Long Beach City Council
February 21, 2023

April 18, 2023

VIA EMAIL:

City Council
c/o City Clerk ([email protected])
Amy Harbin ([email protected])
City of Long Beach
411 W. Ocean Boulevard
Long Beach, CA 90802

RE: Item 25, Link Logistics Warehouse Project (5910 Cherry Avenue); Application No. 2207-30 (SPR22-078); Council File No. 23-0104

Dear Hon. City Council:

This office represents appellants Kirk Davis and Laurie Angel (collectively “Appellants”) in the (“Appeal”) of the City of Long Beach (“City”) Planning Commission approval of a proposed new 303,972 square-foot warehouse (“Project”) at the above-referenced address (“Site”) proposed by Yemi Alade of Link Logistics (“Applicant”).

First, Appellants understand that the Applicant has already withdrawn their application for the Project, thereby revoking the Site Plan Review (“SPR”) entitlement and mooting a need for the Appeal hearing tonight. (See Planning email to Appellants dated April 14, 2023 [attached hereto as Exhibit A].) As such, Appellants have justifiably relied on the City’s position to limit its participation in tonight’s City Council meeting. The City is estopped from changing its position mid-course to resurrect the entitlements and holding an Appeal tonight.1

In the event of any future planning/building permit/entitlement application involving the Site, Appellants respectfully request all notices concerning any land use/zoning actions and/or determinations involving the California Environmental Quality Act (“CEQA”) as required under applicable law. (See e.g., Pub. Res. Code §§ 21092.2, 21167(f); Gov. Code § 65092.) Please send notice by electronic and regular mail to (i) Mr. Davis, (ii) Ms. Angel, and (iii) this office (address already on file).

Out of an abundance of caution, the following comments are provided regarding the now- withdrawn Project, which Appellants ask to be included in the administrative record for the Project.

/ / /

1 See e.g., Shuer v. County of San Diego (2004) 117 Cal.App.4th 476, 487 (“We find, however, that the sum total of county's actions … negligently led [the plaintiff] to conclude that she had no administrative recourse. That being the case, county is estopped from asserting in its demurrer that [the plaintiff] failed to exhaust her administrative remedies.”); Feduniak v. California Coastal Com. (2007) 148 Cal.App.4th 1346, 1372 (“[C]ourts will not hesitate to estop the government from asserting a procedural barrier, such as the statute of limitations or a failure to exhaust remedies, as a defense to claims against it, where the government's affirmative conduct caused the claimant's failure to comply with the procedural requirement.”); J.H. McKnight Ranch, Inc. v. Franchise Tax Bd. (2003) 110 Cal.App.4th 978, 991.

Item 25 RE: Link Logistics Project (Council File No. 23-0104) April 18, 2023

Second, we strongly disagree with the City’s position that the Project is not subject to the CEQA. This position is premised on a novel interpretation of McCorkle Eastside Neighborhood Grp. v. City of St. Helena (2019) 31 Cal. App. 5th 80 (“McCorkle”). Under the Long Beach Municipal Code (“LBMC” or “Code”) § 21.25, SPR clearly includes consideration of environmental impacts under CEQA. (See e.g., Id., subds., .501 [SPR purposes includes “to ensure the maintenance, restoration, enhancement and protection of the environment.” Emphasis added], .506 [findings include issues related to impacts on trees, traffic, green building standards, land use consistency that are relevant to CEQA], .508 [actions by the City include consideration of whether project meets LEED certification], .509 [environmental review for SPR “may” include categorical exemptions].)

Additionally, California courts have held Long Beach’s SPR is a discretionary approval. (See e.g., See Long Beach Sav. & Loan Ass’n v. Long Beach Redevelopment Agency (1986) 188 Cal. App. 3d 249, 263 n.13 (“… site plan review is a discretionary act under CEQA” [citing Pub. Res. Code § 21080].) The fact that the City is proposing conditions to address environmental impacts2 is manifest of the discretionary nature of SPR, whereby the City using its discretion to “use its own judgment … by the public official as to the wisdom or manner of carrying out the project ….” (Protecting Our Water & Envt’l Res. v. County of Stanislaus (2020) 10 Cal.5th 479, 489.) Nor is there any evidence showing any long-held City interpretation that SPR is not subject to CEQA. (See e.g., California Renters Legal Advocacy & Education Fund v. City of San Mateo (2021) 68 Cal.App.5th 820, 843 [principle of deference does not apply where City staff has no consistent interpretation]; Yamaha Corp. of America v. State Bd. of Equalization (1988) 19 Cal.4th 1, 13 [vacillating position warrant no deference].)

Furthermore, McCorkle is entirely distinguishable from the case at bar. While McCorkle involved approval of a residential project in the wake of state housing mandates (McCorkle, 31 Cal. App. 5th at 85), here there is no state mandate streamlining this warehouse Project. While McCorkle involved a city substantively amending its municipal code the year before the housing project heard (id. at 85-87), here the City’s SPR provisions have not been substantially amended, which have been in place since 1988.

While McCorkle involved a city ordinance that “expressly precluded [that city] from disapproving a proposal for non-design related reasons” (id. at 87), here no explicit preclusion is provided under the Code. It would seem that the City’s novel interpretation of McCorkle is but a recent pattern of practice of allowing warehouse projects to evade CEQA review.3

Third, this Project does not qualify for a class 32 exemption due to impacts on air quality, hazards, noise, traffic, vehicle miles traveled, and greenhouse gas emissions—as fully discussed in the enclosed expert comment letters (attached hereto as Exhibits B through D), which are incorporated into this appeal in their entirety.4

2 See Staff Report (2/7/23), PDF p. 10 (“In response to the technical reports, conditions of approval are recommended to (Attachment F–Conditions of Approval) address noise from trucks and construction activities on nearby residences, improved landscaping throughout the site to assist with site drainage, soil management, and fugitive dust containment during construction to reduce impacts on adjacent properties and treatment of archeological resources unearthed by construction activities to preserve Native American artifacts. ” [Emphasis added]), https://longbeach.legistar.com/View.ashx?M=F&ID=11882901&GUID=AEA223A5-553A-47DC- 8518-FDF7D72F073A.
3 See e.g., Link to 5860 Paramount Blvd Warehouse, https://longbeach.legistar.com/LegislationDetail.aspx?ID= 5888398&GUID=CE3CFBAC-58AC-47B6-950A-ECB5FA159DBC&Options=&Search=; 2400 Artesia Warehouse, https://longbeach.legistar.com/LegislationDetail.aspx?ID=4123523&GUID=8FB4718A -CFE5-4F2B-884E- D9A482176B05&Options=&Search=.
4 See also presentation materials, https://www.dropbox.com/s/4d6kve7jihdepvy/Appeal%20to%205910% 20Cherry%20Site%20Plan%20Review%20V4%202.7.23%20.pptx?dl=0.

Item 25 RE: Link Logistics Project (Council File No. 23-0104) April 18, 2023

In closing, Appellants understand the Project’s SPR application has been withdrawn and no Appeal hearing will be held. As discussed above, the SPR review process provides the City substantial discretion to address environmental concerns like those discussed herein. Appellants urge the City to use that discretion to ensure adequate CEQA review, including considering additional mitigation measures—like those specifically recommended in the attached expert comment letters. Please place this letter and the attached/hyperlinked documents in the Project’s administrative record.

Lastly, Appellants thank the City staff for their time and respectfully request notification for any future application involving this Site.

Sincerely,

_________________________________________
Jordan R. Sisson
Attorney for Appellants

Attachments:

Exhibit A: Amy Harbin Email to Appellants (4/14/23)5
Exhibit B: Expert Forrest & Associates Noise Comment Letter (3/30/23)6 Exhibit C: Expert Urban Systems Associated Traffic Comment Letter (4/5/23)7 Exhibit D: Expert SWAPE Air/GHG Comment Letter (4/3/23)8

5 https://www.dropbox.com/s/0te97z23jovrcwr/A_Email.pdf?dl=0. 6 https://www.dropbox.com/s/3l2ficen3tjim8j/B_DLA%20Noise%20Report_Cherry%20Ave%20Warehouse%20 Project%202-6-2023%20%207am-s-s.pdf?dl=0.
7 https://www.dropbox.com/s/qrb1cnxv42gt4j2/C_5910%20Cherry_%20Long%20Beach_Transportation%20 Comments.pdf?dl=0.
8 https://www.dropbox.com/s/l848hw6l9grk6pj/D_2023.04.03_CherryAve_Commentletter_Final.pdf?dl=0 .

EXHIBIT A
1 [email protected]
From: Kirk Davis <[email protected]>
Sent: Friday, April 14, 2023 5:33 PM
To: [email protected]
Cc: Laurie Angel
Subject: Fwd: Withdrawal Of Application -- 5910 Cherry Avenue

FYI
Sent from my iPhone

Begin forwarded message:

From: Amy Harbin <[email protected]>
Date: April 14, 2023 at 4:30:31 PM PDT
To: [email protected], Laurie Angel <[email protected]> Cc: Alexis Oropeza <[email protected]>, Alison Spindler-Ruiz <[email protected]>
Subject: Withdrawal Of Application -- 5910 Cherry Avenue

Good afternoon Kirk and Laurie,

As the Appellants of the project at the above address, I’m writing to let you know that the Applicants have withdrawn their application for the project thereby revoking the site plan entitlement and mooting a need for the hearing. However, since the withdrawal was not received in time to have been included on the supplemental agenda, the withdrawal will be addressed on the floor of the meeting on Tuesday.

Thank you and please let me know if you have any questions.

Amy

Amy L. Harbin, AICP
Planner

Long Beach Development Services | Planning
411 W. Ocean Blvd., 3rd Fl. | Long Beach, CA 90802
Office: 562.570.6872

EXHIBIT B
DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 1 Dale La Forest & Associates
Design, Planning & Environmental Consulting
101 E. Alma Street, Suite 100-A; Mt. Shasta, CA 96067
Phone: (530) 918-8625 E-Mail: [email protected]
[email protected]
Office: 951-405-8127
March 30, 2023
Jordan R. Sisson
Law Office of Jordan R. Sisson
3993 Orange St., Ste. 201
Riverside, CA 92501
Report of Potential Noise Impacts of Cherry Avenue Warehouse Project 5910 Cherry Avenue, Long Beach, CA
Application No. 2207-30 (SPR 22-078)
D e a r M r . S i s s o n :

At your request, I have prepared this report in response to the Project application and Categorical Exemption Request (“CE Request”) for the Cherry Avenue Warehouse (“Project”), including the cursory noise discussion in a Noise Study attachment pertaining to the Project's potentially significant noise impacts. My qualifications are attached hereto as “Attachment 1”.

This report shows that the Project's noise impacts will be significantly adverse under the California Environmental Quality Act, Pub. Res. Code § 21000 et seq., (“CEQA”) and will exceed permissible CEQA standards set by the City of Long Beach (“City”) and other authorities.

During this Project's construction period, its construction noise levels will undoubtedly exceed the City's noise standards. During its subsequent operation as a large warehouse, the Project will also subject neighboring residences to excessive noise levels.

Because construction and operational noise impacts will likely exceed applicable significant thresholds under the CEQA Guidelines, the Long Beach Municipal Code (“Code” or “LBMC”), and the City’s General Plan, the use of a categorical exemption is inappropriate per 14 Cal. Code.

Regs. § 15000 et seq. (the “CEQA Guidelines”).

Hence, the City should require the Project applicant to prepare a more demanding CEQA review, such as an environmental impact report (“EIR”) or mitigated negative declaration (“MND”) to consider feasible mitigation measures.

DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 2 Figure 1
Photo of dozens of homes and some businesses across Cherry Avenue from Project site.

I. EXECUTIVE SUMMARY

As explained herein in this report, I have made the following conclusions about the Cherry Avenue Warehouse Project. (Section references are to my narrative discussion infra in this letter):

Section II (pp. 5-6):1 The City and Applicant agreed to Project-specific noise mitigation in Conditions of Approval (COA-20 and COA-58) that directly conflicts with CEQA’s absolute bar against mitigation measures for categorical exemptions. Thus, by its own practice, the City appears to admit that there is a fair argument that the Project will cause potentially significant noise impacts. The close proximity and age of adjacent homes west of Cherry Avenue constitutes an unusual circumstance related to construction noise impacts, which supports the conclusion that a categorical exemption is inappropriate for the Project.

Even the City’s proposed Conditions of Approval will not adequately reduce the warehouse’s noise impacts to a less-than-significant level. Condition #20 regarding nighttime noise levels and trucking use is too vague and ineffective. Condition #58 which requires the property be maintained in a quiet condition and maintained so as not to be detrimental to adjacent properties and occupant is also too vague to be effective.

Section III (pp. 6-10) The Project will generate noise levels that exceed many of the applicable thresholds of significance, and will therefore create significant noise impacts to its neighbors.

These noise standards are described in this section.

1 Herein, page citations are either to the document’s stated pagination (referenced by “p. ##”) or to the pages’ location within the referenced PDF document (referenced by “PDF-- ##”). Websites and documents cited herein were accessed in February, 2023 and copies of which will be made available to City officials if requested.

DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 3 Section IV (pp. 11-13) The threshold of significance for construction noise should be 70 dBA Leq in the daytime and 65 dBA Leq at nighttime to avoid significant noise impacts, not the excessive daytime 80 dBA Leq standard and 70 dBA Leq nighttime standard employed by the Project’s Noise Study.

Section V .1 (pp. 15-17) The proposed nighttime construction of the concrete slab pour activities would generate significant noise impact at neighboring homes. Those maximum nighttime construction noise levels at a nearest residence of 76.5 dBA L max would exceed the City’s
maximum 65 dBA Lmax nighttime threshold of significance (LBMC § 8.80.150(B)(5)).

Section V .2 (pp. 17-18) Average nighttime construction noise levels of 72 dBA L eq at nearest
residence 220 feet away would exceed the City’s 45 dBA L50 threshold of significance. (LBMC §

8.80.150(B)(1)). Similarly, at more than a dozen homes up to 400 feet away from the concrete slab pour work, nighttime average construction noise levels in excess of of 67 dBA Leq would also exceed the City’s maximum 45 dBA L50 threshold of significance.

Section V .3 (pp. 18- 19) In interior rooms of nearby homes during the Project’s concrete slab pour work, nighttime construction noise levels of 52 dBA L eq would exceed the City’s maximum
35 dBA Leq nighttime interior noise level threshold of significance (LBMC § 8.80.170(A), Table C). Even at more distant homes up to 400 feet away if not blocked by intervening structures, their interior room noise levels could reach 47 dBA Leq at nighttime and also exceed the 35 dBA Leq threshold. Those same construction noise levels if that work is conducted in the daytime would exceed the City’s daytime threshold of 45 dBA Leq (LBMC § 8.80.170(A)). They would also exceed the General Plan’s maximum acceptable indoor noise standards of 45 dBA Ldn (daytime) and 35 dBA Ldn (nighttime), (Noise Element, p. 137, Table 11).

Section V .4 (p. 19) The magnitude of the increase in noise levels at the nearest homes would be significant during nighttime concrete pour activities. The existing average noise level at the nearest homes is about 65.3 dBA Leq at nighttime. That construction noise heard at those homes could add about 72.5 dBA Leq, resulting in over a 7 dB increase during nighttime construction on the concrete pour activities. That increase is significant because it would exceed the 1.5 dBA threshold identified for conditions at these homes where ambient is greater than 65 dBA Leq (FICON; also Noise Study, p. 21, Table 4-1).

Section V .5 (pp. 20-21) Concrete pour activities could generate a 24-hour day-night average noise level of 78.5 dBA L
dn at the nearest home, and 73.3 dBA Ldn or more at more distant dozens of homes within 400 feet of the concrete pour location. Those noise levels would exceed the threshold of significance for 24-hour day-night average noise levels is 70 dBA Ldn. (OPR, General Plan Guidelines, 2003) A noise level louder than that is considered to be “normally unacceptable” for the nearby residences. This Project could generate noise levels of 78.5 dBA Ldn at the nearest home, and 73.3 dBA Ldn or more at more distant dozens of homes within 400 feet of the concrete pour location. Exceedance of this standard would be a significant noise impact. Even if no concrete pour work or other construction was done at nighttime, meaning that construction work would only occur in the daytime hours, the 24-hour day-night average noise level could be over 70 dBA Ldn at the nearest house 220 feet from the concrete pour location and would thus be a significant noise impact.

DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 4

Section VI (pp. 22-23): Backup alarms mandated on heavy equipment and trucks could create noise levels at the nearest home of about 83 dBA Lmax (when adjusted with a 5 dB penalty for a pure tone per LBMC § 8.18.160). The City’s maximum daytime noise standard is 70 dBA Lmax.

Backup alarms could exceed this threshold by 13 dB, resulting in a significant noise impact.

Section VII (pp. 24- 25): Project trucking would expose the adjacent Los Angeles County’s Department of Animal Care and Control building to noise levels from passing heavy trucks in its driveway about 160 feet from this building to maximum noise levels of about 85 dBA L max. The
City’s threshold of significance for maximum noise level exposure for such a commercial building is 75 dBA Lmax. The 10 dBA exceedance of this threshold indicates a significant noise impact at that commercial property.

Section VIII (pp. 26-28): The 50-foot tall massive western wall of the warehouse will increase traffic noise levels by about 2 dBA at homes west of Cherry Avenue by reflecting existing and – Project-added traffic noise toward those homes. Because these homes are already exposed to traffic noise levels in excess of the City’s 65 dBA standard for residential uses, any Project-related increase in noise levels greater than 1.5 dB is considered a significant noise impact (FICON; Noise Study pp. 19-20; CalTrans, FHA).

Section IX (pp. 28-29): The City’s maximum exterior noise standard for homes west of Cherry Avenue at nighttime is 65 dBA L
max (LBMC § 8.80.150(B)(5)). The possible use of mechanical sweeper/vacuums in the parking lot and driveways west of the warehouse could generate noise levels at the nearest homes up to 200 feet away from such pavement cleaning of 67.5 dBA Lmax, thus exceeding the nighttime threshold of significance and creating a significant noise impact at some homes.

Section X (p. 30): The Project’s Noise Study is incomplete, inaccurate, entirely conclusory, is based on insufficient measurement locations, and likely contains artificially-inflated ambient noise levels due to errors in the noise level measurements that were taken and their inconsistent exceedance of noise level data in the General Plan Noise Element. The noise discussion utterly fails to meet the evaluation standards set by the City’s Noise Ordinance or other public agencies, nor is consistent with other noise studies conducted within the City.

Section XI (pp. 31-36): The Project applicant fails to demonstrate that all technically feasible noise attenuation measures are incorporated into the Project, and relies on the City’s Noise Ordinance as a substitute to the significance thresholds provided under the City’s and other applicable noise standards. The Project’s paltry noise analysis failed to provide any meaningful information to allow the City to adequately consider standard mitigation measures provided under applicable CEQA guidance documents, many of which have been incorporated into numerous City projects via enforceable Conditions of Approval. This constitutes a sharp deviation of the City’s practice for similarly-situated projects and must be corrected in a CEQA-compliant MND or EIR—just like other projects of this nature.

DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 5 II. CEQA DOES NOT ALLOW PROJECT-SPECIFIC MITIGATION MEASURES

WHEN CONSIDERING THE ADEQUACY OF A CATEGORICAL EXEMPTION

As an initial observation, it must be noted that the Cherry Avenue Warehouse Project is proposing two Project-specific Conditions of Approval (“COAs”) to directly or indirectly mitigate noise impacts. That is an admission that there is a fair argument that the Project may cause significant noise impacts and, therefore, a categorical exemption is inappropriate for this Project.

The proposed COA-20 and COA-58 relate to noise impacts and compliance with the City’s Noise Ordinance. While the City should be applauded for trying to ameliorate the Project’s noise impacts, these COAs have not been vetted by the public nor tethered to an adequate noise analysis as required by CEQA. Furthermore, CEQA does not allow an agency to use project-specific mitigation measures, like these two noise-related COAs restricting noise levels from outdoor common areas, to reduce a project impacts as a means to qualify for a categorical exemption and avoid a more demanding CEQA review.
2 Even if the Project utilized an MND, which it did not, CEQA requires a lead agency to recirculate the MND if additional mitigation measures are subsequently added after the MND’s initial circulation in order to publicly-vet the adequacy of the new mitigation measures.3

As discussed herein, substantial evidence shows operational impacts will be significant and, therefore, mitigation measures should be considered pursuant to a CEQA-compliant MND or EIR being prepared; which is consistent with the Long Beach General Plan’s Noise Element (“Noise Element”) that clearly states that “… the City has adopted a po licy of requiring Environmental Impact Studies to be conducted for all City projects … include[ing] private projects for which a building permit or other entitlement for use is required.” 4 As recognized by one court, lead agencies are not required to evaluate mitigation measures during its preliminary review of projects and therefore not appropriate in the context of categorical exemptions; instead consideration of mitigation measures is reserved (as relevant here) for MNDs subject to CEQA’s fair argument standard whereby “[i]f there is a disagreement between experts over the significance of an effect . . . the lead agency shall treat the effect as significant ” Azusa Land Reclamation Co. v. Main San Gabriel Basin Watermaster (1997) 52 Cal.App.4th 1165, 1200- 1201 (citing CEQA Guidelines § 15064(h)(2)).

2 See e.g., Salmon Protection & Watershed Network v. County of Marin (2004) 125 Cal.App.4th 1098, 1102, 1108 (stating while “mitigation measures may support a negative declaration but not a categorical exemption … Reliance upon mitigation measures (whether included in the application or later adopted) involves an evaluative process of assessing those mitigation measures and weighing them against potential environmental impacts, and that process must be conducted under established CEQA standards and procedures for EIR's or negative declarations.”); Azusa Land Reclamation Co. v. Main San Gabriel Basin Watermaster (1997) 52 Cal.App.4th 1165, 1200 (“In determining whether the significant effect exception to a categorical exemption exists, ‘[i]t is the possibility of a significant effect . . . which is at issue, not a determination of the actual effect, which would be the subject of a negative declaration or an EIR. Appellants cannot escape the law by taking a minor step in mitigation and then find themselves exempt from the exception to the exemption.’ [Citation].”) 3 See Gentry v. Murrieta (1995) 36 Cal.App.4th 1359, 1380 (“if there was substantial evidence to support a fair argument that the Project would have a significant effect… then the City could not adopt new mitigation conditions aimed at this effect without recirculating its proposed negative declaration. Nevertheless, the City added mitigation condition… without recirculating. In so doing, it abused its discretion.”). 4 Noise Element, p. 130, http://www.lbds.info/civica/filebank/blobdload.asp?BlobID=3051 DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 6

III. OPERATIONAL AND CONSTRUCTION NOISE IMPACTS WILL BE SIGNIFICANT WITH THESE APPLICABLE NOISE STANDARDS:

Applicable Operational Noise Standards

To demonstrate the various ways the Cherry Avenue Warehouse’s operational noise impacts will be significant, one must consider the various thresholds applicable to this Project.

CEQA Guidelines Appendix G

First, under Appendix G to the State CEQA Guidelines,
5 a project’s noise impact is normally
significant if:

 Exposure of persons to or generation of noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies;  A substantial permanent increase in ambient
6 noise levels in the project vicinity above
levels existing without the project; orA substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project.

Long Beach General Plan Noise Element

Second, under the City’s General Plan Noise Element, Recommendation 4 and 4.4 provides (emphasis added) that “[n]o future development shall be allowed which is incompatible with the existing or future noise environment [,]” where any development is considered “incompatible with its noise environment if any of the standards or criteria listed in [the Noise Element] are exceeded.”7 Among the standards/criteria listed in the Noise Element “to protect public health and well-being,” include the maximum limits summarized in Table 1 on the following page, which the Noise Element states (emphasis original) “MUST be utilized along with other relevant data.”8

5 California Natural Resources, Appendix G-Environmental Checklist Form, http://resources.ca.gov/ceqa/guidelines/Appendix_G.html. 6 Ambient Noise is defined in the City’s General Plan. See Noise Element, supra fn. 3, p. 195 (“the all- encompassing noise associated with a given environment, being usually a composite of sounds from many sources near and far. For the purposes of this [proposed model noise] ordinance, ambient noise level is the level obtained when the noise level is averaged over a period of at least 15 minutes without inclusion of noise from occasional or occasional and transient sources, at the location and time of day near that at which a comparison is to be made.”); see also p. 223 (providing similar definition).
7 Noise Element, supra fn. 3, p. 145.
8 Ibid., p. 136-139.

DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 7 Table 1: Long Beach General Plan Noise Element Recommended Criteria for Maximum Acceptable Noise Levels in A-Weighted Decibels (dBA)

Outdoor Indoor
Land Use Type (a) Maximum Single
Hourly Peak L10
(b) L50
(c) Ldn
(d)
Residential 7 am - 10 pm (Daytime) 70 55 45 45
Residential 10 pm -7 am (Nighttime) 60 45 35 35
Notes:
a. Homes and apartments fall under the residential category of the Noise Element. b. Noise Levels exceeded ten percent of the time.
c. Noise levels exceeded fifty percent of the time.
d. Day-night average sound level. The 24-hour A-weighted equivalent sound level with a 10-decibel penalty applied to nighttime levels.

Source: General Plan Noise Element, pp. 136-139, Table 11

Therefore, under the Noise Element, the Project’s noise impact is significant if at residential land uses:
 Outdoor noise levels exceed 70 dBA Lmax (daytime) or 60 dBA Lmax (nighttime).  Outdoor noise levels exceed 45 dBA L50 (daytime) or 35 dBA L50 (nighttime).  Indoors noise levels exceed 45 dBA Ldn (daytime) or 35 dBA Ldn (nighttime).  Average maximum noise levels outside the nearest building at the window of the occupied room closest to the Project site boundary exceeds 70 dBA in areas away from main roads and sources of industrial noise, or exceeds 75 dBA in areas near main roads and heavy industries (General Plan Noise Element, p. 95).

