Agenda packet — Rancho Mirage City Council, October 19, 2023 (part 17 of 17)

need to exercise regulatory authority as provided by the Fish and Game Code. As proposed, for example, the Project may be subject to CDFW’s lake and streambed alteration regulatory authority. (Fish & G. Code, § 1600 et seq.) Likewise, to the extent implementation of the Project as proposed may result in “take” as defined by State law of any species protected under the California Endangered Species Act (CESA) (Fish & G. Code, § 2050 et seq.), the project proponent may seek related take authorization as provided by the Fish and Game Code.

PROJECT DESCRIPTION SUMMARY
Proponent: None indicated in the CEQA document

Objective: The Project proposes the development of a site that occupies approximately 257 acres of mostly vacant undeveloped land within the reservation of the Agua Caliente Band of Cahuilla Indians (Tribe) and within the City’s Sphere of Influence. A General Plan/Zoning Map Amendment is proposed to amend the existing pre-zoning designations of the Project site, which consist of Medium Density Residential (R-M), High Density Residential (R-H), and Community Commercial (C-C). The entire Project area is proposed to have an underlying designation of Mixed Use (M-U), and the Section 24 Specific Plan will be adopted to establish seven (7) planning areas within the subject site. The Project site is also proposed to be annexed into the City of Rancho Mirage. The Project site has already been approved by the Tribe for the potential development of up to 3,138,600 square feet of commercial, retail, office, restaurant, hotel, and entertainment uses, as well as up to 1,406 multifamily residential units.

The Tribe prepared and approved the Section 24 Specific Plan (SCH No. 2014011035) to guide the development of 576 acres of Tribal Reservation Land bounded by Ramon Road to the north, Bob Hope Drive to the east, Dinah Shore Drive to the south, and Los Alamos Road to the west. The property the City is proposing to annex and amend the prezoning designation for is only the Tribal Planning Areas (1-7) identified in the Section 24 Specific Plan. Planning Area 8 for the Active Adult Community within the Section 24 Specific Plan was previously annexed into the City.

The Tribe prepared an Environmental Impact Statement (EIS) addressing the potential environmental effects of the Section 24 Specific Plan, and the EIS was approved by the Tribe on May 12, 2015. The EIS was prepared and adopted consistent with the substantive and procedural requirements of the California Environmental Quality Act (CEQA), as well as the Tribal Environmental Policy Act. The City of Rancho Mirage has reviewed the Section 24 EIS and has determined that the EIS meets the requirements of CEQA and was circulated for public review in conformance with Section 15087(a) of the CEQA Guidelines. In accordance with Sections 15221 and 15225 of the CEQA Guidelines, the City of Rancho Mirage intends to use the Section 24 EIS in the place of an Environmental Impact Report (EIR) for the Section 24 Specific Plan Tribal Planning 12-4111

Ben Torres, Planning Manager
City of Rancho Mirage
May 2, 2023

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Areas, and the City’s notice is being given in the same manner as a notice of public availability of a draft EIR under CEQA Guidelines Section 15087.

The Project’s landscape treatment would incorporate a distinct theme. Rock gardens and water features may also be used. The Project would develop a system of pedestrian, Neighborhood Electric Vehicle (NEV), golf cart, and bicycle travel throughout the Project Site and into the surrounding community. Pedestrian circulation would be provided by 5- to 8-foot-wide sidewalks along internal and perimeter roadways. Within the Project site, Class I bikeways and golf cart paths (8 feet wide) are provided along Bob Hope Drive, Ramon Road, Dinah Shore Drive, and Los Alamos Road as off-street pathways that allow bicyclists, golf carts, and pedestrians to travel along the same route. Infrastructure improvements would be installed to support the Project development including water, sanitary sewer, drainage and flood retention systems, and utility improvements.

Location: The Project Area is located at the southwest corner of Ramon Road and Bob Hope Drive (Assessor’s Parcel Numbers: 685-410-005, -006, -007, -012, and -013) on approximately 257 acres in Riverside County. Adjacent jurisdictions surrounding the Project Site include the City of Palm Desert to the southeast, Cathedral City to the west, and the City of Palm Springs to the northwest.

Timeframe: No timeframe has been established for the development of the Tribal Planning Areas (1-7) of the Section 24 Specific Plan, but the Project anticipates buildout by 2035. Page 2.0-2 of the DEIS indicates that “the Planning Areas have also been constructed to recognize the current ownership patterns, thus enabling the Project to be constructed in an incremental fashion while still achieving a unified development.”

COMMENTS AND RECOMMENDATIONS
CDFW has jurisdiction over the conservation, protection, and management of fish, wildlife, native plants, and habitat necessary for biologically sustainable populations of those species (i.e., biological resources). CDFW offers the comments and recommendations below to assist the City of Rancho Mirage in adequately identifying and/or mitigating the Project’s significant, or potentially significant, direct and indirect impacts on fish and wildlife (biological) resources. The DEIS has not adequately identified and disclosed the Project’s impacts (i.e., direct, indirect, and cumulative) on biological resources and whether those impacts are reduced to less than significant.

CDFW’s comments and recommendations on the DEIS are explained in greater detail below and summarized here. CDFW is concerned that the DEIS does not adequately identify or mitigate the Project’s significant, or potentially significant, impacts to biological resources. CDFW also concludes that the DEIS lacks sufficient information to facilitate a meaningful review by CDFW, including both a complete and accurate 12-4112

Ben Torres, Planning Manager
City of Rancho Mirage
May 2, 2023

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assessment of biological resources on the Project site and a possibly outdated Project description. CDFW requests that additional information and analyses be added to a revised DEIS, along with avoidance, minimization, and mitigation measures that avoid or reduce impacts to less than significant.

Project Description

Compliance with CEQA is predicated on a complete and accurate description of the proposed Project, including reasonably foreseeable future phases of the proposed Project. Without a complete and accurate Project description, the DEIS likely provides an incomplete assessment of Project-related impacts to biological resources. CDFW has identified gaps in information related to the Project description.

The DEIS is dated November 2014, and it is unclear if the Project design has changed since this date. If Project design plans for artificial nighttime lighting, landscaping, Project timeframe, or other design aspects have changed that may result in different and/or additional impacts to fish and wildlife resources, CDFW requests that the DEIS is revised to include up-to-date Project description. To conduct a meaningful review and provide biological expertise on how to protect fish and wildlife resources, CDFW requires an accurate Project description.

Existing Environmental Setting

Compliance with CEQA is predicated on a complete and accurate description of the environmental setting that may be affected by the proposed Project. CDFW is concerned that the assessment of the existing environmental setting has not been adequately analyzed in the DEIS. CDFW is concerned that without a complete and accurate description of the existing environmental setting, the DEIS may provide an incomplete analysis of Project-related environmental impacts.

The DEIS lacks a recent and complete assessment of biological resources within the Project site and surrounding area. A complete and accurate assessment of the environmental setting and Project-related impacts to biological resources is needed to both identify appropriate avoidance, minimization, and mitigation measures and demonstrate that these measures reduce Project impacts to less than significant.

Mitigation Measures

CEQA requires that a DEIS include mitigation measures to avoid or reduce significant impacts. CDFW is concerned that the mitigation measures proposed in the DEIS are not adequate to avoid or reduce impacts to biological resources to below a level of significance. To support City of Rancho Mirage in ensuring that Project impacts to biological resources are reduced to less than significant, CDFW recommends adding mitigation measures for an assessment of biological resources, burrowing owl (Athene 12-4113

Ben Torres, Planning Manager
City of Rancho Mirage
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cunicularia), artificial nighttime lighting, and Coachella Valley Multiple Species Habitat Conservation Plan (CVMSHCP) compliance, as well as revising the mitigation measure for nesting birds.

1) Assessment of Biological Resources

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of 2014. Note that CDFW generally considers biological field assessments for wildlife to be valid for a one-year period. Section 15125(c) of the CEQA Guidelines states that knowledge of the regional setting of a project is critical to the assessment of environmental impacts, that special emphasis should be placed on environmental resources that are rare or unique to the region, and that significant environmental impacts of the proposed Project are adequately investigated and discussed. CDFW recommends that the DEIS is revised to include the findings of a complete, recent inventory of rare, threatened, endangered, and other sensitive species located within the Project footprint and within offsite areas with the potential to be affected, including California Species of Special Concern (CSSC) and California Fully Protected Species (Fish and Game Code § 3511). Based on findings from a recent biological inventory, CDFW recommends that the DEIS is revised to include an analysis of direct, indirect, and cumulative impacts to biological resources and identification of appropriate avoidance, minimization, and mitigation measures. Recent and complete information on biological resources; analysis of a Project’s direct, indirect, and cumulative impacts; and appropriate avoidance, minimization, and mitigation measures support the Lead Agency in demonstrating that Project impacts to biological resources are less than significant.

CDFW recommends that the City of Rancho Mirage include in a revised DEIS the following mitigation measure:

Mitigation Measure BIO-[A]: Assessment of Biological Resources Prior to Project construction activities for all phases of the Project, a complete and recent inventory of rare, threatened, endangered, and other sensitive species located within the Project footprint and within offsite areas with the potential to be affected, including California Species of Special Concern (CSSC) and California Fully Protected Species (Fish and Game Code § 3511), will be completed. Species to be addressed should include all those which meet the CEQA definition (CEQA Guidelines § 15380). The inventory should address seasonal variations in use of the Project area and should not be limited to resident species. Focused species-specific surveys, completed by a qualified biologist and conducted at the appropriate time of year and time of day when the sensitive species are active or otherwise identifiable are required. Acceptable species-specific survey procedures should be developed in consultation with CDFW and the U.S. Fish and Wildlife Service, where necessary. Note that CDFW generally considers biological field assessments 12-4114

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City of Rancho Mirage
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for wildlife to be valid for a one-year period, and assessments for rare plants may be considered valid for a period of up to three years. Some aspects of the proposed Project may warrant periodic updated surveys for certain sensitive taxa, particularly if the Project is proposed to occur over a protracted time frame, or in phases, or if surveys are completed during periods of drought. 2) Burrowing Owl
Burrowing owl (Athene cunicularia) is a California Species of Special Concern. Take of individual burrowing owls and their nests is defined by Fish and Game Code section 86, and prohibited by sections 3503, 3503.5, and 3513. Fish and Game Code section 3513 makes it unlawful to take or possess any migratory nongame bird except as provided by rules and regulations adopted by the Secretary of the Interior under provisions of the Migratory Bird Treaty Act of 1918, as amended (16 U.S.C. § 703 et seq.). Take is defined in Fish and Game Code section 86 as “hunt, pursue, catch, capture or kill, or attempt to hunt, pursue, catch, capture or kill.” Burrowing owl is a Covered Species under the CVMSHCP, which requires that avoidance and minimization measures be implemented for this species.

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Site boundaries during six separate days in 2014, one active burrow was found, and the entire Project Site is considered potential habitat for burrowing owl. Page 5.3-4 states that animal surveys were conducted simultaneously with plant surveys using east/west transects at 10-yard intervals.

CDFW generally considers biological field assessments for wildlife to be valid for a one- year period. CDFW recommends the DEIS is revised to include summary reports from recent and focused surveys for burrowing owl, as described in the Staff Report on Burrowing Owl Mitigation (CDFW 20122), which includes survey methods and survey results among other items. Burrowing owl surveys provide information needed to determine the potential effects of proposed projects and activities on burrowing owls, and to avoid take in accordance with Fish and Game Code sections 86, 3503, 3503.5, and 3513. If focused surveys confirm occupied burrowing owl habitat in or adjacent to the Project area, CDFW recommends that the DEIS is revised to include an impact assessment per guidelines in the Staff Report on Burrowing Owl Mitigation. Impact assessments evaluate the extent to which burrowing owls and their habitat may be

2 California Department of Fish and Game (CDFG). 2012. Staff report on burrowing owl mitigation. State of California, Natural Resources Agency. Available for download at:
https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=83843&inline

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City of Rancho Mirage
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impacted, directly or indirectly, on and within a reasonable distance of the proposed Project. Burrowing owl surveys and an impact assessment will also inform appropriate avoidance, minimization, and mitigation measures for the Project and help demonstrate that impacts to burrowing owls are less than significant.

Importantly, because the Project’s timeframe has not yet been established and may be constructed over multiple phases, and there may be a considerable lapse of time between phases when burrowing owls may reoccupy areas with suitable habitat, CDFW recommends that focused and pre-construction burrowing owl surveys are repeated prior to ground disturbance and vegetation removal activities for all phases of Project construction.

Although the DEIS includes Mitigation Measure 5.3-2 for burrowing owl, CDFW considers the measure to be inadequate in scope and timing to reduce impacts to less than significant. CDFW recommends that City of Rancho Mirage revise Mitigation Measure 5.3-2 in a revised DEIS as follows, with additions in bold and removals in strikethrough:

Mitigation Measure 5.3-2: Burrowing Owl Surveys

Suitable burrowing owl habitat has been confirmed on the site; therefore, focused burrowing owl surveys shall be conducted for all Project phases in accordance with the Staff Report on Burrowing Owl Mitigation (2012 or most recent version). If burrowing owls are detected during the focused surveys, the qualified biologist and Project Applicant shall prepare a Burrowing Owl Plan that shall be submitted to CDFW for review and approval prior to commencing Project activities. The Burrowing Owl Plan shall describe proposed avoidance, monitoring, relocation, minimization, and/or mitigation actions. The Burrowing Owl Plan shall include the number and location of occupied burrow sites, acres of burrowing owl habitat that will be impacted, details of site monitoring, and details on proposed buffers and other avoidance measures if avoidance is proposed. If impacts to occupied burrowing owl habitat or burrow cannot be avoided, the Burrowing Owl Plan shall also describe minimization and relocation actions that will be implemented. Proposed implementation of burrow exclusion and closure should only be considered as a last resort, after all other options have been evaluated as exclusion is not in itself an avoidance, minimization, or mitigation method and has the possibility to result in take. If impacts to occupied burrows cannot be avoided, information shall be provided regarding adjacent or nearby suitable habitat available to owls along with proposed relocation actions. The Permittee shall implement the Burrowing Owl Plan following CDFW review and approval.

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City of Rancho Mirage
May 2, 2023

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Preconstruction surveys should be performed by a qualified biologist following the recommendations and guidelines provided in the Staff Report on Burrowing Owl Mitigation. If the preconstruction surveys confirm occupied burrowing owl habitat, Project activities shall be immediately halted. The qualified biologist shall coordinate with CDFW and USFWS to conduct an impact assessment to develop avoidance, minimization, and mitigation measures to be approved by CDFW prior to commencing Project activities. To avoid impacts to burrowing owls during construction, the following actions, which are consistent with the Staff Report on Burrowing Owl Mitigation prepared by the California Department of Fish and Wildlife on March 7, 2012 and approved and accepted by the U.S. Fish and Wildlife Service, shall be taken: A preconstruction survey should take place not more than 30 days prior to any construction activities planned between February 15 and June 15, the breeding season for burrowing owls, project grading to determine the location of any active burrows on and within 550 yards of an approved project site. If no active burrows are found in the survey area, site disturbance may commence providing a biological monitor is onsite. A biological monitor, with the authority to halt or redirect grading, shall be present whenever grading or construction vehicles are present and operating on the project site. The function of the monitor is to protect burrowing owls that arrive on or near the project site after the clearance survey and during the construction period.

3) Nesting Birds
It is the Project proponent’s responsibility to comply with all applicable laws related to nesting birds and birds of prey. Fish and Game Code sections 3503, 3503.5, and 3513 afford protective measures as follows: section 3503 states that it is unlawful to take, possess, or needlessly destroy the nest or eggs of any bird, except as otherwise provided by Fish and Game Code or any regulation made pursuant thereto. Fish and Game Code section 3503.5 makes it unlawful to take, possess, or destroy any birds in the orders Falconiformes or Strigiformes (birds-of-prey) or to take, possess, or destroy the nest or eggs of any such bird except as otherwise provided by Fish and Game Code or any regulation adopted pursuant thereto. Fish and Game Code section 3513 makes it unlawful to take or possess any migratory nongame bird except as provided by rules and regulations adopted by the Secretary of the Interior under provisions of the Migratory Bird Treaty Act of 1918, as amended (16 U.S.C. § 703 et seq.).

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brief list of birds frequently detected during the surveys in 2014 and indicates that loggerhead shrike (Lanius ludovicianus) was observed. Besides information on 12-4117

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City of Rancho Mirage
May 2, 2023

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burrowing owls, the DEIS lacks additional information on nesting birds. Although the DEIS includes Mitigation Measure 5.3-3 specifically for loggerhead shrike, the DEIS does not include additional mitigation measures for other nesting birds.

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bush scrub plant community, including creosote bush (Larrea tridentata), Emory’s dalea (Dalea emoryi), wingscale (Atriplex Canescens), and croton (Croton californicus). Based on review of Google Earth aerial and street imagery, the Project site supports areas with shrubs and trees that can serve as habitat for nesting birds. Appropriate avoidance and minimization measures are needed to demonstrate that impacts to nesting birds are less than significant. CDFW recommends that disturbance of occupied nests of migratory birds and raptors within the Project site and surrounding area be avoided any time birds are nesting on-site.

Further, because the Project’s timeframe has not yet been established and may be constructed over multiple phases, and there may be a considerable lapse of time between phases when and shrubs and trees can reoccupy an area and create nesting habitat, CDFW recommends that nesting bird surveys are completed prior to all ground disturbance and vegetation removal activities for all phases of Project construction.

