitigation language (second italicized paragraph above) allows a single individual to make a subjective decision, outside the public’s view, to determine the buffer area for any given species. This measure lacks objective criteria, and is unenforceable.
Even assuming some or even all of the nests would be found and salvaged, this benefit to birds nesting on site would apply only to a single breeding season of nesters. The project would nevertheless eliminate the site’s productive capacity to birds.
SMP 40 and Trail Connection Option 2
4.3-3(c) Prior to the commencement of ground-disturbing activities for SMP 40 or Trail Connection Option 2, … [Six minimization and mitigation measures follow, one of which is] … the riparian corridor of Arroyo Mocho, disturbed areas shall be revegetated with native riparian plant species. Replacement of riparian trees to be removed shall be planted near the creek as feasible and/or adjacent to the existing limits of the riparian corridor to contribute to the existing riparian canopy. Riparian plantings shall be maintained for a minimum of 5 years to ensure that the canopy is enhanced and the understory restored.
Trail Connection Option 2 – Undercrossing at Isabel Bridge
4.3-3(d) Prior to initiation of any groundbreaking activity associated with Trail Connection Option 2, … The project applicant shall ensure that the proposed project replaces, restores, or enhances on a “no net loss” basis (in accordance with the RWQCB) the acreage of all riparian habitat and waters of the State that would be removed, lost, and/or degraded due to project implementation by methods agreeable to the RWQCB and the City, as appropriate, depending on agency jurisdiction, and as determined during the Section 401 permitting processes. Methods include, but are not limited to implementation of a riparian enhancement planting plan and/or tree planting mitigation at a 1:1 ratio, or as otherwise prescribed by the RWQCB.
Trail Connection Option 2 – Undercrossing at Isabel Bridge 316
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38 4.3-3(e) If it is determined that work below the OHWM cannot be avoided for Trail Connection Option 2, … Waters that would be lost or disturbed shall be restored, replaced, or rehabilitated on a “no-net-loss” basis. Habitat restoration, rehabilitation, and/or replacement, including the purchase of credits from a USACE approved mitigation bank at a 1:1 ratio, shall be at a location and by methods acceptable to the USACE.
I concur that all of the measures described above should be implemented if the project goes forward. However, these measure alone would be inadequate. Also needed is monitoring of wildlife that is integrated with thresholds of success and failure. If thresholds of failure are exceeded, then the City should be required to take additional steps to achieve success. To this end, an adequate performance bond should be provided by the applicant to the City.
RECOMMENDED MEASURES
Road Mortality: Compensatory mitigation is needed for the increased wildlife mortality that would be caused by bird-window collisions and the project-generated road traffic in the region. I suggest that this mitigation can be directed toward funding research to identify fatality patterns and effective impact reduction measures such as reduced speed limits and wildlife under-crossings or overcrossings of particularly dangerous road segments. Compensatory mitigation can also be provided in the form of donations to wildlife rehabilitation facilities (see below).
Fund Wildlife Rehabilitation Facilities: Compensatory mitigation ought also to include funding contributions to wildlife rehabilitation facilities to cover the costs of injured animals that will be delivered to these facilities for care. Many animals would likely be injured by collisions with automobiles traveling to and from the project’s buildings.
Landscaping: If the project goes forward, California native plant landscaping (i.e., chaparral, grassland, and locally appropriate scrub plants) should be considered to be used as opposed to landscaping with lawn and exotic shrubs. Native plants offer more structure, cover, food resources, and nesting substrate for wildlife than landscaping with lawn. Native plant landscaping has been shown to increase the abundance of arthropods which act as importance sources of food for wildlife and are crucial for pollination and plant reproduction (Narango et al. 2017, Adams et al. 2020, Smallwood and Wood 2022.). Further, many endangered and threated insects require native host plants for reproduction and migration, e.g., monarch butterfly. Around the world, landscaping with native plants over exotic plants increases the abundance and diversity of birds, and is particularly valuable to native birds (Lerman and Warren 2011, Burghardt et al. 2008, Berthon et al. 2021, Smallwood and Wood 2022). Landscaping with native plants is a way to maintain or to bring back some of the natural habitat and lessen the footprint of urbanization by acting as interconnected patches of habitat for wildlife (Goddard et al. 2009, Tallamy 2020). Lastly, not only does native plant landscaping benefit wildlife, it requires less water and maintenance than traditional landscaping with lawn and hedges. 317
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39 Thank you for your consideration,
______________________
Shawn Smallwood, Ph.D.
LITERATURE CITED
Adams, B. J., E. Li, C. A. Bahlai, E. K. Meineke, T. P. McGlynn, and B. V. Brown. 2020.
Local and landscape-scale variables shape insect diversity in an urban biodiversity hot spot. Ecological Applications 30(4):e02089. 10.1002/eap.2089 Berthon, K., F. Thomas, and S. Bekessy. 2021. The role of ‘nativenes’ in urban greening to support animal biodiversity. Landscape and Urban Planning 205:103959. https://doi.org/10.1016/j.landurbplan.2020.103959
Bishop, C. A. and J. M. Brogan. 2013. Estimates of Avian Mortality Attributed to Vehicle Collisions in Canada. Avian Conservation and Ecology 8:2. http://dx.doi.org/10.5751/ACE-00604-080202.
Burghardt, K. T., D. W. Tallamy, and W. G. Shriver. 2008. Impact of native plants on bird and butterfly biodiversity in suburban landscapes. Conservation Biology 23:219-224.
CDFW (California Department of Fish and Wildlife). 2018. Protocols for surveying and evaluating impacts to special status native plant populations and sensitive natural communities. https://nrm.dfg.ca.go
Forman, T. T., D. Sperling, J. A. Bisonette, A. P. Clevenger, C. D. Cutshall, V. H. Dale, L.
Fahrig, R. France, C. R. Goldman, K. Heanue, J. A. Jones, F. J. Swanson, T.
Turrentine, and T. C. Winter. 2003. Road Ecology. Island Press, Covello, California.
Goddard, M. A., A. J. Dougill, and T. G. Benton. 2009. Scaling up from gardens:
biodiversity conservation in urban environments. Trends in Ecology and Evolution 25:90-98. doi:10.1016/j.tree.2009.07.016
Lerman, S. B. and P. S. Warren. 2011. The conservation value of residential yards:
linking birds and people. Ecological Applications 21:1327-1339.
Loss, S. R., T. Will, and P. P. Marra. 2014. Estimation of bird-vehicle collision mortality on U.S. roads. Journal of Wildlife Management 78:763-771. 318
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40 Mendelsohn, M., W. Dexter, E. Olson, and S. Weber. 2009. Vasco Road wildlife movement study report. Report to Contra Costa County Public Works Department, Martinez, California.
Monk & Associates. 2021. Biological Resources Analysis SMP-39 Alameda County, California. Report to Overton Moore Properties, Gardena, California.
Monk & Associates. 2023. Biological Resources Analysis Oaks Business Park City Of Livermore, California. Report to Overton Moore Properties, Gardena, California.
Narango, D. L., D. W. Tallamy, and P. P. Marra. 2017. Native plants improve breeding and foraging habitat for an insectivorous bird. Biological Conservation 213:42-50.
Runge, C. A., T. G. Martin, H. P. Possingham, S. G. Willis, and R. A. Fuller. 2014.
Conserving mobile species. Frontiers in Ecology and Environment 12(7): 395–402, doi:10.1890/130237.
Santos, S. M., F. Carvalho, and A. Mira. 2011. How long do the dead survive on the road? Carcass persistence probability and implications for road-kill monitoring surveys.
PLoS ONE 6(9): e25383. doi:10.1371/journal.pone.0025383 Shuford, W. D., and T. Gardali, [eds.]. 2008. California bird species of special concern: a ranked assessment of species, subspecies, and distinct populations of birds of immediate conservation concern in California. Studies of Western Birds 1. Western Field Ornithologists, Camarillo, California.
Smallwood, K. S. 2015. Habitat fragmentation and corridors. Pages 84-101 in M. L.
Morrison and H. A. Mathewson, Eds., Wildlife habitat conservation: concepts, challenges, and solutions. John Hopkins University Press, Baltimore, Maryland, USA.
Smallwood, K. S. 2022. Utility-scale solar impacts to volant wildlife. Journal of Wildlife Management: e22216. https://doi.org/10.1002/jwmg.22216 Smallwood, K. S., and N. L. Smallwood. 2021. Breeding density and collision mortality of loggerhead shrike (Lanius ludovicianus) in the Altamont Pass Wind Resource Area. Diversity 13, 540. https://doi.org/10.3390/d13110540.
Smallwood, K. S., and N. L. Smallwood. 2023. Measured effects of anthropogenic development on vertebrate wildlife diversity. Diversity 15, 1037. https://doi.org/10.3390/d15101037.
Smallwood, N. L., and E. M. Wood. 2022. The ecological role of native-plant landscaping in residential yards to birds during the nonbreeding period. Ecosphere 2022;e4360.
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41 Tallamy, D.W. 2020. Nature’s Best Hope: A New Approach to Conservation that Starts in Your Yard. Timber Press.
Taylor, P. D., S. A. Mackenzie, B. G. Thurber, A. M. Calvert, A. M. Mills, L. P. McGuire, and C. G. Guglielmo. 2011. Landscape movements of migratory birds and bats reveal an expanded scale of stopover. PlosOne 6(11): e27054. doi:10.1371/journal.pone.0027054.
Warnock, N. 2010. Stopping vs. staging: the difference between a hop and a jump.
Journal of Avian Biology 41:621-626.
Yahner, R. H. 1982. Avian nest densities and nest-site selection in farmstead shelterbelts. The Wilson Bulletin 94:156-175.
Young, H. 1948. A comparative study of nesting birds in a five-acre park. The Wilson Bulletin 61:36-47.
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December 12, 2023
Stephanie Papayanis, Esq.
Mitchel M. Tsai, Attorney at Law
139 South Hudson Avenue, Suite 200
Pasadena CA 91101
[email protected]
Subject: City of Livermore SMP 38/SMP 39/SMP 40 Project Review of DEIR Noise Section & Appendices
Dear Stephanie:
We have completed a review of Section 4.6 (Noise), as well as Appendices J and K (Environmental Noise Assessments) of the Draft Environmental Impact Report for the City of Livermore SMP 38/SMP 39/SMP 40 Project, focusing on the adequacy of the noise impact analyses. Here are our findings:
OVERVIEW
Section 4.6 of the DEIR is based on environmental noise assessments prepared by Salter. • Significance Standards
The DEIR significance standards for noise and vibration impacts are based directly on Section XIII of the Environmental Checklist in Appendix G of the current CEQA Guidelines, which reads as follows:
XIII. NOISE - Would the project result in:
a) Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of the local general plan or noise ordinance, or applicable standards of other agencies?
b) Generation of excessive groundborne vibration or groundborne noise levels? c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the area to excessive noise levels? Salter has proposed a 3 dBA increase in ambient noise levels as the threshold for a “substantial increase”. We concur that this is a reasonable value for CEQA evaluation of this project. • Operational Noise & Construction Vibration
The analysis in Section 4.6 shows that noise impacts from operational noise (loading dock activity, HVAC, on-site vehicle movements) as well as vibration during on-site construction are less-thansignificant. Generally, the analysis supporting this finding appears to be methodical and well done, consistent with current CEQA Guidelines, and we take no exception to it. • Construction Noise Impacts
Section 4.6 also includes an analysis of construction noise impacts on the nearest sensitive uses – i.e.: the single-family residential neighborhood to the east of the project sites. This analysis covers on-site construction activity for SMP 40 as well as the construction of off-site trail connections at three potential locations (each within 200-feet of the nearest residential use). 321
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The impact of construction noise on the SMP 39 site is not covered in the DEIR.
For the off-site trail connection construction, the DEIR states that noise impacts are significant without mitigation and provides a list of mitigation measures (4.6-1) to reduce this impact to lessthan-significant level. Generally, we agree with this finding and the proposed mitigation measures.
For on-site construction, the DEIR states that noise impacts will be less-than-significant. However, the analysis presented in the DEIR does not – in our opinion – adequately support this conclusion, for the reasons outlined below.
PROBLEMS WITH THE ON-SITE CONSTRUCTION NOISE IMPACT ANALYSIS • SMP 39 is Excluded
Construction noise from the SMP 39 site is not included in the analysis in Section 4.6 of the DEIR. An explanation for this omission is provided in the final paragraph on page 4.6-21, which reads in part:
“Due to the substantial distance between SMP 39 and the sensitive noise receptors, it was anticipated that construction noise associated SMP 39 would be below the City of Livermore’s exterior noise level threshold of 60 dBA DNL at the nearest sensitive receptor locations. Thus, construction noise levels for SMP 39 were not evaluated as part of the Environmental Noise Study for SMP 39.”
There are two problems with this explanation:
First, CEQA requires an actual analysis to show whether a project impact is significant or less-thansignificant. Simply “anticipating” that there will be no significant impact falls short of the standard required for a CEQA study.
Second, the 60 dBA DNL exterior noise standard (which comes from the land-use compatibility table in the Noise Element of the City of Livermore General Plan) is only one of the applicable local regulations. The DEIR analysis should address all applicable regulations in both the General Plan and Municipal Code.
• Analysis for SMP 40 is Incomplete
The noise impact analysis for construction on the SMP 40 site compares Salter’s noise level predictions with instantaneous maximum noise level (Lmax) limits of 70 dBA during the day and 60 dBA at night, which are taken from Policy N-1.5.P3 of the City of Livermore General Plan.
However, these Lmax noise limits are not the only local regulations that would apply to construction noise on the SMP 40 site.
For example, the DEIR does not show how construction noise from SMP 40 would compare to Policy N-1.5.P2 of the General Plan, which prescribes the following noise limits, depending on the cumulative duration of the noise:
Daytime Noise Limit
(7AM – 10PM)
Nighttime Noise Limit
(10PM – 7AM) Cumulative Duration
60 dBA 50 dBA No more than 15-minutes in any hour.
65 dBA 55 dBA No more than 5-minutes in any hour.
70 dBA 60 dBA No more than 1-minute in any hour.
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Similarly, the DEIR does not include an DNL analysis for construction noise from SMP 40 to show that it will be below the 60 dBA exterior noise standard taken from land-use compatibility table (Table 9-7) in the General Plan. This will be particularly important if any construction work is to occur at night.
• There is an Error in the Calculations for SMP 40
Table 4.6-6 of the DEIR lists estimated Lmax noise levels for various pieces of construction equipment at a distance of 50-feet (these are standard reference values, taken from the FHWA Construction Noise Handbook) and extrapolates them to a distance of 884 feet.
According to Table 4.6-6, the equipment noise levels received at a distance of 884 are 57 dBA lower than lower than those received at a distance of 50-feet. This is incorrect. According to the radiation equation for point sources (such as individual pieces of construction equipment) the reduction in noise level from 50-feet to 884 feet is:
10 x LOG10 (884/50) = 25 dBA
So, the estimated Lmax noise levels provided in Table 4.6-6 are 32 dBA lower than they should be.
Which means that noise from several of the pieces of equipment listed should be expected to produce a maximum level of noise at the nearest residences that is either right at the 60 dBA nighttime limit or, in the case of paving equipment, 4 dBA above it. • Construction on the East Side of the SMP 40 Site is Overlooked The construction noise analysis in the DEIR for SMP 40 considers assumes receivers 884-feet away from the equipment – which is the distance between the location proposed for Building 2 and the nearest residences. However, there will be certain phases of construction – such as site preparation and paving/landscaping/site concrete – when noisy equipment could be operating closer than 884- feet from nearby residential uses.