Long Beach Municipal Code

Third, under Chapter 8.80 of the LBMC (governing environmental noise), the Project site is located within Receiving Land Use District Two, but also adjacent to residential land uses in District One, and subject to the exterior and interior noise limits as summarized in Table 2 below:

Table 2: Long Beach Noise Standards for Residential – District One, and Commercial Land Uses - District Two (Before 5 dB reduction for speech/music per LBMC § 8.80)

Exterior Interior Land Use
District Exterior Noise Level
(Leq) 7 am to 10 pm
Exterior Noise Level
(Leq) 10 pm to 7 am
Interior Noise Level
(Leq) 7 am to 10 pm
Interior Noise Level
(Leq) 10 pm to 7 am
District One 50 45 45 35
District Two 60 55 45 35
Note: No person shall operate or cause to be operated any source of sound at any location within the incorporated limits of the City or allow the creation of any noise on property owned, leased, occupied, or otherwise controlled by such person, which causes the noise level when measures from any other property to exceed:

1. The noise standard for that land use district as specified in the above Table for a cumulative period of more than thirty (30) minutes in any hour; or

2. The noise standard plus five (5) decibels for a cumulative period of more than fifteen (15) minutes in any hour; or

3. The noise standard plus ten (10) decibels for a cumulative period of more than five (5) minutes in any hour; or

4. The noise standard plus fifteen (15) decibels for a cumulative period of more than one (1) minute in any hour; or

5. The noise standard plus twenty (20) decibels or the maximum measured ambient, for any period of time.

Source: City of Long Beach Municipal Code, Section 8.80.160 and Section 8.80.170. 1977.

DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 8

5 dBA Reduction for Impulsive Noise, Repetitive Speech or Music: However, to protect against the increased human disturbance potential of some sound characteristics, the Code requires a reduction in the City’s exterior and interior noise limits of 5 dB for repeated impulsive noise, music, or speech.9 As proposed, the Project could include speech and possibly music from car stereos in outdoor parking lot areas located to the west of the warehouse building that could continue for more than 5 minutes in any hour, and directly affect the homes west of Cherry Avenue from the Project Site.

Therefore, under the Code and consistent with City’s past practice, 10 the Project’s noise impact is
significant if the homes west of Cherry Avenue experience noise levels that exceed:

 General exterior noise limit of 60 dBA Leq (daytime) or 55 dBA Leq (nighttime), or  Exterior noise limit for impulsive noise, music and speech of 55 dBA Leq (daytime) or 50 dBA Leq (nighttime).

Applicable Construction Noise Standards

Fourth, the applicable construction noise standards are derived from the City’s and other agencies’ thresholds of significance for construction noise, as well as the standards proposed by the City and the applicant discussed in the Project’s Noise Study, which include:

 General exterior noise limit of 70 dBA Leq (daytime) or 65 dBA Leq (nighttime), or  Maximum construction noise level of 65 dBA Lmax at homes (Noise Study, p. 43), or  Average nighttime construction noise level of 45 dBA L50 at neighboring homes (Noise Study, p. 45, Table 8-4: threshold of 45 dBA Leq), or
 Interior noise limit of 35 dBA Leq at nighttime (LBMC § 8.18.170(A)), or  24-hour day-night weighted average of 70 dBA Ldn. (Calif. General Plan Guidelines)

Past Practice by the City of Long Beach

Fifth, based on past environmental reviews where the City served as the lead agency,11 the Project’s noise impact would be significant if:

9 See LBMC § 8.80.160 (for exterior noise limits: “In the event that alleged offensive noise contains a steady audible tone such as a whine, screech, or hum, or is a repetitive noise such as hammering or riveting or contains music or speech conveying informational content, the standard limits … shall be reduced by five (5) decibels.”) (emphasis added); see also LBMC § 8.80.180 (containing same language for interior noise limits). 10 See 100 E. Ocean Blvd. Project (Oct. 2018) MND, p. 121 [fn. 68], https://web.archive.org/web/20190202022910/http:/www.lbds.info/civica/filebank/blobdload.asp?BlobID=7268; 11 See e.g., 207 Seaside Way Project (Mar. 2015) MND, p. 85, http://www.lbds.info/civica/ filebank/blobdload.asp?BlobID=4949; 442 W. Ocean Blvd. Project (Mar. 2015) MND, p. 83, http://www.lbds.info/civica/filebank/blobdload.asp?BlobID=4956; Oceanaire Apartment Project (Mar. 2015) MND, p. 85, http://www.lbds.info/civica/filebank/blobdload.asp?BlobID=4978; 100 E. Ocean Blvd. Project (Oct. 2018) MND, p. 122,
https://web.archive.org/web/20190202022910/http:/www.lbds.info/civica/filebank/blobdload.asp?BlobID=7268 ;
Second + PCH Development Project (Mar. 2011) EIR, pp. IV .I:17-18, DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 9

 Operational noise increase existing ambient noise levels at adjacent sensitive receptors by 5 dBA or more; but where existing ambient noise levels at some affected sensitive receptors exceed 65 dBA Leq, an increase of 1.5 dBA or more would be significant.  Cumulative operational noise levels would increase 3 dB or more over existing conditions and the resulting noise level exceeds applicable exterior standard at a sensitive use;  If noise levels would cause a sensitive land uses, like a residences, to exceed the desirable exterior noise exposure of 65 dBA Community Noise Equivalent Level (CNEL); or  The project causes the ambient noise level measured at the property line of affected uses to increase by 3 dBA in CNEL to or within the “normally unacceptable” or “clearly unacceptable” category identified in Table 7 below.

Project’s Exterior Parking Lot and Loading Dock Area Activity

This Cherry Avenue Warehouse Project will include various operational noise sources typical for the use and maintenance of a warehouse building (e.g., fixed mechanical and HV AC equipment, parking facilities, parking lot mechanical pavement cleaning, loading docks, backup alarms, parking and off-site roadway traffic, etc.). No restrictions prohibit these activities beyond compliance with the City’s noise standards (i.e., COA-20).

However, as discussed herein, noise from these outdoor activities will significantly impact neighboring residences west of Cherry Avenue (as depicted on Figure 2).

Unlike other projects reviewed by the City, the Project applicant has not submitted sufficient noise measurements of existing ambient noise levels or evidence that compliance with the City’ s noise standard (COA-20) is even possible. Such measurements and analysis are critical if the City is to protect nearby residential neighbors from adverse sleep-disturbing impacts from new warehouse noise sources. Absent meaningful and credible noise measurements, the LBMC’s general and music/speech-specific ambient noise levels must be presumed.

http://www.lbds.info/civica/filebank/blobdload.asp?BlobID=3375; Staybridge Suites Hotel (Nov. 2016) MND, p. 53, http://www.lbds.info/civica/filebank/blobdload.asp?BlobID=6245; Shoreline Gateway East Tower Project (Aug. 2016) Final EIR Addendum-Noise Study, pp. 12-13,
http://www.lbds.info/civica/filebank/blobdload.asp?BlobID=6152.

Figure 2: Neighborhood Plan (Showing Proximity to Neighboring Residences) DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 10 DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 11 IV . Threshold of Significance for Construction Noise Should be 70 dBA Leq in the Daytime to Avoid Significant Noise Impacts

The Project’s Noise Study chooses a threshold of significance for construction noise that is not sufficiently protective of the nearby residential neighbors. The Noise Study sets an excessively high threshold of significance for daytime construction noise of 80 dBA Leq and nighttime construction noise of 70 dBA Leq. That daytime noise level is also inconsistent with the standards in the Long Beach General Plan Noise Element on page 95 which sets a lower 70 or 75 dBA Leq daytime noise standard, while discussing construction noise:

“. . . average maximum noise levels outside the nearest building at the window of the occupied room closest to the site boundary, should not exceed: 70 dBA in areas away from main roads and sources of industrial noise; 75 dBA in areas near main roads and heavy industries.” (Emphasis added)

Using an 80 dBA L
eq threshold that is inconsistent with the Long Beach General Plan noise standards would violate CEQA which requires such inconsistencies to be disclosed, and they have not been. Even these General Plan’s noise standards may be insufficient for evaluating this Project’s construction noise impacts if construction were to occur at night as the Noise Study predicts. See: King & Gardiner Farms (2020) 45 Cal.App.5th 814, 881-882 (holding that “conformity with a general plan does not insulate a project from EIR review where it can be fairly argued that the project will generate significant environmental effects.")

But ignoring those General Plan noise standards, the preparer of the Noise Study, on p. 39, erroneously claims that the City of Long Beach General Plan does not establish numeric maximum acceptable construction source noise levels at potentially affected receivers for CEQA analysis purposes. But the Noise Element on page 95 actually does, as discussed above. So more favorable to the client’s concern for less regulation than to the public’s need for peace and quiet, the Noise Study instead uses a daytime exterior construction noise level of 80 dBA L eq at
residential properties that it borrows from the Federal Assessment Manual. There is substantial evidence that an 80 dBA Leq threshold is insufficiently protective for this Project and CEQA requires evaluation and application of stricter standards when applicable.12 The City’s Noise Element standards are certainly applicable. Quieter construction noise standards used in other California communities also are evidence of the need to protect residents from loud noise levels being permitted up to 80 dBA Leq.

The preparers of this Project’s Noise Study, Urban Crossroads, have used 70 dBA L eq as a daytime
construction noise threshold of significance for the development of other large warehouse projects.

One such noise study they prepared was for a 316,082 square foot warehouse in Riverside County

12 See Berkeley Keep Jets Over the Bay Committee v. Board of Port Cmrs. (2001) 91 Cal.App.4th 1334, 1380, [CEQA did not define “significant noise impacts simply in terms of whether a project would violate applicable local, state, or federal noise standards”]); see Sierra Watch v. County of Placer (2021) 69 Cal.App.5th 86, 107 (“a threshold of significance cannot be applied in a way that would foreclose the consideration of other substantial evidence tending to show the environmental effect to which the threshold relates might be significant.”). See: Save Our Capitol! v.

Dept. of General Services (January 18, 2023, C096617) ___ Cal.App.5th ___, at p. 43 (similarly holding “[a] regulatory standard [cannot] be applied so as to foreclose consideration of substantial evidence showing a significant environmental impact from a project.”)
DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 12 where they used 70 dBA Leq as a daytime construction noise threshold.13 Another noise study they prepared was for a 296,297 square foot warehouse building and a smaller 88,746 square foot warehouse building in the City of Fontana using a construction threshold of significance of 70 CNEL in the daytime and 65 CNEL at nighttime.14

To evaluate how significantly a project may disturb its neighbors, one step is to consider how intrusive its noise will be compared to the ambient or background noise levels without the project.

A noise source that is starkly audible above the background noise level is more annoying and harmful to residential neighbors. The L
90 measurement near Cherry Avenue (lowest average
minimum level) is considered to represent the background noise without the prominent traffic noise sources that are not uniformly loud. Homes measured at location “L5” are already exposed to background noise levels in the daytime that, for half the time, are less than 60 dBA L90.15

FIGURE 3 - Graphing L90 “background” noise levels near homes on Cherry Avenue

Figure 3 above is a graph of the background noise levels near homes west of Cherry Avenue at noise measurement location “L5.” 16 This graph is useful in considering how much additional noise the Project might create that would be clearly audible at times above the background noise

13 See the noise study for a 316,082 square foot warehouse by Urban Crossroads for the Harvill and Rider Project’s Mitigated Negative Declaration dated April 28, 2021 and approved by Riverside County, on pages 5-82 to 5-83, which states regarding construction noise: “However, to ensure a more conservative analysis herein, a threshold of 70 dBA L
eq is utilized, which is consistent with the 70 dBA CNEL standard for noise-sensitive uses contained in the County’s General Plan.” This MND will be made available to the City if requested and it is available online at https://planning.rctlma.org/Portals/14/Harvill%20and%20Rider%20MND.pdf 14 See Urban Crossroads’ Noise Study for the North Fontana Industrial Complex (Acacia) for a 296,297 square foot warehouse building and another smaller warehouse building in the City of Fontana, April 13, 2022, at page 19, Table 4-1, Significance Criteria Summary: 70 CNEL in the daytime and 65 CNEL at nighttime. (A 70 CNEL limit is similar to a 70 dBA Leq standard.) This noise study will be made available to the City if requested and it is available online at https://www.fontana.org/DocumentCenter/View/40374/SBC-Appendix-J2_Acacia-Noise-Study 15 See Noise Study, PDF-1039, Wednesday, April 13, 2022 at noise level measurement location L5 - Located west of the Project site near single-family residence at 1919 East Hungerford Street. Also see Figure 3 for a graph of these measured noise levels.
16 ibid.

DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 13 level without exceeding a threshold of significance if the Noise Study’s choice of 80 dBA Leq is used. If 80 dBA Lmax is used as a threshold of significance, neighbors could be exposed to much louder daytime construction noise levels at times as much as 24 dBA greater than background levels with no relief.

The consideration of background noise levels is important when selecting a threshold of significance. The 90th percentile-exceeded noise level, L 90, is a metric that indicates the single
noise level that is exceeded during 90% of a measurement period, although the actual instantaneous noise levels fluctuate continuously. The L90 noise level helps quantify the acoustical character of an environment, such as “rural area,” “urban area,” or “noisy neighborhood” because it represents the residual (i.e., ambient) noise between individual noise events, such as a truck pass-by or aircraft over flight.

The L
90 noise level is often near the low end of the instantaneous noise levels during a measurement period. Brief, intermittent and loud sources, such as an aircraft flyover, car doors closing, bird chirps, dog barks, car horns, truck pass-by, etc., will influence the Leq of the measurement period but typically not the L90, even though these other noise sources may be briefly audible and louder than the a noise source of interest during the same measurement period.

If a person was only listening to one continuously operating noise source, such as a large fan, the Leq and L90 noise levels at that location would be approximately equal.

So in conclusion, substantial evidence demonstrates that the Noise Study’s 80 dBA L eq threshold
for construction noise does not adequately protect the neighborhood, especially when the City’s General Plan sets a 70 dBA Leq threshold “in areas away from main roads” where homes farther away from Cherry Avenue are located. The 70 dBA Leq threshold used by Urban Crossroads in its other noise studies should inform the City of Long Beach that 70 dBA Leq is the proper standard for CEQA review of this Project.

DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 14 Figure 4 – Location of Nearest Homes to the Warehouse and its Western Parking Lot

Table 4 – Distances from Nearby Homes to Warehouse and to Western Parking Lot

Home Address Distance to Ware house Distance to Parking Lot A 5951 Cherry Avenue 240’ 210’
B 5949 Cherry Avenue 220’ 170’
C 5945 Cherry Avenue 220’ 160’
D 5943 Cherry Avenue 230’ 170’
E 5931 Cherry Avenue 220’ 150’
F 5918 Gardenia Ave. 300’ 230’
G 5905 Cherry Avenue 260’ 190’

DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 15 V. NIGHTTIME CONSTRUCTION DURING CONCRETE SLAB POUR FOR WAREHOUSE

BUILDING WOULD CREATE SIGNIFICANT NOISE IMPACTS

The Project’s Noise Study17 states that construction and pouring of the building’s concrete slab will occur at nighttime.18 But the Noise Study (pages 43 to 45) seriously underestimates how loud that nighttime construction noise will be at the nearest residences. The construction noise levels of such concrete pour activities would exceed the City’s noise standards at dozens of nearby homes.

See Figures 2 and 4 above for the locations of these noise-affected nearest homes.

V .1 The Maximum Noise Level of Proposed Construction Would Create a Significant Noise Impact

For example, the City’s threshold of significance for nighttime construction noise from pouring this concrete is a maximum of 65 dBA Lmax at neighboring homes.19 This is a noise level that, even if brief and lasting less than 1 minute, would constitute a significant noise impact. But that noise level would be significant at times at the nearest residence when it would be greater than 76.5 dBA Lmax.

The Noise Study presents these noise standards in its Table 3-1. It uses this Table 3-1 to identify a different noise standard for construction noise during the concrete pouring activities of 45 dBA L50 for an average noise level, where the construction noise level at nearby homes would exceed 45 dBA for more than 30 minutes in an hour. But the Noise Study identifies no other noise threshold of significance for maximum noise levels. It is the very loudest construction noise maximum level that is most disturbing to nearby residents. Those maximum volume sounds are clearly heard above the background or ambient conditions, and are the most disturbing when so loud.

Accordingly, use of a threshold of significance of 65 dBA Lmax for a maximum construction noise level is equally valid.

That noise level of 65 dBA L
max would be exceeded though by even one type of heavy equipment being used for the concrete pour. A single concrete mixer truck operated near the proposed

17 The Project’s Noise Study, by Urban Crossroads, is found at the Attachment E (Notice of Exemption Associated Technical Reports), PDF-pages 945 to 1058, titled: “Cherry Avenue Warehouse Noise Impact Analysis,” dated May 6, 2022.
18 See Noise Study, p. 43. (Attachment E, PDF-993)
19 See Noise Study, p. 15, Table 3-1, 10pm- 7am: 65 dBA Lmax noise standard. (Attachment E, PDF-965) DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 16 building slab will generate noise level as loud as 89 dBA Lmax at 50 feet.20 Alternatively, concrete is not always delivered to the site in a concrete mixer truck from a distant concrete batch plant.

Sometimes a portable concrete batch plant is located onsite when pouring large areas of concrete slabs. Such a portable concrete batch plant, if located onsite temporarily near the proposed warehouse’s location, could generate a louder noise level of about 96 dBA Lmax at a distance of 50 feet.21

Figure 5 – Proximity between Construction Equipment or Parking and Nearby Homes

At a distance of 400 feet from the warehouse location where dozens of homes exist west of Cherry Avenue, the maximum noise level of just one concrete mixer truck’s operation would be as great as about 71 dBA Lmax and would exceed the nighttime maximum noise standards of 65 dBA Lmax.22 Even more disturbing, at the nearest home23 at only about 220 feet from the warehouse building’s concrete floor slab, that maximum noise level would be about 76 dBA Lmax and would

20 See: County of Ventura, Construction Noise Threshold Criteria and Control Plan (2010), “Typical Construction Equipment Noise” (Type: Concrete mixer truck: 89 dBA Lmax maximum noise level at 50 feet), available online at:
https://docs.vcrma.org/images/pdf/planning/ceqa/Construction_Noise_Thresholds.pdf This table of typical construction equipment noise levels is presented in Appendix A attached to this report. 21 Ibid.
22 Calculation: Noise level attenuation due to distance is calculated as reduced by about 6 dB for each doubling of distance from a point source. One can calculate a dB level at different distances when there is a known dB level for a known distance by the following equation: dB2 = dB1 – 10 x A x LOG(d2/d1) where:

LOG = logarithm, base 10,
A = dB drop-off rate coefficient (in this Project's case, a = 2.0 for a 6 dB drop off rate (point source, no atmospheric absorption)).
dB 1 = dB level at know distance from source, d1
dB 2 = dB level at another distance from source, d2
d 1 = known distance from source for known decibel level dB1 d 2 = second distance from source for which known decibel level estimate (dB2) is desired In this case, at a location 400' (d2) from the property line, where dB1 = 89 dBA at 50' (d1), dB 2 = dB1 – 10 x A x LOG(d2/d1) = 89 – 10 x 2.0 x LOG(400'/50') = 89 - 20 x (-0.90) = 71 dBA Lmax . 23 Home “C” at 5945 Cherry Avenue is about 220 feet from the proposed warehouse building, measured using the Project site plan and Google Maps. Heavy equipment might operate even closer to that home when pouring the concrete floor slab for the warehouse building.

DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 17 exceed the 65 dBA Lmax nighttime standard and even the daytime noise standard of 70 dBA Lmax.24 Therefore such maximum noise levels from construction noise during the concrete pours would create significant noise impacts for dozens of nearby homes. (See Figures 2, 4 and 5 above for location of these nearby homes.)

With multiple equipment
25 operated simultaneously during other Project construction work, the noise impact to neighboring residents would be even greater. For example during demolition and site work at a distance of 50 feet, dozers have been measured at 90 dBA Lmax and excavators at 92 dBA Lmax. (See Appendix A [Typical Construction Equipment Noise].)

EQUIPMENT MAX. NOISE USAGE RATE AVERAGE NOISE Dozer 90 dBA Lmax used 40% of an hour 86.0 dBA L eq Excavator 92 dBA Lmax used 40% of an hour 88.0 dBA L eq Jackhammer 88.9 dBA Lmax used 20% of an hour 81.9 dBA Leq (noise levels logarithmically added for total): TOTAL: 90.7 dBA Leq at 50 feet.

Accordingly, the Noise Study fails to disclose how loud the Project’s maximum noise levels would be when measured at neighboring homes, which would be loud enough to create significant noise impacts during the nighttime and the daytime.

V .2 The Average Noise Level of Proposed Construction Would Also Create a Significant Noise Impact

The Noise Study states the City’s threshold of significance for nighttime construction noise from pouring this concrete is an average of 45 dBA L50 when measured at the exterior of neighboring homes.26 That is a noise level that is exceeded for more than 50% of the time.

But the average noise levels generated by a concrete mixer truck operating at nighttime at the edge of the warehouse slab could be greater than 72 dBA L
eq at the nearest homes which about 220 feet
away or less, depending upon where equipment is staged and operated. (See Figure 4 illustrating the possible operation of some heavy equipment in the western parking lot closer to these homes.) That exceedance of the City’s standards by as much as 27 dBA represents a significant noise impact to the closest residential neighbors.

A single concrete mixer truck operated near the proposed warehouse building slab will generate an average noise level of about 85 dBA Leq at 50 feet.27 With two nearby homes each located about

24 Calculation as per footnote above: at 5945 Cherry Avenue, the noise level from the operation of a concrete mixer truck at a location 220' (d2) from the warehouse building, where dB1 = 89 dBA Lmax at 50' (d1), dB 2 = dB1 – 10 x A x LOG(d2/d1) = 89 – 10 x 2.0 x LOG(220'/50') = 89 - 20 x (-0.64) = 76 dBA Lmax . 25 The Noise Study identifies multiple equipment use in pouring concrete for the building floor slab and foundation:
“The reference noise levels describe the expected concrete pour noise sources that may include concrete mixer truck movements and pouring activities, concrete paving equipment, rear mounted concrete mixer truck backup alarms, engine idling, air brakes, generators, and workers communicating/whistling.” 26 See Noise Study, p. 45. (Attachment E, PDF-995) Table 8-4 “Nighttime Concrete Pour Noise Level Compliance”, Nighttime Threshold of 45 dBA Leq.
27 See: County of Ventura, Construction Noise Threshold Criteria and Control Plan (2010), page 4: “Typical Construction Equipment Noise” (Type: Concrete mixer truck: 85 dBA Leq (average) noise level at 50 feet), available DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 18 220 feet from the warehouse’s concrete floor slab, that concrete mixer truck noise would attenuate by distance to about 72 dBA Leq which significantly exceeds the permissible threshold of significance at nighttime of 45 dBA L50. 28

That noise impact would be greater at these homes if more than one piece of heavy equipment is operated simultaneously on the site, or if the equipment is operated at what would become the parking lot immediately west of the warehouse’s floor slab.

For the several dozen homes located within 400 feet of the warehouse’s concrete slab pour work, their residents also could be exposed to excessive noise levels of approximately 67 dBA L eq
or
more on average during the nighttime. They too could experience significant noise impacts since that concrete pour noise level would exceed the 45 dBA Leq nighttime threshold at their homes.

V .3 Interior Noise Levels Inside Homes Would Be Excessive Creating Significant Noise Impacts

The Noise Study fails to evaluate how loud the interior rooms of nearby homes would be during this Project’s construction. The interior noise levels within some of these homes could be excessively loud at night due to Project’s nighttime concrete pour activities. The City’s Noise Ordinance, § 8.18.170(A), establishes a 35 dBA nighttime noise limit inside residences as their maximum allowable interior noise level. But that noise level is likely to be exceeded if a home is exposed to exterior noise levels at nighttime greater than 55 dBA Leq from this Project’s concrete pour activities. That exceedance would likely occur because interior rooms with closed, double- glazed windows can reduce exterior noise levels only by about 20 dBA. (See Table 3 below). (Calculation: If exterior noise level is greater than 55 dBA – 20 dBA = then the interior noise level will be greater than 35 dBA). Many neighboring homes will be exposed to more than 55 dBA of nighttime concrete pour activity noise, creating a significant noise impact.

Table 3

online at: https://docs.vcrma.org/images/pdf/planning/ceqa/Construction_Noise_Thresholds.pdf. Also attached as Appendix A to this report.
28 Note that different descriptors are used in the Noise Study. An equivalent continuous (average) noise level represented by Leq can be approximately the same as an average noise level represented by L50 when noise source does not varying in loudness, and the real world difference is small enough that the exceedance of the 45 dBA L50 limit remains starkly obvious.

DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 19

As mentioned above, operation of just a single concrete mixer truck pouring the building foundation can generate noise levels at the exterior wall of the nearest home 220 feet away of about 72 dBA Leq. With a 20 dBA noise level reduction provided by the home’s wall assembly including closed windows, the interior noise level could be 52 dBA Leq.

Even homes as far away as 400 feet from the Project’s construction work could be exposed to exterior noise levels of approximately 67 dBA L
eq if intervening buildings do not block a
significant amount of noise. With a 20 dBA reduction when windows are closed, the interiors of such more distant homes could exceed 47 dBA Leq. 29 Those noise levels would certainly exceed the City’s maximum interior limit of 35 dBA Leq during concrete pour operations and create significant noise impacts.

V .4 The Temporary Increase in Noise Levels During Construction Would Also Create a Significant Noise Impact

CEQA requires the City to inform the public about how much of an increase in a project’s noise levels that nearby homes will be exposed to.30 But the Project’s Noise Study, pages 43 – 45, utterly fails to describe the magnitude of the increase in noise levels these neighbors will hear during concrete mixer truck or slab pouring construction activities. This failure is serious because the increase in noise levels at nearby homes caused by nighttime concrete pouring operation will be significant.

If the ambient (existing) noise level at the closest homes “that share acoustical equivalence” in the Noise Study averaged about 65.3 dBA L
eq at nighttime,31 the increase in noise levels would be

29 Calculation: 67 dBA – 20 dB = 47 dBA.
30 CEQA mandates the magnitude of such an increase be disclosed. (“A lead agency “should consider both the increase in noise levels and the absolute noise level associated with a project.” (Keep Our Mountains Quiet v. County of Santa Clara (2015) 236 Cal.App.4th 714, 732).); see also King and Gardiner Farms, LLC v. County of Kern et al. (2020) 45 Cal.App.5th 814, 887 (same quote).
31 See Noise Study, p. 24, Table 5-1 Ambient Noise Level Measurements, Location L5, Nighttime: 65.3 dBA Leq.

Inexplicably, the Noise Study provides no ambient noise level measurements for any of the several homes fronting on Cherry Avenue directly across the street from the proposed warehouse. Instead it uses the phrase “that share acoustical equivalence” to imply the noise level at these homes. Those are the homes that would be most severely DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 20 significant. As shown above, the average construction noise during concrete slab work at those closest homes 220 feet from the warehouse building would be about 72.5 dBA Leq. The Noise Study, p. 19, identifies even a 1.5 dBA increase in community noise to be significant when the existing ambient noise levels without the Project already exceed 65 dBA, so that increase of 7.2 dBA would be clearly significant.32

V .5 The Project’s 24-hour Average Construction Noise Level That Includes Night Work Could Exceed Permissible City Noise Standards, Even if Night Work Prohibited.