CDFW recommends the City of Rancho Mirage revise Mitigation Measure 5.3-3 in a revised DEIS to protect all nesting birds (not just loggerhead shrike) and birds of prey as follows, with additions in bold and removals in strikethrough:

Mitigation Measure 5.3-3: Nesting Birds
Regardless of the time of year, nesting bird surveys shall be performed by a qualified avian biologist no more than 3 days prior to vegetation removal or ground-disturbing activities for all phases of the Project. Pre-construction surveys shall focus on both direct and indirect evidence of nesting, including nest locations and nesting behavior. The qualified avian biologist will make every effort to avoid potential nest predation as a result of survey and monitoring efforts. If active nests are found during the pre-construction nesting bird surveys, a qualified biologist shall establish an appropriate nest buffer to be marked on the ground. Nest buffers are species specific and shall be at least 300 feet for passerines and 500 feet for raptors. A smaller or larger buffer may be determined by the qualified biologist familiar with the nesting phenology of the nesting species and based on nest and buffer monitoring results. Established buffers shall remain on-site until a qualified biologist determines the young have fledged or the nest is no longer active. Active nests and adequacy of the established buffer distance shall be monitored daily by the qualified biologist until the qualified biologist has determined the young have fledged or the Project has been completed. The qualified biologist has the authority to stop work if nesting pairs exhibit signs of 12-4118

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City of Rancho Mirage
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disturbance. To avoid impacts to Loggerhead Shrikes during construction, breeding surveys shall be conducted simultaneously with burrowing owls surveys, 30 days prior to any construction activities planned between February 15 and June 15, which is the breeding season for both species. If a shrike nest is found, a buffer shall be established in which construction activities are prohibited until all young have fledged. The width of the buffer shall be determined by a qualified biologist.

4) Coachella Valley Multiple Species Habitat Conservation Plan

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Covered Species under the CVMSHCP, including Coachella Valley fringe-toed lizard (Uma inornata), flat-tailed horned lizard (Phrynosoma mcallii), burrowing owl (Athene cunicularia), Coachella Valley round-tailed ground squirrel (Xerospermophilus tereticaudus chlorus), and seedpods of Coachella Valley milkvetch (Astragalus lentiginosus var. coachellae). Page 5.3-8 indicates that Coachella giant sand treader cricket (Macrobaenetes valgum), Coachella Valley Jerusalem cricket (Stenopelmatus cahuilaensis), and Palms Springs pocket mouse (Perognathus longimembris bangsi) may also occur within the Project site but were not detected during the surveys. Page

5.3-8 further states “Under the THCP [Agua Caliente Tribal Habitat Conservation Plan] adverse impacts to these three species can be mitigated by the project proponent paying the Tribe the required mitigation fee.”
Because a portion of the Section 24 Specific Plan is proposed as part of the Project to be annexed to the City or Rancho Mirage, a Local Permittee under the CVMSHCP, CDFW recommends that the DEIS is revised to include a discussion of the Project’s compliance with the CVMSHCP. Compliance may include the obligation of the City of Rancho Mirage to impose a local development mitigation fee for this Project and comply with other terms and conditions of the CVMSHCP such as encouraging the opportunity to salvage sand-dependent Covered Species (Section 6.6.1 of the CVMSHCP), an obligation for Local Permittees both inside and outside Conservation Areas. CDFW recommends that the City of Rancho Mirage consult with the Coachella Valley Conservation Commission (the Implementing Entity of the CVMSHCP) on the City’s obligations under the CVMSHCP for this Project. CDFW provides the following recommendations below regarding the City of Rancho Mirage’s compliance with the CVMSHCP regarding local development mitigation fees and salvage of sand-dependent Covered Species.

Local Development Mitigation Fees
The DEIS lacks a discussion of the City of Rancho Mirage’s obligations as a Local Permittee under the CVMSHCP to impose a local development mitigation fee for this Project. Section 5.2.1.1 of the CVMSHCP states that “local jurisdictions will impose a mitigation fee on new Development within the Plan Area that impacts vacant land containing Habitat for Covered Species or any of the conserved natural communities in 12-4119

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City of Rancho Mirage
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the Plan through adoption, or amendment of existing fee ordinance. In addition to large vacant areas, this also applies to small vacant lots within urban areas that still contain natural open space.” Section 6.6.1 of the CVMSHCP further discusses the obligation of Local Permittees to impose local development mitigation fees, including “collecting all revenues generated within their respective jurisdictional boundaries for the Plan implementation and transferring those revenues to CVCC within thirty (30) days of collection.” Because the Project site contains habitat for Coachella Valley fringe-toed lizard, flat-tailed horned lizard, Coachella Valley milk vetch, and burrowing owl, which are Covered Species under the CVMSHCP, the Project is subject to the CVMSHCP Local Development Mitigation Fee.

To document the City of Rancho Mirage’s obligation as a Local Permittee under the CVMSHCP to impose a local development mitigation fee for this Project, CDFW recommends the City of Rancho Mirage add the following mitigation measure to a revised DEIS:

Mitigation Measure BIO-[B]: CVMSHCP Compliance
Prior to construction and issuance of any grading permit, the City of Rancho Mirage shall ensure compliance with the Coachella Valley Multiple Species Habitat Conservation Plan (CVMSHCP) and its associated Implementing Agreement and shall ensure the collection of payment of the CVMSHCP Local Development Mitigation Fee and transfer of revenues to the Coachella Valley Conservation Commission.

Salvage of Sand-Dependent Covered Species
With regard to obligations of Local Permittees, Section 6.6.1 of the CVMSHCP indicates that “within and outside conservation areas, on parcels approved for development, the Permittees shall encourage the opportunity to salvage Covered sand-dependent species”. Biological surveys in 2014 detected within the Project site several Covered Species under the CVMSHCP that are sand-dependent, including Coachella Valley fringe-toed lizard, flat-tailed horned lizard, Coachella Valley round-tailed ground squirrel, and Coachella Valley milkvetch. Additional sand-dependent Covered Species may be identified in a subsequent assessment of biological resources recommended by CDFW (see “Assessment of Biological Resources” section above). CDFW recommends the City of Rancho Mirage include in a revised DEIS a plan for salvaging sand-dependent Covered Species. CDFW recommends the following mitigation measure be added to a revised DEIS:

Mitigation Measure BIO-[C]: Salvage of Sand-Dependent Covered Species Prior to construction and issuance of any grading permit, the City of Rancho Mirage shall prepare and submit to the California Department of Fish and 12-4120

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Wildlife and the U.S. Fish and Wildlife Service, for review and approval, a plan to salvage sand-dependent CVMSHCP Covered Species within the Project area. The plan shall be prepared by a qualified biologist experienced in surveying for and handling sand-dependent Covered Species. The plan shall include, but not be limited to, the species-specific salvage methods and timing for each sand-dependent Covered Species identified within the Project site and the location(s) where each species will be translocated. Only qualified biologist(s) with appropriate state and federal permits to handle special-status species shall carry out salvage activities.
5) Artificial Nighttime Lighting
Pages 3.0-30 and 3.0-31 of the DEIS indicate that the Project will incorporate public street lighting, private street lighting, and landscape lighting, including signage lighting, accent-up lighting, and washing of walls to illuminate vines or espaliers. Page 5.1-10 of the DEIS states that all lighting would be hooded and directed downward to minimize light and direct glare impacts on neighboring properties and reduce impacts on dark skies. The DEIS appears to have conflicting information with regard to lighting and avoidance and minimization measures, as accent up-lighting and washing of walls to illuminate vines or espaliers are not directed downward and may not be hooded.

Additionally, the DEIS is dated November 2014 and it is unclear if lighting plans have changed. CDFW recommends the DEIS is revised to include an accurate description of current lighting plans (including design specifications) and avoidance and minimization measures to support CDFW in conducting a meaningful review and providing appropriate biological expertise on the protection of fish and wildlife resources.

The DEIS also lacks an analysis of the direct, indirect, and cumulative impacts of artificial nighttime lighting expected to adversely affect biological resources surrounding the Project site as a result of construction and long-term operation of the Project.

Because the Project is located near open-space areas to the north and east containing partially stabilized sand dunes that receive aeolian (wind-transported) sand and likely support sand-dependent Covered Species under the CVMSHCP, in addition to migratory birds that fly at night, bats, and other nocturnal and crepuscular wildlife, CDFW recommends that additional avoidance and minimization measures for lighting are implemented to reduce impacts to less than significant. Available research indicates that artificial nighttime lighting alters ecological processes including, but not limited to, the temporal niches of species; the repair and recovery of physiological function; the measurement of time through interference with the detection of circadian and lunar and 12-4121

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City of Rancho Mirage
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seasonal cycles; the detection of resources and natural predators; and navigation3.

Further, many of the effects of artificial nighttime lighting on population- or ecosystem- level processes are still poorly understood suggesting that a precautionary approach should be taken when determining appropriate avoidance and minimization measures concerning artificial nighttime lighting.

To reduce impacts of artificial nighttime lighting to less than significant, CDFW recommends that the City of Rancho Mirage include in a revised DEIS the following mitigation measure:

Mitigation Measure BIO-[D]: Artificial Nighttime Lighting

During Project construction and operations over the lifetime of the Project, the City of Rancho Mirage shall eliminate all nonessential lighting throughout the Project area and avoid or limit the use of artificial light during the hours of dawn and dusk when many wildlife species are most active. The City shall ensure that all lighting for Project is fully shielded, cast downward, reduced in intensity to the greatest extent, and does not result in lighting trespass including glare onto other properties or upward into the night sky (see the International Dark-Sky Association standards at http://darksky.org/). The City shall ensure use of LED lighting with a correlated color temperature of 3,000 Kelvins or less, proper disposal of hazardous waste, and recycling of lighting that contains toxic compounds with a qualified recycler.

6) Landscaping

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friendly plants that includes ornamental varieties of trees, shrubs, groundcovers, and vines. Page 3.0-14 of the DEIS indicates that rock gardens and water features may also be used in key landscaping areas. To ameliorate the water demands of this Project, CDFW recommends incorporation of water-wise concepts in any Project landscape design plans. In particular, CDFW recommends xeriscaping with locally native California species and installing water-efficient and targeted irrigation systems (such as drip irrigation). Native plants support butterflies, birds, reptiles, amphibians, small mammals, bees, and other pollinators that evolved with those plants, more information on native plants suitable for the Project location and nearby nurseries is available at CALSCAPE:
https://calscape.org/. Local water agencies/districts and resource conservation districts in your area may be able to provide information on plant nurseries that carry locally

3 Gatson, K. J., Bennie, J., Davies, T., Hopkins, J. The ecological impacts of nighttime light pollution: a mechanistic appraisal. Biological Reviews, 88.4 (2013): 912-927. 12-4122

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City of Rancho Mirage
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native species, and some facilities display drought-tolerant locally native species demonstration gardens. Information on drought-tolerant landscaping and water-efficient irrigation systems is available on California’s Save our Water website:
https://saveourwater.com/. CDFW also recommends that the DEIS include recommendations regarding landscaping from Section 4.0 of the CVMSHCP “Table 4- 112: Coachella Valley Native Plants Recommended for Landscaping” (pp. 4-180 to 4- 182; https://cvmshcp.org/plan-documents/).

ENVIRONMENTAL DATA
CEQA requires that information developed in environmental impact reports and negative declarations be incorporated into a database which may be used to make subsequent or supplemental environmental determinations. (Pub. Resources Code, § 21003, subd. (e).) Accordingly, please report any special status species and natural communities detected during Project surveys to the California Natural Diversity Database (CNDDB). The CNNDB field survey form can be filled out and submitted online at the following link: https://wildlife.ca.gov/Data/CNDDB/Submitting-Data. The types of information reported to CNDDB can be found at the following link:
https://www.wildlife.ca.gov/Data/CNDDB/Plants-and-Animals.

ENVIRONMENTAL DOCUMENT FILING FEES
The Project, as proposed, would have an impact on fish and/or wildlife, and assessment of environmental document filing fees is necessary. Fees are payable upon filing of the Notice of Determination by the Lead Agency and serve to help defray the cost of environmental review by CDFW. Payment of the environmental document filing fee is required in order for the underlying project approval to be operative, vested, and final. (Cal. Code Regs, tit. 14, § 753.5; Fish & G. Code, § 711.4; Pub. Resources Code, § 21089.)

CONCLUSIONS
CDFW appreciates the opportunity to comment on the DEIS to assist the City of Rancho Mirage in identifying and mitigating Project impacts to biological resources. CDFW concludes that the DEIS does not adequately identify or mitigate the Project’s significant, or potentially significant, impacts to biological resources. CDFW also concludes that the DEIS lacks sufficient information for a meaningful review of impacts to biological resources, including an adequate Project description and complete and accurate assessment of biological resources on the Project site. The CEQA Guidelines (§ 15088.5) indicate that recirculation is required when insufficient information in the DEIS precludes meaningful review. CDFW recommends that a revised DEIS with a current Project description, a recent and complete assessment of impacts to biological resources, and mitigation to avoid and reduce those impacts to less than significant be recirculated for public comment.
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City of Rancho Mirage
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CDFW personnel are available for consultation regarding biological resources and strategies to minimize impacts. Questions regarding this letter or further coordination should be directed to Jacob Skaggs, Environmental Scientist, at [email protected].

Sincerely,

Kim Freeburn
Environmental Program Manager

Attachment 1: MMRP for CDFW-Proposed Mitigation Measures

ec:

Heather Brashear, Senior Environmental Scientist (Supervisor), CDFW [email protected]

Office of Planning and Research, State Clearinghouse, Sacramento [email protected]

Rollie White, U.S. Fish and Wildlife Service
[email protected]

Vincent James, U.S. Fish and Wildlife Service
[email protected]

Peter Satin, Coachella Valley Conservation Commission
[email protected]

ATTACHMENT 1: MITIGATION MONITORING AND REPORTING PROGRAM (MMRP) Mitigation Measures Timing and
Methods
Responsible
Parties
12-4124

Ben Torres, Planning Manager
City of Rancho Mirage
May 2, 2023

Page 16 ends

Mitigation Measure BIO-[A]: Assessment of
Biological Resources
Prior to Project construction activities for all
phases of the Project, a complete and recent
inventory of rare, threatened, endangered, and
other sensitive species located within the Project
footprint and within offsite areas with the
potential to be affected, including California
Species of Special Concern (CSSC) and California
Fully Protected Species (Fish and Game Code §
3511), will be completed. Species to be addressed
should include all those which meet the CEQA
definition (CEQA Guidelines § 15380). The
inventory should address seasonal variations in
use of the Project area and should not be limited
to resident species. Focused species-specific
surveys, completed by a qualified biologist and
conducted at the appropriate time of year and
time of day when the sensitive species are active
or otherwise identifiable are required. Acceptable
species-specific survey procedures should be
developed in consultation with CDFW and the
U.S. Fish and Wildlife Service, where necessary.

Note that CDFW generally considers biological
field assessments for wildlife to be valid for a
one-year period, and assessments for rare plants
may be considered valid for a period of up to
three years. Some aspects of the proposed
Project may warrant periodic updated surveys for
certain sensitive taxa, particularly if the Project is
proposed to occur over a protracted time frame,
or in phases, or if surveys are completed during
periods of drought.

Timing: Prior to
Project
construction
activities for all
phases of the
Project
Methods: See
Mitigation
Measure

Implementation:

City of Rancho
Mirage
Monitoring and
Reporting: City of
Rancho Mirage

Mitigation Measure 5.3-2: Burrowing Owl Surveys

Implementation:

Project Applicant

Monitoring and
Reporting: City of
Rancho Mirage
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Ben Torres, Planning Manager
City of Rancho Mirage
May 2, 2023

Page 17 ends

minimization, and/or mitigation actions. The
Burrowing Owl Plan shall include the number
and location of occupied burrow sites, acres of
burrowing owl habitat that will be impacted,
details of site monitoring, and details on
proposed buffers and other avoidance
measures if avoidance is proposed. If impacts
to occupied burrowing owl habitat or burrow
cannot be avoided, the Burrowing Owl Plan
shall also describe minimization and relocation
actions that will be implemented. Proposed
implementation of burrow exclusion and
closure should only be considered as a last
resort, after all other options have been
evaluated as exclusion is not in itself an
avoidance, minimization, or mitigation method
and has the possibility to result in take. If
impacts to occupied burrows cannot be
avoided, information shall be provided
regarding adjacent or nearby suitable habitat
available to owls along with proposed
relocation actions. The Permittee shall
implement the Burrowing Owl Plan following
CDFW review and approval.

Preconstruction burrowing owl surveys shall be
conducted no less than 14 days prior to the
start of Project-related activities for all Project
phases and within 24 hours prior to ground
disturbance, in accordance with the Staff
Report on Burrowing Owl Mitigation (2012 or
most recent version). Preconstruction surveys
should be performed by a qualified biologist
following the recommendations and guidelines
provided in the Staff Report on Burrowing Owl
Mitigation. If the preconstruction surveys
confirm occupied burrowing owl habitat,
Project activities shall be immediately halted.

The qualified biologist shall coordinate with
CDFW and USFWS to conduct an impact
assessment to develop avoidance,
minimization, and mitigation measures to be
approved by CDFW prior to commencing
Project activities. To avoid impacts to burrowing
owls during construction, the following actions,
which are consistent with the Staff Report on
Burrowing Owl Mitigation prepared by the California
Department of Fish and Wildlife on March 7, 2012
and approved and accepted by the U.S. Fish and
Wildlife Service, shall be taken: A preconstruction
survey should take place not more than 30 days
prior to any construction activities planned between
preconstruction
surveys.

