APPENDIX II.2. Land Use Equivalency Program Technical Report Prepared by Christopher A. Joseph & Associates, May 2010

Transcription

1 APPENDIX II.2 Land Use Equivalency Program Technical Report Prepared by Christopher A. Joseph & Associates, May 2010

2 LAND USE EQUIVALENCY PROGRAM TECHNICAL REPORT Prepared for: Wilshire Grand Redevelopment Project 930 Wilshire Boulevard Los Angeles, California Prepared by: Christopher A. Joseph & Associates West Olympic Blvd., Suite 101 Los Angeles, California Contact: Craig Fajnor April, 2010

3 Christopher A. Joseph & Associates April, 2010 DESCRIPTION OF THE PROPOSED WILSHIRE GRAND REDEVELOPMENT PROJECT LAND USE EQUIVALENCY PROGRAM INTRODUCTION The Wilshire Grand Redevelopment Project (Project) would include a Land Use Equivalency Program to maintain flexibility of Project land uses and floor areas so that the Project can, if necessary, respond to the changing needs of the Southern California economy. The Land Use Equivalency Program defines a framework within which the proposed mix of land uses can be modified within the development envelope defined by the approved entitlements without resulting in any new significant impacts or a substantial increase in the severity of previously identified significant impacts as analyzed in the Environmental Impact Report prepared for the Project (Project EIR). In so doing, the application of the Land Use Equivalency Program would, by definition, not require preparation of a Subsequent EIR to address changes in Project land uses that are carried out under the Land Use Equivalency Program. PURPOSE The purpose of the Wilshire Grand Land Use Equivalency Program is: To identify a set of rules for exchanging land uses, one for another, within the scope of development approved for the Wilshire Grand Project, which: 1. Does not result in any increase in PM peak hour trip generation. 2. Does not result in any significant impacts beyond those identified in the EIR for the Wilshire Grand Redevelopment Project. 3. Allows such exchanges without requiring any further discretionary action on the part of the City or any additional CEQA documentation. There are two aspects to addressing these goals in the Wilshire Grand Redevelopment Project EIR: 1. The rules for the Land Use Equivalency Program are defined in the Project Description. Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 2 PRELIMINARY WORKING DRAFT WORK IN PROGRESS

4 Christopher A. Joseph & Associates April, The impacts associated with implementation of the Land Use Equivalency Program are discussed in each of the Project EIR impact area sections. These two aspects are interrelated in that: The rules have been defined in such a way that no additional impacts will result from the implementation of the Land Use Equivalency Program. The conclusions regarding the impacts of the Land Use Equivalency Program are documented in the Project EIR. Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 3 PRELIMINARY WORKING DRAFT WORK IN PROGRESS

5 Christopher A. Joseph & Associates April, 2010 OVERVIEW/SUMMARY The rules of the Land Use Equivalency Program provide for a three step process for identifying a land use exchange that does not result in any additional environmental impacts (Figure 1). Detailed explanations of the calculations associated with each of these steps are provided in the following section of this Technical Report. STEP 1: Determine Proposed Land Use Exchange Based On PM Peak Hour Trip Generation The Land Use Equivalency Program set forth and evaluated in the Wilshire Grand Redevelopment Project EIR is based upon afternoon peak hour traffic generation rates. Afternoon peak hour traffic rates were used since these rates would be the most impactful traffic factor for this type of project in the Downtown area because background traffic levels are higher in the p.m. peak hour than in the a.m. peak hour and traffic generation is higher in the p.m. peak hour than in the a.m. peak hour. Peak hour impacts are used as the basis of identifying the Project s traffic impacts in the traffic study and Project EIR. The Land Use Equivalency Program would allow the uses set forth herein to be exchanged for one another such that no additional PM peak hour traffic generation would result from any exchange that is consistent with the factors contained within the Land Use Equivalency Program. These factors are set forth in Table 1, Land Use Equivalency Program. The conversion factor for a particular exchange is identified by finding the land use being exchanged from (called the donor land use) in the column on the left of Table 1 and cross referencing to the land use being exchanged to (called the recipient land use) on the top row of Table 1. The resulting factor indicates the number of units or 1,000 square feet of the recipient land use that can be included in the project in exchange for the number of units or 1,000 square feet of the donor land use being removed from the project. For example, 1,000 square feet of office use can be exchanged for 2 hotel rooms, or one hotel room can be exchanged for 210 (1,000 * 0.21) square feet of retail use. However, within this context, the Project would not be allowed to exceed the total floor area that would be approved with the requested Transfer of Floor Area (TFAR). In addition, conversions would be limited so as to result in individual maximums of 1,120 hotel rooms, 1,100 residential dwelling units, 200,000 square feet of retail use, 50,000 square feet of fitness center use, 1,750,000 square feet of office uses, and 50,000 square feet of restaurant use. These figures represent the total amount of an individual land use that would be permitted under the Land Use Equivalency Program. The effects of individual land use exchanges are assessed based on the difference from the Project baseline. For instance, the Project includes 100 residential units and the maximum permitted number of residential Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 4 PRELIMINARY WORKING DRAFT WORK IN PROGRESS

