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CHATTEN-BROWN & CARSTENS LLP

Douglas P. Carstens, SBN 193439
Michelle Black, SBN 261962
2200 Pacific Coast Hwy, Suite 318
Hermosa Beach, CA 90254
310.798.2400; Fax 310.798.2402

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Attorneys for Petitioners

Sunset Coalition,
Brentwood Residents Coalition,
Brentwood Hills Homeowners Association,
David and Zofia Wright

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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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FOR THE COUNTY OF LOS ANGELES

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SUNSET COALITION; BRENTWOOD

) CASE NO.: BS157811
RESIDENTS COALITION; BRENTWOOD
)
HILLS HOMEOWNERS ASSOCIATION; and )
DAVID AND ZOFIA WRIGHT
) DECLARATION OF MARCIA BAVERMAN
) IN SUPPORT OF MOTION FOR NEW
Petitioners,
) TRIAL
v.
)
)
) (Violation of California Environmental Quality
CITY OF LOS ANGELES
Respondent.
Act and Los Angeles Municipal Code)
)
)
) Assigned To: Hon. Mary H. Strobel
ARCHER SCHOOL FOR GIRLS,
Does 1-10
Dept. 82
)
)
Hearing on Motion:
)
Real Parties In Interest
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Date:
December 13, 2016
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Time: 9:30 a.m.
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) Petition Filed: September 9, 2015
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)
)
)
)

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Printed on Recycled Paper

Declaration of Marcia Baverman

DECLARATION OF MARCIA BAVERMAN

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I, Marcia Baverman, declare as follows:

1.

I am a Project Manager/Senior Engineer with Environmental Audit, Inc. (EAI). I have

31 years of experience in environmental compliance. I hold a B.S. in chemical engineering and am a

licensed Professional Chemical Engineer in the State of California (No. 5089). Responsibilities

include project management, air dispersion modeling, health risk assessment preparation, CEQA

document preparation, emission inventories development for industrial facilities, air and wastewater

permit application preparation, conducting compliance audits for industrial facilities, environmental

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report preparation to provide support to environmental litigation, expert testimony, and addressing

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RCRA compliance issues.

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2.

Work I have completed includes the calculation and preparation of emission inventories

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for criteria pollutants, toxic air contaminants, and greenhouse gases; preparation of air permit

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applications; analysis of emission inventories for conformity to emission budgets and CEQA

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significance determinations; preparation of health risk assessments of facility and project emissions;

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preparation of air quality assessments; and, justification of reported air emissions for emission fees for

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facilities that include petroleum refineries, electroplating facilities, hazardous waste treatment facilities,

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defense contractors, military installations, marine terminals, engine manufacturers, paper products

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manufacturers, pesticide manufacturers, religious facilities, housing developments, and federal

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facilities. Performed air quality impacts analysis using multiple versions of the EMFAC emissions

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model for mobile sources, multiple versions of the URBEMIS emissions model for new development

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projects, emissions modeling using the U.S. EPA ISCST3 and AERMOD dispersion modeling software

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and CALINE for mobile sources, health risk assessment modeling software including ACE2588,

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HARP, HARP2 and IRAPView.

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3.

Environmental Audit, Inc. (EAI) has examined the health risk assessments for the

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Archer School expansion project. Our letter of July 28, 2015 demonstrated that the HRA included in

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the Archer Draft EIR was incorrect, and that analysis was implicitly admitted by the numerous

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corrections set forth on the day of the final City Council vote on August 4, 2015 in Appendix F-2 to the

Printed on Recycled Paper

Declaration of Marcia Baverman

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FEIR and summarized on page 4 of Errata 6 (AR 35F:5668).

4.

The health risk analysis (HRA) for construction contained in the Final EIR, including the

last-minute submissions of "Errata 6" and the materials submitted by Latham & Watkins on August 3,

2015 is also inadequate and incorrect, and dangerously understate the cancer risks that will impact the

Archer schoolchildren as well as elderly neighbors immediately adjacent to the Archer project.