A common standard for determining the significance of noise impacts is the Day-Night Noise Level (“Ldn”). That is the average A-weighted noise level during a 24-hour day, obtained after the addition of 10 decibels to sound levels measured in the night between 10:00 p.m. and 7:00 a.m.

The day-night average standard was adopted by the EPA for developing criteria for the evaluation of community noise exposure, and it is used by California. In this Project’s nearby residential neighborhood, the 24-hour day-night average noise standard is 70 dBA Ldn.33 That is an applicable threshold of significance because noise levels greater than 70 dBA Ldn are considered to be “normally unacceptable” for residences.34

The Noise Study identifies that construction activities may occur during foundation work for all hours, day and night. If construction work emits an average of 85 dBA L eq at a 50-foot distance
non-stop (for example, the noise level of a single bulldozer), the day-night average noise level would be 91.4 dBA Ldn as shown below. It would be even greater when several pieces of heavy equipment are working simultaneously.

To calculate the dBA L
dn day-night average in this case, a level of 85.0 dBA Leq is assigned to each of the Project's 15 daytime construction hours from 7:00 am to 10:00 pm, and a nighttime construction noise level also of 85.0 dBA Leq is assumed for each of the remaining 9 hours.

L
dn = 10*LOG[(1/24) * (15 * [10EXP(0.1*Ld)] + 9 * [10EXP(0.1*(Ln + 10))])] =

91.4 dBA Ldn (at a 50 foot distance)

affected by construction noise. Measurement location “L5” is described being near a home at 1919 E. Hungerford Street which is located about 100 feet away from Cherry Avenue at a distance which may not be representative of the traffic noise levels of the closest homes. Moreover, that measurement location L5 is partially shielded acoustically by buildings to its east that front on Cherry Avenue. As such, this comment letter is based on the noise measurement data at L5 that the Noise Study provides even if it is questionable. 32 Calculation: 72.5 – 65.3 = 7.2 dB increase.
33 The Long Beach General Plan Noise Element, p. 138, states that “Ldn is the recommended day-njght average sound level not to be exceeded in a 24-hour period.”
34 General Plan Guidelines, Office of Planning and Research, California, Oct. 2003, page 250, Figure 2: 70 dBA Ldn.

Noise levels above 70 dBA Ldn are considered “normally unacceptable,” meaning that “new construction should generally be discouraged. If new construction does proceed, a detailed analysis of the noise reduction requirements must be made and needed noise insulation features included in the design.” https://www.ca- ilg.org/sites/main/files/file-attachments/resources__General_Plan_Guidelines_2003.pdf?1350954879 DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 21 (where * = multiplication; EXP = power function; Ld = Leq for the 15-hour daytime period from 7 am – 10 pm (85 dBA Leq); Ln = Leq for the 9-hour nighttime period from 10:00 pm – 7:00 am: (85 dBA Leq)

Then at the nearest residence about 220 feet away, that 24 hour day-night average construction noise level would diminish to 78.5 dBA L
dn.35 Or at a distance up to 400 feet from such
construction work where numerous homes exist west of Cherry Avenue, the day-night average noise level would be about 73.3 dBA Ldn.36 At both distances the noise impact of 24-hour construction work would be significant since greater than the 70 dBA Ldn threshold.

The Project’s 24-hour Average Construction Noise Levels Even Without Night Work Could Also Exceed the City’s Noise Standards.

If all the construction work is limited just to daytime hours, with no Project noise at nighttime from 10:00 p.m. to 7:00 a.m., the day-night average noise level would still be significant at some homes and greater than the 70 dBA L
dn threshold of significance. The dBA Ldn noise level would be about 83 dBA Ldn at 50 feet:

Ldn = 10*LOG[(1/24) * (15 * [10EXP(0.1*Ld)] + 9 * [10EXP(0.1*(Ln + 10))])] =

83.0 dBA Ldn (at a 50 foot distance)

(where * = multiplication; EXP = power function; Ld = Leq for the 15-hour daytime period from 7 am – 10 pm (85 dBA Leq); Ln = Leq for the 9-hour nighttime period from 10:00 pm – 7:00 am: (0 dBA Leq)

Then at a home 220 feet away from the northwest corner of the warehouse building, that 83.0 dBA L
dn noise level would reduce by distance to 70.1 dBA Ldn.37 That exterior day-night average noise level which would be greater than 70.0 dBA Ldn is considered normally unacceptable by federal and City standards. With the addition of other construction equipment noise from simultaneous use, and at distances on the Project site even closer potentially to the nearest home than 220 feet, the exceedance of this 70 dBA Ldn threshold could be even greater. Therefore even daytime construction work, with no work at all at nighttime, and without more noise mitigations, would have a significant noise impact to some homes west of Cherry Avenue.

The U.S. EPA considers a home’s outdoor areas exposed to greater than 55 dBA L dn to interfere
with activity and risk peoples’ health (EPA 1974, Information on levels of environmental noise, p. 40, Table 4).

35 Calculation: At 5945 Cherry Avenue, Home “C”, the exterior noise level resulting from the Project’s construction work 220' (d2) from that house, where the noise level is dB1 = 91.4 dBA Ldn at 50' (d1):
dB 2 = dB1 – 10 x A x LOG(d2/d1) = 91.4 – 10 x 2.0 x LOG(220'/50') = 91.4 - 20 x (-0.64) = 78.5 dBA Ldn 36 Calc’n: dB2 =dB1 –10 x A x LOG(d2/d1) = 91.4 – 10 x 2.0 x LOG(400'/50') = 91.4 - 20 x (-0.90) = 73.3 dBA Ldn 37 Calc’n: dB2 =dB1 –10 x A x LOG(d2/d1) = 83 – 10 x 2.0 x LOG(220'/50') = 83 - 20 x (-0.64) = 70.1 dBA Ldn

DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 22

VI. N OISE STUDY FAILS TO ANALYZE SIGNIFICANT BACKUP ALARM NOISE LEVELS.

The Noise Study fails to disclose that loud noise from heavy equipment backup warning beepers that would be used could be very audible at some homes near this Project site. Backup alarms or beepers are a frequent source of complaints from neighbors, even when used only during the daytime. Backup alarms must generate a noise level at least 5 to 10 dBA above the background noise in the vicinity of the rear of the machine where a person would be warned by the alarm.

Thus, they are significantly louder than the site excavation and grading equipment’s noise. Yet the Noise Study fails to disclose backup alarms would be used, and fails to describe their decibel rating or suggest placing any limits on their loudness.

Backup alarms typically produce from 97 to 112 decibels at four feet, 38 which attenuates to about
75 to 91 dBA at 50 feet,39 and can even be heard at the distances where the nearest neighbors live.

At those noise levels, their use would exceed the City’s maximum limit of 70 dBA Lmax at 50 feet as measured at those homes. These backup alarms beep about once per second at a penetrating frequency of about 1,100 Hertz designed to be easily heard by most people.

Because these alarms have a narrow frequency or tone, the City’s Noise Ordinance requires a 5 dB adjustment be added to their measured noise levels.
40 Also, the State of California Model
Community Noise Control Ordinance41 provides a more technical definition of tonal noise as the following: A pure tone shall exist if the one-third octave band sound pressure level in the band with the tone exceeds the arithmetic average of the sound pressure levels of the two contiguous one-third octave bands by 5 dB for center frequencies of 500 Hz. And above, by 8 dB for center frequencies between 160 and 400 Hz, and by 15 dB for center frequencies less than or equal to 125 Hz. Therefore, any noise source considered to consist of a pure tone(s) will be subject to a 5 dB penalty. Backup warning alarms emit pure tones. The City must apply that 5 dB penalty when assessing these alarms’ noise impacts on neighbors.

A single backup warning beeper emitting 91 dBA L
max at 50 feet could be louder than
78 dBA Lmax at homes 220 feet away. (Calculated being 6 dB quieter for each doubling of distance.) Noise levels of 78 dBA Lmax could be over 20 dBA greater than the daytime background noise level of less than 60 dBA Leq. That large difference would make the backup alarms very intrusive at nearby homes. That noise level would greatly exceed a maximum 5 dB

38 Source of back-up alarm noise levels from alarm manufactured by Pollak, #41-761, "Manually adjustable Back-up Alarm," rated at 112, 107, 97 dB.
39 Noise level attenuation due to distance is calculated as reduced by about 6 dB for each doubling of distance. 40 See LBMC § 8.18.160.
41 California Office of Noise Control, California Department of Health. Model Community Noise Control Ordinance. p. 21, April 1977
DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 23 increase standard used commonly throughout California. When a 5 dB penalty for its pure tone characteristic is included, the significant impact of backup beeper noise would be greater yet at 83 dBA Lmax at the nearest homes. That increase in noise level of 13 dB greater than the City’s maximum standard with backup alarm use would create a significant noise impact to the nearest residents.

The Noise Study is inadequate for failing to consider that such backup alarms will be used during construction work at least for the site preparation and the building foundation’s and exterior walls’ concrete pour activities.

DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 24 VII. THE PROJECT’S NOISE IMPACT ON A NEIGHBORING COMMERCIAL BUILDING

WOULD BE SIGNIFICANT

This Project would generate noise levels in excess of the City’s noise standards at its neighboring commercial building immediately to the south. The Los Angeles County’s Department of Animal Care and Control building is located about 250 feet south of the Project’s proposed warehouse building. The Project’s main, southern driveway for trucking and cars would be located between these two buildings, as close as about 160 feet to the County’s building. But the Noise Study does not evaluate this Project’s potentially serious noise impact during construction and later operations upon that nearby commercial building.

The City’s threshold of significance for average daytime operational noise when measured at a neighboring commercial building is 60 dBA L
eq. The maximum noise level exposure threshold for
such a commercial building is 75 dBA Lmax.42

FIGURE 6 - Commercial Building Exposed to Loud Warehouse Project Noise

During construction and during warehouse operations, the Project’s southern driveway nearest this County building would likely be used for truck traffic when hauling materials and when being accessed by workers. A single heavy truck loaded with construction or warehouse materials can, while passing by and accelerating at the end of the driveway, generate an average noise level of approximately 88 dBA Leq and a maximum noise level of about 95 dBA Lmax at 50 feet.43 At 160 feet to the County’s building, such heavy trucking noise is attenuated by distance to about 85 dBA Lmax.44 That noise level of 85 dBA Lmax or louder when truck movements occur in the driveway on the southwestern area of the Project’s site would exceed the maximum measured daytime ambient noise level of 79.3 dBA Lmax by over 5 dBA.45 In other words, such heavy

42 See Long Beach General Plan Noise Element, p. 137, Table 11. 43 See County of Ventura Construction Noise Threshold Criteria, Figure 2, Typical Construction Equipment Noise. 44 Calculation: The maximum noise level from the passing of a loaded heavy truck at a distance of 160 feet (d2) from the County’s building south of the warehouse driveway, where dB1 = 95 dBA Lmax at 50' (d1), dB2 = dB1 – 10 x A x LOG(d2/d1) = 95 – 10 x 2.0 x LOG(160'/50') = 95 - 20 x (-0.50) = 85 dBA Lmax . 45 Noise Study, PDF-1038, 24-Hour Noise Level Measurement Summary for Location L4 near 5881 Cherry Avenue (Intercity Fellowship Hall) at 10:00 a.m. (79.3 dBA Lmax) DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 25 delivery and semi-truck passings that close to this existing County building and in much greater numbers than currently occur, along with additional reflected noise from the warehouse’s tall walls, and loading dock noise, would be audible and intrusive to employees and animals there.

More importantly, such truck noise would significantly exceed the City’s allowable noise standards. Other site work activities closer than 160 feet would produce even louder noise levels at this commercial building, especially when more than a single piece of heavy construction equipment is operated simultaneously. The Project applicant is not proposing to install any temporary noise barrier to protect this County building that houses animals that can also be disturbed by loud construction noise. Nor is any permanent noise wall being proposed to shield some of the operational noise from such truck passings and other loading dock noise sources. That noise level there of 85 dBA L
max from truck passings would exceed the City’s daytime threshold of significance of 75 dBA Lmax and, therefore, is considered significant as a noise impact.

DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 26 VIII. Massive Warehouse Will Create Significant Noise Level Increases at Homes West of Cherry Avenue by Reflecting Traffic Noise to the West

The Project’s Noise Study entirely fails to acknowledge and analyze the severity of the noise impact to many existing homes that will occur from a large 50-foot tall warehouse that will be built over 400 feet long on the east side of Cherry Avenue. The west wall of such a huge warehouse, the height of a four-story building, will reflect existing and new traffic noise and new parking lot noise to the west where dozens of homes exist nearby. The resulting noise level increase just due to the sound energy that reflects from this building wall toward many nearby homes will be significant.

The existing project site does not currently have such a large building wall to reflect traffic noise:

F
IGURE 7
VIEW OF PROJECT WAREHOUSE SITE AS SEEN FROM A RESIDENCE WEST OF CHERRY AVE.

But as proposed, a new and very large warehouse building’s western wall would tend to reflect Cherry Avenue traffic noise in a western direction toward homes across the street:

FIGURE 8
SIMULATION OF PROJECT WAREHOUSE AS SEEN FROM A RESIDENCE WEST OF CHERRY AVE.

DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 27 The Project’s Noise Study measured existing noise levels near Cherry Avenue at about 67.8 dBA Leq during the daytime and 65.3 dBA Leq at nighttime.46 The 24-hour weighted day-night average of those measurements is approximately 72.5 dBA Ldn.47

Then, the Noise Study’s Table 4.1 describes a threshold of significance for an increase in noise levels during operations caused by the Project of 1.5 dBA L eq when the ambient noise level is
greater than 65 dBA Leq. That shows noise level measurements closest to the middle of the Project warehouse’s western wall are greater than 65 dBA Leq. Accordingly, if traffic noise levels increase at nearby homes by 1.5 dBA Leq or more, that would constitute a significant noise impact.

Vehicular traffic on Cherry Avenue is one of the main noise sources in the existing neighborhood.

It is well known that:
“In some cases, external building facades can influence reflected noise levels affecting adjacent buildings. This is primarily a problem where high-rise buildings are proposed, and the effect is most evident in urban areas, where an urban canyon may be created.” 48 According to CalTrans:
"A smooth, hard barrier surface, such as masonry or concrete, is considered almost perfectly reflective (i.e., almost all sound striking the barrier is reflected back toward the source and beyond). A barrier surface material that is porous, with many voids, is said to be absorptive (i.e., little or no sound is reflected back). The amount of energy absorbed by a barrier surface material is expressed as an absorption coefficient value ranging from 0 (100% reflective) to 1 (100% absorptive). A perfect reflective barrier, ( = 0) will reflect back virtually all noise energy (assuming a transmission loss of 30 dBA or more) toward the opposite side of a highway. If the difference in path length between the direct and reflected noise paths to the opposite (unprotected) side of a highway is ignored, the maximum expected increase in noise will be 3 dBA.”
49 46 See Noise Study, p. 24, Table 5-1: 24-Hour Ambient Noise Level Measurements, at noise measurement location L5, west of the Project site near single-family residence: Energy Average Noise Level: 67.8 dBA Leq (daytime); 65.3 dBA Leq (nighttime.)
47 Calculation: To calculate the dBA Ldn day-night weighted average for Cherry Avenue near the warehouse site, a level of 67.8 dBA Leq is assigned to each of the 15 daytime hours from 7:00 am to 10:00 pm, and a nighttime noise level also of 65.3 dBA Leq for each of the remaining 9 nighttime hours.

L dn = 10*LOG[(1/24) * (15 * [10EXP(0.1*Ld)] + 9 * [10EXP(0.1*(Ln + 10))])] = 72.5 dBA Ldn (where * = multiplication; EXP = power function; Ld = Leq for the 15-hour daytime period from 7 am – 10 pm (67.8 dBA Leq); Ln = Leq for the 9-hour nighttime period from 10:00 pm – 7:00 am: (65.3 dBA Leq) 48 Michael Brandman Associates (9/29/2011) DEIR Noise Section for Proposed City of Elk Grove Sphere of Influence Amendment, p. 3.12:4,
http://www.saclafco.org/SphereofInfluenceInformation/Documents/elkgrovesoi/proposedsoi_amenddeir/sac_029402. pdf; see also 1020 S. Figueroa St. (DCP Case No. ENV-2015-1159-EIR) DEIR, p. 4.2:2 (noting “A receptor located on the same side of the wall as a noise source may actually experience an increase in the perceived noise level as the wall reflects noise back to the receptor, thereby compounding the noise.”), http://planning.lacity.org/eir/1020SoFigueroa/DEIR/4_G_Noise.pdf; 1211 W. Pico Blvd. (DCP Case No. ENV-2011- 0585-EIR) DEIR, p. IV .E:2, https://planning.lacity.org/eir/ConventionCntr/DEIR/files/IV .E%20Noise.pdf. 49 CalTrans (Sep. 2013) Technical Noise Supplement. Part 1, p. 1:1 (prepared to provide technical background information on transportation-related noise in general and highway traffic noise in particular), https://www.sandiegocounty.gov/content/dam/sdc/pds/ceqa/Soitec-Documents/Final-EIR- Files/references/rtcref/ch2.6/2014-12-19_Caltrans_TrafficNoiseAnalysisProtocol_Part1.pdf; see DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 28

According to research from traffic engineering tests conducted elsewhere, when applied to this Cherry Avenue Warehouse Project, the reflected traffic noise that bounces from its building’s large western facade will add about 2 dBA to the directly-radiated Cherry Avenue traffic noise levels those nearby homes are currently exposed to.50 This warehouse’s western wall will be only about 100 feet from traffic lanes on Cherry Avenue.51 The facade-reflected noise will not be attenuated by any barrier at some homes. A 2 dBA noise level increase would be greater than the appropriate

1.5 dBA threshold of significance when existing noise levels are greater than 65 dBA Leq and is therefore a significant noise impact.

The Project’s cumulative noise impacts will be even greater when considering the other sources of noise the residential neighbors west of Cherry Avenue will be exposed to. That includes vehicle noise from additional traffic the warehouse operations will generate, mechanical equipment noise, and parking lot noise. So not only will this warehouse Project expose some residential neighbors to excessive noise levels that the warehouse operation generates, it additionally will expose neighbors to significantly greater noise levels originating from nearby traffic and reflecting from its tall western wall.

IX. Parking Lot and Driveway Mechanical Sweeper Use May Create Significant Noise Impacts at Some Homes West of Cherry Avenue.

The Project may occasionally employ a motorized, mechanical sweeper/vacuum to clean its large parking lot and driveway pavement areas. But that equipment can be very loud and could cause a significant noise impact to some nearby residents west of Cherry Avenue during its use. (See Figure 4 for illustration of the distances from the western parking lot to the closest homes.)

The Noise Study never evaluates the potential noise impacts that such mechanical sweepers can cause at nighttime when parking lots are more likely to be unobstructed by parked cars. No noise mitigation or Condition of Approval was proposed to restrict such nighttime pavement cleaning.

The Noise Study states that that the City of Long Beach’s nighttime maximum noise standard during project operations is 65 dBA L
max.52 Measurements of these mechanical sweepers/
pavement vacuums predict they can generate a maximum of 71 dBA Lmax at a distance of 100 feet.53 Some street sweepers are even louder.54 Based on that measurement data, at a distance of

also id., Part 2, p. 2:37, https://www.sandiegocounty.gov/content/dam/sdc/pds/ceqa/Soitec-Documents/Final-EIR- Files/references/rtcref/ch2.6/2014-12-19_Caltrans_TrafficNoiseAnalysisProtocol_Part2.pdf. 50 See Noise Control Engineering Journal (Jan. 2014) Traffic Noise and V ehicle Movement at a Controlled Intersection, p. 13 (stating that: “It was found that the facade reflection correction was equal to 2 dB … The value of 2 dB for the facade reflection correction is a reasonable value. It is 1 dB lower than the value of 3 dB corresponding to incoherent summation of equal-amplitude direct and reflected sound waves. The value of 2 dB for the correction implies that the reflected sound is about 2 dB weaker than the direct sound, since the incoherent sum of 0 dB and –2 dB is 2 dB. The 2 dB attenuation of the reflected sound is caused by two effects: i) absorption of sound energy by the facade, and ii) partial screening of the sound field by the parapet.”), attached hereto as “Attachment 6”. 51 Distance of 100 feet estimated from Project’s Site Plan. 52 See Noise Study, p. 15, Table 3-1, Operational Noise Standards, 10 p.m. to 7 a.m., standard is 65 dBA Lmax. 53 See the Environmental Noise Assessment for the Galt Walmart EIR in the City of Galt, CA, November 23, 2009, which states on page 30: “Based upon noise measurements of mechanical parking lot sweeping/vacuuming, noise levels from parking lot cleaning are approximately 62 dB Leq and 71 dB Lmax at a distance of 100 feet from the center DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 29 about 150 feet from the Project’s Cherry Avenue side western parking lot and northern driveway to the nearest home across the street at 5945 Cherry Avenue, that sweeper noise level would be about

67.5 dBA Lmax.55 That noise level exceeds the City’s 65 dBA Lmax nighttime standard and would therefore create a significant noise impact. Some other homes could also be exposed to excessive sweeper noise levels that exceed the City’s 65 dBA Lmax limit up to about 200 feet away.

Such mechanical sweeper noise would be clearly audible and disturbing at some homes as well.

With the background noise level
56 at nighttime sometimes being about 51 dBA L90, the sweeper noise at 67.5 dBA Lmax would be about 16 dBA louder than the background noise level then. That represents a significant increase in noise level due to this project, another type of significant noise impact.

Neighbors are likely to experience significant sleep-disturbance from such intrusive noise at night.

That noise level from sweeper use at the exterior of this nearest house west of Cherry Avenue would also generate interior noise levels inside this house greater than the City’s maximum limit of 35 dBA per LBMC § 8.18.170(A).
57 With closed windows reducing the exterior noise level by about 20 dB, the interior noise level in the house during sweeper operations could be 47.5 dBA Lmax, loud enough to wake residents and 12.5 dB greater than the City’s maximum interior limit of 35 dBA.

of the parking lot cleaning activities.” This study will be made available to City officials if requested, and it is also available online at: https://www.cityofgalt.org/home/showdocument?id=2781 54 See Park Habitat Project Nighttime Construction Noise Assessment, San José, California, July 7, 2021; page 11, Street Sweeper: 80 dBA Lmax at 50 feet, (which reduces by distance to about 74 dBA Lmax at 100 feet.) This report is available online at: https://www.sanjoseca.gov/home/showpublisheddocument/77667/637685200947630000 55 Calculation: at the home at 5945 Cherry Avenue, the noise level from the operation of a mechanical sweeper/ pavement vacuum at a location in the parking lot 150' (d2) from the home, where dB1 = 71 dBA Lmax at 100' (d1), dB 2 = dB1 – 10 x A x LOG(d2/d1) = 71 – 10 x 2.0 x LOG(150'/100') = 71 - 20 x (-0.64) = 67.5 dBA Lmax . 56 See Figure 2 above with a Location L5 Background L90 Noise Level of 50.7 dBA L90 at midnight. 57 Calculation: exterior 67.5 dBA Lmax – 20 dB with windows closed = 47.5 dBA Lmax interior noise level.

DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 30 X. D EFICIENCIES WITH PROJECT’S NOISE STUDY

The Project’s Noise Study prepared by Urban Crossroads, Inc. is incomplete, inaccurate, and entirely conclusory, The Noise Study fails to describe the factors used in estimating the concrete slab pour work. Merely referencing some other project’s noise measurements obtained at 27334 San Bernardino in the City of Redlands is inadequate under CEQA. It provides no way for the public to independently assess the veracity of such distant and also vague evidence. The Noise Study’s calculation factors in Appendix 8-2 (“CadmaA” model input data) are missing essential information that would allow the public to verify the calculations. For example, none of the buildings’ locations used in the calculation model are shown on any map in the Noise Study that would allow someone to check those calculations.

The Noise Study’s calculations also depend upon a noise test for that Redlands concrete slab pour project with no explanation of how its purported measurement of 100.3 dBA L w (a sound power
level) is used in any agency’s regulations and expressed in decibels such as dBA Leq. As such, this cryptic study violates CEQA by making obscure the analytic data and reasoning that would allow the public to independently review the Noise Study’s conclusions.

The Noise Study uses average noise levels, but never analyzes if such concrete construction noise would exceed the City’s maximum allowed noise levels. It is those maximum noise levels that are most starkly troublesome and sleep-disturbing to nearby residents since those peak levels will be clearly audible above the ambient noise levels in their neighborhood.

The Noise Study also fails to identify on any map all the nearest homes which could be exposed to this Project’s noise. Because construction noise from concrete mixer trucks that includes backup warning horns can be so loud at night, some neighboring residents west of Cherry Avenue could be significantly disturbed. If those noise levels at their homes exceed 65 dBA L max at night, that
construction work would create a significant noise impact.58

The Noise Study provides no analysis of the noise contribution to the surrounding community that will result from the addition of this warehouse Project’s additional heavy truck traffic and other vehicles along major routes of travel. No traffic study is provided with traffic flow direction so that the public can assess the significance of such increased traffic noise on roads that are already excessively noisy.

The Noise Study does not indicate if the tilt-up exterior concrete walls of the warehouse will be constructed on-site or delivered from elsewhere, a factor that can affect the construction noise levels.

The Noise Study entirely fails to evaluate the potential for the Project to create significant noise impacts to the interior noise level of nearby buildings and homes.

The noise study fails to describe sufficiently where the noise level measurements were obtained and whether the noise meters were calibrated during these measurements.