6 Christopher A. Joseph & Associates April, 2010 units is 1,100. Therefore the Land Use Equivalency Program would permit land use exchanges that could increase the number of residential units in the Project by 1,000 units. Donor Land Use a Table 1 Land Use Equivalency Program PM Peak Hour Traffic Recipient Land Use b Office Hotel Condo/Apt Fitness Center (ksf) (room) (du) (ksf) Retail (ksf) Restaurant (ksf) Office (ksf) Hotel (room) Condo/Apt (du) Fitness Center (ksf) Retail (ksf) Restaurant (ksf) ksf = 1,000 square feet du = dwelling unit Apt = apartment a Land use changing from b Land use changing to Source (Generation Rates): Trip Generation, 9th Edition, Institute of Transportation Engineers, Source (Table): Christopher A. Joseph & Associates, STEP 2: Calculate Change in ROG emissions for Desired Exchange Compared to Project In addition to not generating any additional PM peak hour traffic, an additional constraint with respect to the proposed Wilshire Grand Redevelopment Project is that, under any land use equivalency exchange, the resulting regional operational air emissions cannot exceed the thresholds established by the South Coast Air Quality Management District (SCAQMD). This is because the Project would not exceed any of the SCAQMD thresholds for regional operational emissions (i.e., no significant regional operational emissions impacts), as shown in Section IV.G, Air Quality, of the EIR. Of the six criteria pollutants for which significance thresholds have been established by SCAQMD (Reactive Organic Gases [ROG] 1, Nitrogen Oxides [NOx], Particulate Matter-less than 10 microns in diameter [PM10], Particulate Matter-less than 2.5 microns in diameter [PM2.5], Sulfur Dioxide [SO2], and Carbon Monoxide [CO]), analysis shows that the Land Use Equivalency Program only has the potential to cause an exceedance of the SCAQMD threshold for ROG emissions. This analysis is provided in full under DETAILED 1 Also referred to as Volatile Organic Compounds (VOC). Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 5 PRELIMINARY WORKING DRAFT WORK IN PROGRESS

7 Christopher A. Joseph & Associates April, 2010 METHODOLOGY, Step 2B, below. Therefore, ROG Emissions are used as the controlling factor for ensuring that any proposed land use exchange under the Land Use Equivalency Program would not exceed SCAQMD thresholds. The change in ROG emissions from a proposed land use exchange, compared to the Project, would be calculated based on the factors shown in Table 2. These factors show the change in ROG emissions associated with each potential land use exchange covered by the Land Use Equivalency Program. If the calculated ROG emissions from the proposed land use exchange would be shown to be below the level that would cause an exceedance of the SCAQMD threshold, the exchange would be acceptable under the Land Use Equivalency Program and the change to the Project could be made without any further environmental review. The level of emissions that would remain below the SCAQMD threshold for ROG emissions is called the Equivalency Threshold and is pounds per day for summertime ROG emissions. The derivation of the Equivalency Threshold of pounds per day is described in full under DETAILED METHODOLOGY, Step 2B, below. Donor Land Use a Units Table 2 Land Use Equivalency Program/Factors for Change in Summer ROG Emissions Recipient Land Use b Factors (pounds per day) Office (ksf) Hotel (room) Condo/Apt (du) Fitness Center (ksf) Retail (ksf) Restaurant (ksf) Office (ksf) Hotel (room) Condo/Apt (du) Fitness Center (ksf) Retail (ksf) Restaurant (ksf) ksf = 1,000 square feet DU = dwelling unit Apt = apartment a Land use changing from b Land use changing to Note: when using these factors to determine the number of hotel rooms or residential units as a recipient land use, any nonwhole number result would be rounded down to the nearest whole unit amount Source (Emissions Factors): URBEMIS, 2007 Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 6 PRELIMINARY WORKING DRAFT WORK IN PROGRESS

8 Christopher A. Joseph & Associates April, 2010 Source (Table): Christopher A. Joseph & Associates, STEP 3: If Calculated ROG Emissions are Higher than the Threshold, Identify an Additional Land Use Offset to Reduce the Emissions Below the Threshold If the ROG emissions resulting from the equivalency exchange as calculated in Step 2 would exceed the Equivalency Threshold of pounds per day, then an additional emissions offset would need to be taken from the land uses remaining in the Project. This offset is calculated using the factors shown in Table 3. Sufficient additional land use must be removed from the Project to bring the ROG emissions below the Equivalency Threshold (and thus not exceed the SCAQMD threshold). If there is not enough land use available in the Project to achieve the desired exchange, then an additional environmental analysis needs to be prepared to address the proposed exchange. Table 3 Land Use Equivalency Program Emission Factors for Calculating ROG Offsets (pounds per day) Office (ksf) ksf = 1,000 square feet Source: URBEMIS, 2007 Hotel (room) Condo/Apt (du) Fitness Center (ksf) Retail (ksf) Restaurant (ksf) du = dwelling unit Apt = apartment Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 7 PRELIMINARY WORKING DRAFT WORK IN PROGRESS

9 Christopher A. Joseph & Associates April, 2010 Figure 1 Overview of Proposed Wilshire Grand Redevelopment Project Land Use Equivalency Program Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 8 PRELIMINARY WORKING DRAFT WORK IN PROGRESS

