Agenda packet, first session — Santa Monica City Council, September 22, 2026 (part 4 of 5)

0.007267
2044 0.007259
243 72 11 610
243 71 11 609
243 71 11 609
243 71 11 609
2043

0.007289
243 73 11 611
243 73 11 611
243 73 11 611
2036 0.007314
2042 $67,028 $41,893 $108,921
2043 $66,990 $41,869 $108,859
2044 $66,952 $41,845 $108,797
2039 $67,143 $41,964 $109,107
2040 $67,105 $41,941 $109,046
2041 $67,067 $41,917 $108,983
2036 $67,231 $42,019 $109,250
2037 $67,202 $42,001 $109,203
2038 $67,172 $41,983 $109,155
2034 $67,289 $42,056 $109,345
243 75 11 612
2035 $67,260 $42,038 $109,298
243 74 11 612
243 74 11 612
243 74 11 611

0.007353
2030 0.007349
2031 0.007344
Targets
2033 $67,319 $42,074 $109,393
243 75 10 613
Fixture Costs
243 75 10 613
243 76 10
243 77 9 613
243 77 9 613 2025
10 613
243 77 10 613 2027 0.007358
2028 2028 0.007355
2031 $67,377 $42,111 $109,488
2032 $67,348 $42,093 $109,441
2029 $67,436 $42,147 $109,583
2030 $67,407 $42,129 $109,536
$109,625
2023 $67,487 $42,179 $109,666
2024 $67,478
2027 $67,453 $42,158 $109,611
$67,444 $42,153
Wash Dow n
MF_2022 $110.00 $100.00 1
CI $110.00 $100.00 1
Process
Kitchen Spray Rinse
Description
The City's Water Conservation requirements SMMC

7.16.020 prohibits the waste of water outdoors, including failure to repair leaks in a timely manner. Water waste enforcement is handled for reported violations with
Notices of Violation sent to the property's account
holder. A contract is being finalized for nighttime water waste patrols. A component of this program could be to
provide coupons for saving water and money at a
certified water smart car wash. Water smart car washes
recycle water on-site or send it to a water treatment
facility where the water is treated, recycled and reused.

Some establishments may go waterless, providing car
cleaning services with environmentally-friendly products using little or no water. Coupons may only be redeemed
at a participating retailer. Coupons could be presented at the time of purchase. Water Resources Protection could
provide coupons when addressing water runoff issues.

Comments
$109,597
2025 $67,470 $42,169 $109,638
2026 $67,461 $42,163
$42,174 $109,652
Name

NEW ADNEW M
Overview
Enforcement: Outdoor Water Waste
INST $110.00 $100.00 1
Administration Costs
Markup Percentage 63%
Internal Leakage
Baths
Other
Irrigation
Pools
NEW A
Utility Customer Fix/Acct
SF $110.00 $50.00 1
Fixture Cost per Device
Measure Life
2023 Permanent ####
Last Year 2045
Measure Length 23
Abbr
Category
Measure Type
Time Period
First Year
15 2
1 Years 3
Repeat ####
Customer Classes SFMF_202 CI LSINST FI
End Uses
SFMF_20CILSINSTFI
Toilets
NEW M
Urinals
Lavatory Faucets
Show ers
Dishw ashers
Cooling
Car Washing
External Leakage
Outdoor
Non-Lavatory/Kitchen Faucets
Clothes Washers
Results
Average Water Savings (mgd)

0.007000
Lifetime Savings - Present Value ($)
Utility $123,747
Community $123,747
Lifetime Costs - Present Value ($)
Utility $1,549,306
Community $2,215,339
Benefit to Cost Ratio
Utility 0.08
Community 0.06
Cost of Savings per Unit Volume ($/mg)
Utility $26,346
End Use Savings Per Replacement
% Savings/Acct Avg GPD/Acct
SF Irrigation 3.0% 45.5
MF_2022 Irrigation 3.0% 13.6
CI Irrigation 3.0% 63.2
INST Irrigation 3.0% 51.7
SF Wash Dow n 3.0% 2.2
MF_2022 Wash Dow n 3.0% 0.7
SF Car Washing 3.0% 2.2
MF_2022 Car Washing 3.0% 0.7
SF External Leakage 95.0% 3.8
MF_2022 External Leakage 95.0% 1.1
CI External Leakage 95.0% 5.7
INST External Leakage 95.0% 5.0
% of Accts Targeted/Yr 3.500%
Only Affects New Accts FALSE
283
2034 283
2031 283

0.002455
243 78 9 613 2024 0.004909
243 78 9 614 2023
613 2029

0.007363
2026 0.007360
243 76
283
2037 283
2038 283
2023 283
2024 283
2025 283
2026 283
2027 283
2028 283
2029 283
2030 283
2032 283
2033
2044 283
2032 0.007338
2033 0.007332
2034 0.007326
2035 0.007320
2039 283
2040 283
2041 283
2042 283
2043 283
2035 283
2036
Method:

Units
Method:

Target Method:

View: View Units

7.A.g
Packet Pg. 978 Attachment: Santa Monica FINAL WCMP_2024-3-29_Submitted (7722 : Sustainable Water Master Plan Update) City of Santa Monica Water Conservation Management Plan 77 Measure 16: Compliance: CA Water Budgeting (Dedicated Irrigation Meters) ## ## ## ## ## ## ## ##
##
##
2044 $0 $0 $0
2045 $0 $0 $0
Targets
2044 0 0
2045 0 0
0 0
$0
$0 $0
0 0
2042
2041 0.000000
2042 0.000000
2043 0.000000
2036 0.097659
2037 0.049029
2038 0.000000
2039 0.000000
2040 0.000000
2044 0.000000
2045 0.000000
2036
2040
2041 $0 $0 $0
2036 $0 $0 $0
2037 $0 $0 $0
2038 $0
2041
2039
$0 $0
$0 $0 $0
2043 $0 $0 $0
0 0
2042 0 0
2043 0 0
0 2039 $0 $0 $0
2040
2035 $86,032 $125,235 $211,267 2035 501 501
2030 0.139062
2031 0.141113
2032 0.142308
2033 0.143502
2034 0.144697
2035 0.145892
0 0
2037 0 0
2038 0
Total Savings (mgd)
2023 0.000000

0.000000
2025 0.041620
2026 0.084495
2027 0.128625
2024
2027 451 451
2025 425
2028 0.132389
2029 0.136154
497
2029
2028 464 464
497
2031 $84,608 $121,166 $205,774
2032 $84,964
2030 $84,252 $120,149 $204,401
2034 $85,676 $124,218 $209,894
$122,183 $207,147
2033 $85,320 $123,200 $208,521
477 477
2023 0 0
2024 0
2030 481 481
2031 485 485
2032 489 489
2033 493 493
0 2034
2025 $79,409 $106,310 $185,719 425
2026 438 438
2029 $83,896 $119,131 $203,028
2026 $80,531 $109,516 $190,046
2027 $81,652 $112,721 $194,373
2028 $82,774 $115,926 $198,700
Avg GPD/Acct
Non-Lavatory/Kitchen Faucets
Comments
Car Washing
% of Accts Targeted/Yr 60.000%
2023 $0
2024 $0
Water Savings
As of March 2023, SWRCB timeline states the CII DIM
requirement will go into effect in summer 2024, thus
starting measure in 2025.
>Utility & Admin Costs: Per Tom, the estimated annual
utility cost will be $35,000 for the WaterView
subscription. Assume this cost for conducting 400 CII
DIM assessments annually. It is estimated that approx.

0.25 of an FTE is spent on this measure per year
collaborating. (Assume Specialist is administering this measure- total burdened salary of $168,827 x .25=
about $42,200 annually.) Subscription costs are tracked as utility fixture costs; whereas staff mgmt. time is
tracked in admin costs to better track staffing
accurately.
>Customer Cost: Customer cost represents average
cost to implement any water saving actions done by
customers as a result of their budget.
>End Use Savings: Using various program estimates, on
average, customers are 15% over budget or "expected"
water use. Customers will become slightly more
efficient on average due to the cost of being
inefficient.
>Targets: Per Tom, target 400 CII DIM Accounts
(estimate). This would be 60% of the 666 start year LS
accounts.

Costs
LS Total
$0 $0
$0 $0
Utility Customer Total
$1,330,465
Lifetime Costs - Present Value ($)
Utility $658,516
Results
Average Water Savings (mgd)

0.066371
MF_20CILSNEW M
Lavatory Faucets
LS External Leakage 15.0% 45.7
Only Affects New Accts FALSE
Administration Costs
Show ers
Benefit to Cost Ratio
Utility 2.02
Community 0.84
External Leakage
Outdoor
Annual Admin Costs $42,200
Description LS Irrigation
% Savings/Acct
Conduct detailed landscape area
measurements for CII dedicated irrigation
accounts. Can use aerial imagery including
freely-available National Agricultural Aerial
Program (NAIP) Imagery. The recommended
standard would require urban retail water
suppliers to identify dedicated irrigation
meters (DIMs) and measure the associated
irrigated CII landscapes within five years after
the State Water Board adopts the regulation.

The total landscape area will be incorporated
into a landscape water use equation/standard
(provided by DWR) to produce a supplier level
CII landscape budget in gallons. The state will
not enforce CII landscape budgets for
individual parcels/customers. Also includes
requirements for new MF and CII
developments to install dedicated irrigation
meters and SF accounts with greater than
5,000' of irrigation to install a dedicated
landscape meter. This is already specified in
Santa Monica's WELIS and enforced in plan
check.

Urinals
Targets
Utility Customer Fix/Acct
606.8
LS $87.50 $250.00 1 Cost of Savings per Unit Volume ($/mg) Utility
Fixture Cost per Device
Wash Dow n
Cooling
Dishw ashers
Clothes Washers
Process
Kitchen Spray Rinse
Internal Leakage
Baths
Pools
Category 2
Measure Life
Permanent ####
Years 3
Repeat
Time Period
Measure Type 1
First Year 2025
Last Year 2035
Measure Length 11 ####
End Uses

15.0%
MF_202CI
Community
Toilets
Customer Classes SF
$1,586,167

SFINSTFINEW A
Lifetime Savings - Present Value ($)
Other
Irrigation
$1,181
End Use Savings Per Replacement
Utility $1,330,465
Community
Overview
Name Compliance: CA Water Budgeti
Abbr 16

LSINSTFINEW ANEW M
Method:

Units
Method:

Target Method:

View: View Units

7.A.g
Packet Pg. 979 Attachment: Santa Monica FINAL WCMP_2024-3-29_Submitted (7722 : Sustainable Water Master Plan Update) 1 Clerk Mailbox
From: Nikki Kolhoff <[email protected]>
Sent: Tuesday, September 22, 2026 2:41 PM
To: Clerk Mailbox
Cc: Heidi von Tongeln
Subject: Fw: City Council 9/22/26 - Item 7A - CEQA Exemption is not Appropriate for Contaminated Business Park Development
Attachments: 2026-04-07 CoSM Letter to RWQCB_Boeing Soil Management Plan_040726_FINAL.pdf; 2026-06-24 SCP 0130B_Boeing SM_Response to Friends of Sunset Park_06_24_2026 _Final.pdf; 2026-03-19 Friends of Sunset Park Letter 3_19_2026.pdf; 2026-08-11 City Response to FOSP re CEQA exemption for business park.pdf

EXTERNAL
There are no public comments posted to Item 7A. Please post this.

Thanks,
Nikki Kolhoff
----- Forwarded Message -----
From: Nikki Kolhoff <[email protected]>
To: [email protected] <[email protected]>; City Clerk <[email protected]> Sent: Tuesday, September 22, 2026 at 12:20:22 PM PDT
Subject: Fw: City Council 9/22/26 - Item 7A - CEQA Exemption is not Appropriate for Contaminated Business Park Development
Hello -
I sent this to all council members but inadvertently left off the meeting email. Please make sure this is in the public comment packet as it was sent before noon.

Thanks,
Nikki
----- Forwarded Message -----
From: Nikki Kolhoff <[email protected]>
To: Lana Negrete <[email protected]>; Caroline Torosis <[email protected]>; Jesse Zwick <[email protected]>; Natalya Zernitskaya <[email protected]>; Ellis Raskin <[email protected]>; Barry Snell <[email protected]>; Dan Hall <[email protected]> Cc: Oliver Chi <[email protected]>; Heidi Von Tongeln <[email protected]>; Jing Yeo <[email protected]>; Ross Fehrman <[email protected]>; Rachel Kwok <[email protected]>
Sent: Tuesday, September 22, 2026 at 11:42:16 AM PDT
Subject: City Council 9/22/26 - Item 7A - CEQA Exemption is not Appropriate for Contaminated Business Park Development
City Council -
Regarding the deteriorating state of Santa Monica's quest for water self-sufficiency, it's worth reminding everyone that development further impedes this goal. While the state has exempted most new development from CEQA, the city can still require a CEQA review if there is a risk to public Item 7-A
September 22, 2026
Item 7-A
September 22, 2026

7.A.h
Packet Pg. 980 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) 2 health and safety, which there is when we have insufficient water, risk of contamination, and harm to residents.

Specifically with regard to the Airport Business Park, which is the former site of aerospace and missile manufacturing, it must be acknowledged that the land is contaminated and failure to remediate further jeopardizes our groundwater and ability to achieve water independence. Given the serious nature of the identified health hazards that would take it out of any claimed CEQA exemption, discussion among two government agencies is no substitute for CEQA's public review and comment process and City Council hearing. Ministerial approval of residential projects is not warranted, and conversely requiring us to accept residential development on contaminated land exposes the fallacy of these state laws pushed by the YIMBY/Abundance lobby.

The following are attached as evidence of contamination at the Business Park and the need for environmental investigation and remediation.

1. March 19, 2026 - Friends of Sunset Park wrote a detailed letter to the Regional Water Quality Board and the CITY PLANNING DEPARTMENT on March 19, 2026, analyzing the issues of contamination of the former Boeing properties now being proposed for residential housing, asking that CEQA be applied for full review of theses issues.

2. April 7, 2026 Letter from City Staff to Regional Water Quality Control Board - "The City respectfully requests that these issues be addressed before approval of redevelopment-related SMP implementation so that soil management activities are carried out in a manner that is consistent, transparent, and protective of human health, groundwater resources, and nearby sensitive receptors."

3. June 24, 2026 - Letter from Regional Water Quality Control Board - The RWQB responded to all points raised by FOSP, and agreed with many of its comments regarding contamination and remediation, but as to CEQA, stated: "The City of Santa Monica is the Lead Agency for the CEQA related to the proposed redevelopment projects at 2716 Ocean Park Boulevard and 2800 28th Street. The Los Angeles Water Board was not involved in any city-sponsored public outreach programs presented by developers as referenced in the Letter."

4. August 11, 2026 Anonymous 311 Response - FOSP submitted a question to Jing Yeo regarding the prior correspondence asking when the City would initiate an environmental review. Instead of responding directly, Jing created a 311 request and an anonymous response was generated stating, "Please note that the two referenced housing projects are Administrative Approvals and are therefore ministerial actions not subject to CEQA. The RWQCB and/or other regional agencies have jurisdictional oversight over any required cleanup and remediation of the site, if deemed necessary.

The City does require that prior to issuance of certificate of occupancy for the project sites, the sites have received a determination from the Regional Water Quality Control Board or other appropriate oversight agency that the site is suitable for residential or residential mixed use." In other words, the City plans to do nothing and let the development proceed with no environmental review of known contamination.

Please instruct staff to take the following actions immediately:

1. Seek an exception from the CEQA exemptions based on risk to health and safety;

2. Halt the processing of all development applications in the Airport Business Park; Item 7-A
September 22, 2026
Item 7-A
September 22, 2026

7.A.h
Packet Pg. 981 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) 3 3. Commence an environmental analysis of the hazards identified, and the recommendations issued, with appropriate mitigation measures to be adopted under CEQA.

Surely the production of housing units is not the only metric by which we evaluate "progress". It is dangerous, irresponsible, and puts our water supply, health and safety at risk to exempt known contamination from the CEQA process. It is your duty to protect the health and safety of Santa Monica residents and ensure future access to clean water. This requires you to seek an exception to the CEQA exemptions for development in the known contaminated site of the Airport Business Park, and conduct a full environmental review and require full remediation and mitigation of all identified harms.

Regards,
Nikki Kolhoff
Sunset Park Resident
City Clerk: Please include this email and all four attachments in the public comment packet.

Item 7-A
September 22, 2026
Item 7-A
September 22, 2026

7.A.h
Packet Pg. 982 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) Caution: External Email. Use caution when clicking links or opening attachments. When in doubt, contact DIT or use the Phish Alert Button.

To: WB-DIT-info4 <[email protected]>
Subject: Letter from FOSP board (Santa Monica neighborhood organization) March 19, 2026
Board Members and Executive Officer
Los Angeles Regional Water Quality Control Board
320 W. 4th Street, Suite 200
Los Angeles, CA 90013
Re: Public Comment for March 26, 2026 RWQB Meeting
And Re: City review of Residential Developments in Santa Monica Business Park Dear Regional Water Quality Board:

The Board of Directors of Friends of Sunset Park (FOSP), a nonprofit neighborhood community representing residents living adjacent to, and directly affected by, activities at and around Santa Monica Airport and the Santa Monica Business Park, submits this letter to expand on concerns previously raised in our February 7, 2024, correspondence to the Regional Water Quality Control Board, given that there are now pending applications for large residential developments on the Business Park parcels.

Friends of Sunset Park submits these comments based on information gleaned from the 2023 Historic Use Analysis of the Business Park, as well as the 2025 "Public Participation Plan" for the Boeing Former Douglas Aircraft Company Plant A Site, prepared for The Boeing Company, as well as the city-sponsored public outreach programs presented by developers concerning proposed development of two side-byside 8-story multi-unit residential buildings at 2716 Ocean Park Boulevard and 2800 28th Street. These disjointed and highly technical information programs are not a proper substitute for CEQA review, which is designed and intended to allow far more rigorous public comment and participation, through the formal legal processes established by statute. Nor does anything in the reports justify avoidance of a full remediation requirement of the subject properties. Because it appears that things are proceeding apace under the public radar, this is causing concern for our members.

Our organization is concerned that the developers’ public outreach and the “Public Participation Plan,” as circulated, are materially inadequate because they do not clearly explain to our residents, or the decision-makers, or prospective occupants, the continuing health and safety significance of unresolved volatile organic compound (“VOC”) contamination underlying portions of the former Douglas Aircraft Company Plant A area, including the portions extending westward toward 25th Street and the parcels now under consideration for high-density residential development at 2716 Ocean Park Boulevard and 2800 28th Street.

Item 7-A
September 22, 2026
Item 7-A
September 22, 2026

7.A.h
Packet Pg. 983 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) Failure to Explain Specific Residential Health Risks
The technical materials referenced in the underlying site reports identify continuing unresolved contamination concerns in Subareas C, D, E, and F, including:
persistent high VOC concentrations in field gas zones underlying former source areas despite more than a decade of soil vapor extraction;
documented historical presence of Trichloroethylene and 1,1-Dichloroethylene in soil vapor and perched groundwater to depths approaching 90 feet below ground surface; downgradient detections indicating possible continuing plume migration; acknowledged need for further lateral and vertical delineation, including westward migration concerns toward Clover Park and adjacent residential areas.

Yet the Public Participation Plan does not explain in plain language that these contaminants present potential vapor intrusion risks to future residents, particularly:
children,
pregnant women,
elderly occupants, and
persons subject to long-duration indoor exposure.

A public participation document that omits a clear explanation of possible vapor intrusion pathways, sub-slab migration, and indoor-air exposure, cannot reasonably be considered effective public notice.

We are specifically concerned about proposals for residential development at 2716 Ocean Park Blvd and 2800 28th Street, and any other proposals in Subareas C, D, E, and F, in light of the documented presence of volatile organic compounds (VOCs) in soil vapor, perched groundwater, and the regional aquifer beneath and downgradient of these areas. The 2023 “Historical Use Analysis Report” by Advisian for the Santa Monica Airport area, as far as we can tell, identifies numerous problems to be addressed, listed at pp 94-95, including but not limited to:

Persistent, elevated VOC concentrations in fine‑grained zones beneath the former DAC Plant A area that have not significantly decreased after many years of soil vapor extraction, indicating a long‑term subsurface VOC reservoir.

Historical detections of trichloroethylene (TCE) and 1,1‑dichloroethene (1,1‑DCE) in soil vapor and perched groundwater in the vadose zone (to depths of approximately 90 feet) along the western portion of the site, and a clear recommendation for additional lateral and vertical delineation, including within and beneath Clover Park.

Consistent detections of 1,1‑DCE at monitoring well MW‑8 in the regional aquifer downgradient of the site since 2019, suggesting an actively migrating VOC plume whose full extent and behavior are not yet fully understood.

An explicit warning that before Airport #1 WSW or any proposed water‑supply wells in Item 7-A
September 22, 2026
Item 7-A
September 22, 2026

7.A.h
Packet Pg. 984 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) the area are brought into production, potential changes to the groundwater flow regime and effects on contaminant concentrations must be evaluated, along with further vadose‑zone characterization to understand VOC migration to the regional aquifer.

These findings underscore that the subsurface conditions remain incompletely characterized and that significant contamination persists in both the vadose zone and groundwater. While such conditions are already a cause for concern for commercial and industrial uses, they are fundamentally incompatible with high‑density residential development—especially when that development would house children, pregnant women, and other sensitive populations.

REMEDIATION IS WARRANTED
Per City of Santa Monica Planning Ordinance, a Phase 2 ESA site investigation is required for the entire Business Park properties prior to construction of multi-family residential housing. The field efforts should include soil vapor, soil, and groundwater sampling and chemical analysis for PCOC to protect public health and safety. BXP and Watt will be required to determine the extent of the contamination on their parcels. Here is the City of Santa Monica regulation, Section 9.31.195 F.:

Phase 1 Environmental Site Assessment. Multiple-unit dwelling projects in nonresidential districts or on a site identified on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 shall conduct a Phase 1 Environmental Site Assessment to investigate for the presence of hazardous materials and/or waste contamination. If the Phase 1 ESA finds that contaminated soil or groundwater is suspected to be present, the Applicant shall perform soil sampling and analysis to determine the extent of contamination. If contaminants are detected in soil at or above regulatory levels, then the results of the soil sampling shall be reviewed and acted upon by the appropriate regional, state, or local regulatory agencies as needed. If remediation is necessary, a No Further Action letter or similar documentation indicating case closure shall be obtained under the appropriate oversight agency prior to project occupancy. (emph. added) From a community‑health perspective, residential uses pose a very different risk profile than historical or ongoing commercial uses:

Residents, including infants and children, can be present in their homes 20–24 hours per day, year‑round, over many years or decades, resulting in far higher cumulative exposure from any vapor intrusion than the typical adult worker in a commercial building.

Children have higher breathing rates per unit body weight and developing organs and nervous systems, making them more vulnerable to the toxic effects of chlorinated VOCs such as TCE and 1,1‑DCE; pregnant residents may face additional risks related to fetal development.

Bedrooms, nurseries, and play areas in residential buildings are often located on the ground floor or directly over slabs, increasing the likelihood that any vapor intrusion will affect spaces where children spend sustained periods and where they sleep.

Item 7-A
September 22, 2026
Item 7-A
September 22, 2026

7.A.h
Packet Pg. 985 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) For these reasons, cleanup strategies, closure criteria, and engineering controls that might be regarded as acceptable for commercial/industrial land use are not adequate for long‑term residential occupancy. The underlying contaminant mass and plume stability must be addressed to a level that provides a substantial margin of safety for the most vulnerable residents, not just for adult workers.

The March 9, 2026, “Limited ESA Phase II Report,” states (page 3) that the BXP 2800 28th St site’s subsurface soil vapor is impacted at concentrations that present a “potential vapor intrusion risk,” i.e., above regulatory thresholds. This is substantial evidence documenting a need for a fulsome assessment of the clear risk to public health and safety at the site:

Investigation activities conducted at the Site have also identified deeper soil and groundwater impacts, which are being addressed by Boeing under oversight by the LARWQCB, Case # 0130B. This Work Plan does not include further assessment of the Site’s deeper impacted soil and groundwater, as BXP’s redevelopment planning does not require the collection of additional deeper data. The redevelopment of the Site will encompass the entire parcel; therefore, there will be no direct exposure to future Site occupants following the construction of the building. Similarly, the Site’s planned excavation will not extend to groundwater, which has been measured to be first encountered as perched groundwater at approximately 70 feet bgs. This Work Plan excludes the collection of additional soil vapor data, as it is already established that the Site’s subsurface soil vapor is impacted at concentrations that present a potential vapor intrusion risk.Given this concern, BXP will be installing a VIMS when constructing the Site’s new building, and further soil vapor data is not required to design the VIMS.

This report seems to imply that “all will be taken care of” by installation of a VIMS. However, installing a VIMS is not sufficient to protect occupants of a residential building; a VIMS is insufficient to mitigate risk to sensitive residential occupants, as this Guidance from the San Francisco RWQB indicates:
“Relationship Between VIM and Remediation
In general, the Regional Water Board considers VIM as an interim measure that is not a substitute for remediation of VFCs in the subsurface. In most cases, for new construction where a VIMS is needed to protect building occupants, we will not approve the VIMS until remediation to the extent feasible has been implemented. This could affect the local agency’s permitting decision for occupancy. Cleanup is the best way to reduce the magnitude of VI exposure that could occur if problems arise with VIMS, and it is the best way to reduce the timeframe over which VIMS are needed.

Nonetheless, VIMS are often necessary since achieving cleanup standards may take years given currently available remedial technologies. Additionally, VIM may be the only viable longterm response action where remediation is infeasible (e.g., further concentration reductions are not possible and residual concentrations pose a VI threat).(S.F. RWQB Vapor Intrusion Mitigation Guidance, p.3; emph. added)

CEQA REVIEW IS WARRANTED
Item 7-A
September 22, 2026
Item 7-A
September 22, 2026

7.A.h
Packet Pg. 986 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) The City seems to believe these projects are subject only to ministerial approval, hence exempt from CEQA review. It may also be laboring under the assumption that impacts on future residents are not subject to CEQA. Although California law generally distinguishes between existing hazards affecting future residents and project-caused environmental effects, the controlling language of the California Supreme Court in California Building Industry Association v. Bay Area Air Quality Management District (2015) 62 Cal.4th 369, expressly preserves CEQA review where development may disturb or exacerbate existing contamination. The Supreme Court stated succinctly:

In light of CEQA‘s text, statutory structure, and purpose, we conclude that agencies subject to CEQA generally are not required to analyze the impact of existing environmental conditions on a project‘s future users or residents. But when a proposed project risks exacerbating those environmental hazards or conditions that already exist, an agency must analyze the potential impact of such
hazards on future residents or users. In those specific instances, it is the project’s
impact on the environment — and not the environment’s impact on the project —
that compels an evaluation of how future residents or users could be affected by exacerbated conditions.
(Id., second paragraph of opinion).

The Court further explained that redevelopment of a former industrial site requires CEQA review where contaminated soil may be disturbed or contamination may migrate.

That principle is directly implicated here because current technical findings acknowledge:
·unresolved VOC reservoirs,
·incomplete delineation,
·possible downgradient migration, and
·uncertainty regarding groundwater flow changes associated with future well production.

We believe that the evidence already in the files is sufficient for the City to find that the public health and safety issue requires CEQA analysis consistent with state law application of that particular assessment for the projects at hand.

Friends of Sunset Park does not agree that a residential building can be approved with this known risk without full review and full remediation, even if it does take years; therefore our Board respectfully requests and recommends the following:

Item 7-A
September 22, 2026
Item 7-A
September 22, 2026

7.A.h
Packet Pg. 987 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update)

1. Full, Health‑Protective Remediation Before Any Residential Approvals The RWQB and City of Santa Monica should not approve any discretionary entitlements, rezonings, or permits that enable residential development in Subareas C, D, E, and F until the Regional Water Quality Control Board has determined that all relevant media—soil, soil vapor, perched groundwater, and the regional aquifer—have been fully investigated and remediated to standards appropriate for unrestricted residential use, including protection of children and pregnant residents.

Remediation must specifically address the persistent VOC reservoirs in the fine‑grained zones beneath the former DAC Plant A and any other identified source areas, with clear, measurable performance objectives based on actual reductions in VOC mass and concentrations, not simply operating time for remediation systems.

2. Completion of Subsurface Characterization and Plume Delineation The additional lateral and vertical delineation of soil vapor and perched groundwater recommended in the 2023 investigations—particularly to the west and into Clover Park—should be completed and made publicly available before any residential entitlements are considered.

The VOC plume in the regional aquifer, including but not limited to 1,1‑DCE detections at MW‑8 and any other downgradient wells, should be fully delineated and modeled, demonstrating that the plume is under control and trending toward cleanup rather than expansion.

3. Integrated Evaluation of Groundwater Pumping and Land‑Use Change Any decision to activate or modify Airport #1 WSW or other water‑supply wells in the area must be evaluated together with proposed land‑use changes, including residential redevelopment, recognizing that groundwater pumping can alter plume behavior and vapor‑intrusion potentials beneath existing and future buildings.

A combined analysis should be required, examining how different pumping scenarios may affect VOC concentrations at supply wells and within underlying soils and vapors beneath current and proposed residential areas.

4. Residential and Child‑Focused Health‑Risk Standards
Cleanup and closure decisions must be based on exposure assumptions and target Item 7-A
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Packet Pg. 988 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) levels appropriate for 24‑hour‑per‑day, long‑term residential occupancy, including infants, children, and pregnant residents—not on less protective commercial/industrial worker scenarios.

A quantitative health‑risk assessment should be required that explicitly evaluates chronic and subchronic indoor‑air exposure to TCE, 1,1‑DCE, and related VOCs for sensitive populations, as well as potential drinking‑water exposure if groundwater is or may be used.

5. Enforceable Long‑Term Protections and Monitoring
If, even after aggressive remediation, residual contamination remains that could contribute to vapor intrusion, residential development should only proceed with enforceable engineering controls (e.g., sub‑slab depressurization, vapor barriers) and robust long‑term monitoring programs that are clearly funded, maintained, and periodically reviewed for the life of the buildings.

Institutional controls, including land‑use covenants, requirements for periodic re‑evaluation of site conditions, and disclosure requirements for future occupants, should be mandatory components of any approval for residential use on or near affected areas.

6. Transparent, Coordinated Oversight and Public Process The City should conduct a full, project‑specific environmental review, consistent with CEQA, that incorporates the most current data and requirements from the Regional Board, and that directly addresses whether site conditions are safe for residential development with child‑sensitive receptors.

The Regional Board should clearly state whether the remedial approach and any prospective closure determinations are intended to support unrestricted residential use and, if so, the technical basis and conditions (including monitoring and contingency measures) for that conclusion.

Our February 7, 2024, letter to the Regional Board raised our concerns only from the perspective of clean-up costs impacting affected neighborhood association as taxpayers. This (new) joint communication to both the City and the Regional Board is intended to make clear that Friends of Sunset Park strongly opposes moving forward with residential development in Subareas C, D, E, and F until the subsurface conditions are thoroughly characterized, aggressively remediated by the property antecedent owners/users , and demonstrated to be protective of long‑term residential use, particularly for children.

We respectfully request that this letter be placed in the administrative record for all land‑use, CEQA, and cleanup decisions affecting the Santa Monica Business Park and surrounding Item 7-A
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Packet Pg. 989 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) areas, with specific reference to residential projects being proposed at 2716 Ocean Park Blvd. and 2800 28th Street and groundwater supply for Santa Monica, and, since we are not the experts in this field, that both agencies provide written responses for public consumption addressing how the issues raised here and in our February 7, 2024, letter will be resolved prior to any project approval for residential development. We are well aware of the claims being made by certain housing advocates that an affordable housing crisis demands more units be built without environmental review of any kind. The idea that environmental review should be skipped is based on the false premises that environmental review is just red tape with no benefit, that thwarts development, or that our vulnerable populations can be relegated to living on contaminated land. We disagree. Everyone is entitled to live on clean and safe land, and expedience can never be justification for avoiding proper study and remediation when contamination is know to exist at the site of a former airplane and munitions manufacturer.

