Jacob P. Duginski 456 Montgomery Street | Suite 1800 San Francisco, CA 94104-1251 +1.415.262.4018 (Office) [email protected]

December 16, 2020

Via E-Mail Clerk of the Boards South Coast Air Quality Management District 21865 Copley Drive Diamond Bar, CA 91765 [email protected]

Re: Request to Take Official Notice in SCAQMD v. Chiquita Canyon, LLC (No. 6177-1)

Dear Madam Chair and Members of the Board:

Respondent Chiquita Canyon, LLC (“Chiquita”) writes to request that the Hearing Board take official notice of the attached Environmental Impact Report (“EIR”) excerpt and two of its appendices. Public testimony at the hearing and the inquiries of some of the Hearing Board members raised questions about the potential health impacts of the operation of the Chiquita Canyon Landfill, as well as any potential impacts on housing values. Chiquita submits the attached EIR and appendices to assist in the Hearing Board’s evaluation of this matter.

The EIR (Attachment 1) was prepared to satisfy Los Angeles County’s obligations under the Environmental Quality Act to consider the potential environmental impacts of a project subject to its discretionary approval. Los Angeles County adopted the attached EIR when approving Chiquita’s most recent Conditional Use Permit (“CUP”) renewal on July 25, 2017. The EIR evaluated Chiquita’s proposed project, which was much larger than what was approved.

Chiquita would like to specifically draw the Hearing Board’s attention to three assessments contained within the EIR.

 A Health Risk Assessment (“HRA”) was conducted to evaluate any potential increase in cancer risk in the surrounding community from continued operation of the Chiquita Canyon Landfill. That analysis concluded that predicted cancer risks would be less than significant, specifically:

Cancer burden is defined as the estimated increase in the occurrence of cancer cases in a population resulting from exposure to carcinogenic air contaminants. Based on the cancer risk estimated using the 2015 OEHHA Guidance, the cancer burden was predicted to be 0.01 excess cancer cases, which is below the SCAQMD threshold of 0.5 excess cancer cases. Based on the cancer risk estimated using the 2003 OEHHA Guidance, the cancer burden was predicted to Austin, TX Baltimore, MD Boston, MA New York, NY San Francisco, CA Seattle, WA Washington, DC

Clerk of the Boards SCAQMD December 16, 2020 Page 2

be 0.004, which is also below the SCAQMD threshold of 0.5 excess cancer cases. The HRA conducted to evaluate exposure of sensitive receptors to pollutant concentrations demonstrates that the predicted impacts would be less than significant.” (Attachment 1, EIR at p. 11-38.)

 An overall public health evaluation as it related to continued operation of the Chiquita Canyon Landfill is contained at Appendix M within the EIR (Attachment 2). That analysis included several salient conclusions:

o The prevalence of asthma in communities around [Chiquita Canyon] falls within the range observed for [Service Planning Areas] designated by the [Los Angeles Department of Public Health]. Asthma prevalence in SPA 2 (where [Chiquita Canyon] is located) is indistinguishable from the asthma prevalence elsewhere in Los Angeles County. (Attachment 2, Appendix M at p. 7.)

o The cancer mortality rates for selected cancers examined (lung cancer and leukemia) in SPA 2 are not distinguishable from mortalities estimated for Los Angeles County. (Attachment 2, Appendix M at p. 7.)

o [Volatile organic compounds] most frequently associated with emissions from a landfill were assessed as part of the health risk assessment. Detection of odors is not considered a reliable surrogate for VOC exposures, but is considered an indicator of potential landfill gas migration. Hydrogen sulfide and other landfill gas emissions are minimized and controlled at landfills through proper operating and maintenance practices. (Attachment 2, Appendix M at p. 7.)

 An analysis was also conducted to determine whether property values in Val Verde were impacted by the properties’ proximity to the Chiquita Canyon Landfill. That analysis conclude that “there is no basis to conclude that the Landfill has impacted surrounding area home price appreciation.” (Attachment 3, Appendix L at p. 2.)

Hearing Board Rule 9(e)(1) allows for the Board to take official notice of any document that may be accepted for judicial notice by a State of California court. The California Evidence Code allows the courts of California to take judicial notice of the records of Counties within the state. (Evid. Code § 452(c).) The EIR and its appendices were adopted by Los Angeles County in approving Chiquita’s 2017 CUP, and therefore are subject to judicial notice, and may be officially noticed by this Hearing Board. A copy of the County’s adoption of the EIR is also provided as Attachment 4 (see p. 16, Conclusion 1, certifying the EIR (excerpt)).

Austin, TX Baltimore, MD Boston, MA New York, NY San Francisco, CA Seattle, WA Washington, DC

Clerk of the Boards SCAQMD December 16, 2020 Page 3

Sincerely,

Jacob P. Duginski Attorney for Chiquita Canyon, LLC

Enclosure: Attachment 1 (Excerpt of Chiquita Canyon Landfill Master Plan Revision Final Environmental Impact Report, Vol. 1)

Attachment 2 (Appendix M – Public Health Evaluation)

Attachment 3 (Appendix L – CCL Housing Price Impact Study)

Attachment 4 (Excerpt of July 25, 2017 Approval of Conditional Use Permit and Adoption of EIR)

cc: Kathryn Roberts, Esq. (Deputy District Counsel II) via email to [email protected]

Mary Reichert, Esq. (Senior Deputy District Counsel) via email to [email protected]

Austin, TX Baltimore, MD Boston, MA New York, NY San Francisco, CA Seattle, WA Washington, DC

Attachment 1 (February 2017 Final EIR)

FINAL

Chiquita Canyon Landfill Master Plan Revision Final Environmental Impact Report

Project No. R2004-00559-(5) SCH No. 2005081071

Lead Agency: County of Los Angeles, Department of Regional Planning

Project Proponent: Chiquita Canyon Landfill

February 2017

CH2M HILL, Inc. 6 Hutton Centre Drive Suite 700 Santa Ana, California 92707

Reader’s Guide to the Final Environmental Impact Report Purpose In accordance with Section 15089 of the California Environmental Quality Act (CEQA) Guidelines, a lead agency shall prepare a Final Environmental Impact Report (EIR) before approving a project. This Final EIR for the Chiquita Canyon Landfill (CCL) Master Plan Revision (Proposed Project) has been prepared in accordance with Section 15132 of the state CEQA Guidelines. As required by that section, this Final EIR consists of the following:  The complete Draft EIR (comprising the July 10, 2014, Original Draft EIR; and superseding chapters, appendixes, and supplemental information included in the November 9, 2016, Partially Recirculated Draft EIR)  A Mitigation Monitoring and Reporting Program (MMRP)  Responses to significant environmental points received during the public comment periods for the Original Draft EIR and Partially Recirculated Draft EIR  Comments received and a transcript of the oral testimonies regarding the Proposed Project and/or Draft EIR Environmental Review Process As defined in Section 15050 of the state CEQA Guidelines, Los Angeles County is the lead agency under CEQA, with the Los Angeles County Department of Regional Planning (LADRP) acting as the lead department of the lead agency for the Proposed Project. LADRP has independently evaluated, directed, and supervised the preparation of this document, in coordination with other County departments. LADRP determined that preparation of an EIR was required for the Proposed Project after conducting preliminary review and preparing an Initial Study, dated November 22, 2011, in accordance with Sections 15060 and 15063 of the state CEQA Guidelines. In accordance with Section 15082 of the state CEQA Guidelines, a Notice of Preparation (NOP) was issued on November 21, 2011, to the State Clearinghouse, various public agencies, and other interested parties for the required 30-day review and comment period. Additionally, a Scoping Meeting was held on December 6, 2011, at the Val Verde Community Regional Park Facility, located at 30300 West Arlington Street, Val Verde, California 91384, to facilitate the public review and comment period. All NOP comments relating to the EIR were received, and the issues raised in those comments were considered in preparation of the Draft EIR. The NOP, including the Initial Study, the NOP comments received by LADRP, and the Scoping Meeting comments are contained in Appendix A of the Original Draft EIR. A Draft EIR (Original Draft EIR) was prepared and distributed directly to agencies, organizations, and interested groups and persons for an extended comment period (105 days), from July 10, 2014, to October 23, 2014, in accordance with Section 15087 of the state CEQA Guidelines. During that review period, a public hearing was held by the LADRP Hearing Examiner on July 31, 2014, at the Castaic Sports Complex – Gymnasium, located at 31320 North Castaic Road, Castaic, California 91384, and public testimony was taken. A Partially Recirculated Draft EIR was prepared in accordance with Section 15088.5 of the state CEQA Guidelines. Specifically, LADRP determined that new or clarified information required recirculation of certain chapters of the Original Draft EIR for the Proposed Project. This Partially Recirculated Draft EIR was distributed directly to agencies, organizations, and interested