10 Christopher A. Joseph & Associates April, 2010 DETAILED METHODOLOGY The following sections describe the assumptions and calculations reflected in the summary description of the Land Use Exchange Program provided in the preceding section. STEP 1: Determine Proposed Land Use Exchange Based On PM Peak Hour Trip Generation Step 1 is a straightforward calculation that identifies the land uses that can be traded for one another without changing the PM peak hour traffic generation. The factors shown in Table 1 are based on the PM peak hour trip generation rates for the Project shown in Table 4, as taken from the Project s traffic study. The trip generation rates are the rates from the transportation study 2 before the application of the Project s Transportation Demand Management (TDM) Program. The use of pre-tdm trip generation rates is appropriate because one purpose of the Land Use Equivalency Program is to ensure no increase in PM peak hour traffic generation so as not to allow the potential for additional significant PM peak hour traffic impacts as identified in the EIR. The only way to ensure this is to use the pre-tdm rates as the basis for the Land Use Equivalency Program. Table 4 Land Use Equivalency Program PM Peak Hour Trip Generation Rates Office (ksf) Hotel (room) Condo/Apt (du) Fitness Center (ksf) Retail (ksf) Restaurant (ksf) ksf = 1,000 square feet du = dwelling unit Apt = apartment Source: Trip Generation, 8 th Edition, Institute of Transportation Engineers, 2008; Gibson Transportation Consulting, 2010 The factors shown in Table 1 are the ratio of donor land use trip generation rate to the recipient land use trip generation. For instance, to convert 1,000 square feet of office use to hotel rooms, the ratio is 0.84/0.42, or Put another way, it can be seen that 1,000 square feet of office generates 0.84 PM peak hour trips and 2 hotel rooms also generate 0.84 PM peak hour trips (2 * 0.42). Thus, Step 1 demonstrates that the PM peak hour traffic impact of 1,000 square feet of office use is the same as the 2 Transportation Study for the Wilshire Grand Redevelopment Project, prepared by Gibson Transportation Consulting, Inc. See Appendix B to this EIR. Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 9 PRELIMINARY WORKING DRAFT WORK IN PROGRESS

11 Christopher A. Joseph & Associates April, 2010 PM peak hour traffic impact of two hotel rooms. The same methodology would apply to any exchange of the land uses identified in Table 1. With respect to PM peak hour traffic impacts, there would be no restrictions on exchanges between land uses because the PM peak hour traffic levels would not change, no matter what exchange occurs. However, some exchanges could potentially result in land use patterns that would be inappropriate for the Project Site. For instance, the large amount of office use contained within the Project could be exchanged for in excess of 3,000 residential units, based on the PM peak hour traffic generation rates. However, given the restriction in floor area that applies to the Project Site, this level of residential development would result in large numbers of very small units that would be infeasible and inappropriate to develop on this downtown site. Thus, the Project Applicant has identified certain voluntary restrictions (i.e., caps) on individual land uses that could be developed under the Land Use Equivalency Program that reflect constraints grounded in the practicality and feasibility of various levels of land uses and development on the Project Site. These limitations reflect the maximum amount of each of these land uses that could be developed individually on the Project Site. These restrictions would also preclude the potential for additional environmental impacts resulting from application of the Land Use Equivalency Program. 3 The voluntary limitations on the development of individual land uses included in the Land Use Equivalency Program are: 1.75 million square feet of office use 1,120 hotel rooms 1,100 residential units 50,000 square feet of fitness center 200,000 square feet of retail use 50,000 square feet of restaurant use 3 For instance, in the example above, a large number of residential units would result in high levels of water consumption, wastewater generation and solid waste generation, which could potentially result in additional significant impacts. Because these levels of development would never be developed on the Project Site, it is appropriate that they not enter into the analysis in the first place. Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 10 PRELIMINARY WORKING DRAFT WORK IN PROGRESS

12 Christopher A. Joseph & Associates April, 2010 STEP 2: Calculate Change in ROG emissions for Desired Exchange Compared to Proposed Project Step 2 calculates the effect of a proposed exchange under the Land Use Equivalency Program with respect to regional operational air emissions and establishes additional constraints on the land use exchanges permitted under the Land Use Equivalency Program. In addition to not generating any additional PM peak hour traffic, an additional constraint with respect to the Project is that, under any land use equivalency exchange, the resulting regional operational emissions cannot exceed the thresholds established by the SCAQMD. This is because the analysis of the regional operational emissions of the Project provided in Section IV.G, Air Quality, of the EIR concludes that the Project does not exceed any of the SCAQMD thresholds for operational emissions (i.e., no significant regional operational emissions impacts). This additional feature of the Land Use Equivalency Program would help ensure that land use exchanges under the Land Use Equivalency Program do not result in any significant impacts beyond those identified in the EIR for the Wilshire Grand Redevelopment Project with respect to regional air emissions. Step 2A: Calculate the Change in ROG Emissions Associated with the Proposed Land Use Exchange To calculate whether a proposed land use exchange would cause emissions that exceed an SCAQMD threshold, emission factors were calculated for the each of the Equivalency Program land use units (e.g., 1,000 sq.ft. office, hotel room, residential unit, etc.) using the URBEMIS 2007 model recommended for use by SCAQMD in analyzing regional operational emissions. These emission factors were calculated based on the Average Daily Trips (ADT) generation rates provided in the Project Transportation Study for each of the individual land uses. The URBEMIS 2007 model output sheets for each of the land uses contained in the Land Use Equivalency Program provide emission factors for the six criteria pollutants required to be evaluated under SCAQMD methodologies (ROG, NOx, PM10, PM2.5, SO2, 4 and CO) are contained in Appendix A to this Technical Report, for both summertime and wintertime scenarios. While the URBEMIS 2007 calculations demonstrate how the emissions related to mobile sources and consumer products vary among the Land Use Equivalency Program land use units, the SCAQMD methodology for evaluating regional operation emissions impacts includes other emissions sources 4 The emission factor for SO2 for all of the Program land uses is Therefore emissions of this criteria pollutant would not change under the Land Use Equivalency Program and are not further evaluated. Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 11 PRELIMINARY WORKING DRAFT WORK IN PROGRESS

