iv. environmental impact analysis c. air …...instead, the scaqmd has prepared the ceqa air quality...

Bellwood Condos IV.C. Air Quality Draft Environmental Impact Report Page IV.C-1

IV. ENVIRONMENTAL IMPACT ANALYSIS C. AIR QUALITY

INTRODUCTION

This section examines the project's potential air quality impacts. Both short-term construction emissions occurring from activities such as site grading and construction truck trips, as well as long-term effects related to the ongoing operation of the project are discussed. The analysis considers both (1) daily emissions and (2) pollutant concentrations. “Emissions” refer to the actual quantity of pollutants and are measured in pounds per day (ppd). “Concentrations” refer to the amount of pollutant material per volumetric unit of air and are measured in parts per million (ppm) or micrograms per cubic meter (µg/m3).

This section also discusses the potential for the project to violate an air quality standard or to contribute substantially to an existing or projected air quality violation, potential cumulative impacts with respect to criteria pollutants for which the project region is in non-attainment, potential exposure of sensitive receptors to substantial pollutant concentrations, and the project's consistency with applicable air quality plans. Documents used in preparation of this section include the South Coast Air Quality Management District (SCAQMD) CEQA Air Quality Handbook and the 2003 Air Quality Management Plan (AQMP), as amended, as well as federal and State regulations and guidelines.

ENVIRONMENTAL SETTING

The project site is located within the South Coast Air Basin (“Basin”), named so because its geographical formation is that of a basin, with the surrounding mountains trapping the air and its pollutants in the valleys below. This area includes all of Orange County and the non-desert portions of Los Angeles, San Bernardino, and Riverside Counties. The regional climate within the Basin is considered semi-arid and is characterized by warm summers, mild winters, infrequent seasonal rainfall, moderate daytime onshore breezes, and moderate humidity. The air quality within the Basin is primarily influenced by a wide range of emissions sources – such as dense population centers, heavy vehicular traffic, industry, and meteorology.

Regulatory Framework

Air quality within the Basin is addressed through the efforts of various federal, State, regional, and local government agencies. These agencies work jointly, as well as individually, to improve air quality through legislation, regulations, planning, policy-making, education, and a variety of programs. The agencies responsible for regulating and improving the air quality within the Basin are discussed below.

Federal

The U.S. Environmental Protection Agency (U.S. EPA) is responsible for setting and enforcing the federal ambient air quality standards for atmospheric pollutants. It regulates emission sources that are under the exclusive authority of the federal government, such as aircraft, ships, and certain locomotives.

City of Los Angeles August 2008


The U.S. EPA also has jurisdiction over emissions sources outside state waters (outer continental shelf), and establishes various emissions standards for vehicles sold in states other than California.

As part of its enforcement responsibilities, the U.S. EPA requires each state with nonattainment areas to prepare and submit a State Implementation Plan (SIP) that demonstrates the means to attain the federal standards. The SIP must integrate federal, state, and local plan components and regulations to identify specific measures to reduce pollution, using a combination of performance standards and market-based programs within the timeframe identified in the SIP.

State

The California Air Resources Board (ARB), a part of the California Environmental Protection Agency, is responsible for the coordination and administration of both federal and State air pollution control programs within California. In this capacity, the ARB conducts research, sets California Ambient Air Quality Standards, compiles emission inventories, develops suggested control measures, provides oversight of local programs, and prepares the SIP. The ARB establishes emissions standards for motor vehicles sold in California, consumer products (such as hair spray, aerosol paints, and barbecue lighter fluid), and various types of commercial equipment. It also sets fuel specifications to further reduce vehicular emissions.

California has responded to the issue of global climate change by adopting a series of laws to reduce Greenhouse Gas (GHG) emissions from various sources within the State. These efforts began in September 2002 when then-Governor Gray Davis signed Assembly Bill (AB) 1493 requiring the development and adoption of regulations to achieve “the maximum feasible reduction of greenhouse gases” emitted by noncommercial passenger vehicles, light-duty trucks, and other vehicles used primarily for personal transportation in the State. In September 2006, Governor Arnold Schwarzenegger signed in to law AB 32, the California Global Warming Solutions Act of 2006. AB 32 requires the California Air Resources Board (ARB) to adopt regulations to require the reporting and verification of statewide greenhouse gas emissions and to monitor and enforce compliance with that program. As part of this effort, the ARB will adopt a statewide greenhouse gas emissions limit equivalent to the statewide greenhouse gas emissions levels in 1990, to be achieved by 2020. The ARB will adopt rules and regulations to achieve the maximum technologically feasible and cost-effective greenhouse gas emission reductions. These are expected to include market-based compliance mechanisms. The statute further requires the ARB to monitor compliance with and enforce any rule, regulation, order, emission limitation, emissions reduction measure, or market-based compliance mechanism that it adopts. Senate Bill (SB) 1368, a companion bill to AB 32, requires the California Public Utilities Commission (PUC) and the California Energy Commission (CEC) to establish GHG emission performance standards for the generation of electricity. These standards will apply not only to power that is generated within California, but will also apply to power that is generated elsewhere and imported into the State.

On June 1, 2005, Governor Schwarzenegger issued Executive Order #S-3-05 in which he established the following emission reductions target for the State of California: by 2010, reduce GHG emissions to 2000 levels; by 2020, reduce GHG emissions to 1990 levels; by 2050, reduce GHG emissions to 80 percent



below 1990 levels. This Executive Order also designates the Cal/EPA Secretary with the primary responsibility for coordinating oversight of the efforts made to meet the targets with: the Secretary of Business, Transportation and Housing, Secretary of the Department of Food and Agriculture, Secretary of the Resources Agency, Chairperson of the Air Resource Board, Chairperson of the Energy Commission, and the President of the Public Utilities Commission. In late December, the Governor announced the members of a blue-ribbon Market Advisory Committee board to devise approaches to develop a market for carbon trading. More developments are likely as the Governor and the Legislature determine who has primary responsibility for implementation and the relationship between regulations and market-based mechanisms. Since the intent of AB 32 is to limit 2020 emissions to the equivalent of 1990, and the present year (2008) is near the midpoint of this timeframe, it is expected that the regulations would affect many existing sources of GHGs and not just new general development projects.

In response to the Executive Order, the Secretary of Cal/EPA created the Climate Action Team (CAT), which, in March 2006, published the Climate Action Team Report to Governor Schwarzenegger and the Legislature (2006 CAT Report). The 2006 CAT Report identifies a recommended list of strategies that the State could pursue to reduce climate change greenhouse gas emissions. These are strategies that could be implemented by various State agencies to ensure that the Governor’s targets are met and can be met with existing authority of the State agencies.

In October 2007, Governor Schwarzenegger signed SB 97, which requires the Governor’s Office of Planning and Research (OPR) to prepare CEQA guidelines for the mitigation of GHG emissions. OPR must prepare these guidelines and transmit them to the Resources Agency by July 1, 2009. The Resources Agency must then certify and adopt the guidelines by January 1, 2010. OPR and the Resources Agency are required to periodically review the guidelines to incorporate new information or criteria adopted by the ARB pursuant to AB 32.

Regional

The South Coast Air Quality Management District (SCAQMD) is the agency principally responsible for comprehensive air pollution control in the Basin. To that end, the SCAQMD, a regional agency, works directly with the Southern California Association of Governments (SCAG), county transportation commissions, and local governments, and cooperates actively with all State and federal government agencies. The SCAQMD develops rules and regulations, establishes permitting requirements, inspects emissions sources, and provides regulatory enforcement through such measures as educational programs or fines, when necessary.

The SCAQMD is directly responsible for reducing emissions from stationary (area and point), mobile, and indirect sources to meet federal and State ambient air quality standards. It has responded to this requirement by preparing a series of Air Quality Management Plans (AQMPs). The most recent of these was adopted by the Governing Board of the SCAQMD on June 1, 2007. This AQMP, referred to as the 2007 AQMP, was prepared to comply with the federal and State Clean Air Acts and amendments, to accommodate growth, to reduce the high levels of pollutants in the Basin, to meet federal and State air quality standards, and to minimize the fiscal impact that pollution control measures have on the local



economy. The 2007 AQMP identifies the control measures that will be implemented over a 20-year horizon to reduce major sources of pollutants. Implementation of control measures established in the previous AQMPs has substantially decreased the population’s exposure to unhealthful levels of pollutants, even while substantial population growth has occurred within the Basin. As discussed on page 2-6 of the 2007 AQMP, levels of ambient pollutants monitored in the Basin have decreased substantially since 1980.

The future air quality levels projected in the 2007 AQMP are based on several assumptions. For example, the SCAQMD assumes that general new development within the Basin will occur in accordance with population growth and transportation projections identified by SCAG in its most current version of the Regional Comprehensive Plan and Guide (RCPG), which was adopted in March 1996. The 2007 AQMP also assumes that general development projects will include strategies (mitigation measures) to reduce emissions generated during construction and operation in accordance with SCAQMD and local jurisdiction regulations which are designed to address air quality impacts and pollution control measures.

According to the Final Program EIR for the 2007 AQMP, the 2007 AQMP as a whole is expected to promote a net decrease in greenhouse gases.1 The recommended control measures and the recommended state and federal control measures that promote fuel efficiency and pollution prevention will also reduce GHG emissions. In general, the strategies that conserve energy and promote clean technologies usually also reduce GHG emissions.

Although the SCAQMD is responsible for regional air quality planning efforts, it does not have the authority to directly regulate the air quality issues associated with plans and new development projects within the Basin. Instead, the SCAQMD has prepared the CEQA Air Quality Handbook to assist Lead Agencies, as well as consultants, project proponents, and other interested parties, in evaluating potential air quality impacts of projects and plans proposed in the Basin.

Local

Local jurisdictions, such as the City of Los Angeles, have the authority and responsibility to reduce air pollution through its police power and decision-making authority. Specifically, the City is responsible for the assessment and mitigation of air emissions resulting from its land use decisions. The City of Los Angeles is also responsible for the implementation of transportation control measures as outlined in the AQMP. Examples of such measures include bus turnouts, energy-efficient streetlights, and synchronized traffic signals.

CEQA Air Quality Handbook

In accordance with CEQA requirements and the CEQA review process, the City assesses the air quality impacts of new development projects, requires mitigation of potentially significant air quality impacts by

1 South Coast Air Quality Management District, Final Program Environmental Impact Report for the 2007 Air Quality Management Plan, June 2007, p. 4.1-58.



conditioning discretionary permits and monitors and enforces implementation of such mitigation. The City utilizes the CEQA Air Quality Handbook as the guidance document for the environmental review of plans and development proposals within its jurisdiction.

The City of Los Angeles has begun to address the issue of global climate change by publishing Green LA, An Action Plan to Lead the Nation in Fighting Global Warming (LA Green Plan). This document outlines the goals and actions the City has established to reduce the generation and emission of GHGs from both public and private activities. According to the LA Green Plan, the City of Los Angeles is committed to the goal of reducing emissions of carbon dioxide (CO2) to 35 percent below 1990 levels. To achieve this, the City will:

• Increase the generation of renewable energy;

• Improve energy conservation and efficiency; and

• Change transportation and land use patterns to reduce dependence on automobiles.

Air Quality Element of the City of Los Angeles General Plan

The Air Quality Element of the City of Los Angeles General Plan was adopted on November 24, 1992 and sets forth the goals, objectives and policies which will guide the City in the implementation of its air quality improvement programs and strategies. The Air Quality Element acknowledges that numerous efforts are underway at the regional, county and city levels addressing clean air concerns and that coordination of these various efforts and the involvement of the area’s residents are crucial to the achievement of state and federal air quality standards.

The Air Quality Element acknowledges the interrelationships among transportation and land use planning in meeting the City’s mobility and clean air goals. Mutually reinforcing strategies need to be developed which work to reduce the use of single occupant vehicles and which work to reduce vehicle trips and vehicle miles traveled.

The Air Quality Element establishes six goals:

• Good air quality in an environment of continued population growth and healthy economic structure;

• Less reliance on single-occupant vehicles with fewer commute and non-work trips;

• Efficient management of transportation facilities and system infrastructure using cost-effective system management and innovative demand-management techniques;

• Minimal impacts of existing land use patterns and future land use development on air quality by addressing the relationship between land use, transportation and air quality;

• Energy efficiency through land use and transportation planning, the use of renewable resources and less-polluting fuels and the implementation of conservation measures including passive measures such as site orientation and tree planting; and



• Citizen awareness of the linkages between personal behavior and air pollution and participation in efforts to reduce air pollution.

Congestion Management Program (CMP)

The CMP is a State-mandated program that serves as the monitoring and analytical basis for transportation funding decisions in the County made through the Regional Transportation Improvement Program (RTIP) and State Transportation Improvement Program (STIP) processes. The CMP requires that a Traffic Impact Analysis (TIA) be performed for all CMP arterial monitoring intersections where a project would add 50 or more trips during either the morning or afternoon weekday peak hours and all mainline freeway monitoring locations where a project would add 150 or more trips (in either direction) during the morning or afternoon weekday peak hours.