58 A threshold of significance for nighttime construction work is 65 dBA Lmax. Source: LBMC § 8.80.150(B)(5).

DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 31

XI. ADDITIONAL MITIGATION MEASURES ARE NECESSARY PURSUANT TO AN

ADEQUATE MND OR EIR

Critical to the MND/EIR review process is the consideration of mitigation measures (“MMs”) and project design features (“PDFs”) to reduce a project’s impact to less than significant, which can subsequently be made enforceable as mandatory COAs. Here, because the Project was reviewed per a categorical exemption, MMs were not analyzed or vetted by the public and, therefore, any ad hoc noise-related COAs imposed by the City at this stage would be untethered to reasoned analysis. This is a sharp deviation of the City’s practice for similar projects, where it considers various standard MMs and PDFs that serve to directly or indirectly reduce a project’s noise impacts below the City’s thresholds of significance, which are entirely missing from the Project’s current COAs. Among these operational noise-related MMs/PDFs/COAs considered for other nearby projects and/or hotel developments within the City59—but missing from the Project’s COAs—include:

CONSTRUCTION NOISE

MM-1 TEMPORARY NOISE BARRIER
60 (with noise barrier also on driveway closure gates)

A 12-foot-tall temporary noise barrier shall be installed along the western Project site boundary, and extending a minimum of 100 feet to the east along both the northern and southern property lines starting from Cherry Avenue, for the duration of Project construction. The temporary noise barrier shall have a solid face from top to bottom and shall meet the following minimum standards:

a) The temporary noise barrier shall provide a minimum transmission loss of 20 dBA (Federal Highway Administration, Noise Barrier Design Handbook). The noise barrier shall be constructed using an acoustical blanket (e.g. vinyl acoustic curtains or quilted blankets) attached to a construction site perimeter fence or equivalent temporary fence posts or barrier materials;

59 See e.g., Second + PCH Development Project (Mar. 2011) EIR, pp. IV .I:312, http://www.lbds.info/civica/filebank/blobdload.asp?BlobID=3375; Belmont Pool Revitalization Project (Apr. 2016) Draft EIR, pp. 4.10:16, 19-21, 25, http://www.lbds.info/civica/filebank/blobdload.asp?BlobID=5781; Midtown Specific Plan (Mar. 2016) Final EIR, p. 4:22 (MM N-5),
http://www.lbds.info/civica/filebank/blobdload.asp?BlobID=5765; Civic Center Project (Oct. 2015) Final Supplemental EIR, pp. 9:38-39 (MMs DT Noise-5-7, and SEIR Noise 2(b)), http://www.lbds.info/civica/filebank/blobdload.asp?BlobID=5574 ; Golden Shore Master Plan Project (Jan. 2010)
Final EIR, pp. V:14- (MMs G-5, G-6), http://www.lbds.info/civica/filebank/blobdload.asp?BlobID=3330; 60 Mitigation measures MM-1 to MM-5 are from the 2019 Draft EIR for the Slover/Cactus Avenue Warehouse Project in the County of San Bernardino, Pages S-22 to S-23. Note: MM-1 is modified by adding 100-foot long side barriers and driveway gate noise barriers. Urban Crossroads prepared this Project’s noise impact analysis. The Draft EIR is available online at:
http://www.sbcounty.gov/Uploads/LUS/Environmental/Alere%20Property%20Group/Slover%20and%20Cactus%20 Avenue%20Warehouse%20-%20Public%20Review%20Draft%20EIR%20(November%202019).pdf DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 32 b) The noise barrier must be maintained, and any damage promptly repaired. Gaps, holes, or weaknesses in the barrier or openings between the barrier and the ground shall be promptly repaired; and

c) The noise control barrier and associated elements shall be completely removed upon the conclusion of the construction activity.

MM-2 Construction contractors sh all equip all construction equipment, fixed or mobile, with properly operating and maintained mufflers, consistent with manufacturer’s standards.

MM-3 Construction contractors shall place all stationary construction equipment so that all emitted noise is generated and directed toward the center of the site and away from the noise sensitive receivers nearest the Project site.

MM-4 Construction contractors shall locate equipment staging areas on the Project site in locations that will create the greatest feasible distance between construction related noise sources and noise sensitive receivers nearest the Project site.

MM-5 Construction contractors shall ensure that delivery trucks use designated truck route(s).

MM-6 CONSTRUCTION NOISE LIMITS
: As measured at nearby sensitive receptors, the
maximum construction noise levels shall not exceed 70 dBA Leq-1 hr. during the daytime, and 65 dBA Leq-1 hr. at nighttime.

For construction noise that has an impulsive character or pure tones, these maximum noise levels will be adjusted with a 5 dB lowered limit pursuant to the California Model Noise Ordinance which includes a 5 dB penalty for noise of certain character, namely, noise that contains ''a steady, audible tone such as a whine, screech, or hum, or is a repetitive noise such as hammering or riveting, or contains music or speech. " [CNMO at p. 21]

MM-7 Prohibit amplified sound system noise or l oudspeaker use during construction activities.

MM-8 Prohibit backup alarms on heavy equipment, and instead using warning devices that cannot be heard from nearby residential properties to the west of Cherry Avenue.

MM-9 Require construction activities to be placed as far as possible from the nearest off-site land uses.

MM-10 Require construction and demolition activities to be scheduled to avoid operating several loud pieces of equipment simultaneously; alternatively, to reduce the overall length of the construction period, combine noisy operations to occur in the same time period if it will not be significantly greater than if operations were performed separately.

MM-11 Require the replacement of noisy equipment with quieter equipment, such as utilizing vibratory pile driver instead of conventional pile driver (or even prohibit the use of driven (impact) pile systems altogether), using rubber-tired equipment rather than track DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 33 equipment, or using quieted and enclosed air compressors with properly working mufflers on all engines.

MM-12 Require construction contractor to avoid using vibratory rollers and packers near sensitive areas of the southern side of the site near the County’s Department of Animal Care and Control building.

MM-13 Require construction staging areas to be as far from sensitive receptors as reasonably possible.

MM-14 Require all construction truck traffic to be restricted to daytime hours only and to truck routes approved by the Department of Building and Safety, which shall avoid residential areas and other noise-sensitive receptors.

MM-15 Require flexible sound control curtains to be placed around all drilling apparatuses, drill rigs, and jackhammers when in use and more extensive noise control barriers protecting the nearest residential structures west of Cherry Avenue.

MM-16 Require power construction equipment operated at the project site to be equipped with effective state-of-the-art noise control devices (e.g., equipment mufflers, enclosures, and barriers) with contractors maintaining all sound-reducing devices and restrictions throughout the construction period and keeping documentation showing compliance.

MM-17 Require contractors to use either plug-in electric or solar powered on-site generators to the extent feasible.

MM-18 Require grading and construction contractors to use equipment that generates lower vibration levels such as rubber-tired equipment rather than metal-tracked equipment, such as a combination loader/excavator for light-duty construction operations.

MM-19 Install low-noise asphalt pavement only within the property.

MM-20 Two weeks before the commencement of construction at the Project Site, require notification to be provided to the immediate surrounding off-site properties located within 500 ft of the Project site that discloses the construction schedule, including the various types of activities and equipment that would be occurring throughout the construction period. A noise disturbance coordinator and hotline telephone number shall be provided to enable the public to call and address construction-related issues. The disturbance coordinator should be responsible for responding to any local complaints about construction noise. The disturbance coordinator should determine the cause of the noise complaint (e.g., starting too early, bad muffler) and should be required to implement reasonable measures to reduce noise levels.

MM-21 Require a list of all mitigation measures restricting construction activity to be posted at the Project Site on a sign legible at a distance of 50 ft and all construction personnel shall be instructed as to the nature of the noise and vibration mitigation measures.

DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 34

MM-22 Require a noise monitoring/control plan that includes absolute noise limits for classes of equipment, noise limits at lot lines of specific noise sensitive properties, specific noise control treatments to be utilized (such as the above-mentioned measures), and a designated compliance officer to respond to promptly respond to complaints and take immediate correction action if limits/restrictions are not complied with.

GROUND-BORNE VIBRATION-RELATED CONSTRUCTION ACTIVITIES:

MM-23 Prior to approval of grading plans and/or prior to issuance of demolition, grading and building permits, the Applicant shall retain a Professional Structural Engineer with experience in structural vibration analysis and monitoring to perform the following tasks:

• Review the Project plans for demolition and construction.

• Survey the Project site, includ ing geological testing, if required.

• Prepare and submit a report to the Director of Planning and Community Development to include but not be limited to the following:

 Description of existing conditions at the nearby County’s Department of Animal Care and Control building;
 Vibration level limits based on building conditions, soil conditions, and planned demolition and construction methods to ensure vibration levels below the potential for damage to the County’s Department of Animal Care and Control building;  Specific measures to be taken during construction to ensure the specified vibration level limits are not exceeded; and
 If considered appropriate, a monitoring plan is to be implemented during demolition and construction that includes post-construction and post-demolition surveys of the County’s Department of Animal Care and Control building. 
Examples of measures that may be specified for implementation during demolition or construction include, but are not limited to:
 Prohibition of certain types of impact equipment such as a pile driver;  Requirement for lighter tracked or wheeled equipment;  The specification that demolition occur by non-impact methods, such as sawing concrete;  The specification that phasing operations avoid simultaneous vibration sources; and  Installation of vibration-measuring devices to guide decision making for subsequent activities.

OPERATIONAL NOISE

MM-24 Perform a full traffic study to evaluate the impact of this Project’s off-site trucking along the major routes of travel. Include traffic routing restrictions to forbid Project traffic in residential areas and restrain trucks and vehicles from clogging up important commuting routes used for busses and other vehicles.

DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 35

MM-25 Limit diesel trucks or equipment idling to 3 minutes and post signs regarding the idling restriction.

MM-26 Prohibit trucks with refrigeration units or refrigeration trailers from operating onsite where such refrigeration equipment would be audible to neighboring residents or nearby property owners.

MM-27 Limit access in and out of the facility to the hours of 6 a.m. to 10 p.m.

MM-28 Prohibit mechanical sweeper use in the Cherry Avenue side parking lot at nighttime to eliminate its noise that will reflect off of the tall warehouse walls and will also directly reach homes west of Cherry Avenue.

MM-29 Prohibit backup alarms on heavy equipment and forklifts, and instead using warning devices that cannot be heard from nearby residential properties to the west of Cherry Avenue.

MM-30 Clearly post on the facility and on the city website how the public can make complaints of facility truck traffic outside of hours excessive dust, fumes, or odors as well as report parking issues.

MM-31 Prohibit the use of any mechanical equipment, exterior fans or HV AC equipment that is audible to residents living west of Cherry Avenue at any time of the day. Rooftops with HV AC units shall include an architectural parapet to reduce noise levels. The parapet shall be constructed along the edges of the structures’ roofs. The parapet shall be at least one foot higher than the tallest rooftop equipment. No gaps or perforations shall be constructed in the parapet.

MM-32 Limit the use of the site to prohibit potential noise generating uses that otherwise are allowed by right within the zone classification of the project site.

MM-33 Prohibition of amplified sounds in outdoor spaces and/or meet specified dBA levels.

Orienting any public address systems onsite away from sensitive receptors and setting system volume at a level not readily audible past the property line

MM-34 Before the issuance of a Certificate of Occupancy, require the sound levels to be measured consistent with documentation of the measurements being submitted to the Department of City Planning for the file to demonstrate specified noise levels are not exceeded at the property line.

MM-35 Post signs indicating that all parking and maintenance of trucks must be conducted within designated on-site areas and not within the surrounding community or public streets.

DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 36 MM-36 Provide nearest residences affected by this Project’s significant construction and operational noise impacts with sound-resistant windows and doors and/or upgraded ventilation systems as a noise mitigation measure.

Require the placement of loading and unloading areas so that Project building and features shield nearby residential and commercial land uses from loud noise generated by parking lot, loading dock and delivery activities. If necessary, additional sound barriers shall be constructed adjacent to the nearby commercial building to protect occupants from excessive noise.

Sound-Rated Windows and Glass Doors Near Commercial Use: If adequate noise barrier walls are not provided to the south of the warehouse building, the applicant shall offer and pay for sound-rated windows and glass doors at the County’s building to the south. Windows shall be at least STC 35 to ensure that this Project’s warehouse activities do not result in interior noise levels at the County’s building exceeding 35 dBA.

CONCLUSION

As discussed above, the Project applicant has failed to provide basic information required for the City to adequately assess the true impacts of this Project. As a result, construction and operational noise impacts were never adequately analyzed. Review of these unresolved noise impacts clearly demonstrates a categorical exemption is inappropriate for the Project’s CEQA review. This inapplicability is further supported by the fact that the City incorporated some Project-specific noise mitigation measures without public scrutiny that CEQA affords.

Moreover, feasible mitigation measures are available and need to be considered pursuant to a CEQA-compliant MND or EIR— just like similar projects reviewed by the City.

Sincerely,

________________________________
Dale La Forest
Professional Planner, Designer, INCE Associate (Institute of Noise Control Engineering) Dale La Forest & Associates

Attachment 1: Statement of Qualifications, Dale La Forest & Associates Appendix A: Typical Construction Eq uipment Noise, County of Ventura Appendix B: Existing Google Earth “Photographs” of Project Neighborhood

DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 37 ATTACHMENT 1
Statement of Qualifications

Dale La Forest & Associates
Design, Planning & Environmental Consulting
101 E. Alma Street, Suite 100-A
Mt. Shasta, CA 96067
(530) 918-8625

INTRODUCTION

Dale La Forest & Associates provides commercial and residential design services, acoustical consulting, environmental review, project planning permitting for government approvals and multi-disciplinary environmental studies for government and private industry and citizens groups.

HIGHLIGHTS

Dale La Forest has over 47 years experience in California environmental and land use planning. He has assisted numerous citizens groups, developers and interested parties in reviewing proposed projects for compliance with planning and environmental regulations in their communities.

During the last 27 years, he has also prepared expert acoustical studies for various development projects and reviewed and commented upon dozens of noise studies prepared by others.

Dale La Forest's design, planning and environmental review experience is supported by a group of consulting planning, architectural / landscape architectural, and engineering professionals selected for their professional yet pragmatic approaches to their specialties. Teams are organized on a project-by-project basis to address project-specific issues.

EXPERIENCE

1975 – 2023 DESIGNER & PLANNER — Dale La Forest & Associates ; Mt. Shasta, CA.

Design of commercial, residential, subdi vision planning projects and environmental and acoustical consulting for commercial and industrial firms and for the public.

Dale La Forest, Designer, INCE Associat e (Institute of Noise Control Engineering)

EDUCATION
1966 – 1973 University of Michigan, College of Architecture and Planning - Bachelor of Architecture, 1973; and Masters studies in architecture and planning.

DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 38

ACOUSTICAL RESEARCH PROJECTS

3/17/21 Pacific Edge Hotel Remodel Pr oject, MND, City of Laguna Beach, CA 1/25/21 Hyatt House Hotel Project, C.E., Los Angeles, CA 8/15/20 Redhills Bioenergy Project, MND, Lake County, CA 8/28/19 CitizenM Hotel Projec t, DEIR, Los Angeles, CA
4/15/19 Mart South Hotel Conversion Project, C.E., Los Angeles, CA 2/27/19 Citizens News Project MND, Los Angeles, CA
2/11/19 2005 James Wood Hotel Project MND, Los Angeles, CA 2/4/19 Breakers Hotel Project C.E., Long Beach, CA
1/23/19 Residence at 1888 N. Lucile Ave. MND, Los Angeles, CA 12/5/18 100 E. Sunset Bridge Housing C.E., Los Angeles, CA 11/6/18 Dewey Hotel Project C.E., Los Angeles, CA
2/12/18 Residence at 17642 Tramonto Dr., Los Angeles, CA 11/16/17 Crystal Geyser Water Company EIR, Mt Shasta, CA 8/18/17 Freeze Car Wash Project MND, Mt. Shasta, CA
3/13/17 Roseburg Water Line Pr oject MND, Mt. Shasta, CA 1/19/17 Residence at 2056 Mandevill e Canyon Rd., Los Angeles, CA 8/31/16 Austin Quarry Projec t EIR, Madera County, CA
10/20/15 Syar Napa Quarry E xpansion Project EIR, Napa
9/30/13 Shasta Dam Raising Draf t EIS, Shasta County, CA 9/30/13 Livermore Walmart Project, Livermore, CA
8/27/13 Talmage Interchange Reconstruction Project MND, Ukiah, CA 6/10/13 Townhouse Project MND, Mt. Shasta, CA
3/15/13 Costco Wholesale Store DEIR, Ukiah, CA
3/14/13 Jaxon Enterprises Asphalt Plant IS/MND, Shasta County, CA 3/14/13 Amdun LLC Asphalt Plant IS/MND, Shasta County, CA 1/30/13 Grist Creek Aggregates Proj ect IS/MND, Mendocino County, CA 9/24/12 Austin Quarry Draft EIR, Madera County, CA
8/26/12 Tesoro Viejo Specific Plan Revised EIR, Madera County, CA 10/10/11 Eagle Peak Asphalt Batch plant MND, Callahan, CA 6/12/11 Walmart Expansion Project EIR, Poway, CA
2/20/11 McCloud Springs Ranch Subdivi sion MND, Siskiyou County, CA 1/4/11 Comingdeer Asphalt Batch Plant MND, Redding, CA 10/1/10 Biogreen Cogeneration Power Plant, La Pine, OR 7/13/10 Chapin Concrete Batch Plant MND, V olta, CA
1/25/10 Walmart Supercente r Draft EIR, Galt, CA
1/11/10 Doctor’s Park MND, Mt. Shasta, CA
9/22/09 Livingston Concrete EIR, Placer County, CA
6/10/09 Poonkinney Quarry MND, Mendocino County, CA
5/11/09 Orchard Subdivision M ND, City of Mt. Shasta, CA 1/2/09 McCloud Springs Ranch Subdi vision MND, Siskiyou County, CA 10/8/02 Shasta Mountain Lodge Hotel 2 (S pringhill Dr.), MND, Mt. Shasta, CA 10/10/95 Shasta Mountain Lodge Hotel 1 (M t. Shasta Blvd.), MND, Mt. Shasta, CA

DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 39

Appendix A: County of Ventura, Construction Noise Threshold Criteria (2010) https://docs.vcrma.org/images/pdf/planning/ceqa/Construction_Noise_Thresholds.pdf

DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 40 Appendix B - Existing Google Earth “Photographs” of Project Neighborhood

Figure 9 – Homes and Businesses Across Cherry Avenue from Project Site (Southern portion)

Figure 10– Homes and Businesses Across Cherry Ave. from Project Site (Northern portion)

DL&A Noise Report – 2/5/2023 - Cherry Avenue Warehouse Project, Long Beach, CA Page 41 Figure 11 – Homes and Businesses Across Cherry Avenue from Existing Project Site

Note: Figures 9 and 10 above are essentially segmented enlargements of the upper half of this Figure 11.

EXHIBIT C

8451 Miralani Drive, Suite A • San Diego, CA 92123 • (858) 560-4911 1 ATTN: Jordan Sisson
Law Office of Jordan R. Sisson E-Mail: ▼
[email protected]
FROM: Justin P. Schlaefli, PE TE TOTAL PAGES (Including Cover):

DATE: April 5, 2023 TIME: 10:15:32
AM JOB NUMBER: N/A
SUBJECT: 5910 Cherry Ave- Transportation and VMT Comments Confidential Communications
This transmittal is intended for the recipient named above. Unless otherwise expressly indicated, this entire communication is confidential and privileged information. If you are not the intended recipient, do not disclose, copy, distribute or use this information. If you received this transmission in error, please notify us immediately by telephone, at our expense and destroy the information.

I have reviewed the information provided on the City of Long Beach website concerning analysis of the proposed 303,972-square-foot concrete, tilt-up industrial warehouse building, including 9,000-square-feet of office space at 5900/5910 Cherry Avenue in Long Beach. After reviewing the file, I conclude that the analysis of transportation impacts of the project is inconclusive.

Specifically, the project was analyzed as a traditional Land Use 155 (High Cube Warehouse Non-Sort) with up to 15% cold storage warehouse. Trip generation assumptions are fundamental to all conclusions related to transportation including Vehicle Miles Traveled (VMT) and level of service (LOS) impacts and mitigation.

Therefore, it is critical for screening and analysis purposes to properly analyze trip generation for a project site.

Within the warehouse category, there have been substantial changes in the past several years as supply-chain and logistics models have evolved with e-commerce and other variables. As a result, traditional warehouse which had relatively low trip generation is no longer common for larger warehouse projects (exceeding 200,000 sf). This has led to shifts in industry standard references such as ITE, Trip Generation as well as localized studies such as NAIOP and South Coast AQMD. Primary findings from some of these studies include the following from an October 2016 study of high-cube warehouse trip generation:
“The HCW market continues to evolve as individual tenants/owners implement different ecommerce business plans. For example, some deliver goods to the customer within two days and others deliver orders to the nearest store for customer pick-up. As business plans and technology continue to evolve, these should continue to be monitored. Although the tenant or its planned operations are often unknown at the time of site development review, for the purpose of estimating vehicle trip generation, it may be as important to know the tenant as much as other facility factors”,
(https://www.ite.org/pub/?id=a3e6679a%2De3a8%2Dbf38%2D7f29%2D2961becdd498).

Due to the wide variation in trip rates noted, it is recommended that a site either commit to a particular category of user and/or evaluate the worst-case allowable under zoning and entitlements. If this process were followed, a worst-case analysis would lead to additional analysis and would not be screened out of providing either VMT or MEMO
Jordan Sisson © Urban Systems Associates, Inc.

Law Office of Jordon R. Sisson 4/5/2023

8451 Miralani Drive, Suite A • San Diego, CA 92123 • (858) 560-4911 2 LOS analysis under the City’s guidelines. It is noted that a proposed condition of approval for the subject project involves trip generation monitoring:

It is recommended that this trip generation and trip distribution analysis not be delayed or deferred for the proposed project. In addition, either limitations on use consistent with the trip generation analyzed for the project in advance of hearing should be imposed or the worst-case scenario, consistent with entitlements should be utilized in determining whether a project is screened out of additional analysis. This is critical to understanding the full impacts of a proposed project.

Furthermore, the Project’s VMT analysis’s conclusion that the project meets the Small Project Low Trip Generator screening criteria is incorrect. This determination is premised on the project resulting in a net increase of 448 vehicle trip-ends per day and below the 500 average daily trip (ADT) threshold under the City of Long Beach Traffic Impact Analysis Guidelines (June 2020) (City Guidelines).1 However, there are several flaws with this analysis.

First, nowhere does the City Guidelines mention industrial uses as being eligible for the small project screening criteria (see City Guidelines, p. 5). The logic of this small project criteria is echoed in the Governor’s Office of Planning and Research released a Technical Advisory on Evaluating Transportation Impacts in CEQA (December of 2018) (OPR Technical Advisory).2 OPR’s screening threshold of 110 daily trips is premised on relatively small projects of 10,000 square feet, including general office building, single tenant office building, office park, and business parks (see OPR Technical Advisory, p. 12). Here, the project replaces 32,815 square feet of existing office/building uses into a 303,972 square foot warehouse development for a net 271,157 square foot increase in uses—well above 10,000 square feet and any common understanding of a typical small project.

Second, the City’s small project threshold is 500 ADTs—not 500 vehicle trip ends (see City Guidelines, pp. 4-

5.) The VMT analysis 448 daily vehicle trip ends are based on the difference between the proposed 564 actual vehicle trips (i.e., 470 passenger car trips + 94 truck trips) and existing 116 actual vehicle trips (i.e., 112 passenger car trips + 4 truck trips). This analysis fails to convert the truck trips into passenger care equivalent (PCE), as mentioned in the City Guidelines (p. 16) indicating a “PCE factor of 2.0 should be used for all heavy- duty trucks.” This is what the Project did for its LOS analysis, which clearly indicates that existing uses generate 120 PCE daily trips compared to the proposed warehouse generating 658 PCE daily trips—for a net increase in 538 PCE daily trips,3 which exceeds the 500 ADT threshold.

Please refer to the attached resume for my credentials and information. 1 https://www.longbeach.gov/globalassets/lbds/media-library/documents/planning/environmental/environmental-planning/tia- guidelines.
2 https://opr.ca.gov/docs/20190122-743_Technical_Advisory.pdf. 3 See Urban Crossroads Cherry Avenue Warehouse Traffic Assessment (Mar. 30, 2022), Tbl. 4.

Responsibilities/ Qualifications
Mr. Schlaefli is President of Urban Systems Associates. He is responsible for managing projects on a day -to-day basis as well as interfacing with other project team members and decision makers/ government staff. He has over seventeen years of experience specializing in Transportation Planning, Construction, Traffic Engineering and Traffic Operations.

He has experience working on both public sector projects as well as private sector development. His experience
ranges from conducting traffic studies to specialized access analysis, parking studies, trip generation studies, traffic micro-simulation, signal operations, traffic control and design/selection of ITS solutions. In addition, Mr. Schlaefli has served as a subject matter expert in court, for the State of California and for vendors in the transportation industry.

Mr. Schlaefli has also served as adjunct faculty at San Diego State University teaching our next generation of
Transportation Engineers.

Mr. Schlaefli’s unique experience includes creating Ur ban Systems’ industry-leading Signal Lab. This Lab is designed to test and integrate the latest technology and is intended to assist Urban Systems in solving some of the most complex traffic operations challenges. In addition to creating the Signal Lab, Mr. Schlaefli has field experience leading
design/build teams and serving as a Resident Engineer
involved in the upgrade and synchronization of almost 150 traffic signals .

Additionally, Mr. Schlaefli has served as
Contract Traffic Engineer for multiple mu nicipalities. This diverse and wide-ranging experience in the office, the field and the lab keeps Urban Systems at the forefront of the transportation industry.

Justin P. Schlaefli
President

EDUCATION AND LICENSES
Bachelor of Science, Civil Engineering
San Diego State University 2005
Master of Civil Engineering
Norwich University 2007
Registered Civil Engineer
California RCE# 74670, 2009
Registered Traffic Engineer
California RTE# 2564, 2010
IMSA Level II Signal Technician—Field
Certified Fiber Optic Technician

EXPERIENCE
Urban Systems Associates Inc.-
Engineering Technician, Project Manager,
Senior Project Manager
Contract City Traffic Engineer-
Calimesa, Wildomar, Rialto & Hesperia
National Academy of Sciences,
Transportation Research Board
Traffic Advisory Committee-
County of San Diego

PROJECT EXPERIENCE
CV Sync- CVAG
City of Chula Vista Adaptive System
Lusk Boulevard Adaptive System (Design/Build)
Main Street Corridor Signal Improvement and
Synchronization Program (Design/Build)
City of Hesperia
Riverwalk Master Plan
Camino Del Rio Mixed-Use
As-Needed ITS Services
City of Hesperia
Contract Traffic Engineering Services
City of Hesperia
City of Wildomar
City of Rialto
City of Calimesa
ViaSat Pedestrian Signal
Signal Synchronization System-
Coachella Valley Association of Gov.