Methods: See
Mitigation
Measure
12-4126

Ben Torres, Planning Manager
City of Rancho Mirage
May 2, 2023

Page 18 ends

February 15 and June 15, the breeding season for
burrowing owls, project grading to determine the
location of any active burrows on and within 550
yards of an approved project site. If no active
burrows are found in the survey area, site
disturbance may commence providing a biological
monitor is onsite. A biological monitor, with the
authority to halt or redirect grading, shall be present whenever grading or construction vehicles are
present and operating on the project site. The
function of the monitor is to protect burrowing owls
that arrive on or near the project site after the
clearance survey and during the construction
period.

Mitigation Measure 5.3-3: Nesting Birds
Regardless of the time of year, nesting bird
surveys shall be performed by a qualified avian
biologist no more than 3 days prior to vegetation
removal or ground-disturbing activities for all
phases of the Project. Pre-construction surveys
shall focus on both direct and indirect evidence
of nesting, including nest locations and nesting
behavior. The qualified avian biologist will make
every effort to avoid potential nest predation as
a result of survey and monitoring efforts. If
active nests are found during the pre-
construction nesting bird surveys, a qualified
biologist shall establish an appropriate nest
buffer to be marked on the ground. Nest buffers
are species specific and shall be at least 300 feet
for passerines and 500 feet for raptors. A smaller
or larger buffer may be determined by the
qualified biologist familiar with the nesting
phenology of the nesting species and based on
nest and buffer monitoring results. Established
buffers shall remain on-site until a qualified
biologist determines the young have fledged or
the nest is no longer active. Active nests and
adequacy of the established buffer distance
shall be monitored daily by the qualified
biologist until the qualified biologist has
determined the young have fledged or the
Project has been completed. The qualified
biologist has the authority to stop work if
nesting pairs exhibit signs of disturbance. To
avoid impacts to Loggerhead Shrikes during
construction, breeding surveys shall be conducted
simultaneously with burrowing owls surveys, 30
days prior to any construction activities planned
between February 15 and June 15, which is the
Timing: No more
than 3 days prior
to vegetation
removal or
ground-disturbing
activities for all
phases of the
Project
Methods: See
Mitigation
Measure

Implementation:

Project Applicant

Monitoring and
Reporting: City of
Rancho Mirage
12-4127

Ben Torres, Planning Manager
City of Rancho Mirage
May 2, 2023

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breeding season for both species. If a shrike nest is
found, a buffer shall be established in which
construction activities are prohibited until all young
have fledged. The width of the buffer shall be
determined by a qualified biologist.

Mitigation Measure BIO-[B]: CVMSHCP Compliance
Prior to construction and issuance of any grading
permit, the City of Rancho Mirage shall ensure
compliance with the Coachella Valley Multiple
Species Habitat Conservation Plan (CVMSHCP)
and its associated Implementing Agreement and
shall ensure the collection of payment of the
CVMSHCP Local Development Mitigation Fee and
transfer of revenues to the Coachella Valley
Conservation Commission.

Timing: Prior to
construction and
issuance of any
grading permit
Methods: See
Mitigation
Measure

Implementation:

City of Rancho
Mirage
Monitoring and
Reporting: City of
Rancho Mirage
Mitigation Measure BIO-[C]: Salvage of Sand-
Dependent Covered Species
Prior to construction and issuance of any grading
permit, the City of Rancho Mirage shall prepare
and submit to the California Department of Fish
and Wildlife and the U.S. Fish and Wildlife
Service, for review and approval, a plan to
salvage sand-dependent CVMSHCP Covered
Species within the Project area. The plan shall be
prepared by a qualified biologist experienced in
surveying for and handling sand-dependent
Covered Species. The plan shall include, but not
be limited to, the species-specific salvage
methods and timing for each sand-dependent
Covered Species identified within the Project site
and the location(s) where each species will be
translocated. Only qualified biologist(s) with
appropriate state and federal permits to handle
special-status species shall carry out salvage
activities.

Timing: Prior to
construction and
issuance of any
grading permit
Methods: See
Mitigation
Measure

Implementation:

City of Rancho
Mirage

Monitoring and
Reporting: City of
Rancho Mirage

Mitigation Measure BIO-[D]: Artificial Nighttime
Lighting

Timing: During
Project
construction and
operations over
the lifetime of the
Project

Implementation:

Project Applicant and
City of Rancho
Mirage

Monitoring and
Reporting: City of
Rancho Mirage
12-4128

Ben Torres, Planning Manager
City of Rancho Mirage
May 2, 2023

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The City shall ensure that all lighting for Project
is fully shielded, cast downward, reduced in
intensity to the greatest extent, and does not
result in lighting trespass including glare onto
other properties or upward into the night sky (see
the International Dark-Sky Association standards
at http://darksky.org/). The City shall ensure use
of LED lighting with a correlated color
temperature of 3,000 Kelvins or less, proper
disposal of hazardous waste, and recycling of
lighting that contains toxic compounds with a
qualified recycler.

Methods: See
Mitigation
Measure

12-4129
Public Comments
ATTACHMENT 14
12-4130
12-4131
12-4132
12-4133
12-4134
12-4135
12-4136
12-4137
12-4138
P: (626) 381-9248
F: (626) 389-5414
E: [email protected]
Mitchell M. Tsai
Attorney At Law
139 South Hudson Avenue
Suite 200
Pasadena, California 91101

VIA EMAIL
September 27, 2023
Ben Torres, Planning Manager
69-825 Highway 111
Rancho Mirage, CA 92270
Tel: 760-328-2266 ext. 253
Em: [email protected]
Agua Caliente Band of Cahuilla Indians
Margaret Park, AICP
5401 Dinah Shore Drive
Palm Springs, CA 92264
Tel: (760) 699-6800
Em: [email protected]
Riverside County Local Agency Formation Commission
6216 Brockton Avenue, Suite 111-B
Riverside, CA 92506
Tel: (951) 369-0631
Em: [email protected]
RE: Southwest Mountain States Regional Council of Carpenters’ Comments Regarding the Section 24 Annexation Project.

Dear Mr. Torres, Ms. Park, and Riverside County Local Agency Formation Commission:

On behalf of the Southwest Mountain States Regional Council of Carpenters (SWMSRCC), my office is submitting these comments ahead of the City of Rancho Mirage’s September 28, 2023, Planning Commission meeting and in regard to the Section 24 Annexation Project (Annexation Case No. ANN22-0001, Environmental Assessment Case No. EA22-0019, General Plan Zoning Map Amendment Case No. 12-4139
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GPZMA22-0003, SCH No. 2014011035, Specific Plan Case No. SP23-0001) (“Project”).

The Project involves the annexation of approximately 257 acres of land (APNs: 685- 410-005, -006, -007, -012, -013) (“Site”)—the remainder of the Section 24 Specific Plan area—owned by the Agua Caliente Band of Cahuilla Indians (“Tribe” or “Lead Agency”) and within the sphere of influence of the City of Rancho Mirage (“City”).

A larger portion of Section 24 Specific Plan area was previously annexed to the City for the development of the Del Webb Rancho Mirage 55+ Retirement Community located at 122 Claret, Rancho Mirage, CA 92270 (“Retirement Community”).

Though no further development is currently proposed, it is our understanding that the Retirement Community will eventually be expanded to include additional residences to be built by Del Webb through Pulte Homes (“Developer”).

According to the Notice of Intent (NOI), the Site is one portion of several that were previously approved by the Tribe for the development of up to 3,138,600 square feet of commercial, retail, office, restaurant, hotel, and entertainment uses; and up to 2,406 residential units on approximately 577 acres of Tribal Reservation Land (“Original Project”). According to the FEIS, the Section 24 Specific Plan was designed to accommodate these uses through the creation of seven land use categories and eight Planning Areas. Each Planning Area is subject to a finite number of allowed uses and specific development standards established among the seven different land use categories. Planning Areas 1 to 7 (“Tribal Planning Areas”) and Planning Area 8 (“Active Adult Community”) are proposed within Section 24.

The Agua Caliente Tribal Environmental Policy Act (TEPA) (Tribal Ordinance No. 28), adopted to “ensure the protection of natural resources and the environment within the Agua Caliente Indian Reservation[,]” (FEIS, p. 1.0-1) mandates that an Environmental Impact Statement (EIS) be prepared when it is determined through preliminary review that a proposed project may result in significant impacts to the quality of the natural environment—hence, the production of the FEIS here.

As a sovereign exercising land use jurisdiction over the lands of its federal Indian Reservation, the Tribe is not required to comply with CEQA or any of the similar regulatory enactments of state or local agencies, though the Tribe claims that it chose to prepare the EIS as if CEQA did directly apply given that the EIS may be used by other agencies such as the City, Riverside Local Agency Formation Commission (LAFCO), or the Coachella Valley Water District (CVWD). 12-4140
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The City now intends on using the EIS in place of an Environmental Impact Report (EIR) for the (impending and/or eventual) annexation and pre-zoning designation amendment(s) of Section 24 Specific Plan Tribal Areas 1 through 7.

SWMSRCC is a labor union representing over 90,000 union carpenters in 12 states, including California, and has a strong interest in well-ordered land use planning and in addressing the environmental impacts of development projects. Individual members of SWMSRCC live, work, and recreate in the City and the surrounding communities and would be directly affected by the Project’s environmental and social impacts.

SWMSRCC expressly reserves the right to supplement these comments at or prior to hearings on the Project, and at any later hearing and proceeding related to this Project.

Gov. Code, § 65009, subd. (b); Pub. Res. Code, § 21177, subd. (a); see Bakersfield Citizens for Local Control v. Bakersfield (2004) 124 Cal.App.4th 1184, 1199-1203; see also Galante Vineyards v. Monterey Water Dist. (1997) 60 Cal.App.4th 1109, 1121.

SWMSRCC incorporates by reference all comments raising issues regarding the Project and its environmental review and associated documents and reports. See California Clean Energy Committee v. City of Woodland (2014) 225 Cal.App.4th 173, 191 (citing Citizens for Open Government v. City of Lodi (2006) 144 Cal.App.4th 865, 875) (finding that any party who has objected to a project’s environmental documentation may assert any issue timely raised by other parties); see also Santa Teresa Citizen Action Group v. City of San Jose (2003) 114 Cal.App.4th 689, 701 (citing Pub. Res. Code, § 21177, subds. (a)-(b)) (to attack a decision that is subject to CEQA, the alleged grounds for noncompliance must have been presented to the public agency, and the person attacking the decision must have raised some objection during the administrative proceedings).

Moreover, SWMSRCC requests that the City provide notice for any and all notices referring or related to the Project issued under CEQA (Pub. Res. Code, § 21000 et seq.), and the California Planning and Zoning Law (“Planning and Zoning Law”) (Gov. Code, §§ 65000–65010). California Public Resources Code, sections 21092.2 and 21167, subsection (f) and California Government Code, section 65092 require agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency’s governing body.
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I. THE CITY SHOULD REQUIRE THE USE OF A LOCAL SKILLED
AND TRAINED WORKFORCE TO BENEFIT THE CITY’S
ECONOMIC DEVELOPMENT AND THE ENVIRONMENT.

The City should require that the Project be built using local workers who have graduated from a Joint Labor-Management Apprenticeship Program approved by the State of California, have at least as many hours of on-the-job experience in the applicable craft which would be required to graduate from such a program, or are registered apprentices in such a program.

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

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

Workforce requirements promote the development of skilled trades that yield sustainable economic development. As the California Workforce Development Board and the University of California, Berkeley Center for Labor Research and Education concluded:
[L]abor should be considered an investment rather than a cost —and investments in growing, diversifying, and upskilling California’s workforce can positively affect returns on climate mitigation efforts. In other words, well-trained workers are key to deliv ering emissions reductions and moving California closer to its climate targets.1
1 California Workforce Development Board (2020) Putting California on the High Road: A Jobs and Climate Action Plan for 2030 at p. ii, available at 12-4142
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Furthermore, workforce policies have significant environmental benefits given that they improve an area’s jobs-housing balance, decreasing the amount and length of job commutes and the associated GHG emissions. In fact, on May 7, 2021, the South Coast Air Quality Management District (“South Coast AQMD”) found that the “[u]se of a local state-certified apprenticeship program” can result in air pollutant reductions.2
Locating jobs closer to residential areas can have significant environmental benefits.

As the California Planning Roundtable noted in 2008:

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

In nearly built -out Berkeley, CA, the approach to balancing jobs and housing is to create local jobs rather than to develop new housing. The https://laborcenter.berkeley.edu/wp-content/uploads/2020/09/ Putting-California-on- the- High-Road.pdf.
2 South Coast Air Quality Management District (May 7, 2021) Certify Final Environmental Assessment and Adopt Proposed Rule 2305 – Warehouse Indirect Source Rule – Warehouse Actions and Investments to Reduce Emissions Program, and Proposed Rule 316 – Fees for Rule 2305, Submit Rule 2305 for Inclusion Into the SIP, and Approve Supporting Budget Actions, available at http://www.aqmd.gov/docs/default- source/Agendas/Governing-Board/2021/2021-May7-027.pdf?sfvrsn=10. 3 California Planning Roundtable (2008) Deconstructing Jobs-Housing Balance at p. 6, available at https://cproundtable.org/static/media/uploads/publications/cpr-jobs- housing.pdf.
4 Cervero, Robert and Duncan, Michael (2006) Which Reduces Vehicle Travel More: Jobs- Housing Balance or Retail-Housing Mixing? Journal of the American Planning Association 72 (4), 475-490, 482, available at http://reconnectingamerica.org/assets/Uploads/UTCT- 825.pdf.
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city’s First Source program encourages businesses to hire local residents, especially for entry- and intermediate-level jobs, and sponsors vocational training to ensure residents are employment -ready. While the program is voluntary, some 300 businesses hav e used it to date, placing more than 3,000 city residents in local jobs since it was launched in 1986. When needed, these carrots are matched by sticks, since the city is not shy about negotiating corporate participation in First Source as a condition of approval for development permits.

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

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

II. THE CALIFORNIA ENVIRONMENTAL QUALITY ACT.

A. Background Concerning Environmental Impacts Reports.

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

CEQA directs public agencies to avoid or reduce environmental damage, when possible, by requiring alternatives or mitigation measures. CEQA Guidelines, § 15002, subds. (a)(2)-(3); see also Berkeley Keep Jets Over the Bay Committee v. Board of Port Commissioners of the City of Oakland (2001) 91 Cal.App.4th 1344, 1354 (hereafter,

5 The CEQA Guidelines, codified in Title 14 of the California Code of Regulations, section 15000 et seq., are regulatory guidelines promulgated by the state Natural Resources Agency for the implementation of CEQA. Pub. Res. Code, § 21083. The CEQA Guidelines are given “great weight in interpreting CEQA except when . . . clearly unauthorized or erroneous.” Center for Biological Diversity v. Dept. of Fish & Wildlife (2015) 62 Cal.4th 204, 217. 12-4144
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“Berkely Keep Jets”); Laurel Heights Improvement Assn. v. Regents of University of California (1988) 47 Cal.3d 376, 400. The Environmental Impact Report (EIR) serves to provide public agencies and the public in general with information about the effect that a proposed project is likely to have on the environment and to “identify ways that environmental damage can be avoided or significantly reduced.” CEQA Guidelines, § 15002, subd. (a)(2). If the project has a significant effect on the environment, the agency may approve the project only upon finding that it has “eliminated or substantially lessened all significant effects on the environment where feasible” and that any unavoidable significant effects on the environment are “acceptable due to overriding concerns” specified in California Public Resources Code, Section 21081.

See CEQA Guidelines, §§ 15092, subds. (b)(2)(A)-(B).

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

The preparation and circulation of an EIR is more than a set of technical hurdles for agencies and developers to overcome. Communities for a Better Environment v. Richmond (2010) 184 Cal.App.4th 70, 80 (quoting Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho Cordova (2007) 40 Cal.4th 412, 449-450). The EIR’s function is to ensure that government officials who decide to build or approve a project do so with a full understanding of the environmental consequences and, equally important, that the public is assured those consequences have been considered. Id. For the EIR to serve these goals it must present information so that the foreseeable impacts of pursuing the project can be understood and weighed, and the public must be given an 12-4145
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adequate opportunity to comment on that presentation before the decision to go forward is made. Id.

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

This presumption is reflected in what is known as the “fair argument” standard under which an EIR must be prepared whenever substantial evidence in the record supports a fair argument that a project may have a significant effect on the environment. Quail Botanical Gardens Found., Inc. v. City of Encinitas (1994) 29 Cal.App.4th 1597, 1602; Friends of “B” St. v. City of Hayward (1980) 106 Cal.3d 988, 1002.

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

Code, §§ 21100, subd. (a), 21151; CEQA Guidelines, §§ 15064, subds. (a)(1), (f)(1). An EIR may be dispensed with only if the lead agency finds no substantial evidence in the initial study or elsewhere in the record that the project may have a significant effect on the environment. Parker Shattuck Neighbors v. Berkeley City Council (2013) 222 Cal.App.4th 768, 785. In such a situation, the lead agency must adopt a negative declaration. Pub. Res. Code, § 21080, subd. (c)(1); CEQA Guidelines, §§ 15063, subd. (b)(2), 15064, subd. (f)(3).
“Significant effect upon the environment” is defined as “a substantial or potentially substantial adverse change in the environment.” Pub. Res. Code, § 21068; CEQA Guidelines, § 15382. A project may have a significant effect on the environment if there is a reasonable probability that it will result in a significant impact. No Oil, supra, 13 Cal.App.3d at p. 83 fn. 16; see Sundstrom v. County of Mendocino (1988) 202 Cal.App.3d 296, 309 (hereafter, “Sundstrom”). If any aspect of the project may result in a significant impact on the environment, an EIR must be prepared even if the overall effect of the project is beneficial. CEQA Guidelines, § 15063, subd. (b)(1); see County Sanitation Dist. No. 2 v. County of Kern (2005) 127 Cal.App.4th 1544, 1580.

