City of Culver City, California
Agenda Item Report
Meeting Date: 05/13/13 Item Number: A-1
CITY COUNCIL AGENDA ITEM: (1) Introduction of an Ordinance Amending the
Culver City Municipal Code by Adding a New Chapter 11.16 Relating to Single-Use
Carryout Bags and (2) Adoption of a Resolution Related to the California
Environmental Quality Act (CEQA) Determination Related Thereto.
Contact Person/Dept.: Helen
Kerstein/PW
Phone Number: (310) 253-5618
Fiscal Impact: Yes [] No [X] General Fund: Yes [] No [X]
Public Hearing: [] Action Item: [X] Attachments: [X]
Commission Action Required: Yes [] No [X] Date: _______________
Public Notification: (E-Mail) Agenda and Meetings – City Council (05/07/13); (Mail)
Approx. 72 Potentially Affected Businesses (04/25/13); (Published) Culver City News
(05/02/13); 05/09/13); (Mail) Chamber of Commerce (04/25/13); (Mail) Downtown
Business Association (04/25/13); (Mail) Californians Against Waste (04/25/13); (Mail)
Heal the Bay (04/25/13); (Mail) Seventh Generation Advisors (04/25/13); (Mail) Surfrider
Foundation, West LA/Malibu Chapter (04/25/13); (Mail) Environment California
(04/25/13); (Mail) Clean Water Action/Clean Water Fund (04/25/13); (Mail) American
Chemistry Council; (04/25/13); (Mail) California Grocers Association (04/25/13); (Mail)
Command Packaging (04/25/13); (Mail) Ballona Creek Renaissance (04/25/13); (Mail)
Santa Monica Baykeepers (04/25/13); (E-Mail) Sustainability and Environmental Issues
Listserv (04/25/13); (E-mail or Mail) Attendees at Community Meetings (04/25/13).
Department Approval:
Charles D. Herbertson (05/01/13)
City Attorney Approval:
Carol Schwab and Roland Miranda
(05/07/13)
Chief Financial Officer Approval:
Jeff Muir (05/07/13)
City Manager Approval:
John M. Nachbar (05/07/13)
RECOMMENDATION:
Staff recommends the City Council
1. Introduce an ordinance amending the Culver City Municipal Code by adding a
new Chapter 11.16 relating to single-use carryout bags; and,
2. Adopt a resolution adopting an Addendum to the Los Angeles County Final
Environmental Impact Report (FEIR) and a Statement of Overriding
Considerations.
BACKGROUND:
On December 10, 2012, the City Council directed staff to proceed with drafting a
proposed ordinance similar to Los Angeles County’s Single-Use Carryout Bag
Ordinance, which bans single-use plastic bags and imposes a fee on single-use City of Culver City, California
Agenda Item Report
paper bags. The City Council also authorized staff to retain a consultant to prepare
an Addendum to Los Angeles County’s FEIR and directed staff to work with the
Sustainability Subcommittee (Subcommittee) on the details of the proposed
ordinance and outreach plan.
Consistent with the City Council’s direction, staff met with the Subcommittee on
January 9, 2013. The Subcommittee suggested minor modifications to the Los
Angeles County’s Ordinance and provided input on the public outreach efforts,
including recommending that the Public Works Department hold two public
meetings, post information on the City’s website, and notice interested parties. The
Subcommittee also concurred with staff’s recommendation for retaining a consultant
to prepare the Addendum to Los Angeles County’s FEIR.
Since then, the City Attorney’s Office has drafted the proposed ordinance
(Attachment 1) and the Public Works Department has conducted two public
meetings: one at the Senior Center on April 16 and the other at City Hall on April 20.
At these meetings, there were a number of questions about the content of the
proposed ordinance. Additionally, one attendee at the second meeting expressed
concerns about reusable bag hygiene-issues and potential contributions to store
theft, among other things.|1010| Written comment cards were made available at both
meetings. Two comment cards were submitted: one was supportive and suggested
additional meetings and the other expressed a continued desire for single-use
plastic bags to enable the author to reuse them for lunch bags and other uses.
In addition to the public meetings, the Public Works Department has prepared an
informational page for the City’s website that includes answers to frequently asked
questions and has conducted public notification as shown on the first page of this
report. Finally, the City’s consultant, Rincon Consultants, Inc., has prepared the
Addendum to Los Angeles County’s FEIR (see Attachment 3).
Accordingly, staff is now returning to the City Council to present the proposed
ordinance for consideration as well as for the City Council’s consideration of the
adoption of a proposed resolution certifying an Addendum to the Los Angeles
County FEIR (which includes a Mitigation Monitoring Program) and adopting a
Statement of Overriding Considerations. If the City Council takes these actions
tonight, staff will return at the next available opportunity to request adoption of the
ordinance.
|1010| Hygiene issues associated with reusable bags have been raised by others, most notably in an unpublished
University of Pennsylvania Law School Institute for Law and Economics study titled “Grocery Bag Bans and
Foodborne Illness.” The San Francisco Public Health Officer issued a memo responding to this study and
pointing out some of its limitations. However, regardless of the validity of this study, it is always advisable to
practice good hygiene and to wash bags regularly. It is also desirable to use produce and product bags to
separate unpackaged items like fresh fruit or raw meat and prevent possible cross contamination. City of Culver City, California
Agenda Item Report
DISCUSSION:
The proposed ordinance, included as Attachment 1, proposes to ban the issuance of
plastic single-use carryout bags (excluding product and produce bags) and requires
that covered stores impose a minimum 10 cent charge on each recyclable paper
carryout bag. These charges are retained by the stores. Low income customers
participating in either the Special Supplemental Food Program for Women, Infants,
and Children (WIC) or in the CalFresh/Supplemental Nutrition Assistance Program
(SNAP) are exempted from these charges.
The proposed ordinance covers the following types of stores (approx. 72 retailers in
Culver City are anticipated to meet these criteria):
1. A full-line, self-service retail store with gross annual sales of two million dollars
($2,000,000), or more, that sells a line of dry grocery, canned goods, or non-food
items and some perishable items; or,
2. A store of at least 10,000 square feet of retail space that generates sales or use
tax and that has a pharmacy; or
3. A drug store, pharmacy, supermarket, grocery store, convenience food store,
food mart, or other entity engaged in the retail sale of a limited line of goods that
includes milk, bread, soda, and snack foods, including those stores with a license
issued by the Department of Alcoholic Beverage Control.
In order to allow sufficient time for businesses to use up their existing inventory of
bags and to adjust to the requirements of the proposed ordinance, its
implementation is proposed to be phased in. Larger stores will be given six months
from the effective date of the proposed ordinance (approximately 210 days after the
date of adoption of the proposed ordinance by the City Council) to comply, whereas
smaller stores will be given twelve months from the effective date of the proposed
ordinance (approximately 395 days after the date of adoption of the proposed
ordinance by the City Council).
The proposed ordinance is very similar to the Los Angeles County Ordinance. The
minor modifications that are proposed include:
1) Requiring retailers to post signage clearly indicating the per bag charge for
recyclable paper carryout bags so customers are not surprised by the charges.
2) Replacing the quarterly reporting requirement with a requirement that stores
keep records and make them available to the City upon request. This should
reduce the reporting burden on stores and staff time required for oversight.
3) Specifying a minimum charge of 10 cents rather than a charge of exactly 10
cents. This will allow stores flexibility to charge more than 10 cents for each City of Culver City, California
Agenda Item Report
recyclable paper bag, recognizing that some stores may pay more than 10 cents
for the bags they provide to customers.
4) Enabling the minimum 10 cent charge to be increased by resolution. This
change will make it easier for the City Council to raise the charge if it elects to do
so at a future date (for example, if the minimum 10 cent charge is no longer
effective at achieving the desired reductions in bag use due to inflation or other
factors).
5) Changing the effective date of the proposed ordinance and the account for
depositing fines.
These minor modifications have the support of the Sustainability Subcommittee and
were found in the Addendum to the FEIR to have no impact on the environmental
determination.
ENVIRONMENTAL DETERMINATION:
Los Angeles County developed a comprehensive FEIR (available on the City’s
website) prior to adopting its Ordinance in November 2010. The County’s FEIR
analysis included all 88 incorporated cities in the County as well as the
unincorporated areas, thus facilitating the use of this FEIR as a foundation for the
environmental review supporting similar Ordinances across the County. As Culver
City’s proposed ordinance is based on the County’s Ordinance, the City’s
environmental consultant, Rincon Consultants, Inc., prepared an Addendum to the
County’s FEIR (Attachment 3) pursuant to the California Environmental Quality Act
(CEQA) guidelines.
Culver City’s Addendum analyzes the potential environmental effects related to the
categories identified in the County’s FEIR as having potential to result in significant
environmental impacts: air quality, biological resources, greenhouse gas emissions,
hydrology and water quality, and utilities and service systems. Consistent with the
County’s FEIR, the Addendum determined that there were either less than
significant or beneficial environmental impacts related to air quality, biological
resources, hydrology and water quality utilities and service systems.
With regard to greenhouse gas emissions, the Addendum noted that there is a
potentially significant impact from “end of life” emissions/landfill degradation and
indicated that Mitigation Measure MM-GHG-1 is required. This determination, which
mirrors the determination made in the County’s FEIR, is based on a very
conservative analysis. As the Addendum describes, the greenhouse gas emission
impacts from the project fall well below the South Coast Air Quality Management
District threshold for project level significance (0.058 metric tons vs. 4.8 metric City of Culver City, California
Agenda Item Report
tons).|1010| However, in an abundance of caution and recognizing that the City of Long
Beach faced legal challenges when it deviated from this approach, staff and the
City’s environmental consultant recommend the City Council adopt a resolution
certifying an Addendum to the Los Angeles County FEIR (including a Mitigation
Monitoring Program) and adopting a Statement of Overriding Considerations along
with its introduction of the proposed ordinance.
FISCAL ANALYSIS:
Some staff time will be required for enforcement of the proposed ordinance, which is
anticipated to be undertaken by the Public Works Department. Staff does not
anticipate a large amount of non-compliance and associated enforcement burden.
However, in the event that there are more enforcement issues than expected,
reconsideration of the impact on workload may be necessary. Enforcement is
associated with monetary penalties, which should offset some or all of the additional
costs associated with the enforcement of the proposed ordinance.
ATTACHMENTS:
1. Proposed Ordinance
2. Proposed Resolution
3. Addendum FEIR, including a Mitigation Monitoring Program
MOTIONS:
That the City Council:
1. Introduce an ordinance amending the Culver City Municipal Code adding a
new Chapter 11.16 relating to single-use carryout bags; and,
2. Adopt a resolution certifying an Addendum to the Los Angeles County Final
Environmental Impact Report (FEIR) and adopting a Statement of Overriding
Considerations.
|1010| This threshold had not yet been set at the time of the County’s adoption of its FEIR.
MEETING DATE: 05/13/2013
AGENDA ITEM: Introduction of an Ordinance Adding a New Chapter 11.16
Relating to Single-Use Carryout Bags and Adoption of a
Resolution Related to the California Environmental Quality Act
(CEQA) Determination.
ATTACHMENTS
Pages
1 Ordinance
1 - 6
2 Resolution 7 - 77
3 Addendum FEIR, including Mitigation Monitoring Program 78 - 132
12345678910
FINDINGS OF FACT AND
STATEMENT OF OVERRIDING CONSIDERATIONS
ORDINANCES TO BAN PLASTIC CARRYOUT BAGS IN
LOS ANGELES COUNTY
(SCH # 2009111104)
Prepared For:
County of Los Angeles Department of Public Works
Environmental Programs Division
900 South Fremont Avenue, 3rd Floor
Alhambra, California 91803
Prepared By:
Sapphos Environmental, Inc.
430 North Halstead Street
Pasadena, California 91107
November 3, 2010
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TABLE OF CONTENTS
SECTION PAGE
I. INTRODUCTION..........................................................................................................I-1
I.A Certification .........................................................................................................I-1
I.B Description of Recommended Ordinances / Alternative 5.....................................I-2
I.C Statement of Project Objectives ..........................................................................I-3
I.D Background .........................................................................................................I-3
I.D.1 Contribution of Plastic Carryout Bags to Litter Stream..............................I-3
I.D.2 County Motion.........................................................................................I-5
I.D.2.1 The County’s Solid Waste Management Function in the
Unincorporated County Area................................................I-6
I.D.2.2 The County’s Solid Waste Management Function Countywide....I-6
I.D.3 Carryout Bag Bans and Fees....................................................................I-7
I.E Existing Conditions.............................................................................................I-11
I.E.1 Plastic Carryout Bags............................................................................I-11
I.E.2 Paper Bags............................................................................................I-13
I.E.3 Reusable Bags.........................................................................................I-14
I.E.4 Voluntary Single Use Bag Reduction and Recycling Program ................I-15
I.F EIR Process.........................................................................................................I-16
I.G General Findings..............................................................................................I-17
II. POTENTIAL ENVIRONMENTAL EFFECTS THAT ARE NOT SIGNIFICANT .....................II-1
II.A Aesthetics..........................................................................................................II-1
II.B Agriculture and Forestry Resources....................................................................II-1
II.C Air Quality........................................................................................................II-2
II.D Biological Resources..........................................................................................II-3
II.E Cultural Resources...............................................................................................II-4
II.F Geology and Soils ...............................................................................................II-4
II.G Hazards and Hazardous Materials .......................................................................II-5
II.H Hydrology and Water Quality............................................................................II-5
II.I Land Use and Planning......................................................................................II-6
II.J Mineral Resources...............................................................................................II-6
II.K Noise................................................................................................................II-7
II.L Population and Housing ....................................................................................II-7
II.M Public Services..................................................................................................II-7
II.N Recreation...........................................................................................................II-8
II.O Traffic and Transportation..................................................................................II-8
II.P Utilities and Service Systems ...............................................................................II-9
III. POTENTIAL ENVIRONMENTAL EFFECTS THAT CAN BE MITIGATED
TO BELOW THE LEVEL OF SIGNIFICANCE ................................................................III-1
IV. SIGNIFICANT UNAVOIDABLE ADVERSE IMPACTS THAT CANNOT
BE MITIGATED TO BELOW THE LEVEL OF IGNIFICANCE..........................................IV-1
IV.A Greenhouse Gas Emissions.................................................................................IV-1
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V. FINDINGS REGARDING ALTERNATIVES ....................................................................V-1
V.A No Project Alternative .........................................................................................V-6
V.B Alternative 1: Ban Plastic and Paper Carryout Bags in Los Angeles County...........V-7
V.C Alternative 2: Ban Plastic Carryout Bags and Impose a Fee on Paper Carryout
Bags in Los Angeles County .....................................................................V-8
V.D Alternative 3: Ban Plastic Carryout Bags for All Supermarkets and Other
Grocery Stores, Convenience Stores, Pharmacies, and Drug Stores in
Los Angeles County...............................................................................V-10
V.E Alternative4: Ban Plastic and Paper Carryout Bags for all Supermarkets and
Other Grocery Stores, Convenience Stores, Pharmacies, and
Drug Stores in Los Angeles County ......................................................V-12
V.F Alternative 5: Ban Plastic Carryout Bags and Impose a Fee on Paper Carryout
Bags for All Supermarkets and Other Grocery Stores, Convenience
Stores, Pharmacies, and Drug Stores in Los Angeles County...................V-14
V.G Proposed Ordinances (Originally Proposed Project)...........................................V-16
VI. FINDINGS REGARDING MITIGATION MONITORING PROGRAM............................VI-1
VI.A Requirements of Mitigation Monitoring Program.................................................VI-1
VII. FINDINGS REGARDING LOCATION AND CUSTODIAN OF DOCUMENTS ...............VII-1
VII.A Location and Custodian of Documents...............................................................VII-1
VIII. CERTIFICATION REGARDING INDEPENDENT JUDGMENT .......................................VIII-1
IX. STATEMENT OF OVERRIDING CONSIDERATIONS....................................................IX-1
IX.A Adverse Environmental Risks............................................................................IX-1
IX.B Overriding Considerations................................................................................IX-3
X. FINDINGS ....................................................................................................................X-1
TABLES PAGE
V-1 Ability of the Proposed Ordinances and Alternatives to Attain Project Objectives ..........V-2
V-2 Comparative Analysis of Impacts for the Proposed Ordinances and Alternatives...............V-4
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SECTION I
INTRODUCTION
An Environmental Impact Report (EIR) was prepared by the County of Los Angeles (County) to evaluate
potential environmental effects that would result from the proposed Ordinances to Ban Plastic Carryout
Bags in Los Angeles County (proposed ordinances) and a reasonable range of alternatives. The EIR was
prepared in accordance with the California Environmental Quality Act (CEQA) of 1970, as amended
(California Public Resources Code, Section 21000 et seq.) and State CEQA Guidelines (California Code
of Regulations, Title 14, Section 15000 et seq.). Alternative 5, the recommended Ordinance to Ban
Plastic Carryout Bags and Impose a Fee on Paper Carryout Bags for All Supermarkets and Other
Grocery Stores, Convenience Stores, Pharmacies, and Drug Stores in Los Angeles County
(recommended ordinances), as evaluated in Section 4.2.6 of the EIR (see Section 12.2, Clarifications
and Revisions, of the EIR), was recommended for adoption by the County of Los Angeles Board of
Supervisors.