Air Pollutants and Effects

Air pollutant emissions within the Basin are generated by stationary and mobile sources. Stationary sources can be divided into two major subcategories: point and area sources. Point sources occur at an identified location and are usually associated with manufacturing and industry. Examples are boilers or combustion equipment that produces electricity or generates heat. Area sources are widely distributed and can produce many small emissions. Examples of area sources include residential and commercial water heaters, painting operations, lawn mowers, agricultural fields, landfills, and consumer products such as barbeque lighter fluid and hair spray. Mobile sources refer to emissions from motor vehicles, including tailpipe and evaporative emissions, and are classified as either on-road or off-road. On-road sources may be legally operated on roadways and highways. Off-road sources include aircraft, ships, trains, racecars, and self-propelled construction equipment. Air pollutants can also be generated by the natural environment such as when fine dust particles are pulled off the ground surface and suspended in the air during high winds.

Both the federal and State governments have established ambient air quality standards for outdoor concentrations of various pollutants in order to protect public health and welfare. These pollutants are referred to as “criteria air pollutants” as a result of the specific standards, or criteria, that have been adopted for them. The national and State standards have been set at levels considered safe to protect public health, including the health of “sensitive” populations such as asthmatics, children, and the elderly with a margin of safety; and to protect public welfare, including protection against decreased visibility and damage to animals, crops, vegetation, and buildings.

The criteria air pollutants which are most relevant to current air quality planning and regulation in the Basin include ozone, carbon monoxide (CO), nitrogen dioxide (NO2), respirable particulate matter (PM10), fine particulate matter (PM2.5), and sulfur dioxide (SO2), and lead. In addition, toxic air contaminants and greenhouse gases are of concern in the Basin. Each of these is briefly described below.

• Ozone is a gas that is formed when volatile organic compounds (VOCs) and nitrogen oxides (NOx)—both byproducts of internal combustion engine exhaust—undergo slow photochemical



reactions in the presence of sunlight. Ozone concentrations are generally highest during the summer months when direct sunlight, light wind, and warm temperature conditions are favorable.

• Carbon Monoxide is a colorless, odorless gas produced by the incomplete combustion of fuels. CO concentrations tend to be the highest during the winter morning, with little to no wind, when surface-based inversions trap the pollutant at ground levels. Because CO is emitted directly from internal combustion engines—unlike ozone—and motor vehicles operating at slow speeds are the primary source of CO in the Basin, the highest ambient CO concentrations are generally found near congested transportation corridors and intersections.

• Respirable Particulate Matter (PM10) and Fine Particulate Matter (PM2.5) consists of extremely small, suspended particles or droplets 10 microns and 2.5 microns or smaller in diameter. Some sources of particulate matter, like pollen and windstorms, are naturally occurring. However, in populated areas, most particulate matter is caused by road dust, diesel soot, combustion products, abrasion of tires and brakes, and construction activities.

• Nitrogen dioxide is byproduct of fuel combustion. The principal form of nitrogen oxide produced by combustion is nitric oxide (NO), which reacts quickly to form NO2, creating the mixture of NO and NO2 commonly called NOx. NO2 absorbs blue light and results in a brownish-red cast to the atmosphere and reduced visibility. NO2 also contributes to the formation of PM10.

• Sulfur dioxide is a colorless, extremely irritating gas or liquid. It enters the atmosphere as a pollutant mainly as a result of burning high sulfur-content fuel oils and coal, and from chemical processes occurring at chemical plants and refineries.

• Lead occurs in the atmosphere as particulate matter. The combustion of leaded gasoline used to be the primary source of airborne lead in the Basin, although the use of leaded gasoline is no longer permitted for on-road motor vehicles. Today the primary sources of airborne lead pollution include the manufacturing and recycling of batteries, paint, ink, ceramics, ammunition, and secondary lead smelters.

• Toxic Air Contaminants (TAC) refer to a diverse group of “non-criteria” air pollutants that can affect human health, but have not had ambient air quality standards established for them. This is not because they are fundamentally different from the pollutants discussed above, but because their effects tend to be local rather than regional. There are hundreds of toxic air contaminants and exposure to these pollutants can cause or contribute to cancer, birth defects, genetic damage, and other adverse health effects.

• Greenhouse Gas (GHG) emissions refer to a group of emissions that are generally believed to affect global climate conditions. Greenhouse gases such as carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O) keep the average surface temperature of the Earth close to a hospitable 60 degrees Fahrenheit. Without the greenhouse effect, the Earth would be a frozen globe with an average surface temperature of about 5 degrees Fahrenheit. However, there



appears to be a close relationship between the concentration of greenhouse gases in the atmosphere and global temperatures. It is believed that the amount of greenhouse gas emissions in the atmosphere has increased at a rapid rate due to the consumption of fossil fuels and that these gases are contributing to an increase in global temperatures.

In addition to CO2, methane, and nitrous oxide, GHGs include hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulfur hexafluoride (SF6), and water vapor. Of all the GHGs, CO2 is the most abundant climate change pollutant with fossil fuel combustion CO2 comprising 81.0% of the total GHG emissions in California in 2002 and non-fossil fuel CO2 comprising 2.3%.2 The other GHGs are less abundant, but have higher global warming potential than CO2. To account for this higher potential, emissions of other GHGs are frequently expressed in the equivalent mass of CO2, denoted as CO2e. The CO2e of methane represented 6.4% of the 2002 California GHG emissions, nitrous oxide 6.8%, and the other high global warming potential gases represented 3.5% of these emissions.3 In addition, there are a number of man-made pollutants, such as carbon monoxide (CO), nitrogen oxides (NOx), nonmethane volatile organic compounds (NMVOCs), and sulfur dioxide (SO2), that have indirect effects on terrestrial or solar radiation absorption by influencing the formation or destruction of other climate change emissions.

Existing State-wide Greenhouse Gas Emissions

In December 2006, the California Energy Commission published the Inventory of California Greenhouse Gas Emissions and Sinks: 1990 to 2004. This report indicates that California is the second largest emitter of greenhouse gasses in the United States next to Texas. This is largely a result of the number of people living in a large state, as opposed to a small state such as Rhode Island. California generates about half as much CO2 emissions as Texas. When considering fossil fuel emissions at the individual level, California is second lowest in the nation in per capita CO2 emissions with only the District of Columbia lower. Between 1990 and 2000, California’s population grew by 4.1 million people and during the 1990 to 2003 period, California’s gross state product grew by 83 percent (in dollars, not adjusted for inflation). However, California’s greenhouse gas emissions grew by only 12 percent between 1990 and 2003. The report concludes that California’s ability to slow the rate of growth of greenhouse gas emissions is largely due to the success of its energy efficiency, renewable energy programs, and commitment to clean air and clean energy. In fact, the State’s programs and commitments lowered its greenhouse gas emissions rate of growth by more than half of what it would have been otherwise.

Existing Regional Air Quality

Ambient air quality is determined primarily by the type and amount of pollutants emitted into the atmosphere, as well as the size, topography, and meteorological conditions of a geographic area. The

2 California Environmental Protection Agency, Climate Action Team Report to Governor Schwarzenegger and the Legislature, March 2006, p. 11.

3 Ibid.



Basin has low mixing heights and light winds, which are conducive to the accumulation of air pollutants. The average daily emissions inventory for the entire Basin and the Los Angeles County portion of the Basin is summarized in Table IV.C-1. As shown, exhaust emissions from mobile sources generate the majority of ROG, CO, NOx, and SOx in the Basin and the Los Angeles County portion of the Basin. Area-wide sources generate the most airborne particulates (i.e., PM10 and PM2.5).

Measurements of ambient concentrations of the criteria pollutants are used by the U.S. EPA and the ARB to assess and classify the air quality of each regional air basin, county, or, in some cases, a specific urbanized area. The classification is determined by comparing actual monitoring data with national and State standards. If a pollutant concentration in an area is lower than the standard, the area is classified as being in “attainment” for that pollutant. If the pollutant concentration meets or exceeds the standard (depending on the specific standard for the individual pollutants), the area is classified as a “nonattainment” area.4 If there are not enough data available to determine whether the standard is exceeded in an area, the area is designated “unclassified.”

The U.S. EPA and the ARB use different standards for determining whether the Basin is in attainment. Under national standards, a large portion of the Basin is currently classified as an extreme nonattainment area for 1-hour ozone concentrations, a serious nonattainment area for PM10, and a nonattainment area for PM2.5. The Basin is also among the few areas in the nation that is still classified as a serious nonattainment area for CO. However, the Basin reached attainment of national standards in 2002 and levels of CO have continued to be low. This has allowed the SCAQMD to demonstrate attainment and, in March 2005, formally request redesignation as an attainment area. The U.S. EPA has 18 months to process the SCAQMD’s request. Los Angeles County is also classified as a Severe 17 nonattainment area for 8-hour ozone concentrations. This means that ambient 8-hour ozone concentrations throughout the County are not expected to be met for more than 17 years. The Basin is in attainment or designated as unclassified for all other pollutants under national standards.

Under State standards, the Basin is designated as a nonattainment area for ozone, CO (Los Angeles County only), PM10, and PM2.5, and an attainment area for all other pollutants.

4 National Ambient Air Quality Standards (other than ozone, particulate matter, and those based on annual averages or annual arithmetic mean) are not to be exceeded more than once a year. The ozone standard is attained when the fourth highest 8-hour concentration in a year, averaged over three years, is equal to or less than the standard. For PM10, the 24-hour standard is attained when the expected number of days per calendar year with a 24-hour average above the standard is less than one. For PM2.5, the 24-hour standard at attained when 98 percent of the daily concentrations, averaged over three years, are equal to or less than the standard.

California Ambient Air Quality Standards for ozone, CO, SO2 (1- and 24-hour), NO2, PM10, PM2.5, and visibility reducing particles are values that are not to be exceeded. Standards for all other pollutants are not to be equaled or exceeded.



Table IV.C-1 2006 Estimated Average Daily Regional Emissions

Emissions in Tons Per Day Emissions Source

ROG CO NOx SOx PM10 PM2.5 South Coast Air Basin Stationary Sources 101.9 55.4 58.3 19.3 20.9 13.7 Area-Wide Sources 148.3 110.3 25.6 0.8 210.3 51.2 Mobile Sources 425.8 3580.0 866.5 28.1 48.4 39.0 Natural (non-anthropogenic) Sources 86.5 164.2 5.0 1.5 16.6 14.1 Total Emissions 762.4 3909.9 955.4 49.8 296.2 117.9 Los Angeles County – South Coast Air Basin

Stationary Sources 59.0 35.8 40.0 17.9 12.6 9.2 Area-Wide Sources 85.3 43.8 15.3 0.4 103.2 26.0 Mobile Sources 252.5 2133.5 529.4 24.6 29.5 24.0 Natural Sources 34.3 65.0 1.9 0.6 6.6 5.6 Total Emissions 431.1 2278.0 586.7 43.5 151.9 64.8 Source: California Air Resources Board, Emission Inventory Data, website: http://www.arb.ca.gov/ei/maps/basins/abscmap.htm, December 10, 2007.

Existing Local Air Quality

The SCAQMD monitors ambient air pollutant concentrations through a series of monitoring stations located throughout the Basin. In doing so, the SCAQMD has divided the region into 38 Source Receptor Areas (SRAs) in which 33 monitoring stations operate. The source receptor areas are located throughout designated forecast areas within the south coast basin. Specifically, the project site is located within SRA 2, which is located within the general forecast area designated as “Northwest Los Angeles County Coastal”. The ambient air pollutant concentrations within the project vicinity are monitored at the Veterans Administration building in West Los Angeles, and only ambient concentrations of ozone, CO, and NO2 are monitored at this location. Therefore, additional ambient conditions for PM10 and NO2 were monitored at the Westchester Parkway monitoring station to provide conditions that would be representative of the general forecast area. Table IV.C-2 identifies the national and state ambient air quality standards for the relevant air pollutants along with the ambient pollutant concentrations that have been measured in SRA 2 (at the Veterans Administration building in West Los Angeles and at the Westchester Parkway location) through the period of 2004 to 2006.

Existing land-uses surrounding the project site include residences, hotels and commercial uses. Air pollutant emissions are generated in the local vicinity by stationary and area-wide sources, such as space and water heating, landscape maintenance from leaf blowers and lawn mowers, consumer products, and mobile sources, primarily automobile traffic. Motor vehicles are the primary source of pollutants in the local vicinity.



Table IV.C-2 Summary of Ambient Air Quality in the Project Vicinity

Year Emissions Source

2004 2005 2006 Ozone Maximum 1-hour concentration measured 0.107 ppm 0.114 ppm 0.099 ppm Days exceeding national 0.12 ppm 1-hour standard 0 0 0 Days exceeding State 0.09 ppm 1-hour standard 5 7 3 Maximum 8-hour concentration 0.089 ppm 0.090 ppm 0.074 ppm Days exceeding national 0.08 ppm 8-hour standard 1 1 0 Respirable Particulate Matter (PM10)* Maximum 24-hour concentration measured 47.0 µg/m3 44.0 µg/m3 45.0 µg/m3 Days exceeding national 150 µg/m3 24-hour standard 0 0 0 Days exceeding State 50 µg/m3 24-hour standard 0 0 0 Fine Particulate Matter (PM2.5) Maximum 24-hour concentration measured -- -- -- Days exceeding national 65 µg/m3 24-hour standard -- -- -- Carbon Monoxide (CO) Maximum 1-hour concentration measured 4.0 ppm 4.0 ppm 3.0 ppm Days exceeding national 35.0 ppm .1-hour standard 0 0 0 Days exceeding State 20.0 ppm 1-hour standard 0 0 0 Maximum 8-hour concentration measured 2.33 ppm 2.11 ppm 2.0ppm Days exceeding national & State 9.0 ppm 8-hour standard 0 0 0 Nitrogen Dioxide (NO2) Maximum 1-hour concentration measured 0.086 ppm 0.075 ppm 0.078 ppm Days exceeding State 0.25 ppm 1-hour standard 0 0 0 AAM 0.020 ppm 0.017ppm 0.017ppm Does measured AAM exceed national 0.0534 ppm AAM standard? No No No Note: ppm = parts per million by volume µg/m3 = micrograms per cubic meter AAM = annual arithmetic mean --No data * This data was not available from the Veterans Administration building in West Los Angeles and was therefore taken from the Westchester Parkway monitoring station. Source: South Coast Air Quality Management District, September 15, 2006.