For example, the eastern corner of the SMP 40 site is within 600-feet of the nearest residential use.
Received noise levels at a distance of 600-feet from the equipment would be 3 dBA higher than those received at 884-feet, which means that the expected noise level at the nearest residences when paving equipment is in use in the eastern corner of the site would be 67 dBA, Lmax and not 32 dBA, Lmax as reported in Table 4.6-6.
SUMMARY & RECOMMENDATIONS
We find that, while much of the noise analysis in the DEIR has been done to the standard expected of a CEQA study, the evaluation of noise impacts during the construction phases is incomplete and contains a significant calculation error. We therefore recommend that the preparers be requested to revise/correct the Noise Section (4.6) of the DEIR as follows:
• Include SMP 39 in the on-site construction noise impact analysis. The analysis should take account of the anticipated number of pieces of equipment in use at any one time during each phase as well as estimated usage factors, so that construction noise impacts can be evaluated in the in the context of the City of Livermore General Plan DNL 60 dBA exterior noise standard (from Table 9-7) and the time-dependent noise limits in Policy N-1.5.P2, as well as the Lmax noise limits in Policy N-1.5.P3. • For on-site construction on the SMP 40 site, the noise impact analysis should be expanded to take account of the anticipated number of pieces of equipment in use at any one time during each phase as well as estimated usage factors, so that construction noise impacts can be evaluated in the in the 323
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context of the City of Livermore General Plan DNL 60 dBA exterior noise standard (from Table 9-7) and the time-dependent noise limits in Policy N-1.5.P2, as well as the Lmax noise limits in Policy N1.5.P3. • Table 4.6-6 should be revised to show the correct (25 dBA) reduction in point-source noise levels from 50-feet to 884-feet.
• Provide additional analysis for any construction activity on the SMP 40 site (such as site preparation, paving/landscaping) that could occur closer than 884-feet from the nearest residential use.
Yours sincerely,
Steve Rogers Acoustics, LLC
Steve Rogers
Principal
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VIA E-MAIL
March 5, 2024
City of Livermore Planning Commission
City Council Chambers
1016 S. Livermore Avenue
Livermore, CA 94550
Em: [email protected]
RE: City of Livermore’s SMP 39 and 40 Planning Commission Meeting
Dear Ashley Vera,
On behalf of “Carpenters Local 713”, my Office is submitting these supplemental comments for the City of Livermore’s (“City”) Draft Environmental Impact Report (“Draft EIR” or “DEIR”) and Final Environmental Impact Report (“Final EIR” or “FEIR”) for the March 5, 2024 Planning Commission Meeting for the SMP 39 and 40 Project (“Project”).
According to the Project’s Notice of Availability (“NOA”) of a Draft EIR Project Description:
“On SMP 38, the proposed project includes a Sphere of Influence (SOI) Amendment to include SMP 38 within the City of Livermore SOI and remove it from the City of Pleasanton’s SOI. The City of Livermore General Plan land use designation for SMP 38 would remain Limited Agriculture and Open Space/Sand and Gravel and the Alameda County zoning designation would remain Agriculture. Development of SMP 38 is not proposed.
For SMP 39, the proposed project would include development of a total of up to six light industrial buildings, consisting of up to approximately 755,500 square feet (sf) of new building space, and associated internal roadways and other improvements. For SMP 40, the proposed project would include development of two industrial buildings containing up to 759,275 sf of new building space with 325
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related internal roadways and other improvements. A number of approvals would be required for development of SMP 39 and SMP 40, including a SOI Amendment for SMP 39, General Plan Amendment, Pre-zoning and Annexation, Zoning Map Amendment/Planned Development, Vesting Tentative Subdivision Maps, a Pre-Annexation Agreement, and Development Agreement. A Site Plan Design Review entitlement is required for SMP 39 and SMP 40, which would include a review of the site plan, building, and landscape design; however, the entitlement is only proposed for SMP 40 at this time. A Site Plan Design Review entitlement will be required at a later date for the future development of SMP 39. In addition, the proposed project would include annexation of four additional parcels (APNs 904-10-2-3, -5, -7, and - 8) located east of SMP 40. Development is not proposed on the additional parcels as part of the proposed project.
The project would include a paved at-grade, on-site trail along the boundaries of the SMP 40 site, consistent with the City’s Active Transportation Plan. Specifically, the on-site trail would extend from the northeastern corner of the site, along the project site’s eastern, southern, and western boundaries, before connecting to an existing off-site paved shared-use path at the northwestern corner of site, which extends along the west side of the Oaks Business Park to the north and connects to West Jack London Boulevard.
In addition, the project would include a new off-site connection to the existing Arroyo Mocho Trail, located on the east side of Isabel Avenue/SR 84. For the purposes of the Draft EIR analysis, three alternatives for the proposed off-site Isabel Avenue/SR 84 crossing to the existing Arroyo Mocho Trail are considered and evaluated in the Draft EIR, including the following, and described in more detail in the Draft EIR:
• Trail Connection Option 1 – At-Grade Crossing at Discovery Drive;
• Trail Connection Option 2 – Undercrossing at Isabel Bridge; and • Trail Connection Option 3 – Overcrossing of Isabel Avenue/SR
84.”
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NOA of Draft EIR, pp. 1-2, emph. added.
The concurrently circulated Draft EIR contains the same project description.
DEIR, pp. 1-2—1-4.
Carpenters Local 713 is a labor union representing union carpenters in Alameda County , and has a strong interest in well-ordered land use planning and in addressing the environmental impacts of development projects.
Local 713 members live, work, and recreate in the City and surrounding communities and would be directly affected by the Project’s environmental impacts.
Carpenters Local 713 expressly reserves the right to supplement these comments at or prior to hearings on the Project, and at any later hearing and proceeding related to this Project. Gov. Code, § 65009, subd. (b); Pub. Res. Code, § 21177, subd. (a); see Bakersfield Citizens for Local Control v. Bakersfield (2004) 124 Cal.App.4th 1184, 1199- 1203; see also Galante Vineyards v. Monterey Water Dist. (1997) 60 Cal.App.4th 1109, 1121.
Carpenters Local 713 incorporates by reference all comments related to the Project or its CEQA review, including the Environmental Impact Report. See Citizens for Clean Energy v City of Woodland (2014) 225 Cal.App.4th 173, 191 (finding that any party who has objected to the project’s environmental documentation may assert any issue timely raised by other parties).
Moreover, Carpenters Local 713 requests that the City provide notice for any and all notices referring or related to the Project issued under the California Environmental Quality Act (CEQA) (Pub. Res. Code, § 21000 et seq.), and the California Planning and Zoning Law (“Planning and Zoning Law”) (Gov. Code, §§ 65000–65010).
California Public Resources Code Sections 21092.2, and 21167(f) and California Government Code Section 65092 require agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency’s governing body.
I. CEQA REQUIRES SUBSEQUENT OR SUPPLEMENTAL
ENVIRONMENTAL REVIEW WHEN SUBSTANTIAL CHANGES
OR NEW INFORMATION COMES TO LIGHT
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Section 21092.1 of the California Public Resources Code requires that “[w]hen significant new information is added to an environmental impact report after notice has been given pursuant to Section 21092 … but prior to certification, the public agency shall give notice again pursuant to Section 21092, and consult again pursuant to Sections 21104 and 21153 before certifying the environmental impact report” in order to give the public a chance to review and comment upon the information. (CEQA Guidelines § 15088.5.)
Significant new information includes “changes in the project or environmental setting as well as additional data or other information” that “deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative).” (CEQA Guidelines § 15088.5(a).) Examples of significant new information requiring recirculation include “new significant environmental impacts from the project or from a new mitigation measure,” “substantial increase in the severity of an environmental impact,” “feasible project alternative or mitigation measure considerably different from others previously analyzed” as well as when “the draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded.” (Id.)
An agency has an obligation to recirculate an environmental impact report for public notice and comment due to “significant new information” regardless of whether the agency opts to include it in a project’s environmental impact report. (Cadiz Land Co. v.
Rail Cycle (2000) 83 Cal.App.4th 74, 95 [finding that in light of a new expert report disclosing potentially significant impacts to groundwater supply “the EIR should have been revised and recirculated for purposes of informing the public and governmental agencies of the volume of groundwater at risk and to allow the public and governmental agencies to respond to such information.”].) If significant new information was brought to the attention of an agency prior to certification, an agency is required to revise and recirculate that information as part of the environmental impact report.
The City’s Supplemental Memorandum (“Exhibit A”) identifies numerous substantial changes to the EIR. Most notably Noise Impacts section was dramatically changed based on updated Noise Studies for SMP 39 and 40 and newly determined significance thresholds were applied. These updated studies were only finalized one day ago and given to the public less than four hours before the Planning Commission hearing.
Moreover, the updated studies and significance thresholds resulted in an entirely new 328
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mitigation measure in the MMRP. (See Exhibit A at 695). Indeed, the most recent revision now predicts SMP 40 construction-related noise will exceed the thresholds established by the City. As such, the dramatic change in the findings of the EIR requires recirculation so that the public may provide its input.
II. THE FEIR IS IMPROPER AS IT DOES NOT INCLUDE ALL
CHANGES TO THE DEIR
The FEIR cannot be certified by the Planning Commission as it does not include the numerous changes created by the Supplemental Memorandum released mere hours before the Planning Commission Hearing. Under CEQA Guidelines Section 15132, a FEIR shall include:
“(a) The draft EIR or a revision of the draft.
(b) Comments and recommendations received on the draft EIR either verbatim or in summary.
(c) A list of persons, organizations, and public agencies commenting on the draft EIR.
(d) The responses of the Lead Agency to significant environmental points raised in the review and consultation process.
(e) Any other information added by the Lead Agency.”
As the FEIR has received two rounds of revisions since it was originally prepared in January 2024, the document proposed for certification is an inaccurate reflection of the FEIR. As such, the Planning Commission must not certify the FEIR until, at a minimum, the document reflects the most up-to-date version.
III. CONCLUSION
Based on the foregoing, the Planning Commission should deny the FEIR’s certification, and the Environmental Impact Report should be revised and recirculated pursuant to CEQA, consistent with the comments and issues identified in this and previous comment letters.
Sincerely,
____________________________
Grace Holbrook
Attorneys for Carpenters Local 713
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Attached:
Supplemental Memorandum (Exhibit A).
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PLANNING COMMISSION STAFF REPORT ITEM NO. 10.1
DATE: March 5, 2024
TO: Chairperson and Members of the Planning Commission
FROM: Steve Riley, Acting Planning Manager
SUBJECT: Supplemental Materials received prior to the meeting.
RECOMMENDED ACTION
SUMMARY
These materials were posted online and made available to the public at the same time that they were distributed to the Planning Commission.
5.1 - Hearing to consider a request for an Annexation/Prezoning, Pre-Annexation and Development Agreements, General Plan Amendment, Zoning Map Amendment, Development Code Amendment, Vesting Tentative Parcel Map, Vesting Tentative Tract Map, Planned Development, and Site Plan Design Review for the SMP 39 and 40 Project to zone for and develop light industrial uses near the northwest part of the City.
Materials: Response to comments memorandum and errata, Conceptual site plan for SMP 39, Revised engineering consideration, Letters received in advance of the meeting, and Development agreements signed by the applicant.
DISCUSSION
ATTACHMENTS
1. Supplemental Materials
Prepared by: Michele Donley
Division Clerk
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SMP 39/SMP 40 Project
Supplemental Responses to Comments Received After the Close of the Draft Environmental Impact Report Public Review Period and Erratum
As mentioned in the memorandum entitled, “Responses to Comments Received After the Close of the Draft Environmental Impact Report Public Review Period and Erratum”, the City would be following up with a supplemental memorandum to provide responses to the “Attorneys for Carpenters Local 713” letter, dated February 14, 2024, which was received after the release of the Final Environmental Impact Report (EIR) for the SMP 39/SMP 40 Project (proposed project).
This supplemental memorandum provides the responses to the above-referenced letter.
While CEQA does not require that written responses be provided for letters received after the close of the public review period, the comments are acknowledged by the City, and the City has chosen to prepare written responses to the comments for the decision-makers consideration in making an informed decision. Responses to the “Attorneys for Carpenters Local 713” comment letter, which is included as Attachment 1, are provided below. Where revisions to the EIR text are required in response to a comment, new text is double underlined and deleted text is struck through.
The comments received did not identify any new significant impact, substantial increase in severity of a significant impact identified in the EIR, or any significant new information. Therefore, recirculation of the EIR is not required.
Response to Stephanie Papayanis, Attorneys for Carpenters Local 713 The majority of the comment letter, including the entirety of Comment I and Comment II(A) of the comment letter, is identical to the comment letter submitted by Attorneys for Carpenters Local 713 during the Draft EIR comment period. As such, with regard to Comment I and Comment II(A) included in the comment letter, please see Responses to Comments 5-3 and 5-5 included in the Final EIR.
The new concerns brought forth in the comment letter are limited to Comment II(B) and Comment II(C) related to biological resources and construction noise. Thus, responses to Comment II(B) and Comment II(C) are provided below.
Comment II(B) Related to Biological Resources
Responses to the commenter’s concerns regarding biological resources are provided below, as informed by Monk & Associates (M&A), who prepared the project-specific Biological Resources Assessments (BRAs) used within the Draft EIR analysis. It should be noted that Comment II(B) is a summary of the comments provided in Exhibit D to the Attorneys for Carpenters Local 713 comment letter, which is a letter authored by Shawn Smallwood, PhD. As such, the following responses are organized based on the comments presented in Exhibit D of the Attorneys for Carpenters Local 713 comment letter.
Environmental Setting Informed by Field Surveys
2023) surveys have been misinterpreted in the reports, resulting in inaccurate characterizations of the existing environmental settings of SMP 39 and SMP 40.” The commenter is referring to the fact that M&A biologists recorded fewer bird species on-site and flying overhead than the commenter did during a reconnaissance visit. The environmental setting or environmental 683 332
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baseline of a project site is informed by much more than the number of birds and mammals one sees in a certain amount of time.
The CEQA Guidelines Section 15125(a) requires that the CEQA document prepared for a project discuss the “baseline” environmental conditions at and in the vicinity of the project sites. CEQA Guidelines Section 15125 (see also Section 15126.6(e)(2)) states the following regarding the environmental setting as it relates to baseline:
(a) [the CEQA review document] must include a description of the physical environmental conditions in the vicinity of the project, as they exist at the time the notice of preparation is published, or if no notice of preparation is published, at the time environmental analysis is commenced, from both a local and regional perspective. This environmental setting will normally constitute the baseline physical conditions by which a lead agency determines whether an impact is significant. The description of the environmental setting shall be no longer than is necessary to understanding the significant effects of the proposed project.
M&A conducted several surveys on each of the project sites. As explained in the SMP 39 BRA included as Appendix D to the Draft EIR, M&A survey work in the project area dates to the year 2000. However, because CEQA requires current baseline conditions, none of the plants or wildlife observed in the early 2000s were reported in the BRAs. The 2021 surveys are the baseline surveys that were conducted to record existing biological resources and to assess the likelihood of resource agency regulated areas on the project sites. The surveys involved searching all habitats on the sites and recording all plant and wildlife species observed. M&A cross-referenced the habitats found on the project sites against the habitat requirements of local or regionally known special-status species to determine if the proposed project could directly or indirectly impact such species and if additional protocol level surveys would be necessary to assess potential impacts to special status species.