El Corazon Roundabouts–
Sudberry Properties
Citywide Engineering & Traffic Survey
Ciry of Coachella

SPECIAL SKILLS
Environmental Impact Assessment (Transportation)
Civil & Traffic Engineering
Project Management
Construction Management
Business Management
Expert Witness
Access Evaluation
Parking Evaluation
Traffic Simulation/Forecasting
Roundabout Analysis
Geographic Information System (GIS)
Traffic Operations
ITS/Adaptive Traffic Control Systems
Traffic Signal Timing
Construction Management

EXHIBIT D

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]
April 3, 2023
Jordan Sisson
Law Office of Gideon Kracov
801 S. Grand Ave., 11th Floor
Los Angeles, CA 90017
Subject: Comments on the Cherry Avenue Warehouse Project Dear Mr. Sisson,
We have reviewed the October 2022 Staff Report for the Cherry Avenue Warehouse (“Project”) located in the City of Long Beach (“City”). The Project proposes to construct a 303,972-square-foot (“SF”) warehouse, 9,000-SF of office space, and 559 parking spaces on the 14.16-acre site.

Our review concludes that the Staff Report fails to adequately evaluate the Project’s air quality, health risk, and greenhouse gas impacts. As a result, emissions and health risk impacts associated with construction and operation of the proposed Project are underestimated and inadequately addressed. A full CEQA analysis should be prepared to adequately assess and mitigate the potential hazards, hazardous materials, air quality, health risk, and greenhouse gas impacts that the project may have on the environment.

Air Quality
Unsubstantiated Input Parameters Used to Estimate Project Emissions The Air Quality Impact Analysis (“AQIA”), included in Attachment E to the Staff Report, relies on emissions calculated with California Emissions Estimator Model (“CalEEMod”) Version 2020.4.0 (AQIA, p. 39). 1 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 project-specific values, but the California Environmental Quality Act (“CEQA”) requires that such

1 “CalEEMod Version 2020.4.0.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at: http://www.aqmd.gov/caleemod/download-model.

2 changes be justified by substantial evidence. Once all of the values are inputted into the model, the Project’s construction and operational emissions are calculated, and “output files” are generated. These output files disclose to the reader what parameters are utilized in calculating the Project’s air pollutant emissions and make known which default values are changed as well as provide justification for the values selected.

When reviewing the Project’s CalEEMod output files, provided in the AQIA and the Greenhouse Gas Analysis (“GHG Analysis”) within Attachment E to the Staff Report, we found that several model inputs are not consistent with information disclosed in the Staff Report. As a result, the Project’s construction and operational emissions may be underestimated. A full CEQA analysis should be prepared to include an updated air quality analysis that adequately evaluates the impacts that operation of the Project will have on local and regional air quality.

Failure to Substantiate Potential Cold Storage Requirements Review of the CalEEMod output files demonstrates that the “Cherry Avenue Warehouse (Construction – Unmitigated)” and “Cherry Avenue Warehouse (High-Cube Cold Storage Operations)” models include a portion of the proposed warehouse space as refrigerated (see excerpt below) (Attachment E, pp. 147, 182, 285, 299, 439, 530).
“Cherry Avenue Warehouse (Construction – Unmitigated)”

“Cherry Avenue Warehouse (High-Cube Cold Storage Operations)”

As demonstrated above, the models include only 45,596-SF of the proposed warehouse space as refrigerated. As previously mentioned, the CalEEMod User’s Guide requires any changes to model defaults be justified.2 According to the “User Entered Comments & Non-Default Data” table, the justification provided for these changes is:
“Total Project area is 14.16 acres” (Attachment E, pp. 147, 182, 439).

Furthermore, regarding the amount of cold storage required for the proposed warehouse, the Traffic Assessment (“TA”), included in Attachment E to the Staff Report, states:

2 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 1, 14.

3 “For the purposes of this assessment, the Project will be evaluated assuming 15% cold storage and 85% high-cube fulfillment (non-sort)” (Attachment E, pp. 1).

However, the claim that only 15% of the proposed warehouse would be used as cold storage is unsubstantiated, as the Staff Report and associated documents fail to justify or provide a source for this assumption whatsoever.

Furthermore, the Staff Report and associated documents fail to identity or reference the future tenants of the Project site. As the future tenants of the Project site are currently unknown, such tenants may require additional cold storage for operation. Absent additional information, we cannot verify that the inclusion of only 45,596-SF of refrigerated warehouse space is an accurate representation of the expected cold-storage requirements.

This presents an issue, as refrigerated warehouses release more criteria air pollutant and GHG emissions when compared to unrefrigerated land uses for three reasons. First, warehouses equipped with cold storage, such as refrigerators and freezers, are known to consume more energy when compared to warehouses without cold storage.3 Second, warehouses equipped with cold storage typically require refrigerated trucks, which are known to idle for much longer when compared to unrefrigerated hauling trucks.4 Lastly, according to a July 2014 Warehouse Truck Trip Study Data Results and Usage presentation prepared by the South Coast Air Quality Management District (“SCAQMD”), hauling trucks that require refrigeration result in greater truck trip rates when compared to non-refrigerated hauling trucks.5 Furthermore, as discussed by SCAQMD, “CEQA requires the use of ‘conservative analysis’ to afford ‘fullest possible protection of the environment.’”6 As such, the AQIA must provide substantial evidence for the inclusion of only 15% of the total warehouse as cold storage space. Otherwise, an updated model should be prepared to include the entire warehouse land use as refrigerated in order account for the additional emissions that refrigeration requirements may generate.

By failing to account for all potential cold storage requirements, the model may underestimate the Project’s construction-related and operational emissions and should not be relied upon to determine Project significance. A full CEQA analysis should be prepared to account for the possibility of additional cold storage needs by future tenants.

3 “Warehouses.” Business Energy Advisor, available at: https://ouc.bizenergyadvisor.com/article/warehouses. 4 “Estimation of Fuel Use by Idling Commercial Trucks.” Transportation Research Record Journal of the Transportation Research Board, January 2006, p. 8, available at:
https://www.researchgate.net/publication/245561735_Estimation_of_Fuel_Use_by_Idling_Commercial_Trucks . 5 “Warehouse Truck Trip Study Data Results and Usage” Presentation. SCAQMD Mobile Source Committee, July 2014, available at: http://www.aqmd.gov/docs/default-source/ceqa/handbook/high-cube-warehouse-trip-rate- study-for-air-quality-analysis/finaltrucktripstudymsc072514.pdf?sfvrsn=2, p. 7, 9. 6 “Warehouse Truck Trip Study Data Results and Usage” Presentation. SCAQMD Inland Empire Logistics Council, June 2014, available at: http://www.aqmd.gov/docs/default-source/ceqa/handbook/high-cube-warehouse-trip- rate-study-for-air-quality-analysis/final-ielc_6-19-2014.pdf?sfvrsn=2. 4 Underestimated Parking Land Use Size
According to the Staff Report:
“The plans demonstrate that additional parking could be provided for future site and building reconfigurations ensuring consistency with the NI PlaceType and allowing flexibility to accommodate more jobs-dense uses on the site. The project has demonstrated that the ability to convert building area and reconfigure parking areas to accommodate the NI PlaceType parking ratio of three spaces per 1,000-square feet of building area and the ability to retrofit the building for smaller scale light industrial and creative uses. This would allow for 559 stalls, mostly configured within the building and some reconfiguration of the exterior parking stalls” (emphasis added) (p. 3)
As such, the model should have included a 559 parking spaces. However, review of the CalEEMod output files demonstrates that the “Cherry Avenue Warehouse (Construction – Unmitigated)” and “Cherry Avenue Warehouse (High-Cube Fulfillment Operations)” models include only 338 parking spaces (see excerpt below) (Attachment E, pp. 147, 182, 251, 267, 439, 506).

As demonstrated above, the amount of parking spaces included in the models is underestimated by 221 spaces.7 This underestimation presents an issue, as the square footage of parking land uses is used for certain calculations such as determining the area to be painted and stripped (i.e., VOC emissions from architectural coatings) and area to include lighting (i.e., energy impacts).8 By underestimating the proposed parking land use size, the models may underestimate the Project’s construction-related and operational emissions and should not be relied upon to determine Project significance.

Unsubstantiated Reductions to Architectural Coating Emission Factors Review of the CalEEMod output files demonstrates that the “Cherry Avenue Warehouse (Construction – Unmitigated)” model includes reductions to the default architectural coating emission factors (see excerpt below) (Attachment E, pp. 148, 183, 440).

As demonstrated above, the nonresidential exterior and interior architectural coating emission factors are reduced from the default values of 100- to 50-grams per liter (“g/L”). As previously mentioned, the

7 Calculated: (559 total vehicle stalls) – (338 modeled stalls) = 221 underestimated stalls. 8 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user’s-guide, p. 29.

5 CalEEMod User’s Guide requires any changes to model defaults be justified.9 According to the “User Entered Comments & Non-Default Data” table, the justification provided for these changes is:
“Rule 1113” (Attachment E, pp. 148, 183, 440).

Furthermore, regarding rules and regulations that would apply to the proposed project, the AQIA states:
“SCAQMD RULE 1113 This rule serves to limit the Volatile Organic Compound (VOC) content of architectural coatings used on projects in the SCAQMD. Any person who supplies, sells, offers for sale, or manufactures any architectural coating for use on projects […] Although the Project would comply with the above regulatory requirements, it should be noted that emission reductions associated with Rules 401, 402, 1301, and 2305 cannot be quantified in the California Emissions Estimator Model (CalEEMod) and are therefore not reflected in the emissions presented herein. Conversely, Rule 403 (Fugitive Dust) (2) and Rule 1113 (Architectural Coatings) (3) can be modeled in CalEEMod. As such, credit for Rule 403 and Rule 1113 have been taken in the analysis.” (p. 2, 3).

However, these reductions remain unsubstantiated, as we cannot verify the accuracy of the revised architectural coating emission factors based on SCAQMD Rule 1113 alone. The SCAQMD Rule 1113 Table of Standards provides the required VOC limits (grams of VOC per liter of coating) for 57 different coating categories.10 The VOC limits for each coating varies from a minimum value of 50 g/L to a maximum value of 730 g/L. As such, we cannot verify that SCAQMD Rule 1113 substantiates reductions to the default coating values without more information regarding what category of coating will be used. As the Staff Report and associated documents fail to explicitly require the use of a specific type of coating which would adhere to a specific VOC limit, we are unable to verify the model’s revised emission factors.

These unsubstantiated reductions present an issue, as CalEEMod uses the architectural coating emission factors to calculate the Project’s reactive organic gas/volatile organic compound (“ROG”/“VOC”) emissions.11 By including unsubstantiated reductions to the default architectural coating emission factors, the model may underestimate the Project’s construction-related ROG/VOC emissions and should not be relied upon to determine Project significance.

Unsubstantiated Changes to Individual Construction Phase Lengths Review of the CalEEMod output files demonstrates that the “Cherry Avenue Warehouse (Construction – Unmitigated)” model includes several changes to the default individual construction phase lengths (see excerpt below) (Attachment E, pp. 148, 183, 440).

9 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 1, 14.
10 SCAQMD Rule 1113 Advisory Notice.” SCAQMD, February 2016, available at: http://www.aqmd.gov/docs/default- source/rule-book/reg-xi/r1113.pdf?sfvrsn=24, p. 1113-14, Table of Standards 1. 11 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 35, 40.
6 As a result of these changes, the model includes the following construction schedule (see excerpt below) (Attachment E, pp. 154, 189, 445, 446).

As demonstrated above, the demolition phase is increased by 25%, from the default value of 20 to 25 days; the grading phase is increased by 17%, from the default value of 30 to 35 days; the building construction phase is decreased by 36%, from the default values of 300 to 191 days; and the architectural coating phase is increased by 100%, from the default value of 20 to 40 days. As previously mentioned, the CalEEMod User’s Guide requires any changes to model defaults be justified.12 According to the “User Entered Comments & Non-Default Data” table, the justification provided for these changes is:
“Construction anticipated to begin in January 2023 and end January 2024” (Attachment E, pp. 147, 182, 439).

Furthermore, regarding the Project’s anticipated construction schedule, the AQIA provides the following table (see excerpt below) (Attachment E, p. 41).

12 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 1, 14.

7 However, the changes to the induvial construction phase lengths remain unsubstantiated. While the AQIA indicates the total construction duration, the Staff Report fails to provide a source for the above table to justify the individual construction phase lengths. This is incorrect, as according to the CalEEMod User’s Guide:
“CalEEMod was also designed to allow the user to change the defaults to reflect site- or project- specific information, when available, provided that the information is supported by substantial evidence as required by CEQA.” 13
As such, until additional information becomes available that substantiates the revised individual construction phase lengths, we are unable to verify the changes included in the model. Instead, the model should have proportionately altered all phase lengths to match the proposed construction duration of one year.14
These unsubstantiated changes present an issue, as the construction emissions are improperly spread out over a longer period of time for some phases, but not for others. According to the CalEEMod User’s Guide, each construction phase is associated with different emissions activities (see excerpt below).15

By disproportionately altering and extending some of the individual construction phase lengths without proper justification, the model assumes there are a greater number of days to complete the construction activities required by the prolonged phases. As a result, there will be less construction activities required per day and, consequently, less pollutants emitted per day. Therefore, the model may underestimate the peak daily emissions associated with some phases of construction and should not be relied upon to determine Project significance.

13 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 13, 14.
14 See Attachment A for proportionally altered construction phases. 15 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 32.

8 Unsubstantiated Reductions to Demolition Hauling Trips Review of the CalEEMod output files demonstrates that the “Cherry Avenue Warehouse (Construction – Unmitigated)” model includes a change to the default demolition hauling trips (see excerpt below) (Attachment E, pp. 149, 184, 441).

As a result of these changes, the models include zero hauling trips for the demolition phase of construction (see excerpt below) (Attachment E, pp. 155, 189, 445, 456).

As previously mentioned, the CalEEMod User’s Guide requires any changes to model defaults be justified.16 According to the “User Entered Comments and Non-Default Data” table, the justification provided for these changes is:
“Vendor Trips adjusted based on CalEEMod Defaults for Building Construction and number of days for Demolition/Crushing, Site Preparation, Grading, and Building Construction” (Attachment E, pp. 148, 183, 440).

However, this is insufficient, as the justification fails to discuss the reductions to the hauling trip numbers. Furthermore, according to the AQIA:
“The site is currently developed with existing asphalt/concrete and buildings which will be demolished. Demolition of the existing asphalt/concrete and buildings will result in approximately 17,500 total tons of material that would be demolished, crushed, and stockpiled on-site to be used as fill” (p. 39).

However, these changes remain unsubstantiated, as the AQIA fails to provide any further information regarding the intended use of the materials generated during demolition. While the AQIA claims that the material would be “stockpiled on-site to be used as fill,” we cannot verify that all of the material

16 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 1, 14.

9 would be used as fill. As such, some of the demolition material may eventually need to be exported off site, thus generating hauling trips. By reducing the model’s construction hauling trip numbers to zero, the model may underestimate the hauling trips required during demolition of the existing buildings.

This potential underestimation presents an issue, as CalEEMod uses the number of hauling trips to estimate the construction-related emissions associated with on-road vehicles. 17 By failing to include any hauling trips for the demolition phase of construction, the model may underestimate the Project’s construction-related emissions and should not be relied upon to determine Project significance.

Updated Analysis Indicates a Potentially Significant Air Quality Impact In an effort to more accurately estimate the Project’s construction-related emissions, we prepared an updated CalEEMod model, using the Project-specific information provided by the Staff Report. In our updated model, we omitted the unsubstantiated changes to the architectural and area coating emission factors and hauling trip numbers; proportionately altered the individual construction phase lengths; and included the correct number of parking spaces.18
Our updated analysis estimates that the Project’s construction-related VOC emissions would exceed the applicable South Coast Air Quality Management District (“SCAQMD”) threshold of 75-pounds per day (“lbs/day”), as referenced by the AQIA (p. 42, Table 3-5) (see table below).19 SWAPE Criteria Air Pollutant Emissions
Construction VOC
(lbs/day)
AQIA 43.92
SWAPE 227.61
% Increase 418%
SCAQMD Threshold 75
Exceeds? Yes
As you can see in the table above, the Project’s construction-related VOC emissions, as estimated by SWAPE, increase by approximately 418% and exceed the applicable SCAQMD significance threshold.

Thus, our updated model demonstrates that the Project would result in a potentially significant air quality impact that was not previously identified or addressed in the Staff Report. As a result, a full CEQA analysis should be prepared to adequately assess and mitigate the potential air quality impacts that the Project may have on the surrounding environment.

17 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 34.
18 See Attachment B for updated air modeling.
19 “South Coast AQMD Air Quality Significance Thresholds.” SCAQMD, April 2019, available at:
http://www.aqmd.gov/docs/default-source/ceqa/handbook/scaqmd-air-quality-significance-thresholds.pdf. 10 Diesel Particulate Matter Emissions Inadequately Evaluated The Mobile Source Health Risk Assessment (“HRA Report”), included within Attachment E to the Staff Report, concludes that the proposed Project would result in a less-than-significant health risk impact based on a quantified construction and operational health risk assessments (“HRAs”). Specifically, the HRA Report estimates that the maximum incremental cancer risk posed to nearby, existing residential sensitive receptors associated with exposure to diesel particulate matter (“DPM”) emissions during Project construction would be 3.24 in one million, which would not exceed the SCAQMD significance threshold of 10 in one million (p. 3, Table ES-1).

Furthermore, the HRA Report estimates that the maximum incremental cancer risk posed to nearby, existing residential sensitive receptors associated with exposure to DPM emissions during operation would be 0.93 in one million, which would also not exceed the SCAQMD significance threshold of 10 in one million (p. 3, Table ES-2).

11 However, the HRA Report’s evaluation of the Project’s potential health risk impacts, as well as the subsequent less-than-significant impact conclusion, is incorrect for three reasons.

First, the Staff Report’s construction HRA is incorrect, as it relies upon emissions estimates from a flawed air model, as discussed above. Specifically, the HRA Report states:
“The emissions calculations for the construction HRA component are based on an assumed mix of construction equipment and hauling activity as presented in the Cherry Avenue Warehouse Air Quality Impact Analysis (“technical study”) prepared by Urban Crossroads, Inc. (4)” (p. 10).

As previously discussed, when we reviewed the Project’s CalEEMod output files, provided in the AQIA within Attachment E to the Staff Report, we found that several of the values inputted into the model are not consistent with information disclosed in the Staff Report. As a result, the HRA utilizes an underestimated DPM concentration to calculate the health risk associated with Project construction. As such, the HRA Report’s construction cancer risk should not be relied upon to determine Project significance.

Second, the construction and operational HRAs utilize incorrect Fraction of Time At Home (“FAH”) values. Specifically, the HRAs utilize a FAH value of 0.85 for the third trimester (age -0.25 to 0) and infant (age 0 to 2) receptors, and an FAH value of 0.72 for the child receptors (age 2 to 16) (see excerpt below) (p. 19, Table 2-6; p. 20, Table 2-7).

However, the FAH values used for the third trimester, infant, and childhood receptors are incorrect, as SCAQMD guidance clearly states:

12 “For Tiers 1, 2, and 3 screening purposes, the FAH is assumed to be 1 for ages third trimester to

16. As a default, children are assumed to attend a daycare or school in close proximity to their home and no discount should be taken for time spent outside of the area affected by the facility’s emissions. People older than age 16 are assumed to spend only 73 percent of their time at home.”20
Per SCAQMD guidance, the HRA Report should have used an FAH of 1 for the third trimester, infant, and child receptors. Thus, by utilizing incorrect FAH values, the HRA Report underestimates the cancer risk posed to nearby, existing sensitive receptors as a result of Project construction and operation.

Third, while the HRA Report includes two HRAs evaluating the health risk impacts to nearby, existing receptors as a result of Project construction and operation, the HRA Report fails to evaluate the combined lifetime cancer risk to nearby receptors as a result of Project construction and operation together. According to OEHHA guidance, “the excess cancer risk is calculated separately for each age grouping and then summed to yield cancer risk at the receptor location.” 21 However, the HRA Report fails to sum the total cancer risks in order to evaluate the combined cancer risk over the course of the Project’s total construction and operation. This is incorrect and, as such, an updated analysis should quantify and sum the Project’s construction and operational cancer risks to compare to the SCAQMD threshold of 10 in one million.

Disproportionate Health Risk Impacts of Warehouses on Surrounding Communities Upon review of the Staff Report and associated documents, we have determined that the development of the proposed Project would result in disproportionate health risk impacts on community members living, working, and going to school within the immediate area of the Project site. According to SCAQMD:
“Those living within a half mile of warehouses are more likely to include communities of color, have health impacts such as higher rates of asthma and heart attacks, and a greater environmental burden.”22
In particular, the SCAQMD found that more than 2.4 million people live within a half mile radius of at least one warehouse, and that those areas not only experience increased rates of asthma and heart attacks, but are also disproportionately Black and Latino communities below the poverty line.23 Another study similarly indicates that “neighborhoods with lower household income levels and higher percentages of minorities are expected to have higher probabilities of containing warehousing

20 “Risk Assessment Procedures.” SCAQMD, August 2017, available at: http://www.aqmd.gov/docs/default- source/rule-book/Proposed-Rules/1401/riskassessmentprocedures_2017_080717.pdf, p. 7. 21 “Guidance Manual for preparation of Health Risk Assessments.” OEHHA, February 2015, available at:
https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf p. 8-4. 22 “South Coast AQMD Governing Board Adopts Warehouse Indirect Source Rule .” SCAQMD, May 2021, available at: http://www.aqmd.gov/docs/default-source/news-archive/2021/board-adopts-waisr-may7-2021.pdf?sfvrsn=9. 23 “Southern California warehouse boom a huge source of pollution. Regulators are fighting back .” Los Angeles Times, May 2021, available at: https://www.latimes.com/california/story/2021-05-05/air-quality-officials-target- warehouses-bid-to-curb-health-damaging-truck-pollution. 13 facilities.”24 Additionally, a report authored by the Inland Empire-based People’s Collective for Environmental Justice and University of Redlands states:
“As the warehouse and logistics industry continues to grow and net exponential profits at record rates, more warehouse projects are being approved and constructed in low-income communities of color and serving as a massive source of pollution by attracting thousands of polluting truck trips daily. Diesel trucks emit dangerous levels of nitrogen oxide and particulate matter that cause devastating health impacts including asthma, chronic obstructive pulmonary disease (COPD), cancer, and premature death. As a result, physicians consider these pollution- burdened areas ‘diesel death zones.’”25
It is evident that the continued development of industrial warehouses within these communities poses a significant environmental justice challenge. However, the acceleration of warehouse development is only increasing despite the consequences on public health.

Long Beach, the setting of the proposed Project, has long borne a disproportionately high pollution burden compared to the rest of California. When using CalEnviroScreen 4.0, CalEPA’s screening tool that ranks each census tract in the State for pollution and socioeconomic vulnerability, we found that the Project’s census tract is in the 99th percentile of most polluted census tracts in the State (see excerpt below).26

24 “Location of warehouses and environmental justice: Evidence from four metros in California.” Metro Freight Center of Excellence, January 2018, available at:
https://www.metrans.org/assets/research/MF%201.1g_Location%20of%20warehouses%20and%20environmental %20justice_Final%20Report_021618.pdf, p. 21.
25 “Warehouses, Pollution, and Social Disparities: An analytical view of the logistics industry’s impacts on environmental justice communities across Southern California.” People’s Collective for Environmental Justice, April 2021, available at:
https://earthjustice.org/sites/default/files/files/warehouse_research_report_4.15.2021.pdf , p. 4. 26 “CalEnviroScreen 4.0.” California Office of Environmental Health Hazard Assessment (OEHHA), October 2021, available at: https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40.

14 Furthermore, the Data Visualization Tool for Mates V, a monitoring and evaluation study conducted by SCAQMD, demonstrates that the City already exhibits a heightened residential carcinogenic risk from exposure to air toxics. Specifically, the location of the Project site is in the 83rd percentile of highest cancer risks in the South Coast Air Basin, with a cancer risk of 508 in one million (see excerpt below).27

Therefore, development of the proposed warehouse would disproportionately contribute to and exacerbate the health conditions of the residents in Long Beach.

In April 2022, the American Lung Association ranked Los Angeles County as the third worst for ozone pollution in the nation.28 This year, the County continues to face the worst ozone pollution, as it has seen the highest recorded Air Quality Index (“AQI”) values for ground-level ozone in California.29 The U.S. Environmental Protection Agency (“EPA”) indicates that ozone, the main ingredient in “smog,” can cause several health problems, which includes aggravating lung diseases and increasing the frequency of asthma attacks. The U.S. EPA states:
“Children are at greatest risk from exposure to ozone because their lungs are still developing and they are more likely to be active outdoors when ozone levels are high, which increases their exposure. Children are also more likely than adults to have asthma.”30

27 “Residential Air Toxics Cancer Risk Calculated from Model Data in Grid Cells.” MATES V, 2018, available at:
https://experience.arcgis.com/experience/79d3b6304912414bb21ebdde80100b23/page/Main-Page/?views=Click- tabs-for-other-data%2CGridded-Cancer-Risk; see also: “MATES V Multiple Air Toxics Exposure Study.” SCAQMD, available at: http://www.aqmd.gov/home/air-quality/air-quality-studies/health-studies/mates-v. 28 “State of the Air 2022.” American Lung Association, April 2022, available at:
https://www.lung.org/research/sota/key-findings/most-polluted-places. 29 “High Ozone Days.” American Lung Association, 2022, available at:
https://www.lung.org/research/sota/city-rankings/states/california. 30 “Health Effects of Ozone Pollution.” U.S. EPA, May 2021, available at: https://www.epa.gov/ground-level-ozone- pollution/health-effects-ozone-pollution.

15 Furthermore, regarding the increased sensitivity of early-life exposures to inhaled pollutants, the California Air Resources Board (“CARB”) states:
“Children are often at greater risk from inhaled pollutants, due to the following reasons:
• Children have unique activity patterns and behavior. For example, they crawl and play on the ground, amidst dirt and dust that may carry a wide variety of toxicants. They often put their hands, toys, and other items into their mouths, ingesting harmful substances. Compared to adults, children typically spend more time outdoors and are more physically active. Time outdoors coupled with faster breathing during exercise increases children’s relative exposure to air pollution. • Children are physiologically unique. Relative to body size, children eat, breathe, and drink more than adults, and their natural biological defenses are less developed. The protective barrier surrounding the brain is not fully developed, and children’s nasal passages aren’t as effective at filtering out pollutants. Developing lungs, immune, and metabolic systems are also at risk.
• Children are particularly susceptible during development. Environmental exposures during fetal development, the first few years of life, and puberty have the greatest potential to influence later growth and development.”31 A Stanford-led study also reveals that children exposed to high levels of air pollution are more susceptible to respiratory and cardiovascular diseases in adulthood.32 Thus, given children’s higher propensity to succumb to the negative health impacts of air pollutants, and as warehouses release more smog-forming pollution than any other sector, it is necessary to evaluate the specific health risk that warehouses pose to children in the nearby community.