Furthermore, this is a market-rate housing development, and building more luxury units in Santa Monica without the proper level of environmental review will not solve the purported “affordability” crisis in any way, and clearly endangers the health of the children and others who will occupy those buildings without knowing the dangers lurking in the vapors they will be breathing.

Thank you for your attention and anticipated response.

Sincerely,
Board of Directors
Friends of Sunset Park
By:

Clare Thomas
President, Friends of Sunset Park
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Packet Pg. 990 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) 2500 Michigan Ave., Building 1, Santa Monica, 90404 • (310) 458-8235 • [email protected] santamonica.gov • @cityofsantamonica • @santamonicacity Public Works Department
Water Resources Division
April 7, 2026
Ana Townsend
Water Resource Control Engineer
Los Angeles Regional Water Quality Control Board
320 W. 4th Street, Suite 200
Los Angeles, CA 90013

RE: Comments and Technical Review of the Soil Management Plan (December 18, 2025), Former Douglas Aircraft Company Plant A, Santa Monica, California
Dear Ms. Townsend,
On behalf of the City of Santa Monica (the City), I am transmitting the enclosed technical memorandum, Technical Review of the Soil Management Plan Prepared for the Former Douglas Aircraft Company Plant A, Santa Monica, California, dated March 18, 2026, prepared by Hazen and Sawyer for the City.

The memorandum presents the City’s technical review of the Soil Management Plan (SMP) prepared by Engineering Analytics, Inc. on behalf of The Boeing Company and dated December 18, 2025. As reflected in the enclosed memorandum, the City recognizes that the SMP includes a generally sound framework and several useful procedural elements. However, given the size and complexity of the approximately 112-acre site, its multi-parcel configuration, phased redevelopment context, contamination history, and the presence of sensitive receptors including schools and daycare facilities, the City believes the SMP requires further revision before it can be considered sufficiently specific and implementable for sitewide redevelopment activities. The City recognizes that the Los Angeles Regional Water Quality Control Board has taken an adaptive approach in which the plan and remediation efforts may be refined over time. However, with housing developments already being proposed over the site—and additional projects anticipated in the near future—it is essential that a more thorough and comprehensive plan be established as soon as possible.In particular, the City requests that the Los Angeles Regional Water Quality Control Board direct Boeing to revise and resubmit the SMP to address the following key recommendations identified in the technical memorandum:
• Develop a parcel-specific SMP implementation matrix and parcel maps for each Assessor’s Identification Number (AIN), including land use, contaminants of potential concern, impact zones, screening levels, monitoring requirements, stop-work triggers, and responsible parties. • Require pre-characterization and delineated contaminant management zones based on site history, prior investigation data, and contaminant-specific behavior, rather than relying primarily on reactive field observations during construction.
• Incorporate a clearly defined stop-work and restart decision framework, including numeric triggers, defined authority, notification pathways, restart criteria, and minimum professional qualifications for oversight personnel.

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Packet Pg. 991 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) 2500 Michigan Ave., Building 1, Santa Monica, 90404 • (310) 458-8235 • [email protected] santamonica.gov • @cityofsantamonica • @santamonicacity • Add a groundwater protection measure for residual contamination at the base of excavations, including confirmation sampling, leaching-to-groundwater evaluation criteria, and notification and approval requirements before backfilling.
• Establish a sensitive receptor protection protocol for areas adjacent to or occupied by schools and daycare facilities, including enhanced dust and air monitoring, operational restrictions, and advance communication procedures.
• Define a clear screening level and risk decision framework, including receptor assumptions, acceptable risk thresholds, cumulative risk methodology, post-remediation human health risk assessment requirements, and clarification that No Further Action determinations are made by the Los Angeles Regional Water Quality Control Board (LARWQCB). • Strengthen stockpile management and soil movement controls, including segregation, tracking, cross-parcel transfer restrictions, and documented approval pathways for reuse or disposal decisions.
• Integrate stormwater management into the soil disturbance framework, with defined best management practices (BMPs), contact water procedures, parcel-level responsibilities, and discharge authorization requirements.
• Include additional process-related contaminants of potential concern where warranted, specifically per- and polyfluoroalkyl substances (PFAS), hexavalent chromium, and 1,4-dioxane, in areas associated with historical plating, surface finishing, degreasing, solvent handling, or wastewater management.
• Address the Phase I Environmental Site Assessment (Phase I ESA) recommendations for 2800 28th Street (AIN 4272-031-005) by requiring parcel-specific pre-characterization and an SMP framework that incorporates those findings before redevelopment proceeds.

The City respectfully requests that these issues be addressed before approval of redevelopment-related SMP implementation so that soil management activities are carried out in a manner that is consistent, transparent, and protective of human health, groundwater resources, and nearby sensitive receptors.

Thank you for your consideration of the City’s comments. Please contact me if you have any questions regarding this transmittal.

Sincerely,
Sunny Wang, P.E.

Water Resources Manager
City of Santa Monica
Enclosure: Technical Memorandum, Technical Review of the Soil Management Plan Prepared for the Former Douglas Aircraft Company Plant A, Santa Monica, California Item 7-A
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Packet Pg. 992 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) Hazen and Sawyer • 800 W. 6th Street, Suite 1400 • Los Angeles, CA 90017 • 213.234.1080 Technical Memorandum
Job no: 20302-000
March 19, 2026
To: Christopher Dishlip, PE (City of Santa Monica)
From: Stephanie Bustos, PG (Hazen and Sawyer)
Mark Trudell, PhD, PG, CHG (Hazen and Sawyer)
cc: Sunny Wang, PE (City of Santa Monica)
Lisette A. Gold, D. Env (City of Santa Monica)
Susan Cola (City of Santa Monica)
Brandon Ward (City of Santa Monica)
Monica Tejeda (City of Santa Monica)
Shannon Parry (City of Santa Monica)
Subject: Technical Review of the Soil Management Plan Prepared for the Former Douglas Aircraft Company Plant A, Santa Monica, California Synopsis
Hazen and Sawyer conducted a technical review of the Soil Management Plan, Former Douglas Aircraft Company Plant A, Santa Monica, California (the Site), prepared by Engineering Analytics, Inc. for The Boeing Company (December 18, 2025). The review evaluated whether the Soil Management Plan (SMP) provides sufficient specificity and governance to ensure consistent and protective implementation during phased redevelopment of the approximately 112-acre Site, which includes multiple parcels, varied land uses, and sensitive receptors including schools and daycare facilities.

Overall, the SMP provides a sound structural framework and includes several strong procedural elements.

However, given the size and complexity of the Site, additional implementation detail and oversight controls are needed to ensure consistent application across parcels and contractors. This memorandum identifies targeted improvements related to parcel-level implementation, contaminant management zoning, stop-work authority, groundwater protection where residual contamination remains at the base of excavations, sensitive receptor protection, risk decision-making, soil movement controls, and stormwater integration. The review also identifies additional contaminants reasonably associated with historical operations that warrant consideration during soil disturbance activities and evaluates alignment with Phase I Environmental Site Assessment (Phase I ESA) recommendations for 2800 28th Street (AIN 4272- 031-005).

The recommended improvements are intended to strengthen the SMP's implementability while preserving its overall structure and supporting protective redevelopment under LARWQCB oversight. This is especially critical given that housing developments are already being proposed across the Site and additional redevelopment projects are anticipated in the near term, making it essential that a more thorough and comprehensive plan be established as soon as possible.

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Packet Pg. 993 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) March 19, 2026
Technical Review of the SMP Prepared for the DAC Plant A, Santa Monica, CA Page ii The undersigned licensed professionals conducted an independent technical review of the Soil Management Plan, Former Douglas Aircraft Company Plant A, Santa Monica, California, prepared by Engineering Analytics, Inc. for The Boeing Company (December 18, 2025). The findings, conclusions, and recommendations presented in this report reflect their professional judgment and are submitted under their respective professional certifications.

Exp. 06/23/2026
Stephanie Bustos, PG
Senior Associate
Exp. 01/31/2028
Mark Trudell, PhD, PG, CHG
Senior Associate
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Packet Pg. 994 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) March 19, 2026
Technical Review of the SMP Prepared for the DAC Plant A, Santa Monica, CA Page iii Table of Contents

1. Introduction............................................................................................................... 1

1.1 Purpose.......................................................................................................................................1

1.2 Summary of SMP Strengths and Areas Requiring Revision ......................................................2

2. Governance and Implementation Framework Improvements ................................... 3

2.1 Recommended Improvement 1: Parcel-Specific SMP Implementation Matrix (AIN-by-AIN) and Parcel Maps ................................................................................................................................3

2.1.1 Issue ..............................................................................................................................4

2.1.2 Recommendation...........................................................................................................4

2.1.3 Rationale........................................................................................................................4

2.2 Recommended Improvement 2: Pre-Characterization and Delineated Contaminant Management Zones ....................................................................................................................5

2.2.1 Issue ..............................................................................................................................5

2.2.2 Recommendation...........................................................................................................5

2.2.2.1 Implementation Controls ................................................................................6

2.2.2.2 Governance Controls .....................................................................................6

2.2.3 Rationale........................................................................................................................6

2.3 Recommended Improvement 3: Stop-Work and Restart Decision Framework with Defined Authority......................................................................................................................................6

2.3.1 Issue ..............................................................................................................................7

2.3.2 Recommendation...........................................................................................................7

2.3.2.1 Defined Stop-Work Triggers...........................................................................7

2.3.2.2 Immediate Response Controls (Implementation Measures)..........................8

2.3.2.3 Defined Authority and Escalation (Governance Measures)...........................8

2.3.2.4 Restart Criteria ...............................................................................................9

2.3.3 Rationale........................................................................................................................9

2.3.4 Professional Qualifications and Oversight...................................................................10

2.3.5 Supplemental Groundwater Protection Measure: Residual Contamination at the Base of Excavations..............................................................................................................10

2.3.5.1 Issue.............................................................................................................10

2.3.5.2 Recommendation .........................................................................................11

2.3.5.3 Rationale ......................................................................................................11 Item 7-A
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2.4 Recommended Improvement 4: Sensitive Receptor Protection Protocol ................................11

2.4.1 Issue ............................................................................................................................12

2.4.2 Recommendation.........................................................................................................12

2.4.2.1 Enhanced Implementation Controls .............................................................12

2.4.2.2 Operational Restrictions...............................................................................13

2.4.2.3 Governance and Communication Measures................................................13

2.4.3 Rationale......................................................................................................................13

2.5 Recommended Improvement 5: Clear Screening Level (SL) and Risk Framework.................13

2.5.1 Issue ............................................................................................................................14

2.5.2 Recommendation.........................................................................................................14

2.5.2.1 Defined Risk Criteria (Governance Elements).............................................14

2.5.2.2 Implementation Requirements .....................................................................15

2.5.3 Rationale......................................................................................................................15

2.5.4 Regulatory Authority for No Further Action Determinations ........................................15

2.5.5 Post-Remediation Human Health Risk Assessment Requirements ............................16

2.6 Recommended Improvement 6: Stockpile Management and Soil Movement Controls ...........16

2.6.1 Issue ............................................................................................................................16

2.6.2 Recommendation.........................................................................................................17

2.6.2.1 Implementation Controls ..............................................................................17

2.6.2.2 Governance Controls ...................................................................................17

2.6.3 Rationale......................................................................................................................18

2.7 Recommended Improvement 7: Stormwater Integration..........................................................18

2.7.1 Issue ............................................................................................................................18

2.7.2 Recommendation.........................................................................................................19

2.7.2.1 Implementation Controls ..............................................................................19

2.7.2.2 Governance Controls ...................................................................................19

2.7.3 Rationale......................................................................................................................20

3. Additional Considerations: Process-Related Contaminants of Potential Concern .. 21

3.1 Per- and Polyfluoroalkyl Substances (PFAS) and Hexavalent Chromium (Cr(VI)) ..................21

3.2 Consideration of 1,4-Dioxane as a Contaminant of Potential Concern ....................................22

4. Evaluation of Phase I ESA Recommendations and SMP Alignment ...................... 24 Item 7-A
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Technical Review of the SMP Prepared for the DAC Plant A, Santa Monica, CA Page v

4.1 Phase I ESA Recommendation 1: Soil Pre-Characterization...................................................24

4.2 Phase I ESA Recommendation 2: Preparation of an SMP Using Pre-Characterization Data .25

5. Conclusions ............................................................................................................ 27

5.1 Recommended Governance and Implementation Revisions ...................................................27

5.2 Additional Contaminant Considerations....................................................................................29

5.3 Phase I ESA Alignment Determinations for 2800 28th Street (AIN 4272-031-005) .................29

6. References ............................................................................................................. 31 Item 7-A
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Packet Pg. 997 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) March 19, 2026
Technical Review of the SMP Prepared for the DAC Plant A, Santa Monica, CA Page 1

1. Introduction
Hazen and Sawyer (Hazen) conducted a technical review of the Soil Management Plan, Former Douglas Aircraft Company Plant A, Santa Monica, California (the Site), prepared by Engineering Analytics, Inc. (EA) on behalf of The Boeing Company (Boeing), dated December 18, 2025. This document is referred to herein as the SMP.

The Site encompasses approximately 112 acres and includes multiple Assessor's Identification Numbers (AINs) across parcels owned by Watt Headquarters Limited Partnership, SMBP LLC, SC Enterprises SMBP LLC, and the City of Santa Monica. Current land uses include the Santa Monica Business Park (SMBP), Clover Park, and a residential neighborhood in the northeastern portion of the property. The Site encompasses varied land uses, multiple ownership structures, phased redevelopment activities, and a complex environmental history involving volatile organic compounds (VOCs), polychlorinated biphenyls (PCBs), metals, petroleum hydrocarbons, and other chemicals of potential concern (COPCs).

Environmental assessment and soil vapor extraction (SVE) are ongoing at the Site under the direction of the Los Angeles Regional Water Quality Control Board (LARWQCB), which retains regulatory oversight authority for investigation and remediation activities at the Site.

The Site was decommissioned and demolished between 1975 and the late 1970s, before modern federal and state regulatory programs for investigation and remediation of subsurface contamination were established. Consequently, decommissioning activities were not conducted in accordance with current risk-based standards and did not include comprehensive subsurface characterization consistent with modern regulatory frameworks. It is therefore not unexpected that residual soil, soil gas, and groundwater impacts remain at the Site despite subsequent VOC reduction efforts, including operation of SVE systems in select areas.

1.1 Purpose
The purpose of this technical review is to assess whether the SMP, as written, is sufficiently prescriptive and implementable to ensure consistent and defensible protection of human health and the environment during phased redevelopment across a large, multi-parcel site. This review focuses on:
• Protectiveness and implementability: Whether the SMP contains adequate governance structure, decision logic, contaminant-specific controls, documentation processes, and implementation standards appropriate for a 112-acre, multi-contractor, phased redevelopment site with sensitive receptors.
• Phase I Environmental Site Assessment alignment for 2800 28th Street (AIN 4272-031-005):

Whether the SMP adequately addresses the recommendations of the Phase I Environmental Site Assessment (Phase I ESA; Haley & Aldrich, Inc., 2025), including pre-characterization of soil and development of the SMP based on characterization results and Boeing data.

Section 2 identifies minimum governance and implementation improvements needed for the SMP to function consistently across a multi-parcel, multi-contractor redevelopment site. Section 3 identifies Item 7-A
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Packet Pg. 998 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) March 19, 2026
Technical Review of the SMP Prepared for the DAC Plant A, Santa Monica, CA Page 2 additional COPCs reasonably associated with historical aerospace processes that warrant inclusion in sampling programs where relevant. Section 4 evaluates alignment with the Phase I ESA recommendations for 2800 28th Street (AIN 4272-031-005) and identifies parcel-specific gaps.

1.2 Summary of SMP Strengths and Areas Requiring Revision The current SMP framework is structurally sound and generally aligned with LARWQCB oversight requirements for construction-phase soil disturbance at a large redevelopment site, and it appropriately incorporates compliance-related elements where applicable under South Coast Air Quality Management District (SCAQMD) requirements. The SMP also includes a number of strong procedural elements:
• Clear notification procedures to the LARWQCB, including defined advance notification timing and responsible party identification.
• Defined field monitoring protocols addressing SCAQMD Rule 1166 and Rule 1466 compliance where applicable, including parcel-specific monitoring areas. • Procedures for soil impact assessment, step-out sampling, confirmation sampling, and excavation management.
• Soil stockpile management and waste characterization and disposal procedures. • Imported fill material screening procedures consistent with the California Department of Toxic Substances Control (DTSC) Information Advisory on Clean Imported Fill (DTSC, 2001). • Parcel-specific reporting requirements submitted to the LARWQCB upon completion of soil management activities at each parcel.

However, due to the Site's size (approximately 112 acres), multi-parcel ownership structure, complex contamination history, and presence of sensitive receptors, including daycare facilities and a private elementary school within the Site boundaries, additional specificity and implementation controls, including clear authority, decision triggers, documentation standards, and parcel-specific execution procedures, are necessary to ensure the SMP is not merely workable in concept, but defensibly protective in implementation across all parcels, contractors, and redevelopment phases.

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2. Governance and Implementation Framework Improvements The primary concern is not the absence of regulatory citations or procedural components within the SMP.

Rather, it is the reliance on generalized implementation language such as "case-by-case application" (SMP Section 2.5), "professional judgment" (SMP Sections 5.1 and 6.5.1), and direction to "notify human health risk assessment (HHRA) team" (SMP Section 5.4), without clearly defined decision criteria, authority thresholds, documentation standards, or parcel-specific execution controls.

While such terminology may be workable at smaller or less complex sites, on a 112-acre, multicontractor, phased redevelopment site, discretionary language without structured decision logic and defined implementation controls introduces the potential for inconsistent field application across parcels, contractors, and construction phases.

DTSC guidance emphasizes that site management plans should establish clear decision logic, defined implementation triggers, and documentation pathways sufficient to ensure consistent protectiveness across varying land uses and site conditions (DTSC, 2011). United States Environmental Protection Agency (EPA) guidance on systematic planning likewise emphasizes predefined decision criteria and documentation pathways to support defensible environmental decision-making (EPA, 2006).

For a site of this scale and complexity, the SMP must function both as a governance framework that defines authority, triggers, escalation pathways, and documentation standards, and as an implementation framework that provides parcel-specific controls, monitoring requirements, defined stop-work and restart criteria, and consistent field execution standards.

Without integration of both governance structure and implementation clarity, protective measures may vary across parcels and project phases, potentially resulting in inconsistent exposure assumptions, uneven application of controls, and reduced regulatory defensibility. The following subsections present the governance and implementation improvements necessary to strengthen field execution, promote consistency across parcels and contractors, and ensure defensible protection of human health and the environment. These improvements are intended to clarify implementation and oversight, not to expand the SMP’s scope beyond construction-phase soil management. The traceability notes provided below identify the principal SMP sections where the current language is either too general, reactive, or incomplete for a site of this scale.

2.1 Recommended Improvement 1: Parcel-Specific SMP Implementation Matrix (AIN-by-AIN) and Parcel Maps
On a multi-parcel redevelopment site with varying land uses, ownership structures, and known areas of contamination, implementation consistency cannot rely solely on sitewide language. A parcel-specific governance and implementation framework is necessary to ensure that risk assumptions, monitoring requirements, and management controls are applied consistently and transparently across all AINs.

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2.1.1 Issue
The SMP applies sitewide but does not provide a parcel-specific governance and implementation structure. On a multi-owner, phased redevelopment site, absence of parcel-level controls may result in inconsistent field application between contractors and construction phases.

Traceability to SMP. This deficiency is traceable to the SMP’s sitewide applicability and ownership discussion in Section 2.1, its sitewide notification and implementation framework in Sections 3.1 through

4.4, and its parcel-specific reporting provision in Section 10.3. While the SMP recognizes parcel ownership and requires parcel-specific reporting, it does not establish parcel-specific implementation controls, parcel maps, or AIN-specific decision criteria before work begins.

2.1.2 Recommendation
Develop a Parcel-Specific SMP Implementation Matrix that functions as both a governance tool and an implementation guide for each AIN. The matrix should define:
• Current and planned land use.
• Presence of sensitive receptors.
• Known COPCs and impact zones.
• Default receptor assumptions and applicable screening levels. • Monitoring and perimeter requirements.
• Stop-work triggers and notification pathways.
• Documentation and approval standards.
• Responsible parties (owner/operator/contractor roles) and designated points of contact.

Parcel maps should visually delineate AIN boundaries, impact zones, sensitive receptor interfaces, and monitoring applicability areas.

2.1.3 Rationale
EPA guidance for large, complex sites emphasizes structured management systems and alignment between land use assumptions, exposure scenarios, and site controls (EPA, 2006). DTSC similarly requires that site management measures be consistent with anticipated land use and exposure conditions (DTSC, 2011). A parcel-specific matrix implements this alignment and promotes consistent field execution.

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2.2 Recommended Improvement 2: Pre-Characterization and Delineated Contaminant Management Zones
Effective soil management requires that site history and contaminant-specific behavior be considered before excavation or other soil-disturbing activities begin. For non-volatile contaminants such as polychlorinated biphenyls (PCBs) and metals, field screening tools commonly used for VOCs, such as photoionization detector (PID) monitoring, are not reliable indicators of the presence or extent of contamination, and impacts may not be visually apparent. Accordingly, pre-characterization and advance delineation of contaminant management zones are necessary to support proactive sampling, consistent implementation of excavation, handling, and worker protection measures appropriate to the contaminants present, and defensible decision-making.

2.2.1 Issue
The SMP relies primarily on visual observations, odors, and PID readings to identify potential impacts during soil disturbance. While these tools may be appropriate for VOCs and petroleum hydrocarbons, they are not suitable for detecting non-volatile contaminants such as PCBs, metals, and certain semivolatile compounds. In the absence of predefined contaminant management zones, reliance on field discretion may result in under-identification of impacts and inconsistent implementation across parcels and contractors.

Traceability to SMP. This deficiency is traceable to Sections 4.1 through 4.3, Section 5.1, Section 5.2, and Sections 6.1 through 6.5, which rely largely on observation, field screening, impact identification during work, step-out sampling, and confirmation sampling after disturbance. The SMP does not require predefined contaminant management zones based on known historical operations and existing investigation data before excavation proceeds.

2.2.2 Recommendation
The SMP should require the development and incorporation of Delineated Contaminant Management Zones that identify areas of known contamination and areas with a high likelihood of contamination based on historical operations, prior investigation data, investigation data being generated through implementation of the Additional Site Assessment Work Plan, Former Douglas Aircraft Company Plant A, Santa Monica, California dated November 26, 2024, and the Additional Site Assessment Work Plan Addendum Number 1, Boeing Former Douglas Aircraft Company (DAC) Plant A, Santa Monica, California (collectively, the Work Plans), both prepared by EA, and contaminant-specific behavior. These zones should be mapped both laterally and vertically and should be clearly referenced to individual parcels.

For each zone, the SMP should define implementation and governance requirements, including, at a minimum, the elements described in Sections 2.2.2.1 and 2.2.2.2 below:

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2.2.2.1 Implementation Controls
• Mandatory pre-disturbance characterization sampling.
• Excavation and confirmation sampling protocols.
• Enhanced air quality, particulate, dust, field screening, and/or sampling requirements appropriate to zone-specific COPCs.
• Waste profiling triggers.

2.2.2.2 Governance Controls
• Defined decision thresholds for additional characterization, removal, or other response actions. • Documentation requirements prior to soil movement, reuse, or off-site disposal. • Defined approval authority for alternative management approaches.

Zone maps should be integrated with the Parcel-Specific Implementation Matrix to ensure alignment between mapped conditions, risk assumptions, and required controls.

2.2.3 Rationale
EPA’s Guidance on Systematic Planning Using the Data Quality Objectives Process emphasizes the need for structured, contaminant-specific planning prior to field implementation (EPA, 2006). DTSC guidance similarly indicates that characterization strategies should reflect contaminant properties and site history rather than rely solely on observational criteria (DTSC, 2011). Establishing delineated contaminant management zones prior to excavation promotes proactive control, reduces reliance on subjective field judgment, and enhances consistency and defensibility across redevelopment phases.

2.3 Recommended Improvement 3: Stop-Work and Restart Decision Framework with Defined Authority
On large, phased redevelopment sites involving multiple contractors and concurrent construction activities, clearly defined stop-work and restart procedures are essential to maintaining consistent environmental oversight. Ambiguity in authority, escalation pathways, or restart criteria may result in inconsistent field decisions, premature resumption of work, and reduced protectiveness. This concern is consistent with EPA guidance emphasizing structured planning and documented implementation responsibilities during contaminated site management and redevelopment, and with DTSC guidance recognizing the need for site-specific soil management procedures where contaminated soil may be encountered during cleanup and redevelopment activities (EPA, 2021; EPA, 2012; DTSC, 2011).

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2.3.1 Issue
The SMP states that work “should stop” if impacts are discovered; however, it does not clearly define stop-work authority, immediate response requirements, escalation thresholds, or restart criteria. On a multi-contractor redevelopment site, reliance on discretionary interpretation without defined restart conditions creates the potential for inconsistent implementation, uneven application of protective measures, and premature resumption of work.

EPA and DTSC guidance for contaminated site cleanup and redevelopment supports the use of clearly defined roles, decision-making procedures, and documented response actions to help maintain protective and consistent implementation during redevelopment activities. EPA redevelopment guidance describes a structured process for evaluating contaminated properties, documenting redevelopment decision-making, and identifying actions needed to support productive reuse, including management of environmental conditions and risk. EPA institutional controls guidance also emphasizes planning, implementation, maintenance, and enforcement responsibilities as part of long-term site management. DTSC guidance likewise recognizes that site-specific soil management procedures may be necessary to ensure contaminated soil is handled in a manner that prevents exposure during cleanup and redevelopment activities. Occupational and construction safety regulations likewise require defined procedures to protect workers when hazardous materials or other unsafe conditions may be encountered during excavation and related work, including Title 8, California Code of Regulations, Section 5192 (Hazardous Waste Operations and Emergency Response) and Section 1541 (General Requirements for Excavations) (EPA, 2021; EPA, 2012; DTSC, 2011).

2.3.2 Recommendation
Incorporate a clearly defined Stop-Work and Restart Decision Framework that establishes both governance and implementation controls. A one-page decision tree should be included within the SMP and referenced in contractor pre-construction meetings.

2.3.2.1 Defined Stop-Work Triggers
Work within the affected area must immediately stop upon occurrence of any of the following:
• PID readings exceeding a site-specific numeric action level above background conditions, as defined in the field screening plan, including instrument calibration and bump test requirements and the background determination method, and documented by the qualified environmental professional (QEP) of record. For purposes of this review, the QEP is the designated environmental professional responsible for SMP implementation and oversight, under the supervision of a California-licensed Professional Geologist (PG) and/or Professional Engineer (PE), as appropriate.
• Visible staining or discoloration of soil, or chemical odors detected in ambient air during soil disturbance.

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• Receipt of laboratory analytical results exceeding the applicable soil matrix screening level or cumulative risk threshold.
• Perimeter air monitoring exceedance under SCAQMD Rule 1166 or Rule 1466, where those rules are applicable to the activity being conducted.

Where feasible, all triggers should be expressed as numeric thresholds to minimize subjective field interpretation.

2.3.2.2 Immediate Response Controls (Implementation Measures) Upon stop-work, the following measures should be implemented without delay:
• Establish an exclusion zone around the affected area. • Secure and cover exposed soils and stockpiles.
• Implement dust suppression measures.
• Stabilize the excavation as necessary to prevent further exposure or migration. • Initiate the defined notification cascade, such as Environmental Observer to Site EH&S Manager to Property Owner to LARWQCB, as applicable.
• Collect confirmation samples and submit for expedited laboratory analysis to confirm or refute field observations prior to restart. Analytical turnaround requirements should be defined in advance and coordinated with the contract laboratory to minimize work stoppage duration while ensuring data defensibility.

Immediate response procedures should be standardized across all parcels and contractors to ensure consistent field execution.

2.3.2.3 Defined Authority and Escalation (Governance Measures) The SMP should explicitly identify the following authority designations:
• Environmental Observer authority to initiate stop-work at the parcel level. • Site EH&S Manager authority to suspend broader site operations if warranted. • Defined regulatory notification thresholds triggering LARWQCB contact. • Circumstances requiring LARWQCB concurrence prior to restart.

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2.3.2.4 Restart Criteria
Work in the affected area may not resume until all of the following conditions are satisfied:
• Impact delineation is completed, with lateral and vertical extent defined or bounded. • A control strategy is established, consisting of removal to applicable screening levels, a documented risk evaluation for residual concentrations, or incorporation of engineering controls, as appropriate to site conditions.
• Applicable field monitoring demonstrates conditions are below pre-established action levels for a defined minimum interval, as specified in the SMP and/or the activity-specific monitoring approach, as applicable.
• Regulatory notification is completed where required under applicable LARWQCB oversight requirements.
• Written restart authorization is issued by both the Environmental Observer and the Site EH&S Manager, with LARWQCB concurrence obtained where required. • All stop-work conditions, response actions, and restart determinations are documented in the daily field log and weekly report.

2.3.3 Rationale
On large redevelopment sites, ambiguity regarding stop-work initiation, escalation, and restart authority can lead to inconsistent application, contractor pressure to resume work, and increased potential for exposure or incomplete response actions. Clearly defined restart criteria are as important as stop-work triggers because they establish the basis for determining when conditions have been sufficiently evaluated and controlled to allow work to resume in a protective and documented manner.

A defined Stop-Work and Restart Decision Framework strengthens implementation consistency by assigning responsibility, standardizing response actions, and reducing reliance on individual judgment in the field. This approach is consistent with United States Environmental Protection Agency (EPA) guidance emphasizing documented planning, implementation responsibilities, and long-term protectiveness in contaminated site management, as well as DTSC guidance recognizing the importance of site-specific soil management procedures during cleanup and redevelopment activities (EPA, 2021; EPA, 2012; DTSC, 2011).

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2.3.4 Professional Qualifications and Oversight
The SMP should specify minimum professional qualifications for individuals responsible for implementing and supervising soil management activities. At a minimum, the qualified environmental professional of record should hold a current California Professional Geologist (PG) or Professional Engineer (PE) license, or work under the direct supervision of a licensed PG or PE, as appropriate to the scope of work. The SMP should clearly define field decision authority for stop-work initiation, sample selection, and excavation expansion decisions. Clear delineation of professional oversight responsibilities strengthens implementation consistency, accountability, and defensibility during SMP execution. This recommendation is consistent with the broader EPA and DTSC emphasis on documented implementation responsibilities and site-specific management procedures at contaminated sites (EPA, 2012; DTSC, 2011).

2.3.5 Supplemental Groundwater Protection Measure: Residual Contamination at the Base of Excavations
This section considers the need for a groundwater-protective approach when contaminated soil may remain at the base of excavations. The SMP currently focuses on shallow soil exposure but does not clearly address whether deeper residual contamination left in place could continue to affect groundwater.

Because groundwater beneath the Site is already impacted by contamination from historical site use and the groundwater aquifer is designated for drinking water use, this issue should be addressed explicitly in the SMP.

2.3.5.1 Issue
The SMP does not establish procedures for addressing contaminated soil that may remain at the base of excavations after final grade is reached. Section 2.5, Screening Levels, states that “12 feet would be the likely maximum depth of disturbance during potential future redevelopment and Site use and maintenance activities, and that 12 feet is therefore the maximum depth of soil to which future receptor populations could be directly exposed.” However, this framework considers only potential direct exposure to shallow soil and does not address the potential risk that deeper residual contamination may continue to pose to groundwater. Given that groundwater beneath the Site, and potentially downgradient of the Site, has already been affected by contamination, including trichloroethylene (TCE) at concentrations above the applicable maximum contaminant level (MCL) of 5 µg/L and tert-butyl alcohol (TBA) above the California notification level of 12 µg/L, and that the groundwater is designated for Municipal and Domestic Supply (MUN) beneficial use, residual soil contamination at depth may represent an ongoing source of contaminant loading to an already impaired groundwater resource.