13 Christopher A. Joseph & Associates April, 2010 (natural gas usage, landscape maintenance equipment, architectural coatings, helicopters and on-site broilers), as shown in Section IV.G, Air Quality, of the EIR. These sources are also accounted for in the Land Use Equivalency Program, as discussed in detail under Step 2B below. Analysis of the potential emission levels associated with each of the criteria pollutants, under both summertime and wintertime conditions, provided in full under DETAILED METHODOLOGY, Step 2B, below, shows that ROG emissions are the controlling factor in determining whether any additional regional operational air emissions impacts would result from the Land Use Equivalency Program, because there is no potential for any of the other criteria pollutants to exceed SCAQMD thresholds under the land use exchanges that would be permitted under the Land Use Equivalency Program. In addition, the margin for change in summertime ROG emissions without causing an impact is lower than for wintertime emissions. Therefore, the summertime ROG emissions are more restrictive than the wintertime (stated another way, if the summertime ROG emissions associated with a proposed land use exchange do not cause an additional impact to occur, no additional impact with respect to wintertime ROG emissions would occur). This analysis is discussed in detail under Step 2B below. The summertime ROG emission factors for the land use units included in the Land Use Equivalency Program, based on the URBEMIS 2007 model calculations, are shown in Table 3 above. Table 2 shows the change in ROG emissions that would result from exchanging one land use for another based on PM peak hour traffic (Step 1). Because the land use exchanges represent changes from the land uses included in the Project as evaluated in the EIR, the change in summertime ROG emissions as compared to the Project provides the correct basis for this analysis. An example of how the factors shown in Table 2 were derived is shown below. Example: Calculate the factor for the change in summertime ROG emissions that would be associated with a change in land use from one unit of office space (i.e., 1,000 square feet) to the equivalent units of hotel use (i.e., rooms) 1. 1,000 sq.ft. of office use = 2 hotel rooms based on PM peak hour traffic generation rates (per Table 1) 2. Per the emission factors for each unit of land use based on the URBEMIS 2007 model calculations (Table 3): Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 12 PRELIMINARY WORKING DRAFT WORK IN PROGRESS

14 Christopher A. Joseph & Associates April, ,000 sq.ft of office use =0.02 pounds per day of ROG emissions 2 hotel rooms = 0.06 pounds per day of ROG emissions (2 * 0.03) 3. Adding 2 hotel rooms to the Project while reducing the Project by 1,000 sq.ft. of office use would add 0.06 pounds per day and subtract 0.02 pounds per day, which would result in a net increase in ROG emissions of 0.04 pounds per day (i.e., represent the change in ROG emissions resulting from the conversion of 1,000 square feet of office use to hotel use under the rules of the Land Use Equivalency Program). To calculate the total change in ROG emissions associated with a proposed land use exchange, the total units of the land use being exchanged are multiplied by the corresponding factor in Table 2. Example: Calculate the total change in summertime ROG emissions that would be associated with the change of 100,000 square feet of office space to hotel use. 100 (units of 1,000 square feet of office use) * 0.04 (factor from Table 2 for exchange of office space to hotel units) = 4 pounds per day increase in ROG emissions over the Project To check this calculation: ,000 square feet of office use = 200 hotel rooms per PM peak hour traffic (Table 1) ,000 sq.ft. of office use = 2 pounds per day ROG (100 * 0.02 [emission factor for 1,000 square feet of office use per Table 3]) 200 hotel rooms = 6 pounds per day ROG (200 * 0.03 [from Table 3]) 3. Adding 200 hotel rooms to the Project while reducing the Project by 100,000 sq.ft. of office use would add 6 pounds per day and subtract 2 pounds per day, which would result in a net increase in ROG emissions of 4 pounds per day (i.e., represents the change in ROG emissions resulting from the conversion of 100,000 square feet of office use to hotel use under the rules of the Land Use Equivalency Program). Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 13 PRELIMINARY WORKING DRAFT WORK IN PROGRESS