CEQA does not require an exhaustive list of all bird species that could occur on a project site, nor does CEQA require a discussion of what each species is doing at the time the species is observed. Rather, CEQA requires an analysis of potential impacts to special-status birds and/or nesting habitat for common birds that rise to the level of significance pursuant to CEQA as determined by an expert, based on database searches, field surveys, etc. M&A’s BRAs provide that analysis and recommend pre-construction surveys to address potentially significant impacts.
Overall, the BRAs meet the standards of care warranted under CEQA.
Habitat Loss
The commenter’s estimate on the number of birds “denied to California” is primarily based on two studies. The commenter states that the two study sites have grassland/wetland/woodland complexes within agricultural matrices, and found total bird nesting densities of 32.8 and 35.8 nests per acre. The commenter uses one-third of such estimates for the project sites’ calculation due to the annual discing that occurs on the project sites. However, the estimation is likely still an overestimate, as one study was conducted in a five-acre, undisturbed, unfragmented and preserved area within the over-500-acre University of Wisconsin Arboretum dedicated in 1934, adjacent to a 321-acre lake (Lake Wingra). The SMP 39 and SMP 40 project sites are not surrounded by hundreds of acres of preserved natural lands but rather the relatively small project sites are fragmented from natural areas by surrounding, existing development (busy roads, an airport, and active industrial uses).
The other study mentioned by the commenter was conducted within farmstead shelterbelts, or “man-made habitats consisting of parallel rows of trees and shrubs designed to protect farmsteads from damaging winds, drifting snow and blowing soil…” referred to as “wooded 684 333
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islands.” The study determined that the wooded islands are important for avifauna in regions of intensive agriculture and found many nests within the wooded region. The SMP 40 project site has a similar “wooded island,” in that the wooded area that is a riparian corridor along Arroyo Mocho is being preserved within a riparian set back and will provide high-quality habitat for many nesting birds post-development. The preservation of Arroyo Mocho’s riparian habitat was not considered in the commenter’s calculations.
Further, the commenter’s comparison of development of the proposed project to the high avian mortality rate by wind turbine collision in the Altamont Pass Wind Resource Area is not an appropriate comparison. The commenter is comparing 50-foot-tall buildings on the project sites to 430-foot-tall wind turbines with active, moving blades in a known avian migration zone; an area that supports the highest number of nesting Golden Eagles in the world.1
Regardless of the commenter’s inappropriate comparison and overestimate of the number of birds “denied to California” due the loss of nesting habitat by the proposed projects, CEQA requires an analysis of potential impacts to special-status birds and/or nesting habitat for common birds that raise to the level of significance. Therefore, impacts to nesting birds were regarded as significant pursuant to CEQA in the Draft EIR. However, mitigation measures to protect special-status birds and all nesting birds have been prescribed in the Draft EIR (see Mitigation Measures 4.3-2[a] through 4.3-2[d] in the Draft EIR). The mitigation measures included therein reduce impacts to nesting birds to a less-than-significant level pursuant to the CEQA. Thus, the commenter’s concerns about the projects’ impacts to nesting birds have been sufficiently addressed.
Interference with Wildlife Movement
The commenter is correct that the Essential Habitat Connectivity Area mapped by the California Department of Fish and Wildlife (CDFW) is focused on connecting very large blocks of mostly protected natural lands. While the Draft EIR does state that the project sites are not located in this mapped area, that is only one sentence of the three-paragraph description under the Wildlife Movement Corridor section of the Draft EIR (see pages 4.3-14 to 4.3-15 of the Draft EIR). The comment implies that sufficient research and in-person assessments were not conducted accordingly, and that the determination that the project sites will not impact significant wildlife corridors was solely based on using the CDFW’s Essential Habitat Connectivity Area map, which simply is not true.
For example, M&A conducted online research and project-specific field surveys to become informed about the project sites’ habitats and the potential for any impacts to regional wildlife corridors based on development of the proposed projects. M&A recorded wildlife observed during site visits, in addition to extensively noting the habitat types and surrounding land uses during their visits and how the surrounding land uses would affect wildlife movement. As such, the commenter’s statement that the conclusions of the Draft EIR regarding wildlife movement on the project site are speculative and conclusory is untrue.
Wildlife corridors are linear and/or regional habitats that provide connectivity to other natural vegetation communities within a landscape fractured by urbanization and other development.
Wildlife corridors are extremely important habitats to preserve and are valuable for wildlife. While local wildlife may use the undeveloped sites in their current state, neither of the project sites currently provide a significant regional wildlife corridor that may be impacted by the proposed project. The project sites are regularly disced or disturbed for agriculture. For SMP 40, an 1 National Audubon Society. National Audubon Society Sues California County to Improve Bird Protections in Controversial Wind Energy Project. Available at: https://www.audubon.org/news/national-audubon-society-suescalifornia-county-improve-bird-protections#:~:text=17%2C%202021)%2D%2DThe%20National,turbine%20facility %20at%20Altamont%20Pass%2C. Accessed February 2024.
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industrial development, Oaks Business Park, is located to the north of the project site, east of the project site is Isabel Avenue, a heavily-trafficked road, south is an active railroad track and Stanley Boulevard, another heavily-trafficked road, and west of the project site are quarry ponds. SMP 39 is bordered by West Jack London Boulevard, a well-trafficked road, the Livermore Municipal Airport, the Oaks Business Park, and quarry ponds. The quarry ponds were excavated in uplands and, thus, are not associated with a creek or drainage, and have nearly vertical slopes, preventing wildlife from traversing the ponds easily or using the quarry area as a corridor. As mentioned in M&A’s BRAs, both SMP 39 and SMP 40 are isolated from regional open spaces, and, as such, do not have regional wildlife corridor value for terrestrial mammals and contain minimal habitat that could be used by some migrating avian species.
The commenter states: “On the other hand, the coyote I saw on site got there somehow, and so did the ground squirrels and pocket gophers, and so did all of the birds I saw on and over SMP
39.” One might infer from this statement that M&A’s reports and the Draft EIR implied that wildlife do not use, or could not be found on the project sites, which is incorrect. Each of M&A’s BRAs included a table of wildlife species observed on the project sites during site visits, which, as described in the BRAs, is not intended to be exhaustive or to describe the only species that could be found on the project sites. Rather, the focus was, as required by CEQA and as appropriate, on the assessment of biological resources with regard to suitable habitat and potential for the occurrence of any special-status species, as determined by a qualified biologist for the purposes of an impact analysis. Movement of a species through an area or an area’s incidental use does not necessarily imply importance to the species, the characteristics of the habitat are more relevant.
For example, Figure 3 of the commenter’s report shows the fly over and resting locations of Golden Eagles, which provides an example of how local wildlife may use the project sites as well as all surrounding areas, including properties completely developed with warehouses and surrounded by busy roads. However, while species such as the Golden Eagle may use the project site for foraging or resting on occasion, or may flyover, it is clear that the project sites are not the main sites that are relied upon by these large raptors for any of the above functions, or for nesting, as the existing trees are too small and in close proximity to disturbance.
The SMP 40 riparian area may provide significantly more suitable rest, foraging and nesting habitat for many bird species than the open and disturbed grassland does. However, as previously described, the riparian area on SMP 40 will be completely preserved within a riparian setback and will continue to connect local wildlife within the riparian corridor along the Arroyo Mocho.
The commenter also mentions that 19 special-status species so far have been documented on the project site, as further detailed in Table 1 of the commenter’s report. However, the commenter’s list includes species that do not meet the definition of “rare” pursuant to the CEQA.
For example, Table 1 includes Red-tailed Hawk (Buteo jamaicensis), California Gull (Laus californicus), Double-crested Cormorant (Phalacrocorax auritus), Nuttall’s Woodpecker (Picoides nuttallii), and Oak Titmouse (Baeolophus inornatus), which are designated as Birds of Prey (BOP), Birds of Conservation Concern (BCC) by U.S. Fish and Wildlife Service, and Taxa to Watch List. However, the aforementioned listings are not considered special-status under the California or Federal Endangered Species Acts (CESA and FESA), by other regulations, or by the scientific community pursuant to the CEQA. Nonetheless, it should be noted that these species, their nests, eggs and/or young are provided protection pursuant to other resource agency regulations such as the Migratory Bird Treaty Act (MTBA) and the California Fish and Game Code Sections 3503, 3503.5, 3511, and 3513C, which are both fully accounted for and discussed in M&A’s BRAs and the Draft EIR.
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In addition, the commenter does not specify which of the 19 species were observed during his site visit, or which were taken as observations from eBird. While many experienced birders may use eBird, anyone can report incidental bird sightings to eBird without any way to confirm the qualifications of the observer. As such, relying only on eBird data to say confidently that a specialstatus species is present on a property is not sufficient and would need to be confirmed by a qualified biologist. As mentioned by the commenter, several of the species sightings are birds flying over the project sites. As discussed in sections above, observing sensitive birds flying over a property, foraging over the site, or using the habitat on the sites during the non-nesting season does not warrant reporting to the California Natural Diversity Database (CNDDB), as such sightings are not of permanent breeding/nesting/larval development habitat (dependent on what type of animal it is) that warrant protection. The types of “incidental” sightings of common bird species do not necessarily translate into a “potentially significant biological impact” pursuant to CEQA Guidelines and regulations.
Further, while the project sites in their current state may be used by local wildlife, they provide very low value for foraging, resting or nesting, as the project sites are mainly comprised of nonnative ruderal herbaceous habitats and are highly disturbed due to agricultural practices. The project sites are not one of the last remaining stopover and staging opportunities in the region, as stated by the commenter, as acres of undeveloped land similar to the project sites is located within the very immediate area, as well as dozens of local parks. The 80-acre Shadow Cliffs Regional Recreation Area is less than two miles from the project sites and the 160-acre Doolan Canyon Regional Preserve beyond provides more undeveloped land to the north. All of the aforementioned habitats in the region provide habitat for the species listed in the table of wildlife observed included in Exhibit D of the comment letter, and have far greater wildlife corridor habitat value than the project sites. The commenter’s concerns about the loss of the ruderal habitats onsite should be assuaged by the fact that more trees and shrubs will be planted on the project sites post-development than are currently on site, which will provide additional stopover opportunities for birds.
Finally, as previously mentioned, the Arroyo Mocho runs along the southern project site boundary of SMP 40. Arroyo Mocho may serve as a local movement corridor for mammals, amphibians, and reptiles to move unobtrusively through the general geographic area. Animals moving along Arroyo Mocho could leave the Arroyo and enter the project site to move across the landscape.
Such animals expected to migrate along the Arroyo and possibly enter the upland areas of the project site are common species such as coyote, raccoons, skunks, deer, and rodents, and would be able to navigate their way around SMP 40 even after the site was developed. The Arroyo Mocho would remain unchanged by the proposed project and as such, the wildlife corridor values of the channel would remain intact. Under all circumstances, any disruption to the very localized use of the project sites by common wildlife species would not be regarded as a potentially significant impact pursuant to CEQA.
Traffic Impacts to Wildlife
Common wildlife associated with humans and urban development such as Virginia opossum (Didelphis virginiana), striped skunk (Mephitis mephitis) and raccoon (Procyon lotor) are often involved in vehicle collisions. However, the aforementioned species and other common wildlife species, including Mourning Dove (Zenaida macroura) and northern pacific rattlesnake (Crotalus oreganus), are not considered special-status or rare. In addition, while roadkill is present in the vicinity of the project sites, as is the case at any area with road traffic, the approximation included in Exhibit D of the comment letter is likely an overestimate, as the numbers are based on another study that is not directly comparable to the project area. Vasco Road is the principal north-south route between eastern Alameda and Contra Costa Counties, traveled by approximately 22,000 vehicles per day. Increased traffic to the project sites on local roadways, Isabel Avenue and West 687 336
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Jack London Boulevard, is not comparable to the heavily trafficked Vasco Road, which is a corridor in the middle of hundreds of acres of protected open space lands and significant wildlife habitat. By contrast, Stanley Boulevard and I-580, near the project sites, are already heavily trafficked roads in a developed region and the increase in vehicles associated with the project sites would not contribute significantly to the existing traffic volumes on these roads daily.
Moreover, regulations that protect common wildlife species that could be killed by vehicular traffic do not exist. As such, vehicle collisions that result in the mortality of wildlife do not constitute a significant impact pursuant to CEQA.
Western Burrowing Owl Mitigation
The CDFW has not released an official statement that the avian breeding season has changed.
In M&A’s experience, when permits are acquired from the CDFW, the nesting season window can vary slightly. Some permits say February 1 through August 31, while others say February 15 through September 1. The variation in start and end dates could be based on geography, as different geographic regions have slightly different nesting windows. In fact, the CDFW acknowledges a certain amount of variation in the 2012 CDFW Staff Report on Burrowing Owl Mitigation, which states, “In California, the burrowing owl breeding season extends from 1 February to 31 August (Haug et al. 1993, Thompsen 1971) with some variances by geographic location and climatic conditions.” Nonetheless, in response to the comment, Mitigation Measure
4.3-2(a) included in the Draft EIR is hereby revised as follows:
Western Burrowing Owl
4.3-2(a) If project construction begins during the western burrowing owl nesting season (February 15 to August 31), a qualified biologist shall conduct targeted burrowing owl nest surveys within 14 days prior to construction activities using seven- to 20-foot transects. A separate preconstruction survey shall be conducted for SMP 39 and SMP 40 (including the off-site trail connection area) if the components of the project are not constructed concurrently. The survey shall include the project site and all accessible areas within 500 feet of the project impact zone, and shall follow CDFW guidelines outlined in the 2012 Staff Report on Burrowing Owl Mitigation. The results of the survey shall be submitted to the City of Livermore Community Development Department within 30 days of the completed survey. The survey report shall be valid for one construction season.
If western burrowing owls are not detected on-site during the survey, further mitigation shall not be required. If any western burrowing owls are detected on-site, pursuant to the CDFW’s 2012 Staff Report on Burrowing Owl Mitigation, the following restricted activity dates and setback distances shall be implemented:
• From April 1 through October 15, low disturbance activities shall have a 200-meter buffer while high disturbance activities shall have a 500-meter buffer from occupied nests.
• From April 1 through August 15, medium disturbance
activities shall have a 500-meter buffer from occupied nests.
Medium disturbance activities can have a reduced buffer of 200 meters starting August 16 through October 15.
• From October 16 through March 31, low disturbance activities shall have a 50-meter buffer, medium disturbance activities shall have a 100-meter buffer, and high disturbance activities shall have a 500-meter buffer from occupied nests.
• Earth-moving activities or other disturbance shall not occur within the aforementioned buffer zones of occupied burrows 688 337
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unless monitoring of the nest site by a qualified biologist determines that the owls are acclimated to the disturbance and would not be disturbed by a smaller buffer. The buffer zones shall be fenced.
• A qualified biologist shall delineate the extent of burrowing owl habitat on the site.
• Owls may be passively relocated from the project site between October 1 and February 1. Passive removal shall be conducted by a qualified biologist with demonstrated
experience with passive relocation.
• Credits shall be purchased from a mitigation bank in
coordination with CDFW and the City of Livermore to offset the project’s habitat loss on the burrowing owl.
A report detailing compliance with the provisions set forth herein shall be prepared by the qualified biologist and submitted for review and approval to the City of Livermore Community Development Department.
Further, M&A biologists have conducted several surveys, some of which are dated October 2000; March 11, 2002; May 11 and 20, 2002; June 14 and 25, 2002; September 2003, November 2013, June 10, 2019, November 2019, September 10, 2021, November 13, 2021, and June 15, 2022.
