4.12 Energy - Los Angeles City Planning
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4. Environmental Impact Analysis
4.12 Energy
4.12.1 Introduction
Section 21100(b) of the California Environmental Quality Act (CEQA) Guidelines (State CEQA
Guidelines) requires that an EIR include a detailed statement setting forth mitigation measures
proposed to minimize a project’s significant effects on the environment, including, but not limited
to, measures to reduce the wasteful, inefficient, or unnecessary consumption of energy. Appendix
F of the State CEQA Guidelines states that, in order to ensure that energy implications are
considered in project decisions, the potential energy implications of a project shall be considered
in an EIR, to the extent relevant and applicable to the project. Appendix F further states that a
project’s energy consumption and proposed conservation measures may be addressed, as relevant
and applicable, in the Project Description, Environmental Setting and Impact Analysis portions of
technical sections, as well as through mitigation measures and alternatives.
In accordance with the intent of Appendix F of the State CEQA Guidelines, which requires an EIR
to include a discussion of the potential energy impacts of a proposed project with an emphasis on
avoiding or reducing inefficient, wasteful, or unnecessary consumption of energy, this Draft EIR
includes relevant information and analyses that address the energy implications of the Project. This
section represents a summary of the Project’s anticipated energy needs, impacts, and conservation
measures. As is discussed further below, the Project would incorporate Project Design Features
(PDFs), such as PDF AQ-1 (Green Building Measures), PDF AQ-2 (Construction Measures), and
PDF WS-1 (Water Conservation Features) that would minimize energy consumption. The
incorporation of PDF TRAF-1 (Construction Management Plan) and Mitigation Measures (MM)-
TRAF-1 (Travel Demand Management Program), as well as and land use characteristics, would
reduce vehicle miles traveled (increased density, location efficiency, increased land use diversity
and mixed uses, increased destination accessibility, increased transit accessibility, improved design
of development, and pedestrian network improvements). Information found herein, as well as other
aspects of the Project’s energy implications, are discussed in greater detail elsewhere in this Draft
EIR, including in Chapter 2, Project Description, and Sections 4.4, Greenhouse Gas Emissions, and
4.10, Transportation and Traffic, and Appendix D, of this Draft EIR.
The analysis in this section is based, in part, on information contained in the Utility Technical
Report: Water, Wastewater, and Energy (Utility Technical Report) prepared for the Project by
KPFF Consulting Engineers, provided as Appendix L of this Draft EIR1, and information provided
in Appendix M, Energy Analysis.
The Project entitlements include a Sign District on the Project Site and surrounding parcels.
Installation of signage would not result in impacts related to energy consumption. Thus, this issue
is not addressed further in this Energy section.
1 KPFF Consulting Engineers, Fig + Pico Conference Center Hotels: Utility Technical Report: Water, Wastewater,
and Energy, May 15, 2017.
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4.12. Energy
4.12.2 Environmental Setting
Existing Conditions
Existing Electricity Consumption
The Los Angeles Department of Water and Power (LADWP) is the utility provider for the City of
Los Angeles (City). The annual electricity sale to customers for the 2015-2016 fiscal year was
approximately 23,616 million kilowatt hours (kWh).2 Based on the City’s Substructure Maps
113-5, 126-205-13, and 134-1, the approximately 1.22-acre site (Project Site) receives electric
power from S. Figueroa Street and S. Flower Street via an underground electrical distribution
system. Based on the LADWP electrical billing data, the existing restaurant building generates a
demand of approximately 334,080 kWh per year.3
Existing Natural Gas Consumption
Southern California Gas Company (SoCalGas) is responsible for providing natural gas supply to
the City and is regulated by the California Public Utilities Commission and other state agencies.
The annual natural gas sale to customers in 2015 was approximately 304,290 million kilo British
thermal units (kBtu).4
Based on the City’s Substructure Maps 113-5, 126-205-13, and 134-1, there are four gas lines
serving the Project Site: (1) a 4-inch gas line in S. Figueroa Street; (2) a 3-inch SoCalGas-operated
gas line in W. Pico Boulevard; (3) a 3-inch gas line in S. Flower Street; and (4) a 2-inch gas line in
the alley between S. Figueroa Street and S. Flower Street. Based on SoCalGas utility billing data,
the existing restaurant building is connected to the S. Figueroa Street gas line and has an average
estimated load of 11,075 therms per year (1,107,500 kBtu per year).5
Existing Transportation Energy
According to the California Energy Commission, transportation accounts for nearly 37 percent of
California’s total energy consumption.6 Based on available fuel consumption data from the United
States Energy Information Administration (USEIA), in 2015, California consumed a total of
342,523 thousand barrels of gasoline for transportation, which is equivalent to a total annual
2 Los Angeles Department of Water and Power, 2016 Retail Electric Sales and Demand Forecast, June 2016,
http://ezweb.ladwp.com/Admin/Uploads/Load%20Forecast/2016/08/2016%20Retail%20Sales%20Forecast_Signed
.pdf. Accessed May 2017.
3 KPFF Consulting Engineers, Fig + Pico Conference Center Hotels: Utility Technical Report: Water, Wastewater,
and Energy, May 15, 2017.
4 Sempra Energy, 2016 Annual Report, 2017, http://www.sempra.com/pdf/financial-reports/2016_annualreport.pdf.
Accessed May 2017. Converted from 294 billion cubic feet and a conversion factor of 1,035 Btu per cubic foot
based on United States Energy Information Administration data (see: United States Energy Information
Administration, Natural Gas, Heat Content of Natural Gas Consumed, April 28, 2017, https://www.eia.gov/dnav/
ng/ng_cons_heat_a_EPG0_VGTH_btucf_a.htm. Accessed May 2017).
5 KPFF Consulting Engineers, Fig + Pico Conference Center Hotels: Utility Technical Report: Water, Wastewater,
and Energy, May 15, 2017. One therm equals 100,000 Btu.
6 California Energy Commission, 2015 Integrated Energy Policy Report, CEC-100-2015-001-CMF, 2016, page 153,
http://docketpublic.energy.ca.gov/PublicDocuments/15-IEPR-01/TN212017_20160629T154354_2015_Integrated
_Energy_Policy_Report_Small_File_Size.pdf. Accessed May 2017.
