Agenda packet — Livermore City Council, March 25, 2024 (part 8 of 10)

INTRODUCTION
This report summarizes our environmental noise study of future traffic and loading dock activities from the proposed 6-building warehouse facility along Jack London Boulevard, south of Livermore Airport and west of Discovery Drive in Livermore, California. The purpose of the study was to determine the estimated growth in traffic noise levels resulting in the loading dock trucking activity and if traffic noise impacts from the proposed facility will meet the relevant requirements of the City General Plan Noise Element and Noise Ordinance.

EXECUTIVE SUMMARY
● Noise from the project’s loading docks, future intra-project vehicle traffic, and likely HVAC equipment will increase CNEL1 or DNL2 noise levels at noise-sensitive receiver locations by 1 dB. An increase of 3 dB or less DNL is not expected to be noticeable and is not considered significant. ● Noise from project-created traffic would not result in a significant increase in noise levels on Jack London Boulevard or Isabel Avenue at adjacent properties. ● Temporary construction noise will be consistent with the City’s Noise Ordinance and will not exceed the criteria established by General Plan Noise Objectives N-1.1 and N-1.5.

REPORT ORGANIZATION
This report contains the following sections:
● Project Site
● Acoustical Criteria
● Existing Noise Environment
● Noise Impact Assessment
o Construction Noise
o Loading Dock and Intra-Project Traffic Noise (Parking Lot) o Tenant HVAC Equipment Noise
1 Community Noise Equivalent Level (CNEL) – A descriptor for the 24-hour A-weighted average noise level. The CNEL concept accounts for the increased acoustical sensitivity of people to noise during the evening and nighttime hours. Sound levels during the hours from 7 pm to 10 pm are penalized 5 dB; sound levels during the hours from 10 pm to 7 am are penalized 10 dB. A 10-dB increase in sound level is perceived by people to be a doubling of loudness.
2 Day-Night Average Sound Level (DNL) – A descriptor established by the U.S. Environmental Protection Agency to describe the average day-night level with a penalty applied to noise occurring during the nighttime hours (10 pm - 7 am) to account for the increased sensitivity of people during sleeping hours. Also noted as Ldn. The difference between CNEL and DNL is often less than 1 dB.

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PROJECT SITE
The proposed project will have a total lot area of approximately 47.86 acres, located south of West Jack London Boulevard. It is bounded by the Livermore Airport to the north, and Discovery Drive to the east, in the City of Livermore.

There will be six warehouse buildings totaling 2,084,953 square feet with 104 total loading docks. The site is adjacent to existing office and warehouse facilities to the east, approximately 850 feet away. An industrial quarry is located to the south. There are no noise-sensitive residential properties within 2,300 feet of the project site.

ACOUSTICAL CRITERIA
The following are project criteria and/or guidelines for the City of Livermore and State of California.

City of Livermore 2003-2025 General Plan Noise Element
Policy P4, Objective N-1.1
The Noise Element of the Livermore General Plan (Chapter 9, Policy P4 of Objective N-1.1) contains land use compatibility guidelines for environmental noise in the community. Table 1, below, summarizes these guidelines for residential and industrial land uses3in terms of CNEL or DNL. The definitions of each land use category follow below the table.

Table 1: Summary of Table 9-7 – Land Use Compatibility Guidelines for Community Noise CNEL or DNL, dB Land Use Category
Normally
Acceptable
Conditionally
Acceptable
Normally
Unacceptable
Clearly
Unacceptable
Residential Low-Density4, Singlefamily, Duplex, Mobile Homes ≤60 55-70 70-75 >75 Industrial, Manufacturing,
Utilities, Agricultural ≤75 70-80 >75 --

3 Table 9-7 of the Noise Element, page 9-27.
4 Per General Plan Noise Ordinance Objective N-1.4, Policy P4, the criterion for single-family residential back yards is 60 dB CNEL/DNL.

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Normally Acceptable: If the noise level is within the “normally acceptable” level, noise exposure would be acceptable for the intended land use. Development may occur without requiring an evaluation of the noise environment unless the use could generate noise impacts on adjacent uses.

Conditionally Acceptable: If the noise level is within the “conditionally acceptable” level, noise exposure would be conditionally acceptable; a specified land use may be permitted only after detailed analysis of the noise environment and the project characteristics to determine whether noise insulation or protection features are required. Such noise insulation features may include measures to protect noise-sensitive outdoor activity areas (e.g., at residences, schools, or parks) or may include building sound insulation treatments such as sound-rated windows to protect interior spaces in sensitive receptors.

Normally Unacceptable: If the noise level is within the “normally unacceptable” level, analysis and mitigation are required. Development should generally not be undertaken unless adequate noise mitigation options have been analyzed and appropriate mitigations incorporated into the project to reduce the exposure of people to unacceptable noise levels.

Clearly Unacceptable: New construction should not be undertaken unless all feasible noise mitigation options have been analyzed and appropriate mitigation incorporated into the project to adequately reduce exposure of people to unacceptable noise levels.

Noise Element Objective N-1.5
Objective N-1.5 seeks to reduce the level of noise generated by “stationary mechanical and other noisegenerating equipment”. Policy P1 states that “the City shall require that industrial and commercial uses be designed and operated to avoid the generation of noise effects on surrounding land uses from exceeding the following noise levels for exterior environments, operating longer than half an hour per hour:
● 55 dBA5L506(7:00am to 10:00pm)
● 45 dBA L50 (10:00pm to 7:00am)
Policy P2 allows short-term events to have levels louder than those cited above. For events that occur less than 15 minutes per hour, levels can be increased by 5 dBA; events no more than 5 minutes per hour are allowed an additional 10 dBA, and those taking place one minute or less per hour are allowed an additional 15 dBA. Policy P4 allows an exemption from Policy P1 for motor vehicles on public streets between the hours of 7:00am and 8:00pm. We understand that Policies P1, P2, and P4 could apply to the noise from backup alarms (aka “beepers” or “squawkers”). 5 A-Weighted Sound Level – The A-weighted sound pressure level, expressed in decibels (dB). Sometimes the unit of sound level is written as dB(A). A weighting is a standard weighting that accounts for the sensitivity of human hearing to the range of audible frequencies. People perceive a 10 dB increase in sound level to be twice as loud. 6 L50 – The noise level exceeded 50% of the time. For a discussion of environmental acoustics, please refer to Appendix A.

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Objective N-1.5 specifically describes “stationary source noises”, so when referring to L50 noise levels we analyzed the noise of trucks that are expected to sit in the loading dock area, estimated to be at least 2,395 feet from the nearest residence.

Policy P3 establishes instantaneous maximum noise levels allowed (Lmax7) of 70 dBA during the day and 60 dBA during the night.

California Department of Transportation (CalTrans) Construction Vibration Criteria The California Department of Transportation8(DOT) provides vibration guidelines for two scenarios:
human perception and construction damage. These tables are included below as guidelines for potential project vibration levels. “Transient” vibrations are classified as impulsive events that are short in duration (e.g., debris falling, blasting). “Continuous” vibrations are more sustained vibration events over longer periods of time (e.g., jackhammering, drilling). Table 2 describes the human response to different levels of ground-borne vibration for transient and continuous events.

Table 2: Guideline Vibration Annoyance Potential Threshold Criteria9 Human Response
Maximum PPV10 (in/sec)
Transient
Sources
Continuous/Frequent
Intermittent Sources
Barely perceptible 0.04 0.01
Distinctly perceptible 0.25 0.04
Strongly perceptible 0.90 0.10
Severe 2.00 0.40
Table 3 provides a guideline for vibration criteria to assess the damage potential from ground vibration induced by construction equipment. Thresholds for continuous vibrations are lower than those for transient vibrations and are therefore considered more “conservative”. These are standard significance thresholds used in the industry to determine impacts of ground borne vibrations on structures. 7 Lmax (Maximum Sound Level) – The maximum sound level for a specified measurement period of time as defined in ASTM E1686.
8 Transportation and Construction Vibration Guidance Manual September 2013 (DOT Document). 9 This is Table 20 from the DOT document.
10 (PPV): Peak Particle Velocity.

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Table 3: Guideline Vibration Damage Potential Threshold Criteria11 Structure and Condition
Maximum PPV (in/sec)
Transient
Sources
Continuous/Frequent
Intermittent Sources
Extremely fragile historic buildings, ruins, ancient monuments 0.12 0.08 Fragile buildings 0.20 0.10
Historic and some old buildings 0.50 0.25
Older residential structures 0.50 0.30
New residential structures 1.00 0.50
Modern industrial/commercial buildings 2.00 0.50
The immediate adjacent properties are all modern industrial or commercial buildings. Across Isabel Avenue/Highway 84 to the east are existing single-family residences. Based on Table 3, we have applied the more stringent residential criteria of 1.0 PPV for transient events and 0.50 PPV for continuous events.

State of California CEQA Guidelines and Impact Criteria The California Environmental Quality Act (CEQA) contains guidelines that evaluate the significance of noise attributable to a proposed project. This would include (but is not limited to) added traffic noise, mechanical equipment noise, and construction noise. CEQA asks the following applicable questions.

Would the project result in:

1. Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?

2. Generation of excessive ground borne vibration or ground borne noise levels?

3. For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public-use airport, would the project expose people residing or working in the project area to excessive noise levels? CEQA does not define the noise level increase that is considered “substantial”. Typically, the local general plan would establish limits with respect to allowable noise and vibration increases. However, the City of Livermore General Plan does not contain numerical standards of significance for noise increases. For the items above, noise level increases of 3 dBA or less are generally considered less-than-significant.

Substantial adverse community response would be expected only for increases of 5 dBA or more. 11 This is Table 19 of the DOT document.

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EXISTING NOISE ENVIRONMENT
Project Site Description
To quantify the existing site noise environment, a monitor continuously measured noise levels along Jack London Boulevard on 5 and 10 April 2023. Table 4 shows a summary of the measured data. Figure 1, attached, shows the approximate measurement location.

Table 4: Measured Environmental Noise Levels
Site Location DNL (dB) Leq(h) (dB)
LT-1 Jack London Boulevard, approximately 12-feet above grade 75 76 Site Noise Context
Noise measurements at the project site (see Figure 1), collected data from vehicle pass-bys on Jack London Boulevard. The measured on-site noise level was DNL 75 dB (see Figure 1). LT-1 was placed on the closest access utility pole across from the future site on Jack London Boulevard. Adjustments were made, as appropriate, to estimate the change in noise levels from the long-term monitor location to the locations of the nearest residences east of Isabel Avenue.

We have combined cumulative existing and future noise sources that would result from the project’s completion. Future project sources include the proposed loading dock noise, rooftop HVAC equipment, parking areas, and estimated traffic contribution, while the existing noise sources are the existing traffic.

Adding expected noise contribution to the existing noise environment logarithmically would result in a noise level of approximately DNL 75 dB from all contributing noise sources upon the project’s completion.

DNL 30a dB [HVAC] + DNL 32b dB [employee lot] + DNL 50 c dB [trucks] = DNL 50 d dB [future noise level at receivers] a = cumulative building rooftop HVAC noise
b = employee parking lot noise
c = loading dock truck noise
d = cumulative future project sources
DNL 67e dB [existing traffic] + DNL 50e dB [combined future sources] = DNL 67f dB [future noise level at receivers] e = measured at project site, see Figure 1
e = determined from loading docks + HVAC noise + parking lots f = calculated
See Appendix A for additional information on decibel mathematics.

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NOISE IMPACT ASSESSMENT ANALYSIS
We evaluated the following noise sources from the proposed project on the surrounding environment:
● Potential rooftop mechanical equipment noise
● Short-term construction noise and vibration
● Project-related traffic increases
We have drawn the following conclusions from the analysis:

The following summarizes the portion of the CEQA checklist pertaining to noise.

Would the project result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project exceeding standards established in the local general plan or noise ordinance, or applicable standards of other agencies? A: Permanent Increase in Noise Levels due to Project-Generated Noise It is anticipated that the potential office spaces located on northern facades of the six buildings will be mechanically ventilated. Based on previous projects of similar design, we have assumed the use of up to four typical 5-ton package rooftop units located above each office (a total of 56 units). No outdoor mechanical equipment has been specified at this time. Specific equipment will be confirmed during the design phase.

Preliminary sound power level data provided from a similarly sized project with similar 5-ton outdoor package fan units indicates that combined noise from these units sums to approximately DNL 30 dB at the nearest property lines, assuming the units operate continuously for 24-hour operation. The rooftop parapet is assumed to provide acoustical shielding to nearby neighbors because they would break line-ofsight to the nearest receivers.

Depending on the final equipment placement, as well as any specific parapets, barriers, and shielding provided by buildings (which would reduce noise levels at the property lines), noise levels may vary. We do not expect the noise contribution to be significant in these aspects.

B: Predicted Permanent Increase in Noise Levels due Project Traffic Volumes It has been communicated by the team that the projected truck trips per day will be approximately as shown below in Table 5.

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Table 5: SMP-39 Truck Trips
Hour Percent ITE Trips
7 – 9 AM 10.8% 78
9 AM – 4 PM 61.0% 439
4 – 6 PM 10.8% 78
6 – 10 PM 3.9% 28
10 PM – 7 AM 13.4% 96
Total 100 % 719
Overall, the project would result in a net increase in daily trips by 719, amounting to an overall traffic noise DNL increase of <1 dB. Therefore, this would not result in a significant increase in noise levels at existing adjacent properties.

C: Temporary Increase in Noise Levels due to Construction Construction activities will likely include the use of heavy equipment for grading and other activities, through completion of buildings and landscaping. Heavy trucks would travel to, from, and within the site hauling soil, equipment, and building materials. Smaller equipment, such as jackhammers, pneumatic tools, and saws could also be used throughout the demolition and construction phases in various areas.

The noise and vibration associated with these activities would be generated within the entire project area.

Based on our experience with similar projects’ construction methods and phasing, our preliminary understanding and assumptions of expected equipment is shown in Table 6. Reference levels for construction equipment are listed in Table 7, both at the reference distance of 50-feet and at 2,640-feet, which is the distance from eastern edge of the SMP 39 property to the residences across Isabel Avenue.

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Table 6: List of Typical Construction Equipment and Phasing Phase Equipment
Demolition Concrete/Industrial Saws, Excavators, RubberTired Dozers, Tractors/Loaders/Backhoes Site Preparation Graders, Rubber-Tired Dozers,
Tractors/Loaders/Backhoes
Grading/Excavation
Excavators, Drill Rig for Shoring Beams
(Caisson Drilling), Rubber-Tired Dozers,
Tractors/Loaders/Backhoes
Trenching Tractor/Loader/Backhoe, Excavators
Building Exterior Cranes, Forklifts, Generator Sets,
Tractors/Loaders/Backhoes, Welders
Building Interior/
Architectural Coating Air Compressors, Aerial Lift
Paving/Landscaping/
Site Concrete
Cement and Mortar Mixers, Paving
Equipment, Rollers,
Tractors/Loaders/Backhoes

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Table 7: Construction Equipment Reference Noise Levels12 Typical 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 for 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/Loaders/Backhoes 84 50
Welders 73 39
Actual construction noise levels will vary based on distance to each piece of equipment or work area from the receiver and shielding from adjacent buildings and construction elements. It should be noted that construction activities are prohibited during the specific time period outlined in Section 9.36.080 of the City’s Municipal Code, and our calculations do not take shielding from adjacent buildings into consideration. Section 9.36.080 is as follows:
12 Equipment noise levels at 50-feet are from Section 9, Federal Highway Administration Highway Traffic Noise Construction Noise Handbook (August 2006) and Table 12-2, Transit Noise and Vibration Impact Assessment, United States Department of Transportation, Office of Planning and Environment, Federal Transit Administration, May 2006.

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Section 9.36.080 Hammers, pile drivers, pneumatic tools and similar equipment The operation between the hours of 6:00 p.m. Saturday to 7:00 a.m. Monday; 8:00 p.m. to 7:00 a.m. on Monday, Tuesday, Wednesday and Thursdays; 8:00 p.m. Friday to 9:00 a.m. on Saturday or at all on cityobserved holidays of any pile driver, pneumatic tools, derrick, electric hoist, sandblaster or other equipment used in construction, demolition or other repair work, the use of which is attended by loud or unusual noise, is prohibited. (Ord. 1672 § 2, 2002; Ord. 1128 § 2, 1983; 1960 code § 13B.3(f)) Construction Equipment Schedule
We received the following equipment schedule that CalEEMod utilized for their model for air quality emissions. Table 8 below summarizes the equipment and associated sound levels at the nearest residential property (approximately 2,640 feet away).