The aforementioned surveys conducted in May and June were focused Burrowing Owl breeding season surveys conducted in accordance with the CDFW 1995 Staff Report protocol. Burrowing owl, or signs of burrowing owl, were not observed during any of the M&A surveys. Thus, based upon M&A’s multiple surveys of the project site spanning multiple years, evidence suggests that burrowing owls have not nested on-site for the following reasons: (1) the grass grows very tall on SMP 40 in between discing activities, which does not allow ground nesting birds, such as the burrowing owl, an opportunity to detect aerial predators, which likely discourages them from nesting; (2) discing activities may disrupt nesting attempts.
Based on habitat assessments and past negative survey results, M&A believes that burrowing owls are unlikely to nest on-site. However, given that the burrowing owl is a mobile species, a mitigation measure for preconstruction surveys was provided in the Draft EIR to ensure that “take” of burrowing owls does not occur. The prescribed preconstruction surveys, consistent with “take avoidance surveys” outlined in the CDFW’s Staff Report 2012, are sufficient and appropriate to detect nesting owls should the species be present on-site in light of the prior surveys’ negative results, including a year of protocol-level breeding season surveys. Burrowing owls residing in topographically flat areas are typically easy to detect if surveys consist of walking transects using high-powered binoculars. As such, the mitigation measure included in the Draft EIR is sufficient to reduce any potential project impacts on burrowing owl to a less-than-significant level.
Tricolored Blackbird Mitigation
As stated above, M&A biologists have been on both project sites multiple times over the last 20 years. Tricolored blackbirds have not been observed on-site and on-site habitat for the species is marginal, as the sites are routinely disturbed, water is not present on SMP 39, and Arroyo Mocho at SMP 40 is typically dry during the middle to end of the nesting season. The tricolored blackbird prefers nesting near water. The preconstruction surveys proposed in the Draft EIR to determine if tricolored blackbird is nesting on-site are sufficient to detect the species’ presence. The species can also be looked for during the burrowing owl surveys, which will take place at the same time as tricolored blackbird nesting season.
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Nesting Bird and Raptor Mitigation
As discussed above, the CDFW has not released an official statement that the avian breeding season has changed. In M&A’s experience when permits are acquired from the CDFW, the nesting season window can vary slightly, as different geographic regions have slightly different nesting windows.
In addition, with regard to nest detection, while grassland nesting birds are difficult to detect, M&A biologists are experienced in surveying for ground-nesting and short grass nesting birds and have had success finding nests in the past. Typically, if pedestrian walking transect surveys are conducted by two or more people walking closely together, nests will be found. Further, if experienced consulting biologists are hired to conduct the nesting bird surveys, the biologists will know the appropriate methods to survey for nesting passerine birds, including the Loggerhead Shrike, and raptors. The most suitable habitat for Loggerhead Shrike on the project sites is along SMP 40’s riparian corridor, which will be preserved by the project. Many trees along the riparian corridor and south of the project site could serve as a blind for the observer to hide behind and watch bird behavior to determine if birds are nesting. Finally, the qualified biologist making the nesting buffer determination would provide a report to the City of Livermore and communication between the City of Livermore, the applicant’s biologist, and the construction team would be ongoing throughout the construction period. The biologist will ensure that the buffer is maintained throughout construction to ensure that the nesting attempt is protected.
While development does remove potential bird nesting habitat, the project applicant is avoiding the riparian corridor on the SMP 40 project site, which is the most valuable nesting habitat onsite. Additionally, in accordance with City of Livermore General Plan Policy OSC-1.3 P1, as presented on page 4.3-21 of the Draft EIR, the proposed project is required to landscape with native vegetation.
Based on the above, changes to the Draft EIR mitigation for nesting birds and raptors are not warranted.
Comment II(C) Related to Construction Noise
As discussed on page 4.6-21 of the Draft EIR, due to the substantial distance between SMP 39 and the sensitive noise receptors, it was anticipated, based on the professional judgment of the project noise consultant, that construction noise associated with SMP 39 would be below the City of Livermore’s exterior noise level threshold at the nearest sensitive receptor locations. In response to the comments regarding construction noise impacts associated with SMP 39, Salter, the project noise consultant who prepared the project-specific Environmental Noise Studies used in the Draft EIR analysis, estimated the construction noise levels associated with SMP 39 at the nearest noise sensitive receptor to the site (see Attachment 2). In addition, in response to the comments regarding construction noise impacts associated with SMP 40, Salter provided an updated analysis of construction noise associated with SMP 40 (see Attachment 3). Because construction is not permitted during nighttime hours (pursuant to Section 9.36.080 of the Livermore Municipal Code), the applicable noise level threshold for construction noise levels associated with SMP 39 and SMP 40 would be 70 dBA Lmax, as established by the City of Livermore (see Draft EIR page 4.6-14 and General Plan Policy N-1.5 P3).
The commenter alleges that Table 9-7, Land Use Compatibility Guidelines for Exterior Noise, of the General Plan applies to construction noise; this is not correct. As stated in General Plan Policy N-1.1 P4, presented on page 4.6-8 of the Draft EIR, the City shall use the Land Use Compatibility Guidelines for Exterior Noise (measured in dBA CNEL or Ldn) contained in Table 9-7 (i.e., the DNL 60 dBA exterior noise level standard referenced in the comment letter) to direct the siting, design, and insulation of new development to reduce exposure to excessive noise. Construction 690 339
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noise standards are established in General Plan Policies N-1.5 P2, P3, and P4, as presented on page 4.6-12 of the Draft EIR, which do not include a DNL standard. In particular, General Plan Policy N-1.5 P3 states that in order to allow for temporary construction, demolition or maintenance noise and other necessary short-term noise events, the stationary noise standards in Policy N1.5.P1 shall not be exceeded within the receiving land use by more than 15 dBA for any period of time. General Plan Policy N-1.5.P1 requires that industrial and commercial uses be designed and operated so as to avoid the generation of noise effects on surrounding sensitive land uses from exceeding 55 dBA L50 during the hours of 7:00 AM to 10:00 PM and 45 dBA L50 during the hours of 10:00 PM to 7:00 AM. Thus, for analysis purposes of project construction noise within the Draft EIR, the threshold of significance for the maximum allowable construction noise level at a sensitive receptor is 70 dB Lmax during daytime hours and 60 dB Lmax during nighttime hours (i.e., 15 dB above the numerical criteria listed in P1). Consequently, the DNL 60 dBA exterior noise level standard included in the comment letter would not apply to the temporary, intermittent construction noise associated with either SMP 39 or SMP 40.
Based on the comments regarding construction noise impacts associated with SMP 39 and SMP 40, pages 4.6-21 through 4.6-24 of the Draft EIR are hereby revised as follows. Such revisions are also reflected in the Revised Environmental Noise Studies for SMP 39 and SMP 40, included as Attachment 2 and Attachment 3 to this memo. It should be noted that all revisions to pages
4.6-22 through 4.6-24 of the Draft EIR previously included in the Final EIR are also shown in strikethrough and double underlined text below.
Due to the substantial distance between SMP 39 and the sensitive noise receptors, it was anticipated that The noise levels generated by construction equipment would vary greatly depending upon factors such as the type and specific model of the equipment, the operation being performed, the condition of the equipment and the prevailing wind direction. Table 4.6-6 shows maximum noise levels associated with each piece of construction equipment anticipated to be used during construction of SMP 39 at a reference level of 50 feet, as well as at 2,640 feet, which is the distance from Building 1 on the SMP 39 site to the nearest sensitive receptors (the residences located across Isabel Avenue to the east). Based on the project-specific construction schedule assumed in the air quality analysis conducted for SMP 39, Table 4.6-7 summarizes the anticipated construction equipment associated with each phase of project construction, and the relative sound levels at the nearest residential property (approximately 2,640 feet away), assuming that equipment is running simultaneously during each phase of construction. As shown in Table 4.6-7, construction noise associated with SMP 39 would range between 59 and 61 dBA Lmax, be which would be below the City of Livermore’s exterior noise level threshold of 60 70 dBA DNL Lmax at the nearest sensitive receptor locations. Thus, construction noise levels for SMP 39 were not evaluated as part of the Environmental Noise Study prepared for SMP 39. Therefore, the following discussion focuses on SMP 40 and the off-site trail connections. 691 340
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Table 4.6-6
Typical Construction Equipment Noise at SMP 39
Equipment
Estimated
Maximum
Instantaneous Lmax
Noise Level
(dBA at 50 feet)
Estimated Maximum
Instantaneous Lmax
Noise Level
(dBA at 2,640 feet)
Aerial Lift 83 49
Air Compressors 81 47
Cement and Mortar Mixers 85 51
Concrete/Industrial Saws 76 42
Cranes 83 49
Drill Rig of Shoring Beams
(Caisson Drilling) 85 51
Excavators 85 51
Forklifts 83 49
Generator Sets 81 47
Graders 85 51
Paving Equipment 89 55
Rollers 74 40
Rubber-Tired Dozers 85 51
Tractors/Welders/Backhoes 84 50
Welders 73 39
Source: Salter, 2024.
Table 4.6-7
Construction Equipment Noise Levels at Nearest Receptor – SMP 39
Offroad Equipment
Type Amount Usage Hours Resulting Lmax
Grading
Excavators 2 8 54
Graders 1 8 51
Rubber Tired Dozers 1 8 51
Scrapers 2 8 54
Tractors/ Loaders/ Backhoes 2 8 53
All Grading Equipment Running Simultaneously 60
Paving
Pavers 2 8 58
Paving Equipment 2 8 58
Rollers 2 8 43
All Paving Equipment Running Simultaneously 61
Building Construction
Cranes 1 7 49
Forklifts 3 8 54
Generator Sets 1 8 47
Tractors/ Loaders/ Backhoes 3 7 56
Welders 1 8 39
All Building Construction Equipment Running Simultaneously 59 Architectural Coating
Air Compressors 1 8 47
Source: Salter, 2024.
The noise levels generated by construction equipment would vary greatly depending upon factors such as the type and specific model of the equipment, the operation being performed, the condition of the equipment and the prevailing wind direction. Table 4.6- 6 8 shows maximum noise levels associated with typical each piece of construction equipment anticipated to be used during construction of SMP 40 at a reference level of 50 feet, as well as at 884 600 feet, which is the distance from the proposed Building 692 341
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2 on northeast corner of the SMP 40 site to the nearest residences across Isabel Avenue/SR 84. Based on the project-specific construction schedule assumed in the air quality analysis conducted for SMP 40, Table 4.6-9 summarizes the anticipated construction equipment associated with each phase of project construction, and the relative sound levels at the nearest residential property (approximately 600 feet away), assuming that equipment is running simultaneously during each phase of construction.
Table 4.6-6 8
Typical Construction Equipment Noise at SMP 40
Equipment
Estimated
Maximum
Instantaneous Lmax
Noise Level
(dBA at 50 feet)
Estimated Maximum
Instantaneous Lmax
Noise Level
(dBA at 884 600
feet)
Demolition
Concrete/Industrial Saw 76 19 54
Excavators 85 28 63
Rubber-Tired Dozer 85 28 63
Tractor/Loader/Backhoe 84 2762
Site Preparation
Grader 85 28 63
Rubber-Tired Dozer 85 28
Tractor/Loader/Backhoe 84 27
Grading/Excavation
Drill Rig for Shoring Beams
(Caisson Drilling) 85 28 63
Excavators 85 28
Rubber-Tired Dozer 85 28
Tractor/Loader/
Backhoe 84 27
Trenching
Tractor/Loader/Backhoe 84 27
Excavators 85 28
Building Exterior Construction
Crane 83 26 61
Fork Lift 83 26 61
Generator Sets 81 24 59
Tractor/Loader/Backhoe 84 27
Welders 73 16 51
Building Interior Construction/Architectural Coating
Aerial Lift 83 26 61
Air Compressors 81 24 59
Paving/Landscaping/Site Concrete
Cement and Mortar Mixers 85 28 63
Paving Equipment 89 32 67
Rollers 74 17 52
Tractor/Loader/Backhoe 84 27
Source: Salter, 2023 2024.
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Table 4.6-9
Construction Equipment Noise Levels at Nearest Receptor – SMP 40
Offroad Equipment
Type Amount Usage Hours Resulting Lmax
Grading
Excavators 2 8 66
Graders 1 8 63
Rubber Tired Dozers 1 8 63
Scrapers 2 8 66
Tractors/ Loaders/ Backhoes 2 8 65
All Grading Equipment Running Simultaneously 72
Paving
Pavers 2 8 70
Paving Equipment 2 8 70
Rollers 2 8 55
All Paving Equipment Running Simultaneously 73
Building Construction
Cranes 1 7 61
Forklifts 3 8 66
Generator Sets 1 8 59
Tractors/ Loaders/ Backhoes 3 7 67
Welders 1 8 51
All Building Construction Equipment Running Simultaneously 70 Architectural Coating
Air Compressors 1 8 59
Source: Salter, 2024.
As shown in the table Table 4.6-7, construction of SMP 40 is predicted to generate noise levels ranging between 16 70 to 32 73 dBA Lmax at the nearest noise‐sensitive receptors. As discussed in detail above, for analysis purposes of project construction noise within this EIR, a threshold of significance for the maximum allowable construction noise level at a sensitive receptor has been assumed to be 70 dB Lmax during daytime hours and 60 dB Lmax during nighttime hours. Because construction is not permitted during nighttime hours (pursuant to Section 9.36.080 of the Livermore Municipal Code), the 60 dB Lmax noise level standard for nighttime hours would not apply to the proposed project. Accordingly Nonetheless, the maximum predicted construction noise level of 32 73 dBA Lmax associated with SMP 40 would be below above the thresholds of significance being applied.
The three potential off-site trail connection options would be located approximately 160 feet, 150 feet, and 200 feet, respectively, west of the nearest single-family residences.
The anticipated construction activities required for the trail connection options would use construction equipment anticipated to generate maximum noise levels of up to 85 dB at a distance of 50 feet. As previously noted, stationary noise sources lessen at a rate of approximately six dB per doubling of distance from the source. Therefore, at a distance of 160 feet, construction equipment associated with Trail Connection Option 1 would generate maximum noise levels of up to 75 dB Lmax; at a distance of 150 feet, construction equipment associated with Trail Connection Option 2 would generate maximum noise levels of up to 76 dB Lmax; and at a distance of 200 feet, construction equipment associated with Trail Connection Option 3 would generate maximum noise levels of up to 73 dB Lmax. Thus, construction activities associated with development of the off-site trail connection options would exceed the thresholds of significance being applied of 70 dB Lmax during daytime hours and 60 dB Lmax during nighttime hours.
Based on the above, construction‐related noise associated with SMP 39 and SMP 40 would not result in the generation of a substantial temporary increase in ambient noise levels in the vicinity of the project in excess of standards established in the local 694 343
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general plan or noise ordinance, or applicable standards of other agencies. However, while construction activities are temporary in nature and would be exempt during the hours of 7:00 AM to 8:00 PM, construction‐related noise associated with SMP 40 and the off-site trail connection could result in disturbance to existing noise‐sensitive land uses in the project vicinity.
Therefore, construction‐related noise associated with the proposed project could be considered to result in generation of a substantial temporary increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies, and impacts would be considered significant.
Mitigation Measure(s)
Implementation of the following mitigation measures would reduce the above potential impact to a less-than-significant level.