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4.12. Energy
consumption of approximately 14.4 billion gallons by the transportation sector.7 California
consumed a total of 80,487 thousand barrels of diesel fuel for transportation, which is equivalent
to a total annual consumption of approximately 3.4 billion gallons by the transportation sector.8
The existing restaurant generates transportation energy demand from vehicles traveling to and from
the Site. Transportation fuels, primarily gasoline and diesel, would be provided by local or regional
suppliers, vendors, and patrons. According to the California Air Resources Board on-road vehicle
emissions factor (EMFAC2014) model, the average fuel economy for the fleet-wide mix of vehicles
operating in the South Coast Air Basin region is approximately 20.17 miles per gallon for gasoline-
fueled vehicles and approximately 7.81 miles per gallon for diesel-fueled vehicles. Gasoline-fueled
vehicles account for approximately 96 percent of the total vehicles and diesel-fueled vehicles
account for approximately 3.6 percent of the total vehicles.9 Electric vehicles account for
approximately 0.3 percent of the total vehicles.
The vehicles miles traveled (VMT) for the existing restaurant was estimated as part of the air quality
and greenhouse gas (GHG) assessment conducted for the Project.10 Based on the estimated VMT
of 5,011,651 VMT per year, vehicles associated with the existing restaurant use approximately
238,588 gallons of gasoline and 23,321 gallons of diesel fuel in a year.
Regulatory Framework
Federal
Fuel efficiency standards for medium- and heavy-duty trucks have been jointly developed by the
United States Environmental Protection Agency (USEPA) and the National Highway Traffic
Safety Administration (NHTSA). The Phase 1 heavy-duty truck standards apply to combination
tractors, heavy-duty pickup trucks and vans, and vocational vehicles for model years 2014 through
2018 and result in a reduction in fuel consumption from 6 to 23 percent over the 2010 baseline,
depending on the vehicle type.11 The USEPA and NHTSA also adopted the Phase 2 heavy-duty
truck standards, which cover model years 2021 through 2027 and require the phase-in of a 5 to 25
percent reduction in fuel consumption over the 2017 baseline depending on the compliance year
and vehicle type.12
7 United States Energy Information Administration, Table F3: Motor Gasoline Consumption, Price, and Expenditure
Estimates, 2015, http://www.eia.gov/state/seds/data.cfm?incfile=/state/seds/sep_fuel/html/fuel_mg.html&sid=CA.
Accessed May 2017.
8 United States Energy Information Administration, Table F7: Distillate Fuel Oil Consumption Estimates, 2015,
http://www.eia.gov/state/seds/data.cfm?incfile=/state/seds/sep_fuel/html/fuel_use_df.html&sid=CA. Accessed May
2017.
9 Based on the California Air Resources Board on-road vehicle emissions model, EMFAC2014 (Modeling input: San
Francisco Bay Area Air Basin; LDA, LDT1, LDT2; Annual; 2020). The modeling input values are considered
generally representative of project buildout conditions for the region and representative of the majority of vehicles
associated with project-related VMT.
10 Refer to the California Emissions Estimator Model (CalEEMod) worksheets provided in Appendices C and D of this
Draft EIR for the existing restaurant.
11 United States Environmental Protection Agency, Fact Sheet: EPA and NHTSA Adopt First-Ever Program to Reduce
Greenhouse Gas Emissions and Improve Fuel Efficiency of Medium- and Heavy-Duty Vehicles, August 2011,
https://nepis.epa.gov/Exe/ZyPDF.cgi/P100BOT1.PDF?Dockey=P100BOT1.PDF. Accessed August 2017.
12 United States Environmental Protection Agency, Federal Register/Vol. 81, No. 206/Tuesday, Greenhouse Gas
Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles—Phase 2, October
25, 2016, https://www.gpo.gov/fdsys/pkg/FR-2016-10-25/pdf/2016-21203.pdf. Accessed August 2017.
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SCH No. 2016121063 September 20174. Environmental Impact Analysis 4.12. Energy State of California Senate Bill 1389 Senate Bill 1389 (SB), codified in Public Resources Code Sections 25300-25323, requires the California Energy Commission (CEC) to prepare a biennial integrated energy policy report that assesses major energy trends and issues facing the state’s electricity, natural gas, and transportation fuel sectors and provides policy recommendations to conserve resources; protect the environment; ensure reliable, secure, and diverse energy supplies; enhance the state’s economy; and protect public health and safety (Public Resources Code Section 25301[a]). The 2015 Integrated Energy Policy Report provides the results of the CEC’s assessments of a variety of energy issues facing California including energy efficiency, strategies related to data for improved decisions in the Existing Buildings Energy Efficiency Action Plan, building energy efficiency standards, the impact of drought on California’s energy system, achieving 50 percent renewables by 2030, the California Energy Demand Forecast, the Natural Gas Outlook, the Transportation Energy Demand Forecast, Alternative and Renewable Fuel and Vehicle Technology Program benefits updates, update on electricity infrastructure in Southern California, an update on trends in California’s sources of crude oil, an update on California’s nuclear plants, and other energy issues. Senate Bill 1078 (SB 1078, Sher) (Chapter 516, Statutes of 2002) and Senate Bill 107 (SB 107, Simitian) (Chapter 464, Statutes of 2006) and Executive Order S-14-08 The State of California has adopted standards to increase the percentage that retail sellers of electricity, including investor-owned utilities and community choice aggregators, must provide from renewable sources. The standards are referred to as the Renewables Portfolio Standard and require 33 percent by 2020 and 50 percent by 2040. Refer to Section 4.4, Greenhouse Gas Emissions, of this Draft EIR, for details regarding this regulation. Title 24, Building Standards Code and California Green Building Standards (CALGreen) Code The CEC first adopted the Energy Efficiency Standards for Residential and Nonresidential Buildings (California Code of Regulations (CCR), Title 24, Part 6) in 1978 in response to a legislative mandate to reduce energy consumption in the State. The standards are updated periodically to allow for the consideration and inclusion of new energy efficiency technologies and methods. The California Building Standards Commission (CBSC) adopted Part 11 of the Title 24 Building Energy Efficiency Standards, referred to as the California Green Building Standards (CALGreen) Code. The purpose of the CALGreen Code is to “improve public health, safety and general welfare by enhancing the design and construction of buildings through the use of building concepts having a positive environmental impact and encouraging sustainable construction practices. Although the CALGreen Code was adopted as part of the State’s efforts to reduce GHG emissions, the standards have co-benefits of reducing energy consumption from residential and nonresidential buildings subject to the standard. Refer to Section 4.4, Greenhouse Gas Emissions, of this Draft EIR, for additional details regarding these standards. California Assembly Bill No. 1493 (AB 1493, Pavley), (Chapter 200, Statutes of 2002) In response to the transportation sector accounting for more than half of California’s carbon dioxide (CO2) emissions, Assembly Bill (AB) 1493 (Chapter 200, Statutes of 2002), enacted on July 22, 2002, required the California Air Resource Board (CARB) to set GHG emission standards for City of Los Angeles 4.12-4 Fig+Pico Conference Center Hotels SCH No. 2016121063 September 2017
4. Environmental Impact Analysis
4.12. Energy
passenger vehicles, light duty trucks, and other vehicles whose primary use is non-commercial
personal transportation manufactured in and after 2009. Refer to Section 4.4, Greenhouse Gas
Emissions, for details regarding this regulation.
