South El Monte City Council
April 15, 2025

2222 Rosemead Boulevard Warehouse Development Section 4.0 Initial Study and Mitigated Negative Declaration Environmental Analysis 115 WORKING DRAFT–NOT FOR PUBLIC DISTRIBUTION

4.20 Wildfire
Threshold (a) If located in or near State responsibility areas or lands classified as very high fire hazard severity zones, would the Project substantially impair an adopted emergency response plan or emergency evacuation plan?
Threshold (b) If located in or near State responsibility areas or lands classified as very high fire hazard severity zones, would the project, due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose Project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire? Threshold (c) If located in or near State responsibility areas or lands classified as very high fire hazard severity zones, would the Project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
Threshold (d) If located in or near State responsibility areas or lands classified as very high fire hazard severity zones, would the Project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, postfire slope instability, or drainage changes? No Impact. The project site is in a highly urbanized area and is not classified as Very High Fire Hazard Severity Zone (VHFHSZ).49 The Project is a warehouse and retail development that would tie into existing infrastructure and would not require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines, or other utilities. The project site and surrounding vicinity are relatively flat. There are no known landslides near the site nor is the site in the path of any known or potential landslides. Therefore, the Project would result in no impact concerning wildfire.

Mitigation Program
Standard Conditions and Mitigation Measures
No standard conditions or mitigation measures are applicable. 49 CALFire. (2024). Fire Hazard Severity Zones in State Responsibility Area. Retrieved from https://osfm.fire.ca.gov/what-we-do/communitywildfire-preparedness-and-mitigation/fire-hazard-severity-zones, Accessed July 30, 2024.

Section 4
Determination
116 WORKING DRAFT–NOT FOR PUBLIC DISTRIBUTION

4.21 Mandatory Findings of Significance
Threshold (a) Does the Project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory?
Less than Significant Impact. On the basis of the foregoing analysis, the Project does not have the potential to significantly degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten or eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory. The project site is bordered by existing development in an urbanized area of the City of South El Monte. The proposed Project is consistent with the General Plan and Municipal Code. Therefore, the Project would not have a significant impact on any sensitive, rare, or endangered plant/wildlife community.

Threshold (b) Does the Project have possible environmental effects which are individually limited, but cumulatively considerable?
Less Than Significant Impact. The Project does not have impacts that are individually limited, but cumulatively considerable. Incremental impacts resulting from development and operation of the proposed Project and other cumulative projects that would be under construction include air quality, biological resources, cultural resources, geology and soils, hazards and hazardous materials, noise, and tribal cultural resources. The analysis concluded that these incremental impacts are each less than significant or can be mitigated to a less than significant level. When viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects, these impacts are not cumulatively considerable. No cumulative impacts are anticipated in connection with this or other projects. The Project complies with long-term regional air quality plans, and regional population forecasts, and is within the service capabilities of utility purveyors. No significant adverse environmental impacts have been identified. The analysis contained in this Initial Study evaluated existing conditions, potential impacts associated with Project development, and possible environmental cumulative impacts.

The Project does not have any impact on projected growth or planned projects for the City of South El Monte or neighboring jurisdictions known as of the date of this analysis.

Threshold (c) Does the Project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly? Less Than Significant Impact. There are no known substantial adverse effects on human beingsthat would be directly or indirectly caused by the proposed Project. The environmental evaluation has concluded that no significant environmental impacts would result from the Project.

Section 5
Preparers
117 WORKING DRAFT–NOT FOR PUBLIC DISTRIBUTION

5.0 PREPARERS
City of South El Monte (Lead Agency)
1415 Santa Anita Avenue
South El Monte, California 91733
Gerardo Marquez, Planning Manager
CEQA Analysis
Phil Martin & Associates
Phil Martin, Principal
Kimley-Horn and Associates, Inc.
1100 W. Town & Country Road, Suite 700
Orange, California 92868
Dana C. Privitt, AICP, Project Director
Kiana Graham, AICP, Project Manager
Danielle Millar, Technical Manager
Cassie Bretschger, Technical Manager
Ganddini Group
Giancarlo Ganddini, Traffic, Principal
Cate Howe, Air Quality, Health Risk Assessment, Greenhouse Gas, Energy Impact Analyses Katie Wilson, Noise Impact Analysis

Section 6
References
118 WORKING DRAFT–NOT FOR PUBLIC DISTRIBUTION

6.0 REFERENCES
California, State of, Department of Conservation, Earthquake Zones of Required Investigation EQ Zapp Application, Available at https://maps.conservation.ca.gov/cgs/EQZApp/app/.

California, State of, Department of Conservation. California Important Farmland Finder. Available at https://maps.conservation.ca.gov/dlrp/ciff/.

California, State of, Department of Forestry and Fire Protection, Los Angeles County Fire Severity Map, Available at https://osfm.fire.ca.gov/what-we-do/community-wildfire-preparedness-andmitigation/fire-hazard-severity-zones California, State of, Department of Toxic Substances Control. Envirostor Tool. Available at http://www.envirostor.dtsc.ca.gov/public/.

California, State of, Department of Toxic Substances Control. Hazardous Waste and Substances Site List - Site Cleanup (Cortese List). Available at: http://www.dtsc.ca.gov/SiteCleanup/Cortese_List.cfm.

California, State of, Department of Transportation. California Scenic Highway Mapping System, Available at https://dot.ca.gov/programs/design/lap-landscape-architecture-and-communitylivability/lap-liv-i-scenic-highways.

California, State of, Water Resources Control Board. Available at http://geotracker.waterboards.ca.gov/.

California, State of, Water Resources Control Board. Sustainable Groundwater Management Act (SGMA).

Available at https://www.waterboards.ca.gov/water_issues/programs/gmp/sgma.html.

CalRecycle. Solid Waste Information System (SWIS). Available at https://www2.calrecycle.ca.gov/SWFacilities/Directory.

City of South El Monte. General Plan. Available at https://www.cityofsouthelmonte.org/186/GeneralPlan.

County of Los Angeles Department of Public Works. Disaster Route Maps, City of South El Monte. Available at: https://pw.lacounty.gov/dsg/DisasterRoutes/map/South%20El%20Monte.pdf.

County of Los Angeles Department of Regional Planning, Los Angeles County Airport Land Use Commission, San Gabriel Valley Airport Layout Plan. Available at https://planning.lacounty.gov/assets/upl/project/aluc_elmonte-plan.pdf.

EEC Environmental. (2023). Soil Vapor Assessment Report, Former Pacific Drum Company (Rosemead Holding, LLC) 2200, 2212, 2218, and 2226 North Rosemead Boulevard, South El Monte, California 91733; see Appendix C.

Ganddini Group Inc. (2024). Rosemead and Rush Industrial Project Memorandum – Updated Plan Set and Transportation, Noise, and Air Quality/Greenhouse Gas/Energy Impact Studie; see Appendix A.

Ganddini Group Inc. (2023). Rosemead and Rush Industrial Project Transportation Impact Analysis; see Appendix F.

Ganddini Group Inc. (2024). Rosemead and Rush Industrial Project Air Quality, Global Climate Change, HRA, And Energy Impact Analysis; see Appendix A.

Section 6
References
119 WORKING DRAFT–NOT FOR PUBLIC DISTRIBUTION
Ganddini Group Inc. (2024). Rosemead and Rush Industrial Project Noise Impact Analysis; see Appendix E.

Haley & Aldrich, Inc. (2024) Limited Soil Remediation Work Plan Addendum for 2200-2226 N. Rosemead Boulevard, South El Monte, California; see Appendix C.

Leighton Consulting, Inc. (2023). Limited Soil Investigation Report, Rosemead Holding LLC, 2200-2226 North Rosemead Boulevard, South El Monte, California; see Appendix C.

Leighton Consulting, Inc. (2023). Limited Soil Remediation Work Plan for the Eastern Portion of 2200 North Rosemead Boulevard, South El Monte, California; see Appendix C.

Ramboll US Corporation. (2020), Phase I Environmental Site Assessment, 2212, 2218, and 2226 North Rosemead Boulevard, South El Monte; see Appendix C.

Ramboll US Corporation. (2020). Phase I Environmental Site Assessment, 2200 North Rosemead Boulevard, South El Monte; see Appendix C.

San Gabriel Valley Water Company. (2021). 2020 Urban Water Management Plan. Available at https://www.sgvwater.com/water-quality-supply/2020-urban-water-management-plan/.

Southern California Association of Governments. (2020). Adopted Final Connect SoCal 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy. Available at https://scag.ca.gov/prior-plans.

Southern California Association of Governments. (2024). Adopted Final Connect SoCal 2024–2050 Regional Transportation Plan/Sustainable Communities Strategy. Available at https://scag.ca.gov/connect-socal.

Tait & Associates, Inc. (2022). Low Impact Development Plan (LID) for Rockland Business Park at 2222 Rosemead Boulevard; see Appendix D.

Tait & Associates, Inc. (2024). Hydrology and Hydraulics Report for Rockland Business Park at 2220 2212 2218 and 2226 North Rosemead; see Appendix D.

TGR Geotechnical, Inc. (2020). Geotechnical Investigation, Proposed Industrial Building, 2200 Rosemead Blvd., South El Monte, California; see Appendix B.

United States, Federal Emergency Management Agency. FEMA. Flood Insurance Rate Map 06037C1665F. https://msc.fema.gov/portal/search.

APPENDIX A

AIR QUALITY, GLOBAL CLIMATE CHANGE, HRA, AND ENERGY IMPACT ANALYSIS

APPENDIX B

GEOTECHNICAL INVESTIGATION

APPENDIX C

HAZARDOUS MATERIALS REPORTS

APPENDIX D

HYDROLOGY STUDIES

APPENDIX E

NOISE IMPACT ANALYSIS

APPENDIX F

TRAFFIC IMPACT ASSESSMENT

2222 ROSEMEAD BOULEVARD

WAREHOUSE DEVELOPMENT PROJECT

MITIGATION MONITORING

AND REPORTING PROGRAM
Prepared for City of South El Monte
1415 Santa Anita Avenue
South El Monte, California 91733

Prepared by Kimley-Horn and Associates, Inc.
1100 W Town and Country Road, Suite 700
Orange, California 92868
Date: November 2024

2222 Rosemead Boulevard Warehouse Development Project
Mitigation Monitoring and Reporting Program
City of South El Monte 1
PURPOSE OF MITIGATION MONITORING AND REPORTING PROGRAM
The California Environmental Quality Act (CEQA) requires that all public agencies establish monitoring and/or reporting proceduresfor mitigation adopted as conditions of approval in order to mitigate or avoid significant environmental impacts. This Mitigation Monitoring and Reporting Program (MMRP) has been developed to provide a vehicle by which to monitor standard conditions (SCs) and mitigation measures (MMs) identified in the 2222 Rosemead Boulevard Warehouse Development Project (Project) Initial Study/Mitigated Negative Declaration (IS/MND). This MMRP has been prepared in conformance with Public Resources Code Section 21081.6. Specifically, Public Resources Code Section 21081.6 states:
(a)  When making findings required by paragraph (1) of subdivision (a) of Section 21081 or when adopting a mitigated negative declaration pursuant to paragraph (2) of subdivision (c) of Section 21080, the following requirements shall apply:
(1) The public agency shall adopt a reporting or monitoring program for the changes made to the project or conditions of project approval, adopted in order to mitigate or avoid significant effects on the environment. The reporting or monitoring program shall be designed to ensure compliance during project implementation. For those changes which have been required or incorporated into the project at the request of a responsible agency or a public agency having jurisdiction by law over natural resources affected by the project, that agency shall, if so requested by the lead or responsible agency, prepare and submit a proposed reporting or monitoring program.
(2) The lead agency shall specify the location and custodian of the documents or other material which constitute the record of proceedings upon which its decision is based.
(b)  A public agency shall provide that measures to mitigate or avoid significant effects on the environment are fully enforceable through permit conditions, agreements, or other measures. Conditions of project approval may be set forth in referenced documents which address required mitigation measures or incase of the adoption of a plan, policy, regulation, or other public project, by incorporating the mitigation measures into the plan, policy, regulation, or project design. (c)   Prior to the close of the public review period for a draft environmental impact report or mitigated negative declaration, a responsible agency, or a public agency having jurisdiction over natural resources affected by the project, shall either submit to the lead agency complete and detailed performance objectives for mitigation measures which would address the significant effects on the environment identified by the responsible agency or agency having jurisdiction over natural resources affected by the project, or refer the lead agency to appropriate, readily available guidelines or reference documents. Any mitigation measures submitted to a lead agency by a responsible agency or an agency having jurisdiction over natural resources affected by the projectshall be limited to measures which mitigate impactsto resources which are subject to the statutory authority of, and definitions applicable to, that agency.

Compliance or noncompliance by a responsible agency or agency having jurisdiction over natural resources affected by a project with that requirement shall not limit the authority of the responsible agency or an agency having jurisdiction over natural

2222 Rosemead Boulevard Warehouse Development Project
Mitigation Monitoring and Reporting Program
City of South El Monte 2
resources affected by a project, or the authority of the lead agency, to approve, condition, or deny projects as provided by this division or any other provision of law.

State CEQA Guidelines Section 15097 provides clarification of mitigation monitoring and reporting requirements and guidance to local lead agencies on implementing strategies. The reporting or monitoring program must be designed to ensure compliance during Project implementation. The City of South El Monte (City) is the Lead Agency for the Project and is therefore responsible for ensuring the implementation of the MMRP. The MMRP has been drafted as a fully enforceable monitoring program to meet Public Resources Code Section 21081.6 requirements.

The MMRP is comprised includes measuresto implement and monitorthe Mitigation Program. The MMRP defines the following for each MM:
 Definition of Mitigation. The MM contains the criteria for mitigation, either in the form of adherence to certain adopted regulations or identification of the steps to be taken in mitigation.  Responsible Party or Designated Representative. Unless otherwise indicated, an applicant would be the responsible party for implementing the mitigation, and the City or its designated representative is responsible for monitoring the performance and implementation of the mitigation measures. To guarantee that the mitigation will not be inadvertently overlooked, a supervising public official acting as the designated representative is the official who grants the permit or authorization called for in the performance. Where more than one official is identified, permits or authorization from all officials shall be required.  Time Frame. In each case, a time frame is provided for the performance of the mitigation or the review of evidence that mitigation hastaken place. The performance pointsselected are designed to ensure that impact‐related components of project implementation do not proceed without establishing that the mitigation is implemented or ensured. All activities are subject to the approval of all required permits from agencies with permitting authority over the specific activity.

The MM numbering system in the table corresponds with the MM numbering system in the IS/MND. The MMRP table’s last column will be used by the parties responsible for documenting when MM implementation has been completed. The ongoing documentation and monitoring of mitigation compliance will be completed by the City. The completed MMRP and supplemental documents will be kept on file at the Community Development Department, Planning Division.

2222 Rosemead Boulevard Warehouse Development Project
Initial Study and Mitigated Negative Declaration Mitigation Monitoring and Reporting Program City of South El Monte 3
2222 ROSEMEAD BOULEVARD WAREHOUSE DEVELOPMENT PROJECT

MITIGATION MONITORING AND REPORTING PROGRAM
Mitigation Measures (MMs) Implementation Timing
Monitoring/Reporting
Methods
Responsible for
Approval/ Monitoring
Verification
Date Initials
Cultural Resources
MM CUL‐1: Prior to the issuance of the first grading permit or permit for ground disturbance activities, the Applicant shall provide evidence to the City of South El Monte that a qualified archaeologist has been retained. The selection of the qualified archaeologist shall be subject to approval by the City. The archaeologist shall train project construction workers on the types of archaeological resources that could be found in site soils.

The archaeologist shall periodically monitor ground‐disturbing activities. If cultural resources are inadvertently unearthed during excavation and grading activities of any future development project, the contractor shall immediately cease all earth‐disturbing activities within a 100‐foot radius of the area of discovery (the distance shall be determined by the archaeologist) and the archaeologist shall be contacted to evaluate the significance of thefind. Work can continue beyond the find. For finds that are not significant, work may resume immediately after the find is documented and removed at the direction of the archaeologist. If a find is significant, a mitigation plan shall be developed and approved by the City of South El Monte Planning Manager and all required mitigation completed prior to ground disturbance activity continuing within the established buffer radius.

Prior to first Grading Permit
Issuance or permit for
ground disturbance activitiesDuring excavation and
grading activities
Verify Retention of aQualified Professional
If cultural resources are
unearthed, evaluatesignificance of findings
If a find is significant, a
mitigation plan is
required
CommunityDevelopmentDepartment, PlanningDivision; Building & Safety Division
QualifiedArchaeologist
Geology and Soils
MM GEO‐1: Prior to the issuance of grading permits, the City of South El Monte Building and Safety Division shall review all Project plans for grading, foundation, structural, infrastructure, and all other relevant construction permits to ensure compliance with the applicable recommendations from the Geotechnical Investigation.

Prior to Grading Permit
issuance
Verify compliance onproject plans
CommunityDevelopmentDepartment, Building
& Safety Division

2222 Rosemead Boulevard Warehouse Development Project
Initial Study and Mitigated Negative Declaration Mitigation Monitoring and Reporting Program City of South El Monte 4
Mitigation Measures (MMs) Implementation Timing
Monitoring/Reporting
Methods
Responsible for
Approval/ Monitoring
Verification
Date Initials
MM GEO‐2: Prior to the issuance of the first grading permit for ground‐disturbing activities, the Applicant shall provide evidence to the City of South El Monte Building and Safety Division that a qualified paleontologist has been retained. The selection of the qualified paleontologist shall be subject to the acceptance of the City.If paleontological resources are encountered, the contractor shall immediately cease all earth‐moving activities within a 100‐foot radius of the area of discovery. The qualified paleontologist shall be contacted to evaluate the significance of the finding and determine an appropriate course of action. If avoidance of the resource(s) is not feasible, salvage operation requirements under State CEQA Guidelines Section 15064.5 shall be followed. After the find has been appropriately avoided or mitigated, work in the area may resume.

Prior to Grading Permitissuance
Verify retention of a
qualified PaleontologistIf paleontologicalresources are unearthed; evaluate
significance of findings
CommunityDevelopmentDepartment, PlanningDivision; Building &Safety Division QualifiedPaleontologist
Hazards and Hazardous Materials
MM HAZ‐1: Prior to the issuance of a grading permit, the Applicant shall submit a Soil Management Plan (or equivalent document) for approval by the Los Angeles Regional Water Quality Control Board (Los Angeles RWQCB). The Soil Management Plan (SMP) (or equivalent document) shall specify the details regarding the handling, stockpiling, sampling, and reuse or disposal of soil with concentrations of Chemicals of Potential Concern (COPC) in excess of their respective site‐specific remedial action goals (RAGs) or re‐ use criteria that were established as part of a Human Health Risk Assessment (HHRA) and integrated into the SMP. Once approved, the SMP (or equivalent document) shall be kept on site by the general contractor throughout construction and distributed to thegrading contractor and other contractors that may be trenching or boring on the site.

Prior to Grading Permit
issuance
Verify Soil ManagementPlan (or equivalent
document) has been
approved
Los Angeles RWQCB
CommunityDevelopmentDepartment, Building& Safety Division

2222 Rosemead Boulevard Warehouse Development Project
Initial Study and Mitigated Negative Declaration Mitigation Monitoring and Reporting Program City of South El Monte 5
Mitigation Measures (MMs) Implementation Timing
Monitoring/Reporting
Methods
Responsible for
Approval/ Monitoring
Verification
Date Initials
 The SMP shall Identify and implement accident prevention and control measures for soil disturbance and remediation
activities, and for ongoing operations that are protective of the health and safety of the public (i.e., vapor intrusion mitigation system [VIMS]), and construction workers including a routine inspection program to ensure that such measures are being implemented during construction. At a minimum, such
measures shall include compliance with applicable federal, State, and local laws and regulations.

MM HAZ‐2: Prior to the issuance of a grading permit by the City of South El Monte, the Applicant shall in accordance with the Soil Vapor Assessment Report (EEC Environmental, 2023), Limited Soil Remediation Work Plan (Leighton, 2023), Limited Soil Remediation Work Plan Addendum (Haley & Aldrich, 2024a), and TSCA
Application for Risk‐Based Clean‐up (Haley & Aldrich, 2024b) (included as Appendix C to the Initial Study):
 Remove the existing soil vapor extraction system (SVE) system and properly abandon the associated extraction wells in accordance with Los Angeles Regional Water Quality Control Board; and
 Perform limited shallow soil excavation in the eastern portion of the site in coordination with the Los Angeles RWQCB and U.S. EPA.

Prior to Grading Permit
issuance
Verify compliance ongrading plansVerify SVE systemremoval and associated extraction well
abandonment
Verify soil excavation
CommunityDevelopmentDepartment, Building& Safety Division Los Angeles RWQCB
Los Angeles RWQCB
and U.S. EPA
MM HAZ‐3: Prior to grading permit issuance, the Applicant shall demonstrate to the City of South El Monte Building and Safety Division implementation of the Limited Soil Remediation Work Plan for the Eastern Portion of 2200 North Rosemead Boulevard and Limited Soil Remediation Work Plan Addendum for 2200‐2226 N.

Rosemead Boulevard as approved by the Los Angeles Regional Water Quality Control Board, and the TSCA Application for Risk‐ Based Clean‐up as approved by the U.S. EPA. The Los Angeles Regional Water Quality Control Board and U.S. EPA shall provide Prior to Grading Permitissuance
Verify implementationof the Limited Soil
Remediation Work Plan
CommunityDevelopmentDepartment, Building& Safety Division Los Angeles RWQCB
and U.S. EPA

2222 Rosemead Boulevard Warehouse Development Project
Initial Study and Mitigated Negative Declaration Mitigation Monitoring and Reporting Program City of South El Monte 6
Mitigation Measures (MMs) Implementation Timing
Monitoring/Reporting
Methods
Responsible for
Approval/ Monitoring
Verification
Date Initials
oversight for the implementation of soil remediation and mitigation activities performed.

MM HAZ‐4: Prior to the issuance of a grading permit, the City of South El Monte Building and Safety Division shall review the building plans to verify that a vapor intrusion mitigation system (VIMS) is included in the Project design in accordance with the Limited Soil Remediation Work Plan Addendum for 2200‐2226 N.

Rosemead Boulevard to minimize vapor intrusion risks from VOC impacted soil and soil vapor on the project site.

A construction quality assurance program shall be developed and implemented during VIMS construction that includes a pre‐ construction meeting and routine meetings during construction of the system, observations of construction and testing activities, and pre‐occupancy (post‐construction) system inspection and performance monitoring. The construction quality assurance program shall be summarized on the final VIMS design drawings and detailed in a Construction Quality Assurance Plan (CQAP).

A VIMS Construction Completion Summary Report shall also be prepared and submitted to the Los Angeles RWQCB within 60 days of VIMS construction completion. The VIMS Construction
Completion Summary Report shall include a summary of the construction quality assurance program and VIMS installation activities, as‐built drawings, and VIMS Engineer certification that the VIMS was installed in general accordance with the design. The City of South El Monte Building and Safety Division shall have oversight/sign‐off responsibility for the vapor barrier.

Prior to Grading Permit
issuanceDuring VIMS construction
Within 60 days of VIMS
construction completion
Verify vapor intrusion
mitigation system(VIMS) is included in the
Project designVerify ConstructionQuality Assurance
Program on final VIMS
design drawing andCQAPMonitor during
constructionVerify submittal of VIMSConstructionCompletion SummaryReport CommunityDevelopmentDepartment, Building& Safety Division Building & SafetyDivisionCommunityDevelopmentDepartment, Building& Safety Division Los Angeles RWCQB
MM HAZ‐5: In accordance with Los Angeles Regional Water Quality Control Board Comment No. 6 and requirements dated August 17, 2022, prior to the issuance of the first occupancy permit, baseline indoor air sampling involving at least two rounds of sampling shall be performed to account for seasonal fluctuation of contaminants Prior to First OccupancyPermit issuance
Submit two rounds of
Air Sampling data for
approval to the Los
Angeles RWQCB
CommunityDevelopmentDepartment, Building& Safety Division

2222 Rosemead Boulevard Warehouse Development Project
Initial Study and Mitigated Negative Declaration Mitigation Monitoring and Reporting Program City of South El Monte 7
Mitigation Measures (MMs) Implementation Timing
Monitoring/Reporting
Methods
Responsible for
Approval/ Monitoring
Verification
Date Initials
in the indoor air. Air sampling results shall be submitted to and approved by the Los Angeles Regional Water Quality Control Board.

Los Angeles RWQCB
Noise
MM NOI‐1: Prior to issuance of any demolition or grading permit, the City of South El Monte Public Works Department shall verify that the Project plans and specifications include provisions that either: (1) require the installation of a 10‐foot‐high concrete masonry wall along the southern property line of the project site; or (2) prohibit truck movement and loading and unloading between the hours of 10:00 PM and 7:00 AM.

Prior to Demolition orGrading Permit issuance
Verify compliance onproject plans
CommunityDevelopment
Department, Planning
DivisionPublic Works
Department
MM NOI‐2: Prior to issuance of any demolition or grading permit, the City of South El Monte Public Works Department shall verify that the Project plans and specifications include provisions prohibiting the use of vibratory rollers, or other similar vibratory equipment, within 15 feet – or large bulldozers within 8 feet of the project site’s north, south, and east boundary.

Prior to Demolition orGrading Permit issuance
Verify compliance onproject plans
Monitor during grading
and construction
Public Works
Department
Transportation
MM TRANS‐1: Prior to the issuance of the first occupancy permit, the Applicant shall submit to the City of South El Monte Public Works Department a transportation demand management (TDM)program the purpose of which is to reduce VMT and vehicular trips to the project site and project area. The TDM program shall be implemented with the occupancy of the Project. The TDM program shall include the following strategy:
 [T‐5] Implement Commute Trip Reduction Program: Implement a voluntary commute trip reduction (CTR) program to
discourage single‐occupancy vehicle trips and encourage alternative modes of transportation such as carpooling, taking transit, walking, and biking, thereby reducing VMT and GHG Prior to First Occupancy
Permit issuance
Annually After Project
Occupancy
Verify Submittal of TDM
ProgramVerify implementationof Commute Trip
Reduction Program
Public Works
Department

2222 Rosemead Boulevard Warehouse Development Project
Initial Study and Mitigated Negative Declaration Mitigation Monitoring and Reporting Program City of South El Monte 8
Mitigation Measures (MMs) Implementation Timing
Monitoring/Reporting
Methods
Responsible for
Approval/ Monitoring
Verification
Date Initials
emissions. The voluntary CTR program must include the
following elements:
o Employer‐provided services, infrastructure, and
incentives for alternative modes such as ridesharing,
discounted transit, bicycling, vanpool, and guaranteed
ride homes.
o Information, coordination, and marketing for said
services, infrastructure, and incentives.

Tribal Cultural Resources
MM TCR‐1: Retain a Native American Monitor Prior to
Commencement of Ground‐Disturbing Activities.

A. The Applicant shall retain a Native American monitor from (or approved by) the Gabrieleño Band of Mission Indians – Kizh Nation (the “Kizh” or the “Tribe”) ‐ the direct lineal descendants of the project location. The monitor shall be retained prior to the commencement of any “ground‐
disturbing activity” for the subject project, at all project locations (i.e., both on‐site and any off‐site locations that are included in the project description/definition and/or required in connection with the project, such as public improvement work). “Ground‐disturbing activity” includes, but is not limited to, pavement removal, potholing,
auguring, grubbing, tree removal, boring, grading,
excavation, drilling, and trenching.

B. A copy of the executed monitoring agreement shall be provided to the City of South El Monte prior to the earlier of the commencement of any ground‐disturbing activity
for the project, or the issuance of any permit necessary to commence a ground‐disturbing activity.