This standard sets a “low threshold” for preparation of an EIR. Consolidated Irrigation Dist. v. City of Selma (2012) 204 Cal.App.4th 187, 207; Nelson v. County of Kern (2010) 190 Cal.App.4th 252; Pocket Protectors v. City of Sacramento (2004) 124 Cal.App.4th 903, 928; Bowman v. City of Berkeley (2004) 122 Cal.App.4th 572, 580; Citizen Action to Serve 12-4146
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All Students v. Thornley (1990) 222 Cal.App.3d 748, 754; Sundstrom, supra, 202 Cal.App.3d at p. 310. If substantial evidence in the record supports a fair argument that the project may have a significant environmental effect, the lead agency must prepare an EIR even if other substantial evidence before it indicates the project will have no significant effect. See Jensen, supra, 23 Cal.App.5th at p. 886; Clews Land & Livestock v. City of San Diego (2017) 19 Cal.App.5th 161, 183; Stanislaus Audubon Society, Inc. v. County of Stanislaus (1995) 33 Cal.App.4th 144, 150; Brentwood Assn. for No Drilling, Inc. v. City of Los Angeles (1982) 134 Cal.App.3d 491; Friends of “B” St., 106 Cal.App.3d 988; CEQA Guidelines, § 15064, subd. (f)(1).

B. Background Concerning Initial Studies, Negative Declarations, and Mitigated Negative Declarations.

CEQA and CEQA Guidelines are strict and unambiguous about when an MND may be used. A public agency must prepare an EIR whenever substantial evidence supports a “fair argument” that a proposed project “may have a significant effect on the environment.” Pub. Res. Code, §§ 21100, 21151; CEQA Guidelines, §§ 15002, subds. (f)(1)-(2), 15063; No Oil, supra, 13 Cal.App.3d at p. 75; Communities for a Better Environment v. California Resources Agency (2002) 103 Cal.App.4th 98, 111-112.

Essentially, should a lead agency be presented with a fair argument that a project may have a significant effect on the environment, the lead agency shall prepare an EIR even though it may also be presented with other substantial evidence that the project will not have a significant effect. CEQA Guidelines, §§ 15064(f)(1)-(2); see No Oil, supra, 13 Cal.App.3d at p. 75 (internal citations and quotations omitted). Substantial evidence includes “enough relevant information and reasonable inferences from this information that a fair argument can be made to support a conclusion, even though other conclusions might also be reached.” CEQA Guidelines, § 15384, subd. (a).

The fair argument standard is a “low threshold” test for requiring the preparation of an EIR. No Oil, supra, 13 Cal.App.3d at p. 84; County Sanitation, supra, 127 Cal.App.4th at p. 1579. It “requires the preparation of an EIR where there is substantial evidence that any aspect of the project, either individually or cumulatively, may cause a significant effect on the environment, regardless of whether the overall effect of the project is adverse or beneficial[.]” County Sanitation, supra, 127 Cal.App.4th at p. 1580 (quoting CEQA Guidelines, § 15063, subd. (b)(1)). A lead agency may adopt an MND only if “there is no substantial evidence that the project will have a significant effect on the environment.” CEQA Guidelines, § 15074, subd. (b). 12-4147
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Evidence supporting a fair argument of a significant environmental impact triggers preparation of an EIR regardless of whether the record contains contrary evidence.

League for Protection of Oakland’s Architectural and Historical Resources v. City of Oakland (1997) 52 Cal.App.4th 896, 904-905. “Where the question is the sufficiency of the evidence to support a fair argument, deference to the agency’s determination is not appropriate[.]” County Sanitation, supra, 127 Cal.App.4th at p. 1579 (quoting Sierra Club v. County of Sonoma (1992) 6 Cal.App.4th 1307, 1317-1318).

Further, it is the duty of the lead agency, not the public, to conduct the proper environmental studies. “The agency should not be allowed to hide behind its own failure to gather relevant data.” Sundstrom, supra, 202 Cal.App.3d at p. 311. “Deficiencies in the record may actually enlarge the scope of fair argument by lending a logical plausibility to a wider range of inferences.” Ibid; see also Gentry v. City of Murrieta (1995) 36 Cal.App.4th 1359, 1382 (lack of study enlarges the scope of the fair argument which may be made based on the limited facts in the record).

Thus, refusal to complete recommended studies lowers the already low threshold to establish a fair argument. The court may not exercise its independent judgment on the omitted material by determining whether the ultimate decision of the lead agency would have been affected had the law been followed. Environmental Protection Information Center v. Cal. Dept. of Forestry (2008) 44 Cal.4th 459, 486 (internal citations and quotations omitted). The remedy for this deficiency would be for the trial court to issue a writ of mandate. Id.

Both the review for failure to follow CEQA’s procedures and the fair argument test are questions of law, thus, the de novo standard of review applies. Vineyard Area Citizens for Responsible Growth v. City of Rancho Cordova (2007) 40 Cal.4th 412, 435. “Whether the agency’s record contains substantial evidence that would support a fair argument that the project may have a significant effect on the environment is treated as a question of law. Consolidated Irrigation Dist., supra, 204 Cal.App.4th at p. 207; Kostka and Zischke, Practice Under the Environmental Quality Act (2017, 2d ed.) at § 6.76.

In the MND context, courts give no deference to the agency. The agency or the court should not weigh expert testimony or decide on the credibility of such evidence⁠—this is the EIR’s responsibility. As stated in Pocket Protectors v. City of Sacramento:
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Unlike the situation where an EIR has been prepared, neither the lead agency nor a court may “weigh” conflicting substantial evidence to determine whether an EIR must be prepared in the first instance.

Guidelines section 15064, subdivision (f)(1) provides in pertinent part: if a lead agency is presented with a fair argument that a project may have a significant effect on the environment, the lead agency shall prepare an EIR even though it may also be presented with other substantial evidence that the proje ct will not have a significant effect. Thus, as Claremont itself recognized, [c]onsideration is not to be given contrary evidence supporting the preparation of a negative declaration.
(2004) 124 Cal.App.4th 903, 935 (internal citations and quotations omitted).

In cases where it is not clear whether there is substantial evidence of significant environmental impacts, CEQA mandates erring on the side of a “preference for resolving doubts in favor of environmental review.” Mejia v. City of Los Angeles (2005) 130 Cal.App.4th 322, 332 “The foremost principle under CEQA is that the Legislature intended the act to be interpreted in such manner as to afford the fullest possible protection to the environment within the reasonable scope of the statutory language. Friends of Mammoth v. Bd. of Supervisors (1972) 8 Cal.3d 247, 259.

As explained further below, the IS/MND here fails to make certain essential findings.

Further, for a number of findings which the IS/MND does make, it fails to offer support with sufficient analysis and substantial evidence, or it fails to incorporate adequate mitigation measures. Therefore, there is a fair argument that the Project will have a significant effect on the environment, triggering the “low threshold” standard for preparation of an EIR.

C. Background Concerning CEQA Exemptions.

Where a lead agency chooses to dispose of CEQA by asserting a CEQA exemption, it has a duty to support its CEQA exemption findings by substantial evidence, including evidence that there are no applicable exceptions to exemptions. This duty is imposed by CEQA and related case law. CEQA Guidelines, § 15020 (lead agency shall not knowingly release a deficient document hoping that public comments will correct the defects); see Citizens for Environmental Responsibility v. State ex rel. 14th Dist. Agriculture Assn. (2015) 242 Cal.App.4th 555, 568 (lead agency has the burden of demonstrating that a project falls within a categorical exemption and must support the determination 12-4149
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with substantial evidence); accord Assn. for Protection etc. Values v. City of Ukiah (1991) 2 Cal.App.4th 720, 732 (lead agency is required to consider exemption exceptions where there is evidence in the record that the project might have a significant impact.) The duty to support CEQA and exemption findings with substantial evidence is also required by the Code of Civil Procedure (CCP) and case law on administrative or traditional writs. Under the CCP, an abuse of discretion is established if the decision is unsupported by the findings, or the findings are unsupported by the evidence. CCP, § 1094.5, subd. (b). In Topanga Assn. for a Scenic Comm. v. County of Los Angeles, our Supreme Court held that implicit in CCP section 1094.5 is a requirement that the agency which renders the challenged decision must set forth findings to bridge the analytic gap between the raw evidence and ultimate decision or order. (1977) 11 Cal.3d 506, 515 (internal citations and quotations omitted) (hereafter, “Topanga”). The lead agency’s findings may be determined to be sufficient if a court has no trouble under the circumstances discerning the analytic route the administrative agency traveled from evidence to action. West Chandler Blvd. Neighborhood Assn. vs. City of Los Angeles (2011) 198 Cal.App.4th 1506, 1521-1522 (internal citations and quotations omitted). However, “mere conclusory findings without reference to the record are inadequate.” Ibid. at p. 1521 (finding city council findings conclusory in violation of Topanga).

Further, CEQA exemptions must be narrowly construed to accomplish CEQA’s environmental objectives. Cal. Farm Bureau Federation v. Cal. Wildlife Conservation Bd. (2006) 143 Cal.App.4th 173, 187; accord Save Our Carmel River v. Monterey Peninsula Water Management Dist. (2006) 141 Cal.App.4th 677, 697 (“These rules ensure that in all but the clearest cases of categorical exemptions, a project will be subject to some level of environmental review.”)
Finally, CEQA procedures reflect a preference for resolving doubts in favor of environmental review. See Pub. Res. Code, § 21080, subd. (c) (an EIR may be disposed of only if there is no substantial evidence, in light of the entire record before the lead agency, that the project may have a significant effect on the environment or revisions in the project); CEQA Guidelines, §§ 15061, subd. (b)(3) (common sense exemption only where it can be seen with certainty); 15063, subd. (b)(1) (prepare an EIR if the agency determines that there is substantial evidence that any aspect of the project, either individually or cumulatively, may cause a significant effect on the environment, regardless of whether the overall effect of the project is adverse or 12-4150
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beneficial]; 15064, subd. (h) (the agency must consider cumulative impacts of past, current, and probable future projects); 15070 (a negative declaration may be prepared only if there is no substantial evidence, in light of the whole record, that the project may have a significant effect on the environment, or project revisions would avoid the effects or mitigate the effects to a point where clearly no significant effects would occur, and there is no substantial evidence, in light of the whole record, that the project as revised may have a significant effect on the environment); No Oil, supra, 13 Cal.App.3d at pp. 83-84 (significant impacts are to be interpreted so as to afford the fullest possible protection).

III. THE PROJECT WOULD BE APPROVED IN VIOLATION OF THE
CALIFORNIA ENVIRONMENTAL QUALITY ACT.

As a preliminary matter, while this Office recognizes that the FEIS cannot technically constitute as an EIR and agrees that the Tribe itself is a sovereign nation and cannot be subject to CEQA in its preparation of an EIS, the Tribe explicitly and repeatedly references the FEIS’s compliance with CEQA and the CEQA Guidelines throughout the document. In fact, the FEIS is introduced on its first page with a direct statement that the Tribe “decided to prepare this EIS in compliance with . . . the California Environmental Quality Act (CEQA) [and] the CEQA Guidelines” both substantively and procedurally. FEIS, pp. 1.0-1, 1.0-2, 1.0-4 (“Prior to considering approval of the Project in accordance with TEPA, Section 15090 of the CEQA Guidelines also requires the Tribe to certify that . . . [t]he Final EIS was completed in compliance with CEQA.”), 2.0-30. The Tribe further states that it:

Prepared this EIS in compliance with the substantive and procedural requirements of CEQA . . . to minimize the duplication of environmental studies and documentation by other agencies that may be involved with the future review and approval of actions related to the Project that would be subject to CEQA.

FEIS, p. 1.0-1.

Apart from the Tribe’s explicit constitution of the FEIS as a CEQA-compliant report, the FEIS itself makes consistent attempts to comply with CEQA and the CEQA Guidelines. For example, the FEIS includes information in compliance with CEQA Guidelines, Section 15132, including the Draft EIS (DEIS), a list of agencies that commented on the DEIS, actual comments received on the DEIS, responses to 12-4151
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significant environmental points raised in the comments received, and revisions to the DEIS. FEIS, pp. 1.0-2, 1.0-4. Further, the Tribe, in compliance with CEQA Guidelines, Section 15191, included one or more written findings of fact for each significant environmental impact identified in the Final EIS.” FEIS, p. 1.0-5. Last, the Tribe adopted a Mitigation Monitoring and Reporting Program (MMRP) and included the draft MMRP as Appendix 1.0 in accordance with CEQA Guidelines, Section 15097. FEIS, p. 1.0-5.

Inarguably, the Tribe prepared and constitutes the FEIS as an EIR (or otherwise as a CEQA-compliant environmental assessment) for all intents and purposes. For these reasons, this letter addresses and analyzes the FEIS as an environmental assessment in presumed and intentional compliance with CEQA and the CEQA Guidelines.

A. The Lead Agency Must Conduct a Revised, Updated, and Project- Specific Environmental Assessment.

1. The FEIS Failed to Analyze the Project’s Environmental Impacts.

The FEIS did not adequately analyze the environmental impacts of the Project.

According to TEPA, production of an EIS is required when a Determination of Significance (DS) has been made that a proposed project—including site development of a space that exceeds 400 square feet (TEPA, § 27.02.08, subd. (A)) or non-project actions such as land-use and other management plans that govern the development or management of land (TEPA, § 27.02.08, subd. (M)—is likely to have a significant adverse environmental impact. TEPA, § 27.01.02, subd. (L). Here, the Project involves the annexation and amendment of the pre-zoning designation for the eventual and impending development of approximately 257 acres of land.

Unfortunately, the FEIS prepared and circulated in 2014 and certified in March 2015 failed to account for or adequately analyze several of the Project’s significant impacts and failed to propose or mandate sufficient mitigation measures for the reduction of those impacts to less than significant. The Original Project for annexation of the 577 acres did not include the portion of the land now proposed for annexation (i.e., the Site) and thus the FEIS did not and could not have considered the specific environmental impacts of development of the Site. Consequently, the Original Project has resulted in significant and unmitigated environmental impacts in violation of TEPA and CEQA—mandating, at minimum, the preparation and circulation of an updated and revised EIS to account for the eventual development of the Site, or, 12-4152
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more appropriately, a CEQA-compliant, Project-specific EIR. Production and circulation of a new EIS or EIR is required in order to afford the public a meaningful chance to submit commentary on the Project.

2. Changed Circumstances and/or New Information Warrant the Production of a Revised Environmental Assessment.

As mentioned previously, the preparation and circulation of a project-specific EIR is more than a set of technical hurdles for agencies and developers to overcome. The EIR’s function is to ensure that government officials who decide to build or approve a project do so with a full understanding of the environmental consequences and, equally important, that the public is assured those consequences have been considered. In order for an environmental assessment to serve these goals it must present sufficient information to allow for the foreseeable impacts of pursuing the project to be understood and weighed, and the public must be given an adequate opportunity to comment on that presentation before the decision to go forward is made. Communities for a Better Environment, supra, 184 Cal.App.4th at p. 80 (internal citation and quotation omitted). Unfortunately, the FEIS does here does not satisfy this mandate.

The California Environmental Quality Act requires a subsequent or supplemental EIR when substantial changes occur in a project’s circumstances or when new information of substantial importance becomes available. Here, the City intends on adopting the FEIS in furtherance of the rezoning of and development of the Site, and, presumably, will deem the Project CEQA-compliant and justly covered in the FEIS.

Unfortunately, substantial changes have come to light regarding the inadequacy of the FEIS and whether it encompasses the current Project—therefore justifying its recirculation in accordance with what would generally be required of any environmental assessment when significant new information arises. See CEQA Guidelines, §§ 15088.5, 15162; Pub. Res. Code, § 21166. ‘Significant new information’ which would generally require recirculation of, for example, a Draft Environmental Impact Report (DEIR) includes:
1) A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented.
2) A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce impacts to a level of insignificance.
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3) A feasible project alternative or mitigation measures considerably different from others previously analyzed would clearly lessen the significant environmental impacts of the project, but the project proponents decline to adopt it.
4) The draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded.

CEQA Guidelines, § 15088.5, subd. (a).

Similarly, in the context of an EIR which has previously been certified, a subsequent EIR must be prepared if:
1) Substantial changes are proposed in the project which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects;
2) Substantial changes occur with respect to the circumstances under which the project is undertaken which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or
3) New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete or the negative declaration was adopted, shows any of the following:

A) The project will have one or more significant effects not discussed in the previous EIR or negative declaration;
B) Significant effects previously examined will be substantially more severe than shown in the previous EIR;
C) Mitigation measures or alternatives previously found not to be feasible would in fact be feasible and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative; or
D) Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative. 12-4154
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CEQA Guidelines, § 15162, subd. (a).

Once a project has been approved, no further steps to comply with CEQA are required unless a further discretionary approval of the project is necessary. New information appearing after a project approval does not require that the approval be reopened. CEQA Guidelines, § 15162, subd. (c). However, if another discretionary approval for a project is required, the agency considering that approval must determine whether further CEQA review is necessary due to changes in the project, change of circumstances, or new information. CEQA Guidelines, § 15162, subd. (a), (c). Additionally, if the lead agency finds that no substantial changes have occurred and no new information has come to light, the lead agency is not required to prepare a subsequent or supplemental environmental assessment. Nonetheless, if the lead agency cannot make that finding, it must prepare and certify a subsequent or supplemental EIR (or EIS). See Pub. Res. Code, § 21157.6.