Traffic-congested roadways and intersections have the potential to generate localized high levels of CO. Localized areas where ambient concentrations exceed national and/or state standards for CO are termed CO “hotspots.” The SCAQMD considers CO as a localized problem requiring additional analysis when a project is likely to subject sensitive receptors to CO hotspots. Land uses such as primary and secondary schools, hospitals, and convalescent homes are considered to be sensitive receptors to poor air quality because the very young, the old, and the infirm are more susceptible to respiratory infections and other air



quality-related health problems than the general public. Residential uses are considered sensitive because people in residential areas are often at home for extended periods of time, so they could be exposed to pollutants for extended periods. Recreational areas are considered moderately sensitive to poor air quality because vigorous exercise associated with recreation places a high demand on the human respiratory function.

The SCAQMD recommends the use of CALINE4, a dispersion model for predicting CO concentrations, as the preferred method of estimating localized pollutant concentrations at sensitive receptors near congested roadways and intersections. For each intersection analyzed, CALINE4 adds roadway-specific CO emissions calculated from peak-hour turning volumes to ambient CO air concentrations. For this analysis, localized CO concentrations were calculated based on a simplified CALINE4 screening procedure developed by the Bay Area Air Quality Management District and accepted by the SCAQMD. The simplified procedure is intended as a screening analysis, which identifies a potential CO hotspot. This methodology assumes worst-case conditions and provides a screening of maximum, worst-case CO concentrations. However, the emission factors used in the analysis have been updated to EMFAC2007 by the EIR consultant.5

Maximum existing 8-hour and 1-hour CO concentrations were calculated for the intersections included in the project traffic impact analysis that have sensitive receptors in close proximity and would be most affected by the traffic generated by the proposed project and cumulative development. The results of these calculations are presented in Table IV.C-3 for representative receptor locations at the roadway edge, and 25 and 50 feet from each roadway. The national 1-hour ambient air quality standard is 35.0 ppm and the State 1-hour ambient air quality standard is 20.0 ppm. The 8-hour national and State ambient air quality standard is 9.0 ppm.

As shown in Table IV.C-3, under worst-case conditions, existing CO concentrations near all of the study-area intersections do not exceed national or State ambient air quality standards. Therefore, CO hotspots do not exist near these intersections.

Existing Project Site Emissions

The proposed project site is currently developed with three separate residential apartment complexes totaling 112 units. Air pollutant emissions are generated by stationary and area-wide sources, such as space and water heating, landscape maintenance equipment, architectural coatings (painting), consumer products, and motor vehicle traffic traveling to and from the project site. The average daily emissions generated by the existing uses in 2007 at the site have been calculated utilizing the URBEMIS 2007 computer model recommended by the SCAQMD. The results of these calculations are presented in Table IV.C-4.

5 The emission factors used in the BAAQMD’s localized CO screening procedure are based on EMFAC7G, which is out of date by several years and has been superceded by newer emission factor models, the current version of which is EMFAC2007.



Table IV.C-3 Existing Localized Carbon Monoxide Concentrations

CO Concentrations in Parts Per Million

Roadway Edge 25 Feet 50 Feet Intersection 1-Hour 8-Hour 1-Hour 8-Hour 1-Hour 8-Hour

Olympic Boulevard & Beverly Glen 7.5 4.7 5.8 3.7 5.2 3.3 Olympic Boulevard & Kerwood Avenue 6.9 4.3 5.3 3.4 4.8 3.1 Olympic Boulevard & Bellwood Avenue (west) 6.8 4.3 5.2 3.3 4.7 3.0 Olympic Boulevard & Bellwood Avenue (east) 6.6 4.2 5.1 3.3 4.6 3.0 Olympic Boulevard & Century Park West 6.8 4.3 5.3 3.4 4.8 3.1 Note: National 1-hour standard is 35.0 ppm State 1-hour standard is 20.0 ppm National and State standard is 9.0 ppm Source: Christopher A. Joseph & Associates, 2007. Calculation sheets are provided in Appendix C. Based on year 2007 EMFAC2007 Winter emission factors.

Table IV.C-4 Estimated Daily Operational Emissions – Existing Project Site Land Uses – 2007

Emissions in Pounds per Day Emissions Source

VOC NOx CO SOx PM10 PM2.5

Summertime (Smog Season) Emissions Natural Gas 0.08 1.10 0.47 0.00 0.00 0.00 Landscape Maintenance Equipment 0.13 0.02 1.60 0.00 0.00 0.00 Architectural Coatings 0.42 -- -- -- -- -- Consumer Products 5.75 -- -- -- -- -- Motor Vehicles 5.62 4.58 56.64 0.04 6.55 1.25 Total Emissions 12.00 5.70 58.71 0.04 6.55 1.25 Winter Emissions Natural Gas 0.08 1.10 0.47 0.00 0.00 0.00 Consumer Products 5.75 -- -- -- -- -- Architectural Coatings 0.42 -- -- -- -- -- Motor Vehicles 5.71 5.65 55.44 0.03 6.55 1.25 Total Winter Emissions 11.96 6.75 55.91 0.03 6.55 1.25 Note: Subtotals may not appear to add correctly due to rounding in the URBEMIS 2007 model. Source: Christopher A. Joseph & Associates, 2007. Calculation sheets are provided in Appendix C.



ENVIRONMENTAL IMPACTS

Methodology

The air quality analysis presented in this Draft EIR focuses on the nature and magnitude of the change in the air quality environment due to implementation of the proposed project. Air pollutant emissions associated with the proposed project would result from project operations and from project-related traffic volumes. Construction activities would also generate air pollutant emissions at the project site and on roadways resulting from construction-related traffic. The net increase in project site emissions generated by these activities and other secondary sources (i.e., project emissions minus emissions from existing on-site activities) have been quantitatively estimated and compared to the thresholds of significance recommended by the District (see below). The methodology used to analyze the project’s air quality impacts are described below under separate subheadings.

Construction Emissions

The regional construction emissions associated with the proposed project are calculated using the URBEMIS 2007 computer model developed for the ARB by estimating the types and number of pieces of equipment that would be used to demolish existing structures, grade and excavate the project site, and construct the proposed development. These construction emissions are analyzed according to the regional thresholds established by the District in their Localized Significance Thresholds Methodology (LST). It is assumed that all of the construction equipment used would be diesel-powered.

To determine whether or not construction activities associated with the proposed project would create significant adverse localized air quality impacts on nearby sensitive receptors located off-site, the project’s construction emissions are also analyzed by performing air pollution dispersion modeling to determine the localized pollutant concentrations at nearby off-site sensitive receptors. The air quality dispersion modeling is done by defining the construction area footprint for the proposed project and setting up a series of sources across the project site such that an appropriate distribution of construction-related emissions (i.e., combustion and fugitive dust emissions) across the project site are generated. The construction emissions modeled for each criteria pollutant are those representing the worst-case day emissions based on the mass emissions calculations for each pollutant.

Operational Emissions

Regional operational emissions associated with the proposed project are estimated using the URBEMIS 2007 computer model developed for the ARB and the information provided in the traffic study prepared for the proposed project. Operational emissions would be comprised of mobile source emissions and area source emissions. Mobile source emissions are generated by the increase in motor vehicle trips to and from the project site associated with the operation of the proposed project. Area source emissions are generated by natural gas consumption for space and water heating, and landscape maintenance equipment. To determine if an air quality impact would occur, the increase in emissions is compared with the District’s recommended thresholds.



In addition, the SCAQMD CEQA guidance requires the potential risks from CO as emitted from traffic in concentrated areas. The localized CO concentration impacts associated with the proposed project have been evaluated with the addition of traffic growth associated with cumulative development. A simplified CALINE4 screening procedure was used to predict future CO concentrations at the study-area intersections in the vicinity of the project site in the year 2010 with cumulative development. The results of these calculations are provided in Table IV.C-9. The resulting emissions are compared with adopted national and State ambient air quality standards.

Hazardous Air Pollutants (HAPs)

The proposed project is a large mixed-use development that includes a notable retail component that would require the delivery of goods using medium and heavy duty diesel trucks. As emissions of diesel particulate matter from diesel engines are considered to be hazardous air pollutants, a screening analysis was performed on the estimated truck traffic at the project site to determine the impacts associated with hazardous air pollutants on nearby sensitive receptors (e.g., residential uses) in accordance with the methodology recommended by the District. This portion of the air quality analysis also addresses the extent to which off-site sources of hazardous air pollutants have the potential to impact on-site occupants.

Greenhouse Gas Emissions

The emissions generated by the proposed project, and indeed any project, are too small to influence global climate change on their own. Even if an individual project’s GHG emissions were large enough to influence global climate change, the significance of the impact of a single project on global climate cannot be determined at this time. First, no guidance exists to indicate what level of GHG emissions would be considered substantial enough to result in a significant adverse impact on global climate. Second, global climate change models are not sensitive enough to be able to predict the effect of a single project on global temperatures and the resultant effect on climate; therefore, they cannot be used to evaluate the significance of a project’s impact. Thus, insufficient information and predictive tools exist to assess whether a single project would result in a significant impact on global climate. Furthermore, as discussed previously, there are currently no adopted thresholds or guidance adopted by the District or other agencies in California to assess the significance of potential impacts associated with greenhouse gases. Although SB 97 requires the OPR to prepare CEQA guidelines for the mitigation of GHG emissions, these guidelines will not be finalized until July 1, 2009 and will not be certified or adopted until January 1, 2010. In the absence of established thresholds, however, a quantitative analysis containing an inventory of a project‘s GHG emissions and a qualitative analysis assessing a project’s compliance with adopted programs and policies to reduce GHG emissions have been suggested as a method to evaluate a project’s potential effect on climate change.6

6 Association of Environmental Professionals (AEP), Alternative Approaches to Analyzing Greenhouse Gas Emissions and Global Climate Change in CEQA Documents, Final, June 29, 2007.



In terms of generating an inventory of the proposed project’s GHG emissions, the California Climate Action Registry (CCAR) has prepared a protocol (CCAR Protocol) for calculating and reporting GHG emissions from a number of general and industry-specific activities. However, there is no clear guidance defining the extent to which direct and indirect emissions resulting from a project need be included under CEQA. For example, composting of yard waste and decomposing solid waste at landfills result in the emission of GHGs. From a global perspective, whether produced locally or throughout the world, the manufacture and transport of construction materials result in the emission of GHGs, and the loss of forests to produce wood products reduces the earth’s ability to retain carbon emissions. It is, however, reasonable to consider only the GHG emissions resulting from the incremental increase in usage of on-road mobile vehicles, electricity, and natural gas upon implementation of the proposed project as project-related. This approach is the same as that used in this DEIR section for criteria pollutants.

The consumption of fossil fuels to generate electricity and to provide heating and hot water for the proposed project, as well as the consumption of fuel by on-road mobile vehicles associated with the proposed project, creates GHG emissions. As such, in generating the GHG emissions for the proposed project, the future fuel consumption rates for the proposed project by these sources are estimated based on the proposed residential, retail, and office square footage. Natural gas and electricity demand factors typical for the City are used to project fuel consumption rates. The future fuel consumption rates by the on-road mobile vehicles are estimated using the vehicle fleet mix and daily vehicle miles traveled data generated by the URBEMIS 2007 computer model for the proposed project, and data obtained from the National Highway Traffic Safety Administration and U.S. Department of Energy pertaining to the fuel economy of each vehicle class. The GHG emission factors from the CCAR Protocol for natural gas, electricity, and mobile sources are then applied to the respective consumption rates, to calculate annual GHG emissions in metric tons.

Not all GHGs exhibit the same ability to induce climate change; as a result, greenhouse gas contributions are commonly quantified in carbon dioxide equivalencies (CO2e). The GHG mass emissions for the proposed project are calculated by converting pollutant specific emissions to CO2e emissions by applying the applicable global warming potential (GWP) value.7 These GWP ratios are published in the CCAP Protocol. By applying the GWP ratios, the proposed project-related CO2e emissions are converted to metric tons per year.