C. The Applicant shall provide the Tribe with a minimum of 30 days advance written notice of the commencement of
any project ground‐disturbing activity so that the Tribe has Prior to ground disturbing
activitiesMonitoring during grading
Retention of an
approved Native
American Monitor;
Executed MonitoringAgreementMonitoring during
ground disturbance
activitiesPre‐Construction
Sensitivity/EducationalMeetingDaily Tribal Monitoring
Logs
CommunityDevelopmentDepartment, PlanningDivisionCommunityDevelopmentDepartment, Building& Safety Division Kizh Monitor and/or
Kizh Archaeologist

2222 Rosemead Boulevard Warehouse Development Project
Initial Study and Mitigated Negative Declaration Mitigation Monitoring and Reporting Program City of South El Monte 9
Mitigation Measures (MMs) Implementation Timing
Monitoring/Reporting
Methods
Responsible for
Approval/ Monitoring
Verification
Date Initials
sufficient time to secure and schedule a monitor for the project.

D. The Applicant shall hold at least one pre‐construction sensitivity/educational meeting prior to the
commencement of any ground‐disturbing activities, whereat a senior member of the Tribe will inform and educate the project’s construction and managerial crew and staff members (including any project subcontractors and
consultants) about the tribal cultural resources (“TCR”) mitigation measures and compliance obligations, as well as places of significance located on the project site (if any), the appearance of potential TCRs, and other informational and operational guidance to aid in the project’s
compliance with the TCR mitigation measures.

E. The monitor will complete daily monitoring logs that will provide descriptions of the relevant ground disturbing
activities, the type of construction activities performed,locations of ground‐disturbing activities, soil types, cultural‐related materials, and any other facts, conditions, materials, or discoveries of significance to the Tribe.

Monitor logs will identify and describe any discovered
TCRs, including but not limited to, Native American
cultural and historical artifacts, remains, places of
significance, etc. (collectively, tribal cultural resources, or“TCR”), as well as any discovered Native American (ancestral) human remains and burial goods. Copies of
monitor logs will be provided to the City upon written
request.

F. Native American monitoring for the project shall conclude upon the latter of the following: (1) written confirmation from a designated project point of contact to the Tribe that all ground‐disturbing activities and all phases that

2222 Rosemead Boulevard Warehouse Development Project
Initial Study and Mitigated Negative Declaration Mitigation Monitoring and Reporting Program City of South El Monte 10
Mitigation Measures (MMs) Implementation Timing
Monitoring/Reporting
Methods
Responsible for
Approval/ Monitoring
Verification
Date Initials
may involve ground‐disturbing activities on the project site and at any off‐site project location are complete; or (2) written notice by the Tribe to the Applicant and City that no future, planned construction activity and/or
development/construction phase (known by the Tribe at
that time) at the project site and at any off‐site project location possesses the potential to impact TCRs.

MM TCR‐2: Discovery of TCRs, Human Remains, and/or Grave Goods
A. Upon the discovery of a TCR, all construction activities in the immediate vicinity of the discovery (i.e., not less than the surrounding 50 feet) shall cease. The Tribe shall be immediately informed of the discovery, and a Kizh monitor and/or Kizh archaeologist will promptly report to the
location of the discovery to evaluate the TCR and advise the project manager regarding the matter, protocol, and any mitigating requirements. No project construction
activities shall resume in the surrounding 50 feet of the discovered TCR unless and until the Tribe has completed its assessment/evaluation/recovery of the discovered TCR and surveyed the surrounding area.

B. The Tribe will recover and retain all discovered TCRs in the form and/or manner the Tribe deems appropriate in its
sole discretion, and for any purpose the Tribe deems
appropriate, including but not limited to, educational, cultural and/or historic purposes.

C. If Native American human remains and/or grave goods are discovered or recognized on the project site or at any off‐ site project location, then all construction activities shall immediately cease. Native American “human remains” are
defined to include “an inhumation or cremation, and in
any state of decomposition or skeletal completeness.”
During construction, if
human remains are found
Kizh Monitor and/or
Kizh Archaeologist
assigned and on site, if
remains are found
CommunityDevelopmentDepartment, Planning
Division; Building &
Safety Division
Kizh Monitor and/or
Kizh Archaeologist

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(Public Resources Code [PRC] §5097.98 (d)(1).) Funerary objects, referred to as “associated grave goods,” shall be treated in the same manner and with the same dignity and respect as human remains. (PRC §5097.98 (a), d)(1) and
(2)).

D. Any discoveries of human skeletal material or human
remains shall be immediately reported to the County
Coroner (Health & Safety Code §7050.5(c); 14 Cal. Code
Regs. §15064.5(e)(1)(B)), and all ground‐disturbing project ground‐disturbing activities on site and in any other area where the presence of human remains and/or grave goods
are suspected to be present, shall immediately halt and remain halted until the coroner has determined the nature of the remains. (14 Cal. Code Regs. §15064.5(e).) If the coroner recognizes the human remains to be those of a
Native American or has reason to believe they are Native American, he or she shall contact, within 24 hours, the Native American Heritage Commission, and Public
Resources Code Section 5097.98 shall be followed.

E. Thereafter, construction activities may resume in other parts of the project site at a minimum of 200 feet away from discovered human remains and/or grave goods, if the Tribe determines in its sole discretion that resuming
construction activities at that distance is acceptable and provides the project manager express consent of that
determination (along with any other mitigation measures the Tribal monitor and/or archaeologist deems necessary). (14 Cal. Code Regs. §15064.5(f).)
F. Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human remains
and/or grave goods.

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G. Any historic archaeological material that is not Native American in origin (non‐TCRs) shall be curated at a public, non‐profit institution with a research interest in the
materials, such as the Natural History Museum of Los
Angeles County or the Fowler Museum, if such an
institution agrees to accept the material. If no institution accepts the archaeological material, it shall be offered to a local school or historical society in the area for educational purposes.

H. Any discovery of human remains and/or grave goods
discovered and/or recovered shall be kept confidential to prevent further disturbance.

MM TCR‐3: Procedures for Burials, Funerary Remains, and Grave Goods
A. As the Most Likely Descendant (“MLD”), the Koo‐nas‐gna Burial Policy shall be implemented for all discovered
Native American human remains and/or grave goods.

Tribal Traditions include, but are not limited to, the
preparation of the soil for burial, the burial of funerary objects and/or the deceased, and the ceremonial burning of human remains.

B. If the discovery of human remains includes four (4) or more burials, the discovery location shall be treated as a cemetery and a separate treatment plan shall be created.

C. The prepared soil and cremation soils are to be treated in the same manner as bone fragments that remain intact.Associated “grave goods” (aka, burial goods or funerary objects) are objects that, as part of the death rite or ceremony of a culture, are reasonably believed to have
been placed with individual human remains either at the time of death or later, as well as other items made
exclusively for burial purposes or to contain human
During construction, if
remains are found
Compliance with Koo‐nas‐gna Burial Policy
CommunityDevelopmentDepartment, PlanningDivision; Building &Safety Division Kizh Monitor and/or
Kizh Archaeologist

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remains. Cremations will either be removed in bulk or by means necessary to ensure complete recovery of all sacred materials.

D. In the case where discovered human remains cannot be fully recovered (and documented) on the same day, the
remains will be covered with muslin cloth and a steel plate that can be moved by heavy equipment placed over the
excavation opening to protect the remains. If this type of steel plate is not available, a 24‐hour guard should be posted outside of working hours. The Tribe will make
every effort to divert the project while keeping the
remains in situ and protected. If the project cannot be diverted, it may be determined that burials will be
removed.

E. In the event preservation in place is not possible despite good faith efforts by the Applicant and/or landowner,
before ground‐disturbing activities may resume on the
project site, the landowner shall arrange a designated site location within the footprint of the project for the
respectful reburial of the human remains and/or
ceremonial objects. The site of reburial/repatriation shall be agreed upon by the Tribe and the landowner, and shall be protected in perpetuity.

F. Each occurrence of human remains and associated grave goods will be stored using opaque cloth bags. All human remains, grave goods, funerary objects, sacred objects and objects of cultural patrimony will be removed to a secure container on site if possible. These items will be retained and shall be reburied within six months of recovery.

G. The Tribe will work closely with the project’s qualified archaeologist to ensure that the excavation is treated
carefully, ethically and respectfully. If data recovery is

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approved by the Tribe, documentation shall be prepared
and shall include (at a minimum) detailed descriptive
notes and sketches. All data recovery data recovery‐
related forms of documentation shall be approved in
advance by the Tribe. If any data recovery is performed, once complete, a final report shall be submitted to the Tribe and the NAHC. The Tribe does NOT authorize any
scientific study or the utilization of any invasive and/or destructive diagnostics on human remains.

Standard Conditions (SCs) Implementation Timing
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Biological ResourcesSC BIO‐1: Nesting Migratory Birds. During construction,grubbing, brushing, or tree removal shall be conducted outside of the state identified nesting season for migratory birds (i.e., typically March 15 through September 1), if possible. If construction activities cannot be conducted outside of nesting season, a Pre‐Construction Nesting Bird Survey within and adjacent to the project site shall be conducted by a qualified biologist within three days prior to initiating construction activities. If active nests are found during the Pre‐Construction Nesting Bird Survey, a Nesting Bird Plan (NBP) shall be prepared by a qualified biologist and implemented during construction. At a minimum, the NBP shall include guidelines for addressing active nests, establishing buffers, monitoring, and reporting. The size and location of all buffer zones, if required, shall be based on the nesting species, nesting sage, nest location, its sensitivity to disturbance, and intensity and duration of the disturbance activity.

Three days prior to first site
disturbance, if duringmigratory bird nesting
season
Verify requirementsincluded on grading and
construction plans
Verify pre‐construction
nesting bird survey
conducted and nesting
bird plan prepared, if
required
CommunityDevelopmentDepartment,Planning Division;Building & Safety DivisionQualified Biologist

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Cultural Resources
SC CUL 1: California Health and Safety Code Section 7050.5 through 7055, and Public Resources Code Sections 5097.98 and 5097.99 mandate the process to be followed in the event of an accidental discovery of any human remains in a location other than a dedicated cemetery. California Health and Safety Code Section 7050.5 requires that in the event that human remains are discovered within the project site, disturbance of the site shall be halted until the coroner has conducted an investigation into the circumstances, manner and cause of death, and the
recommendations concerning the treatment and disposition of the human remains have been made to the person responsible for the excavation, or to his or her authorized representative, in the manner provided in Section 5097.98 of the Public Resources Code.

If the coroner determines that the remains are not subject to his or her authority and if the coroner recognizes or has reason to believe the human remains to be those of a Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission.

In the event of an accidental
discovery of human remains
Verify Requirements onConstruction Plans;Verify Coroner Investigation, if required
CommunityDevelopmentDepartment,
Planning Division;Building & Safety
DivisionLos Angeles County
CoronerNative AmericanHeritage Commission,
if remains are Native
American
Noise
SC N‐1: All construction activities should be limited to the hours between the hours of 7:00 AM and 10:00 PM on weekdays, or any time on weekends or holidays per City of South El Monte Municipal Code Chapter 8.20.

During grading andconstruction
Verify requirements on
construction plansConduct Site Inspections
CommunityDevelopmentDepartment,Planning Division;Building & Safety Division
SC N‐2: The Applicant shall ensure through contract specifications that construction best management practices (BMPs) be
implemented by contractors to reduce construction noise levels.

Contract specifications shall be included in construction documents, which shall be reviewed by the City prior to issuance of Prior to Grading or Building
Permit issuance, whichever
issued first
Verify requirements on
construction plansConduct Site Inspections
CommunityDevelopmentDepartment,Planning Division;

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a grading or building permit (whichever is issued first). The construction BMPs shall include the following:
 All equipment, whether fixed or mobile, will be equipped with properly operating and maintained mufflers, consistentwith manufacturer standards.  All stationary construction equipment will be placed so that emitted noise is directed away from the noise‐sensitive receptors nearest the project site.
 As applicable, all equipment shall be shut off and not left idle when not in use.
 To the degree possible, equipment staging will be located in areas that create the greatest distance between
construction‐related noise and vibration sources and existing sensitive receptors.
 Jackhammers, pneumatic equipment, and all other portable stationary noise sources will be directed away and shielded from existing residences in the vicinity of the project site.

Either one‐inch plywood or sound blankets can be utilized for this purpose. They should reach up from the ground and block the line of sight between equipment and existing
residences. The shielding should be without holes and
cracks.
 No amplified music and/or voice will be allowed on the project site.
 Haul truck deliveries will not occur outside the hours presented as exempt for construction per City of South El Monte Municipal Code Section 8.20.030(D).

Building & Safety
Division

2222 ROSEMEAD BOULEVARD

WAREHOUSE DEVELOPMENT PROJECT

MITIGATION MONITORING

AND REPORTING PROGRAM
Prepared for City of South El Monte
1415 Santa Anita Avenue
South El Monte, California 91733
Prepared by Kimley-Horn and Associates, Inc.
1100 W Town and Country Road, Suite 700
Orange, California 92868
Date:

November 2024
revised February 2025

ATTACHMENT C

EXHIBIT B
TO RESOLUTION NO. 25-035

2222 Rosemead Boulevard Warehouse Development Project
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PURPOSE OF MITIGATION MONITORING AND REPORTING PROGRAM
The California Environmental Quality Act (CEQA) requires that all public agencies establish monitoring and/or reporting procedures for mitigation adopted as conditions of approval in order to mitigate or avoid significant environmental impacts. This Mitigation Monitoring and Reporting Program (MMRP) has been developed to provide a vehicle by which to monitor standard conditions (SCs) and mitigation measures (MMs) identified in the 2222 Rosemead Boulevard Warehouse Development Project (Project) Initial Study/Mitigated Negative Declaration (IS/MND). This MMRP has been prepared in conformance with Public Resources Code Section 21081.6. Specifically, Public Resources Code Section 21081.6 states:
(a) When making findings required by paragraph (1) of subdivision (a) of Section 21081 or when adopting a mitigated negative declaration pursuant to paragraph (2) of subdivision (c) of Section 21080, the following requirements shall apply:
(1) The public agency shall adopt a reporting or monitoring program for the changes made to the project or conditions of project approval, adopted in order to mitigate or avoid significant effects on the environment. The reporting or monitoring program shall be designed to ensure compliance during project implementation. For those changes which have been required or incorporated into the project at the request of a responsible agency or a public agency having jurisdiction by law over natural resources affected by the project, that agency shall, if so requested by the lead or responsible agency, prepare and submit a proposed reporting or monitoring program.
(2) The lead agency shall specify the location and custodian of the documents or other material which constitute the record of proceedings upon which its decision is based.
(b) A public agency shall provide that measures to mitigate or avoid significant effects on the environment are fully enforceable through permit conditions, agreements, or other measures. Conditions of project approval may be set forth in referenced documents which address required mitigation measures or incase of the adoption of a plan, policy, regulation, or other public project, by incorporating the mitigation measures into the plan, policy, regulation, or project design. (c) Prior to the close of the public review period for a draft environmental impact report or mitigated negative declaration, a responsible agency, or a public agency having jurisdiction over natural resources affected by the project, shall either submit to the lead agency complete and detailed performance objectives for mitigation measures which would address the significant effects on the environment identified by the responsible agency or agency having jurisdiction over natural resources affected by the project, or refer the lead agency to appropriate, readily available guidelines or reference documents. Any mitigation measures submitted to a lead agency by a responsible agency or an agency having jurisdiction over natural resources affected by the project shall be limited to measures which mitigate impacts to resources which are subject to the statutory authority of, and definitions applicable to, that agency.

Compliance or noncompliance by a responsible agency or agency having jurisdiction over natural resources affected by a project with that requirement shall not limit the authority of the responsible agency or an agency having jurisdiction over natural

2222 Rosemead Boulevard Warehouse Development Project
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resources affected by a project, or the authority of the lead agency, to approve, condition, or deny projects as provided by this division or any other provision of law.

State CEQA Guidelines Section 15097 provides clarification of mitigation monitoring and reporting requirements and guidance to local lead agencies on implementing strategies. The reporting or monitoring program must be designed to ensure compliance during Project implementation. The City of South El Monte (City) is the Lead Agency for the Project and is therefore responsible for ensuring the implementation of the MMRP. The MMRP has been drafted as a fully enforceable monitoring program to meet Public Resources Code Section 21081.6 requirements.

The MMRP is comprised includes measures to implement and monitor the Mitigation Program. The MMRP defines the following for each MM:
 Definition of Mitigation. The MM contains the criteria for mitigation, either in the form of adherence to certain adopted regulations or identification of the steps to be taken in mitigation.  Responsible Party or Designated Representative. Unless otherwise indicated, an applicant would be the responsible party for implementing the mitigation, and the City or its designated representative is responsible for monitoring the performance and implementation of the mitigation measures. To guarantee that the mitigation will not be inadvertently overlooked, a supervising public official acting as the designated representative is the official who grants the permit or authorization called for in the performance. Where more than one official is identified, permits or authorization from all officials shall be required.  Time Frame. In each case, a time frame is provided for the performance of the mitigation or the review of evidence that mitigation has taken place. The performance points selected are designed to ensure that impact-related components of project implementation do not proceed without establishing that the mitigation is implemented or ensured. All activities are subject to the approval of all required permits from agencies with permitting authority over the specific activity.

The MM numbering system in the table corresponds with the MM numbering system in the IS/MND. The MMRP table’s last column will be used by the parties responsible for documenting when MM implementation has been completed. The ongoing documentation and monitoring of mitigation compliance will be completed by the City. The completed MMRP and supplemental documents will be kept on file at the Community Development Department, Planning Division.

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MITIGATION MONITORING AND REPORTING PROGRAM
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Cultural Resources
MM CUL-1: Prior to the issuance of the first grading permit or permit for ground disturbance activities, the Applicant shall provide evidence to the City of South El Monte that a qualified archaeologist has been retained. The selection of the qualified archaeologist shall be subject to approval by the City. The archaeologist shall train project construction workers on the types of archaeological resources that could be found in site soils. The archaeologist shall periodically monitor ground-disturbing activities. If cultural resources are inadvertently unearthed during excavation and grading activities of any future development project, the contractor shall immediately cease all earth-disturbing activities within a 100-foot radius of the area of discovery (the distance shall be determined by the archaeologist) and the archaeologist shall be contacted to evaluate the significance of the find. Work can continue beyond the find. For finds that are not significant, work may resume immediately after the find is documented and removed at the direction of the archaeologist. If a find is significant, a mitigation plan shall be developed and approved by the City of South El Monte Planning Manager and all required mitigation completed prior to ground disturbance activity continuing within the established buffer radius.

Prior to first Grading Permit Issuance or permit for ground disturbance activities During excavation and grading activities Verify Retention of a Qualified Professional If cultural resources are unearthed, evaluate significance of findings If a find is significant, a mitigation plan is required Community Development Department, Planning Division; Building & Safety Division Qualified Archaeologist Geology and Soils
MM GEO-1: Prior to the issuance of grading permits, the City of South El Monte Building and Safety Division shall review all Project plans for grading, foundation, structural, infrastructure, and all other relevant construction permits to ensure compliance with the applicable recommendations from the Geotechnical Investigation.

Prior to Grading Permit issuance
Verify compliance on project plans
Community Development Department, Building & Safety Division

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MM GEO-2: Prior to the issuance of the first grading permit for ground-disturbing activities, the Applicant shall provide evidence to the City of South El Monte Building and Safety Division that a qualified paleontologist has been retained. The selection of the qualified paleontologist shall be subject to the acceptance of the City. If paleontological resources are encountered, the contractor shall immediately cease all earth-moving activities within a 100-foot radius of the area of discovery. The qualified paleontologist shall be contacted to evaluate the significance of the finding and determine an appropriate course of action. If avoidance of the resource(s) is not feasible, salvage operation requirements under State CEQA Guidelines Section 15064.5 shall be followed. After the find has been appropriately avoided or mitigated, work in the area may resume.

Prior to Grading Permit issuance
Verify retention of a qualified Paleontologist If paleontological resources are unearthed; evaluate significance of findings Community Development Department, Planning Division; Building & Safety Division Qualified Paleontologist Hazards and Hazardous Materials
MM HAZ-1: Prior to the issuance of a grading permit, the Applicant shall submit a Soil Management Plan (or equivalent document) for approval by the Los Angeles Regional Water Quality Control Board (Los Angeles RWQCB). The Soil Management Plan (SMP) (or equivalent document) shall specify the details regarding the handling, stockpiling, sampling, and reuse or disposal of soil with concentrations of Chemicals of Potential Concern (COPC) in excess of their respective site-specific remedial action goals (RAGs) or reuse criteria that were established as part of a Human Health Risk Assessment (HHRA) and integrated into the SMP. Once approved, the SMP (or equivalent document) shall be kept on site by the general contractor throughout construction and distributed to the grading contractor and other contractors that may be trenching or boring on the site.

Prior to Grading Permit issuance
Verify Soil Management Plan (or equivalent document) has been approved Los Angeles RWQCB Community Development Department, Building & Safety Division

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 The SMP shall Identify and implement accident prevention and control measures for soil disturbance and remediation activities, and for ongoing operations that are protective of the health and safety of the public (i.e., vapor intrusion mitigation system [VIMS]), and construction workers including a routine inspection program to ensure that such measures are being implemented during construction. At a minimum, such measures shall include compliance with applicable federal, State, and local laws and regulations.

MM HAZ-2: Prior to the issuance of a grading permit by the City of South El Monte, the Applicant shall in accordance with the Soil Vapor Assessment Report (EEC Environmental, 2023), Limited Soil Remediation Work Plan (Leighton, 2023), Limited Soil Remediation Work Plan Addendum (Haley & Aldrich, 2024a), and TSCA Application for Risk-Based Clean-up (Haley & Aldrich, 2024b) (included as Appendix C to the Initial Study):  Remove the existing soil vapor extraction system (SVE) system and properly abandon the associated extraction wells in accordance with Los Angeles Regional Water Quality Control Board; and  Perform limited shallow soil excavation in the eastern portion of the site in coordination with the Los Angeles RWQCB and U.S. EPA.

Prior to Grading Permit issuance
Verify compliance on grading plans Verify SVE system removal and associated extraction well abandonment Verify soil excavation Community Development Department, Building & Safety Division Los Angeles RWQCB Los Angeles RWQCB and U.S. EPA MM HAZ-3: Prior to grading permit issuance, the Applicant shall demonstrate to the City of South El Monte Building and Safety Division implementation of the Limited Soil Remediation Work Plan for the Eastern Portion of 2200 North Rosemead Boulevard and Limited Soil Remediation Work Plan Addendum for 2200-2226 N. Rosemead Boulevard as approved by the Los Angeles Regional Water Quality Control Board, and the TSCA Application for RiskBased Clean-up as approved by the U.S. EPA. The Los Angeles Regional Water Quality Control Board and U.S. EPA shall provide Prior to Grading Permit issuance
Verify implementation of the Limited Soil Remediation Work Plan Community Development Department, Building & Safety Division Los Angeles RWQCB and U.S. EPA

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oversight for the implementation of soil remediation and mitigation activities performed.MM HAZ-4: Prior to the issuance of a grading permit, the City of South El Monte Building and Safety Division shall review the building plans to verify that a vapor intrusion mitigation system (VIMS) is included in the Project design in accordance with the Limited Soil Remediation Work Plan Addendum for 2200-2226 N. Rosemead Boulevard to minimize vapor intrusion risks from VOC impacted soil and soil vapor on the project site. A construction quality assurance program shall be developed and implemented during VIMS construction that includes a preconstruction meeting and routine meetings during construction of the system, observations of construction and testing activities, and pre-occupancy (post-construction) system inspection and performance monitoring. The construction quality assurance program shall be summarized on the final VIMS design drawings and detailed in a Construction Quality Assurance Plan (CQAP). A VIMS Construction Completion Summary Report shall also be prepared and submitted to the Los Angeles RWQCB within 60 days of VIMS construction completion. The VIMS Construction Completion Summary Report shall include a summary of the construction quality assurance program and VIMS installation activities, as-built drawings, and VIMS Engineer certification that the VIMS was installed in general accordance with the design. The City of South El Monte Building and Safety Division shall have oversight/sign-off responsibility for the vapor barrier.

Prior to Grading Permit issuance During VIMS construction Within 60 days of VIMS construction completion Verify vapor intrusion mitigation system (VIMS) is included in the Project design Verify Construction Quality Assurance Program on final VIMS design drawing and CQAP Monitor during construction Verify submittal of VIMS Construction Completion Summary Report Community Development Department, Building & Safety Division Building & Safety Division Community Development Department, Building & Safety Division Los Angeles RWCQB MM HAZ-5: In accordance with Los Angeles Regional Water Quality Control Board Comment No. 6 and requirements dated August 17, 2022, prior to the issuance of the first occupancy permit, baseline indoor air sampling involving at least two rounds of sampling shall be performed to account for seasonal fluctuation of contaminants Prior to First Occupancy Permit issuance
Submit two rounds of Air Sampling data for approval to the Los Angeles RWQCB Community Development Department, Building & Safety Division

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in the indoor air. Air sampling results shall be submitted to and approved by the Los Angeles Regional Water Quality Control Board.

Los Angeles RWQCB
Noise
MM NOI-1: Prior to issuance of the first building permit, the City of South El Monte Public Works Department shall verify that the Project plans and specifications include provisions that either: (1) require the installation of a 10-foot-high noise attenuation wall along the southern property line of the project site; and (2) prohibit truck movement and loading and unloading between the hours of 10:00 PM and 7:00 AM. The effectiveness of the 10-foot noise attenuation wall (temporary or permanent) shall be verified to confirm it reduces noise by a minimum of 10 dBA prior to tenant occupancy of the building. If the verification confirms the attenuation wall does not achieve the required 10 dBA reduction, the wall shall be modified to ensure it achieves such reduction.

Prior to Building Permit issuance
Verify compliance on project plans
Community Development Department, Planning Division Public Works Department MM NOI-2: Prior to issuance of any demolition or grading permit, the City of South El Monte Public Works Department shall verify that the Project plans and specifications include provisions prohibiting the use of vibratory rollers, or other similar vibratory equipment, within 15 feet – or large bulldozers within 8 feet of the project site’s north, south, and east boundary.

Prior to Demolition or Grading Permit issuance
Verify compliance on project plans Monitor during grading and construction Public Works Department
Transportation
MM TRANS-1: Prior to the issuance of the first occupancy permit, the Applicant shall submit to the City of South El Monte Public Works Department a transportation demand management (TDM) program the purpose of which is to reduce VMT and vehicular trips to the project site and project area. The TDM program shall be implemented with the occupancy of the Project. The TDM program shall include the following strategy:  [T-5] Implement Commute Trip Reduction Program: Implement a voluntary commute trip reduction (CTR) program to
Prior to First Occupancy Permit issuance Annually After Project Occupancy Verify Submittal of TDM Program Verify implementation of Commute Trip Reduction Program Public Works Department

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discourage single-occupancy vehicle trips and encourage alternative modes of transportation such as carpooling, taking transit, walking, and biking, thereby reducing VMT and GHG emissions. The voluntary CTR program must include the following elements:
o Employer-provided services, infrastructure, and
incentives for alternative modes such as ridesharing, discounted transit, bicycling, vanpool, and guaranteed ride homes. o Information, coordination, and marketing for said
services, infrastructure, and incentives.

Tribal Cultural Resources
MM TCR-1: Retain a Native American Monitor Prior to Commencement of Ground-Disturbing Activities.

A. The Applicant shall retain a Native American monitor from (or approved by) the Gabrieleño Band of Mission Indians – Kizh Nation (the “Kizh” or the “Tribe”) - the direct lineal descendants of the project location. The monitor shall be retained prior to the commencement of any “grounddisturbing activity” for the subject project, at all project locations (i.e., both on-site and any off-site locations that are included in the project description/definition and/or required in connection with the project, such as public improvement work). “Ground-disturbing activity” includes, but is not limited to, pavement removal, potholing, auguring, grubbing, tree removal, boring, grading, excavation, drilling, and trenching.

B. A copy of the executed monitoring agreement shall be provided to the City of South El Monte prior to the earlier of the commencement of any ground-disturbing activity for the project, or the issuance of any permit necessary to commence a ground-disturbing activity.

Prior to ground disturbing activities Monitoring during grading Retention of an approved Native American Monitor; Executed Monitoring Agreement Monitoring during ground disturbance activities Pre-Construction Sensitivity/Educational Meeting Daily Tribal Monitoring Logs Community Development Department, Planning Division Community Development Department, Building & Safety Division Kizh Monitor and/or Kizh Archaeologist

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C. The Applicant shall provide the Tribe with a minimum of 30 days advance written notice of the commencement of any project ground-disturbing activity so that the Tribe has sufficient time to secure and schedule a monitor for the project.