Here, given that further discretionary approval will be required in the immediate future with regard not only to the Project but also to the subsequent development of the Retirement Community—more than eight years after the original certification of the FEIS—the City must evaluate whether new and/or changed circumstances now exist that would warrant publication of a subsequent or supplemental environmental report. Neither the FEIS nor any other decision or assessment undertaken by the Tribe or the City include any analysis of whether there have been any substantial changes since the certification of the 2015 FEIS nor is there any analysis of whether any new information is available. Such an evaluation should be undertaken as soon as possible in order to prevent the possibility that this City’s neglect constitute as a violation of CEQA’s requirements with respect to the use of a “master EIR,” which is the functional equivalent of the FEIS. See Pub. Res. Code, § 21157, subd. (a); CEQA Guidelines, § 1575, subd. (b).

It is indisputable that new information is available that would impact any future development of the Site. The Project involves a General Plan/Zoning Map Amendment to amend the several existing pre-zoning designations of the Site to Mixed Use (M-U) for the eventual development of the expansion of the Retirement Community. When the FEIS was prepared and certified, the Site and the 577 previously annexed acres were mostly undeveloped. Today, there sits over 1,000 single-family residences and several more sensitive receptors immediately next to the Site. The FEIS could not and did not consider the environmental impacts of 12-4155
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development of the Site as it exists in its state today. This constitutes as changed circumstances and new information sufficient for preparation of an addendum or subsequent environmental review.

It is also worth noting that the FEIS was circulated and adopted eight years ago.

Should an application for a follow-up or subsequent project be filed more than five years after the master EIR—or, in the matter at hand, the FEIS—was certified, the lead agency must review the adequacy of that assessment. Pub. Res. Code, § 21157.6; CEQA Guidelines, § 15179. Therefore, the lapse of eight years since the certification of the FEIS alone constitutes as sufficient impetus to warrant recirculation of the FEIS or the preparation of a new Project-specific EIR. See Berkeley Keep Jets, supra, 91 Cal.App.4th at p. 1367 (where the court concluded that the EIR was not a reasoned and good faith effort to inform decision makers and the public about certain environmental impacts where it relied on outdated information).

While this Office recognizes that no entitlements are currently requested or development proposals underway, it is worth mentioning that City’s potential reliance on the outdated FEIS for eventual Project approval would be entirely inappropriate.

There exists substantial evidence that the Project may have several potentially significant environmental impacts, including on biological resources, air quality, GHG emissions, and more—thereby mandating the preparation of, at the very least, an addendum to the FEIS focusing on specific impacts and mitigation measures. Last, because the Project constitutes a new proposal distinct from the Original Project and will require its own individual approvals, the City must make its own independent environmental determinations and findings and cannot rely on the outdated and generally inapplicable FEIS. An EIR is necessary.

B. The Final Environmental Impact Statement Does Not Comply with the California Environmental Quality Act.

1. An EIS Does Not Rise to the Level of, and Therefore Cannot Supplant the Standards of, an EIR.

As previously mentioned, the FEIS does not comply with CEQA, nor can preparation of an EIS dispose of the requirement to prepare an EIR in a situation such as that present here. Despite the Tribe’s claims that the FEIS was prepared in accordance with CEQA and its Guidelines, CEQA is significantly more demanding than the National Environmental Policy Act (NEPA), and by default, TEPA. While tribal 12-4156
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governments have substantial authority through their retained tribal sovereignty for environmental protection on lands within their jurisdiction, and while such authority is distinct from the responsibilities under NEPA,6 TEPA is a tribal law adapted from NEPA. See Daniel R. Mandelker, NEPA Law and Litigation § 12:1 (2d ed., 2002).

Nevertheless, because the enactment of a TEPA does not circumvent compliance with NEPA, most TEPAs align closely with NEPA requirements and procedures in order to reduce duplication of efforts. Dean B. Suagee, Tribal Environmental Policy Acts and the Landscape of Environmental Law, Natural Resources & Environment (vol. 23, no. 4, 2009) (quotation omitted). In essence, TEPA and NEPA are sufficiently and closely aligned to warrant analysis of the intersection between the two and CEQA interchangeably.

While CEQA and NEPA are counterparts in their procedures and effects, CEQA is more restrictive and afford the environment more protection than NEPA. Given that the FEIS was in presumable compliance with TEPA (and therefore NEPA), its analysis—though helpful in introducing and potentially summarizing the Project’s potential impacts and necessary mitigation—does not rise to the standards inherent and required in CEQA. Our Supreme Court has stated that “while federal authority interpreting environmental requirements under NEPA and residential land use planning standards may be helpful[,]” it is important to stress when a case is brought under CEQA given that it imposes its own requirements for assessing environmental impacts. Berkeley Keep Jets, supra, 91 Cal.App.4th at pp. 1379-1380. The court went on to mandate that federal precedent under NEPA be ignored in light of those of CEQA “when the federal provisions cannot fairly by said to parallel” CEQA. Ibid. (quoting Mountain Lion Foundation v. Fish & Game Comm. (1997) 16 Cal.4th 105, 121. The court in Berkeley Keep Jets chose to depart from the federal cases on the subject of environmental impacts after finding that there are important distinctions between the requirements imposed by CEQA and by NEPA in that context. Ibid.

2. The Standard of Review of NEPA, and, by Default, TEPA, is More Deferential Than That of CEQA.

As stated previously, while courts review an EIR using an “abuse of discretion” standard, “the reviewing court is not to ‘uncritically rely on every study or analysis

6 Indian Affairs National Environmental Policy Act (NEPA) Guidebook (2012), available at https://www.bia.gov/sites/default/files/dup/assets/public/raca/handbook/pdf/59_IAM _3-H_v1.1_508_OIMT.pdf.
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presented by a project proponent in support of its position.’ A ‘clearly inadequate or unsupported study is entitled to no judicial deference.’” Berkeley Keep Jets, supra, 91 Cal.App.4th at 1355 (quoting Laurel Heights, supra, 47 Cal.3d at 391, 409 fn. 12).

Drawing this distinction and assessing whether the EIR is in compliance with CEQA’s information disclosure mandates presents a question of law subject to independent review by the courts. Sierra Club v. Cnty. of Fresno (2018) 6 Cal.5th 502, 515; Madera Oversight Coalition, Inc. v. County of Madera (2011) 199 Cal.App.4th 48, 102, 131. As the court stated in Berkeley Keep Jets, supra:

A prejudicial abuse of discretion occurs if the failure to include relevant information precludes informed decision -making and informed public participation, thereby thwarting the statutory goals of the EIR process. 91 Cal.App.4th at 1355 (internal citation and quotation omitted).

In contrast, NEPA’s standard of review is not a prejudicial abuse of discretion, but rather a more deferential ‘arbitrary and capricious’ standard. “A court’s inquiry, when reviewing whether an agency complied with NEPA, is whether the agency adequately considered a project’s potential impacts and whether the consideration given amounted to a ‘hard look’ at the environmental effects. Idaho Sporting Congress, Inc. v. Rittenhouse, 305 F.3d 957, 963 (9th Cir. 2002). A ‘hard look’ includes considering all foreseeable direct and indirect impacts. Id. at 973. Additionally, a ‘hard look’ should involve the analysis of adverse impacts that does not improperly minimize negative side effects. Native Ecosystems Council v. U.S. Forest Service, 428 F.3d 1233, 1241 (9th Cir. 2005).

The courts will review substantive agency decisions concerning NEPA under the ‘arbitrary and capricious’ standard, meaning courts must determine whether the lead agency’s decision is based on a consideration of the relevant factors or whether its action was “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law.” Blue Mountains Biodiversity Project v. Blackwood, 161 F.3d 1208, 1211 (9th Cir. 1998) (quoting the APA, 5 U.S.C. § 706, subd. (2)(A)); see also Northern Alaska Environmental Center v. Kempthorne (9th Cir. 2006) 457 F.3d 969, 975.

3. Responsible Agencies Must Make Their Own Independent Findings.

According to CEQA Guidelines, § 15084, subsection (e), the lead agency must subject the environmental assessment to the agency’s own review and analysis. Additionally, the environmental assessment—in the case of § 15084, the draft EIR—which is sent 12-4158
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out for public review must reflect the independent judgment of the lead agency, which is responsible for the adequacy and objectivity of the environmental assessment. Ibid.

In We Advocate Through Environmental Review v. City of Mount Shasta (2022), the County prepared an EIR though the City was responsible for approving a portion of the Project, namely, a permit for the bottling facility. The City attempted to rely on the County’s EIR and reasoned that the project would have no impacts. The Court mandated that the City make its own independent findings. 78 Cal.App.5th 629, 639- 640.

Here, the lead agency for both the Original Project and the current Project, technically, is the Tribe. The Project, though, involves the annexation of the Site to the City of Rancho Mirage, which will then become the lead agency for purposes of approving the impending additional development of the Retirement Community.

When that time comes, the City will have the option of affirming the adequacy of the Tribe’s environmental assessment and rest its decision to avoid CEQA-compliant environmental review on the FEIS. Upon review of such reasoning, the City would be required to comply with the CEQA Guidelines and make its own determinations regarding the adequacy and applicability of the FEIS, though through the lens of the heightened standards of CEQA. To determine whether a TEPA-compliant document rises to the standards of CEQA would be an exercise in futility. Consequently, the City should bypass the wasteful expenditure of time and resources required to assess the FEIS pursuant to § 15084 (or its TEPA equivalent), and prepare its own environmental assessment through a Project-specific EIR.

The City may contend that, pursuant to CEQA Guidelines, § 21083.5, subsection (a), “all or any part” of the FEIS may be imported into or substituted for an EIR if the FEIS complies with CEQA. Specifically, according to that section:

When an environmental impact statement has been, or will be, prepared for the same project pursuant to the requirements of the National Environmental Policy Act of 1969 (42 U.S.C. Sec. 4321 et seq.) . . . all or any part of that statement or report may be submitted in lieu of all or any part of an environmental impact report required by this division, if that statement or report, or the part which is used, complies with the requirements of this division and the guidelines adopted pursuant thereto.

CEQA Guidelines, § 21083.5, subd. (a).
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Here, though, the FEIS cannot be used in lieu of a Project-specific EIR given that it does not meet CEQA’s standards, including, inter alia, that it failed to consider the impacts of the impending annexation as well as the Project’s buildout on that annexed portion of the Section 24 land, including the project’s impacts on the City itself.

4. The FEIS Grants TEPA Ongoing Governance of Annexed Land.

By having prepared the environmental assessment in compliance with TEPA, thereby governing land that is within the sphere of influence and soon-to-be annexed into the City for years to come, the Tribe effectively maintains control over the environmental conditions of the future uses of the Site and mitigation measures without actually maintaining any responsibility for the oversight and approval of future developments.

The presumably increasingly intensified uses of the Site are bound to have significant environmental impacts, though the City will have wide and potentially unchecked discretion in reaffirming the applicability and adequacy of the FEIS. The FEIS, then, takes away the discretion of the elected City Council to provide for certain uses in line with CEQA by extending the governance of TEPA over the Site. Such an eventuality, however improbable, assails the very purpose of CEQA to afford the environment the greatest protections possible. Consequently, the City should prepare a Project- specific EIR.

C. Due to the COVID-19 Crisis, the City Must Adopt a Mandatory Finding of Significance that the Project May Cause a Substantial Adverse Effect on Human Beings and Mitigate COVID-19 Impacts.

First, CEQA requires that an agency make a finding of significance when a Project may cause a significant adverse effect on human beings. Pub. Res. Code, § 21083, subd. (b)(3); CEQA Guidelines, § 15065, subd. (a)(4).

Public health risks related to construction work require a mandatory finding of significance under CEQA. Construction work has been defined as a lower- to high- risk activity for COVID-19 spread by the Occupations Safety and Health Administration. Recently, several construction sites have been identified as sources of community-wide spreads of COVID-19.

SWMSRCC recommends that the City adopt additional CEQA mitigation measures to mitigate public health risks from the Project’s construction activities. SWMSRCC also 12-4160
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requests that the City require safe on-site construction work practices as well as training and certification for any construction workers on the Project site.

In particular, and based upon its experience with safe construction site work practices, SWMSRCC recommends that the City require that while construction activities are being conducted at the Project Site:

Construction Site Design:
• The Project Site be limited to two controlled entry points. • Entry points have temperature screening technicians taking temperature readings when the entry point is open.
• The Temperature Screening Site Plan shows details regarding access to the Project Site and Project Site logistics for conducting temperature screening. • A 48-hour advance notice be provided to all trades prior to the first day of temperature screening.
• The perimeter fence directly adjacent to the entry points be clearly marked indicating the appropriate 6-foot social distancing position for when you approach the screening area. Please reference the Apex temperature screening site map for additional details.
• There be clear signage posted at the project site directing you through temperature screening.
• Provide hand washing stations throughout the construction site.

Testing Procedures:
• The temperature screenings used are non-contact devices. • Temperature readings are not to be recorded.
• Personnel be screened upon entering the testing center and should only take one to two seconds per individual.
• Hard hats, head coverings, sweat, dirt, sunscreen, or any other cosmetics must be removed on the forehead before temperature screening. • Anyone who refuses to submit to a temperature screening or does not answer the health screening questions be refused access to the Project Site. • Screenings be performed at both entrances from 5:30 am to 7:30 am at the main gate and personnel gate.
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• After 7:30 am, only the main gate entrance continues to be used for temperature testing for anybody gaining entry to the project site such as returning personnel, deliveries, and visitors.
• If the digital thermometer displays a temperature reading above 100.0 degrees Fahrenheit, a second reading will be taken to verify an accurate reading. • If the second reading confirms an elevated temperature, DHS will instruct the individual that he/she will not be allowed to enter the Project Site. DHS will also instruct the individual to promptly notify his/her supervisor and human resources representative and provide them with a copy of Annex A.

Planning:
• Require the development of an Infectious Disease Preparedness and Response Plan that will include basic infection prevention measures (requiring the use of personal protection equipment), policies and procedures for prompt identification and isolation of sick individuals, social distancing (prohibiting gatherings of no more than 10 people including all-hands meetings and all- hands lunches) communication and training and workplace controls that meet standards that may be promulgated by the Center for Disease Control, Occupational Safety and Health Administration, Cal/OSHA, California Department of Public Health or applicable local public health agencies.

The United Brotherhood of Carpenters and Carpenters International Training Fund has developed COVID-19 Training and Certification to ensure that Carpenter union members and apprentices conduct safe work practices. The City should require that all construction workers undergo COVID-19 Training and Certification before being allowed to conduct construction activities at the Project Site.

SWMSRCC has also developed a rigorous Infection Control Risk Assessment (ICRA) training program to ensure it delivers a workforce that understands how to identify and control infection risks by implementing protocols to protect themselves and all others during renovation and construction projects in healthcare environments.

The ICRA protocols are intended to contain pathogens, control airflow, and protect patients during the construction, maintenance, and renovation of healthcare facilities.

These protocols prevent cross-contamination, minimizing the risk of secondary infections in patients at hospital facilities. The City should require that the Project be built using a workforce trained in ICRA protocols.
12-4162
City of Rancho Mirage – Section 24 Annexation
September 27, 2023

Page 25 of 25 ends

IV. CONCLUSION
In light of the aforementioned concerns, SWMSRCC respectfully requests that the City: (1) require a local and skilled workforce for any future development of the Site; (2) deem the Project not exempt from CEQA; (3) deny recommendation to the City Council regarding the Project’s use of the Tribal EIS, approval of the General Plan Zoning Map Amendment, and approval of the Section 24 Specific Plan; and, (4) order the preparation and circulation of a thorough, Project-specific EIR or EIS. Should the City have any questions or concerns, it should feel free to contact my Office.

Sincerely,

___________________________________
Reza Bonachea Mohamadzadeh
Attorney for Southwest Mountain
States Regional Council of Carpenters

Attached:

March 8, 2021, SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and Considerations for Greenhouse Gas Modeling (Exhibit A); Air Quality and GHG Expert Paul Rosenfeld CV (Exhibit B); Air Quality and GHG Expert Matt Hagemann CV (Exhibit C). 12-4163

EXHIBIT A
12-4164

1 2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
[email protected]
Paul E. Rosenfeld, PhD
(310) 795-2335
[email protected]
March 8, 2021

Mitchell M. Tsai
155 South El Molino, Suite 104
Pasadena, CA 91101

Subject: Local Hire Requirements and Considerations for Greenhouse Gas Modeling Dear Mr. Tsai,
Soil Water Air Protection Enterprise (“SWAPE”) is pleased to provide the following draft technical report explaining the significance of worker trips required for construction of land use development projects with respect to the estimation of greenhouse gas (“GHG”) emissions. The report will also discuss the potential for local hire requirements to reduce the length of worker trips, and consequently, reduced or mitigate the potential GHG impacts.