Traceability to SMP. This deficiency is traceable to Section 2.5, Section 6.5, and Section 6.6. The SMP’s risk framework is tied to direct exposure assumptions for shallow soil, and its confirmation sampling and post-remediation HHRA provisions do not establish separate criteria for evaluating whether deeper residual soil left at the base of excavations may continue to affect groundwater.

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2.3.5.2 Recommendation
Boeing should be directed to revise the SMP to incorporate procedures for managing residual soil contamination remaining in place at the base of excavations. At a minimum, the revised SMP should define:
• Confirmation sampling requirements at the base of each excavation upon reaching planned final grade, including minimum sample density and spatial distribution criteria. • Leaching-to-groundwater evaluation criteria for residual soil concentrations remaining at depth, including applicable soil-to-groundwater screening values or leaching factors consistent with California regulatory practice.
• Concentration thresholds for base-of-excavation soils requiring LARWQCB notification prior to backfill, including the notification pathway and required supporting documentation; and • Documentation requirements for any residual-in-place determination, including the basis for determining that residual concentrations are acceptable relative to groundwater protection criteria, the identity of the QEP of record approving the determination, and submission to the LARWQCB prior to backfill authorization.

2.3.5.3 Rationale
The SMP addresses soil management during and following excavation but does not establish a groundwater-protective framework for conditions where contaminated soil remains in place at depth at the conclusion of excavation activities. Where excavation reaches final grade and contaminated soil is left in place, the leaching potential of residual concentrations to underlying groundwater represents a longterm loading consideration distinct from the direct-contact and airborne exposure pathways addressed by the existing SMP framework.

Groundwater beneath the Site is already impacted by contaminants above applicable regulatory thresholds and is designated for MUN beneficial use, meaning it is treated as a drinking water resource under applicable regulatory frameworks. Residual soil contamination at the base of excavations, if not evaluated against groundwater protection criteria prior to backfill, may represent an ongoing and potentially unquantified source loading contribution to an already impaired resource. This gap is significant because backfilling an excavation without a documented groundwater protection evaluation eliminates the opportunity for additional removal and creates conditions that may be difficult to reassess following construction.

2.4 Recommended Improvement 4: Sensitive Receptor Protection Protocol The presence of daycare facilities and a private elementary school within or adjacent to redevelopment parcels necessitate enhanced implementation controls beyond standard construction-phase measures.

Where soil disturbance occurs in proximity to child receptors, additional monitoring, operational Item 7-A
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2.4.1 Issue
The SMP acknowledges the presence of daycare facilities (Bright Horizons Early Education and Preschool, and Hill and Dale Family Learning Center) and a private elementary school (Seven Arrows Elementary School) within the Site boundaries; however, it does not define parcel-specific enhanced protective measures for these areas. On a large redevelopment site with active soil disturbance, reliance solely on standard dust suppression and monitoring provisions may not provide a sufficient margin of safety where child receptors are present. EPA guidance recognizes that children warrant age-specific consideration in exposure assessment and that early-life exposure may increase susceptibility to certain carcinogens, supporting a more protective approach where child receptors are present (EPA, 2005a; EPA, 2005b). DTSC school-site guidance likewise identifies school properties as sensitive settings warranting particular consideration in site evaluation and community protection planning (DTSC, 2006).

Southern California precedent supports a more protective, receptor-specific approach where schools or daycare centers are present at or adjacent to contaminated sites. In the former Athens Tank Farm/Ujima Village matter in Willowbrook, the LARWQCB recommended that demolition scheduling accommodate relocation of Honey's Little Angels Daycare due to the potential impact of demolition activities on the immediate surroundings and ordered additional offsite air quality investigation at nearby residential properties where elevated VOC and methane levels were detected (LARWQCB, 2012). More broadly, California Water Boards guidance identifies occupied buildings with sensitive receptors, including schools and day-care centers, as high priority for vapor intrusion evaluation (State Water Resources Control Board, 2023).

2.4.2 Recommendation
Incorporate a Sensitive Receptor Protection Protocol applicable to parcels adjacent to or occupied by schools and daycare facilities. The protocol should include both implementation controls and governance measures and should be integrated into the Parcel-Specific Implementation Matrix.

2.4.2.1 Enhanced Implementation Controls
• Enhanced dust suppression measures, including increased water application frequency and use of soil stabilizers where appropriate.
• Continuous or high-frequency perimeter air and dust monitoring adjacent to school and daycare boundaries during active soil disturbance.
• Defined numeric action levels and corresponding response measures if monitoring thresholds are exceeded.

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2.4.2.2 Operational Restrictions
• Work-hour limitations during active school operations, where feasible. • Defined truck routing and staging restrictions to minimize proximity to sensitive receptor boundaries.
• Stockpile placement and material staging setbacks from receptor interfaces.

2.4.2.3 Governance and Communication Measures
• Advance written notification to school and daycare administrators prior to major soil disturbance activities.
• Designated point of contact for school and daycare administrators during active construction phases.
• Defined complaint response and exceedance notification pathway. • Documentation requirements for monitoring data, notifications, and corrective actions.

2.4.3 Rationale
Construction-phase activities near sensitive receptors are subject to greater scrutiny and heightened community concern than long-term modeled risk scenarios. EPA guidance recognizes that childhood exposures warrant age-specific consideration and that early-life exposure may increase susceptibility to certain carcinogens, supporting a more protective approach where child receptors are present (EPA, 2005a; EPA, 2005b). DTSC school-site guidance likewise identifies school properties as sensitive settings warranting particular consideration in site evaluation and community protection planning (DTSC, 2006).

Establishing parcel-specific sensitive receptor protocols strengthens implementation clarity, promotes consistent application of enhanced controls, and reduces the potential for community disruption or regulatory escalation. Clear definition of both operational measures and governance pathways helps ensure that protective measures are applied systematically rather than on an ad hoc basis.

2.5 Recommended Improvement 5: Clear Screening Level (SL) and Risk Framework
Risk-based decision making must be applied consistently across parcels, contractors, and redevelopment phases. Where soil screening levels may be exceeded and site-specific risk evaluations are permitted, clearly defined assumptions, target thresholds, documentation standards, and approval authority are necessary to ensure consistent and defensible implementation.

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2.5.1 Issue
The SMP allows exceedances of soil screening levels (SLs) to be evaluated through additional human health risk assessment (HHRA) calculations. However, it does not clearly define default receptor assumptions by parcel type, the target cancer risk range or hazard index threshold, the cumulative risk evaluation approach, required documentation standards, or the approval authority for alternative determinations.

Without clearly defined risk decision criteria, there is a significant risk that SL exceedances may be addressed through progressively adjusted risk calculations rather than remediation, a pattern that is inconsistent with the protective intent of the SMP and may not align with regulatory expectations for transparent and consistent risk-based decision making. The framework should therefore establish explicit thresholds, receptor assumptions, and approval pathways that prevent use of case-by-case risk evaluations as a substitute for soil removal where removal is technically feasible and protective.

On a multi-parcel redevelopment site, absence of defined risk decision criteria increases the potential for inconsistent application of SL exceedance evaluations between parcels and construction phases. DTSC guidance emphasizes transparent documentation of exposure assumptions, screening and risk evaluation methodology, and decision criteria when applying risk-based cleanup determinations, while EPA’s systematic planning and Data Quality Objectives framework emphasizes structured decision logic and predefined decision criteria rather than discretionary determinations (DTSC, 2022; DTSC, 2025; EPA, 2006).

2.5.2 Recommendation
Establish a clear Screening Level and Risk Decision Framework that integrates both governance and implementation elements.

2.5.2.1 Defined Risk Criteria (Governance Elements)
• Default receptor assumptions by parcel type, such as construction worker, commercial/industrial worker, child receptor, and residential receptor, as applicable. It is noted that the existing Site HHRA did not evaluate residential receptor scenarios, and any change in land use that introduces residential occupancy, such as the proposed mixed-use development at AIN 4272-031-005, will require preparation of an updated HHRA using residential exposure assumptions. • Explicit identification of applicable screening level sources by land use, such as DTSC and other California regulatory screening levels where applicable, and EPA Regional Screening Levels as supplemental references where site-specific risk-based concentrations are not available. • A defined acceptable cancer risk range of 1 x 10^-6 (one in one million, as the target) to 1 x 10^- 4 (one in ten thousand, as the upper bound), consistent with typical California regulatory practice, with a target of 1 x 10^-6 where feasible.

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Packet Pg. 1011 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) March 19, 2026
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• Clarification of cumulative risk evaluation methodology, including the treatment of multiple COPCs and multiple exposure pathways.
• Defined approval authority for alternative risk-based determinations. • Defined circumstances requiring regulatory notification or LARWQCB concurrence.

2.5.2.2 Implementation Requirements
• Standardized format for alternative risk evaluations submitted for regulatory review. • Required documentation of exposure assumptions, receptor scenarios, and input parameters. • Clear identification of the parcel or parcels to which the determination applies. • Documentation of any engineering or institutional controls relied upon in lieu of soil removal.

This framework should be integrated into the Parcel-Specific Implementation Matrix to ensure consistent application across all parcels and redevelopment phases.

2.5.3 Rationale
DTSC guidance emphasizes that risk-based determinations should be supported by clearly documented exposure assumptions, transparent screening and risk evaluation methods, and defined decision criteria.

EPA guidance on systematic planning likewise emphasizes predefined decision logic to support defensible environmental decisions (DTSC, 2022; DTSC, 2025; EPA, 2006). Without clearly defined risk thresholds and approval pathways, reliance on case-by-case evaluation may lead to variability in decision making across contractors and parcels. A structured screening level and risk framework helps ensure that alternative determinations are applied consistently, documented transparently, and remain defensible under regulatory review.

2.5.4 Regulatory Authority for No Further Action Determinations The SMP should clarify that No Further Action (NFA) determinations are made by the appropriate regulatory agency, such as the LARWQCB, not by the property owner or environmental consultant.

Where an NFA determination is sought, supporting documentation should be prepared and submitted to the LARWQCB for review and concurrence prior to any parcel-level determination that soil management obligations have been completed. This clarification strengthens governance transparency and regulatory alignment.

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2.5.5 Post-Remediation Human Health Risk Assessment Requirements The SMP requires preparation of post-remediation HHRAs following completion of remediation activities at each parcel (SMP Section 6.6). However, the SMP does not address whether the LARWQCB will direct the specific timing and format of HHRA submission, and it does not define in advance the minimum content expectations, responsible party obligations, submission pathway to the LARWQCB, whether LARWQCB review and concurrence is required before a parcel is considered complete for soil management purposes, or the relationship between post-remediation HHRA findings and any subsequent NFA determination, if required.

On a multi-parcel, phased redevelopment site, absence of defined post-remediation HHRA management standards introduces the potential for inconsistent documentation across parcels and contractors, and for parcel closure-related decisions to proceed without explicit regulatory concurrence. The SMP should be revised to define minimum post-remediation HHRA requirements, including submission timing relative to completion of remediation and confirmation sampling at each parcel; minimum content requirements, including documentation of remaining in-place soil concentrations, receptor assumptions, land use scenarios evaluated, and cumulative risk findings; identification of the responsible party for preparation and submission; the LARWQCB review and concurrence pathway prior to parcel-level closure-related determinations; and the relationship between post-remediation HHRA findings and any NFA determination as described in Section 2.5.4.

2.6 Recommended Improvement 6: Stockpile Management and Soil Movement Controls
Stockpile management and soil movement represent critical implementation control points on large, phased redevelopment sites. Where multiple excavation areas and contractors operate concurrently, clearly defined segregation, tracking, and authorization procedures are necessary to prevent crosscontamination, data gaps, and inconsistent reuse or disposal decisions.

2.6.1 Issue
The SMP restricts soil reuse to the parcel of origin unless otherwise evaluated; however, it does not establish detailed governance controls for stockpile segregation, tracking, sampling frequency, or crossparcel soil movement. On a 112-acre site with phased construction and potentially multiple active excavation areas, absence of structured stockpile management increases the potential for commingling of soils with differing contaminant profiles, inconsistent analytical characterization, cross-parcel transfer without documented risk evaluation, and reduced defensibility of reuse or disposal determinations.

EPA guidance on systematic planning emphasizes predefined decision criteria, documentation pathways, and structured decision logic to support defensible environmental decision-making. DTSC guidance likewise recognizes that soil management plans may need to address soil excavation, soil stockpiling, stockpile characterization, soil disposal, and soil reuse as part of remedial implementation. Together, these concepts support the need for a structured stockpile management and soil movement framework on a large, phased redevelopment site (EPA, 2006; DTSC, 2011).

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2.6.2 Recommendation
Establish a Stockpile Management and Soil Movement Control Framework that integrates both implementation controls and oversight controls.

2.6.2.1 Implementation Controls
• Defined stockpile segregation criteria by COPC type and concentration relative to applicable screening levels.
• Minimum sampling frequency based on stockpile volume, where not already specified in the SMP. The SMP should confirm that the proposed frequency is sufficient given the parcel-specific COPC profile and contaminant distribution variability and provide a basis for the sampling frequency selected.
• Analytical parameter selection tied to known parcel COPCs and delineated contaminant management zones.
• Physical separation of stockpiles by parcel of origin and contaminant category. • Clearly labeled stockpile identification in the field, consistent with the soil impact identification convention established in SMP Section 4.3.
• Defined measures to minimize track-out and off-site transport of contaminated soil by construction vehicles. While hazardous waste manifests are used where required for regulated waste shipments, the SMP should also establish chain-of-custody procedures for non-hazardous impacted soil loads to document origin, destination, and approval prior to departure from the Site.

These measures should include stabilized construction entrances at all active site access points, rumble strips or equivalent track-out reduction devices, and tire wash or wheel wash stations where soil conditions or activity levels warrant.
• Defined inspection, housekeeping, and escalation procedures, including defined street sweeping frequency for adjacent public roadways, daily inspection protocols for track-out conditions at site exits, and defined escalation criteria and response procedures when track-out is observed.

2.6.2.2 Governance Controls
• A unique identification system linking excavation ID, stockpile ID, analytical data, and load tickets.
• A centralized tracking log maintained throughout active construction. • Prohibition of cross-parcel soil transfer without a documented risk evaluation approved by the qualified environmental professional of record.
• Defined written approval authority prior to reuse outside parcel of origin.

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Stockpile management requirements should align with the Parcel-Specific Implementation Matrix and the Screening Level and Risk Decision Framework described in Section 2.5 to ensure consistency across all parcels and redevelopment phases.

2.6.3 Rationale
On large redevelopment sites, stockpile management is a common implementation and documentation control point. Without structured segregation, characterization, and tracking standards, soil movement decisions may become inconsistent across contractors, parcels, and construction phases. A defined stockpile management and soil movement framework helps ensure that reuse, disposal, and transfer decisions are supported by documented analytical data, clear authorization pathways, and consistent implementation procedures (EPA, 2006; DTSC, 2011).

2.7 Recommended Improvement 7: Stormwater Integration
Stormwater runoff represents a primary contaminant migration pathway during active construction. On large redevelopment sites involving soil disturbance and stockpiling, integration of soil management controls with stormwater compliance requirements is essential to prevent off-site transport and maintain regulatory alignment.

2.7.1 Issue
The SMP references stormwater controls in connection with stockpile management (SMP Section 6.4.1); however, stormwater management is not fully integrated into the broader soil disturbance implementation framework at the parcel level. While compliance with the Construction General Permit is a standard regulatory obligation, the SMP does not specify parcel-level responsible parties, minimum best management practice (BMP) requirements tied to known contaminant zones or contact water characterization and management protocols. Without these specifics, implementation may remain inconsistent across parcels and contractors even where general regulatory compliance is intended.

Given the Site's size and phased redevelopment approach, stormwater runoff and dewatering discharges1 may represent potential pathways for off-site migration of contaminated sediments or dissolved-phase constituents if not governed by structured implementation standards. The California Construction General Permit, State Water Resources Control Board Order No. 2022-0057-DWQ, regulates stormwater and authorized non-stormwater discharges associated with construction activity, identifies the discharger as the party responsible for permit compliance, requires implementation of controls, structures, and management practices to minimize or prevent pollutant discharges, and authorizes the Water Boards to require additional BMPs or revised Storm Water Pollution Prevention Plan (SWPPP) provisions to address site-specific conditions. EPA guidance on systematic planning likewise supports the use of 1 Dewatering is unlikely to be required given the depth to groundwater beneath the Site, approximately 150 feet below ground surface; however, perched water may be encountered during excavation activities and could require localized dewatering.

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2.7.2 Recommendation
Establish a Stormwater Management Framework that aligns soil disturbance governance with regulatory discharge compliance requirements and defines both implementation controls and oversight mechanisms.

2.7.2.1 Implementation Controls
• Explicit alignment with the applicable California Construction General Permit (Order No. 2022- 0057-DWQ, as amended).
• Integration with the Site-level or parcel-level SWPPP, as applicable. • Defined minimum BMPs for run-on and runoff control during soil disturbance activities. • Stabilized construction entrances and perimeter controls at all active work areas. • Covered stockpiles and secondary containment where soil contains COPCs above applicable screening levels.
• Procedures for identification and management of contact water generated during excavation activities.
• Sampling and analytical characterization requirements prior to any discharge of contact water or dewatering effluent.
• Defined treatment protocols for dewatering effluent where discharge thresholds may be exceeded.

2.7.2.2 Governance Controls
• Identification of the responsible party for Construction General Permit and SWPPP compliance at the parcel level.
• Defined documentation pathway for discharge authorization, including sanitary sewer approval, National Pollutant Discharge Elimination System (NPDES) permit coverage, or off-site disposal, as applicable.
• Integration of stormwater and dewatering controls into the Parcel-Specific Implementation Matrix for parcels with known impact zones or perched water conditions.

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2.7.3 Rationale
Stormwater runoff and dewatering activities represent key regulatory compliance obligations and potential contaminant migration pathways during active construction. Without structured integration of these requirements into the SMP governance framework, implementation may vary between parcels and contractors, increasing the potential for unintended off-site transport of contaminated sediments or dissolved-phase constituents and inconsistent discharge compliance across redevelopment phases. A defined stormwater management framework helps ensure that BMP implementation, contact water management, discharge authorization, and documentation requirements are applied consistently across all parcels and phases of work (State Water Resources Control Board, 2022; EPA, 2006).

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3. Additional Considerations: Process-Related Contaminants of Potential Concern
Historical operations at the Site included manufacturing processes characteristic of the aerospace industry during the mid-20th century, including surface finishing, electroplating, degreasing, solvent storage, and wastewater handling activities. Identification COPCs is a foundational component of a defensible conceptual site model and should reflect not only documented releases but also constituents reasonably associated with historical industrial process trains. Where process-related constituents are excluded from the COPC list, that exclusion should be supported by sufficient technical justification and analytical evidence rather than inferred solely from limited datasets or incomplete spatial characterization (DTSC, 2011; EPA, 1995; EPA, 1998).

The following subsections evaluate select process-related constituents that are reasonably associated with documented historical operations at the Site and warrant consideration within the Soil Impact Assessment and Characterization framework (SMP Section 5.0) to help ensure that the investigation remains technically complete and protective of human health and the environment.

Inclusion of these constituents in the analytical suite is a completeness and defensibility measure, not an assertion of presence. Where these constituents are not detected at method detection limits at or below the applicable screening levels, they may be screened out of the parcel-specific COPC list with appropriate documentation.

3.1 Per- and Polyfluoroalkyl Substances (PFAS) and Hexavalent Chromium (Cr(VI))
Aerospace manufacturing during the Site’s operational period commonly included surface finishing operations such as degreasing, etching, anodizing, passivation, and electroplating (EPA, 1995; EPA, 1998). These processes were integral to corrosion protection and structural durability of aircraft and missile components.

Chromium electroplating is of particular relevance. The Interstate Technology and Regulatory Council (ITRC) states that PFAS, particularly perfluorooctane sulfonate (PFOS), were used as mist suppressants added to metal plating and finishing baths to prevent air emissions of toxic metal fumes. This supports consideration of PFAS as a plausible process-related COPC in areas associated with historical chromium plating or related surface-finishing operations (ITRC, 2023).

Chromium plating uses chromic acid solutions, and Cr(VI) is directly associated with such operations.

While total chromium may have been analyzed in limited groundwater samples at the Site, chromium speciation has not been evaluated to distinguish Cr(VI) from total chromium. Because Cr(VI) exhibits distinct toxicity and mobility relative to total chromium, it represents a discrete analyte that should be evaluated independently where plating-related activities are plausible. Reliance on total chromium alone can therefore be insufficient for evaluating potential human health risk or waste handling requirements in plating-related source areas.

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Technical Review of the SMP Prepared for the DAC Plant A, Santa Monica, CA Page 22 Given the documented industrial processes and recognized source categories, PFAS and Cr(VI) are reasonably associated with historical Site operations and warrant consideration where field observations or historical infrastructure indicate potential plating-related source areas. Although EPA finalized National Primary Drinking Water Regulations for six PFAS in April 2024, EPA subsequently announced in May 2025 that it would retain the standards for PFOA and PFOS while rescinding and reconsidering the regulatory determinations for PFHxS, PFNA, HFPO-DA, and the associated hazard index mixture approach. This changing federal regulatory posture does not diminish the technical relevance of PFAS evaluation at the Site; rather, it underscores the need for a reasoned, site-specific assessment of PFAS where source history and site conditions indicate potential presence. ATSDR toxicological information for perfluoroalkyls further supports the human health relevance of PFAS evaluation.

Within the Soil Impact Assessment and Characterization framework described in SMP Section 5.0, soil samples collected during disturbance activities in areas where infrastructure or residual materials consistent with historical surface finishing or metal plating operations are encountered should include PFAS and Cr(VI) in the analytical suite. For PFAS in soil, the current EPA multi-matrix method is Method 1633A, which applies to aqueous, solid, biosolids, and tissue samples. For Cr(VI) in soil, the standard SW-846 approach is Method 3060A for alkaline digestion extraction, followed by an appropriate determinative method such as Method 7196A; where lower-level or more defensible speciation data are needed, Method 6800 may be considered as a higher-tier analytical alternative. Inclusion of these analytes does not presume their presence but ensures that potential impacts reasonably associated with documented process trains are evaluated and that exclusion, if appropriate, is supported by sufficient analytical evidence.

3.2 Consideration of 1,4-Dioxane as a Contaminant of Potential Concern Chlorinated solvents were widely used in aerospace manufacturing for degreasing and cleaning of metal components (EPA, 1995; EPA, 1998). ATSDR states that 1,4-dioxane was used primarily as a stabilizer in chlorinated solvents, particularly 1,1,1-trichloroethane, and the Interstate Technology and Regulatory Council (ITRC) likewise identifies its historical use as a solvent stabilizer and its common co-occurrence with chlorinated solvent releases (ATSDR, 2012; ITRC, 2020). 1,4-Dioxane is highly water soluble, only weakly retarded by sorption to soil, does not form a separate non-aqueous phase liquid, and is relatively resistant to biodegradation under many subsurface conditions (EPA, 2017; ITRC, 2020; ATSDR, 2012). As a result, 1,4-dioxane may migrate beyond the spatial extent of associated solvent plumes and may not be adequately characterized by monitoring networks designed primarily to define chlorinated solvent distribution. Accordingly, the absence of detections within a spatially or vertically limited monitoring network is not, by itself, a sufficient technical basis to conclude that 1,4-dioxane is absent in areas that have not yet been sampled.

In addition, 1,4-dioxane has been detected in groundwater beneath the Site. Site data indicate one exceedance of the 1 microgram per liter notification level in January 2024 in groundwater sampled from an onsite well, as well as low-level detections in an adjacent well. Boeing is currently conducting additional investigations at the Site, including the installation of additional monitoring wells, to expand and improve the current monitoring network.

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Packet Pg. 1019 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) March 19, 2026
Technical Review of the SMP Prepared for the DAC Plant A, Santa Monica, CA Page 23 Because soil often represents the initial release medium for solvent-related compounds at manufacturing facilities, evaluation of potential source areas in soil is necessary to support defensible exclusion of solvent stabilizer constituents from the COPC list. Within the Soil Impact Assessment and Characterization framework described in SMP Section 5.0, soil samples collected in areas associated with solvent storage, degreasing operations, wastewater handling, or disposal infrastructure should include 1,4- dioxane in the analytical suite where chlorinated solvent impacts are observed or reasonably suspected.

Appropriate analytical methods for 1,4-dioxane in soil may include EPA Method 8270E using selective ion monitoring, where laboratory sensitivity is adequate, or EPA Method 8260D with laboratoryvalidated low-level detection capability sufficient to achieve reporting limits at or below applicable soil screening levels. Inclusion of 1,4-dioxane in the analytical suite does not presume its presence but helps ensure technical completeness and supports defensible exclusion where appropriate.

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4. Evaluation of Phase I ESA Recommendations and SMP Alignment The Phase I ESA for 2800 28th Street (AIN 4272-031-005) identified a Recognized Environmental Condition (REC #1) associated with historical aircraft manufacturing activities and recommended two actions in connection with redevelopment of the property. The following subsections evaluate whether the current SMP sufficiently addresses each recommendation at both a conceptual and implementation level.

4.1 Phase I ESA Recommendation 1: Soil Pre-Characterization The Phase I ESA recommends collection of soil data sufficient to laterally and vertically characterize subsurface conditions anticipated to be encountered during construction activities. The intent of this recommendation is to define, in advance of redevelopment, the horizontal and vertical extent of impacted soil so that excavation planning, handling procedures, worker protection measures, and disposal pathways can be established before construction begins.

Lateral and vertical characterization, as intended by the Phase I recommendation, implies:
• Delineation of the horizontal footprint of impacted areas within the parcel boundaries. • Determination of vertical extent of impacts relative to planned excavation depths. • Identification of contaminant types and concentration ranges present within the parcel. • Integration of characterization findings into construction planning and soil management controls prior to disturbance.

The current SMP includes procedures for soil monitoring during excavation and confirmation sampling following removal. However, it does not establish a structured, parcel-specific precharacterization framework for AIN 4272-031-005.

To satisfy the intent of the Phase I recommendation, the SMP would need to define, at a minimum:
• Sampling density and spatial distribution sufficient to support parcel-level delineation. • Lateral and vertical delineation criteria to be achieved prior to disturbance. • Integration of historical operations, prior investigation data, and investigation data being generated through implementation of the Work Plans into mapped contaminant management zones.
• Survey-controlled documentation of excavation extents and confirmation sampling locations. • Inclusion of process-related COPCs, such as PFAS, Cr(VI), and 1,4-dioxane, in the precharacterization analytical suite, as discussed in Section 3 of this review.

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Technical Review of the SMP Prepared for the DAC Plant A, Santa Monica, CA Page 25 Instead, the SMP relies primarily on field observations, PID screening, and reactive sampling triggered during soil disturbance. While these measures are appropriate as construction-phase controls, they do not substitute for structured pre-characterization where a REC has been identified and advanced characterization has been recommended. Reliance on reactive identification of impacts during active soil disturbance increases the potential for exposure, inadequate waste segregation, and uncertainty regarding disposal pathways that pre-characterization is intended to reduce.

Recommendation 1 Alignment Determination
The SMP does not establish a defined, parcel-specific pre-characterization program for AIN 4272-031- 005 and therefore does not fully satisfy the intent of the Phase I ESA recommendation for lateral and vertical characterization of subsurface conditions in advance of redevelopment.

4.2 Phase I ESA Recommendation 2: Preparation of an SMP Using PreCharacterization Data The Phase I ESA recommends preparation of an SMP that incorporates both newly collected soil precharacterization data and existing Boeing investigation data to identify areas of concern and define special handling and disposal requirements. The intent of this recommendation is to ensure that characterization findings are formally integrated into a structured management framework before construction, rather than addressed reactively during soil-disturbing activities.

Preparation of an SMP based on pre-characterization data, as intended by the Phase I recommendation, implies:
• Integration of delineated impact zones into mapped contaminant management areas. • Definition of contaminant-specific handling, segregation, and disposal criteria tied to characterized conditions.
• Establishment of parcel-specific controls informed by known subsurface conditions. • Structured procedures for managing previously unknown conditions discovered during construction.
• Clear documentation and approval pathways for all soil management decisions.

The current SMP contains general soil handling and disturbance procedures applicable across the Site.

However, it does not define or implement a parcel-specific framework for AIN 4272-031-005 that integrates pre-characterization findings consistent with the intent of this recommendation. As discussed in Section 2 of this review, key missing elements include delineated contaminant management zones, a parcel-specific implementation matrix, defined risk decision logic, and structured stop-work and restart criteria, among others. The process-related COPCs identified in Section 3 of this review should also be incorporated into the parcel-level analytical program, as appropriate.

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Packet Pg. 1022 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) March 19, 2026
Technical Review of the SMP Prepared for the DAC Plant A, Santa Monica, CA Page 26 Although the SMP includes procedures for addressing previously unknown conditions encountered during disturbance, those procedures rely largely on field observations, notification, and professional judgment rather than structured decision logic and clearly defined authority thresholds of the type described in Section 2 of this review. The intent of the Phase I recommendation is an SMP built on a characterized foundation, rather than one that relies primarily on reactive discovery during disturbance.

Recommendation 2 Alignment Determination
The SMP provides general soil management procedures but does not establish a parcel-specific implementation and governance framework for AIN 4272-031-005 that fully integrates precharacterization findings consistent with the intent of the Phase I ESA recommendation. The improvements described in Section 2 of this review, together with incorporation of the process-related COPCs discussed in Section 3, represent the minimum framework necessary to address this recommendation at the parcel level.

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5. Conclusions
Hazen conducted a technical review of the Soil Management Plan, Former Douglas Aircraft Company Plant A, Santa Monica, California, prepared by EA for The Boeing Company and dated December 18, 2025. The review evaluated whether the SMP, as written, is sufficiently specific and implementable to ensure consistent and defensible protection of human health and the environment during phased redevelopment of a 112-acre, multi-parcel site with sensitive receptors and a complex contamination history.

The SMP contains a structurally sound framework and a number of strong procedural elements. However, as detailed in the preceding sections of this review, the SMP requires revision in several areas before it can be considered sufficiently specific and implementable for a site of this scale and complexity. These revisions are especially critical given that housing developments are already being proposed across the Site and additional redevelopment projects are anticipated in the near term, making it essential that a more thorough and comprehensive plan be established as soon as possible.

The following subsections summarize the recommended revisions and Phase I ESA alignment determinations for the LARWQCB’s consideration in directing Boeing to revise and resubmit the SMP.

5.1 Recommended Governance and Implementation Revisions The SMP should be revised to incorporate the following seven primary improvements, including the supplemental groundwater protection measure described under Improvement 3. Boeing should be directed to address each item prior to approval of redevelopment-related SMP implementation.

Recommended Improvement 1: Parcel-Specific SMP Implementation Matrix and Parcel Maps (Section

2.1). The SMP should include a parcel-specific implementation matrix for each AIN defining current and planned land use, known COPCs and impact zones, applicable screening levels, monitoring requirements, stop-work triggers, notification pathways, and documentation standards, supported by parcel maps visually delineating AIN boundaries, contaminant impact zones, sensitive receptor locations, and monitoring applicability areas.