Table 8: Construction Equipment Schedule
Phase Name Offroad Equipment Type
Amount Usage
Hours
Resulting
DNL
Resulting
Lmax
Grading Excavators 2 8 66 54
Grading Graders 1 8 66 51
Grading Rubber Tired Dozers 1 8 66 51
Grading Scrapers 2 8 66 54
Grading Tractors/Loaders/Backhoes 2 8 66 53
Total Grading Phase All Equipment Running Simultaneously 67 60 Paving Pavers 2 8 67 58
Paving Paving Equipment 2 8 67 58
Paving Rollers 2 8 66 43
Total Paving Phase All Equipment Running Simultaneously 67 61 Building Construction Cranes 1 7 66 49
Building Construction Forklift 3 8 66 54
Building Construction Generator Sets 1 8 66 47
Building Construction Tractors/Loaders/Backhoes 3 7 66 56 Building Construction Welders 1 8 66 39
Total Building Construction All Equipment Running Simultaneously 67 59 Architectural Coating Air Compressors 1 8 66 47

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It should be noted that the DNL was calculated using daytime construction noise levels for daytime hours for the listed hours of operation and measured nighttime hours from existing traffic. Despite restrictions of nighttime construction activities, from the noise levels shown above in Table 8, it could be possible to exceed the General Plan Objectives as follows:

Objective N-1.5 P3
● As shown above in Table 8, with all the phases running construction equipment as intended, the resulting Lmax would range between 59 and 61 dBA. Since construction is not permitted during nighttime hours, the Lmax criterion of 70 dBA would be met and not be considered a significant increase.

Due to these results, it will not be necessary to incorporate any mitigation measures for construction noise.

Would the project result in generation of excessive ground-borne vibration or ground-borne noise levels?
A: Permanent Increase in Vibration Levels due to Project-Generated Vibration The planned use for the site, as warehouse buildings, is not expected to generate significant amounts of ground-borne noise or vibration.

B: Temporary Increase in Vibration Levels due to Construction The nearest and most sensitive adjacent receivers include residences to the east approximately 500 feet from the closest area of construction on the project site. Industrial-zoned parcels to the north are assumed to be less sensitive.

Project construction may include activities such as the use of concrete saws, excavation and grading, and the use of rolling stock equipment (tracked vehicles, compactors, etc.). Typical construction vibration levels at 50-feet are listed in Table 9, below. Most of the construction will occur set back from the property line. As indicated in the criteria section above, the risk of damage to nearby structures may begin to occur at a limit of 1.0 in/sec PPV for transient vibration events and 0.50 PPV for continuous events.

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Table 9: Example Construction Vibration Levels13
Equipment PPV at 50 ft. (in/sec)14
Vibratory Roller 0.049
Hydraulic Breaker 0.03 to 0.08
Large Bulldozer 0.03
Loaded Trucks 0.03
Excavator 0.03
Caisson/pier drilling 0.03
Jackhammer 0.01
Small Bulldozer 0.001
Crane, Forklift, Bobcat No significant vibration
Based on the vibration levels shown in Table 8, construction equipment is not expected to cause structural damage to adjacent properties because project construction is not expected to exceed the thresholds for new residential buildings or commercial/industrial structures as shown above in Table 3.

Ground-borne noise would also not be expected to be significant at these vibration levels.

FUTURE LOADING DOCK AND INTRA-PROJECT TRAFFIC NOISE ESTIMATES Future Loading Dock Calculation Methodology
Operational noise from the proposed facility is expected to consist primarily of tractor-trailers accessing loading dock areas. To estimate truck noise at the proposed facility, we referenced recently measured noise levels at a distribution facility elsewhere in California which involved semi-trucks similar in size to those that are expected to access the proposed project’s facility.

Calculations for resulting noise levels due to on-site truck and car trip generation durations and activities were based on the measurements at this local distribution facility with ancillary information provided to us for that reference project in 2018.

Traffic volumes for the proposed project were referenced from the provided Traffic Impact Analysis document (dated 4 April 2023) by TJKM, which describes the total daily truck trips and the partial 13 Table 12-2, Transit Noise and Vibration Impact Assessment, United States Department of Transportation, Office of Planning and Environment, Federal Transit Administration, May 2006. 14 Using a value of n = 1.5 per FTA recommendation, where n is the attenuation rate through the ground

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distribution over the peak AM and PM hours and the relative expected proportion of project-generated trips using Jack London Boulevard and Isabel Avenue.

Intra-Project Traffic Methodology
Intra-project traffic noise will consist of traffic noise associated with future warehouse employee vehicles within the designated parking lots. To estimate vehicle noise at the employee parking lots, we also reference the Traffic Impact Analysis document for the expected traffic volume of warehouse employees.

Noise Source Analysis and Assumptions
Future Loading Docks
Our analysis estimated future noise from the facility based on the following assumptions discussed with the client via email, and per the overall site plan:

1. Trucks will enter and exit the site from three driveways off West Jackson Boulevard, from the north.

2. Non-truck noises associated with loading/unloading activity (i.e., forklifts, rolling doors, carts, pallet crushing, items dropping), are assumed to be located near the dock doors and are included in our analysis.

3. An average truck trip (not including unloading/loading) is estimated to last for a cumulative period of about 2 minutes and be at least 930 feet from the nearest commercial property line.

4. Trucks occupy the loading dock in their loading area that is nearest to noise-sensitive receiver (Commercial buildings east of Discovery Drive, to the east of the building).

5. Total number of loading docks: 104

6. Number and distribution of truck trips is based on the traffic impact analysis, with approximately 719 total truck trips per 24-hour period (continuous 24/7 operation) distributed as follows:
● AM Peak is 7-9 AM- 10.8%
● 9-4 PM -61%
● PM Peak is 4 PM - 6 PM -10.8%
● 6 PM - 10 PM 3.9%
● 10 PM -7 AM 13.4%

7. The proposed warehouse buildings have south-facing loading docks which are recessed approximately 60 feet from the easternmost building’s façade, providing substantial shielding for truck operation noise. This feature is expected to obstruct the direct line of sight of the project’s loading docks from the commercial neighbors to the east, especially in buildings closer to Discovery Drive.

8. Having measured operations at a local representative loading dock site, a typical truck “trip” consists of the following events (estimated sound levels based on measurements at similar facilities):

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a. Truck passby (arrival, departure): 69 dBA at 30 feet b. Truck airbrakes: 72 dBA at 25 feet
c. Truck backup alarm: 79 dBA at 30 feet
d. Brief idle before engine shutoff: 70 dBA at 25 feet
e. Truck engine ignition and airbrakes: 71 dBA at 25 feet f. Truck accelerating from stop: 74 dBA at 25 feet
g. Truck trip reference heights15 (above grade)
i. Passby, brief idle, acceleration, and ignition: 8 feet ii. Back-up beeper and airbrake: 2.5 feet
Intra-Project Traffic Noise
Our analysis estimated future noise from the facility parking lots is based on the following assumptions:

1. Employees will enter and exit the site from the three driveways from the north (via Jack London Boulevard).

2. Vehicle trips will be split between Jack London Boulevard and Isabel Avenue per the TJKM report’s traffic projections. Our traffic analysis calculations tell us the following:
● 80% of project generated trips will be along Jack London Boulevard ● 20% of project generated trips will be along Isabel Avenue ● There will be an average noise level increase of approximately 3dB on both roadways due to traffic increases. This increase is not considered to be significant.

3. Once on site, vehicles will travel an average of 15 miles per hour or less.

4. Vehicles will be spread out evenly amongst the parking areas.

5. An average vehicle trip is estimated to last for a cumulative period of about 2 minutes and be at least 900 feet from the nearest commercial property line.

6. Similar percentages were assumed for intra-project vehicle trips in the project parking lots as were truck trips, as shown in the distribution below.
• AM Peak is 7-9 AM- 10.8%
• 9-4 PM -61%
• PM Peak is 4 PM - 6 PM -10.8%
• 6 PM - 10 PM 3.9%
• 10 PM -7 AM 13.4%
15 Truck source heights excerpted from Caltrans Technical Noise Supplement document (TeNS) document dated October 1998.

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Estimated Future Noise Levels
Loading Dock Future Noise Levels (CNEL/DNL)
We estimated noise levels at local receptors from the sources described in the previous section. To account for future increases in local traffic noise levels, we added 1 dB DNL to the measured levels16 (see Table 4 above).

Table 10 below summarizes the estimated DNL levels at the closest property plane to the east of the building, under the assumption that the facility would receive its trucking activities 24 hours per day.

Table 10: Calculated Future Facility Noise at Noise-Sensitive Land Uses: CNEL/DNL, dBA Scenario
Nearby Receiving
Locations
Existing
Noise at
Receiver
Loading
Docks at
Receiver
IntraProject
Traffic
Noise
Levels at
Receiver
Combined
Existing
plus
Project
Change
(dB)
24-hour
Operations
East Property Line
(Residences across
Isabel Avenue)
67 61 32 68 +1 dB
The data shows that loading dock-generated noise is not expected to impact adjacent receivers to the north and the residences to the east. The calculated increase in DNL at the nearest property line with the project and future traffic noise levels (near term 2025) will be approximately 1 dB. A change of 3 dB or less is not expected to be noticeable and is not considered significant.

Future L50Noise Levels
The following assumptions were made about the 24-hour operation of the project in our estimated L50 calculations:
● The volume of expected truck trips is consistent with the truck trip distribution established in item 6 of the Noise Source Analysis and Assumptions section (i.e., a maximum of 10 truck per hour at nighttime, or 13.4% of trucks between 10:00 pm and 7:00 am). ● The 6- and 10-foot berms will be incorporated into the project. ● Backup alarms are expected to be at a height of approximately 2.5 feet. ● Trucks do not move great distances when their backup alarm is engaged. 16 The California Department of Transportation assumes a traffic volume increase of three-percent per year, which corresponds to a 1 dB increase in DNL over a ten-year period.

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Table 11 summarizes the estimated daytime and nighttime L50 for the proposed project. Since backup alarms for nighttime are predicted to occur less than 15 minutes per hour, the criterion can increase by 5 dBA per Policy P2. However, since back up alarms would be more than 15 minutes per hour during the daytime, no additional increases are accounted for in our analysis.

Table 11: Calculated 24-Hour Future Facility L50 Value: L50, dBA Time of Day Estimated L50 Value Criterion L50 Value
Daytime (7am-10pm) 40 dBA 55 dBA
Nighttime (10pm-7am) 35 dBA 50 dBA
Our calculations of overall operational L50 noise levels do not exceed the allowable values stated by the City (i.e., Policy P1, Objective N-1.5), it is our understanding that other current similar projects in the vicinity have caused local neighbor complaints due to trucks’ back-up alarms at those locations in the past.

Back-up alarms were assumed to be 79 dB at a reference distance of 30 feet. The distance attenuation between the loading dock to the façade of the nearest residence provides a 31 dB reduction. Although backup alarms would be audible from the residences, the L50 threshold of 50 dBA will not be exceeded due to the limited number of trips during this timeframe (estimated at 40 trips in 9-hour time frame).

Calculations assumed the source height of these backup alarms to be approximately 2.5 feet from grade.

The current buildings would adequately obstruct the direct line-of-sight of these backup alarms to the residential receivers. The dimensions of the proposed berms are calculated to reduce intermittent noise levels (such as those produced by backup alarms) by up to 6 dB at the closest residents.

Quieter backup alarms (aka “squawkers”), which are becoming more prevalent in delivery vehicles for various large e-commerce websites, and other vendors, may be used by trucking operators visiting this site in the future, therefore beeper noise has the potential to be reduced. A best practice for consideration would be to implement these alternative devices in other truck populations in the future.

CONCLUSIONS AND COMMENTS

1. Future loading dock-generated noise (due to on-site trucks and vehicles) over a 24-hour operation period is not expected to impact receivers to the east. The calculated increase in CNEL/DNL at the nearest noise-sensitive residential receivers with the project and future traffic noise levels will be <1 dB. A change of 2 dB or less is not considered significant nor is it expected to be noticeable to residents east of the project site.

2. Temporary construction noise will be consistent with the City’s Noise Ordinance and will not exceed the criteria established by General Plan Noise Objectives N-1.1 and N-1.5.

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3. Considering the 2,395-foot distance between the nearest loading dock and the closest residents, and the trucks being a stationary source rather than a moving vehicle once the leaving the loading dock area of the project site, the city's L50 criterion is not applicable once a truck begins moving closer to the residential area. Given the minority of expected project truck trips conducted in the nighttime hours (10 trips per hour on average from 10 PM to 7 AM), noise from stationary trucks at the nearest loading dock are expected to comply with the City’s L50 nighttime requirement assuming backup alarms are not continuously operating for more than 30 minutes per hour. * * *

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APPENDIX A: FUNDAMENTAL CONCEPTS OF ENVIRONMENTAL NOISE This section provides background information to aid in understanding the technical aspects of this report.

Three dimensions of environmental noise are important in determining subjective response. These are:
● The intensity or level of the sound
● The frequency spectrum of the sound
● The time-varying character of the sound
Airborne sound is a rapid fluctuation of air pressure above and below atmospheric pressure. Sound levels are usually measured and expressed in decibels (dBA), with 0 dBA corresponding roughly to the threshold of hearing.

The "frequency" of a sound refers to the number of complete pressure fluctuations per second in the sound. The unit of measurement is the cycle per second (cps) or hertz (Hz). Most of the sounds, which we hear in the environment, do not consist of a single frequency, but of a broad band of frequencies, differing in level. The name of the frequency and level content of a sound is its sound spectrum. A sound spectrum for engineering purposes is typically described in terms of octave bands, which separate the audible frequency range (for human beings, from about 20 to 20,000 Hz) into ten segments.

Many rating methods have been devised to permit comparisons of sounds having quite different spectra.

Surprisingly, the simplest method correlates with human response practically as well as the more complex methods. This method consists of evaluating all of the frequencies of a sound in accordance with a weighting that progressively de-emphasizes the importance of frequency components below 1000 Hz and above 5000 Hz. This frequency weighting reflects the fact that human hearing is less sensitive at low frequencies and at extreme high frequencies relative to the mid-range.

The weighting system described above is called "A"-weighting, and the level so measured is called the "Aweighted sound level" or "A-weighted noise level." The unit of A-weighted sound level is sometimes abbreviated "dBA." In practice, the sound level is conveniently measured using a sound level meter that includes an electrical filter corresponding to the A-weighting characteristic. All U.S. and international standard sound level meters include such a filter. Typical sound levels found in the environment and in industry are shown in Figure A-1.

Although a single sound level value may adequately describe environmental noise at any instant in time, community noise levels vary continuously. Most environmental noise is a conglomeration of distant noise sources, which results in a relatively steady background noise having no identifiable source. These distant sources may include traffic, wind in trees, industrial activities, etc. and are relatively constant from moment to moment. As natural forces change or as human activity follows its daily cycle, the sound level may vary slowly from hour to hour. Superimposed on this slowly varying background is a succession of identifiable noisy events of brief duration. These may include nearby activities such as single vehicle passbys, aircraft flyovers, etc. which cause the environmental noise level to vary from instant to instant.

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To describe the time-varying character of environmental noise, statistical noise descriptors were developed. "L10" is the A-weighted sound level equaled or exceeded during 10 percent of a stated time period. The L10 is considered a good measure of the maximum sound levels caused by discrete noise events. "L50" is the A-weighted sound level that equals or exceeded 50 percent of a stated time period; it represents the median sound level. The "L90" is the A-weighted sound level equaled or exceeded during 90 percent of a stated time period and is used to describe the background noise.