5.

Specifically, the HRA fails to use the correct emission factor for diesel particulate matter

(DPM). It uses dangerously outdated health risk guidance for calculating cancer risks. These technical

and methodological errors very substantially underestimate the health risks posed to the "sensitive

populations" identified in current statewide guidance (schoolchildren and elderly adults) on and near

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the proposed project site.

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In addition, the FEIR does not contain factual support for the conclusion that peak day

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air quality and health impacts will be no worse under the fmal 36-month construction schedule

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disclosed in the chart submitted with Errata 6 (AR 5:140). Details such as were presented in Apps. C-1

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and C-2 to the DEIR are absolutely necessary to any acceptable analysis of air quality and health

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impacts, and were never provided to the public or the City.

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7.

Compressed construction schedule and newly overlapping project elements: In Apri

2015, as set forth in Errata 2, Archer decided to compress its construction activities from 74 months to
36 months but until August 3, 2015 Archer did not disclose which of its project elements would now
overlap (see one-page chart at AR 5:140, included in Errata 6 and attached as Exhibit D), and even then

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did not disclose any of the necessary details that would allow responsible expert analysis of the air

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quality and health risk impacts of onsite construction equipment and the related arrivals and departures

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of construction vehicles.

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8.

Among other changes, AR 5:140 reflects changes in the number of months that some of

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the original six project elements would now take. For example, Archer's original schedule presented

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that the North Wing Renovation work would be spread over 16 months, while Exhibit D shows that

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project element compressed into 14 months and now would fully overlap the nearby work on the
underground parking garage/athletic fields, and the Multipurpose Facility.
9.

Despite the very significant changes in the construction schedule reflected in Exhibit D,

the only updated "analysis" presented to the City in Errata 6 consisted of "assumptions and conclusions,
without any of the absolutely necessary underlying data. Data in the form of Appendix C-1 and

Printed on Recycled Paper

Declaration of Marcia Baverman

Appendix C-2 to the DEIR are necessary for any scientifically reliable analysis of the amount of

nitrogen dioxide and airborne particles during the weeks of maximum air pollution and elevated cancer

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risk. Those details have not been provided to the public or to the City authorities. In addition, to
determine the actual air quality impacts due to overlapping phases, the project would have to be
remodeled in CalEEMod.
10.

In Appendices C-1 and C-2 (and Exhibit C), it can be seen that when construction was to

be spread over 74 months, only two major elements of the Archer project would overlap in time the

Underground Parking Garage/Athletic Field, and the Multipurpose Facility. In contrast, when the

project is compressed into 36 months, the North Wing Renovation work would now overlap those two

elements for fourteen months (AR 5:140).

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11.

As the first step in analyzing the impact of onsite construction equipment on airborne

toxins and health risks, one must total the equipment that is projected to be active onsite during the
elements that are planned to overlap.

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Emissions from arriving and departing construction vehicles are additive to those from

onsite construction equipment. As the first step in analyzing the impact of construction vehicles on

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airborne toxins and health risks, one must total the vehicles that are projected to arrive and depart during

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the elements that are planned to overlap. For example, in week 80, Appendix C-2 shows that 16

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concrete trucks (Class VII) will arrive and depart each day of that week to support the onsite activities

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for the underground parking structure/outdoor athletic fields, and another 10 concrete trucks for the

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Multipurpose Facility.
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This step of aggregating the vehicles by Class and calculating their emissions, and

aggregating emissions of the onsite construction equipment operating concurrently on different parts of
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the worksite, then leads to determining which weeks and days will have "peak" impacts as to NOx

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emissions, particulate emissions, and health risks. The DEIR and FEIR present no such details and

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aggregation for the compressed 36-month schedule. In addition, to determine the actual air quality

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impacts due to overlapping phases, the project would have to be remodeled in CalEEMod. However,

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new CalEEMod runs were not included in the FEIR.

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14.