I.A CERTIFICATION
FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS REGARDING THE
FINAL ENVIRONMENTAL IMPACT REPORT FOR THE ORDINANCES TO BAN PLASTIC CARRYOUT
BAGS IN LOS ANGELES COUNTY (STATE CLEARINGHOUSE NUMBER 2009111104)
The County hereby certifies the EIR for the Ordinances to Ban Plastic Carryout Bags in Los Angeles
County, County of Los Angeles, California, State Clearinghouse Number 2009111104. The EIR consists
of Volume I: Draft EIR, dated June 2010; Volume II: Technical Appendices to the Draft EIR, dated June
2010; and Volume III: Final EIR, dated October 2010. The EIR has been completed in compliance with
the CEQA; the State CEQA Guidelines; the County of Los Angeles General Plan; and all applicable
federal, state, and local statutes and regulations that govern the management of environmental resources.
The County of Los Angeles Board of Supervisors has received, reviewed, and considered the information
contained in the Final EIR, all hearings, and submissions of testimony from officials representing the
County of Los Angeles, as well as from other agencies, organizations, and private individuals with a
particular vested interest in the proposed ordinances.
In accordance with CEQA Guidelines Section 15090, the County of Los Angeles, as lead agency pursuant
to CEQA, certifies the following:
(a) The Final EIR has been completed in compliance with CEQA
(b) The Final EIR was presented to the Board of Supervisors, and the Board of Supervisors, as
the decision-making body for the County of Los Angeles, reviewed and considered the
information contained in the Final EIR prior to approving the project
(c) The Final EIR reflects the County of Los Angeles’s independent judgment and analysis
The County has exercised independent judgment in accordance with Public Resources Code Section
21082.1(c) in retaining its own environmental consultant, directing the consultant in preparation of the
EIR, and reviewing, analyzing, and revising material prepared by the consultant.
These Findings of Fact (Findings) and Statement of Overriding Considerations have been prepared in
accordance with CEQA and the State CEQA Guidelines. The purpose of these Findings is to satisfy the
requirements of Public Resources Code Section 21081 and Title 14 California Code of Regulations
Sections 15090, 15091, 15092, 15093, and 15097 of the State CEQA Guidelines, in connection with the
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approval of an alternative to the proposed ordinance, which is to adopt an ordinance to ban the issuance
of plastic carryout bags and impose a fee or charge on the issuance of paper carryout bags for all
supermarkets and other grocery stores, convenience stores, pharmacies, and drug stores in the County.
Having received, reviewed, and considered the foregoing information, and recommendations of the
County staff, including the Chief Executive Office and the Department of Public Works, as well as any
and all other information in the record, and Section I herein, the County hereby makes Findings
pursuant to and in accordance with Section 21081 of the Public Resources Code as presented in
Sections II through X of these Findings of Fact and Statement of Overriding Considerations.
I.B DESCRIPTION OF RECOMMENDED ORDINANCES / ALTERNATIVE 5
The recommended County ordinance, identified and analyzed as Alternative 5 in the EIR, will ban the
issuance of plastic carryout bags and place a fee or charge on the issuance of paper carryout bags at
certain retail establishments in the unincorporated territories of the County. The County will also
encourage the County’s 88 incorporated cities to adopt similar ordinances. The County provided a
detailed analysis of impacts from adoption of the recommended County ordinance in combination
with adoption of similar ordinances by the 88 incorporated cities in the County in Section 4.2.6 of the
EIR.
The recommended County ordinance aims to significantly reduce the number of carryout bags that are
disposed of or that enter the litter stream by ensuring that certain retail establishments located in the
County will not distribute or make available to customers any plastic carryout bags, including
compostable and biodegradable plastic carryout bags. The recommended County ordinance will ban
the issuance of plastic carryout bags and place a fee or charge on the issuance of paper carryout bags by
any retail establishment, as defined, that is located in the unincorporated territory of the County. The
recommended County ordinance will impose a $0.10 charge (which satisfies the minimum of $0.05
that was studied in Alternative 5 in the EIR) on the issuance of paper carryout bags, which will be
called "recyclable paper carryout bags," and will require that the bags be 100 percent recyclable
overall and contain a minimum of 40 percent post-consumer recycled material, among other criteria.
The recommended ordinance will require a store to provide or make available to a customer only
reusable bags or recyclable paper carryout bags. The recommended ordinance also will encourage
each store to educate its staff to promote reusable bags and to post signs encouraging customers to use
reusable bags.
The retail establishments that will be affected by the recommended ordinance are located within the
unincorporated area of the County and meet the following criteria:
(1) A full-line, self-service retail store with gross annual sales of 2 million dollars
($2,000,000) or more that sells a line of dry grocery, canned goods, or nonfood items
and some perishable items;
(2) A store of at least 10,000 square feet of retail space that generates sales or use tax
pursuant to the Bradley-Burns Uniform Local Sales and Use Tax Law (Part 1.5
(commencing with Section 7200) of Division 2 of the Revenue and Taxation Code) and
that has a pharmacy licensed pursuant to Chapter 9 (commencing with Section 4000)
of Division 2 of the Business and Professions Code; or
(3) A drug store, pharmacy, supermarket, grocery store, convenience food store, foodmart,
or other entity engaged in the retail sale of a limited line of goods that includes milk,
bread, soda, and snack foods, including those stores with a Type 20 or 21 license
issued by the Department of Alcoholic Beverage Control.
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The recommended County ordinance will also include a performance standard for reusable bags,
which among other things, will require reusable bags to have a minimum lifetime of 125 uses and be
machine washable. The recommended County ordinance will also include a phased approach, where
the ordinance will apply to large grocery stores and pharmacies before applying to smaller grocery
stores, convenience stores, and drug stores. The recommended County ordinance also prescribes
procedures so affected retail establishments can report on a quarterly basis the number of recyclable
paper carryout bags provided to customers.
I.C STATEMENT OF PROJECT OBJECTIVES
The County is seeking to substantially reduce the operational cost and environmental degradation
associated with the use of plastic carryout bags in the County, particularly the component of the litter
stream composed of plastic bags, and reduce the associated government funds used for prevention,
clean-up, and enforcement efforts.
The County has identified five goals of the recommended ordinances, listed in order of importance: (1)
litter reduction, (2) blight prevention, (3) coastal waterways and animal and wildlife protection, (4)
sustainability (as it relates to the County’s energy and environmental goals), and (5) landfill disposal
reduction. The ordinance program has six objectives:
• Conduct outreach to all 88 incorporated cities of the County to encourage adoption of
comparable ordinances
• Reduce the Countywide consumption of plastic carryout bags from the estimated 1,600
plastic carryout bags per household in 2007, to fewer than 800 plastic bags per
household in 2013
• Reduce the Countywide contribution of plastic carryout bags to litter that blights public
spaces Countywide by 50 percent by 2013
• Reduce the County’s, cities’, and Flood Control District’s costs for prevention, cleanup,
and enforcement efforts to reduce litter in the County by $4 million
• Substantially increase awareness of the negative impacts of plastic carryout bags and
the benefits of reusable bags, and reach at least 50,000 residents (5 percent of the
population) with an environmental awareness message
• Reduce Countywide disposal of plastic carryout bags in landfills by 50 percent from
2007 annual amounts
The recommended ordinances meet all of these objectives.
I.D BACKGROUND
I.D.1 Contribution of Plastic Carryout Bags to Litter Stream
The California Integrated Waste Management Board (CIWMB) estimates that plastic grocery and other
merchandise bags make up 0.4 percent of California’s overall disposed waste stream by weight, but
have been shown to make a more significant contribution to litter, particularly within catch basins.|1010|
The City of San Francisco Litter Audit in 2008 showed that plastic materials were the second most
1
California Environmental Protection Agency, Integrated Waste Management Board. December 2004. “Table ES-3:
Composition of California’s Overall Disposed Waste Stream by Material Type, 2003.” Contractor’s Report to the Board:
Statewide Waste Characterization Study, p. 6. Produced by: Cascadia Consulting Group, Inc. Berkeley, CA. Available at:
http://www.ciwmb.ca.gov/Publications/default.asp?pubid=1097
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prevalent form of litter, with 4.7 percent of all litter collected being unidentified miscellaneous plastic
litter, and branded plastic retail bags constituting 0.6 percent of the total number of large litter items
collected.|1010| As an example of the prevalence of plastic bag litter found in catch basins, during the Great
Los Angeles River Clean Up, which collected trash from 30 catch basins in the Los Angeles River, it
was observed that 25 percent by weight and 19 percent by volume of the trash collected consisted of
plastic bags.|1010| Results of a California Department of Transportation (Caltrans) study of catch basins
alongside freeways in Los Angeles indicated that plastic film composed 7 percent by mass and 12
percent by volume of the total trash collected.
4
County Flood Control District staff have photographed
carryout bags in the catch basins and storm drains.|1010| According to research conducted by the Los
Angeles County Department of Public Works (LACDPW), approximately 6 billion plastic carryout bags
are consumed in the County each year, which is equivalent to approximately 1,600 bags per
household per year.
6,7,8
Public agencies in California spend more than $375 million each year for litter
prevention, cleanup, and disposal.|10 10| The County of Los Angeles Flood Control District alone spends
more than $18 million annually for prevention, cleanup, and enforcement efforts to reduce litter.
10,11,12,13
In 2008–2009, the most recent data available, the County Flood Control District spent over $24
million on these activities.
14
2
City of San Francisco, San Francisco Environment Department. 2008. The City of San Francisco Streets Litter Re-audit.
Prepared by: HDR; Brown, Vence & Associates, Inc.; and MGM Management Environmental and Management Service.
San Francisco, CA. Available at: http://www.sfenvironment.org/downloads/library/2008_litter_audit.pdf
3
City of Los Angeles. 18 June 2004. Characterization of Urban Litter. Prepared by: Ad Hoc Committee on Los Angeles
River and Watershed Protection Division. Los Angeles, CA. |1010| Combs, Suzanne, John Johnston, Gary Lippner, David Marx, and Kimberly Walter. 2001. Results of the Caltrans Litter
Management Pilot Study. Sacramento, CA: California Department of Transportation. Available at:
http://www.owp.csus.edu/research/papers/papers/PP020.pdf |1010| County of Los Angeles. 2010. Photographs of Catch Basins in Los Angeles County provided to Sapphos Environmental,
Inc. by the County of Los Angeles Flood Control District. Available for viewing at Sapphos Environmental, Inc.
Headquarters, Pasadena, CA.
6
California Integrated Waste Management Board. 12 June 2007. Board Meeting Agenda, Resolution: Agenda Item 14.
Sacramento, CA. |1010| U.S. Census Bureau. 2000. “State & County Quick Facts: Los Angeles County, California.” Available at:
http://quickfacts.census.gov/qfd/states/06/06037.html |1010| At an average of slightly fewer than three persons per household.
9
California Department of Transportation. Accessed on: September 2009. “Facts at a Glance.” Don’t Trash California.
Available at: http://www.donttrashcalifornia.info/pdf/Statistics.pdf
10
Los Angeles County Municipal Storm Water Permit (Order 01-182) Individual Annual Report Form. October 2009.
Available at: http://dpw.lacounty.gov/wmd/NPDESRSA/AnnualReport/2009/Appendix%20D%20-
%20Principal%20Permittee%20Annual%20Report/Principal%20Permittee%20Annual%20Report.pdf
11
Los Angeles County Municipal Storm Water Permit (Order 01-182) Individual Annual Report Form. October 2008.
Available at: http://dpw.lacounty.gov/wmd/NPDESRSA/AnnualReport/2008/Appendix%20D%20-
%20Principal%20Permittee%20Annual%20Report/Principal%20Permittee%20&%20County%20Annual%20Report%20
FY07-08.pdf
12
Los Angeles County Municipal Storm Water Permit (Order 01-182) Individual Annual Report Form. October 2007.
Available at: http://dpw.lacounty.gov/wmd/NPDESRSA/AnnualReport/2007/Appendix%20D%20-
%20Principal%20Permittee%20Annual%20Report/Annual%20Rpt%2006-07.pdf
13
Los Angeles County Municipal Storm Water Permit (Order 01-182) Individual Annual Report Form. October 2006.
Available at: http://dpw.lacounty.gov/wmd/NPDESRSA/AnnualReport/2006/Appendix%20D%20-
%20Principal%20Permittee%20Annual%20Report/PrincipalPermittee_AnnualReportFY05-06.pdf
14
Los Angeles County Municipal Storm Water Permit (Order 01-182) Individual Annual Report Form. October 2009.
Available at: http://dpw.lacounty.gov/wmd/NPDESRSA/AnnualReport/2009/Appendix%20D%20-
%20Principal%20Permittee%20Annual%20Report/Principal%20Permittee%20Annual%20Report.pdf
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In addition, the County has obtained survey data from employees at solid waste facilities within the
County that indicate that plastic carryout bags pose serious operational problems for landfills.
15
All
survey respondents stated that plastic carryout bags cause serious litter issues due to their lightweight
nature and propensity to become airborne.
16
Each survey respondent indicated that it was costly and
time consuming to provide cleanup crews to address the plastic bag litter problem in neighborhoods in
County unincorporated and incorporated areas that are adjacent to the landfills.
17
I.D.2 County Motion
On April 10, 2007, the County Board of Supervisors instructed the County Chief Administrative Officer to
work with the Director of Internal Services and the Director of Public Works to solicit input from outside
environmental protection and grocer organizations related to three areas and report their findings and
accomplish the following:
1. Investigate the issue of polyethylene plastic and paper sack consumption in the County,
including the pros and cons of adopting a policy similar to that of San Francisco;
2. Inventory and assess the impact of the current campaigns that urge recycling of paper
and plastic sacks; and
3. Report back to the Board of Supervisors on findings and recommendations to reduce
grocery and retail sack waste, any impact an ordinance similar to the one proposed in
San Francisco would have on recycling efforts in Los Angeles County, and any
unintended consequences of the ordinance.
18,19
In response to the directive of the Board of Supervisors, the LACDPW prepared and submitted a staff
report, An Overview of Carryout Bags in Los Angeles County, (LACDPW Report) in August 2007.
20
The LACDPW Report made four key findings:
1. Plastic carryout bags have been found to significantly contribute to litter and
have other negative impacts on marine wildlife and the environment.