For the qualitative GHG emissions analysis for the proposed project, the 2006 CAT Report, as discussed previously, has recommended a list of strategies that the State could pursue to reduce climate changing greenhouse gas emissions. Thus, in the absence of regulatory guidance, this DEIR will also address the potential impacts associated with GHG emissions resulting from implementation of the proposed project by evaluating qualitatively whether the proposed project would be consistent with any of the emission reduction strategies identified by the CAT. It should be noted that many of the CAT strategies are

7 CO2E was developed by the Intergovernmental Panel on Climate Change (IPCC), and published in its Second Assessment Report (SAR) 1996.



applicable only to State agencies such as the ARB. Whereas some of the CAT strategies that apply to GHG emissions from the operational activities of a project can be implemented at the project level, the identified CAT strategies pertaining to construction-related GHG emissions can only be implemented by the ARB. In particular, the only two CAT strategies that are relevant to the construction-related GHG emissions associated with the proposed project include the development of regulations to require the use of one to four percent biodiesel displacement of California diesel fuel, and increasing the efficiency in the design of heavy duty vehicles. As neither of the recommended CAT strategies that are relevant to construction emissions can be implemented independently by the applicant, the analysis of the proposed project’s GHG emissions focuses on GHG emissions generated during the proposed project’s operational phase.

Thresholds of Significance

In accordance with Appendix G to the State CEQA Guidelines, a project may be deemed to have a significant adverse air quality impact if it would:

(a) Conflict with or obstruct implementation of the applicable air quality plan;

(b) Violate any air quality standard or contribute substantially to an existing or projected air quality violation;

(c) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors);

(d) Expose sensitive receptors to substantial pollutant concentrations; or

(e) Create objectionable odors affecting a substantial number of people.

The thresholds discussed below are currently recommended by the SCAQMD in the CEQA Air Quality Handbook to translate the State CEQA Guidelines thresholds into numerical values or performance standards. As discussed previously in this EIR section, the City utilizes the CEQA Air Quality Handbook as the guidance document for the environmental review of plans and development proposals within its jurisdiction.

Consistency with the Applicable AQMP

For general development projects, the SCAQMD uses the following two key indicators of consistency:

(1) Whether the project will not result in an increase in frequency or severity of existing air quality violations or cause or contribute to new violations, or delay timely attainment of air quality standards or the interim emissions reductions specified in the AQMP.

(2) Whether the project will exceed the assumptions in the AQMP in 2010 or increments based on the year of project build-out and phase.



In order to address the first criterion, an air quality modeling analysis that identifies the project’s impact on air quality will need to be performed. In order to be found consistent, the analysis will need to demonstrate that the project’s emissions will not increase the frequency or severity of existing violations, or contribute to a new violation at the project.

Consistency with the AQMP assumptions is determined by performing an analysis of the project with the assumptions in the AQMP for the year 2010. The proposed project will be evaluated based on its consistency with the population growth assumptions used in the AQMP.

Violation of Air Quality Standards or Substantial Contribution to Air Quality Violations

Construction Period Emissions – Mass Daily Emissions

The SCAQMD currently recommends that projects with construction-related mass daily emissions that exceed any of the following emissions thresholds should be considered significant8:

• 75 pounds per day of VOC

• 100 pounds per day of NOx

• 550 pounds per day of CO

• 150 pounds per day of SOx

• 150 pounds per day of PM10

• 55 pounds per day of PM2.5

The SCAQMD also recommends that any construction-related emissions from individual development projects that exceed these thresholds be considered cumulatively considerable. These thresholds apply to individual development projects only; they do not apply to the combined emissions generated by a set of cumulative development projects.

Operational Emissions – Mass Daily Emissions

The SCAQMD currently recommends that projects with operational mass daily emissions that exceed any of the following emissions thresholds should be considered significant:

• 55 pounds per day of VOC

• 55 pounds per day of NOx

• 550 pounds per day of CO

• 150 pounds per day of SOx

• 150 pounds per day of PM10

8 South Coast Air Quality Management District, Air Quality Significance Thresholds, revised December 2007, can be accessed online at: http://www.aqmd.gov/ceqa/handbook/signthres.pdf.



• 55 pounds per day of PM2.5

The SCAQMD also recommends that any operational emissions from individual projects that exceed these thresholds be considered cumulatively considerable.9 These thresholds apply to individual development projects only; they do not apply to the combined emissions generated by a set of cumulative development projects.

Cumulatively Considerable Net Increase of Criteria Pollutants

The SCAQMD’s CEQA Air Quality Handbook identifies several methods to determine the cumulative significance of land use projects (i.e., whether the contribution of a project is cumulatively considerable). However, the SCAQMD no longer recommends the use of these methodologies. Instead, the SCAQMD recommends that any construction-related emissions and operational emissions from individual development projects that exceed the project-specific daily emissions thresholds identified above also be considered cumulatively considerable. The SCAQMD neither recommends quantified analyses of the emissions generated by a set of cumulative development projects nor provides thresholds of significance to be used to assess the impacts associated with these emissions.

Exposure of Sensitive Receptors to Substantial Pollutant Concentrations

Construction Period Emissions – Localized Pollutant Concentrations

The SCAQMD currently recommends that projects with site-specific construction-related emissions that generate the following localized pollutant concentrations at existing human receptors should be considered significant:

• 10.4 micrograms per cubic meter (µg/m3) of PM10 averaged over a 24-hour period

• 10.4 micrograms per cubic meter of PM2.5 averaged over a 24-hour period

Because the Basin is currently in attainment of the national and State ambient air quality standards for NO2 and CO, the SCAQMD currently recommends that projects with construction-related emissions that cause the following ambient air quality standards to be exceeded or contributes substantially to an exceeded standard at existing human receptors should be considered significant:

• 0.25 parts per million NO2 averaged over a 1-hour period (State standard)

• 20 parts per million of CO averaged over a 1-hour period (State standard)

• 9.0 parts per million of CO averaged over an 8-hour period (national and State standard)

9 Ibid.



Operational Emissions – Localized Pollutant Concentrations

The SCAQMD currently recommends that projects with site-specific operational emissions that generate the following localized pollutant concentrations at existing human receptors should be considered significant:

• 2.5 micrograms per cubic meter (µg/m3) of PM10 averaged over a 24-hour period

• 2.5 micrograms per cubic meter of PM2.5 averaged over a 24-hour period

Because the Basin is currently in attainment of the national and State ambient air quality standards for NO2 and CO, the SCAQMD currently recommends that projects with site-specific operational emissions that cause the following ambient air quality standards to be exceeded or contributes substantially to an exceeded standard at existing human receptors should be considered significant:

• 0.25 parts per million NO2 averaged over a 1-hour period (State standard)

• 20 parts per million of CO averaged over a 1-hour period (State standard)

• 9.0 parts per million of CO averaged over an 8-hour period (national and State standard)

Operational Emissions - Localized CO Concentrations

The SCAQMD currently recommends that impacts to sensitive receptors be considered significant when localized CO concentrations at sensitive receptors located near congested intersections exceed the national or State ambient air quality standards and the traffic generated by the project contributes at least 1.0 ppm to the 1-hour concentrations or 0.45 ppm to the 8-hour concentrations. These thresholds would also apply to the contribution of emissions associated with cumulative development.

Toxic Air Contaminants

The SCAQMD also recommends that projects that could emit carcinogenic or toxic air contaminants that exceed the maximum individual cancer risk of 10 in one million be considered significant and cumulatively considerable.


While it is difficult to predict the specific impact of one project's incremental contribution to the global effects of GHG emissions due to a variety of factors, including the complex and long term nature of such effects and the global scale of climate change, it is possible to determine whether a project is implementing design strategies consistent with the guidance that is available. As an interim policy, the City of Los Angeles has recently provided a Memorandum of Understanding (MOU) that stipulates a zero-emission threshold for GHG emissions. Therefore, any project which generates GHG emissions would be considered incrementally cumulatively considerable. However, if a project implements design strategies that are consistent with the goals of AB32, the 2006 CAT strategies, and the Green LA Plan, the project would not be considered to have a significant impact with respect to global climate change, either



on a project-specific basis or with respect to its contribution to a cumulative impact on global climate change.

Project Impacts

Consistency with Applicable Air Quality Planning Documents and Regional Initiatives

Project Design Features

The project incorporates a number of design characteristics that would help to reduce the operational emissions that would otherwise be generated. These characteristics include the following:

• The project provides housing in an area that has an acute and deepening housing shortage, and in an area that is located less than a mile from Century City and close to Westwood/UCLA, both of which are designated Regional Centers for employment and commerce;

• The project increases the density of residential use of the site, thereby providing a larger number of units close to major employment centers, and likely reducing VMT by persons commuting to work;

• The project provides housing within close proximity to public transit;

• Consistent with City of Los Angeles policy, the project includes air filters capable of achieving a Minimum Efficiency Rating Value (MERV) of at least 8 or better (for residential uses) or 11 or better (for non-residential uses).

Air Quality Management Plan (SCAQMD/SCAG)

The purpose of the AQMP is to bring the Basin into compliance with State and federal standards. A significant impact may occur if the project is not consistent with the AQMP or would in some way represent a substantial hindrance to employing the policies or obtaining the goals of that plan. The project’s consistency with the AQMP is summarized below with respect to a set of Consistency Criteria identified in the AQMP. Additionally, consistency with the AQMP ensures that the project would not result in a cumulative impact to air quality (in the absence of project-specific violations of State and federal air quality standards).

Consistency Criterion No. 1: The proposed project would not result in an increase in the frequency or severity of existing air quality violations or cause or contribute to new violations, or delay the timely attainment of air quality standards or the interim emissions reductions specified in the AQMP.

Consistency Criterion No. 1 refers to the California Ambient Air Quality Standards (CAAQS). The SCAQMD has identified carbon monoxide (CO) as the best indicator pollutant for determining whether air quality violations would occur since it is most directly related to automobile traffic. The CO hotspot



analysis (described below) indicates that the project would not exacerbate existing violations of the State one-hour and eight-hour CO concentration standards and no significant adverse impacts are anticipated. Therefore, the project is consistent with Consistency Criterion No. 1.

Consistency Criterion No. 2: The proposed project would not exceed the assumptions in the AQMP in 2010 or increments based on the year of project build-out phase.

The future air quality levels projected in the 2003 AQMP are based on several assumptions. For example, the SCAQMD assumes that general new development within the Basin will occur in accordance with population growth and transportation projections identified by SCAG in its most current version of the RCPG, which was adopted in March 1996. SCAG derives its assumptions, in part, based on the general plans of cities located within the SCAG region. Therefore, if a project is consistent with the growth projections in the General Plan, it is considered consistent with the growth assumptions in the AQMP. The analysis in Section IV.H (Land Use and Planning) of this Draft EIR (under the “Consistency with Land Use Plans, Policies, and Regulations” heading) indicates that the project would be consistent with the growth projections in the RCPG, which form the basis for growth projections in the AQMP.

Another measurement tool used in determining consistency with the AQMP is to determine how a project accommodates the expected increase in population or employment. Generally, if a project is planned in a way that it results in the minimization of VMT, both within the project and the community in which it is located, and consequently the minimization of air pollutant emissions, that aspect of the project is consistent with the AQMP.

In its separate guidance document for local government concerning integrating regional air quality goals and objectives with local general plans and decisions about development,10 SCAQMD also highlights “jobs-housing balance” as a strategy to reduce vehicle trips and VMT, when sufficient jobs are available locally to balance the employment demands of the community, and when commercial services are convenient to residential areas. As discussed in Section IV.J (Population and Housing) of this Draft EIR, the project’s addition of 46 net new dwelling units within the City of Los Angeles subregion would improve the subregion’s jobs-housing balance, as measured using SCAG’s most recent regional growth forecast.11 Further, the project site’s location in proximity to Century City and Westwood/UCLA and other employment centers in the area would provide new opportunities for workers to reside closer to their place of employment. As a result, the project would likely reduce VMT, and would comply with Consistency Criterion No. 2.

Because the project is consistent with both AQMP Consistency Criteria Nos. 1 and 2, the project is considered to be consistent with the AQMP.

10 SCAQMD, Guidance Document for Addressing Air Quality Issues in General Plans and Local Planning, May 2005, p. 2-13.

11 SCAG’s October 11, 2005 NOP comment letter encourages use of SCAG policy numbers.



Regional Comprehensive Plan and Guide (SCAG)

The degree to which the project is responsive to air quality-related policies included in the Growth Management Chapter of the RCPG is presented below. For additional discussion of the project’s consistency with the RCPG see Sections IV.H (Land Use and Planning) and IV.J (Population and Housing) of this Draft EIR.

3.01 The population, housing and jobs forecasts, which are adopted by SCAG’s Regional Council and reflect local plans and policies, shall be used by SCAG in all phases of implementation review.

The project is located in the City of Los Angeles subregion. As presented in Section IV.J (Population and Housing) of this Draft EIR, the project’s new multi-family ownership units and their estimated population increase of 93 persons represent 3.8 percent of both SCAG’s households and population forecast for the subregion between 2004 and 2010 (see Tables IV.J-2 and IV.J-3 in Section IV.J [Population and Housing] of this Draft EIR). The project would be consistent with this objective.

3.04 Encourage local jurisdictions’ efforts to achieve a balance between the types of jobs they seek to attract and housing prices.

The project would add 158 new market rate multi-family ownership units (46 net new units when the existing 112 units are taken into account) primarily targeted to entry level buyers proximate to Century City, Westwood/UCLA, and the Beverly Hills commercial core where regional employers are concentrated.