EN1129161114SCO III READER’S GUIDE TO THE FINAL ENVIRONMENTAL IMPACT REPORT groups and persons for comment during an extended comment period (60 days), from November 9, 2016, to January 9, 2017, in accordance with Section 15087 of the state CEQA Guidelines. During that review period, a public hearing was held by the LADRP Hearing Examiner on December 15, 2016, at the West Ranch High School Theater, located at 26255 Valencia Boulevard, Stevenson Ranch, California 91381, and public testimony was taken. Contents of the Final EIR The Final EIR is organized into three main volumes, as follows: Volume 1. Executive Summary, Complete Draft EIR, and MMRP. This volume consists of an Executive Summary, which includes a summary of the Proposed Project and of major findings and conclusions of the Draft EIR, followed by the complete Draft EIR, including revisions, and a visual supplement. This volume also includes the MMRP, which identifies Proposed Project Mitigation Measures by environmental issue and identifies the action required, mitigation timing, responsible party, and monitoring agency or party responsible for monitoring of each mitigation measure. Volume 2. Responses to Comments. This volume presents the comments provided by public agencies and interested parties during the public review periods for the Original Draft EIR and the Partially Recirculated Draft EIR. Written responses are provided for each significant environmental point raised during the public review periods. Written responses are also provided for significant environmental points received during oral testimony at the July 31, 2014, and December 15, 2016, Hearing Examiner meetings. Volume 3. Appendixes. This volume includes the complete EIR appendixes.

IV EN1129161114SCO CHAPTER 11 – AIR QUALITY

Table 11-11. Maximum Predicted 8-hour CO Concentrations Chiquita Canyon Landfill Final EIR Maximum Modeled Background CO Total 8-hour CO 8-hour CO Concentration Concentration Concentration Scenario (ppm) (ppm) (ppm) SR-126 and Wolcott Way Existing Conditions (2015) 0.14 1.15 1.29 2017 Without Proposed Project 0.07 1.15 1.22 2017 With Proposed Project 0.07 1.15 1.22 SR-126 and Commerce Center Drive Existing Conditions (2015) 0.28 1.15 1.43 2017 Without Proposed Project 0.21 1.15 1.36 2017 With Proposed Project 0.21 1.15 1.36 National and State Threshold 9 Notes: Existing background concentrations are the highest observed 8-hour CO concentrations from 2010 to 2012, the latest 3 years of data available. The maximum 8-hour CO concentration is calculated by multiplying the project-level 1-hour CO contribution by the 8-hour persistence factor (0.7) and adding the 8-hour CO background concentration.

Based on the modeled results above, the Proposed Project would not cause or significantly contribute to a modeled CO violation. Therefore, operation of the Proposed Project would have a less-than-significant impact for CO at offsite receptors and at hotspots near roadways. Project Design Measures Same as previously described under Impact AQ-4, and listed in Table 11-1. Impact AQ-7: Combined operation and construction would not expose sensitive receptors to substantial pollutant concentrations. Combined operation and construction impacts at sensitive receptors would be less than significant, based on the results of a health risk assessment. Impact Discussion. An HRA was conducted to evaluate potential human health risks associated with exposure of sensitive receptors to pollutant concentrations, in this case, project-related emissions of TACs. The risk categories evaluated include individual lifetime cancer risk, non-cancer health effects from chronic (long-term) exposure, and non-cancer health effects from acute (short-term) exposure. At the recommendation of SCAQMD staff, the HRA was performed following both the previous guidance outlined in the Air Toxics Hot Spots Program Risk Assessment Guidelines (Office of Environmental Health Hazard Assessment [OEHHA], 2003), and the latest guidance outlined in the Guidance Manual for Preparation of Health Risk Assessments (OEHHA, 2015). The evaluation of potential impacts and determination of significance for potential impacts in this chapter were based on the 2015 OEHHA guidance. Results obtained using the 2003 guidance are included for continuity with the Original Draft EIR. Tables 11-12 and 11-13 present the predicted cancer and non-cancer health risks associated with lifetime and workplace exposures to the combined operation and construction emissions estimated for the Proposed Project. Results obtained using the 2003 guidance are presented in Table 11-12, and results for the 2015 guidance are presented in Table 11-13.

11-36 FINAL EIR EN1129161114SCO CHAPTER 11 – AIR QUALITY

Table 11-12. Operation and Construction Emissions Risk Summary (2003 Methodology) Chiquita Canyon Landfill Final EIR Receptor Location Max Cancer Max HIC Max HIA MEIR 3.5 per million 0.049 0.64 MEIW 0.78 per million 0.056 0.91 Sensitive Receptor 0.49 per million 0.0039 0.45 SCAQMD Significance Threshold 10 in 1 million 1.0 1.0 Notes: MEIR = residential maximally exposed individual MEIW = worker maximally exposed individual

Table 11-13. Operation and Construction Emissions Risk Summary (2015 Methodology) Chiquita Canyon Landfill Final EIR Receptor Location Max Cancer Max HIC Max HIA MEIR 9.3 per million 0.049 0.64 MEIW 0.85 per million 0.056 0.91 Sensitive Receptor 1.2 per million 0.0039 0.44 SCAQMD Significance Threshold 10 in 1 million 1.0 1.0

The TAC emission rates used in the HRA analysis were divided into short-term (for acute risks) and long- term (for cancer and chronic risks) emission rates for modeling of potential exposure concentrations. The 2039 year was chosen for the short-term emissions analysis, because it represented the highest flare and fugitive LFG emissions. Long-term emissions were calculated using the highest 30-year average emissions. Using the 2003 OEHHA guidance, the incremental increase in lifetime cancer risk associated with exposure to combined construction and operations emissions at the location of the residential maximally exposed individual (MEIR) is predicted to be 3.5 in 1 million. The MEIR location would be approximately 250 meters northwest from the facility boundary. The maximum incremental increase in cancer risk predicted for worker exposures at the location of the workplace maximally exposed individual (MEIW) is predicted to be 0.78 in 1 million. The MEIW location would be approximately 220 meters from the facility’s northwest boundary. The maximum incremental increase in lifetime cancer risk predicted for the location of the nearest sensitive receptor is predicted to be 0.49 in 1 million. Sensitive receptor locations include schools, hospitals, convalescent homes, day-car centers, and other locations where children, chronically ill individuals or other sensitive persons could be exposed to TACs. The sensitive receptor location would be approximately 1,750 meters from the facility’s northeast boundary. The locations of the maximally exposed receptors for cancer risk and chronic impacts for construction and operation emissions are shown on Figure 11-4. Maximum impacts predicted for the MEIR, MEIW, and sensitive receptor locations using the 2003 OEHHA guidance would not exceed the SCAQMD cancer risk significance threshold of 10 in 1 million, under any of the scenarios. The cancer risk estimates discussed in the above paragraph were developed using the 2003 OEHHA guidance for determining incremental increases in lifetime cancer risk associated with human exposures to estimated emissions from the Proposed Project operation and construction. Per the 2003 OEHHA guidance, this study conservatively assumed that operation and construction emissions would occur simultaneously, 24 hours per day continuously for 70 years for residential exposures, and 8 hours per day, 5 days per week, for 30 years for workplace exposures.