Worker Trips and Greenhouse Gas Calculations
The California Emissions Estimator Model (“CalEEMod”) is a “statewide land use emissions computer model designed to provide a uniform platform for government agencies, land use planners, and environmental professionals to quantify potential criteria pollutant and greenhouse gas (GHG) emissions associated with both construction and operations from a variety of land use projects.”1 CalEEMod quantifies construction-related emissions associated with land use projects resulting from off-road construction equipment; on-road mobile equipment associated with workers, vendors, and hauling; fugitive dust associated with grading, demolition, truck loading, and on-road vehicles traveling along paved and unpaved roads; and architectural coating activities; and paving.2
The number, length, and vehicle class of worker trips are utilized by CalEEMod to calculate emissions associated with the on-road vehicle trips required to transport workers to and from the Project site during construction.3

1 “California Emissions Estimator Model.” CAPCOA, 2017, available at: http://www.aqmd.gov/caleemod/home. 2 “California Emissions Estimator Model.” CAPCOA, 2017, available at: http://www.aqmd.gov/caleemod/home. 3 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 34. 12-4165

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

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

Default Worker Trip Parameters and Potential Local Hire Requirements As previously discussed, the number, length, and vehicle class of worker trips are utilized by CalEEMod to calculate emissions associated with the on-road vehicle trips required to transport workers to and from the Project site during construction.7 In order to understand how local hire requirements and associated worker trip length reductions impact GHG emissions calculations, it is important to consider the CalEEMod default worker trip parameters. CalEEMod provides recommended default values based on site-specific information, such as land use type, meteorological data, total lot acreage, project type and typical equipment associated with project type. If more specific project information is known, the user can change the default values and input project- specific values, but the California Environmental Quality Act (“CEQA”) requires that such changes be justified by substantial evidence.8 The default number of construction-related worker trips is calculated by multiplying the

4 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 14-15. 5 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 23. 6 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 15. 7 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 34. 8 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 1, 9. 12-4166

3 number of pieces of equipment for all phases by 1.25, with the exception of worker trips required for the building construction and architectural coating phases.9 Furthermore, the worker trip vehicle class is a 50/25/25 percent mix of light duty autos, light duty truck class 1 and light duty truck class 2, respectively.”10 Finally, the default worker trip length is consistent with the length of the operational home-to-work vehicle trips.11 The operational home-to-work vehicle trip lengths are:
“[B]ased on the location and urbanization selected on the project characteristic screen. These values were supplied by the air districts or use a default average for the state. Each district (or county) also assigns trip lengths for urban and rural settings” (emphasis added). 12 Thus, the default worker trip length is based on the location and urbanization level selected by the User when modeling emissions. The below table shows the CalEEMod default rural and urban worker trip lengths by air basin (see excerpt below and Attachment A).13
Worker Trip Length by Air Basin
Air Basin Rural (miles) Urban (miles)
Great Basin Valleys 16.8 10.8
Lake County 16.8 10.8
Lake Tahoe 16.8 10.8
Mojave Desert 16.8 10.8
Mountain Counties 16.8 10.8
North Central Coast 17.1 12.3
North Coast 16.8 10.8
Northeast Plateau 16.8 10.8
Sacramento Valley 16.8 10.8
Salton Sea 14.6 11
San Diego 16.8 10.8
San Francisco Bay Area 10.8 10.8
San Joaquin Valley 16.8 10.8
South Central Coast 16.8 10.8
South Coast 19.8 14.7
Average 16.47 11.17
Minimum 10.80 10.80
Maximum 19.80 14.70
Range 9.00 3.90

9 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 34. 10 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at:
http://www.aqmd.gov/docs/default-source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 15. 11 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at:
http://www.aqmd.gov/docs/default-source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 14. 12 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at:
http://www.aqmd.gov/docs/default-source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 21. 13 “Appendix D Default Data Tables.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/05_appendix-d2016-3-2.pdf?sfvrsn=4, p. D-84 – D-86. 12-4167

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

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

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

This serves as an example of the potential impacts of local hire requirements on estimated project-level GHG emissions, though it does not indicate that local hire requirements would result in reduced construction-related GHG emission for all projects. As previously described, the significance of a local hire requirement depends on the worker trip length enforced and the default worker trip length for the project’s urbanization level and location.

14 “Appendix D Default Data Tables.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/05_appendix-d2016-3-2.pdf?sfvrsn=4, p. D-85. 12-4168

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

Sincerely,

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

Paul E. Rosenfeld, Ph.D.
12-4169
Location Type Location Name Rural H-W
(miles)
Urban H-W
(miles)
Air Basin Great Basin 16.8 10.8
Air Basin Lake County 16.8 10.8
Air Basin Lake Tahoe 16.8 10.8
Air Basin Mojave Desert 16.8 10.8
Air Basin Mountain 16.8 10.8
Air Basin North Central 17.1 12.3
Air Basin North Coast 16.8 10.8
Air Basin Northeast 16.8 10.8
Air Basin Sacramento 16.8 10.8
Air Basin Salton Sea 14.6 11
Air Basin San Diego 16.8 10.8
Air Basin San Francisco

10.8 10.8
Air Basin San Joaquin 16.8 10.8
Air Basin South Central 16.8 10.8
Air Basin South Coast 19.8 14.7
Air District Amador County 16.8 10.8
Air District Antelope Valley 16.8 10.8
Air District Bay Area AQMD 10.8 10.8
Air District Butte County 12.54 12.54
Air District Calaveras

16.8 10.8
Air District Colusa County 16.8 10.8
Air District El Dorado

16.8 10.8
Air District Feather River 16.8 10.8
Air District Glenn County 16.8 10.8
Air District Great Basin 16.8 10.8
Air District Imperial County 10.2 7.3
Air District Kern County 16.8 10.8
Air District Lake County 16.8 10.8
Air District Lassen County 16.8 10.8
Air District Mariposa

16.8 10.8
Air District Mendocino

16.8 10.8
Air District Modoc County 16.8 10.8
Air District Mojave Desert 16.8 10.8
Air District Monterey Bay

16.8 10.8
Air District North Coast

16.8 10.8
Air District Northern Sierra 16.8 10.8
Air District Northern

16.8 10.8
Air District Placer County 16.8 10.8
Air District Sacramento 15 10
Attachment A
12-4170
Air District San Diego

16.8 10.8
Air District San Joaquin

16.8 10.8
Air District San Luis Obispo

13 13
Air District Santa Barbara

8.3 8.3
Air District Shasta County 16.8 10.8
Air District Siskiyou County

16.8 10.8
Air District South Coast 19.8 14.7
Air District Tehama County 16.8 10.8
Air District Tuolumne 16.8 10.8
Air District Ventura County 16.8 10.8
Air District Yolo/Solano 15 10
County Alameda 10.8 10.8
County Alpine 16.8 10.8
County Amador 16.8 10.8
County Butte 12.54 12.54
County Calaveras 16.8 10.8
County Colusa 16.8 10.8
County Contra Costa 10.8 10.8
County Del Norte 16.8 10.8
County El Dorado-Lake 16.8 10.8
County El Dorado- 16.8 10.8
County Fresno 16.8 10.8
County Glenn 16.8 10.8
County Humboldt 16.8 10.8
County Imperial 10.2 7.3
County Inyo 16.8 10.8
County Kern-Mojave 16.8 10.8
County Kern-San 16.8 10.8
County Kings 16.8 10.8
County Lake 16.8 10.8
County Lassen 16.8 10.8
County Los Angeles- 16.8 10.8
County Los Angeles- 19.8 14.7
County Madera 16.8 10.8
County Marin 10.8 10.8
County Mariposa 16.8 10.8
County Mendocino- 16.8 10.8
County Mendocino- 16.8 10.8
County Mendocino- 16.8 10.8
County Mendocino- 16.8 10.8
County Merced 16.8 10.8
County Modoc 16.8 10.8
County Mono 16.8 10.8
County Monterey 16.8 10.8
County Napa 10.8 10.8
12-4171
County Nevada 16.8 10.8
County Orange 19.8 14.7
County Placer-Lake 16.8 10.8
County Placer-Mountain 16.8 10.8
County Placer- 16.8 10.8
County Plumas 16.8 10.8
County Riverside- 16.8 10.8
County Riverside-

19.8 14.7
County Riverside-Salton 14.6 11
County Riverside-South 19.8 14.7
County Sacramento 15 10
County San Benito 16.8 10.8
County San Bernardino-

16.8 10.8
County San Bernardino-

19.8 14.7
County San Diego 16.8 10.8
County San Francisco 10.8 10.8
County San Joaquin 16.8 10.8
County San Luis Obispo 13 13
County San Mateo 10.8 10.8
County Santa Barbara-

8.3 8.3
County Santa Barbara-

8.3 8.3
County Santa Clara 10.8 10.8
County Santa Cruz 16.8 10.8
County Shasta 16.8 10.8
County Sierra 16.8 10.8
County Siskiyou 16.8 10.8
County Solano- 15 10
County Solano-San 16.8 10.8
County Sonoma-North 16.8 10.8
County Sonoma-San 10.8 10.8
County Stanislaus 16.8 10.8
County Sutter 16.8 10.8
County Tehama 16.8 10.8
County Trinity 16.8 10.8
County Tulare 16.8 10.8
County Tuolumne 16.8 10.8
County Ventura 16.8 10.8
County Yolo 15 10
County Yuba 16.8 10.8
Statewide Statewide 16.8 10.8
12-4172
Air Basin Rural (miles) Urban (miles)
Great Basin Valleys 16.8 10.8
Lake County 16.8 10.8
Lake Tahoe 16.8 10.8
Mojave Desert 16.8 10.8
Mountain Counties 16.8 10.8
North Central Coast 17.1 12.3
North Coast 16.8 10.8
Northeast Plateau 16.8 10.8
Sacramento Valley 16.8 10.8
Salton Sea 14.6 11
San Diego 16.8 10.8
San Francisco Bay Area 10.8 10.8
San Joaquin Valley 16.8 10.8
South Central Coast 16.8 10.8
South Coast 19.8 14.7
Average 16.47 11.17
Mininum 10.80 10.80
Maximum 19.80 14.70
Range 9.00 3.90
Worker Trip Length by Air Basin
12-4173

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population General Office Building 45.00 1000sqft 1.03 45,000.00 0 High Turnover (Sit Down Restaurant) 36.00 1000sqft 0.83 36,000.00 0 Hotel 50.00 Room 1.67 72,600.00 0
Quality Restaurant 8.00 1000sqft 0.18 8,000.00 0
Apartments Low Rise 25.00 Dwelling Unit 1.56 25,000.00 72 Apartments Mid Rise 975.00 Dwelling Unit 25.66 975,000.00 2789 Regional Shopping Center 56.00 1000sqft 1.29 56,000.00 0

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

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company Southern California Edison
2028Operational Year
CO2 Intensity
(lb/MWhr)
702.44 0.029CH4 Intensity
(lb/MWhr)

0.006N2O Intensity
(lb/MWhr)
Village South Specific Plan (Proposed)
Los Angeles-South Coast County, Annual
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 1 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual Attachment B
12-4174
Project Characteristics - Consistent with the DEIR's model.

Land Use - See SWAPE comment regarding residential and retail land uses.

Construction Phase - See SWAPE comment regarding individual construction phase lengths.

Demolition - Consistent with the DEIR's model. See SWAPE comment regarding demolition.

Vehicle Trips - Saturday trips consistent with the DEIR's model. See SWAPE comment regarding weekday and Sunday trips.

Woodstoves - Woodstoves and wood-burning fireplaces consistent with the DEIR's model. See SWAPE comment regarding gas fireplaces.

Energy Use -
Construction Off-road Equipment Mitigation - See SWAPE comment on construction-related mitigation.

Area Mitigation - See SWAPE comment regarding operational mitigation measures.

Water Mitigation - See SWAPE comment regarding operational mitigation measures.

Table Name Column Name Default Value New Value
tblFireplaces FireplaceWoodMass 1,019.20 0.00
tblFireplaces FireplaceWoodMass 1,019.20 0.00
tblFireplaces NumberWood 1.25 0.00
tblFireplaces NumberWood 48.75 0.00
tblVehicleTrips ST_TR 7.16 6.17
tblVehicleTrips ST_TR 6.39 3.87
tblVehicleTrips ST_TR 2.46 1.39
tblVehicleTrips ST_TR 158.37 79.82
tblVehicleTrips ST_TR 8.19 3.75
tblVehicleTrips ST_TR 94.36 63.99
tblVehicleTrips ST_TR 49.97 10.74
tblVehicleTrips SU_TR 6.07 6.16
tblVehicleTrips SU_TR 5.86 4.18
tblVehicleTrips SU_TR 1.05 0.69
tblVehicleTrips SU_TR 131.84 78.27
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 2 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4175

2.0 Emissions Summary
tblVehicleTrips SU_TR 5.95 3.20
tblVehicleTrips SU_TR 72.16 57.65
tblVehicleTrips SU_TR 25.24 6.39
tblVehicleTrips WD_TR 6.59 5.83
tblVehicleTrips WD_TR 6.65 4.13
tblVehicleTrips WD_TR 11.03 6.41
tblVehicleTrips WD_TR 127.15 65.80
tblVehicleTrips WD_TR 8.17 3.84
tblVehicleTrips WD_TR 89.95 62.64
tblVehicleTrips WD_TR 42.70 9.43
tblWoodstoves NumberCatalytic 1.25 0.00
tblWoodstoves NumberCatalytic 48.75 0.00
tblWoodstoves NumberNoncatalytic 1.25 0.00
tblWoodstoves NumberNoncatalytic 48.75 0.00
tblWoodstoves WoodstoveDayYear 25.00 0.00
tblWoodstoves WoodstoveDayYear 25.00 0.00
tblWoodstoves WoodstoveWoodMass 999.60 0.00
tblWoodstoves WoodstoveWoodMass 999.60 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 3 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4176

2.1 Overall Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2021 0.1713 1.8242 1.1662 2.4000e-
003

0.4169 0.0817 0.4986 0.1795 0.0754 0.2549 0.0000 213.1969 213.1969 0.0601 0.0000 214.6993 2022 0.6904 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721.682 6 1,721.682
6 0.1294 0.0000 1,724.918
7 2023 0.6148 3.3649 5.6747 0.0178 1.1963 0.0996 1.2959 0.3203 0.0935 0.4138 0.0000 1,627.529 5 1,627.529
5 0.1185 0.0000 1,630.492
5 2024 4.1619 0.1335 0.2810 5.9000e-
004

0.0325 6.4700e-
003

0.0390 8.6300e-
003

6.0400e-
003

0.0147 0.0000 52.9078 52.9078 8.0200e-
003

0.0000 53.1082
Maximum 4.1619 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721.682 6 1,721.682
6 0.1294 0.0000 1,724.918
7 Unmitigated Construction
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 4 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4177

0.4169 0.0817 0.4986 0.1795 0.0754 0.2549 0.0000 213.1967 213.1967 0.0601 0.0000 214.6991 2022 0.6904 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721.682 3 1,721.682
3 0.1294 0.0000 1,724.918
3 2023 0.6148 3.3648 5.6747 0.0178 1.1963 0.0996 1.2959 0.3203 0.0935 0.4138 0.0000 1,627.529 1 1,627.529
1 0.1185 0.0000 1,630.492
1 2024 4.1619 0.1335 0.2810 5.9000e-
004

0.0325 6.4700e-
003

0.0390 8.6300e-
003

6.0400e-
003

0.0147 0.0000 52.9077 52.9077 8.0200e-
003

0.0000 53.1082
Maximum 4.1619 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721.682 3 1,721.682
3 0.1294 0.0000 1,724.918
3 Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Quarter Start Date End Date Maximum Unmitigated ROG + NOX (tons/quarter) Maximum Mitigated ROG + NOX (tons/quarter) 1 9-1-2021 11-30-2021 1.4103 1.4103
2 12-1-2021 2-28-2022 1.3613 1.3613
3 3-1-2022 5-31-2022 1.1985 1.1985
4 6-1-2022 8-31-2022 1.1921 1.1921
5 9-1-2022 11-30-2022 1.1918 1.1918
6 12-1-2022 2-28-2023 1.0774 1.0774
7 3-1-2023 5-31-2023 1.0320 1.0320
8 6-1-2023 8-31-2023 1.0260 1.0260
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 5 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4178

2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Area 5.1437 0.2950 10.3804 1.6700e-
003

0.0714 0.0714 0.0714 0.0714 0.0000 220.9670 220.9670 0.0201 3.7400e- 003
222.5835
Energy 0.1398 1.2312 0.7770 7.6200e-
003

0.0966 0.0966 0.0966 0.0966 0.0000 3,896.073
2 3,896.073
2 0.1303 0.0468 3,913.283
3 Mobile 1.5857 7.9962 19.1834 0.0821 7.7979 0.0580 7.8559 2.0895 0.0539 2.1434 0.0000 7,620.498 6 7,620.498
6 0.3407 0.0000 7,629.016
2 Waste 0.0000 0.0000 0.0000 0.0000 207.8079 0.0000 207.8079 12.2811 0.0000 514.8354 Water 0.0000 0.0000 0.0000 0.0000 29.1632 556.6420 585.8052 3.0183 0.0755 683.7567 Total 6.8692 9.5223 30.3407 0.0914 7.7979 0.2260 8.0240 2.0895 0.2219 2.3114 236.9712 12,294.18 07 12,531.15
19 15.7904 0.1260 12,963.47
51 Unmitigated Operational
9 9-1-2023 11-30-2023 1.0265 1.0265
10 12-1-2023 2-29-2024 2.8857 2.8857
11 3-1-2024 5-31-2024 1.6207 1.6207
Highest 2.8857 2.8857
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 6 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4179

0.0714 0.0714 0.0714 0.0714 0.0000 220.9670 220.9670 0.0201 3.7400e- 003
222.5835
Energy 0.1398 1.2312 0.7770 7.6200e-
003