D. The Applicant shall hold at least one pre-construction sensitivity/educational meeting prior to the commencement of any ground-disturbing activities, where at a senior member of the Tribe will inform and educate the project’s construction and managerial crew and staff members (including any project subcontractors and consultants) about the tribal cultural resources (“TCR”) mitigation measures and compliance obligations, as well as places of significance located on the project site (if any), the appearance of potential TCRs, and other informational and operational guidance to aid in the project’s compliance with the TCR mitigation measures.

E. The monitor will complete daily monitoring logs that will provide descriptions of the relevant ground disturbing activities, the type of construction activities performed, locations of ground-disturbing activities, soil types, cultural-related materials, and any other facts, conditions, materials, or discoveries of significance to the Tribe. Monitor logs will identify and describe any discovered TCRs, including but not limited to, Native American cultural and historical artifacts, remains, places of significance, etc. (collectively, tribal cultural resources, or “TCR”), as well as any discovered Native American (ancestral) human remains and burial goods. Copies of monitor logs will be provided to the City upon written request.

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F. Native American monitoring for the project shall conclude upon the latter of the following: (1) written confirmation from a designated project point of contact to the Tribe that all ground-disturbing activities and all phases that may involve ground-disturbing activities on the project site and at any off-site project location are complete; or (2) written notice by the Tribe to the Applicant and City that no future, planned construction activity and/or development/construction phase (known by the Tribe at that time) at the project site and at any off-site project location possesses the potential to impact TCRs.

MM TCR-2: Discovery of TCRs, Human Remains, and/or Grave Goods A. Upon the discovery of a TCR, all construction activities in the immediate vicinity of the discovery (i.e., not less than the surrounding 50 feet) shall cease. The Tribe shall be immediately informed of the discovery, and a Kizh monitor and/or Kizh archaeologist will promptly report to the location of the discovery to evaluate the TCR and advise the project manager regarding the matter, protocol, and any mitigating requirements. No project construction activities shall resume in the surrounding 50 feet of the discovered TCR unless and until the Tribe has completed its assessment/evaluation/recovery of the discovered TCR and surveyed the surrounding area.

B. The Tribe will recover and retain all discovered TCRs in the form and/or manner the Tribe deems appropriate in its sole discretion, and for any purpose the Tribe deems appropriate, including but not limited to, educational, cultural and/or historic purposes.

C. If Native American human remains and/or grave goods are discovered or recognized on the project site or at any offDuring construction, if human remains are found Kizh Monitor and/or Kizh Archaeologist assigned and on site, if remains are found Community Development Department, Planning Division; Building & Safety Division Kizh Monitor and/or Kizh Archaeologist

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site project location, then all construction activities shall immediately cease. Native American “human remains” are defined to include “an inhumation or cremation, and in any state of decomposition or skeletal completeness.” (Public Resources Code [PRC] §5097.98 (d)(1).) Funerary objects, referred to as “associated grave goods,” shall be treated in the same manner and with the same dignity and respect as human remains. (PRC §5097.98 (a), d)(1) and (2)).

D. Any discoveries of human skeletal material or human
remains shall be immediately reported to the County Coroner (Health & Safety Code §7050.5(c); 14 Cal. Code Regs. §15064.5(e)(1)(B)), and all ground-disturbing project ground-disturbing activities on site and in any other area where the presence of human remains and/or grave goods are suspected to be present, shall immediately halt and remain halted until the coroner has determined the nature of the remains. (14 Cal. Code Regs. §15064.5(e).) If the coroner recognizes the human remains to be those of a Native American or has reason to believe they are Native American, he or she shall contact, within 24 hours, the Native American Heritage Commission, and Public Resources Code Section 5097.98 shall be followed.

E. Thereafter, construction activities may resume in other parts of the project site at a minimum of 200 feet away from discovered human remains and/or grave goods, if the Tribe determines in its sole discretion that resuming construction activities at that distance is acceptable and provides the project manager express consent of that determination (along with any other mitigation measures the Tribal monitor and/or archaeologist deems necessary). (14 Cal. Code Regs. §15064.5(f).)

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F. Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human remains and/or grave goods.

G. Any historic archaeological material that is not Native American in origin (non-TCRs) shall be curated at a public, non-profit institution with a research interest in the materials, such as the Natural History Museum of Los Angeles County or the Fowler Museum, if such an institution agrees to accept the material. If no institution accepts the archaeological material, it shall be offered to a local school or historical society in the area for educational purposes.

H. Any discovery of human remains and/or grave goods
discovered and/or recovered shall be kept confidential to prevent further disturbance.

MM TCR-3: Procedures for Burials, Funerary Remains, and Grave Goods A. As the Most Likely Descendant (“MLD”), the Koo-nas-gna Burial Policy shall be implemented for all discovered Native American human remains and/or grave goods. Tribal Traditions include, but are not limited to, the preparation of the soil for burial, the burial of funerary objects and/or the deceased, and the ceremonial burning of human remains.

B. If the discovery of human remains includes four (4) or more burials, the discovery location shall be treated as a cemetery and a separate treatment plan shall be created.

C. The prepared soil and cremation soils are to be treated in the same manner as bone fragments that remain intact. Associated “grave goods” (aka, burial goods or funerary objects) are objects that, as part of the death rite or During construction, if remains are found
Compliance with Koonas-gna Burial Policy Community Development Department, Planning Division; Building & Safety Division Kizh Monitor and/or Kizh Archaeologist

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ceremony of a culture, are reasonably believed to have been placed with individual human remains either at the time of death or later, as well as other items made exclusively for burial purposes or to contain human remains. Cremations will either be removed in bulk or by means necessary to ensure complete recovery of all sacred materials.

D. In the case where discovered human remains cannot be fully recovered (and documented) on the same day, the remains will be covered with muslin cloth and a steel plate that can be moved by heavy equipment placed over the excavation opening to protect the remains. If this type of steel plate is not available, a 24-hour guard should be posted outside of working hours. The Tribe will make every effort to divert the project while keeping the remains in situ and protected. If the project cannot be diverted, it may be determined that burials will be removed.

E. In the event preservation in place is not possible despite good faith efforts by the Applicant and/or landowner, before ground-disturbing activities may resume on the project site, the landowner shall arrange a designated site location within the footprint of the project for the respectful reburial of the human remains and/or ceremonial objects. The site of reburial/repatriation shall be agreed upon by the Tribe and the landowner, and shall be protected in perpetuity.

F. Each occurrence of human remains and associated grave goods will be stored using opaque cloth bags. All human remains, grave goods, funerary objects, sacred objects and objects of cultural patrimony will be removed to a secure

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container on site if possible. These items will be retained and shall be reburied within six months of recovery.

G. The Tribe will work closely with the project’s qualified archaeologist to ensure that the excavation is treated carefully, ethically and respectfully. If data recovery is approved by the Tribe, documentation shall be prepared and shall include (at a minimum) detailed descriptive notes and sketches. All data recovery data recoveryrelated forms of documentation shall be approved in advance by the Tribe. If any data recovery is performed, once complete, a final report shall be submitted to the Tribe and the NAHC. The Tribe does NOT authorize any scientific study or the utilization of any invasive and/or destructive diagnostics on human remains.

Standard Conditions (SCs) Implementation Timing
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Biological Resources SC BIO-1: Nesting Migratory Birds. During construction, grubbing, brushing, or tree removal shall be conducted outside of the state identified nesting season for migratory birds (i.e., typically March 15 through September 1), if possible. If construction activities cannot be conducted outside of nesting season, a Pre-Construction Nesting Bird Survey within and adjacent to the project site shall be conducted by a qualified biologist within three days prior to initiating construction activities. If active nests are found during the Pre-Construction Nesting Bird Survey, a Nesting Bird Plan (NBP) shall be prepared by a qualified biologist and implemented during construction. At Three days prior to first site disturbance, if during migratory bird nesting season Verify requirements included on grading and construction plans Verify pre-construction nesting bird survey conducted and nesting Community Development Department, Planning Division; Building & Safety Division Qualified Biologist

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a minimum, the NBP shall include guidelines for addressing active nests, establishing buffers, monitoring, and reporting. The size and location of all buffer zones, if required, shall be based on the nesting species, nesting sage, nest location, its sensitivity to disturbance, and intensity and duration of the disturbance activity. bird plan prepared, if required
Cultural Resources
SC CUL 1: California Health and Safety Code Section 7050.5 through 7055, and Public Resources Code Sections 5097.98 and 5097.99 mandate the process to be followed in the event of an accidental discovery of any human remains in a location other than a dedicated cemetery. California Health and Safety Code Section 7050.5 requires that in the event that human remains are discovered within the project site, disturbance of the site shall be halted until the coroner has conducted an investigation into the circumstances, manner and cause of death, and the recommendations concerning the treatment and disposition of the human remains have been made to the person responsible for the excavation, or to his or her authorized representative, in the manner provided in Section 5097.98 of the Public Resources Code. If the coroner determines that the remains are not subject to his or her authority and if the coroner recognizes or has reason to believe the human remains to be those of a Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission.

In the event of an accidental discovery of human remains Verify Requirements on Construction Plans; Verify Coroner Investigation, if required Community Development Department, Planning Division; Building & Safety Division Los Angeles County Coroner Native American Heritage Commission, if remains are Native American Noise
SC N-1: All construction activities should be limited to the hours between the hours of 7:00 AM and 10:00 PM on weekdays, or any time on weekends or holidays per City of South El Monte Municipal Code Chapter 8.20.

During grading and construction
Verify requirements on construction plans Conduct Site Inspections Community Development Department, Planning Division;

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Building & Safety Division
SC N-2: The Applicant shall ensure through contract specifications that construction best management practices (BMPs) be implemented by contractors to reduce construction noise levels. Contract specifications shall be included in construction documents, which shall be reviewed by the City prior to issuance of a grading or building permit (whichever is issued first). The construction BMPs shall include the following:
 All equipment, whether fixed or mobile, will be equipped with properly operating and maintained mufflers, consistent with manufacturer standards.  All stationary construction equipment will be placed so that emitted noise is directed away from the noise-sensitive receptors nearest the project site.  As applicable, all equipment shall be shut off and not left idle when not in use.
 To the degree possible, equipment staging will be located in areas that create the greatest distance between construction-related noise and vibration sources and existing sensitive receptors.  Jackhammers, pneumatic equipment, and all other portable stationary noise sources will be directed away and shielded from existing residences in the vicinity of the project site. Either one-inch plywood or sound blankets can be utilized for this purpose. They should reach up from the ground and block the line of sight between equipment and existing residences. The shielding should be without holes and cracks.  No amplified music and/or voice will be allowed on the project site.

Prior to Grading or Building Permit issuance, whichever issued first Verify requirements on construction plans Conduct Site Inspections Community Development Department, Planning Division; Building & Safety Division

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 Haul truck deliveries will not occur outside the hours presented as exempt for construction per City of South El Monte Municipal Code Section 8.20.030(D).

kimley-horn.com 1100 Town and Country Road | Suite 700, Orange, CA 92868 714 939 1030 Responses to Public Comments on the 2222 Rosemead Boulevard Warehouse Development Project Initial Study and Mitigated Negative Declaration Introduction
The purpose of this memo is to transmit the public comments and responses to these comments received on the Initial Study and Mitigated Negative Declaration (IS/MND) for the 2222 Rosemead Boulevard Warehouse Development Project located in the City of South El Monte. The Draft IS/MND was released for public review and comment by the City of South El Monte on October 1, 2024, for a 30-day public comment period ending on October 30, 2024.

In accordance with the California Environmental Quality Act (CEQA) Guidelines Section 15074, the City of South El Monte, as the Lead Agency, must consider the IS/MND together with any comments received during the public review process. Written responses have been prepared to comments received during and after the public review period.

CEQA Requirements Regarding Comments and Responses
State CEQA Guidelines Section 15204(b) states that “persons and public agencies should focus on the proposed finding that the project will not have a significant effect on the environment. If persons and public agencies believe that the project may have a significant effect, they should:

1. Identify the specific effect,

2. Explain why they believe the effect would occur, and

3. Explain why they believe the effect would be significant.” State CEQA Guidelines Section 15204(c) further advises, “Reviewers should explain the basis for their comments and should submit data or references offering facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of the comments. Pursuant to State CEQA Guidelines Section 15064, an effect shall not be considered significant in the absence of substantial evidence.” State CEQA Guidelines Section 15204(d) states, “Reviewing agencies or organizations should include with their comments the name of a contact person who would be available for later consultation if necessary. Each responsible agency and trustee agency shall focus its comments on environmental information germane to that agency’s statutory responsibility.” State CEQA Guidelines Section 15204(e) states, “This section shall not be used to restrict the ability of reviewers to comment on the general adequacy of a document or of the lead agency to reject comments not focused as recommended by this section.”

ATTACHMENT D

EXHIBIT C
TO RESOLUTION NO. 25-035

kimley-horn.com 1100 W Town and Country Road | Suite 700, Orange, CA 92868 714 939 1030 List of Respondents
The comment letters received during and after the public review period are listed below and provided in Appendix A: Comment Letters.

Letter Number / Author / Date

1. Marjan R. Abubo, Lozeau Drury, LLP (on behalf of Supporters Alliance for Environmental Responsibility [“SAFER”] and its members in and around the City), October 29, 2024.

2. Aidan P. Marshall, Adams Broadwell Joseph & Cardozo Attorneys at Law (on behalf of Coalition for Responsible Equitable Economic Development Los Angeles [“CREED LA”]), October 30, 2024.

3. Patricia Horsley, Environmental Planner, Facilities Planning Department, Los Angeles County Sanitation Districts, October 28, 2024.

4. Sam Wang, Program Supervisor, CEQA IGR, South Coast Air Quality Management District, October 30, 2024.

5. Anthony Higgins, Acting LDR Branch Chief, California Department of Transportation – District 7, November 5, 2024.

Responses to Comments
Responses have been provided to comments on significant environmental points to describe the disposition of issues and new information or clarifications, as appropriate. When comments did not address the completeness or adequacy of the environmental documentation or did not raise significant environmental issues, the receipt of the comment is noted; no further response is provided.

kimley-horn.com 1100 W Town and Country Road | Suite 700, Orange, CA 92868 714 939 1030 RESPONSE TO COMMENT LETTER 1
Marjan R. Abubo, Lozeau Drury, LLP (on behalf of Supporters Alliance for Environmental Responsibility [“SAFER”] and its members in and around the City), October 29, 2024. 1-1 The comment states that the Supporters Alliance for Environmental Responsibility (SAFER) believes that the IS/MND is improper under CEQA due to the IS/MND’s failure to adequately analyze and review the Project’s potentially significant impacts. The comment states there is substantial evidence of a fair argument that the Project may have adverse environmental impacts related to noise and air quality. SAFER requests that an EIR be prepared for the Project rather than an MND to ensure that potentially significant impacts of this project are fully disclosed, analyzed, and mitigated.

The City respectfully disagrees. An EIR is not required for the Project because all potentially significant impacts would be mitigated to a less than significant level under the MND, and the commenter has not provided any evidence to the contrary. The commenter is referred to the entirety of the IS/MND, which provides a full analysis of the project’s elements and an evaluation of both project construction and operations. The IS/MND also identifies multiple mitigation measures to reduce impacts to less than significant levels. 1-2 This comment reiterates the Project Description. No response is required. 1-3 The commenter describes the legal standard for Negative Declarations. No response is required. 1-4 The comment asserts that an EIR is required because substantial evidence in the record indicates a fair argument that the Project may have significant noise impacts. The comment states the Project underestimates noise and vibration impacts, and that correcting these errors reveals the Project’s potentially significant noise and vibration impacts that must be disclosed and mitigated.

Because this comment does not contain any specific comments about the environmental analysis or conclusions contained in the IS/MND. This is factually incorrect; responses to specific comments are provided below.
1-5 See Response to Lozeau Drury Comment Letter Dated October 29, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) – Response to Comment 5.
1-6 See Response to Lozeau Drury Comment Letter Dated October 29, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) – Response to Comment 6.
1-7 See Response to Lozeau Drury Comment Letter Dated October 29, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) – Response to Comment 7.

kimley-horn.com 1100 W Town and Country Road | Suite 700, Orange, CA 92868 714 939 1030 1-8 See Response to Lozeau Drury Comment Letter Dated October 29, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) – Response to Comment 8.
1-9 See Response to Lozeau Drury Comment Letter Dated October 29, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) – Response to Comment 9.
1-10 See Response to Lozeau Drury Comment Letter Dated October 29, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) – Response to Comment 10.
1-11 See Response to Lozeau Drury Comment Letter Dated October 29, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) – Response to Comment 11.
1-12 See Response to Lozeau Drury Comment Letter Dated October 29, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) – Response to Comment 12.
1-13 This comment refers to a comment letter prepared by the Office of Environmental Health Hazard Assessment (OEHHA) dated July 12, 2023, regarding their review of the Limited Soil Remediation Work Plan for the Eastern Portion of 2200 North Rosemead Boulevard, South El Monte, California (April 2023 LSRWP). A Limited Soil Remediation Work Plan Addendum for 2200-2226 N. Rosemead Boulevard, South El Monte, California, was prepared by Haley & Aldrich, Inc., dated April 2024 (LSRWP Addendum) and was provided in IS/MND Appendix C, which supplements the April 2023 Soil Remediation Workplan with additional soil samples collected in January 2024 and addresses Los Angeles Regional Water Quality Board (LARWQCB) and OEHHA comments, including those in the July 12, 2023 letter. The OEHHA comment letter dated July 12, 2023, provided in the Lozeau Drury letter, was specifically addressed in Appendix A of the LSRWP Addendum, which was also provided as Appendix C of the IS/MND provided for public review and was approved by the LAWRQCB on October 2, 2024 (see Appendix B).

The commenter is incorrect in their statement that the IS/MND fails to disclose, analyze, or mitigate impacts related to cancer risk and hazard index as they are addressed in detail in Appendix C and IS/MND Section 4.9: Hazards and Hazardous Materials. Specifically, as concluded in the human health risk assessment, it is noted that current levels of chemicals of concern (COCs) in soil required risk management prior to site redevelopment for future commercial/industrial land use and states that soil excavation and removal was the selected remedy to address the threat to human health and groundwater quality. The proposed soil remediation will include excavation and removal of COC-impacted soils. PCB-impacted soils will be regulated by the United States Environmental Protection Agency (USEPA) 40 CFR 761 and will be managed with the USEPA

kimley-horn.com 1100 W Town and Country Road | Suite 700, Orange, CA 92868 714 939 1030 as the lead agency in accordance with the Toxic Substances Control Act (TSCA) Cleanup Plan that was submitted to the USEPA. Other COCs are generally co-located with PCB shallow soil impacts and will be removed during the TSCA remedial excavation. Additionally, the commenter is incorrect in their statement that these impacts are not mitigated. Mitigation measures (MM) HAZ-1 through HAZ-4 specifically address soil contamination.

MM HAZ-1 requires the Applicant to submit a Soil Management Plan for approval by the LARWQCB that specifies details regarding the handling, stockpiling, sampling, and reuse or disposal of soil with concentrations of Chemicals of Potential Concern (COPC) in excess of their respective site-specific remedial action goals (RAGs) or re-use criteria that were established as part of a Human Health Risk Assessment (HHRA) and integrated into the SMP. In accordance with MM HAZ-1, a SMP dated October 11, 2024 was approved by the LARWQCB on November 5, 2024 that establishes guidelines and recommended procedures including air quality monitoring requirements, soil management procedures, and worker health and safety requirements that manage risks to human health and the environment during soil disturbance activities associated with the redevelopment. The LARWQCB SMP Approval Letter is provided as Appendix B, which states the primary objectives of the SMP are to (1) appropriately manage risks to human health and the environment due to soil disturbance activities; and (2) provide a framework to evaluate and manage potentially impacted soil during disturbance activities.

Further, MM HAZ-3 requires the Applicant to demonstrate to the City of South El Monte Building and Safety Division implementation of the LSRWP and LSWRP Addendum as approved by the LARWQCB, the TSCA Application for Risk-Based Clean-up as approved by the USEPA. MM HAZ-3 further states that the LARWQCB and USEPA shall provide oversight for the implementation of soil remediation and mitigation activities. This is further supported in Appendix B, which requires a technical report documenting implementation of the proposed remediation be submitted to the LARWQCB after implementation of the LSWRP and LSWRP Addendum.

Finally, MM HAZ-4 requires a vapor intrusion mitigation system to be included in the Project design in accordance with the LSWRP Addendum to minimize vapor intrusion risks from VOC impacted soil and soil vapor on the project site. This is further supported in Appendix B, which states that construction of the warehouse cannot begin until the VIMS work plan has been approved by the LARWQCB.

Therefore, the IS/MND accurately considers the health risks and impacts associated with required remediation efforts, and as concluded in the IS/MND and approved by the LARWQCB, with implementation of MM HAZ-1 through MM HAZ-4, impacts concerning the release of hazardous materials into the environment would be less than significant. 1-14 See Response to Lozeau Drury Comment Letter Dated October 29, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) – Response to Comment 14.

kimley-horn.com 1100 W Town and Country Road | Suite 700, Orange, CA 92868 714 939 1030 1-15 See Response to Lozeau Drury Comment Letter Dated October 29, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) – Response to Comment 15.
1-16 See Response to Lozeau Drury Comment Letter Dated October 29, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) – Response to Comment 16.
1-17 See Response to Lozeau Drury Comment Letter Dated October 29, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) – Response to Comment 17.
1-18 See Response to Lozeau Drury Comment Letter Dated October 29, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) – Response to Comment 18.
1-19 This comment states that for the reasons set forth above, SAFER requests that the City prepare and circulate an EIR for the Project prior to approval. See responses 1-1 through 1-18 above. This is a generalized comment that does not require a response. 1-20 This comment introduces Wilson Ihrig’s review of the Noise Impact Analysis and provides background information concerning adverse effects of noise. This comment does not specifically state concerns or issues with the environmental analysis in the IS/MND. 1-21 Refer to Comment Response No. 1-5.
1-22 Refer to Comment Response No. 1-6.
1-23 Refer to Comment Response No. 1-9.
1-24 Refer to Comment Response No. 1-8.
1-25 This comment provides a closing to the Wilson Ihrig comment letter and does not raise any new issues regarding the adequacy of the IS/MND.
1-26 This comment introduces Clark and Associates review of the project and provides a summary of the project description. Note that this comment incorrectly identifies the project as within the City of El Monte. The project is in the City of South El Monte. 1-27 Refer to Comment Response No. 1-12.
1-28 Refer to Comment Response No. 1-15.
1-29 Refer to Comment Response No. 1-17.

kimley-horn.com 1100 W Town and Country Road | Suite 700, Orange, CA 92868 714 939 1030 1-30 Refer to Comment Response No. 1-17.
1-31 This comment provides a closing to the Clark & Associates comment letter and does not raise any new issues regarding the adequacy of the IS/MND.
1-32 Refer to Comment Response No. 1-13.

transportation ■ noise ■ air quality | GANDDINI GROUP
555 Parkcenter Drive, Suite 225, Santa Ana, CA 92705
(714) 795-3100 | ganddini.com

MEMORANDUM
TO: Dana Privett | KIMLEY-HORN & ASSOCIATES, INC.

FROM: Roma Stromberg, Katie Wilson, Giancarlo Ganddini | GANDDINI GROUP, INC.

DATE: November 13, 2024
SUBJECT: Response to Lozeau Drury Comment Letter Dated October 29, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618)
On behalf of Supporters Alliance for Environmental Responsibility (SAFER), the law firm of Lozeau Drury, LLP submitted a comment letter dated October 29, 2024 regarding the Initial Study/Mitigated Negative Declaration (IS/MND) for the proposed 2222 Rosemead Boulevard Warehouse Development project. This memorandum contains responses to comments relating to the technical studies prepared by Ganddini Group.

RESPONSE TO COMMENTS 1-3
These comments consist of introductory text, the project description, and legal standards. There are no comments relating to the technical studies prepared by Ganddini Group.

RESPONSE TO COMMENT 4
This comment notes that Wilson Ihrig was retained by the commenter to review the proposed project, MND, and the noise impact analysis prepared by Ganddini Group. The commenter claims that noise and vibration impacts are underestimated and correcting these errors would result in a potentially significant noise and vibration impacts that must be disclosed and mitigated.

Because the comment does not contain any specific comments or questions about the environmental analysis or conclusions contained in the Draft EIR, no further response is required. Responses to specific comments are provided below.

RESPONSE TO COMMENT 5
The Project’s Technical Noise Analysis1 estimated project construction noise levels using the Federal Transit Administration (FTA) methodologies and significance thresholds found in the Transit Noise and Vibration Impact Assessment Manual (FTA Manual) (2018). Specifically, project construction would be significant if it exceeds 80 dBA Leq for an 8-hour period at residential land uses.

how all of the different noise sources should not be lumped together as one source at the center of the site because in reality, each operational noise source is typically situated in one area of the site over the life of the project. This does not apply to construction noise because construction equipment moves all over the project 1 Rosemead and Rush Industrial Park Noise Impact Analysis (Ganddini Group, June 15, 2023).

Dana Privett
KIMLEY-HORN & ASSOCIATES, INC.

November 13, 2024
2222 Rosemead Boulevard Warehouse Development
Response to Lozeau Drury Comment Letter Dated October 29, 202419618 2 19618
site throughout any particular day and the location of temporary stationary noise sources will also shift from hour to hour and day to day. That is why the FTA manual includes instructions to model construction noise sources from the center of the site. This is a way of averaging the noise over the construction period, which is appropriate for an 8-hour Leq. The Project’s Technical Noise Analysis modeled all of the likely noise sources associated with each construction phase using well documented noise reference levels at the center of the site and projected that noise to nearby land uses. Well researched usage factors provided in the Caltrans Department of Transportation Technical Noise Supplement (2013) that are also used in the frequently used Road Construction Noise Model (RCNM). This was the appropriate methodology.

The comment concerning General vs. Detailed construction noise FTA methodologies is incorrect. A General Assessment was not conducted. As shown in Appendix D of the technical noise study prepared for the project, Detailed Construction Analysis methodologies were used to the degree possible. Specifically, the construction noise analysis includes noise level calculations of each piece of equipment at each receptor, during each phase and provides a cumulative noise level for each phase.

The construction noise methodology described by Wilson Ihrig’s is inappropriate to use with an 8-hour Leq, because it is highly unlikely that one piece of equipment is going to be operating in the same place for the entire day. The whole purpose of the 8-hour threshold is to average noise levels that will move closer and farther from each sensitive receptor throughout the day.

As stated in page 1 of the Technical Noise Analysis, even though Project construction noise levels were found to be less than significant, the following Best Management Practices (BMPs) are included on project plans and will be adopted as Conditions of Approval.

1. All equipment, whether fixed or mobile, will be equipped with properly operating and maintained mufflers, consistent with manufacturer standards.

2. All stationary construction equipment will be placed so that emitted noise is directed away from the noise sensitive receptors nearest the project site.

3. As applicable, all equipment shall be shut off and not left to idle when not in use.

4. To the degree possible, equipment staging will be located in areas that create the greatest distance between construction-related noise and vibration sources and existing sensitive receptors.

5. All other portable stationary noise sources will be directed away and shielded from existing residences in the vicinity of the project site. Either one-inch plywood or sound blankets can be utilized for this purpose. They should reach up from the ground and block the line of sight between equipment and existing residences. The shielding should be without holes and cracks.

6. No amplified music and/or voice will be allowed on the project site.

7. Haul truck deliveries will not occur outside of the hours presented as exempt for construction per City of South El Monte Municipal Code Section 8.20.030(D).

RESPONSE TO COMMENT 6
A detailed roof plan was not available when the Technical Noise Analysis was prepared. It has since been provided and is part of the application package. As shown in the roof plan and mechanical plans, HVAC units are only proposed on the western rooftop of the proposed building over office spaces and will not require warehouse sized units. Ceiling fans are proposed for warehouse ventilation.

Dana Privett
KIMLEY-HORN & ASSOCIATES, INC.