EN1129161114SCO FINAL EIR 11-37 CHAPTER 11 – AIR QUALITY

OEHHA adopted a revised risk assessment methodology in 2015. Per the 2015 OEHHA guidance, it was conservatively assumed that operation and construction emissions would occur simultaneously, 24 hours per day continuously for 30 years for residential exposures, and 8 hours per day, 5 days per week, for 25 years for workplace exposures. Though exposure durations decreased, changes to the exposure pathway methodology in the 2015 OEHHA guidance have resulted in overall increases in predicted health risks. Using the 2015 OEHHA guidance, the incremental increase in lifetime cancer risk associated with exposure to combined construction and operations emissions at the location of the MEIR is predicted to be 9.3 in 1 million. The MEIR location would be approximately 250 meters northwest from the facility boundary. The maximum incremental increase in cancer risk predicted for worker exposures at the location of the MEIW is predicted to be 0.85 in 1 million. The MEIW location would be approximately 220 meters from the facility’s northwest boundary. The maximum incremental increase in lifetime cancer risk predicted for the location of the nearest sensitive receptor is predicted to be 1.2 in 1 million. The sensitive receptor location would be approximately 1,750 meters from the facility’s northeast boundary. The locations of the maximally exposed receptors using the 2015 guidance for cancer risk and chronic impacts for construction and operation emissions are shown on Figure 11-5. Maximum impacts predicted for the MEIR, MEIW, and sensitive receptor locations using the 2015 OEHHA guidance would not exceed the SCAQMD cancer risk significance threshold of 10 in 1 million, under any of the scenarios. The chronic and acute (HIC and HIA) non-carcinogenic impacts predicted for exposure to estimated Proposed Project emissions would be below the SCAQMD significance threshold of 1.0 for all receptors. As noted above, the incremental increase in lifetime cancer risk associated with exposure to combined construction and operation emissions at the location of the MEIR, calculated based on the 2015 OEHHA guidance, was predicted to be 9.3 in 1 million. Because the predicted cancer risk, per individual unit, was greater than 1 in 1 million, the cancer burden was calculated for each census block receptor. Cancer burden is defined as the estimated increase in the occurrence of cancer cases in a population resulting from exposure to carcinogenic air contaminants. Based on the cancer risk estimated using the 2015 OEHHA Guidance, the cancer burden was predicted to be 0.01 excess cancer cases, which is below the SCAQMD threshold of 0.5 excess cancer cases. Based on the cancer risk estimated using the 2003 OEHHA Guidance, the cancer burden was predicted to be 0.004, which is also below the SCAQMD threshold of 0.5 excess cancer cases. The HRA conducted to evaluate exposure of sensitive receptors to pollutant concentrations demonstrates that the predicted impacts would be less than significant. Project Design Measures Same as previously described under Impact AQ-4, and listed in Table 11-1. Impact AQ-8: Expanded landfill operation would not create objectionable odors affecting a substantial number of people. Operation impacts would be less than significant. Impact Discussion. The Proposed Project would introduce several changes at CCL that could result in an increased potential for odor impacts. First, the Proposed Project would include an increase in daily waste disposal tonnage, from 6,000 to a maximum of 12,000 tons per day. This would result in an increased potential for odors from the aerobic decomposition of incoming waste, due to additional loads and the increased size of the working face. CCL would continue to actively preempt odors through the landfill’s waste exclusion program and through best operating practices for sanitary landfill waste disposal. If odors occur, CCL would continue to aggressively manage such events, using methods such as applying odor neutralizing agents or strategically placing large fans on the landfill to disperse odors.

11-38 FINAL EIR EN1129161114SCO Cancer Risk Sensitive HIC Sensitive HIA Sensitive

Cancer Risk MEIW HIC MEIW

HIA MEIW

Project Boundary 0 500 1000 Meters Impact Location 1000 MEIR: residential maximally exposed individual MEIW: workplace maximally exposed individual HIC: chronic hazard index HIA: acute hazard index Figure 11.4.

2003 OEHHA Guidance Chiquita Canyon Landfill Master Plan Revision

EN1030151026SCO CCL_Figure_11.4_Max_Health_Impacts_Locs_2016.ai 1/17 Project Boundary 0 500 1000 Meters Impact Location

MEIR: residential maximally exposed individual MEIW: workplace maximally exposed individual HIC: chronic hazard index HIA: acute hazard index Figure 11.5.

2015 OEHHA Guidance Chiquita Canyon Landfill Master Plan Revision

EN1030151026SCO CCL_Figure_11-5_Max_Health_Impacts_Locs_11.2016_rev.ai

Attachment 2 (Appendix M to Final EIR)

Appendix M Public Health Evaluation

T E C H N I C A L MEMORANDUM Public Health Evaluation – Chiquita County Landfill

PREPARED BY: CH2M HILL

DATE: January 14, 2017

Introduction In comments on the Original Draft Environmental Impact Report (EIR) and Partially Recirculated Draft EIR, members of the public stated concerns regarding health impacts in the vicinity of the Chiquita Canyon Landfill (CCL) Master Plan Revision (Proposed Project) site. These concerns primarily include odors as a potential indicator of exposure, prevalence of asthma, increased risks of health effects such as cancer or respiratory disease, and potential contribution to existing environmental burdens. In addition to these concerns, commenters stated that expanding the landfill would increase the potential for odor impacts. Further, commenters expressed concerns regarding current environmental burdens in the community nearest to the Proposed Project site, and stated that potential emissions from the landfill operations and diesel emissions from truck travel would add to the existing environmental burdens experienced by the surrounding community. This technical memorandum presents a public health evaluation to respond to comments regarding the existing environmental burden experienced by persons living near CCL and potential health impacts associated with the Proposed Project. This public health evaluation is provided to supplement the health risk assessment, which has been prepared to address air toxics emissions as part of the air quality impacts analysis of the Proposed Project. The analysis contained in this technical memorandum addresses comments about possible disproportionate mortality and morbidity within the geographical area that includes the residential communities surrounding the Proposed Project site. This analysis is based on health statistics collected by the Los Angeles County Department of Public Health (LADPH), air toxics analyses conducted by the South Coast Air Quality Management District (SCAQMD), and an assessment of health impacts presented in the CalEnviroScreen 3.0 model developed by the California Environmental Protection Agency (CalEPA), Office of Environmental Health Hazard Assessment (OEHHA). Methodology The following methodologies were used in conducting this public health evaluation:  Evaluation of statistics describing the prevalence of asthma and selected cancers were obtained from LADPH for communities around the Proposed Project vicinity and compared with the prevalence of diseases found in populations located in other parts of Los Angeles County.  Evaluation of data presenting air toxics concentrations and risks in the South Coast Air Basin (SCAB), including in and around the Proposed Project site, were obtained from the SCAQMD. These data are presented in the Multiple Air Toxics Exposure Study (MATES IV) study. The magnitude of health risks from air toxics around the Proposed Project site was compared with populations elsewhere in the SCAB.  Evaluation of potential odor impacts and volatile organic compounds (VOCs), including a description of some of the factors related to the occurrence of odors associated with landfill operations, evaluation of the frequency of VOCs detected in landfill gas, along with a description of the types of health impacts potentially indicated by the presence of odors, particularly from exposure to hydrogen sulfide.

EN1129161114SCO 1 PUBLIC HEALTH EVALUATION – CHIQUITA COUNTY LANDFILL

 Evaluation of the potential exposures and health impacts that have been analyzed by CalEPA as part of the CalEnviroScreen 3.0 model. CalEnviroScreen 3.0 is a geographically-based environmental indicators modeling methodology that evaluates potential cumulative impacts to California communities as a function of pollution burden and population characteristics. Demographics and Site Setting CCL is located in the northwestern portion of unincorporated Los Angeles County approximately 3 miles west of the Interstate 5 (I-5) and State Route 126 (SR-126) junction. CCL is approximately 7 miles northwest of the City of Santa Clarita, 3.5 miles southwest of the community of Castaic, and approximately 0.5 miles southwest of Val Verde, an unincorporated community in Los Angeles county and the nearest existing community to CCL. The population in the vicinity of the Proposed Project site based on the 2010 Census is approximately 3,110 persons. The population consists of 55 percent Latino, 37 percent white, and 8 percent other ethnic groups (African-American, Asian, Pacific Islander, or Native American/Alaskan Native) (CalEPA, 2014). Much of the area surrounding CCL consists of undeveloped open space. Surrounding land uses include primarily open lands to the north and rural residential development to the west and northwest along Chiquita Canyon Road and in the Val Verde area. The closest of these residential dwellings is located approximately 500 feet from the northwest site boundary and 1,200 feet from the landfill footprint, with intervening topography which prevents residential view of the operating landfill from these locations. The U.S. Postal Service has a general mail facility adjacent to the eastern edge of the landfill property boundary. The property immediately west and south of the landfill is owned by the Newhall Land and Farming Company and is currently either vacant or used for agricultural activities. Limited suburban residential areas are located further to the northeast, and industrial/commercial uses are also located further to the northeast, east and southeast. Oil extraction fields and associated storage areas are located less than 1 mile from the landfill to the west and south. Valencia Travel Village, a short- and long-term recreational vehicle resort, is located approximately one mile east of the landfill on the south side of SR-126. Evaluation of Asthma Prevalence Data collected and published by the LADPH (Health Atlas of California, 2015; LADPH, 2013, 2015a, 2015b) were reviewed to identify the prevalence of asthma in the Proposed Project vicinity and found to be similar when compared with the prevalence of asthma in populations located in other parts of Los Angeles County. Asthma is one of the most common childhood diseases in the United States. It is an inflammation of the respiratory tract that can obstruct air flow, producing symptoms such as wheezing and shortness of breath. There are many factors that can cause asthma, including heredity (i.e., genetic predisposition), allergies to common items, socioeconomic factors and environmental factors including air pollutants (Mannino et al., 1998; NIEHS, 2012). National statistics indicated that asthma prevalence increased in the 1990s, despite numerous advancements in the diagnosis and treatment of asthma. Reasons suggested for this included increased self-reporting of cases by patients, poor or inappropriate use of medications, poor access to medical care in inner-city populations, and increased exposure to environmental allergens or air pollutants. Surveillance information indicated an increase in self-reported asthma prevalence rates and asthma death rates in recent years both nationally and regionally. Asthma hospitalization rates increased in some regions and decreased in others (Mannino et al., 1998; AAAAI, 1999). The asthma prevalence has increased more slowly in more recent years, with some hospitalization rates remaining stable or declining in the 2000s (CDC, 2012).