Health Risk Guidance. The State of California Office of Environmental Health Hazard

Assessment (OEHHA) promulgated significantly updated scientific information in 2015 as to the

breathing rates of schoolchildren and elderly adults designated as "sensitive receptors. Further, studies
have shown that young animals are more sensitive than adults to exposure to many carcinogens,
therefore, the new OEHHA methodology includes an Age Sensitivity Factor (ASF). The ASF for

Printed on Recycled Paper

Declaration of Marcia Baverman

fetuses in the third trimester up to children age two is ten times higher than an adult, and children two to

sixteen are three times higher. In February 2015, a Guidance Manual that included that the new data an'

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methodologies was adopted in final form by OEHHA.

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Archer and the City used the outdated 2003 Guidance Manual in their HRA instead of the

updated scientific data, which uses outdated breathing rates and completely ignores ASF. This results in
dangerously underestimating the cancer risks of the Archer construction project on the Archer

schoolchildren as well as nearby children and elderly residents. Archer's proximity to sensitive

receptors elevates the risks created by the project's construction activities. (See Exhibit A, a map the

city block that contains Archer with five apartment complexes nearby labeled A, B, C, D, E, and F.)

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16.

City environmental review documents claim that the AQMD has not adopted the new

OEHHA guidance for CEQA purposes, and that the EIR correctly used the older OEHHA guidance.
Errata 5 at page 6 stated:
"Per the South Coast Air Quality Management District's (SCAQMD) direction, the analysis
was conducted consistent with SCAQMD's Risk Assessment Procedures for Rules 1401 and 212 and A
based on OEHHA's Guidance Manual from August 2003. Contrary to what is stated in this comment, th(
SCAQMD has not adopted the new version of the Guidance Document for use in CEQA analyses.
According to Jillian Wong, Ph.D., SCAQMD CEQA Program Supervisor, SCAQMD is currentli
evaluating the new Guidance Manual and will start the public participation process this summer as th
develop recommendations on its use for SCAQMD CEQA analyses."
17.

Context is important; the email exchange between Eyestone and Jillian Wong

(SCAQMD) can be found at page AR013180 in the administrative record. The actual question Eyestone
asked Jillan Wong was whether the SCAQMD had any guidance for construction health risk. The

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AQMD has never had any guidance specifically for construction health risk, but SCAQMD has

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absolutely adopted the new 2015 OEHHA guidance for both CEQA and permitting purposes. The

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approved (June 15, 2015) SCAQMD Rule 1401, which follows the new 2015 OEHHA guidance can be

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found on the SCAQMD website. Therefore, while an applicant does not have to offer a construction

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HRA, if an applicant volunteers to provide one, the HRA must use the most current scientific data.

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18.

Furthermore, OEHHA's Toxic Hotspots Program Guidance Manual of February 2015

states "local air pollution control districts sometimes use the risk assessment guidelines for the Hot
Spots program in permitting decisions for short-term projects such as construction." (Page 8-18 of
February 2015 Guidance.)
19.

The Archer FEIR uses scientifically outdated data used by OEHHA in guidance

promulgated in 2003, but superseded by Guidance OEHHA promulgated in 2015. Applying the updated

Printed on Recycled Paper

Declaration of Marcia Baverman

OEHHA Guidance could increase the cancer risk up to 10 times compared to the old method for

"sensitive receptors", and would increase the cancer risk of due to construction by three times for the

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actual student population at Archer.

20.

I have examined the "Archer School For Girls Cancer Risk Contour" Diagram in the

DEIR (AR 7564.) A copy of this is included as Exhibit B. I have compared this to the location of
temporary classrooms set forth in an application submitted to the City July 24, 2015. (AR 118:13188.)

This location map is included as Exhibit E. From comparison of the two documents, even using the

incorrect DPM contour calculations used by the DEIR, it appears that approximately 8 of the modular

classrooms would be in the area exposed to significantly unhealthful air quality conditions during

construction, without adequate mitigation. Under the compressed 36-month schedule, the ground level

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concentrations, and thus the cancer risks to schoolchildren in those buildings during construction hours,
would be even higher than those shown on the diagram, and higher still when the updated breathing
rates and ASFs published by OEHHA are incorporated.