November 13, 2024
2222 Rosemead Boulevard Warehouse Development
Response to Lozeau Drury Comment Letter Dated October 29, 202419618 3 19618
RESPONSE TO COMMENT 7
As stated in the Technical Noise Analysis, in regard to vibration, the City of South El Monte’s Municipal Code Section 8.20.020(B) states that no person shall operate or permit the operation of any device or machine that creates a vibration above the vibration perception threshold when measured at or beyond the property boundary of the source. However, because the City does not provide a numerical threshold of significance concerning groundborne vibration, groundborne vibration impacts were based on guidance from the Transportation and Construction Vibration Guidance Manual (California Department of Transportation, 2020).

This manual provides direction for addressing vibration issues associated with the construction, operation, and maintenance of projects.2 Both the architectural damage and annoyance thresholds utilized from this manual were developed from a synthesis of various vibration criteria. Therefore, these thresholds are based on the use of scientific methods and mathematics supported by multiple other vibration studies including International Standards Organization (ISO) Guide to the Evaluation of Human Exposure to Vibration and Shock in Buildings (ISO 1981), Federal Transit Administration (FTA) Transit Noise and Vibration Impact Assessment (2018), Vibration Criteria for Historic Buildings Journal of Construction Engineering and Management (Konon 1985), A Survey of Traffic-Induced Vibrations (Whiffen 1971), American Association of State Highway and Transportation Officials (AASHTO) Standard Recommended Practice for Evaluation of Transportation-Related Earthborne Vibrations (1990), National Cooperative Highway Research Program (NCHRP) Current Practices to Address Construction Vibration and Potential Effects to Historic Buildings Adjacent to Transportation Projects (2021), and many others (see Chapter 6 of the Caltrans Manual). Furthermore, the vibration levels associated with the project were calculated based on vibration propagation equations and construction equipment source levels obtained from the FTA Transit Noise and Vibration Impact Assessment Manual (2018). These equations and vibration source levels are widely accepted for use in vibration related analyses. Therefore, the analysis used to assess the Project’s construction vibration is supported by industry accepted methodology and standards.

The commenter states that “even when an accepted method and standards are used to assess a significant impact, the EIR’s analysis can nevertheless be rejected if a reviewing court concludes its characterization of a significant impact does not provide information sufficient to give the public and decisionmakers a complete picture of its nature and scope.” However, the comment does not provide any substantial evidence or fair arguments that the groundborne vibration methodology is insufficient or does not disclose the full nature of the impacts. There is no specific evidence provided by the commenter regarding errors or omissions in the project analysis that result in an incomplete picture of the potential impacts. As stated above, the analysis calculated the Project’s vibration levels at all of the nearest receptors and then compared them to adopted thresholds. Both the calculation methodology and thresholds are founded in data consistently utilized in this type of analysis and based on scientific evidence. Furthermore, Mitigation Measure NOI-2 was provided to reduce any potential significant impacts related to architectural damage due to construction vibration. With incorporation of mitigation, the Project’s vibration levels are less than significant as they do not exceed the identified vibration thresholds. Therefore, the Project correctly analyzes the potential vibration related construction impacts and no additional analysis is required.

RESPONSE TO COMMENT 8
Please also see response to Comment 7 above. Commercial and industrial uses are not considered vibrationsensitive land uses. Therefore, the annoyance threshold applies only to the residential receptors to the south of the project site. As shown in Table 17 of the Technical Noise Analysis, the nearest residential uses would have vibration levels that reach up to 0.084 PPV in/sec. Therefore, even if the analysis used the lower 2 https://dot.ca.gov/programs/environmental-analysis/noise-vibration/guidance-manuals

Dana Privett
KIMLEY-HORN & ASSOCIATES, INC.

November 13, 2024
2222 Rosemead Boulevard Warehouse Development
Response to Lozeau Drury Comment Letter Dated October 29, 202419618 4 19618
“strongly perceptible” annoyance threshold of 0.10 PPV in/sec instead of the “severe” annoyance threshold of 0.4 PPV in/sec, the project would still not exceed vibration related annoyance significance thresholds.

The last few sentences of the comment state the “highest rung of FTA Manual thresholds.” The project utilizes thresholds from the Caltrans manual not the FTA Manual; these are two different manuals. Furthermore, comment incorrectly claims that the use of the “highest rung” of thresholds potentially results in a vibration level that would be deemed a significant impact under the next level of thresholds. As demonstrated above, vibration levels at the residential uses do not exceed the more stringent “strong perceptible” annoyance threshold level.

Although construction is anticipated to last one year, due to the nature of construction, equipment moves within and around a project site. Therefore, one piece of equipment would not be at the modeled closest distance to the receptor for the entirety of project construction. Rather, the modeled annoyance levels would only occur during times that that particular piece of equipment is within the specified closest distance. At other times construction equipment would be further away resulting in lower vibration levels. Therefore, receptors will not be subjected to high levels of annoyance from vibration for the full year of construction.

With the statements above, the project does in fact disclose the potential impacts of project related vibration annoyance and the use of the “strongly perceptible” vibration threshold would not create a change in the significance level of the project nor would it result in the need to add any additional mitigation measures. No revisions or additional mitigation measures are necessary.

RESPONSE TO COMMENT 9
It is not necessary to model every piece of construction equipment, but rather provide a representative analysis. Therefore, it is common practice to model the highest vibration producing equipment that is anticipated to be utilized during a project, which provides the highest potential vibration level that may occur at the nearest sensitive receptors. Furthermore, it is not anticipated that pile drivers are to be utilized during project construction; however, a Condition of Approval is to be added to the Project and within the project plans that prohibits the use of pile drivers on the project site during project construction.

RESPONSE TO COMMENT 10
The Technical Noise Analysis Appendix G includes the vibration calculations for the project. These calculations are based on the reference equations from the Transportation and Construction Vibration Guidance Manual, (California Department of Transportation, April 2020, page 37). The last two sheets of Appendix G of the Technical Noise Analysis include modeling the vibration level at the specified distances provided in Mitigation Measure NOI-2. These two sheets provide evidence that implementation of the mitigation measure would result in groundborne vibration levels that do not exceed the damage threshold. Therefore, evidence is provided that the mitigation measure would reduce vibration impacts to below the threshold of significance.

It is not anticipated that pile drivers are to be utilized during project construction; however, a Condition of Approval is to be added to the Project and within the project plans that prohibits the use of pile drivers on the project site during project construction.

RESPONSE TO COMMENT 11
Because the comment does not contain any specific comments or questions about the environmental analysis or conclusions contained in the Draft EIR, no further response is required. Responses to specific comments are provided below.

Dana Privett
KIMLEY-HORN & ASSOCIATES, INC.

November 13, 2024
2222 Rosemead Boulevard Warehouse Development
Response to Lozeau Drury Comment Letter Dated October 29, 202419618 5 19618
RESPONSE TO COMMENT 12
The analysis of potential hazards due to on-site contamination has been addressed in Section 4.9 Hazards and Hazardous Materials, on pages 64 through 77 of the 2222 Rosemead Boulevard Warehouse Development IS-MND dated October 2024. This type of analysis is not part of an air quality analysis, is not required by the SCAQMD and is not included in CalEEMod modeling. Analysis and mitigation measures contained in the ISMND in Section 4.9 Hazards and Hazardous Materials address impacts to workers.

RESPONSE TO COMMENT 13
See response to comment 12 above.

RESPONSE TO COMMENT 14
See response to comment 12 above.

RESPONSE TO COMMENT 15
Per the project Applicant, there are no back-up generators (BUGs) in the approved design. The project includes an electrical fire pump and would only be used on an as-needed (emergency) basis. As the fire pump is electrical, there would be no generation of emissions of criteria pollutants or toxic air contaminants. Any increase in the energy use from the emergency use of the electrical fire pump would be negligible. No additional analysis is warranted or required.

RESPONSE TO COMMENT 16
See response to comment 12 above.

RESPONSE TO COMMENT 17
In his construction HRA conducted for this SAFER comment letter, Dr. Clark has made errors in the calculations for determining the emission rate for the input into the AERMOD model. In the calculations, he showed in a Table that the duration of the project’s construction will be 269 days; however, during another part of his calculation, he only used a construction duration of 259 days. As this number was used in the denominator of a calculation, the actual result (using 269 days) for the emissions rate came out to 4.45 x 10- 7 grams/hour per m2
; whereas the emissions rate that Dr. Clark used was 3.67 x 10-6lbs per hour of operation.

One pound (lb) is equal to 453.6 grams. As Dr. Clarks emissions factor is in lbs/hour per m2 and not grams/hour per m2, and also off by a factor of 10, the results of the dispersion modeling with AERMOD would not be correct and would over-estimate the construction health risk by at least a factor of 10. Therefore, as the results are not reliable, the conclusions of a signficant impact from construction equipment TACs cannot be relied upon either, as the data inputs were incorrect. Addittionally, the Google Drive link that was included in the comment letter to access the output data for the modeling was not accessible/denied and access needed to be requested. This data should have been provided with the comment letter, or via a non-access-restricted link.

Neither the City of South El Monte nor the SCAQMD require projects to conduct construction-related health risk assessments. The SCAQMD leave the decision up to the Lead Agency. Futhermore, as the project site is relatively small, 5.14 acres, the project will not be using a large amount of construction equipment at any one time. The SCAQMD have also commented on this project (see SCAQMD comment letter dated October 30th,

Dana Privett
KIMLEY-HORN & ASSOCIATES, INC.

November 13, 2024
2222 Rosemead Boulevard Warehouse Development
Response to Lozeau Drury Comment Letter Dated October 29, 202419618 6 19618
2024) and they have not requested or required that either a construction HRA or operational HRA be conducted for this project. Therefore, no construction HRA is warranted or required.

RESPONSE TO COMMENT 18
See response to comment 17 above.

CONCLUSION
We appreciate the opportunity to assist you on this project. Should you have any questions or if we can be of further assistance, please contact us at 714-795-3100.

Respectfully submitted,
GANDDINI GROUP, INC.

Giancarlo Ganddini
Principal Traffic Engineer
Roma Stromberg, MS
Senior Noise Analyst
Katie Wilson, MS
Senior Air Quality Analyst

kimley-horn.com 1100 W Town and Country Road | Suite 700, Orange, CA 92868 714 939 1030 RESPONSE TO COMMENT LETTER 2
Aidan P. Marshall, Adams Broadwell Joseph & Cardozo Attorneys at Law (on behalf of Coalition for Responsible Equitable Economic Development Los Angeles [“CREED LA”]), October 30, 2024. 2-1 This introductory comment provides a summary of the proposed project and states that the IS/MND’s project description is inaccurate, preventing meaningful review of the Project’s impacts and that substantial evidence supports a fair argument that the Project would have potentially significant public health, air quality, energy, GHG emissions, transportation, noise, and public utilities impacts that are not adequately mitigated by the mitigation proposed in the IS/MND.

However, the commenter does not provide any explanation concerning how the project description is inaccurate or any substantial evidence that impacts are not adequately mitigated.

Individual responses to the comments raised in the comment letter are provided in the responses below. As discussed below, none of the issues identified in the comment letter change the conclusions of the IS/MND, and therefore, an Environmental Impact Report (EIR) is not required.

Impacts remain less than significant with implementation of mitigation measures. 2-2 This comment identifies individuals and labor organizations that are part of CREED LA and the association’s interest in enforcing environmental laws. This comment also states that CREED LA supports the development of commercial, mixed-use, and medical office projects where properly analyzed and carefully planned to minimize impacts on public health, climate change, and the environment. It notes that projects should avoid adverse impacts to air quality, public health, climate change, noise, and traffic, and must incorporate all feasible mitigation so that any remaining adverse impacts are reduced to the maximum extent feasible. The City acknowledges the individuals and organizations that are part of CREED LA. However, the comment does not address the adequacy or accuracy of the IS/MND. No further response is required. 2-3 This commenter incorrectly states that the IS/MND does not include an accurate and complete Project Description and summarizes the CEQA requirements and case law related to describing a project. The commenter’s criticism of the IS/MND is unsupported and does not identify any specific concerns or provide evidence that the Project Description is incomplete. The City agrees with the commenter that a Project Description must be “accurate, stable, and finite,” which is what is provided in the IS/MND. The Response to Comments below addresses specific comments related to the Project Description and demonstrates that the IS/MND includes an accurate and complete Project Description that adequately meets CEQA requirements. 2-4 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) – Response to Comment 4.
2-5 This comment states that the IS/MND is internally inconsistent regarding whether truck movement, loading, and unloading activities would be authorized between the hours of 10:00 PM

kimley-horn.com 1100 W Town and Country Road | Suite 700, Orange, CA 92868 714 939 1030 and 7:00 AM. As a point of clarification, should the Applicant decide to install a 10-foot-high concrete masonry wall in accordance with MM NOI-2, truck movement and loading and unloading between the hours of 10:00 PM and 7:00 AM would be allowed. 2-6 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) – Response to Comment 6.
2-7 This comment summarizes the purpose, goal, and requirements of CEQA, as well as when an EIR is required. The comment explains the fair argument standard with regards to the preparation of an EIR and an MND. The comment also states that the IS/MND for the proposed project does not satisfy the basic purposes of CEQA; does not adequately disclose, investigate, and analyze the proposed project’s potentially significant impacts; and does not provide substantial evidence to conclude that impacts would be mitigated to a less than significant level. The comment states that substantial evidence shows that the proposed project may result in potentially significant impacts and that a fair argument can be made that the Project may cause significant impacts requiring the preparation of an EIR.

The IS/MND evaluates the proposed project’s potential environmental impacts associated with 21 environmental factors identified in State CEQA Guidelines Appendix G. The City will consider the analysis in the IS/MND prior to making a decision on whether to adopt the MND and approve the project and, thus, the IS/MND meets the purpose and goal of CEQA.

The IS/MND identifies, discusses, and summarizes the documents and databases that were used to substantiate the analysis and conclusions of the environmental impacts, along with the models that were used in the environmental analysis. The documents and programs that were used to support the no impact and less than significant impacts (with and without mitigation measures) are from applicable regulatory agencies associated with the environmental factors that were discussed in the IS/MND, including the South Coast Air Quality Management District, California Department of Transportation, U.S. Department of Fish and Wildlife Services, California Department of Fish and Wildlife, California Department of Conservation, California Department of Toxic Substances Control, California Water Resources Control Board, Southern California Association of Governments, San Gabriel Valley Water Company, and CalRecycle. Site-specific evaluations were also conducted (e.g., Air Quality, Global Climate Change, HRA, and Energy Impact Analysis, Geotechnical Investigation, Phase I Environmental Site Assessment, Limited Soil and Soil Vapor Site Investigation Report, Limited Soil Investigation Report, Soil Vapor Assessment Report, Limited Soil Remediation Work Plan Addendum, Preliminary Hydrology and Hydraulics and LID Report, and Transportation Impact Analysis) to determine whether the proposed project would result in any potentially significant impacts. As analyzed throughout the IS/MND, the proposed project would either result in no impact or less than significant impacts (with and without mitigation measures). Thus, there is substantial evidence that the proposed project

kimley-horn.com 1100 W Town and Country Road | Suite 700, Orange, CA 92868 714 939 1030 would not have a significant effect on the environment with implementation of mitigation measures.
2-8 Refer to Comment Response No. 2-7.
2-9 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) – Response to Comment 9.
2-10 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) – Response to Comment 10.
2-11 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) – Response to Comment 11.
2-12 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) – Response to Comment 12.
2-13 The commenter states the requirements from State CEQA Guidelines Sections 15130(a), 15065(a)(3), and 15355(b) regarding cumulative impacts and the importance of a proper cumulative impact analysis. This comment does not raise any issues concerning the environmental analysis provided in the IS/MND, and thus no further response is required. 2-14 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) – Response to Comment 14.
2-15 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) – Response to Comment 15.
2-16 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) – Response to Comment 16.
2-17 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) – Response to Comment 17.

kimley-horn.com 1100 W Town and Country Road | Suite 700, Orange, CA 92868 714 939 1030 2-18 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) – Response to Comment 18.
2-19 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) - Response to Comment 19.
2-20 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) - Response to Comment 20.
2-21 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) - Response to Comment 21.
2-22 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) - Response to Comment 22.
2-23 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) - Response to Comment 23.
2-24 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) - Response to Comment 24.
2-25 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) - Response to Comment 25.
2-26 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) - Response to Comment 26.
2-27 The commenter asserts that the IS/MND fails to analyze the Project’s fire flow requirement or the availability of existing infrastructure to supply adequate fire flow, and without an evaluation of these factors, the public utility impact remains unanalyzed and potentially significant. As stated on IS/MND page 99, “As part of the development review process, the LACFD Fire Prevention Division would review the proposed project site plan and determine if access and water system requirements, which would enhance the proposed development’s fire protection, are adequate.

Further, the Project would be required to comply with standard LACFD conditions of approval.

kimley-horn.com 1100 W Town and Country Road | Suite 700, Orange, CA 92868 714 939 1030 Specifically, the LACFD review addresses fire and life safety requirements for project construction at the fire plan check stage. This includes a review of the design details of the architectural, structural, mechanical, plumbing, and electrical systems. The Project would be required to comply with applicable City, County, and State code requirements for fire protection and be subject to pay any applicable fees. Municipal Code Chapter 15.14 adopts the Los Angeles County Fire Code by reference. Implementation of all Fire Code requirements would further reduce potential impacts concerning fire protection services.” As described in the IS/MND, the Project would implement applicable Fire Code requirements, which include requirements concerning fire flow.

The LACFD has reviewed the proposed project’s site plan and has determined that the project would meet City fire flow requirements.
2-28 This comment states the City lacks substantial evidence to support the reliance on an MND, and there is substantial evidence supporting a fair argument that an EIR must be prepared for the Project. The commenter urges the City to fulfill its responsibilities under CEQA by withdrawing the IS/MND and preparing an EIR to address the issues raised in the letter. As discussed in the above responses for Comment Letter No. 2, the MND fully disclosed and mitigated potentially significant impacts to less than significant levels, and that substantial evidence was used to support the analysis and conclusions of the Initial Study. Therefore, the preparation of an EIR is not required for the Project. This comment is noted for the record and will be forwarded to the decision-makers for their review and consideration.
2-29 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) - Response to Comment 29.
2-30 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) - Response to Comment 31.
2-31 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) - Response to Comment 31.
2-32 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) - Response to Comment 32.
2-33 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) - Response to Comment 33.

kimley-horn.com 1100 W Town and Country Road | Suite 700, Orange, CA 92868 714 939 1030 2-34 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) - Response to Comment 34.
2-35 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) - Response to Comment 35.
2-36 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) - Response to Comment 36.
2-37 See Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024 Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) - Response to Comment 37.

transportation ■ noise ■ air quality | GANDDINI GROUP
555 Parkcenter Drive, Suite 225, Santa Ana, CA 92705
(714) 795-3100 | ganddini.com

MEMORANDUM
TO: Dana Privitt | KIMLEY-HORN & ASSOCIATES, INC.

FROM: Roma Stromberg, Katie Wilson, Giancarlo Ganddini | GANDDINI GROUP, INC.

DATE: November 13, 2024
SUBJECT: Response to Adams Broadwell Joseph & Cardozo Comment Letter Dated October 30, 2024, Regarding IS/MND Technical Studies for the 2222 Rosemead Boulevard Warehouse Development
(GGI Project No. 19618)
On behalf of Coalition for Responsible Equitable Economic Development Los Angeles (CREED LA), the law firm of Adams Broadwell Joseph & Cardozo submitted a comment letter dated October 30, 2024 regarding the Initial Study/Mitigated Negative Declaration (IS/MND) for the proposed 2222 Rosemead Boulevard Warehouse Development project. This memorandum contains responses to comments relating to the technical studies prepared by Ganddini Group.

RESPONSE TO COMMENTS 1-3
These comments consist of introductory text, the project description, and legal standards. There are no comments relating to the technical studies prepared by Ganddini Group.

RESPONSE TO COMMENT 4
Part of this comment claims that the ITE Land Use Code 150 (Warehousing) “is just one of many land use codes potentially applicable to the Project, and does not reflect all reasonably foreseeable uses of the Project.” As noted on page 18 of the traffic impact analysis for the project (IS/MND Appendix F), ITE Land Use Code 150 was determined to adequately represent the warehousing component of the proposed project based on review of the ITE land use descriptions. The current edition of the ITE Trip Generation Manual (11th Edition) provides the following description for Land Use Code 150:
“A warehouse is primarily devoted to the storage of materials, but it may also include office and maintenance areas. High-cube transload and short-term storage warehouse (Land Use 154), high-cube fulfillment center warehouse (Land Use 155), high-cube parcel hub warehouse (Land Use 156), and high-cube cold storage warehouse (Land Use 157) are related uses.” Furthermore, at 156,877 square feet, the proposed project falls squarely within the range of data points used by ITE to establish the average trip rate for ITE Land Use Code 150.

The comment also provides a comparison to trip rates for other warehousing land uses, including Fulfillment Center Warehouse – Non-Sort, Cold Storage Warehouse, Parcel Hub Warehouse, and Fulfillment Center

Dana Privitt
KIMLEY-HORN & ASSOCIATES, INC.

November 13, 2024
2222 Rosemead Boulevard Warehouse Development Response to Adams Broadwell Joseph & Cardozo Comment Letter
2 19618
Warehouse – Sort. These land uses fall under the High-Cube Warehouse category (ITE Land Use Codes 154 through 157). ITE describes a high-cube warehouse as follows:
“A high-cube warehouse (HCW) is a building that typically has at least 200,000 gross square feet of floor area, has a ceiling height of 24 feet or more, and is used primarily for the storage and/or consolidation of manufactured goods (and to a lesser extent, raw materials) prior to their distribution to retail locations or other warehouses.”
Furthermore, the ITE data plots for the various high-cube warehousing land uses show that the average trip rates for these land use codes are derived from developments with a minimum of 200,000 square feet. At 156,877 square feet, the proposed project falls outside the range of data points. Therefore, comparison to trip rates for these other warehousing land uses (Fulfillment Center Warehouse – Non-Sort, Cold Storage Warehouse, Parcel Hub Warehouse, and Fulfillment Center Warehouse – Sort) is not appropriate since the ITE land use description and data plots are only applicable to warehousing buildings larger than 200,000 square feet and thus are not representative of the proposed project.

Additionally, per the Applicant, there will not be any cold storage at this facility and the building is not designed as such; therefore, an analysis of the facility as a refrigerated warehouse and analysis of emissions from TRUs is not warranted or required. The project can be conditioned to prohibit cold storage, if required, by the City Planning Department.

Based on the above, use of ITE Land Use Code 150 (Warehousing) as evaluated in the IS/MND provides the most conservative daily trip rate for trucks (0.6 daily truck trips per thousand square feet) when compared to other industrial ITE codes, except for high-cube cold-storage warehousing which is not proposed, and therefore represents the most conservative scenario when analyzing mobile source emissions.

RESPONSE TO COMMENT 5
This comment does not contain any issues relating to the technical studies prepared by Ganddini Group.

RESPONSE TO COMMENT 6
Per the project Applicant, there are no back-up generators in the approved design. The project includes an electrical fire pump and would only be used on an as-needed (emergency) basis. As the fire pump is electrical, there would be no emissions of criteria pollutants or toxic air contaminants. Any increase in the energy use from the emergency use of the electrical fire pump would be negligible. No additional analysis is warranted or required.

RESPONSE TO COMMENT 7
This comment does not contain any issues relating to the technical studies prepared by Ganddini Group.

RESPONSE TO COMMENT 8
This comment does not contain any issues relating to the technical studies prepared by Ganddini Group.

RESPONSE TO COMMENT 9
The commenter states that “the Office of Environmental Health Hazard Assessment’s (“OEHHA”) risk assessment guidelines also recommend a formal health risk analysis (“HRA”) for short-term construction

Dana Privitt
KIMLEY-HORN & ASSOCIATES, INC.

November 13, 2024
2222 Rosemead Boulevard Warehouse Development Response to Adams Broadwell Joseph & Cardozo Comment Letter
3 19618
exposures to TACs lasting longer than 2 months and exposures from projects lasting more than 6 months should be evaluated for the duration of the project.” This is a recommendation from OEHHA and the determination of whether or not to require the analysis of short-term construction HRAs is left up to discretion of the Air District. The SCAQMD leaves the decision up to the Lead Agency. Furthermore, as the project site is relatively small, 5.14 acres, the project will not be using a large amount of construction equipment at any one time.

Neither the City of South El Monte nor the SCAQMD require projects to conduct construction-related health risk assessments.

The SCAQMD has also commented on this project (see SCAQMD comment letter dated October 30th, 2024) and they have not requested or required that either a construction HRA or operational HRA be conducted for this project. As stated in response to comment 4 above, the trip generation analyzed for the project is correct.

The project will not have any cold storage facilities and will not have any TRUs. ITE code used in the Traffic Analysis for the ISMND would be most conservative since the project does not include cold storage (please see response to comment 4 above).

The ISMND does not fail to quantify sensitive receptors exposure to TACs and whether significance thresholds would be exceeded for the following reasons: As the project would generate only 89 truck trips per day, would not have cold storage or TRUs, and does not exceed the CAPCOA and CARB advisory recommendations to avod siting sensitive uses within 1,000 feet of distribution centers that have 100 or more trucks per day, a full dispersion-modeled (quantitative) HRA is not warranted or required. Furthermore, CARB’s recommendation is based on health studies and air quality modeling and monitoring studies (see pages 12-15 of the CARB 2005 Air Quality and Land Use Handbook: A Community Health Perspective. A project with less than 100 trucks would not exceed the 10 in a million threshold. Please see response to comment 6 regarding TAC-related impacts from generators and fire pumps.

As stated above, neither the City nor SCAQMD require a construction health risk assessment to quantify TACrelated impacts to sensitive receptors. SCAQMD have used the LST analysis to show whether there will be any local impacts to sensitive receptors. SCAQMD LST thresholds were created to ensure that local sources of emissions don’t create localized adverse air quality impacts. The project-specific LST analysis analyzes both PM10 and PM2.5 emissions emitted on-site. Diesel particulate matter (DPM) exhaust is a component of PM10 and PM2.5. As the project’s emissions do not exceed the SCAQMD LST thresholds, which are screening thresholds and are, per SCAQMD, conservative by design, that is, the predicted impacts tend to overestimate the actual impacts, the DPM component of PM10 and PM2.5 would also not cause any impacts and SCAQMD MICR thresholdswould also not be exceeded duirng construction or operation.

As stated above, SCAQMD have reviewed the analysis for the project, provided comments, but have not requested or required any additional toxic air contaminant (TAC) analysis.

For the reasons given above, sensitive receptors near the project site, including the mobile home park residents south of the site, would not be exposed to significant TAC-related health risks from construction activities and would not be exposed to significant lifetime (30-year) health risks during operation.

RESPONSE TO COMMENT 10
Please see response to comment 8 above addressing the CAPCOA guidance and the number of trucks that would trigger an HRA. The entry and exit points for the project site are located along Rosemead Boulevard and would not be in close proximity to the closest sensitive receptors, located south of the project boundary.

Please see the response to comment 8 above regarding construction HRAs. Furthermore, because the project

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would not exceed the 10 in a million threshold (see response to comment 9 above), the project would not result in an excess incremental cancer risk. SCAQMD have stated in their HRA Cumulative Threshold Working Group that “unless the cancer risk from a project is greater than 10 in a million, no further analysis of cumulative impacts from air toxics is required.”1
RESPONSE TO COMMENT 11
SCAQMD LST thresholds were created to ensure that local sources of emissions don’t create localized adverse air quality impacts. The project-specific LST analysis analyzes both PM10 and PM2.5 emissions emitted onsite. Diesel particulate matter (DPM) exhaust (the main source of TACs) is a component of PM10 and PM2.5.

As the project’s emissions do not exceed the SCAQMD LST thresholds, which are screening thresholds and are, per SCAQMD, conservative by design, that is, the predicted impacts tend to overestimate the actual impacts, the DPM component of PM10 and PM2.5 would also not cause any impacts. Construction-related DPM emissions and their significance is addressed on page 40 and 41 of the ISMND; operational TACs are addressed on page 40 of the ISMND.