According to the above-mentioned study by the People’s Collective for Environmental Justice and University of Redlands, there are 640 schools in the South Coast Air Basin that are located within half a mile of a large warehouse, most of them in socio-economically disadvantaged areas.33 Regarding the proposed Project itself, the Staff Report states:
“Location R6 represents Harte Elementary School at 1671 E. Phillips Street, approximately 1,002 feet southwest of the Project site. Receptor R6 is placed at the building façade” (p. 51).

31 “Children and Air Pollution.” California Air Resources Board (CARB), available at:
https://ww2.arb.ca.gov/resources/documents/children-and-air-pollution. 32 “Air pollution puts children at higher risk of disease in adulthood, according to Stanford researchers and others .” Stanford, February 2021, available at: https://news.stanford.edu/2021/02/22/air-pollution-impacts-childrens- health/.
33 “Warehouses, Pollution, and Social Disparities: An analytical view of the logistics industry’s impacts on environmental justice communities across Southern California.” People’s Collective for Environmental Justice, April 2021, available at:
https://earthjustice.org/sites/default/files/files/warehouse_research_report_4.1 5.2021.pdf, p. 4. 16 As discussed, Harte Elementary School is located approximately 1,002 feet, or 0.19 miles from the Project site. Therefore, this Project poses a significant threat because, as outlined above, children are a vulnerable population that are more susceptible to the damaging side effects of air pollution. As such, the Project would have detrimental short-term and long-term health impacts on local children if approved.

A full CEQA analysis should be prepared to evaluate the disproportionate impacts of the proposed warehouse on the community adjacent to the Project, including an analysis of the impact on children and people of color who live and attend school in the surrounding area. Finally, in order to evaluate the cumulative air quality impact from the several warehouse projects proposed or built in a one-mile radius of the Project site, the full CEQA analysis should prepare a cumulative health risk assessment (“HRA”) to quantify the adverse health outcome from the effects of exposure to multiple warehouses in the immediate area in conjunction with the poor ambient air quality in the Project’s census tract.

Greenhouse Gas
Failure to Adequately Evaluate Greenhouse Gas Impacts
The GHG Analysis estimates that the Project would generate net annual greenhouse gas (“GHG”) emissions of 1,666.60 metric tons of carbon dioxide equivalents per year during construction and operation (“MT CO2e/year”) (p. 56, Table 3-8).

As such, the GHG Analysis concludes:
“The Project would result in approximately 1,666.60 MT CO2e/yr. As such, the Projects would not exceed the SCAQMD’s numeric threshold of 3,000 MT CO2e/yr if it were applied. Thus, the

17 Projects would not have the potential to result in a cumulatively considerable impact with respect to GHG emissions” (p. 57).

As discussed above, the GHG Analysis states that because emissions are not projected to exceed the threshold of 3,000 MT CO2e/yr, the Project will result in a less-than-significant GHG impact.

Furthermore, the GHG Analysis relies upon the Project’s consistency with the CARB’s 2017 Scoping Plan to conclude that the Project would result in a less-than-significant GHG impact (p. 58 – 63). However, the GHG Analysis’s quantitative analysis, as well as the subsequent less-than-significant impact conclusion, is incorrect for three reasons.
(1) The GHG Analysis’s quantitative analysis relies upon a flawed air model; (2) The GHG Analysis’s quantitative analysis relies upon an outdated threshold; (3) The AQIA’s unsubstantiated air model indicates a potentially significant impact; and (4) The GHG Analysis fails to consider performance-based standards under CARB’s 2017 scoping plan.
1) Incorrect and Unsubstantiated Quantitative Analysis of Emissions As previously stated, the GHG Analysis estimates that the Project would generate net annual GHG emissions of 1,666.60 MT CO2e/year (p. 56, Table 3-8). However, the GHG Analysis’s quantitative analysis is unsubstantiated. As previously discussed, when reviewing the Project’s CalEEMod models, provided in the AQIA and the GHG Analysis within Attachment E to the Staff Report, we found that several of the values inputted into the models are not consistent with information disclosed in the Staff Report. As a result, the models may underestimate the Project’s emissions, and the GHG Analysis’s quantitative analysis should not be relied upon to determine Project significance. A full CEQA analysis should be prepared that adequately assesses the potential GHG impacts that construction and operation of the proposed Project may have on the environment.
2) Incorrect Reliance on an Outdated Quantitative GHG Threshold As previously stated, the GHG Analysis estimates that the Project would generate net annual GHG emissions of 1,666.60 MT CO2e/year, which would not exceed the SCAQMD threshold of 3,000 MT CO2e/year (p. 56, Table 3-8). However, the guidance that provided the 3,000 MT CO2e/year threshold, the SCAQMD’s 2008 Interim CEQA GHG Significance Threshold for Stationary Sources, Rules, and Plans report, was developed when the Global Warming Solutions Act of 2006, commonly known as “AB 32”, was the governing statute for GHG reductions in California. AB 32 requires California to reduce GHG emissions to 1990 levels by 2020.34 Furthermore, AEP guidance states:

34 “Health & Safety Code 38550.” California State Legislature, January 2007, available at:
https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=HSC&sectionNum=38550. 18 “[F]or evaluating projects with a post 2020 horizon, the threshold will need to be revised based on a new gap analysis that would examine 17 development and reduction potentials out to the next GHG reduction milestone.”35
As it is currently February 2023, thresholds for 2020 are not applicable to the proposed Project and should be revised to reflect the current GHG reduction target. As such, the SCAQMD bright-line threshold of 3,000 MT CO2e/year is outdated and inapplicable to the proposed Project, and the Staff Report’s less-than-significant GHG impact conclusion should not be relied upon. Instead, we recommend that the Project apply the SCAQMD 2035 service population efficiency target of 3.0 MT CO2e/SP/year, which was calculated by applying a 40% reduction to the 2020 targets.36 3) Failure to Identify a Potentially Significant GHG Impact In an effort to quantitatively evaluate the Project’s GHG emissions, we compared the Project’s GHG emissions, as estimated by the GHG Analysis, to the SCAQMD 2035 efficiency target of 3.0 MT CO2e/SP/year. When applying this threshold, the Project’s incorrect and unsubstantiated air model indicates a potentially significant GHG impact.

As previously stated, the GHG Analysis estimates that the Project would generate net annual GHG emissions of 1,666.60 MT CO2e/year (p. 56, Table 3-8). According to CAPCOA’s CEQA & Climate Change report, a service population (“SP”) is defined as “the sum of the number of residents and the number of jobs supported by the project.”37 According to the Employment Density Study Summary Report completed by the Southern California Association of Governments (“SCAG”), the project would support approximately 200 employees.38, 39 As the project is not expected to support any residential land uses, we estimate an SP of 200 people. When dividing the Project’s net annual GHG emissions, as estimated by the GHG Analysis, by an SP of 200 people, we find that the Project would emit approximately 8.3 MT CO2e/SP/year (see table below).40

35 “Beyond Newhall and 2020: A Field Guide to New CEQA Greenhouse Gas Thresholds and Climate Action Plan Targets for California.” Association of Environmental Professionals (AEP), October 2016, available at:
https://califaep.org/docs/AEP-2016_Final_White_Paper.pdf, p. 39. 36 “Minutes for the GHG CEQA Significance Threshold Stakeholder Working Group #15.” SCAQMD, September 2010, available at: http://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa- significance-thresholds/year-2008-2009/ghg-meeting-15/ghg-meeting-15-minutes.pdf, p. 2. 37 “CEQA & Climate Change.” California Air Pollution Control Officers Association (CAPCOA), January 2008, available at: http://www.capcoa.org/wp-content/uploads/2012/03/CAPCOA-White-Paper.pdf, p. 71-72. 38 Calculated: (303,972-SF warehouse) / (1,518-SF average per one warehouse employee in Los Angeles County) = 200.2 employees.
39 “Employment Density Study Summary Report.” Southern California Association of Governments (SCAG), October 2001, available at: https://docplayer.net/30300085-Employment-density-study-summary-report-october-31- prepared-for-southern-california-association-of-governments.html, p. 4. 40 Calculated: (1,666.60 MT CO2e/year) / (200 service population) = (8.3 MT CO2e/SP/year). 19 Project Greenhouse Gas Emissions
Annual Emissions (MT CO2e/year) 1,666.60
Service Population 200
Service Population Efficiency (MT CO2e/SP/year) 8.3
SCAQMD 2035 Target 3.0
Exceeds? Yes
As demonstrated above, the Project’s service population efficiency value exceeds the SCAQMD 2035 efficiency target of 3.0 MT CO2e/SP/year, indicating a potentially significant impact not previously identified or addressed by the GHG Analysis. As a result, the GHG Analysis’s less-than-significant GHG impact conclusion should not be relied upon. A full CEQA analysis should be prepared, including an updated GHG analysis and incorporating additional mitigation measures to reduce the Project’s GHG emissions to less-than-significant levels.
4) Failure to Consider Performance-based Standards Under CARB’s 2017 Scoping Plan As previously discussed, the GHG Analysis concludes that the Project would be consistent with CARB’s 2017 Climate Change Scoping Plan (p. 58 - 63). However, this is incorrect, as the GHG Analysis fails to consider the performance-based measures proposed by CARB. i. Passenger & Light Duty VMT Per Capita Benchmarks per SB 375 In reaching the State’s long-term GHG emission reduction goals, CARB’s 2017 Scoping Plan explicitly cites to SB 375 and the VMT reductions anticipated under the implementation of Sustainable Community Strategies.41 CARB has identified the population and daily VMT from passenger autos and light-duty vehicles at the state and county level for each year between 2010 to 2050 under a “baseline scenario” that includes “current projections of VMT included in the existing Regional Transportation Plans/Sustainable Communities Strategies (RTP/SCSs) adopted by the State’s 18 Metropolitan Planning Organizations (MPOs) pursuant to SB 375 as of 2015.”42 By dividing the projected daily VMT by the population, we calculated the daily VMT per capita for each year at the state and county level for 2010 (baseline year), 2024 (Project operational year), and 2030 (target years under SB 32) (see table below).

41 “California’s 2017 Climate Change Scoping Plan.” CARB, November 2017, available at:
https://ww3.arb.ca.gov/cc/scopingplan/scoping_plan_2017.pdf , p. 25, 98, 101-103. 42 “Supporting Calculations for 2017 Scoping Plan-Identified VMT Reductions,” California Air Resources Board (CARB), January 2019, available at: https://ww2.arb.ca.gov/resources/documents/carb-2017-scoping-plan- identified-vmt-reductions-and-relationship-state-climate; see also:
https://ww2.arb.ca.gov/sites/default/files/2019-01/sp_mss_vmt_calculations_jan19_0.xlsx. 20 2017 Scoping Plan Daily VMT Per Capita
Los Angeles County State Year Population LDV VMT Baseline VMT Per Capita Population LDV VMT Baseline VMT Per Capita 2010 9,838,771 216,979,222 22.05 37,335,085 836,463,980.46 22.40 2024 10,627,846 219,237,757 22.62 41,994,283 926,776,780.89 22.07 2030 10,868,614 215,539,586 19.83 43,939,250 957,178,153.19 21.78 As the Staff Report fails to evaluate the Project’s consistency with the performance-based daily VMT per capita projections from CARB’s 2017 Scoping Plan, the Staff Report’s claim that the proposed Project would be consistent with the Scoping Plan is unsupported.

Furthermore, as of November 16, 2022, CARB has released an updated scoping plan for achieving carbon neutrality. However, the GHG Analysis fails to discuss the updated CARB 2022 Scoping plan whatsoever. A full CEQA analysis should be prepared for the proposed Project to provide additional information and analysis to conclude less-than-significant GHG impacts.

Mitigation
Feasible Mitigation Measures Available to Reduce Emissions Our analysis demonstrates that the Project would result in potentially significant air quality and GHG impacts that should be mitigated further. As such, in an effort to reduce the Project’s emissions, we identified several mitigation measures that are applicable to the proposed Project. Feasible mitigation measures can be found in the California Department of Justice Warehouse Project Best Practices document.43 Therefore, to reduce the Project’s emissions, consideration of the following measures should be made:
• Requiring off-road construction equipment to be hybrid electric-diesel or zero emission, where available, and all diesel-fueled off-road construction equipment to be equipped with CARB Tier IV-compliant engines or better, and including this requirement in applicable bid documents, purchase orders, and contracts, with successful contractors demonstrating the ability to supply the compliant construction equipment for use prior to any ground-disturbing and construction activities.
• Prohibiting off-road diesel-powered equipment from being in the “on” position for more than 10 hours per day.
• Using electric-powered hand tools, forklifts, and pressure washers, and providing electrical hook ups to the power grid rather than use of diesel-fueled generators to supply their power. • Designating an area in the construction site where electric-powered construction vehicles and equipment can charge.
• Limiting the amount of daily grading disturbance area.

43 “Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act.” State of California Department of Justice, September 2022, available at:
https://oag.ca.gov/system/files/media/warehouse-best-practices.pdf, p. 8 – 10. 21 • Prohibiting grading on days with an Air Quality Index forecast of greater than 100 for particulates or ozone for the project area.
• Forbidding idling of heavy equipment for more than three minutes. • Keeping onsite and furnishing to the lead agency or other regulators upon request, all equipment maintenance records and data sheets, including design specifications and emission control tier classifications.
• Conducting an on-site inspection to verify compliance with construction mitigation and to identify other opportunities to further reduce construction impacts. • Using paints, architectural coatings, and industrial maintenance coatings that have volatile organic compound levels of less than 10 g/L.
• Providing information on transit and ridesharing programs and services to construction employees.
• Providing meal options onsite or shuttles between the facility and nearby meal destinations for construction employees.
• Requiring all heavy-duty vehicles engaged in drayage to or from the project site to be zero- emission beginning in 2030.
• Requiring all on-site motorized operational equipment, such as forklifts and yard trucks, to be zero-emission with the necessary charging or fueling stations provided. • Requiring tenants to use zero-emission light- and medium-duty vehicles as part of business operations.
• Forbidding trucks from idling for more than three minutes and requiring operators to turn off engines when not in use.
• Posting both interior- and exterior-facing signs, including signs directed at all dock and delivery areas, identifying idling restrictions and contact information to report violations to CARB, the local air district, and the building manager.
• Installing solar photovoltaic systems on the project site of a specified electrical generation capacity that is equal to or greater than the building’s projected energy needs, including all electrical chargers.
• Designing all project building roofs to accommodate the maximum future coverage of solar panels and installing the maximum solar power generation capacity feasible. • Constructing zero-emission truck charging/fueling stations proportional to the number of dock doors at the project.
• Running conduit to designated locations for future electric truck charging stations. • Unless the owner of the facility records a covenant on the title of the underlying property ensuring that the property cannot be used to provide refrigerated warehouse space, constructing electric plugs for electric transport refrigeration units at every dock door and requiring truck operators with transport refrigeration units to use the electric plugs when at loading docks.
• Oversizing electrical rooms by 25 percent or providing a secondary electrical room to accommodate future expansion of electric vehicle charging capability. 22 • Constructing and maintaining electric light-duty vehicle charging stations proportional to the number of employee parking spaces (for example, requiring at least 10% of all employee parking spaces to be equipped with electric vehicle charging stations of at least Level 2 charging performance)
• Running conduit to an additional proportion of employee parking spaces for a future increase in the number of electric light-duty charging stations.
• Installing and maintaining, at the manufacturer’s recommended maintenance intervals, air filtration systems at sensitive receptors within a certain radius of facility for the life of the project.
• Installing and maintaining, at the manufacturer’s recommended maintenance intervals, an air monitoring station proximate to sensitive receptors and the facility for the life of the project, and making the resulting data publicly available in real time. While air monitoring does not mitigate the air quality or greenhouse gas impacts of a facility, it nonetheless benefits the affected community by providing information that can be used to improve air quality or avoid exposure to unhealthy air.
• Requiring all stand-by emergency generators to be powered by a non-diesel fuel. • Requiring facility operators to train managers and employees on efficient scheduling and load management to eliminate unnecessary queuing and idling of trucks. • Requiring operators to establish and promote a rideshare program that discourages single- occupancy vehicle trips and provides financial incentives for alternate modes of transportation, including carpooling, public transit, and biking.
• Meeting CalGreen Tier 2 green building standards, including all provisions related to designated parking for clean air vehicles, electric vehicle charging, and bicycle parking. • Designing to LEED green building certification standards. • Providing meal options onsite or shuttles between the facility and nearby meal destinations. • Posting signs at every truck exit driveway providing directional information to the truck route. • Improving and maintaining vegetation and tree canopy for residents in and around the project area.
• Requiring that every tenant train its staff in charge of keeping vehicle records in diesel technologies and compliance with CARB regulations, by attending CARB-approved courses. Also require facility operators to maintain records on-site demonstrating compliance and make records available for inspection by the local jurisdiction, air district, and state upon request. • Requiring tenants to enroll in the United States Environmental Protection Agency’s SmartWay program, and requiring tenants who own, operate, or hire trucking carriers with more than 100 trucks to use carriers that are SmartWay carriers.
• Providing tenants with information on incentive programs, such as the Carl Moyer Program and Voucher Incentive Program, to upgrade their fleets.

These measures offer a cost-effective, feasible way to incorporate lower-emitting design features into the proposed Project, which subsequently, reduce emissions released during Project construction and operation.
23 Furthermore, as it is policy of the State that eligible renewable energy resources and zero-carbon resources supply 100% of retail sales of electricity to California end-use customers by December 31, 2045, we emphasize the applicability of incorporating solar power system into the Project design. Until the feasibility of incorporating on-site renewable energy production is considered, the Project should not be approved.

A full CEQA analysis should be prepared to include all feasible mitigation measures, as well as include updated air quality and GHG analyses to ensure that the necessary mitigation measures are implemented to reduce emissions to below thresholds. The analysis should also demonstrate a commitment to the implementation of these measures prior to Project approval, to ensure that the Project’s significant emissions are reduced to the maximum extent possible.

Disclaimer
SWAPE has received limited discovery regarding this project. 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.

Attachment A: Proportionally Altered Construction Schedule Attachment B: Updated CalEEMod Output Files
Attachment C: Matt Hagemann CV
Attachment D: Paul Rosenfeld CV

Phase
Default Phase
Length
Co
nstruction
Duration %

Construction
Duration
Revised Phase
Length
Demolition 20 558 0.0358 363 13
Site Preparation 10 558 0.0179 363 7
Grading 30 558 0.0538 363 20
Construction 300 558 0.5376 363 195
Paving 20 558 0.0358 363 13
Architectural Coating 20 558 0.0358 363 13
Total Default
Construction
Duration
Revised
Construction
Duration
Start Date 1/15/2023 1/15/2023
End Date 7/26/2024 1/13/2024
Total Days 558 363
Construction Schedule Calculations
Attachment A
Cherry Avenue Warehouse (Construction - Unmitigated)
Los Angeles-South Coast County, Annual
Project Characteristics - Consistent with the Staff Report's model.

Land Use - See SWAPE's comments on "Underestimated Parking Land Use Size" Construction Phase - See SWAPE's comments on "Unsubstantiated Changes to Individual Construction Phase Lengths" Off-road Equipment - Consistent with the Staff Report's model.

Off-road Equipment - Consistent with the Staff Report's model.

Off-road Equipment - Consistent with the Staff Report's model.

Off-road Equipment - Consistent with the Staff Report's model.

Off-road Equipment - Consistent with the Staff Report's model.

Off-road Equipment - Consistent with the Staff Report's model.

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population Refrigerated Warehouse-No Rail 45.60 1000sqft 1.05 45,596.00 0 Unrefrigerated Warehouse-No Rail 258.38 1000sqft 5.93 258,376.00 0 Other Asphalt Surfaces 261.15 1000sqft 6.00 261,149.00 0 Parking Lot 559.00 Space 5.03 223,600.00 0

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
9 Wind Speed (m/s) Precipitation Freq (Days)2.2 33

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company Southern California Edison
2024Operational Year
CO2 Intensity
(lb/MWhr)
390.98 0.033CH4 Intensity
(lb/MWhr)

0.004N2O Intensity
(lb/MWhr)
CalEEMod Version: CalEEMod.2020.4.0 Date: 2/2/2023 1:20 PMPage 1 of 37 Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Attachment B
Trips and VMT - See SWAPE's comments on "Failure to Model All Required Demolition" Demolition - See SWAPE's comments on "Failure to Model All Required Demolition" Grading - Consistent with the Staff Report's model.

Architectural Coating - See SWAPE's comments on "Unsubstantiated Reductions to Architectural Coating Emission Factors" Vehicle Trips - Consistent with the Staff Report's model.

Energy Use - Consitent with the Staff Report's model.

Water And Wastewater - Consistent with the Staff Report's model.

Solid Waste - Consistent with the Staff Report's model.

Table Name
Column Name
Default Value
New Value
tblConstructionPhase
NumDays

20.00 13.00
tblConstructionPhase
NumDays
300.00
195.00
tblConstructionPhase
NumDays

20.00 13.00
tblConstructionPhase
NumDays

30.00 20.00
tblConstructionPhase
NumDays

20.00 13.00
tblConstructionPhase
NumDays

10.00 7.00
tblEnergyUse
LightingElect

0.35 0.00
tblEnergyUse
LightingElect

2.73 0.00
tblEnergyUse
LightingElect

1.91 0.00
tblEnergyUse
NT24E

13.61 0.00
tblEnergyUse
NT24E

1.34 0.00
tblEnergyUse
NT24NG

0.09 0.00
tblEnergyUse
NT24NG

0.03 0.00
tblEnergyUse
T24E

0.37 0.00
tblEnergyUse
T24E

0.58 0.00
tblEnergyUse
T24NG

0.93 0.00
tblEnergyUse
T24NG

0.83 0.00
tblLandUse
LandUseSquareFeet
45,600.00
45,596.00
tblLandUse
LandUseSquareFeet
258,380.00
258,376.00
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

tblLandUse
LandUseSquareFeet
261,150.00
261,149.00
tblOffRoadEquipment
OffRoadEquipmentUnitAmount

1.00 2.00
tblOffRoadEquipment
OffRoadEquipmentUnitAmount

3.00 5.00
tblOffRoadEquipment
OffRoadEquipmentUnitAmount

1.00 2.00
tblOffRoadEquipment
OffRoadEquipmentUnitAmount

3.00 5.00
tblOffRoadEquipment
OffRoadEquipmentUnitAmount

2.00 0.00
tblOffRoadEquipment
OffRoadEquipmentUnitAmount

4.00 0.00
tblOffRoadEquipment
OffRoadEquipmentUnitAmount

1.00 2.00
tblOffRoadEquipment
UsageHours

6.00 8.00
tblOffRoadEquipment
UsageHours

7.00 8.00
tblOffRoadEquipment
UsageHours

8.00 4.00
tblOffRoadEquipment
UsageHours

7.00 8.00
tblSolidWaste
SolidWasteGenerationRate

42.86 0.00
tblSolidWaste
SolidWasteGenerationRate
242.88

0.00 tblTripsAndVMT
VendorTripNumber

0.00 10.00
tblTripsAndVMT
VendorTripNumber

0.00 4.00
tblTripsAndVMT
VendorTripNumber

0.00 14.00
tblVehicleTrips
CC_TL

8.40 0.00
tblVehicleTrips
CC_TL

8.40 0.00
tblVehicleTrips
CC_TL

8.40 0.00
tblVehicleTrips
CC_TL

8.40 0.00
tblVehicleTrips
CNW_TL

6.90 0.00
tblVehicleTrips
CNW_TL

6.90 0.00
tblVehicleTrips
CNW_TL

6.90 0.00
tblVehicleTrips
CNW_TL

6.90 0.00
tblVehicleTrips
CNW_TTP

41.00 0.00
tblVehicleTrips
CNW_TTP

41.00 0.00
tblVehicleTrips
CW_TL

16.60 0.00
tblVehicleTrips
CW_TL

16.60 0.00
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

2.0 Emissions Summary
tblVehicleTrips
CW_TL

16.60 0.00
tblVehicleTrips
CW_TL

16.60 0.00
tblVehicleTrips
CW_TTP

59.00 0.00
tblVehicleTrips
CW_TTP

59.00 0.00
tblVehicleTrips
DV_TP

5.00 0.00
tblVehicleTrips
DV_TP

5.00 0.00
tblVehicleTrips
PB_TP

3.00 0.00
tblVehicleTrips
PB_TP

3.00 0.00
tblVehicleTrips
PR_TP

92.00 0.00
tblVehicleTrips
PR_TP

92.00 0.00
tblVehicleTrips
ST_TR

2.12 0.00
tblVehicleTrips
ST_TR

1.74 0.00
tblVehicleTrips
SU_TR

2.12 0.00
tblVehicleTrips
SU_TR

1.74 0.00
tblVehicleTrips
WD_TR

2.12 0.00
tblVehicleTrips
WD_TR

1.74 0.00
tblWater
IndoorWaterUseRate
10,545,000.00

0.00 tblWater
IndoorWaterUseRate
59,750,375.00

0.00 CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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
2023

0.7328

4.1921

4.9241

0.0124

0.8106

0.1686

0.9792

0.2239

0.1583

0.3822

0.0000
1,120.335
2 1,120.335
2 0.1556

0.0490
1,138.812
0 2024

1.2516

9.7500e-
003

0.0248

6.0000e-
005

3.9800e-
003

4.7000e-
004

4.4500e-
003

1.0600e-
003

4.7000e-
004

1.5200e-
003

0.0000

4.9491

4.9491

1.8000e-
004

8.0000e-
005

4.9765
Maximum

1.2516

4.1921

4.9241

0.0124

0.8106

0.1686

0.9792

0.2239

0.1583

0.3822

0.0000
1,120.335
2 1,120.335
2 0.1556

0.0490
1,138.812
0 Unmitigated 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
2023

0.7328

4.1921

4.9241

0.0124

0.8106

0.1686

0.9792

0.2239

0.1583

0.3822

0.0000
1,120.334
6 1,120.334
6 0.1556

0.0490
1,138.811
3 2024

1.2516

9.7500e-
003

0.0248

6.0000e-
005

3.9800e-
003

4.7000e-
004

4.4500e-
003

1.0600e-
003

4.7000e-
004

1.5200e-
003

0.0000

4.9491

4.9491

1.8000e-
004

8.0000e-
005

4.9765
Maximum

1.2516

4.1921

4.9241

0.0124

0.8106

0.1686

0.9792

0.2239

0.1583

0.3822

0.0000
1,120.334
6 1,120.334
6 0.1556

0.0490
1,138.811
3 Mitigated Construction
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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 1-15-2023
4-14-2023