15 Christopher A. Joseph & Associates April, 2010 For multiple proposed land use exchanges, the ROG emissions change associated with each is calculated separately and the results are added to give the total net change in ROG emissions associated with the proposed land use exchange: Example: Calculate the total change in summertime ROG emissions that would be associated with the exchange of 100,000 square feet of office space to hotel use and the exchange of 30 residential units to restaurant use (units of 1,000 square feet of office use) * 0.04 (factor from Table 2 for exchange of office space to hotel units) = 4 pounds per day increase in ROG emissions over the Project residential units * (factor from Table 2 for exchange of residential units to restaurant use) = pounds per day increase (i.e., pounds per day decrease) in ROG emissions over the Project 3. Net effect of proposed land use exchange = 4 + ( 1.143) = pounds per day increase in ROG emissions compared to the Project Step 2B: Determine Whether the Proposed Land Use Exchange Would Cause the SCAQMD Threshold for ROG Emissions to be Exceeded To determine whether the proposed land use exchange would cause the SCAQMD threshold for ROG emissions to be exceeded, thereby resulting in an additional significant regional operational emissions impact, the result provided in Step 2A is compared to an Equivalency Threshold. The Equivalency Threshold represents that maximum increase in ROG emissions that could occur without exceeding the SCAQMD daily operational ROG emissions threshold. The Equivalency Threshold for each criteria pollutant, under both summertime and wintertime conditions, was calculated by subtracting the total of the net increase in emissions associated with the Project and the calculated maximum natural gas emissions expected to occur under the Land Use Equivalency Program, from the SCAQMD threshold. A detailed discussion of the derivation of the Equivalency Threshold follows. Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 14 PRELIMINARY WORKING DRAFT WORK IN PROGRESS

16 Christopher A. Joseph & Associates April, 2010 As shown in Table IV.G-12 of the Draft EIR (also included as Appendix B to this Technical Report), under the SCAQMD methodology for assessing impacts related to regional operational emissions and as reflected in the URBEMIS 2007 model, regional operational emissions associated with a development project are comprised of the following categories: Natural Gas Usage fuel combustion emissions from space and water heating, including wood stoves, fireplaces, and natural gas fired stoves Landscape Maintenance Equipment fuel combustion emissions from landscape maintenance equipment, emissions from evaporation of unburned fuel, and fugitive dust generated by equipment such as leaf blowers Consumer Products ROG emissions from consumer products, including air fresheners, automotive products, household cleaners, and personal care products Architectural Coatings ROG emissions from the application of architectural coatings for building maintenance Mobile Sources emissions from vehicles associated with the Project In addition, reflecting the particular characteristics associated with the Project, regional operational emissions calculated for the Project include: Helicopters fuel combustion emissions from helicopters utilizing the Project s helistop On-site Broilers fuel combustion and particulate emissions from broilers associated with restaurants located within existing and proposed hotel facilities As shown in Table IV.G-12, the Draft EIR calculated the net increase in regional operational emissions by calculating the future with project emissions level and subtracting the emissions associated with the existing site uses. The net increases for each of the criteria pollutants are shown below in Table 5. As shown, none of the net increases in Project emissions exceed the applicable SCAQMD threshold. Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 15 PRELIMINARY WORKING DRAFT WORK IN PROGRESS

17 Christopher A. Joseph & Associates April, 2010 Table 5 Estimated Future (2020) Project Daily Operational Emissions Emissions Source Emissions in Pounds per Day ROG/VOC NO x CO SO x PM 10 PM 2.5 Summertime Emissions Future With Project Emissions Existing Site Emissions Total Project Net Emissions (9.38) SCAQMD Thresholds Significant Impact? No No No No No No Wintertime Emissions Future With Project Emissions Existing Site Emissions Total Project Net Emissions (5.80) SCAQMD Thresholds Significant Impact? No No No No No No Source: Christopher A. Joseph & Associates, The first step in calculating the Equivalency Threshold is to calculate the difference between the SCAQMD threshold and the Project net emissions so that the Equivalency Threshold represents the additional emissions (over the Project emissions) that can occur without exceeding the SCAQMD threshold, using the formula: Equivalency Threshold = SCAQMD Threshold Project Net Emissions Applying this formula to the Project emissions in Table 5 yields the Equivalency Thresholds shown in Table 6. Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 16 PRELIMINARY WORKING DRAFT WORK IN PROGRESS

18 Christopher A. Joseph & Associates April, 2010 Table 6 Equivalency Thresholds First Step Emissions Source Emissions in Pounds per Day ROG/VOC NO x CO SO x PM 10 PM 2.5 Summertime Emissions SCAQMD Threshold Total Project Net Emissions (9.38) Adjustment Equivalency Threshold Wintertime Emissions SCAQMD Threshold Total Project Net Emissions (5.80) Adjustment Equivalency Threshold Source: Christopher A. Joseph & Associates, The next step in calculating the Equivalency Threshold is to adjust for emissions that could vary under the Land Use Equivalency Program, but are not directly related to a particular land use square footage or unit count. Several categories of emissions would be expected to occur at the same levels under exchanges within the Land Use Equivalency Program as under the Project. No adjustment is made for these categories of emissions. These include: Landscape Maintenance Equipment the use of landscape maintenance equipment is related to the size of the Project Site and the configuration of the landscaping (planter boxes, tree wells, etc.) which are not expected to vary if the land uses of the Project are modified under the Land Use Equivalency Program. The basic configuration of the Project would remain the same two high rise buildings occupying most of the Project Site. Architectural Coatings the application of architectural coatings for building maintenance is expected to remain the same since the basic configuration of the Project would remain the same two high rise buildings occupying most of the Project Site. Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 17 PRELIMINARY WORKING DRAFT WORK IN PROGRESS