Senate Bill 375 (SB 375, Steinberg) (Chapter 728, Statutes of 2008)
SB 375 establishes mechanisms for the development of regional targets for reducing passenger
vehicle greenhouse gas emissions and was adopted by the State on September 30, 2008. Under SB
375, the target must be incorporated within that region’s Regional Transportation Plan (RTP),
which is used for long-term transportation planning, in a Sustainable Communities Strategy (SCS).
Certain transportation planning and programming activities would then need to be consistent with
the SCS; however, SB 375 expressly provides that the SCS does not regulate the use of land, and
further provides that local land use plans and policies (e.g., general plan) are not required to be
consistent with either the RTP or SCS. Refer to Section 4.4, Greenhouse Gas Emissions, of this
Draft EIR, for details regarding these standards.
California Health and Safety Code, Division 25.5 – California Global Warming Solutions
Act of 2006
In 2006, the California State Legislature adopted AB 32 (codified in the California HSC, Division
25.5 – California Global Warming Solutions Act of 2006), which focuses on reducing GHG
emissions in California to 1990 levels by 2020. Under HSC Division 25.5, CARB has the primary
responsibility for reducing the State’s GHG emissions, however, it also tasked the CEC and the
California Public Utilities Commission (CPUC) with providing information, analysis, and
recommendations to CARB regarding strategies to reduce GHG emissions in the energy sector.
In 2016, the California State Legislature adopted SB 32 and its companion bill AB 197; both were
signed by Governor Brown. SB 32 and AB 197 amends HSC Division 25.5 and establishes a new
climate pollution reduction target of 40 percent below 1990 levels by 2030 and includes provisions
to ensure that the benefits of state climate policies reach into disadvantaged communities. Refer to
Section 4.4, Greenhouse Gas Emissions, for details regarding these regulations.
CARB Heavy-Duty On-Road and Off-Road Vehicle Regulations
In 2004, the CARB adopted an Airborne Toxic Control Measure to Limit Diesel-Fueled
Commercial Motor Vehicle Idling in order to reduce public exposure to diesel particulate matter
emissions (Title 13 California CCR Section 2485). The measure applies to diesel-fueled
commercial vehicles with gross vehicle weight ratings greater than 10,000 pounds that are licensed
to operate on highways, regardless of where they are registered. This measure does not allow diesel-
fueled commercial vehicles to idle for more than 5 minutes at any given location. While the goal
of this measure is primarily to reduce public health impacts from diesel emissions, compliance with
the regulation also results in energy savings in the form of reduced fuel consumption from
unnecessary idling.
In addition to limiting exhaust from idling trucks, CARB also promulgated emission standards for
off-road diesel construction equipment of greater than 25 horsepower (hp) such as bulldozers,
loaders, backhoes and forklifts, as well as many other self-propelled off-road diesel vehicles. The
In-Use Off-Road Diesel-Fueled Fleets regulation adopted by CARB on July 26, 2007 aims to
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reduce emissions by installation of diesel soot filters and encouraging the retirement, replacement,
or repower of older, dirtier engines with newer emission controlled models (13 CCR Section 2449).
The compliance schedule requires full implementation by 2023 in all equipment for large and
medium fleets and by 2028 for small fleets. While the goal of this measure is primarily to reduce
public health impacts from diesel emissions, compliance with the regulation has shown an increase
in energy savings in the form of reduced fuel consumption from more fuel efficient engines.
City of Los Angeles
Green LA Plan
The City, in May 2007, published Green LA: An Action Plan to Lead the Nation in Fighting Global
Warming (Green LA Plan), outlining the goals and actions the City has established to reduce the
generation and emission of GHGs from both public and private activities.13 Although the Green
LA Plan was adopted as part of the City’s efforts to reduce GHG emissions, the standards have co-
benefits of reducing energy consumption from residential and nonresidential buildings. In 2008,
the City released an implementation program for the Green LA Plan, referred to as ClimateLA,
which provides detailed information about each action item discussed in the Green LA Plan
framework. Action items range from harnessing wind power for electricity production and energy
efficiency retrofits in City buildings, to converting the City’s fleet vehicles to cleaner and more
efficient models, and reducing water consumption, which has co-benefits of reducing energy
demand for water supply, conveyance, distribution and treatment. Refer to Section 4.4, Greenhouse
Gas Emissions, for details regarding the Green LA Plan and ClimateLA.
Sustainable City pLAn
The Sustainable City pLAn is a comprehensive and actionable directive from the Mayor to improve
the environmental, economic, and equitable conditions in the City.14 The pLAn is a tool that the
Mayor is using to manage the City and establish visions, goals, and metrics for City Departments.
The Sustainable City pLAn establishes visions for City Departments for the following categories:
(1) Environment (energy efficiency, water conservation, and waste reduction); (2) Economy
(housing needs, transportation system investments, green jobs investments, and natural disaster
preparedness); and (3) Equity (environmental justice, revitalized urban areas, and healthy
neighborhoods). Refer to Section 4.4, Greenhous Gas Emissions, od tis Draft EIR, for details
regarding the Sustainable City pLAn.