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

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 7 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4180
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 9/1/2021 10/12/2021 5 30
2 Site Preparation Site Preparation 10/13/2021 11/9/2021 5 20 3 Grading Grading 11/10/2021 1/11/2022 5 45
4 Building Construction Building Construction 1/12/2022 12/12/2023 5 500 5 Paving Paving 12/13/2023 1/30/2024 5 35
6 Architectural Coating Architectural Coating 1/31/2024 3/19/2024 5 35 OffRoad Equipment
Residential Indoor: 2,025,000; Residential Outdoor: 675,000; Non-Residential Indoor: 326,400; Non-Residential Outdoor: 108,800; Striped Parking Area: 0 (Architectural Coating ±sqft)
Acres of Grading (Site Preparation Phase): 0
Acres of Grading (Grading Phase): 112.5
Acres of Paving: 0
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 8 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4181
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Demolition Concrete/Industrial Saws 1 8.00 81 0.73
Demolition Excavators 3 8.00 158 0.38
Demolition Rubber Tired Dozers 2 8.00 247 0.40
Site Preparation Rubber Tired Dozers 3 8.00 247 0.40
Site Preparation Tractors/Loaders/Backhoes 4 8.00 97 0.37 Grading Excavators 2 8.00 158 0.38
Grading Graders 1 8.00 187 0.41
Grading Rubber Tired Dozers 1 8.00 247 0.40
Grading Scrapers 2 8.00 367 0.48
Grading Tractors/Loaders/Backhoes 2 8.00 97 0.37
Building Construction Cranes 1 7.00 231 0.29
Building Construction Forklifts 3 8.00 89 0.20
Building Construction Generator Sets 1 8.00 84 0.74
Building Construction Tractors/Loaders/Backhoes 3 7.00 97 0.37 Building Construction Welders 1 8.00 46 0.45
Paving Pavers 2 8.00 130 0.42
Paving Paving Equipment 2 8.00 132 0.36
Paving Rollers 2 8.00 80 0.38
Architectural Coating Air Compressors 1 6.00 78 0.48
Trips and VMT
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 9 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4182

3.2 Demolition - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0496 0.0000 0.0496 7.5100e-
003

0.0000 7.5100e-
003

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 0.0475 0.4716 0.3235 5.8000e-
004

0.0233 0.0233 0.0216 0.0216 0.0000 51.0012 51.0012 0.0144 0.0000 51.3601 Total 0.0475 0.4716 0.3235 5.8000e-
004

0.0496 0.0233 0.0729 7.5100e-
003

0.0216 0.0291 0.0000 51.0012 51.0012 0.0144 0.0000 51.3601 Unmitigated Construction On-Site

3.1 Mitigation Measures Construction
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Demolition 6 15.00 0.00 458.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Site Preparation 7 18.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Grading 8 20.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Building Construction 9 801.00 143.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Paving 6 15.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Architectural Coating 1 160.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 10 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4183

3.2 Demolition - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 1.9300e-
003

0.0634 0.0148 1.8000e-
004

3.9400e-
003

1.9000e-
004

4.1300e-
003

1.0800e-
003

1.8000e-
004

1.2600e-
003

0.0000 17.4566 17.4566 1.2100e-
003

0.0000 17.4869
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 9.7000e-
004

7.5000e-
004

8.5100e-
003

2.0000e-
005

2.4700e-
003

2.0000e-
005

2.4900e-
003

6.5000e-
004

2.0000e-
005

6.7000e-
004

0.0000 2.2251 2.2251 7.0000e-
005

0.0000 2.2267
Total 2.9000e-
003

0.0641 0.0233 2.0000e-
004

6.4100e-
003

2.1000e-
004

6.6200e-
003

1.7300e-
003

2.0000e-
004

1.9300e-
003

0.0000 19.6816 19.6816 1.2800e-
003

0.0000 19.7136
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0496 0.0000 0.0496 7.5100e-
003

0.0000 7.5100e-
003

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 0.0475 0.4716 0.3235 5.8000e-
004

0.0233 0.0233 0.0216 0.0216 0.0000 51.0011 51.0011 0.0144 0.0000 51.3600 Total 0.0475 0.4716 0.3235 5.8000e-
004

0.0496 0.0233 0.0729 7.5100e-
003

0.0216 0.0291 0.0000 51.0011 51.0011 0.0144 0.0000 51.3600 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 11 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4184

0.0634 0.0148 1.8000e-
004

3.9400e-
003

1.9000e-
004

4.1300e-
003

1.0800e-
003

1.8000e-
004

1.2600e-
003

0.0000 17.4566 17.4566 1.2100e-
003

0.0000 17.4869
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 9.7000e-
004

7.5000e-
004

8.5100e-
003

2.0000e-
005

2.4700e-
003

2.0000e-
005

2.4900e-
003

6.5000e-
004

2.0000e-
005

6.7000e-
004

0.0000 2.2251 2.2251 7.0000e-
005

0.0000 2.2267
Total 2.9000e-
003

0.0641 0.0233 2.0000e-
004

6.4100e-
003

2.1000e-
004

6.6200e-
003

1.7300e-
003

2.0000e-
004

1.9300e-
003

0.0000 19.6816 19.6816 1.2800e-
003

0.0000 19.7136
Mitigated Construction Off-Site

3.3 Site Preparation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.1807 0.0000 0.1807 0.0993 0.0000 0.0993 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0389 0.4050 0.2115 3.8000e-
004

0.0204 0.0204 0.0188 0.0188 0.0000 33.4357 33.4357 0.0108 0.0000 33.7061 Total 0.0389 0.4050 0.2115 3.8000e-
004

0.1807 0.0204 0.2011 0.0993 0.0188 0.1181 0.0000 33.4357 33.4357 0.0108 0.0000 33.7061 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 12 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4185

3.3 Site Preparation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 7.7000e-
004

6.0000e-
004

6.8100e-
003

2.0000e-
005

1.9700e-
003

2.0000e-
005

1.9900e-
003

5.2000e-
004

1.0000e-
005

5.4000e-
004

0.0000 1.7801 1.7801 5.0000e-
005

0.0000 1.7814
Total 7.7000e-
004

6.0000e-
004

6.8100e-
003

2.0000e-
005

1.9700e-
003

2.0000e-
005

1.9900e-
003

5.2000e-
004

1.0000e-
005

5.4000e-
004

0.0000 1.7801 1.7801 5.0000e-
005

0.0000 1.7814
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.1807 0.0000 0.1807 0.0993 0.0000 0.0993 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0389 0.4050 0.2115 3.8000e-
004

0.0204 0.0204 0.0188 0.0188 0.0000 33.4357 33.4357 0.0108 0.0000 33.7060 Total 0.0389 0.4050 0.2115 3.8000e-
004

0.1807 0.0204 0.2011 0.0993 0.0188 0.1181 0.0000 33.4357 33.4357 0.0108 0.0000 33.7060 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 13 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4186

3.3 Site Preparation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 7.7000e-
004

6.0000e-
004

6.8100e-
003

2.0000e-
005

1.9700e-
003

2.0000e-
005

1.9900e-
003

5.2000e-
004

1.0000e-
005

5.4000e-
004

0.0000 1.7801 1.7801 5.0000e-
005

0.0000 1.7814
Total 7.7000e-
004

6.0000e-
004

6.8100e-
003

2.0000e-
005

1.9700e-
003

2.0000e-
005

1.9900e-
003

5.2000e-
004

1.0000e-
005

5.4000e-
004

0.0000 1.7801 1.7801 5.0000e-
005

0.0000 1.7814
Mitigated Construction Off-Site

3.4 Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.1741 0.0000 0.1741 0.0693 0.0000 0.0693 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0796 0.8816 0.5867 1.1800e-
003

0.0377 0.0377 0.0347 0.0347 0.0000 103.5405 103.5405 0.0335 0.0000 104.3776 Total 0.0796 0.8816 0.5867 1.1800e-
003

0.1741 0.0377 0.2118 0.0693 0.0347 0.1040 0.0000 103.5405 103.5405 0.0335 0.0000 104.3776 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 14 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4187

3.4 Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 1.6400e-
003

1.2700e-
003

0.0144 4.0000e-
005

4.1600e-
003

3.0000e-
005

4.2000e-
003

1.1100e-
003

3.0000e-
005

1.1400e-
003

0.0000 3.7579 3.7579 1.1000e-
004

0.0000 3.7607
Total 1.6400e-
003

1.2700e-
003

0.0144 4.0000e-
005

4.1600e-
003

3.0000e-
005

4.2000e-
003

1.1100e-
003

3.0000e-
005

1.1400e-
003

0.0000 3.7579 3.7579 1.1000e-
004

0.0000 3.7607
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.1741 0.0000 0.1741 0.0693 0.0000 0.0693 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0796 0.8816 0.5867 1.1800e-
003

0.0377 0.0377 0.0347 0.0347 0.0000 103.5403 103.5403 0.0335 0.0000 104.3775 Total 0.0796 0.8816 0.5867 1.1800e-
003

0.1741 0.0377 0.2118 0.0693 0.0347 0.1040 0.0000 103.5403 103.5403 0.0335 0.0000 104.3775 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 15 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4188

1.2700e-
003

0.0144 4.0000e-
005

4.1600e-
003

3.0000e-
005

4.2000e-
003

1.1100e-
003

3.0000e-
005

1.1400e-
003

0.0000 3.7579 3.7579 1.1000e-
004

0.0000 3.7607
Total 1.6400e-
003

1.2700e-
003

0.0144 4.0000e-
005

4.1600e-
003

3.0000e-
005

4.2000e-
003

1.1100e-
003

3.0000e-
005

1.1400e-
003

0.0000 3.7579 3.7579 1.1000e-
004

0.0000 3.7607
Mitigated Construction Off-Site

3.4 Grading - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0807 0.0000 0.0807 0.0180 0.0000 0.0180 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0127 0.1360 0.1017 2.2000e-
004

5.7200e-
003

5.2600e-
003

0.0000 19.0871 19.0871 6.1700e-
003

0.0000 19.2414
Total 0.0127 0.1360 0.1017 2.2000e-
004

0.0807 5.7200e-
003

0.0865 0.0180 5.2600e-
003

0.0233 0.0000 19.0871 19.0871 6.1700e-
003

0.0000 19.2414
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 16 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4189

3.4 Grading - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 2.8000e-
004

2.1000e-
004

2.4400e-
003

1.0000e-
005

7.7000e-
004

1.0000e-
005

7.7000e-
004

2.0000e-
004

1.0000e-
005

2.1000e-
004

0.0000 0.6679 0.6679 2.0000e-
005

0.0000 0.6684
Total 2.8000e-
004

2.1000e-
004

2.4400e-
003

1.0000e-
005

7.7000e-
004

1.0000e-
005

7.7000e-
004

2.0000e-
004

1.0000e-
005

2.1000e-
004

0.0000 0.6679 0.6679 2.0000e-
005

0.0000 0.6684
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0807 0.0000 0.0807 0.0180 0.0000 0.0180 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0127 0.1360 0.1017 2.2000e-
004

5.7200e-
003

5.2600e-
003

0.0000 19.0871 19.0871 6.1700e-
003

0.0000 19.2414
Total 0.0127 0.1360 0.1017 2.2000e-
004

0.0807 5.7200e-
003

0.0865 0.0180 5.2600e-
003

0.0233 0.0000 19.0871 19.0871 6.1700e-
003

0.0000 19.2414
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 17 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4190

2.1000e-
004

2.4400e-
003

1.0000e-
005

7.7000e-
004

1.0000e-
005

7.7000e-
004

2.0000e-
004

1.0000e-
005

2.1000e-
004

0.0000 0.6679 0.6679 2.0000e-
005

0.0000 0.6684
Total 2.8000e-
004

2.1000e-
004

2.4400e-
003

1.0000e-
005

7.7000e-
004

1.0000e-
005

7.7000e-
004

2.0000e-
004

1.0000e-
005

2.1000e-
004

0.0000 0.6679 0.6679 2.0000e-
005

0.0000 0.6684
Mitigated Construction Off-Site

0.1023 0.1023 0.0963 0.0963 0.0000 293.1324 293.1324 0.0702 0.0000 294.8881 Total 0.2158 1.9754 2.0700 3.4100e-
003

0.1023 0.1023 0.0963 0.0963 0.0000 293.1324 293.1324 0.0702 0.0000 294.8881 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 18 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4191

3.5 Building Construction - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0527 1.6961 0.4580 4.5500e-
003

0.1140 3.1800e-
003

0.1171 0.0329 3.0400e-
003

0.0359 0.0000 441.9835 441.9835 0.0264 0.0000 442.6435
Worker 0.4088 0.3066 3.5305 0.0107 1.1103 8.8700e-
003

1.1192 0.2949 8.1700e-
003

0.3031 0.0000 966.8117 966.8117 0.0266 0.0000 967.4773
Total 0.4616 2.0027 3.9885 0.0152 1.2243 0.0121 1.2363 0.3278 0.0112 0.3390 0.0000 1,408.795 2 1,408.795
2 0.0530 0.0000 1,410.120
8 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.2158 1.9754 2.0700 3.4100e-
003

0.1023 0.1023 0.0963 0.0963 0.0000 293.1321 293.1321 0.0702 0.0000 294.8877 Total 0.2158 1.9754 2.0700 3.4100e-
003

0.1023 0.1023 0.0963 0.0963 0.0000 293.1321 293.1321 0.0702 0.0000 294.8877 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 19 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4192

0.1140 3.1800e-
003

0.1171 0.0329 3.0400e-
003

0.0359 0.0000 441.9835 441.9835 0.0264 0.0000 442.6435
Worker 0.4088 0.3066 3.5305 0.0107 1.1103 8.8700e-
003

1.1192 0.2949 8.1700e-
003

0.0864 0.0864 0.0813 0.0813 0.0000 286.2789 286.2789 0.0681 0.0000 287.9814 Total 0.1942 1.7765 2.0061 3.3300e-
003

0.0864 0.0864 0.0813 0.0813 0.0000 286.2789 286.2789 0.0681 0.0000 287.9814 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 20 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4193

3.5 Building Construction - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0382 1.2511 0.4011 4.3000e-
003

0.1113 1.4600e-
003

0.1127 0.0321 1.4000e-
003

0.0335 0.0000 417.9930 417.9930 0.0228 0.0000 418.5624
Worker 0.3753 0.2708 3.1696 0.0101 1.0840 8.4100e-
003

1.0924 0.2879 7.7400e-
003

0.2957 0.0000 909.3439 909.3439 0.0234 0.0000 909.9291
Total 0.4135 1.5218 3.5707 0.0144 1.1953 9.8700e-
003

1.2051 0.3200 9.1400e-
003

0.3292 0.0000 1,327.336
9 1,327.336
9 0.0462 0.0000 1,328.491
6 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.1942 1.7765 2.0061 3.3300e-
003

0.0864 0.0864 0.0813 0.0813 0.0000 286.2785 286.2785 0.0681 0.0000 287.9811 Total 0.1942 1.7765 2.0061 3.3300e-
003

0.0864 0.0864 0.0813 0.0813 0.0000 286.2785 286.2785 0.0681 0.0000 287.9811 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 21 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4194

0.1113 1.4600e-
003

0.1127 0.0321 1.4000e-
003

0.0335 0.0000 417.9930 417.9930 0.0228 0.0000 418.5624
Worker 0.3753 0.2708 3.1696 0.0101 1.0840 8.4100e-
003

1.0924 0.2879 7.7400e-
003

0.2957 0.0000 909.3439 909.3439 0.0234 0.0000 909.9291
Total 0.4135 1.5218 3.5707 0.0144 1.1953 9.8700e-
003

1.2051 0.3200 9.1400e-
003

0.3292 0.0000 1,327.336
9 1,327.336
9 0.0462 0.0000 1,328.491
6 Mitigated Construction Off-Site

3.6 Paving - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 6.7100e-
003

0.0663 0.0948 1.5000e-
004

3.3200e-
003

3.0500e-
003

0.0000 13.0175 13.0175 4.2100e-
003

0.0000 13.1227
Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 6.7100e-
003

0.0663 0.0948 1.5000e-
004

3.3200e-
003

3.0500e-
003

0.0000 13.0175 13.0175 4.2100e-
003

0.0000 13.1227
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 22 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4195

3.6 Paving - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 3.7000e-
004

2.7000e-
004

3.1200e-
003

1.0000e-
005

1.0700e-
003

1.0000e-
005

1.0800e-
003

2.8000e-
004

1.0000e-
005

2.9000e-
004

0.0000 0.8963 0.8963 2.0000e-
005

0.0000 0.8968
Total 3.7000e-
004

2.7000e-
004

3.1200e-
003

1.0000e-
005

1.0700e-
003

1.0000e-
005

1.0800e-
003

2.8000e-
004

1.0000e-
005

2.9000e-
004

0.0000 0.8963 0.8963 2.0000e-
005

0.0000 0.8968
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 6.7100e-
003

0.0663 0.0948 1.5000e-
004

3.3200e-
003

3.0500e-
003

0.0000 13.0175 13.0175 4.2100e-
003

0.0000 13.1227
Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 6.7100e-
003

0.0663 0.0948 1.5000e-
004

3.3200e-
003

3.0500e-
003

0.0000 13.0175 13.0175 4.2100e-
003

0.0000 13.1227
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 23 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4196

2.7000e-
004

3.1200e-
003

1.0000e-
005

1.0700e-
003

1.0000e-
005

1.0800e-
003

2.8000e-
004

1.0000e-
005

2.9000e-
004

0.0000 0.8963 0.8963 2.0000e-
005

0.0000 0.8968
Total 3.7000e-
004

2.7000e-
004

3.1200e-
003

1.0000e-
005

1.0700e-
003

1.0000e-
005

1.0800e-
003

2.8000e-
004

1.0000e-
005

2.9000e-
004

0.0000 0.8963 0.8963 2.0000e-
005

0.0000 0.8968
Mitigated Construction Off-Site

3.6 Paving - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0109 0.1048 0.1609 2.5000e-
004

5.1500e-
003

4.7400e-
003

0.0000 22.0292 22.0292 7.1200e-
003

0.0000 22.2073
Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0109 0.1048 0.1609 2.5000e-
004

5.1500e-
003

4.7400e-
003

0.0000 22.0292 22.0292 7.1200e-
003

0.0000 22.2073
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 24 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4197

