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City of Santa Ana—Cabrillo Town Center Project <br /> May 16,2023 <br /> Page 2of12 <br /> The Carpenters incorporates by reference all comments raising issues regarding the <br /> environmental assessment for the Project prior to approval of the Project. See Citi-Zens <br /> for Clean Energy v City of lloodland(2014) 225 Cal.AppAth 173, 191 (finding that any <br /> party who has objected to the project's environmental documentation may assert any <br /> issue timely raised by other parties). <br /> I. THE CITY SHOULD REQUIRE THE USE OF A LOCAL <br /> WORKFORCE TO BENEFIT THE COMMUNITY'S ECONOMIC <br /> DEVELOPMENT AND ENVIRONMENT <br /> The City should require the Project to be built using a local workers who have <br /> graduated from a Joint Labor-Management Apprenticeship Program approved by the <br /> State of California, have at least as many hours of on-the-job experience in the <br /> applicable craft which would be required to graduate from such a state-approved <br /> apprenticeship training program, or who are registered apprentices in a state-approved <br /> apprenticeship training program. <br /> Community benefits such as local hire can also be helpful to reduce environmental <br /> impacts and improve the positive economic impact of the Project. Local hire <br /> provisions requiring that a certain percentage of workers reside within 10 miles or less <br /> of the Project site can reduce the length of vendor trips, reduce greenhouse gas <br /> emissions, and provide localized economic benefits. As environmental consultants <br /> Matt Hagemann and Paul E. Rosenfeld note: <br /> [A]ny local hire requirement that results in a decreased worker trip length <br /> from the default value has the potential to result in a reduction of <br /> construction-related GHG emissions, though the significance of the <br /> reduction would vary based on the location and urbanization level of the <br /> project site. <br /> March 8, 2021 SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and <br /> Considerations for Greenhouse Gas Modeling. <br /> Workforce requirements promote the development of skilled trades that yield <br /> sustainable economic development. As the California Workforce Development Board <br /> and the University of California, Berkeley Center for Labor Research and Education <br /> concluded: <br /> [L]abor should be considered an investment rather than a cost—and <br /> investments in growing,diversifying,and upskilling California's workforce <br />