19 Christopher A. Joseph & Associates April, 2010 Helicopters the same level of helicopter use at the Project s helistop would be expected to occur regardless of the land uses contained within the Project as the helistop is envisioned as a facility with the potential to serve downtown as a whole, not just the Project On-site Broilers the Project includes 40,000 square feet of restaurant use that is already assumed to include the operation of large-scale broilers. The Land Use Equivalency Program only allows for an additional 10,000 square feet of restaurant use which is not enough to require installation/operation of an additional broiler. One category of emissions that could increase under the Land Use Equivalency Program as compared to the Project is natural gas usage. This increase in emissions would be associated with the need to include a greater number of natural gas-fueled boilers in the Project if office, hotel and/or residential uses were to increase under the Land Use Equivalency Program. Because the installation of this additional equipment and associated emissions does not directly relate to the square footage or unit count of these uses that could be included in the Project under the Land Use Equivalency Program, a one-time adjustment to the Equivalency Thresholds was made reflecting the maximum equipment levels that would be expected to be installed in the Project under the Land Use Equivalency Program. Under this conservative approach, the impacts of the Land Use Equivalency Program on regional operational emissions are thus always assumed to include the maximum amount of natural gas-fueled equipment. The one-time adjustment for the natural gas usage category is shown in Table 7, along with the resulting Equivalency Thresholds. The calculation of the natural gas usage adjustment is provided in Appendix C to this Technical Report. The formula for this calculation is: Equivalency Threshold (Final) = Equivalency Threshold (First Step) Natural Gas Usage Adjustment Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 18 PRELIMINARY WORKING DRAFT WORK IN PROGRESS

20 Christopher A. Joseph & Associates April, 2010 Table 7 Equivalency Thresholds Final Emissions Source Emissions in Pounds per Day ROG/VOC NO x CO SO x PM 10 PM 2.5 Summertime Emissions Equivalency Threshold (First Step) Natural Gas Usage Adjustment Equivalency Threshold (Final) Wintertime Emissions Equivalency Threshold (First Step) Natural Gas Usage Adjustment Equivalency Threshold (Final) Source: Christopher A. Joseph & Associates, As discussed above, the calculations outlined in Tables 6 and 7 above account for five of the seven categories of regional operation emissions included in the SCAQMD methodology for calculating regional emissions impacts (natural gas usage, landscape maintenance equipment, architectural coatings, helicopters, and on-site broilers) that are applicable to the Project. The remaining two categories, Consumer Products and Mobile Sources, vary directly by land use square footage, unit count or daily traffic generation according to the formulas that are embedded in the URBEMIS 2007 model. A series of tables was created to show the changes in emissions that would result from exchanging one land use for another under the Land Use Equivalency Program, based on PM peak hour traffic. These tables are included in Appendix D to this Technical Report. In addition, a second table was included the table for each criteria pollutant in Appendix D that shows the maximum change in emissions that could occur if the donor land use was exchanged for the maximum amount of the recipient land use. The emissions associated with these maximum exchanges were then compared to the Equivalency Thresholds for each of the criteria pollutants, calculated as described above. This analysis shows that, for each of the criteria pollutants, except ROG, under both summertime and wintertime scenarios, the exchange of the largest component of Project land use (office) for the Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 19 PRELIMINARY WORKING DRAFT WORK IN PROGRESS

21 Christopher A. Joseph & Associates April, 2010 maximum amounts of the other land uses would not exceed the Equivalency Threshold and therefore would not cause an additional significant impact with respect to that criteria pollutant. Similarly, for each of the criteria pollutants, except ROG, under both summertime and wintertime scenarios, if all of the land uses in the Project were to be exchanged under the most impactful scenario (i.e., exchanged for the maximum number of residential units), the sum of these exchanges (which could actually not all occur simultaneously) would not exceed the Equivalency Threshold and therefore would not cause an additional significant impact with respect to that criteria pollutant. As such, for all criteria pollutants except ROG, under both summertime and wintertime scenarios, all of the land use exchanges allowed under the Land Use Equivalency Program would not cause additional significant regional operational emissions impacts. With respect to ROG emissions, the tables in Appendix D show that, under both summertime and wintertime scenarios, there are potential land use exchanges that could exceed the Equivalency Threshold. Comparison of these two tables also reveals that, for all land use exchanges that result in an increase in emissions, the change in the summertime ROG emissions is greater than for the same exchange under wintertime conditions. In addition, the Equivalency Threshold for summertime ROG emissions (23.49) is less than the Equivalency Threshold for wintertime ROG emissions (24.07). As such, increases in ROG emissions resulting from permitted land uses exchanges are more restrictive for summertime conditions and the analysis of only summertime ROG emissions in this Step is sufficient to ensure that land use exchanges allowed under the Land Use Equivalency Program would not cause additional significant regional operational emissions impacts (i.e., if a potential exchange would not have additional impacts related to summertime ROG emissions, it would also not have additional impacts related to wintertime ROG emissions). Thus for ROG emissions, an additional calculation is required in Step 2 to determine whether a proposed exchange would result in summertime ROG emissions that would exceed the SCAQMD threshold. To calculate the total change in ROG emissions associated with a proposed land use exchange, the total units of the land use being exchanged would be multiplied by the corresponding factor in Table 2. This amount would then be compared to the Equivalency Threshold for summertime ROG emissions of pounds per day. If the calculated ROG emissions from the proposed land use exchange would be below the Equivalency Threshold, the exchange would be acceptable under the Equivalency Program and the change to the Project could be made without any further environmental review. Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 20 PRELIMINARY WORKING DRAFT WORK IN PROGRESS