As it is often cumbersome to quantify the noise environment with a set of statistical descriptors, a single number called the average sound level or "Leq" is now widely used. The term "Leq" originated from the concept of a so-called equivalent sound level which contains the same acoustical energy as a varying sound level during the same time period. In simple but accurate technical language, the Leq is the average A-weighted sound level in a stated time period. The Leq is particularly useful in describing the subjective change in an environment where the source of noise remains the same but there is change in the level of activity. Widening roads and/or increasing traffic are examples of this kind of situation.

In determining the daily measure of environmental noise, it is important to account for the different response of people to daytime and nighttime noise. During the nighttime, exterior background noise levels are generally lower than in the daytime; however, most household noise also decreases at night, thus exterior noise intrusions again become noticeable. Further, most people trying to sleep at night are more sensitive to noise. To account for human sensitivity to nighttime noise levels, a special descriptor was developed. The descriptor is called the Ldn (Day/Night Average Sound Level), which represents the 24- hour average sound level with a penalty for noise occurring at night. The Ldn computation divides the 24- hour day into two periods: daytime (7:00 am to 10:00 pm); and nighttime (10:00 pm to 7:00 am). The nighttime sound levels are assigned a 10 dBA penalty prior to averaging with daytime hourly sound levels.

For highway noise environments, the average noise level during the peak hour traffic volume is approximately equal to the Ldn.

The effects of noise on people can be listed in three general categories:
● Subjective effects of annoyance, nuisance, dissatisfaction ● Interference with activities such as speech, sleep, and learning ● Physiological effects such as startle, hearing loss
The sound levels associated with environmental noise usually produce effects only in the first two categories. Unfortunately, there has never been a completely predictable measure for the subjective effects of noise nor of the corresponding reactions of annoyance and dissatisfaction. This is primarily because of the wide variation in individual thresholds of annoyance and habituation to noise over time.

Thus, an important factor in assessing a person's subjective reaction is to compare the new noise environment to the existing noise environment. In general, the more a new noise exceeds the existing, the less acceptable the new noise will be judged.

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Regarding increases in noise level, knowledge of the following relationships will be helpful in understanding the quantitative sections of this report:

Except in carefully controlled laboratory experiments, a change of only 1 dBA in sound level cannot be perceived. Outside of the laboratory, a 3 dBA change is considered a just-noticeable difference. A change in level of at least 5 dBA is required before any noticeable change in community response would be expected. A 10 dBA change is subjectively heard as approximately a doubling in loudness and would almost certainly cause an adverse community response.

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A1
A1

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LT-1: DNL 75 dB, Leq(h) 76 dB
www.salter-inc.com San Francisco San Jose Honolulu Seattle Los Angeles

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Attachment 3
SMP 40 Revised Environmental Noise Study

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Oaks Business Park SMP-40
Livermore, CA

UPDATE TO ENVIRONMENTAL NOISE STUDY
4 March 2024
Prepared for: Michael Johnson Timur Tecimer
Overton Moore Properties
19700 S Vermont Avenue Suite #101
Torrance, CA 90502
[email protected]
Overton Moore Properties
19700 S Vermont Avenue Suite #101
Torrance, CA 90502
[email protected]
Prepared by: Salter
Diego Hernandez – Associate
Ethan Salter – Vice President
[email protected]
[email protected]
Salter Project 21-0471

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INTRODUCTION
This report summarizes our study of environmental noise of the proposed project (Livermore Oaks Business Park SMP-40) on nearby land uses. The project site is west of Isabel Avenue (State Highway 84), north of Stanley Boulevard, and south of Discovery Drive in Livermore, California. The purpose of the study was to determine whether estimated activity noise and construction noise from the proposed facility will meet the relevant requirements of the City General Plan Noise Element and Noise Ordinance at adjacent land uses.

EXECUTIVE SUMMARY
● Noise from the project’s loading docks, future intra-project vehicle traffic, and likely HVAC equipment will increase CNEL1 or DNL2 noise levels at noise-sensitive receiver locations at most by 3 dB. An increase of 3 dB or less DNL is not expected to be noticeable and is not considered significant. ● Noise from project-created traffic would not result in a significant increase in noise levels on Isabel Avenue at adjacent properties.
● Temporary construction noise will exceed the City’s Noise Ordinance and will need mitigation measures not to exceed the criteria established by General Plan Noise Objectives N-1.1 and N-1.5.

REPORT ORGANIZATION
This report is organized into the following sections:
● Project Site
● Acoustical Criteria
● Existing Noise Environment
● Noise Impact Assessment
o Construction Noise
o Loading Dock and Intra-Project Traffic Noise (Parking Lot) o Tenant HVAC Equipment Noise
1 Community Noise Equivalent Level (CNEL) – A descriptor for the 24-hour A-weighted average noise level. The CNEL concept accounts for the increased acoustical sensitivity of people to noise during the evening and nighttime hours. Sound levels during the hours from 7 pm to 10 pm are penalized 5 dB; sound levels during the hours from 10 pm to 7 am are penalized 10 dB. A 10-dB increase in sound level is perceived by people to be a doubling of loudness.
2 Day-Night Average Sound Level (DNL) – A descriptor established by the U.S. Environmental Protection Agency to describe the average day-night level with a penalty applied to noise occurring during the nighttime hours (10 pm - 7 am) to account for the increased sensitivity of people during sleeping hours. Also noted as Ldn. The difference between CNEL and DNL is often less than 1 dB.

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PROJECT SITE
The proposed project will have a total area of approximately 40 acres, west of Isabel Avenue (State Highway 84) and between Stanley Boulevard and Discovery Drive in the City of Livermore. Warehouse Building 1 will be about 470,350 square feet with 68 loading docks, while Building 2 will be 288,750 square feet with 62 loading docks. The site is adjacent to existing industrially zoned warehouse facilities with loading docks to the north. Noise-sensitive residential receivers are located across Isabel Avenue to the east about 1,785-feet away from Building 1, and 600-feet away the northeast corner of the SMP-40 site. Two berms have been incorporated on the project site: a 6-foot by 125-foot landscape berm on the Northeast corner of the project property line, and a 10-foot by 60-foot screening wall east of Building 2’s southern loading docks.

ACOUSTICAL CRITERIA
The following are project criteria and/or guidelines per the City of Livermore and State of California.

3 Table 9-7 of the Noise Element, page 9-27.
4 Per General Plan Noise Ordinance Objective N-1.4, Policy P4, the criterion for single-family residential back yards is 60 dB CNEL/DNL.

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Noise Element Objective N-1.5
Objective N-1.5 seeks to reduce the level of noise generated by “stationary mechanical and other noisegenerating equipment”. Policy P1 states that “the City shall require that industrial and commercial uses be designed and operated to avoid the generation of noise effects on surrounding land uses from exceeding the following noise levels for exterior environments, operating longer than half an hour per hour:
● 55 dBA5L506(7:00am to 10:00pm)
● 45 dBA L50 (10:00pm to 7:00am)
Policy P2 allows short-term events to have levels louder than those cited above. For events that occur less than 15 minutes per hour, levels can be increased by 5 dBA; events no more than 5 minutes per hour are allowed an additional 10 dBA, and those taking place one minute or less per hour are allowed an additional 15 dBA.
5 A-Weighted Sound Level – The A-weighted sound pressure level, expressed in decibels (dB). Sometimes the unit of sound level is written as dB(A). A weighting is a standard weighting that accounts for the sensitivity of human hearing to the range of audible frequencies. People perceive a 10 dB increase in sound level to be twice as loud. 6 L50 – The noise level exceeded 50% of the time. For a discussion of environmental acoustics, please refer to Appendix A.

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Policy P4 allows an exemption from Policy P1 for motor vehicles on public streets between the hours of 7:00am and 8:00pm. We understand that Policies P1, P2, and P4 could apply to the noise from backup alarms (aka “beepers” or “squawkers”).

Policy P3 establishes instantaneous maximum noise levels allowed (Lmax7) of 70 dBA during the day and 60 dBA during the night.

7 Lmax (Maximum Sound Level) – The maximum sound level for a specified measurement period of time as defined in ASTM E1686.
8 Transportation and Construction Vibration Guidance Manual September 2013 (DOT Document). 9 This is Table 20 from the DOT document.
10 (PPV): Peak Particle Velocity.

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Table 3 provides a guideline for vibration criteria to assess the damage potential from ground vibration induced by construction equipment. Thresholds for continuous vibrations are lower than those for transient vibrations and are therefore considered more “conservative”. These are standard significance thresholds used in the industry to determine impacts of ground borne vibrations on structures.

Would the project result in:

2. Generation of excessive ground borne vibration or ground borne noise levels?

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CEQA does not define the noise level increase that is considered “substantial”. Typically, the local general plan would establish limits with respect to allowable noise and vibration increases. However, the City of Livermore General Plan does not contain numerical standards of significance for noise increases. For the items above, noise level increases of 3 dBA or less are generally considered less-than-significant.

Substantial adverse community response would be expected only for increases of 5 dBA or more.

EXISTING NOISE ENVIRONMENT
Project Site Description
To quantify the existing site noise environment, two monitors continuously measured noise levels along the project property lines to the north and east between 2 and 4 November 2021. Table 4 summarizes measured data and Figure 1, attached, shows the approximate measurement locations. Locations were selected based not only on project setbacks but also on what nearby locations were accessible via public rights-of-way.

Table 4: Measured Environmental Noise Levels
Site Location Measured DNL (dBA)
LT-1 Business Park, approximately 10-feet above grade 65 LT-2 Arroyo Bike Trail, approximately 10-feet above grade 67 Site Noise Context
Noise measurements at the project site (see Figure 1), collected data from vehicle pass-bys on nearby roads. Measured on-site noise levels were DNL 65 dB and 67 dB at the project site (see Figure 1). LT-1 was placed near the nearest existing warehouse across from residences, and LT-2 was placed on the closest accessible utility pole across from residences. Adjustments were made, as appropriate, to estimate the change in noise levels from the long-term monitor location to the locations of the nearest residences east of Isabel Avenue.

Adding expected noise contribution to the existing noise environment logarithmically would result in a noise level of approximately DNL 67 dB from all contributing noise sources upon the project’s completion.

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DNL 29
a dB [Future HVAC] + DNL 29b dB [employee lot] + DNL 52 c dB [trucks] = DNL 52 d dB [future noise level at receivers] a = cumulative building rooftop HVAC noise
b = employee parking lot noise
c = truck noise at loading docks
d = cumulative future project sources
DNL 67e dB [existing traffic] + DNL 52
e dB [combined future sources] = DNL 67f dB [future noise level at receivers] e = measured at project site, see Figure 1
e = determined from loading docks + HVAC noise + parking lots f = calculated
See Appendix A for additional information on decibel mathematics.

The following summarizes the portion of the CEQA checklist pertaining to noise.

Would the project result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? A: Permanent Increase in Noise Levels due to Project-Generated Noise The owner anticipates that tenant office spaces located on the corners of each building will be mechanically ventilated with typical 5-ton package units located above the offices in each corner of each building. No other outdoor mechanical equipment has been specified at this time. Specific equipment will be confirmed during the design phase.

Preliminary sound power level data has been provided for these 5-ton outdoor package fan units indicating that combined noise from these units sums to approximately DNL 29 dB at the nearest property lines. This assumes 24-hour operation of this equipment (in line with the operation hours of the building). The rooftop parapet is assumed to provide acoustical shielding to nearby neighbors because they would break line-of-sight to the nearest receivers.

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Table 5: SMP-40 Truck Trips
Hour Percent ITE Trips
7 – 9 AM 9.4% 20
9 AM – 4 PM 42.7% 91
4 – 6 PM 12.7% 27
6 – 10 PM 16.4% 35
10 PM – 7 AM 18.8% 40
Total 100 % 213
Overall, the project would result in a net increase in daily trips by 213, amounting to an overall traffic noise DNL increase of approximately 2 dB. Therefore, this would not result in a significant increase in noise levels at existing adjacent properties.

The noise and vibration associated with these activities would be generated within the entire project area.

Based on our experience with similar projects’ construction methods and phasing, our preliminary understanding and assumptions of expected equipment is shown in Table 6. Reference levels for construction equipment are listed in Table 7, both at the reference distance of 50-feet and at 600-feet, which is the closest distance between the project and the residences across Isabel Avenue.

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Table 7: Construction Equipment Reference Noise Levels12 Typical Equipment
Estimated Maximum
Instantaneous Lmax
13 Noise Level (dBA at 50
feet)
Estimated Maximum
Instantaneous Lmax Noise
Level (dBA at 600 feet)
Aerial Lift 83 61
Air Compressors 81 59
Cement and Mortar Mixers 85 63
Concrete/Industrial Saws 76 54
Cranes 83 61
Drill Rig for Shoring Beams (Caisson Drilling) 85 63
Excavators 85 63
Forklifts 83 61
Generator Sets 81 59
Graders 85 63
Paving Equipment 89 67
Rollers 74 52
Rubber-Tired Dozers 85 63
Tractors/Loaders/Backhoes 84 62
Welders 73 51
Actual construction noise levels will vary based on distance to each piece of equipment or work area from the receiver and shielding from adjacent buildings and construction elements. It should be noted that construction activities are prohibited during the specific time period outlined in Section 9.36.080 of the City’s Municipal Code. Section 9.36.080 is as follows:
12 Equipment noise levels at 50-feet are from Section 9, Federal Highway Administration Highway Traffic Noise Construction Noise Handbook (August 2006) and Table 12-2, Transit Noise and Vibration Impact Assessment, United States Department of Transportation, Office of Planning and Environment, Federal Transit Administration, May 2006. 13 Lmax (Maximum Sound Level) – The maximum sound level for a specified measurement period of time as defined in ASTM E1686.

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Table 8: Construction Equipment Schedule
Phase Name Offroad Equipment Type
Amount Usage
Hours
Resulting
DNL
Resulting
Lmax
Grading Excavators 2 8 67 66
Grading Graders 1 8 67 63
Grading Rubber Tired Dozers 1 8 67 63
Grading Scrapers 2 8 67 66
Grading Tractors/Loaders/Backhoes 2 8 67 65
Total Grading Phase All Equipment Running Simultaneously 70 72 Paving Pavers 2 8 69
70 Paving Paving Equipment 2 8 69 70
Paving Rollers 2 8 66 55
Total Paving Phase All Equipment Running Simultaneously 70 73 Building Construction Cranes 1 7 67 61
Building Construction Forklift 3 8 67 66
Building Construction Generator Sets 1 8 67 59
Building Construction Tractors/Loaders/Backhoes 3 7 68 67 Building Construction Welders 1 8 66 51
Total Building Construction All Equipment Running Simultaneously 69 70 Architectural Coating Air Compressors 1 8 67 59

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Objective N-1.5 P3
● As shown above in Table 8, with all the phases running construction equipment as intended, the resulting Lmax would range between 70 and 73 dBA. Since construction is not permitted during nighttime hours, only the daytime Lmax criterion of 70 dBA would be applicable and would not be met. Therefore, it will be necessary to implement the mitigation measures shown below.

Due to these possibilities, the following is a list of measures that are required to be adopted by the contractor to reduce the impact of construction noise on neighbors:

1. Consistent with the Livermore Municipal Code, construction will be limited to weekdays between the hours of 7:00 a.m. and 8:00 p.m. and Saturdays through Sunday between the hours of 9:00 a.m. and 6:00 p.m.

2. There are residences located approximately 600 feet from the project site. Thus, to help reduce the impact of noise construction, it will be necessary that a barrier be built prior to the planned permanent 10-foot tall berm on the east side of the project. If this is not feasible, we recommend building the planned permanent 10-foot tall berm before construction activities. This will be necessary to reduce construction noise impacts on the residences. The barrier/berm should be 10 feet tall. This would help reduce the construction noise impacts on the residences by approximately 10 dB.

3. The barrier can be field-built provided they meet the following criteria:
a. Minimum surface density of 4 psf.

Many constructions could meet the surface density requirement. For example, a stud wall with exterior-grade plywood sheathing and a stucco finish (or two layers of 5/8-inch thick plywood) would meet this requirement.
b. The barrier should be free of cracks and drainage holes/slots along the bottom of the barrier be kept to a minimum. Where needed, they should be covered by 1 psf mass-loaded vinyl flaps (e.g., Kinetics KNM-100) so water can flow around the vinyl and still drain. c. Joints between sheathing layers be offset by 16 inches minimum.