As stated above, SCAQMD has reviewed the analysis for the project, provided comments, but has not requested or required any additional toxic air contaminant (TAC) analysis.

RESPONSE TO COMMENT 12
Please see response to comments 4, 8, 9, and 10 above. The analysis for the project meets SCAQMD and CEQA requirements for analysis and disclosure of impacts. No additional analyses are warranted or required.

RESPONSE TO COMMENT 13
Comment noted. This comment cites CEQA provisions and case law regarding cumulative impacts analysis but does not contain any specific issues relating to the technical studies prepared by Ganddini Group.

RESPONSE TO COMMENT 14
The project was evaluated for cumulative impacts per currently approved SCAQMD methodology. As the project is not significant on a project level, per SCAQMD guidance, the project will not contribute cumulatively considerable emissions either. In regards to TACs, as the project does not generate enough traffic to require a full operational HRA (see response to comments 4, 9, 10 and 11 above), then the project would not exceed the SCAQMD Maximum Incremental Cancer Risk (MICR) threshold of 10 in a million either, and no further analysis of cumulative impacts from air toxics is required.2 No additional analyses are warranted or required.

The CaEnviroscreen score of 78.4 for PM and 91.6 for DPM are included in the ISMND for informational purposes and are not associated with any cumulative thresholds.

RESPONSE TO COMMENT 15
See response to comment 14. Additionally, the Attorney General’s Guidance cites the 2019 CARB Concept Paper for Frieght Handbook, page 22, Table 5, where it states in the Local Governments and Air Districts column, that they are to “Establish screening criteria to evaluate a freight facility's contribution to a cumulatively considerable air quality impact including but not limited to identifying impacted areas, adopting local thresholds of significance, and developing standardized modeling parameters.” As mentioned previously 1 https://www.aqmd.gov/docs/default-source/ceqa/documents/wgm-6-20241106.pdf?sfvrsn=13. Slide 11. 2 https://www.aqmd.gov/docs/default-source/ceqa/documents/wgm-6-20241106.pdf?sfvrsn=13

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that the SCAQMD is in the process of developing cumulative thresholds, in their Cumulative Impacts from Air Toxics for CEQA Projects Working Group. As stated previously, in their latest meeting (#6) the Working Group has stated that “unless the cancer risk from a project is greater than 10 in a million, no further analysis of cumulative impacts from air toxics is required.” Please see response to comment 10.

RESPONSE TO COMMENT 16
See response to comment 15.

RESPONSE TO COMMENT 17
The ISMND included an energy analysis (see Section 6. Energy, pages 48 through 51 of the ISMND). The energy analysis for the project discusses and quantitatively analyzes (using CalEEMod) the project’s energy use during construction and operation and answers the threshold questions a) Would the Project result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during Project construction or operation? And b) Would the Project conflict with or obstruct a State or local plan for renewable energy or energy efficiency? There are no quantitative (numerical) thresholds for an energy analysis.The project will comply with current State and City requirements for energy efficient building standards and Green building standards. Fuel efficiency for project-related construction equipment and project-related vehicular traffic is regulated at the State level. The project is required to comply with State and local regulations for energy efficiency. Impacts are considered to be less than signficant. No further analysis is warranted or required.

RESPONSE TO COMMENT 17
The project does not have significant environmental impacts. See response to comment 15.

RESPONSE TO COMMENT 18
The commenter asserts that the MND’s energy analysis fails to investigate energy conservation measures and, therefore, violates CEQA. The commenter is incorrect. First, the MND adequately assesses whether the project would result in wasteful, inefficient, or unnecessary energy consumption. The analysis of that issue is not simply limited to whether a project incorporates energy conservation measures (none are suggested by the commenter), but collectively whether the project, based on its features, uses and design, would result in wasteful, inefficient, or unnecessary energy consumption. The MND considered those factors and concluded that the project would not unnecessarily use energy because (a) the project would comply with the requirements of the California Building Code, which includes robust energy efficient measures (including, now, solar mandates – a form of renewable energy), (b) state regulations related to industrial uses, and (c) whether the project would use energy in a manner inconsistent with expectations. As compared to similar projects, the project would not unnecessarily or wastefully use energy. Also, as discussed above, the current CBC includes more robust provisions to ensure energy efficiency (than were in existence at the time the CEQA analyses in cases cited by commenter were completed [). CBC Section 140.0 establishes both performance and prescriptive compliance approaches to energy efficient for non-residential buildings. Each approach, as outlined in the CBC, requires a project to demonstrate energy efficiency for proposed buildings. The prescriptive approach, for instance, identifies multiple requirements to ensure energy efficiency, such as solar reflectance, PV and battery storage requirements, skylights and daylighting requirements, space conditioning controls, and water heating and indoor lighting, among other things. Thus, the updated CBC includes many of the concepts identified by commenter, including solar facilities, passive energy efficient measures, and

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building design considerations.3 Moreover, with each iteration of the CBC (updated every three years), the CBC’s mandates exponentially increase efficiency. The MND concluded that these measures ensure the project would not result in wasteful, inefficient, or unnecessary energy use, and also reflect the considerations identified in CEQA Guidelines Appendix F. Thus, no discussion of mitigation is required. (CEQA Guidelines § 15126.4(a)(1)(C) [measures shall be discussed “when relevant”].) The MND properly evaluates potential energy impacts and commenter presents no evidence that an energy impact may result.

RESPONSE TO COMMENT 19
See response to comment 18.

RESPONSE TO COMMENT 20
The project does not have significant environmental impacts. See response to comment 17.

RESPONSE TO COMMENT 21
See reponses to comments 17 through 20 above. No additional energy analyses are warranted or required.

RESPONSE TO COMMENT 22
See reponses to comments 17 through 20 above. No additional energy analyses are warranted or required.

RESPONSE TO COMMENT 23
The core point of this comment is that the IS/MND fails to fully mitigate the Project’s significant VMT impact.

First, the comment claims that the IS/MND incorrectly reports the project-generated VMT as 16.4 VMT per worker. Appendix H of the traffic impact analysis for the project (IS/MND Appendix F) contains the SGVCOG VMT Evaluation Tool Report used to assess the project’s VMT impacts in accordance with the City of South El Monte methodology. As shown on the SGVCOG VMT Evaluation Tool Report (page Apx-104), the proposed project is estimated to generate 16.4 VMT per worker. The comment claims that the correct project-generated VMT value should be 16.5; however, this is incorrectly based on the “without project” value.

Next the comment claims that the 4.0% VMT reduction associated with mitigation measure TRANS-1 (implementation of a commute trip reduction program) is unsupported because such measures “would not apply to project workers during night shifts, resulting in lower reductions.” The supporting “Marshall Comments” letter claims that there will be some regular employees who work nighttime hours when transit and rideshare services are not available and who therefore should be excluded from the percentage of employees eligible for the commute trip reduction program. Mitigation measure TRANS-1 requires that the commute trip reduction program be provided to City of South El Monte Public Works Department prior to project occupancy. Depending on the tenant-specific needs, the Public Works Department may require the commute trip reduction program to include trip reduction measures that are applicable to nighttime workers, such as services or incentives that encourage walking, biking, and carpooling, all of which would be available even when transit services are not. Therefore, MM-TRANS-1 enables the City to ensure the voluntary commute trip reduction program includes components that are applicable to 100% of employees. 3 The California Energy Commission’s website for Title 24 explains that the Building Energy Efficiency Standards (part of the CBC) “serve to reduce wasteful, uneconomical, and unnecessary uses of energy for the state.” See also https://www.energy.ca.gov/sites/default/files/2021-08/CEC_2022_EnergyCodeUpdateSummary_ADA.pdf.

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Lastly, the comment claims that mitigation measure TRANS-1 insufficiently reduces the project-generated VMT to 15.84 VMT per worker, which still exceeds the threshold value of 15.8. This calculation is based on rounding precision that is not supported by the SGVCOG VMT Evaluation Tool. As shown on the SGVCOG VMT Evaluation Tool Report (page Apx-104), the project VMT is reported with a precision of one decimal point. Therefore, calculating the VMT reduction to two decimal points inappropriately adds a significant digit.

Furthermore, the project-generated VMT value noted by the commenter appears to be calculated based on the incorrect baseline VMT value of 16.5 for “without project.” As explained above, the correct projectgenerated VMT value is 16.4 VMT per worker. Therefore, VMT calculations have been verified to be correct and the project’s VMT impact is fully mitigated as documented by the SGVCOG VMT Evaluation Tool Report provided in Appendix H of the traffic impact analysis for the project (IS/MND Appendix F).

RESPONSE TO COMMENT 24
The IS/MND does apply the correct noise standards in the municipal code. Although the City ordinance does not outright exempt construction noise from compliance with the numerical standards presented in Table 1 Exterior Noise Limits by Zone, it is quite clear that that a sound level limit of 55 dBA for construction activity would be unreasonable, as 55 dBA is half as loud as normal conversation (65 dBA). Further, the City Planning Manager, Gerado Marquez has provided the following clarification regarding the implementation of City Ordinance 8.20.020 and 8.20.030. The email correspondence is attached. “The intent of the code is to regulate any type of construction noise during times that would not customarily have construction activities taking place. To clarify the code section 8.20.030(D) is meant to prohibit the omission of construction noises between 10:00 pm and 7:00 am. It was not the intent of the City to regulate construction noise outside of that time. With that said code enforcement officers would only respond to noise complaints based on the verbage of the municipal code that calls for prohibited acts. 8.20.030.”
The intent of the code is to regulate any type of construction noise during times that would not customarily have construction activities taking place. To clarify, the code section 8.20.030(D) is meant to prohibit the omission of construction noises between 10:00 PM and 7:00 AM and it was not the intent of the City to regulate construction noise outside of that time. It should also be noted that the City has consistently interpreted and applied section 8.20.030(D) as an exemption for construction noise from the noise standards applicable to other, non-construction sources (section 8.20.020). The approved Starlite Residential Development MND, for instance, recognized that section 8.20.030(D) exempted construction noise occurring during the hours specified.

This is not to say that construction noise impacts were not evaluated quantitatively, in absence of a City adopted quantitative noise threshold for construction noise that occurs during daytime hours, which are exempt from the Exterior Noise Standards in Table 1, construction noise was evaluated using widely accepted Federal Transit Administration (FTA) methodologies and significance thresholds found in the Transit Noise and Vibration Impact Assessment Manual (2018). Specifically, construction noise levels were modeled for all expected pieces of equipment by phase and the threshold applied was an eight-hour Leq at residential land uses. Project construction noise levels were found to be less than significant. The same analysis (utilizing the FTA’s noise standard) is regularly used by the City to evaluate potential construction noise impacts, including for the approved Starlite Residential Development MND. The FTA Manual notes that “[g]enerally local noise ordinances are not very useful for evaluating construction noise impact. They usually relate to nuisance and hours of allowed activity, and sometimes specify limits in terms of maximum levels, but are generally not practical for assessing the impact of a construction project.” “While it is not the purpose of this manual to specify standardized criteria for construction noise impact, the following guidelines can be considered

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reasonable criteria for assessment. If these criteria are exceeded, there may be adverse community reaction.” Thus, the City’s use of the FTA thresholds is reasonable and supported by substantial evidence. As stated in page 1 of the technical noise study prepared for the project, 4 even though project impacts would be less than
significant the following Best Management Practices (BMPs) are included on project plans and will be adopted as Conditions of Approval.

1. All equipment, whether fixed or mobile, will be equipped with properly operating and maintained mufflers, consistent with manufacturer standards.

2. All stationary construction equipment will be placed so that emitted noise is directed away from the noise sensitive receptors nearest the project site.

3. As applicable, all equipment shall be shut off and not left to idle when not in use.

4. To the degree possible, equipment staging will be located in areas that create the greatest distance between construction-related noise and vibration sources and existing sensitive receptors.

5. All other portable stationary noise sources will be directed away and shielded from existing residences in the vicinity of the project site. Either one-inch plywood or sound blankets can be utilized for this purpose. They should reach up from the ground and block the line of sight between equipment and existing residences. The shielding should be without holes and cracks.

6. No amplified music and/or voice will be allowed on the project site.

7. Haul truck deliveries will not occur outside of the hours presented as exempt for construction per City of South El Monte Municipal Code Section 8.20.030(D).

RESPONSE TO COMMENT 25
Regarding the argument that the magnitude of an increase was not considered: measured daytime noise levels in the project vicinity range between 54.1 and 72.3 dBA Leq and modeled project operational noise is expected to range between 31 and 54 dBA Leq without mitigation. When adding two of the same noise levels, the resulting 3 dBA increase is considered a barely perceptible increase (per Caltrans Technical Noise Supplement to the Traffic Noise Analysis Protocol). Operational noise levels without mitigation would not exceed existing daytime ambient noise levels (see MND Appendix E – Noise Impact Analysis, Table 12); therefore, the projectrelated noise level change would not exceed a barely perceptible increase of 3 dBA and the project impact is less than significant. The project’s daytime noise would be even less with proposed Mitigation Measure NOI1. During the quietest nighttime hour, noise levels at the single-family residential south of the project site were measured at 44.4 dBA (see MND Appendix E – Noise Impact Analysis, Table 12) and mitigated project operational noise would not exceed 45 dBA at this receptor, well below the 50 dBA noise standard. Also, the project-related noise level change is considered barely perceptible at an approximately 3 dBA increase (which would also remain below the applicable 50 dBA standard) and the project impact is less than significant.

Notwithstanding the above, with mitigation, the MND concluded that operational noise would not result in a significant impact because it would not exceed applicable standards. California courts have upheld an analysis that is based in applicable standards. (Mount Shasta Bioregional Ecology Center v. County of Siskiyou (2012) 210 Cal.App.4th 184, 205-207.) The finding of a less than significant impact is supported by compliance with the applicable plans, policies and ordinances.
4 Rosemead and Rush Industrial Project Noise Impact Analysis. Ganddini Group Inc., June 15, 2023.

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Further, regarding the referenced case Keep our Mountains Quiet v. County of Santa Clara was decided in 2015. Revisions made to the California Environmental Quality Act (CEQA) Appendix G checklist questions that were made in 2018 revised the previously ambiguous CEQA checklist question as to what qualifies as a substantial increase in noise levels. The clarification that was added to the CEQA checklist question was to add the underlined text below.
“Would the project generate a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?
Also, the commentor does not provide substantial evidence or make a fair argument that operational noise would result in substantial increases in noise levels under this threshold. The referenced case law determines that “Relevant personal observations of area residents on nontechnical subjects may qualify as substantial evidence.” (Pocket Protectors v. City of Sacramento (2004) 124 Cal.App.4th 903, 928, 21 Cal.Rptr.3d 791.) “For example, an adjacent property owner may testify to traffic conditions based upon personal knowledge.” (Citizens Assn. for Sensible Development of Bishop Area v. County of Inyo (1985) 172 Cal.App.3d 151, 173, 217 Cal.Rptr. 893.). However, no relevant observations have been provided that would challenge the validity of the operational noise modeling.

Furthermore, the case that is referenced repeatedly and that other case law builds upon (Berkeley Keep Jets Over the Bay Com. v. Board of Port Cmrs. (2001) 91 Cal.App.4th 1344, 111 Cal.Rptr.2d 598) does not apply to the proposed project. This case is in relation to the use of a 24-hour weighted noise standard (CNEL) for aircraft noise. Use of the weighted CNEL can easily mask relatively short noise events associated with aircraft flyovers that wake residents from sleep. However, the City applies shorter, more appropriate noise standards for stationary noise sources that may impact other nearby land uses. In this case, the City is applying appropriate criteria and additional criteria is not necessary.

To the extent the commenter is asserting that construction noise should have been assessed using an ambient increase standard, the commenter is incorrect. As discussed above, the FTA Manual’s thresholds are reflective of the limited duration of temporary construction activities and the fact that construction is a common component of the urban environment. The City regularly issues building permits for construction within the City, which is mostly built-out with existing and new developments in close proximity. Thus, the use of the FTA thresholds accounts for reasonable expectations during daytime and nighttime hours and also include absolute noise levels that are intended to protect human health.

RESPONSE TO COMMENT 26
See response to comment 24 and 25.

RESPONSE TO COMMENT 27
These comments are related to public facilities. This comment does not contain any issues relating to the technical studies prepared by Ganddini Group.

RESPONSE TO COMMENT 28
These comments consist of conclusory text. This comment does not contain any issues relating to the technical studies prepared by Ganddini Group.

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(EXHIBIT A – NORMAN MARSHALL LETTER)
RESPONSE TO COMMENT 29
This comment summarizes the findings of the review, including claims that the project trip generation and truck trip generation could be higher than assumed, the project VMT is incorrectly reported, and that the proposed mitigation measure is insufficient. These claims are refuted in response to the more specific comments below.

RESPONSE TO COMMENT 30
See Response to Comment 4. As noted in Response to Comment 4, comparison to high-cube warehouse trip generation rates is not applicable to the proposed project based on the ITE land use descriptions and data plots. Per the Applicant, there will not be any cold storage at this facility and the building is not designed as such; therefore, an analysis of the facility as a refrigerated warehouse and analysis of emissions from TRUs is not warranted or required. The project can be conditioned to prohibit cold storage, if required, by the City Planning Department.

RESPONSE TO COMMENT 31
This comment claims that the truck trip generate rate used in the MND is lower than the rates for some warehouse types and provides cold storage warehouse as an example; however, the cold storage warehouse example provided is based on rates for ITE Land Use Code 157 (High-Cube Cold Storage Warehouse). The comment claims that a toxic air contaminant analysis should be prepared since the project truck trip generation would exceed 100 trips per day for the cold storage warehouse use provided as an example.

As noted in Response to Comment 4, comparison to high-cube warehouse trip generation rates is not applicable to the proposed project based on the ITE land use descriptions and data plots.

As also noted in Response to Comment 4, per the Applicant, there will not be any cold storage at this facility and the building is not designed as such; therefore, an analysis of the facility as a refrigerated warehouse and analysis of emissions from TRUs is not warranted or required. The project can be conditioned to prohibit cold storage, if required, by the City Planning Department.

As also noted in Response to Comment 4, use of ITE Land Use Code 150 (Warehousing) as evaluated in the IS/MND provides the most conservative daily trip rate for trucks (0.6 daily truck trips per thousand square feet) when compared to other industrial ITE codes, except for high-cube cold-storage warehousing which is not proposed. Therefore, the project truck trip generation would not exceed 100 truck trips per day and TAC impacts would be less than significant.

RESPONSE TO COMMENT 32
The comment incorrectly claims there is a discrepancy between the MND and the VMT Evaluation Tool.

Appendix H of the traffic impact analysis for the project (IS/MND Appendix F) contains the SGVCOG VMT Evaluation Tool Report used to assess the project’s VMT impacts in accordance with the City of South El Monte methodology. As shown on the SGVCOG VMT Evaluation Tool Report (page Apx-104), the proposed project is estimated to generate 16.4 VMT per worker. The comment claims that the correct project-generated VMT value should be 16.5; however, this is incorrectly based on the “without project” value. Therefore, there is no discrepancy between the MND and VMT Evaluation Tool results.

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RESPONSE TO COMMENT 33
The comment correctly notes a minor discrepancy on page 104 of the MND, which refers to implementation of a Commute Trip Reduction Marketing/Education Program, whereas the formal description of MM-TRANS1 on page 105 of the MND requires implementation of a voluntary commute trip reduction program (CTR).

The comment correctly notes that CAPCOA Measure T-7 is a component of CAPCOA Measure T-5 and the MND is proposing implementation of a voluntary commute trip reduction program consistent with CAPCOA Measure T-5.

RESPONSE TO COMMENT 34
The comment claims that a 4.0% VMT reduction associated with the proposed MM-TRANS-1 insufficiently reduces the project-generated VMT to 15.84 VMT per worker, which still exceeds the threshold value of 15.8.

This calculation is based on rounding precision that is not supported by the SGVCOG VMT Evaluation Tool.

As shown on the SGVCOG VMT Evaluation Tool Report (page Apx-104), the project VMT is reported with a precision of one decimal point. Therefore, calculating the VMT reduction to two decimal points inappropriately adds a significant digit. Furthermore, the project-generated VMT value noted by the commenter appears to be calculated based on the incorrect baseline VMT value of 16.5 for “without project.” As explained above, the correct project-generated VMT value is 16.4 VMT per worker. Therefore, VMT calculations have been verified to be correct and the project’s VMT impact is fully mitigated as documented by the SGVCOG VMT Evaluation Tool Report provided in Appendix H of the traffic impact analysis for the project (IS/MND Appendix F).

RESPONSE TO COMMENT 35
The comment claims that the 4.0% VMT reduction associated with MM-TRANS-1 is unsupported because there will be some regular employees who work nighttime hours when transit and rideshare services are not available and who therefore should be excluded from the percentage of employees eligible for the commute trip reduction program. MM-TRANS-1 requires that the commute trip reduction program be provided to City of South El Monte Public Works Department prior to project occupancy. Depending on the tenant-specific needs, the Public Works Department may require the commute trip reduction program to include trip reduction measures that are applicable to nighttime workers, such as services or incentives that encourage walking, biking, and carpooling, all of which would be available even when transit services are not. Therefore, MM-TRANS-1 enables the City to ensure the voluntary commute trip reduction program includes components that are applicable to 100% of employees.

RESPONSE TO COMMENT 36
The comment correctly notes that the CAPCOA Handbook precludes taking separate reductions for CAPCOA Measures T-5 and T-7. The comment incorrectly claims that CAPCOA Measure T-5 provides insufficient VMT mitigation and suggests implementation of CAPCOA Measure T-6 - Implement Commute Trip Reduction Program (Mandatory Implementation and Monitoring).

VMT reductions were calculated using the SGVCOG VMT Evaluation Tool in accordance with City of South El Monte guidelines and is the tool used by most, if not all, of the 27 jurisdictions within the San Gabriel Valley Council of Governments. While the tool adapts much of the guidance and supporting evidence from the CAPCOA Handbook, each reduction measure includes direct citations to source materials and the tool is not relegated to the CAPCOA Handbook.

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Additionally, the project’s VMT reduction calculation does not combine reduction credits for measures T-5 and T-7. As shown on the SGVCOG VMT Evaluation Tool Report (IS/MND Appendix F, page Apx-105 and Apx-106), the VMT reductions applied consist of SGVCOG VMT Evaluation Tool measures PK02 (Provide Bicycle Parking Facilities) and TP04 (CTR Marketing and Education). Measure PK02 was applied as a project design feature based on nine (9) bicycle parking spaces proposed. TP04 consists of commute trip reduction marketing/education, which is only one component of the more robust requirements in MM-TRANS-1.

Therefore, the project’s VMT impact is sufficiently mitigated with implementation of MM-TRANS-1; no additional mitigation is necessary to reduce the project’s impact to a less than significant level.

RESPONSE TO COMMENT 37
This comment claims that the TDM program required for project VMT reduction should be prepared now and included in the EIR for public review to ensure the TDM measures will reduce VMT to less than significant levels. The comment also claims that the TDM program must go beyond CAPCOA Measure T-5.

This comment omits the full text of MM-TRANS-1 which specify additional requirements of the TDM program, including that the program must include the following elements:
▪ Employer-provided services, infrastructure, and incentives for alternative modes such as ridesharing, discounted transit, bicycling, vanpool, and guaranteed ride homes. ▪ Information, coordination, and marketing for said services, infrastructure, and incentives.

Therefore, MM-TRANS-1 sufficiently outlines requirements of the TDM program necessary to achieve the VMT reduction associated with a voluntary commute trip reduction program as supported by the guidance for Measure T-5 of the CAPCOA Handbook. To achieve maximum efficacy, the commute trip reduction program should be tailored to tenant-specific needs and characteristics. Thus, the TDM program is best-suited to be prepared prior to tenant occupancy at which time tenant-specific needs and characteristics can be taken into consideration. MM-TRANS-1 enables the Public Works Department to ensure the program sufficiently complies with the requirements of MM-TRANS-1.

The TDM program does not require additional measures beyond those specified in MM-TRANS-1 to sufficiently mitigate the project’s VMT impact to less than significant levels; see Response to Comment 36.

CONCLUSION
We appreciate the opportunity to assist you on this project. Should you have any questions or if we can be of further assistance, please contact us at 714-795-3100.

Respectfully submitted,
GANDDINI GROUP, INC.

Giancarlo Ganddini
Principal Traffic Engineer
Roma Stromberg, MS
Senior Noise Analyst
Katie Wilson, MS
Senior Air Quality Analyst

kimley-horn.com 1100 W Town and Country Road | Suite 700, Orange, CA 92868 714 939 1030 RESPONSE TO COMMENT LETTER 3
Patricia Horsley, Environmental Planner, Facilities Planning Department, Los Angeles County Sanitation Districts, October 28, 2024.
3-1 This comment introduces the Los Angeles County Sanitation Districts’ (Districts) response to the Project’s Notice of Intent. This comment does not address the IS/MND’s adequacy or raise a significant environmental issue. As such, no further response is necessary. 3-2 This comment notes that the wastewater flow originating from the proposed project would discharge to a local sewer line, which is not maintained by the Districts for conveyance to the Districts’ Rush Street Trunk Sewer, located in Rush Street at Rosemead Boulevard. The Districts’ 15-inch diameter trunk sewer has a capacity of 1.4 million gallons per day (mgd) and conveyed a peak flow of 1.0 mgd when last measured in 2013. This comment is acknowledged and does not address the IS/MND’s adequacy or raise a significant environmental issue. As such, no further response is necessary.
3-3 This comment states that the expected average wastewater flow from the project is 8,066 gallons per day and provides a link to the District’s average wastewater generation factors. The ISMND analyzed an average wastewater flow of 10,095 gallons per day for the project and concluded that sufficient capacity exists at existing facilities to treat the project’s wastewater. This comment is acknowledged and does not address the IS/MND’s adequacy or raise a significant environmental issue. As such, no further response is necessary.
3-4 This comment states that the wastewater generated by the proposed project will be treated at the Whittier Narrows Water Reclamation Plant (WRP) located near the City of South El Monte, which has a capacity of 15 mgd and currently processes an average recycled flow of 9 mgd, or at the Los Coyotes WRP located in the City of Cerritos, which has a capacity of 37.5 mgd and currently processes an average recycled flow of 19.1 mgd. This comment is acknowledged and does not change the IS/MND’s analysis concerning adequate wastewater treatment capacity to serve the project’s projected demand in addition to the provider’s existing commitments and impacts would remain less than significant.
3-5 This comment provides information regarding the Districts’ connection fees. This comment does not address the IS/MND’s adequacy or raise a significant environmental issue. As such, no further response is necessary.
3-6 This comment provides background information concerning the Districts’ wastewater treatment facility capacities. This comment does not address the IS/MND’s adequacy or raise a significant environmental issue. As such, no further response is necessary.

kimley-horn.com 1100 W Town and Country Road | Suite 700, Orange, CA 92868 714 939 1030 RESPONSE TO COMMENT LETTER 4
Sam Wang, Program Supervisor, CEQA IGR, South Coast Air Quality Management District, October 30, 2024.
4-1 See Response to SCAQMD Letter Dated October 30, 2024 Regarding the IS/MND for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) 4-2 See Response to SCAQMD Letter Dated October 30, 2024 Regarding the IS/MND for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) 4-3 See Response to SCAQMD Letter Dated October 30, 2024 Regarding the IS/MND for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618) 4-4 See Response to SCAQMD Letter Dated October 30, 2024 Regarding the IS/MND for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618)

transportation ■ noise ■ air quality | GANDDINI GROUP
555 Parkcenter Drive, Suite 225, Santa Ana, CA 92705
(714) 795-3100 | ganddini.com

MEMORANDUM
TO: Dana Privett | KIMLEY-HORN & ASSOCIATES, INC.

FROM: Katie Wilson | GANDDINI GROUP, INC.

DATE: November 7, 2024
SUBJECT: Response to SCAQMD Letter Dated October 30, 2024 Regarding the IS/MND for the 2222 Rosemead Boulevard Warehouse Development
(GGI Project No. 19618)
The South Coast Air Quality Management District (SCAQMD) submitted a comment letter dated October 30, 2024, regarding the Initial Study/Mitigated Negative Declaration (IS/MND) for the proposed 2222 Rosemead Boulevard Warehouse Development project. This memorandum contains responses to the comments received from SCAQMD.