2. Biodegradable carryout bags are not a practical solution to this issue in the
County because there are no local commercial composting facilities able to
process the biodegradable carryout bags at this time.
3. Reusable bags contribute toward environmental sustainability over plastic and
paper carryout bags.
15
County of Los Angeles Department of Public Works. 2007. Survey: All Solid Waste Facilities: Plastic Bag Analysis for
the County of Los Angeles. Los Angeles, CA.
16
County of Los Angeles Department of Public Works. 2007. Survey: All Solid Waste Facilities: Plastic Bag Analysis for
the County of Los Angeles. Los Angeles, CA.
17
County of Los Angeles Department of Public Works. 2007. Survey: All Solid Waste Facilities: Plastic Bag Analysis for
the County of Los Angeles. Los Angeles, CA.
18
County of Los Angeles Board of Supervisors. 10 April 2007. Board of Supervisors Motion. Los Angeles, CA.
19
County of Los Angeles, Department of Public Works, Environmental Programs Division. August 2007. An Overview of
Carryout Bags in Los Angeles County: A Staff Report to the Los Angeles County Board of Supervisors. Alhambra, CA.
Available at: http://dpw.lacounty.gov/epd/PlasticBags/PDF/PlasticBagReport_08-2007.pdf
20
County of Los Angeles, Department of Public Works, Environmental Programs Division. August 2007. An Overview of
Carryout Bags in Los Angeles County: A Staff Report to the Los Angeles County Board of Supervisors. Alhambra, CA.
Available at: http://dpw.lacounty.gov/epd/PlasticBags/PDF/PlasticBagReport_08-2007.pdf
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4. Accelerating the widespread use of reusable bags will diminish plastic bag
litter and redirect environmental preservation efforts and resources toward
“greener” practices.
21
I.D.2.1 The County's Solid Waste Management Function in the Unincorporated County Area
The County is responsible for numerous solid waste management functions throughout the County,
pursuant to the California Integrated Waste Management Act of 1989 [Assembly Bill (AB) 939].
22
• Implements source reduction and recycling programs in the unincorporated
County areas to comply with the State of California’s 50-percent waste reduction
mandate. In 2004, the County was successful in documenting a 53-percent waste
diversion rate for the unincorporated County areas.
• Operates seven Garbage Disposal Districts providing solid waste collection,
recycling, and disposal services for over 300,000 residents.
• Implements and administers a franchise solid waste collection system which, once
fully implemented, will provide waste collection, recycling, and disposal services to
over 700,000 residents, and will fund franchise area outreach programs to enhance
recycling and waste reduction operations in unincorporated County areas that
formerly operated under an open market system.
I.D.2.2 The County's Solid Waste Management Function Countywide
• Implements a variety of innovative Countywide recycling programs, including:
Smart Gardening to teach residents about backyard composting and water wise
gardening; Waste Tire Amnesty for convenient waste tire recycling; the
convenient Environmental Hotline and Environmental Resources Internet
Outreach Program; interactive Youth Education/Awareness Programs; and the
renowned Household Hazardous/Electronic Waste Management and Used Oil
Collection Programs.
• Prepares and administers the Countywide Siting Element, which is a planning
document that provides for the County’s long-term solid waste management
disposal needs.
• Administers the Countywide Integrated Waste Management Summary Plan
which describes how all 89 of the jurisdictions Countywide, acting
independently and collaboratively, are complying with the State’s waste
reduction mandate.
• Provides staff for the Los Angeles County Solid Waste Management Task Force
(Task Force). The Task Force is comprised of appointees from the League of
California Cities, the County Board of Supervisors, the City of Los Angeles,
solid waste industries, environmental groups, governmental agencies, and the
private sector. The County performs the following Task Force functions:
Reviews all major solid waste planning documents prepared by all 89
jurisdictions prior to their submittal to the California Integrated Waste
Management Board;
21
County of Los Angeles, Department of Public Works, Environmental Programs Division. August 2007. An Overview of
Carryout Bags in Los Angeles County: A Staff Report to the Los Angeles County Board of Supervisors, p. 1. Alhambra, CA.
Available at: http://dpw.lacounty.gov/epd/PlasticBags/PDF/PlasticBagReport_08-2007.pdf
22
California State Assembly. Assembly Bill 939, “Integrated Waste Management Act,” Chapter 1095.
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Assists the Task Force in determining the levels of needs for solid waste
disposal, transfer and processing facilities; and
Facilitates the development of multi-jurisdictional marketing strategies
for diverted materials.
23
I.D.3 Carryout Bag Bans and Fees
The State of California considered placing a ban on the issuance of plastic carryout bags under AB
1998. There are currently four local governments in California that have imposed bans on plastic
carryout bags: City and County of San Francisco, City of Malibu, Town of Fairfax, and City of Palo
Alto. In addition, there is a plastic carryout bag fee ordinance in effect in the District of Columbia.
Assembly Bill 1998
AB 1998 was introduced in February 2010 to prohibit convenience food stores, foodmarts, and certain
specified stores in California from providing plastic carryout bags to customers. Originally, the bill
would have required a store, beginning on July 1, 2011, to provide only reusable bags, as defined, or
to make recycled paper bags available for sale at a reasonable cost, but not for less than $0.25. AB
1998 would have preempted local regulations on the use and sales of reusable bags, plastic carryout
bags, and recycled paper bags. AB 1998 underwent revisions throughout the legislative process that
changed certain provisions in the bill, including changing the $0.25 fee to the actual average cost of
the recycled paper bag provided to the consumer, rounded to the nearest penny.
24
Supporters of the
bill included Californians Against Waste, Heal the Bay, California Grocers Association, California
League of Conservation Voters, over 20 California cities, Communities for a Better Environment, the
County of Los Angeles and five other California counties, Environment California, certain paper and
plastic bag manufacturers, and a number of other environmental, business, and commerce groups.
25
Opposers of AB 1998 included the American Chemistry Council and two plastic bag manufacturers
(Crown Poly, Inc. and Command Packaging) who, as part of the Save the Plastic Bag Coalition, sued
the County over its voluntary Single Use Bag Reduction and Recycling Program. In August 2010, the
American Chemistry Council, Exxon, and Hilex Poly Co., a South Carolina–based bag manufacturer,
made a series of campaign donations to certain California lawmakers.
26
AB 1998 failed to achieve the
number of votes required to pass the State Senate on August 31, 2010, and is currently not under
consideration in California.
City and County of San Francisco
The City and County of San Francisco adopted an ordinance to ban non-compostable plastic carryout
bags, which became effective on November 20, 2007.
27
This ordinance, known as the Plastic Bag
23
County of Los Angeles, Department of Public Works, Environmental Programs Division. August 2007. An Overview of
Carryout Bags in Los Angeles County: A Staff Report to the Los Angeles County Board of Supervisors, Preface. Alhambra,
CA. Available at: http://dpw.lacounty.gov/epd/PlasticBags/PDF/PlasticBagReport_08-2007.pdf
24
Assembly Bill No. 1998. Amended in Senate August 27, 2010. Available at: http://www.leginfo.ca.gov/pub/09-
10/bill/asm/ab_1951-2000/ab_1998_bill_20100827_amended_sen_v94.pdf
25
Californians Against Waste. Accessed on: October 2010. AB 1998 (Brownley): Plastic Bag Ban. Available at:
http://www.cawrecycles.org/issues/current_legislation/ab1998_10
26
Ferriss, Susan. 26 August 2010. “Plastic-bag backers donate to California lawmakers ahead of bill’s vote.” The
Sacramento Bee. Available at: http://www.sacbee.com/2010/08/26/2983643/plastic-bag-backers-donate-to.html
27
City and County of San Francisco. “Plastic Bag Reduction Ordinance.” Web site. Available at:
http://www.sfgov.org/site/sf311csc_index.asp?id=71355
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Reduction Ordinance, stipulates that all stores shall provide only the following as checkout bags to
customers: recyclable paper bags, compostable plastic carryout bags, and/or reusable bags.
28
The
ordinance further defines stores as a retail establishment located within the geographical limits of the
City and County of San Francisco that meets either of the following requirements:
(1) A full-line, self-service supermarket with gross annual sales of 2 million dollars
($2,000,000) or more, which sells a line of dry grocery, canned goods, or nonfood
items and some perishable items. For purposes of determining which retail
establishments are supermarkets, the City shall use the annual updates of the
Progressive Grocer Marketing Guidebook and any computer printouts developed in
conjunction with the guidebook.
(2) A retail pharmacy with at least five locations under the same ownership within the
geographical limits of San Francisco.
Since adoption of the ordinance, initial feedback from the public has been positive and the use of
reusable bags has increased.
29
There have been no reported negative public health issues (salmonella,
e. coli, food poisoning, etc.) related to the increased use of reusable bags.
30
As a result of the
ordinance, San Francisco has not noted an increase in the number of waste discharge permits or air
quality permits required for paper bag manufacturing in the district, nor has there been a noticeable
increase in traffic congestion in proximity to major supermarkets due to increased paper bag delivery
trucks.
31
San Francisco has also not noticed any increase in eutrophication in waterways due to
increased use of paper bags.
32
San Francisco has not noted any adverse environmental impacts due to
paper carryout bag manufacturing, because there are no facilities located in San Francisco that
manufacture paper carryout bags.
Although no studies have been performed to document the potential impacts of the ordinance upon
plastic carryout bag litter in storm drains, field personnel from the San Francisco Public Utilities
Commission have noted a reduction in the amount of plastic carryout bags in catch-basins and have
noted that fewer bags are now being entangled in equipment, which can often slow or stop work in
the field.
33
City of Malibu
On May 27, 2008, the City of Malibu adopted an ordinance banning plastic carryout bags: Chapter
9.28.020, Ban on Shopping Bags, provides that no affected retail establishment, restaurant, vendor or
nonprofit vendor shall provide plastic bags or compostable plastic bags to customers.
34
Further, this
28
San Francisco Environment Code, Chapter 17, Section 1703.
29
Galbreath, Rick, County of San Francisco, California. 10 May 2010. Telephone conversation with Angelica SantaMaría,
County of Los Angeles, Department of Public Works, Alhambra, California.
30
Galbreath, Rick, County of San Francisco, California. 10 May 2010. Telephone conversation with Angelica SantaMaría,
County of Los Angeles, Department of Public Works, Alhambra, California.
31
Galbreath, Rick, County of San Francisco, California. 10 May 2010. Telephone conversation with Angelica SantaMaría,
County of Los Angeles, Department of Public Works, Alhambra, California.
32
Galbreath, Rick, County of San Francisco, California. 10 May 2010. Telephone conversation with Angelica SantaMaría,
County of Los Angeles, Department of Public Works, Alhambra, California.
33
Hurst, Karen, San Francisco Public Utilities Commission, California. 18 May 2010. Telephone conversation with Luke
Mitchell, County of Los Angeles, Department of Public Works, Alhambra, California.
34
Malibu Municipal Code, Title 9, “Public Peace and Welfare,” Chapter 9.28, “Ban on Shopping Bags,” Section 9.28.020.
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same section of the ordinance prohibits any person from distributing plastic carryout bags or
compostable plastic carryout bags at any City facility or any event held on City property.
Since the adoption of this ordinance, the City of Malibu has noted a generally positive reaction from
the public and an increase in the use of reusable bags.
35
City of Palo Alto
On March 30, 2009, the City of Palo Alto adopted an ordinance banning plastic carryout bags: Chapter
5.35 of Title 5, Health and Sanitation, of the Palo Alto Municipal Code provides that all supermarkets
in the City of Palo Alto will only provide reusable bags and/or recyclable paper bags. Retail
establishments in the City of Palo Alto are required to provide paper bags either as the only option for
customers, or alongside the option of plastic bags.
36
If the retail establishment offers a choice between
paper and plastic, the ordinance requires that the customer be asked whether he or she requires or
prefers paper bags or plastic bags.
37
All retail establishments and supermarkets were to comply with
the requirements of this ordinance by September 18, 2009.
Since the adoption of this ordinance, the City of Palo Alto has received a mostly positive reaction from
the public. Due to the lack of available baseline data and the fact that the ordinance is relatively
recent, the City of Palo Alto has not been able to quantify the potential increase in use of reusable
bags.
38
Town of Fairfax
The Town of Fairfax, pursuant to Ordinance No. 722, requires that all stores, shops, eating places, and
retail food vendors, as defined, shall provide only recyclable paper bags, reusable bags, or
compostable plastic bags as checkout bags to customers at the point of sale.
39
With respect to
compostable plastic bags, the ordinance indicates, “because of the ongoing threat that compostable
plastic bags pose to marine life, the permitted continued use of compostable plastic bags under Section
4 (a) shall be terminated by operation of law, three years from the date of passage of this ordinance.”
40
District of Columbia
The District of Columbia adopted an ordinance that became effective on September 23, 2009, to
implement the provisions of the Anacostia River Clean Up and Protection Act of 2009. The ordinance
stipulates that a retail establishment shall charge each customer making a purchase from the
establishment a fee of $0.05 for each disposable carryout bag provided to the customer with the
purchase.
41
35
Nelson, Rebecca, City of Malibu Department of Public Works, Malibu, California. 22 April 2010. Telephone
conversation with Angelica SantaMaría, County of Los Angeles, Department of Public Works, Alhambra, California.
36
Palo Alto Municipal Code, Title 5, “Health and Sanitation,” Chapter 5.35, Section 5.35.020.
37
Palo Alto Municipal Code, Title 5, “Health and Sanitation,” Chapter 5.35, Section 5.35.020.
38
Bobel, Phil, City of Palo Alto Department of Public Works, Palo Alto, California. 22 April 2010. Telephone
conversation with Angelica SantaMaría, County of Los Angeles, Department of Public Works, Alhambra, California.
39
Town of Fairfax. Ordinance No. 722, Section 18.18.080. 1 August 2007. Available at:
http://www.stopwaste.org/docs/fairfax_plastic_bag_ordinance.pdf
40
Town of Fairfax. Ordinance No. 722. 1 August 2007. Available at:
http://www.stopwaste.org/docs/fairfax_plastic_bag_ordinance.pdf
41
District of Columbia Municipal Regulations, Title 21, Chapter 10, “Retail Establishment Carryout Bags,” Section 1001.
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The tax, one of the first of its kind in the nation, is designed to change consumer behavior and limit
pollution in the Chesapeake Bay watershed.
42
Under regulations created by the District of Columbia
Department of the Environment, bakeries, delicatessens, grocery stores, pharmacies, and convenience
stores that sell food, as well as restaurants and street vendors, liquor stores and "any business that sells
food items," must charge the tax on paper or plastic carryout bags. The ordinance also regulates
disposable carryout bags used by retail establishments.
Since the adoption of this ordinance, the District of Columbia has seen a marked decrease in the
number of bags consumed. In its first assessment of the new law, the District of Columbia Office of
Tax and Revenue estimates that city food and grocery establishments issued about 3.3 million bags in
January, which suggests a significant decrease.
43
Prior to the bag tax taking effect on January 1, 2010,
the Office of the Chief Financial Officer had estimated that approximately 22.5 million bags were
being issued per month in 2009.
44
Efforts Outside of the United States
American Samoa
American Samoa is the first United States territory to ban plastic shopping bags. The law, signed by
Governor Togiola Tulafono, takes effect February 23, 2011. The U.S. Environmental Protection
Agency’s (USEPA’s) regional administrator for the Pacific Southwest (Mr. Jared Blumenfeld) recently
stated, “we welcome American Samoa’s leadership in the Pacific islands to ban plastic shopping bags.
This action will decrease the amount of plastic waste in the territory and directly protect marine and
bird life in the Pacific.”
45
The USEPA notes that other countries that have banned free plastic bags
include China, Bangladesh, Australia, Italy, South Africa, Ireland, and Taiwan.