According to the SCAG regional growth forecast, the Los Angeles Subregion’s ratio of jobs to households (1.378) currently exceeds the regional ratio (1.337), and it is therefore considered “jobs rich and housing poor.” By 2012, the SCAG forecast indicates the Subregional ratio will worsen to 1.448, without the project, compared to 1.392 in the region. The project's 158 new housing units (46 net new units) will contribute to improving this ratio.

The project would be consistent with this objective.

3.05 Encourage patterns of urban development and land use that reduce costs on infrastructure construction and make better use of existing facilities.

The project would be an infill development, located in an urbanized area with existing infrastructure. The project would utilize and make better use of existing infrastructure, and would therefore be consistent with this objective. The project would increase the density of residential use bringing more housing units closer to major employment centers. The project would be consistent with this objective.



3.09 Support local jurisdictions’ efforts to minimize the cost of infrastructure and public service delivery, and efforts to seek new sources of funding for development and the provision of services.

The project would be an infill project in an area served by existing infrastructure. Connections to existing infrastructure would be provided by the development, thus minimizing the public cost of the project. Private funds would be used for services that supplement public services (e.g., private on-site security personnel and equipment), making development at this location less costly than at other locations without the existing infrastructure and private funding. This issue and related mitigation measures are discussed in Sections IV.K (Public Services) and IV.M (Utilities and Service Systems) of this Draft EIR. The project would be consistent with this objective.

3.12 Encourage existing or proposed local jurisdictions’ programs aimed at designating land uses which encourage the use of transit and thus reduce the need for roadway expansion, reduce the number of auto trips and vehicle miles traveled, and create opportunities for residents to walk and bike.

The project would be an infill development that would take advantage of infrastructure already in place and would require minimal roadway expansion. The project would increase the density of residential use bringing more housing units closer to major employment centers. This additional density would be located immediately adjacent to Century City, enabling walking trips to work and shopping, in an area currently served by public transit (buses), and would be located near existing transportation corridors. The project’s multi-family density is more supportive of transit use. The project would incorporate a shuttle stop for a Century City area shuttle. The project would be consistent with this objective.

3.13 Encourage local jurisdictions’ plans that maximize the use of existing urbanized areas accessible to transit through infill and redevelopment.

The project would be an infill project in an existing urbanized area. The infill development would occur on a site currently served by existing public transit (buses), and is on an existing transportation corridor. The project would increase the density of residential use bringing more housing units closer to major employment centers. This additional density would be located immediately adjacent to Century City in an area currently served by public transit (buses), and would be located near existing transportation corridors. The project’s multi-family density is more supportive of transit use than lower single-family density. The project would maximize the use of an existing transit-served urbanized area. The project would be consistent with this objective.

3.14 Support local plans to increase density of future development located at strategic points along the regional commuter rail, transit systems, and activity centers.

The project would is located immediately adjacent to Century City, will incorporate a stop for a Century City area shuttle, and is immediately adjacent to a public transit route along Olympic Boulevard. The project would be consistent with this objective.



3.15 Support local jurisdictions’ strategies to establish mixed-use clusters and other transit-oriented developments around transit stations and along transit corridors.

The project provides additional housing adjacent to Century City and nearby Westwood/UCLA which are designated Regional Centers, as well as nearby the Beverly Hills commercial core. The project is located immediately adjacent to a public transit (bus) routes along Olympic Boulevard. The project’s multi-family density is supportive of transit use. The project will incorporate a stop for a Century City shuttle. The project's proximity to Century City makes walking trips to work, shopping and entertainment possible. The project would be consistent with this objective.

3.16 Encourage development in and around activity centers, transportation corridors, underutilized infrastructure systems, and areas needing recycling and redevelopment.

The project site is an infill development site. The project would be located along a major transportation corridor with bus service and adjacent to major local and regional activity centers. The project would be consistent with this objective.

3.17 Support and encourage settlement patterns which contain a range of urban densities.

The project will increase the residential density of the site and the number of housing units provided at the site proximate to major employment centers. Even if the project is developed as proposed, however, it is likely that a significant unmet housing need will remain in the City of Los Angeles. The project would address housing needs that are currently unmet and are contributing to urban sprawl and associated automobile trip emissions in contravention of the RCPG and AQMP. The project’s density falls within the range of densities found within the area, and provides housing closer to jobs at densities that are consistent with the VMT reduction strategies of the RCPG and AQMP. The project would be consistent with this objective.

3.24 Encourage efforts of local jurisdictions in the implementation of programs that increase the supply and quality of housing and provide affordable housing as evaluated in the Regional Housing Needs Assessment (RHNA).

The project’s new multi-family units would assist the City of Los Angeles in addressing a chronic undersupply of housing in general, as discussed in the City’s Housing Element and the Citywide Housing Crisis Task Force Report and for multi-family units and units for seniors in particular. This would assist the City in meeting its next RHNA for the post-2005 Housing Element planning period, which is currently being developed by SCAG. Although the project’s specific unit pricing has not been established at this time, the applicant has indicated that the project will be primarily targeted to entry-level buyers in the area. The project also proposes to set aside 5% of its units for very low income households. The project would be consistent with this objective.



Regional Transportation Plan (SCAG)

The following 2004 RTP goals are relevant to the project:

• Maximize mobility and accessibility for all people and goods in the region.

The project would be consistent with this goal by virtue of its character as an infill development that is located in an area of the SCAG region that is “jobs rich and housing poor.” The project would add new market rate multi-family ownership units proximate to designated Regional Centers such as Century City, Westwood/UCLA, as well as the Beverly Hills commercial core, all of which are major employment, shopping, educational, and employment centers.

The project site is currently served by public transit (buses) and is immediately adjacent to a public transit route along Olympic Boulevard. The project would also provide a shuttle stop for a Century City area shuttle. The project would be consistent with this objective.

• Preserve and ensure a sustainable regional transportation system.

The project would be consistent with this goal by virtue of its character as an infill development that is located in an area of the SCAG region that is “jobs rich and housing poor.” The project would add new market rate multi-family ownership units for families and seniors to the West Los Angeles Community Plan area proximate to some of the designated Regional Centers of Century City, Westwood/UCLA, and the Beverly Hills commercial core. The project site is currently served by public transit (buses) and is immediately adjacent to a public transit route along Olympic Boulevard and will incorporate a shuttle stop for a Century City area shuttle. Further, the project's proximity to Century City, and urban design will encourage walking trips, bicycling, and public transit. The project would be consistent with this objective.

• Maximize the productivity of our transportation system.

The project would be consistent with this goal by virtue of its character as an infill development that is located in an area of the SCAG region that is “jobs rich and housing poor.” The project would add new market rate multi-family ownership units proximate to the designated Regional Centers of Century City, Westwood/UCLA, and the Beverly Hills commercial core. The project site is currently served by public transit (buses) and is immediately adjacent to a public transit route along Olympic Boulevard and will incorporate a shuttle stop for a Century City area shuttle. Further, the project's proximity to Century City, and urban design will encourage walking trips, bicycling, and public transit. The project would be consistent with this objective.

• Protect the environment, improve air quality and promote energy efficiency.

The project would be consistent with this goal by virtue of its character as an infill development that would add new market rate multi-family ownership units to an area of the SCAG region that is “jobs rich and housing poor.” The project would add new market rate multi-family ownership units proximate to



the designated Regional Centers of Century City, Westwood/UCLA, and the Beverly Hills commercial core. The project site is currently served by public transit (buses) and is immediately adjacent to a public transit route along Olympic Boulevard and will incorporate a shuttle stop for a Century City area shuttle. Further, the project's proximity to Century City, and urban design will encourage walking trips, bicycling, and public transit. The project thus addresses currently unmet housing needs that are contributing to urban sprawl and associated automobile trip emissions, and provides housing closer to jobs at densities that are consistent with the VMT reduction strategies of the RCPG and AQMP. The project would also likely reduce vehicle trips, VMT, and related emissions by including convenience retail and services for future residents. The project is consistent with and would implement relevant AQMP, RCPG, and RTP strategies to attain and maintain compliance with federal and State ambient air quality standards. The project would be consistent with this objective.

• Encourage land use and growth patterns that complement our transportation investments.

The transportation investments to which the above goal refers are outlined in the six-year RTPs that are developed every two years. These investments are selected based on a series of performance indicators established in the RTP. These performance indicators are, in part, oriented toward improving the performance of the transportation infrastructure and systems so that such ancillary benefits such as reducing commuting times and improving air quality are achieved. The project would be consistent with this goal by virtue of its character as an infill development that is located designated Regional Centers of Century City, Westwood/UCLA, and the Beverly Hills commercial core. The project is also adjacent to a regional transportation corridor utilized by public transit, and in an area of the SCAG region that is “jobs rich and housing poor.” The project would be consistent with this objective.

For additional discussion of the project’s consistency with the RTP and related transportation-oriented planning documents, see Sections IV.H (Land Use and Planning) and IV.L (Transportation and Traffic) of this Draft EIR.

Construction-Related Impacts

Construction Period Emissions – Mass Daily Emissions

During construction of the proposed project, three basic types of activities would be expected to occur and generate emissions. First, 41,939 square feet of existing residential uses would be demolished. Second, the development site would be prepared, excavated, and graded to accommodate the subterranean parking structures and building foundations. Third, the residential units would be constructed.

The analysis of daily construction emissions has been prepared utilizing the URBEMIS 2007 computer model recommended by the SCAQMD. Due to the construction time frame and the normal day-to-day variability in construction activities, it is difficult, if not impossible, to precisely quantify the daily emissions associated with each phase of the proposed construction activities. Nonetheless, Table IV.C-5 identifies daily emissions that are estimated to occur on peak construction days along with the thresholds of significance recommended by the SCAQMD and used by the City of Los Angeles. The daily construction



Table IV.C-5 Estimated Daily Construction Emissions



Site Demolition Phase (2009) Fugitive Dust -- -- -- -- 8.82 1.83 Off-Road Diesel Equipment 3.25 25.16 14.26 0.00 1.48 1.37 On-Road Diesel Equipment 0.80 10.62 4.15 0.01 0.50 0.44 Worker Trips 0.04 0.07 1.21 0.00 0.01 0.00 Total Emissions 4.08 35.86 19.63 0.01 10.82 3.64 SCAQMD Thresholds 75.00 100.00 550.00 150.00 150.00 55.00 Significant Impact? No No No No No No Site Grading and Excavation Phase (2009) Fugitive Dust -- -- -- -- 65.44 13.67 Off-Road Diesel Equipment 4.11 34.64 17.17 0.00 1.75 1.61 On-Road Diesel Equipment 1.39 18.50 7.23 0.02 0.88 0.76 Worker Trips 0.04 0.07 1.21 0.00 0.01 0.00 Total Emissions 5.54 53.21 25.62 0.02 68.08 16.04 SCAQMD Thresholds 75.00 100.00 550.00 150.00 150.00 55.00 Significant Impact? No No No No No No Building Construction Phase (2009) Off-Road Diesel Equipment 1.90 15.31 7.07 0.00 0.86 0.79 Vendor Trips 0.50 5.98 4.47 0.01 0.29 0.25 Worker Trips 0.41 0.75 12.31 0.01 0.09 0.05 Total Emissions 2.80 22.03 23.84 0.02 1.25 1.09 SCAQMD Thresholds 75.00 100.00 550.00 150.00 150.00 55.00 Significant Impact? No No No No No No Building Construction Phase (2010) Off-Road Diesel Equipment 1.78 14.34 6.79 0.00 0.83 0.76 Vendor Trips 0.47 5.61 4.17 0.01 0.27 0.23 Worker Trips 0.37 0.69 11.44 0.01 0.09 0.05 Total Emissions 2.62 20.63 22.40 0.02 1.19 1.04 SCAQMD Thresholds 75.00 100.00 550.00 150.00 150.00 55.00 Significant Impact? No No No No No No Building Construction Phase (with paving and coating) (2010) Building Construction Off-Road Diesel Equipment 1.78 14.34 6.79 0.00 0.83 0.76

Building Construction Vendor Trips 0.47 5.61 4.17 0.01 0.27 0.23 Building Construction Worker Trips 0.37 0.69 11.44 0.01 0.09 0.05 Architectural Coatings Off-Gas 29.35 -- -- -- -- -- Architectural Coatings Worker Trips 0.05 0.09 1.52 0.00 0.01 0.01 Asphalt Off-Gas 0.05 -- -- -- -- -- Asphalt Off-Road Diesel Equipment 2.40 14.50 8.17 0.00 1.25 1.15 Asphalt On-Road Diesel Equipment 0.03 0.34 0.13 0.00 0.02 0.01 Asphalt Worker Trips 0.06 0.12 1.97 0.00 0.02 0.01 Total Emissions 34.56 35.68 34.19 0.03 2.49 2.22 SCAQMD Thresholds 75.00 100.00 550.00 150.00 150.00 55.00 Significant Impact? No No No No No No Note: Subtotals may not appear to add correctly due to rounding in the URBEMIS 2007 model. Source: Christopher A. Joseph & Associates, 2007. Calculation sheets are provided in Appendix C.



emissions shown in Table IV.C-5 have been estimated for peak construction days based on assumptions described below.

