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Correspondence - #27
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Correspondence - #27
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27
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5/16/2023
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As demonstrated above, default rural worker trip lengths for air basins in California vary from 10.8-to 19.8- <br /> miles,with an average of 16.47 miles. Furthermore, default urban worker trip lengths vary from 10.8-to 14.7- <br /> miles,with an average of 11.17 miles. Thus, while default worker trip lengths vary by location, default urban <br /> worker trip lengths tend to be shorter in length. Based on these trends evident in the CalEEMod default worker <br /> trip lengths, we can reasonably assume that the efficacy of a local hire requirement is especially dependent <br /> upon the urbanization of the project site, as well as the project location. <br /> Practical Application of a Local Hire Requirement and Associated Impact <br /> To provide an example of the potential impact of a local hire provision on construction-related GHG emissions, <br /> we estimated the significance of a local hire provision for the Village South Specific Plan ("Project") located in <br /> the City of Claremont ("City").The Project proposed to construct 1,000 residential units, 100,000-SF of retail <br /> space,45,000-SF of office space, as well as a 50-room hotel, on the 24-acre site.The Project location is classified <br /> as Urban and lies within the Los Angeles-South Coast County. As a result, the Project has a default worker trip <br /> length of 14.7 miles.14 In an effort to evaluate the potential for a local hire provision to reduce the Project's <br /> construction-related GHG emissions,we prepared an updated model, reducing all worker trip lengths to 10 <br /> miles (see Attachment B). Our analysis estimates that if a local hire provision with a 10-mile radius were to be <br /> implemented, the GHG emissions associated with Project construction would decrease by approximately 17% <br /> (see table below and Attachment C). <br /> Local Hire Provision Net Change <br /> Without Local Hire Provision <br /> Total Construction GHG Emissions (MT CO2e) 3,623 <br /> Amortized Construction GHG Emissions (MT CO2e/year) 120.77 <br /> With Local Hire Provision <br /> Total Construction GHG Emissions (MT CO2e) 3,024 <br /> Amortized Construction GHG Emissions (MT CO2e/year) 100.80 <br /> Decrease in Construction-related GHG Emissions 17% <br /> As demonstrated above, by implementing a local hire provision requiring 10 mile worker trip lengths,the Project <br /> could reduce potential GHG emissions associated with construction worker trips. More broadly, any local hire <br /> requirement that results in a decreased worker trip length from the default value has the potential to result in a <br /> reduction of construction-related GHG emissions, though the significance of the reduction would vary based on <br /> the location and urbanization level of the project site. <br /> This serves as an example of the potential impacts of local hire requirements on estimated project-level GHG <br /> emissions,though it does not indicate that local hire requirements would result in reduced construction-related <br /> GHG emission for all projects. As previously described,the significance of a local hire requirement depends on <br /> the worker trip length enforced and the default worker trip length for the project's urbanization level and <br /> location. <br /> 14"Appendix D Default Data Tables."CAPCOA,October 2017, available at:http://www.agmd.gov/docs/default- <br /> source/caleemod/05 appendix-d2016-3-2.pdf?sfvrsn=4, p. D-85. <br /> 4 <br />
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