Denmark
In 1994, Denmark levied a tax on suppliers of both paper and plastic carryout bags. Denmark
experienced an initial reduction of 60 percent in total use of disposable bags, with a slight increase in
this rate over time.
46
Ireland
In 2002, Ireland levied a nationwide tax on plastic shopping bags that is paid directly by consumers.
Known as the “PlasTax,” the 0.15-euro levy is applied at the point-of-sale to retailers and is required to
be passed on directly to the consumer as an itemized line on any invoice. The PlasTax applies to all
plastic carryout bags, including biodegradable polymer bags. It does not apply to bags for fresh
42
Craig, Tim. 29 March 2010. “Bag tax raises $150,000, but far fewer bags used.” The Washington Post. Available at:
http://voices.washingtonpost.com/dc/2010/03/bag_tax_raises_150000_but_far.html?wprss=dc
43
Craig, Tim. 29 March 2010. “Bag tax raises $150,000, but far fewer bags used.” The Washington Post. Available at:
http://voices.washingtonpost.com/dc/2010/03/bag_tax_raises_150000_but_far.html?wprss=dc
44
Craig, Tim. 29 March 2010. “Bag tax raises $150,000, but far fewer bags used.” The Washington Post. Available at:
http://voices.washingtonpost.com/dc/2010/03/bag_tax_raises_150000_but_far.html?wprss=dc
45
U.S. Environmental Protection Agency. 30 September 2010. Press Release: “U.S. EPA applauds American Samoa’s
decision to ban plastic shopping bags.” Available at:
http://yosemite.epa.gov/opa/admpress.nsf/0/921A87D72D9AAFC1852577AE007394F1
46
GHK Ltd. May 2007. The Benefits and Effects of the Plastic Shopping Bag Charging Scheme. Prepared for:
Environmental Protection Department, Hong Kong, China.
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produce, reusable bags sold for 0.70+ euro, or to bags holding goods sold on board a ship or plane or
in an area of a port or airport exclusive to intended passengers.
47
After implementation of the PlasTax, plastic carryout bag usage in Ireland initially declined 90 to 95
percent, and subsequently leveled off closer to 75 percent of the original value.
48,49
Australia
The Environmental Protection and Heritage Council in Australia has been very active in attempting to
reduce plastic carryout bag use. Retailers support carryout bag reductions via a voluntary “Retailers
Code.” As a result, from 2002 to 2005, plastic carryout bag use fell from 5.95 billion bags to 3.92
billion bags, and then fell again to 3.36 billion bags in 2006, which represents a 44-percent decrease
over four years from voluntary activities. However, consumption of plastic carryout bags rose back up
to 3.93 billion bags in 2007, a 17-percent increase from 2006.
50
Taiwan
In 2003, the Taiwanese government set a direct charge to consumers as part of a wider waste-reduction
initiative. The charge resulted in a 68-percent reduction in plastic carryout bag use; however, there
was also a significant rate of conversion to paper bags and alternative bags. The initial ban on thin
plastic carryout bags was withdrawn from application to storefront restaurants following an increase in
total plastic use and problems with compliance.
51
I.E EXISTING CONDITIONS
I.E.1 Plastic Carryout Bags
In 1977, supermarkets began offering to customers plastic carryout bags designed for single use, and
by 1996, four out of every five grocery stores were using plastic carryout bags.
52,53,54,55
Since then,
plastic carryout bags have been found to contribute substantially to the litter stream and to have
47
Nolan-ITU Pty Ltd., et al. December 2002. Environment Australia: Department of the Environment and Heritage:
Plastic Shopping Bags –Analysis of Levies and Environmental Impacts: Final Report, p.21. Sydney, Australia.
48
Cadman, James, Suzanne Evans, Mike Holland and Richard Boyd. August 2005. Proposed Plastic Bag Levy -- Extended
Impact Assessment: Volume 1: Main Report: Final Report, p.7. Edinburgh, Scotland: Scottish Executive.
49
GHK Ltd. May 2007. The Benefits and Effects of the Plastic Shopping Bag Charging Scheme. Prepared for:
Environmental Protection Department, Hong Kong, China.
50
Environment Protection and Heritage Council. April 2008. Decision Regulatory Impact Statement: Investigation of
options to reduce the impacts of plastic bags. Adelaide, Australia.
51
GHK Ltd. May 2007. The Benefits and Effects of the Plastic Shopping Bag Charging Scheme. Prepared for:
Environmental Protection Department, Hong Kong, China.
52
SPI: The Plastics Industry Trade Association. 2007. Web site. Available at: http://www.plasticsindustry.org/
53
County of Los Angeles, Department of Public Works, Environmental Programs Division. August 2007. An Overview of
Carryout Bags in Los Angeles County: A Staff Report to the Los Angeles County Board of Supervisors. Alhambra, CA.
Available at: http://dpw.lacounty.gov/epd/PlasticBags/PDF/PlasticBagReport_08-2007.pdf
54
SPI: The Plastics Industry Trade Association. 2007. Web site. Available at: http://www.plasticsindustry.org/
55
County of Los Angeles, Department of Public Works, Environmental Programs Division. August 2007. An Overview of
Carryout Bags in Los Angeles County: A Staff Report to the Los Angeles County Board of Supervisors. Alhambra, CA.
Available at: http://dpw.lacounty.gov/epd/PlasticBags/PDF/PlasticBagReport_08-2007.pdf
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adverse effects on marine wildlife.
56,57,58,59,60,61
The prevalence of litter from plastic bags in the urban
environment also compromises the efficiency of systems designed to channel storm water runoff.
Furthermore, plastic bag litter leads to increased cleanup costs for the County, Caltrans, and other
public agencies.
62,63,64
Plastic bag litter also contributes to environmental degradation and degradation
of the quality of life for County residents and visitors.
65
In particular, the prevalence of plastic bag litter
in the storm water system and coastal waterways hampers the ability of, and exacerbates the cost to,
local agencies to comply with the National Pollution Discharge Elimination System and total maximum
daily loads limits (TMDLs) for trash, pursuant to the federal Clean Water Act (CWA).
66,67
The CIWMB estimates that approximately 3.9 percent of plastic waste can be attributed to plastic
carryout bags used for grocery and other merchandise, which represents approximately 0.4 percent of
the total waste stream in California.
68,69
Several organizations have studied the effects of plastic litter:
Caltrans conducted a study on freeway storm water litter;
70
the Friends of Los Angeles River conducted
56
United Nations Environment Programme. April 2009. Marine Litter: A Global Challenge. Nairobi, Kenya. Available at :
http://www.unep.org/regionalseas/marinelitter/publications/docs/Marine_Litter_A_Global_Challenge.pdf
57
California Integrated Waste Management Board. 12 June 2007. Board Meeting Agenda, Resolution: Agenda Item 14.
Sacramento, CA.
58
County of Los Angeles, Department of Public Works, Environmental Programs Division. August 2007. An Overview of
Carryout Bags in Los Angeles County: A Staff Report to the Los Angeles County Board of Supervisors. Alhambra, CA.
Available at: http://dpw.lacounty.gov/epd/PlasticBags/PDF/PlasticBagReport_08-2007.pdf
59
Bjorndal, K. et al. 1994. “Ingestion of marine debris by juvenile sea turtles in coastal Florida habitats.” In Marine
Pollution Bulletin, 28 (3). Available at:
http://accstr.ufl.edu/publications/BjorndalEtAl_1994_IngestionOfMarineDebrisByJuvenileSeaTurtlesInCostalFlorida.pdf
60
Okeanos Ocean Research Foundation. 1989. Marine Mammal and Sea Turtle Encounters with Marine Debris in the
New York Bight and the Northeast Atlantic. Available at: http://swfsc.noaa.gov/publications/TM/SWFSC/NOAA-TM-
NMFS-SWFSC-154_P562.PDF
61
Gomer ci c, H. et al. European Journal of Wildlife Research. 2006. “Biological aspects of Cuvier’s beaked whale
(Ziphius cavirostris) recorded in the Croation part of the Adriatic Sea.” DOI 10.1007/s10344-006-0032-8
62
California Integrated Waste Management Board. 12 June 2007. Board Meeting Agenda, Resolution: Agenda Item 14.
Sacramento, CA.
63
County of Los Angeles, Department of Public Works, Environmental Programs Division. August 2007. An Overview of
Carryout Bags in Los Angeles County: A Staff Report to the Los Angeles County Board of Supervisors. Alhambra, CA.
Available at: http://dpw.lacounty.gov/epd/PlasticBags/PDF/PlasticBagReport_08-2007.pdf
64
Combs, Suzanne, John Johnston, Gary Lippner, David Marx, and Kimberly Walter. 1998–2000. Caltrans Litter
Management Pilot Study. Sacramento, CA: California Department of Transportation.
65
Keep America Beautiful. Accessed on: 19 October 2010. Litter Prevention. Available at:
http://www.kab.org/site/PageServer?pagename=focus_litter_prevention
66
United States Code, Title 33, Section 1313, “Water Quality Standards and Implementation Plans.” Clean Water Act,
Section 303(d).
67
County of Los Angeles, Department of Public Works, Environmental Programs Division. August 2007. An Overview of
Carryout Bags in Los Angeles County: A Staff Report to the Los Angeles County Board of Supervisors. Alhambra, CA.
Available at: http://dpw.lacounty.gov/epd/PlasticBags/PDF/PlasticBagReport_08-2007.pdf
68
California Environmental Protection Agency, Integrated Waste Management Board. December 2004. “Table ES-3:
Composition of California’s Overall Disposed Waste Stream by Material Type, 2003.” Contractor’s Report to the Board:
Statewide Waste Characterization Study, p. 6. Produced by: Cascadia Consulting Group, Inc. Berkeley, CA. Available at:
http://www.ciwmb.ca.gov/Publications/default.asp?pubid=1097
69
Note: Plastics make up approximately 9.5 percent of California’s waste stream by weight, including 0.4 percent for
plastic carryout bags related to grocery and other merchandise, 0.7 percent for non-bag commercial and industrial
packaging film, and 1 percent for plastic trash bags.
70
Combs, Suzanne, John Johnston, Gary Lippner, David Marx, and Kimberly Walter. 1998–2000. Caltrans Litter
Management Pilot Study. Sacramento, CA: California Department of Transportation.
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a waste characterization study of the Los Angeles River;
71
the City of Los Angeles conducted a waste
characterization study on 30 storm drain basins;
72
and LACDPW conducted a trash reduction and a
waste characterization study of street sweeping and trash capture systems near and within the
Hamilton Bowl, located in Long Beach, California.
73
These studies concluded that plastic film
(including plastic bag litter) composed between 7 to 30 percent by mass and between 12 to 34 percent
by volume of the total litter collected. Despite the implementation of best management practices,
installation of litter control devices such as cover fences for trucks, catch basins, and facilities to
prevent airborne bags from escaping, and despite the use of roving patrols to pick up littered bags,
plastic bag litter remains prevalent throughout the County.
74
AB 2449 requires all supermarkets
(grocery stores with more than $2 million in annual sales) and retail businesses of at least 10,000
square feet with a licensed pharmacy to establish a plastic carryout bag recycling program at each
store. Starting on July 1, 2007, each store must provide a clearly marked bin that is easily available for
customers to deposit plastic carryout bags for recycling. The stores’ plastic bags must display the
words “please return to a participating store for recycling.”
75
In addition, the affected stores must make
reusable bags available to their patrons. These bags can be made of cloth, fabric, or plastic with a
thickness of 2.25 mils or greater.
76
The stores are allowed to charge their patrons for reusable bags.
77
Store operators must maintain program records for a minimum of three years and make the records
available to the local jurisdiction.
78
I.E.2 Paper Bags
The production, distribution, and disposal of paper carryout bags also have known adverse effects on
the environment.
79,80
There is a considerable amount of energy that is used, trees that are felled, and
pollution that is generated in the production of paper carryout bags.
81,82
The CIWMB determined in
the 2004 Statewide Waste Characterization Study that approximately 117,000 tons of paper carryout
bags are disposed of each year by consumers throughout the County. This amount accounts for
71
Friends of the Los Angeles River and American Rivers. 2004. Great Los Angeles River. Los Angeles and Nevada City, CA.
72
City of Los Angeles, Sanitation Department of Public Works. June 2006. Technical Report: Assessment of Catch Basin
Opening Screen Covers. Los Angeles, CA.
73
County of Los Angeles, Department of Public Works, Environmental Programs Division. August 2007. An Overview of
Carryout Bags in Los Angeles County: A Staff Report to the Los Angeles County Board of Supervisors. Alhambra, CA.
Available at: http://dpw.lacounty.gov/epd/PlasticBags/PDF/PlasticBagReport_08-2007.pdf
74
County of Los Angeles, Department of Public Works, Environmental Programs Division. August 2007. An Overview of
Carryout Bags in Los Angeles County: A Staff Report to the Los Angeles County Board of Supervisors. Alhambra, CA.
Available at: http://dpw.lacounty.gov/epd/PlasticBags/PDF/PlasticBagReport_08-2007.pdf
75
Public Resources Code, Section 42250–42257. 2006. Assembly Bill 2449.
76
Public Resources Code, Section 42250–42257. 2006. Assembly Bill 2449.
77
Public Resources Code, Section 42250–42257. 2006. Assembly Bill 2449.
78
California Integrated Waste Management Board. 12 June 2007. Board Meeting Agenda, Resolution: Agenda Item 14.
Sacramento, CA.
79
County of Los Angeles, Department of Public Works, Environmental Programs Division. October 2008. County of Los
Angeles Single Use Bag Reduction and Recycling Program – Program Resource Packet. Alhambra, CA.
80
Green Cities California. March 2010. Master Environmental Assessment on Single-Use and Reusable Bags. Prepared by
ICF International. San Francisco, CA.
81
County of Los Angeles Board of Supervisors. 22 January 2008. Single Use Bag Reduction and Recycling Program
(Resolution and Alternative 5). Los Angeles, CA. Available at: http://dpw.lacounty.gov/epd/PlasticBags/Resources.cfm
82
County of Los Angeles, Department of Public Works, Environmental Programs Division. October 2008. County of Los
Angeles Single Use Bag Reduction and Recycling Program – Program Resource Packet. Alhambra, CA.
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approximately 1 percent of the total 12 million tons of solid waste generated each year.
83
However,
paper bags have the potential to biodegrade if they are sufficiently exposed to oxygen, sunlight,
moisture, soil, and microorganisms (such as bacteria); they are denser and less susceptible to becoming
airborne; and they generally have a higher recycling rate than do plastic bags. The U.S. Environmental
Protection Agency reported that the recycling rate for high-density polyethylene plastic bags and sacks
was 11.9 percent in 2007, compared to a recycling rate of 36.8 percent of paper bags and sacks.
84
The
County currently has an education outreach program for curbside recycling, which includes paper
carryout bags.
85
There is nearly universal access to curbside recycling throughout the County, where
paper bags can be recycled by homeowners conveniently. The paper used to make standard paper
carryout bags is originally derived from wood pulp, which is a naturally biodegradable and
compostable material. The brown paper bags commonly found at supermarkets are made from Kraft
paper.
86
It also appears that the paper carryout bags currently used by stores in the County are made of
at least 40 percent post-consumer recycled content.
87
Based upon the available evidence, paper
carryout bags are less likely to become litter than are plastic carryout bags.
I.E.3 Reusable Bags
Reusable bags offer an alternative to plastic carryout bags, compostable plastic carryout bags, and
paper carryout bags. The utility of a reusable bag has been noted in various reports, such as the 2008
report by Green Seal, which estimates the life of a reusable bag as being between two and five years.
88
In 1994, the Green Seal report encouraged an industry standard of a minimum of 300 reusable bag
uses; today, Green Seal recommends a more ambitious standard of a minimum of 500 uses under wet
conditions (bag testing under wet conditions is more stringent testing).