4. Contractors shall utilize “quiet” models of air compressors and other stationary noise sources where technology exists.

5. Internal combustion engine-driven equipment shall be equipped with mufflers which are in good condition and appropriate for the equipment.

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6. Stationary noise-generating equipment, such as air compressors and portable power generators, shall be located as far away as possible from adjacent property lines.

7. Staging areas and construction material areas shall be located as far away as feasible from adjacent residences.

8. All unnecessary idling of internal combustion engines should be prohibited.

9. The contractor should 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 will determine the cause of the noise complaint (e.g., starting too early, bad muffler, etc.) and will require that reasonable measures are implemented to correct the problem. The telephone number for the noise disturbance construction superintendent will be posted at the construction site and included in any construction notices sent to neighbors.

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Table 9: Example Construction Vibration Levels14
Equipment PPV at 50 ft. (in/sec)15
Vibratory Roller 0.049
Hydraulic Breaker 0.03 to 0.08
Large Bulldozer 0.03
Loaded Trucks 0.03
Excavator 0.03
Caisson/pier drilling 0.03
Jackhammer 0.01
Small Bulldozer 0.001
Crane, Forklift, Bobcat No significant vibration
Based on the vibration levels shown in Table 9, construction equipment is not expected to cause structural damage to adjacent properties because project construction is not expected to exceed the thresholds for new residential buildings or commercial/industrial structures as shown above in Table 3.

Ground-borne noise would also not be expected to be significant at these vibration levels.

FUTURE LOADING DOCK AND INTRA-PROJECT TRAFFIC NOISE
Future Loading Dock Calculation Methodology
Operational noise from the proposed facility is expected to consist primarily of tractor-trailers accessing loading dock areas. To estimate truck noise at the proposed facility, we referenced recently measured noise levels at a local distribution facility which involved semi-trucks similar in size to those that are expected to access the proposed project’s facility.

Based on the assumptions described below, estimated noise levels were then compared to applicable criteria to determine if noise from the proposed facility would exceed the City’s noise goals (described above) at adjacent residences.
14 Table 12-2, Transit Noise and Vibration Impact Assessment, United States Department of Transportation, Office of Planning and Environment, Federal Transit Administration, May 2006. 15 Using a value of n = 1.5 per FTA recommendation, where n is the attenuation rate through the ground

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Traffic volumes produced by the proposed project were provided by TJKM in December 2023. Their study estimated that a total of 213 truck trips
16 would occur at the facilities throughout the 24 hours of operation. Overton Moore Properties provided further details about the potentially likely distribution of those trucks each hour throughout the 24-hour operation period.

Intra-Project Traffic Analysis Methodology
Intra-project traffic noise will consist of traffic noise associated with future warehouse employee vehicles within the designated parking lots. To estimate vehicle noise at the employee parking lots, we referenced the TJKM provided traffic volumes for the proposed project.

1. Trucks will enter and exit the site from Atlantis Court and Challenger Street, from the north (via Discovery Drive).

3. An average truck trip (not including unloading/loading) is estimated to last for a cumulative period of about 2 minutes and be at least 1025 feet from the nearest residential property line.

4. Trucks occupy the loading dock in their loading area that is nearest to noise-sensitive receiver (Residents across Isabel Avenue, to the east of the building).

5. Total number of loading docks: 130 (68 in Building 1 and 62 in Building 2)

6. Number and distribution of truck trips is based on TJKM’s traffic study estimate, with approximately 213 total truck trips per 24-hour period (continuous 24/7 operation) distributed as follows:
● AM Peak is 7-9 AM – 9.4%
● 9-4 PM – 42.7%
● PM Peak is 4 PM - 6 PM – 12.7%
● 6 PM - 10 PM – 16.4%
● 10 PM - 7 AM – 18.8%
16 Email correspondence provided on 12/20/23 confirmed the 213 daily truck trips as 20% of total vehicle trips based in ITE data (TJKM Study)

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7. Building 2 provides substantial acoustical shielding for most of Building 1 and its operations to the eastern residents. Because of this, Building 1 is not expected to have a meaningful impact on the residential receivers’ sound environment to the east.

8. Loading docks in Building 2 are located on the north and south facades, configured to maintain the maximum possible distance away from the residential area to the east.

9. North-facing docks of Building 2 will have a direct line-of-sight to the warehouse to the north. We assume that some shielding is provided by the perpendicular orientation of the docks of Building 1, which would slightly reduce our overall calculated noise contribution of the loading docks to the northern warehouse receivers because of the partial line-of-sight.

10. 24-hour operation assumed.

11. Loading docks not in use on each building have closed doors.

12. A typical truck “trip” consists of the following events (estimated sound levels based on aforementioned measurements at similar facilities):
a. Truck passby (arrival, departure at slow speed): 69 dBA at 30 feet b. Truck airbrakes: 72 dBA at 25 feet
c. Truck backup alarm: 79 dBA at 30 feet
d. Brief idle before engine shutoff: 70 dBA at 25 feet
e. Truck engine ignition and airbrakes: 71 dBA at 25 feet f. Truck accelerating from stop: 74 dBA at 25 feet
g. Truck noise source reference heights17 (above grade) i. Passby, brief idle, acceleration, and ignition: 8 feet ii. Back-up beeper and airbrake: 2.5 feet
iii. Topographical site analysis included in Section C3.1 of the Grading and Drainage Plan show potential terrain shielding of about three feet between the dock elevation and receivers to the east of Isabel Avenue
Intra-Project Traffic Noise
Our analysis estimated future noise from the facility parking lots is based on the following assumptions:

1. Employees will enter and exit the site from Atlantis Court and Challenger Street, from the north (via Discovery Drive).

2. Once on site, vehicles will move at 15 miles per hour or less.

3. Vehicles will be spread out evenly amongst the seven parking areas. 17 Truck source heights excerpted from Caltrans Technical Noise Supplement document (TeNS) document dated October 1998.

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4. An average vehicle trip is estimated to last for a cumulative period of about 2 minutes and be at least 550 feet from the nearest residential property line.

5. Similar proportional percentages were assumed for vehicle trips in the project parking lots as were the truck trips, as shown in the distribution below.
● AM Peak is 7 AM - 9 AM- 9.4%
● 9 AM – 4 PM -42.7%
● PM Peak is 4 PM -6 PM -12.7%
● 7 PM - 10 PM 16.4%
● 10 PM - 7 AM 18.8%
Estimated Future Noise Levels
Future Average Noise Levels (CNEL/DNL)
We estimated noise levels at local receptors from the sources described in the previous section. To account for future increases in local traffic noise levels (growth in traffic on Isabel Avenue and other local roadways), we added 1 dB DNL to the measured levels18 (see Table 4 above).

We calculated the acoustical impact of project traffic increase due to both projects SMP-39 and SMP-40 with the provided peak hour traffic volumes for the cumulative without project and cumulative with project scenarios. The analysis used the FHWA-RD-77-108 traffic noise calculation model. The figures below show the various calculations for the intersections of interest (i.e., 5, 9, 10, and 11) as provided to us via the traffic volume study developed for both SMP-39 and SMP-40.

Figure A: Intersection Map Legend
18 The California Department of Transportation assumes a traffic volume increase of three-percent per year, which corresponds to a 1 dBA increase in DNL over a ten-year period.

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Figure B: Traffic Volume Analysis for Intersection 5
Figure C: Traffic Volume Analysis for Intersection 9

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Figure D: Traffic Volume Analysis for Intersection 10
Figure E: Traffic Volume Analysis for Intersection 11
As shown above, the increase in traffic due to the project would be approximately 1 to 2 dBA to the DNL when combined.

Table 10 below summarizes the estimated DNL levels at the closest property plane to the east of the building, under the assumption that the facility would receive its trucking and commuting employee activities during the 24 hours of operation.

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Table 10: Calculated 24-Hour Future Facility Noise at Nearest Noise-Sensitive Land Uses: CNEL/DNL, dBA Nearby Receiving
Locations
Existing Noise
at Receiver
(Residences)
Loading
Docks at
Receiver
Intra-Project
Traffic Noise
Levels at
Receiver
Combined
Existing
plus
Project
Change
(dBA)
East Property Line
(Residences
across Isabel)
67 60 32 69 +2
North Property
Line (Neighboring
Warehouse)
65 65 36 68 +3
The calculated increase in DNL at the residential property line with the project and future traffic noise levels (near term 2025) will be approximately 2 dB. At the northern industrial uses, a DNL 3 dB change is predicted. A change of 3 dB or less is not expected to be noticeable and is not considered significant.

Our calculations of maximum noise levels assume that the trucks operating at the closest docks to the residences will be active at the same proportion as stated above. The noise analysis also assessed the increase in traffic noise levels resulting from project traffic in combination with future traffic noise level increases on the surrounding roadway network resulting from other anticipated development in the region. The resultant cumulative increase is 3 dB. This would not be considered a significant increase to the predicted project operation noise environment.

Future L50Noise Levels
The following assumptions were made about the 24-hour operation of the project in our estimated L50 calculations:
● The volume of expected truck trips is consistent with the truck trip distribution established in item 6 of the Noise Source Analysis and Assumptions section (i.e., a maximum of 5 trucks per hour at nighttime, or 18.8% of trucks between 10:00 pm and 7:00 am). ● The 6- and 10-foot berms will be incorporated into the project. ● Backup alarms are expected to be at a height of approximately 2.5 feet. ● Trucks do not move great distances when their backup alarm is engaged.

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Table 11: Calculated 24-Hour Future Facility L50 Value: L50, dBA Time of Day Estimated L50 Value Criterion L50 Value
Daytime (7am-10pm) 50 dBA 55 dBA
Nighttime (10pm-7am) 45 dBA 50 dBA
Although our calculations of overall operational L50 noise levels do not exceed the allowable values stated by the City (i.e., Policy P1, Objective N-1.5), backup alarm noise may be audible at residences to the east during quieter nighttime hours. It is our understanding that other current similar projects in the vicinity have caused local neighbor complaints due to trucks’ back-up alarms at those locations in the past.

Calculations assumed the source height of these backup alarms to be approximately 2.5 feet from grade.

The incorporation of the proposed 6- and 10-foot-tall berms would adequately obstruct the direct line-ofsight of these backup alarms to the residential receivers. The dimensions of the proposed berms are calculated to reduce intermittent noise levels (such as those produced by backup alarms) by up to 6 dB at the closest residents.

CONCLUSIONS AND COMMENTS

1. Future cumulative project site noise from rooftop HVAC equipment, loading dock-generated noise, stationary trucks, and employee vehicles, is not expected to significantly impact receivers to the east or to the north. The calculated increase in CNEL/DNL for the warehouse receivers to the north will be 3 dB, while the closest residential receivers across Isabel Avenue will have a 2dB increase from the existing environment under the expected 24-hour operations.

A change of 3 dB or less is not considered significant for residents to the east or the commercial neighbors to the north of the project site. A cumulative DNL of 69 dB for the receivers does not exceed the industrial 75 dB DNL threshold defined in Table 9-7 of the Livermore Noise Element as well as the L50 level from Objective N-1.5 of the General Plan.

Considering the 1,025-foot distance between the nearest loading dock and the closest residents, and the trucks being a stationary source rather than a moving vehicle once the leaving the loading dock area of the project site, the city's L50 criterion is not applicable once a truck begins moving closer to the residential area. Given the minority of expected project truck trips conducted in the nighttime

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hours (less than 5 trips per hour on average from 10 PM to 7 AM), noise from stationary trucks at the nearest loading dock are expected to comply with the City’s L50 nighttime requirement assuming backup alarms are not continuously operating for more than 30 minutes per hour.

2. Temporary construction noise will impact the residences, and thus, it will be necessary to incorporate mitigation measures such as a 10-foot-tall berm or barrier on the east side of the project to reduce the noise by 10 dB.

3. It is our understanding that there are no State or Federal requirements for noise levels of backup alarms except for OSHA, which only requires them to be “significantly louder” than the surrounding environment. Because the background noise levels around most facilities are not known, manufacturers typically increase the alarm volume to compensate.

Best practices to reduce alarm audibility at the facility to be evaluated would be to require users to limit alarm volume levels, employ signal personnel, lights, and other means to notify people about ongoing truck activities within the facility.
* * *
Cc: Jennifer Freedman ([email protected])

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APPENDIX A: FUNDAMENTAL CONCEPTS OF ENVIRONMENTAL NOISE This section provides background information to aid in understanding the technical aspects of this report.

Many rating methods have been devised to permit comparisons of sounds having quite different spectra.

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identifiable noisy events of brief duration. These may include nearby activities such as single vehicle passbys, aircraft flyovers, etc. which cause the environmental noise level to vary from instant to instant.

To describe the time-varying character of environmental noise, statistical noise descriptors were developed. "L10" is the A-weighted sound level equaled or exceeded during 10 percent of a stated time period. The L10 is considered a good measure of the maximum sound levels caused by discrete noise events. "L50" is the A-weighted sound level that is equaled or exceeded 50 percent of a stated time period; it represents the median sound level. The "L90" is the A-weighted sound level equaled or exceeded during 90 percent of a stated time period and is used to describe the background noise.

For highway noise environments, the average noise level during the peak hour traffic volume is approximately equal to the Ldn.

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With regard to increases in noise level, knowledge of the following relationships will be helpful in understanding the quantitative sections of this report:

Except in carefully controlled laboratory experiments, a change of only 1 dBA in sound level cannot be perceived. Outside of the laboratory, a 3 dBA change is considered a just-noticeable difference. A change in level of at least 5 dBA is required before any noticeable change in community response would be expected. A 10 dBA change is subjectively heard as approximately a doubling in loudness, and would almost certainly cause an adverse community response.

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A1
A1

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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
In addition to the letters that were provided responses in the “Responses to Comments Received After the Close of the Draft Environmental Impact Report Public Review Period and Erratum”, as well as the “Supplemental Responses to Comments Received After the Close of the Draft Environmental Impact Report Public Review Period and Erratum” dated March 4, 2024, the City received four subsequent comment letters in regard to the proposed project. Written comments were received from the following entities:

Date Commenter
3/5/2024 Grace Holbrook, Attorneys for Carpenters Local 713 (1) 3/5/2024 Grace Holbrook, Attorneys for Carpenters Local 713 (2) N/A Pete Sheehan, Golden State Environmental Justice Alliance 3/5/2024 Margaret R. Akerblom, Allen Matkins Leck Gamble Mallory & Natsis LLP 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 comment letters, which are 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 Grace Holbrook, Attorneys for Carpenters Local 713 (1) The majority of the comment letter, including the entirety of Comment I and Comment II within the comment letter, is identical to the comment letter dated February 14, 2024 submitted by Attorneys for Carpenters Local 713 and responded to in the “Supplemental Responses to Comments Received After the Close of the Draft Environmental Impact Report Public Review Period and Erratum” dated March 4, 2024. As such, with regard to Comment I and Comment II included in the comment letter, please see the “Supplemental Responses to Comments Received After the Close of the Draft Environmental Impact Report Public Review Period and Erratum.” The only new comment included in the letter is Comment III related to certification/recirculation of the Final EIR. See the response provided below regarding certification/recirculation of the EIR.

As discussed above, CEQA does not require that written responses be provided for letters received after the close of the public review period. Nonetheless, the City has voluntarily provided written responses to all letters submitted by the commenter, including those received after the close of the Draft EIR public review period, and has addressed all environmental issues mentioned in the comment letters. The commenter does not provide any justification to support their claim that “the City provided inadequate responses” to their concerns.

Response to Grace Holbrook, Attorneys for Carpenters Local 713 (2) As clearly stated in the in the “Supplemental Responses to Comments Received After the Close of the Draft Environmental Impact Report Public Review Period and Erratum” dated March 4, 2024, under Laurel Heights Improvement Ass’n v Regents of Univ. of Cal. (1993) 6 C4th 1112

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(Laurel Heights II) and Section 15088.5 of the State CEQA Guidelines,1 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.