Recommended Improvement 2: Pre-Characterization and Delineated Contaminant Management Zones (Section 2.2). The SMP should require development and incorporation of delineated contaminant management zones based on historical operations, prior investigation data, investigation data generated through implementation of the Work Plans, and contaminant-specific behavior. These zones should be mapped laterally and vertically and referenced to individual parcels. For each zone, the SMP should define implementation and governance requirements, including mandatory pre-disturbance characterization sampling, excavation and confirmation sampling protocols, enhanced air quality, particulate, dust, field screening, and/or sampling requirements appropriate to zone-specific contaminants of potential concern, waste profiling triggers, defined decision thresholds for additional characterization or response actions, and documentation requirements prior to soil movement, reuse, or off-site disposal.

Recommended Improvement 3: Stop-Work and Restart Decision Framework with Defined Authority (Section 2.3). The SMP should include a clearly defined stop-work and restart decision framework Item 7-A
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Technical Review of the SMP Prepared for the DAC Plant A, Santa Monica, CA Page 28 supported by a one-page decision tree, defining numeric stop-work triggers, immediate response procedures, a defined notification cascade, explicit authority designations for the Environmental Observer and Site EH&S Manager, circumstances requiring LARWQCB concurrence prior to restart, written restart authorization requirements, and minimum professional qualifications for environmental oversight personnel.

Supplemental Groundwater Protection Measure under Improvement 3: Residual Contamination at the Base of Excavations (Section 2.3.5). The SMP should establish procedures for addressing contaminated soil that may remain at the base of excavations after final grade is reached. At a minimum, the SMP should require base-of-excavation confirmation sampling, leaching-to-groundwater evaluation criteria, defined notification thresholds, authorization prior to backfilling, and documentation requirements for any residual contamination left in place where groundwater protection may be affected.

Recommended Improvement 4: Sensitive Receptor Protection Protocol (Section 2.4). The SMP should include a sensitive receptor protection protocol applicable to parcels adjacent to or occupied by schools and daycare facilities, defining enhanced dust suppression measures, continuous or high-frequency perimeter air monitoring with defined numeric action levels, operational restrictions during active school hours, truck routing and staging setbacks, advance notification procedures, and a designated point of contact for school and daycare administrators during active construction phases.

Recommended Improvement 5: Screening Level and Risk Decision Framework (Section 2.5). The SMP should establish a screening level and risk decision framework defining default receptor assumptions by parcel type, applicable screening level tables by land use, an acceptable cancer risk range of 1 x 10^-6 to 1 x 10^-4 and a Hazard Index threshold of 1.0, cumulative risk evaluation methodology, approval authority for alternative risk-based determinations, and clarification that No Further Action determinations are made by the LARWQCB and not by the property owner or consultant. The SMP should also define post-remediation HHRA submission timing, minimum content requirements, responsible party identification, and LARWQCB review and concurrence pathway prior to parcel-level closure.

Recommended Improvement 6: Stockpile Management and Soil Movement Controls (Section 2.6). The SMP should establish a stockpile management and soil movement control framework defining stockpile segregation criteria by COPC type, minimum sampling frequency by volume and contaminant profile, physical separation requirements by parcel of origin, a unique identification system linking excavation and stockpile data, a centralized tracking log, prohibition on cross-parcel soil transfer without documented risk evaluation and written approval, and defined track-out prevention, inspection, housekeeping, and escalation procedures.

Recommended Improvement 7: Stormwater Integration (Section 2.7). The SMP should integrate stormwater and dewatering management into the soil disturbance governance framework by explicitly aligning with the California Construction General Permit (Order No. 2022-0057-DWQ, as amended), defining minimum BMPs for run-on and runoff control, establishing contact water characterization and discharge authorization procedures, identifying the responsible party for SWPPP compliance at the parcel level, and defining written approval authority prior to initiating any dewatering discharge.

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5.2 Additional Contaminant Considerations
As detailed in Section 3, the following process-related constituents are reasonably associated with documented historical operations at the Site and should be incorporated into the analytical suite for soil samples collected during disturbance activities in relevant areas. Exclusion of these constituents from the COPC list should be supported by sufficient analytical evidence rather than inferred absence.

PFAS: Soil samples collected in areas where surface finishing or metal plating infrastructure or residual materials are encountered should be analyzed for PFAS using EPA Method 1633A, or the most current EPA-validated multi-matrix PFAS method.

Hexavalent Chromium (Cr(VI)): Chromium speciation has not been evaluated at the Site to distinguish Cr(VI) from total chromium. Soil samples collected in relevant areas should be analyzed using EPA Method 3060A with an appropriate determinative method such as EPA Method 7196A, or EPA Method 6800 where higher analytical defensibility is warranted. 1,4-Dioxane: Soil samples collected in areas associated with solvent storage, degreasing operations, wastewater handling, or disposal infrastructure should include analysis for 1,4-dioxane using EPA Method 8270E with selective ion monitoring, or EPA Method 8260D with validated low-level detection capability sufficient to achieve reporting limits at or below applicable screening levels.

In addition, the potential for off-site vapor migration to nearby residential properties should be considered if existing SVE systems are modified, temporarily halted, or permanently shut down during redevelopment activities, as cessation of active vapor extraction could affect the basis for prior conclusions regarding the vapor intrusion pathway.

5.3 Phase I ESA Alignment Determinations for 2800 28th Street (AIN 4272-031- 005)
The SMP does not fully address the intent of the two recommendations identified in the Phase I ESA for 2800 28th Street (AIN 4272-031-005). Prior to approving redevelopment activities for this parcel, the LARWQCB should direct Boeing, or another responsible party as appropriate, to address the following items.

Phase I ESA Recommendation 1: Soil Pre-Characterization. The SMP does not establish a defined, parcel-specific pre-characterization program for AIN 4272-031-005 and therefore does not fully satisfy the intent of the Phase I ESA recommendation for lateral and vertical characterization of subsurface conditions in advance of redevelopment. As noted in Section 2.2, a parcel-specific pre-characterization program should, at a minimum, define sampling density and spatial distribution sufficient to support parcel-level delineation, lateral and vertical delineation criteria to be achieved prior to disturbance, integration of historical operations, prior investigation data, and existing Boeing data into mapped contaminant management zones, and inclusion of PFAS, Cr(VI), and 1,4-dioxane in the analytical suite, as appropriate, for LARWQCB review and approval prior to commencement of construction at this parcel.

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Packet Pg. 1026 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) March 19, 2026
Technical Review of the SMP Prepared for the DAC Plant A, Santa Monica, CA Page 30 Phase I ESA Recommendation 2: SMP Preparation Using Pre-Characterization Data. The SMP does not fully define and implement a parcel-specific governance and implementation framework for AIN 4272-031-005 that integrates pre-characterization findings consistent with the intent of the Phase I ESA recommendation. Boeing should be directed to revise and resubmit the SMP to incorporate the parcellevel improvements described in Section 2 of this review for AIN 4272-031-005 prior to LARWQCB approval. At a minimum, these improvements should include delineated contaminant management zones, parcel-specific implementation requirements, defined risk decision logic, structured stop-work and restart criteria, and clear documentation and approval pathways for soil management decisions. The parcel-level analytical program should also incorporate the process-related COPCs identified in Section 3, as appropriate.

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6. References
Agency for Toxic Substances and Disease Registry (ATSDR). 2012. Toxicological Profile for 1,4- Dioxane. https://www.atsdr.cdc.gov/toxprofiles/tp187.pdf Agency for Toxic Substances and Disease Registry (ATSDR). 2021. Toxicological Profile for Perfluoroalkyls. https://www.atsdr.cdc.gov/ToxProfiles/tp200.pdf California Code of Regulations, Title 8, Section 1541. General Requirements for Excavations. https://www.dir.ca.gov/title8/1541.html
California Code of Regulations, Title 8, Section 5192. Hazardous Waste Operations and Emergency Response. https://www.dir.ca.gov/title8/5192.html
California Department of Toxic Substances Control (DTSC). 2001. Information Advisory: Clean Imported Fill Material Fact Sheet. October. https://dtsc.ca.gov/information-advisory-clean-imported-fillmaterial-fact-sheet/ California Department of Toxic Substances Control (DTSC). 2006. Interim Guidance: Evaluation of School Sites with Potential Soil Contamination as a Result of Lead-Based Paint, Termiticides, and Electrical Transformers. https://dtsc.ca.gov/wpcontent/uploads/sites/31/2018/01/School_Lead_Guidance.pdf California Department of Toxic Substances Control (DTSC). 2011. Investigation and Remediation of Plating Facilities. May. https://dtsc.ca.gov/wp-content/uploads/sites/31/2018/11/Plating_051611.pdf California Department of Toxic Substances Control (DTSC). 2022. HHRA Note 4: Guidance for Screening Level Human Health Risk Assessments. March. https://dtsc.ca.gov/wpcontent/uploads/sites/31/2022/02/HHRA-Note-Number-4-March-2022-A2.pdf California Department of Toxic Substances Control (DTSC). 2025. HHRA Note 1: Default HHRA Exposure Parameters. April. https://dtsc.ca.gov/wp-content/uploads/sites/31/2025/05/HHRA-Note-1- Revised-April-2025.pdf
Engineering Analytics, Inc. (EA). 2024. Additional Site Assessment Work Plan, Former Douglas Aircraft Company Plant A, Santa Monica, California. Prepared for The Boeing Company. November 26. https://documents.geotracker.waterboards.ca.gov/esi/uploads/geo_report/2306899905/SLT4307472.PDF Engineering Analytics, Inc. (EA). 2025a. Additional Site Assessment Work Plan Addendum Number 1, Boeing Former Douglas Aircraft Company (DAC) Plant A, Santa Monica, California. Prepared for The Boeing Company. February 19.
https://documents.geotracker.waterboards.ca.gov/esi/uploads/geo_report/4096414506/SLT4307472.PDF Engineering Analytics, Inc. (EA). 2025b. Soil Management Plan, Former Douglas Aircraft Company Plant A, Santa Monica, California. Prepared for The Boeing Company. December 18. https://documents.geotracker.waterboards.ca.gov/esi/uploads/geo_report/2180769026/SLT4307472.PDF Item 7-A
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Technical Review of the SMP Prepared for the DAC Plant A, Santa Monica, CA Page 32 Haley & Aldrich, Inc. 2025. Report on ASTM Phase I Environmental Site Assessment, 2800 28th Street, Santa Monica, California. December 5.

Interstate Technology and Regulatory Council (ITRC). 2020. 1,4-Dioxane Technical and Regulatory Guidance. https://14d-1.itrcweb.org/
Interstate Technology and Regulatory Council (ITRC). 2023. PFAS Technical and Regulatory Guidance Document and Fact Sheets. https://pfas-1.itrcweb.org/
Los Angeles Regional Water Quality Control Board (LARWQCB). 2012. Executive Officer's Report.

July 12.
https://www.waterboards.ca.gov/losangeles/board_info/eo_reports/past_eo_report/2012/eorpt12jul.pdf South Coast Air Quality Management District (SCAQMD), Rule 1166. Volatile Organic Compound Emissions from Decontamination of Soil. https://www.aqmd.gov/docs/default-source/rule-book/regxi/rule-1166.pdf South Coast Air Quality Management District (SCAQMD), Rule 1466. Control of Particulate Emissions from Soils with Toxic Air Contaminants. https://www.aqmd.gov/docs/default-source/rule-book/regxiv/rule-1466.pdf State Water Resources Control Board. 2022. NPDES General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities, Order WQ 2022-0057-DWQ. https://www.waterboards.ca.gov/water_issues/programs/stormwater/construction/general_permit_reissuan ce.html
State Water Resources Control Board. 2023. Final Draft Supplemental Vapor Intrusion Guidance.

February.
https://www.waterboards.ca.gov/water_issues/programs/site_cleanup_program/vapor_intrusion/docs/202 3/Final-Draft-Supplemental-VI-Guidance-Feb2023.pdf
U.S. Environmental Protection Agency (EPA). 1995. Profile of the Aerospace Industry. EPA/310-R-95- 013. https://www.epa.gov/sites/default/files/2015-09/documents/aero.pdf U.S. Environmental Protection Agency (EPA). 1998. Sector Notebook Project: Aerospace Manufacturing Industry. EPA/310-R-97-005. https://www.epa.gov/compliance/sector-notebook-project U.S. Environmental Protection Agency (EPA). 2005a. Guidance on Selecting Age Groups for Monitoring and Assessing Childhood Exposures to Environmental Contaminants. EPA/630/P-03/003F. https://www.epa.gov/sites/default/files/2014-05/documents/childrens_agegroups.pdf U.S. Environmental Protection Agency (EPA). 2005b. Supplemental Guidance for Assessing Susceptibility from Early-Life Exposure to Carcinogens. EPA/630/R-03/003F. https://www.epa.gov/sites/default/files/2013-09/documents/childrens_supplement_final.pdf U.S. Environmental Protection Agency (EPA). 2006. Guidance on Systematic Planning Using the Data Quality Objectives Process: EPA QA/G-4. EPA/240/B-06/001. https://www.epa.gov/sites/default/files/2015-06/documents/g4-final.pdf Item 7-A
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Packet Pg. 1029 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) March 19, 2026
Technical Review of the SMP Prepared for the DAC Plant A, Santa Monica, CA Page 33 U.S. Environmental Protection Agency (EPA). 2012. Institutional Controls: A Guide to Planning, Implementing, Maintaining, and Enforcing Institutional Controls at Contaminated Sites. EPA-540-R-09- 001. December. https://www.epa.gov/sites/default/files/2015-09/documents/ic-guide.pdf U.S. Environmental Protection Agency (EPA). 2017. Technical Fact Sheet: 1,4-Dioxane. EPA 505-F-17- 001. https://nepis.epa.gov/Exe/ZyPDF.cgi/P100THWG.PDF?Dockey=P100THWG.PDF U.S. Environmental Protection Agency (EPA). 2018a. SW-846 Test Method 8260D: Volatile Organic Compounds by Gas Chromatography/Mass Spectrometry (GC/MS). Revision 4, June 2018. https://www.epa.gov/hw-sw846/sw-846-test-method-8260d-volatile-organic-compounds-gaschromatographymass-spectrometry-gcms U.S. Environmental Protection Agency (EPA). 2018b. SW-846 Test Method 8270E: Semivolatile Organic Compounds by Gas Chromatography/Mass Spectrometry (GC/MS). Revision 6, June 2018. https://www.epa.gov/hw-sw846/sw-846-test-method-8270e-semivolatile-organic-compounds-gaschromatographymass-spectrometry U.S. Environmental Protection Agency (EPA). 2021. Revitalization-Ready: A Guide to Revitalizing Land in Your Community. EPA Office of Brownfields and Land Revitalization. December. https://www.epa.gov/system/files/documents/2021-12/revitalization-ready-guide-final-508compliant-12- 10-21.pdf
U.S. Environmental Protection Agency (EPA). 2024a. PFAS National Primary Drinking Water Regulation. 89 Fed. Reg. 32532. April 26, 2024. https://www.epa.gov/sdwa/and-polyfluoroalkylsubstances-pfas U.S. Environmental Protection Agency (EPA). 2024b. Method 1633A: Analysis of Per- and Polyfluoroalkyl Substances (PFAS) in Aqueous, Solid, Biosolids, and Tissue Samples by LC-MS/MS.

December 2024. https://www.epa.gov/cwa-methods/method-1633-analysis-and-polyfluoroalkylsubstances-pfas-aqueous-solid-biosolids-and-tissue U.S. Environmental Protection Agency (EPA). n.d. SW-846 Test Method 3060A: Alkaline Digestion for Hexavalent Chromium. https://www.epa.gov/hw-sw846/sw-846-test-method-3060a-alkaline-digestionhexavalent-chromium U.S. Environmental Protection Agency (EPA). n.d. SW-846 Test Method 6800: Elemental and Molecular Speciated Isotope Dilution Mass Spectrometry. https://www.epa.gov/hw-sw846/sw-846-test-method6800-elemental-and-molecular-speciated-isotope-dilution-mass-spectrometry U.S. Environmental Protection Agency (EPA). n.d. SW-846 Test Method 7196A: Chromium, Hexavalent (Colorimetric). https://www.epa.gov/hw-sw846/sw-846-test-method-7196a-chromium-hexavalentcolorimetric Item 7-A
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Packet Pg. 1030 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) Los Angeles Regional Water Quality Control Board
June 24, 2026
Mr. Clare Thomas
President
Friends of Sunset Park
P.O. Box 5823
Santa Monica, CA 90409
SUBJECT: COMMENTS ON THE FRIENDS OF SUNSET PARK LETTER DATED MARCH 19, 2026
SITE: THE BOEING COMPANY, FORMER DOUGLAS AIRCRAFT COMPANY PLANT A, 3000 OCEAN PARK BOULEVARD, SANTA MONICA,
CALIFORNIA (SCP NO. 0130B, SITE ID NO. 2043H00, GLOBAL ID SLT4307472)
Dear Mr. Thomas:

Los Angeles Regional Water Quality Control Board (Los Angeles Water Board) staff have received your letter dated March 19, 2026 (Letter), which arrived via email on March 24, 2026, regarding comments on the residential development activities in the Santa Monica Business Park and on issues previously raised in a letter dated February 7, 2024.

Friends of Sunset Part Comments
The Letter submits comments based on information obtained from the 2023 Historic Use Analysis of the Business Park, the 2025 Public Participation Plan as well as the City of Santa Monica sponsored public outreach programs presented by developers concerning proposed developments of two side-by-side 8-story multi-unit residential buildings at 2716 Ocean Park Boulevard and 2800 28th Street. The following are your concerns (italicized verbatim) documented in the Letter followed by Los Angeles Water Board staff responses to your comments:

1. The Letter indicates that documents referenced above and submitted to the Los Angeles Water Board are not a proper substitute for California Environmental Quality Act (CEQA) review, which is designed and intended to allow far more rigorous public comment and participation, through the formal legal processes established by statute. Nor does anything in the reports justify avoidance of a full remediation requirement of the subject properties. Because it appears that things are proceeding apace under the public radar, this is causing concern for our members.

Item 7-A
September 22, 2026
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September 22, 2026

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Packet Pg. 1031 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) Mr. Clare Thomas - 2 - June 24, 2026
Friends of Sunset Park
SCP No. 0130B
Responses:
a. The 2023 Historic Use Analysis of the Business Park and the 2025 Public Participation Plan were not intended to be a substitute for the CEQA review process. These documents were created before any proposed redevelopment and pertain to the entire Boeing Former Douglas Aircraft Company Plant A Site (Site) which environmental site assessment and cleanup activities are being overseen by the Los Angeles Water Board Site Cleanup Program (SCP). The City of Santa Monica is the Lead Agency for the CEQA related to the proposed redevelopment projects at 2716 Ocean Park Boulevard and 2800 28th Street. The Los Angeles Water Board was not involved in any city-sponsored public outreach programs presented by developers as referenced in the Letter.
b. The 2023 Historical Use Analysis of the Business Park prepared by Advisian was used to identify data gaps and determine where additional site assessment activities may be needed for the Site.
c. The goal of the Site’s 2025 Public Participation Plan prepared by Engineering Analytics was to develop a strategy to identify and address potential stakeholder concerns and establish effective channels of communication between the community and other stakeholders, the Los Angeles Water Board, and Boeing, in order to understand and prepare to respond to community concerns and questions about the Site, inform the community of the progress of activities associated with the Site, and provide opportunities for the community to comment on the Site. d. Boeing is completing ongoing remediation activities at the Site. Community outreach activities have been conducted and they’re ongoing, which included the distribution of a number of Fact Sheets and work notices to inform the community of various Site activities.

2. Our organization is concerned that the developers’ public outreach and the “Public Participation Plan,” as circulated, are materially inadequate because they do not clearly explain to our residents, or the decision-makers, or prospective occupants, the continuing health and safety significance of unresolved volatile organic compound (“VOC”) contamination underlying portions of the former Douglas Aircraft Company Plant A area, including the portions extending westward toward 25th Street and the parcels now under consideration for high-density residential development at 2716 Ocean Park Boulevard and 2800 28th Street.

Response:
a. As previously noted, the Los Angeles Water Board is the regulatory agency overseeing Boeing’s site assessment and cleanup work at the Site. The two proposed development activities are located within the Site. Los Angeles Water Board staff are currently working with Boeing, the developers, and Item 7-A
September 22, 2026
Item 7-A
September 22, 2026

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Packet Pg. 1032 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) Mr. Clare Thomas - 3 - June 24, 2026
Friends of Sunset Park
SCP No. 0130B
the City of Santa Monica to make sure the Site is suitable for its intended use. The Los Angeles Water Board was not part of the developers’ public outreach activities and will continue conducting our own public participation associated with Boeing’s site assessment and cleanup.

3. The technical materials referenced in the underlying site reports identify continuing unresolved contamination concerns in Subareas C, D, E, and F, including: persistent high VOC concentrations in field gas zones underlying former source areas despite more than a decade of soil vapor extraction; documented historical presence of Trichloroethylene and 1,1-Dichloroethylene in soil vapor and perched groundwater to depths approaching 90 feet below ground surface; downgradient detections indicating possible continuing plume migration; acknowledged need for further lateral and vertical delineation, including westward migration concerns toward Clover Park and adjacent residential areas.

Response:
a. The Los Angeles Water Board acknowledges the residual contamination concerns identified in Subareas C, D, E, and F, including persistent VOC concentrations in soil vapor and groundwater, potential plume migration, and remaining data gaps related to the lateral and vertical extent of impacts.

The Los Angeles Water Board is currently working with Boeing to complete additional site assessment and remediation activities to ensure the Site is suitable for its intended use. Current assessment activities include expanded soil, soil vapor, and groundwater investigations intended to further delineate the nature and extent of contamination, evaluate potential migration pathways, and address identified data gaps, including areas toward Clover Park and adjacent residential areas.

4. The Public Participation Plan does not explain in plain language that these contaminants present potential vapor intrusion risks to future residents, particularly; children, pregnant women, elderly occupants, and persons subject to long-duration indoor exposure.

Response:
a. The Public Participation Plan describes how project information will be provided to the local community and other interested stakeholders concerning the Site activities being performed at the Site. It would not be the document that provides information on the contaminants of concern at the Site. Information about the contaminants of concern at the Site can be found at on the State Water Resources Control Board GeoTracker database (GeoTracker) under the Summary tab at the following location:
https://geotracker.waterboards.ca.gov/profile_report.asp?global_id=SLT43 07472.

Item 7-A
September 22, 2026
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September 22, 2026

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Packet Pg. 1033 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) Mr. Clare Thomas - 4 - June 24, 2026
Friends of Sunset Park
SCP No. 0130B
The Los Angeles Water Board will continue providing project updates and fact sheets to the community in plain language regarding the ongoing environmental investigations of VOCs in soil, soil vapor and groundwater.

Previous public communications issued by the Los Angeles Water Board can also be found on GeoTracker under the Community Involvement tab.

5. We are specifically concerned about proposals for residential development at 2716 Ocean Park Blvd and 2800 28th Street, and any other proposals in Subareas C, D, E, and F, in light of the documented presence of volatile organic compounds (VOCs) in soil vapor, perched groundwater, and the regional aquifer beneath and downgradient of these areas. The 2023 “Historical Use Analysis Report” by Advisian for the Santa Monica Airport area, as far as we can tell, identifies numerous problems to be addressed, listed at pp 94-95, including but not limited to:
• Persistent, elevated VOC concentrations in fine grained zones beneath the former DAC Plant A area that have not significantly decreased after many years of soil vapor extraction, indicating a long-term subsurface VOC reservoir.
• Historical detections of trichloroethylene (TCE) and 1,1dichloroethene (1,1DCE) in soil vapor and perched groundwater in the vadose zone (to depths of approximately 90 feet) along the western portion of the site, and a clear recommendation for additional lateral and vertical delineation, including within and beneath Clover Park.
• Consistent detections of 1,1DCE at monitoring well MW8 in the regional aquifer downgradient of the site since 2019, suggesting an actively migrating VOC plume whose full extent and behavior are not yet fully understood.
• An explicit warning that before Airport #1 WSW or any proposed water supply wells in the area are brought into production, potential changes to the groundwater flow regime and effects on contaminant concentrations must be evaluated, along with further vadose zone characterization to understand VOC migration to the regional aquifer.

These findings underscore that the subsurface conditions remain incompletely characterized and that significant contamination persists in both the vadose zone and groundwater. While such conditions are already a cause for concern for commercial and industrial uses, they are fundamentally incompatible with high density residential development—especially when that development would house children, pregnant women, and other sensitive populations.

Item 7-A
September 22, 2026
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September 22, 2026

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Packet Pg. 1034 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) Mr. Clare Thomas - 5 - June 24, 2026
Friends of Sunset Park
SCP No. 0130B
Response:
a. The Los Angeles Water Board agrees that the Historical Use Analysis Report identified various Site data gaps. This document was used to aid in the development of a work plan to conduct additional Site assessment activities.
b. These Site assessment activities are currently being conducted and a report documenting the results is due to the Los Angeles Water Board via GeoTracker by October 30, 2026. Based on the data collected the need to expand the current remediation system will be evaluated.

6. Per City of Santa Monica Planning Ordinance, a Phase 2 ESA site investigation is required for the entire Business Park property prior to construction of multi-family residential housing. The field efforts should include soil vapor, soil, and groundwater sampling and chemical analysis for PCOC to protect public health and safety. BXP and Watt will be required to determine the extent of the contamination on their parcels.

Response:
a. As indicated above, additional Site assessment activities are currently being conducted by Boeing. It should be noted that the City of Santa Monica Planning requirements are separate from the Los Angeles Water Board requirements.

7. The March 9, 2026, “Limited ESA Phase II Report” states (page 3) that the BXP 2800 28th St site’s subsurface soil vapor is impacted at concentrations that present a “potential vapor intrusion risk,” i.e., above regulatory thresholds. This is substantial evidence documenting a need for a fulsome assessment of the clear risk to public health and safety at the site.

Investigation activities conducted at the Site have also identified deeper soil and groundwater impacts, which are being addressed by Boeing under oversight by the LARWQCB, Case # 0130B. This Work Plan does not include further assessment of the Site’s deeper impacted soil and groundwater, as BXP’s redevelopment planning does not require the collection of additional deeper data The redevelopment of the Site will encompass the entire parcel; therefore, there will be no direct exposure to future Site occupants following the construction of the building. Similarly, the Site’s planned excavation will not extend to groundwater, which has been measured to be first encountered as perched groundwater at approximately 70 feet bgs. This Work Plan excludes the collection of additional soil vapor data, as it is already established that the Site’s subsurface soil vapor is impacted at concentrations that present a potential vapor intrusion risk.  Given this concern, BXP will be installing a VIMS when constructing the Site’s new building, and further soil vapor data is not required to design the VIMS.

Item 7-A
September 22, 2026
Item 7-A
September 22, 2026

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Packet Pg. 1035 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) Mr. Clare Thomas - 6 - June 24, 2026
Friends of Sunset Park
SCP No. 0130B
Response:
a. As a point of clarification, the “Limited ESA Phase II Report” is actually the Limited Phase II Environmental Site Assessment Work Plan. This work plan was not intended to be used to completely assess the Site’s soil and groundwater contamination. The work plan was developed in order to characterize the current soil conditions for on-site soil management and proper off-site disposal. The data collected from this assessment will allow for the evaluation of potential risks associated with the excavation activities and waste profiling for future off-site disposal. As previously indicated, Boeing is working with the Los Angeles Water Board and is currently conducting additional Site assessment activities to identify any additional data gaps and determine the need to expand the current Site remediation and assessment activities.

8. This report seems to imply that “all will be taken care of” by installation of a VIMS.

However, installing a VIMS is not sufficient to protect occupants of a residential building; a VIMS is insufficient to mitigate risk to sensitive residential occupants, as this Guidance from the San Francisco RWQB indicates: “Relationship Between VIM and Remediation In general, the Regional Water Board considers VIM as an interim measure that is not a substitute for remediation of VFCs in the subsurface.

In most cases, for new construction where a VIMS is needed to protect building occupants, we will not approve the VIMS until remediation to the extent feasible has been implemented. This could affect the local agency’s permitting decision for occupancy. Cleanup is the best way to reduce the magnitude of VI exposure that could occur if problems arise with VIMS, and it is the best way to reduce the timeframe over which VIMS are needed. Nonetheless, VIMS are often necessary since achieving cleanup standards may take years given currently available remedial technologies. Additionally, VIM may be the only viable long-term response action where remediation is infeasible (e.g., further concentration reductions are not possible and residual concentrations pose a VI threat).(S.F.

RWQB Vapor Intrusion Mitigation Guidance, p.3; emph. added) Response:
a. As previously indicated soil vapor remediation is currently on-going at the Site. VIMS is not proposed to be the only remediation action that will occur at the Site, but rather an interim protective measure while assessment and remediation efforts continue. Los Angeles Water Board staff is working with Boeing to further assess, delineate, and remediate soil vapor and groundwater impacts to ensure the Site is suitable for its proposed use. In addition, occupancy of residential buildings would only be allowed once the necessary assessment, remediation, and confirmation sampling demonstrate that conditions are protective of residential use and human health.

Item 7-A
September 22, 2026
Item 7-A
September 22, 2026

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Packet Pg. 1036 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) Mr. Clare Thomas - 7 - June 24, 2026
Friends of Sunset Park
SCP No. 0130B

9. CEQA Review is Warranted
Response:
a. The City of Santa Monica is the agency that will make the determination on whether a full CEQA review is needed for the redevelopments or whether ministerial review will suffice. The Los Angeles Water Board is not involved in the CEQA process for these redevelopments at this time.

Friends of Sunset Park Requests and Recommendations:

1. Full, Health Protective Remediation Before Any Residential Approvals • The RWQB and City of Santa Monica should not approve any discretionary entitlements, rezonings, or permits that enable residential development in Subareas C, D, E, and F until the Regional Water Quality Control Board has determined that all relevant media—soil, soil vapor, perched groundwater, and the regional aquifer—have been fully investigated and remediated to standards appropriate for unrestricted residential use, including protection of children and pregnant residents.
• Remediation must specifically address the persistent VOC reservoirs in the fine-grained zones beneath the former DAC Plant A and any other identified source areas, with clear, measurable performance objectives based on actual reductions in VOC mass and concentrations, not simply operating time for remediation systems.

Responses:
a. The Los Angeles Water Board concurs with these comment and is currently working with Boeing and the developers, as well as the City of Santa Monica staff to ensure any proposed developments are protective of the intended uses.
b. Site assessment activities are currently on-going. Based on results and data, the need for additional Site remediation activities by Boeing will be evaluated as warranted.

2. Completion of Subsurface Characterization and Plume Delineation • The additional lateral and vertical delineation of soil vapor and perched groundwater recommended in the 2023 investigations—particularly to the west and into Clover Park—should be completed and made publicly available before any residential entitlements are considered.
• The VOC plume in the regional aquifer, including but not limited to 1,1DCE detections at MW8 and any other downgradient wells, should be fully Item 7-A
September 22, 2026
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September 22, 2026

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Packet Pg. 1037 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) Mr. Clare Thomas - 8 - June 24, 2026
Friends of Sunset Park
SCP No. 0130B
delineated and modeled, demonstrating that the plume is under control and trending toward cleanup rather than expansion.

Responses:
a. As stated in the previous responses, additional site assessment activities are currently being completed at the Site by Boeing, and the results of these activities are due to the Los Angeles Water Board by October 30, 2026. b. Based on the results of the Site assessment activities currently being completed at the Site, additional groundwater monitoring wells will be installed if warranted. A groundwater monitoring program is also currently on-going. The groundwater monitoring plan is re-evaluated every 2 years.

3. Integrated Evaluation of Groundwater Pumping and Land Use Change • Any decision to activate or modify Airport #1 WSW or other water-supply wells in the area must be evaluated together with proposed land-use changes, including residential redevelopment, recognizing that groundwater pumping can alter plume behavior and vapor-intrusion potentials beneath existing and future buildings.
• A combined analysis should be required, examining how different pumping scenarios may affect VOC concentrations at supply wells and within underlying soils and vapors beneath current and proposed residential areas.