89
Furthermore, life cycle studies
for plastic products have documented the adverse impacts related to various types of plastic and paper
bags; however, life cycle studies have also indicated that reusable bags are the preferable option to
both paper bags and plastic bags.
90,91,92,93
83
California Environmental Protection Agency, Integrated Waste Management Board. December 2004. Contractor’s
Report to the Board: 2004 Statewide Waste Characterization Study. Produced by: Cascadia Consulting Group, Inc.
Berkeley, CA. Available at: http://www.ciwmb.ca.gov/publications/localasst/34004005.pdf
84
U.S. Environmental Protection Agency. November 2008. “Table 21: Recovery of Products in Municipal Solid Waste,
1960 to 2007.” Municipal Solid Waste in the United States: 2007 Facts and Figures. Washington, DC. Available at:
http://www.epa.gov/waste/nonhaz/municipal/pubs/msw07-rpt.pdf. The referenced table included the recovery of post-
consumer wastes for the purposes of recycling or composting, it did not include conversion/fabrication scrap. The report
includes the recovery of plastic bags, sacks, and wraps (excluding packaging) for a total of 9.1 percent of plastic
recovered in this category. The County of Los Angeles conservatively estimates that the percentage of plastic bags in this
category for the County of Los Angeles is less than 5 percent.
85
County of Los Angeles Department of Public Works. Accessed October 12, 2010. Outreach Programs. Web sites
available at: http://dpw.lacounty.gov/epd/recycling/outreach.cfm and http://dpw.lacounty.gov/epd/recycling/crm.cfm
86
American Forest and Paper Association. Accessed on: 25 October 2010. “Facts about Paper.” Web site. Available at:
http://www.afandpa.org/FunFacts.aspx
87
Perez, David, County of Los Angeles, Department of Public Works. 30 October 2008. E-mail correspondence; Paper
Bag Distribution – Field Survey Summary - on file at Sapphos Environmental, Inc. Pasadena, CA.
88
Green Seal, Inc. is an independent non-profit organization that uses science-based standards and the power of the
marketplace to provide recommendations regarding sustainable products, standards, and practices.
89
Green Seal, Inc. 13 October 2008. Green Seal Proposed Revised Environmental Standard For Reusable Bags (GS-16).
Washington, DC. Available at: http://www.greenseal.org/certification/gs-
16_reusable_bag_proposed_revised_standard_background%20document.pdf
90
Reusable bag manufacturers in the United States are expected to enforce industry standards and recommendations,
such as using recycled materials, to reduce adverse environmental impacts.
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Reusable bags are intended to provide a viable alternative to the use of paper or plastic carryout bags.
94
Currently, some stores within the County, such as certain Whole Foods divisions, do not offer plastic
carryout bags at checkout, but instead offer reusable bags for sale and provide rebates if its patrons
bring their own reusable bags. Other stores, such as certain Ralphs divisions, offer reusable bags for
purchase at registers and offer various incentives such as store rewards or store credit to customers who
use reusable bags.
95
I.E.4 Voluntary Single Use Bag Reduction and Recycling Program
On January 22, 2008, the County Board of Supervisors approved a motion to implement the voluntary
Single Use Bag Reduction and Recycling Program in partnership with large supermarkets and retail
stores, the plastic bag industry, environmental organizations, recyclers and other key stakeholders.
The program aims to promote the use of reusable bags, increase at-store recycling of plastic bags,
reduce consumption of single-use bags, increase the post-consumer recycled material content of paper
bags, and promote public awareness of the effects of litter and consumer responsibility in the County.
The voluntary program establishes benchmarks for measuring the effectiveness of the program, seeking
a 30-percent decrease in the disposal rate of carryout plastic bags from the fiscal year 2007–2008
usage levels by July 1, 2010, and a 65-percent decrease by July 1, 2013.
96
The County identified three tasks to be undertaken by the County, stores, and manufacturers as part of
the voluntary program’s key components:
1. Large supermarket and retail stores: develop and implement store-specific programs
such as employee training, reusable-bag incentives, and efforts related to consumer
education
2. Manufacturer and trade associations: encourage members to participate in the
program, provide technical assistance and marketing recommendations, and
coordinate with large supermarkets and stores
3. County of Los Angeles Working Group: facilitate program meetings, determine specific
definitions for target stores, establish a framework describing participant levels and
participation expectations, and develop and coordinate program specifics such as
educational material, reduction strategies, establishment of disposal rates and
measurement methodology, progress reports, and milestones
91
Green Seal, Inc. 13 October 2008. Green Seal Proposed Revised Environmental Standard For Reusable Bags (GS-16).
Washington, DC. Available at: http://www.greenseal.org/certification/gs-
16_reusable_bag_proposed_revised_standard_background%20document.pdf
92
Boustead Consulting & Associates, Ltd. 2007. Life Cycle Assessment for Three Types of Grocery Bags – Recyclable
Plastic; Compostable, Biodegradable Plastic; and Recycled, Recyclable Paper. Available at:
http://www.americanchemistry.com/s_plastics/doc.asp?CID=1106&DID=7212
93
Green Cities California. March 2010. Master Environmental Assessment on Single-Use and Reusable Bags. Prepared
by: ICF International. San Francisco, CA.
94
Green Seal, Inc. 13 October 2008. Green Seal Proposed Revised Environmental Standard For Reusable Bags (GS-16).
Washington, DC. Available at: http://www.greenseal.org/certification/gs-
16_reusable_bag_proposed_revised_standard_background%20document.pdf
95
Ralphs Grocery Company. 2009. “Doing Your Part: Try Reusable Shopping Bags.” Web site. Available at:
http://www.ralphs.com/healthy_living/green_living/Pages/reusable_bags.aspx
96
County of Los Angeles Board of Supervisors. 22 January 2008. Single Use Bag Reduction and Recycling Program
(Resolution and Alternative 5). Los Angeles, CA. Available at: http://dpw.lacounty.gov/epd/PlasticBags/Resources.cfm
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In March 2008, the County provided each of the 88 incorporated cities in the County with a sample
“Resolution to Join” letter that extended to the cities an opportunity to join the County in the
abovementioned activities related to the Single Use Plastic Bag Reduction and Recycling Program.
There are currently 11 cities within the County that have signed resolutions to join the County in its
efforts and in adopting similar ordinances for their respective cities: Agoura Hills, Azusa, Bell,
Glendale, Hermosa Beach, Lomita, Pico Rivera, Pomona, Redondo Beach, Santa Fe Springs, and Signal
Hill. These cities have implemented a variety of public education and outreach efforts to encourage
participation within their cities, including developing public education brochures, running public
service announcements on their city’s cable television channel, establishing committees focused on
community outreach, and distributing recycled-content reusable bags at community events.
These endeavors were undertaken in an effort to increase the participation of grocery stores, to shift
consumer behavior to the use of recycled plastic bags, and to encourage a considerable transition to
the use of reusable bags.
Since that time, the County Working Group found that the program was not successful in achieving its
goals. Over a two-year period and despite State law, stores in the unincorporated area did not provide
data that would enable County staff to determine if the voluntary Program benchmark of 30 percent
disposal reduction of plastic bags had been met. Furthermore, although the public education and
outreach aspects of the program, including the successful Brag About Your Bag Campaign, were
effective in raising awareness of the environmental impacts of carryout bags and the benefits of
reusable bags, it did not translate into changes in consumer behavior significant enough to address the
County’s major objectives.
97
I.F EIR PROCESS
The County prepared an EIR for the proposed ordinances in accordance with CEQA. The County has
taken steps to encourage the public to participate in preparation of the environmental analysis for the
proposed ordinances. On December 1, 2009, the County circulated an NOP for a Draft EIR for the
proposed ordinances to the State Clearinghouse and to various federal, state, regional, and local
government agencies. A public Notice of Availability (NOA) of the NOP was published in the Los
Angeles Times. The NOP and Initial Study were mailed (or e-mailed) directly to approximately 480
agencies and interested parties. The NOP advertised six public scoping meetings for interested parties
to receive information on the proposed ordinances and the CEQA process, as well as providing an
opportunity for the submittal of comments. The scoping meetings facilitated early consultation with
interested parties in compliance with Section 15082 of the State CEQA Guidelines. The meetings
were held on December 7, 8, 9, 10, 11, and 14, 2009, at the following seven locations:
• East Los Angeles College, 1700 Avenida Cesar Chavez, Monterey Park, California 91754
• Yvonne B. Burke Community and Senior Center, 4750 West 62nd Street
(Baldwin Hills / Ladera Heights Area), Los Angeles, California 90056
• County of Los Angeles Department of Public Works (LACDPW) headquarters,
Conference Room C, 900 South Fremont Avenue, Alhambra, California 91803
• Calabasas Library, Founder’s Hall, 101 Civic Center Way, Calabasas, California 91302
• Steinmetz Senior Center, 1545 South Stimson Avenue, Hacienda Heights, California
91745
97
County of Los Angeles Chief Executive Office. 5 August 2010. Single Use Bag Reduction and Recycling Program and
Expanded Polystyrene Food Containers – Final Quarterly Progress Report. Available at:
http://dpw.lacounty.gov/epd/PlasticBags/PDF/BoardLetters/bdls_080510_bagrpt10.pdf
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• Castaic Regional Sports Complex, 31230 North Castaic Road, Castaic, California 91384
• Jackie Robinson Park, 8773 East Avenue R, Littlerock, California 93543
A total of 18 individuals attended the scoping meetings. The public review period closed on January
4, 2010. The County requested information from the public related to the range of actions under
consideration and alternatives, mitigation measures, and significant effects to be analyzed in depth in
the EIR. All verbal and written comments related to environmental issues that were provided during
public review of the NOP and at scoping meetings were considered in the preparation of this EIR.
This EIR considers alternatives that are capable of avoiding or reducing significant effects of the
proposed ordinances. The comment period for the NOP and Initial Study closed on January 4, 2010.
A total of seven comment letters were received in response to the NOP and Initial Study. The Final
EIR considered the environmental issues identified in the NOP, responses to letters of comments
received on the Draft EIR, and clarifications and revisions resulting from public review of the Draft EIR.
The EIR was prepared to inform public agency decision makers and the general public about the
proposed ordinances and their potentially significant environmental effects, to suggest possible ways of
minimizing those significant effects, and to describe a reasonable range of alternatives that could
feasibly attain most of the basic objectives of the proposed ordinances, but would avoid or
substantially lessen any of the potentially significant effects of the proposed ordinances. The Draft EIR
was completed and forwarded to the Governor’s Office of Planning and Research (OPR) State
Clearinghouse on June 2, 2010, for a 45-day review period that ended on July 16, 2010.
An electronic copy of the Draft EIR was made available at all public libraries in the County, and a hard
copy of the Draft EIR was made available at each of 10 public libraries. An NOA of the Draft was
advertised EIR for public review in the Los Angeles Times, delivered to all public libraries in the
County, and sent via postal mail and/or e-mail to 27 public agency representatives and approximately
460 stakeholders, including private organizations and individuals. Copies of the Draft EIR were
available for purchase, at reproduction cost, from the County. A total of 11 letters of comment and a
petition with more than 1,800 signatures were received in response to the Draft EIR. In addition, the
County hosted six public meetings throughout the County to provide the public with key findings of
the Draft EIR and to solicit comments.
The Final EIR was prepared based on the Draft EIR, comments received in response the Draft EIR
during circulation of the document for public review, and clarifications and revisions resulting from
public review of the Draft EIR. A total of 11 letters of comment and a petition with over 1,800
signatures urging the County to ban plastic carryout bags, were received on the Draft EIR from resource
agencies, organized groups, and individuals: County of Los Angeles Fire Department, City of Palmdale,
City of Pasadena, American Chemistry Council, Heal the Bay, Renewable Bag Council, Symphony
Environmental Technologies, Save the Plastic Bag Coalition, Mr. Lars Clutterham, Ms. Hillary Gordon,
and OPR State Clearinghouse. Upon completion of the review period for the Draft EIR, a Final EIR was
prepared and provided to the County Board of Supervisors for certification of compliance with CEQA,
and for review and consideration as part of the decision-making process for the proposed ordinances.
I.G GENERAL FINDINGS
During the environmental evaluation of the proposed ordinances, the County evaluated all
environmental issues recommended by CEQA and the State CEQA Guidelines.
The Initial Study determined that the proposed ordinances would not be expected to result in
significant impacts to 12 environmental issue areas: aesthetics, agricultural and forestry resources,
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cultural resources, geology and soils, hazards and hazardous materials, land use and planning, mineral
resources, noise, population and housing, public services, recreation, and transportation and traffic.
The Initial Study, which addressed several arguments raised by certain members of the plastic bag
industry, concluded that the proposed ordinances may have the potential to result in significant
negative or beneficial impacts related to 5 environmental issue areas: air quality, biological resources,
greenhouse gas (GHG) emissions, hydrology and water quality, and utilities and service systems.
The EIR determined that the recommended County ordinance (analyzed as Alternative 5), based on the
County’s assumption of a conservative number of plastic bags used in its analysis and a conservative
scenario of 50 percent conversion to paper carryout bags, when applying the threshold “generate
greenhouse gas emissions, either directly or indirectly that may have a significant effect on the
environment,” that GHG emissions due to the end of life of paper carryout bags in landfills would be
cumulatively considerable.
The County has evaluated six alternatives to the proposed ordinances (including the No Project
Alternative): ban plastic and paper carryout bags in Los Angeles County; ban plastic carryout bags and
impose a fee on paper carryout bags in Los Angeles County; ban plastic carryout bags for all
supermarkets and other grocery stores, convenience stores, pharmacies, and drug stores in Los Angeles
County; or ban plastic and paper carryout bags for all supermarkets and other grocery stores,
convenience stores, pharmacies, and drug stores in the County; or ban plastic carryout bags and
impose a fee on paper carryout bags for all supermarkets and other grocery stores, convenience stores,
pharmacies, and drug stores in the County. In addition, the EIR also analyzed the No Project
Alternative pursuant to CEQA. Alternative 4 was determined to be the environmentally superior
alternative because it would result in the greatest reduction in the use of both plastic and paper
carryout bags. Alternative 5 will also result in a significant reduction in plastic carryout bags, while
retaining an option for consumers to purchase paper carryout bags should they choose to pay a charge
for paper carryout bags, forget their reusable bags, or are visiting in the area and do not have reusable
bags with them. Alternative 5 was recommended for adoption by the County Board of Supervisors.
Before project approval, an EIR must be certified pursuant to Section 15090 of the State CEQA
Guidelines. Prior to approving a project for which an EIR has been certified, and for which the EIR
identifies one or more significant environmental impacts, the approving agency must make one or
more of the following findings, with a brief explanation of the rationale, pursuant to Public Resources
Code Section 21081 and Section 15091 of the State CEQA Guidelines, for each identified significant
impact:
(1) Changes or alterations have been required in, or incorporated into, the project that avoid
or substantially lessen the significant environmental effect as identified in the final EIR.
(2) Such changes or alterations are within the responsibility and jurisdiction of another
public agency and not the agency making the finding. Such changes have been
adopted by such other agency or can and should be adopted by such other agency.
(3) Specific economic, legal, social, technological, or other considerations, including
provision of employment opportunities for highly trained workers, make infeasible the
mitigation measures or project alternatives identified in the EIR.
The County has made one or more of the specific written Findings above regarding each significant
impact associated with the project. Those Findings are presented in Chapter X of this document, along
with a presentation of facts in support of the Findings.
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Section 15092 of the State CEQA Guidelines states that after consideration of an EIR, and in
conjunction with the Section 15091 findings identified above, the lead agency may decide whether or
how to approve or carry out the project. The lead agency may approve a project with unavoidable
adverse environmental effects only when it finds that specific economic legal, social, technological, or
other benefits of the project outweigh those effects. Section 15093 requires the lead agency to
document and substantiate any such determination in a “statement of overriding considerations” as a
part of the record. The Authority’s Statement of Overriding Considerations is presented in Chapter IX
of this document.