Green Building Ordinance
To achieve goals outlined in the Green LA Plan, in April 2008, the City adopted the Green Building
Program Ordinance to address the impact on climate change from new development. Projects filed
on or after January 1, 2014, must comply with the Green Building Code as amended to comply
with various provisions of the CALGreen Code. Although the Green Building Program Ordinance
was adopted as part of the City’s efforts to reduce GHG emissions, the standards have co-benefits
13 City of Los Angeles, GREEN LA, An Action Plan to Lead the Nation in Fighting Global Warming, May 2007,
http://environmentla.org/pdf/GreenLA_CAP_2007.pdf.
14 City of Los Angeles Mayor’s Office of Sustainability, Sustainable City pLAn, 2015, https://www.lamayor.org/plan.
Accessed March 2017.
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of reducing energy and water consumption from residential and nonresidential buildings. Refer to
Section 4.4, Greenhouse Gas Emissions, od this Draft EIR, for additional details.
Solid Waste Programs and Ordinances
The generation of solid waste results in fuel demand from collection service vehicles to transport
waste to a material recovery facility or landfill. The City has enacted plans, policies and regulations
to address solid waste services and reduction of the solid waste stream. The City has developed and
is in the process of implementing the Solid Waste Integrated Resources Plan (SWIRP), also referred
to as the City’s Zero Waste Plan, whose goal is to lead Los Angeles towards being a “zero waste”
City by 2030.15 These waste reduction plans, policies, and regulations, along with Mayoral and
City Council directives, have increased the level of waste diversion (e.g., recycling) for the City to
76 percent as of 2013.16 The City has also approved Ordinance No. 181519 (Los Angeles Municipal
Code (LAMC) Chapter VI, Article 6, Section 66.32-66.32.5), which requires the diversion of mixed
construction and demolition debris to City certified construction and demolition waste processors.
4.12.3 Environmental Impacts
Methodology
Analysis of the Project’s energy impacts is based in part on the Energy Analysis provided in
Appendix M of this Draft EIR. The evaluation of potential impacts related to energy usage that
may result from the construction and long-term operations of the Project has been conducted as
described below.
Construction
The Project would be constructed in a single phase with overlapping development activities.
Construction could commence as early as 2018, pending Project approval and EIR certification,
with full buildout and occupancy of the Project anticipated by 2022. Construction energy
consumption would result primarily from transportation fuels (e.g., diesel and gasoline) used for
haul trucks, heavy-duty construction equipment, and construction workers traveling to and from
the Site. Construction activities can vary substantially from day to day, depending on the specific
type of construction activity and the number of workers and vendors traveling to the Site. This
analysis considers these factors and provides the estimated maximum construction energy
consumption for the purposes of evaluating the associated impacts on energy resources.
Energy use during construction is forecasted by assuming a conservative estimate of construction
activities (i.e., maximum daily equipment usage levels). The energy usage required for Project
construction has been estimated based on the number and type of construction equipment that
would be used during Project construction, the extent that various equipment are utilized in terms
of equipment operating hours or miles driven, and the estimated duration of construction activities.
Energy for construction worker commuting trips has been estimated based on the predicted number
15 City of Los Angeles Department of Public Works, LA Sanitation, Solid Waste Integrated Resources Plan (SWIRP)
– A Zero Waste Management Plan, October 2013, https://www.lacitysan.org/san/sandocview?docname=cnt012522.
Accessed May 2017.
16 City of Los Angeles Department of Public Works, LA Sanitation, Recycling, 2017, https://www.lacitysan.org/san/
faces/home/portal/s-lsh-wwd/s-lsh-wwd-s/s-lsh-wwd-s-r?_adf.ctrl-state=kq9mn3h5a_188. Accessed May 2017.
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SCH No. 2016121063 September 20174. Environmental Impact Analysis 4.12. Energy of workers for the various phases of construction and the estimated VMT. The assessment also includes a discussion of the Project’s compliance with relevant energy-related regulatory measures and Project Design Features (PDF AQ-2; PDF TRAF-1) that would minimize the amount of energy usage during construction. These measures are also discussed in Chapter 2, Project Description, Section 4.4, Greenhouse Gas Emissions, Section 4.7, Land Use and Planning, and Section 4.10, Transportation and Traffic, of this Draft EIR. The construction equipment would likely be diesel-fueled (with the exception of construction worker commute vehicles, which would primarily be gasoline-fueled). For the purposes of this assessment, it is conservatively assumed heavy-duty construction equipment and haul trucks would be diesel-fueled. This represents a worst-case scenario intended to represent the maximum potential energy use during construction. The estimated fuel economy for heavy-duty construction equipment is based on fuel consumption factors from the CARB off-road vehicle (OFFROAD) emissions model, which is a state-approved model for estimating emissions from off-road heavy- duty equipment. The estimated fuel economy for haul trucks and worker commute vehicles is based on fuel consumption factors from the CARB EMFAC emissions model, which is a state-approved model for estimating emissions on-road vehicles and trucks. Both OFFROAD and EMFAC are incorporated into the California Emissions Estimator Model (CalEEMod), which is a state- approved emissions model used for the Project’s air quality and GHG emissions assessment. Therefore, this energy assessment is consistent with the modeling approach used for other environmental analyses in the EIR and consistent with general CEQA standards. Operation Operation of the Project would require energy in the form of electricity and natural gas for building heating, cooling, cooking, lighting, water demand and wastewater treatment, consumer electronics, and other energy needs, and transportation-fuels, primarily gasoline, for vehicles traveling to and from the Site. The energy usage required for Project operations and routine and incidental maintenance activities is estimated based on the net change in energy demand from the new buildings and facilities compared to the existing restaurant. The energy usage takes into account building energy standards pursuant to the Title 24 Building Standards Code and CALGreen Code. Energy for transportation from employees and visitors to the Site is estimated based on the predicted number of trips to and from the Site and the estimated VMT. Energy usage from water demand (e.g., electricity used to supply, convey, treat, and distribute) is estimated based on the net change from the new buildings and facilities compared to the existing restaurant. The assessment also includes a discussion of the Project’s compliance with relevant energy-related regulations, Project Design Features (PDF AQ-1), and land use transportation characteristics that would minimize the amount of energy usage during operations. These measures are also discussed in Chapter 2, Project Description, Section 4.4, Greenhouse Gas Emissions, Section 4.7, Land Use and Planning, and Section 4.10, Transportation and Traffic, of this Draft EIR. Building energy use factors, water demand factors, vehicle trips from all vehicle types to and from the Project Site (including waste collection vehicles), and vehicle trip lengths from CalEEMod are used to estimate building energy use and VMT. The estimated fuel economy for vehicles is based City of Los Angeles 4.12-8 Fig+Pico Conference Center Hotels SCH No. 2016121063 September 2017
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4.12. Energy
on fuel consumption factors from the CARB EMFAC emissions model. As discussed above,
EMFAC is incorporated into CalEEMod, which is a state-approved emissions model used for the
Project’s air quality and GHG emissions assessment. Therefore, this energy assessment is
consistent with the modeling approach used for other environmental analyses in this Draft EIR and
consistent with general CEQA standards. The Project’s estimated energy demands were then
analyzed relative to LADWP’s and SoCalGas’s existing and planned energy supplies in the Project
buildout year to determine if these two energy utility companies would be able to meet the Project’s
energy demands.