22 Christopher A. Joseph & Associates April, 2010 Example 1 shows a land use exchange permitted under the Land Use Equivalency Program that could be made without any further environmental review. EXAMPLE 1: Exchange office use to allow 300 additional hotel rooms STEP 1: Determine Proposed Land Use Exchange Based On PM Peak Hour Trip Generation (Table 1) 1,000 square feet of office = 2 hotel rooms Therefore, adding 300 hotel rooms requires an exchange of 150,000 square feet of office STEP 2: Calculate Change in ROG emissions for Desired Exchange Compared to Proposed Project 150,000 square feet of office exchanged for hotel rooms results in an increase of 6 pounds per day of ROG (150 *0.04 [Table 2]) 6 pounds per day is below the Equivalency Threshold of pounds per day Therefore the exchange of 150,000 square feet of office use for 300 hotel rooms is acceptable under the Land Use Equivalency Program without further environmental review. Under this scenario, 1,350,000 square feet of office use would remain in the project for development or further exchanges. Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 21 PRELIMINARY WORKING DRAFT WORK IN PROGRESS

23 Christopher A. Joseph & Associates April, 2010 STEP 3: If Calculated ROG Emissions are Higher than the Equivalency Threshold, Identify an Additional Land Use Offset to Reduce the Emissions Below the Threshold If the ROG emissions resulting from the proposed land use exchange as calculated in Step 2 exceed the Equivalency Threshold, an additional emissions offset needs to be taken from the land uses remaining in the Project that reduces the emissions level below the Equivalency Threshold. The amount of additional land use that needs to be reduced is determined using the emissions factors in Table 3. If the calculation shows the ROG emissions resulting from the proposed exchange to still be above the Equivalency Threshold, the exchange needs to be redefined and the process repeated from Step 1 until the emissions are reduced below the Equivalency Threshold. If there is not enough land use available in the Project to achieve the desired exchange, then an additional environmental analysis needs to be prepared to address the proposed exchange. Examples 2 and 3 show, respectively, land use exchanges that would be permitted under the Land Use Equivalency Program without any further environmental review, with an additional ROG offset, and a land use exchange that would not be permitted under the Land Use Equivalency Program and would require further environmental review. Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 22 PRELIMINARY WORKING DRAFT WORK IN PROGRESS

24 Christopher A. Joseph & Associates April, 2010 EXAMPLE 2: Exchange office use to allow 1,000 additional residential units STEP 1: Determine Proposed Land Use Exchange Based On PM Peak Hour Trip Generation (Table 1) 1,000 square feet of office = 3.11 residential units (Table 1) Therefore, adding 1,000 residential units requires an exchange of 321,544 square feet of office ( * 3.11 = 1,000) STEP 2: Calculate Change in ROG emissions for Desired Exchange Compared to Proposed Project 321,544 square feet of office exchanged for residential units results in an increase of pounds per day of ROG ( * [Table 2] = 43.60) pounds per day is above the Equivalency Threshold of pounds per day STEP 3: If Calculated ROG Emissions are Higher than the Equivalency Threshold, Identify an Additional Land Use Offset to Reduce the Emissions Below the Threshold In order to reduce ROG emissions below the Equivalency Threshold, an offset of pounds per day is required ( = 20.11). Using the emission factor for office use, an additional reduction of 1,005,500 square feet of office is required to equal the Equivalency Threshold ( * 0.02 [Table 3] = 20.11). Therefore the exchange of 1,327,044 (321, ,005,500) square feet of office use for 1,000 residential units is acceptable under the Equivalency Program without further environmental review. Under this scenario, 172,956 square feet of office use would remain in the project for development or further exchange. Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 23 PRELIMINARY WORKING DRAFT WORK IN PROGRESS