Demolition

The demolition phase for the proposed project is expected to occur over a 20-day work period. The most intense activities associated with demolition at the project site would involve the use of the following equipment: one (1) concrete/industrial saw, one (1) rubber tired dozer, and two (2) tractors/loaders/backhoes. Each of these pieces of equipment is assumed to operate a maximum of eight hours per day.

Grading

The grading phase for the proposed project is expected to occur over an 80-day work period. The most intense activities associated with site grading at the project site would involve the use of the following equipment: one (1) grader, one (1) rubber tired dozer, one (1) tractor/loader/backhoe, and one (1) water truck. Each of these pieces of equipment is assumed to operate a maximum of eight hours per day.

Building Construction

The building phase for the proposed project is expected to occur over a 180-day work period. During this phase, the maximum daily amount of equipment that would operate onsite would include the following: one (1) crane, two (2) forklifts, and one (1) tractor/loader/backhoe. Each of these pieces of equipment is assumed to operate a maximum of eight hours per day.

Asphalt/Architectural Coating

The asphalt and architectural coating phase of the project is expected to occur over a 30-day period concurrent with the last 30 days of the building construction phase. During this phase, the maximum daily amount of equipment that would operate onsite would include the following: four (4) cement and mortar mixers, one (1) paver, one (1) roller, and one (1) tractor/loader/backhoe. Each of these pieces of equipment is assumed to operate a maximum of eight hours per day.

As shown in Table IV.C-5, emissions generated during the project’s construction period would not exceed the thresholds recommended by the SCAQMD. Therefore, the impacts from mass construction emissions are considered to be less than significant.

Construction Period Emissions – Localized Emissions of CO, NOx, PM10, and PM2.5

The SCAQMD has developed localized significance threshold (LST) look-up tables for project sites that are one, two, and five acres in size to simplify the evaluation of localized emissions at small sites. LSTs are provided for each SRA and various distances from the source of emissions. In the case of this proposed project, the nearest homes are directly south and east of the project site. Therefore, the LSTs for a two acre site with receptors located within 25 meters are used to address the potential localized NOx and CO impacts to the area immediately surrounding the project site. The average daily construction



emissions that would be generated at the project site during the construction phases are shown in Table IV.C-6 along with the applicable LSTs for SRA 2.

Table IV.C-6 Localized Construction-Related Air Quality Impacts – Proposed Project


NOx CO PM10* PM2.5* Site Demolition Phase (2009) Total Site-Specific Emissions 34.5 14.8 2.3 2.0 SCAQMD LSTs for SRA 2 218.71 777.81 6.37 4.11 Significant Impact? No No No No Site Grading and Excavation Phase (2009) Total Site-Specific Emissions 39.9 16.3 3.6 2.3 SCAQMD LSTs for SRA 2 218.71 777.81 6.37 4.11 Significant Impact? No No No No Building Construction Phase (2009) Total Site-Specific Emissions 33.5 18.3 3.0 2.8 SCAQMD LSTs for SRA 2 218.71 777.81 6.37 4.11 Significant Impact? No No No No Building Construction Phase (2010) Total Site-Specific Emissions 31.8 18.1 2.9 2.6 SCAQMD LSTs for SRA 2 218.71 777.81 6.37 4.11 Significant Impact? No No No No Building Construction Phase (with paving and coating) (2010) Total Site-Specific Emissions 50.1 28.9 4.4 4.0 SCAQMD LSTs for SRA 2 218.71 777.81 6.37 4.11 Significant Impact? No No No No *Includes a 68% reduction in fugitive particulate emissions per SCAQMD Rule 403. Source: Christopher A. Joseph & Associates, 2007. Calculation sheets are provided in Appendix C.

This analysis assumes that the project site will be watered at least 3 times a day per SCAQMD Rule 403. As shown, construction-related daily emissions will not exceed the SCAQMD localized significance thresholds. Therefore project impacts on localized pollutant concentrations are less than significant.

Operational Impacts

Operational Emissions – Mass Daily Emissions

Operational emissions generated by both stationary and mobile sources would result from normal day-to-day activities on the project site after occupation. Stationary area source emissions would be generated by the consumption of natural gas for space and water heating devices and cooking appliances, the operation of landscape maintenance equipment, the use of consumer products, and the application of architectural coatings (paints). Mobile emissions would be generated by the motor vehicles traveling to and from the project site.



The analysis of daily operational emissions has been prepared utilizing the URBEMIS 2007 computer model recommended by the SCAQMD. The results of these calculations are presented in Table IV.C-7. As shown, the proposed project would not generate a net increase in average daily emissions that exceeds the thresholds of significance recommended by the SCAQMD. This is a less than significant impact.

Operational Emissions – Localized Emissions of CO, NOx, PM10, and PM2.5

The average daily emissions associated with stationary and area sources, and motor vehicles operating within the project site have the potential to generate localized emissions of NOx, CO, PM10, and PM2.5. The average daily emissions have been calculated assuming that each vehicle would travel a maximum of 0.1 mile within the project site. The results of these calculations for area sources and the internal vehicle trips are shown in Table IV.C-8. As shown, the average daily emissions generated within the project site would not exceed the applicable operational LSTs for SRA 2. This is a less than significant impact.

Operational Emissions – Localized CO Concentrations

The localized CO concentration impacts associated with the proposed project have been evaluated with the addition of traffic growth associated with cumulative development.

As was done to assess existing CO concentrations, the simplified CALINE4 screening procedure was used to predict future CO concentrations at the study-area intersections in the vicinity of the project site in the year 2010 with cumulative development. The results of these calculations are provided in Table IV.C-9.

As shown, future CO concentrations near these intersections would not exceed the national and State ambient air quality standards for CO. Therefore, implementation of the proposed project and cumulative development would not expose any possible sensitive receptors (such as residential uses, schools, hospitals) located in close proximity to these intersections to substantial localized pollutant concentrations. This would be a less than significant impact regarding the exposure of sensitive receptors to substantial pollutant concentrations.

Operational Emissions – Toxic Air Contaminants

Diesel particulate emissions, a known toxic air contaminant, would occur from trucks picking up garbage and recyclable materials, and making deliveries to the project site. To address diesel particulate emissions, statewide programs and regulations are presently being developed and implemented by the ARB and U.S. EPA to reduce the risks of exposure to diesel exhaust. These programs include emission control requirements along with subsidies for upgrading older diesel engines to low-emissions models. In light of the available information, the effects of the toxic emissions from future vehicle operations at the project site are not expected to be substantial.



Table IV.C-7 Estimated Daily Operational Emissions – Proposed Project – 2010



Summertime (Smog season) Emissions Proposed Land Uses Natural Gas 0.12 1.55 0.66 0.00 0.00 0.00 Landscape Maintenance Equipment 0.13 0.02 1.60 0.00 0.00 0.00 Consumer Products 8.11 -- -- -- -- -- Architectural Coatings 0.27 -- -- -- -- -- Motor Vehicles 10.37 9.14 113.08 0.09 16.09 3.08 Subtotal 19.00 10.71 115.34 0.09 16.09 3.08 Existing Land Uses Natural Gas 0.08 1.10 0.47 0.00 0.00 0.00 Landscape Maintenance Equipment 0.13 0.02 1.60 0.00 0.00 0.00 Architectural Coatings 0.19 -- -- -- -- -- Consumer Products 5.75 -- -- -- -- -- Motor Vehicles 5.62 4.58 56.64 0.04 6.55 1.25 Subtotal 11.77 5.70 58.71 0.04 6.55 1.25 Total Net Increase (Proposed – Existing) 7.23 5.01 56.63 0.05 9.54 1.83 SCAQMD Thresholds 55.00 55.00 550.00 150.00 150.00 55.00 Significant Impact? No No No No No No Wintertime Emissions Proposed Land Uses Natural Gas 0.12 1.55 0.66 0.00 0.00 0.00 Consumer Products 8.11 -- -- -- -- -- Architectural Coatings 0.27 -- -- -- -- -- Motor Vehicles 11.07 11.22 110.92 0.08 16.09 3.08 Subtotal 19.57 12.77 111.58 0.08 16.09 3.08 Existing Land Uses Natural Gas 0.08 1.10 0.47 0.00 0.00 0.00 Architectural Coatings 0.19 -- -- -- -- -- Consumer Products 5.75 -- -- -- -- -- Motor Vehicles 5.71 5.65 55.44 0.03 6.55 1.25 Subtotal 11.73 6.75 55.91 0.03 6.55 1.25 Total Net Increase (Proposed – Existing) 7.84 6.02 55.67 0.05 9.54 1.83 SCAQMD Thresholds 55.00 55.00 550.00 150.00 150.00 55.00 Significant Impact? No No No No No No Note: Subtotals may not appear to add correctly due to rounding in the URBEMIS 2007 model. Source: Christopher A. Joseph & Associates, 2007. Calculation sheets are provided in Appendix C.

Toxic or carcinogenic air pollutants are not expected to occur in any meaningful amounts in conjunction with operation of the proposed land uses at the project site. Only small quantities of common forms of



hazardous or toxic substances, such as cleaning agents, which are typically used or stored in conjunction with residential uses, would be present. Most uses of such substances would occur indoors. Based on the common uses expected on the site, any emission would be minor.

Table IV.C-8 Localized Operational Air Quality Impacts – Proposed Project


NOx CO PM10 PM2.5 Summertime Emissions Area Sources 1.57 2.26 0.00 0.00 Motor Vehicles 1.11 15.96 0.18 0.05 Total Localized Emissions 2.68 18.22 0.18 0.05 SCAQMD LSTs for SRA 2 218.71 777.81 2.05 1.05 Significant Impact? No No No No Wintertime Emissions Area Sources 1.55 0.66 0.00 0.00 Motor Vehicles 1.29 18.99 0.18 0.05 Total Localized Emissions 2.84 19.65 0.18 0.05 SCAQMD LSTs for SRA 2 218.71 777.81 2.05 1.05 Significant Impact? No No No No Note: Subtotals may not appear to add correctly due to rounding in the URBEMIS2007 model. Source: Christopher A. Joseph & Associates, 2007. Calculation sheets are provided in Appendix C.

Table IV.C-9 Predicted Future Localized Carbon Monoxide Concentrations

CO Concentrations in Parts Per Million

Roadway Edge 25 Feet 50 Feet Intersection 1-Hour 8-Hour 1-Hour 8-Hour 1-Hour 8-Hour

Olympic Boulevard and Beverly Glen 6.5 4.1 5.2 3.3 4.7 3.0 Olympic Boulevard and Kerwood Ave 6.1 3.9 4.8 3.1 4.4 2.8 Olympic Boulevard and Bellwood Ave (west) 6.0 3.8 4.8 3.1 4.4 2.8 Olympic Boulevard and Bellwood Ave (east) 5.9 3.7 4.7 3.0 4.3 2.8 Olympic Boulevard and Century Park West 6.1 3.9 4.9 3.1 4.5 2.9 Note: National 1-hour standard is 35.0 ppm State 1-hour standard is 20.0 ppm National and State standard is 9.0 ppm Source: Christopher A. Joseph & Associates, 2007. Calculation sheets are provided in Appendix C. Based on year 2010 EMFAC2007 Winter emission factors.



This would be a less than significant impact regarding the exposure sensitive receptors to substantial pollutant concentrations

Operational Emissions – Airborne Odors

The occurrence and severity of potential odor impacts depends on numerous factors. The nature, frequency, and intensity of the source, the wind speeds and direction, and the sensitivity of the receiving location each contribute to the intensity of the impact. While offensive odors rarely cause any physical harm, they can be unpleasant and cause distress among the public and generate citizen complaints.

Odors are typically associated with the use of chemicals, solvents, petroleum products, and other strong-smelling elements used in manufacturing processes. The proposed project would include residential uses, and would not contain any of the above-listed odor producing uses. Instead potential operational airborne odors could result from cooking activities associated with the new residential units. These odors would be minimal, if noticeable at all; would be similar to existing residential and commercial uses in the local vicinity; and would be confined to the immediate vicinity of the new buildings. Therefore, implementation of the proposed project is not expected to create objectionable odors affecting a substantial number of people. This is a less than significant impact


The emissions generated by the proposed project, and indeed any project, are too small to influence global climate change on their own. Even if an individual project’s GHG emissions were large enough to influence global climate change, the significance of the impact of a single project on global climate cannot be determined at this time. First, no guidance exists to indicate what level of GHG emissions would be considered substantial enough to result in a significant adverse impact on global climate. Second, global climate change models are not sensitive enough to be able to predict the effect of a single project on global temperatures and the resultant effect on climate; therefore, they cannot be used to evaluate the significance of a project’s impact. Thus, insufficient information and predictive tools exist to assess whether a single project would result in a significant impact on global climate. For these reasons, determining the significance of the impact of the proposed project on global climate is speculative, and a reasonable conclusion cannot be reached. Furthermore, there are currently no adopted thresholds or guidance adopted by the SCAQMD or other agencies in California to assess the significance of potential impacts associated with greenhouse gases. In the absence of established thresholds, however, a quantitative analysis containing an inventory of a project‘s GHG emissions and a qualitative analysis involving a project’s compliance with adopted programs and policies to reduce GHG emissions have been suggested as a method to evaluate a project’s potential effect on climate change.12

12 Association of Environmental Professionals (AEP), Alternative Approaches to Analyzing Greenhouse Gas Emissions and Global Climate Change in CEQA Documents, Final, June 29, 2007.



