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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

SUPERIOR COURT OF THE STATE OF CALIFORNIA

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FOR THE COUNTY OF LOS ANGELES

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SUNSET COALITION; BRENTWOOD

RESIDENTS COALITION; BRENTWOOD
HILLS HOMEOWNERS ASSOCIATION; and
DAVID AND ZOFIA WRIGHT
Petitioners,

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V.

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CITY OF LOS ANGELES

Respondent.

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ARCHER SCHOOL FOR GIRLS,

Does 1-10

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Real Parties In Interest

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CASE NO.: BS157811

DECLARATION OF MARCIA BA VERMAN

IN SUPPORT OF MOTION FOR NEW
TRIAL

(Violation of California Environmental Quality

Act and Los Angeles Municipal Code)
Assigned To: Hon. Mary H. Strobel
Dept. 82
Hearing on Motion:
Date:
December 13, 2016
Time:
9:30 a.m.
Petition Filed: September 9, 2015

28

Printed on Recycled Paper

Declaration of Marcia Baverman

DECLARATION OF MARCIA BA VERMAN

1
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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 EMF AC 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

1
2

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

10
11

the proposed project site.

6.

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 final 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

15

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

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17
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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

19

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

20

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

21

of construction vehicles.

22

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.

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9.

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

the only updated "analysis" pres ented to the City in Errata 6 consisted of "as sumptions 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

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.
5

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

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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12.

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.
13.

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

22 aggregation for the compressed 36-month schedule. In addition, to determine the actual air quality
23

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

24

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

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have shown that young animals are more sensitiv e than adults to exposur e to many carcinogens ,
therefore, the new OEHHA methodology includes an Age Sensitivity Factor (ASF). The ASF for

Printed on Recycled Paper

4

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

3
4

methodologies was adopted in final form by OEHHA.

15.

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
5

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 BIR correctly used the older OEHHA guidance.
Errata 5 at page 6 stated:

"Per the South Coast Air Quality Management District's (SCAQMD) direction, the analysi
was conducted consistent with SCAQMD's Risk Assessment Procedures for Rules 1401 and 212 and i
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 current/;
evaluating the new Guidance Manual and will start the public participation process this summer as the
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 ARO13180 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

20

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

22

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.
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
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26

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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

5

Declaration of Marcia Baverman

OEHHAGuidance could increasethe cancerrisk up to 10 times comparedto the old method for

"sensitivereceptors",and would increasethe cancer risk of due to constructionby three times for the

4
5

actual student populationat Archer.

20.

I have examinedthe "Archer School For Girls Cancer Risk Contour"Diagramin the

DEIR (AR 7564.) A copy of this is includedas Exhibit B. I have comparedthis to the locationof
temporaryclassroomsset forth in an applicationsubmittedto the City July 24, 2015. (AR 118:13188.)

This location map is includedas ExhibitE. From comparisonof the two documents,even using the

incorrectDPM contourcalculationsused by the DEIR, it appearsthat approximately8 of the modular

classroomswould be in the area exposedto significantlyunhealthfulair qualityconditionsduring

construction,without adequatemitigation. Under the compressed36-monthschedule,the ground level

10 concentrations,and thus the cancer risks to schoolchildrenin those buildingsduring constructionhours,

would be even higher than those shownon the diagram,and higher still when the updatedbreathing
11
rates and ASFs publishedby OEHHAare incorporated.
12

21. Similarly,I have comparedExhibitA to ExhibitB. Even using the incorrectDPM

13 contourcalculationsused by the DEIR (AR 115: 13046-13047),it appearsthat elderlyresidentsin some
14 of the apartmentsimmediatelyadjacentto the Archer worksitewouldbe exposedto significantly
15 unhealthfulair quality conditionsduringconstruction,without adequatemitigation. Under the
16 compressed36-monthschedule,the ground level concentrations,and thus the cancerrisks to elderly
17 adults in those buildingsduring constructionhours, would be even higher than those shown on the
18
19

20
21

diagram,and higher still when the updatedbreathingrates and ASFs publishedby OEHHAare
incorporated.
I declare under penalty of perjury that the foregoingis true and correctto the best of my knowledgeand
is executedon November \~ , 2016 at Placentia,California.

22
23

Marcia Bavennan

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Printed on RecycledPaper

Declarationof Marcia Baverman

..

E XHIBIT A
MB01

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QISIN..
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Figunt V-1

No Project~ ContinuedOperationof Exltistlng Campus

AltermativeConceptualSite Plan

environme ntal
PageV-10
S....... Pera*xMlocltllll Inc 2013

MB02

E XHIBIT B
MB03

- -IArcher School for Glrls

PROJECTTITLE:

!Cancer Risk Canto

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I
1B

u
::,

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I
I
I

384100

364000

364150

384250

384200

UTM East[m]
PLOTALE OF PERIODVALUESFORSOURCEGROUP:ALL

1.0

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3.0

5.0

COMMENTS:

SOURCES:

ConstructionCancer Risk

Contour
1 In a mNlion

RECEP10RS:

8.0

8.0

10.0

30.0

COMPANYNA1,IE

MODELER:

501
OUTPUTlYPE:

SCALE
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:

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AR007564

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AR007&66

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Archer School for Girls

Constructioncancer RiskBurdencalculations
Step 1. Determinecancer risk multiplier.
Cone(ug/m3)
1.00000

CancerRisk DPM EmissionRate(g/s)

2.S4E-OS

1.l 9E-02

Scaler(ug/m3 CancerRisk)
3.04E-07

Step 2. calculate net area within 1 in a millioncontour.

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

1 in million Contour
ProjectSite
Net Area(1 in million contour)
2
)

Net Area (km

0.05026377

Step 3. calculate cancerBurden

PopulationDensity (people/ml2)b

7,000

Populationwithin .1 in million contour

CancerBurden
1

352
0.0003S18S

Measuredusing LakesAERMOD-Vlew

b SCAQMDRiskAssessmentProceduresfor

Rules1401 & 212, Page19

AR007666

MB06

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MB07

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

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MB12

PROOF OF SERVICE

2
3
4

5
6

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 BA VERMAN IN SUPPORT OF MOTION FOR NEW TRIAL

8
9

10

11

r--,/"VIA OVERNIGHT DELIVERY. I enclosed the above-referenced document(s) in an

L::j 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.

12
13
14
15

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.

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 .)

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17

18
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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 .
VIA ELECTRONIC SERVICE. I caused the above-referenced document(s) to be sent to
the person(s) at the electronic address(es) listed below.

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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.

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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, 70 I City Hall East
Los Angeles, CA 90012
Jennifer.tobkin @lacit y.org

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Andrea K. Leisy
Sabrina Teller
Remy Moose Manley, LLP
555 Capitol Mall, Ste. 800
Sacramento, CA 9 5 814
aleis yra>rmmenvirolaw .com
steller @rmmenvirolaw.com

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Attorney for Real Party in Interest,

Archer School for Girls
15 James Arnone
16 Benjamin J. Hanelin
Latham & Watkins LLP
17 355 South Grand Avenue
18 Los Angeles, CA 90071-1560
JAMES.ARNONE @lw.com
19 Ben jamin.hanelin @lw.com
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