3.6 Paving - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 5.9000e-
004

4.1000e-
004

4.9200e-
003

2.0000e-
005

1.8100e-
003

1.0000e-
005

1.8200e-
003

4.8000e-
004

1.0000e-
005

4.9000e-
004

0.0000 1.4697 1.4697 4.0000e-
005

0.0000 1.4706
Total 5.9000e-
004

4.1000e-
004

4.9200e-
003

2.0000e-
005

1.8100e-
003

1.0000e-
005

1.8200e-
003

4.8000e-
004

1.0000e-
005

4.9000e-
004

0.0000 1.4697 1.4697 4.0000e-
005

0.0000 1.4706
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0109 0.1048 0.1609 2.5000e-
004

5.1500e-
003

4.7400e-
003

0.0000 22.0292 22.0292 7.1200e-
003

0.0000 22.2073
Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0109 0.1048 0.1609 2.5000e-
004

5.1500e-
003

4.7400e-
003

0.0000 22.0292 22.0292 7.1200e-
003

0.0000 22.2073
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 25 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4198

4.1000e-
004

4.9200e-
003

2.0000e-
005

1.8100e-
003

1.0000e-
005

1.8200e-
003

4.8000e-
004

1.0000e-
005

4.9000e-
004

0.0000 1.4697 1.4697 4.0000e-
005

0.0000 1.4706
Total 5.9000e-
004

4.1000e-
004

4.9200e-
003

2.0000e-
005

1.8100e-
003

1.0000e-
005

1.8200e-
003

4.8000e-
004

1.0000e-
005

4.9000e-
004

0.0000 1.4697 1.4697 4.0000e-
005

0.0000 1.4706
Mitigated Construction Off-Site

0.0213 0.0317 5.0000e-
005

1.0700e-
003

0.0000 4.4682 4.4682 2.5000e-
004

0.0000 4.4745
Total 4.1404 0.0213 0.0317 5.0000e-
005

1.0700e-
003

0.0000 4.4682 4.4682 2.5000e-
004

0.0000 4.4745
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 26 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4199

3.7 Architectural Coating - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0101 6.9900e-
003

0.0835 2.8000e-
004

0.0307 2.3000e-
004

0.0309 8.1500e-
003

2.2000e-
004

8.3700e-
003

0.0000 24.9407 24.9407 6.1000e-
004

0.0000 24.9558
Total 0.0101 6.9900e-
003

0.0835 2.8000e-
004

0.0307 2.3000e-
004

0.0309 8.1500e-
003

2.2000e-
004

8.3700e-
003

0.0000 24.9407 24.9407 6.1000e-
004

0.0000 24.9558
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Archit. Coating 4.1372 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 3.1600e-
003

0.0213 0.0317 5.0000e-
005

1.0700e-
003

0.0000 4.4682 4.4682 2.5000e-
004

0.0000 4.4745
Total 4.1404 0.0213 0.0317 5.0000e-
005

1.0700e-
003

0.0000 4.4682 4.4682 2.5000e-
004

0.0000 4.4745
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 27 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4200

4.0 Operational Detail - Mobile

4.1 Mitigation Measures Mobile

0.0835 2.8000e-
004

0.0307 2.3000e-
004

0.0309 8.1500e-
003

2.2000e-
004

8.3700e-
003

0.0000 24.9407 24.9407 6.1000e-
004

0.0000 24.9558
Total 0.0101 6.9900e-
003

0.0835 2.8000e-
004

0.0307 2.3000e-
004

0.0309 8.1500e-
003

2.2000e-
004

8.3700e-
003

0.0000 24.9407 24.9407 6.1000e-
004

0.0000 24.9558
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 28 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4201
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 1.5857 7.9962 19.1834 0.0821 7.7979 0.0580 7.8559 2.0895 0.0539 2.1434 0.0000 7,620.498 6 7,620.498
6 0.3407 0.0000 7,629.016
2 Unmitigated 1.5857 7.9962 19.1834 0.0821 7.7979 0.0580 7.8559 2.0895 0.0539 2.1434 0.0000 7,620.498 6 7,620.498
6 0.3407 0.0000 7,629.016
2 4.2 Trip Summary Information

4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Apartments Low Rise 145.75 154.25 154.00 506,227 506,227 Apartments Mid Rise 4,026.75 3,773.25 4075.50 13,660,065 13,660,065 General Office Building 288.45 62.55 31.05 706,812 706,812 High Turnover (Sit Down Restaurant) 2,368.80 2,873.52 2817.72 3,413,937 3,413,937 Hotel 192.00 187.50 160.00 445,703 445,703
Quality Restaurant 501.12 511.92 461.20 707,488 707,488 Regional Shopping Center 528.08 601.44 357.84 1,112,221 1,112,221 Total 8,050.95 8,164.43 8,057.31 20,552,452 20,552,452
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 29 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4202
Miles Trip % Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by Apartments Low Rise 14.70 5.90 8.70 40.20 19.20 40.60 86 11 3 Apartments Mid Rise 14.70 5.90 8.70 40.20 19.20 40.60 86 11 3 General Office Building 16.60 8.40 6.90 33.00 48.00 19.00 77 19 4 High Turnover (Sit Down
Restaurant)

16.60 8.40 6.90 8.50 72.50 19.00 37 20 43
Hotel 16.60 8.40 6.90 19.40 61.60 19.00 58 38 4
Quality Restaurant 16.60 8.40 6.90 12.00 69.00 19.00 38 18 44 Regional Shopping Center 16.60 8.40 6.90 16.30 64.70 19.00 54 35 11

5.0 Energy Detail

5.1 Mitigation Measures Energy

4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH Apartments Low Rise 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Apartments Mid Rise 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 General Office Building 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 High Turnover (Sit Down
Restaurant)

0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Hotel 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Quality Restaurant 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Regional Shopping Center 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Historical Energy Use: N
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 30 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4203
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Electricity
Mitigated

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

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

0.1398 1.2312 0.7770 7.6200e-
003

0.0966 0.0966 0.0966 0.0966 0.0000 1,383.426
7 1,383.426
7 0.0265 0.0254 1,391.647
8 NaturalGas
Unmitigated

0.1398 1.2312 0.7770 7.6200e-
003

0.0966 0.0966 0.0966 0.0966 0.0000 1,383.426
7 1,383.426
7 0.0265 0.0254 1,391.647
8 CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 31 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4204

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
Apartments Low
Rise
408494 2.2000e-
003

0.0188 8.0100e-
003

1.2000e-
004

1.5200e-
003

0.0000 21.7988 21.7988 4.2000e-
004

4.0000e-
004

21.9284
Apartments Mid
Rise

1.30613e
+007

0.0704 0.6018 0.2561 3.8400e-
003

0.0487 0.0487 0.0487 0.0487 0.0000 696.9989 696.9989 0.0134 0.0128 701.1408 General Office
Building
468450 2.5300e-
003

0.0230 0.0193 1.4000e-
004

1.7500e-
003

0.0000 24.9983 24.9983 4.8000e-
004

4.6000e-
004

25.1468
High Turnover (Sit
Down Restaurant)

8.30736e
+006

0.0448 0.4072 0.3421 2.4400e-
003

0.0310 0.0310 0.0310 0.0310 0.0000 443.3124 443.3124 8.5000e- 003

8.1300e-
003
445.9468
Hotel 1.74095e
+006

9.3900e-
003

0.0853 0.0717 5.1000e-
004

6.4900e-
003

0.0000 92.9036 92.9036 1.7800e-
003

1.7000e-
003

93.4557
Quality
Restaurant

1.84608e
+006

9.9500e-
003

0.0905 0.0760 5.4000e-
004

6.8800e-
003

0.0000 98.5139 98.5139 1.8900e-
003

1.8100e-
003

99.0993
Regional
Shopping Center
91840 5.0000e-
004

4.5000e-
003

3.7800e-
003

3.0000e-
005

3.4000e-
004

0.0000 4.9009 4.9009 9.0000e-
005

9.0000e-
005

4.9301
Total 0.1398 1.2312 0.7770 7.6200e-
003

0.0966 0.0966 0.0966 0.0966 0.0000 1,383.426
8 1,383.426
8 0.0265 0.0254 1,391.647
8 Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 32 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4205

0.0188 8.0100e-
003

1.2000e-
004

1.5200e-
003

0.0000 21.7988 21.7988 4.2000e-
004

4.0000e-
004

21.9284
Apartments Mid
Rise

1.30613e
+007

0.0704 0.6018 0.2561 3.8400e-
003

0.0487 0.0487 0.0487 0.0487 0.0000 696.9989 696.9989 0.0134 0.0128 701.1408 General Office
Building
468450 2.5300e-
003

0.0230 0.0193 1.4000e-
004

1.7500e-
003

0.0000 24.9983 24.9983 4.8000e-
004

4.6000e-
004

25.1468
High Turnover (Sit
Down Restaurant)

8.30736e
+006

0.0448 0.4072 0.3421 2.4400e-
003

0.0310 0.0310 0.0310 0.0310 0.0000 443.3124 443.3124 8.5000e- 003

8.1300e-
003
445.9468
Hotel 1.74095e
+006

9.3900e-
003

0.0853 0.0717 5.1000e-
004

6.4900e-
003

0.0000 92.9036 92.9036 1.7800e-
003

1.7000e-
003

93.4557
Quality
Restaurant

1.84608e
+006

9.9500e-
003

0.0905 0.0760 5.4000e-
004

6.8800e-
003

0.0000 98.5139 98.5139 1.8900e-
003

1.8100e-
003

99.0993
Regional
Shopping Center
91840 5.0000e-
004

4.5000e-
003

3.7800e-
003

3.0000e-
005

3.4000e-
004

0.0000 4.9009 4.9009 9.0000e-
005

9.0000e-
005

4.9301
Total 0.1398 1.2312 0.7770 7.6200e-
003

0.0966 0.0966 0.0966 0.0966 0.0000 1,383.426
8 1,383.426
8 0.0265 0.0254 1,391.647
8 Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 33 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4206

5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
Apartments Low
Rise
106010 33.7770 1.3900e-
003

2.9000e-
004

33.8978
Apartments Mid
Rise

3.94697e
+006
1,257.587
9 0.0519 0.0107 1,262.086
9 General Office
Building
584550 186.2502 7.6900e-
003

1.5900e-
003
186.9165
High Turnover (Sit
Down Restaurant)

1.58904e
+006
506.3022 0.0209 4.3200e-
003
508.1135
Hotel 550308 175.3399 7.2400e-
003

1.5000e-
003
175.9672
Quality
Restaurant
353120 112.5116 4.6500e-
003

9.6000e-
004
112.9141
Regional
Shopping Center
756000 240.8778 9.9400e-
003

2.0600e-
003
241.7395
Total 2,512.646
5 0.1037 0.0215 2,521.635
6 Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 34 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4207

6.1 Mitigation Measures Area

6.0 Area Detail

5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
Apartments Low
Rise
106010 33.7770 1.3900e-
003

2.9000e-
004

33.8978
Apartments Mid
Rise

3.94697e
+006
1,257.587
9 0.0519 0.0107 1,262.086
9 General Office
Building
584550 186.2502 7.6900e-
003

1.5900e-
003
186.9165
High Turnover (Sit
Down Restaurant)

1.58904e
+006
506.3022 0.0209 4.3200e-
003
508.1135
Hotel 550308 175.3399 7.2400e-
003

1.5000e-
003
175.9672
Quality
Restaurant
353120 112.5116 4.6500e-
003

9.6000e-
004
112.9141
Regional
Shopping Center
756000 240.8778 9.9400e-
003

2.0600e-
003
241.7395
Total 2,512.646
5 0.1037 0.0215 2,521.635
6 Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 35 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4208
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 5.1437 0.2950 10.3804 1.6700e-
003

0.0714 0.0714 0.0714 0.0714 0.0000 220.9670 220.9670 0.0201 3.7400e- 003
222.5835
Unmitigated 5.1437 0.2950 10.3804 1.6700e-
003

0.0714 0.0714 0.0714 0.0714 0.0000 220.9670 220.9670 0.0201 3.7400e- 003
222.5835

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

0.4137 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

4.3998 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Hearth 0.0206 0.1763 0.0750 1.1200e-
003

0.0143 0.0143 0.0143 0.0143 0.0000 204.1166 204.1166 3.9100e- 003

3.7400e-
003
205.3295
Landscaping 0.3096 0.1187 10.3054 5.4000e-
004

0.0572 0.0572 0.0572 0.0572 0.0000 16.8504 16.8504 0.0161 0.0000 17.2540 Total 5.1437 0.2950 10.3804 1.6600e-
003

0.0714 0.0714 0.0714 0.0714 0.0000 220.9670 220.9670 0.0201 3.7400e- 003
222.5835
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 36 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4209

7.1 Mitigation Measures Water

7.0 Water Detail

0.4137 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

4.3998 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Hearth 0.0206 0.1763 0.0750 1.1200e-
003

0.0143 0.0143 0.0143 0.0143 0.0000 204.1166 204.1166 3.9100e- 003

3.7400e-
003
205.3295
Landscaping 0.3096 0.1187 10.3054 5.4000e-
004

0.0572 0.0572 0.0572 0.0572 0.0000 16.8504 16.8504 0.0161 0.0000 17.2540 Total 5.1437 0.2950 10.3804 1.6600e-
003

0.0714 0.0714 0.0714 0.0714 0.0000 220.9670 220.9670 0.0201 3.7400e- 003
222.5835
Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 37 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4210
Total CO2 CH4 N2O CO2e
Category MT/yr
Mitigated 585.8052 3.0183 0.0755 683.7567
Unmitigated 585.8052 3.0183 0.0755 683.7567
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 38 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4211

7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
Apartments Low
Rise

1.62885 /

1.02688

10.9095 0.0535 1.3400e-
003

12.6471
Apartments Mid
Rise

63.5252 /

40.0485
425.4719 2.0867 0.0523 493.2363
General Office
Building

7.99802 /

4.90201

53.0719 0.2627 6.5900e-
003

61.6019
High Turnover (Sit
Down Restaurant)

10.9272 /

0.697482

51.2702 0.3580 8.8200e-
003

62.8482
Hotel 1.26834 /

0.140927

6.1633 0.0416 1.0300e-
003

7.5079
Quality
Restaurant

2.42827 /

0.154996

11.3934 0.0796 1.9600e-
003

13.9663
Regional
Shopping Center

4.14806 /

2.54236

27.5250 0.1363 3.4200e-
003

31.9490
Total 585.8052 3.0183 0.0755 683.7567
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 39 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4212

8.1 Mitigation Measures Waste

7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
Apartments Low
Rise

1.62885 /

1.02688

10.9095 0.0535 1.3400e-
003

12.6471
Apartments Mid
Rise

63.5252 /

40.0485
425.4719 2.0867 0.0523 493.2363
General Office
Building

7.99802 /

4.90201

53.0719 0.2627 6.5900e-
003

61.6019
High Turnover (Sit
Down Restaurant)

10.9272 /

0.697482

51.2702 0.3580 8.8200e-
003

62.8482
Hotel 1.26834 /

0.140927

6.1633 0.0416 1.0300e-
003

7.5079
Quality
Restaurant

2.42827 /

0.154996

11.3934 0.0796 1.9600e-
003

13.9663
Regional
Shopping Center

4.14806 /

2.54236

27.5250 0.1363 3.4200e-
003

31.9490
Total 585.8052 3.0183 0.0755 683.7567
Mitigated

8.0 Waste Detail
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 40 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4213
Total CO2 CH4 N2O CO2e
MT/yr
Mitigated 207.8079 12.2811 0.0000 514.8354
Unmitigated 207.8079 12.2811 0.0000 514.8354
Category/Year
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 41 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4214

8.2 Waste by Land Use
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
Apartments Low
Rise

11.5 2.3344 0.1380 0.0000 5.7834
Apartments Mid
Rise
448.5 91.0415 5.3804 0.0000 225.5513
General Office
Building

41.85 8.4952 0.5021 0.0000 21.0464
High Turnover (Sit
Down Restaurant)
428.4 86.9613 5.1393 0.0000 215.4430
Hotel 27.38 5.5579 0.3285 0.0000 13.7694
Quality
Restaurant

7.3 1.4818 0.0876 0.0000 3.6712
Regional
Shopping Center

58.8 11.9359 0.7054 0.0000 29.5706
Total 207.8079 12.2811 0.0000 514.8354
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 42 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4215

8.2 Waste by Land Use
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
Apartments Low
Rise

11.5 2.3344 0.1380 0.0000 5.7834
Apartments Mid
Rise
448.5 91.0415 5.3804 0.0000 225.5513
General Office
Building

41.85 8.4952 0.5021 0.0000 21.0464
High Turnover (Sit
Down Restaurant)
428.4 86.9613 5.1393 0.0000 215.4430
Hotel 27.38 5.5579 0.3285 0.0000 13.7694
Quality
Restaurant

7.3 1.4818 0.0876 0.0000 3.6712
Regional
Shopping Center

58.8 11.9359 0.7054 0.0000 29.5706
Total 207.8079 12.2811 0.0000 514.8354
Mitigated

9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type

10.0 Stationary Equipment
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 43 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4216

11.0 Vegetation
Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment
Equipment Type Number
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 44 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual 12-4217

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
2028Operational Year
CO2 Intensity
(lb/MWhr)
702.44 0.029CH4 Intensity
(lb/MWhr)

0.006N2O Intensity
(lb/MWhr)
Village South Specific Plan (Proposed)
Los Angeles-South Coast County, Summer
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:54 PMPage 1 of 35 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer 12-4218
Project Characteristics - Consistent with the DEIR's model.