In terms of generating an inventory of the proposed project’s GHG emissions, the California Climate Action Registry (CCAR) published version 2.2 of its General Reporting Protocol (Protocol) in March 2007 as a means for businesses, government agencies, and non-profit organizations to calculate GHG emissions from a number of general and industry-specific activities and participate in the Registry. This Protocol is not intended for CEQA purposes, but it does provide methods that can be used to quantify the GHG emissions of CO2, CH4, and N2O associated with a project’s increase in on-road mobile vehicle operations, electricity consumption, and natural gas consumption.

The consumption of fossil fuels to generate electricity and to provide heating and hot water for the proposed project, as well as the consumption of fuel by on-road mobile vehicles associated with the proposed project, has the potential to create GHG emissions. As such, in generating the GHG emissions for the proposed project, the future fuel consumption rates for the proposed project by these sources are estimated based on the amount of proposed residential units. Natural gas and electricity demand factors derived from the SCAQMD’s CEQA Air Quality Handbook are used to project fuel consumption rates. The GHG emission factors from the CCAR Protocol for natural gas and electricity are then applied to the respective consumption rates, to calculate annual GHG emissions in metric tons. Mobile source CO2 emissions were obtained from the URBEMIS2007 emissions inventory model. Mobile source CH4 and N2O emissions were obtained using vehicle miles traveled data generated by URBEMIS2007 and emission factors obtained from the CARB’s EMFAC2007 model. It should be noted that it is difficult to identify the specific generating source of electricity. The Los Angeles Department of Water and Power (LADWP) produces power at City-operated plants and also imports power during peak demand periods. The emission factors used in this analysis represent a State-wide average of known power producing facilities, utilizing various technologies and emission control strategies, and do not take into account the LADWP’s unique emissions profile nor do they reflect targeted future reductions in GHG emissions under SB 1368 or the LA Green Plan. At this time, these emission factors are considered conservative and representative.

Not all greenhouse gases exhibit the same ability to induce climate change; as a result, greenhouse gas contributions are commonly quantified in carbon dioxide equivalencies (CO2e). The GHG mass emissions for the proposed project are calculated by converting pollutant specific emissions to CO2e emissions by applying the applicable global warming potential (GWP) value.13 These GWP ratios are published in the CCAR Protocol. By applying the GWP ratios, the proposed project-related CO2e emissions are converted to metric tons per year.

For the qualitative GHG emissions analysis for the proposed project, the 2006 CAT Report, as discussed previously, has recommended a list of strategies that the State could pursue to reduce climate change greenhouse gas emissions. Thus, in the absence of any other adopted thresholds, this Draft EIR assumes that the Proposed Project would be considered to generate a substantial increase in greenhouse gas emissions if it is not consistent with the CAT Report strategies that the Lead Agency deems to be

13 CO2E was developed by the Intergovernmental Panel on Climate Change (IPCC), and published in its Second Assessment Report (SAR) 1996.



applicable and feasible for the proposed land uses, the goals of AB32, and the Green LA plan. It should be noted that many of the CAT strategies are applicable only to State agencies such as the CARB. Whereas some of the CAT strategies that apply to GHG emissions from the operational activities of a project can be implemented at the project level, the identified CAT strategies pertaining to construction-related GHG emissions can only be implemented by the CARB. In particular, the only two CAT strategies that are relevant to the construction-related GHG emissions associated with the proposed project include the development of regulations to require the use of one to four percent biodiesel displacement of California diesel fuel, and increasing the efficiency in the design of heavy duty vehicles. As neither of the recommended CAT strategies that are relevant to construction emissions can be implemented independently by the Applicant, the analysis of the proposed project’s GHG emissions focuses on GHG emissions generated during the proposed project’s operational phase.

Greenhouse Gas Inventory

In March 2007, the California Climate Action Registry (CCAR) published version 2.2 of its General Reporting Protocol as a means for businesses, government agencies, and non-profit organizations to calculate GHG emissions from a number of general and industry-specific activities and participate in the Registry. This Protocol is not intended for CEQA purposes, but it does provide methods that can be used to quantify the GHG emissions of CO2, methane, and nitrous oxide associated with a project’s increase in on-road mobile vehicle operations, electricity consumption, and natural gas consumption.

The consumption of fossil fuels to generate electricity and to provide heating, cooking heat, and hot water (natural gas consumption) creates GHG emissions. The natural gas use and energy demand of the proposed project has been calculated using the URBEMIS 2007 model and demand factors presented in the SCAQMD’s CEQA Air Quality Handbook. GHG emission factors from the CCAR Protocol are then applied to the respective consumption rates, to calculate annual GHG emissions in metric tons. Motor vehicle emissions are calculated using the URBEMIS 2007 model and emission factors from the CCAR Protocol. The emissions are then converted to CO2 emissions by applying the applicable global warming potential (GWP) value presented in the CCAR Protocol.

The predicted operational greenhouse gas emissions are shown in Table IV.C-10 for the proposed uses at the project site. Also included in this table is the California Energy Commission’s estimated 2004 State-wide inventory, the latest year for which data are available. As shown, the increase in GHG emissions from vehicle, electrical, and natural gas usage is approximately 0.00026 percent of the 2004 State-wide emission level.

Emitting GHGs into the atmosphere is not itself an adverse environmental effect. Rather, it is the increased accumulation of GHGs in the atmosphere that may result in global climate change; the consequences of which result in adverse environmental effects. However, it is not possible to predict the specific impact, if any, to global climate change from the relatively small incremental increase in emissions associated with one general development project.



Table IV.C-10 Predicted Operational Greenhouse Gas Emissions

Emissions Source CO2e Emissions in Metric Tons per Year

Existing Land Uses Natural Gas Consumption 291.16 Electricity Generation 230.33 Motor Vehicles 503.85 Subtotal 1025.33 Proposed Land Uses Natural Gas Consumption 410.75 Electricity Generation 324.93 Motor Vehicles 1237.10 Subtotal 1972.77 Net Increase (Project - Existing) 947.44 2004 Statewide Totala 364,000,000 Net Increase as a Percentage of 2004 Statewide Total 0.00026 a Statewide totals were derived from the California Energy Commission: http://www.energy.ca.gov/2006publications/CEC-600-2006-013/CEC-600-2006-013-SF.PDF.

Source: Christopher A. Joseph & Associates, 2007.

Compliance with 2006 CAT Report Strategies

The consistency of the proposed project with the strategies from the 2006 CAT Report is evaluated in Table IV.C-11. As shown, the project would be consistent with all feasible and applicable strategies to reduce greenhouse gas emissions in California. Therefore, the impact of the proposed project would be less than significant with the incorporation of energy conservation measures.

Table IV.C-11 Project Consistency with 2006 CAT Report Greenhouse Gas Emission Reduction Strategies

Strategy Project Consistency

California Air Resources Board Vehicle Climate Change Standards. AB 1493 (Pavley) required the state to develop and adopt regulations that achieve the maximum feasible and cost-effective reduction of climate change emissions emitted by passenger vehicles and light duty trucks. Regulations were adopted by the ARB I September 2004.

Consistent. The vehicles that travel to and from the project site on public roadways would be in compliance with ARB vehicle standards that are in effect at the time of vehicle purchase.


Table IV.C-11 (Continued) Project Consistency with 2006 CAT Report Greenhouse Gas Emission Reduction Strategies


Strategy Project Consistency Diesel Anti-Idling. In July 2004, the ARB adopted a measure to limit diesel-fueled commercial motor vehicle idling.

Consistent. Current State law restricts diesel truck idling to five minutes or less. Diesel trucks making deliveries to the project site are subject to this State-wide law. Signs would be posted at the proposed project site which would state that idling is not permitted longer than 5 minutes and would also inform the public of the health hazards of inhaling diesel exhaust.

Hydrofluorocarbon Reduction. 1) Ban retail sale of HFC in small cans. 2) Require that only low GWP refrigerants be used in new vehicular systems. 3) Adopt specifications for new commercial refrigeration. 4) Add refrigerant leak-tightness to the pass criteria for vehicular inspection and maintenance programs. 5) Enforce federal ban on releasing HFCs.

Consistent. This strategy applies to consumer products. All applicable products purchased by project residents and tenants would comply with the regulations that are in effect at the time of manufacture.

Transportation Refrigeration Units, Off-Road Electrification, Port Electrification (ship to shore). Require all new transportation refrigeration units (TRU) to be equipped with electric standby. Require cold storage facilities to install electric infrastructure to support electric standby TRUs. Require off-road electrification and port electrification.

Consistent. The project does not involve any large scale shipping operations; therefore, most aspects of this strategy are not applicable. However, Mitigation Measure C-1 will require that the project rely on electricity infrastructure rather than electrical generators powered by internal combustion engines to the maximum extent feasible during construction of the project.

Manure Management. Improved management practices, manure handling practices, and lagoon/liquid waste control options.

Not applicable. The proposed project does not involve any manure handling operations; therefore, this strategy is not applicable to the project.

Semi Conductor Industry Targets. Emission reduction rules for semiconductor operations.

Not applicable. The proposed project does not involve any semiconductor operations; therefore this strategy is not applicable to the project.

Alternative Fuels: Biodiesel Blends. ARB would develop regulations to require the use of 1 to 4 percent biodiesel displacement of California diesel fuel.

Consistent. The diesel vehicles that travel to and from the project site on public roadways could utilize this fuel once it is commercially available.

Alternative Fuels: Ethanol. Increased use of E-85 fuel. Consistent. Residents of the project site could purchase flex-fuel vehicles and utilize this fuel once it is commercially available in the region and local vicinity.

Heavy-Duty Vehicle Emission Reduction Measures. Increased efficiency in the design of heavy duty vehicles and an education program for the heavy duty vehicle sector.

Consistent. The heavy-duty vehicles that travel to and from the project site on public roadways would be subject to all applicable ARB efficiency standards that are in effect at the time of vehicle manufacture.

Reduced Venting and Leaks on Oil and Gas Systems. Improved management practices in the production, processing, transport, and distribution of oil and natural gas.

Not applicable. The proposed project does not involve any production, transport, or distribution of oil and natural gas; therefore, this strategy is not applicable to the project.




Strategy Project Consistency Hydrogen Highway. The California Hydrogen Highway Network (CA H2 Net) is a State initiative to promote the use of hydrogen as a means of diversifying the sources of transportation energy.

Not applicable. This strategy does not apply to individual development projects; however, the project would not preclude the implementation of this strategy by any other agency.

Achieve 50% Statewide Recycling Goal. Achieving the State’s 50 percent waste diversion mandate as established by the Integrated Waste Management Act of 1989, (AB 939, Sher, Chapter 1095, Statutes of 1989), will reduce climate change emissions associated with energy intensive material extraction and production as well as methane emission from landfills. A diversion rate of 48% has been achieved on a statewide basis. Therefore, a 2% additional reduction is needed.

Consistent. As discussed in Section IV.M.3, Utilities and Service Systems, Solid Waste, the project would divert at least 50 percent of its solid waste after the recyclable content is diverted. Mitigation measure M.3-1 provides for recycling of construction waste. Mitigation measure M.3-1 provides recycling bins at the project site.

Landfill Methane Capture. Install direct gas use or electricity projects at landfills to capture and use emitted methane.

Not applicable. The proposed project does not involve any landfill operations; therefore, this strategy is not applicable to the project.

Zero Waste – High Recycling. Efforts to exceed the 50 percent goal would allow for additional reductions in climate change emissions.

Consistent. As discussed in Section IV.M.3, Utilities and Service Systems, Solid Waste, the project would divert at least 50 percent of its solid waste after the recyclable content is diverted. Mitigation measure M.3-1 provides recycling bins at the project site. The project would also be subject to all applicable State and City requirements for solid waste reduction as they change in the future.

Department of Forestry Forest Management. Increasing the growth of individual forest trees, the overall age of trees prior to harvest, or dedicating land to older aged trees.

Not applicable. The proposed project is not located on or near a forest.

Forest Conservation. Provide incentives to maintain an undeveloped forest landscape.


Fuels Management/Biomass. Reduce the risk of wildland fire through fuel reduction and biomass development.

Not applicable. The proposed project is not located on or near a forest where accumulation of biomass would be an issue.

Urban Forestry. A new statewide goal of planting 5 million trees in urban areas by 2020 would be achieved through the expansion of local urban forestry programs.

Consistent. The landscaping proposed for the revised project would include new trees within the open space areas of the site.

Afforestation/Reforestation. Reforestation projects focus on restoring native tree cover on lands that were previously forested and are now covered with other vegetative types.





Strategy Project Consistency Department of Water Resources

Water Use Efficiency. Approximately 19 percent of all electricity, 30 percent of all natural gas, and 88 million gallons of diesel are used to convey, treat, distribute and use water and wastewater. Increasing the efficiency of water transport and reducing water use would reduce greenhouse gas emissions.

Consistent. As discussed in Section IV.M.2, Utilities and Service Systems, Water, the project developer will ensure that all landscape irrigation is installed to provide uniform coverage and minimize spraying onto walkways and streets. Furthermore, the project will at minimum, set irrigation timers during the early morning or late evening hours to reduce evaporative loses. The project will also have low flush water toilets and water saving showerheads.