COMMENT 1
Warehouse Cold Storage Land Use and the Associated Emissions from Transport Refrigeration Units (TRU)
The project description in the MND does not specify whether the Proposed Project includes allocating warehouse land for cold storage. Cold storage warehouses typically utilize more trucks and trailers equipped with TRUs compared to those without cold storage. Therefore, it is recommended that the Lead Agency revise the project description in the Final MND to clarify if cold storage would be a part of the Proposed Project, and additionally, the Final MND should provide an estimate for the number of TRU trucks and trailers that would be involved in the operation of the warehouses with cold storage. If TRUs are planned to be used, the Lead Agency should also update the emissions calculations in the Final MND to include the emissions from the TRUs in addition to the those from truck operation.

RESPONSE
Within Section 2.0 Project Description under the subheading Section 2.4 Project Characteristics of the IS/MND, it is stated that the project does not proposed refrigeration as part of the warehouse operations.

Therefore, no additional emissions calculations or other revisions are needed regarding warehouse cold storage.

COMMENT 2
Rule 2305: Warehouse Indirect Source Rule - Warehouse Actions and Investments To Reduce Emissions (WAIRE) Program
On May 7, 2021, South Coast AQMD’s Governing Board adopted Rule 2305 – Warehouse Indirect Source Rule – Warehouse Actions and Investments to Reduce Emissions (WAIRE) Program, and Rule 316 – Fees for Rule 2305.

Rules 2305 and 316 are new rules that will reduce regional and local emissions of nitrogen oxides (NOx) and

Dana Privett
KIMLEY-HORN & ASSOCIATES, INC.

November 7, 2024
2222 Rosemead Boulevard Warehouse Development
Response to SCAQMD Letter Dated October 30, 2024
2 19618
particulate matter (PM), including diesel PM. These emission reductions will reduce public health impacts for communities located near warehouses from mobile sources that are associated with warehouse activities. Also, the emission reductions will help the region attain federal and state ambient air quality standards. Rule 2305 applies to owners and operators of warehouses greater than or equal to 100,000 square feet. Under Rule 2305, operators are subject to an annual WAIRE Points Compliance Obligation that is calculated based on the annual number of truck trips to the warehouse. WAIRE Points can be earned by implementing actions in a prescribed menu in Rule 2305, implementing a site-specific custom plan, or paying a mitigation fee. Warehouse owners are only required to submit limited information reports, but they can opt in to earn Points on behalf of their tenants if they so choose because certain actions to reduce emissions may be better achieved at the warehouse development phase, for instance the installation of solar and charging infrastructure. Rule 316 is a companion fee rule for Rule 2305 to allow South Coast AQMD to recover costs associated with Rule 2305 compliance activities. Since the Proposed Project consists of the development of a 643,419 square foot warehouse, the Proposed Project’s warehouse owners and operators will be required to comply with Rule 2305 once the warehouse is occupied. Therefore, South Coast AQMD staff recommends that the Lead Agency review South Coast AQMD Rule 2305 to determine the potential WAIRE Points Compliance Obligation for future operators and explore whether additional project requirements and CEQA mitigation measures can be identified and implemented at the Proposed Project that may help future warehouse operators meet their compliance obligation.
1 South Coast AQMD staff is available to answer questions concerning Rule 2305 implementation and compliance by phone or email at (909) 396-3140 or [email protected]. For implementation guidance documents and compliance and reporting tools, please visit South Coast AQMD’s WAIRE Program webpage.2

RESPONSE
The project proposes to construct an approximately 156,877 square foot concrete tilt-up warehouse and 13 dock doors. Of the 156,877 square feet, the project would have 113,703 square feet of warehouse space, 7,879 square feet of retail use, 20,305 square feet of accessory warehouse office use, and 14,990 square feet of warehouse storage. As the project includes over 100,000 thousand square feet of warehouse use, it will be required to comply with Rule 2305 once occupied. As this comment is a recommendation, it is up to the project applicant to decide whether, at this time, they want to determine the potential WAIRE points and compliance obligations of the warehouse to identify any potential measures that can be implemented at this stage of the project in order to assist the future warehouse operators in meeting compliance with Rule 2305.

Compliance with Rule 2305 is required and can be part of the City’s Conditions of Approval for the project.

COMMENT 3
South Coast AQMD Air Permits and Role as a Responsible Agency If the implementation of the Proposed Project would require the use of new stationary and portable sources, including but not limited to emergency generators, fire water pumps, boilers, spray booths, and etc., air permits from South Coast AQMD will be required and the role of South Coast AQMD would change from a Commenting Agency to a Responsible Agency under CEQA. In addition, if South Coast AQMD is identified as a Responsible Agency, per CEQA Guidelines Sections15086, the Lead Agency is required to consult with South Coast AQMD. In addition, CEQA Guidelines Section 15096 sets forth specific procedures for a Responsible Agency, including making a decision on the adequacy of the CEQA document for use as part of evaluating the applications for air permits. For these reasons, the Final MND should include a discussion about any new stationary and portable equipment requiring South Coast AQMD air permits and identify South Coast AQMD as a Responsible Agency for the Proposed Project. 1 South Coast AQMD Rule 2305 – Warehouse Indirect Source Rule – Warehouse Actions and Investments to Reduce Emissions (WAIRE) Program. Accessed at: http://www.aqmd.gov/docs/default-source/rule-book/reg-xxiii/r2305.pdf. 2 South Coast AQMD WAIRE Program. Accessed at: http://www.aqmd.gov/waire.

Dana Privett
KIMLEY-HORN & ASSOCIATES, INC.

November 7, 2024
2222 Rosemead Boulevard Warehouse Development
Response to SCAQMD Letter Dated October 30, 2024
3 19618
The Final MND should also include calculations and analyses for construction and operation emissions for the new stationary and portable sources, as this information will also be relied upon as the basis for the permit conditions and emission limits for the air permit(s). Please contact South Coast AQMD’s Engineering and Permitting staff at (909) 396-3385 for questions regarding what types of equipment would require air permits. For more general information on permits, please visit South Coast AQMD’s webpage at: http://www.aqmd.gov/home/permits.

RESPONSE
Per the project Applicant, there are no back-up generators in the approved design. The project includes an electrical fire pump and would only be used on an as-needed (emergency) basis. As the fire pump is electrical, there would be no emissions of criteria pollutants or toxic air contaminants. Any increase in the energy use from the emergency use of the electrical fire pump would be negligible. No additional analysis is warranted or required.

CONCLUSION
We appreciate the opportunity to assist you on this project. Should you have any questions or if we can be of further assistance, please contact us at 714-795-3100.

Respectfully submitted,
GANDDINI GROUP, INC.

Katie Wilson, M.S.

Senior Air Quality Analyst

kimley-horn.com 1100 W Town and Country Road | Suite 700, Orange, CA 92868 714 939 1030 RESPONSE TO COMMENT LETTER 5
Anthony Higgins, Acting LDR Branch Chief, California Department of Transportation – District 7, November 5, 2024.

Comments 5-1 through 5-6: See Response to Caltrans Letter Dated November 5, 2024 Regarding the IS/MND for the 2222 Rosemead Boulevard Warehouse Development (GGI Project No. 19618)

transportation ■ noise ■ air quality | GANDDINI GROUP
555 Parkcenter Drive, Suite 225, Santa Ana, CA 92705
(714) 795-3100 | ganddini.com

MEMORANDUM
TO: Dana Privett | KIMLEY-HORN & ASSOCIATES, INC.

FROM: Giancarlo Ganddini | GANDDINI GROUP, INC.

DATE: November 7, 2024
SUBJECT: Response to Caltrans Letter Dated November 5, 2024 Regarding the IS/MND for the 2222 Rosemead Boulevard Warehouse Development
(GGI Project No. 19618)
The California Department of Transportation (Caltrans) submitted a comment letter dated November 5, 2024, regarding the Initial Study/Mitigated Negative Declaration (IS/MND) for the proposed 2222 Rosemead Boulevard Warehouse Development project. This memorandum contains responses to the comments received from Caltrans.

COMMENT 1
Dear Gerardo Marquez:

Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the above referenced environmental document. The Project would result in the construction of an approximately 156,877-square-foot (sf) concrete tilt-up warehouse with 13 dock doors. Of the 156,877 sf, the Project would have 113,703 sf of warehouse space, 7,879 sf of retail use, 20,305 sf of accessory warehouse office use, and 14,990 sf of warehouse storage. The proposed warehouse would be at a maximum height of 48 feet 10 inches and have a site coverage of approximately 55 percent with a Floor-Area Ratio of 0.7. Access to the site would be from two driveways on Rosemead Boulevard.

The mission of Caltrans is to provide a safe and reliable transportation network that serves all people and respects the environment. Senate Bill 743 (2013) has codified into CEQA law and mandated that CEQA review of transportation impacts of proposed development be modified by using Vehicle Miles Traveled (VMT) as the primary metric in identifying transportation impacts for all future development projects. You may reference the Governor’s Office of Planning and Research (OPR) for more information:
https://opr.ca.gov/ceqa/#guidelines-updates
As a reminder, VMT is the standard transportation analysis metric in CEQA for land use projects after July 1, 2020, which is the statewide implementation date.

RESPONSE
This comment consists of introductory text, the project description, and information regarding current CEQA provisions requiring the evaluation of VMT. This comment does not contain any issues relating to the technical studies prepared by Ganddini Group.

Dana Privett
KIMLEY-HORN & ASSOCIATES, INC.

November 7, 2024
2222 Rosemead Boulevard Warehouse Development
Response to Caltrans Letter Dated November 5, 2024
2 19618
COMMENT 2
Caltrans is aware of challenges that the region faces in identifying viable solutions to alleviating congestion on State and Local facilities. With limited room to expand vehicular capacity, this project should incorporate multi-modal and complete streets transportation elements that will actively promote alternatives to car use and better manage existing parking assets. Prioritizing and allocating space to efficient modes of travel such as bicycling and public transit can allow streets to transport more people in a fixed amount of right-of-way.

Caltrans encourages city planning that promotes complete streets and pedestrian safety through measures like road diets, recognized for enhancing safety and being cost-effective when combined with street resurfacing. City planning should focus on reducing single-occupancy vehicle trips, improving safety, lowering vehicle miles traveled (VMT), and cutting greenhouse gas emissions.

RESPONSE
This comment consists of general recommendations for the City’s consideration with respect to multi-modal planning and reducing VMT. This comment does not contain any issues relating to the technical studies prepared by Ganddini Group; no additional response is necessary.

COMMENT 3
The project site is served by LA Metro Routes 266 and 287, with bus stops on both sides of Rosemead Boulevard, approximately 400 feet north of the site. Further transit access is available via the El Monte Station/San Bernardino Freeway Busway at 3501 Santa Anita Avenue, providing connections to Metrolink, regional transit, carpools, and vanpools. Sidewalks along Rosemead Boulevard will remain intact, preserving pedestrian access. There are no bicycle facilities adjacent to the project site. The project site will include bike racks to accommodate cyclists. Given the industrial nature of the proposed use, the project’s VMT per worker (16.4) exceeds the city threshold of 15.83, necessitating MM TRANS-1, a Commute Trip Reduction Marketing/Education Program, to mitigate VMT impacts to a level of 15.80 VMT per worker, meeting the established criteria for significance.

MM TRANS-1 is a mitigation requirement that, before the first occupancy permit is issued, the Applicant submits a Transportation Demand Management (TDM) program to the City of South El Monte Public Works Department to reduce Vehicle Miles Traveled (VMT) and vehicle trips associated with the project. The program, implemented upon occupancy, includes a Commute Trip Reduction (CTR) strategy, which offers incentives and infrastructure to encourage alternative transportation methods like carpooling, transit, and biking, along with services such as ridesharing support, discounted transit, and guaranteed rides home for employees.

RESPONSE
This comment accurately summarizes the transit, pedestrian, and bicycle setting in the project vicinity and summarizes the project’s VMT impact and proposed mitigation measure. This comment does not cite any issues/deficiencies with the technical studies prepared by Ganddini Group; no additional response is necessary.

COMMENT 4
Given the project's VMT of 15.8, which is very close to the city threshold of 15.83, a post-development VMT analysis is recommended to confirm project impacts and aid in future VMT threshold adjustments. If the analysis indicates any significant traffic impacts, additional mitigation measures should be implemented. The analysis, potentially

Dana Privett
KIMLEY-HORN & ASSOCIATES, INC.

November 7, 2024
2222 Rosemead Boulevard Warehouse Development
Response to Caltrans Letter Dated November 5, 2024
3 19618
including surveys of project occupants, could capture data such as trip origins, timing, transportation modes, and mode selection reasons. This data would be valuable for validating existing thresholds, setting future VMT benchmarks, and identifying effective Transportation Demand Management (TDM) measures for future applications.

RESPONSE
This comment recommends post-development VMT analysis to “confirm project impacts and aid in future VMT threshold adjustments” since the project’s mitigated VMT is close to the threshold. As documented by the IS/MND, the project VMT impact is sufficiently mitigated below the City-established threshold of significance with implementation of mitigation measure TRANS-1. Requiring preparation of a post-development VMT analysis would place an undue burden on the project with no nexus to a significant impact. While such data may be “valuable for validating existing thresholds, setting future VMT benchmarks, and identifying effective Transportation Demand Management (TDM) measures for future applications,” such information is beyond the scope of assessing the project’s impacts. This comment does not cite any issues/deficiencies with the VMT analysis prepared by Ganddini Group; no revisions or additional analysis are necessary.

COMMENT 5
A sight distance analysis was performed, confirming that both the desired and minimum stopping sight distances will be met, assuming no landscape obstructions. To maintain these sightlines in accordance with the Highway Design Manual and California MUTCD standards, it is recommended that on-street parking be prohibited on both sides of the project driveways along Rosemead Boulevard (Route 164). This prohibition should extend six feet from the curb return to ensure adequate visibility for vehicles entering and exiting the driveways.

RESPONSE
This comment accurately summarizes the sight distance analysis and recommendations included in the traffic impact analysis prepared for the project (IS/MND Appendix F); no revisions or additional analysis are necessary.

COMMENT 6
Please be reminded that any work performed within the State Right-of-way will require an Encroachment Permit from Caltrans. Any modifications to State facilities must meet all mandatory design standard and specifications. A project (EA 39410) along Rosemead Boulevard (Route 164) is set to install a traffic signal at the intersection of Klingerman Street. It is essential to update the traffic impact assessment to incorporate this improvement when submitting the encroachment permit application.

As a reminder, any transportation of heavy construction equipment and/or materials which require use of oversized transport vehicles on State highways will need a Caltrans transportation permit. We recommend large-size truck trips be limited to off-peak commute periods. Truck drivers should cover construction trucks with tarpaulin to avoid debris spillage onto the State Highway.

RESPONSE
This comment includes general information regarding permits required to be obtained from Caltrans. This comment does not contain any issues relating to the technical studies prepared by Ganddini Group; no additional response is necessary.

Dana Privett
KIMLEY-HORN & ASSOCIATES, INC.

November 7, 2024
2222 Rosemead Boulevard Warehouse Development
Response to Caltrans Letter Dated November 5, 2024
4 19618

CONCLUSION
We appreciate the opportunity to assist you on this project. Should you have any questions or if we can be of further assistance, please contact us at 714-795-3100.

Respectfully submitted,
GANDDINI GROUP, INC.

Giancarlo Ganddini, PE, PTP
Principal

APPENDIX A
Comment Letters

Via Email
October 29, 2024
Gerardo Marquez, Planning Manager
City of South El Monte
1415 Santa Anita Avenue
South El Monte, CA 91733
[email protected]
Re: Comment on the Initial Study/Mitigated Negative Declaration 2222 Rosemead Blvd. Warehouse Development Project
Dear Mr. Marquez:

I am writing on behalf of Supporters Alliance for Environmental Responsibility (“SAFER”) and its members in and around the City of South El Monte (“City”) regarding the Initial Study and Mitigated Negative Declaration (“MND” or “IS/MND”) prepared for the 2222 Rosemead Boulevard Warehouse Project (“Project”).

After careful review of the IS/MND and its accompanying documents prepared by Kimley-Horn & Associates, Inc. (“KHA”) and Phil Martin and Associates, Inc., SAFER believes that the MND is improper under the California Environmental Quality Act, and that an environmental impact report (“EIR”) is required. As explained in more detail below, the MND fails to adequately analyze and review the Project’s impacts. Further, there is substantial evidence of a fair argument that the Project may have adverse environmental impacts related to noise and air quality. SAFER’s review of the MND was assisted by Jack Meighan of acoustical consulting firm Wilson Ihrig and Dr. James Clark of Clark & Associates Environmental Consulting, Inc. Wilson Ihrig and Dr. Clark’s expert comments and CVs are attached as Exhibits A and B.

SAFER requests that the City not proceed with approving the MND and to instead prepare an EIR to ensure that potentially significant adverse impacts of this Project are fully disclosed, analyzed, and mitigated.

PROJECT DESCRIPTION
The Applicants propose to construct of a 156,877-square-foot (sf) concrete tilt-up warehouse with 13 dock doors, and is anticipated to operate 24 hours a day, seven days a week.

The Project site is immediately adjacent to a residential neighborhood, where the closest resident is only 45 feet away. Of the 156,877 sf, the Project would have 113,703 sf of warehouse space, 1-1
1-2

October 29, 2024
Comment on IS/MND for 2222 Rosemead Blvd. Warehouse Project South El Monte, CA

7,879 sf of retail use, 20,305 sf of accessory warehouse office use, and 14,990 sf of warehouse storage. The building would be at a maximum height of 48 feet 10 inches and have a site coverage of approximately 55 percent with a Floor-Area Ratio of 0.7. Access to the site would be from two driveways on Rosemead Boulevard.

The 5.14-acre project site is in the City of South El Monte at 2200, 2212, 2218, and 2226 Rosemead Boulevard (Assessor Parcel Numbers 8102-039-029, 8102-039-030, 8102-039-031, 8102-039-035). The project site is accessed off Rosemead Boulevard (State Route 164 [SR164]), which is located adjacent to the project site; SR-60, which is 0.9-mile south of the project site; and Interstate 10 (1-10), which is approximately 1.3 miles north of the project site.

LEGAL STANDARD
As the California Supreme Court has held “[i]f no EIR has been prepared for a nonexempt project, but substantial evidence in the record supports a fair argument that the project may result in significant adverse impacts, the proper remedy is to order preparation of an EIR.” (Communities for a Better Env’t v. South Coast Air Quality Mgmt. Dist. (2010) 48 Cal.4th 310, 319-320 [citing No Oil, Inc. v. City of Los Angeles (1974) 13 Cal.3d 68, 75, 88; Brentwood Assn. for No Drilling, Inc. v. City of Los Angeles (1982) 134 Cal.App.3d 491, 504–505].) “Significant environmental effect” is defined very broadly as “a substantial or potentially substantial adverse change in the environment.” (Pub. Res. Code § 21068; see also 14 CCR § 15382.)

The EIR is the very heart of CEQA. Bakersfield Citizens for Local Control v. City of Bakersfield (2004) 124 Cal.App.4th 1184, 1214 (Bakersfield Citizens); Pocket Protectors v. City of Sacramento (2004) 124 Cal.App.4th 903, 927. The EIR is an “environmental ‘alarm bell’ whose purpose is to alert the public and its responsible officials to environmental changes before they have reached the ecological points of no return.” Bakersfield Citizens, 124 Cal.App.4th at 1220. The EIR also functions as a “document of accountability,” intended to “demonstrate to an apprehensive citizenry that the agency has, in fact, analyzed and considered the ecological implications of its action.” Laurel Heights Improvements Assn. v. Regents of Univ. of Cal. (1988) 47 Cal.3d 376, 392. The EIR process “protects not only the environment but also informed selfgovernment.” Pocket Protectors, 124 Cal.App.4th at 927.

An EIR is required if “there is substantial evidence, in light of the whole record before the lead agency, that the project may have a significant effect on the environment.” (PRC § 21080(d); see also Pocket Protectors, supra, 124 Cal.App.4th at 927.) An MND rather than an EIR is proper only if the project revisions would avoid or mitigate the potentially significant effects identified in the initial study “to a point where clearly no significant effect on the environment would occur, and…there is no substantial evidence in light of the whole record before the public agency that the project, as revised, may have a significant effect on the environment.” PRC §§ 21064.5 and 21080(c)(2); Mejia v. City of Los Angeles (2005) 130 Cal.App.4th 322, 331. In that context, “may” means a reasonable possibility of a significant effect on the environment. PRC §§ 21082.2(a), 21100, 21151(a); Pocket Protectors, 124 1-2
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October 29, 2024
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Cal.App.4th at 927; League for Protection of Oakland's etc. Historic Res. v. City of Oakland (1997) 52 Cal.App.4th 896, 904–05.

An EIR must be prepared rather than an MND “whenever it can be fairly argued on the basis of substantial evidence that the project may have a significant environmental impact.” (No Oil, Inc. v City of Los Angeles (1974) 13 Cal.3d 68, 75.) Under the “fair argument” standard, an EIR is required if any substantial evidence in the record indicates that a project may have significant environmental impacts —even if contrary evidence exists to support the agency’s decision. 14 CCR § 15064(f)(1); Pocket Protectors, 124 Cal.App.4th at 931; Stanislaus Audubon Society v. County of Stanislaus (1995) 33 Cal.App.4th 144, 150-51; Quail Botanical Gardens Found., Inc. v. City of Encinitas (1994) 29 Cal.App.4th 1597, 1602. The “fair argument” standard creates a “low threshold” favoring environmental review through an EIR rather than through issuance of negative declarations or notices of exemption from CEQA. Pocket Protectors, 124 Cal.App.4th at 928. The “fair argument” standard is virtually the opposite of the typical deferential standard accorded to agencies. As a leading CEQA treatise explains:

This ‘fair argument’ standard is very different from the standard normally followed by public agencies in making administrative determinations. Ordinarily, public agencies weigh the evidence in the record before them and reach a decision based on a preponderance of the evidence. [Citations]. The fair argument standard, by contrast, prevents the lead agency from weighing competing evidence to determine who has a better argument concerning the likelihood or extent of a potential environmental impact.

The lead agency’s decision is thus largely legal rather than factual; it does not resolve conflicts in the evidence but determines only whether substantial evidence exists in the record to support the prescribed fair argument.

Kostka & Zishcke, Practice Under CEQA, §6.29, pp. 273–74.

The Courts have explained that “it is a question of law, not fact, whether a fair argument exists, and the courts owe no deference to the lead agency’s determination. Review is de novo, with a preference for resolving doubts in favor of environmental review.” Pocket Protectors, 124 Cal.App.4th at 928 (emphasis in original).

DISCUSSION
I. There is Substantial Evidence of a Fair Argument that the Project May Have Significant Noise Impacts.

An EIR is required because substantial evidence in the record indicates a fair argument that the Project may have significant noise impacts. Jack Meighan of Wilson Ihrig reviewed the Project, MND, and the Noise Impact Analysis prepared by Ganddini (“Ganddini Noise Report”).

Wilson Ihrig concluded that the Project not only underestimates noise and vibration impacts, but that correcting these errors reveals the Project’s potentially significant noise and vibration impacts that must be disclosed and mitigated.
1-3
cont.
1-4

October 29, 2024
Comment on IS/MND for 2222 Rosemead Blvd. Warehouse Project South El Monte, CA

For the following reasons set forth below, the City should not approve the MND and must instead prepare and circulate an EIR for the Project.

A. The MND Fails to Adequately Evaluate the Project’s Noise Impacts.

The MND’s noise analysis relies on the Ganddini Noise Report to conclude that the Project will not have significant noise impacts. However, the Ganddini Noise Report’s analysis is misleading and inaccurate. Residents of a mobile home park abut the Project site. (MND, p.

87.) According to Footnote 3 of the Ganddini Noise Report’s Construction Noise Model Worksheets, the Project site the “[d]istance to receptor [is] calculated from center of site.

Construction noise projected from the center of the project site to nearest sensitive use (property line).” (Ganddini Noise Report, p. 109.) However, the Ganddini Noise Report conducts measurements of noise impacts from the acoustical center of the Project site and applies an incorrect usage factor, which underestimates the Project’s noise impacts. As Wilson Ihrig explains, “[a] project site with large dimensions cannot be characterized in such a way since the noise source will be unrepresentatively far from the closest receivers.” (Ex. A, p. 2.) “Since the threshold of the detailed assessment is used in the IS/MND, it stands to reason that the distance to each receiver should be used in the calculation. The document's approach of using the detailed assessment thresholds while utilizing part of the general assessment methodology significantly underestimates the potential impact of construction noise.” (Id., p. 3.) The Project site is 5.14 acres large, and so measuring noise levels from the center (over 200 feet away from the nearest sensitive receptor) would not provide an accurate representation of the noise levels on adjacent sensitive receptors – a residential neighborhood. Correcting the above errors, Wilson Ihrig concludes that when noise levels are more accurately calculated at 45 feet, which is the distance of the closest sensitive residential receptor, the noise levels would be

88.2 decibels (dBA). (Id.) This would exceed the daytime noise significance threshold cited in the Ganddini Noise Report of 80 dBA, as well as the nighttime threshold, which is lower.

Therefore, a more accurate measurement of noise levels on sensitive receptors reveals potentially significant impacts that must be disclosed and mitigated in an EIR.

Furthermore, the Ganddini Noise Report relies on unrealistic assumptions when analyzing operational noise impacts. For instance, the Ganddini Noise Report assumes that ten 5- ton HVAC units will be included for Project operations (Ganddini Noise Report, p. 23.) However, as Wilson Ihrig identified, this severely underestimates the required amount that would be required to operate the warehouse:

For warehouses, The American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) minimum ventilation rate is 0.06 CFM per square foot, per person, which must be adjusted for occupancy rates, indoor air quality, and other factors. [citation] According to the IS/MND, the project will build 156,999 square feet of industrial warehouse space [citation. A simple calculation using a rule of thumb for industrial buildings (1 ton of cooling per 500-600 sq. ft. of commercial space) [citation] shows that a warehouse of this size would need 125 5-ton units (spread out across the roof) to properly ventilate the space. 63 5-ton units – or 13 25-ton units – would be 1-4
cont.
1-5
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October 29, 2024
Comment on IS/MND for 2222 Rosemead Blvd. Warehouse Project South El Monte, CA

required to cool the space. The current analysis uses ten 5-ton units, underestimating source noise. Typically, but not always, 25-ton units are used for warehouses for this reason. Either way, the analysis assumes an unrealistically low amount of cooling power, and thus a low source noise level. (emph. added.) (Ex. A, p. 3.) Because of this underestimation of operational noise impacts, Wilson Ihrig suggests that the City revise the MND to better reflect the amount of HVAC units required for the Project to operate. Until and unless the MND properly evaluates the operational noise impacts, the City cannot proceed with the Project or approve the MND.

B. The MND’s Selected Vibration Threshold Impermissibly Obscures the Project’s Potentially Significant Impacts.
“[A] threshold of significance cannot be applied in a way that would foreclose the consideration of other substantial evidence tending to show the environmental effect [] might be significant.” (Protect the Historic Amador Waterways v. Amador Water Agency (2004) 116 Cal.App.4th 1099, 1109.) Even when an accepted method and standards are used to assess a significant impact, the EIR’s analysis can nevertheless be rejected if a reviewing court concludes its characterization of a significant impact does not provide information sufficient to give the public and decisionmakers a complete picture of its nature and scope. (See Sierra Club v County of Fresno (2018) 6 Cal.5th 502 [reliance on air pollution control district’s standard of significance coupled with description of potential health impacts found inadequate]; City of Long Beach v City of Los Angeles (2018) 19 Cal.App.5th 465, 483 [use of industry-accepted protocol to assess project’s air pollution impacts provided incomplete analysis of frequency and duration of excessive pollution]; Berkeley Keep Jets Over the Bay Comm. v Board of Port Comm'rs (2001) 91 Cal.App.4th 1344, 1372 [EIR’s analysis of significance of aircraft noise impacts using standard industry methodology for measuring cumulative noise rejected because single event noise was not also considered].)
The City improperly fails to disclose and mitigate potentially significant vibration impacts. Specifically, the MND exclusively relies on the “severe” annoyance threshold of the Caltrans Transportation and Construction Vibration Guidance Manual (“FTA Manual”) despite other thresholds that may offer additional analysis on the Project’s impacts on human health and comfort. According to Wilson Ihrig, “[s]ince the purpose of CEQA is not only to prevent damage but also to improve quality of life, using a ‘strongly perceptible’ vibration threshold better aligns with CEQA’s goals of minimizing adverse effects. A ‘severe’ threshold might only address more extreme cases of disturbance, overlooking smaller but still important quality-of-life issues.” (Ex.