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21.

Similarly, I have compared Exhibit A to Exhibit B. Even using the incorrect DPM

contour calculations used by the DEIR (AR 115: 13046-13047), it appears that elderly residents in some

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of the apartments immediately adjacent to the Archer worksite would be exposed to significantly

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unhealthful air quality conditions during construction, without adequate mitigation. Under the

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compressed 36-month schedule, the ground level concentrations, and thus the cancer risks to elderly

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adults in those buildings during construction hours, would be even higher than those shown on the

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diagram, and higher still when the updated breathing rates and ASFs published by OEHHA are
incorporated.

I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge and
is executed on November 11, 2016 at Placentia, California.

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Marcia Baverman

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Printed on Recycled Paper

Declaration of Marcia Baverman

_,XHIBIT ..A

MB 01

1.7

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MB 02

Figure V-1
No Project - Continued Operation of Exitisdng Campus
Allermative Conceptual Site Plan
Flags V-10

EXHIBIT B
MB 03

PROJECT TITLE:
i

Archer School for Girls

Cancer Risk Conto

364050

364000

364100

364150

364200

384250

364300

UTM East [rn]

usfrnA3

PLOT FILE OF PERIOD VALUES FOR SOURCE GROUP: ALL

-r.1111
1.0

111111Mr
5.0
3.0

COMMENTS:

SOURCES:

Construction Cancer Risk

Contour
1 in a million

1
RECEPTORS:

8.0

8.0

30.0

10.0

COMPANY NAME

MODELER:

501
OUTPUT TYPE:

SCALE:

Concentration

AERMOD View - Lakes Envirovrtental Softweue

0"'

MAX:

DATE:

36.41003 ughn"ti

101112013

1:2,553
_

. :.05 km
1PROJECT

CADropboAArcheriAIr fluallbjACons tructIonlAERMODUIpm1dpinisc

AR007564
MB 04

Archer School far Girls

DPM Risk Calculations Adult Exposure (Construction)
Archer School for Girls

-_ ^

....

Source

Mass GLC

(R/a3)

Carehoogerlic Irma

Contandisint

WNW
FranIon

IMF
01114u3i'

MOM

CPF
EuSROMICO 4

(IQ

Conduction bPlit
(Construction Durationl_

035914

3.6E-04

RISE

RID
tocisafoo)

Diesel Egg=
1.00E490 Path:Wee

3.0E-04

1.1E400

DPM Taal
Key to Tog000logical Endpoials

Noe
Respiratory System
CentraPeripland llama System
Cardiovascular/Blood System
bun= System
Kidney
Gasnoiotadnal Systannives
Raproductiva Systan
arena& and devdopments1 effects)
Eye irritation and/or other effects

CW&PIES

ft)

O)

Thud

RESP
ENS/MS
CMS
RAMP
MEN
GELV
REPRO
EYES

Noarorebsogente Mozart I /Toleologleal Ettdpohrfo"

REL
000113)

9.141346
5.0E+00
1.4E43
1.1E-03
934E-06
3.6E+04
1.0E+01
1.07E-02
9.131111
in a million
Exposum Paton used to Wad*, onnarainain intake
mos= frequency (days/yam)
=ponce &union (yars)
inhalation tate (m3Iday)
:MOPtady wd1116 End
twanging time(canCen (drys)
averaging dune(nonancer) (des)
diesel pagodas Wand efficiency

COM

DOWN

KIDN

le

mom*

00E+00

0.0E+00

0.08+00

GIILV

REPRO

(P1

for

0.0E+00

0.0E400

0.0E400

GOLF

REPRO

EYES

fpy

et,

rro

0.0E+00

0.0E+00

60E+00

EYES

365
19.0
70
25550
14600
0%

Archer School for Girls

Adult Risk (Miduatedl

Source

Max GLC

weialle

lusin0
to
eanetruclion
(Donshuction Duration)