2 EN1129161114SCO PUBLIC HEALTH EVALUATION – CHIQUITA COUNTY LANDFILL The incidence of asthma in Los Angeles County is measured from statistics collected by the LADPH Health Assessment Unit. Asthma incidence in Los Angeles County is tabulated by Service Planning Areas (SPA) and within the SPAs’ Health Districts. The SPA boundaries are shown in Figure 1. The Proposed Project location is within the northern portion of SPA 2, San Fernando Valley. The Proposed Project location, as obtained from the LADPH online mapping tool, Health Viewer (LADPH, 2015a), is shown in Figure 2. The racial/ethnic makeup of the populations in the SPAs are shown in Table 1. Compared with the SPA 2, the communities around the Proposed Project site have slightly higher proportions of Latinos and lower proportions of Whites, with a much lower proportion of Asian/Pacific Islanders. Asthma incidence statistics for Los Angeles County and individual SPAs were obtained from the LADPH online data query tool, LA HealthDataNow! (LADPH, 2015b). Asthma incidence is presented for 2005, the most recent data showing asthma prevalence by both race/ethnicity and SPA (Table 2). The asthma prevalence in SPA 2, where the Proposed Project site is located, is either similar to (i.e. smaller than a factor of twofold) or less than the prevalence observed in most other SPAs. Comparison of the trends in different years is shown in Figure 3. The trend in prevalence of asthma in SPA 2 has been consistent in the years between 2002 and 2011, and appears to be similar to trends observed for several other SPAs (Figure 3). Evaluation of Cancer Mortality Data collected and published by the LADPH were reviewed to identify the trends in cancer mortality for selected cancer in the Proposed Project vicinity and found that to be similar when compared with the trends in populations located in other parts of Los Angeles County. Trends were examined in selected cancers (lung cancer and leukemia) for all individuals and Latinos in Los Angeles County and SPA 2 (Figure 4). Lung cancer and leukemia were selected because these represent adverse health outcomes associated with key air toxics associated with Proposed Project emissions, specifically diesel particulate matter and benzene. Trends of leukemia deaths in SPA 2 are more variable than trends for Los Angeles County, but comparison of the overall trends shows little difference between these two areas. Trends of lung cancer deaths in SPA 2 are similar to or lower than trends observed for Los Angeles County. Odors and Volatile Organic Compounds Landfill gas is formed from microorganisms within the landfill. Methane and carbon dioxide are the primary constituents of landfill gas. Typically, landfill gas also contains VOCs. Nearly 180 different VOCs reportedly have been detected at varying concentrations in landfill gas (EPA, 2008). A subset of these VOCs which have been historically detected the most frequently in landfill gas testing include: 1,1,1-Trichloroethane Toluene 1,1-Dichloroethane Xylenes 1,1-Dichloroethene Chloroform 1,2-Dichloroethane Vinyl chloride Benzene Tetrachloroethylene Carbon Tetrachloride Trichloroethylene

The above-listed VOCs have been evaluated as part of the health risk assessment for the Proposed Project site.

EN1129161114SCO 3 PUBLIC HEALTH EVALUATION – CHIQUITA COUNTY LANDFILL Sulfides are a class of compounds that typically give landfill gas a rotten egg smell. Sulfides include hydrogen sulfide and several reduced sulfide compounds, including: Carbon disulfide Diethyl sulfide Carbonyl sulfide Ethyl mercaptan Propyl mercaptan Methyl mercaptan Dimethyl disulfide

Hydrogen sulfide is one of the most common sulfides responsible for landfill odors. Some individuals can smell it at concentrations as low as 0.5 part per billion in air (ATSDR, 2004), though there is considerable variability in abilities to detect odors. Landfill gases can include odor-producing gases such ammonia and hydrogen sulfide. The perception of odors of these gases can be an indication of potential landfill gas migration. Odor perception varies widely among individuals, and is affected by numerous factors such as ethnicity, gender, age, presence of certain medical conditions, alcohol or tobacco use, and odor fatigue based on the frequency and concentration of exposure to odor-producing substances. Psychosocial influences also affect the intensity of perceived odors and associated symptoms. Since the concept of odor is intrinsically and cognitively linked to illness, detection of odors potentially results in a more significant reporting of health-related symptoms (Greenberg, et al., 2013). Attempts to verify intensity of exposure to chemical substances in air with perceived odors generally is considered to be of limited reliability for exposure assessment (Greenberg et al., 2013; Ruth, 1986). Landfill gases can move from a landfill through soil into outdoor air as well as the indoor air of nearby buildings. Landfill gases in outdoor air can enter a building through windows, doors, and ventilation systems. In soil, landfill gases can migrate and enter a building through cracks in the basement floors and walls, utility entry points (e.g., where underground water or electrical lines enter a building), sump pump holes or floor drains. This is called soil vapor intrusion. Once they enter a building, landfill gases may collect in areas of poor ventilation, such as basements, crawlspaces, and utility tunnels. The primary hazard from landfill gas is methane which, at high enough levels in air, poses a health hazard by displacing oxygen in addition to a fire/explosion hazard. Landfills are required to maintain landfill gas control so that flammable and explosive methane in landfill gas in soil at the landfill boundary remains below the lower explosive limit of 5 percent. The allowable limit of methane in air (indoor and outdoor) is more stringent – typically 25 percent of the lower explosive limit or 1.25 percent. Uncontrolled migration of landfill gases is undesired by posing potential health and explosion hazards. Hydrogen sulfide and other landfill gas emissions are minimized and controlled at landfills through proper operating and maintenance practices (MADEP, 2007). Currently, CCL also employs a comprehensive approach to controlling odors by employing multiple odor control measures. The utilization of landfill gas collection and control systems, daily cover, water trucks, odor neutralizers, and good housekeeping practices, when applied in concert, can be effective in reducing the creation as well as the transport of offensive odors. CCL also utilizes portable wind fans that can be moved around the landfill boundaries and ridge line based on the immediate wind conditions, supplementing the air flow to dissipate odors. Occasionally, District Inspectors will visit the landfill when responding to odor complaints. Inspectors have recorded actions used by CCL to mitigate the odors at the time of their visit, including spraying odor neutralizers, utilizing portable wind fans, and delaying future deliveries of alternative daily cover from the supplier to allow for the wind patterns to change, reducing impacts to the neighborhood. The SCAQMD has conditions in the CCL Title V operating permit requiring the landfill to stop operations if confirmed odors cannot be mitigated. The landfill can be penalized for failing to cease operations or mitigate odors as required in the operating permit. Once the odors are mitigated, the landfill may