Response:
a. As the water purveyor for the aforementioned wells, the City of Santa Monica would make the determination to activate or modify Airport #1 WSW or other water supply wells in the area.

4. Residential and Child Focused Health Risk Standards
• Cleanup and closure decisions must be based on exposure assumptions and target levels appropriate for 24-hour-per-day, long-term residential occupancy, including infants, children, and pregnant residents, not on less protective commercial/industrial worker scenarios.
• A quantitative health risk assessment should be required that explicitly evaluates chronic and sub chronic indoor air exposure to TCE, 1,1DCE, and related VOCs for sensitive populations, as well as potential drinking water exposure if groundwater is or may be used.

Item 7-A
September 22, 2026
Item 7-A
September 22, 2026

7.A.h
Packet Pg. 1038 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) Mr. Clare Thomas - 9 - June 24, 2026
Friends of Sunset Park
SCP No. 0130B
Responses:
a. Human health risk assessments have been completed at the Site that consider the current and anticipated land uses at the time each risk assessment was completed. In addition, certain risk assessments have evaluated hypothetical residential and child exposure scenarios. These health risk assessments, along with other Site-related documents are available on GeoTracker at the following location:
https://geotracker.waterboards.ca.gov/profile_report.asp?global_id=SLT43 07472.

Prior to Site closure or occupancy of future buildings, additional human health risk assessments will be conducted as new data becomes available and, if warranted, to ensure that human health and the environment remain protected. In addition, confirmation indoor air sampling will need to be completed for the proposed residential developments before residential occupancy is permitted.
b. All HHRA’s have been reviewed and will continue to be reviewed by toxicologists with the Office of Environmental Health Hazard Assessment (OEHHA).

5. Enforceable Long-Term Protections and Monitoring
• If, even after aggressive remediation, residual contamination remains that could contribute to vapor intrusion, residential development should only proceed with enforceable engineering controls (e.g., sub-slab depressurization, vapor barriers) and robust long-term monitoring programs that are clearly funded, maintained, and periodically reviewed for the life of the buildings. • Institutional controls, including land use covenants, requirements for periodic reevaluation of site conditions, and disclosure requirements for future occupants, should be mandatory components of any approval for residential use on or near affected areas.

Response:
a. The Los Angeles Water Board agrees that residual contamination may warrant the need for engineering controls as well as institutional controls such as a Land Use Covenant that provides for long-term monitoring to be put in place.

6. Transparent, Coordinated Oversight and Public Process • The City should conduct a full project specific environmental review, consistent with CEQA, that incorporates the most current data and requirements from the Item 7-A
September 22, 2026
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September 22, 2026

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Packet Pg. 1039 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) Mr. Clare Thomas - 10 - June 24, 2026
Friends of Sunset Park
SCP No. 0130B
Regional Board, and that directly addresses whether site conditions are safe for residential development with child sensitive receptors. • The Regional Board should clearly state whether the remedial approach and any prospective closure determinations are intended to support unrestricted residential use and, if so, the technical basis and conditions (including monitoring and contingency measures) for that conclusion.

Responses:
a. Comment noted. This request should be directed to the City of Santa Monica since the Los Angeles Water Board does not have the authority to require the City to conduct a full project specific environmental review. b. Comment noted. Once the Site meets the Los Angeles Water Board closure requirements, a no further action letter will be issued and the letter will indicate if there are any restrictions associated with the property.

7. Our February 7, 2024, letter to the Regional Board raised our concerns only from the perspective of clean-up costs impacting affected neighborhood association as taxpayers. This (new) joint communication to both the City and the Regional Board is intended to make clear that Friends of Sunset Park strongly opposes moving forward with residential development in Subareas C, D, E, and F until the subsurface conditions are thoroughly characterized, aggressively remediated by the property antecedent owners/users , and demonstrated to be protective of long-term residential use, particularly for children.

Responses:
a. Comment noted. Friends of Sunset Park’s March 19, 2026, communication clarifies that, in addition to concerns previously raised in the February 7, 2024, letter regarding potential cleanup costs and taxpayer impacts, the organization also opposes moving forward with residential redevelopment in Subareas C, D, E, and F until subsurface conditions are adequately characterized, appropriate remediation has been completed by the responsible parties, and the Site is demonstrated to be protective for longterm residential use, including sensitive receptors such as children. As previously noted, the Los Angeles Water Board is overseeing ongoing site investigation and remediation activities being conducted by Boeing to further characterize soil, soil vapor, and groundwater conditions and to address remaining data gaps and contamination concerns. Decisions regarding redevelopment and land use approvals fall under the authority of the City of Santa Monica and other local agencies; therefore, the March 19, 2026, communication should also be shared with the City for consideration as part of any redevelopment review process.

Item 7-A
September 22, 2026
Item 7-A
September 22, 2026

7.A.h
Packet Pg. 1040 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) Mr. Clare Thomas - 11 - June 24, 2026
Friends of Sunset Park
SCP No. 0130B
Thank you for your interest in the Site activities. All reports and correspondences for the Former Boeing Santa Monica DAC Site, including this March 19, 2026, and the February 7, 2024, letters from Friends of Sunset Park have been uploaded to the GeoTracker database.

Should you have any further questions related to this project, please contact Ms.

Ana Townsend at (213) 576-6738 ([email protected]) or Mr.

Joshua Cwikla, Supervisor, Site Cleanup Program Unit I, at (213) 576-6735 ([email protected]).

Sincerely,
__________________
Susana Arredondo
Executive Officer
cc: E-Mailing List
Lisette A. Gold, City of Santa Monica
Monica Hanley, City of Santa Monica
John Scott, The Boeing Company
Ken Puentes, Engineering Analytics, Inc.

Marlene Jurgensen, SNAP CHAT
Nana Wilberforce, SNAP CHAT
Kathleen Goodhart, Cooley, LLP
Reece Trevor, Cooley, LLP
Renee Van De Griend, PhD, PE, Ramboll
Danny Murtagh, BXP (SMBP LLC)
Kara Russel, SMBP LLC
Roberta Irish, Transpacific Development Company (SCE Enterprises SMB, LLP) Item 7-A
September 22, 2026
Item 7-A
September 22, 2026

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Packet Pg. 1041 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) August 11, 2026 Email from 311 System responding to request from FOSP to Planning Sta? re CEQA evaluation of Airport Business Park
Item 7-A
September 22, 2026
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Packet Pg. 1042 Attachment: Written Comments (7722 : Sustainable Water Master Plan Update) Update on Sustainable
Water Master Plan
9/22/2026
Item 7-A
September 22, 2026
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Packet Pg. 1043 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) Regional Water Supply Outlook
Colorado River
State Water Project
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September 22, 2026

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Packet Pg. 1044 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) Diverse, sustainable, & drought
resilient water supply to support a
sustainable community
Energy footprint reduction to
support carbon reduction goals for
the City
Long term cost benefits for rate
payers
Goals of the City’s Sustainable Water Master Plan
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September 22, 2026
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September 22, 2026

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Packet Pg. 1045 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) Charnock
Arcadia WTP
Potable Water Wastewater To City of
Los Angeles
Olympic Well Field
Restoration
Clean Beaches
SWIP Initiative Tank
AWTF + SMURRF
Recycled
Water
Component 1
Conservation
Component 2
Alternative Water Supply
Component 3
New Local
Groundwater
2018 Sustainable Water Master Plan (SWMP)
Item 7-A
September 22, 2026
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September 22, 2026

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Packet Pg. 1046 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) Recap of 2018 SWMP Implementation
5 • Implementation impacted by COVID-19 pandemic and geopolitical events • Majority of 2018 SWMP completed in 2025
• Estimated Local Water Supply Production = 80-85% local, new baseline in FY26/27 • Component 1 – Water Conservation
• Maintained status quo due to COVID-19 restructuring
• 2024 Water Conservation Master Plan
• Component 2 – Alternative Water Supply
• Sustainable Water Infrastructure Project Completed in December 2022 • Arcadia WTP Production Efficiency Enhancement Completed in June 2025 • Extension of recycled water network and 2nd groundwater recharge well delayed • Component 3 – New Local Water Groundwater
• Olympic Wells SM-8 and SM-9 Completed in 2022
• Olympic Well Field Restoration Project Completed in June 2025 • Other Projects:
• AMI Smart Water Meter
• Charnock Well 13 and 18 Replacement (Fall 2026)
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September 22, 2026
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Packet Pg. 1047 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) 6 SWIP Advanced Water Treatment Facility
Item 7-A
September 22, 2026
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September 22, 2026

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Packet Pg. 1048 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) 7 First Municipal Flow Reversal RO in the World
• Producing more drinking water
with the same amount of
groundwater pumped
• Increase RO recovery to ≥90%
• Maximize use of existing assets
• Reduce specific energy
consumption by almost 10%
• Operation flexibility
• Lower operation and life-cycle
cost while increasing drinking
water production
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September 22, 2026
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September 22, 2026

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Packet Pg. 1049 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) Advanced Water Metering Infrastructure (AMI)
Deployment Across the City
24% 23% 22% 13% 10% 8%
Capital
Improvement
Projects
Labor
• Customers Can Access Their Water Usage
Information in Real Time
• Help Customers Budget Their Utility Bill
• Water Leak Alerts
Leak detected
https://www.santamonica.gov/ami
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September 22, 2026

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Packet Pg. 1050 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) Things that We Learned Along the Way
9 • Sustainable Groundwater Management
• Sustainable yield and water budget
• Production/relaxation of groundwater wells -
unable to sustain 100% capacity and 24/7
operation of each well
• Limited groundwater recharge capacity
• Impact of peak day/week water demand
– local production unable to keep up
• Emergency preparedness –
regional wildfire response
• Regulations
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September 22, 2026
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September 22, 2026

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Packet Pg. 1051 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) Objective of 2026 One Water Master Plan
10 • Update 2018 SWMP to recalibrate water supply and demand analysis (e.g., water supply gap for water self-sufficiency)
• Identify near-term and long-term local water supply opportunities to close the gap • Evaluate and recommend near-term and long-term water supply programs • Position for outside funding to implement near-term opportunities Item 7-A
September 22, 2026
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Packet Pg. 1052 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) Water Supply Gap Analysis
Up to 4,500 AF gap
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September 22, 2026
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September 22, 2026

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Packet Pg. 1053 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) Local Water Supply Alternatives
12 • Alternative 1 – Water Conservation Program B • Alternative 2 – Maximize Local Water Recycling • Alternative 3 – Groundwater Remediation (Airport) • Alternative 4 – Water Supply Exchange • Alternative 5 – Seawater Desalination Item 7-A
September 22, 2026
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September 22, 2026

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Packet Pg. 1054 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) Alternative 1 – Water Conservation Program B
13 • Conservation Program B
• Lowest cost per unit of water
saved
• Estimated to save ~200 acre-feet
per year over the next 20 years
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September 22, 2026
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September 22, 2026

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Packet Pg. 1055 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) Alternative 2 – Maximize Local Reuse w/SWIP
14 Project Description
This alternative will realize up to 0.9 MGD by
maximizing available capacity at:

1. SWIP AWTF product water, and

2. SMURRF effluent
The expanded reuse will include both non-potable
reuse (NPR) and direct potable reuse (DPR)
applications. The recycled water network will be
expanded to serve new NPR customers and
remaining local supply will be further treated to DPR
water quality standards at Olympic and Arcadia
treatment plants prior to potable distribution.

Sustainable Water Gain: up to 0.9 mgd
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September 22, 2026

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Packet Pg. 1056 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) Title 22 Advanced Treated Recycled Water Pipeline
Title 22 Diluent Water Pipeline
Blended Recycled Water and Olympic Groundwater Pipeline New Title 22 Advanced Treated Recycled Water Pipeline

SWIP AWTF
SMURRF
Groundwater
Recharge
Charnock
WTP
Arcadia
Wells

GREENSAND
FILTER

RO FEED

TANK RO DECARBONATORS
Arcadia WTP

RESERVOIR

DISTRIBUTION
Olympic AWTF
UV/H2O2 AOP GAC
Olympic
Wells

GREENSAND
FILTER
Looking to the Future:

Direct Potable Reuse
NonPotable
Item 7-A
September 22, 2026
Item 7-A
September 22, 2026

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Packet Pg. 1057 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) Title 22 Advanced Treated Recycled Water Pipeline
Title 22 Diluent Water Pipeline
Blended Recycled Water and Olympic Groundwater Pipeline New Title 22 Advanced Treated Recycled Water Pipeline

SWIP AWTF
SMURRF
NonPotableGroundwater
Recharge
Charnock
WTP
Arcadia
Wells

GREENSAND
FILTER

RO FEED

TANK RO DECARBONATORS
Arcadia WTP

RESERVOIR

DISTRIBUTION
Olympic AWTF
UV/H2O2 AOP GAC
Olympic
Wells

GREENSAND
FILTER
FLOW

CONTROL
VALVE
PUMP

STATION
Looking to the Future:

Direct Potable Reuse
Up to 10% contribution
Item 7-A
September 22, 2026
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September 22, 2026

7.A.i
Packet Pg. 1058 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) Alternative 3 – Groundwater Remediation
17 Project Description
This alternative increases local supply by further
developing the Santa Monica Basin by extracting
groundwater from the Coastal Subbasin at the
Santa Monica Airport.

The groundwater would be treated by a new,
standalone groundwater treatment plant to
remove industrial pollutants.

Timing dependent on responsible party’s
characterization and remediation work.

Sustainable Water Gain: + 1.0 mgd
Item 7-A
September 22, 2026
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September 22, 2026

7.A.i
Packet Pg. 1059 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) Local Water Supply Alternatives
18 • Alternative 1 – Water Conservation Program B
• Alternative 2 – Maximize Local Water Recycling
• Alternative 3 – Groundwater Remediation (Airport)
• Alternative 4 – Water Supply Exchange
• 4A – Water Supply Exchange through MWD’s Pure Water So Cal • 4B – Regional IPR @ Charnock Well Field through Pure Water LA • 4C – DPR through Pure Water LA
• Alternative 5 – Seawater Desalination
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September 22, 2026

7.A.i
Packet Pg. 1060 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) Alternative 4A – Water Supply Exchange w/MWD
19 Project Description
This alternative assumes a water supply
exchange program, where the City will purchase
water from one of two regional supply programs:
• Metropolitan's Pure Water Southern California
(PWSC) Program
• Pure Water Los Angeles (PWLA) program.

The additional water will be provided to the City
via existing Metropolitan interconnection.

Sustainable Water Gain: + 1.0 mgd
Item 7-A
September 22, 2026
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September 22, 2026

7.A.i
Packet Pg. 1061 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) Alternative 4B – Regional IPR at Charnock
20 Project Description
This alternative assumes diversion of purified
water from Pure Water Los Angles
(PWLA) through a new conveyance system from
the PWLA Sepulveda Alignment . This water will
be injected into the underlying aquifer using the
Charnock Well Field to maintain existing
production and potentially increase production
when needed.

New production wells will be used to extract
water and send to Arcadia WTP using the
existing Charnock Transmission line.

Sustainable Water Gain: + 3.0 mgd
Item 7-A
September 22, 2026
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September 22, 2026

7.A.i
Packet Pg. 1062 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) Alternative 4C – Regional DPR w/Pure Water LA
21 Project Description
This alternative assumes water from Pure
Water Los Angles (PWLA) will be diverted
through a new conveyance system from the
PWLA Sepulveda Alignment and treated using
Ozone/BAC + MF + RO at a new treatment
facility at Santa Monica Airport. The treated
water will be used for DPR via treated water
augmentation and distributed directly into the
potable water system.

Sustainable Water Gain: + 3.0 mgd
Item 7-A
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7.A.i
Packet Pg. 1063 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) Alternative 5 – Seawater Desalination
22 Project Description
Standalone 7 mgd seawater desalination facility
for the City as use of subsurface seawater intake
could impact local groundwater production
Emerging technologies (e.g., Oceanwell) or
partnerships opportunities (e.g. Water
Infrastructure Funding Authority) may be
available in the future.

Sustainable Water Gain: + 7.0 mgd
Photo Courtesy of Keppel
Item 7-A
September 22, 2026
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September 22, 2026

7.A.i
Packet Pg. 1064 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) Evaluation Criteria
23 • Environmental and Social Considerations – impacts on natural environment, public acceptance, and environmental justice • Technical Considerations - treatment process and infrastructure complexity, innovative technology, permitting, beneficial use, and maximize existing facilities
• Operational Considerations – impacts on staffing, operational complexity, and energy efficiency
• Life Cycle Cost – capital and annual operating costs
• Alignment with City’s Overall Goals – water self-sufficiency, project schedule, and control over implementation
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Packet Pg. 1065 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) Preliminary Alternatives Scoring
24 Alt No.

Evenly Weighted
Emphasis on City
Goals
Alt 1 – Water Conservation Program B 1 1
Alt 2A – DPR w/SWIP + SMURRF 4 2
Alt 3 – Groundwater Remediation (Airport) 3 3
Alt 4A – Water Supply Exchange w/MWD 2 4
Alt 4B – Regional Reuse IPR 5 5
Alt 4C – Regional Reuse DPR 6 7
Alt 5 – Seawater Desalination 7 6
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7.A.i
Packet Pg. 1066 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) Summary
25 • Near-Term Portfolio (5-10 years)
• Alternative 1 – Water Conservation
(Program B from 2024 Water Conservation Master Plan)
• Alternative 2 – Maximize Local Water Reuse with Direct Potable Reuse • Long-Term Portfolio (10+ years out)
• Regional Partnership with MWD or City of Los Angeles to increase water reuse for groundwater recharge and/or direct potable reuse • Monitor advancements in seawater desalination technology or partnership opportunities
• Monitor responsible party site clean-up
at the airport for Alternative 3
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Packet Pg. 1067 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) Portfolio Implementation Approach
26 Up to 4,500 AF gap by 2045
Item 7-A
September 22, 2026
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7.A.i
Packet Pg. 1068 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) City Council Discussion and Input
27 • Long-Term Portfolio
• Hold formal discussions on regional partnerships with MWD or City of Los Angeles to increase water reuse for groundwater recharge and/or direct potable reuse
• Monitor advancements in seawater desalination technology or partnership opportunities
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September 22, 2026

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Packet Pg. 1069 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) THANK YOU…
Item 7-A
September 22, 2026
Item 7-A
September 22, 2026

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Packet Pg. 1070 Attachment: PowerPoint Presentation (7722 : Sustainable Water Master Plan Update) City Council
Report
City Council Meeting: September 22, 2026
Agenda Item: 11.A
1 of 6
To: Mayor and City Council
From: Darrick Jacob, Police Chief, Police Department
Subject: 2025 Palisades Fire and Windstorm After-Action Report Recommended Action
Staff recommends that the City Council review and comment on the Palisades Fire After-Action Report, and direct staff to proceed with evaluating and completing the report’s identified improvement actions. This report is not a “project” subject to the California Environmental Quality Act (“CEQA”). The report is administrative and informative in nature. Pursuant to CEQA Section 21065, the project does not meet the definition of a “project” subject to CEQA as it will not “cause either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment.”
Summary
On January 28, 2025, the Santa Monica City Council directed staff to conduct an “After Action Review” across all City departments to “accurately capture lessons learned during the City’s response to the Palisades Fire and to better prepare for the next natural disaster or emergency crisis.” The City of Santa Monica retained Jacob Green & Associates (JGA), to assess Santa Monica’s response and recovery efforts to the Palisades Fire and related wind event and to prepare an independent After-Action Report (Appendix A). The completed report by JGA provides an incident overview, evaluates key actions taken by City personnel, and presents recommendations and an improvement plan to enhance disaster readiness.

Successful implementation of the improvement plan will require a multi-departmental approach, supported by the leadership and participation of the City Council. Staff recommends City Council review the Palisades Fire After-Action Report and direct City

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staff to evaluate all recommendations for improvement of Santa Monica’s disaster preparedness and response capabilities and to implement such recommendations as necessary and to the extent applicable.

Discussion
The January 2025 Palisades Fire and windstorms caused devastating impacts in the Pacific Palisades neighborhood of the City of Los Angeles, directly north of Santa Monica. The wildfire resulted in 12 civilian fatalities, destroyed over 6,000 residential and commercial structures, and burned 23,448 acres of the Santa Monica Mountains, which impacted the Pacific Palisades, Topanga, and Malibu communities. The Palisades Fire was one of fourteen destructive wildfires that ignited in Los Angeles County during January 2025, placing substantial strain on local and regional emergency response resources.

Although Santa Monica did not sustain direct wildfire damage, the fire perimeter reached within 0.4 miles of the City’s northern boundary. In response to extreme Santa Ana winds and rapidly deteriorating wildfire conditions in neighboring communities, the City of Santa Monica initiated substantial emergency response activities in coordination with other local and state response agencies. The City’s Emergency Operations Center (EOC) and City response personnel were mobilized to address three primary response activities: 1) firefighting monitoring and coordination; 2) evacuation and curfew order implementation; and 3) debris removal of downed trees related to the windstorm.

Mandatory evacuation orders affected approximately 5,550 Santa Monica households and businesses. The City issued a local emergency proclamation due to the scale of Santa Monica’s local response, with the event also receiving a state emergency proclamation and federal disaster declaration. Throughout the dynamic incident, City staff worked diligently to share timely and verified information and amplify messaging from the regional, state, and federal response partners.

The City of Santa Monica successfully transitioned from response to recovery operations by mid-January 2025. In the months that followed, City staff continued to support local and regional recovery efforts, including hosting the U.S. Small Business

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Administration’s Business Recovery Center, facilitating wildfire debris testing and cleanup along local beaches and parks, and temporary relocating several Pacific Palisades schools, businesses, and community programming to Santa Monica facilities.

In March 2025, the City’s emergency management team facilitated FEMA disaster cost recovery efforts to secure $1.48 million in reimbursement for disaster-related response costs.

In response to the Council’s direction to complete an independent after action review, the City requested proposals from several firms with emergency incident review expertise. Jacob Green & Associates was selected by Santa Monica public safety leadership in part due to it having the most experience with California public safety agencies. JGA was tasked to provide a critical evaluation of the City’s response to the Palisades Fire and windstorm, to evaluate the effectiveness of response activities, and identify the areas where the City could improve. JGA conducted the after-action review in accordance with the principles and methodology outlined in the California Office of Emergency Services After-Action Review Creator Guidance (2025). JGA collected and analyzed information using a systems-based approach, including a review of relevant plans, policies, incident documentation, and publicly available information. The firm also conducted 16 structured interviews with 29 individual members of current City leadership and staff, including councilmembers, and several former personnel who served in leadership roles during the incident.

The Palisades Fire After-Action Report describes key City response agencies, provides an incident overview, and lays out key decision points and actions taken by City personnel. The report’s Implementation and Improvement Plan identifies 36 recommendations to build stronger planning and response capabilities in the following subject areas:
• Public information, communications and elected official coordination; • Emergency Operations Center (EOC) governance and staffing; • Emergency Management program development;
• Fire Department operations and interagency coordination; • Police Department operations and security;

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• Evacuation planning and traffic management;
• Public works, utilities and field safety;
• Training, exercises, and community preparedness;
• Citywide planning.

The After-Action Report specifies lead and supporting departments or divisions, estimated timelines, and measures of success for each recommendation. Eight departments have a role in leading or supporting report recommendations and all departments are needed to participate in Emergency Operations Center staff training and development. The Police Department’s Emergency Services & Preparedness Unit will oversee citywide progress towards Improvement Plan implementation; however, individual city departments are responsible for implementing their respective recommendations.

Past Council Actions
On January 28, 2025, City Council directed staff to conduct an independent review of City department actions during the January 2025 windstorm and Palisades Fire. Since the historic event, City Council has taken several actions to improve wildfire mitigation and overall disaster readiness.

In February 2025, the City Council adopted updates to the Safety Element of the General Plan, establishing a long-term framework for reducing potential risk caused by natural and human-related hazards. The Safety Element includes goal, policy, and action recommendations related to fire mitigation, emergency preparedness, community hazard awareness, and climate change.

In March 2025, the CAL FIRE Office of the State Fire Marshal released a revised Local Responsibility Area Fire Hazard Severity Zone (FHSZ) map for Santa Monica. For the first time, portions of northern Santa Monica were designated as Very High, High, and Moderate fire hazard severity zones. In June 2025, City Council approved an ordinance to designate Fire Hazard Severity Zones in the northern section of Santa Monica,

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pursuant to California Government Code 51178. As a result, certain code modifications will be implemented in Santa Monica’s Very High-risk areas to ensure properties are compliant with safety wildfire risk reduction standards.

The City Council adopted a revised Local Hazard Mitigation Plan (LHMP) in November 2025, identifying fourteen high-priority mitigation actions including brush fire mitigation, Red Flag Warning restrictions, evacuation planning, and inclusive emergency communications. These actions have a five-year implementation target. The LHMP has received approval from the California Governor’s Office of Emergency Services and U.S. Federal Emergency Management Agency.

Several of the After-Action Reports Improvement Plan priorities align with recommendations presented in the revised Safety Element and Local Hazard Mitigation Plan, including evacuation planning, coastal bluff and freeway slope mitigation, and technology enhancements.

Meeting Date Description
01/28/25 (attachment B) City Council directed staff to conduct an After Action Review across all City departments to
capture lessons learned during the City’s response to the Palisades Fire to better prepare for the next natural
disaster or emergency crisis.
02/11/25 (attachment C) City Council adopted the City of Santa Monica’s amended Safety Element of the General Plan
06/24/25 (attachment D) Adoption of an Ordinance to add chapter 8.46 to the Santa Monica Municipal Code to designate Fire Hazard
Severity Zones pursuant to California Government Code
Section 51178
11/18/25 (attachment E) City Council approved and adopted the City of Santa Monica’s Updated Local Hazard Mitigation Plan
Environmental Review
This report is not a “project” subject to the California Environmental Quality Act (“CEQA”). The report is administrative and informative in nature. Pursuant to CEQA Section 21065, the project does not meet the definition of a “project” subject to CEQA

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as it will not “cause either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment”.

Financial Impacts and Budget Actions
There is no immediate financial impact or budget action necessary as a result of the recommended actions. It is expected that the implementation of recommendations will require significant staff time. Recommendations related to technology improvements and any studies or training requiring consultant support may require additional funding.

Staff will return to Council if specific budget actions are required in the future.

Prepared By: Lindsay Call, Chief Resilience Officer
Approved Forwarded to Council
Attachments:

A. Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm
B. Attachment B_SR 01-28-2025 16M_Palisades Fire After Action Review Direction C. Attachment C_SR 02-11-2025 12A_2025 Safety Element (weblink) D. Attachment D_SR 06-24-2025 4E_Fire Hazard Severity Zones (weblink) E. Attachment E_SR 11-18-2025 4S_Local Hazard Mitigation Plan (weblink) F. Written Comments
G. PowerPoint Presentation

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PALISADES FIRE

AFTER-ACTION REPORT

PALISADES FIRE

AFTER-ACTION REPORT
After-ActionReport
CityofSantaMonica
After-ActionReport
CityofSantaMonica
January2025PalisadesFire

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Packet Pg. 1077 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only

REPORT PRODUCED IN PARTNERSHIP WITH
JACOB GREEN AND ASSOCIATES

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Packet Pg. 1078 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only Table of Contents
Introduction ...........................................................................................................................................4 Overview of Palisades Fire.................................................................................................................4 Objectives and Scope ...........................................................................................................................5 Purpose ....................................................................................................................................................................5 Methodology..........................................................................................................................................................5 Limitations and Assumptions ........................................................................................................................6 City of Santa Monica.............................................................................................................................7 Agencies and Stakeholders................................................................................................................8 Of;ice of Emergency Management................................................................................................................9 Emergency Operations Center .................................................................................................................... 10 Law Enforcement.............................................................................................................................................. 13 Fire Department................................................................................................................................................ 14 Public Works....................................................................................................................................................... 15 Transportation................................................................................................................................................... 16 Incident Overview ............................................................................................................................. 17 Weather................................................................................................................................................................. 17 Ignition.................................................................................................................................................................. 18 Evacuation ........................................................................................................................................................... 19 Air Quality............................................................................................................................................................ 21 Palisades Fire Incident Sequence of SigniGicant Incidents................................................... 25 Key Decision Points & Actions Taken.......................................................................................... 29 Communications ............................................................................................................................................... 34 Internal and External Communications............................................................................................. 34 Recovery Efforts ................................................................................................................................................ 35 Environmental Health, Water Quality, and Beach Recovery ..................................................... 36 Debris Removal Coordination ................................................................................................................ 37 Transportation Impacts and Economic Effects............................................................................... 37 Business Recovery and Community Support................................................................................... 37 School Relocation and Community Services.................................................................................... 38

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Packet Pg. 1079 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only FEMA Public Assistance and Financial Recovery........................................................................... 38 Observations and Recommendations ......................................................................................... 39 Observations....................................................................................................................................................... 39 Recommendations............................................................................................................................................ 43

1. Public Information, Communications, and Elected Of;icial Coordination...................... 43

2. Emergency Operations Center (EOC) Governance and Staf;ing ......................................... 44

3. Emergency Management Program Development..................................................................... 44

4. Fire Department Operations and Interagency Coordination............................................... 45

5. Police Department Operations and Security............................................................................... 45

6. Evacuation Planning and Traf;ic Management........................................................................... 46

7. Public Works, Utilities, and Field Safety........................................................................................ 46

8. Training, Exercises, and Community Preparedness................................................................. 46

9. Citywide Planning................................................................................................................................... 47 Implementations and Improvement Plan ................................................................................. 47 Conclusion............................................................................................................................................ 51 Appendix 1: Acronym List............................................................................................................... 52 Appendix 2: Data Sources ............................................................................................................... 54

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Packet Pg. 1080 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 1 Executive Summary
Jurisdiction City of Santa Monica, California, United States of America Type of Agency Local Government (Charter City)
Cal OES Admin.

Region Southern Region
Cal OES Mutual Aid
Region Region I
Incident Palisades Fire
Type of Hazard Wind Driven Wild;ire
Incident
Period/Duration January 7, 2025, to January 31, 2025
Period Covered by
this Review December 31, 2024, to January 18, 2025 (EOC Deactivated) Mission Area Response
Applicable U.S.

Department of
Homeland Security
Core Capabilities
• Access Control and
Identity Veri;ication
• Community resilience
• Critical
Transportation
• Environmental
Response/Health and
Safety
• Fire Management and
Suppression
• Housing
• Infrastructure Systems
• Intelligence and
Information Sharing
• Mass Care Services
On-scene Security,
Protection, and Law
Enforcement
• Operational
Communications
• Operational
Coordination
• Physical Protective
Measures
• Planning
• Public Health,
Healthcare, and
Emergency Medical
Services
• Public Information
and Warning
• Risk Management for
Protection Programs
and Activities
• Situational
Assessment

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Packet Pg. 1081 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 2 Notable Strengths
• Strong Incident Management through early situational
awareness, decisive leadership, and effective crossdepartment coordination. • Leveraged established emergency management
structures to maintain a common operating picture and
support timely decision-making.
• Close collaboration between SMFD, SMPD, OEM, and
regional partners enabled the City to address public
safety, infrastructure protection, and information sharing. • Coordinated public information efforts supported
community awareness and con;idence.

Notable
Improvements
• Strengthening public information by providing updated training to Communications Team members.
• Expanding Communications Team staf;ing.
• Establishing formal protocols and liaison roles for elected of;icial engagement.
• Continue to expand EOC staf;ing depth.
• Targeted training for executive leadership and Policy Group members.
• Development of a comprehensive evacuation annex,
traf;ic modeling, and liaison integration with Caltrans and CHP.
• Enhancing ;ield safety for Public Works and PD ;ield staff by providing additional PPE.