A, p. 4.) For instance, Wilson Ihrig concluded that had the MND used the “strongly perceptible” threshold of 0.1 PPV for Continuous/Frequent Intermittent Sources from the FTA Manual, the measurements in the Ganddini Noise Report would exceed significance thresholds. (Id.) Because construction is anticipated to last one year, the Project’s construction vibration levels would be continuous and frequent on nearby sensitive receptors. Therefore, the MND’s reliance on the highest rung of the FTA Manual thresholds as the sole threshold for analyzing construction vibration levels violates CEQA because it forecloses the possibility of other vibration levels to be deemed as a significant impact, no matter how strong.
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Comment on IS/MND for 2222 Rosemead Blvd. Warehouse Project South El Monte, CA

Measured vibration levels on nearby sensitive receptors will exceed the “strongly perceptible” thresholds under the FTA Manual. (Id.) This is a significant impact that the City must consider, disclose, and mitigate.

II. The MND’s Proposed Mitigation Measures are Inadequate and Ineffective.

The Project’s only proposed mitigation measures for vibration impacts are inadequate because they do not adequately analyze all vibration-producing machines that may be used for the Project. To reduce vibration impacts to a level below significance, the MND states that Mitigation Measure NOI-2 would be required. (MND, p. 97.) However, Wilson Ihrig notes that the MND and Ganddini Noise Report do not analyze the impacts and levels associated with the use of a pile driver, which may create vibration impacts that exceed significance thresholds. (Ex.

A, p. 4.) There is nothing in the MND or Ganddini Noise Report to conclude that pile driving operations would not be used for the Project, and so “[a]s it stands now, pile driving would represent an undisclosed significant impact, as it would exceed all levels presented in Table 17.” (Id.) If the Project requires pile-driving, such impacts must be disclosed and mitigated in the MND.

Even assuming that pile driving would be used, Mitigation Measure NOI-2 merely limits the use of impact-causing vibratory equipment. Specifically, the measure states that the City “shall verify that the Project plans and specifications include provisions prohibiting the use of vibratory rollers, or other similar vibratory equipment, within 15 feet – or large bulldozers within 8 feet - of the project site’s north, south, and east boundary.” (MND, p. 97.) However, there is no substantial evidence in the MND or Ganddini Noise Report to conclude that prohibiting the use of vibratory equipment to 15 feet from the boundary would effectively reduce vibration impacts to a level below significance. Mitigation Measure NOI-2 provides an express ban on vibratory rollers “or other similar vibratory equipment.” (Id.) “[A] vibratory roller could generate up to

0.21 in/sec PPV at 25 feet and operation of a large bulldozer could generate up to 0.089 PPV at a distance of 25 feet (two of the most vibratory pieces of construction equipment).” (Ganddini Noise Report, p. 24.) In contrast, a pile driver could generate up to 1.518 in/sec PPV at 25 feet. (Id., p. 28.) This level is nearly eight times the vibration impact as that of vibratory roller. As such, pile drivers are unlike “other similar vibratory equipment” as suggested to be covered under Mitigation Measure NOI-2, and the City must adequately evaluate the vibration impacts for pile drivers.

Therefore, this potentially unanalyzed vibration impact renders Mitigation Measure NOI2 inadequate. The MND must be revised to reflect this impact. 1-8
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October 29, 2024
Comment on IS/MND for 2222 Rosemead Blvd. Warehouse Project South El Monte, CA

III. There is Substantial Evidence of a Fair Argument that the Project May Have Significant Air Quality Impacts.

An EIR is required because substantial evidence in the record indicates a fair argument that the Project may have significant air quality impacts. Dr. James Clark reviewed the Project, MND, and the Air Quality, Global Climate Change, HRA, and Energy Impact Analysis prepared by Ganddini (“Ganddini AQ Report”). Dr. Clark additionally reviewed a letter prepared by the Office of Environmental Health Hazard Assessment (“OEHHA”) to the South Coast Air Quality Management District (“SCAQMD”), attached as Exhibit C. Dr. Clark concluded that the Project not only underestimates and fails to include analysis of air quality and health risk impacts, but that correcting these errors reveals the Project’s potentially significant air quality impacts that must be disclosed and mitigated.

For the following reasons set forth below, the City should not approve the MND and must instead prepare and circulate an EIR for the Project.

A. The MND Fails to Adequately Evaluate the Project’s Health Risk Impacts from Soil Contamination.

To support its conclusion that the Project will not have significant air quality impacts, the MND for the Project relies on emissions calculated from the California Emissions Estimator Model (“CalEEMod”). (MND, p. 37.) The model is used to generate a project’s construction and operational emissions. Dr. Clark reviewed the Project’s CalEEMod output files and found that the values input into the model was inadequate. According to the MND, the Project will require extensive remediation efforts due to historical contamination of the Project site and adjacent areas. (MND, pp. 64-68.) For instance, “[t]he site is located in an area known as “Area 1”, which includes the South El Monte Operable Unit. Groundwater in the area is generally contaminated with volatile organic compounds (VOCs), in particular, Trichloroethylene (TCE), perchloroethylene (PCE), and carbon tetrachloride; perchlorate; 1,4-dioxane; and NNitrosodimethylamine (NDMA), many of which are cancer-causing chemicals. According to the Environmental Database Report (EDR), the site of the former occupant (PCD) and numerous surrounding properties and other properties in the vicinity listed on the CPS-SLIC and Well Investigation Program (WIP) databases are located in San Gabriel Valley Area 1 and listed as Potentially Responsible Parties (PRPs) for contributing to the groundwater contaminant plume that comprises an area of approximately 11 square miles. [footnote].” (MND, pp. 64-65.) As Dr.

Clark explains, extensive work that must be performed will have significant health risk impacts to construction workers and outdoor workers. (Ex. B, p. 6.) OEHHA found that the [cancer] risk to construction workers and outdoor workers at the Project Site were 3.4 in 1,000,000 and 23 in 1,000,000 respectively. The acute risk (represented as the Hazard Index (HI)) was 6.8 and 1.9, respectively. This means that construction workers are 6.8 times more likely to have an acute health impact and outdoor workers are nearly 2 times more likely to have an acute health impact due to the presence of the chemicals on site. The risk drivers were arsenic, Arochlor 1248 (a PCB), 1-12
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October 29, 2024
Comment on IS/MND for 2222 Rosemead Blvd. Warehouse Project South El Monte, CA

tetrachloroethene (a chlorinated VOC), and naphthalene (a semi-VOC). (Id., p. 5.)
Table 2: OEHHA’s Partial Risk and Hazard Estimates
Exposure Scenarios OEHHA risk OEHHA HI
Construction Worker 3.4E-6 6.8
Outdoor Worker 2.3E-5 1.9
Table Notes: Risk estimates are presented in scientific notation. For example, a cancer risk of 1 in a million (0.000001) is written as 1E−6. HI is the estimated hazard index. The modifier “partial” is in the title to indicate that some COPCs were omitted due to lack of statistical analysis.
(Ex. C, p. 4.) According to the South Coast Air Quality Management District (“SCAQMD”), the significance thresholds for maximum incremental cancer risk is 10 in one million, and the threshold for chronic and acute hazard index is 1.0.1 The Project would exceed both thresholds for construction workers outdoor workers, representing a significant impact that is not disclosed, analyzed, or mitigated. (Ex. C, p. 4.) Yet, the MND fails to disclose or analyze these impacts or related impacts associated with the required remediation efforts. (Id., p. 6.) This omission results in an inadequate MND document and fails to accurately represent the Project’s emissions and health risks associated with remediating the Project site. As such, the MND’s conclusion that the Project will not have health risk or air quality impacts, regardless of implementation of mitigation measures, is deficient. The City must revise and recirculate an updated document that accurately models the Project’s emissions and considers the health risks and impacts associated with required remediation efforts.

Similarly, the MND fails to analyze the impacts of installing fire pump systems and a back-up generator (BUG) on the Project site. “In addition to the testing emissions the air quality analysis in the MND must include the substantial increase in operational emissions from BUGs in the Air Basin due to unscheduled events, including but not limited to Public Safety Power Shutoff (PSPS) events and extreme heat events. Nowhere in the City’s analysis of the operational emissions of stationary equipment (i.e., fire pumps and or BUGs) or emissions from those sources included in the CalEEMOD analysis.” (Ex. B, p. 7.) As such, the CalEEMod did not account for these additional emissions, which are required to comply with the California Fire Code and local fire authorities. (Id.)
The MND cannot conclusively state that the Project will have less than significant air quality and health impacts because it fails to adequate analyze, measure, and potentially mitigate health related impacts stemming from the Project. This is not surprising given the area’s prevalence and increased activity surrounding heavy-duty trucks and warehouse operations.

Therefore, the MND lacks substantial evidence to support a finding that the Project will not have significant impacts on human health. As such, an EIR is required. 1 south-coast-aqmd-air-quality-significance-thresholds.pdf 1-13
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October 29, 2024
Comment on IS/MND for 2222 Rosemead Blvd. Warehouse Project South El Monte, CA

B. The Project Will Have Significant Health Impacts from Unanalyzed Exposure to Toxic Air Contaminants.

Project construction will generate toxic air contaminants (“TAC”) like diesel particulate matter (“DPM”), and nearby residences located on adjacent parcels will be exposed to these emissions. (Ex. B, p. 8.) As a cancer-causing agent of concern, DPM contains 40 toxic chemicals, including benzene, arsenic and lead.2 DPM is listed separately by the State of California as a toxic air contaminant known to cause cancer in humans.3 According to the US Environmental Protection Agency, “[e]xposure to diesel exhaust can lead to serious health conditions like asthma and respiratory illnesses and can worsen existing heart and lung disease, especially in children and the elderly. These conditions can result in increased numbers of emergency room visits, hospital admissions, absences from work and school, and premature deaths.”4

Despite this potentially significant impact on human health, the MND failed to analyze health risks to nearby sensitive receptors only 45-feet away during Project construction as a result of DPM emissions. (Ex. B, p. 8.)
Figure 1: DPM concentrations during construction (red) (Ex. B, p. 13.) Dr. Clark performed an analysis using the American Meteorological Society/Environmental Protection Agency Regulatory Model Improvement Committee’s Dispersion Model (“AERMOD”). (Ex. B, p. 11.) According to Dr. Clark, the Project will cause a 2 www.p65warnings.ca.gov/fact-sheets/diesel-engine-exhaust. 3 https://oehha.ca.gov/media/downloads/proposition-65//p65chemicalslistsinglelisttable2021p.pdf. 4 https://www.epa.gov/dera/learn-about-impacts-diesel-exhaust-and-diesel-emissions-reduction-act-dera. 1-17
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Comment on IS/MND for 2222 Rosemead Blvd. Warehouse Project South El Monte, CA

cancer risk for infants of 16.4 per one million, which exceeds SCAQMD’s threshold of significance of 10 per million. (Ex. B, p. 13.) “Using the maximum averaged concentrations modeled, the cumulative risk for exposure of infants during the 1.0 years of construction is 10.9 in 1,000,000, much greater than the 10 in 1,000,000 significance threshold outlined by SCAQMD, resulting in a significant impact.” (Id.) Dr. Clark’s comments are substantial evidence that the Project’s construction will significantly impact human health. Since the City failed to analyze this impact, it lacks substantial evidence to conclude that the impact will be less than significant. The Project’s analysis must be revised to analyze and mitigate this impact in an EIR.

CONCLUSION
For the reasons set forth above, SAFER respectfully requests that the City prepare and circulate an EIR for the Project prior to approval.

Sincerely,

Marjan R. Abubo

LOZEAU DRURY LLP
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Exhibit A

WI #24-001.20
November 21st, 2024
Marjan Kris Abubo
Lozeau | Drury LLP
1939 Harrison Street, Suite 150
Oakland, CA 94612
SUBJECT: 2222 Rosemead Blvd Warehouse IS/MND
South El Monte, California
Review and Comment on Noise Study
Dear Mr. Abubo,
Per your request, Wilson Ihrig has reviewed the information and noise impact analysis in the following documents:
2222 ROSEMEAD BOULEVARD WAREHOUSE DEVELOPMENT
Initial Study and Mitigation Negative Declaration (IS/MND) October 2024
With Emphasis on Appendix E, The Noise Impact Analysis prepared by Gandini Group Inc.

The Proposed Project is a 150,000+ square foot warehouse, expected to operate 24 hours a day, seven days a week. The Project site is surrounded by noise sensitive uses, most notably singlefamily houses directly south of the property, and warehouse buildings that are against the adjoining property line.

Wilson Ihrig, Acoustical Consultants, has practiced exclusively in the field of acoustics since 1966.

During our 58 years of operation, we have prepared hundreds of noise studies for Environmental Impact Reports and Statements. We have one of the largest technical laboratories in the acoustical consulting industry. We also utilize industry-standard acoustical programs such as Roadway Construction Noise Model (RCNM), SoundPLAN, and CADNA. In short, we are well qualified to prepare environmental noise studies and review studies prepared by others. 1-20

WILSON IHRIG
2222 Rosemead Blvd Warehouse IS/MND
Review and Comment on Noise Study

Adverse Effects of Noise1
Although the health effects of noise are not taken as seriously in the United States as they are in other countries, they are real and, in many parts of the country, pervasive.

Noise-Induced Hearing Loss. If a person is repeatedly exposed to loud noises, he or she may experience noise-induced hearing impairment or loss. In the United States, both the Occupational Health and Safety Administration (OSHA) and the National Institute for Occupational Safety and Health (NIOSH) promote standards and regulations to protect the hearing of people exposed to high levels of industrial noise.

Speech Interference. Another common problem associated with noise is speech interference. In addition to the obvious issues that may arise from misunderstandings, speech interference also leads to problems with concentration fatigue, irritation, decreased working capacity, and automatic stress reactions. For complete speech intelligibility, the sound level of the speech should be 15 to 18 dBA higher than the background noise. Typical indoor speech levels are 45 to 50 dBA at 1 meter, so any noise above 30 dBA begins to interfere with speech intelligibility. The common reaction to higher background noise levels is to raise one’s voice. If this is required persistently for long periods of time, stress reactions and irritation will likely result.

Sleep Disturbance. Noise can disturb sleep by making it more difficult to fall asleep, by waking someone after they are asleep, or by altering their sleep stage, e.g., reducing the amount of rapid eye movement (REM) sleep. Noise exposure for people who are sleeping has also been linked to increased blood pressure, increased heart rate, increase in body movements, and other physiological effects. Not surprisingly, people whose sleep is disturbed by noise often experience secondary effects such as increased fatigue, depressed mood, and decreased work performance.

Cardiovascular and Physiological Effects. Human’s bodily reactions to noise are rooted in the “fight or flight” response that evolved when many noises signaled imminent danger. These include increased blood pressure, elevated heart rate, and vasoconstriction. Prolonged exposure to acute noises can result in permanent effects such as hypertension and heart disease.

Impaired Cognitive Performance. Studies have established that noise exposure impairs people’s abilities to perform complex tasks (tasks that require attention to detail or analytical processes), and it makes reading, paying attention, solving problems, and memorizing more difficult. This is why there are standards for classroom background noise levels and why offices and libraries are designed to provide quiet work environments.

Construction Noise Impacts are Underestimated
The Noise Memo in Appendix E errs at identifying significant impacts by focusing the analysis at the acoustical center of the project site. A project site with large dimensions cannot be characterized in such a way since the noise source will be unrepresentatively far from the closest receivers. The analysis also incorrectly applies the significance thresholds of the cited Federal Transit Administration (FTA) document.
1 More information on these and other adverse effects of noise may be found in Guidelines for Community Noise, eds B Berglund, T Lindvall, and D Schwela, World Health Organization, Geneva, Switzerland, 1999. (https://www.who.int/publications/i/item/a68672)
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WILSON IHRIG
2222 Rosemead Blvd Warehouse IS/MND
Review and Comment on Noise Study

Appendix E states that “Based on the FTA criteria, project construction noise would be considered significant if it exceeds 80 dBA Leq for an 8-hour period at residential and noise-sensitive outdoor areas” and that “as shown in Table 11, project construction noise levels would not exceed the FTA residential threshold” (Appendix E, Page 30).

Table 11 presents the results of this modeling, which is expanded upon in Appendix D. A footnote says “distance to receptor calculated from center of site. Construction noise projected from the center of the project site to nearest sensitive use” (Appendix E, Apx-58). Usage Factors - defined as the percentage of time during a construction noise operation that a piece of construction equipment is operating at full power - are presented as well.

However, it should be noted that the Federal Transit Administration advises using a usage factor of 1 when analyzing construction equipment from the acoustical center of a project site in the Transit Noise and Vibration Impact Assessment Manual (FTA manual, page 177) 2 in a general assessment.

The usage factors are then utilized in the detailed assessment, where worst-case distances are considered between the construction source and the property line (FTA, page 178). Since the threshold of the detailed assessment is used in the IS/MND, it stands to reason that the distance to each receiver should be used in the calculation. The document's approach of using the detailed assessment thresholds while utilizing part of the general assessment methodology significantly underestimates the potential impact of construction noise.

This is particularly crucial given the large footprint of the project, where the nearest receiver is 219 feet away from the center of the proposed construction site. Distance correction factors are provided in Appendix D of Appendix E, where 12.8 decibels of reduction are calculated from the center of the construction site to the receivers to the south. The closest façade of the sensitive single-family receivers to the south is 45 feet away from the edge of the project site. Using a simple distance correction, a source that produces a level of 74.5 dBA at 219 feet – as presented in Appendix D of Appendix E in the IS/MND – adjusts to a new level of 88.2 dBA at 45 feet. This is above the significance threshold presented in the IS/MND and represents an undisclosed impact. As such, an EIR is required to study potential mitigation options, such as a temporary sound wall.

Operational Noise Impact Analysis Underestimates HVAC
The operational noise analysis includes ten 5-ton HVAC units (appendix E, page 23). For warehouses, The American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) minimum ventilation rate is 0.06 CFM per square foot, per person, which must be adjusted for occupancy rates, indoor air quality, and other factors.3 According to the IS/MND, the project will build 156,999 square feet of industrial warehouse space (Appendix E, page iii). A simple calculation using a rule of thumb for industrial buildings (1 ton of cooling per 500-600 sq. ft. of commercial space) 4 shows that a
warehouse of this size would need 125 5-ton units (spread out across the roof) to properly ventilate the space.
2 https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/transit-noise-andvibration-impact-assessment-manual-fta-report-no-0123_0.pdf 3https://www.ashrae.org/file%20library/technical%20resources/standards%20and%20guidelines/standards%20ad denda/62_1_2013_p_20150707.pdf
4https://airfixture.com/resources/blog/ton-per-square-footage-commercial-hvac 1-21
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WILSON IHRIG
2222 Rosemead Blvd Warehouse IS/MND
Review and Comment on Noise Study

156,999 sq. ft ÷ 500 sq. ft. per ton = ~314 ton load
313 ton load ÷ 5 tons per unit = ~63 units
63 5-ton units – or 13 25-ton units – would be required to cool the space. The current analysis uses ten 5-ton units, underestimating source noise. Typically, but not always, 25-ton units are used for warehouses for this reason. Either way, the analysis assumes an unrealistically low amount of cooling power, and thus a low source noise level. This should be corrected in an updated MND or in an EIR.

Not all Construction Vibration Sources Considered
In Table 10 of Appendix E, construction vibration source levels are presented. Among them is a Pile Driver, which creates the most intrusive vibration levels. However, Table 17, which presents the results of the analysis, does not include the use of a pile driver. This may be intentional – pile driving is not used on every project. However, there is no discussion of why this is or is not the case. As it stands now, pile driving would represent an undisclosed significant impact, as it would exceed all levels presented in Table 17. The MND should be updated to either expand mitigation measure VIB1 to include distances where pile driving cannot be used, or a Project Design Feature should be included which explicitly bans the use of pile driving.

Construction Vibration May Use Improper Annoyance Threshold The IS/MND states “Groundborne vibration levels generated by the project have the potential to cause severe annoyance to people living or working in nearby buildings by exceeding a PPV of 0.4 in/sec” (Appendix E, page 33). This is from the Caltrans Transportation and Construction Vibration Guidance Manual. However, several annoyance thresholds are presented, from ‘severe’ through ‘strongly perceptible’ and ‘distinctly perceptible’ to ‘barely perceptible’.

CEQA aims to minimize significant environmental impacts, including those affecting human health and comfort. Since the purpose of CEQA is not only to prevent damage but also to improve quality of life, using a ‘strongly perceptible’ vibration threshold better aligns with CEQA’s goals of minimizing adverse effects. A ‘severe’ threshold might only address more extreme cases of disturbance, overlooking smaller but still important quality-of-life issues.

If a ‘strongly perceptible’ threshold is used, the levels presented in Table 17 of Appendix E would be over the ‘strongly perceptible’ threshold of 0.1 PPV for Continuous/Frequent Intermittent Sources.

As such, this would be considered a significant impact, and mitigation, such as a vibration control plan prepared by a qualified acoustic engineer, should be studied in an EIR.

Conclusion
The project may result in potentially significant noise construction impacts, and mitigation should be addressed. The construction noise analysis improperly uses FTA methodology, potentially underrepresents the HVAC noise source levels, and does not consider all equipment and proper thresholds in the construction vibration analysis. We believe these errors should be fixed in an Environmental Impact Report.

Please feel free to contact me with any questions regarding this information. 1-22
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WILSON IHRIG
2222 Rosemead Blvd Warehouse IS/MND
Review and Comment on Noise Study

Very truly yours,

WILSON IHRIG
Jack Meighan
Associate
2222 rosemead blvd warehouse comments on noise analysis.docx

JACK MEIGHAN
Associate
Jack joined Wilson Ihrig in 2021 and works out of our Los Angeles office.

He is an experienced acoustical engineer with expertise in projects involving rail transit systems, highways, CEQA analysis, environmental noise reduction, mechanical drawing reviews, and construction noise and vibration mitigation. He has hands-on experience with project management, including client coordination and presentations, as well as in designing, developing, and testing MATLAB code used in acoustics applications. His expertise includes field measurements, developing test plans and specifying, purchasing, setting up and repairing acoustic measurement equipment. He has experience in using Traffic Noise Model (TNM), CadnaA, EASE, Visual Basic, LabView, and CAD software.

Education
• B.S. in Mechanical Engineering, University of Southern California, Los Angeles, CA Project Experience
LA Metro Regional Connector, Los Angeles CA
Planned, took, and processed measurements as part of a team to determine the effectiveness of floating slab trackwork for a new subway in downtown Los Angeles that travels below the Walt Disney Concert Hall and the Colburn School of Music.

Rodeo Credit Enterprise CEQA Analysis for New Construction, Palmdale, CA Wrote an accepted proposal and executed it for a noise study project to determine noise mitigation requirements on a new housing development. Led all aspects of the project and managed the budget during all phases of project completion. Completed five separate projects of this type for this company.

Blackhall Studios, Santa Clarita, CA
Led the vibration measurement effort for a new soundstage directly adjacent to an existing freight and commuter rail line. Tested equipment, processed data, and analyzed results to determine the vibration propagation through the soil to the proposed soundstage locations, and was part of the team that developed mitigation techniques for the office spaces directly next to the rail line.

Octavia Residential Condos CEQA Study, San Francisco, CA Calculated the STC ratings for the proposed windows to meet Title 24 requirements, modeled the acoustic performance of floor and ceiling structures, researched noise codes, helped with a mechanical design review, and wrote a report summarizing the results for a new Condominium project being developed in San Francisco.

ARRIVE San Diego Airport Terminal 1 Replacement, CA
Conducted interior noise and vibration measurements, analyzed measurement data to help determine project criteria, modeled the existing and future terminals in CadnaA, and was part of a team that did a complete HVAC analysis of the entire terminal, as part of a CEQA analysis where a new terminal for the airport is being designed.

Five Points Apartments Noise Study, Whittier, CA

WILSON IHRIG
Jack Meighan – Page 2
*Work done prior to working for Wilson Ihrig
Conducted measurements, researched sound data and solutions, and recommended mitigation for a new apartment complex that was located next to an existing car wash, as part of a CEQA review.

USC Ellison Vibration Survey, Los Angeles, CA
Conducted vibration measurements as part of a survey to determine the effectiveness of vibration isolation platforms that are used to insulate cell growth in a cancer research facility. Determined the effectiveness and presented this information to the client. Researched and recommended a permanent monitoring system so the client could view data in real time.

TEN50 Condos Noise Investigation, Los Angeles, CA
Was part of a team that investigated the noise source of an unwanted popping noise in luxury condominiums in Downtown Los Angeles. Helped isolate the noise source location with accelerometers to determine where vibrations were occurring first and used an acoustic camera to determine where in the condo the noise was coming from. 2000 University Mixed-Use Building, Berkely, CA
Wrote a construction noise monitoring plan based on environmental noise calculations, as required by CEQA, wrote a report summarizing the results, and attended a client meeting to discuss options.

Bay Area Rapid Transit (BART) On-Track, CA, San Francisco Bay Area, CA* Day to day project manager, responsible for meetings, presentations, and coordination with the client for an ongoing noise study on the BART system. Developed MATLAB code to process measurements and determine areas where high corrugation was present, contributing to excessively high in-car noise levels. Performed noise measurements inside both the right of way and the vehicle cabin, in addition to rail corrugation measurements.

California I-605/SR-60 Interchange Improvement, Los Angeles, CA* Developed a noise model of the area that predicted sound levels for abatement design, in addition to conducting noise measurements and analysis. Led the Team in use of the FHWA Traffic Noise Model Software for the project, involving three major highways and two busy interchanges extending over 17 miles in southern California.

Sound Transit On-Track, Seattle, WA*
Took measurements, fixed equipment, and developed software in MATLAB to process Corrugation Analysis Trolley measurements as part of an ongoing noise study on the Sound Transit Link system.

Tested vibration data to determine the best measurement and processing techniques to store the data in an online database for in-car measurements.

LA Metro CRRC Railcar Testing, Los Angeles, CA*
Led the effort to plan the measurements, determine measurement locations and finalize the test plan. Formulated a method to capture speed data directly from legacy train vehicles. Executed noise and vibration specification measurements for new rail cars delivered by CRRC.

City of Los Angeles, Pershing Square Station Rehabilitation Noise Monitoring, CA* Built noise models, wrote a construction noise plan, and assisted in on-site construction noise issues as they arose for a renovation of the Pershing Square metro station in downtown Los

WILSON IHRIG
Jack Meighan – Page 3
*Work done prior to working for Wilson Ihrig
Angeles. Trained construction personnel in techniques for noise reduction and how to conduct noise monitoring measurements to meet project specifications.

City of Orange Metrolink Parking Garage Construction Monitoring, CA* Wrote an adaptive management vibration monitoring plan, set up equipment to monitor live vibration levels, and generated weekly reports as part of an effort to build a new parking garage.

Designed, planned, and completed measurements to predict and mitigate pile driving construction impacts at three historic building locations adjacent to the construction site. Coordinated with the client whenever an on-site problem arose.

LA Metro Westside Subway Construction, Los Angeles, CA* Planned, organized, and processed noise measurements for the Purple Line extension construction.

Implemented both long term microphones to measure noise levels and accelerometers to measure vibration levels in existing subway tunnels. Oversaw noise monitoring at sensitive construction sites for the project and worked with the contractor to find ways to reduce construction noise levels by approximately 10dB.

Montreal Réseau Express Métropolitain, Canada*
Conducted vibration propagation measurements used to create models to predict operational vibration levels for an under-construction transit line. Managed equipment, solved problems in the field, and wrote parts of the report summarizing the findings of the acoustic study.