4 EN1129161114SCO PUBLIC HEALTH EVALUATION – CHIQUITA COUNTY LANDFILL resume operations. Additionally, CCL has an Odor Hotline that the public can call to report odor complaints, allowing faster, more direct action to be taken to resolve the complaint. Evaluation of Air Toxics Estimated cancer risks and noncancer health risks associated with toxic air pollutants in the SCAB were characterized in the MATES IV study (SCAQMD, 2015). The MATES IV study was based on the results of air monitoring, emissions inventories of toxic air contaminants and modeling to estimate cancer risks across the SCAB. The air toxics risks based on air monitoring data from fixed monitoring stations ranged from 320 to 480 per million. This risk refers to a conservative upper-bound estimate of the expected number of additional cancers in a population of one million individuals if they were exposed to these levels over a 70-year lifetime. About 90 percent of the risk is attributed to emissions associated with mobile sources, with the remainder attributed to toxics emitted from stationary sources, including industrial operations such as refineries, metal processing facilities and ports, as well as smaller business such as gas stations and chrome platers. The largest contributor to cancer risks was diesel particulate matter, followed by benzene, 1,3-butadiene and aldehydes (formaldehyde and acetaldehyde). Modeling was used to simulate toxic air pollutant concentrations in air at on a 2-kilometer by 2-kilometer grid throughout the SCAB. Risk-based maps have been developed by the SCAQMD based on these modeling results. While these maps do not represent actual health outcomes associated with potential exposure to toxic air pollutants, they provide an indication of the differences in estimated cancer risks at different locations within the SCAB. Based on these risk maps (SCAQMD, 2015), cancer risks from existing toxic air pollutant emissions range from 300 to 400 in 1 million. The highest cancer risk estimated from Proposed Project emissions in all of the communities, primarily from diesel particulate matter and benzene emissions is 9.3 in 1 million (Table 11-13 in the Partially Recirculated Draft EIR). The cumulative risk from existing risks combined with the maximum risk from project emissions would only be 2-3 percent greater than cancer risks based on existing air toxics emissions. Since the project risk is based on the maximum exposed individual location, risks are lower at all other locations around the Proposed Project. It is unlikely that emissions from the Proposed Project would result in a cumulative increase in cancer risks in the surrounding residential communities. Health Studies of Municipal Landfills Management of solid waste (mainly landfills and incineration) releases a number of toxic substances, most in small quantities and at extremely low levels. A systematic review has been performed of the available epidemiological literature on the health effects in the vicinity of landfills and incinerators and among workers at waste processing plants to derive usable excess risk estimates for health impact assessment (Porta, et al., 2009). Porta et al., 2009, concluded that in most cases the overall evidence was inadequate to establish a relationship between a specific waste process and health effects. The evidence from occupational studies was not sufficient to make an overall assessment. For community studies, at least for some processes, there was limited evidence of a causal relationship between congenital anomalies and low birth weight, and proximity to municipal landfills. However, in all cases, the relative risks for adverse effects in populations near municipal solid waste landfills were less than a factor of 2.0. Relative risks less than 2.0 represent a weak association, which might occur simply by chance, bias or confounding effects (Boffetta, 2010; Monson, 1980).

EN1129161114SCO 5 PUBLIC HEALTH EVALUATION – CHIQUITA COUNTY LANDFILL CalEnviroScreen 3.0 CalEnviroScreen 3.0 is a statewide analysis conducted by CalEPA, OEHHA that:

“. . . identifies communities in California most burdened by pollution from multiple sources and most vulnerable to its effects, taking into account their socioeconomic characteristics and underlying health status.”

CalEnviroScreen 3.0 is a geographically-based environmental indicators modeling methodology. The model calculates a unitless score representing cumulative impacts as a function of two components: 1) pollution burden, and 2) population characteristics. Environmental indicators that reflect air quality, drinking water quality, proximity to hazardous waste facilities, etc. were assigned numerical weights by OEHHA staff, and analyzed in a numerical scoring system to weight and sum each set of indicators within pollution burden and population characteristics components. The overall result is a unitless score described as: “. . . a CalEnviroScreen score for a given place relative to other places in the state. . . “. The environmental indicators are constructed with available data obtained from agency databases. The detailed description of the indicators methodology and supporting data sets is provided in the CalEnviroScreen 3.0 report (CalEPA, 2017). The CalEnviroScreen 3.0 scores for the census tract containing the Proposed Project site and the surrounding census tracts are shown in Figure 5. Based on the indicators evaluated in CalEnviroScreen, the census tract containing the Proposed Project site ranks in the 66th to 70th percentile of California census tracts for cumulative impacts (Table 3). This is similar to the calculated impacts for census tracts located to the west. Pollutant burdens around the Proposed Project site are similar to burdens calculated for census tracts located to the south and east of the Proposed Project site (Figure 5). Disadvantaged communities in California are specifically targeted for investments from a quarter of the proceeds from the Greenhouse Gas Reduction Fund. Disadvantaged communities included areas disproportionately affected by environmental pollution and other hazards that can lead to negative public health effects, exposure, or environmental degradation, and areas with concentrations of people that are of low income, high unemployment, low levels of home ownership, high rent burden, sensitive populations or low levels of educational attainment. Senate Bill 535, passed in 2012, gave CalEPA responsibility for identifying those communities. Using CalEnviroScreen, CalEPA published the list of disadvantaged communities under Senate Bill 535. Census tracts with CalEnviroScreen scores in the 75th percentile or higher or in other words, the top 25 percent of census tracts in the state in terms of combined pollutant impacts and population characteristics, were considered disadvantaged. The selection of the top 25 percent was rooted in a technical basis that a “threshold in the range of 20 to 25 percent would be consistent with other legislation and studies regarding disadvantaged communities,” (CalEPA, 2014). The CES 3.0 score for the census tract containing the Proposed Project site and the Val Verde community fall within the 66th to 70th percentile of census tracts across the state which falls below a 75th percentile threshold used to identify disadvantaged communities. Discussion and Conclusions Potential public health impacts raised as concerns by members of communities around the Proposed Project included concerns of elevated rates of asthma rates and other diseases, potential exposures to emissions based on reportedly detected odors, potentially increased cumulative health risks resulting from superimposing project impacts (as calculated in the health risk assessment) on existing levels of pollutant exposures. The analysis of these concerns provides the following results:

6 EN1129161114SCO PUBLIC HEALTH EVALUATION – CHIQUITA COUNTY LANDFILL

 The prevalence of asthma in communities around the Proposed Project site falls within the range observed for SPAs designated by the LADPH. Asthma prevalence in SPA 2 (where the Proposed Project is located) is indistinguishable from the asthma prevalence elsewhere in Los Angeles County.  The cancer mortality rates for selected cancers examined (lung cancer and leukemia) in SPA 2 are not distinguishable from mortalities estimated for Los Angeles County.  Maximum air toxics impacts to human health projected for the Proposed Project site are a very small fraction (approximately 2 to 3 percent) of the existing air toxics impacts projected for the SCAB. It is unlikely that cumulative impacts from Proposed Project and existing air toxics risks would be different from the existing risks.  VOCs most frequently associated with emissions from a landfill were assessed as part of the health risk assessment. Detection of odors is not considered a reliable surrogate for VOC exposures, but is considered an indicator of potential landfill gas migration. Hydrogen sulfide and other landfill gas emissions are minimized and controlled at landfills through proper operating and maintenance practices.  Epidemiological studies are limited in their ability to detect low-level health risks around municipal landfills. However, the health outcomes observed from the existing studies are not specific for emissions from municipal landfill sites and the relative risks for most of the elevated cases were low (less than 2.0). Low relative risks in epidemiological studies represent weak associations between landfills and health effects, which may easily be due to chance, bias or confounding effects.  While cumulative impacts in the census tract containing the Proposed Project site, as calculated using CalEnviroScreen 3.0, are higher compared with adjoining communities to the north, south and east, these impacts are similar to adjoining communities to the west. The census tract containing the Proposed Project site would not be considered a disadvantaged community based on criteria developed by CalEPA. References Agency for Toxics Substances and Disease Registry (ATSDR). 2004. Draft Toxicological Profile for Hydrogen Sulfide. Atlanta, GA. American Academy of Allergy, Asthma and Immunology (AAAAI). 1999. Environmental allergen avoidance in allergic asthma. Ad Hoc Working Group on Environmental Allergens and Asthma. https://www.aaaai.org/Aaaai/media/MediaLibrary/PDF%20Documents/Practice%20and%20Parameters /Environmental-allergen-avoidance-1999.pdf Boffetta, P. 2010. “Causation in the presence of weak associations.” Critical Reviews in Food Science and Nutrition. 50:13-16. California Environmental Protection Agency (CalEPA). 2014. Designation of Disadvantaged Communities Pursuant to Senate Bill 535 (De Leon). October 2014. http://www.calepa.ca.gov/EnvJustice/GHGInvest/ California Environmental Protection Agency (CalEPA). 2017. Update to the California Communities Environmental Health Screening Tool, CalEnviroScreen 3.0. January. http://oehha.ca.gov/calenviroscreen/report/calenviroscreen-30 Greenberg, M.I., J.A. Curtis and D. Vearrier. 2013. The perception of odor is not a surrogate marker for chemical exposure: a review of factors influencing human odor perception. Clinical Toxicology. 51(2): 70-76. http://www.ncbi.nlm.nih.gov/pubmed/23387344 Health Care Atlas of California. 2015. Census Tract - Details, Tract 9201.06 in Los Angeles County & MSSA #76.2. http://gis.oshpd.ca.gov/atlas/places/tract/06037920106. Accessed 4/5/2015.