The City of Santa Monica’s response to the January 2025 Palisades Fire re;lected a coordinated, citywide effort focused on protecting residents, maintaining essential public services, and supporting regional ;ire suppression operations during an unprecedented wind-driven wild;ire. Although the incident originated outside City limits, the Santa Monica Of;ice of Emergency Management (OEM) proactively activated its Emergency Operations Center (EOC), the ;ire department upstaffed resources in anticipation of predicted Red Flag conditions, and both police and ;ire imbedded senior leadership into the incident command post (ICP) to maintain continual situational awareness and alignment between ;ield operations and City decision making. As conditions deteriorated, the Santa Monica Police Department (SMPD) implemented a citywide tactical alert and, as multiple evacuation zones were placed on warning and order status, increased security measures were implemented including a local curfew order. SMPD utilized mutual aid resources to assist with the increased activity in the evacuation zones and to help maintain patrol coverage citywide.

Additionally, the California National Guard was utilized to assist in managing signi;icant traf;ic impacts along Paci;ic Coast Highway (PCH), the Interstate-10 (I-10) corridor, and points of egress and ingress into the Palisades. Additionally, the Santa Monica Public Works

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Packet Pg. 1082 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 3 Department utilized personnel and equipment from all divisions including Water Resources, Public Landscape, and Resource Recovery and Recycling, as well as contracted service providers to execute a large-scale cleanup, removing more than 531 tons of debris and ash while continually maintaining reservoir water levels to protect the City from secondary ignitions and ensure a safe repopulation of impacted areas.

The response to the Palisades Fire was characterized by strong interdepartmental collaboration and an “all-hands” operational approach. Public Information Of;icers (PIOs) from the City Manager’s Of;ice, Fire, Police, and Information Services coordinated multilingual incident messaging across SMAlerts, social media, the City website, and other traditional channels while simultaneously responding directly to high volumes of public inquiries. The EOC provided centralized coordination for logistics, transportation, business outreach, executive brie;ings, and regional partner engagement. Notable strengths included, but were not limited to, early operational brie;ings, effective working relationships with the Los Angeles City Fire Department (LAFD), Los Angeles County Fire Department (LACoFD), California Department of Forestry and Fire Protection (CAL FIRE), neighboring jurisdictions, and innovative use of City and privately-owned facilities to house and support mutual aid resources. These actions helped sustain local readiness and reinforce public safety, while providing consistent community messaging during a period of heightened anxiety and uncertainty.

While the After-Action Review (AAR) details the City’s strong, collaborative response, it also identi;ies key opportunities to strengthen governance, preparedness, and communications.

Key recommendations include establishing clearer protocols between the EOC, Communications Team, and the City Council; formal onboarding and emergency operations training for elected of;icials regarding EOC roles and emergency information ;low; enhanced GIS and mapping support; re;ining evacuation and curfew policies; improving interagency communications; and expanding staf;ing and surge capacity for emergency communications.

Additional recommendations include formalizing Red Flag upstaf;ing criteria; strengthening succession planning; improving personal protective equipment (PPE) availability for ;ield crews; and continuing to build internal Incident Command System (ICS) depth across departments. Collectively, these lessons reinforce that while the City of Santa Monica’s operational response was effective and highly collaborative, targeted investments in preparedness, communications structure, and leadership continuity will further strengthen the City’s resilience for future large-scale emergencies.

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Packet Pg. 1083 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 4 Introduction
Jacob Green and Associates (JGA) was selected by the City of Santa Monica to conduct an independent After-Action Review (AAR) and subsequent After-Action Review Report (AARR), undertaken at the direction of the Santa Monica City Council, to evaluate the City’s coordination, communication, and operational response to the January 2025 Palisades Fire and extreme wind event.

JGA would like to thank the City of Santa Monica and all of the City staff for their assistance and input during the entirety of the Palisades Fire AAR.

Overview of Palisades Fire
The January 2025 Palisades Fire was a fast-moving and highly destructive wild;ire that burned along the western edge of the City of Los Angeles and into the Santa Monica Mountains, directly affecting the Paci;ic Palisades area and placing adjacent communities, including the City of Santa Monica, under signi;icant threat. The ;ire ignited during a period of critical ;ire weather marked by strong Santa Ana winds, low relative humidity, and exceptionally dry fuels. These conditions drove rapid ;ire spread in steep, brush-covered terrain within the wildland urban interface (WUI), allowing the ;ire to expand quickly toward residential neighborhoods and major transportation corridors.

As the incident escalated, large-scale evacuations were ordered across portions of Paci;ic Palisades, Topanga Canyon, and surrounding hillside communities. Regional transportation infrastructure was signi;icantly impacted, including closures of PCH and the western terminus of Interstate 10 at Lincoln Boulevard to support evacuation operations and ensure responder safety. Initially a uni;ied, multi-agency response was established involving Los Angeles City and County Fire Departments, law enforcement agencies, and regional partners.

Command was transferred to CAL FIRE Incident Management Team II on January 8, 2025.

Fire suppression efforts included extensive use of ground resources, aircraft, structure defense operations, and coordinated evacuation and public information activities under challenging and evolving conditions.

The Palisades Fire resulted in substantial structural loss and the displacement of thousands of residents. Following full containment on January 31, 2025, recovery efforts focused on damage assessment, debris removal, restoration of transportation access, and reentry planning. The incident prompted renewed examination of wild;ire preparedness, evacuation coordination, interagency and public communications, and infrastructure resilience in coastal and hillside communities, reinforcing the growing risks posed by extreme ;ire weather events in Southern California.

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Packet Pg. 1084 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 5 Objectives and Scope
Purpose
The purpose of conducting an AAR for the 2025 Palisades Fire is to provide a structured, objective, and independent assessment of the City of Santa Monica’s response to the winddriven wild;ire incident. Consistent with guidance from the Federal Emergency Management Agency (FEMA), the Homeland Security Exercise and Evaluation Program (HSEEP), and the California Governor’s Of;ice of Emergency Services (Cal OES), the AAR documents actions taken, evaluates performance against established plans and procedures, and examines how effectively the City activated and utilized its emergency management framework, including departmental coordination and EOC operations. This review ensures that both successful practices and operational challenges are captured in a clear and factual manner grounded in veri;iable information.

Equally important, the AAR serves as a forward-looking tool to strengthen future readiness and resilience. By identifying strengths to sustain and gaps to improve, the review informs actionable recommendations and an Improvement Plan (IP) designed to enhance communications, interagency coordination, situational awareness, and resource management during future wild;ire and large-scale emergency events. The AAR promotes accountability and transparency to City leadership, elected of;icials, and the community, while ensuring that lessons learned from the Palisades Fire are translated into measurable improvements in plans, training, and operational capability.

Serving as an independent consultant, JGA's role was to provide a critical evaluation of the City's response to the Palisades Fire, the effectiveness of the response, and areas where the City's internal processes could be improved.

Methodology
This AAR is intended to evaluate the City of Santa Monica’s preparedness, response, coordination, and recovery related actions during the January 2025 Palisades Fire and extreme wind event. The AAR was conducted by JGA in accordance with the principles and methodology outlined in the California Of+ice of Emergency Services (OES) After-Action Review Creator Guidance, 2025 edition. The review is intended to identify strengths, areas for improvement, and actionable recommendations to enhance future public safety and emergency management capabilities.

The evaluation relied on a qualitative, systems-based approach, including 16 structured interviews with 29 individual members of City leadership and staff, review of relevant plans and policies, analysis of available documentation, and examination of publicly available

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Packet Pg. 1085 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 6 information. The ;indings focus on organizational performance, decision-making frameworks, and information ;low rather than individual actions or outcomes.

An incident timeline was created utilizing timestamped data provided by the City as well as publicly available CAL FIRE Incident Status Reports. Only data that was timestamped or validated was utilized in the creation of the Palisades Fire Incident Timeline.

Following a thorough review of all available documentation and information, the City was given the opportunity to review the draft report and provide feedback. All of the feedback from the City was reviewed and taken into consideration with the ultimate goal of providing a factually accurate report.

Limitations and Assumptions
This report is intended to provide a valuable external perspective on the City of Santa Monica’s response to the Palisades Fire, but it is subject to several important limitations.

These constraints should be acknowledged to ensure appropriate interpretation of the ;indings and recommendations. Limitations and assumptions include the following:
• All information utilized in this report was obtained from City documentation, stakeholder interviews, and open-source data and documentation. • All information obtained through stakeholder interviews is subject to recall bias, inconsistent recollection, and post-incident rationalization due to the months-long period between the actual event and conducting the interviews. • No interviews or data were obtained through outside agencies. • Not every activity performed by City staff during the Palisades Fire is speci;ically addressed in this report.
• This report does not speci;ically focus on any one person or a speci;ic action leading up to, during, or immediately following the Palisades Fire. • The goal of this report is to identify strengths and potential opportunities for improvement.
• All information included in this report obtained through individual interviews is based on personal recollection and the perception of events. • In an attempt to maintain anonymity and to avoid a singular point of view, individual sources were not cited unless speci;ically necessary.
• The primary goal of completing an AAR and AARR is to systematically improve future performance by identifying what occurred, why it occurred, and how organizations can strengthen their preparedness and recovery capabilities. An AAR is fundamentally a learning and improvement tool, not an audit or fault-;inding exercise.

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Packet Pg. 1086 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 7 City of Santa Monica
The City of Santa Monica is a coastal city of just over 93,0001 residents located on the west side of Los Angeles County, covering approximately 8.3 square miles bordered on its west by Paci;ic Ocean shoreline and beaches. The City is bordered on its remaining boundaries by City of Los Angeles neighborhoods that include Paci;ic Palisades to the north, Brentwood and West Los Angeles to the northeast and east, Mar Vista to the southeast, and Venice to the south. It is known for its scenic beaches, three miles of shoreline, the Santa Monica Pier, vibrant commercial districts, and a strong tourism economy that draws millions of visitors annually, swelling the daytime population to roughly 250,000. The City’s demographic pro;ile re;lects a diverse and educated population, with a high median household income and a large share of residents employed in creative industries, technology, healthcare, education, and tourism.

Santa Monica was incorporated as a City on November 30, 1886, and is one of the older municipalities in Los Angeles County. In 1945, the City adopted a charter and in 1947 established a City Council-City Manager form of government, which remains the core of its municipal governance. The Santa Monica City Council is made up of seven members elected at-large for staggered four-year terms. Every two years, after each election, the City Council selects one of its members to serve as Mayor and another to serve as Mayor Pro Tempore.

The City Council serves as the central legislative jurisdictional authority for City policies and regulations.

As a full-service city, Santa Monica provides a full range of municipal services. These include public safety through the SMPD and SMFD, water and wastewater utilities, street maintenance, refuse and recycling, planning and building services, parks and recreation, libraries, and economic development. The City also operates regional transportation services such as the Big Blue Bus, supports affordable housing programs, provides digital infrastructure such as free public Wi-Fi, and manages cultural and community programs.

Education is served locally by the Santa Monica-Malibu Uni;ied School District and Santa Monica College within the City, while county and private entities ful;ill other social, health, and judicial functions.
1 United States Census Bureau, Quick Facts. Retrieved from https://www.census.gov/quickfacts/fact/table/santamonicacitycalifornia/PST040224#PST040224

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Packet Pg. 1087 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 8 Map 1: City of Santa Monica Jurisdiction
Agencies and Stakeholders
The City of Santa Monica consists of 12 internal departments that include 64 speci;ic divisions. During the Palisades Fire, nearly all City departments were impacted in some manner. Nine departments plus the City Manager’s and City Attorney’s Of;ices were represented in the EOC while other departments including Police, Fire, Public Works, and the Santa Monica Department of Transportation (SaMoDOT) had additional personnel operating throughout the City, as well as directly interacting with the Incident Management Team at the ICP or assigned to the incident directly. Although several City departments did not have representation in the EOC and were not immediately impacted by the Palisades Fire, they were actively involved in policy group support, making operational adjustments to their own standard department functions and recovery activities, and supporting team members who were directly impacted by the Palisades Fire.

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Packet Pg. 1088 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 9 Of8ice of Emergency Management
At the time of the Palisades Fire, OEM was a function of the Santa Monica City Manager’s Of;ice with the primary responsibility of providing emergency management and public safety dispatching for the City. As the emergency management department, OEM is responsible for coordinating the mitigation of, preparedness for, response to, and recovery from emergencies and disasters that threaten life, property, the environment, and the continuity of government.

It serves as the central authority that aligns City departments, external partners, and elected of;icials under a common framework to ensure timely decision making, effective resource management, accurate public information, and sustained operational continuity across all hazards.

During the initial response to the Palisades Fire, OEM faced staf;ing constraints due to the prolonged vacancy of the Emergency Services Administrator position. Because the Chief Resilience Of;icer also manages the public safety dispatch center, the City of Santa Monica has the equivalent of 1.5 emergency managers when fully staffed. This staf;ing gap limits the Of;ice’s ability to manage planning, preparedness, and mitigation efforts while actively involved in response and recovery mode. This incident reinforced the need for a staf;ing needs assessment as recommended in the 2023 Emergency Management Program Gap Analysis to identify gaps in staf;ing capacity, succession planning and staf;ing continuity within the emergency management function. Since the Palisades Fire, OEM ;illed the Emergency Services Administrator vacancy and is fully staffed, based upon its current staf;ing structure.

City of Santa Monica OEM Organizational Chart on January 7, 2025 Effective December 28, 2025, the City of Santa Monica implemented an organizational realignment that transitioned OEM from the City Manager’s Of;ice to SMPD. As part of this change, the function was redesignated as the Emergency Management Department (EMD) and placed under the administrative oversight of the Deputy Police Chief.

City Manager’s Office
Chief Resilience
Officer
Emergency Services
Administrator
(Vacant)
Admin Staff
Assistant

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Packet Pg. 1089 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 10 Emergency Operations Center
On Monday, January 6, 2025, personnel
from OEM attended a brie;ing by the NWS
regarding the issuance of a Red Flag and PDS
weather event that was anticipated to
impact nearly all of Southern California. The
information obtained was disseminated by
OEM to department heads and managers
throughout the City. Additionally, OEM
coordinated with other local cities, the Los
Angeles Emergency Management
Department (LA City EMD), and Los Angeles
County OEM to facilitate the release of
public messaging. Santa Monica OEM
utilized its social media platforms as well as
a SMAlerts text and email to advise the public of the impending conditions.

On January 7, 2025, as the smoke rose from the Santa Monica Mountains, City staff began to gather in the EOC. Shortly thereafter, the decision was made by City leadership in consultation with OEM staff to activate the EOC. This decision was due to the ;ire’s proximity to the City, the extreme Red Flag weather conditions, the potential for rapid ;ire spread into densely populated areas, the knowledge of previous ;ire history in the Malibu Canyon region, and the potential impact to the City due to it being the primary evacuation route out of the impacted areas. Forecasted Santa Ana winds, low relative humidity levels, and volatile ;ire behavior signi;icantly increased the risk of escalation, necessitating early activation to ensure that the City could quickly transition from a position of monitoring to a coordinated response if conditions warranted.

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Packet Pg. 1090 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 11 Graphic 1: Palisades Fire EOC Org Chart. Information obtained from City of Santa Monica OEM Early EOC activation allowed the City to establish a centralized coordination structure before impacts reached the City, rather than reacting after conditions deteriorated. This proactive approach supported the development of a common operating picture across City departments, allowing City leadership to assess the evolving threat to the community, evaluate City readiness levels, and make timely policy decisions related to emergency declarations, curfews, and evacuation preparedness. The decision to activate the EOC also enhanced interdepartmental coordination. Departments were able to coordinate and communicate through a structured EOC framework to align priorities, share information, and make contingency plans that included evacuation support and the management of additional impacts, such as air quality degradation and citywide transportation disruptions.

Additionally, the early EOC activation facilitated effective regional coordination and public information efforts. OEM and EOC staff maintained communications with the City of Los Liaison Officer
Community
Development
Legal Officer
City Attorney’s Office
Water Resources
Public Works
Plans Section
Chief
Library
Logistics Section
Chief
Public Works
Public Works
Branch
Public Works
Law Branch
SMPD
Operations
Section Chief
SMFD
Safety Officer
Finance
Public Information
Officer
City Manager’s Office
Transportation
Public Works
Ground
Support/Staging
SMFD
SMPD
Recreation & Arts
GIS Mapping
Information Services
Debris Removal
Public Works
Finance Section
Chief
Finance
Facilities
Public Works
City Council
Cost Recovery
Finance
Care & Shelter
Recreation & Arts
American Red Cross
(Remote)
EOC Coordinator
City Manager’s Office
Joint Info Center
City Manager’s Office
Council Liaison
City Manager’s Office
EOC Director
City Manager’s Office
Policy Group Director
of Emergency
Services
City Manager’s Office

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Packet Pg. 1091 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 12 Angeles, Los Angeles County, Cal OES, CAL FIRE, and neighboring jurisdictions to ensure consistent response actions and messaging throughout the incident. Maintaining the communications function within the EOC ensured that public messaging was timely, accurate, and consistent.

Picture 1: EOC Staff Discussion. Photo Credit: City of Santa Monica The EOC was initially activated on the morning of Wednesday, January 7, 2025, and was demobilized on the afternoon of Saturday, January 18, 2025, following the removal of all City evacuation zones from evacuation order and warning status.

EOC Activation Status
Date Time Activation Level Staf2ing
Jan. 7, 2025 Afternoon Level 2-Moderate In-person
Jan. 8, 2025 0200 Level 2-Moderate Duty Of;icer
0800 Level 2-Moderate In-person
2300 Level 2-Moderate Duty Of;icer
Jan.9, 2025 0700 Level 2-Moderate In-person
2300 Level 2-Moderate Duty Of;icer
Jan. 10, 2025 0900 Level 2-Moderate In-person
1900 Level 2-Moderate Duty Of;icer
Jan. 11, 2025 0900 Level 2-Moderate Remote
1900 Level 2-Moderate Duty Of;icer
Jan. 12, 2025 0900 Level 2-Moderate Remote
1900 Level 2-Moderate Duty Of;icer
Jan. 13, 2025 0700 Level 2-Moderate In-person

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Packet Pg. 1092 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 13 1900 Level 2-Moderate Duty Of;icer
Jan. 14, 2025 0700 Level 2-Moderate In-person
1900 Level 2-Moderate Duty Of;icer
Jan. 15, 2025 0700 Level 2-Moderate In-person
1900 Level 2-Moderate Duty Of;icer
Jan.16, 2025 0700 Level 3-Monitoring Remote
1700 Level 3-Monitoring Duty Of;icer
Jan. 17, 2025 0700 Level 3-Monitoring Remote
1700 Level 3-Monitoring Duty Of;icer
Jan. 18, 2025 0700 Level 3-Monitoring Remote
1200 Level 3-Monitoring EOC Demobilized
Graphic 2: EOC Activation dates, level, and hours.

Law Enforcement
During the entirety of the Palisades Fire, SMPD personnel ;illed roles within the EOC, staffed a stand-alone SMPD ;ield command post to direct and oversee all responses, maintained ongoing citywide patrols, and responded to 911 calls. SMPD personnel staffed traf;ic control points and maintained a constant presence in impacted evacuation zones to assist in safely evacuating residents and patrolling to minimize the threat to evacuated property owners from potential looters. A January 10, 2025, press release advised, “the 330th Military Police, part of the Law Enforcement Branch of the
California National Guard, are stationed at
traf;ic control points around the City of Santa
Monica to ensure the safety of the
surrounding community.”
National Guard members augmented SMPD
Traf;ic Services bureau staf;ing at the
designated traf;ic control points. In addition
to utilizing the assistance provided by the
California National Guard, SMPD coordinated
with the California Highway Patrol (CHP), the
California Department of Transportation
(Caltrans), and utilized the mutual aid system
to request additional local assistance.

Between January 7 and January 9,
approximately 22 personnel from Beverly
Hills, Culver City, Hawthorne, and Redondo
Beach Police Departments provided patrols
and additional response capabilities in the
City of Santa Monica.

Picture 2: National Guard operating at trafLic
checkpoint. Photo Credit: City of Santa Monica

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Packet Pg. 1093 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 14 On January 8, 2025, City of;icials declared the existence of a local emergency that included an evacuation zone curfew between the hours of 6:00 p.m. and 6:00 a.m. This curfew order applied to 7,428 households in the City.

The curfew provided an additional tool for the SMPD to maintain security within the evacuated areas of the City by allowing of;icers to stop and question any unauthorized individuals within the evacuation areas. On January 10, the LA County Sherrif’s Department implemented a curfew order for all Los Angeles County evacuation order zones. With this curfew in place, the City of Santa Monica promptly amended its order to fully align with the County order. This amended order reduced the number of impacted households to 2,205.

According to a SMPD press release, hundreds of individuals were detained and questioned and over 40 were arrested.

Fire Department
According to Santa Monica Fire Department (SMFD) command personnel, SMFD does not have a speci;ic policy regarding upstaf;ing for inclement weather conditions including Red Flag Warnings; however, due to the extreme nature of the predicted weather pattern that the National Weather Service (NWS) identi;ied as a potentially life-threatening event—known as a Particularly Dangerous Situation (PDS)—the decision was made to staff two additional Type I ;ire engines on the morning of January 7, 2025. According to the National Oceanic and Atmospheric Administration (NOAA), “PDS wording is used in rare situations when long-lived, strong and violent tornadoes are possible. This enhanced wording may also accompany severe thunderstorm watches for intense convective windstorms.”2 Immediately following the initial noti;ication of the Palisades Fire SMFD, in coordination with the other Los Angeles County Disaster Management Area “A” agencies, SMFD responded to the Palisades Fire as part of Strike Team 1075-A. Strike Team 1075-A was requested at 10:52 a.m. and was on scene in the Palisades by 11:23 a.m. By 1:00 p.m., SMFD had recalled suf;icient personnel to maintain full staf;ing in the City and to assemble a task force that operated within the City limits. This task force responded to spot ;ires, responded to smoke and potential ;ire calls in the high vegetation areas, patrolled the northernmost area of the City looking for embers and ;ire spread, and worked closely with ;ire units assigned to the southern edge of the Palisades Fire.

The task force consisted of a Task Force Leader with an assigned Fire Captain, Truck 2, 2- Type I Fire Engines, and 1-Type VI wildland ;ire apparatus. Overhead staff, including the Fire Chief and one Deputy Chief, were primarily assigned to the IMT as agency representatives.

Having these individuals work closely with the IMT at the ICP proved to be a valuable means for the EOC to maintain current situational awareness.
2 NOAA’s National Weather Service-Glossary. Retrieved from https://forecast.weather.gov/glossary.php?word=PDS

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Packet Pg. 1094 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 15 Public Works
Fortunately, the Palisades Fire
did not reach the Santa Monica
City limits. Maps indicate that
the closest spot ;ire was
approximately 0.4 miles north
of the City limits. Even though
the City did not sustain any
direct ;ire damage, signi;icant
damage was noted throughout
the area due to the extreme
straight-line winds. According
to a City damage assessment,
there were 178 tree branch or
whole-tree failures, and
approximately 445 tons of
debris had to be removed from streets, sidewalks, storm drains, and beaches throughout the City. Multiple Public Works divisions, working with outside vendors, spent extensive hours removing debris. Crews prioritized evacuation zones to ensure safe egress and to support residents’ safe return once evacuation orders were lifted. In addition to the debris, downed trees also damaged several sections of sidewalk and chain link fencing at Memorial Park.

Proving that relationships with outside agencies are bene;icial, SMFD was able to coordinate with CAL FIRE Incident Management Team 2 to utilize multiple hand crews to perform long overdue vegetation management in the Bluffs along PCH. These crews, with assistance from Caltrans, spent January 15 and 16 cutting and removing over 85 tons of trees, overgrowth and other debris to proactively reduce the threat of wild;ire spreading into this essential route. Public Works hauled all debris to approved recycling facilities. According to Public Works of;icials, this area along PCH had not been cleaned in years and this work potentially saved the City several hundred thousand dollars.

Picture 3: Tree damage. Photo Credit: City of Santa Monica

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Packet Pg. 1095 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 16 Picture 4: PCH Bluffs cleanup efforts by CAL FIRE and Santa Monica Public Works.

Photo Credit: City of Santa Monica
Transportation
SaMoDOT, which operates the City’s public transportation system known as the Big Blue Bus, was immediately impacted by the Palisades Fire. The Big Blue Bus implemented temporary detours to several lines including lines 18 and 43 that operated through or immediately adjacent to evacuation zones. To assist residents impacted by evacuations, Big Blue Bus, through the EOC, provided evacuees transportation to the West LA Red Cross evacuation shelter at designated pick-up locations within the Santa Monica evacuation zones and also facilitated pick-ups at senior housing facilities. All impacted Big Blue Bus routes resumed normal operations as the evacuation warnings and orders were lifted.

Route 9 and Route 9 Express, which provide riders with direct access into the Palisades, were more greatly impacted. At the onset of the ;ire, operators made immediate adjustments to the routes because of the evacuation-related gridlock on Sunset Boulevard. As noted in many reports, some residents abandoned their vehicles on the road and walked due to impassable conditions. Some of these individuals were able to access the Big Blue Bus and safely evacuate the area. According to SaMoDOT of;icials, Route 9 Express was not transporting riders to Palisades High School on January 7 due to a school closure, otherwise additional buses may have become involved in evacuation congestion. According to SaMoDOT, Route 9 resumed normal operations on August 10, 2025, while Route 9 Express was out of service until January 27, 2026.

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Packet Pg. 1096 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 17 Picture 5: Santa Monica Department of Transportation Big Blue Bus In addition to modifying several Big Blue Bus routes, SaMoDOT provided incident support by allowing mutual aid ;ire resources to utilize its bus storage yard as an incident staging location, and by utilizing transportation department mechanics to provide maintenance and repairs for ;ire apparatus during the event. These actions allowed for apparatus and ;ire;ighting personnel to remain in service and tactically involved with ;ire;ighting operations.

Incident Overview
Weather
On the morning of January 7, 2025, Southern California was bracing for extreme weather conditions. As early as December 31, 2024, NWS had advised of the potential for a Santa Ana wind-driven Fire Weather Watch for the area, and anticipating a Red Flag Warning beginning on January 7 and lasting through January 9, 2025. According to NWS, a Red Flag Warning is issued either during or up to 24 hours prior to an event where the combination of dry fuels and weather conditions support extreme ;ire conditions. Speci;ic criteria required for a Red Flag warning to be issued, as de;ined by NWS for Southern California include:
• Relative humidity of 15 percent or less with either sustained winds of 25 mph or greater or frequent gusts 35 mph or greater for a duration of 6 hours or more. • Relative humidity of 10 percent or less with either sustained winds 15 mph or greater or frequent gusts 25 mph or greater for a duration of 6 hours or more.

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Packet Pg. 1097 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 18 • Widespread and/or signi;icant dry lightning.
• Other (forecaster discretion) – unusual but signi;icant meteorological and or fuel conditions in coordination with the Geographic Area Coordination Center (GACC) or local agency.3
On January 2, 2025, NWS once again advised of the potential for a moderate to strong Santa Ana event with extreme ;ire weather conditions between January 6 and January 9, 2025. On January 6, 2025, NWS issued an of;icial Red Flag Warning for nearly all of Southern California from San Luis Obispo to the Mexico border. Following the previous advisories, on the morning of January 6, 2025, NWS updated its forecast to include the potentially lifethreatening event known as a Particularly Dangerous Situation (PDS). NOAA states, “PDS wording is used in rare situations when long-lived, strong and violent tornadoes are possible.

This enhanced wording may also accompany severe thunderstorm watches for intense convective windstorms.”4
Winds in the areas of the Malibu coast, Santa Monica Mountains, and in the San Gabriel, San Fernando, and Santa Clarita Valleys were forecasted to be between 60-80 mph (97-129 km/h), with gusts anticipated to reach 90 mph (140 km/h) or greater. These extreme winds were anticipated to impact areas of Southern California that had just experienced extreme weather swings of wet and dry conditions. During the past several years, this area has experienced what some weather observers have termed “weather whiplash.” Two consecutive rainy winters that boosted vegetation growth followed by extremely dry, nearzero rainfall conditions over the previous eight months—in addition an extremely strong Santa Ana wind event—made for extremely ;ire-friendly climate conditions that set the stage for the January 2025 ;ires.

Ignition
On the morning of January 7, 2025, at 10:20 a.m., a camera operated by AlertCalifornia observed the ;irst signs of smoke in the Santa Monica Mountains near Temescal Trailhead 1 adjacent to the 8-acre burn scar left by the January 1, 2025, Lachman Fire. By 10:30 a.m., LAFD had received multiple 911 calls advising of the same. The Palisades Fire rapidly grew, pushed by increasingly high wind speeds and highly variable wind directions. The winds continued to worsen throughout the day, reaching 60-80 mph (97-129 km/h) with gusts up to 100 mph (161 km/h), severely impacting the ability to extinguish the wild;ire. Air resources including ;ixed-wing retardant tankers, Super-Scoopers, and helicopters assisted in the ;ire;ighting efforts but were eventually grounded due to the extreme wind conditions. 3 NOAA DeLinitions of a Fire Weather Watch and a Red Flag Warning. Retrieved from https://www.weather.gov/media/lox/LOX-Red-Flag-Criteria.pdf 4 NOAA Glossary. Retrieved from https://forecast.weather.gov/glossary.php?word=WATCH

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Packet Pg. 1098 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 19 Within one hour, CAL FIRE reported that the ;ire, pushed by hurricane-force winds, had grown to 200 acres, destroying homes, cars, and everything in its path. Over the next days and weeks, as weather conditions became more favorable, ;ire crews continued to gain control of the Palisades Fire. On the evening of January 31, 2025, the ;ire was declared 100 percent contained. The Palisades Fire burned 23,448 acres, destroyed 6,833 structures, damaged 973 structures, killed 12 civilians, and injured one ;ire;ighter and three civilians, making it the tenth deadliest and third most destructive California wild;ire on record, and the most destructive to occur in the City of Los Angeles. Cause and origin investigators with the Bureau of Alcohol, Tobacco, and Firearms (ATF), along with local ;ire and police investigators, have determined that the Palisades Fire was a “holdover” ;ire, a continuation of the Lachman Fire which was suppressed by ;ire;ighters on January 1, 2025, but continued to smolder within the root structure of dense vegetation before reigniting amid ;ierce Santa Ana winds on the morning of January 7, 2025. Investigators determined that the Lachman Fire was intentionally set, and on October 7, 2025, arrested and charged Jonathan Rinderknecht with multiple counts of destruction of property by means of ;ire for intentionally setting the initial ;ire that eventually caused the Palisades Fire.

Evacuation
As the Palisades Fire rapidly grew from
ignition to over 200 acres in the ;irst hour,
pushed by hurricane-force winds in an
area known for steep terrain, dry
overgrown brush, and narrow winding
roads, the Incident Management Team
(IMT) determined that getting ;ire
suppression resources into the area and
residents out of the area was going to be a
dif;icult process. Traf;ic on Sunset
Boulevard and PCH quickly became
inundated with vehicles and pedestrians
trying to leave the area. At one point,
bulldozers had to be utilized to push
abandoned vehicles out of the road to
allow for incoming ;ire units.

According to Cal Fire Status Update Reports, on January 7, 2025, at 11:49 a.m., the ;irst Evacuation Warning was issued followed by the establishment of the initial Evacuation Order for the “;ire area all the way down to Paci;ic Coast Highway” at 12:00 p.m. By 12:37 p.m., the large Evacuation Zone that abuts the City limits of Santa Monica at Adelaide Drive, LOS11.A.a Packet Pg. 1099 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 20 Q0767, had been placed on Evacuation Orders. This evacuation order came with the advisory “leave now.” Prior to the of;icial evacuation orders being issued many residents in the Palisades had been advised to evacuate the area by ;irst responders.

Due to evacuation orders reaching the Santa Monica City limits, by midafternoon EOC staff began drafting contingency plans for implementing evacuation orders within the City. At the time of the Palisades Fire, LA County was in the process of ;inalizing speci;ic evacuation zones to be included in the Genasys Protect public safety platform, but the zones had not yet been ;inalized or adopted. The evacuation zones utilized during the Palisades Fire were created by the EOC team in coordination with SMPD, SMFD, the IMT, and the LA County EOC.