4.6-1(a) Prior to issuance of a grading permit for SMP 40, the project applicant shall prepare a construction noise management plan that identifies measures to be taken to minimize construction noise on surrounding sensitive land uses and include specific noise management measures to be included within the plans and specifications for SMP 40, subject to review and approval by the City of Livermore Community Development Department. The project applicant shall demonstrate, to the satisfaction of the City that the project complies with the following:
• Consistent with the Livermore Municipal Code, construction shall be limited to weekdays between the hours of 7:00 AM and 8:00 PM and Saturdays through Sunday between the
hours of 9:00 AM and 6:00 PM.
• Either a temporary noise barrier shall be built prior to development of the planned berm on the east side of the project site, or the berm shall be built prior to construction activities. The barrier/berm shall be a minimum of 10 feet tall.
The barrier can be field-built provided it meets the following criteria:
o The barrier shall be constructed to have a minimum
surface density of four pounds per square foot (psf). For example, a stud wall with exterior-grade plywood
sheathing and a stucco finish (or two layers of 5/8-inch thick plywood).
o The barrier shall be free of cracks, and drainage
holes/slots along the bottom of the barrier shall be kept to a minimum. Where needed, drainage holes/slots
shall be covered by one psf mass-loaded vinyl flaps
(e.g., Kinetics KNM-100) so water can flow around the
vinyl and still drain.
o Joints between sheathing layers shall be offset by 16 inches minimum.
• Contractors shall use “quiet” models of air compressors and other stationary noise sources, where technology exists. • Internal combustion engine-driven equipment shall be
equipped with mufflers which are in good condition and
appropriate for the equipment.
• Stationary noise-generating equipment, such as air
compressors and portable power generators, shall be located as far away as possible from adjacent property lines.
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• Staging areas and construction material areas shall be located as far away as feasible from adjacent residences. • All unnecessary idling of internal combustion engines should be prohibited.
• The contractor shall designate a "noise disturbance
construction superintendent" who will be responsible for tracking and responding to any complaints about construction noise. The noise disturbance construction superintendent shall determine the cause of the noise complaint (e.g., starting too early, bad muffler, etc.) and shall require that reasonable measures are implemented to correct the problem. The
telephone number for the noise disturbance construction superintendent shall be posted at the construction site and included in any construction notices sent to neighbors.
4.6-1(b) Prior to issuance of a grading permit for the chosen off-site trail connection option, the project applicant shall prepare a construction noise management plan that identifies measures to be taken to minimize construction noise on surrounding sensitive land uses and include specific noise management measures to be included within the plans and specifications for the trail connection option, subject to review and approval by the City of Livermore Community
Development Department. The project applicant shall demonstrate, to the satisfaction of the City that the project complies with the following:
• All heavy construction equipment used on the proposed project shall be maintained in good operating condition, with all internal combustion, engine‐driven equipment fitted with intake and exhaust mufflers that are in good condition.
• All mobile or fixed noise producing equipment used on the proposed project that is regulated for noise output by a local, state, or federal agency shall comply with such regulations while in the source of involved with a project activity.
• Where feasible, electrically‐powered equipment shall be used instead of pneumatic or internal combustion powered
equipment.
• All stationary noise‐generating equipment shall be located as far away as possible from the nearest residential uses.
• Signs prohibiting unnecessary idling of internal combustion engines shall be posted at entrances to construction sites and at construction equipment staging areas.
• The use of noise‐producing signals, including horns, whistles, alarms and bells shall be for safety warning purposes only. • The use of temporary sound barriers shall be incorporated along the outer work area of the construction site, east of Isabel Avenue/SR 84. Barrier height and location(s) shall be
determined by a qualified acoustical engineer to ensure that the resultant construction noise levels at the nearest residence would meet the applicable standard. The sound barrier fencing shall consist of 0.5-inch plywood or minimum STC 27 sound curtains placed to shield nearby sensitive receptors. The plywood barrier shall be free from gaps, openings, or
penetrations to ensure maximum performance.
Due to the addition of Table 4.6-7, all subsequent tables included in Chapter 4.6, Noise, of the Draft EIR are hereby renumbered accordingly.
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While a new mitigation measure (Mitigation Measure 4.6-1[a]) has been added as part of the text revisions above, under Laurel Heights Improvement Ass’n v Regents of Univ. of Cal. (1993) 6 C4th 1112 (Laurel Heights II) and Section 15088.5 of the State CEQA Guidelines,2 a lead agency is only required to recirculate a draft EIR when “significant new information” is added to the document after public notice is given of the availability of the Draft EIR for public review under Section 15087 but before certification. Pursuant to CEQA Guidelines Section 15088.5, the term “information” can include changes in the project or environmental setting, as well as additional data or other information. New information added to an EIR is not considered “significant” unless the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the City has decided not to implement. “Significant new information” requiring recirculation includes any of the following:
1. A new significant environmental impact would result from the project or for a new mitigation measure proposed to be implemented.
2. A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance.
3. A feasible project alternative or mitigation measure considerably different from other previously analyzed would clearly lessen the environmental impacts of the project, but the project’s proponents decline to adopt it.
4. The Draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded.
In the case of the proposed project, the Draft EIR already determined that the proposed project would result in a significant temporary construction noise impact (see page 4.6-23 of the Draft EIR). Thus, a new noise impact has not been identified in response to public comments. Rather, in response to public comments, a new construction noise mitigation measure (Mitigation Measure 4.6-1[a]) has been added that would clearly lessen the potential environmental impact to a less-than-significant level, and the applicant has agreed to adopt Mitigation Measure 4.6- 1(a). In addition, the requirements of Mitigation Measure 4.6-1(a) are similar to the requirements already included in Mitigation Measure 4.6-1 of the Draft EIR. Thus, according to Section 15188.5(a)(3), recirculation is not required.
The Mitigation Monitoring and Reporting Program, as well as the Findings, Facts in Support Of Findings, and Statement Of Overriding Considerations, will be updated in accordance with the changes shown above and included in the staff report packet for the City Council hearing on the proposed project.
Attachments
Attachment 1 – Attorneys for Carpenters Local 713 Comment Letter Attachment 2 – SMP 39 Revised Environmental Noise Study Attachment 3 – SMP 40 Revised Environmental Noise Study 2 Stephen L. Kostka and Michael H. Zischke. Practice Under the California Environmental Quality Act, Second Edition, March 2022 Update, Volume 2. March 2022, pg. 16-21. 697 346
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Presented by Ashley Vera
March 5, 2024
Surface Mining Permit (SMP) 39/40 Project
Planning Commission
347
ATTACHMENT 3
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Project Location
348
ATTACHMENT 3
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Entitlement/Action Summary
• General Plan Amendment
• Annexation/Prezoning
• Zoning Map Amendment/Planned Development District/Development Code Amendment
• Vesting Tentative Subdivision Map (2)
• Development Agreement (2)
• Site Plan Design Review (1)
• EIR Certification
• LAFCo application submittal
349
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SMP 39 Conceptual Site Plan
350
ATTACHMENT 3
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Revised Engineering Consideration
The widening of West Jack London Boulevard shall
include the installation of streetlights. The final layout of the streetlights will be determined by the City
Engineer during the development of improvement
plans for the street widening.
351
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SMP 40 Site Plan
352
ATTACHMENT 3
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SMP 40 Elevations – Western Building
353
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SMP 40 Elevations – Eastern Building
354
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Planned Development Zoning
Light industrial uses including:
• Research and development facilities
• Professional and administrative offices
• Experimental and testing laboratories
• Manufacturing uses
• Warehouse and distribution – permitted on SMP 40,
conditionally permitted on SMP 39 and limited to 20% of buildable area
355
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Trail Improvements
Off-site trail
improvements
356
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Development Agreement
• Developer financial contribution toward marketing SMP 39 towards desired uses in PD-I 22-001
• Developer financial contribution and construction of off-site trail improvements
• Forfeiture of mining rights
357
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EIR Topics Analyzed
• Agricultural Resources
• Air Quality, Greenhouse Gas Emissions, and Energy
• Biological Resources
• Cultural and Tribal Cultural Resources
• Hydrology and Water Quality
• Noise
• Public Services, Utilities, and Service Systems
• Transportation
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EIR Impact Summary
Less than Significant with Mitigation:
• Air Quality, Greenhouse Gases and Energy
• Biological Resources
• Cultural and Tribal Cultural Resources
• Hydrology and Water Quality
• Public Services, Utilities and Service Systems
• Noise
• Transportation
Significant and Unavoidable:
• Agricultural Resources
359
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Statement of Overriding Considerations
• Revitalizes underutilized lands appropriate for infill development and which are compatible with surrounding
development
• Promotes industrial development consistent with the General Plan
• Provides opportunity for local jobs with competitive salaries • Creates logical boundaries which align with the City’s UGB • Includes improvements to West Jack London Boulevard and on and off-site trail improvements
• Generates long-term sustainable property and potential sales tax revenue
360
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Next Steps
• City Council – March 25
• LAFCo – Spring 2024
361
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Staff Recommendation
Staff recommends the Planning Commission recommend City Council:
1. Adopt a resolution certifying the Final Environmental Impact Report (including the Supplemental Response to Comments and Errata) pursuant to the California Environmental Quality Act (CEQA); and
2. Adopt a resolution approving Annexation/Prezoning (APZ) 21-003, PreAnnexation and Development Agreement (DA) 21-001, Pre-Annexation and Development Agreement (DA) 23-002, General Plan Amendment (GPA) 21-001, Zoning Map Amendment (ZMA) 21-002, Development Code Amendment (DCA) 21-005, Planned Development Industrial (PD-I) 22-001, Vesting Tentative Parcel Map (SUB) 21-008, Vesting Tentative Tract Map (SUB) 21-009, and Site Plan Design Review (SPDR) 21-008, subject to conditions of approval as modified by staff.
362
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OMP OAKS BUSINESS PARK 363
ATTACHMENT 3
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OMP OAKS BUSINESS PARK
SITE HISTORY
• SMP-39 AND SMP-40 owned by Pleasanton
Gravel Company in excess of 50 years
• Vacant grassland with Surface Mining Permits
• PCG Acquired these properties with the
intention of mining these properties
• PGC-OMP Introduction and agreement since
2019
• OMP working on this project with City of
Livermore over 3 years
364
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OMP OAKS BUSINESS PARK
AERIAL OVERVIEW
365
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OMP OAKS BUSINESS PARK
PROJECT DESCRIPTION- SMP 39
• Six proposed building/ 755,000 SF
• Designed to meet user flexibility- for sale or
lease; smaller buildings for local
entrepreneurs
• Site planning submittal in 4Q 2024
• Planning Commission 2Q 2025
• Dedicating land and cost of improvements for
widening of Jack London Blvd and bike trail
366
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OMP OAKS BUSINESS PARK
PROPOSED ELEVATIONS SMP 39
367
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OMP OAKS BUSINESS PARK
PROPOSED ELEVATIONS SMP 39
368
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OMP OAKS BUSINESS PARK
PROJECT DESCRIPTION- SMP 40
• Two buildings- 477,000 and 280,000 sf
• Building 1 Pre-leased to LAM ResearchExpanding in Livermore • Building 2 Design: Sensitive to Neighbors to
the east
• North/South loading
• Screened loading areas
• 884-1,000’ from neighbors to the East
• Limited night time traffic
• Commence grading 6/15/24
369
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OMP OAKS BUSINESS PARK
SITE PLAN SMP 40
370
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OMP OAKS BUSINESS PARK
371
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OMP OAKS BUSINESS PARK
PROJECT BENEFITS
• Hundreds of new high quality jobs and tens of millions of dollars in annual salaries and wages
• Annex property into the City of Livermore. Long term tax revenue • Combination of warehouse/Dist. and Advance Mfg. jobs
• Hundreds of new construction jobs- Sheet Metals Workers Local 104, IBEW, Sprinkler Fitters, Ironworkers, UA P&S
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OMP OAKS BUSINESS PARK
PROJECT BENEFITS
• Additional Revenue for the City of Livermore, MUSD, and other agencies • Improved Jobs – Housing Balance- reduce commute times • Expansion Opportunities for a new or existing companies in Livermore- Building 1 • Support for Livermore retail and restaurants
• Arroyo Mucho Trail Connection- get bikes off Isabel/Jack London 373
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ECONOMIC BENEFITS SMP 40 ONLY
(Source Kosmont & Assoc)
$180,000/yr. of $3.6 million over
20 years in direct revenues to
support resident services.
$79,000/yr. for LARPD
One time $ 792,000 in LVJUSD
Fees + $280,000/yr.
Over $14 million in one-time
development fees
Development Impact and City Fees
Funding Local Schools
Police and Fire Services
Parks and Recreation
$100,000 contribution for
Marketing and City branding Funding to Livermore IEDD to promote City of Livermore
OMP OAKS BUSINESS PARK
374
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PROJECT BENEFITS
OMP OAKS BUSINESS PARK 375
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OMP OAKS BUSINESS PARK
TRAIL OVERVIEW
376
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OMP OAKS BUSINESS PARK
BUILDING DISTANCES
377
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MARCH 5, 2024 Draft Minutes PLANNING COMMISSION
PLANNING COMMISSION
MARCH 5, 2024
________________________________________________________________
REGULAR MEETING
1. CALL TO ORDER – The meeting of the Planning Commission was called to order by Chairperson Jacob Anderson at 7:00 pm, held in person at 1016 S.
Livermore Avenue.
ROLL CALL – Present: Chairperson Jacob Anderson, Vice-Chairperson Yolanda Fintschenko, Commissioner Steven Dunbar, Commissioner Daniel Leary, Commissioner Tracy Kronzak.
PLEDGE OF ALLEGIANCE
3. OPEN FORUM
Chairperson Anderson opened the public comment period.
Weng Tam, provided a comment.
There were no more speakers, and the public comment period was closed.
4. CONSENT CALENDAR - NONE
5. PUBLIC HEARINGS
5.1 Hearing to consider a request for an Annexation/Prezoning, PreAnnexation and Development Agreements, General Plan Amendment, Zoning Map Amendment, Development Code Amendment, Vesting Tentative Parcel Map, Vesting Tentative Tract Map, Planned Development, and Site Plan Design Review for the SMP 39 and 40 Project to zone for and develop light industrial uses near the northwest part of the City.
Recommendation:
Staff recommends the Planning Commission recommend the City Council take the following actions to authorize the future development of light industrial buildings on the SMP 39 and SMP 40 properties:
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PLANNING COMMISSION Draft Minutes MARCH 5, 2024
1. Adopt a resolution certifying the Final Environmental Impact Report pursuant to the California Environmental Quality Act (CEQA); and
2. Adopt a resolution approving Annexation/Prezoning (APZ) 21-003, PreAnnexation and Development Agreement (DA) 21-001, Pre-Annexation and Development Agreement (DA) 23-002, General Plan Amendment (GPA) 21-001, Zoning Map Amendment (ZMA) 21-002, Development Code Amendment (DCA) 21-005, Planned Development-Industrial (PDI) 22-001, Vesting Tentative Parcel Map (SUB) 21-008, Vesting Tentative
Senior Planner Ashley Vera presented the staff report.
The Developer, Timur Tecimer, Managing Partner, CEO, Overton Moore Properties, presented an overview of the project
Chairperson Anderson opened the public comment period.
Jason Camara, provided a comment in support of the project.
Jean King, provided a comment in support of the project.
Brian Werner, provided a comment in support of the project.
Joel Toscano, provided a comment in opposition of the project.
Ruhama Tereda, provided a comment in opposition of the project.
There were no more speakers, and the public comment period was closed.
In response to Commissioner Leary, Senior Planner Vera explained that the noise levels were consistent with those allowed in the General Plan, except for construction noise which required mitigation. She clarified that the Planning Commission could require reporting for more than three years under Mitigation Measure 4.8-3. Ms. Vera explained that the City of Pleasanton was taking a resolution to its Council on March 19, 2024, to support SMP 39 going to Livermore and that Surface Mining Permit (SMP) 38 was no longer part of the project.