NCHRP Research Report 882 & 886, Multiple Locations (Dayton and Columbus, OH) Took on-highway measurements and wrote, designed, developed, and tested MATLAB code to identify specific spectrograms to use for analyses for a project evaluating barrier reflected highway traffic noise differences in the presence of a single absorptive or reflective noise barrier.

Siemens Railcar Testing for Sound Transit, Seattle, WA* Measured in-car noise and vibration for new rail cars delivered by Siemens. Developed new internal techniques for measurements based on the written specifications. Contributed to the team that helped identify issues that new cars had in meeting the Sound Transit specifications for noise and vibration. Participated in developing the test plan and specified then acquired new equipment for the measurement.

Toronto/Ontario Eglinton Crosstown Light Rail, Final Design, Canada* Assisted in vibration propagation measurements, analysis, and recommendations for mitigation for a 12-mile light-rail line both on and under Eglinton Avenue. Set up and ran equipment for at-grade measurements with an impact hammer for underground measurements with an impact load cell that was used during pre-construction borehole drilling.

Exhibit B

1 1
Ocotber 24, 2024
Lozeau Drury LLP
1939 Harrison Street, Suite 150
Oakland, CA 94612
Attn: Mr. Marjan Abubo
Subject: Comment Letter on Draft Initial Study/Mitigated Negative Declaration (IS/MND) For The 2222 Rosemead
Boulevard Warehouse Project, City of El Monte,
California
Dear Mr. Drury:

At the request of Lozeau Drury LLP (Lozeau Drury), Clark and Associates (Clark) has reviewed materials related to the above referenced project.

Clark’s review of the materials in no way constitutes a validation of the conclusions or materials contained within the IS/MND. If we do not comment on a specific item, this does not constitute acceptance of the item.

Project Description:

The Project would construct an approximately 156,877-sf concrete tilt-up warehouse and 13 dock doors. Of the 156,877 sf, the Project would have 113,703 sf of warehouse space, 7,879 sf of retail use, 20,305 sf of accessory warehouse office use, and 14,990 sf of warehouse storage. The building would have a maximum height of 48 feet 10 inches. The City of El Monte (the City) states that the retail and Clark & Associates
Environmental Consulting, Inc.

OFFICE
12405 Venice Blvd
Suite 331
Los Angeles, CA 90066
PHONE
310-907-6165
FAX
310-398-7626
EMAIL
[email protected]
1-26

2 warehouse end users are unknown at this time. The hours of operation would be determined by the lessee; however, at this time, the hours are proposed to be seven days a week and operate 24 hours a day. However, all on-site truck movement and loading and unloading activities at the proposed loading docks, which are located behind electronic gates, would be prohibited from 10:00 PM to 7:00 AM.

The Project does not propose refrigeration as part of the warehouse operations. The Project proposes to install an 18,144-sf solar-ready zone on the roof.

Figure 1: Project Site Location
Project construction is anticipated to take approximately 12 months. For this environmental analysis, Project construction is estimated to begin in fall/winter 2024. Construction would occur in the following sequence:
• Site clearing (removal of existing vehicle storage and containers and trees); • Site preparation;
1-26

3 • Grading. Approximately 11,951 cubic yards (cy) of cut and 14,561 cy of fill with 2,610 cy of net export, including on-site grading and installation of infrastructure within existing rights-of-way. All infrastructure (i.e., storm drain, water, wastewater, dry utilities, and street improvements) would be installed within the existing rights-of-way with connections to the project site;
• Building construction; and
• Paving, architectural coating, and landscaping.

Figure 2: Conceptual Site Plan
The IS/MND concludes that no mitigation is required to prevent impacts from the project on air quality in the area and that there are no hazards from chemicals that would be significant with mitigation. This conclusion is in conflict with the facts provided within the IS/MND. 1-26

4 Specific Comments:

1. The Site On Which The Project Will Be Constructed Is Currently Under Investigation By The Los Angeles Regional Water Quality Control Board (LA-RWQCB) And The Office Of Environmental Health And Hazard Assessment (OEHHA) For Hazardous Chemicals. The Site Requires Excavation of Impacted Soils And Long-Term Soil Vapor Extraction. These Necessary Steps Were Not Included In The Air Quality Analysis Of The Construction Phase Or Operational Phase Of The Project.

According to Section 4.9 Hazards and Hazardous Materials of the IS/MND, the Project Site will require remediation prior to the development of the Site. Investigations of the Project Site determined that elevated concentrations of metals, Polychlorinated Biphenyl (PCBs), Volatile Organic Compounds (VOCs), total petroleum hydrocarbons (TPH), and toxic metals (including lead, arsenic, and hexavalent chromium) were present in soils to depths of 8.5 feet below ground surface (bgs) above regulatory health thresholds . VOCs have also been measured in soil vapor, which would migrate into structures above the vapor plume, above regulatory health thresholds. The IS/MND assumes that the with the implementation of a Limited Soil Remediation Work Plan Addendum (LSRWP Addendum) and a Vapor Intrusion Mitigation System (VIMS) the potential hazardous materials impacts would be reduced to less than significant.

The excavation plan will require the removal of 4,999 cubic yards of impacted soils, at varying depths to a maximum of 8.5 feet within the eastern portion of the project site, which is deeper than identified within previous reports. The areas to be excavated at included in the figure below. Soil impacted with lead, arsenic, hexavalent chromium, and TPH, 4,670 cubic yards will be managed under the oversight of the Los Angeles RWQCB and 329 cubic yards of PCB impacted soil will be managed through the TSCA Application for Risk-Based Cleanup Approval under the oversight of the U.S. EPA since PCBs are federally regulated. Approval of the LSRWP from the LA-RWQCB was received by the remediation consultant on October 2, 2024. The letter from LA-RWQCB requires the work to be completed and an investigation report be submitted to the agency by December 31, 2024. 1-27

5 In a July 12, 2023 letter from OEHHA to LA-RWQCB, OEHHA found that the risk to construction workers and outdoor workers at the Project Site were 3.4 in 1,000,000 and 23 in 1,000,000 respectively. The acute risk (represented as the Hazard Index (HI)) was 6.8 and 1.9, respectively. This means that construction workers are 6.8 times more likely to have an acute health impact and outdoor workers are nearly 2 times more likely to have an acute health impact due to the presence of the chemicals on site. The risk drivers were arsenic, Arochlor 1248 (a PCB), tetrachloroethene (a chlorinated VOC), and naphthalene (a semi-VOC).

The workplan for the VIMS has yet been published. Currently consultants for the Project Site have stopped (discontinued in December 2022) due to the migration of VOCs from the adjacent Chemrite site. The figure below indicates the last isopleth from monitoring of soil vapor wells onsite and at the Chemrite site for the shallowest wells.
1-27

6 In order to control vapors across the site, the Proponent must include a vapor mitigation system.

Whether the system is passive or active, the plan will require the construction of the system prior to the building phase of the Project.

A review of the Air Quality analysis for the Project shows five distinct phases of the Construction Schedule. No where in the schedule is there a specific analysis for the emissions from the soil remediation efforts or the installation of the vapor control system.

The Air Quality analysis clearly is deficient, since it fails to include logically and statutorily required steps in the construction phase. The IS/MND must be replaced with an environmental impact report that details all of the required steps for the Project construction and operational phases. 1-27

7 2. The Air Quality Analysis Of The Operational Phase Of The Project Fails To Include Back-Up Generators And Fire Pumps In The Analysis.

To be compliant with the California Fire Code (CFC) and local fire authorities, the Project will be required to install fire pump systems and are likely to have a back-up generator (BUG) onsite. The fire pump and BUG will need to be tested and maintained annually. Under the California Air Resources Board (CARB) Airborne Toxic Control Measure (ATCM) for Stationary Compression Ignition Engines Guidance, the District may allow a new stationary emergency standby diesel-fueled Cl engine (> 50 hp) to operate up to 100 hours per year for maintenance and testing purposes on a sitespecific basis, provided the diesel PM emission rate is less than or equal to 0.01 g/bhp-hr. In addition to the testing emissions the air quality analysis in the MND must include the substantial increase in operational emissions from BUGs in the Air Basin due to unscheduled events, including but not limited to Public Safety Power Shutoff (PSPS) events and extreme heat events. Nowhere in the City’s analysis of the operational emissions of stationary equipment (i.e., fire pumps and or BUGs) or emissions from those sources included in the CalEEMOD analysis.

Figure 3: CalEEMOD Analysis Of Operational Emissions
This failure to include the emissions from the fire pumps and BUGS are a significant unaddressed emission source for the Project. The City’s analysis is therefore incomplete and must be corrected in an EIRfor the Project.
1-28

8 3. The Air Quality Analysis Of The Project Fails To Perform A Health Risk Analysis Of The Toxic Air Contaminants (TACs) That Will Be Emitted From The Construction Phase Of The Project.

The Air Quality Analysis fails to perform a health risk analysis of the construction and the operational phases of the Project. The language in the MND and Air Quality is vague and there is not quantitative analysis of the potential health risks from TACs that will be emitted from the Project Site. Appendix A to the MND includes the February 16, 2024 revised Air Quality Analysis1 for the Project regarding the Project. The report states in the Executive Summary that “Given the temporary and short-term construction schedule, the project would not result in a long-term (i.e., lifetime or 30- year) exposure to Toxic Air Contaminants (TACs) as a result of project construction. Furthermore, construction-based particulate matter (PM) emissions (including diesel exhaust emissions) do not exceed any local or regional thresholds. Therefore, impacts from TACs during construction would be less than significant.”2
This qualitative assessment is meaningless since the potential for developing cancer from exposure to TACs must be quantitatively assessed. The City therefore lacks supporting evidence for its conclusion that the Project would not result in significant health effects. The City’s failure to perform such an analysis is clearly a major flaw in the IS/MND and may be placing the residents of the adjacent structures at risk from the construction phase of the Project.

Diesel exhaust, in particular diesel particulate matter (DPM), is classified by the State of California as a TAC. TACs, including DPM, contribute to a host of respiratory impacts and may lead to the development of various cancers. Failing to quantify the carcinogenic and other health risk impacts places the community at risk for unwanted adverse health impacts. Even brief exposures to the TACs could lead to the development of adverse health impacts over the life of an individual.

Diesel exhaust contains nearly 40 toxic substances, including TACs, and may pose a serious public health risk for residents in the vicinity of the Project. TACs are airborne substances that are capable of causing short-term (acute) and/or long-term (chronic or carcinogenic, i.e., cancer causing) adverse human health effects (i.e., injury or illness). TACs include both organic and inorganic 1 Gandinni. 2024. Rosemead and Rush Industrial Project Air Quality, Global Climate Chanes, HRA, And Energy Impact Analysis from Ganddini Group, Inc. to the City of South El Monte. Pg iv. 2 Ibid.
1-29

9 chemical substances. The current California list of TACs includes approximately 200 compounds, including particulate emissions from diesel-fueled engines.

Diesel exhaust has been linked to a range of serious health problems including an increase in respiratory disease, lung damage, cancer, and premature death. Fine DPM is deposited deep in the lungs in the smallest airways and can result in increased respiratory symptoms and disease; decreased lung function, particularly in children and individuals with asthma; alterations in lung tissue and respiratory tract defense mechanisms; and premature death. Exposure to DPM increases the risk of lung cancer. It also causes non-cancer effects including chronic bronchitis, inflammation of lung tissue, thickening of the alveolar walls, immunological allergic reactions, and airway constriction.

DPM is a TAC that is recognized by state and federal agencies as causing severe health risk because it contains toxic materials, unlike PM2.5 and PM10.

The inherent toxicity of TACs requires the City to first quantify the concentration released into the environment at each of the sensitive receptor locations through air dispersion modeling, calculate the dose of each TAC at that location, and quantify the cancer risk and hazard index for each of the chemicals of concern. Following that analysis, then the City can make a determination of the relative significance of the emissions. The City must assess the potential impacts from DPM in an EIR.

4. Using The Data From The CalEEMOD Analysis Of The Construction Phase Of The Project, An Air Dispersion Model Of Potential Releases of DPM Shows The Annual Average Concentration Of DPM At The Nearest Receptor Would Exceed 0.067 ug/m3 During The Construction Phase, Resulting In A Cancer Risk In Excess Of 10 in 1,000,000 At The Closest Residential Receptor(s).

Using the CalEEMOD analysis supplied in Gandinni Air Quality Report3 it is possible to calculate potential emissions of DPM at the nearest receptor to the Project site during the construction phase of the Project. In 2024, the CalEEMOD model calculated 42 work days in 2023 and 227 days in 2024. The duration of exposure for the residents living across from the construction site would therefore be approximately 1 year.
3 Ibid.
1-29
1-30

10 Phase Year Daily DPM
Emissions
Duration Total DPM
Emissions For
Phase
lbs/day days lbs
Demolition 2023 1.2 20 24
Grading 2023 0.94 20 18.8
Building
Construction 2023 3.95 2 7.9
Building
Construction 2024 0.59 182 107.38
Paving 2024 0.39 20 7.8
Architectural
Coating 2024 0.03 25 0.75
Total 269 158.08
Using the emission rate calculated in the CalEEMOD model for each construction phase, the total amount of DPM emitted from off-road equipment would be equal to the number of work days multiplied by the emission rate calculated in the CalEEMOD model.

𝐷𝐷𝐷𝐷𝐷𝐷 (𝑙𝑙𝑙𝑙𝑙𝑙) = �𝐸𝐸𝐸𝐸𝐸𝐸 𝐸𝐸𝐸𝐸𝐸𝐸 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅 �
𝑙𝑙𝑙𝑙𝑙𝑙
𝑑𝑑 𝑑𝑑
� ∗ 𝑁𝑁𝑁𝑁 𝑁𝑁 𝑂𝑂𝑂𝑂 𝑊𝑊 𝑊𝑊 𝐷𝐷 (𝑑𝑑 𝑑𝑑 )
The total amount of emissions over the site was calculated to be 158.08 lbs of DPM. The total amount emitted, 158.08 lbs was converted to grams by multiplying the pounds of DPM emitted by 453.49 grams per pound.

𝐷𝐷𝐷𝐷𝐷𝐷 (𝑔𝑔) = 𝐶𝐶𝐶𝐶 �
453.59 𝑔𝑔
𝑙𝑙𝑙𝑙𝑙𝑙 � ∗ 𝐷𝐷𝐷𝐷𝐷𝐷 (𝑙𝑙𝑙𝑙𝑙𝑙)
To calculate the daily emission rate of DPM for the construction period (259 days), the total mass of DPM emitted was divided by the area of the construction site (20,8000 square meters (m2)) divided by the number of hours of construction (2,072 hours = 8 hours/day * 259 days) corrected to seconds (3,600 seconds per hour).

𝐸𝐸𝐸𝐸𝐸𝐸 𝐸𝐸𝐸𝐸𝐸𝐸 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅 � 𝑔𝑔
sec∗ 2� = 𝐸𝐸𝐸𝐸𝐸𝐸 𝐸𝐸𝐸𝐸𝐸𝐸 (𝑔𝑔)𝐷𝐷 ( 𝑠𝑠) ∗ 𝐴𝐴 ( 2)
Limiting the emissions to an 8-hour period during weekdays, the emission rate was calculated to be

3.67 x 10-6 lbs per hour of operation per square meter.

Assuming that emissions will be limited to an eight-hour period during weekdays, it is possible to calculate an averaged emissions over the whole construction site. Using AERMOD, the US EPA’s 1-30

11 preferred air dispersion model, it is possible to calculate the concentrations of DPM from the construction area at the closest receptors near the construction site.

Figure 4: Receptors In Model
AERMOD is an acronym for the American Meteorological Society/Environmental Protection Agency Regulatory Model Improvement Committee’s Dispersion Model. AERMOD contains the necessary algorithms to model air concentrations from a wide range of emission source types, including stack-based point sources, fugitive area sources, and volume sources. The modeling domain with the building around the Project site are indicated in the figure below. The green area is the source area of DPM from construction of the Project.

Residential Receptors
1-30

12 Figure 5: Model Domain
Using the meteorological data from SCAQMD for the Pico Rivera monitoring station (closest met station to the Project site), the digital elevation model for the El Monte region, limiting the emissions to an 8-hour period on weekdays, the concentrations at the residences immediate across the street from the Project site were calculated and are summarized below. The model results are included as an Exhibit to this letter.

Table 2: DPM Concentrations Modeled For Construction Phase Receptor
1st Year of
Met Data
2nd Year of
Met Data
3rd Year of
Met Data
4th Year of
Met Data
5th Year of
Met Data
ug/m3 ug/m3 ug/m3 ug/m3 ug/m3
Residences south of
Project Site

5.41E-02 4.30E-02 6.53E-02 7.08E-02 1.00E-01
Based on the assumptions detailed above, the maximum concentration of DPM from the construction phase of the project is 0.0996 ug/m3 and is received at a residential point directly across 1-30

13 from the Project Site. The maximum averaged concentration within the residential receptor points identified above is 0.067 ug/m3.

Figure 6: Model output showing DPM concentrations During Construction Phase Using the algorithm outlined in OEHHA’s HARP 2 Standalone Risk software, the cancer risk to the most sensitive population, infants less than 3 years old was calculated. Using the maximum concentration modeled, the cumulative risk for exposure of infants during the 1.0 year of construction is 16.4 in 1,000,000, much greater than the 10 in 1,000,000 significance threshold outlined by SCAQMD, resulting in a significant impact. Using the maximum averaged concentrations modeled, the cumulative risk for exposure of infants during the 1.0 years of construction is 10.9 in 1,000,000, much greater than the 10 in 1,000,000 significance threshold outlined by SCAQMD, resulting in a significant impact. For adults the risk from exposure to DPM from the construction phase of the project (using the average and maximum concentrations) is 0.25 in 1,000,0000 to 1.1 in 1,000,000.

The results of the air model and the health risk analysis are attached as an appendix to this letter. The City must quantify and disclose these significant impacts in an EIR for the Project. 1-30

14 Conclusion
The facts identified and referenced in this comment letter lead me to reasonably conclude that the Project could result in significant impacts if allowed to proceed. An EIR should be prepared to address these substantial concerns.

Sincerely,
NOTE: A link to access the output data for Dr. Clark's analysis can be accessed here:
https://drive.google.com/file/d/1_JLQz1Zjjj-CakGvc1gTqMA7wu2ZlWdS/view? usp=drive_web
1-31

Risk Calculations For Diesel Exhaust
Riskinh-res = Doseair * CPF * ASF * ED/AT Doseair = Cair * {BR/BW} * A * EF * 10-6 Variable Description Units Value Variable Description Units Value Riskinh-air Residential inhalation
cancer risk
Unitless Calculated Doseair Daily inhalation dose mg/kg-day Calculated Doseair Daily inhalation dose mg/kg-day Calculated Cair Concentration in air ug/m3

0.066632806 0.0666328
CPF Inhalation cancer
potency factor
(mg/kg-day)-1 Chemical Specific {BR/BW} Daily Breathing rate normalized to body
weight
L/kg body weight-day Calculated
ASF Age sensitivity factor
for a specified age
group
Unitless Calculated A Inhalation absorption
fraction
Unitless 1
ED Exposure duration (in
years) for a specified
age group
years Calculated EF Exposure frequency
(days/365 days)
Unitless Calculated
AT Averaging time for
lifetime caner risk
years 70 10-6 migrograms to
milligrams conversion,
liters to cubic meters
conversion
Unitless Calculated
FAH Fraction of time spent
at home
Unitless Calculated 0.00E+00
Residential Exposures
Age Group Risk Age Sensitivity FAH ED CPF Dose Air Cair BR/BW A EF 3rd Trimester 0.00E+00 10 1 0 1.1 2.31E-05 0.067 361 1 0.958904 0-1 1.09E-05 10 1 1 1.1 6.96E-05 0.067 1090 1 0.958904
1-2 0.00E+00 10 1 0 1.1 6.96E-05 0.067 1090 1 0.958904
2-3 0.00E+00 3 1 0 1.1 3.65E-05 0.067 572 1 0.958904
3-4 0.00E+00 3 1 0 1.1 3.65E-05 0.067 572 1 0.958904
2<9 0.00E+00 3 0.72 0 1.1 5.50E-05 0.067 861 1 0.958904 2<16 0.00E+00 3 0.72 0 1.1 4.76E-05 0.067 745 1 0.958904 16<30 2.46E-07 1 0.73 1 1.1 2.14E-05 0.067 335 1 0.958904 16-70 0.00E+00 1 0.73 0 1.1 1.85E-05 0.067 290 1 0.958904 3rd trimeseter to 4. 1.09E-05
3rd trimester to 30 0.00E+00
3rd trimester to 70 1.12E-05

James J. J. Clark, Ph.D.

Principal Toxicologist
Toxicology/Exposure Assessment Modeling
Risk Assessment/Analysis/Dispersion Modeling
Education:

Ph.D., Environmental Health Science, University of California, 1995 M.S., Environmental Health Science, University of California, 1993 B.S., Biophysical and Biochemical Sciences, University of Houston, 1987 Professional Experience:

Dr. Clark is a well recognized toxicologist, air modeler, and health scientist. He has 20 years of experience in researching the effects of environmental contaminants on human health including environmental fate and transport modeling (SCREEN3, AEROMOD, ISCST3, Johnson-Ettinger Vapor Intrusion Modeling); exposure assessment modeling (partitioning of contaminants in the environment as well as PBPK modeling); conducting and managing human health risk assessments for regulatory compliance and risk-based clean-up levels; and toxicological and medical literature research.

Significant projects performed by Dr. Clark include the following:

LITIGATION SUPPORT
Case: James Harold Caygle, et al, v. Drummond Company, Inc. Circuit Court for the Tenth Judicial Circuit, Jefferson County, Alabama. Civil Action. CV-2009 Client: Environmental Litgation Group, Birmingham, Alabama Dr. Clark performed an air quality assessment of emissions from a coke factory located in Tarrant, Alabama. The assessment reviewed include a comprehensive review of air quality standards, measured concentrations of pollutants from factory, an inspection of the facility and detailed assessment of the impacts on the community. The results of the assessment and literature have been provided in a declaration to the court.

Clark & Associates
Environmental Consulting, Inc
OFFICE
12405 Venice Blvd.

Suite 331
Los Angeles, CA 90066
PHONE
310-907-6165
FAX
310-398-7626
EMAIL
[email protected]

Case Result: Settlement in favor of plaintiff.

Case: Rose Roper V. Nissan North America, et al. Superior Court of the State Of California for the County Of Los Angeles – Central Civil West. Civil Action.

NC041739
Client: Rose, Klein, Marias, LLP, Long Beach, California Dr. Clark performed a toxicological assessment of an individual occupationally exposed to multiple chemicals, including benzene, who later developed a respiratory distress. A review of the individual’s medical and occupational history was performed to prepare an exposure assessment. The exposure assessment was evaluated against the known outcomes in published literature to exposure to respiratory irritants. The results of the assessment and literature have been provided in a declaration to the court.

Case Result: Settlement in favor of plaintiff.

Case: O’Neil V. Sherwin Williams, et al. United States District Court Central District of California
Client: Rose, Klein, Marias, LLP, Long Beach, California Dr. Clark performed a toxicological assessment of an individual occupationally exposed to petroleum distillates who later developed a bladder cancer. A review of the individual’s medical and occupational history was performed to prepare a quantitative exposure assessment. The results of the assessment and literature have been provided in a declaration to the court.

Case Result: Summary judgment for defendants.

Case: Moore V., Shell Oil Company, et al. Superior Court of the State Of California for the County Of Los Angeles
Client: Rose, Klein, Marias, LLP, Long Beach, California Dr. Clark performed a toxicological assessment of an individual occupationally exposed to chemicals while benzene who later developed a leukogenic disease. A review of the individual’s medical and occupational history was performed to prepare a quantitative exposure assessment. The exposure assessment was evaluated against the known outcomes in published literature to exposure to refined petroleum hydrocarbons. The results of the assessment and literature have been provided in a declaration to the court.

Case Result: Settlement in favor of plaintiff.

Case: Raymond Saltonstall V. Fuller O’Brien, KILZ, and Zinsser, et al. United States District Court Central District of California
Client: Rose, Klein, Marias, LLP, Long Beach, California Dr. Clark performed a toxicological assessment of an individual occupationally exposed to benzene who later developed a leukogenic disease. A review of the individual’s medical and occupational history was performed to prepare a quantitative exposure assessment. The exposure assessment was evaluated against the known outcomes in published literature to exposure to refined petroleum hydrocarbons. The results of the assessment and literature have been provided in a declaration to the court.

Case Result: Settlement in favor of plaintiff.

Case: Richard Boyer and Elizabeth Boyer, husband and wife, V. DESCO Corporation, et al. Circuit Court of Brooke County, West Virginia. Civil Action Number 04-C-7G.

Client: Frankovitch, Anetakis, Colantonio & Simon, Morgantown, West Virginia.

Dr. Clark performed a toxicological assessment of a family exposed to chlorinated solvents released from the defendant’s facility into local drinking water supplies. A review of the individual’s medical and occupational history was performed to prepare a qualitative exposure assessment. The exposure assessment was evaluated against the known outcomes in published literature to exposure to chlorinated solvents. The results of the assessment and literature have been provided in a declaration to the court.

Case Result: Settlement in favor of plaintiff.

Case: JoAnne R. Cook, V. DESCO Corporation, et al. Circuit Court of Brooke County, West Virginia. Civil Action Number 04-C-9R
Client: Frankovitch, Anetakis, Colantonio & Simon, Morgantown, West Virginia.

Dr. Clark performed a toxicological assessment of an individual exposed to chlorinated solvents released from the defendant’s facility into local drinking water supplies. A review of the individual’s medical and occupational history was performed to prepare a qualitative exposure assessment. The exposure assessment was evaluated against the known outcomes in published literature to exposure to chlorinated solvents. The results of the assessment and literature have been provided in a declaration to the court.

Case Result: Settlement in favor of plaintiff.

Case: Patrick Allen And Susan Allen, husband and wife, and Andrew Allen, a minor, V. DESCO Corporation, et al. Circuit Court of Brooke County, West Virginia. Civil Action Number 04-C-W
Client: Frankovitch, Anetakis, Colantonio & Simon, Morgantown, West Virginia.

Dr. Clark performed a toxicological assessment of a family exposed to chlorinated solvents released from the defendant’s facility into local drinking water supplies. A review of the individual’s medical and occupational history was performed to prepare a qualitative exposure assessment. The exposure assessment was evaluated against the known outcomes in published literature to exposure to chlorinated solvents. The results of the assessment and literature have been provided in a declaration to the court.

Case Result: Settlement in favor of plaintiff.

Case: Michael Fahey, Susan Fahey V. Atlantic Richfield Company, et al. United States District Court Central District of California Civil Action Number CV-06 7109 JCL.

Client: Rose, Klein, Marias, LLP, Long Beach, California Dr. Clark performed a toxicological assessment of an individual occupationally exposed to refined petroleum hydrocarbons who later developed a leukogenic disease. A review of the individual’s medical and occupational history was performed to prepare a qualitative exposure assessment. The exposure assessment was evaluated against the known outcomes in published literature to exposure to refined petroleum hydrocarbons.

The results of the assessment and literature have been provided in a declaration to the court.

Case Result: Settlement in favor of plaintiff.

Case: Constance Acevedo, et al., V. California Spray-Chemical Company, et al., Superior Court of the State Of California, County Of Santa Cruz. Case No. CV 146344
Dr. Clark performed a comprehensive exposure assessment of community members exposed to toxic metals from a former lead arsenate manufacturing facility. The former manufacturing site had undergone a DTSC mandated removal action/remediation for the presence of the toxic metals at the site. Opinions were presented regarding the elevated levels of arsenic and lead (in attic dust and soils) found throughout the community and the potential for harm to the plaintiffs in question.

Case Result: Settlement in favor of defendant.

Case: Michael Nawrocki V. The Coastal Corporation, Kurk Fuel Company, Pautler Oil Service, State of New York Supreme Court, County of Erie, Index Number I2001-11247
Client: Richard G. Berger Attorney At Law, Buffalo, New York Dr. Clark performed a toxicological assessment of an individual occupationally exposed to refined petroleum hydrocarbons who later developed a leukogenic disease. A review of the individual’s medical and occupational history was performed to prepare a qualitative exposure assessment. The exposure assessment was evaluated against the