At 7:24 p.m., representatives from Santa Monica OEM, SMPD, SMFD determined that it was necessary to implement an Evacuation Order for the northernmost areas of the city. The ;irst evacuation zones within the Santa Monica City limits were placed on Evacuation Orders.

Identi;ied as Evacuation Zones SAN-Q1395-B and SAN-Q1396-B, these zones encompassed the area north of San Vicente Boulevard to Adelaide Drive extending from the Paci;ic Ocean east to 26th Street. Residents living in these zones were advised to leave the area immediately due to an imminent threat to both life and property. Concurrently, the two zones located immediately to the south, zones SAN-Q1388-B (originally identi;ied as SAN-Q1395- A) and SAN-Q1396-A were included in evacuation warnings. These warnings included the area bounded by Montana Avenue to the south, the Paci;ic Ocean to the west, and 26th Street to the east. Emergency messaging advising residents of the Evacuation Orders and Warnings were issued in both English and Spanish through multiple channels including SMAlerts to all registered users, a Wireless Emergency Alert (WEA) to all cell phones located within the geographic boundaries of the Evacuation Order and Warning zones, social media platforms, and the City’s website.

On Wednesday, January 8, 2025, as the ;ire continued to progress, numerous evacuation zones throughout the entire region were included in the Evacuation Warnings and multiple zones were modi;ied from Warning to Orders. At 2:30 p.m., Santa Monica zone SAN-Q1396- A was upgraded from Evacuation Warning to Evacuation Orders. This included the area of Montana Ave north to San Vicente Blvd and the Paci;ic Ocean to 11th St. By upgrading this zone from a Warning to an Order, the City opted to place Zone SAN-Q1389 on Evacuation Warning status. This additional zone runs from Wilshire Blvd north to Montana Ave and from the Paci;ic Ocean to 10th St. City of Santa Monica staff advised that this zone did not appear to be in any danger, but due to the adjacent zone having been upgraded to Evacuation Orders it was their determination, based upon earlier direction from Cal Fire to not have zone SANQ1396-A abut a zone that was not on Evacuation Warning status. The SMAlerts and City press release advised:

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Packet Pg. 1100 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 21 “The evacuation warning has been expanded to all areas north of Wilshire Boulevard and west of 10th Street. Residents in this area should gather essentials and prepare to leave if needed. Those who require additional time to evacuate should leave now.” Evacuation zone SAN-Q1389 was ultimately never upgraded to an Evacuation Order and remained in Evacuation Warning status until Friday, January 10, 2025, at 3:22 p.m., when the evacuation warning was of;icially lifted.

Map 2: Provided by the City of Santa Monica OEM
Air Quality
During a wild;ire event similar to the January 2025 Palisades Fire, air quality in the immediate area and surrounding communities can be greatly impacted. Exposure to wild;ire smoke poses respiratory and cardiovascular risks, ranging from short-term effects such as coughing and eye irritation to long-term conditions including heart or lung disease and, in severe cases, premature death. The smoke contains hazardous pollutants including ;ine particles known to researchers as PM2.5. These particles impact what is known as the Air Evacuation order
Evacuation warning
Evacuation warning
Palisades Fire_Maximum Santa Monica Evacuation Zones_01.08.25 Esri, NASA, NGA, USGS, FEMA, Sources: Esri, TomTom, Garmin, FAO, NOAA, USGS, © OpenStreetMap contributors, and the GIS User Community Road Closures
City Boundary
Palisades Fire Evacuation Zones_phases - PalisadesFireEvacuationZone 1 8 25 1430 maximum evac order Evacuation order
Evacuation warning
World_Hillshade
5/28/2025 0 0.3 0.6 1.2 mi
0 0.5 1 2 km
1:44,485

11.A.a
Packet Pg. 1101 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 22 Quality Index (AQI). AQI is a system used to report on how clean or polluted the air is in a given area. The AQI is scored on a scale of 0 to 500 with higher scores representing worse air quality and greater health concerns. The scale is divided into six color-coded categories ranging from “Good” to “Hazardous” to help the public quickly understand the current air quality conditions and the potential health impacts.

Air Quality Index
Pollutant Speci2ic Cautionary Statements
Health
Category Ozone
Very Small
Particles
(PM2.5)
Small Particles
(PM10)
Carbon
Monoxide (CO)
Very
Unhealthy
(201 to 300)
Active children and
adults, and people
with respiratory
disease, such as
asthma, should avoid
all outdoor exertion;
everyone else,
especially children,
should limit outdoor
exertion.

People with
respiratory or heart
disease, the elderly,
and children should
avoid any outdoor
activity; everyone else
should avoid
prolonged exertion.

People with
respiratory disease,
such as asthma,
should avoid any
activity; everyone else,
especially the elderly
and children, should
limit outdoor exertion.

People with
cardiovascular
disease, such as
angina, should avoid
exertion and sources
of CO, such as heavy
traf>ic.

Unhealthy
(151 to 200)
Active children and
adults, and people
with respiratory
disease, such as
asthma, should avoid
prolonged outdoor
exertion; everyone
else, especially
children, should limit
prolonged outdoor
exertion.

People with
respiratory or heart
disease, the elderly
and children should
avoid prolonged
exertion; everyone
else should limit
prolonged exertion.

People with
respiratory disease,
such as asthma,
should avoid outdoor
exertion; everyone
else, especially the
elderly and children,
should limit
prolonged outdoor
exertion.

People with
cardiovascular
disease, such as
angina, should limit
moderate exertion
and avoid sources of
CO, such as heavy
traf>ic.

Unhealthy
for Sensitive
Groups (101
to 150)
Active children and
adults, and people
with respiratory
disease, such as
asthma, should limit
prolonged outdoor
exertion.

People with
respiratory or heart
disease, the elderly
and children should
limit prolonged
exertion.

People with
respiratory disease,
such as asthma,
should limit outdoor
exertion.

People with
cardiovascular
disease, such as
angina, should limit
heavy exertion and
avoid sources of CO,
such as heavy traf>ic.

Moderate
(51 to 100)
Unusually sensitive
people should
consider limiting
prolonged outdoor
exertion.

None None None
Good
(0 to 50)
None None None None
Graphic 3: Air Quality Index. Retrieved from South Coast Air Quality Management District https://www.aqmd.gov/docs/default-source/students/air-quality-index-airpollution-affects-everyone.pdf

11.A.a
Packet Pg. 1102 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 23 Primary responsibility for ongoing air quality monitoring in the Southern California region belongs to the South Coast Air Quality Management District (AQMD). The South Coast AQMD is the air pollution control agency for all of Orange County and the urban portions of Los Angeles, Riverside, and San Bernardino counties. The mission of the South Coast AQMD is:
“To clean the air and protect the health of all residents in the South Coast Air District through practical and innovative strategies.”
In addition to the air quality monitoring completed by the South Coast AQMD, the City of Santa Monica also uses data from AirNow.gov and approximately 35-40 PurpleAir sensors to collect neighborhood-speci;ic, real-time air quality data and share it with the public.

The South Coast AQMD issued its ;irst Smoke Advisory for Northwest Los Angeles County due to the Palisades Fire on Tuesday, January 7, 2025, at 2:00 p.m. The advisory forecasted AQI levels potentially reaching Unhealthy for Sensitive Groups (101-150) in the local area beginning Wednesday morning and extending through the afternoon. Daily Smoke Advisories were issued by the South Coast AQMD through January 14, 2025, when the AQI reached Good to Moderate levels due to decreased smoke production. As smoke production from the Palisades Fire decreased and the air quality in the region returned to Good and Moderate levels, the South Coast AQMD transitioned their advisories from smoke advisories to windblown ash advisories and monitoring.

On January 31, 2025, the AQMD expanded its air monitoring in the region by deploying two mobile monitors with additional stationary monitors installed in the area. Increased air monitoring continued in the region throughout the cleanup process and results were issued on a weekly basis until July 11, 2025. Results of the air monitoring showed air quality levels below the Federal standards throughout the cleanup process. Utilizing data obtained from community-based PurpleAir sensors and Airnow.gov, the City of Santa Monica provided multiple updates to the community through its SMAlerts system, social media outlets, press releases, and its Palisades Fire website regarding air quality issues. On January 8, 2025, the City utilized its social media platforms to advise that air quality levels ranged from Unhealthy for Sensitive Groups (Orange 101-150) levels on the west side of the City to Moderate (Yellow 51-100) levels on the east side of the City. On January 9, 2025, at 1:05 p.m., following a change in wind direction, the City updated the air quality noti;ication advising that air quality had reached Unhealthy (Red 151-200) throughout parts of the City. Included in the advisories was the following information:

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Packet Pg. 1103 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 24 “If you are in a sensitive group, please take precautionary measures by: Staying indoors, reducing unnecessary travel, wearing an N95 mask if outdoors. View air quality map at AQMD.gov.”
Maps 3 & 4: Air Quality Jan. 7-Jan 10, 2025. Retrieved from South Coast Air Quality Management District

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Packet Pg. 1104 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 25 Palisades Fire Incident Sequence of
SigniBicant Incidents
Tuesday, December 31, 2025
9:21 a.m. NWS Santa Ana wind forecast beginning 01/06/2025 Thursday, January 2, 2025
6:26 p.m. NWS advises of potential Red Flag conditions and damaging winds between 1/7/25 and 1/9/25
1:32 p.m.

NWS issues Red Flag Warning beginning Tuesday,
January 7 through Thursday, January 9, 2025
9:21 a.m. NWS Santa Ana wind forecast beginning 01/06/2025 Sunday, January 5, 2025
Monday, January 6, 2025
Tuesday, January 7, 2025
10:20 a.m. AlertCalifornia camera observes Nirst smoke
11:06 a.m. LAFD reports Nire at 10 acres
11:44 a.m. First Evacuation Warnings issues. (200 acres) 1:00 p.m. Wind gusts reported to 57 mph
2:27 p.m. Evacuation center opened at Westwood Recreation Center
12:37 p.m.

Evacuation Order issued for zone LOS-Q0767 to Santa
Monica City limits

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Packet Pg. 1105 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 26 3:34 p.m. UniNied Command established: LAFD, LACoFD & LAPD. (1,262 acres)
5:15 p.m. Evacuation Orders issued for Topanga west of Tuna Canyon Rd. “Leave Now”
6:45 p.m. Aircraft grounded due to high winds
7:00 p.m. Wind gusts to 69 mph
7:56 p.m. LAFD: LA City evacuation Order issued for PaciNic Palisades
2:27 p.m. Evacuation center opened at Westwood Recreation Center
8:00 p.m. Wind gusts to 83 mph
7:24 p.m.

Evacuation Orders issued for Santa Monica:

SAN-Q1395-B & SAN-Q-1396-B.

Evacuation Warnings issued for Santa Monica:

SAN-Q1388-B & SAN-Q1396-A
4:06 p.m. CAL FIRE IMT II activated
8:35 p.m. 2nd Evacuation Center opened at El Camino Real Charter High School
9:00 p.m. Wind gusts to 79 mph
10:00 p.m. Wind gusts to 88 mph
Wednesday, January 8, 2025
12:00 a.m. Wind gusts to 86 mph
8:24 a.m. 3rd Evacuation Center opened at Pasadena Convention Ctr. 9:01 a.m. Air operations to restart
11:45 a.m. Fire has burned 11,802 acres
City of Los Angeles Declares Local Emergency
LA County proclaims the existence of a Local Emergency
California issues Proclama:on of a State of Emergency
FEMA approves Fire Management Assistance Grant (FMAG)

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Packet Pg. 1106 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 27 1:20 p.m. Fire has burned 15,832 acres
2:30 p.m.

SAN-Q1396-A moved from Evacuation Warning to
Order Evacuation Warning issued for SAN-Q1389
11:10 p.m. Fire has burned 17,234 acres
Thursday, January 9, 2025
6:45 p.m. Fire has burned 19,978 acres: 6% containment Friday, January 10, 2025
7:49 a.m. Fire has burned 20,438 acres: 8% containment 3:22 p.m.

SAN-Q1396-A moved from Evacuation Orders to
Warning SAN-Q1389 removed from Evacuation
Warning
3:37 p.m. Fire has burned 21,317 acres
Saturday, January 11, 2025
4:37 p.m. Fire has burned 23,654 acres: 11% containment Sunday, January 12, 2025
6:54 p.m. Fire has burned 23,713 acres: 13% containment Santa Monica Declares the Existence of a Local Emergency includes City Curfew Order
President Biden approves California Major Disaster
Declara:on
Los Angeles County Board of Supervisors issues Curfew
Order
Santa Monica modiNies existing Curfew Order to align
with LA County order
Los Angeles County Health OfNicer declares a local health emergency due to hazardous air quality

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Packet Pg. 1107 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 28 Monday, January 13, 2025
8:00 a.m.

SAN-Q1396-B & SAN-Q1395-B removed from
Evacuation Orders and placed on Evacuation
Warnings. SAN-Q1396-A & SAN-Q1388-B removed
from Evacuation Warning.

Saturday, January 18, 2025
12:00 p.m. SAN-Q1396-B & SAN-Q1395-B removed from
Evacuation Warnings
12:00 p.m. Fire has burned 23,713 acres: 43% containment Saturday, January 18, 2025
12:00 p.m.

CAL FIRE Status Report Incident Data:
23,448 acres
100% containment
6,833 structures destroyed
973 structures damaged
0 NireNighter fatalities
12 civilian fatalities
1 NireNighter injury
3 civilian injuries

11.A.a
Packet Pg. 1108 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 29 Key Decision Points & Actions Taken
City of Santa Monica
Actions Taken During 2025 Palisades Fire
Monday, January 6,
2025
1:00 p.m.

OEM attends brieNing with NWS regarding dangerous
weather conditions. Distributes information to key
personnel/Departments, Area A, LA City EMD, and LA
Co EMD
2:30 p.m.

Social Media post advising Red Flag Warning and High
Wind Warning
City of Santa Monica uses SMAlerts to registered users, Instagram, Facebook, Twitter/X, and its own website
for social media notices
Tuesday, January 7,
2025
10:20
a.m.

AlertCalifornia camera observes Nirst smoke
10:27
a.m.

Santa Monica Dispatch receives Nirst call reporting
smoke in the Santa Monica Mountains
10:30
a.m. Initial reports of Palisades Fire
10:52
a.m.

LAFD requests mutual aid from Santa Monica Fire
Department
11:00
a.m.

City staff begin to gather in EOC.

EOC activated to Level 2-Moderate
11:23
a.m.

SMFD on scene of Palisades Fire
SMPD TrafNic Services Division implements
TrafNic Services Functional Brush Fire Evacuation Plan
Closures include:

I-10 Fwy. westbound at 4th St on to PCH
Moomat Ahiko & CA Incline on ramps on to PCH
Northbound Ocean Ave., 7th St., & 26th St. @ San
Vicente Blvd. to prevent trafNic into LA/Palisades
11:27
a.m.

Social Media post advising City of Santa Monica
monitoring brushNire in PaciNic Palisades
11:48
a.m.

SMAlerts issued advising City of Santa Monica
monitoring brushNire in PaciNic Palisades
12:37
p.m.

Evacuation Orders issued for Zone LOS-Q-0767 (Now
LFD-1097) PaciNic Palisades area south to Adelaide Dr.
(City of Santa Monica northern boundary)
1:34 p.m. SMAlerts/social media issued advising of

11.A.a
Packet Pg. 1109 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 30 Westbound I-10 @Lincoln Blvd. & northbound PCH
will be closed until further notice
2:40 p.m. EOC creates incident webpage to communicate
information to the public
2:50 p.m. Social Media post advising there is currently no threat to the City and no evacuation orders in the City
2:58 p.m. SMAlerts/social media post issued advising currently no evacuation orders or warnings within the City
4:00 p.m.

Social media post advising the City is closely
monitoring Nire and working with ICP to assist with
evacuations on PCH
4:30 p.m. EOC developing evacuation protocols
4:40 p.m. Social Media post advising of road closures in the City 6:00 p.m. EOC contacts ICP to coordinate evacuations
7:24 p.m.

SAN-Q1395-B & SAN-Q1396-B placed on Evacuation
Orders
San Vicente Blvd. north to Adelaide Dr.

PaciNic Ocean to 26th St.

SAN-Q1388-B, SAN-Q1395-A, & SAN-Q1396-A
Placed on Evacuation Warning
Montana Ave. to San Vicente Blvd
PaciNic Ocean to 26th St
7:24 p.m. SMAlerts issued advising of updated evacuations 7:33 p.m. The City contacts LACo EM to assist with adding SM Evac Zones to Genasys Protect
8:00 p.m.

Social Media post advising of Evacuation Orders for all areas north of San Vicente Blvd. Advises to
“Leave Now.’ Additional Evacuation Warning issued
for area north of Montana Ave. from PCH to 26th St.
9:13 p.m. Press Release issued regarding evacuation orders and warnings
Wednesday, January
8, 2025
2:00 a.m. EOC transitions to Duty OfNicer status
5:30 a.m. Social media post the City is working with Palisades Fire command post. No changes to evacuation zones
12:14
p.m.

SMAlerts issued advising City continuing to monitor
the Palisades Fire
8:00 a.m. EOC staffed: Level 2-Moderate
SMPD Issues Tactical Alert
10:30
a.m. City evacuation zones remain unchanged
12:14
p.m.

SMAlerts, WEA, social media, and website: Santa
Monica closely monitoring the Palisades Fire. No
changes to evacuation zones
Proclamation of existence of a Local Emergency issued
for the City of Santa Monica includes curfew order

11.A.a
Packet Pg. 1110 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 31 2:00 p.m.

Social Media post advising free Big Blue Bus
transportation to the Palisades Fire evacuation center
located at Westwood Recreation Center. Pickup
location at Lincoln Blvd. and Montana Ave.
2:30 p.m.

SAN-Q1396-A Moved from Evacuation Warning to
Evacuation Order.

Montana Ave. north to San Vicente Blvd
PCH to 11th St.
2:30 p.m.

SAN-Q1389 Placed on Evacuation Warning
Wilshire Blvd. north to Montana Ave.

PCH to 10th St.

Warning advised: Those who require additional
time to evacuate and those with pets should leave
now.
2:30 p.m.

Social Media post expanding the evacuation order for
the area north of Montana Ave. and from PCH to 11th
St.
2:31 p.m. SMAlerts issued updating evacuation orders and warnings
7:00 p.m.

Social Media post advising current air quality levels
are ranging from Unhealthy for Sensitive Groups on
the west side of the City to Moderate levels on the east side. If you are in a sensitive group, please take
precautionary measures by: staying indoors and
reducing unnecessary travel, and wearing an N95
mask if outdoors.

City issues Curfew Order for evacuation zones from
6:00 p.m. to 6:00 a.m.
8:56 p.m.

Press Release issued advising of the issuance of an
Emergency Order that includes a sunset to sunrise
curfew for all mandatory evacuation zones
11:00
p.m. EOC transitions to Duty OfNicer
Thursday, January 9,
2025
7:00 a.m. EOC staffed: Level 2-Moderate
7:05 a.m. SMAlerts issued regarding current evacuation zones 1:05 p.m.

SMAlerts issued regarding Air Quality. Current air
quality levels are reaching unhealthy levels in some
parts of the City. Stay indoors to reduce exposure.
4:07 p.m.

SMAlerts issued regarding an erroneous county
evacuation alert that had been issued for areas in the
City outside of the current evacuation zones
11:00
p.m. EOC transitions to Duty OfNicer
Friday, January 10,
2025
9:00 a.m. EOC staffed: Level 2-Moderate

11.A.a
Packet Pg. 1111 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 32 10:43
a.m.

Press Release issued advising that California National
Guard personnel will be manning trafNic control points
in the City
City curfew order amended to align with LA County
curfew order
3:01 p.m. Press Release issued updating evacuation zone orders and warnings
3:16 p.m.

Social Media post advising the evacuation warning had
been lifted for the area of Wilshire Blvd. north to
Montana Ave. and from PCH to 11th St.
3:22 p.m. SMAlerts issued advising updates to evacuation zones 3:22 p.m.

SAN-Q1396-A moved from Evacuation Orders to
Evacuation Warning
Montana Ave. north to San Vicente Blvd. and
PCH to 11th St
SAN-Q1389 removed from Evacuation Warning back to
normal status
Wilshire Blvd. north to Montana Ave.

PCH to 10th St.
7:00 p.m. EOC transitions to Duty OfNicer
Saturday, January 11,
2025
9:00 a.m. EOC activated but staffed remotely: Level 2-Moderate 6:12 p.m. SMAlerts issued advising the NWS had issued a Red Flag Warning through Wednesday, January 15, 2025
6:47 p.m. Press Release issued updating evacuation zone orders and warnings also advising of Red Flag Warning
7:00 p.m. EOC transitions to Duty OfNicer
Sunday, January 12,
2025
9:00 a.m. EOC Activated but staffed remotely: Level 2-Moderate 7:00 p.m. EOC transitions to Duty OfNicer
Monday, January 13,
2025
7:00 a.m. EOC staffed: Level 2-Moderate
8:00 a.m.

SAN-Q1395-B & SAN-Q1396-B moved from evacuation
orders to warnings
San Vicente Blvd. to Adelaide Dr.

PaciNic Ocean to 26th St
SAN-Q1396-A removed from evacuation warning back
to normal status
Montana Ave. north to San Vicente Blvd.

PCH to 11th St.

SAN-Q1395-A removed from evacuation warning back
to normal status
Montana Ave. north to San Vicente Blvd
11th St. to 26th St.

11.A.a
Packet Pg. 1112 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 33 8:02 a.m. SMAlerts issued advising evacuation zone updates 8:16 a.m. Press Release issued advising evacuation zone updates 5:08 p.m. Press Release issued advising evacuation zone updates 7:00 p.m. EOC transitions to Duty OfNicer
Tuesday, January 14,
2025
7:00 a.m. EOC activated but staffed remotely: Level 2-Moderate 7:00 p.m. EOC transitions to Duty OfNicer
Wednesday, January
15, 2025
7:00 a.m. EOC activated but staffed remotely: Level 2-Moderate SMPD Rescinds Tactical Alert
Santa Monica Public Works in coordination with State
resources perform debris clearance in Santa Monica
Bluffs along PCH
7:00 p.m. EOC transitions to Duty OfNicer
Thursday, January 16,
2025
7:00 a.m.

EOC activated with decreased staff working remotely:

Level 3-Monitoring
Bluff cleanup completed. Approximately 85 tons of
debris removed.
5:00 p.m. EOC transitions to Duty OfNicer
Friday, January 17,
2025
7:00 a.m. EOC activated with decreased staff working remotely:

Level 3-Monitoring
5:00 p.m. EOC transitions to Duty OfNicer
Saturday, January 18,
2025
7:00 a.m. EOC activated with decreased staff working remotely:

Level 3-Monitoring
Moomat Ahiko and CA Incline onramps to PCH reopen
for local access
12:00
p.m.

SAN-Q1395-B &SAN-Q1396-B both removed from
evacuation warnings back to normal status
San Vicente Blvd. north to Adelaide Dr.

PaciNic Ocean to 26th St.

City rescinds curfew order
12:07
p.m.

SMAlerts issued advising that ALL City evacuation
zones had returned to normal status
EOC demobilized

11.A.a
Packet Pg. 1113 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 34 Friday, February 28,
2025
I-10 reopens at 4th & 5th street exits and one lane to
PCH
Friday, May 23, 2025
PCH reopened northbound at Entrada Dr.

Timeline Legend
Date
City Actions
EOC Status Updates
Evacuation Zone Updates
Fire Status Updates
Incident Updates from the City of Santa Monica
(SMAlerts, WEA, Press Release, social media post, City website)
Road Closure Updates
Communications
Internal and External Communications
Internal and external communications were essential to the City of Santa Monica’s ability to maintain situational awareness and operational readiness during the 2025 Palisades Fire.

Although the incident did not directly impact City boundaries, its proximity and regional effects required coordinated information sharing to support decision making, public safety actions, and interagency coordination.

Internally, consistent communications across City departments supported a shared common operating picture and enabled timely policy and operational decisions. Information related to ;ire progression, evacuation activity in adjacent jurisdictions, air quality impacts, and potential escalation scenarios was regularly communicated to City leadership and operational staff through twice daily department head brie;ings. This coordination supported the implementation of emergency orders, curfews, readiness activities, and resource staging, while ensuring City personnel had accurate and consistent information when engaging with the public and partner agencies.

Externally, the City’s communications focused on delivering clear, timely, and accurate information to residents, businesses, and visitors. Public messaging addressed evolving ;ire

11.A.a
Packet Pg. 1114 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 35 conditions, weather advisories, public safety advisories, curfews, evacuation zone order and warnings, and available resources, helping reduce confusion and misinformation during a rapidly changing regional emergency. Transparent and consistent messaging reinforced public con;idence and demonstrated the City’s preparedness despite the ;ire occurring primarily outside municipal limits.

Additionally, the City played a key role in amplifying information from County and State partners and supporting regional response efforts through public information sharing. These communications aided evacuees, supported ;irst responders, and enhanced regional situational awareness. Overall, effective internal and external communications strengthened operational coordination, supported informed decision-making, and maintained public trust throughout the Palisades Fire incident.

Palisades Fire Communications Team
Role City Department
EOC PIO City Manager’s Of;ice
Media Relations/JIC City Manager’s Of;ice
Social Media City Manager’s Of;ice
Social Media & Website Content Updates City Manager’s Of;ice Everbridge/SMAlerts City Manager’s Of;ice
Everbridge/SMAlerts & Website Content
Updates Information Services Department
Police Department Liaison Santa Monica Police Department Police Department Liaison Santa Monica Police Department Fire Department Liaison Santa Monica Fire Department
Graphic 4: Communications Team StafLing. Information provided by City of Santa Monica OEM.

Recovery Efforts
Following the Palisades Fire, the City of Santa Monica implemented a coordinated recovery effort focused on protecting public health, minimizing environmental impacts, restoring access and economic activity, and supporting regional recovery. Although the City did not sustain direct wild;ire damage, its proximity to severely impacted neighboring communities resulted in prolonged secondary impacts affecting ocean water quality, debris management, transportation, tourism, and business continuity.

11.A.a
Packet Pg. 1115 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 36 Environmental Health, Ocean Water Quality, and Beach Recovery A primary recovery priority was addressing wild;ire debris and sediment that entered Santa Monica Bay. Following post-;ire rain events, ash, burned materials, and sediment from upstream burn areas accumulated along regional shorelines and within City storm drains.

The City coordinated closely with Los Angeles County Department of Public Health, the Los Angeles Regional Water Quality Control Board (LARWQCB), LA County Beaches & Harbors, and LA County OEM to advocate for expanded environmental testing within the City and transparent public reporting of results. Multiple organizations, including the Southern California Coastal Water Research Project (SCCWRP), LARWQCB, and the Surfrider Foundation L.A. Chapter, conducted water quality and sand sediment monitoring throughout Santa Monica Bay between January 22, 2025, and ending on May 1, 2025. According to test results released by LARWQCB, “the board compared ocean water quality results with U.S.

EPA risk-based screening levels for recreation in water and Ocean Plan objectives for consumption of ;ish and all results were below these standards.” Picture 6: Fire debris on Santa Monica Beach. Photo Credit: City of Santa Monica While awaiting formal health guidance, Santa Monica Public Works implemented interim protective measures, including the construction of sand berms to contain debris in storm channels and prevent secondary contamination. City crews conducted repeated mechanical and hand removal of ;ire-related debris from beaches following storm events. City staff also actively participated in a Joint Information Center (JIC) that was established to disseminate consistent, coordinated messaging regarding beach health and regional recovery efforts. City staff also hosted a town hall with environmental health agencies, and developed a dedicated

11.A.a
Packet Pg. 1116 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 37 wild;ire recovery webpage to provide clear, consistent information on beach conditions and public safety considerations. According to OEM, ;ire debris stopped washing onto the City beaches by summer 2025.

Debris Removal Coordination
Debris removal from the Paci;ic Palisades and Malibu burn areas had direct recovery implications for the City. The hazardous debris removal phase, led by the U.S. Environmental Protection Agency (EPA), required transportation along key City corridors. The City declined requests to locate hazardous debris staging sites within City limits due to concerns regarding proximity to beaches, residences, and businesses, while maintaining close coordination with Federal and State partners.

Transportation of hazardous and non-hazardous ;ire debris did occur through the City on PCH and Interstate 10. Throughout the debris removal process, U.S. Army Corps of Engineers representatives provided safety brie;ings and maintained liaison support with the City to address community concerns. Hazardous debris removal was substantially completed by February 2025, limiting prolonged environmental risk.

Transportation Impacts and Economic Effects
Transportation disruptions represented one of the most signi;icant indirect impacts to the City’s recovery. Although PCH reopened within the City by late February 2025, the continued closure of the corridor between the City of Santa Monica and Malibu until May 23, 2025, constrained coastal access, commuter travel, and tourism activity. These conditions resulted in a nearly $1 million reduction in coastal parking revenue compared to the previous year and signi;icantly increased commute times for employees, students, and visitors traveling between the City of Santa Monica and the San Fernando Valley.

Business Recovery and Community Support
The City prioritized outreach to businesses impacted by evacuation zones, access restrictions, and public uncertainty related to post-;ire environmental conditions. The City’s EOC Liaison Of;icer maintained regular communication with business organizations, improvement districts, and stakeholders to identify concerns and recovery needs.

The City coordinated with FEMA and the U.S. Small Business Administration (SBA) to support local business recovery. FEMA personnel conducted in-person canvassing of City businesses to share information on ;inancial assistance, and the City hosted a community recovery forum on January 28, 2025, to connect businesses with recovery resources and public health guidance. In January 2025, the Santa Monica Chamber of Commerce partnered with the SBA to open a Business Recovery Center to allow local businesses a space to meet with SBA specialists to apply for disaster loans and obtain recovery guidance. In April 2025,

11.A.a
Packet Pg. 1117 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 38 the City facilitated the relocation of the SBA Business Recovery Center into the Santa Monica Main Library.

School Relocation and Community Services
The wild;ire displaced multiple schools in the Paci;ic Palisades, prompting the City to support educational continuity through emergency land-use ;lexibility. Under an Emergency Order and a coordinated multi-departmental effort led by Community Development, ;ive displaced schools relocated to the City by April 2025. The largest relocation involved Palisades Charter High School, which temporarily relocated more than 2,400 students to a former retail facility in downtown Santa Monica.

City departments collaborated extensively to address life safety, transportation, parking, and emergency planning considerations associated with non-traditional school sites. These efforts enabled students to return to in-person learning while also activating vacant commercial space and supporting downtown economic activity.

FEMA Public Assistance and Financial Recovery
Santa Monica OEM led the City’s efforts to document eligible response and recovery costs and pursue FEMA Public Assistance reimbursement. Departments used standardized EOC timekeeping and accounting codes to track labor, contracts, and materials. OEM coordinated closely with Finance and Public Works to assemble required documentation, inspection reports, and proof of payment.

Drawing on prior FEMA reimbursement experience, City staff proactively collected documentation and responded promptly to requests, positioning the City to ef;iciently pursue reimbursement and mitigate long-term ;iscal impacts associated with the Palisades Fire. The following chart identi;ies public assistance projects that the City submitted for FEMA reimbursement and the total that was reimbursed by FEMA following the Palisades Fire.

FEMA Public Assistance Projects
Public Assistance
Project Description Amount Invoiced
Best Available
Reimbursement
Total Amount
Obligated

EOC/ICP
Supply/Resource
Costs
Supply and
Equipment costs for
Emergency
Operations Center
and Incident
Command Post
$72,562.05 $72,562.05 $72,562.05
Wildfire Response
Activities: FD, PD,
DOT, OEM staff
labor costs
City staff overtime
costs to conduct
evacuation order,
curfew order, and
$1,121,904.60 $1,121,904.60 $1,121,904.60

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Packet Pg. 1118 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 39 wildfire monitoring
activities.