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SECTION II
POTENTIAL ENVIRONMENTAL EFFECTS THAT ARE NOT SIGNIFICANT
The analysis undertaken in support of the Initial Study for the ordinances that was completed on
December 1, 2009, determined that there are 12 environmental issue areas pursuant to the State
CEQA Guidelines that will not have significant impacts resulting from implementation of the
ordinances: aesthetics, agriculture and forestry resources, cultural resources, geology and soils,
hazards and hazardous materials, land use and planning, mineral resources, noise, population and
housing, public services, recreation, and transportation and traffic. Therefore, these issue areas
were not carried forward for detailed analysis in the EIR for the ordinances.
The EIR analysis also determined that the recommended ordinances (analyzed as Alternative 5 in
the EIR) will not result in significant impacts related to air quality, biological resources, hydrology
and water quality, and utilities and service systems.
II.A AESTHETICS
Significant Impact:
None.
Finding:
The recommended ordinances will not result in significant impacts to aesthetics. Therefore,
no mitigation is required.
Rationale:
The above finding is made based on the analysis in the EIR and Initial Study for the
ordinances, including in, but not limited to, Section 2.0, Environmental Checklist, and
Section 3.0, Environmental Analysis, of the Initial Study. The recommended ordinances will
not have a substantial adverse effect on a scenic vista, will not substantially damage scenic
resources within a state scenic highway, will not substantially degrade existing visual
character or quality, and will not create a new source of substantial light or glare.
II.B AGRICULTURE AND FORESTRY RESOURCES
Significant Impact:
None.
Finding:
The recommended ordinances will not result in significant impacts to agriculture and forest
resources. Therefore, no mitigation is required.
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Rationale:
The above finding is made based on the analysis in, but not limited to, the EIR and Sections
2.0 and 3.0 of the Initial Study for the ordinances, as well as additional analysis undertaken
to support the EIR, as discussed in response to Comment No. 25 from the American
Chemistry Council in Section 13 of the Final EIR. There are no Prime Farmlands, Unique
Farmlands, Farmlands of Statewide Importance, forest land, or timberland that would be
significantly impacted by the recommended ordinances. No Farmlands will be converted
to nonagricultural use, and the recommended ordinances will not conflict with zoning for
agriculture, forest land, or any Williamson Act contracts. The majority of paper carryout
bags supplied to the greater Los Angeles metropolitan area are produced in and delivered
from states outside of California, or from countries outside of the United States, such as
Canada (see EIR, page 3.1-17). The State CEQA Guidelines state, “An evaluation of the
environmental effects of a proposed project need not be exhaustive, but the sufficiency of
an EIR is to be reviewed in the light of what is reasonably feasible”;|1010| based on this
stipulation, the County finds that a detailed analysis of impacts to forest resources is too
speculative and would be unreasonably burdensome. Specifically, the location and type of
forest (certified sustainable, plantations, reforested, etc.) and the amount of wood fiber
procured from trees that could be attributed to the project is unknown. Section 15145 of
the State CEQA Guidelines states, “If, after a thorough investigation, a lead agency finds
that a particular impact is too speculative for evaluation, the agency should note its
conclusion and terminate discussion of the impact.”
II.C AIR QUALITY
Significant Impact:
None.
Finding:
The recommended ordinances will not result in significant impacts to air quality.
Therefore, no mitigation is required.
Rationale:
The above finding is made based on the analysis included in, but not limited to, Sections
2.0 and 3.0 of the Initial Study and Sections 3.1, Air Quality, and 4.0, Alternatives, of the
EIR for the ordinances. The recommended ordinances (analyzed as Alternative 5) will not
conflict with or obstruct implementation of the applicable air quality plan; will not violate
any air quality standard or contribute substantially to an existing or projected air quality
violation; will not result in a cumulatively considerable net increase of any criteria pollutant
for which the County is in non-attainment under an applicable federal or state ambient air
quality standard; will not expose sensitive receptors to substantial pollutant concentrations;
and will not create objectionable odors affecting a substantial number of people. The
recommended ordinances will ban the issuance of plastic carryout bags and impose a fee
or charge on the issuance of paper carryout bags, and therefore will not result in significant
criteria pollutant emissions from the manufacture, distribution, and disposal of paper or
|1010| California Code of Regulations, Title 14, Division 6, Chapter 3, Section 15151, Appendix G.
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plastic carryout bags. The analysis in Section 4.2.6 of the EIR (see Section 12.2 of the EIR),
which evaluated a conservative scenario using the Ecobilan life cycle assessment, indicated
an overall decrease in indirect emissions of criteria pollutants as a result of 50 percent of
customers switching from using plastic carryout bags to using paper carryout bags.
Nevertheless, any indirect increase in air pollutant emissions from paper carryout bag
manufacturing facilities affected by the recommended ordinances will be controlled by the
facility owners in compliance with applicable local, regional, and national air quality
standards. Any indirect increase in air pollutant emissions from end of life of paper
carryout bags, including from truck trips transporting paper carryout bag waste to landfills
in the County, are currently controlled by regional and state regulations, including South
Coast Air Quality Management District (SCAQMD) Rule 1150.1, Control of Gaseous
Emissions from Landfills; SCAQMD Rule 1193, Clean On-road Residential and Commercial
Refuse Collection Vehicles; California Air Resources Board’s Solid Waste Collection
Vehicle Rule; and by the County controlling for emissions by requiring in its new refuse
agreements that alternative-fuel refuse vehicles be used.
2,3,4,5
Therefore, indirect air quality
impacts due to a potential increase in the demand for paper carryout bags will be below
the level of significance. Since the recommended ordinances will not cause a significant
impact to air quality, will not generate a significant number of vehicle trips, and will not
promote employment or population growth, the recommended ordinances will cause a less
than significant cumulative air quality impact. Implementation of the recommended
ordinances would be consistent with the policies, plans, and regulations for air quality set
forth by the County. Any related projects in the County must also comply with the
County’s air quality regulations. Therefore, implementation of the recommended
ordinances will not result in a cumulatively considerable contribution to a significant
cumulative impact.
II.D BIOLOGICAL RESOURCES
Significant Impact:
None.
Finding:
The recommended ordinances will result in beneficial impacts to biological resources.
Therefore, no mitigation is required.
Rationale:
The above finding is made based on the analysis included in, but not limited to, Section
3.2, Biological Resources, and Section 4.0 of the EIR and Sections 2.0 and 3.0 of the Initial
|1010| County of Los Angeles, Department of Public Works. 11 May 2010. Award of Contract for Walnut Park Garbage
Disposal District. Available at: http://file.lacounty.gov/bos/supdocs/54560.pdf |1010| County of Los Angeles, Department of Public Works. 11 May 2010. Award of Contract for Athens/Woodcrest/Olivita
Garbage Disposal District. Available at: http://file.lacounty.gov/bos/supdocs/54567.pdf
4
County of Los Angeles, Department of Public Works. 11 May 2010. Award the Contract for Firestone Garbage Disposal
District. Available at: http://file.lacounty.gov/bos/supdocs/54559.pdf |1010| County of Los Angeles, Department of Public Works. 19 January 2010. Award of Contract for an Exclusive Franchise
Agreement to Valley Vista Services, Inc. for the Unincorporated Area of Hacienda Heights. Available at:
http://file.lacounty.gov/bos/supdocs/52931.pdf
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Study for the ordinances. The recommended ordinances (analyzed as Alternative 5) will
not adversely impact State-designated sensitive habitats; rare, threatened, or endangered
species; locally important species; or federally protected wetlands; and will not conflict
with any habitat conservation plan, natural community plan, or any approved state, local,
or regional plans. The recommended ordinances will have the potential to result in
beneficial impacts to biological resources, as they will, among other things, reduce the
amount of litter attributable to plastic carryout bags throughout the County, and particularly
within the storm drain system, which drains directly to the Pacific Ocean. Similarly,
implementation of the recommended ordinances will not result in a cumulatively
considerable contribution to a significant cumulative impact.
II.E CULTURAL RESOURCES
Significant Impact:
None.
Finding:
The recommended ordinances will not result in significant impacts to cultural resources.
Therefore, no mitigation is required.
Rationale:
The above finding is made based on the analysis included in Section 2.0 and Section 3.0 of
the Initial Study for the ordinances. The recommended ordinances (analyzed as Alternative
5) will not cause a substantial adverse change in the significance of a historical resource,
archeological resource or paleontological resource. The recommended ordinances will not
disturb any human remains.
II.F GEOLOGY AND SOILS
Significant Impact:
None.
Finding:
The recommended ordinances will not result in significant impacts to geology and soils.
Therefore, no mitigation is required.
Rationale:
The above finding is made based on the analysis included in, but not limited to, the EIR
and Sections 2.0 and 3.0 of the Initial Study for the ordinances. Although potentially active
faults are known to exist in the County of Los Angeles, the recommended ordinances will
not cause any additional risk of strong seismic ground shaking or ground failure. The
recommended ordinances will not cause any substantial risks to life or property due to
landslides, soil erosion, or unstable or expansive soil.
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II.G HAZARDS AND HAZARDOUS MATERIALS
Significant Impact:
None.
Finding:
The recommended ordinances will not result in significant impacts to hazards and
hazardous materials. Therefore, no mitigation is required.
Rationale:
The above finding is made based on the analysis included in, but not limited to, the EIR
and Sections 2.0 and 3.0 of the Initial Study for the ordinances. The recommended
ordinances (analyzed as Alternative 5) will not create a significant hazard to the public or
the environment, handle hazardous materials within one-quarter mile of an existing or
proposed school, be located on a site which is included on a list of hazardous materials
sites, or result in a safety hazard for people residing or working in the County.
II.H HYDROLOGY AND WATER QUALITY
Significant Impact:
None.
Finding:
The recommended ordinances will not result in significant impacts to hydrology and water
quality. Therefore, no mitigation is required.
Rationale:
The above finding is made based on the analysis included in, but not limited to, Section
3.4, Hydrology and Water Quality, and Section 4.0 the EIR and Sections 2.0 and 3.0 of the
Initial Study for the ordinances. The recommended ordinances (analyzed as Alternative 5)
will not violate any water quality standards or waste discharge requirements; will not
substantially deplete groundwater supplies or interfere substantially with groundwater
recharge such that there will be a net deficit in aquifer volume or a lowering of the local
groundwater table level; will not substantially alter the existing drainage pattern of the area
in a manner that will result in substantial erosion or siltation; will not substantially alter the
existing drainage pattern of the area or substantially increase the rate or amount of surface
runoff in a manner that will result in flooding; will not create or contribute runoff water that
will exceed the capacity of existing or planned storm water drainage systems or provide
substantial additional sources of polluted runoff; will not otherwise substantially degrade
water quality; will not place housing within a 100-year flood hazard area; will not place
within a 100-year flood hazard area structures that will impede or redirect flood flows; will
not expose people or structures to a significant risk of loss, injury or death involving
flooding, including flooding as a result of the failure of a levee or dam; and will not cause
inundation by seiche, tsunami, or mudflow. The recommended ordinances will result in
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positive impacts to drainage by reducing the amount of plastic carryout bag trash that may
originate from sources in the County and be transported from rivers to oceans, and may
improve surface water quality caused by anticipated reductions in the use of plastic
carryout bags. Any indirect impacts related to increased demand for manufacturing of
paper carryout bags or reusable bags would be controlled by the USEPA and the Regional
Water Quality Control Boards (RWQCBs) under the federal CWA and other applicable
federal, state, and/or local regulations. Therefore, implementation of the recommended
ordinances will not result in a cumulatively considerable contribution to a significant
cumulative impact.
II.I LAND USE AND PLANNING
Significant Impact:
None.
Finding:
The recommended ordinances will not result in significant impacts to land use and
planning. Therefore, no mitigation is required.
Rationale:
The above finding is made based on the analysis included in, but not limited to, the EIR
and Sections 2.0 and 3.0 of the Initial Study for the ordinances. The recommended
ordinances (analyzed as Alternative 5) will not cause the physical division of an established
community; will not conflict with any applicable land use plan, policy, or regulation; and
will not conflict with any applicable habitat conservation plan or natural community
conservation plan.
II.J MINERAL RESOURCES
Significant Impact:
None.
Finding:
The recommended ordinances will not result in significant impacts to mineral resources.
Therefore, no mitigation is required.
Rationale:
The above finding is made based on the analysis included in, but not limited to, the EIR and
Sections 2.0 and 3.0 of the Initial Study for the ordinances. Although there are mineral
resource areas of value to the region or to the residents of the state within the County, the
recommended ordinances will not affect the extraction of these resources. Further, the
recommended ordinances will not result in the loss of availability of a locally important
mineral resource recovery site delineated on a local general plan, specific plan, or other
land use plan.
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II.K NOISE
Significant Impact:
None.
Finding:
The recommended ordinances will not result in significant impacts to noise. Therefore, no
mitigation is required.
Rationale:
The above finding is made based on the analysis included in, but not limited to, the EIR and
Sections 2.0 and 3.0 of the Initial Study for the ordinances. The recommended ordinances
(analyzed as Alternative 5) will not generate noise levels in excess of standards; will not
generate excessive groundborne vibration; and will not generate a substantial permanent,
temporary, or periodic increase in ambient noise levels.
II.L POPULATION AND HOUSING
Significant Impact:
None.
Finding:
The recommended ordinances will not result in significant impacts to population and
housing. Therefore, no mitigation is required.
Rationale:
The above finding is made based on the analysis included in, but not limited to, the EIR
and Sections 2.0 and 3.0 of the Initial Study for the ordinances. The recommended
ordinances (analyzed as Alternative 5) will not result in direct or indirect population
growth. The recommended ordinances do not include construction of new homes or
businesses and do not extend infrastructure into areas not currently served by roads or
other infrastructure. The recommended ordinances do not include the construction of any
new housing units and will not alter the need for residential development in the County.
Furthermore, the recommended ordinances will also not result in the displacement of a
substantial amount of people.
II.M PUBLIC SERVICES
Significant Impact:
None.
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Finding:
The recommended ordinances will not result in significant impacts to public services.
Therefore, no mitigation is required.
Rationale:
The above finding is made based on the analysis included in, but not limited to, the EIR
and Sections 2.0 and 3.0 of the Initial Study for the ordinances. The recommended
ordinances (analyzed as Alternative 5) will not result in substantial adverse physical impacts
associated with the provision of new or physically altered governmental facilities. The
recommended ordinances will not affect acceptable service ratios, response times, and
other performance objectives for the public services of fire protection, police protection,
schools, parks, and other public facilities.
II.N RECREATION
Significant Impact:
None.
Finding:
The recommended ordinances will not result in significant impacts to recreation.
Therefore, no mitigation is required.
Rationale:
The above finding is made based on the analysis included in, but not limited to, the EIR and
Sections 2.0 and 3.0 of the Initial Study for the ordinances. The recommended ordinances
(analyzed as Alternative 5) will not induce substantial growth or concentration of
population beyond regional projections. Therefore, no individual park or recreation facility
will experience physical deterioration. The recommended ordinances will not result in a
significant increase in the number of people, residents, or visitors that will avail themselves
of existing park facilities. The recommended ordinances do not include the construction of
any recreational facilities, and thus will not require additional or the expansion of existing
such facilities.
II.O TRAFFIC AND TRANSPORTATION
Significant Impact:
None.
Finding:
The recommended ordinances will not result in significant impacts to traffic and
transportation. Therefore, no mitigation is required.