OrShue
to

Corcborgerde flame

Connualuout
ORE
Seror3)4

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(ISSRAkeli

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REL

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ito

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ONIA~

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LAWNS

ea,

In

MEL

REARM

VON

ruf

Chad Exhaust
023503

2.4E-04

1.00E400 Partiadae

3.0E-04

1.1E+00

Total
DPMTetal

Key to Tosocological Endpoints

RESP
CIPS/PNS
CYRIL
1MMUN
MEN
GIEN
REPRO
BYES

Nooreercluogerdc Hawed / SaticolevIrot Eiedpobus.

RISE

Nola
Respiratory System
Cential/Pcdpbend Nervous System
CarBovasadaiBlood Systan
Immune System
Kidney
Gastrointestinal Systera/Liver
Reproductive Sys= (e.g., tennogethe ad developmental elliscts)
Eye iffilatian snifter otherefroas

Assumption and Analysis Summary-Revised Dec 13

5.968-06
5.0E+00
1.4E-03
7.0E-03
5.9111E46 I_ 3.6E+04
1.0E401
6.9PE-03
5.9307
in a million
Exposure Eldora used to casaba coritassinsnt brake
(=Pam &await (d11.1ryellr)
espouse duration (wars)
inhalalios rate (03/day)
average body PM& GPO
masking thae(amar) (days)
averaging tiznanaucancer) (days)
diesel paniadate weird efficienry

Page 1 cif 1

0.0E+00

0.0E+00

0.0E+00

0.0E+00

365
19.0
70
23550
14600
0%

SAO PM 1/14/2014

AR007565
MB 05

Archer School for Girls

Construction Cancer Risk Burden Calculations
Step 1. Determine cancer risk multiplier.
Conc (ug/m3)
1.00000

Cancer Risk DPM Emission Rate (g/s)

1.19E-02
f

I 2.54E-05

Scaler (ug/m3 * Cancer Risk)

3.04E.07
_

Step 2. Calculate net area within 1 in a million contour.

1 in million Contour
Project Site
Net Area (1 in million contour)
Net Area (km2)

Area (m2)8
92,069
41,805
50,264
0.05026377

Step 3. Calculate Cancer Burden

Population Density (peopleimiT
Population within 1 in million contour
Cancer Burden

7,000
352
0.00035185

Measured using Lakes AERMOD-View

SCAQMD Risk Assessment Procedures for Rules 1401 & 212, Page 19

AR007566
MB 06

EXHIBIT_ ff-1

'

MB 07

Archer Forward: Campus Preservation and Improvement Plan

Construction Timeline Comparison: Draft EIR Six-Year Construction Schedule vs. Final EIR Five-Year Construction Schedule
Six-Year Construction Schedule (Draft EIR)

Phase 1
Phase 2 Option A
Phase 2 Option B

Year
Month
North Wing Renovation and Temporary Classroom Village
Site Preparation and Excavation and Haul
Parking Structure / Outdoor Athletic Facilities
Multipurpose Facility
Aquatics Center / Visual Arts Center
Performing Arts Center
Aquatics Center / Visual Arts Center
Performing Arts Center

1
6

10

11

12

13

14

15

16

17

2
18 19

20

21

22

23

24

25

26

27

28

29

3
30 31

32

33

34

35

36

37

38

39

40

41

4
42 43

41

4
42 43

44

45

46

47

48

49

50

51

52

53

5
54 55

53

5
54 55

56

57

58

59

60

61

62

63

64

65

6
66 67

65

6
66 67

68

69

70

71

72

73

7
74

75

73

7
74

75

Five-Year Construction Schedule (Final EIR)

Year
Month

Phase 1
Phase 2

Week
North Wing Renovation and Temporary Classroom Village
Site Preparation and Excavation and Haul
Parking Structure / Outdoor Athletic Facilities
Multipurpose Facility
Aquatics Center / Visual Arts Center
Performing Arts Center