1.2990

1.2990
2 4-15-2023
7-14-2023

1.2470

1.2470
3 7-15-2023
10-14-2023

1.2627

1.2627
4 10-15-2023
1-14-2024

2.3277

2.3277
5 1-15-2024
4-14-2024

0.0819

0.0819
Highest

2.3277

2.3277

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

1.2787

1.3000e-
004

0.0143

0.0000

5.0000e-
005

5.0000e-
005

5.0000e-
005

5.0000e-
005

0.0000

0.0279

0.0279

7.0000e-
005

0.0000

0.0297
Energy

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
Mobile

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
Waste

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Water

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Total

1.2787

1.3000e-
004

0.0143

0.0000

0.0000

5.0000e-
005

5.0000e-
005

0.0000

5.0000e-
005

5.0000e-
005

0.0000

0.0279

0.0279

7.0000e-
005

0.0000

0.0297
Unmitigated Operational
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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

1.2787

1.3000e-
004

0.0143

0.0000

5.0000e-
005

5.0000e-
005

5.0000e-
005

5.0000e-
005

0.0000

0.0279

0.0279

7.0000e-
005

0.0000

0.0297
Energy

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
Mobile

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
Waste

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Water

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Total

1.2787

1.3000e-
004

0.0143

0.0000

0.0000

5.0000e-
005

5.0000e-
005

0.0000

5.0000e-
005

5.0000e-
005

0.0000

0.0279

0.0279

7.0000e-
005

0.0000

0.0297
Mitigated Operational

3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name
Phase Type
Start Date
End Date
Num Days
Week
Num Days
Phase Description
1 Demolition/Crushing
Demolition
1/15/2023
2/1/2023
5 13
2 Site Preparation
Site Preparation
2/2/2023
2/10/2023
5 7
3 Grading
Grading
2/11/2023
3/10/2023
5 20
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.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

4 Building Construction
Building Construction
3/11/2023
12/8/2023
5 195
5 Paving
Paving
12/9/2023
12/27/2023
5 13
6 Architectural Coating
Architectural Coating
12/28/2023
1/15/2024
5 13
OffRoad Equipment
Phase Name
Offroad Equipment Type
Amount
Usage Hours
Horse Power
Load Factor
Demolition/Crushing
Concrete/Industrial Saws
1 8.00
81 0.73
Demolition/Crushing
Crushing/Proc. Equipment
1 8.00
85 0.78
Demolition/Crushing
Excavators
3 8.00
158

0.38 Demolition/Crushing
Rubber Tired Dozers
2 8.00
247

0.40 Site Preparation
Crawler Tractors
4 8.00
212

0.43 Site Preparation
Rubber Tired Dozers
3 8.00
247

0.40 Site Preparation
Tractors/Loaders/Backhoes
0 8.00
97 0.37
Grading
Crawler Tractors
2 8.00
212

0.43 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 4.00
367

0.48 Grading
Tractors/Loaders/Backhoes
0 8.00
97 0.37
Building Construction
Cranes
2 8.00
231

0.29 Building Construction
Forklifts
5 8.00
89 0.20
Building Construction
Generator Sets
2 8.00
84 0.74
Building Construction
Tractors/Loaders/Backhoes
5 8.00
97 0.37
Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 455,958; Non-Residential Outdoor: 151,986; Striped Parking Area:
29,085 (Architectural Coating
–
sqft)
Acres of Grading (Site Preparation Phase): 24.5
Acres of Grading (Grading Phase): 60
Acres of Paving: 11.03
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.1 Mitigation Measures Construction
Building Construction
Welders
2 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 8.00
78 0.48
Trips and VMT
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/Crushing
7 18.00

10.00 1,730.00

14.70 6.90

20.00 LD_Mix
HDT_Mix
HHDT
Site Preparation
7 18.00

4.00 0.00

14.70 6.90

20.00 LD_Mix
HDT_Mix
HHDT
Grading
8 20.00

14.00 0.00

14.70 6.90

20.00 LD_Mix
HDT_Mix
HHDT
Building Construction
16 331.00
129.00

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 66.00

0.00 0.00

14.70 6.90

20.00 LD_Mix
HDT_Mix
HHDT
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.2 Demolition/Crushing - 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
Fugitive Dust

0.1872

0.0000

0.1872

0.0284

0.0000

0.0284

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Off-Road

0.0177

0.1591

0.1558

3.0000e-
004

7.4900e-
003

7.4900e-
003

7.0400e-
003

7.0400e-
003

0.0000

26.0134

26.0134

6.4200e-
003

0.0000

26.1739
Total

0.0177

0.1591

0.1558

3.0000e-
004

0.1872

7.4900e-
003

0.1947

0.0284

7.0400e-
003

0.0354

0.0000

26.0134

26.0134

6.4200e-
003

0.0000

26.1739
Unmitigated Construction On-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
Hauling

1.8200e-
003

0.1189

0.0303

5.1000e-
004

0.0149

7.1000e-
004

0.0156

4.0900e-
003

6.8000e-
004

4.7700e-
003

0.0000

50.4528

50.4528

2.7800e-
003

8.0100e-
003

52.9098
Vendor

7.0000e-
005

2.6200e-
003

9.8000e-
004

1.0000e-
005

4.1000e-
004

1.0000e-
005

4.2000e-
004

1.2000e-
004

1.0000e-
005

1.3000e-
004

0.0000

1.1818

1.1818

4.0000e-
005

1.7000e-
004

1.2335
Worker

3.7000e-
004

2.9000e-
004

3.9900e-
003

1.0000e-
005

1.2800e-
003

1.0000e-
005

1.2900e-
003

3.4000e-
004

1.0000e-
005

3.5000e-
004

0.0000

1.0205

1.0205

3.0000e-
005

3.0000e-
005

1.0291
Total

2.2600e-
003

0.1219

0.0353

5.3000e-
004

0.0166

7.3000e-
004

0.0173

4.5500e-
003

7.0000e-
004

5.2500e-
003

0.0000

52.6552

52.6552

2.8500e-
003

8.2100e-
003

55.1725
Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.2 Demolition/Crushing - 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
Fugitive Dust

0.1872

0.0000

0.1872

0.0284

0.0000

0.0284

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Off-Road

0.0177

0.1591

0.1558

3.0000e-
004

7.4900e-
003

7.4900e-
003

7.0400e-
003

7.0400e-
003

0.0000

26.0134

26.0134

6.4200e-
003

0.0000

26.1739
Total

0.0177

0.1591

0.1558

3.0000e-
004

0.1872

7.4900e-
003

0.1947

0.0284

7.0400e-
003

0.0354

0.0000

26.0134

26.0134

6.4200e-
003

0.0000

26.1739
Mitigated Construction On-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
Hauling

1.8200e-
003

0.1189

0.0303

5.1000e-
004

0.0149

7.1000e-
004

0.0156

4.0900e-
003

6.8000e-
004

4.7700e-
003

0.0000

50.4528

50.4528

2.7800e-
003

8.0100e-
003

52.9098
Vendor

7.0000e-
005

2.6200e-
003

9.8000e-
004

1.0000e-
005

4.1000e-
004

1.0000e-
005

4.2000e-
004

1.2000e-
004

1.0000e-
005

1.3000e-
004

0.0000

1.1818

1.1818

4.0000e-
005

1.7000e-
004

1.2335
Worker

3.7000e-
004

2.9000e-
004

3.9900e-
003

1.0000e-
005

1.2800e-
003

1.0000e-
005

1.2900e-
003

3.4000e-
004

1.0000e-
005

3.5000e-
004

0.0000

1.0205

1.0205

3.0000e-
005

3.0000e-
005

1.0291
Total

2.2600e-
003

0.1219

0.0353

5.3000e-
004

0.0166

7.3000e-
004

0.0173

4.5500e-
003

7.0000e-
004

5.2500e-
003

0.0000

52.6552

52.6552

2.8500e-
003

8.2100e-
003

55.1725
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.3 Site Preparation - 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
Fugitive Dust

0.0762

0.0000

0.0762

0.0362

0.0000

0.0362

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Off-Road

0.0134

0.1466

0.0640

2.0000e-
004

6.1500e-
003

6.1500e-
003

5.6600e-
003

5.6600e-
003

0.0000

17.5080

17.5080

5.6600e-
003

0.0000

17.6496
Total

0.0134

0.1466

0.0640

2.0000e-
004

0.0762

6.1500e-
003

0.0824

0.0362

5.6600e-
003

0.0418

0.0000

17.5080

17.5080

5.6600e-
003

0.0000

17.6496
Unmitigated Construction On-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
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

2.0000e-
005

5.6000e-
004

2.1000e-
004

0.0000

9.0000e-
005

0.0000

9.0000e-
005

3.0000e-
005

0.0000

3.0000e-
005

0.0000

0.2546

0.2546

1.0000e-
005

4.0000e-
005

0.2657
Worker

2.0000e-
004

1.6000e-
004

2.1500e-
003

1.0000e-
005

6.9000e-
004

0.0000

6.9000e-
004

1.8000e-
004

0.0000

1.9000e-
004

0.0000

0.5495

0.5495

1.0000e-
005

1.0000e-
005

0.5541
Total

2.2000e-
004

7.2000e-
004

2.3600e-
003

1.0000e-
005

7.8000e-
004

0.0000

7.8000e-
004

2.1000e-
004

0.0000

2.2000e-
004

0.0000

0.8041

0.8041

2.0000e-
005

5.0000e-
005

0.8198
Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.3 Site Preparation - 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
Fugitive Dust

0.0762

0.0000

0.0762

0.0362

0.0000

0.0362

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Off-Road

0.0134

0.1466

0.0640

2.0000e-
004

6.1500e-
003

6.1500e-
003

5.6600e-
003

5.6600e-
003

0.0000

17.5080

17.5080

5.6600e-
003

0.0000

17.6496
Total

0.0134

0.1466

0.0640

2.0000e-
004

0.0762

6.1500e-
003

0.0824

0.0362

5.6600e-
003

0.0418

0.0000

17.5080

17.5080

5.6600e-
003

0.0000

17.6496
Mitigated Construction On-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
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

2.0000e-
005

5.6000e-
004

2.1000e-
004

0.0000

9.0000e-
005

0.0000

9.0000e-
005

3.0000e-
005

0.0000

3.0000e-
005

0.0000

0.2546

0.2546

1.0000e-
005

4.0000e-
005

0.2657
Worker

2.0000e-
004

1.6000e-
004

2.1500e-
003

1.0000e-
005

6.9000e-
004

0.0000

6.9000e-
004

1.8000e-
004

0.0000

1.9000e-
004

0.0000

0.5495

0.5495

1.0000e-
005

1.0000e-
005

0.5541
Total

2.2000e-
004

7.2000e-
004

2.3600e-
003

1.0000e-
005

7.8000e-
004

0.0000

7.8000e-
004

2.1000e-
004

0.0000

2.2000e-
004

0.0000

0.8041

0.8041

2.0000e-
005

5.0000e-
005

0.8198
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.4 Grading - 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
Fugitive Dust

0.0920

0.0000

0.0920

0.0365

0.0000

0.0365

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Off-Road

0.0312

0.3341

0.2194

5.6000e-
004

0.0135

0.0135

0.0124

0.0124

0.0000

49.4846

49.4846

0.0160

0.0000

49.8847
Total

0.0312

0.3341

0.2194

5.6000e-
004

0.0920

0.0135

0.1055

0.0365

0.0124

0.0489

0.0000

49.4846

49.4846

0.0160

0.0000

49.8847
Unmitigated Construction On-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
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

1.6000e-
004

5.6400e-
003

2.1100e-
003

3.0000e-
005

8.8000e-
004

3.0000e-
005

9.1000e-
004

2.5000e-
004

3.0000e-
005

2.8000e-
004

0.0000

2.5455

2.5455

9.0000e-
005

3.7000e-
004

2.6568
Worker

6.3000e-
004

5.0000e-
004

6.8100e-
003

2.0000e-
005

2.1900e-
003

1.0000e-
005

2.2100e-
003

5.8000e-
004

1.0000e-
005

5.9000e-
004

0.0000

1.7445

1.7445

5.0000e-
005

5.0000e-
005

1.7592
Total

7.9000e-
004

6.1400e-
003

8.9200e-
003

5.0000e-
005

3.0700e-
003

4.0000e-
005

3.1200e-
003

8.3000e-
004

4.0000e-
005

8.7000e-
004

0.0000

4.2900

4.2900

1.4000e-
004

4.2000e-
004

4.4160
Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.4 Grading - 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
Fugitive Dust

0.0920

0.0000

0.0920

0.0365

0.0000

0.0365

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Off-Road

0.0312

0.3341

0.2194

5.6000e-
004

0.0135

0.0135

0.0124

0.0124

0.0000

49.4845

49.4845

0.0160

0.0000

49.8846
Total

0.0312

0.3341

0.2194

5.6000e-
004

0.0920

0.0135

0.1055

0.0365

0.0124

0.0489

0.0000

49.4845

49.4845

0.0160

0.0000

49.8846
Mitigated Construction On-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
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

1.6000e-
004

5.6400e-
003

2.1100e-
003

3.0000e-
005

8.8000e-
004

3.0000e-
005

9.1000e-
004

2.5000e-
004

3.0000e-
005

2.8000e-
004

0.0000

2.5455

2.5455

9.0000e-
005

3.7000e-
004

2.6568
Worker

6.3000e-
004

5.0000e-
004

6.8100e-
003

2.0000e-
005

2.1900e-
003

1.0000e-
005

2.2100e-
003

5.8000e-
004

1.0000e-
005

5.9000e-
004

0.0000

1.7445

1.7445

5.0000e-
005

5.0000e-
005

1.7592
Total

7.9000e-
004

6.1400e-
003

8.9200e-
003

5.0000e-
005

3.0700e-
003

4.0000e-
005

3.1200e-
003

8.3000e-
004

4.0000e-
005

8.7000e-
004

0.0000

4.2900

4.2900

1.4000e-
004

4.2000e-
004

4.4160
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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

0.3016

2.7671

3.0463

5.1700e-
003

0.1327

0.1327

0.1250

0.1250

0.0000
444.6142
444.6142

0.1051

0.0000
447.2425
Total

0.3016

2.7671

3.0463

5.1700e-
003

0.1327

0.1327

0.1250

0.1250

0.0000
444.6142
444.6142

0.1051

0.0000
447.2425
Unmitigated Construction On-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
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

0.0142

0.5069

0.1897

2.3400e-
003

0.0793

2.4300e-
003

0.0817

0.0229

2.3300e-
003

0.0252

0.0000
228.6869
228.6869

7.6400e-
003

0.0329
238.6856
Worker

0.1024

0.0813

1.0996

3.0700e-
003

0.3536

2.1700e-
003

0.3558

0.0939

2.0000e-
003

0.0959

0.0000
281.4949
281.4949

7.4900e-
003

7.3300e-
003
283.8656
Total

0.1166

0.5882

1.2893

5.4100e-
003

0.4329

4.6000e-
003

0.4375

0.1168

4.3300e-
003

0.1211

0.0000
510.1818
510.1818

0.0151

0.0402
522.5512
Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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

0.3016

2.7671

3.0463

5.1700e-
003

0.1327

0.1327

0.1250

0.1250

0.0000
444.6136
444.6136

0.1051

0.0000
447.2420
Total

0.3016

2.7671

3.0463

5.1700e-
003

0.1327

0.1327

0.1250

0.1250

0.0000
444.6136
444.6136

0.1051

0.0000
447.2420
Mitigated Construction On-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
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

0.0142

0.5069

0.1897

2.3400e-
003

0.0793

2.4300e-
003

0.0817

0.0229

2.3300e-
003

0.0252

0.0000
228.6869
228.6869

7.6400e-
003

0.0329
238.6856
Worker

0.1024

0.0813

1.0996

3.0700e-
003

0.3536

2.1700e-
003

0.3558

0.0939

2.0000e-
003

0.0959

0.0000
281.4949
281.4949

7.4900e-
003

7.3300e-
003
283.8656
Total

0.1166

0.5882

1.2893

5.4100e-
003

0.4329

4.6000e-
003

0.4375

0.1168

4.3300e-
003

0.1211

0.0000
510.1818
510.1818

0.0151

0.0402
522.5512
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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

6.7100e-
003

0.0663

0.0948

1.5000e-
004

3.3200e-
003

3.3200e-
003

3.0500e-
003

3.0500e-
003

0.0000

13.0175

13.0175

4.2100e-
003

0.0000

13.1227
Paving

0.0145

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Total

0.0212

0.0663

0.0948

1.5000e-
004

3.3200e-
003

3.3200e-
003

3.0500e-
003

3.0500e-
003

0.0000

13.0175

13.0175

4.2100e-
003

0.0000

13.1227
Unmitigated Construction On-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
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

3.1000e-
004

2.5000e-
004

3.3200e-
003

1.0000e-
005

1.0700e-
003

1.0000e-
005

1.0700e-
003

2.8000e-
004

1.0000e-
005

2.9000e-
004

0.0000

0.8504

0.8504

2.0000e-
005

2.0000e-
005

0.8576
Total

3.1000e-
004

2.5000e-
004

3.3200e-
003

1.0000e-
005

1.0700e-
003

1.0000e-
005

1.0700e-
003

2.8000e-
004

1.0000e-
005

2.9000e-
004

0.0000

0.8504

0.8504

2.0000e-
005

2.0000e-
005

0.8576
Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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

6.7100e-
003

0.0663

0.0948

1.5000e-
004

3.3200e-
003

3.3200e-
003

3.0500e-
003

3.0500e-
003

0.0000

13.0175

13.0175

4.2100e-
003

0.0000

13.1227
Paving

0.0145

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Total

0.0212

0.0663

0.0948

1.5000e-
004

3.3200e-
003

3.3200e-
003

3.0500e-
003

3.0500e-
003

0.0000

13.0175

13.0175

4.2100e-
003

0.0000

13.1227
Mitigated Construction On-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
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

3.1000e-
004

2.5000e-
004

3.3200e-
003

1.0000e-
005

1.0700e-
003

1.0000e-
005

1.0700e-
003

2.8000e-
004

1.0000e-
005

2.9000e-
004

0.0000

0.8504

0.8504

2.0000e-
005

2.0000e-
005

0.8576
Total

3.1000e-
004

2.5000e-
004

3.3200e-
003

1.0000e-
005

1.0700e-
003

1.0000e-
005

1.0700e-
003

2.8000e-
004

1.0000e-
005

2.9000e-
004

0.0000

0.8504

0.8504

2.0000e-
005

2.0000e-
005

0.8576
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.7 Architectural Coating - 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
Archit. Coating

0.2271

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Off-Road

2.6000e-
004

1.7400e-
003

2.4100e-
003

0.0000

9.0000e-
005

9.0000e-
005

9.0000e-
005

9.0000e-
005

0.0000

0.3404

0.3404

2.0000e-
005

0.0000

0.3409
Total

0.2274

1.7400e-
003

2.4100e-
003

0.0000

9.0000e-
005

9.0000e-
005

9.0000e-
005

9.0000e-
005

0.0000

0.3404

0.3404

2.0000e-
005

0.0000

0.3409
Unmitigated Construction On-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
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

2.1000e-
004

1.7000e-
004

2.2500e-
003

1.0000e-
005

7.2000e-
004

0.0000

7.3000e-
004

1.9000e-
004

0.0000

2.0000e-
004

0.0000

0.5757

0.5757

2.0000e-
005

1.0000e-
005

0.5805
Total

2.1000e-
004

1.7000e-
004

2.2500e-
003

1.0000e-
005

7.2000e-
004

0.0000

7.3000e-
004

1.9000e-
004

0.0000

2.0000e-
004

0.0000

0.5757

0.5757

2.0000e-
005

1.0000e-
005

0.5805
Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.7 Architectural Coating - 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
Archit. Coating

0.2271

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Off-Road

2.6000e-
004

1.7400e-
003

2.4100e-
003

0.0000

9.0000e-
005

9.0000e-
005

9.0000e-
005

9.0000e-
005

0.0000

0.3404

0.3404

2.0000e-
005

0.0000

0.3409
Total

0.2274

1.7400e-
003

2.4100e-
003

0.0000

9.0000e-
005

9.0000e-
005

9.0000e-
005

9.0000e-
005

0.0000

0.3404

0.3404

2.0000e-
005

0.0000

0.3409
Mitigated Construction On-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
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

2.1000e-
004

1.7000e-
004

2.2500e-
003

1.0000e-
005

7.2000e-
004

0.0000

7.3000e-
004

1.9000e-
004

0.0000

2.0000e-
004

0.0000

0.5757

0.5757

2.0000e-
005

1.0000e-
005

0.5805
Total

2.1000e-
004

1.7000e-
004

2.2500e-
003

1.0000e-
005

7.2000e-
004

0.0000

7.3000e-
004

1.9000e-
004

0.0000

2.0000e-
004

0.0000

0.5757

0.5757

2.0000e-
005

1.0000e-
005

0.5805
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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
Archit. Coating

1.2492

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Off-Road

1.3300e-
003

8.9400e-
003

0.0133

2.0000e-
005

4.5000e-
004

4.5000e-
004

4.5000e-
004

4.5000e-
004

0.0000

1.8724

1.8724

1.1000e-
004

0.0000

1.8750
Total

1.2505

8.9400e-
003

0.0133

2.0000e-
005

4.5000e-
004

4.5000e-
004

4.5000e-
004

4.5000e-
004

0.0000

1.8724

1.8724

1.1000e-
004

0.0000

1.8750
Unmitigated Construction On-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
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

1.0700e-
003

8.2000e-
004

0.0115

3.0000e-
005

3.9800e-
003

2.0000e-
005

4.0000e-
003

1.0600e-
003

2.0000e-
005

1.0800e-
003

0.0000

3.0767

3.0767

8.0000e-
005

8.0000e-
005

3.1015
Total

1.0700e-
003

8.2000e-
004

0.0115

3.0000e-
005

3.9800e-
003

2.0000e-
005

4.0000e-
003

1.0600e-
003

2.0000e-
005

1.0800e-
003

0.0000

3.0767

3.0767

8.0000e-
005

8.0000e-
005

3.1015
Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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
Archit. Coating

1.2492

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Off-Road

1.3300e-
003

8.9400e-
003

0.0133

2.0000e-
005

4.5000e-
004

4.5000e-
004

4.5000e-
004

4.5000e-
004

0.0000

1.8724

1.8724

1.1000e-
004

0.0000

1.8750
Total

1.2505

8.9400e-
003

0.0133

2.0000e-
005

4.5000e-
004

4.5000e-
004

4.5000e-
004

4.5000e-
004

0.0000

1.8724

1.8724

1.1000e-
004

0.0000

1.8750
Mitigated Construction On-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
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

1.0700e-
003

8.2000e-
004

0.0115

3.0000e-
005

3.9800e-
003

2.0000e-
005

4.0000e-
003

1.0600e-
003

2.0000e-
005

1.0800e-
003

0.0000

3.0767

3.0767

8.0000e-
005

8.0000e-
005

3.1015
Total

1.0700e-
003

8.2000e-
004

0.0115

3.0000e-
005

3.9800e-
003

2.0000e-
005

4.0000e-
003

1.0600e-
003

2.0000e-
005

1.0800e-
003

0.0000

3.0767

3.0767

8.0000e-
005

8.0000e-
005

3.1015
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

4.0 Operational Detail - Mobile
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

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
Unmitigated

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

4.1 Mitigation Measures Mobile

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
Other Asphalt Surfaces

0.00 0.00

0.00 Parking Lot

0.00 0.00

0.00 Refrigerated Warehouse-No Rail

0.00 0.00

0.00 Unrefrigerated Warehouse-No Rail

0.00 0.00

0.00 Total

0.00 0.00

0.00 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
Other Asphalt Surfaces

0.00 0.00

0.00 0.00

0.00 0.00
0 0
0 Parking Lot

0.00 0.00

0.00 0.00

0.00 0.00
0 0
0 Refrigerated Warehouse-No
Rail

0.00 0.00

0.00 0.00

0.00 0.00
0 0
0 CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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
Unrefrigerated Warehouse-No
Rail

0.00 0.00

0.00 0.00

0.00 0.00
0 0
0 4.4 Fleet Mix
Land Use
LDA
LDT1
LDT2
MDV
LHD1
LHD2
MHD
HHD
OBUS
UBUS
MCY
SBUS
MH
Other Asphalt Surfaces

0.542464

0.063735

0.188241

0.126899

0.023249

0.006239

0.010717

0.008079

0.000923

0.000604

0.024795

0.000702

0.003352
Parking Lot

0.542464

0.063735

0.188241

0.126899

0.023249

0.006239

0.010717

0.008079

0.000923

0.000604

0.024795

0.000702

0.003352
Refrigerated Warehouse-No Rail

0.542464

0.063735

0.188241

0.126899

0.023249

0.006239

0.010717

0.008079

0.000923

0.000604

0.024795

0.000702

0.003352
Unrefrigerated Warehouse-No
Rail

0.542464

0.063735

0.188241

0.126899

0.023249

0.006239

0.010717

0.008079

0.000923

0.000604

0.024795

0.000702

0.003352

5.0 Energy Detail

5.1 Mitigation Measures Energy
Historical Energy Use: N
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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

0.0000

0.0000

0.0000

0.0000

0.0000
Electricity
Unmitigated

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
NaturalGas
Mitigated

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
NaturalGas
Unmitigated

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
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Land Use
kBTU/yr
tons/yr
MT/yr
Other Asphalt
Surfaces
0 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
Parking Lot
0 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
Refrigerated
Warehouse-No
Rail
0 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
Unrefrigerated
Warehouse-No
Rail
0 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
Total

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
Unmitigated
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Land Use
kBTU/yr
tons/yr
MT/yr
Other Asphalt
Surfaces
0 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
Parking Lot
0 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
Refrigerated
Warehouse-No
Rail
0 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
Unrefrigerated
Warehouse-No
Rail
0 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
Total

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
Mitigated
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2
CH4
N2O
CO2e
Land Use
kWh/yr
MT/yr
Other Asphalt
Surfaces
0 0.0000