Commissioner Leary discussed the letter from the Regional Water Quality Control Board regarding storm water quality or hydromodification controls. Senior Civil Engineer Debbie Salgado clarified that the issues had been clarified with the Water Board. Civil Engineer Adam Mahony explained removal of the 100-year overflow and that flows could drain towards the Oaks Business Park retention basin and would be overland release.
In response Commissioner Kronzak, Senior Planner Vera explained that CEQA evaluated the likelihood of habitat occurrence on a site and the impact of development. She stated the 884-foot noise measurement was from the northeast side of the building. She discussed the necessary coordination and permits from Caltrans, PGE and Zone 7 required for the overpass crossing; timelines in the ATTACHMENT 4
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MARCH 5, 2024 Draft Minutes PLANNING COMMISSION
Development Agreement for construction of the trail; and timeline for Alameda County Local Agency Formation Commission (LAFCO) required consent letters for annexation in advance of the construction.
In response to Commissioner Dunbar, Senior Planner Vera confirmed that it was not the responsibility of an EIR to mitigate Vehicle Miles Travelled (VMT) beyond that required to mitigate significant impact; nor the responsibility of the developer to mitigate VMT beyond the City’s determination of their fair share of mitigation set by the development impact fees. She stated onsite trail improvements would be part of the Citywide Community Facilities District and the Citywide Benefit Fund was not fully developed.
In response to Commissioner Dunbar, Timur Tecimer, Managing Partner, CEO, Overton Moore Properties, Developer, explained that both buildings would have secured yards and there would be bike racks around the building.
Commissioner Dunbar concurred with the idea of a longer review period for the Transportation Demand Management Program (TDM), which includes an employee carpool program,
In response to Vice-Chairperson Fintschenko, Senior Planner Vera explained the difference between a tentative tract map and tentative parcel map. She discussed costs associated with reporting on the carpooling program. Mr. Tecimer stated the cost would be borne by the tenant and that they were not opposed to extending the TDM reporting requirement but would request reporting be ended if the third year showed mitigation was performed. Senior Planner Vera explained that CEQA covered transportation related impacts to both construction and operation of the project. She stated she did not know why the Golden State Environmental Justice Organization in Southern California was interested in development in Northern California. She explained coordination between all agencies to ensure mitigation measures were met; and confirmed that no agricultural uses were proposed and no agriculture uses were occurring on the project site. She stated it was unlikely that the number of agricultural jobs would be greater than jobs created for industrial development. Ms. Vera clarified that fast food, banks and personal uses would be considered conditional uses and other uses providing goods for the convenience and support of the surrounding occupants would also require a CUP and be brought to the Planning Commission for review and approval.
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PLANNING COMMISSION Draft Minutes MARCH 5, 2024
Chairperson Anderson expressed appreciation for site lines in the development plan and appreciation to the applicant for making changes to reduce noise impacts. He suggested a better shading tree for the employee amenities area.
Commissioner Leary indicated he could make the required findings. Mr. Tecimer confirmed that Kosmont and Associates had conducted an economic analysis for both SMP 39 and 40 and determined the benefits to the City.
In response to Commissioner Kronzak, Acting Planning Manager Steve Riley stated, in the past, there had been noise complaints from loading at Tesla building north of the project site but there were very few complaints over the last few years.
Commissioner Kronzak discussed the need to ensure the EIR met the full requirements of the State of California. In response to Commissioner Kronzak, Senior Planner Vera confirmed that zoning to Open Space Floodplain was appropriate for the Annexation-Only parcels just east of SMP 40.
Commissioner Dunbar confirmed that, with mitigations, the project complied with Level of Service (LOS) standards and that Airway Boulevard intersection was exempt. Senior Planner Vera stated staff was open to looking into fencing and access in coordination with Zone 7. She discussed the trail to the parking lot.
Commissioner Dunbar suggested it be concrete with ramp to parking lot. Mr.
Tecimer indicated they would look into it. Commissioner Dunbar confirmed that the design of Jack London Boulevard was prescribed by the General Plan and suggested consideration of the long-term asset management plan for the street.
He discussed the jobs - housing balance and match and stated the findings could be made. He expressed concern about the grade on the proposed trail options and suggested Option 3. He urged careful attention to the trail crossing on Jack London for safety and indicated he could make all the required findings.
Vice-Chairperson Fintschenko indicated and provided reasons for being able to make the required findings and indicated support for Trail Option 3.
The Commission discussed the suggestion to increase VMT reporting beyond three years and determined to defer to staff to amend the three-year reporting requirement between 3-8 years.
In response to Commissioner Leary, Mr. Tecimer explained that the proposed buildings were not ideal for e-commerce facilities.
ATTACHMENT 4
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MARCH 5, 2024 Draft Minutes PLANNING COMMISSION
ON THE MOTION OF COMMISSIONER LEARY, SECONDED BY VICE-CHAIR FINTSCHENKO AND CARRIED ON A 5-0 VOTE, THE PLANNING COMMISSION ADOPTED THE FOLLOWING RESOLUTIONS:
Resolution 02-24 certifying the Final Environmental Impact Report Resolution 03-24 approving Annexation/Prezoning (APZ) 21-003, Pre-Annexation and Development Agreement (DA) 21-001, Pre-Annexation and Development Agreement (DA) 23-002, General Plan Amendment (GPA) 21-001, Zoning Map Amendment (ZMA) 21-002, Development Code Amendment (DCA) 21-005, Planned Development-Industrial (PD-I) 22-001, Vesting Tentative Parcel Map (SUB) 21-008, Vesting Tentative Tract Map (SUB) 21-009, and Site Plan Design Review (SPDR) 21-008, with the condition that paved ramps be provided from each building connecting to their respective parking lots at the access gates to the on-site trail.
6. MATTERS FOR CONSIDERATION - NONE
7. MATTERS INITIATED BY PLANNING COMMISSION AND STAFF
Commissioner Kronzak reemphasized the City’s success with its Climate Action Plan and Urban Forestry goals and encouraged planting and replanting native species.
Commissioner Dunbar suggested discussion of a policy on preferred VMT mitigation.
8. ADJOURNMENT – at 9:03pm to a Regular Planning Commission Meeting on Tuesday, March 19, 2024, at 7:00 pm, Civic Center Meeting Hall, City Council Chambers, 1016 S. Livermore Avenue.
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9 Figure 3-2
Approximate Project Site Boundaries Map
Oaks
Business
Park Single-Family
Residences Gravel Quarries/ Industrial Ponds
Legend:
SMP 39 and SMP 40 (Annexation and Development Area) Additional Annexation Only Parcels Existing City of Livermore Limits Existing City of Livermore SOI Existing City of Livermore South Livermore UGB Existing City of Pleasanton SOI Las Positas Golf
Course
Livermore
Municipal
Airport
San Francisco
Premium Outlets
Undeveloped
Land
Gravel Quarries/
Industrial Ponds
ATTACHMENT
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10 Figure 3-3
Proposed SOI Amendment Area
Legend:
Proposed SOI Amendment Area Existing City of Livermore SOI Existing City of Pleasanton SOI Proposed Modifications to the City of Livermore SOI Proposed Modifications to the City of Pleasanton SOI Additional Annexation Only Parcels P
ATTACHMENT
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11 Figure 3-4
Proposed Annexation Area
Legend:
Proposed Annexation Area Existing City of Livermore Limits Proposed Modifications to the City of Livermore Limits P
ATTACHMENT
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TM-1
OF OF 4 SHEETSSHEET
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OVERTON MOORE PROPERTIES
DATE OCT, 2022SCALEDRAWN BYJOB NO. 96562-59
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CF
CALIFORNIA
SURVEYOR JAM
AS SHOWN
NO. NO. REVISION BY REVISION BY
LEGEND
DEVELOPER
OVERTON MOORE PROPERTIESATTN: TIMUR TECIMER19700 S VERMONT AVE., SUITE 101TORRANCE, CA 90502310-354-2460
CIVIL ENGINEER
KIER & WRIGHT CIVIL ENGINEERS & SURVEYORS, INC.
ATTN: ADAM MAHONEY, P.E.
2850 COLLIER CANYON ROAD
LIVERMORE, CA 94551
925-245-8788
GEOTECHNICAL ENGINEER
CORNERSTONE EARTH GROUP INCDAHN T. TRAN P.E.1259 OAKMEAD PARKWAYSUNNYVALE, CA 94085408-245-4600 x 108
STORM AND SANITARY NETWORK CITY OF LIVERMORE
TELEPHONE NETWORK PACIFIC BELL
GAS AND ELECTRICITY PACIFIC GAS & ELECTRIC
WATER CITY OF LIVERMORE
FIRE HYDRANTS TO BE LOCATED TO THE SATISFACTION
OF THE FIRE MARSHALL AND CITY
ENGINEER
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# SHEET NO. SHEET
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2 TM-2 VESTING TENTATIVE MAP
3 TM-3 VESTING TENTATIVE MAP
4 TM-4 VESTING TENTATIVE MAP - STRIPING PLAN
VESTING TENTATIVE MAP - COVER SHEET
WEST JACK LONDON BOULEVARD
1 A.P.N.
EXISTING LAND USEPROPOSED LAND USE
GENERAL PLAN DESIGNATION
EXISTING ZONING
TRACT AREA
LOTS
SMALLEST LOT
LARGEST LOTPUBLIC DEDICATION
GROSS AREA 51.88-ACRES±
2.33-ACRES±11.76-ACRES±(LOT01)5.75-ACRES±(LOT-06)649.55-ACRES±COUNTY-AGRICULTURALPD-(PLANNED-DEVELOPMENT)COUNTY-AGRICULTURAL1-2-(MEDIUM-DENSITY-INDUSTRIAL)904-0003-001-04
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DATE OCT, 2022SCALEDRAWN BYJOB NO. 96562-59
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SURVEYOR JAM
AS SHOWN
NO. NO. REVISION BY REVISION BY
TM-2
MATCHLINE SEE SHEET TM-3
SCALE:
PUBLIC EASEMENT (SECTION C-C)
1" = 20' C
SCALE:
JACK LONDON BLVD.
1" = 20' A SCALE: MULTI-USE TRAIL 1" = 20' B
2 ATTACHMENT
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WEST JACK LONDON BLVD.
VESTING TENTATIVE MAP
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DATE OCT, 2022SCALEDRAWN BYJOB NO. 96562-59
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WEST JACK LONDON BOULEVARD
WEST JACK LONDON BOULEVARD
WEST JACK LONDON BOULEVARD
TM-4
VESTING TENTATIVE MAP - STRIPING PLAN
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DATE OCT, 2022SCALEDRAWN BYJOB NO. 96562-59
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MATCHLINE SEE BELOW
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North Elevation
OBLIQUE VIEW L
South Elevation
JOB# 19177
LIVERMORE OAKS BUSINESS PARK - BLDG. 1 LIVERMORE, CA OMP Conceptual Colored Elevations OVERTON MOORE PROPERTIES
JUNE 13, 2022
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Figure 3-12
Proposed Trail Connection Options
Trail Connection
Option 3
Trail Connection
Option 2
Trail Connection
Option 1
Legend:
Arroyo Bike Trail
Proposed On-Site Trail
ATTACHMENT 10
1310
The SMP 39/SMP 40 environmental documents are available on the City’s website:
htps://www.livermoreca.gov/departments/communitydevelopment/planning/environmental-documents ATTACHMENT 11
1311
RESOLUTION NO. ________
IN THE CITY COUNCIL OF THE CITY OF LIVERMORE, CALIFORNIA
A RESOLUTION CERTIFYING THE FINAL ENVIRONMENTAL IMPACT
REPORT FOR THE SMP 39/SMP 40 PROJECT AND ADOPTING
CALIFORNIA ENVIRONMENTAL QUALITY ACT FINDINGS, A STATEMENT
OF OVERRIDING CONSIDERATIONS, AND A MITIGATION MONITORING
AND REPORTING PROGRAM
The City of Livermore (“City”) is considering an Annexation/Prezoning (APZ) 21- 003, Pre-Annexation and Development Agreement (DA) 21-001, Pre-Annexation and Development Agreement (DA) 23-002, General Plan Amendment (GPA) 21-001, Zoning Map Amendment (ZMA) 21-002, Planned Development Industrial (PD-I) 22-001, Development Code Amendment (DCA) 21-005, Vesting Tentative Parcel Map (SUB) 21- 008, Vesting Tentative Tract Map (SUB) 21-009, and Site Plan Design Review (SPDR) 21-008 for the SMP 39/SMP 40 Project (“Project”) to develop approximately 1.51 million square feet of industrial development and associated parking, lighting, landscaping, and other improvements.
The City determined that the Project is subject to the California Environmental Quality Act (“CEQA”) and that an Environmental Impact Report (“EIR”) is required.
On January 6, 2023, the City issued a Notice of Preparation pursuant to CEQA to obtain comments on the proposed scope of the EIR for the Project.
On August 30, 2023, the Draft EIR was distributed to the Planning Commission, the City Council, responsible agencies, trustee agencies and federal agencies involved in funding or approval of a project, State Clearinghouse, state, regional and local agencies and special districts, and interested groups and individuals for a 45-day public comment period.
On October 3, 2023, the Planning Commission held a duly noticed public hearing to consider the adequacy of the Draft EIR at which time oral and written comments were presented to the Planning Commission. Members of the public and other interested parties were invited by formal public notice to testify on the adequacy of the Draft EIR at the public hearing.
On October 13, 2023, at 5:00 p.m. the public comment period on the Draft EIR was closed. The City received six written comment letters.
On January 16, 2024, the Final EIR was distributed consisting of copies of all written and oral comments, a list of commenters, and all responses to oral and written comments and minor corrections to the Draft EIR. A copy of the written responses to comments received after the release of the Final EIR are attached hereto as Exhibit E. 1312
RESOLUTION NO. ________
On March 5, 2024, the Planning Commission held a public hearing to consider its recommendation to the City Council, and upon review and consideration of the information in the Final EIR and administrative record, adopted Resolution No. 02-24, attached hereto as Exhibit A, recommending that the City Council certify the Final EIR.
On March 25, 2024, the City Council held a duly noticed public hearing to consider the Project, Planning Commission and staff recommendations, all public comments and testimony, and findings.
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Livermore that prior to taking action on the Project, and at a properly noticed public hearing, the City Council reviewed written and oral staff reports, conducted a public hearing on the Project and took testimony, and received into the record all pertinent documents related to the Project (collectively, the “Record Evidence”). The City Council’s determination is based on the Record Evidence, which is incorporated into this Resolution by reference.
BE IT FURTHER RESOLVED that the City Council of the City of Livermore, has considered the findings made in Planning Commission Resolution No. 02-24, attached hereto as Exhibit A, and hereby adopts the same findings by this reference and incorporates them as their own findings as part of this resolution. Based upon the City Council’s own independent review of the Record Evidence and considerations, the City Council hereby finds that the Final EIR has been completed in compliance with the intent and requirements of the California Environmental Quality Act (“CEQA”), CEQA Guidelines, and the City’s local CEQA requirements and has considered the information contained in the Final EIR and the record prior to taking any action on the Project, other related Project actions, or any of the alternatives. The City Council hereby certifies the Final EIR, attached hereto as Exhibit B, as amended by the Responses to Comments Received After the Close of the Final Environmental Impact Report Public Review Period and Erratum, attached hereto as Exhibit E, and approves and adopts the Findings, Facts in Support of Findings and Statement of Overriding Considerations Regarding the Environmental Impact Report, attached hereto as Exhibit C.