Thresholds of Significance
Appendix F of the State CEQA Guidelines
Appendix G of the State CEQA Guidelines provides significance thresholds for the evaluation of a
number of environmental impacts, but does not provide specific thresholds for the evaluation of
impacts related to energy resources. Appendix F of the State CEQA Guidelines states that the
evaluation of energy use should be evaluated in an EIR and provides guidance for consideration in
this evaluation. While Appendix F does not provide specific thresholds for energy use, it
recommends consideration of the following environmental impacts, to the extent relevant and
applicable:
The project’s energy requirements and its energy use efficiencies by amount and fuel type for
each stage of the project including construction, operation, maintenance and/or removal. If
appropriate, the energy intensiveness of materials may be discussed.
The effects of the project on local and regional energy supplies and on requirements for
additional capacity.
The effects of the project on peak and base period demands for electricity and other forms of
energy.
The degree to which the project complies with existing energy standards.
The effects of the project on energy resources.
The project’s projected transportation energy use requirements and its overall use of efficient
transportation alternatives.
In accordance with Appendix F of the State CEQA Guidelines, for purposes of this Draft EIR, the
Project would have a significant impact with regard to energy if the Project would:
Conflict with adopted energy conservation plans;
Violate State or federal energy standards;
Cause wasteful, inefficient, or unnecessary consumption of energy during construction or
operation; or
Result in an increase in demand for electricity or natural gas that exceeds available supply or
distribution infrastructure capabilities that could result in the construction of new energy
facilities or expansion of existing facilities, the construction of which could cause significant
environmental effects.
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Project Characteristics and Project Design Features
Land Use Characteristics
The Project would represent an urban infill development, since it would be undertaken on a
currently developed site, and would be located near existing off-site commercial, residential, and
retail destinations and in close proximity to existing public transit stops, which would result in
reduced vehicle trips and VMT. This would be in comparison to a business-as-usual project of
similar size and land without close access to off-site destinations and public transit stops. The
Project would result in a corresponding reduction in transportation-related emissions compared to
a business-as-usual project that is developed at a site without existing off-site destinations and
public transit stops.
The California Air Pollution Control Officers Association (CAPCOA) has provided guidance for
mitigating or reducing transportation-related VMT from land use development projects within its
guidance document titled Quantifying Greenhouse Gas Mitigation Measures.17 The land use
characteristics listed below are consistent with the CAPCOA guidance document, and would reduce
vehicle trips to and from the Project Site and vehicle trip distances and would achieve a reduction
in associated transportation-related fuel demand, as well as co-benefits of reducing air pollutant
and GHG emissions.
Increased Density: Increased density, measured in terms of persons, jobs, or dwelling units
per unit area, reduces VMT associated with transportation as it reduces the distance people
travel for work or services and provides a foundation for the implementation of other strategies
such as enhanced transit services. This measure corresponds to CAPCOA guidance measure
LUT-1.18 According to CAPCOA, the reduction in VMT from this measure applies to urban
and suburban settings for residential, retail, office, industrial, and mixed-use projects. The
Project is located in an urban infill19 location and is mixed-use; therefore, this measure applies
to the Project. The Project would be expected to increase the Project Site density to
approximately 594 jobs.20
Location Efficiency: Location efficiency describes the location of a project relative to the type
of urban landscape such as an urban area, compact infill, or suburban center. In general,
compared to the statewide average, a project could realize VMT reductions up to 65 percent in
an urban area, up to 30 percent in a compact infill area, or up to 10 percent in a suburban center
17 California Air Pollution Control Officers Association, Quantifying Greenhouse Gas Mitigation Measures, 2010,
http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf. Accessed
May 2017.
18 California Air Pollution Control Officers Association, Quantifying Greenhouse Gas Mitigation Measures, 2010,
pages 155-158, http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-
Final.pdf.
19 California Air Pollution Control Officers Association, Quantifying Greenhouse Gas Mitigation Measures, 2010,
pages 59-60 http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf.
The project area meets the characteristics for an urban setting with respect to typical building heights of 6 stories or
much higher, grid street pattern, minimal setbacks, constrained parking, high parking prices, high quality rail service
(i.e., Metro Blue and Expo Lines at the Metro Pico station), location relative to regional cores (5 miles or less) and
jobs/housing balance (the Central City Community Plan Area has an existing jobs/housing ratio of approximately
7.2).
20 Based on employment density factors in the Los Angeles Unified School District, 2014 Developer Fee Justification
Study, March 2014.
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SCH No. 2016121063 September 20174. Environmental Impact Analysis
4.12. Energy
for land use/location strategies.21 This measure corresponds to CAPCOA guidance measure
LUT-2.22 According to CAPCOA, the reduction in VMT from this measure applies to urban
and suburban settings for residential, retail, office, industrial, and mixed-use projects. The
Project is located in an urban infill location and is mixed-use; therefore, this measure applies
to the Project. According to the CAPCOA guidance, factors that contribute to VMT reductions
under this measure include the geographic location of the Project within the region. The Project
Site represents an urban infill location within Downtown Los Angeles. The Project Site is
served by existing public transportation located within a quarter-mile. The Project Site is within
an active urban center with many existing off-site commercial, entertainment, hotel, and
residential buildings. The location efficiency of the Project Site would result in reduced vehicle
trips and VMT compared to the statewide and South Coast Air Basin average.