The revisions made to the Draft EIR in response to 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. Specifically, in the case of the proposed project, while revisions were made to Chapter 4.6, Noise, of the Draft EIR, 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 impact related to noise has not been identified in response to public comments. In addition, the revisions did not find that the Draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded. Therefore, recirculation of the EIR related to criteria 1, 2, or 4, described above, is not required.

With regard to criterion 3, while a new construction noise mitigation measure (Mitigation Measure

4.6-1[a]) has been added in response to public comments, the measure is feasible and would clearly lessen the potential environmental impact to a less-than-significant level. 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. Furthermore, the applicant has agreed to adopt Mitigation Measure 4.6-1(a). Thus, according to Section 15188.5(a)(3), recirculation is not required.

The written responses to comments received after the close of the Draft EIR public review period, as well as the associated errata showing further revisions to the Draft EIR text since the Final EIR was released, are included in the record and considered part of the EIR. As stated in the Findings, Facts in Support of Findings, and Statement of Overriding Considerations prepared for the proposed project, the Draft EIR, Final 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.
1 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.

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It should also be noted that, while the commenter states that, “the Planning Commission must not certify the Final EIR until, at a minimum, the document reflects the most up-to-date version,” the Planning Commission is not charged with certifying the Final EIR. Rather, the Planning Commission’s action related to the CEQA document for the proposed project is whether or not to recommend that City Council adopt a resolution certifying the Final EIR. The City Council has the decision-making authority on the proposed project.

Response to Pete Sheehan, Golden State Environmental Justice Alliance The comment letter does not provide any new information or comments beyond the comment letter dated October 13, 2023, submitted by Golden State Environmental Justice Alliance during the Draft EIR comment period, to which the City provided responses in the Final EIR. As such, with regard to the comments and information included in this subsequent comment letter, please see Response to Comment 6-8 included on page 2-105 of the Final EIR. As stated therein, the commenter’s concerns and information appear to be related to environmental justice; however, CEQA Guidelines Appendix G does not include a section specifically dedicated to the topic of environmental justice. In addition, the analysis of potential health effects of criteria pollutants is discussed under Impact 4.2-6 of the Draft EIR, which begins on page 4.2-54. The Draft EIR also includes an evaluation of aggregate total health risks in the Air Quality, Greenhouse Gas Emissions, and Energy chapter, starting on page 4.2-58. As detailed therein, in accordance with Bay Area Air Quality Management District (BAAQMD) Air Quality Guidelines, an analysis of all known sources of toxic air contaminants (TACs) within a 1,000-foot radius of the project site boundary was conducted, in conjunction with health risks associated with the proposed project, and compared to the applicable BAAQMD thresholds of significance. As shown in Table 4.2-12 of the Draft EIR on page 4.2-58, the evaluation included a quantitative analysis of health risks associated with heavy-duty truck operations, emergency generators, and vehicles traveling along Isabel Avenue/SR 84. The Draft EIR concludes that the proposed project would not cause an aggregate total increase in cancer risk levels of more than 100 persons in one million, a chronic non-cancer hazard index greater than 10.0, or result in an annual average concentration of 0.8 micrograms per cubic meter (µg/m3
) or greater of particulate matter 2.5 micrometers in diameter (PM2.5), and a less-than-significant impact would occur.

Furthermore, the Draft EIR notes in several instances throughout Chapter 4.2, Air Quality, Greenhouse Gas Emissions, and Energy, that the San Francisco Bay Area Air Basin is designated as nonattainment for State and federal eight-hour ozone and State PM10 ambient air quality standards (AAQS). The BAAQMD’s thresholds of significance for CEQA review were established with consideration given to the health-based AAQS and are designed to aid the BAAQMD in implementing the applicable attainment plans to achieve attainment of the AAQS.2 Response to Margaret R. Akerblom, Allen Matkins Leck Gamble Mallory & Natsis LLP The provision of safety features and fencing along the proposed trail are not a CEQA issue. The proposed trail would be constructed in accordance with all applicable City standards, including those set forth within Chapter 12, Parks and Trails, of the City of Livermore Design Standards and Guidelines, and all additional design standards included in the proposed SMP 40 Development Agreement. The proposed trail design is conceptual at this time. The City will review the final design of the trail to ensure consistency with all applicable standards. To assume that the public would leave the Zone 7 portion of the proposed trail and enter the Arroyo Mocho or the adjacent mining properties, or that doing so would create a substantial public safety hazard, is speculative. The comment is noted for the record and will be forwarded to the decision-makers for their consideration.
2 Bay Area Air Quality Management District. Air Quality Guidelines [pg. 5-10]. April 2023.

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Additional Staff-Initiated Changes
Based on comments received by the Planning Commission during the March 5, 2024 public hearing on the proposed project, the following additional staff-initiated changes have been made to Mitigation Measure 4.8-3 of the Draft EIR:

4.8-3 Prior to the issuance of the first building permit, the project applicant shall be required to develop a Transportation Demand Management (TDM) Program for SMP 39 and SMP 40. The TDM Program shall be monitored by the project applicant/operator on an annual basis to determine the efficacy of the selected TDM strategies in achieving the reduction below the regional average VMT per employee of three percent (i.e., the performance target). An Annual Status Report on the TDM Program shall be submitted to the City of Livermore Engineering Division beginning a year after the issuance of any certificate of occupancy and shall include details on the TDM strategies, including an Employer Carpool Program which has a goal to reduce VMT per employee by approximately four percent and, thus, would meet and exceed the performance target. The Employer Carpool Program shall implement a ridesharing program and establish a permanent transportation management association with funding requirements for employers. Data shall be collected in October of each year and the Annual Status Report shall be submitted by December 31st of each year. The report shall be prepared in the form and format designated by the City. The data shall include project-generated VMT estimates compatible with the methodology used to estimate the benchmark VMT so that performance comparisons can be made. If the Annual Status Report demonstrates that the project is not in compliance with the performance target set forth in this mitigation measure, the project must incorporate additional TDM strategies to meet the performance target in coordination with City staff. The project applicant/operator may propose new TDM strategies that develop over time to further reduce project-generated VMT if substantial evidence is provided to support the efficacy of the strategy. If the Annual Status Reports demonstrate that the performance target has been achieved for three five consecutive years once SMP 39 and SMP 40 are both fully occupied and operational, the project shall no longer need to provide annual reporting. The five-year reporting requirement shall reset when a new use occupies any portion of the SMP 39 or SMP 40 property.

The foregoing revisions are for clarification purposes and do not change the conclusions of the Draft EIR. In addition, the applicant has agreed to the foregoing changes to Mitigation Measure

4.8-3.

The MMRP, as well as the Findings, Facts in Support Of Findings, and Statement Of Overriding Considerations, have been updated to reflect all changes made to the Draft EIR text since the close of the Draft EIR public review period, and are included in the staff report packet for the City Council hearing on the proposed project.

Attachments
Attachment 1 – Comment Letters

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Attachment 1
Comment Letters

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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 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

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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. THE CITY SHOULD REQUIRE THE USE OF A LOCAL
WORKFORCE TO BENEFIT THE COMMUNITY’S ECONOMIC

DEVELOPMENT AND ENVIRONMENT

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The City should require the Project to be built using local workers who have graduated from a Joint Labor-Management Apprenticeship Program and make a commitment to hiring a local workforce.

Community benefits such as local hire can also be helpful to reduce environmental impacts and improve the positive economic impact of the Project. Local hire provisions requiring that a certain percentage of workers reside within 10 miles or less of the Project site can reduce the length of vendor trips, reduce greenhouse gas emissions, and provide localized economic benefits. As environmental consultants Matt Hagemann and Paul E. Rosenfeld note:
[A]ny local hire requirement that results in a decreased worker trip length from the default value has the potential to result in a reduction of construction-related GHG emissions, though the significance of the reduction would vary based on the location and urbanization level of the project site.

March 8, 2021 SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and Considerations for Greenhouse Gas Modeling.

Workforce requirements promote the development of skilled trades that yield sustainable economic development. As the California Workforce Development Board and the University of California, Berkeley Center for Labor Research and Education concluded:
[L]abor should be considered an investment rather than a cost—and investments in growing, diversifying, and upskilling California’s workforce can positively affect returns on climate mitigation efforts. In other words, well-trained workers are key to delivering emissions reductions and moving California closer to its climate targets.1
Furthermore, workforce policies have significant environmental benefits given that they improve an area’s jobs-housing balance, decreasing the amount and length of job commutes and the associated greenhouse gas (GHG) emissions. In fact, on May 7, 1 California Workforce Development Board (2020) Putting California on the High Road: A Jobs and Climate Action Plan for 2030 at p. ii, available at https://laborcenter.berkeley.edu/ wp-content/uploads/2020/09/Putting-California-on-the-High-Road.pdf.

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2021, the South Coast Air Quality Management District found that that the “[u]se of a local state-certified apprenticeship program” can result in air pollutant reductions.2

Locating jobs closer to residential areas can have significant environmental benefits.

As the California Planning Roundtable noted in 2008:

People who live and work in the same jurisdiction would be more likely to take transit, walk, or bicycle to work than residents of less balanced communities and their vehicle trips would be shorter. Benefits would include potential reductions in both vehicle miles traveled and vehicle hours traveled.3
Moreover, local hire mandates and skill-training are critical facets of a strategy to reduce vehicle miles traveled (VMT). As planning experts Robert Cervero and Michael Duncan have noted, simply placing jobs near housing stock is insufficient to achieve VMT reductions given that the skill requirements of available local jobs must match those held by local residents.4 Some municipalities have even tied local hire and other workforce policies to local development permits to address transportation issues. Cervero and Duncan note that:

In nearly built-out Berkeley, CA, the approach to balancing jobs and housing is to create local jobs rather than to develop new housing. The city’s First Source program encourages businesses to hire local residents, especially for entry- and intermediate-level jobs, and sponsors vocational training to ensure residents are employment-ready. While the program is voluntary, some 300 businesses have used it to date, placing more than 3,000 city residents in local jobs since it was launched in 1986. When needed, these carrots are matched by sticks, since the city is not shy about 2 South Coast Air Quality Management District (May 7, 2021) Certify Final Environmental Assessment and Adopt Proposed Rule 2305 – Warehouse Indirect Source Rule – Warehouse Actions and Investments to Reduce Emissions Program, and Proposed Rule 316 – Fees for Rule 2305, Submit Rule 2305 for Inclusion Into the SIP, and Approve Supporting Budget Actions, available at http://www.aqmd.gov/docs/default-source/Agendas/Governing-Board/2021/2021- May7-027.pdf?sfvrsn=10. 3
California Planning Roundtable (2008) Deconstructing Jobs-Housing Balance at p. 6, available at https://cproundtable.org/static/media/uploads/publications/cpr-jobs-housing.pdf 4 Cervero, Robert and Duncan, Michael (2006) Which Reduces Vehicle Travel More: Jobs-Housing Balance or Retail-Housing Mixing? Journal of the American Planning Association 72 (4), 475-490, 482, available at http://reconnectingamerica.org/assets/Uploads/UTCT-825.pdf.

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negotiating corporate participation in First Source as a condition of approval for development permits.

Recently, the State of California verified its commitment towards workforce development through the Affordable Housing and High Road Jobs Act of 2022, otherwise known as Assembly Bill No. 2011 (“AB2011”). AB2011 amended the Planning and Zoning Law to allow ministerial, by-right approval for projects being built alongside commercial corridors that meet affordability and labor requirements.

The City should consider utilizing local workforce policies and requirements to benefit the local area economically and to mitigate greenhouse gas, improve air quality, and reduce transportation impacts.

II. THE PROJECT WOULD BE APPROVED IN VIOLATION OF THE

CALIFORNIA ENVIRONMENTAL QUALITY ACT
A. Background Concerning the California Environmental Quality Act The California Environmental Quality Act is a California statute designed to inform decision-makers and the public about the potential significant environmental effects of a project. 14 California Code of Regulations (“CEQA Guidelines”), § 15002, subd. (a)(1).5 At its core, its purpose is to “inform the public and its responsible officials of the environmental consequences of their decisions before they are made.” Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 564.

1. Background Concerning Environmental Impact Reports
CEQA directs public agencies to avoid or reduce environmental damage, when possible, by requiring alternatives or mitigation measures. CEQA Guidelines, § 15002, subds. (a)(2)-(3); see also Berkeley Keep Jets Over the Bay Committee v. Board of Port Comes (2001) 91 Cal.App.4th 1344, 1354; Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553; Laurel Heights Improvement Assn., 47 Cal.3d at p. 400. The EIR serves to provide public agencies and the public in general with information about the effect that a proposed project is likely to have on the environment and to “identify ways that environmental damage can be avoided or significantly reduced.” CEQA 5 The CEQA Guidelines, codified in Title 14 of the California Code of Regulations, section 15000 et seq., are regulatory guidelines promulgated by the state Natural Resources Agency for the implementation of CEQA. Cal. Pub. Res. Code, § 21083. The CEQA Guidelines are given “great weight in interpreting CEQA except when . . . clearly unauthorized or erroneous.” Center for Biological Diversity v. Dept. of Fish & Wildlife (2015) 62 Cal.4th 204, 217.

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Guidelines, § 15002, subd. (a)(2). If the project has a significant effect on the environment, the agency may approve the project only upon finding that it has “eliminated or substantially lessened all significant effects on the environment where feasible” and that any unavoidable significant effects on the environment are “acceptable due to overriding concerns” specified in Public Resources Code section 21081. See CEQA Guidelines, § 15092, subds. (b)(2)(A)-(B).

While the courts review an EIR using an ‘abuse of discretion’ standard, the reviewing court is not to uncritically rely on every study or analysis presented by a project proponent in support of its position. Berkeley Jets, 91 Cal.App.4th at p. 1355 (quoting Laurel Heights Improvement Assn., 47 Cal.3d at pp. 391, 409 fn. 12) (internal quotations omitted). A clearly inadequate or unsupported study is entitled to no judicial deference. Id. Drawing this line and determining whether the EIR complies with CEQA’s information disclosure requirements presents a question of law subject to independent review by the courts. Sierra Club v. County of Fresno (2018) 6 Cal.5th 502, 515; Madera Oversight Coalition, Inc. v. County of Madera (2011) 199 Cal.App.4th 48, 102, 131. As the court stated in Berkeley Jets, prejudicial abuse of discretion occurs if the failure to include relevant information precludes informed decision-making and informed public participation, thereby thwarting the statutory goals of the EIR process. 91 Cal.App.4th at p. 1355 (internal quotations omitted).

The preparation and circulation of an EIR is more than a set of technical hurdles for agencies and developers to overcome. Communities for a Better Environment v. Richmond (2010) 184 Cal.App.4th 70, 80 (quoting Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho Cordova (2007) 40 Cal.4th 412, 449-450). The EIR’s function is to ensure that government officials who decide to build or approve a project do so with a full understanding of the environmental consequences and, equally important, that the public is assured those consequences have been considered. Id. For the EIR to serve these goals it must present information so that the foreseeable impacts of pursuing the project can be understood and weighed, and the public must be given an adequate opportunity to comment on that presentation before the decision to go forward is made. Id.

A strong presumption in favor of requiring preparation of an EIR is built into CEQA.

This presumption is reflected in what is known as the “fair argument” standard under which an EIR must be prepared whenever substantial evidence in the record supports a fair argument that a project may have a significant effect on the environment. Quail

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Botanical Gardens Found., Inc. v. City of Encinitas (1994) 29 Cal.App.4th 1597, 1602; Friends of “B” St. v. City of Hayward (1980) 106 Cal.3d 988, 1002.

The fair argument test stems from the statutory mandate that an EIR be prepared for any project that “may have a significant effect on the environment.” PRC, § 21151; see No Oil, Inc. v. City of Los Angeles (1974) 13 Cal.App.3d 68, 75; accord Jensen v. City of Santa Rosa (2018) 23 Cal.App.5th 877, 884. Under this test, if a proposed project is not exempt and may cause a significant effect on the environment, the lead agency must prepare an EIR. PRC, §§ 21100 (a), 21151; CEQA Guidelines, § 15064 (a)(1), (f)(1).