EN1129161114SCO 7 PUBLIC HEALTH EVALUATION – CHIQUITA COUNTY LANDFILL Los Angeles County Department of Public Health (LADPH). 2013. Key Indicators of Health. http://publichealth.lacounty.gov/ha/docs/kir_2013_finals.pdf Los Angeles County Department of Public Health (LADPH). 2015a. Health Viewer. http://publichealth.lacounty.gov/epi/HealthViewer.htm. Accessed April 1, 2015. Los Angeles County Department of Public Health (LADPH). 2015b. LA HealthDataNow! https://dqs.publichealth.lacounty.gov/ Mannino, D.M., Homa, D.M. Pertowski, C.A. et al. 1998. Surveillance for Asthma -- United States, 1960 1995. Morbidity and Mortality Weekly Report, April 24, 1998 / 47(SS-1);1-28. http://www.cdc.gov/epo/mmwr/preview/mmwrhtml/00052262.htm. U.S. Centers for Disease Control. Massachusetts Department of Environmental Protection (MADEP). 2007. Control of Odorous Gas at Massachusetts Landfills, in Support of 310 CMR 19.000, Solid Waste Management Regulations. Monson, R.R. 1980. Occupational Epidemiology, 2nd Edition. CRC Press. National Institute for Environmental Health Sciences (NIEHS). 2012. Asthma and its Environmental Triggers. http://www.niehs.nih.gov/health/assets/docs_a_e/asthma_and_its_environmental_triggers_508.pdf Porta, Daniela, S. Milani, A.I. Lazzarino, C.A. Perucci and F. Forastiere. 2009. Systematic review of epidemiological studies on health effects associated with management of solid waste. Environmental Health. 8:60. https://ehjournal.biomedcentral.com/articles/10.1186/1476-069X-8-60 Ruth, J.H. 1986. Odor thresholds and irritation levels of several chemical substances: A Review. American Industrial Hygiene Association Journal. 47(3): A142-A151. South Coast Air Quality Management District (SCAQMD). 2015. Multiple Air Toxics Exposure Study IV (MATES IV). May. http://www.aqmd.gov/home/library/air-quality-data-studies/health-studies/mates-iv U.S. Centers for Disease Control (CDC). 2012. Trends in Asthma Prevalence, Health Care Use, and Mortality in the United States, 2001-2012. NCHS Data Brief No. 94. http://www.cdc.gov/nchs/data/databriefs/db94.htm

U.S. Environmental Protection Agency (EPA). 2008. Background Information Document for Updating AP42 Section 2.4 for Estimating Emissions from Municipal Solid Waste Landfills. EPA/600/R-08-116.

8 EN1129161114SCO Table 1. Racial/Ethnic Makeup of Populations in Los Angeles County and Service Planning Agencies, 2013 Chiquita Canyon Landfill Final EIR SPA 1 ‐ Los Angeles Antelope SPA 2 ‐ SPA 3 ‐ SPA 4 ‐ SPA ‐ 5 SPA 6 ‐ SPA 7 ‐ SPA 8 ‐ Race/Ethnicity County Valley San Fernando San Gabriel Metro West South East South Bay Latino 48.1% 44.3% 39.1% 46.4% 52.2% 15.7% 67.7% 73.5% 39.5% White 28.9% 35.9% 45.9% 21.6% 24.9% 65.4% 2.0% 14.3% 29.7% African American 8.5% 15.3% 3.4% 3.7% 4.7% 5.8% 28.5% 2.9% 14.8% Asian/Pacific Islander 14.3% 4.0% 11.4% 28.2% 18.0% 13.0% 1.6% 9.0% 15.8% American Indian/ 0.2% 0.4% 0.2% 0.2% 0.2% 0.2% 0.1% 0.2% 0.2% Alaskan Native Source: Los Angeles County Department of Public Health. 2013. Key Indicators of Health . http://publichealth.lacounty.gov/ha/docs/kir_2013_finals.pdf

Table 2. Prevalence of Current Asthma in Adults and Children In Los Angeles County, 2005 Chiquita Canyon Landfill Final EIR Adults (18+ years old) Children (0‐17 years old) Area All Latino All Latino SPA 1 ‐ Antelope Valley 11.4% 7.5% 15.8% 7.2% SPA 2 ‐ San Fernando 6.6% 5.1% 7.9% 7.7% SPA 3 ‐ San Gabriel 5.8% 4.9% 8.3% 8.9% SPA 4 ‐ Metro 6.2% 6.0% 6.7% 5.8% SPA 5 ‐ West 7.6% no data 4.9% 6.4% SPA 6 ‐ South 7.2% 3.0% 9.0% 4.7% SPA 7 ‐ East 5.1% 4.3% 8.8% 7.5% SPA 8 ‐ South Bay 6.7% 5.6% 11.0% 9.0%

Table 3. Summary of CalEnviroScreen 3.0 Analysis Chiquita Canyon Landfill Final EIR Pollution Population Total California CalEnviroScreen CalEnviroScreen CalEnviroScreen Burden Characteristics Census Tract Population County City 3.0 Score 3.0 Percentile 3.0 Percentile Percentiles Percentiles 6037920106 3,110 Los Angeles Castaic (Proposed Project) 33.9 66.6 66‐70 65.9 58.7 6111000200 2,822 Ventura Fillmore (West) 33.2 65.2 66‐70 44.7 72.7 6037920326 6,840 Los Angeles Stevenson Ranch (South) 19.6 37.4 36‐40 60.4 24.8 6037920116 5,181 Los Angeles Castaic (Northeast) 14.9 24.8 21‐25 24.3 29.2 6037920339 7,377 Los Angeles Valencia (Southeast) 13.7 21.8 21‐25 79.3 8.5 6037920104 2,798 Los Angeles Castaic (North) 9.8 12.8 15‐Nov 16.7 16.0

EN1129161114SCO Lancaster

Lake Quartz Los Angeles 1 Hill ,! Palmdale

Littlerock

Val Verde ,!2 Santa Clarita

San Fernando

Burbank ,!3 Glendale Los Angeles

Calabasas Pasadena Azusa Los Angeles West 4 Arcadia Hollywood,! San Dimas Beverly Los Alhambra Malibu Hills Angeles El Monte Pomona Santa Los Monica Angeles Montebello Diamond Bar Vernon Whittier 5 6 ,! ,! Downey Lynwood ,!7 Hawthorne Compton Norwalk Redondo Cerritos Beach Carson Torrance,!8 Rolling Long Beach Hills !1 Antelope Valley !2 San Fernando Valley !3 San Gabriel Valley !4 Metro !5 West !6 South FIGURE 1 7 East Service Planning Areas of the ! Los Angeles County Department of Health South Bay Chiquita Canyon Landfill !8 Includes Catalina Island Master Plan Revision

\\galt\proj\chiquita\MapFiles\2016\Service_Planning_Areas.mxd SPA 1

SPA 2

Approximate Project Area

SPA 2 SPA 3

SPA 4 SPA 5

SPA 6 SPA 7

Pacific Ocean SPA 8

LEGEND

Service Planning Area Boundary FIGURE 2 Approximate Project Location Approximate Project Location in $ LADPH Service Planning Areas Chiquita Canyon Landfill 0 6 12 Master Plan Revision Miles