0.0000

0.0000

0.0000
Parking Lot
0 0.0000

0.0000

0.0000

0.0000
Refrigerated
Warehouse-No
Rail
0 0.0000

0.0000

0.0000

0.0000
Unrefrigerated
Warehouse-No
Rail
0 0.0000

0.0000

0.0000

0.0000
Total

0.0000

0.0000

0.0000

0.0000
Unmitigated
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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
Other Asphalt
Surfaces
0 0.0000

0.0000

0.0000

0.0000
Parking Lot
0 0.0000

0.0000

0.0000

0.0000
Refrigerated
Warehouse-No
Rail
0 0.0000

0.0000

0.0000

0.0000
Unrefrigerated
Warehouse-No
Rail
0 0.0000

0.0000

0.0000

0.0000
Total

0.0000

0.0000

0.0000

0.0000
Mitigated
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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

1.2787

1.3000e-
004

0.0143

0.0000

5.0000e-
005

5.0000e-
005

5.0000e-
005

5.0000e-
005

0.0000

0.0279

0.0279

7.0000e-
005

0.0000

0.0297
Unmitigated

1.2787

1.3000e-
004

0.0143

0.0000

5.0000e-
005

5.0000e-
005

5.0000e-
005

5.0000e-
005

0.0000

0.0279

0.0279

7.0000e-
005

0.0000

0.0297

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

0.1476

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Consumer
Products

1.1297

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Landscaping

1.3200e-
003

1.3000e-
004

0.0143

0.0000

5.0000e-
005

5.0000e-
005

5.0000e-
005

5.0000e-
005

0.0000

0.0279

0.0279

7.0000e-
005

0.0000

0.0297
Total

1.2787

1.3000e-
004

0.0143

0.0000

5.0000e-
005

5.0000e-
005

5.0000e-
005

5.0000e-
005

0.0000

0.0279

0.0279

7.0000e-
005

0.0000

0.0297
Unmitigated
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

7.1 Mitigation Measures Water

7.0 Water Detail

6.2 Area by SubCategory
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
SubCategory
tons/yr
MT/yr
Architectural
Coating

0.1476

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Consumer
Products

1.1297

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Landscaping

1.3200e-
003

1.3000e-
004

0.0143

0.0000

5.0000e-
005

5.0000e-
005

5.0000e-
005

5.0000e-
005

0.0000

0.0279

0.0279

7.0000e-
005

0.0000

0.0297
Total

1.2787

1.3000e-
004

0.0143

0.0000

5.0000e-
005

5.0000e-
005

5.0000e-
005

5.0000e-
005

0.0000

0.0279

0.0279

7.0000e-
005

0.0000

0.0297
Mitigated
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

Total CO2
CH4
N2O
CO2e
Category
MT/yr
Mitigated

0.0000

0.0000

0.0000

0.0000
Unmitigated

0.0000

0.0000

0.0000

0.0000

7.2 Water by Land Use
Indoor/Out
door Use
Total CO2
CH4
N2O
CO2e
Land Use
Mgal
MT/yr
Other Asphalt
Surfaces
0 / 0

0.0000

0.0000

0.0000

0.0000
Parking Lot
0 / 0

0.0000

0.0000

0.0000

0.0000
Refrigerated
Warehouse-No
Rail
0 / 0

0.0000

0.0000

0.0000

0.0000
Unrefrigerated
Warehouse-No
Rail
0 / 0

0.0000

0.0000

0.0000

0.0000
Total

0.0000

0.0000

0.0000

0.0000
Unmitigated
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

7.2 Water by Land Use
Indoor/Out
door Use
Total CO2
CH4
N2O
CO2e
Land Use
Mgal
MT/yr
Other Asphalt
Surfaces
0 / 0

0.0000

0.0000

0.0000

0.0000
Parking Lot
0 / 0

0.0000

0.0000

0.0000

0.0000
Refrigerated
Warehouse-No
Rail
0 / 0

0.0000

0.0000

0.0000

0.0000
Unrefrigerated
Warehouse-No
Rail
0 / 0

0.0000

0.0000

0.0000

0.0000
Total

0.0000

0.0000

0.0000

0.0000
Mitigated

8.1 Mitigation Measures Waste

8.0 Waste Detail
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

Total CO2
CH4
N2O
CO2e
MT/yr
Mitigated

0.0000

0.0000

0.0000

0.0000
Unmitigated

0.0000

0.0000

0.0000

0.0000
Category/Year

8.2 Waste by Land Use
Waste
Disposed
Total CO2
CH4
N2O
CO2e
Land Use
tons
MT/yr
Other Asphalt
Surfaces
0 0.0000

0.0000

0.0000

0.0000
Parking Lot
0 0.0000

0.0000

0.0000

0.0000
Refrigerated
Warehouse-No
Rail
0 0.0000

0.0000

0.0000

0.0000
Unrefrigerated
Warehouse-No
Rail
0 0.0000

0.0000

0.0000

0.0000
Total

0.0000

0.0000

0.0000

0.0000
Unmitigated
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

8.2 Waste by Land Use
Waste
Disposed
Total CO2
CH4
N2O
CO2e
Land Use
tons
MT/yr
Other Asphalt
Surfaces
0 0.0000

0.0000

0.0000

0.0000
Parking Lot
0 0.0000

0.0000

0.0000

0.0000
Refrigerated
Warehouse-No
Rail
0 0.0000

0.0000

0.0000

0.0000
Unrefrigerated
Warehouse-No
Rail
0 0.0000

0.0000

0.0000

0.0000
Total

0.0000

0.0000

0.0000

0.0000
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
Boilers
Equipment Type
Number
Heat Input/Day
Heat Input/Year
Boiler Rating
Fuel Type
User Defined Equipment
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

11.0 Vegetation
Equipment Type
Number
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:20 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

Cherry Avenue Warehouse (Construction - Unmitigated)
Los Angeles-South Coast County, Summer
Project Characteristics - Consistent with the Staff Report's model.

Land Use - See SWAPE's comments on "Underestimated Parking Land Use Size" Construction Phase - See SWAPE's comments on "Unsubstantiated Changes to Individual Construction Phase Lengths" Off-road Equipment - Consistent with the Staff Report's model.

Off-road Equipment - Consistent with the Staff Report's model.

Off-road Equipment - Consistent with the Staff Report's model.

Off-road Equipment - Consistent with the Staff Report's model.

Off-road Equipment - Consistent with the Staff Report's model.

Off-road Equipment - Consistent with the Staff Report's model.

1.1 Land Usage
Land Uses
Size
Metric
Lot Acreage
Floor Surface Area
Population
Refrigerated Warehouse-No Rail

45.60 1000sqft

1.05 45,596.00
0 Unrefrigerated Warehouse-No Rail
258.38
1000sqft

5.93 258,376.00
0 Other Asphalt Surfaces
261.15
1000sqft

6.00 261,149.00
0 Parking Lot
559.00
Space

5.03 223,600.00
0 1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
9 Wind Speed (m/s)
Precipitation Freq (Days)

2.2 33

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company
Southern California Edison
2024
Operational Year
CO2 Intensity
(lb/MWhr)
390.98

0.033
CH4 Intensity
(lb/MWhr)

0.004
N2O Intensity
(lb/MWhr)
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:23 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

Trips and VMT - See SWAPE's comments on "Failure to Model All Required Demolition" Demolition - See SWAPE's comments on "Failure to Model All Required Demolition" Grading - Consistent with the Staff Report's model.

Architectural Coating - See SWAPE's comments on "Unsubstantiated Reductions to Architectural Coating Emission Factors" Vehicle Trips - Consistent with the Staff Report's model.

Energy Use - Consitent with the Staff Report's model.

Water And Wastewater - Consistent with the Staff Report's model.

Solid Waste - Consistent with the Staff Report's model.

Table Name
Column Name
Default Value
New Value
tblConstructionPhase
NumDays

20.00 13.00
tblConstructionPhase
NumDays
300.00
195.00
tblConstructionPhase
NumDays

20.00 13.00
tblConstructionPhase
NumDays

30.00 20.00
tblConstructionPhase
NumDays

20.00 13.00
tblConstructionPhase
NumDays

10.00 7.00
tblEnergyUse
LightingElect

0.35 0.00
tblEnergyUse
LightingElect

2.73 0.00
tblEnergyUse
LightingElect

1.91 0.00
tblEnergyUse
NT24E

13.61 0.00
tblEnergyUse
NT24E

1.34 0.00
tblEnergyUse
NT24NG

0.09 0.00
tblEnergyUse
NT24NG

0.03 0.00
tblEnergyUse
T24E

0.37 0.00
tblEnergyUse
T24E

0.58 0.00
tblEnergyUse
T24NG

0.93 0.00
tblEnergyUse
T24NG

0.83 0.00
tblLandUse
LandUseSquareFeet
45,600.00
45,596.00
tblLandUse
LandUseSquareFeet
258,380.00
258,376.00
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:23 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

tblLandUse
LandUseSquareFeet
261,150.00
261,149.00
tblOffRoadEquipment
OffRoadEquipmentUnitAmount

1.00 2.00
tblOffRoadEquipment
OffRoadEquipmentUnitAmount

3.00 5.00
tblOffRoadEquipment
OffRoadEquipmentUnitAmount

1.00 2.00
tblOffRoadEquipment
OffRoadEquipmentUnitAmount

3.00 5.00
tblOffRoadEquipment
OffRoadEquipmentUnitAmount

2.00 0.00
tblOffRoadEquipment
OffRoadEquipmentUnitAmount

4.00 0.00
tblOffRoadEquipment
OffRoadEquipmentUnitAmount

1.00 2.00
tblOffRoadEquipment
UsageHours

6.00 8.00
tblOffRoadEquipment
UsageHours

7.00 8.00
tblOffRoadEquipment
UsageHours

8.00 4.00
tblOffRoadEquipment
UsageHours

7.00 8.00
tblSolidWaste
SolidWasteGenerationRate

42.86 0.00
tblSolidWaste
SolidWasteGenerationRate
242.88

0.00 tblTripsAndVMT
VendorTripNumber

0.00 10.00
tblTripsAndVMT
VendorTripNumber

0.00 4.00
tblTripsAndVMT
VendorTripNumber

0.00 14.00
tblVehicleTrips
CC_TL

8.40 0.00
tblVehicleTrips
CC_TL

8.40 0.00
tblVehicleTrips
CC_TL

8.40 0.00
tblVehicleTrips
CC_TL

8.40 0.00
tblVehicleTrips
CNW_TL

6.90 0.00
tblVehicleTrips
CNW_TL

6.90 0.00
tblVehicleTrips
CNW_TL

6.90 0.00
tblVehicleTrips
CNW_TL

6.90 0.00
tblVehicleTrips
CNW_TTP

41.00 0.00
tblVehicleTrips
CNW_TTP

41.00 0.00
tblVehicleTrips
CW_TL

16.60 0.00
tblVehicleTrips
CW_TL

16.60 0.00
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:23 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

2.0 Emissions Summary
tblVehicleTrips
CW_TL

16.60 0.00
tblVehicleTrips
CW_TL

16.60 0.00
tblVehicleTrips
CW_TTP

59.00 0.00
tblVehicleTrips
CW_TTP

59.00 0.00
tblVehicleTrips
DV_TP

5.00 0.00
tblVehicleTrips
DV_TP

5.00 0.00
tblVehicleTrips
PB_TP

3.00 0.00
tblVehicleTrips
PB_TP

3.00 0.00
tblVehicleTrips
PR_TP

92.00 0.00
tblVehicleTrips
PR_TP

92.00 0.00
tblVehicleTrips
ST_TR

2.12 0.00
tblVehicleTrips
ST_TR

1.74 0.00
tblVehicleTrips
SU_TR

2.12 0.00
tblVehicleTrips
SU_TR

1.74 0.00
tblVehicleTrips
WD_TR

2.12 0.00
tblVehicleTrips
WD_TR

1.74 0.00
tblWater
IndoorWaterUseRate
10,545,000.00

0.00 tblWater
IndoorWaterUseRate
59,750,375.00

0.00 CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:23 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

2.1 Overall Construction (Maximum Daily Emission)
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Year
lb/day
lb/day
2023
227.5921

42.2577

45.1245

0.1273

31.4010

1.7597

32.6656

10.3922

1.6190

12.0112

0.0000
13,344.13
31 13,344.13
31 1.7906

1.3910
13,797.95
74 2024
227.5631

1.7565

4.6299

0.0103

0.7377

0.0855

0.8232

0.1957

0.0851

0.2808

0.0000
1,016.605
9 1,016.605
9 0.0362

0.0142
1,021.732
0 Maximum
227.5921

42.2577

45.1245

0.1273

31.4010

1.7597

32.6656

10.3922

1.6190

12.0112

0.0000
13,344.13
31 13,344.13
31 1.7906

1.3910
13,797.95
74 Unmitigated 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
lb/day
lb/day
2023
227.5921

42.2577

45.1245

0.1273

31.4010

1.7597

32.6656

10.3922

1.6190

12.0112

0.0000
13,344.13
31 13,344.13
31 1.7906

1.3910
13,797.95
74 2024
227.5631

1.7565

4.6299

0.0103

0.7377

0.0855

0.8232

0.1957

0.0851

0.2808

0.0000
1,016.605
9 1,016.605
9 0.0362

0.0142
1,021.732
0 Maximum
227.5921

42.2577

45.1245

0.1273

31.4010

1.7597

32.6656

10.3922

1.6190

12.0112

0.0000
13,344.13
31 13,344.13
31 1.7906

1.3910
13,797.95
74 Mitigated Construction
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:23 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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.2020.4.0
Date: 2/2/2023 1:23 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

2.2 Overall Operational
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Area

7.0099

1.0400e-
003

0.1146

1.0000e-
005

4.1000e-
004

4.1000e-
004

4.1000e-
004

4.1000e-
004

0.2460

0.2460

6.4000e-
004

0.2621
Energy

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
Mobile

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
Total

7.0099

1.0400e-
003

0.1146

1.0000e-
005

0.0000

4.1000e-
004

4.1000e-
004

0.0000

4.1000e-
004

4.1000e-
004

0.2460

0.2460

6.4000e-
004

0.0000

0.2621
Unmitigated Operational
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Area

7.0099

1.0400e-
003

0.1146

1.0000e-
005

4.1000e-
004

4.1000e-
004

4.1000e-
004

4.1000e-
004

0.2460

0.2460

6.4000e-
004

0.2621
Energy

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
Mobile

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
Total

7.0099

1.0400e-
003

0.1146

1.0000e-
005

0.0000

4.1000e-
004

4.1000e-
004

0.0000

4.1000e-
004

4.1000e-
004

0.2460

0.2460

6.4000e-
004

0.0000

0.2621
Mitigated Operational
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:23 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name
Phase Type
Start Date
End Date
Num Days
Week
Num Days
Phase Description
1 Demolition/Crushing
Demolition
1/15/2023
2/1/2023
5 13
2 Site Preparation
Site Preparation
2/2/2023
2/10/2023
5 7
3 Grading
Grading
2/11/2023
3/10/2023
5 20
4 Building Construction
Building Construction
3/11/2023
12/8/2023
5 195
5 Paving
Paving
12/9/2023
12/27/2023
5 13
6 Architectural Coating
Architectural Coating
12/28/2023
1/15/2024
5 13
OffRoad Equipment
Phase Name
Offroad Equipment Type
Amount
Usage Hours
Horse Power
Load Factor
Demolition/Crushing
Concrete/Industrial Saws
1 8.00
81 0.73
Demolition/Crushing
Crushing/Proc. Equipment
1 8.00
85 0.78
Demolition/Crushing
Excavators
3 8.00
158

0.38 Demolition/Crushing
Rubber Tired Dozers
2 8.00
247

0.40 Site Preparation
Crawler Tractors
4 8.00
212

0.43 ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio-CO2
Total CO2
CH4
N20
CO2e
Percent
Reduction

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00
Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 455,958; Non-Residential Outdoor: 151,986; Striped Parking Area:
29,085 (Architectural Coating
–
sqft)
Acres of Grading (Site Preparation Phase): 24.5
Acres of Grading (Grading Phase): 60
Acres of Paving: 11.03
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:23 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.1 Mitigation Measures Construction
Site Preparation
Rubber Tired Dozers
3 8.00
247

0.40 Site Preparation
Tractors/Loaders/Backhoes
0 8.00
97 0.37
Grading
Crawler Tractors
2 8.00
212

0.43 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 4.00
367

0.48 Grading
Tractors/Loaders/Backhoes
0 8.00
97 0.37
Building Construction
Cranes
2 8.00
231

0.29 Building Construction
Forklifts
5 8.00
89 0.20
Building Construction
Generator Sets
2 8.00
84 0.74
Building Construction
Tractors/Loaders/Backhoes
5 8.00
97 0.37
Building Construction
Welders
2 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 8.00
78 0.48
Trips and VMT
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/Crushing
7 18.00

10.00 1,730.00

14.70 6.90

20.00 LD_Mix
HDT_Mix
HHDT
Site Preparation
7 18.00

4.00 0.00

14.70 6.90

20.00 LD_Mix
HDT_Mix
HHDT
Grading
8 20.00

14.00 0.00

14.70 6.90

20.00 LD_Mix
HDT_Mix
HHDT
Building Construction
16 331.00
129.00

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 66.00

0.00 0.00

14.70 6.90

20.00 LD_Mix
HDT_Mix
HHDT
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:23 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.2 Demolition/Crushing - 2023
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Fugitive Dust

28.8064

0.0000

28.8064

4.3615

0.0000

4.3615

0.0000

0.0000
Off-Road

2.7193

24.4686

23.9699

0.0459

1.1519

1.1519

1.0823

1.0823
4,411.514
1 4,411.514
1 1.0891
4,438.742
3 Total

2.7193

24.4686

23.9699

0.0459

28.8064

1.1519

29.9582

4.3615

1.0823

5.4439
4,411.514
1 4,411.514
1 1.0891
4,438.742
3 Unmitigated Construction On-Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Hauling

0.2886

17.3652

4.6349

0.0778

2.3294

0.1095

2.4389

0.6387

0.1048

0.7435
8,552.322
9 8,552.322
9 0.4713

1.3581
8,968.818
9 Vendor

0.0115

0.3838

0.1487

1.8600e-
003

0.0641

1.9300e-
003

0.0660

0.0184

1.8500e-
003

0.0203
200.2825
200.2825

6.7100e-
003

0.0288
209.0311
Worker

0.0576

0.0402

0.6505

1.7800e-
003

0.2012

1.2100e-
003

0.2024

0.0534

1.1100e-
003

0.0545
180.0136
180.0136

4.5400e-
003

4.1500e-
003
181.3650
Total

0.3577

17.7892

5.4341

0.0815

2.5947

0.1127

2.7073

0.7105

0.1078

0.8182
8,932.619
0 8,932.619
0 0.4826

1.3910
9,359.215
1 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:23 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.2 Demolition/Crushing - 2023
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Fugitive Dust

28.8064

0.0000

28.8064

4.3615

0.0000

4.3615

0.0000

0.0000
Off-Road

2.7193

24.4686

23.9699

0.0459

1.1519

1.1519

1.0823

1.0823

0.0000
4,411.514
1 4,411.514
1 1.0891
4,438.742
3 Total

2.7193

24.4686

23.9699

0.0459

28.8064

1.1519

29.9582

4.3615

1.0823

5.4439

0.0000
4,411.514
1 4,411.514
1 1.0891
4,438.742
3 Mitigated Construction On-Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Hauling

0.2886

17.3652

4.6349

0.0778

2.3294

0.1095

2.4389

0.6387

0.1048

0.7435
8,552.322
9 8,552.322
9 0.4713

1.3581
8,968.818
9 Vendor

0.0115

0.3838

0.1487

1.8600e-
003

0.0641

1.9300e-
003

0.0660

0.0184

1.8500e-
003

0.0203
200.2825
200.2825

6.7100e-
003

0.0288
209.0311
Worker

0.0576

0.0402

0.6505

1.7800e-
003

0.2012

1.2100e-
003

0.2024

0.0534

1.1100e-
003

0.0545
180.0136
180.0136

4.5400e-
003

4.1500e-
003
181.3650
Total

0.3577

17.7892

5.4341

0.0815

2.5947

0.1127

2.7073

0.7105

0.1078

0.8182
8,932.619
0 8,932.619
0 0.4826

1.3910
9,359.215
1 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:23 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.3 Site Preparation - 2023
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Fugitive Dust

21.7780

0.0000

21.7780

10.3315

0.0000

10.3315

0.0000

0.0000
Off-Road

3.8307

41.8798

18.2937

0.0569

1.7577

1.7577

1.6171

1.6171
5,514.089
1 5,514.089
1 1.7834
5,558.673
3 Total

3.8307

41.8798

18.2937

0.0569

21.7780

1.7577

23.5357

10.3315

1.6171

11.9486
5,514.089
1 5,514.089
1 1.7834
5,558.673
3 Unmitigated Construction On-Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
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
Vendor

4.6100e-
003

0.1535

0.0595

7.4000e-
004

0.0256

7.7000e-
004

0.0264

7.3800e-
003

7.4000e-
004

8.1200e-
003

80.1130

80.1130

2.6800e-
003

0.0115

83.6124
Worker

0.0576

0.0402

0.6505

1.7800e-
003

0.2012

1.2100e-
003

0.2024

0.0534

1.1100e-
003

0.0545
180.0136
180.0136

4.5400e-
003

4.1500e-
003
181.3650
Total

0.0622

0.1937

0.7100

2.5200e-
003

0.2268

1.9800e-
003

0.2288

0.0607

1.8500e-
003

0.0626
260.1266
260.1266

7.2200e-
003

0.0157
264.9775
Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:23 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.3 Site Preparation - 2023
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Fugitive Dust

21.7780

0.0000

21.7780

10.3315

0.0000

10.3315

0.0000

0.0000
Off-Road

3.8307

41.8798

18.2937

0.0569

1.7577

1.7577

1.6171

1.6171

0.0000
5,514.089
1 5,514.089
1 1.7834
5,558.673
3 Total

3.8307

41.8798

18.2937

0.0569

21.7780

1.7577

23.5357

10.3315

1.6171

11.9486

0.0000
5,514.089
1 5,514.089
1 1.7834
5,558.673
3 Mitigated Construction On-Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
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
Vendor

4.6100e-
003

0.1535

0.0595

7.4000e-
004

0.0256

7.7000e-
004

0.0264

7.3800e-
003

7.4000e-
004

8.1200e-
003

80.1130

80.1130

2.6800e-
003

0.0115

83.6124
Worker

0.0576

0.0402

0.6505

1.7800e-
003

0.2012

1.2100e-
003

0.2024

0.0534

1.1100e-
003

0.0545
180.0136
180.0136

4.5400e-
003

4.1500e-
003
181.3650
Total

0.0622

0.1937

0.7100

2.5200e-
003

0.2268

1.9800e-
003

0.2288

0.0607

1.8500e-
003

0.0626
260.1266
260.1266

7.2200e-
003

0.0157
264.9775
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:23 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.4 Grading - 2023
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Fugitive Dust

9.2036

0.0000

9.2036

3.6538

0.0000

3.6538

0.0000

0.0000
Off-Road

3.1206

33.4100

21.9388

0.0563

1.3456

1.3456

1.2379

1.2379
5,454.739
4 5,454.739
4 1.7642
5,498.843
7 Total

3.1206

33.4100

21.9388

0.0563

9.2036

1.3456

10.5491

3.6538

1.2379

4.8917
5,454.739
4 5,454.739
4 1.7642
5,498.843
7 Unmitigated Construction On-Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
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
Vendor

0.0161

0.5374

0.2082

2.6100e-
003

0.0897

2.7000e-
003

0.0924

0.0258

2.5800e-
003

0.0284
280.3955
280.3955

9.4000e-
003

0.0403
292.6436
Worker

0.0640

0.0446

0.7228

1.9800e-
003

0.2236

1.3400e-
003

0.2249

0.0593

1.2400e-
003

0.0605
200.0151
200.0151

5.0400e-
003

4.6200e-
003
201.5167
Total

0.0801

0.5820

0.9310

4.5900e-
003

0.3132

4.0400e-
003

0.3173

0.0851

3.8200e-
003

0.0889
480.4105
480.4105

0.0144

0.0449
494.1602
Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:23 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.4 Grading - 2023
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Fugitive Dust

9.2036

0.0000

9.2036

3.6538

0.0000

3.6538

0.0000

0.0000
Off-Road

3.1206

33.4100

21.9388

0.0563

1.3456

1.3456

1.2379

1.2379

0.0000
5,454.739
4 5,454.739
4 1.7642
5,498.843
7 Total

3.1206

33.4100

21.9388

0.0563

9.2036

1.3456

10.5491

3.6538

1.2379

4.8917

0.0000
5,454.739
4 5,454.739
4 1.7642
5,498.843
7 Mitigated Construction On-Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
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
Vendor

0.0161

0.5374

0.2082

2.6100e-
003

0.0897

2.7000e-
003

0.0924

0.0258

2.5800e-
003

0.0284
280.3955
280.3955

9.4000e-
003

0.0403
292.6436
Worker

0.0640

0.0446

0.7228

1.9800e-
003

0.2236

1.3400e-
003

0.2249

0.0593

1.2400e-
003

0.0605
200.0151
200.0151

5.0400e-
003

4.6200e-
003
201.5167
Total

0.0801

0.5820

0.9310

4.5900e-
003

0.3132

4.0400e-
003

0.3173

0.0851

3.8200e-
003

0.0889
480.4105
480.4105

0.0144

0.0449
494.1602
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:23 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.5 Building Construction - 2023
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Off-Road

3.0930

28.3801

31.2440

0.0530

1.3610

1.3610

1.2815

1.2815
5,026.699
7 5,026.699
7 1.1886
5,056.415
1 Total

3.0930

28.3801

31.2440

0.0530

1.3610

1.3610

1.2815

1.2815
5,026.699
7 5,026.699
7 1.1886
5,056.415
1 Unmitigated Construction On-Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
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
Vendor

0.1485

4.9515

1.9182

0.0240

0.8263

0.0249

0.8512

0.2379

0.0238

0.2617
2,583.643
9 2,583.643
9 0.0866

0.3715
2,696.501
3 Worker

1.0593

0.7385

11.9623

0.0328

3.6998

0.0223

3.7221

0.9812

0.0205

1.0017
3,310.249
5 3,310.249
5 0.0835

0.0764
3,335.101
2 Total

1.2078

5.6899

13.8805

0.0568

4.5261

0.0472

4.5733

1.2191

0.0443

1.2634
5,893.893
4 5,893.893
4 0.1701

0.4478
6,031.602
5 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 2/2/2023 1:23 PM

Cherry Avenue Warehouse (Construction - Unmitigated) - Los Angeles-South Coast County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.5 Building Construction - 2023
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Off-Road