An EIR may be dispensed with only if the lead agency finds no substantial evidence in the initial study or elsewhere in the record that the project may have a significant effect on the environment. Parker Shattuck Neighbors v. Berkeley City Council (2013) 222 Cal.App.4th 768, 785. In such a situation, the agency must adopt a negative declaration. PRC, § 21080, subd. (c)(1); CEQA Guidelines, §§ 15063 (b)(2), 15064(f)(3).
“Significant effect upon the environment” is defined as “a substantial or potentially substantial adverse change in the environment.” PRC, § 21068; CEQA Guidelines, § 15382. A project may have a significant effect on the environment if there is a reasonable probability that it will result in a significant impact. No Oil, Inc., 13 Cal.3d at p. 83 fn. 16; see Sundstrom v. County of Mendocino (1988) 202 Cal.App.3d 296, 309. If any aspect of the project may result in a significant impact on the environment, an EIR must be prepared even if the overall effect of the project is beneficial. CEQA Guidelines, § 15063(b)(1); see County Sanitation Dist. No. 2 v. County of Kern (2005) 127 Cal.App.4th 1544, 1580.

This standard sets a “low threshold” for preparation of an EIR. Consolidated Irrigation Dist. v. City of Selma (2012) 204 Cal.App.4th 187, 207; Nelson v. County of Kern (2010) 190 Cal.App.4th 252; Pocket Protectors v. City of Sacramento (2004) 124 Cal.App.4th 903, 928; Bowman v. City of Berkeley (2004) 122 Cal.App.4th 572, 580; Citizen Action to Serve All Students v. Thornley (1990) 222 Cal.App.3d 748, 754; Sundstrom, 202 Cal.App.3d at p. 310. If substantial evidence in the record supports a fair argument that the project may have a significant environmental effect, the lead agency must prepare an EIR even if other substantial evidence before it indicates the project will have no significant effect. See Jensen, 23 Cal.App.5th at p. 886; Clews Land & Livestock v. City of San Diego (2017) 19 Cal.App.5th 161, 183; Stanislaus Audubon Society, Inc. v. County of Stanislaus (1995) 33 Cal.App.4th 144, 150; Brentwood Assn. for No Drilling, Inc. v. City of

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Los Angeles (1982) 134 Cal.App.3d 491; Friends of “B” St., 106 Cal.App.3d 988; CEQA Guidelines, § 15064(f)(1).

B. The Project May Have a Significant Impact on Biological Resources There is substantial evidence the Project will have a significant impact on biological resources. As discussed in further detail in a comment letter from biological resources expert Shawn Smallwood, PhD with regards to the proposed Project, incorporated by reference herein, “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.” (See Exhibit D [December 12, 2023 comment letter from Shawn Smallwood, PhD regarding SMP 38, SMP 39, and SMP 40 biological resources analysis].)
First, for example, with regards to the potential for habitat loss, Dr. Smallwood predicts:

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, ad SMP 40, on 204.6 would eliminate 2,332 nest sites.
(Exhibit D, p. 28.)
Accordingly, Dr. Smallwood points out that this loss in nest sites would constitute a significant impact from the Project that was not quantitatively addressed in the Draft EIR. (Exhibit D, p. 28.) Further, Dr. Smallwood notes that the loss in nests would lead to a loss in the reproductive capacity of the site, thus decreasing the number of birds at the Site over time. (Id.)
Second, Dr. Smallwood discusses the Projects impacts on interference with wildlife movement, highlighting that the DEIR’s analysis of whether the Project will interfere with wildlife movement in the Project Site area is “flawed and misleading.” (Exhibit D, p. 29.) Specifically, Dr. Smallwood states that:

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

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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.
(Exhibit D, p. 29.)
Moreover, Dr. Smallwood points out that the DEIR contains a flawed “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” and notes that the same argument is used for SMP 40. (Id.) However, as Dr. Smallwood notes, the DEIR simply uses speculation here and provides no supporting evidence to this assertion. (Id.)
Third, Dr. Smallwood discusses the Project’s traffic impacts to wildlife, noting that traffic generated from the Project will endanger wildlife that must cross roads used by traffic getting to and from the Project Site. (Exhibit D, p. 30.) Dr. Smallwood discusses traffic-caused wildlife mortality and highlights various traffic mortality numbers collected from a wildlife mortality study performed only eleven (11) miles from the Project Site in the County of Contra Costa. (Id.) Dr. Smallwood concludes an analysis should be done on “whether increased traffic generated by the project site would similarly result in local impacts on wildlife.” (Id. at p. 31.) In addition, the biological impact analysis of the EIR is legally flawed for the following reasons.

First, the DEIR’s biological resources impact analysis relies on multiple inadequate biological field surveys outlined in Appendices D and E of the DEIR prepared by Monk & Associates that are described in insufficient detail.

For example, with regards to the field surveys, the DEIR states that:

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“SMP 39 and SMP 40 were both first surveyed in 2000, with follow-up surveys over the years, including in November 2013, for various development proposals. In addition, a project-specific field survey was conducted on SMP 39 on October 14, 2021, and on SMP 40 on June 10, 2019 to record biological resources within the sites, and to assess the likelihood of resource agency regulated areas to be located within the sites.

An additional survey was conducted for SMP 40 on June 21, 2019 to flag the Arroyo Mocho’s riparian drip line to allow for the project engineers to survey the limits of the riparian vegetation and overlay the area on the project site plan, and another general survey of SMP 40 was conducted on September 10, 2021.”
DEIR, p. 4.3-24. [Emphasis added.’]
However, the DEIR’s reliance on these biological resources field surveys is improper for several reasons.

First, the DEIR and its accompanying Appendices D and E leave out crucial information about the site surveys.

In summarizing the various site surveys that occurred in 2013, 2019, and 2021, DEIR Appendix D’s Biological Resources Analysis (“SMP-39 BRA”) states that “[e]ach site survey involved searching all habitats on the site and recording all plant and wildlife species observed. . . .” and that the “evaluation included an 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 . . .” DEIR Appendix D, p. 2.

Thus, the SMP-39 BRA field surveys seem to indicate that visual inspections were done during these site visits. However, SMP-39 BRA is insufficient for numerous reasons as it leaves out crucial information about the site surveys while relying on the surveys to form conclusions about the Project’s potential biological resources impacts.

As a preliminary matter, one (1) single field survey alone for just the SMP-39 Project Site is insufficient to adequately identify all of the potential habitats and plant and wildlife species occurring within the Project Site, as the site surveys purport to have looked for. In the City’s Final EIR Responses to Comments, Response No. 5-12, the City counters our office’s prior comment that “[o]ne single field survey is sufficient to get a baseline description of a project site’s pant communities and wildlife habitats and to determine if additional surveys for special-status species are necessary.” (FEIR

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Response to Comments, p. 2-75.) However, as Dr. Smallwood notes in his comment letter on the Project, “[m]ore surveys are needed than my two surveys [sic] to inventory use of the project site by wildlife” (Exhibit D, pp. 14-15), that the appropriate detection surveys have not been completed at SMP 39 and SMP 40,” (id. at p. 17), that “[r]econnaissance surveys for wildlife are not designed to detect specialstatus species” indicating that protocol-level detection surveys are appropriate but that Monk & Associates did not perform such detection surveys here, thus rendering the Draft EIR’s “characterization of the existing environmental setting . . . therefore incomplete and inaccurate.” (Id. at p. 19.) Therefore, it is clear that the single survey conducted for SMP-39 is inadequate.

Moreover, the SMP-39 BRA does not specify what time of the day the surveys were conducted during, (DEIR Appendix D, p. 2) which, again, leaves open the possibility that certain species, for example, nocturnal species, could present themselves at different times of the day. This is further highlighted in Dr. Smallwood’s comment letter, where he notes that:

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.
(Exhibit D, p. 16.)
Even further, in one (1) single survey, the surveyor may fail to identify species that would only present themselves during certain times of the year. According to the SMP-39 BRA in Appendix D, for example, the most recent surveys were conducted in June 2019 (a summer month) and October 2021 (a fall month), while failing to account for the spring and winter months. DEIR Appendix D, p. 2. However, there may be certain plant or animal species that would not be identifiable to an observer during the summer or fall months but that could nevertheless be present at the Project Site and be identifiable during other seasons of the year. For example, and as noted by Dr. Smallwood, in response to the DEIR’s assertion that no special-status plants were observed during some of the surveys at the Project Sites during various months over the years, Dr. Smallwood responds that this reporting is misleading

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“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 [California Department of Fish and Wildlife’s (“CDFW”)] (2018) plant survey guidelines. While the FEIR’s Responses to Comments counters our office’s prior comments, asserting that the CDFW’s survey guidelines cited are guidelines for conducting floristic surveys for rare and endangered or other special-status species, the site surveys still failed to meet the CDFW’s minimum plant survey guidelines standards. Thus, new surveys must be conducted that meet these standards.

Therefore, the DEIR’s reliance on surveys not in compliance with California Department of Fish and Wildlife’s survey guidelines6 and its misuse of the California Natural Diversity Database (“CNDD”) resulted in potentially inaccurate determinations. For example, with regards to botanical field surveys, the CDFW’s survey guidelines state that such field surveys should be conducted in a way that will maximize the likelihood of identifying special status plants and sensitive natural communities that may be present at a site.7 Specifically, the guidelines state that “[m]ore than one field visit is usually necessary to adequately capture the floristic diversity of a project area.”8
For each of the foregoing reasons, the Project may have a significant impact on biological resources. Accordingly, the DEIR’s findings as to the Project’s biological impacts are not supported with substantial evidence that is of verifiable or credible value and the DEIR must be revised and recirculated to reassess those impacts, including on the wildlife species with potential to occur on the Project Site using protocol-level detection surveys and describing those surveys with sufficient detail.

C. The Project May Have Significant Noise Impacts.

There is substantial evidence that the Project will have significant traffic impacts. As discussed by Principal Steve Rogers of Steve Rogers Acoustics, “the evaluation of noise impacts during the construction phases is incomplete and contains a significant 6 See, California Natural Resources Agency, Department of Fish and Wildlife Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities, available at https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=18959&inline, pp. 4, 5-6, accessed on Oct. 9, 2023), updated on Feb. 3, 2023; see generally California Department of Fish and Wildlife California Natural Diversity Database, available at https://wildlife.ca.gov/Data/CNDDB/Plantsand-Animals (last visited on Oct. 9, 2023.) 7 California Natural Resources Agency, supra, at p. 4. 8 Id.

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calculation error.” (Exhibit E, p. 3 [December 12, 2023 comment letter re City of Livermore SMP 38/SMP 39/SMP 40 Project Review of DEIR Noise Section & Appendices]), fully incorporated herein.

First, as noted by Mr. Rogers for the DEIR’s construction noise impacts, the DEIR concludes there will be a less than significant impact for on-site construction, but per the DEIR’s analysis, the DEIR fails to adequately support this conclusion for multiple reasons. (Exhibit E, p. 2.) For example, the DEIR fails to include SMP 39’s construction noise impacts in its section 4.6 analysis. (Id.) Second, Mr. Rogers notes that the noise analysis for SMP 40 is incomplete. Specifically, 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.
. . .

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.
(Exhibit E, pp. 2-3.)
Third, Mr. Rogers highlights that there was an error in the calculations for SMP 40 with regards to various construction equipment pieces at a 50-foot distance. (Id.) Lastly, Mr. Rogers states that the construction noise analysis on the east side of the SMP 40 site is overlooked, as it assumes receivers 884 feet away from the equipment, while during other phases of construction, the noisy equipment may be operating closer than 884-feet from nearby residential uses. (Id.) For each of the foregoing reasons, the Project may have a significant noise impact and the EIR should therefore be revised and recirculated.

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III. THE FEIR CANNOT BE CERTIFIED AS THE CITY HAS FAILED

TO RESPOND TO THE ISSUES RAISED BY CARPENTERS LOCAL
713
The City’s argues that recirculation of the EIR is not required as the comments submitted on the FEIR “did not identify any new significant effect, substantial increase in severity of an impact identified in the EIR, or any significant new information.” (Staff Report Exhibit D at 1). However, as reiterated above, numerous substantial issues with the EIR were identified by Carpenters Local 713 in its two prior comment letters. (DEIR Comment Letter, Exhibit F; FEIR Comment Letter, Exhibit G). The City provided inadequate responses to the issues addressed in the DEIR Comment Letter.

Further, despite the City stating that it would provide a response to the FEIR Comment Letter, no such memorandum has been provided prior to the comment deadline for this Planning Commission Hearing. (See Staff Report Exhibit D at 1). As the City has failed to provide responded to the significant issues raised by Carpenters Local 713, the FEIR cannot be certified under CEQA.

IV. CONCLUSION
Based on the foregoing, the City 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
Attached:

March 8, 2021 SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and Considerations for Greenhouse Gas Modeling (Exhibit A); Air Quality and GHG Expert Paul Rosenfeld CV (Exhibit B); Air Quality and GHG Expert Matt Hagemann CV (Exhibit C);

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December 12, 2023 Comment Letter from Biological Resources Expert regarding SMP 38, SMP 39, and SMP 40 Project (Exhibit D); and
December 12, 2023 Comment Letter from Noise Expert Steve Rogers regarding Review of DEIR Noise Section an Appendices (Exhibit E).

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EXHIBIT A

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1 2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
[email protected]
Paul E. Rosenfeld, PhD
(310) 795-2335
[email protected]
March 8, 2021
Mitchell M. Tsai
155 South El Molino, Suite 104
Pasadena, CA 91101
Subject: Local Hire Requirements and Considerations for Greenhouse Gas Modeling Dear Mr. Tsai,
Soil Water Air Protection Enterprise (“SWAPE”) is pleased to provide the following draft technical report explaining the significance of worker trips required for construction of land use development projects with respect to the estimation of greenhouse gas (“GHG”) emissions. The report will also discuss the potential for local hire requirements to reduce the length of worker trips, and consequently, reduced or mitigate the potential GHG impacts.

Worker Trips and Greenhouse Gas Calculations
The California Emissions Estimator Model (“CalEEMod”) is a “statewide land use emissions computer model designed to provide a uniform platform for government agencies, land use planners, and environmental professionals to quantify potential criteria pollutant and greenhouse gas (GHG) emissions associated with both construction and operations from a variety of land use projects.”1 CalEEMod quantifies construction-related emissions associated with land use projects resulting from off-road construction equipment; on-road mobile equipment associated with workers, vendors, and hauling; fugitive dust associated with grading, demolition, truck loading, and on-road vehicles traveling along paved and unpaved roads; and architectural coating activities; and paving.2
The number, length, and vehicle class of worker trips are utilized by CalEEMod to calculate emissions associated with the on-road vehicle trips required to transport workers to and from the Project site during construction.3 1 “California Emissions Estimator Model.” CAPCOA, 2017, available at: http://www.aqmd.gov/caleemod/home. 2 “California Emissions Estimator Model.” CAPCOA, 2017, available at: http://www.aqmd.gov/caleemod/home. 3 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 34.

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2 Specifically, the number and length of vehicle trips is utilized to estimate the vehicle miles travelled (“VMT”) associated with construction. Then, utilizing vehicle-class specific EMFAC 2014 emission factors, CalEEMod calculates the vehicle exhaust, evaporative, and dust emissions resulting from construction-related VMT, including personal vehicles for worker commuting.4
Specifically, in order to calculate VMT, CalEEMod multiplies the average daily trip rate by the average overall trip length (see excerpt below):
“VMTd = Σ(Average Daily Trip Rate i * Average Overall Trip Length i) n Where:
n = Number of land uses being modeled.”5
Furthermore, to calculate the on-road emissions associated with worker trips, CalEEMod utilizes the following equation (see excerpt below):
“Emissionspollutant = VMT * EFrunning,pollutant
Where:

Emissionspollutant = emissions from vehicle running for each pollutant VMT = vehicle miles traveled
EFrunning,pollutant = emission factor for running emissions.” 6 Thus, there is a direct relationship between trip length and VMT, as well as a direct relationship between VMT and vehicle running emissions. In other words, when the trip length is increased, the VMT and vehicle running emissions increase as a result. Thus, vehicle running emissions can be reduced by decreasing the average overall trip length, by way of a local hire requirement or otherwise.