BE IT FURTHER RESOLVED that the City Council of the City of Livermore hereby adopts the Mitigation Monitoring and Reporting Program, attached hereto as Exhibit D, which is incorporated into the conditions of approval for the project.
BE IT FURTHER RESOLVED that the City Council of the City of Livermore directs the Planning Manager to file a Notice of Determination with the Alameda County Clerk, if the project is approved.
The documents that constitute the record of proceedings upon which this decision is based can be found in the City Clerk’s Office, 1052 S. Livermore Avenue, in Livermore, California. This resolution shall be effective upon adoption by the City Council. 1313
RESOLUTION NO. ________
On motion of Council Member _______________________, seconded by Council Member _______________________, the foregoing resolution was passed and adopted on March 25, 2024, by the following vote:
AYES: COUNCIL MEMBERS:
NOES: COUNCIL MEMBERS:
ABSENT: COUNCIL MEMBERS:
ABSTAIN: COUNCIL MEMBERS:
ATTEST: APPROVED AS TO FORM:
_____________________________ /s/ Kimberly D. Cilley
Deborah L. Elam Kimberly D. Cilley
Acting City Clerk Senior Assistant City Attorney
Exhibit A – Planning Commission Resolution No. 02-24
Exhibit B – Final EIR for the SMP 39/SMP 40 Project
Exhibit C – Findings, Facts in Support of Findings and Statement of Overriding Considerations
Exhibit D – Mitigation, Monitoring and Reporting Program Exhibit E – Responses to Comments Received After the Close of the Draft Environmental Impact Report Public Review Period and Erratum 1314
EXHIBIT A
1315
EXHIBIT A
1316
EXHIBIT A
1317
EXHIBIT B
The SMP 39/SMP 40 Final Environmental Impact Report is available on the City’s website:
htps://www.livermoreca.gov/departments/communitydevelopment/planning/environmental-documents 1318
EXHIBIT C
1 FINDINGS, FACTS IN SUPPORT OF FINDINGS AND STATEMENT OF OVERRIDING
CONSIDERATIONS REGARDING THE ENVIRONMENTAL IMPACT REPORT FOR THE
SMP 39/SMP 40 PROJECT
(SCH NO. 2023010091)
The following Findings, the mitigation measures specified herein, and the Mitigation Monitoring and Reporting Program attached hereto are hereby adopted by the Livermore City Council in accordance with California Environmental Quality Act (“CEQA”), Public Resources Code Section 21081, 21081.5 and 21081.6, and the CEQA Guidelines, Title 14, California Code of Regulations, Sections 15091 through 15093 for the SMP 39/SMP 40 Project (“Project”).
A. ENVIRONMENTAL REVIEW PROCESS
On January 6, 2023, the City issued a Notice of Preparation pursuant to CEQA to obtain comments on the proposed scope of the Environmental Impact Report (EIR) for the Project. The City released the Draft EIR on August 30, 2023, for a 45-day public comment period. The City made available the Draft EIR to the Planning Commission, the City Council, State Clearinghouse, state, regional and local agencies and special districts, and interested groups and individuals. On October 3, 2023, the Planning Commission conducted a public hearing on the Draft EIR. Members of the public and other interested parties were invited by formal public notice to provide comments on the scope and content of the Draft EIR at the public hearing. On October 13, 2023, at 5:00 PM, the public comment period on the Draft EIR closed. Nine written and oral comments were received during the public comment period.
The City released the Final EIR for public review on January 16, 2024. Subsequent to the Final EIR, a number of additional comment letters were received from the public regarding the Project. While CEQA does not require that written responses be provided for letters received after the close of the Draft EIR public review period, the comments were acknowledged by the City, and the City chose to prepare written responses to the comments and associated errata for the decisionmakers consideration in making an informed decision. The Final EIR consists of copies of all written or oral comments received on the Draft EIR, a list of commenters, all responses to written and oral comments, and proposed revisions to the Draft EIR. The Final EIR, Draft EIR, Mitigation Monitoring and Reporting Program (MMRP), and the written responses to comments and associated errata prepared subsequent to the Final EIR that were included with the Planning Commission and City Council staff reports together comprise the EIR for the Project. The analysis and conclusions contained in the EIR reflect the independent judgment of the City.
B. PROJECT DESCRIPTION
Chapter 3 of the Draft EIR includes a detailed description of the Project. The Project, as described in the Draft EIR, has been revised as described in the Final EIR. The revisions make only minor technical changes, clarifications or additions to the Draft EIR.
The approximately 105.34-acre project site consists of six separate parcels identified by Assessor’s Parcel Numbers (APNs) 904-3-1-4; 904-10-2-2, -3, -5, -7, and -8 located in 1319
EXHIBIT C
2 unincorporated Alameda County. The Project site is located adjacent to the existing Oaks Business Park, which consists of eight light industrial warehouse buildings, in the northwestern corner of the City of Livermore. The parcels are currently undeveloped, with the exception of a few structures located on the Additional Annexation Only Parcels. The Project site is generally located west of Isabel Avenue/State Route (SR) 84, north of Stanley Boulevard, south of West Jack London Boulevard, and east of El Charro Road. APN 904-3-1-4 is also known as SMP 39; and 904-10-2-2 is also known as SMP 40. The aforementioned SMP numbers are due to the Surface Mining Permit (SMP) numbers applicable to each site. The Surface Mining Permits for each of the sites were approved by Alameda County in 2004 to allow for the extraction of sand and gravel (i.e., aggregate) within the sites; however, aggregate mining has not occurred within any of the sites. Four additional parcels (APNs 904-10-2-3, -5, -7, and -8) located east of SMP 40 are included in the overall Project area.
SMP 39, SMP 40, and the Additional Annexation Only Parcels are within the City of Livermore South Livermore Urban Growth Boundary (UGB); however, SMP 39 is also within the City of Pleasanton’s Sphere of Influence (SOI). Accordingly, an SOI Amendment for SMP 39 is proposed in order to modify City of Pleasanton SOI, align the SOI and South Livermore UGB boundaries to be consistent with one another, and provide a contiguous division of land between the cities of Livermore and Pleasanton. It should be noted that the likelihood for any future development on the Additional Annexation Only Parcels is low due to physical constraints to development present on the parcels and their small size. Thus, the analysis of the Draft EIR assumed that any development on the Additional Annexation Only Parcels would be limited to cooperating with the Project applicant regarding development of the proposed trail and trail connection.
On the SMP 39 site, the Project would include development of a total of up to six light industrial buildings, consisting of up to approximately 755,500 square feet (sf) total of new building space, and associated internal roadways, parking, landscaping, utilities, and other improvements. On the SMP 40 site, the Project would include development of two industrial buildings containing up to approximately 759,275 sf of new building space with related internal roadways, parking, landscaping, utilities, and other improvements. The Project would include frontage improvements along SMP 39 and right-of-way dedication for the ultimate buildout of West Jack London Boulevard, which would include an at-grade, paved shared-use path along the Project frontage, consistent with the City’s Active Transportation Plan (ATP). Similarly, a paved at-grade, on-site trail would be provided along the boundaries of the SMP 40 site, consistent with the City’s ATP.
The proposed on-site trails would provide connection between SMP 39 to the existing path along the western boundary of the Oaks Business Park, SMP 40, and eventually to the Arroyo Mocho Trail, as the Project would include a new off-site trail connection to the existing Arroyo Mocho Trail, located on the east side of Isabel Avenue/SR 84. Three alternatives for the proposed off-site trail crossing to the existing Arroyo Mocho Trail are being considered and evaluated in the Draft EIR, including an at-grade crossing at Discovery Drive, an undercrossing at the existing Isabel Bridge, and an overcrossing of Isabel Avenue/SR 84 just north of the existing railroad tracks and associated crossing (north of Stanley Boulevard).
A detailed description of the Project’s entitlements can be found in Chapter 3 of the Draft EIR. Overall, the Project includes approval of the following entitlements and agreements by the City of Livermore and Responsible Agencies, including Alameda County and the City of Pleasanton:
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3 SMP 39
• Resolution authorizing submittal of an annexation and SOI Amendment application to the Alameda LAFCo;
• Property tax exchange agreement between Alameda County and the City of Livermore;
• General Plan Amendment to modify the City’s land use designation for SMP 39 from Open Space/Sand and Gravel to Low Intensity Industrial (LII); • Pre-zone the site as Planned Development-Industrial (PDI-22-001); • Zoning Map Amendment;
• Vesting Tentative Subdivision Map;
• Development Agreement; and
• Pre-Annexation Agreement.
SMP 40
• Resolution authorizing submittal of an annexation application to the Alameda LAFCo;
• Property tax exchange agreement between Alameda County and the City of Livermore;
• General Plan Amendment to modify the City’s land use designation for SMP 40 from Open Space/Sand and Gravel to LII;
• Pre-zone the site as PDI-22-001;
• Zoning Map Amendment;
• Vesting Tentative Subdivision Map;
• Site Plan and Design Review;
• Development Agreement; and
• Pre-Annexation Agreement.
Additional Annexation Only Parcels (APNs 904-10-2-3, -5, -7, and -8) • Resolution authorizing submittal of an annexation application to the Alameda LAFCo;
• Property tax exchange agreement between Alameda County and the City of Livermore;
• General Plan Amendment to modify the City’s land use designation from Open Space/Sand and Gravel to Parks, Trailways and Recreation Areas (OSP); and • Pre-zone the sites to Open Space Flood Plain (OS-F).
A number of other agencies, such as Alameda LAFCo, would serve as Responsible and Trustee Agencies, pursuant to CEQA Guidelines Section 15381 and Section 15386, respectively.
The Draft EIR provided environmental information, which may be required to grant approvals or coordinate with other agencies, to the agencies as part of Project implementation. These agencies could include, but may not be limited to, the following:
• Alameda LAFCo;
• Alameda County Airport Land Use Commission (ALUC);
• Alameda County;
• City of Pleasanton;
• Pacific Gas and Electric Company (PG&E);
• Federal Aviation Administration (FAA);
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4 • Federal Emergency Management Agency (FEMA);
• Bay Area Air Quality Management District (BAAQMD);
• California State Water Resources Control Board (SWRCB); • San Francisco Regional Water Quality Control Board (RWQCB); • Zone 7 Water Agency;
• Caltrans;
• California Department of Fish and Wildlife (CDFW); and • U.S. Army Corps of Engineers (USACE).
C. SIGNIFICANT UNAVOIDABLE ADVERSE IMPACTS AND DISPOSITION OF
RELATED MITIGATION MEASURES
The Final EIR identifies the following significant and unavoidable adverse impacts associated with the approval of the Project and identifies related mitigation measures. It is hereby determined that these significant unavoidable adverse impacts are acceptable for the reasons specified in Section J below.
The impacts and related mitigation measures identified below are presented in summary form.
For a detailed description of impacts and mitigation measures, see the MMRP in the Final EIR.
1. Agricultural Resources Impact 4.1-2: Implementation of the Project would involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use.
Buildout of the Project has the potential to result in impacts to agricultural resources, specifically the conversion of farmland to non-agricultural uses. SMP 39 and SMP 40 have on-site soils that result in the land being considered prime agricultural land by Alameda LAFCo.
According to the Alameda LAFCo’s General Proposal Policies, the LAFCo shall discourage City annexations of prime agricultural land, as defined by Government Code Section 56064, if such areas are not needed for urbanization within five years. The City has identified a need for additional industrial uses within the City of Livermore, and vacant land that would be viable for development of industrial uses similar to the Project does not exist within current Livermore city limits. Further, given the existing surrounding land uses, the project site is generally a suitable location for the Project, and a reasonable assumption can be made that other properties within the City may not be as well suited for the Project as the project site. Therefore, urbanization of the project site within the next five years would be needed to allow for the development of additional light industrial uses within the City. It should be noted, however, that annexation is ultimately subject to approval by Alameda LAFCo.
Potential mitigation for impacts analyzed in the Draft EIR related to the conversion of prime agricultural land to non-agricultural uses included purchasing agricultural conservation easements outside the Project area. However, this mitigation would not create new agricultural land; rather, the mitigation would preserve existing agricultural land elsewhere. Feasible mitigation measures do not exist to reduce the above impact to a less-than-significant level. Therefore, the impact would remain significant and unavoidable.
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5 2. Agricultural Resources Impact 4.1-3: Implementation of the proposed Project would result in impacts related to the cumulative loss of agricultural land.
As discussed above, SMP 39 and SMP 40 have on-site soils that are considered prime agricultural land by Alameda LAFCo. Therefore, implementation of the Project would convert prime agricultural land to non-agricultural uses, which would conflict with Alameda LAFCo policies related to prime agricultural land. Accordingly, the Project would prevent further use of the site for agricultural uses, and the Project-specific impact would be considered significant and unavoidable. Feasible mitigation measures do not exist to reduce the impact to a less-thansignificant level. Therefore, the impact would remain significant and unavoidable.
D. SIGNIFICANT IMPACTS IDENTIFIED IN THE EIR THAT ARE REDUCED TO A LEVEL OF “LESS THAN SIGNIFICANT” BY THE MITIGATION MEASURES
INCORPORATED INTO THE PROJECT
The Final EIR identifies the following significant impacts associated with the Project that are reduced to a level of less than significant by mitigation measures identified in the Draft EIR. It is hereby determined that the following environmental impacts will be mitigated to a less-thansignificant level or avoided by incorporation of the mitigation measures into the Project (for a detailed description of impacts and mitigation measures, see the appropriate text in the EIR):
1. Air Quality Impact 4.2-1: Implementation of the proposed Project would not conflict with or obstruct implementation of the applicable air quality plan during Project construction, with incorporation of the following mitigation measures: MM 4.2-1(a) and MM 4.2-1(b).
2. Air Quality Impact 4.2-2: Implementation of the proposed Project would not conflict with or obstruct implementation of the applicable air quality plan during Project operation, with incorporation of MM 4.2-2.
3. Biological Resources Impact 4.3-2: Implementation of the proposed Project would not have a substantial adverse effect, either directly or through habitat modifications, on special-status wildlife species, with incorporation of the following mitigation measures:
MM 4.3-2(a), MM 4.3-2(b), MM 4.3-2(c), and MM 4.3-2(d).
4. Biological Resources Impact 4.3-3: Implementation of the proposed Project would not have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the CDFW or the U.S. Fish and Wildlife Service (USFWS), or State or Federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means, with incorporation of the following mitigation measures: MM 4.3-3(a), MM 4.3-3(b), MM 4.3-3(c), MM 4.3-3(d), and MM
4.3-3(e).
5. Cultural and Tribal Cultural Resources Impact 4.4-2: Implementation of the proposed Project would not cause a substantial adverse change in the significance of a unique archeological resource pursuant to CEQA Guidelines, Section 15064.5, with implementation of MM 4.4-2.
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6 6. Cultural and Tribal Cultural Resources Impact 4.4-3: Implementation of the proposed Project would not disturb any human remains, including those interred outside of dedicated cemeteries, with incorporation of MM 4.4-3.
7. Cultural and Tribal Cultural Resources Impact 4.4-4: Implementation of the proposed Project would not cause a substantial adverse change in the significance of a tribal cultural resource, defined in PRC Section 21074, with incorporation of MM 4.4-4.
8. Hydrology and Water Quality Impact 4.5-1: Implementation of the proposed Project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade water quality during construction, with incorporation of MM 4.5-1.