\\galt\proj\chiquita\MapFiles\2016\Service_Planning_Areas_CCL.mxd 12.0%

10.0%

8.0%

6.0% 2002 2005 4.0%

2.0%

0.0% SPA1 SPA2 SPA3 SPA4 SPA5 SPA6 SPA7 SPA8

Prevalence of Current Asthma in Los Angeles County in Adults, 2002 and 2005

18.0% 16.0% 14.0% 12.0% 2002 10.0% 2005 8.0% 2007 6.0% 2011 4.0% 2.0% FIGURE 3 0.0% Trends of Prevalence of Current SPA1 SPA2 SPA3 SPA4 SPA5 SPA6 SPA7 SPA8 Asthma in Adults and Children Chiquita Canyon Landfill Prevalence of Current Asthma in Los Angeles County in Children, 2002 to 2011 Master Plan Revision 45 9 40 8 35 7 30 6 25 5 20 LA 4 LA 15 SPA2 3 SPA2 Deaths per 100,000 10 Deaths per 100,000 2 5 1 0 0

Age-Adjusted Mortality of All Individuals from Lung Cancer Age-Adjusted Mortality of All Individuals from Leukemia

25 7 6 20 5 15 4 LA LA 10 3 SPA2 SPA2 2 Deaths per 100,000 5 Deaths per 100,000 1 0 0

Age-Adjusted Mortality of Latino Individuals from Lung Cancer Age-Adjusted Mortality of Latino Individuals from Leukemia FIGURE 4 Trends of Cancer Mortality (Lung Cancer and Leukemia) in Los Angeles County and SPA 2 Chiquita Canyon Landfill Master Plan Revision

Attachment 3 (Appendix L to Final EIR)

Appendix L Housing Price Impact Study

Memorandum

DATE: February 2, 2017

TO: Brenda Eells

COMPANY: CH2M Hill

FROM: Taylor Mammen and Ben Maslan

SUBJECT: Chiquita Canyon Landfill Housing Price Impact Study

RCLCO was retained to evaluate residential pricing trends in Val Verde, a census-designated place in Los Angeles County, and similar surrounding areas of the Chiquita Canyon Landfill (“Landfill”) as compared to Los Angeles. In particular, RCLCO was retained to determine if the Landfill impacted the rate of housing price appreciation in Val Verde and the surrounding residential areas to the Landfill relative to the broader Los Angeles MSA.

We conclude that there is no evidence that the Landfill had any impact on the change in housing prices in Val Verde or areas of similar geographic proximity to the Landfill.

Methodology We have calculated the annual rate of change in housing prices based on the average price per square foot for each home sold in Val Verde and other housing units in the 91384 zip code located within five miles of the Landfill (the “Subject Areas”).1 Sales records used in the analysis include only single-family, detached residential units located in the Subject Areas during the time periods specified below.2

The annual rates of change in the average price per square foot for the Subject Areas were then compared to the annual changes in the Federal Housing Finance Administration Home Price Index (“FHFA HPI”) and S&P/Case-Shiller Home Price Index (“Case Shiller HPI”) for the Los Angeles MSA. The FHFA HPI uses the repeat-sales method, which compares sale prices of the same single-family, detached properties over time. The FHFA HPI is calculated based on mortgages that have been purchased or securitized by Fannie Mae or Freddie Mac, and thus includes both refinances as well as sales.3 The Case-Shiller HPI also uses the repeat-sales method; however, does not include mortgage refinances.4

Both indices only include transactions on single-family properties; thus, we have limited our analysis to detached single-family properties and excluded transaction on condominiums, townhomes, cooperatives, multi-unit properties, and planned unit developments. In addition, because the FHFA HPI is based only on transactions involving conforming, conventional mortgages purchased or securitized by Fannie Mae or

1 Five miles is the approximate maximum distance from the Landfill to homes located within Val Verde. 2 Sales records were pulled from Real Quest, which obtains its data from the county assessor. Records that appeared to be incomplete or inaccurate (e.g., the order of magnitude in prices appeared unrealistic) were omitted to ensure data integrity. 3 Federal Housing Finance Agency Housing Price Index Frequently Asked Questions, August, 26, 2014. 4 S&P/Case-Shiller Home Price Indices Methodology, February 2015.

Robert Charles Lesser & Co. 233 Wilshire Blvd., Suite 370, Santa Monica, CA 90401 Tel: (310) 914-1800 Fax: (310) 914-1810

Freddie Mac,5 we have included only homes that would qualify for a conforming mortgage assuming an 80% loan-to-value (“LTV”) ratio when comparing Subject Area price changes to the LA FHFA HPI.6

We examined changes in house prices over two time periods: from 1997 to 1999, the three years immediately subsequent to the last expansion of the Landfill; and the most recent ten years (2005 to 2014).

Results Our analysis indicates that the Landfill has not impacted the rate of change in home prices in the Subject Areas, and that there is no clear relationship between the Landfill and changes in home prices in its surrounding residential areas. Indeed, depending on the time period selected, home prices in the Subject Areas either increased at a faster rate or lagged home price changes in the Los Angeles MSA, as shown in the accompanying Exhibits.

From 1997 to 1999, the three-year period immediately subsequent to the last expansion of the Landfill, home prices in the Subject Areas increased at a faster rate than home prices in Los Angeles County. In fact, home prices in Val Verde outpaced the LA FHFA HPI by 29.6% and the LA Case-Shiller HPI by 21.4% over this three-year period. While sales volumes were low in Val Verde (primarily due to its small size), sales volumes were much larger within five miles of the Landfill in 91384 with similar results. Specifically, home prices within five miles of the Landfill in 91384 outpaced the LA FHFA HPI by 16.1% and the LA Case-Shiller HPI by 7.1% over the three-year period. Similarly, from 2010 to 2014, home prices in Val Verde outpaced the LA FHFA HPI by 17.8% and the LA Case-Shiller HPI by 4.4%.7 Over the same time period, home prices within five miles of the Landfill in 91384 displayed mixed results, and outpaced the LA FHFA HPI by 8.7% while declining relative to the LA Case-Shiller HPI by -4.7%.

From 2005 to 2009, however, home prices in Val Verde declined at a faster rate than the broader Los Angeles MSA as measured by the LA FHFA HPI by -30.4% and the LA Case-Shiller HPI by -14.4%. Home prices within five miles of the Landfill in 91384 declined by an incremental -19.2% over the FHFA HPI and by -0.3% over the Case-Shiller HPI.

Conclusion Based on the high variance and inconsistency in the rate of change between home prices in the Subject Areas and the Los Angeles home price indices, there is no basis to conclude that the Landfill has impacted surrounding area home price appreciation.

5 A conforming mortgage is equal to or less than the dollar amount established by the conforming loan limit set by the Office of Federal Housing Enterprise Oversight and meets the funding criteria of Freddie Mac and Fannie Mae. Los Angeles County is considered a “high-cost area,” and thus has a conforming loan limit of $625,000 as of 2015, higher than the national norm of $417,000. Conventional mortgages are those that are neither insured nor guaranteed by a federal government entity. 6 An 80% LTV (i.e., a 20% down payment), has historically been the maximum LTV required by conventional lenders and the GSEs to fund a loan. 7 We note that sales volume declined in Val Verde in 2014 relative to prior years. A substantial portion of this decline cannot be attributable to a decline in housing demand as a result of the public release of the environmental impact report (“EIR”) in August 2014, as the decline in sales volume occurred prior to the EIR was released. For example, the average monthly year-over-year decline in sales volumes for Q1 2014 (January 2014 to March 2014) was 88.9%, substantially greater than the average monthly year-over-year decline for Q4 2014 (October 2014 to December 2014) of 50.0%. Moreover, a decline in demand would have resulted in a decline in price, as sellers would have had to lower asking prices in response to the downward shift in demand. This, however, is not the case, as prices in Val Verde actually increased by 34.7% in 2014 year-over-year, compared to 12.1% for the LA FHFA HPI and 5.5% for the LA Case-Shiller HPI.

2 February 2, 2017 | L1-13484.01

General Limiting Conditions

Reasonable efforts have been made to ensure that the data contained in this study reflect accurate and timely information and are believed to be reliable. This study is based on estimates, assumptions, and other information developed by RCLCO from its independent research effort, general knowledge of the industry, and consultations with the client and its representatives. No responsibility is assumed for inaccuracies in reporting by the client, its agent, and representatives or in any other data source used in preparing or presenting this study. This report is based on information that to our knowledge was current as of the date of this report, and RCLCO has not undertaken any update of its research effort since such date.