Default Worker Trip Parameters and Potential Local Hire Requirements As previously discussed, the number, length, and vehicle class of worker trips are utilized by CalEEMod to calculate emissions associated with the on-road vehicle trips required to transport workers to and from the Project site during construction.7In order to understand how local hire requirements and associated worker trip length reductions impact GHG emissions calculations, it is important to consider the CalEEMod default worker trip parameters. CalEEMod provides recommended default values based on site-specific information, such as land use type, meteorological data, total lot acreage, project type and typical equipment associated with project type. If more specific project information is known, the user can change the default values and input projectspecific values, but the California Environmental Quality Act (“CEQA”) requires that such changes be justified by substantial evidence.8 The default number of construction-related worker trips is calculated by multiplying the 4 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 14-15. 5 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 23. 6 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 15. 7 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 34. 8 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 1, 9.

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3 number of pieces of equipment for all phases by 1.25, with the exception of worker trips required for the building construction and architectural coating phases.9Furthermore, the worker trip vehicle class is a 50/25/25 percent mix of light duty autos, light duty truck class 1 and light duty truck class 2, respectively.”10 Finally, the default worker trip length is consistent with the length of the operational home-to-work vehicle trips.11 The operational home-to-work vehicle trip lengths are:
“[B]ased on the location and urbanization selected on the project characteristic screen. These values were supplied by the air districts or use a default average for the state. Each district (or county) also assigns trip lengths for urban and rural settings” (emphasis added). 12 Thus, the default worker trip length is based on the location and urbanization level selected by the User when modeling emissions. The below table shows the CalEEMod default rural and urban worker trip lengths by air basin (see excerpt below and Attachment A).13
Worker Trip Length by Air Basin
Air Basin Rural (miles) Urban (miles)
Great Basin Valleys 16.8 10.8
Lake County 16.8 10.8
Lake Tahoe 16.8 10.8
Mojave Desert 16.8 10.8
Mountain Counties 16.8 10.8
North Central Coast 17.1 12.3
North Coast 16.8 10.8
Northeast Plateau 16.8 10.8
Sacramento Valley 16.8 10.8
Salton Sea 14.6 11
San Diego 16.8 10.8
San Francisco Bay Area 10.8 10.8
San Joaquin Valley 16.8 10.8
South Central Coast 16.8 10.8
South Coast 19.8 14.7
Average 16.47 11.17
Minimum 10.80 10.80
Maximum 19.80 14.70
Range 9.00 3.90
9 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 34. 10 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at:
http://www.aqmd.gov/docs/default-source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 15. 11 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at:
http://www.aqmd.gov/docs/default-source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 14. 12 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at:
http://www.aqmd.gov/docs/default-source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 21. 13 “Appendix D Default Data Tables.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/05_appendix-d2016-3-2.pdf?sfvrsn=4, p. D-84 – D-86.

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4 As demonstrated above, default rural worker trip lengths for air basins in California vary from 10.8- to 19.8- miles, with an average of 16.47 miles. Furthermore, default urban worker trip lengths vary from 10.8- to 14.7- miles, with an average of 11.17 miles. Thus, while default worker trip lengths vary by location, default urban worker trip lengths tend to be shorter in length. Based on these trends evident in the CalEEMod default worker trip lengths, we can reasonably assume that the efficacy of a local hire requirement is especially dependent upon the urbanization of the project site, as well as the project location.

Practical Application of a Local Hire Requirement and Associated Impact To provide an example of the potential impact of a local hire provision on construction-related GHG emissions, we estimated the significance of a local hire provision for the Village South Specific Plan (“Project”) located in the City of Claremont (“City”). The Project proposed to construct 1,000 residential units, 100,000-SF of retail space, 45,000-SF of office space, as well as a 50-room hotel, on the 24-acre site. The Project location is classified as Urban and lies within the Los Angeles-South Coast County. As a result, the Project has a default worker trip length of 14.7 miles.14 In an effort to evaluate the potential for a local hire provision to reduce the Project’s construction-related GHG emissions, we prepared an updated model, reducing all worker trip lengths to 10 miles (see Attachment B). Our analysis estimates that if a local hire provision with a 10-mile radius were to be implemented, the GHG emissions associated with Project construction would decrease by approximately 17% (see table below and Attachment C).

Local Hire Provision Net Change
Without Local Hire Provision
Total Construction GHG Emissions (MT CO2e) 3,623
Amortized Construction GHG Emissions (MT CO2e/year) 120.77 With Local Hire Provision
Total Construction GHG Emissions (MT CO2e) 3,024
Amortized Construction GHG Emissions (MT CO2e/year) 100.80 % Decrease in Construction-related GHG Emissions 17%
As demonstrated above, by implementing a local hire provision requiring 10 mile worker trip lengths, the Project could reduce potential GHG emissions associated with construction worker trips. More broadly, any local hire requirement that results in a decreased worker trip length from the default value has the potential to result in a reduction of construction-related GHG emissions, though the significance of the reduction would vary based on the location and urbanization level of the project site.

This serves as an example of the potential impacts of local hire requirements on estimated project-level GHG emissions, though it does not indicate that local hire requirements would result in reduced construction-related GHG emission for all projects. As previously described, the significance of a local hire requirement depends on the worker trip length enforced and the default worker trip length for the project’s urbanization level and location.
14 “Appendix D Default Data Tables.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/05_appendix-d2016-3-2.pdf?sfvrsn=4, p. D-85.

EXHIBIT E
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5 Disclaimer
SWAPE has received limited discovery. Additional information may become available in the future; thus, we retain the right to revise or amend this report when additional information becomes available. Our professional services have been performed using that degree of care and skill ordinarily exercised, under similar circumstances, by reputable environmental consultants practicing in this or similar localities at the time of service. No other warranty, expressed or implied, is made as to the scope of work, work methodologies and protocols, site conditions, analytical testing results, and findings presented. This report reflects efforts which were limited to information that was reasonably accessible at the time of the work, and may contain informational gaps, inconsistencies, or otherwise be incomplete due to the unavailability or uncertainty of information obtained or provided by third parties.

Sincerely,
Matt Hagemann, P.G., C.Hg.

Paul E. Rosenfeld, Ph.D.

EXHIBIT E
2140
Location Type Location Name Rural H-W
(miles)
Urban H-W
(miles)
Air Basin Great Basin 16.8 10.8
Air Basin Lake County 16.8 10.8
Air Basin Lake Tahoe 16.8 10.8
Air Basin Mojave Desert 16.8 10.8
Air Basin Mountain 16.8 10.8
Air Basin North Central 17.1 12.3
Air Basin North Coast 16.8 10.8
Air Basin Northeast 16.8 10.8
Air Basin Sacramento 16.8 10.8
Air Basin Salton Sea 14.6 11
Air Basin San Diego 16.8 10.8
Air Basin San Francisco 10.8 10.8
Air Basin San Joaquin 16.8 10.8
Air Basin South Central 16.8 10.8
Air Basin South Coast 19.8 14.7
Air District Amador County 16.8 10.8
Air District Antelope Valley 16.8 10.8
Air District Bay Area AQMD 10.8 10.8
Air District Butte County 12.54 12.54
Air District Calaveras 16.8 10.8
Air District Colusa County 16.8 10.8
Air District El Dorado 16.8 10.8
Air District Feather River 16.8 10.8
Air District Glenn County 16.8 10.8
Air District Great Basin 16.8 10.8
Air District Imperial County 10.2 7.3
Air District Kern County 16.8 10.8
Air District Lake County 16.8 10.8
Air District Lassen County 16.8 10.8
Air District Mariposa 16.8 10.8
Air District Mendocino 16.8 10.8
Air District Modoc County 16.8 10.8
Air District Mojave Desert 16.8 10.8
Air District Monterey Bay 16.8 10.8
Air District North Coast 16.8 10.8
Air District Northern Sierra 16.8 10.8
Air District Northern

16.8 10.8
Air District Placer County 16.8 10.8
Air District Sacramento 15 10
Attachment A

EXHIBIT E
2141
Air District San Diego 16.8 10.8
Air District San Joaquin

16.8 10.8
Air District San Luis Obispo 13 13
Air District Santa Barbara 8.3 8.3
Air District Shasta County 16.8 10.8
Air District Siskiyou County 16.8 10.8
Air District South Coast 19.8 14.7
Air District Tehama County 16.8 10.8
Air District Tuolumne 16.8 10.8
Air District Ventura County 16.8 10.8
Air District Yolo/Solano 15 10
County Alameda 10.8 10.8
County Alpine 16.8 10.8
County Amador 16.8 10.8
County Butte 12.54 12.54
County Calaveras 16.8 10.8
County Colusa 16.8 10.8
County Contra Costa 10.8 10.8
County Del Norte 16.8 10.8
County El Dorado-Lake 16.8 10.8
County El Dorado- 16.8 10.8
County Fresno 16.8 10.8
County Glenn 16.8 10.8
County Humboldt 16.8 10.8
County Imperial 10.2 7.3
County Inyo 16.8 10.8
County Kern-Mojave 16.8 10.8
County Kern-San 16.8 10.8
County Kings 16.8 10.8
County Lake 16.8 10.8
County Lassen 16.8 10.8
County Los Angeles- 16.8 10.8
County Los Angeles- 19.8 14.7
County Madera 16.8 10.8
County Marin 10.8 10.8
County Mariposa 16.8 10.8
County Mendocino- 16.8 10.8
County Mendocino- 16.8 10.8
County Mendocino- 16.8 10.8
County Mendocino- 16.8 10.8
County Merced 16.8 10.8
County Modoc 16.8 10.8
County Mono 16.8 10.8
County Monterey 16.8 10.8
County Napa 10.8 10.8

EXHIBIT E
2142
County Nevada 16.8 10.8
County Orange 19.8 14.7
County Placer-Lake 16.8 10.8
County Placer-Mountain 16.8 10.8
County Placer- 16.8 10.8
County Plumas 16.8 10.8
County Riverside- 16.8 10.8
County Riverside-

19.8 14.7
County Riverside-Salton 14.6 11
County Riverside-South 19.8 14.7
County Sacramento 15 10
County San Benito 16.8 10.8
County San Bernardino- 16.8 10.8
County San Bernardino- 19.8 14.7
County San Diego 16.8 10.8
County San Francisco 10.8 10.8
County San Joaquin 16.8 10.8
County San Luis Obispo 13 13
County San Mateo 10.8 10.8
County Santa Barbara-

8.3 8.3
County Santa Barbara-

8.3 8.3
County Santa Clara 10.8 10.8
County Santa Cruz 16.8 10.8
County Shasta 16.8 10.8
County Sierra 16.8 10.8
County Siskiyou 16.8 10.8
County Solano- 15 10
County Solano-San 16.8 10.8
County Sonoma-North 16.8 10.8
County Sonoma-San 10.8 10.8
County Stanislaus 16.8 10.8
County Sutter 16.8 10.8
County Tehama 16.8 10.8
County Trinity 16.8 10.8
County Tulare 16.8 10.8
County Tuolumne 16.8 10.8
County Ventura 16.8 10.8
County Yolo 15 10
County Yuba 16.8 10.8
Statewide Statewide 16.8 10.8

EXHIBIT E
2143
Air Basin Rural (miles) Urban (miles)
Great Basin Valleys 16.8 10.8
Lake County 16.8 10.8
Lake Tahoe 16.8 10.8
Mojave Desert 16.8 10.8
Mountain Counties 16.8 10.8
North Central Coast 17.1 12.3
North Coast 16.8 10.8
Northeast Plateau 16.8 10.8
Sacramento Valley 16.8 10.8
Salton Sea 14.6 11
San Diego 16.8 10.8
San Francisco Bay Area 10.8 10.8
San Joaquin Valley 16.8 10.8
South Central Coast 16.8 10.8
South Coast 19.8 14.7
Average 16.47 11.17
Mininum 10.80 10.80
Maximum 19.80 14.70
Range 9.00 3.90
Worker Trip Length by Air Basin

EXHIBIT E
2144

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, Annual
CalEEMod Version: CalEEMod.2016.3.2 Page 1 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual Attachment B

EXHIBIT E
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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.

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
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
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
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EXHIBIT E
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2.0 Emissions Summary
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
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EXHIBIT E
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2.1 Overall 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 N2O CO2e
Year tons/yr MT/yr
2021 0.1713 1.8242 1.1662 2.4000e0030.4169 0.0817 0.4986 0.1795 0.0754 0.2549 0.0000 213.1969 213.1969 0.0601 0.0000 214.6993 2022 0.6904 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721.682 6 1,721.682
6 0.1294 0.0000 1,724.918
7 2023 0.6148 3.3649 5.6747 0.0178 1.1963 0.0996 1.2959 0.3203 0.0935 0.4138 0.0000 1,627.529 5 1,627.529
5 0.1185 0.0000 1,630.492
5 2024 4.1619 0.1335 0.2810 5.9000e0040.0325 6.4700e0030.0390 8.6300e0036.0400e0030.0147 0.0000 52.9078 52.9078 8.0200e0030.0000 53.1082 Maximum 4.1619 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721.682 6 1,721.682
6 0.1294 0.0000 1,724.918
7 Unmitigated Construction
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EXHIBIT E
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2.1 Overall 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 N2O CO2e
Year tons/yr MT/yr
2021 0.1713 1.8242 1.1662 2.4000e0030.4169 0.0817 0.4986 0.1795 0.0754 0.2549 0.0000 213.1967 213.1967 0.0601 0.0000 214.6991 2022 0.6904 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721.682 3 1,721.682
3 0.1294 0.0000 1,724.918
3 2023 0.6148 3.3648 5.6747 0.0178 1.1963 0.0996 1.2959 0.3203 0.0935 0.4138 0.0000 1,627.529 1 1,627.529
1 0.1185 0.0000 1,630.492
1 2024 4.1619 0.1335 0.2810 5.9000e0040.0325 6.4700e0030.0390 8.6300e0036.0400e0030.0147 0.0000 52.9077 52.9077 8.0200e0030.0000 53.1082 Maximum 4.1619 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721.682 3 1,721.682
3 0.1294 0.0000 1,724.918
3 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 Quarter Start Date End Date Maximum Unmitigated ROG + NOX (tons/quarter) Maximum Mitigated ROG + NOX (tons/quarter) 1 9-1-2021 11-30-2021 1.4103 1.4103
2 12-1-2021 2-28-2022 1.3613 1.3613
3 3-1-2022 5-31-2022 1.1985 1.1985
4 6-1-2022 8-31-2022 1.1921 1.1921
5 9-1-2022 11-30-2022 1.1918 1.1918
6 12-1-2022 2-28-2023 1.0774 1.0774
7 3-1-2023 5-31-2023 1.0320 1.0320
8 6-1-2023 8-31-2023 1.0260 1.0260
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EXHIBIT E
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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 tons/yr MT/yr
Area 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 Energy 0.1398 1.2312 0.7770 7.6200e0030.0966 0.0966 0.0966 0.0966 0.0000 3,896.073 2 3,896.073
2 0.1303 0.0468 3,913.283
3 Mobile 1.5857 7.9962 19.1834 0.0821 7.7979 0.0580 7.8559 2.0895 0.0539 2.1434 0.0000 7,620.498 6 7,620.498
6 0.3407 0.0000 7,629.016
2 Waste 0.0000 0.0000 0.0000 0.0000 207.8079 0.0000 207.8079 12.2811 0.0000 514.8354 Water 0.0000 0.0000 0.0000 0.0000 29.1632 556.6420 585.8052 3.0183 0.0755 683.7567 Total 6.8692 9.5223 30.3407 0.0914 7.7979 0.2260 8.0240 2.0895 0.2219 2.3114 236.9712 12,294.18 07 12,531.15
19 15.7904 0.1260 12,963.47
51 Unmitigated Operational
9 9-1-2023 11-30-2023 1.0265 1.0265
10 12-1-2023 2-29-2024 2.8857 2.8857
11 3-1-2024 5-31-2024 1.6207 1.6207
Highest 2.8857 2.8857
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EXHIBIT E
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3.0 Construction Detail
Construction Phase
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- 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 7 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

EXHIBIT E
2151
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
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
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EXHIBIT E
2152
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
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EXHIBIT E
2153