9. Hydrology and Water Quality Impact 4.5-2: Implementation of the proposed Project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade water quality during operations, with incorporation of the following mitigation measures: MM 4.5-2(a) and MM 4.5-2(b).
10. Hydrology and Water Quality Impact 4.5-4: Implementation of the proposed Project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would: substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site; create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or result in substantial erosion or siltation on- or off-site, with incorporation of MM 4.5-4.
11. Hydrology and Water Quality Impact 4.5-5: Implementation of the proposed Project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would impede or redirect flood flows, or in flood hazard, tsunami, or seiche zone, risk release of pollutants due to Project inundation, with incorporation of MM
4.5-5.
12. Noise Impact 4.6-1: Implementation of the proposed Project would not result in the generation of a substantial temporary increase in ambient noise levels in the vicinity of the Project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies, with incorporation of MM 4.6-1(a) and MM 4.6- 1(b).
13. Public Services, Utilities, and Service Systems Impact 4.7-8: Implementation of the proposed Project would not result in an increase in demand for utilities and service systems associated with the proposed Project, in combination with future buildout of the Livermore General Plan, with incorporation of the following mitigation measures: MM 4.7-8(a) and MM 4.7-8(b).
14. Transportation Impact 4.8-1: Implementation of the proposed Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system during construction activities, with incorporation of MM 4.8-1. 1324
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7 15. Transportation Impact 4.8-3: Implementation of the proposed Project would not conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b), with incorporation of MM 4.8-3.
E. LESS THAN SIGNIFICANT IMPACTS IDENTIFIED IN THE EIR
The Draft EIR identified the following less-than-significant impacts (for a detailed description of the less-than-significant impacts, see the appropriate text in the Draft EIR):
1. Agricultural Resources Impact 4.1-1: Implementation of the proposed Project would not conflict with existing zoning for agricultural use, or a Williamson Act contract.
2. Air Quality Impact 4.2-3: Implementation of the proposed Project would not expose sensitive receptors to substantial pollutant concentrations.
3. Air Quality Impact 4.2-4: Implementation of the proposed Project would not result in other emissions (such as those leading to odors) affecting a substantial number of people.
4. Air Quality Impact 4.2-5: Implementation of the proposed Project would not result in the inefficient or wasteful use of energy or conflict with a State or local plan for renewable energy or energy efficiency.
5. Air Quality Impact 4.2-6: Implementation of the proposed Project would not 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 (including releasing emissions which exceed quantitative thresholds for ozone precursors).
6. Air Quality Impact 4.2-7: Implementation of the proposed Project would not generate greenhouse gas (GHG) emissions, either directly or indirectly, that may have a significant impact on the environment, or conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs.
7. Air Quality Impact 4.2-8: Implementation of the proposed Project would not result in a cumulatively considerable inefficient or wasteful use of energy or conflict with a State or local plan for renewable energy or energy efficiency.
8. Biological Resources Impact 4.3-1: Implementation of the proposed Project would not have a substantial adverse effect, either directly or through habitat modifications, on specialstatus plant species.
9. Biological Resources Impact 4.3-4: Implementation of the proposed Project would not interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites.
10. Biological Resources Impact 4.3-5: Implementation of the proposed Project would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.
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8 11. Biological Resources Impact 4.3-6: Implementation of the proposed Project would not conflict with the provisions of an adopted Habitat Conservation Plan (HCP), Natural Community Conservation Plan (NCCP), or other approved local, regional, or State habitat conservation plan.
12. Biological Resources Impact 4.3-7: Implementation of the proposed Project would not cause cumulative loss of habitat for special-status species.
13. Cultural and Tribal Cultural Resources Impact 4.4-1: Implementation of the proposed Project would not cause a substantial adverse change in the significance of a historical resource pursuant to CEQA Guidelines, Section 15064.5.
14. Cultural and Tribal Cultural Resources Impact 4.4-5: Implementation of the proposed Project would not cause a cumulative loss of cultural and tribal cultural resources.
15. Hydrology and Water Quality Impact 4.5-3: Implementation of the proposed Project would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the Project may conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.
16. Hydrology and Water Quality Impact 4.5-6: Implementation of the proposed Project would not result in cumulative impacts related to the violation of water quality standards or waste discharge requirements, and impacts resulting from the alteration of existing drainage patterns.
17. Noise Impact 4.6-2: Implementation of the proposed Project would not result in the generation of a substantial permanent increase in ambient noise levels in the vicinity of the Project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies.
18. Noise Impact 4.6-3: Implementation of the proposed Project would not result in the exposure of persons to or generation of excessive groundborne vibration or groundborne noise levels.
19. Noise Impact 4.6-4: Implementation of the proposed Project would not, for a Project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, expose persons residing or working in the project area to excessive noise levels.
20. Noise Impact 4.6-5: Implementation of the proposed Project would not result in the generation of a substantial permanent increase in ambient noise levels associated with development of the proposed Project in combination with buildout of the City of Livermore General Plan.
21. Public Services, Utilities, and Service Systems Impact 4.7-1: Implementation of the proposed Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental services and/or facilities, the construction of which could cause significant environmental impacts, in order to maintain 1326
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9 acceptable service ratios, response times, or other performance objectives for fire protection services.
22. Public Services, Utilities, and Service Systems Impact 4.7-2: Implementation of the proposed Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental services and/or facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for police protection services.
23. Public Services, Utilities, and Service Systems Impact 4.7-3: Implementation of the proposed Project would not require or result in the relocation or construction of new or expanded water, wastewater treatment, or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects.
24. Public Services, Utilities, and Service Systems Impact 4.7-4: Implementation of the proposed Project would continue to have sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry, and multiple dry years.
25. Public Services, Utilities, and Service Systems Impact 4.7-5: Implementation of the proposed Project would not result in a determination by the wastewater treatment provider which serves or may serve the Project that it does not have adequate capacity to serve the Project’s projected demand in addition to the provider’s existing commitments.
26. Public Services, Utilities, and Service Systems Impact 4.7-6: Implementation of the proposed Project would not generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals, or conflict with federal, State, and local management and reduction statutes and regulations related to solid waste.
27. Public Services, Utilities, and Service Systems Impact 4.7-7: Implementation of the proposed Project would not result in cumulative impacts to public services.
28. Transportation Impact 4.8-2: Implementation of the proposed Project would not conflict with a program, plan, ordinance or policy addressing the circulation system during operations.
29. Transportation Impact 4.8-4: Implementation of the proposed Project would not substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment), or result in inadequate emergency access.
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10 F. SIGNIFICANT IMPACTS IDENTIFIED IN THE INITIAL STUDY THAT ARE REDUCED TO A LEVEL OF “LESS THAN SIGNIFICANT” BY THE MITIGATION MEASURES
INCORPORATED INTO THE PROJECT
The mitigation measures contained in the Initial Study are designed to avoid or mitigate significant environmental impacts whenever possible. Implementation of the mitigation measures contained in the Initial Study will result the following less-than-significant impacts (for a detailed description of the less than significant impacts, see the appropriate text in the Initial Study):
1. Aesthetics Impacts I-a and I-b: The proposed Project would not have a substantial adverse effect on a scenic vista and would not substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a State scenic highway, with incorporation of MM I-1.
2. Geology and Soils Impacts VII-a-iii and -iv, VII-c, and VII-d: The proposed Project would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving: seismic-related ground failure, including liquefaction, or landslides; be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the Project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse; or be located on expansive soil, as defined in Table 18-1B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property, with incorporation of MMs VII-1 and VII-2.
3. Geology and Soils Impact VII-f: The proposed Project would not directly or indirectly destroy a unique paleontological resource or site or unique geologic feature, with incorporation of MM VII-3.
4. Hazards and Hazardous Materials Impact IX-b: The proposed Project would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the likely release of hazardous materials into the environment, with incorporation of MM IX-1 and IX-2.
G. LESS THAN SIGNIFICANT IMPACTS IDENTIFIED IN THE INITIAL STUDY The Initial Study identified the following impacts at a level of less than significant or no impact (for a detailed description of the impacts, see the appropriate text in the Initial Study):
1. Aesthetics Impacts I-c and I-d.
2. Agriculture and Forest Resources Impacts II-a, II-c, and II-d.
3. Geology and Soils Impacts VII-a-i and -ii, as well as VII-e.
4. Hazards and Hazardous Materials Impacts IX-a, IX-c, IX-d, IX-e, IX-f, and IX-g.
5. Land Use and Planning Impact XI-a.
6. Mineral Resources Impacts XII-a and XII-b.
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11 7. Population and Housing Impacts XIV-a and XIV-b.
8. Public Services Impacts XV-c, XV-d, and XV-e.
9. Recreation Impacts XVI-a and XVI-b.
10. Wildfire Impacts XX-a, XX-b, XX-c, and XX-d.
H. MITIGATION MONITORING AND REPORTING PROGRAM
When making findings, the lead agency must adopt a reporting or monitoring program for the mitigation measures it has adopted or made a condition of Project approval in order to mitigate or avoid significant effects on the environment. The City hereby adopts the MMRP for the Project, included as Exhibit A to these findings. The mitigation measures identified in the EIR to reduce significant impacts and adopted and incorporated into the Project will be monitored pursuant to the MMRP.
I. ALTERNATIVES
The Draft EIR evaluated three alternatives to the proposed Project. The City Council has reviewed the significant unavoidable impacts associated with each alternative as compared with the proposed Project, and has also considered each alternative’s feasibility, considering a range of economic, environmental, social, and legal factors. Overall, the City Council concludes that each of the three alternatives to the proposed Project is infeasible and less desirable than the proposed Project. The City Council’s analysis and conclusions are described below.
1. No Project (No Build) Alternative: The No Project (No Build) Alternative does not involve changes to the current conditions of the Project site would remain, and the site would not be developed. The significant and unavoidable impact associated with agricultural resources would not occur as part of the Alternative. Because the alternative fails to meet multiple Project objectives and failure to meet even a single objective would be sufficient for rejection of the alternative, the alternative is considered infeasible and undesirable.
2. No Project (Maximum Allowable Operations) Alternative: The No Project (Maximum Allowable Operations) Alternative assumes SMP 39 and SMP 40 would be mined as allowed under the current surface mining permits previously approved for the sites by Alameda County, though not on the Additional Annexation Only Parcels. The significant and unavoidable impact associated with agricultural resources would not occur as part of the Alternative. The Alternative would not meet any of the objectives for the Project, as the sites would not be annexed into the City, industrial uses would not be developed on the sites, and off-site improvements, such as the widening of West Jack London Boulevard and the construction of an off-site trail connection, would not occur.
3. Reduced Intensity Alternative: The Reduced Intensity Alternative would involve development of the Project at a reduced scale. The overall building square footage would be reduced from a total of 1,514,775 sf to a total of approximately 1,226,025 sf. The eastern building on SMP 40 would not be developed, so the disturbance area would be reduced by
16.93 acres. All other aspects of the Project, including building heights, vehicle access, 1329
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12 required entitlements, and the off-site improvements, would be similar under the Alternative.
While the eastern building on SMP 40 would not be developed under the Reduced Intensity Alternative, the Alternative would generally meet all the objectives of the Project. For instance, the project objectives refer to developing industrial uses on-site, to the annexation of the sites into the City, and to the development of off-site improvements that would occur under both the Project and the Alternative, including dedicating, widening, and improving West Jack London Boulevard and the construction of off-site trail improvements.
However, under the Reduced Intensity Alternative, the significant and unavoidable impact related to agricultural resources, which was identified for the Project, would still occur. As such, the number of significant and unavoidable impacts under the Reduced Intensity Alternative would be the same as the Project. Therefore, the alternative is considered undesirable and is rejected.
J. STATEMENT OF OVERRIDING CONSIDERATIONS
As set forth above, there is a significant adverse environmental impact to agricultural resources, which was identified in the Final EIR, but is not mitigated to a less-than-significant level.
CEQA requires the decision-makers to balance the benefits of the Project against its unavoidable environmental risks in determining to approve the Project. Entirely avoiding many of the significant unavoidable impacts would require undermining key Project objectives (see Section 3.4 of the Draft EIR for the list of Project objectives). Therefore, the City of Livermore finds that the benefits of the Project described below outweigh the unavoidable adverse environmental impact as identified above, and that the adverse environmental impact of the Project is, therefore, considered acceptable.
These social, economic, and other benefits constitute overriding considerations justifying Project approval:
1. Approval of the Project advances key Project objectives to revitalize underutilized lands that are appropriate for infill development in which workers can enjoy an environment comprised of modern professional and administrative facilities, research institutions, manufacturing operations, warehouse and distribution facilities, experimental and testing laboratory and related uses compatible with surrounding land uses in the area, the City’s General Plan, and the Alameda County Airport Land Use Compatibility Plan (Objectives 2 and 5).
2. Approval of the Project supports the key Project objective to promote industrial development consistent with the goals, policies, and objectives set forth in both the existing City of Livermore General Plan and General Plan update, including facilities with high-quality architectural design, landscaping, and signage that are consistent with the City’s design standards and guidelines. Such facilities would provide jobs with competitive salaries, reduce vehicle miles traveled, and provide necessary off-site and onsite improvements to the area roadway system, public works, power, and telecommunications infrastructure consistent with planned infrastructure systems (Objectives 1 and 3).
3. Approval of the Project advances key Citywide goals (Objectives 4, 6, and 8). The proposed project would create logical and future City boundaries in cooperation with the City of Pleasanton and Alameda County that align with the City of Livermore’s General Plan and 1330
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13 Urban Growth Boundary (UBG). In addition, as envisioned by the City, the Project would dedicate, widen, and improve West Jack London Boulevard and construct on- and off-site trail improvements and connections to the existing trail network.
4. Approval of the Project would generate long-term sustainable property tax and sales tax revenue for the City of Livermore by way of the annexation of SMP 39 and SMP 40 (Objective 7). The proposed project would also generate funding for local school services through payment of the City’s School Impact Mitigation Development Fees.
K. RECIRCULATION NOT REQUIRED
New or substantial changes to the Draft EIR were not proposed as a result of the public comment process. The Final EIR and the responses to comments memoranda and errata prepared as part of the Planning Commission and City Council staff reports responds to comments and makes only minor technical changes, clarifications, or additions to the Draft EIR. The minor revisions to the Draft EIR do not identify any new significant impacts or substantial increase in the severity of any environmental impacts. The revisions are for clarification purposes only and do not change the conclusions of the Draft EIR. Therefore, recirculation of the Draft EIR is not required.
L. RECORD OF PROCEEDINGS
Various documents and other materials constitute the record of proceedings upon which the City Council base their findings and decisions contained herein. Documents related to this Project are located in the Livermore Community Development Department, Planning Division, 1052 South Livermore Avenue, Livermore, CA.
M. SUMMARY
1. Based on the foregoing Findings and the information contained in the record, the City has made one or more other following findings with respect to each of the significant effects of the Project:
• Changes or alternations have been required in, or incorporated into, the Project, which mitigate or avoid the significant effects on the environment.
• Those changes or alterations are within the responsibility and jurisdiction of another public agency and have been, or can and should be, adopted by that agency.
• Specific economic, legal, social, technological, economic or other considerations made infeasible the mitigation measures or alternatives identified in the Final EIR.
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14 2. Based on the foregoing Findings and the information contained in the record, it is determined that:
• All significant effects on the environmental due to the approval of the SMP 39/SMP 40 Project have been eliminated or substantially lessened where feasible. • Any remaining significant effects on the environment found to be unavoidable are acceptable due to the factors described in the Statement of Overriding Considerations in Section J, above.
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Mitigation Monitoring and Reporting Program