Increased Land Use Diversity and Mixed-Uses: Locating different types of land uses near
one another can decrease VMT since trips between land use types are shorter and could be
accommodated by alternative modes of transportation, such as public transit, bicycles, and
walking. This measure corresponds to CAPCOA guidance measure LUT-3.23 According to
CAPCOA, the reduction in VMT from this measure applies to urban and suburban settings
(also potentially for rural master-planned communities) for mixed-use projects. The Project is
located in an urban infill location and is mixed-use; therefore, this measure applies to the
Project. According to the CAPCOA guidance, factors that contribute to VMT reductions under
this measure include the percentage of each land use type in the Project. The Project would co-
locate complementary hotel, retail, and restaurant land uses in close to proximity to existing
off-site commercial and residential uses. The Project would include on-site hotel, retail, and
restaurant land uses and would be located within a quarter-mile of off-site commercial and
residential uses, as well as major transit facilities. The increases in land use diversity and mix
of uses on the Project Site, as well as proximity to transit, would reduce vehicle trips and VMT
by encouraging walking and non-automotive forms of transportation.
Increased Destination Accessibility: This measure corresponds to CAPCOA guidance
measure LUT-4.24 According to CAPCOA, the reduction in VMT from this measure applies to
urban and suburban settings for residential, retail, office, industrial, and mixed-use projects.
21 CalEEMod, by default, assumes that trip distances in the South Coast Air Basin are slightly longer than the statewide
average. This is due to the fact that commute patterns in the South Coast Air Basin involve a substantial portion of
the population commuting relatively far distances, which is documented in the Southern California Association of
Governments 2016-2040 Regional Transportation Plan/Sustainable Communities Strategy. The 2016 RTP/SCS
shows that, even under future Plan conditions, upwards of 50 percent of all work trips are 10 miles or longer (SCAG,
Performance Measures Appendix, page 13, 2016). The 2016 RTP/SCS does not specify the current percentage of
work trips greater than 10 miles in the region, but it can be assumed that the percentage is currently greater than 50
percent since the goal of the 2016 RTP/SCS is to reduce overall VMT in the region. It is thus reasonable to assume
that the trip distances in South Coast Air Basin are analogous to the statewide average given that the default model
trip distances in the South Coast Air Basin are slightly longer but still generally similar to the statewide average.
Therefore, projects could achieve similar levels of VMT reduction (65 percent in an urban area, 30 percent in a
compact infill area, or 10 percent for a suburban center) compared to the South Coast Air Basin average.
22 California Air Pollution Control Officers Association, Quantifying Greenhouse Gas Mitigation Measures, 2010,
pages 159-161, http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-
Final.pdf.
23 California Air Pollution Control Officers Association, Quantifying Greenhouse Gas Mitigation Measures, 2010,
pages 162-166, http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-
Final.pdf.
24 California Air Pollution Control Officers Association, Quantifying Greenhouse Gas Mitigation Measures, 2010,
pages 167-170, http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-
Final.pdf.
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SCH No. 2016121063 September 20174. Environmental Impact Analysis
4.12. Energy
The Project is located in an urban infill location and is mixed-use, including hotel, retail, and
restaurant land uses; therefore, this measure applies to the Project. According to the CAPCOA
guidance, factors that contribute to VMT reductions under this measure include the distance to
Downtown Los Angeles or major job center. The Project would be located in an area that offers
access to multiple other nearby destinations including restaurant, bar, office, retail,
entertainment, movie theater, the Convention Center, and residential uses. The Project Site is
also located near other job centers in the region and within Downtown Los Angeles. The access
to multiple destinations in close proximity to the Project Site would reduce vehicle trips and
VMT compared to the statewide and South Coast Air Basin average, encourage walking and
non-automotive forms of transportation.
Increased Transit Accessibility: Locating a high-density project near transit facilitates
encourages the use of transit by people traveling to or from a project site. This measure
corresponds to CAPCOA guidance measure LUT-5.25 According to CAPCOA, the reduction
in VMT from this measure applies to urban and suburban settings (also potentially for rural
settings adjacent to a commuter rail station with convenient access to a major employment
center) for residential, retail, office, industrial, and mixed-use projects. The Project is located
in an urban infill location and is mixed-use; therefore, this measure applies to the Project.
According to the CAPCOA guidance, factors that contribute to VMT reductions under this
measure include the distance to transit stations near the Project. The Project would be located
within a quarter-mile of public transportation, including the existing Metro Pico light rail
station, Metro bus routes (e.g., local 14, 28, 30, 33, 37, 55, 66, 70, 71, 76, 78, 79, 81, and 96;
limited 330, 335, and 378; express 442 and 460; rapid 728, 733, and 770; and Metro Silver),
LADOT’s Downtown Area Short Hop (DASH), LADOT Commuter Express, Santa Monica
Big Blue Bus, Foothill Transit, Orange County Transportation Authority (OCTA), and
Torrance Transit. The Project would provide access to on-site uses from existing pedestrian
pathways. The Project would also provide parking for bicycles on-site to encourage utilization
of alternative modes of transportation. The increased transit accessibility would reduce vehicle
trips and VMT versus the statewide and South Coast Air Basin average, encourage walking
and non-automotive forms of transportation.
Improve Design of Development: Improved street network characteristics within a
neighborhood enhances walkability and connectivity. Characteristics include street
accessibility usually measured in terms of number of intersections (e.g., 4-way intersections)
per square mile. This measure corresponds to CAPCOA guidance measure LUT-9.26 According
to CAPCOA, the reduction in VMT from this measure applies to urban and suburban settings
for residential, retail, office, industrial, and mixed-use projects. The Project is located in an
urban infill location and is mixed-use; therefore, this measure applies to the Project. The Project
would be located in a highly street-accessible area with approximately 98 four-way
intersections within a 1-mile area of the Project Site, which exceeds the standard intersection
density assumed in baseline VMT modeling. The increased intersection density would reduce
vehicle trips and VMT versus the statewide and South Coast Air Basin average, encourage
walking and non-automotive forms of transportation.