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 tons/yr MT/yr
Fugitive Dust 0.0496 0.0000 0.0496 7.5100e0030.0000 7.5100e0030.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0475 0.4716 0.3235 5.8000e0040.0233 0.0233 0.0216 0.0216 0.0000 51.0012 51.0012 0.0144 0.0000 51.3601 Total 0.0475 0.4716 0.3235 5.8000e0040.0496 0.0233 0.0729 7.5100e0030.0216 0.0291 0.0000 51.0012 51.0012 0.0144 0.0000 51.3601 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 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Site Preparation 7 18.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Grading 8 20.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Building Construction 9 801.00 143.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Paving 6 15.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Architectural Coating 1 160.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod.2016.3.2 Page 10 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

EXHIBIT E
2154

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 tons/yr MT/yr
Hauling 1.9300e0030.0634 0.0148 1.8000e0043.9400e0031.9000e0044.1300e0031.0800e0031.8000e0041.2600e0030.0000 17.4566 17.4566 1.2100e0030.0000 17.4869 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 9.7000e0047.5000e0048.5100e0032.0000e0052.4700e0032.0000e0052.4900e0036.5000e0042.0000e0056.7000e0040.0000 2.2251 2.2251 7.0000e0050.0000 2.2267 Total 2.9000e0030.0641 0.0233 2.0000e0046.4100e0032.1000e0046.6200e0031.7300e0032.0000e0041.9300e0030.0000 19.6816 19.6816 1.2800e0030.0000 19.7136 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 tons/yr MT/yr
Fugitive Dust 0.0496 0.0000 0.0496 7.5100e0030.0000 7.5100e0030.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0475 0.4716 0.3235 5.8000e0040.0233 0.0233 0.0216 0.0216 0.0000 51.0011 51.0011 0.0144 0.0000 51.3600 Total 0.0475 0.4716 0.3235 5.8000e0040.0496 0.0233 0.0729 7.5100e0030.0216 0.0291 0.0000 51.0011 51.0011 0.0144 0.0000 51.3600 Mitigated Construction On-Site
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EXHIBIT E
2155

EXHIBIT E
2156

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 tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 7.7000e0046.0000e0046.8100e0032.0000e0051.9700e0032.0000e0051.9900e0035.2000e0041.0000e0055.4000e0040.0000 1.7801 1.7801 5.0000e0050.0000 1.7814 Total 7.7000e0046.0000e0046.8100e0032.0000e0051.9700e0032.0000e0051.9900e0035.2000e0041.0000e0055.4000e0040.0000 1.7801 1.7801 5.0000e0050.0000 1.7814 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 tons/yr MT/yr
Fugitive Dust 0.1807 0.0000 0.1807 0.0993 0.0000 0.0993 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0389 0.4050 0.2115 3.8000e0040.0204 0.0204 0.0188 0.0188 0.0000 33.4357 33.4357 0.0108 0.0000 33.7060 Total 0.0389 0.4050 0.2115 3.8000e0040.1807 0.0204 0.2011 0.0993 0.0188 0.1181 0.0000 33.4357 33.4357 0.0108 0.0000 33.7060 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 13 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

EXHIBIT E
2157

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 tons/yr MT/yr
Fugitive Dust 0.1741 0.0000 0.1741 0.0693 0.0000 0.0693 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0796 0.8816 0.5867 1.1800e0030.0377 0.0377 0.0347 0.0347 0.0000 103.5405 103.5405 0.0335 0.0000 104.3776 Total 0.0796 0.8816 0.5867 1.1800e0030.1741 0.0377 0.2118 0.0693 0.0347 0.1040 0.0000 103.5405 103.5405 0.0335 0.0000 104.3776 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 14 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

EXHIBIT E
2158

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 tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 1.6400e0031.2700e0030.0144 4.0000e0054.1600e0033.0000e0054.2000e0031.1100e0033.0000e0051.1400e0030.0000 3.7579 3.7579 1.1000e0040.0000 3.7607 Total 1.6400e0031.2700e0030.0144 4.0000e0054.1600e0033.0000e0054.2000e0031.1100e0033.0000e0051.1400e0030.0000 3.7579 3.7579 1.1000e0040.0000 3.7607 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 tons/yr MT/yr
Fugitive Dust 0.1741 0.0000 0.1741 0.0693 0.0000 0.0693 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0796 0.8816 0.5867 1.1800e0030.0377 0.0377 0.0347 0.0347 0.0000 103.5403 103.5403 0.0335 0.0000 104.3775 Total 0.0796 0.8816 0.5867 1.1800e0030.1741 0.0377 0.2118 0.0693 0.0347 0.1040 0.0000 103.5403 103.5403 0.0335 0.0000 104.3775 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 15 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

EXHIBIT E
2159

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 tons/yr MT/yr
Fugitive Dust 0.0807 0.0000 0.0807 0.0180 0.0000 0.0180 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0127 0.1360 0.1017 2.2000e0045.7200e0035.7200e0035.2600e0035.2600e0030.0000 19.0871 19.0871 6.1700e0030.0000 19.2414 Total 0.0127 0.1360 0.1017 2.2000e0040.0807 5.7200e0030.0865 0.0180 5.2600e0030.0233 0.0000 19.0871 19.0871 6.1700e0030.0000 19.2414 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 16 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

EXHIBIT E
2160

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 tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 2.8000e0042.1000e0042.4400e0031.0000e0057.7000e0041.0000e0057.7000e0042.0000e0041.0000e0052.1000e0040.0000 0.6679 0.6679 2.0000e0050.0000 0.6684 Total 2.8000e0042.1000e0042.4400e0031.0000e0057.7000e0041.0000e0057.7000e0042.0000e0041.0000e0052.1000e0040.0000 0.6679 0.6679 2.0000e0050.0000 0.6684 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 tons/yr MT/yr
Fugitive Dust 0.0807 0.0000 0.0807 0.0180 0.0000 0.0180 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0127 0.1360 0.1017 2.2000e0045.7200e0035.7200e0035.2600e0035.2600e0030.0000 19.0871 19.0871 6.1700e0030.0000 19.2414 Total 0.0127 0.1360 0.1017 2.2000e0040.0807 5.7200e0030.0865 0.0180 5.2600e0030.0233 0.0000 19.0871 19.0871 6.1700e0030.0000 19.2414 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 17 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

EXHIBIT E
2161

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 tons/yr MT/yr
Off-Road 0.2158 1.9754 2.0700 3.4100e0030.1023 0.1023 0.0963 0.0963 0.0000 293.1324 293.1324 0.0702 0.0000 294.8881 Total 0.2158 1.9754 2.0700 3.4100e0030.1023 0.1023 0.0963 0.0963 0.0000 293.1324 293.1324 0.0702 0.0000 294.8881 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 18 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

EXHIBIT E
2162

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 tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0527 1.6961 0.4580 4.5500e0030.1140 3.1800e0030.1171 0.0329 3.0400e0030.0359 0.0000 441.9835 441.9835 0.0264 0.0000 442.6435 Worker 0.4088 0.3066 3.5305 0.0107 1.1103 8.8700e0031.1192 0.2949 8.1700e0030.3031 0.0000 966.8117 966.8117 0.0266 0.0000 967.4773 Total 0.4616 2.0027 3.9885 0.0152 1.2243 0.0121 1.2363 0.3278 0.0112 0.3390 0.0000 1,408.795 2 1,408.795
2 0.0530 0.0000 1,410.120
8 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.2158 1.9754 2.0700 3.4100e0030.1023 0.1023 0.0963 0.0963 0.0000 293.1321 293.1321 0.0702 0.0000 294.8877 Total 0.2158 1.9754 2.0700 3.4100e0030.1023 0.1023 0.0963 0.0963 0.0000 293.1321 293.1321 0.0702 0.0000 294.8877 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 19 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

EXHIBIT E
2163

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 tons/yr MT/yr
Off-Road 0.1942 1.7765 2.0061 3.3300e0030.0864 0.0864 0.0813 0.0813 0.0000 286.2789 286.2789 0.0681 0.0000 287.9814 Total 0.1942 1.7765 2.0061 3.3300e0030.0864 0.0864 0.0813 0.0813 0.0000 286.2789 286.2789 0.0681 0.0000 287.9814 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 20 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

EXHIBIT E
2164

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 tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0382 1.2511 0.4011 4.3000e0030.1113 1.4600e0030.1127 0.0321 1.4000e0030.0335 0.0000 417.9930 417.9930 0.0228 0.0000 418.5624 Worker 0.3753 0.2708 3.1696 0.0101 1.0840 8.4100e0031.0924 0.2879 7.7400e0030.2957 0.0000 909.3439 909.3439 0.0234 0.0000 909.9291 Total 0.4135 1.5218 3.5707 0.0144 1.1953 9.8700e0031.2051 0.3200 9.1400e0030.3292 0.0000 1,327.336 9 1,327.336
9 0.0462 0.0000 1,328.491
6 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 tons/yr MT/yr
Off-Road 0.1942 1.7765 2.0061 3.3300e0030.0864 0.0864 0.0813 0.0813 0.0000 286.2785 286.2785 0.0681 0.0000 287.9811 Total 0.1942 1.7765 2.0061 3.3300e0030.0864 0.0864 0.0813 0.0813 0.0000 286.2785 286.2785 0.0681 0.0000 287.9811 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 21 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

EXHIBIT E
2165

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 tons/yr MT/yr
Off-Road 6.7100e0030.0663 0.0948 1.5000e0043.3200e0033.3200e0033.0500e0033.0500e0030.0000 13.0175 13.0175 4.2100e0030.0000 13.1227 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 6.7100e0030.0663 0.0948 1.5000e0043.3200e0033.3200e0033.0500e0033.0500e0030.0000 13.0175 13.0175 4.2100e0030.0000 13.1227 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 22 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

EXHIBIT E
2166

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 tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 3.7000e0042.7000e0043.1200e0031.0000e0051.0700e0031.0000e0051.0800e0032.8000e0041.0000e0052.9000e0040.0000 0.8963 0.8963 2.0000e0050.0000 0.8968 Total 3.7000e0042.7000e0043.1200e0031.0000e0051.0700e0031.0000e0051.0800e0032.8000e0041.0000e0052.9000e0040.0000 0.8963 0.8963 2.0000e0050.0000 0.8968 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 tons/yr MT/yr
Off-Road 6.7100e0030.0663 0.0948 1.5000e0043.3200e0033.3200e0033.0500e0033.0500e0030.0000 13.0175 13.0175 4.2100e0030.0000 13.1227 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 6.7100e0030.0663 0.0948 1.5000e0043.3200e0033.3200e0033.0500e0033.0500e0030.0000 13.0175 13.0175 4.2100e0030.0000 13.1227 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 23 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

EXHIBIT E
2167

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 tons/yr MT/yr
Off-Road 0.0109 0.1048 0.1609 2.5000e0045.1500e0035.1500e0034.7400e0034.7400e0030.0000 22.0292 22.0292 7.1200e0030.0000 22.2073 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0109 0.1048 0.1609 2.5000e0045.1500e0035.1500e0034.7400e0034.7400e0030.0000 22.0292 22.0292 7.1200e0030.0000 22.2073 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 24 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

EXHIBIT E
2168

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 tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 5.9000e0044.1000e0044.9200e0032.0000e0051.8100e0031.0000e0051.8200e0034.8000e0041.0000e0054.9000e0040.0000 1.4697 1.4697 4.0000e0050.0000 1.4706 Total 5.9000e0044.1000e0044.9200e0032.0000e0051.8100e0031.0000e0051.8200e0034.8000e0041.0000e0054.9000e0040.0000 1.4697 1.4697 4.0000e0050.0000 1.4706 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 tons/yr MT/yr
Off-Road 0.0109 0.1048 0.1609 2.5000e0045.1500e0035.1500e0034.7400e0034.7400e0030.0000 22.0292 22.0292 7.1200e0030.0000 22.2073 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0109 0.1048 0.1609 2.5000e0045.1500e0035.1500e0034.7400e0034.7400e0030.0000 22.0292 22.0292 7.1200e0030.0000 22.2073 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 25 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

EXHIBIT E
2169

EXHIBIT E
2170

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 tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0101 6.9900e0030.0835 2.8000e0040.0307 2.3000e0040.0309 8.1500e0032.2000e0048.3700e0030.0000 24.9407 24.9407 6.1000e0040.0000 24.9558 Total 0.0101 6.9900e0030.0835 2.8000e0040.0307 2.3000e0040.0309 8.1500e0032.2000e0048.3700e0030.0000 24.9407 24.9407 6.1000e0040.0000 24.9558 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 tons/yr MT/yr
Archit. Coating 4.1372 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 3.1600e0030.0213 0.0317 5.0000e0051.0700e0031.0700e0031.0700e0031.0700e0030.0000 4.4682 4.4682 2.5000e0040.0000 4.4745 Total 4.1404 0.0213 0.0317 5.0000e0051.0700e0031.0700e0031.0700e0031.0700e0030.0000 4.4682 4.4682 2.5000e0040.0000 4.4745 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Page 27 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

EXHIBIT E
2171

4.0 Operational Detail - Mobile

4.1 Mitigation Measures Mobile

EXHIBIT E
2172
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 1.5857 7.9962 19.1834 0.0821 7.7979 0.0580 7.8559 2.0895 0.0539 2.1434 0.0000 7,620.498 6 7,620.498
6 0.3407 0.0000 7,629.016
2 Unmitigated 1.5857 7.9962 19.1834 0.0821 7.7979 0.0580 7.8559 2.0895 0.0539 2.1434 0.0000 7,620.498 6 7,620.498
6 0.3407 0.0000 7,629.016
2 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 29 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

EXHIBIT E
2173
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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EXHIBIT E
2174
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
Electricity
Mitigated

0.0000 0.0000 0.0000 0.0000 0.0000 2,512.646
5 2,512.646
5 0.1037 0.0215 2,521.635
6 Electricity
Unmitigated

0.0000 0.0000 0.0000 0.0000 0.0000 2,512.646
5 2,512.646
5 0.1037 0.0215 2,521.635
6 NaturalGas
Mitigated

0.1398 1.2312 0.7770 7.6200e0030.0966 0.0966 0.0966 0.0966 0.0000 1,383.426 7 1,383.426
7 0.0265 0.0254 1,391.647
8 NaturalGas
Unmitigated

0.1398 1.2312 0.7770 7.6200e0030.0966 0.0966 0.0966 0.0966 0.0000 1,383.426 7 1,383.426
7 0.0265 0.0254 1,391.647
8 CalEEMod Version: CalEEMod.2016.3.2 Page 31 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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2175

1.30613e
+007

0.0704 0.6018 0.2561 3.8400e0030.0487 0.0487 0.0487 0.0487 0.0000 696.9989 696.9989 0.0134 0.0128 701.1408 General Office
Building
468450 2.5300e0030.0230 0.0193 1.4000e0041.7500e0031.7500e0031.7500e0031.7500e0030.0000 24.9983 24.9983 4.8000e0044.6000e00425.1468 High Turnover (Sit
Down Restaurant)

8.30736e
+006

0.0448 0.4072 0.3421 2.4400e0030.0310 0.0310 0.0310 0.0310 0.0000 443.3124 443.3124 8.5000e0038.1300e003445.9468 Hotel 1.74095e
+006

9.3900e0030.0853 0.0717 5.1000e0046.4900e0036.4900e0036.4900e0036.4900e0030.0000 92.9036 92.9036 1.7800e0031.7000e00393.4557 Quality
Restaurant

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 Unmitigated
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2176

1.30613e
+007

8.30736e
+006

0.0448 0.4072 0.3421 2.4400e0030.0310 0.0310 0.0310 0.0310 0.0000 443.3124 443.3124 8.5000e0038.1300e003445.9468 Hotel 1.74095e
+006

9.3900e0030.0853 0.0717 5.1000e0046.4900e0036.4900e0036.4900e0036.4900e0030.0000 92.9036 92.9036 1.7800e0031.7000e00393.4557 Quality
Restaurant

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
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2177

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
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2178

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
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EXHIBIT E
2179
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
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2180

7.1 Mitigation Measures Water

7.0 Water Detail

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
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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
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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
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2183

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
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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
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2185

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
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2186

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: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

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11.0 Vegetation
Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment
Equipment Type Number
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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
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Project Characteristics - Consistent with the DEIR's model.