Debris RemovalContract Services
Contracted labor
costs for time spent
clearing large
trees/branches due
to wind event
$202,576.60 $151,932.00 $151,932.00
Debris RemovalCity Staff time
Staff labor costs
spent on clearing
citywide debris due
to wind event
$97,200.80 $72,900.60 $72,900.60
PCH/Bluffs Debris
Removal-City Staff
time
Staff labor costs to
pick up vegetation
cleared by CAL FIRE
from PCH coastal
bluffs for fire
mitigation
$24,177.98 $18,133.49 $18,133.49
Memorial Park
Fence Repair
Repairs of damaged
fencing at baseball
field caused by
downed tree
$59,080.00 $44,310.00 $44,310.00
Total $1,577,502.03 $1,481,742.74 $1,481,742.74
Graphic 7: Information regarding FEMA Public Assistance Project reimbursements provided by the City of Santa Monica
Observations and Recommendations
This AAR analysis is based on structured interviews with City of Santa Monica executive leadership, EOC participants, command staff from the SMFD and SMPD, OEM, Public Works, and elected of;icials. Interview data were supplemented by a review of incident-related operational documentation and publicly available information. The scope of this analysis is limited to actions, coordination, and resource utilization within the City of Santa Monica’s jurisdiction and authority during the 2025 Palisades Fire and does not evaluate the decisionmaking processes, operational performance, or infrastructure capabilities of external agencies beyond those directly supporting City operations.

Observations
Observation 1: SEMS/NIMS Compliance
California Code of Regulations Title 19, § 2401 establishes the Standardized Emergency Management System (SEMS) based upon the Incident Command System (ICS). ICS was originally developed by the Fire;ighting Resources of California Organized for Potential Emergencies (FIRESCOPE) program. SEMS is intended to standardize responses to emergencies and disasters. Beginning December 1, 1996, the California Emergency Services

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Packet Pg. 1119 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 40 Act required all local government agencies to utilize SEMS in order to be eligible for reimbursement of response-related costs under the State’s disaster assistance programs.

SEMS Organizational Levels and Functions, § 2403 mandates the utilization of SEMS when the following occur:
• When a local emergency, as de;ined in § 8558(c), is declared or proclaimed. • When a local government EOC is activated, communications and coordination shall be established between the Incident Commander(s) and the department operations center(s) to the EOC or between the Incident Commander(s) and the EOC.

Coordination of ;ire and law enforcement resources shall be accomplished through their respective mutual aid systems.
• Communications and coordination shall be established between a local government EOC, when activated, and any state or local emergency response agency having jurisdiction at an incident occurring within that local government's boundaries. • Local government shall use multi-agency or inter-agency coordination to facilitate decisions for overall local government level emergency response activities.

SEMS is the cornerstone of California’s emergency response system and provides the fundamental structure for the response phase of emergency management. The system combines all elements of emergency management into a single integrated system with standardized elements. The key elements of SEMS include:
• Incident Command System (ICS): ICS is a ;ield-level emergency response system based upon management by objectives.
• Multi/Inter-agency coordination: Impacted agencies working together to coordinate resources and emergency response activities.
• Mutual Aid: A system for obtaining additional resources from non-impacted jurisdictions.

City of Santa Monica Plans
To meet the State and Federal response requirements the City of Santa Monia has adopted multiple plans outlining public safety priorities, response operations, and recovery priorities following a disaster. These plans include:
• Emergency Management Program Gap Analysis Plan, February 2023 • City of Santa Monica Local Hazard Mitigation Plan 2025-2030 (Awaiting Cal OES approval)
• SEMS/NIMS Multi Hazard Functional Emergency Plan, Dated 2013 • Crisis Communications Plan, Revised May 2019
• Alert and Warning Policy and Procedures, Dated January 6, 2025 • Traf;ic Services Functional Brush Fire Evacuation Plan, Approved September 22, 2021

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Packet Pg. 1120 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 41 Due to the ;luid nature of an emergency response, these plans establish priorities for disaster response and recovery. They outline the roles and responsibilities required for establishing and running an EOC leading up to, during, and throughout the recovery phase of an emergency. These plans provide the general strategies allowing for the implementation of SEMS, therefore meeting the State requirement for remaining eligible for response related costs under the State’s disaster assistance programs. In 2023 a thorough assessment was completed evaluating the City’s Emergency Management Department.

The City’s decision to activate the EOC early in the incident supported effective multidepartment coordination and resource management. The EOC functioned as intended under both the SEMS and the National Emergency Management System (NIMS) speci;ically in the areas of coordination, policy support, and information sharing. Prior EOC experience including the COVID-19 pandemic, civil unrest, and planned community events as well as recurring position training for EOC participants signi;icantly enhanced operational performance within the EOC.

Observation #2: Fire Service and Regional Incident Integration SMFD demonstrated forward-leaning emergency preparedness and situational awareness through proactively upstaf;ing the department based upon the NWS Red Flag and PDS advisories, rapid strike team deployment, and the decision to form an in-city task force to patrol the City’s northernmost boundary and prevent potential ;ire spread into the community. Additionally, embedding SMFD command staff into the ICP ensured real-time intelligence ;low and advocacy for City interests.

Observation #3: Law Enforcement Operations
SMPD effectively balanced evacuation zone security, traf;ic management, and routine service delivery by establishing a tactical alert, activating the mutual aid system, and participating with the implementation and enforcement of the City’s curfew order. The curfew order proved to be a critical force multiplier for public safety by signi;icantly reducing unauthorized access and criminal activity in the evacuation zones.

Observation #4: Public Information
The City’s Communications Team prioritized message accuracy, accessibility, and bilingual outreach consistent with FEMA crisis communications philosophy. Multiple communication platforms, including SMAlerts, WEA, social media, the City of Santa Monica website, 311, City digital kiosks, and direct outreach to vulnerable populations, were effectively utilized. During the Palisades Fire, the Communications Team successfully corrected misinformation, including a WEA broadcast advising City residents to boil their water and a false report that the ;ire was burning within the City’s jurisdiction.

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Packet Pg. 1121 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 42 Observation #5: Public Works
The Public Works Department, including the Water Resources Division, provided critical risk mitigation by conducting large-scale debris removal, protecting pressure zones, maintaining water reservoir levels, and communicating water system limitations to ;ire personnel. These actions reduced secondary ignition risk potential and supported the safe repopulation of evacuation zones.

Observation #6: Governance, Policy, and Organizational Resilience According to the City’s website, “the City Manager’s Office leads the team of City departments and staff to implement the City Council’s vision based on their established community-wide priorities and direction.” The City Manager’s Office (CMO) includes the City Manager (CM), Assistant City Manager (ACM), and the Deputy City Manager (DCM). On January 7, 2025, at the onset of the Palisades Fire the CM and ACM were both out of the country placing the DCM into the Acting City Manager leadership role. The absence of both the CM and ACM at the onset of the incident created a governance gap. This gap resulted in an increased demand for OEM leadership and department heads to manage both the emergency response and elected of;icial expectations, potentially leading to delays and confusion.

Observation #7: Reinstate Elected OfGicial Training and Integration A common concern among elected of;icials was the lack of training in emergency operations, their role during an emergency, and crisis communications and information release protocols. At the time of the Palisades Fire, four of the seven members of the Santa Monica City Council had been in their positions for less than one month, and all expressed that they had received no exposure to the EOC during the new-member onboarding process. Several members of the City Council, including both recently elected and longer-tenured members, advised that they did not even know where the EOC was located.

During the Palisades Fire, City Council members sought real-time operational information without fully understanding the veri;ication and approval process, and on at least one occasion, an elected of;icial released unvetted information regarding a potential ;ire within Santa Monica City limits that later had to be corrected by the Communications Team.

Observation #8: Interagency Communications and Coordination Interviews with current and former SMPD management personnel indicated that there were minor radio communication interoperability issues between SMPD and mutual aid law enforcement units, but those were quickly overcome. A lack of communication occurred when a stretch of PCH was reopened without notifying Caltrans personnel who were

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Packet Pg. 1122 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 43 operating in the area. This lack of noti;ication could have led to serious injury, but fortunately for all involved, Caltrans personnel maintained good situational awareness and there were no injuries.

Observation #9: CAL FIRE, Fire Hazard Severity Zone Maps Prior to the Palisades Fire, CAL FIRE issued Fire Hazard Severity Zone (FHSZ) Maps that identi;ied Very High FHSZ areas immediately abutting the northernmost boundary of the City of Santa Monica but showed no zones within the City limits. When the State reassessed this area following the Palisades Fire and issued updated FHSZ maps in March 2025, they identi;ied areas within the City limits now rated as moderate, high, and very high.

Recommendations
Depending on resources, City can address next steps. As the City focuses on realignment, budget and technology, these areas would be recommended to revisit going forward.

1. Public Information, Communications, and Elected OfSicial Coordination

1.1 Review and Update the Crisis Communications Plan
Review and update the City’s Crisis Communications Plan (last updated in 2019) to re;lect current platforms, WEA usage, Everbridge con;iguration, bilingual messaging requirements, social media monitoring, and misinformation management during regional incidents.

1.2 Establish a Formal Elected Officials Communications Protocol Develop a written protocol de;ining what information is shared with the Mayor and City Council, when it is shared, and through what mechanism to include pre-release brie;ings, incident summaries, or situation reports. This protocol should clearly distinguish between situational awareness and public release authority.

1.3 Create a Dedicated Elected Officials Liaison Function During EOC activations, designate a single senior-level liaison responsible for managing Mayor and Council information requests, coordinating messaging expectations, and preventing operational distractions to the PIO and OEM teams.

1.4 Provide Mandatory Crisis Communications Training for Elected Officials Incorporate emergency communications, misinformation risks, and social media considerations into Council onboarding and annual refresher training, including expectations for social media posting during emergencies.

1.5 Expand Emergency Communications Staffing Capacity
Evaluate options to augment the communications function during prolonged or high-tempo incidents, including pre-quali;ied contract support, mutual aid PIO agreements, or an additional dedicated emergency communications position within OEM.

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Packet Pg. 1123 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 44 1.6 Enhance Technology and Visualization Tools for Public Messaging Expand GIS, mapping, and dashboard capabilities to support evacuation zone clarity, traf;ic impacts, and situational updates. Ensure the City website can sustain high traf;ic volumes during emergencies without degradation.

1.7 Provide Additional Training to All Communications Team Members Provide updated training through a third-party provider potentially California Specialized Training Institute (CSTI) or Texas A&M Engineering Extension Services (TEEX) to include updated material on JIC roles, structure, and delegation.

1.8 Conduct Joint Training for OEM, PIOs, and Policy Group Implement joint training and exercises focused on emergency communications, JIC operations, evacuation decision making, and elected of;icial engagement.

2. Emergency Operations Center (EOC) Governance and StafSing

2.1 Strengthen Policy Group and Executive Leadership Training Provide targeted EOC and Policy Group training for the City Manager, Assistant City Manager, Deputy City Manager and Department Directors to clarify decision-making roles, authorities, and expectations during emergencies.

2.2 Ensure Executive Continuity and Succession Planning Establish clear succession protocols to avoid simultaneous out-of-country absences of the City Manager and Assistant City Manager and document delegation of authority.

2.3 Expand and Formalize EOC Staffing Depth
Continue building two-deep or three-deep staf;ing for all EOC positions and formalize succession planning across OEM, Fire, Police, Public Works, and Logistics functions.

2.4 Integrate Key Support Functions into the EOC
Formalize procedures for embedding IT, GIS, and transportation systems specialists into the EOC during complex incidents to improve situational awareness and operational coordination.

3. Emergency Management Program Development

3.1 Supplement and Stabilize OEM Staffing Levels
Consider expanding staf;ing within the Santa Monica OEM, including maintaining competitive compensation, to reduce single-point-of-failure risk during preparedness and mitigation operations as identi;ied in the 2023 Emergency Management Program Gap Analysis.

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Packet Pg. 1124 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 45 3.2 Clarify OEM Authority and Interdepartmental Coordination Document OEM’s coordinating authority across departments, particularly following its transition to the Police Department, to ensure consistent expectations during multi-agency incidents.

3.3 Finalize City Evacuation Zones
Continue to revise and update evacuation zones to align with natural boundaries and existing neighborhoods and CAL FIRE, Fire Hazard Severity Zones. Verify that new evacuation zones are included in the Genasys Protect system.

4. Fire Department Operations and Interagency Coordination

4.1 Develop a Formal Red Flag and Extreme Weather Staffing Policy Establish written criteria for proactive upstaf;ing, recall tiers, and resource back;ill for winddriven wild;ire threats.

4.2 Formalize Dispatch and Call-Triage Modifications
Create policy guidance allowing for temporary dispatch protocol changes during extreme conditions (e.g., prioritization of con;irmed ;ires over odor or wire arcing calls).

4.3 Improve Communications Interoperability and Radio Clarity Update radio identi;iers and interoperability protocols to reduce confusion when working with outside agencies and strike teams.

4.4 Strengthen Succession and Delegation Planning
Ensure quali;ied, credentialed personnel are identi;ied and trained to assume key command and liaison roles during extended incidents.

5. Police Department Operations and Security

5.1 Develop Weather-Based and Pre-Incident Upstaffing Guidance Establish policy for proactive SMPD staf;ing adjustments during forecasted Red Flag or evacuation scenarios.

5.2 Formalize Curfew Decision-Making and Implementation Policy Create a written policy outlining criteria, legal considerations, coordination requirements, and communication strategies for curfews during evacuations.

5.3 Enhance Officer Health and Safety Monitoring
Implement baseline and post-incident health assessments for of;icers exposed to smoke and airborne hazards and evaluate issuance of appropriate ;ire-resistant PPE.

5.4 Improve Interagency Communications for Mutual Aid
Standardize procedures for radio access, equipment issuance, and brie;ing of mutual aid partners upon arrival.

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Packet Pg. 1125 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 46 5.5 Review and Update Traffic Service Plan
The Traf;ic Services Functional Brush Fire Evacuation Plan should be updated based on lessons learned from the Palisades Fire. This plan received Departmental approval in 2021.

6. Evacuation Planning and TrafSic Management

6.1 Develop a Comprehensive Evacuation Annex
Create a detailed evacuation plan addressing triggers, zones, warnings vs. orders, law enforcement roles, ;ire input, public messaging, and repopulation coordination.

6.2 Enhance Traffic Modeling and Signal Control Capabilities Expand pre-incident traf;ic modeling for wild;ire evacuations, including freeway closures, arterial choke points, and transit rerouting.

6.3 Embed Transportation and Caltrans Coordination in the EOC Formalize Caltrans and CHP liaison participation during incidents impacting State highways and freeways.

7. Public Works, Utilities, and Field Safety

7.1 Formalize Water System Readiness Procedures
Document reservoir ;illing strategies, hydrant ;low limitations, and coordination protocols with Fire Department during Red Flag events.

7.2 Improve PPE Availability for Field Crews
Ensure adequate respiratory and eye protection is available for Public Works and utility personnel operating in smoke and debris environments.

7.3 Expand Mutual Aid and Contracting Triggers
Clarify thresholds for requesting Public Works mutual aid or activating pre-existing debris removal and tree maintenance contracts.

7.4 PCH Bluff and I-10 Freeway Slope Mitigation
Continue to monitor the PCH bluff and I-10 freeway slopes for growth and debris removal.

8. Training, Exercises, and Community Preparedness

8.1 Provide Annual EOC Tours and Orientation for City Council Institutionalize annual EOC walkthroughs and role brie;ings for elected of;icials.

8.2 Conduct Multi-Agency Wildfire Exercises
Include OEM, Fire, Police, Public Works, Communications, and elected of;icials in scenariobased exercises emphasizing evacuations, curfews, and regional coordination.

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Packet Pg. 1126 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 47 8.3 Enhance Public Preparedness Outreach
Reinforce community education efforts (e.g., evacuation readiness, information sources, gokits) through regular outreach and City publications.

8.4 Promote Citywide Alerting and Information PlatformsEngage in a public campaign alerting residents and businesses to register for SMAlerts noti;ications and register for SMFD’s Community Connect.

9. Citywide Planning

9.1 Implement a Citywide Mentorship Program
Multiple department heads expressed that they lack staff who are ready to step into leadership roles. Departments should design and implement mentorship programs to train tomorrow’s leaders and ensure that institutional knowledge is not lost as current leadership transitions out of the City.

Implementations and Improvement Plan
The purpose of the Implementation and Improvement Plan for the Santa Monica Palisades Fire AAR is to translate identi;ied ;indings and recommendations into clear, actionable corrective actions that strengthen the City’s preparedness and response capabilities. The plan establishes responsibility, timelines, and performance measures to ensure lessons learned from the incident result in measurable, sustained improvements to policies, procedures, training, and interagency coordination consistent with guidance from FEMA and Cal OES.

Implementation & Improvement Plan
Recommendation Lead/Support Timeline
Key
Implementation
Actions
Performance
Metrics
Public Information, Communications, and Elected OfGicial Coordination

1.1 Update Crisis
Communications
Plan
Lead: CMO/PIO
Support: SMPD
EMD
Short-Term
Review 2019
Plan; incorporate
WEA, Everbridge,
bilingual
standards,
misinformation
protocols;
Council Adoption
Plan updated
and adopted;
annual review
cycle
established

1.2 Elected
OfGicials
Communications
Protocol
Lead: CMO
Support: SMPD
EMD, CMO/PIO,
CAO
Short-Term
Draft policy;
de;ine situational
awareness vs
release
Policy
approved;
brie;ing

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Packet Pg. 1127 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 48 authority; adopt
Policy Group SOP
cadence
documented

1.3 Dedicated
Elected OfGicials
Liaison
Lead: EMD
Support: CMO Short-Term
Identify liaison
and alternates;
integrate into
EOC org chart;
exercise role
Liaison
assigned
within 24 hrs.
of EOC
activation

1.4 Crisis
Communications
Training for
Council
Lead: CMO
Support:

CMO/PIO, SMPD
EMD
Mid-Term
Develop module;
deliver
onboarding and
annual
refreshers
100% Council
participation
annually

1.5 Expand
Communications
StafGing Capacity
Lead: PIO
Support: HR,
EMD
Mid-Term
Evaluate staf;ing
models; establish
contracts/mutual
aid; budget
review
Surge support
available
withing 48
hours

1.6 Enhance GIS &
Visualization
Tools
Lead: ISD
Support: EMD,
SMFD, SMPD
Mid-Term
Develop
evacuation maps,
dashboards, web
scaling
improvements
GIS products
available
within EOC
;irst
operational
period

1.7 JIC &
Communications
Training
Lead: EMD
Support: PIO Mid-Term
Enroll staff in
CSTI/TEEX;
Conduct JIC
tabletop exercise
> 80% of
Comms Team
trained

1.8 Joint
EMD/PIO/Policy
Training
Lead: EMD Mid-Term
Conduct joint
exercises and
workshops
Annual joint
training
completed
Emergency Operations Center (EOC) Governances and StafGing

2.1 Policy Group
& Executive
Training
Lead: EMD
Support: CMO Short-Term
Deliver
executive-level
EOC Policy Group
training
Executives
trained within
6 months

2.2 Executive
Continuity &
Succession
Lead: CMO
Support: EMD Short-Term
Draft succession
policy; de;ine
delegations;
adopt
administratively
Succession
plan adopted

2.3 Expand EOC
StafGing Depth
Lead: EMD
Support; All
Depts.

Mid-Term
Identify
alternates; crosstrain; update
EOC roster
Two-deep
staf;ing for all
EOC roles

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Packet Pg. 1128 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 49 2.4 Integrate IT,
GIS,
Transportation
in EOC
Lead: EMD
Support: ISD,
PW, SMPD
Mid-Term
De;ine trigger
criteria; update
EOC SOPs
Specialists
embedded
within ;irst 12
hours
Emergency Management Program Development

3.1 Supplement
& Stabilize EMD
StafGing
Lead: SMPD
Support: HR Mid-Term
Fill vacancies;
review
compensation;
succession
planning
No singlepoint-offailure
positions

3.2 Clarify EMD
Authority
Lead: EMD
Support: CAO Short-Term Update Plans/SOPs
EMD authority
documented
and
disseminated

3.3 Finalize
Evacuation Zones
Lead: EMD
Support: SMFD,
ISD
Short-Term
Align zones with
FHSZ and major
streets; upload
into Genasys
Protect
Zones
validated and
live in system
Fire Department Operations and Interagency Coordination

4.1 Red Flag
StafGing Policy Lead: SMFD Short-Term Draft upstaf;ing and recall tiers Policy adopted

4.2 Dispatch &
Call-Triage Policy
Lead: SMFD
Support: EMD Mid-Term
Update triage
SOPs; supervisor
training
Reduced nonpriority call
backlog

4.3 Radio
Interoperability
Lead SMFD
Support: ISD Mid-Term
Update
identi;iers;
conduct training
and drills
Interop issues
reduced in
exercises

4.4 Succession &
Delegation
Planning
Lead: SMFD Mid-Term
Identify
alternates;
credentialling
Command
continuity
maintained
Police Department Operations and Security

5.1 WeatherBased UpstafGing Lead: SMPD Short-Term Draft Red Flag Staf;ing Triggers Policy Adopted

5.2 Curfew Policy
Lead: SMPD
Support: CMO,
CAO EMD
Short-Term
Develop criteria,
messaging
framework
Policy
Approved

5.3 OfGicer Health
& Safety
Lead: SMPD
Support: HR,
Safety
Mid-Term
Health
assessments;
PPE evaluation
PPE issued;
health tracking
in place

5.4 Mutual Aid
Communications Lead: SMPD Mid-Term
Standardize
radio & brie;ing
protocols
Reduced
onboarding
time for

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Packet Pg. 1129 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 50 mutual aid
resources

5.5 Update
TrafGic Services
Plan
Lead: SMPD
Support: PW,
EMD
Short-Term
Revise 2021
plan; adopt
updates
Plan updated
and exercised
Evacuation Planning and TrafGic Management

6.1 Evacuation
Annex
Lead: EMD
Support: SMPD Mid-Term
Draft annex;
integrate into
existing plans
Annex adopted

6.2 TrafGic
Modeling &
Signals
Lead: PW
Support: ISD,
SMPD
Long-Term
Enhance
modeling tools;
signal plans
Modeling used
in exercises

6.3 Caltrans &
CHP Liaisons Lead: EMD Short-Term Formalize liaison roles Liaisons
embedded
when
triggered
Public Works, Utilities, and Field Safety

7.1 Water System
Readiness Lead: PW/Water Short-Term Document Red Flag procedures SOP adopted

7.2 PPE for Field
Crews
Lead: PW
Support: Safety Mid-Term Procure PPE; Train staff
PPE
availability
tracked

7.3 Mutual Aid &
Contract Triggers Lead: PW Mid-Term
De;ine
thresholds;
update contracts
Faster
activation
times

7.4 PCH & I-10
Slope Monitoring Lead: PW Ongoing
Continue
inspections &
debris removal
Ongoing
hazard
mitigation
Training, Exercises, and Community Preparedness

8.1 Annual
Council EOC
Orientation
Lead: EMD
Support: CMO Annual Conduct tours and brie;ings
100% Council
participation

8.2 Multi-Agency
WildGire
Exercises
Lead: EMD Annual
Full-scale or
functional
exercise
Corrective
actions
tracked

8.3 Public
Preparedness
Outreach
Lead: EMD
Support: PIO,
ISD
Ongoing
Community
campaigns;
publications
Increased
engagement
metrics

8.4 Alerting
Platform
Promotion
Lead: SMPD
EMD
Support:

CMO PIO
Ongoing
SMAlerts &
Community
Connect
campaign
Registrations
increased
annually
Citywide Planning

11.A.a
Packet Pg. 1130 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 51 9.1 Citywide
Mentorship
Program
Lead: HR
Support: All
Departments
Long-Term
Develop
program; assign
mentors
Leadership
bench strength
increased
Note: Following the transition of Santa Monica OEM from the City Manager’s Of;ice to the Police Department, OEM was renamed as the Emergency Management Division (EMD).

OEM was used throughout the AAR due to its role in the Palisades Fire.

Timelines are expressed as:

Short-Term: 0-6 months
Mid-Term: 6-12 months
Long-Term: 12-24 months
Conclusion
The City of Santa Monica’s response to the January 2025 Palisades Fire demonstrated a proactive, coordinated, and effective approach to managing a complex, fast-moving regional disaster that posed a direct and credible threat to the community. Early activation of the EOC, strong interdepartmental collaboration, and sustained engagement with regional, State, and Federal partners enabled the City to maintain situational awareness, protect public safety, and support large-scale evacuation, law enforcement, ;ire suppression, and recovery operations under extreme conditions. Although the ;ire did not ultimately enter City limits, the City’s actions re;lected sound, risk-based decision making and a commitment to preparedness rather than reactive response.

This AAR identi;ies meaningful strengths across operations, communications, and coordination while also highlighting targeted opportunities for improvement related to governance, staf;ing continuity, communications structure, evacuation policy re;inement, and surge capacity. Addressing these areas through the recommendations outlined in this report will further enhance the City’s readiness, resilience, and ability to operate effectively during future large-scale emergencies. Collectively, the lessons learned from the Palisades Fire reinforce that continued investment in planning, training, and organizational alignment will strengthen the City’s capacity to protect its residents, infrastructure, and continuity of government in an increasingly complex hazard environment. It should be acknowledged that due to than a one-year separation between the Palisades Fire and the completion of this report some recommendations contained within this report have previously been commenced or completed by city staff.

JGA was honored to partner with the City of Santa Monica in its ongoing efforts to strengthen organizational resilience, enhance community preparedness, and advance continuous improvement.

11.A.a
Packet Pg. 1131 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 52 Appendix 1: Acronym List
AAR: After-Action Review
AARR: After-Action Review Report
AQI: Air Quality Index
CAL FIRE California Department of Forestry and Fire Protection Cal OES: California Governor’s Of;ice of Emergency Services Caltrans: California Department of Transportation
CHP: California Highway Patrol
CSTI: California Specialized Training Institute
EOC: Emergency Operations Center
EPA: United States Environmental Protection Agency
FIRESCOPE: Fire;ighting Resources of Southern California Organized for Potential Emergencies
FEMA: Federal Emergency Management Agency
FHSZ: Fire Hazard Severity Zone
GACC: Geographic Area Coordination Centers
HSEEP: Homeland Security Exercise and Evaluation Program ICS: Incident Command System
ICP: Incident Command Post
IMT: Incident Management Team
IP: Implementation Plan
JIC: Joint Information Center
LACoFD Los Angeles County Fire Department
LAFD: Los Angeles Fire Department
LAPD: Los Angeles Police Department
NOAA: National Oceanic and Atmospheric Administration

11.A.a
Packet Pg. 1132 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 53 NFPA: National Fire Protection Association
NIMS: National Incident Management System
NWS: National Weather Service
OEM: Of;ice of Emergency Management
PCH: Paci;ic Coast Highway
PDS: Particularly Dangerous Situation
PPE: Personal Protective Equipment
PIO: Public Information Of;icer
PSPS: Public Safety Power Shutoff
SBA: Small Business Administration
SCAQMD: South Coast Air Management District
SEMS: Standardized Emergency Management System
TEEX: Texas A & M Engineering Extension Service
WEA: Wireless Emergency Alert
WUI: Wildland Urban Interface

11.A.a
Packet Pg. 1133 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm Palisades Fire After-Action Report-For Official Use Only 54 Appendix 2: Data Sources
Publicly Available Data Sources: • City of Santa Monica Data • Watch Duty • National Weather Service o Forecasts o Weather Data • Genasys Protect o Evacuation Zones • CAL FIRE o Incident Status Updates o Maps o Fire Hazard Severity Zones • Social Media Posts • Community-generated content

11.A.a
Packet Pg. 1134 Attachment: Attachment A_City of Santa Monica After-Action Report_Palisades Fire Windstorm (7798 : 2025 Palisades Fire and Windstorm City Council
Report
City Council Meeting: January 28, 2025
Agenda Item: 16.M
1 of 1
To: Mayor and City Council
From: Nikima Newsome, City Clerk, Records and Election Services Department Subject: Request of Councilmember Hall and Mayor Pro Tempore Torosis, that, in order to accurately capture lessons learned during the City’s response to the Palisades Fire and to better prepare for the next natural disaster or emergency crisis, the Council direct the City Manager, City Attorney, and City Clerk’s Offices to conduct an After Action Review across all City Departments and to return to Council no later than 12 months from now with a public report, improvement action items, and implementation plan.

Prepared By: Nikima Newsome, City Clerk
Approved Forwarded to Council
Attachments:

A. 20250128 16 Item - After Action Review of City Response to Palisades Fire - Hall Torosis

16.M
Packet Pg. 1699

11.A.b
Packet Pg. 1135 Attachment: Attachment B_SR 01-28-2025 16M_Palisades Fire After Action Review Direction (7798 : 2025 Palisades Fire and Windstorm After- Meeting: January 28, 2024
1 16 ITEM BY COUNCILMEMBER DAN HALL AND MAYOR PRO TEMPORE 2 CAROLINE TOROSIS
3 Request of Councilmember Hall and Mayor Pro Tempore Torosis, that, in order to 4 accurately capture lessons learned during the City’ s response to the Palisades 5 Fire and to better prepare for the next natural disaster or emergency crisis, the 6 Council direct the City Manager, City Attorney, and City Clerk’ s Offices to 7 conduct an After Action Review across all City Departments and to return to 8 Council no later than 12 months from now with a public report, improvement 9 action items, and implementation plan.
10 After Action Reviews ( AAR) are a critical tool used by organizations to assess an 11 organization’ s performance during an event, capture lessons learned, determine 12 improvements to be made, and strategize over improvement implementation. 13 Following the destructive riots and looting of May 31, 2020, Council directed the 14 City to conduct a thorough AAR involving an independent, third party consultant, 15 community members, City staff, and City advisory bodies and commissions. This direction 16 resulted in a 121 page report from the OIR Group that outlined 44 recommendations for 17 the City to improve. The City has since implemented 38 of those recommendations and 18 have improved our operations.
19 We are eternally grateful for the preparedness and actions of our Santa Monica 20 Fire Department, Santa Monica Police Department, Office of Emergency Management, 21 Public Works Department, Department of Transportation, and City Manager’ s Office - and 22 all of our City team during the Palisades Fire emergency. This item should not be 23 interpreted as an indication of Council’ s displeasure at any department or office’ s 24 response, rather as our guidance to seize this opportunity to improve as an organization. 25 As the City of Santa Monica sits at the nexus of massive urban sprawl, fault lines, 26 an ocean, mountains, and increasing risk of wildfires with a nearby suburban- rural 27 interface, we believe it is prudent for the City to use its largely successful response to the 28 Palisades Fire to prepare for future natural disasters. It is imperative to assure our entire 29 City staff, community leadership, and the general public that we are effectively capturing 30 these lessons, seeking wide community feedback, and improving where needed. 31 WE THEREFORE MOVE THAT THE COUNCIL:
32 1. Direct the City Manager, City Attorney, and City Clerk’ s Offices to effectuate a City33 wide AAR for each department and office, with an emphasis on looking at the City 34 as a whole and across departments.
35 2. Direct the City Manager to retain an independent, third party consultant to lead this 36 effort and produce a comprehensive public report.

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11.A.b
Packet Pg. 1136 Attachment: Attachment B_SR 01-28-2025 16M_Palisades Fire After Action Review Direction (7798 : 2025 Palisades Fire and Windstorm After- 16 ITEM BY COUNCILMEMBER DAN HALL AND MAYOR PRO TEMPORE CAROLINE

TOROSIS
Palisades Fire After Action Review

Page 2 of 2 ends

Santa Monica City CouncilSeptember 22, 2026

Santa Monica City Council
September 22, 2026