Energy Commission (CEC) Building Energy Efficiency Standards in Place and in Progress. Public Resources Code 25402 authorizes the CEC to adopt and periodically update its building energy efficiency standards (that apply to newly constructed buildings and additions to and alterations to existing buildings).

Consistent. The project would be required to be constructed with the standards of Title 24 that are in effect at the time of development. In addition, the proposed project would be constructed to maximize building efficiency with LEED characteristics, and would exceed Title 24 requirements by more than 10%.

Appliance Energy Efficiency Standards in Place and in Progress. Public Resources Code 25402 authorizes the Energy Commission to adopt and periodically update its appliance energy efficiency standards (that apply to devices and equipment using energy that are sold or offered for sale in California).

Consistent. Under State law, appliances that are purchased for the project – both pre- and post-development – would be consistent with energy efficiency standards that are in effect at the time of manufacture.

Fuel-Efficient Replacement Tires & Inflation Programs. State legislation established a statewide program to encourage the production and use of more efficient tires.

Consistent. Residents of the project site could purchase tires for their vehicles that comply with State programs for increased fuel efficiency.

Cement Manufacturing. Cost-effective reductions to reduce energy consumption and to lower carbon dioxide emissions in the cement industry.

Not applicable. The proposed project does not include any cement manufacturing operations; therefore, this strategy is not applicable to the project.

Municipal Utility Energy Efficiency Programs/Demand Response. Includes energy efficiency programs, renewable portfolio standard, combined heat and power, and transitioning away from carbon-intensive generation.

Consistent. The DWP currently has a green power program which residents of the proposed project could purchase.

Municipal Utility Renewable Portfolio Standard. California’s Renewable Portfolio Standard (RPS), established in 2002, requires that all load serving entities achieve a goal of 20 percent of retail electricity sales from renewable energy sources by 2017, within certain cost constraints.

Not applicable. This strategy is not applicable, but the project would not preclude the implementation of this strategy by municipal utility providers.

Municipal Utility Combined Heat and Power. Cost effective reduction from fossil fuel consumption in the commercial and industrial sector through the application of on-site power production to meet both heat and electricity loads.





Strategy Project Consistency Municipal Utility Electricity Sector Carbon Policy. State agencies to address ways to transition investor-owned utilities away from carbon-intensive electricity sources.


Alternative Fuels: Non-Petroleum Fuels. Increasing the use of non-petroleum fuels in California’s transportation sector, as recommended as recommended in the CEC’s 2003 and 2005 Integrated Energy Policy Reports.

Consistent. Residents of the project site could purchase alternative fuel vehicles and utilize these fuels once they are commercially available in the region and local vicinity.

Business, Transportation and Housing Measures to Improve Transportation Energy Efficiency. Builds on current efforts to provide a framework for expanded and new initiatives including incentives, tools and information that advance cleaner transportation and reduce climate change emissions.

Consistent. The location of the project promotes fuel conservation through pedestrian activity, nearby access to public transportation, and jobs and shopping in close proximity to homes.

Smart Land Use and Intelligent Transportation Systems (ITS). Smart land use strategies encourage jobs/housing proximity, promote transit-oriented development, and encourage high-density residential/commercial development along transit corridors. ITS is the application of advanced technology systems and management strategies to improve operational efficiency of transportation systems and movement of people, goods and services. The Governor is finalizing a comprehensive 10-year strategic growth plan with the intent of developing ways to promote, through state investments, incentives and technical assistance, land use, and technology strategies that provide for a prosperous economy, social equity and a quality environment. Smart land use, demand management, ITS, and value pricing are critical elements in this plan for improving mobility and transportation efficiency. Specific strategies include: promoting jobs/housing proximity and transit-oriented development; encouraging high density residential/commercial development along transit/rail corridor; valuing and congestion pricing; implementing intelligent transportation systems, traveler information/traffic control, incident management; accelerating the development of broadband infrastructure; and comprehensive, integrated, multimodal/intermodal transportation planning.

Consistent. The project locates new residential within walking distance of existing commercial uses. The project site is also located along a transit corridor with opportunities for the project residents to use public transit rather than automobiles.




Strategy Project Consistency Department of Food and Agriculture

Conservation Tillage/Cover Crops. Conservation tillage and cover crops practices are used to improve soil tilth and water use efficiency, and to reduce tillage requirements, labor, fuel, and fertilizer requirements.

Not applicable. The proposed project does not involve any agricultural operations; therefore, this strategy is not applicable to the project.

Enteric Fermentation. Cattle emit methane from digestion processes. Changes in diet could result in a reduction in emissions.

Not applicable. The proposed project does not involve any agricultural operations; therefore, this strategy is not applicable to the project.

State and Consumer Services Agency Green Buildings Initiative. Green Building Executive Order, S-20-04 (CA 2004), sets a goal of reducing energy use in public and private buildings by 20 percent by the year 2015, as compared with 2003 levels. The Executive Order and related action plan spell out specific actions state agencies are to take with state-owned and –leased buildings. The order and plan also discuss various strategies and incentives to encourage private building owners and operators to achieve the 20 percent target.

Consistent. The project would be required to be constructed with the standards of Title 24 that are in effect at the time of development. In addition, the proposed project would be constructed to maximize building efficiency with LEED characteristics, and would exceed Title 24 requirements by more than 10%.

Public Utilities Commission (PUC) Accelerated Renewable Portfolio Standard. The Governor has set a goal of achieving 33 percent renewable in the State’s resource mix by 2020. The joint PUC/Energy Commission September 2005 Energy Action Plan II (EAP II) adopts the 33 percent goal.


California Solar Initiative. The solar initiative includes installation of 1 million solar roofs or an equivalent 3,000 MW by 2017 on homes and businesses, increased use of solar thermal systems to offset the increasing demand for natural gas, use of advanced metering in solar applications, and creation of a funding source that can provide rebates over 10 years through a declining incentive schedule.

Consistent. Although solar roofs are not proposed as part of the project, solar equipment could purchased by residents in the future if it becomes cost effective from a purchase and maintenance standpoint of the property owners.

Investor-Owned Utility Programs. These strategies include energy efficiency programs, combined heat and power initiative, and electricity sector carbon policy for investor owned utilities.


Sources: Climate Action Team, 2006 and Christopher A. Joseph & Associates, 2007.

The following planned City actions, as presented in the LA Green Plan, when implemented, may further decrease emissions of GHGs from the proposed project:

• Decreasing emissions from Department of Water and Power electrical generation and import activities;



• Providing compact fluorescent light (CFL) bulbs to encourage acceptance and use of CFLs; and

• Expanding the regional rail network to reduce VMT.

In addition, the project is designed with a number of features which are consistent with the following City of Los Angeles goals:

• Promoting high-density housing close to mass transportation; and

• Creating walkable neighborhoods.

CUMULATIVE IMPACTS

Consistency with the 2007 AQMP

Cumulative development could possibly result in a significant impact in terms of conflicting with, or obstructing implementation of, the 2007 AQMP. The 2007 AQMP was prepared to accommodate growth, to reduce the high levels of pollutants within the areas under the jurisdiction of SCAQMD, to return clean air to the region, and to minimize the impact on the economy. Growth considered to be consistent with the 2007 AQMP would not interfere with attainment because this growth is included in the projections utilized in the formulation of the AQMP. Consequently, as long as growth in the Basin is within the projections for growth identified in the Growth Management Chapter of the RCPG, implementation of the 2007 AQMP will not be obstructed by such growth. Since the development of the proposed project would not jeopardize attainment of air quality standards in the 2007 AQMP for the Basin and the Los Angeles County portion of the Basin, they would not have a cumulatively considerable contribution to this impact regarding a potential conflict with or obstruction of the implementation of the applicable air quality plan.

Consistency with the Regional Comprehensive Plan and Guide (RCPG)

Additionally, cumulative development could possibly result in a significant impact in terms of conflicting with, or obstructing implementation of, the RCPG. As discussed above, the proposed project is consistent with the air quality-related policies in the Growth Management Chapter of the RCPG, as it would be an infill development that would take advantage of infrastructure already in place and would require only minimal roadway expansion. The project would increase the density of the residential use on the project site, therefore bringing more housing units closer to major employment centers. This additional density would be located immediately adjacent to Century City, enabling walking trips to work and shopping, in an area currently served by public transit (buses), and would be located near existing transportation corridors. Consequently, as the project would be consistent with the air quality-related policies in the Growth Management Chapter of the RCPG, the project would not have a cumulatively considerable contribution to this impact regarding a potential conflict with or obstruction of the implementation of the RCPG.



Construction and Operational Impacts

Because the Basin is currently in nonattainment for ozone and PM10, cumulative development could exceed an air quality standard or contribute a substantial increase to an existing or projected air quality exceedance. With regard to cumulative air quality impacts, the SCAQMD neither recommends quantified analyses of the emissions generated by a set of cumulative development projects nor provides thresholds of significance to be used to assess these emissions. Instead, the SCAQMD recommends that a project’s potential contribution to cumulative impacts should be assessed utilizing the same significance criteria as those for project specific impacts. As impacts from the proposed project are less than significant, cumulative impacts are considered to be less than significant.


As discussed previously, the increased accumulation of GHGs in the atmosphere may result in global climate change, the consequences of which result in adverse environmental effects. The State has mandated a goal of reducing State-wide emissions to 1990 levels by 2020, even though State-wide population and commerce is predicted to grow substantially. The increase in residential and commercial space with implementation of the proposed project would not result in an unplanned level of development and does not represent a substantial new source of GHG emissions. However, the proposed project would generate greater than zero GHG emissions and the cumulative effect of global climate change would be considered incrementally cumulatively considerable. This would be considered a potentially significant cumulative impact.

MITIGATION MEASURES

Construction-Related Project Impacts

Because the proposed project would have a less than significant impact on air quality construction, mitigation measures are not required pursuant to CEQA Guidelines Section 15126.4. However, the following mitigation measures have been added to further reduce project-specific air quality construction impacts:

C-1 The project developer shall implement measures to reduce the emissions of pollutants generated by heavy-duty diesel-powered equipment operating at the project site throughout the project construction phases. The project developer shall include in construction contracts the control measures required and recommended by the SCAQMD at the time of development. Examples of the types of measures currently required and recommended include the following:

• Keep all construction equipment in proper tune in accordance with manufacturer’s specifications.

• Use late model heavy-duty diesel-powered equipment at the project site to the extent that it is readily available in the South Coast Air Basin (meaning that it does not have to be imported



from another air basin and that the procurement of the equipment would not cause a delay in construction activities of more than two weeks).

• Use low-emission diesel fuel for all heavy-duty diesel-powered equipment operating and refueling at the project site to the extent that it is readily available and cost effective in the South Coast Air Basin (meaning that it does not have to be imported from another air basin, that the procurement of the equipment would not cause a delay in construction activities of more than two weeks, that the cost of the equipment use is not more than 20 percent greater than the cost of standard equipment). (This measure does not apply to diesel-powered trucks traveling to and from the site.)

• Utilize alternative fuel construction equipment (i.e., compressed natural gas, liquid petroleum gas, and unleaded gasoline) to the extent that the equipment is readily available and cost effective in the South Coast Air Basin (meaning that it does not have to be imported from another air basin, that the procurement of the equipment would not cause a delay in construction activities of more than two weeks, that the cost of the equipment use is not more than 20 percent greater than the cost of standard equipment).

• Limit truck and equipment idling time to five minutes or less.

• Rely on the electricity infrastructure surrounding the construction sites rather than electrical generators powered by internal combustion engines to the extent feasible.

C-2 The project developer shall implement fugitive dust control measures in accordance with SCAQMD Rule 403. The project developer shall include in construction contracts the control measures required and recommended by the SCAQMD at the time of development. Examples of the types of measures currently required and recommended include the following:

• Use watering to control dust generation during demolition of structures or break-up of pavement.

• Water active grading/excavation sites and unpaved surfaces at least three times daily.

• Cover stockpiles with tarps or apply non-toxic chemical soil binders.

• Limit vehicle speed on unpaved roads to 15 miles per hour.

• Sweep daily (with water sweepers) all paved construction parking areas and staging areas.

• Provide daily clean-up of mud and dirt carried onto paved streets from the site.

• Install wheel washers for all exiting trucks, or wash off the tires or tracks of all trucks and equipment leaving the site.



• Suspend excavation and grading activity when winds (instantaneous gusts) exceed 15 miles per hour over a 30-minute period or more.

• An information sign shall be posted at the entrance to each construction site that identifies the permitted construction hours and provides a telephone number to call and receive information about the construction project or to report complaints regarding excessive fugitive dust generation. Any reasonable complaints shall be rectified within 24 hours of their receipt.

Cumulative GHG Emission Impacts

C-3 The proposed project shall follow the guidelines and regulations outlined by AB 32, the 2006 CAT Report Strategies and the LA Green Plan.

LEVEL OF SIGNIFICANCE AFTER MITIGATION

Cumulative Impacts

With implementation of Mitigation Measure C-3 above, the proposed project would be consistent with the goals of AB32, the 2006 CAT Report strategies, and the Green LA Plan, cumulative impacts would be less than significant. Furthermore, with implementation of Mitigation Measures M.2-1 through M.2-9, impacts from the generation of GHG emissions from water supply would be minimized to the greatest extent feasible. Overall, air quality impacts would be less than significant.