25 Christopher A. Joseph & Associates April, 2010 EXAMPLE 3: Exchange uses to allow 1,000 additional residential units and 300 hotel rooms STEP 1: Determine Proposed Land Use Exchange Based On PM Peak Hour Trip Generation (Table 1) 1,000 square feet of office = 3.11 residential units Therefore, adding 1,000 residential units requires an exchange of 321,544 square feet of office 1,000 square feet of office = 2 hotel rooms Therefore, adding 300 hotel rooms requires an exchange of 150,000 square feet of office STEP 2: Calculate Change in ROG emissions for Desired Exchange Compared to Proposed Project 321,544 square feet of office results in an increase of pounds per day of ROG [Example 2] 150,000 square feet of office results in an increase of 6 pounds per day of ROG [Example 1] pounds per day ( ) is above the Equivalency Threshold of pounds per day STEP 3: If Calculated ROG Emissions are Higher than the Equivalency Threshold, Identify Additional Land Use Offsets to Reduce the Emissions Below the Threshold In order to reduce ROG emissions below the Equivalency Threshold, an offset of pounds per day is required ( = 26.11). Using the emission factor for office use, an additional reduction of 1,305,500 square feet of office is required to equal the Equivalency Threshold ( * 0.02 [Table 3] = 26.11); however, only 1,028,456 square feet of office use still remains in the project after the exchange 1,028,456 square feet of office provides pounds per day of ROG emissions for offset ( * 0.02 = 20.57). Exchanging the rest of the land uses remaining in the project provides additional ROG emissions offsets. o 20,000 square feet of fitness center provides 1 pound per day of offset (20 * 0.05 = 1) o 10,000 square feet of retail provides 0.9 pounds per day of offset (10 * 0.09 = 0.9) Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 24 PRELIMINARY WORKING DRAFT WORK IN PROGRESS

26 Christopher A. Joseph & Associates April, 2010 o 40,000 square feet of restaurant provides 3.6 pounds per day of offset (40 * 0.09 = 3.6) As such, exchanging all of the remaining land uses in the project provides only pounds per day of offsets ( ), which is below the pounds per day of offset required. Therefore this proposed exchange would result in a significant impact with respect to ROG emissions and would not be acceptable under the Equivalency Program without further environmental review. Two options are possible at this point, (1) redefine the exchange to reduce the ROG emissions increase below the Equivalency Threshold; or (2) prepare a supplemental environmental analysis. Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 25 PRELIMINARY WORKING DRAFT WORK IN PROGRESS

27 Christopher A. Joseph & Associates April, 2010 IMPACTS OTHER THAN TRAFFIC AND REGIONAL AIR QUALITY As discussed in the preceding sections, the Land Use Equivalency Program, as defined above, has been structured to assure that, if the rules set forth in the Program are followed, no additional PM peak hour traffic impacts and no regional operational air emissions impacts would occur under any proposed land use equivalency exchange. With respect to other environmental impacts evaluated in the Project EIR, each section of the Project EIR includes an analysis of the potential effects of the Land Use Equivalency Program. Quantitative analysis is provided for sewer, water, solid waste, police, schools, parks and recreation, and library impacts using tables that show that the maximum exchanges would not cause significant impacts with respect to each of these issues. Qualitative analysis is provided for the remaining impact areas that cannot be quantified. These analyses can be found in the corresponding sections in the Draft EIR. The combination of these approaches provides the information and analysis required to establish that implementation the Land Use Equivalency Program would not result in additional significant impacts in any potential area of environmental impact. Therefore, implementation of the Land Use Equivalency Program would not require any additional environmental review if changes to the Project that follow the rules outlined herein are proposed in the future. Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 26 PRELIMINARY WORKING DRAFT WORK IN PROGRESS

28 Christopher A. Joseph & Associates April, 2010 APPENDIX A URBEMIS 2007 MODEL OUTPUT SHEETS FOR UNITS OF LAND USE INCLUDED IN THE LAND USE EQUIVALENCY PROGRAM Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 27 PRELIMINARY WORKING DRAFT WORK IN PROGRESS

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

47

48

49

50

51

52

53

54

55

56

57

58

59

60

61

62

63

64

65

66

67

68

69 Christopher A. Joseph & Associates April, 2010 APPENDIX B REGIONAL OPERATIONAL AIR EMISSIONS ANALYSIS FROM DRAFT EIR Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 28 PRELIMINARY WORKING DRAFT WORK IN PROGRESS

70 Christopher A. Joseph & Associates April, 2010 Emissions Source Table IV.G-12 Estimated Future (2020) Daily Operational Emissions Emissions in Pounds per Day VOC NO x CO SO x PM 10 PM 2.5 Summertime Emissions Future With Project Emissions Natural Gas Usage Landscape Maintenance Equipment Consumer Products Architectural Coatings Mobile (Vehicle) Sources Helicopters On-site Broilers Total Emissions Existing Site Emissions Natural Gas Usage Landscape Maintenance Equipment Architectural Coatings Mobile (Vehicle) Sources On-site Broilers Total Emissions Total Project Net Emissions (9.38) SCAQMD Thresholds Significant Impact? No No No No No No Wintertime Emissions Future With Project Emissions Natural Gas Usage Consumer Products Architectural Coatings Mobile (Vehicle) Sources Wilshire Grand Redevelopment Project Land Use Equivalency Program Technical Report Draft Environmental Impact Report Page 29 PRELIMINARY WORKING DRAFT WORK IN PROGRESS