10

14

18

1
6
23

10

11

12

13

14

15

16

17

2
18 19

27

31

36

40

44

49

53

57

62

66

70

75

79

24

25

26

27

28

29

3
30 31

20

21

22

23

32

33

34

35

36

37

38

39

40

44

45

46

47

48

49

50

51

52

56

57

58

59

60

61

62

63

64

68

69

70

71

72

83

88

92

96 101 105 109 114 118 122 127 131 135 140 144 148 153 157 161 166 170 174 179 183 187 192 196 200 205 209 213 218 222 226 230 235 239 243 248 252 256 261 265 269 274 278 282 287 291 295 300 304 308 313 317 321

AR004967

XHIBIT D
MB 09

MATT
CONSTRUCTION
CORPORATION

9814

SUITE 100

NORWALK BOULEVARD

SANTA FE SPRINGS

90670-2936

CALIFORNIA

562 903-2290 FAX

562 903-2277

www.mattconstruction.com

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EXHIBIT E

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AR013188

MB 12

PROOF OF SERVICE
I am employed by Chatten-Brown & Carstens LLP in the County of Los Angeles, State of California.
I am over the age of 18 and not a party to the within action. My business address is 2200 Pacific Coast
Highway, Ste. 318, Hermosa Beach, CA . On November 14, 2016, I served the within documents:
DECLARATION OF MARCIA BAVERMAN IN SUPPORT OF MOTION FOR NEW TRIAL
VIA UNITED STATES MAIL. I am readily familiar with this business' practice for
collection and processing of correspondence for mailing with the United States Postal Service.
On the same day that correspondence is placed for collection and mailing, it is deposited in
the ordinary course of business with the United States Postal Service in a sealed envelope with
postage fully prepaid. I enclosed the above-referenced document(s) in a sealed envelope or
package addressed to the person(s) at the address(es) as set forth below, and following
ordinary business practices I placed the package for collection and mailing on the date and at
the place of business set forth above.
7 VIA OVERNIGHT DELIVERY. I enclosed the above-referenced document(s) in an
envelope or package designated by an overnight delivery carrier with delivery fees paid or
provided for and addressed to the person(s) at the address(es) listed below. I placed the
envelope or package for collection and overnight delivery at an office or a regularly utilized
drop box of the overnight delivery carrier.

VIA MESSENGER SERVICE. I served the above-referenced document(s) by placing them

in an envelope or package addressed to the person(s) at the address(es) listed below and
provided them to a professional messenger service for service. (A declaration by the
messenger must accompany this Proof of Service or be contained in the Declaration of
Messenger below.)
VIA FACSIMILE TRANSMISSION. Based on an agreement of the parties to accept
service by fax transmission, I faxed the above-referenced document(s) to the persons at the
fax number(s) listed below. No error was reported by the fax machine that I used. A copy of
the record of the fax transmission is attached.

Er

VIA ELECTRONIC SERVICE. I caused the above-referenced document(s) to be sent to

the person(s) at the electronic address(es) listed below.

I declare that I am employed in the office of a member of the bar of this court whose direction the
service was made. I declare under penalty of perjury under the laws of the State of California that the above is
true and correct. Executed November 14, 2016, at Hermosa Beach, California.

Cynthia Kellman

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SERVICE LIST
Attorneys for City of Los Angeles
Michael N. Feuer
Terry Kaufmann Macias
Jennifer K. Tobkin
200 North Main Street, 701 City Hall East
Los Angeles, CA 90012
Jennifer.tobkin@lacity.org

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Andrea K. Leisy
Sabrina Teller
Remy Moose Manley, LLP
555 Capitol Mall, Ste. 800
Sacramento, CA 95814
aleisy@rmmenvirolaw.com
steller@rmmenvirolaw.com

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Attorney for Real Party in Interest,

Archer School for Girls
James Arnone
Benjamin J. Hanelin
Latham & Watkins LLP
355 South Grand Avenue
Los Angeles, CA 90071-1560
JAMES.ARNONE@lw.com
Benjamin.hanelinglw.corn