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Rationale:
The above finding is made based on the analysis included in, but not limited to, the EIR
and Sections 2.0 and 3.0 of the Initial Study for the ordinances. The recommended
ordinances (analyzed as Alternative 5) will not conflict with an applicable plan, ordinances
or policy establishing measures of effectiveness for the performance of the circulation
system; will not conflict with an applicable congestion management program; will not
result in a change in air traffic patterns; will not substantially increase hazards due to a
design feature; will not result in inadequate emergency access; and will not conflict with
adopted plans, policies, or programs regarding public transit.
II.P UTILITIES AND SERVICE SYSTEMS
Significant Impact:
None.
Finding:
The recommended ordinances will not result in significant impacts to utilities and service
systems. Therefore, no mitigation is required.
Rationale:
The above finding is made based on the analysis included in, but not limited to, Section
3.5, Utilities and Service Systems, and Section 4.0 the EIR and Sections 2.0 and 3.0 of the
Initial Study for the ordinances. The recommended ordinances (analyzed as Alternative 5)
will not be expected to exceed wastewater treatment requirements of the applicable
regional water quality control board; will not require or result in the construction of new
water or wastewater treatment facilities; will not require or result in the construction of new
storm water drainage facilities or expansion of existing facilities; will not require new or
expanded entitlements for water supply; will not result in a determination by the
wastewater treatment provider that it has inadequate capacity to serve the ordinances’
projected demand in addition to the provider’s existing commitments; will not be served by
a landfill with insufficient permitted capacity to accommodate the ordinances’ solid waste
disposal needs; and will comply with federal, state, and local statutes and regulations
related to solid waste. The recommended ordinances will lead to reduced operational
impacts and costs associated with storm drain system maintenance due to a reduction in
plastic carryout bag litter. Based on existing capacities, adoption of the recommended
ordinances will not result in adverse impacts to storm drain systems, water supply, solid
waste, energy consumption, or wastewater treatment. Therefore, implementation of the
recommended ordinances will not result in a cumulatively considerable contribution to a
significant cumulative impact.
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SECTION III
POTENTIAL ENVIRONMENTAL EFFECTS THAT CAN
BE MITIGATED TO BELOW THE LEVEL OF SIGNIFICANCE
The analysis undertaken in the EIR for the recommended ordinance to ban the issuance of plastic
carryout bags and impose a fee or charge on paper carryout bags at a greater number of stores
(analyzed as Alternative 5) determined that the incorporation of mitigation measures is not
expected to reduce the potential indirect impact of the recommended ordinances to GHG
emissions to below the level of significance. While the incorporation of mitigation measure
GHG-1 will be implemented to monitor and reduce the use of paper carryout bags resulting from
the recommended ordinances and will indirectly offset end-of-life GHG emissions to the maximum
extent feasible, the County has decided that no emission reduction credit will be taken for the
measure, and for the purposes of the decision-making process, the County will proceed with the
conclusion that indirect impacts to GHG emissions will remain cumulatively considerable.
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SECTION IV
SIGNIFICANT UNAVOIDABLE ADVERSE IMPACTS THAT CANNOT BE
MITIGATED TO BELOW THE LEVEL OF SIGNIFICANCE
Based on a conservative analysis, the County has determined that cumulative indirect GHG
emissions resulting from implementation of the recommended ordinances will have the potential to
result in significant unavoidable impacts even with implementation of mitigation measure GHG-1,
which will be expected to reduce significant adverse impacts to GHG emissions to the maximum
extent feasible. Consequently, in accordance with Section 15093 of the State CEQA Guidelines, a
Statement of Overriding Considerations has been prepared (see Section IX of this document) to
substantiate the County’s decision to accept this potential unavoidable adverse environmental
effect because it is outweighed by the potential benefits afforded by the recommended ordinances.
IV.A GREENHOUSE GAS EMISSIONS
Significant Impact:
Indirect impacts resulting from the decomposition of paper carryout bags in landfills will be
potentially cumulatively significant under the County's conservative worst-case analysis.
Finding:
The County Board of Supervisors finds that changes or alterations have been required in, or
incorporated into, the recommended County ordinance that avoid or substantially lessen its
significant environmental effect as identified in the EIR. Specifically, incorporation of mitigation
measure GHG-1, described below, will monitor, reduce use of, and encourage further recycling of
paper carryout bags, and will indirectly offset end-of-life GHG emissions to the maximum extent
feasible. However, despite mitigation, impacts from the decomposition of paper carryout bags in
landfills will remain cumulatively significant under a conservative worst-case analysis. Further,
with respect to the impacts that could occur if the County’s 88 incorporated cities adopted similar
ordinances, the Board of Supervisors finds that incorporation of changes or alterations similar to
those set forth in mitigation measure GHG-1 are within the responsibility and jurisdiction of those
agencies and not the County. Such changes have been adopted by such other agencies or can and
should be adopted by such other agencies. However, the Board of Supervisors acknowledges that
the feasibility of such changes or alterations similar to those set forth in mitigation measure GHG-1,
including the feasibility of each element of such a mitigation measure, is within the sole discretion
of such other agencies. The Board of Supervisors finds that specific economic, legal, social,
technological, or other considerations make additional mitigation measures infeasible.
Mitigation Measure:
Mitigation Measure MM-GHG-1 Implement and/or expand public outreach and educational
programs to increase the percentage of paper carryout bags
that are recycled curbside.
If the adopted ordinance includes a fee or charge on the
issuance of paper carryout bags of at least $0.05, consider
increases to the fee or charge to further reduce consumption
of paper carryout bags.
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Distribute reusable grocery bags, free of charge within the
project area to encourage further transitions to reusable bags.
Consider public/private partnerships to offset costs of
distribution.
Implement an outreach program for affected stores to
encourage consumer transition to reusable bags, to reduce
double bagging, and to encourage reuse and in-store
recycling of paper carryout bags.
Encourage grocery stores to implement energy efficiency
technology particularly in relation to storage of cold and
frozen foods (assuming a reduction of 0.65 metric ton
carbon dioxide equivalent for each megawatt hour saved|1010|).
Consider converting public vehicles to low-emitting fuels
(assuming a reduction of 0.45 metric ton carbon dioxide
equivalent for each 1,000 vehicle miles traveled2). Consider
funding conversion of vehicles through participation in
South Coast Air Quality Management District’s Carl Moyer
Program.
Rationale:
The above finding is based on the analysis included in Sections 2.0 and 3.0 of the Initial Study and
Sections 3.3 and 4.0 of the EIR. The recommended ordinances (analyzed as Alternative 5 in the
EIR) will not directly generate GHG emissions that may have a significant impact on the
environment, and will not conflict with any applicable plan, policy, or regulation of an agency
adopted for the purpose of reducing the emissions of GHGs. The recommended ordinances will
ban the issuance of plastic carryout bags and impose a fee or charge on the issuance of paper
carryout bags, and therefore will not result in significant GHG emissions from the overall life cycle
of paper or plastic carryout bags. However, indirect impacts resulting from end of life from the
decomposition of paper carryout bags in landfills will be cumulatively significant under a
conservative worst-case analysis. Mitigation measure GHG-1 will reduce the cumulative impact by
increasing public awareness, promoting recycling of paper bags, promoting use of reusable bags,
and encouraging further efforts to reduce GHG emissions. While the County will not take credits
for the reduction in GHG emissions resulting from mitigation measures, these measures will be
expected to reduce GHG emissions from the decomposition of paper carryout bags in landfills to
the greatest extent feasible. It is also important to note that GHG emissions from landfills located
in the County are already controlled in accordance with applicable regional, State, and federal
regulations pertaining to GHG emissions. Any potential increases in GHG emissions due to
decomposition of paper carryout bags in landfills in the County will be controlled by Antelope
Valley Air Quality Management District (AVAQMD) Rule 1150.1 or SCAQMD Rule 1150.1.
Therefore, current regulations will aid in mitigating impacts to GHG emissions resulting from
decomposition of paper carryout bags in landfills; additional feasible mitigation separate from
mitigation measure GHG-1 is not available.
1
Emission factors taken from http://www.epa.gov/cleanenergy/energy-resources/calculator.html#results |1010| Emission factors taken from http://www.epa.gov/cleanenergy/energy-resources/calculator.html#results
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Moreover, the County anticipates that the $0.10 fee or charge on paper carryout bags included in
the recommended County ordinance will significantly reduce the number of consumers that will
use paper carryout bags in place of plastic carryout bags, while still retaining an option for
consumers to purchase paper carryout bags. It would be infeasible at this time to implement a full
ban on the issuance of paper bags, as the County anticipates a certain transition period for
consumers to become aware of and adapt to the recommended County ordinance, particularly, to
remember to take and use reusable bags at affected stores. In addition, visitors to the County may
not be aware of recommended County ordinance and may not know to take and use reusable bags
at affected stores in the County.
Implementation of a fee or charge on the issuance of paper carryout bags will help to minimize the
number of paper carryout bags used in the County and any corresponding GHG emissions due to
the decomposition of paper carryout bags in landfills. If the paper carryout bag fee decreases
conversion to paper carryout bags by 80 to 90 percent, similar to what occurred with the Ireland
and Washington, DC, bag fees, indirect impacts to GHG emissions would be reduced even further.
The recommended ordinances will require each affected store to issue a quarterly report of the
total number of paper carryout bags provided to customers, along with a summary of any efforts
undertaken by the store to promote the use of reusable bags. The County will keep and analyze
these reports to determine and ensure that consumers in the County are using fewer carryout bags.
The County will also use the reports to assess whether the recommended ordinances are having the
desired effects, and if other measures are needed. The County will also conduct additional public
outreach through an education program to increase the percentage of paper carryout bags that are
diverted from landfills. Currently, there is nearly universal access to curbside recycling throughout
the County where homeowners can conveniently recycle paper bags. Additional public education
and outreach would increase the number of bags recycled and further reduce indirect impacts to
GHG emissions. Any remaining cumulative GHG emission impacts are overridden as described in
Section IX, Statement of Overriding Considerations.
The County acknowledges that some commenters on the Draft EIR have called for mitigation to
reduce potential health impacts from reusable bags. However, the there is no evidence available
to the County that suggests that use of reusable bags results in any environmental impacts such that
mitigation would be required or would be appropriate. It is expected that consumers will wash
their reusable bags along with the rest of their laundry, and it is unlikely that the need to wash
reusable bags will require the average consumer to do additional loads of laundry. In addition, all
wastewater that enters the sewer pipeline in the County is subjected to a secondary treatment at a
minimum, thus avoiding further significant adverse impact to the natural environment.|1010|
In addition, commenters have suggested that carbon offsets be used to reduce GHG emissions.
The County finds that carbon offsets are infeasible at this time for the recommended County
ordinance. Payment of an infinite number of carbon offsets for a potentially unlimited amount of
time lacks a sufficient legal nexus (i.e. results from a highly attenuated GHG source based on
speculative life cycle data that may not be directly attributable to the County and the cities), and is
more appropriately considered when specific project-level details are known for the manufacturing
and disposal facilities. As noted in response to Comment No. 8 of the July 16, 2010, comment
letter from Save the Plastic Bag Coalition (see Section 13 of the EIR), and as provided in the Natural
Resource Agency’s statement of reasons for revisions to the State CEQA Guidelines, “In some
instances, materials may be manufactured for many different projects as a result of general market
|1010| Sanitation Districts of Los Angeles County. Accessed on: 15 October 2010. “Wastewater Treatment and Water
Reclamation.” Web site. Available at: http://www.lacsd.org/about/wastewater_facilities/moresanj/default.asp
45Ordinances to Ban Plastic Carryout Bags in Los Angeles County FOF/SOC
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demand, regardless of whether one particular project proceeds. Thus, such emissions may not be
‘caused by’ the project under consideration. Similarly, in this scenario, a lead agency may not be
able to require mitigation for emissions that result from the manufacturing process. Mitigation can
only be required for emissions that are actually caused by the project [State CEQA Guidelines,
Section 15126.4(a)(4)].”|1010|
Furthermore, the County believes that imposition of carbon offset fees would be infeasible for
policy considerations and economic reasons, and would fail to meet the objectives of the
recommended County ordinance. There are still outstanding policy concerns regarding carbon
offsets and their approach and effectiveness.
5,6,7,8,9,10,11
Economically, imposition of carbon offset
fees could deter future adoption of the recommended ordinances or alternatives by the County’s
incorporated cities, especially given the economic hardship facing the County and many
cities,
12,13,14,15,16,17
and therefore would not further the objectives of the recommended ordinances:
(1) conduct outreach to the County’s 88 incorporated cities to encourage adoption of comparable
ordinances; (2) reduce the Countywide consumption of plastic carryout bags from the estimated
1,600 plastic carryout bags per household in 2007, to fewer than 800 plastic bags per household in
2013; (3) reduce by 50 percent by 2013 the Countywide contribution of plastic carryout bags to
litter that blights public spaces Countywide; (4) reduce by $4 million the County’s, cities’, and
County Flood Control District’s costs for prevention, cleanup, and enforcement efforts to reduce
|1010| California Natural Resources Agency. December 2009. Final Statement of Reasons for Regulatory Action: Amendments
to the State CEQA Guidelines Addressing Analysis and Mitigation of Greenhouse Gas Emissions Pursuant to SB97.
Available at: http://ceres.ca.gov/ceqa/docs/Final_Statement_of_Reasons.pdf |1010| Mitchell, Dan. 5 May 2007. “How Clean Is Your Carbon Credit?” The New York Times. Available at:
http://www.nytimes.com/2007/05/05/business/05online.html |1010| Revkin, Andrew. 29 April 2007. “Carbon-Neutral Is Hip, but Is It Green?” The New York Times. Available at:
http://www.nytimes.com/2007/04/29/weekinreview/29revkin.html?ex=1335499200&en=d9e2407e4f1a20f0&ei=5124 |1010| Davies, Nick. 16 June 2007. “The Inconvenient Truth about the Carbon Offset Industry.” The Guardian. Available at:
http://www.guardian.co.uk/environment/2007/jun/16/climatechange.climatechange |1010| Kaste, Martin, National Public Radio. 28 November 2006. “’Carbon Offset’ Business Takes Root.” Available at:
http://www.npr.org/templates/story/story.php?storyId=6548098 |10 10| Monbiot, George. 18 October 2006. “Selling Indulgences.” The Guardian. Available at:
http://www.monbiot.com/archives/2006/10/19/selling-indulgences/
10
David Suzuki Foundation. Accessed on: 25 October 2010. “The problems with carbon offsets from tree-planting.” Web
site. Available at: http://www.davidsuzuki.org/issues/climate-change/science/the-problems-with-carbon-offsets-from-tree-
planting/
11
Granda, Patricia. 2005. Carbon Sink Plantations in the Ecuadorian Andes: Impacts of the Dutch FACE-PROFAFOR
monoculture tree plantations’ projects on indigenous and peasant communities. Quito, Ecuador: Acción Ecológica.
Available at: http://www.wrm.org.uy/countries/Ecuador/face.pdf
12
CBS Evening News. 26 March 2010. “City, State Budgets Crippled Nationwide.” Available at:
http://www.cbsnews.com/stories/2010/03/26/eveningnews/main6336699.shtml
13
Luhby, Tami. 6 October 2010. “City budgets slammed by falling property taxes.” Available at:
http://money.cnn.com/2010/10/06/news/economy/cities_property_taxes/index.htm
14
Dougherty, Conor. 25 May 2010. “States, Still Grappling with Budget Woes.” The Wall Street Journal. Available at:
http://online.wsj.com/article/SB10001424052748704792104575264772303847934.html
15
Riccardi, Nicholas. 7 October 2010. “Cities’ budgets squeezed by housing crunch.” Los Angeles Times. Available at:
http://articles.latimes.com/2010/oct/07/nation/la-na-league-20101007
16
Semuels, Alana. 18 October 2010. “California Cities are Lowering Standards to Raise Revenue.” Los Angeles Times.