25 California Air Pollution Control Officers Association, Quantifying Greenhouse Gas Mitigation Measures, 2010,
pages 171-175, http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-
Final.pdf.
26 California Air Pollution Control Officers Association, Quantifying Greenhouse Gas Mitigation Measures, 2010,
pages 182-185, http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-
Final.pdf.
City of Los Angeles 4.12-12 Fig+Pico Conference Center Hotels
SCH No. 2016121063 September 20174. Environmental Impact Analysis
4.12. Energy
Provide Pedestrian Network Improvements: Providing pedestrian access that minimizes
barriers and links a project site with existing or planned external streets encourages people to
walk instead of drive. This measure corresponds to CAPCOA guidance measure SDT-1.27
According to CAPCOA, the reduction in VMT from this measure applies to urban, suburban,
and rural settings for residential, retail, office, industrial, and mixed-use projects. The Project
is located in an urban infill location and is mixed-use; therefore, this measure applies to the
Project. According to the CAPCOA guidance, factors that contribute to VMT reductions under
this measure include pedestrian access connectivity within the Project and to/from off-site
destinations. As discussed in Section 4.10, Transportation and Traffic, the walkability of
existing facilities is based on the availability of pedestrian routes necessary to accomplish daily
tasks without the use of an automobile. These attributes are quantified by WalkScore.com and
assigned a score out of 100 points. With the various commercial businesses and entertainment
facilities adjacent to residential neighborhoods of Downtown Los Angeles and proximity to
public transit, the walkability of Downtown Los Angeles is approximately 91 points;28 this
compares to the citywide score of 64 points. As discussed in Chapter 2, Project Description, of
this Draft EIR, the Project would improve pedestrian connectivity and the pedestrian
experience between the Convention Center (including Gilbert Lindsey Plaza and LA Live) and
the Metro Pico light rail station. The Project would provide retail establishments, restaurants,
and hotel lobby facilities that adjoin street frontages. On the ground level, the Project would
provide approximately 8,626 square feet of open space within the setback and sidewalk areas
to enhance the pedestrian experience. At the street level, the Project would be designed to
reinforce the pedestrian nature of the S. Figueroa Street corridor and would include an internal
motor court drop-off from W. Pico Boulevard connecting to the hotels’ ground floor lobbies
and retail/restaurant spaces. In summary, the Project would provide an internal pedestrian
network for Project visitors and employees that links to the existing off-site pedestrian network
including existing off-site sidewalks, and would therefore result in some reduction in VMT.
Project Design Features
The Project incorporates many project design features that target sustainable site development,
water savings, energy efficiency, green-oriented materials selection, and improved indoor
environmental quality. PDFs applicable to energy include:
PDF AQ-1: Green Building Features: (refer to Section 4.2, Air Quality, and Section 4.4,
Greenhouse Gas Emissions).
PDF AQ-2: Construction Features (refer to Section 4.2, Air Quality, and Section 4.4,
Greenhouse Gas Emissions).
PDF TRAF-1: Construction Management Plan (refer to Section 4.10, Transportation
and Traffic).
PDF WS-1: Water Conservation Features (refer to Section 4.11.1, Water Supply).
27 California Air Pollution Control Officers Association, Quantifying Greenhouse Gas Mitigation Measures, 2010,
pages 186-189, http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-
Final.pdf.
28 WalkScore.com (www.walkscore.com) rates the Project Site area (zip code 90015) with a score of 91 of 100 possible
points (scores accessed on January 24, 2017 for the Downtown Los Angeles district). Walk Score calculates the
walkability of specific addresses by taking into account the ease of living in the neighborhood with a reduced reliance
on automobile travel.
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SCH No. 2016121063 September 20174. Environmental Impact Analysis
4.12. Energy
Project Impacts
Project Consistency with Plans, Policies, or Regulations
Threshold EN-1: Would the Project conflict with adopted energy conservation plans?
The Project would be designed in a manner that is consistent with relevant energy conservation
plans designed to encourage development that results in the efficient use of energy resources. The
Project would comply with the Los Angeles Green Building Code to reduce energy consumption
by implementing energy efficient building designs, reducing indoor and outdoor water demand,
and installing energy-efficient appliances and equipment. These measures are consistent with the
City’s sustainability and smart-growth goals of improving energy and water efficiency in buildings,
decreasing per-capita water use, using energy efficient appliances and equipment, and creating a
more livable city.
When implemented, the following planned City actions, as presented in the Green LA Plan, may
further decrease energy consumption from the Project. These actions are not under the control of
the Project; however, they would nonetheless further reduce Project-related energy use from non-
renewable sources:
Decreasing emissions from LADWP electrical generation and import activities;
Promoting walking and biking to work, within neighborhoods, and to large events and venues;
and
Expanding the regional rail network to reduce VMT.
A detailed discussion of the Project’s consistency with the Green LA Plan and Sustainable City
pLAn is provided in Section 4.4, Greenhouse Gas Emissions (refer to Table 4.4-7 and Table 4.4-
8). The analysis describes the consistency of the Project with applicable plan goals and actions. As
discussed in Table 4.4-7 and Table 4.4-8, the Project would be consistent with the applicable goals
and actions to minimize energy use.29 In addition, as provided in PDF AQ-1, PDF AQ-2, PDF
TRAF-1, and PDF WS-1, the Project would also implement features that would result in energy
reductions beyond those specified by regulation by incorporating energy efficient design features
and VMT reduction land use characteristics.
As a result, the Project would implement PDFs and incorporate water conservation, energy
conservation, tree-planting, and other features consistent with the City’s Green LA Plan and the
Sustainable City pLAn, as well as PDFs that go beyond those specified by regulations such as the
City’s Green Building Ordinance. Therefore, the Project would be consistent with the City’s
applicable plans for conserving energy and impacts would be less than significant.
29 In Table 4.4-7, refer to the Project’s consistency with applicable measures for the following Focus Areas: Energy,
Water, and Transportation. In Table 4.4-8, refer to the Project’s consistency with applicable measures for Focus Area:
Environment.
City of Los Angeles 4.12-14 Fig+Pico Conference Center Hotels
SCH No. 2016121063 September 20174. Environmental Impact Analysis
4.12. Energy
Energy Standards
Threshold EN-2: Would the Project violate State or federal energy standards?