Our report may contain prospective financial information, estimates, or opinions that represent our view of reasonable expectations at a particular time, but such information, estimates, or opinions are not offered as predictions or assurances that a particular level of income or profit will be achieved, that particular events will occur, or that a particular price will be offered or accepted. Actual results achieved during the period covered by our prospective financial analysis may vary from those described in our report, and the variations may be material. Therefore, no warranty or representation is made by RCLCO that any of the projected values or results contained in this study will be achieved.

Possession of this study does not carry with it the right of publication thereof or to use the name of "Robert Charles Lesser & Co." or "RCLCO" in any manner without first obtaining the prior written consent of RCLCO. No abstracting, excerpting, or summarization of this study may be made without first obtaining the prior written consent of RCLCO. This report is not to be used in conjunction with any public or private offering of securities or other similar purpose where it may be relied upon to any degree by any person other than the client without first obtaining the prior written consent of RCLCO. This study may not be used for any purpose other than that for which it is prepared or for which prior written consent has first been obtained from RCLCO.

3 February 2, 2017 | L1-13484.01

Attachment 4 (LA County Certification of Final EIR)

~~of~g~,~ COUNTY OF LOS ANGELES ° ~'~~ OFFICE OF THE COUNTY COUNSEL + ~f 648 KENNETH EIAHN HALL OF ADMINISTRATION x * ~ ! 500 WEST TEMPLE STREET ~~ltFa0.M~ LOS ANGELES, CA LIF02NIA 90012-2713 TELEPHONE (213)787-0688

MARY C. WICKHAM FACSIMILE c2~3~ b13-a~s~ County Counsel July 25, 2017 TDB

(213)633-0901 The Honorable Board of Supervisors County of Los Angeles 383 Kenneth Hahn Hall of Administration Agenda No. S-1 500 West Temple Street 06/27/17 Los Angeles, California 90012

Re: PROJECT NO. R2004-00559-(5) CONDITIONAL USE PERMIT NO. 2004-00042-(5) OAK TREE PERMIT NO. 2015-00007-(5) FIFTH SUPERVISORIAL DISTRICT/THREE-VOTE MATTER

Dear Supervisors:

Your Board previously conducted aduly-noticed public hearing regarding four appeals of Regional Planning Commission's approval of the above-referenced entitlements, which authorized the continued operation and expansion of a Class III Landfill, located at 29201 Henry Mayo Drive, in the unincorporated community of Castaic, subject to conditions of approval. At the conclusion of the hearing, your Board indicated an intent to deny the appeals and approve the permits and instructed our office to prepare findings and conditions for your consideration. Enclosed are findings and conditions for your consideration.

Very truly yours,

MARY C. WICKHAM County Cour}~el

County Counsel

JJ:ph Enclosures c: Sachi A. Hamai, Chief Executive Office Lori Glasgow, Executive Officer, Board of Supervisors Richard J. Bruckner, Director, Department of Regional Planning HOA.101707201.1 FINDINGS OF THE BOARD OF SUPERVISORS AND ORDER PROJECT NO. R2004-00559-(5) CONDITIONAL U5E PERMIT NO. 2004-00042-(5) OAK TREE PERMIT NO. 2015-00007-(5)

The Los Angeles County ("County") Board of Supervisors ("Board") conducted a duly-noticed public hearing on June 27, 2017, in the matter of Project No. R2004- 00559-(5), consisting of Conditional Use Permit No. 2004-00042-(5)("CUP") and Oak Tree Permit No. 2015-00007-(5)("OTP") (collectively the "Project Permits"). The County Regional Planning Commission ("Commission") previously conducted duly-noticed public hearing sessions on the Project Permits on March 1, 2017, and April 19, 2017.

2. The permittee, Chiquita Canyon, LLC ("permittee"), requests the CUP to continue the operation and expansion of a Class III Landfill ("Project") located at 29201 Henry Mayo Drive ("Project Site"), in the unincorporated community of Castaic, in the A-2-2 (Heavy Agricultural —Two Acre Minimum Required Lot Area) and A-2-5 (Heavy Agricultural —Five Acre Minimum Required Lot Area) Zones. A CUP is required in the A-2 Zone for land reclamation projects, pursuant to Los Angeles County Code ("County Code") Section 22.24.150.

3. The permittee also requested the OTP to remove four oak trees related to the landfill operation and expansion within the A-2-2 and A-2-5 Zones, pursuant to County Code Section 22.56.2060.

4. In its Project application, the permittee requested the following: lateral expansion of the existing waste footprint from 257 acres to 400 acres; increased maximum elevation from 1,430 feet to 1,573 feet; increased daily disposal limits from 6,000 tons per day of waste to 12,000 tons per day; new entrance and support facilities; possible development of a household hazardous waste facility; mixed organics processing/composting operation; permission to accept all nonhazardous waste permitted at a Class III solid waste disposal landfill, exclusive of sludge; continued operation of the landfill and landfill gas-to-energy facility ("LFGTE"); new design features; environmental monitoring; relocation of a portion of Southern California Edison's existing Saugus-Elizabeth Lake-Fillmore 66 kilovolt (kV) Subtransmission Line to accommodate landfill improvements; and removal of four oak trees.

5. The Project Site consists of approximately 639 acres, and includes Assessor's Parcel Nos.("APN") 3271-002-011, 3271-002-013, 3271-002-019, 3271-002- 036, 3271-002-039, and 3271-005-034. The irregularly-shaped Project Site contains the existing landfill operations and LFGTE. Most of the site is mountainous, with elevations ranging from approximately 950 feet above sea level near the south property line, to a high of approximately 1,640 feet near the north property line. The Project Site fronts State Highway 126, the portion known

HOA.101707379.5 67. The location of the documents and other materials constituting the record of proceedings upon which the Board's decision is based in this matter is the Los Angeles County Department of Regional Planning, 13th Floor, Hall of Records, 320 West Temple Street, Los Angeles, California 90012. The custodian of such documents and materials shall be the Section Head of the Zoning Permits North Section, Department of Regional Planning.

BASED ON THE FOREGOING, THE BOARD OF SUPERVISORS CONCLUDES:

A. The proposed use with the attached conditions will be consistent with the adopted General Plan and the Area Plan; will not adversely afFect the health, peace, comfort, or welfare of persons residing or working in the surrounding area; will not be materially detrimental to the use, enjoyment, or valuation of property of other persons located in the vicinity of the Project Site; and will not jeopardize, endanger, or otherwise constitute a menace to the public health, safety, or general welfare.

B. The proposed Project Site is adequate in size and shape to accommodate the yards, walls, fences, parking and loading facilities, landscaping and other development features prescribed in Title 22 of the County Code, or as is otherwise required to integrate said use with the uses in the surrounding area, and is adequately served by highways or streets of sufficient width, and improved as necessary to carry the kind and quantity of traffic such use would generate, and by other public or private service facilities as are required.

C. The proposed construction of the proposed use will be accomplished without endangering the health of the remaining oak trees, subject to Part 16 of Title 22 of the County Code, on the subject property; the removal of the oak trees proposed will not result in soil erosion through the diversion or increased flow of surface waters, which cannot be satisfactorily mitigated; removal of the oak trees is necessary, as continued existence at the present locations frustrates the planned improvement or proposed use of the subject property to such an extent that alternative development plans cannot achieve the same permitted density, or that the cost of such alternative would be prohibitive; and the removal of the oak trees proposed will not be contrary to or be in substantial conflict with the intent and purpose of the oak tree permit procedure.

THEREFORE,THE BOARD OF SUPERVISORS:

Certifies that the EIR for the Project was completed in compliance with CEQA and the State and County Guidelines related thereto; certifies that it independently reviewed and considered the information contained in the EIR, and that the EIR reflects the independent judgment and analysis of the Board as to the environmental consequences of the Project; indicates that it certified the EIR at the conclusion of its hearing on the Project and adopted the CEQA Findings and SOC, and MMRP, finding that pursuant to section 21081.6 of the California Public Resources Code, the MMRP is adequately designed to ensure

HOA.701707379,5 ~ 6 compliance with the mitigation measures during Project implementation, found that the unavoidable significant effects of the Project after said mitigation measures are described in those CEQA Findings and SOC; and determined that the remaining, unavoidable environmental effects of the Project have been reduced to an acceptable level and are outweighed by specific health and safety, social, economic, legal, and/or environmental benefits of the Project, as stated in the. Findings and SOC; and

Denies the appeals and approves Conditional Use Permit No. 2004-00042-(5) and Oak Tree Permit No. 2015-00007-(5), subject to the attached conditions.

HOA.101707379.5 ~ 7