The Project would utilize construction contractors who demonstrate compliance with applicable
CARB regulations restricting the idling of heavy-duty diesel motor vehicles and governing the
accelerated retrofitting, repowering, or replacement of heavy duty diesel on- and off-road
equipment. As discussed in Section 4.4, Greenhouse Gas Emissions, of this Draft EIR, CARB has
adopted an Airborne Toxic Control Measure to limit heavy-duty diesel motor vehicle idling in order
to reduce public exposure to diesel particulate matter and other toxic air contaminants. The measure
prohibits diesel-fueled commercial vehicles greater than 10,000 pounds from idling for more than
5 minutes at any given time. While intended to reduce construction emissions, compliance with the
above anti-idling and emissions regulations would also result in energy savings from the use of
more fuel efficient engines. According to the CARB staff report that was prepared at the time the
anti-idling Airborne Toxic Control Measure was being proposed for adoption in late 2004/early
2005, the regulation was estimated to reduce non-essential idling and associated emissions of diesel
particulate matter and nitrogen oxide (NOX) emissions by 64 and 78 percent respectively in analysis
year 2009.30 These reductions in emissions are directly attributable to overall reduced idling times
and the resultant reduced fuel consumption.
CARB has also adopted emission standards for off-road diesel construction equipment of greater
than 25 hp. The emissions standards are referred to as “tiers” with Tier 4 being the most stringent
(i.e., less polluting). The requirements are phased in, with full implementation for large and medium
fleets by 2023 and for small fleets by 2028. The Project would accelerate the use of cleaner
construction equipment by using equipment that meet at a minimum the Tier 3 or Tier 4 interim
off-road emissions standards as specified in PDF AQ-2. Field testing from construction equipment
manufacturers have shown that higher tier equipment results in lower fuel consumption. For
example, Tier 4 interim engines have shown a 5 percent reduced fuel consumption compared to a
Tier 3 engine.31 Similar reductions in fuel consumption have been shown for Tier 3 engines
compared to a Tier 2 engine.32
The daily operation of the Project would generate demand for electricity, natural gas, and water
supply, as well as generating wastewater requiring conveyance, treatment and disposal off-site and
municipal solid waste requiring collection and transport off-site. The Project would comply with
or exceed the applicable provisions of Title 24 and the CALGreen Code in affect at the time of
building permit issuance. According to the CEC, the Title 24 (2016) standards use 5 percent less
30 California Air Resources Board, Staff Report: Initial Statement of Reasons for Proposed Rulemaking, Airborne Toxic
Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling, Appendix F, July 2004,
https://www.arb.ca.gov/regact/idling/idling.htm. Accessed May 2017.
31 Cummins, “Fuel Duel” Confirms 5 Percent Higher Fuel Efficiency for Cummins Tier 4, June 25, 2009,
http://www.businesswire.com/news/home/20090625005468/en/%E2%80%9CFuel-Duel%E2%80%9D-Confirms-
5-Percent-Higher-Fuel. Accessed May 2017.
32 John Deere, Engine Performance, Fuel Efficiency, and Clean Air, Emissions Technology for Non-Road Applications,
2006, http://bellpower.com/uploads/product_brochures/15_Exp_EmissionsBrochure%20dswt14%5B1%5D.pdf.
Accessed May 2017.
City of Los Angeles 4.12-15 Fig+Pico Conference Center Hotels
SCH No. 2016121063 September 20174. Environmental Impact Analysis 4.12. Energy energy for lighting, heating, cooling, ventilation, and water heating than the prior Title 24 (2013) standards for non-residential uses.33 As specified in PDF AQ-1, the Project would be designed to include numerous energy and waste reduction features that would allow the Project to comply with and exceed the Title 24 standards and achieve greater energy savings than required by state regulations. With respect to operational transportation-related fuel usage, the Project would support statewide efforts to improve transportation energy efficiency and reduce transportation energy consumption with respect to private automobiles. The Project itself would co-locate complementary hotel, retail, and restaurant land uses on the site in close proximity to existing off-site commercial, residential, and retail destinations and in close proximity to existing public transit stops, which would result in reduced vehicle trips and VMT. The Project would be consistent with and support the goals and benefits of the SCAG 2016 RTP/SCS, which seeks improved access and mobility by placing “destinations closer together, thereby decreasing the time and cost of traveling between them”34 (refer to Section 4.4, Greenhouse Gas Emissions, for a detailed discussion regarding the Project’s VMT reduction land use characteristics and consistency with the 2016 RTP/SCS). Therefore, construction and operation of the Project would be consistent with State and federal energy standards and would be designed to include numerous energy and waste saving features as well as waste reduction features that would achieve greater energy savings than required. The Project would also be sited in a transportation-efficient location and achieve reductions in VMT from private automobiles traveling to and from the site consistent with the 2016 RTP/SCS. As a result, impacts would be less than significant. Energy Demand Threshold EN-3: Would the Project cause wasteful, inefficient, or unnecessary consumption of energy during construction or operation? Construction Electricity Electrical power would be consumed to construct the Project. The demand would be supplied from existing electrical services at the Project Site. Overall, demolition and construction activities would require minimal electricity consumption and would not be expected to have any adverse impact on available electricity supplies and infrastructure. The City’s noise ordinance generally restricts construction during nighttime hours (see LAMC Section 41.40 as well as Section 4.8, Noise, of this Draft EIR), which would minimize the need for nighttime lighting. Therefore, impacts on electricity supply and infrastructure associated with short-term construction activities would be less than significant. 33 California Energy Commission, Adoption Hearing, 2016 Building Energy Efficiency Standards, June 10, 2015, http://www.energy.ca.gov/title24/2016standards/rulemaking/documents/2015-06-10_hearing/2015-06- 10_Adoption_Hearing_Presentation.pdf. Accessed May 2017. 34 Southern California Association of Governments, The 2016-2040 Regional Transportation Plan/Sustainable Communities Strategy, April 2016, page 16, http://scagrtpscs.net/Documents/2016/final/f2016RTPSCS.pdf. Accessed May 2017. City of Los Angeles 4.12-16 Fig+Pico Conference Center Hotels SCH No. 2016121063 September 2017
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