Available at: http://www.latimes.com/business/la-fi-desperate-cities-20101018,0,7536692.story
17
County of Los Angeles Chief Executive Office. 5 August 2010. Memorandum re: Sacramento Update. Available at:
http://file.lacounty.gov/bc/q3_2010/cms1_150053.pdf#search="shortfall"
46Ordinances to Ban Plastic Carryout Bags in Los Angeles County FOF/SOC
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litter in the County; (5) substantially increase awareness of the negative impacts of plastic carryout
bags and the benefits of reusable bags, and reach at least 50,000 residents (5 percent of the
population) with an environmental awareness message; and (6) reduce Countywide disposal of
plastic carryout bags in landfills by 50 percent from 2007 annual amounts.
47Ordinances to Ban Plastic Carryout Bags in Los Angeles County FOF/SOC
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SECTION V
FINDINGS REGARDING ALTERNATIVES
The EIR analyzed alternatives in accordance with the recommendations of Section 15126.6 of the State
CEQA Guidelines, which require evaluation of a range of reasonable alternatives to the project, or to
the location of the project, that would feasibly attain most of the basic objectives of the project but
could potentially avoid or substantially lessen any of the significant effects of the project, and
evaluation of the comparative merits of the alternatives. The discussion of alternatives is intended to
focus on four criteria:
• Alternatives to the proposed ordinances or their location that may be capable of
avoiding or substantially reducing any significant effects that a project may have on the
environment
• Alternatives capable of accomplishing most of the basic objectives of the proposed
ordinances and potentially avoid or substantially lessen one or more of the significant
effects
• The provision of sufficient information about each alternative to allow meaningful
evaluation, analysis, and comparison with the proposed ordinances
• The no-project analysis of what would be reasonably expected to occur in the
foreseeable future if the proposed ordinances were not approved
Pursuant to Section 15126.6(e)(2) of the State CEQA Guidelines, if the environmentally superior
alternative is the No Project Alternative, the EIR shall also identify an environmentally superior
alternative among the feasible action alternatives. The analysis of alternatives should be limited to
those that the County determines could feasibly attain most of the basic objectives of the proposed
ordinances. Section 15364 of the State CEQA Guidelines defines feasibility as “capable of being
accomplished in a successful manner within a reasonable period of time, taking into account
economic, environmental, legal, social, and technological factors.”
Alternatives addressed in the EIR were derived from work undertaken by the County, as well as from
comments received in response to the NOP and NOA of the EIR and from interested parties who
attended the public scoping meetings. As a result of the Initial Study, comments received during the
scoping period and public review period for the Draft EIR, and the environmental analysis undertaken
in the Draft EIR, six alternatives, including the No Project Alternative, were determined to represent a
reasonable range of alternatives:
1. No Project Alternative
2. Alternative 1, Ban Plastic and Paper Carryout Bags in Los Angeles County
3. Alternative 2, Ban Plastic Carryout Bags and Impose a Fee on Paper Carryout Bags in
Los Angeles County
4. Alternative 3, Ban Plastic Carryout Bags for All Supermarkets and Other Grocery
Stores, Convenience Stores, Pharmacies, and Drug Stores in Los Angeles County
5. Alternative 4, Ban Plastic and Paper Carryout Bags for All Supermarkets and Other
Grocery Stores, Convenience Stores, Pharmacies, and Drug Stores in Los Angeles County
6. Alternative 5, Ban Plastic Carryout Bags and Impose a Fee on Paper Carryout Bags for
All Supermarkets and Other Grocery Stores, Convenience Stores, Pharmacies, and
Drug Stores in Los Angeles County
48Ordinances to Ban Plastic Carryout Bags in Los Angeles County FOF/SOC
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The effectiveness of each alternative to achieve the basic objectives of the proposed ordinances was
evaluated in relation to the statement of objectives described in Section 2.0, Project Description, of the
EIR. The proposed ordinances would meet all of the basic objectives established by the County (Table
V-1, Ability of the Proposed Ordinances and Alternatives to Attain County Objectives). Although the
No Project Alternative would not meet most of the basic objectives of the proposed ordinances, it was
analyzed as required by CEQA.
TABLE V-1
ABILITY OF THE PROPOSED ORDINANCES AND ALTERNATIVES
TO ATTAIN COUNTY OBJECTIVES
Objective
Proposed
Ordinances
No
Project
Alternative
1
Alternative
2
Alternative
3
Alternative
4
Alternative
5
Conduct outreach to all 88
incorporated cities of the
County to encourage
adoption of comparable
ordinances
Yes No Yes Yes Yes Yes Yes
Reduce the Countywide
consumption of plastic
carryout bags from the
estimated 1,600 plastic
carryout bags per household in
2007 to fewer than 800 plastic
bags per household in 2013
Yes No Yes Yes Yes Yes Yes
Reduce the Countywide
contribution of plastic
carryout bags to litter that
blights public spaces by 50
percent
Yes No Yes Yes Yes Yes Yes
Reduce by $4 million the
County’s, cities’, and Flood
Control District’s costs for
prevention, cleanup, and
enforcement efforts to reduce
litter in the County
Yes No Yes Yes Yes Yes Yes
Substantially increase
awareness of the negative
impacts of plastic carryout
bags and the benefits of
reusable bags, and reach at
least 50,000 residents (5
percent of the population)
with an environmental
awareness message
Yes No Yes Yes Yes Yes Yes
Reduce Countywide disposal
of plastic carryout bags in
landfills by 50 percent from
2007 annual amounts
Yes No Yes Yes Yes Yes Yes
Although the No Project Alternative would reduce potential impacts to air quality and GHG emissions
compared with the proposed ordinances, impacts to biological resources, hydrology and water quality,
and utilities and service systems would be exacerbated, rather than avoided or reduced. In addition,
49Ordinances to Ban Plastic Carryout Bags in Los Angeles County FOF/SOC
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the No Project Alternative would not meet any of the basic objectives of the proposed ordinances
established by the County. Although the proposed ordinances originally studied in the EIR meet all of
the basic objectives, the proposed ordinances were deemed to be infeasible as they are
environmentally inferior to the alternatives analyzed in the EIR because they do not restrict the
issuance of paper carryout bags and only affect a limited range of stores. Alternatives 1, 2, 3, 4, and 5
would meet all of the basic objectives established by the County. Alternatives 3, 4, and 5 would result
in additional benefits to biological resources as a result of reduced consumption of plastic carryout
bags due to a greater number of stores being included in the proposed ordinances. As with the
proposed ordinances, and consistent with the County’s evaluation of impacts resulting from paper
carryout bags from a conservative worst-case scenario, Alternative 3 may have the potential to result in
cumulatively considerable impacts to GHG emissions because it would not limit the issuance of paper
carryout bags. Alternatives 2 and 5 would be expected to reduce consumption of paper carryout bags
through implementation of a fee. Unlike the proposed ordinances, Alternatives 1 and 4 would not
result in any increase in the use of paper carryout bags, but these alternatives were deemed infeasible
because Alternatives 1 and 4 do not allow an option for consumers to purchase carryout bags.
Table V-2, Comparative Analysis of Impacts of the Proposed Ordinances and Alternatives, provides a
comparative analysis for the originally proposed ordinances, the No Project Alternative, and the six
alternatives discussed in this document. Based on the analysis, the Environmentally Superior
Alternative is Alternative 4. This alternative is capable of creating the maximum reductions in the
consumption of both paper and plastic carryout bags, and would meet all of the six objectives of the
proposed ordinances. Alternative 5 will also result in a significant reduction in the use of plastic
carryout bags, while retaining an option for consumers to purchase paper carryout bags.
As a result of the CEQA process, including the analysis of the alternatives and public comments, the
County has determined that Alternative 5 is feasible, and has decided to adopt Alternative 5 as the
recommended County ordinance. The County will encourage each of the 88 incorporated cities in the
County to adopt comparable ordinances.
Table V-2 denotes comparative analyses as neutral (similar/equivalent impacts compared with the
proposed ordinances), positive (reduced adverse impacts or increased beneficial impacts compared
with the proposed ordinances), or negative (increased adverse impacts compared with the originally
proposed ordinances).
50TABLE V-2
COMPARATIVE ANALYSIS OF IMPACTS OF THE PROPOSED ORDINANCES AND ALTERNATIVES
Ordinances to Ban Plastic Carryout Bags in Los Angeles County FOF/SOC
November 3, 2010 Sapphos Environmental, Inc.
W:\Projects\1012\1012-035\Documents\Fof.Soc\Section 05 (V) Alternatives.Doc Page V-4
Resource Originally Proposed Ordinances No Project
Ban Plastic and Paper
Carryout Bags in Los Angeles
County
Ban Plastic Carryout Bags and
Impose a Fee on Paper Carryout
Bags in Los Angeles County
Ban Plastic Carryout Bags for All
Supermarkets and Other Grocery
Stores, Convenience Stores,
Pharmacies, and Drug Stores in
Los Angeles County
Ban Plastic and Paper
Carryout Bags for All
Supermarkets and Other
Grocery Stores, Convenience
Stores, Pharmacies, and Drug
Stores in Los Angeles County
Ban Plastic Carryout Bags and
Impose a Fee on Paper Carryout
Bags for All Supermarkets and
Other Grocery Stores,
Convenience Stores, Pharmacies,
and Drug Stores in Los Angeles
County
Air Quality
The proposed ordinances may
indirectly result in an increased
demand for paper carryout bags,
which may subsequently result in
increased criteria pollutant
emissions from the manufacture,
distribution, and disposal of paper
carryout bags, which would be
offset to some degree by the
anticipated reduction in plastic
carryout bags and increase in
reusable bags.
Impact: Emissions due to the life
cycle of paper carryout bags are
below the level of significance
The No Project Alternative would not
result in a potential increase in the use
of paper carryout bags, but would not
result in any decrease in the use of
plastic carryout bags. The No Project
Alternative would result in criteria
pollutant emissions from the
manufacture, distribution, and disposal
of plastic carryout bags, which would
be offset to some degree by the fact that
there would be no increase in the use of
paper carryout bags. However, the No
Project Alternative would not
encourage a transition to the use of
reusable bags.
Comparative Impact: Neutral
Alternative 1 would not result
in a potential increase in the
use of paper or plastic
carryout bags, and would
result in a greater use of
reusable bags. Alternative 1
would not result in criteria
pollutant emissions from the
manufacture, distribution, and
disposal of paper carryout
bags.
Comparative Impact: Positive
Alternative 2 would not result in
as much of a potential increase
in the use of paper carryout
bags, while reducing the use of
plastic carryout bags and
increasing the use of reusable
bags. Alternative 2 would not
result in the same degree of
criteria pollutant emissions from
the manufacture, distribution,
and disposal of paper carryout
bags.
Comparative Impact: Positive
Alternative 3 may indirectly result
in an increased demand for paper
carryout bags, which may
subsequently result in increased
criteria pollutant emissions from
the manufacture, distribution, and
disposal of paper carryout bags,
which would be offset to some
degree by the anticipated
reduction in plastic carryout bags
and increase in reusable bags.
Comparative Impact: Negative
Alternative 4 would not result
in a potential increase in the
use of paper or plastic
carryout bags, and would
result in a greater use of
reusable bags. Alternative 4
would not result in criteria
pollutant emissions from the
manufacture, distribution, and
disposal of paper carryout
bags.
Comparative Impact: Positive
Alternative 5 will substantially
reduce the use of plastic carryout
bags. Due to the implementation of
a fee on the issuance of paper
carryout bags, the degree of
increase in use of paper carryout
bags will be limited, and
Alternative 5 will result in a greater
use of reusable bags. Criteria
pollutant emissions due to the life
cycle of paper carryout bags will
be below the level of significance.
Comparative Impact: Positive
Biological
Resources
The proposed ordinances would
be expected to result in beneficial
impacts to biological resources as
they would reduce the amount of
litter attributable to plastic
carryout bags in the County of Los
Angeles storm drain system,
which drains directly to the
Pacific Ocean.
Impact: Beneficial
No Project Alternative would not
result in a significant reduction in the
use and disposal of plastic carryout
bags within the County. Therefore,
the No Project Alternative would not
assist in reducing marine litter
attributed to plastic carryout bag
waste, which has been shown to have
potentially significant adverse impacts
upon biological resources.
Comparative Impact: Negative
Alternative 1 would be
expected to result in beneficial
impacts to biological
resources as it would reduce
the amount of litter
attributable to plastic carryout
bags in the County of Los
Angeles storm drain system,
which drains directly to the
Pacific Ocean.
Comparative Impact: Neutral
Alternative 2 would be expected
to result in beneficial impacts to
biological resources as it would
reduce the amount of litter
attributable to plastic carryout
bags in the County of Los
Angeles storm drain system,
which drains directly to the
Pacific Ocean.
Comparative Impact: Neutral
Alternative 3 would be expected to
result in additional beneficial
impacts to biological resources as
it would further reduce the amount
of litter attributable to plastic
carryout bags in the County of Los
Angeles storm drain system, which
drains directly to the Pacific
Ocean.
Comparative Impact: Positive
Alternative 4 would result in
additional beneficial impacts
to biological resources, as it
would further reduce the
amount of litter attributable to
plastic carryout bags in the
County storm drain system,
which drains directly to the
Pacific Ocean.
Comparative Impact: Positive
Alternative 5 will result in
additional beneficial impacts to
biological resources as it would
further reduce the amount of litter
attributable to plastic carryout bags
in the County of Los Angeles storm
drain system, which drains directly
to the Pacific Ocean.
Comparative Impact:
Positive
Greenhouse
Gas Emissions
The proposed ordinances may
indirectly result in an increased
demand for paper carryout bags.
The increase in demand for paper
carryout bags may result in
increased GHG emissions as a
result of the manufacture,
distribution, and disposal of paper
carryout bags, which would be
offset to some degree by the
anticipated reduction in plastic
carryout bags and increase in
reusable bags.
Impact: Life cycle impacts resulting
from paper carryout bags would be
cumulatively significant under a
conservative worst-case analysis
The No Project Alternative would not
result in a potential increase in the use
of paper carryout bags, but would not
result in any decrease in the use of
plastic carryout bags. The No Project
Alternative would result in GHG
emissions from the manufacture,
distribution, and disposal of plastic
carryout bags, which would be offset
to some degree by the fact that there
would be no increase in the use of
paper carryout bags. However, the No
Project Alternative would not
encourage a transition to the use of
reusable bags.
Comparative Impact: Neutral
Alternative 1 would not result
in a potential increase in the
use of paper or plastic
carryout bags, and would
result in a greater use of
reusable bags. Alternative 1
would not result in GHG
emissions from the
manufacture, distribution, and
disposal of paper carryout
bags.
Comparative Impact: Positive
Alternative 2 would not result in
as much of a potential increase in
the use of paper carryout bags,
while reducing the use of plastic
carryout bags and increasing the
use of reusable bags. Alternative 2
would not result in the same
degree of GHG emissions from
the manufacture, distribution, and
disposal of paper carryout bags.
Comparative Impact: Positive
Alternative 3 may indirectly result
in an increased demand for paper
carryout bags. The increase in
demand for paper carryout bags
may result in increased GHG
emissions as a result of the
manufacture, distribution, and
disposal of paper carryout bags,
which would be offset to some
degree by the anticipated
reduction in plastic carryout bags
and increase in reusable bags.
Comparative Impact: Negative
Alternative 4 would not
increase use of paper or
plastic carryout bags, and
would result in a greater use
of reusable bags. Alternative 4
would not result in GHG
emissions from the
manufacture, distribution, and
disposal of paper carryout
bags.
Comparative Impact: Positive
Alternative 5 will result in
substantial reductions in the use of
plastic carryout bags and would
result in a greater use of reusable
bags. Due to the implementation of
a fee on the issuance of paper
carryout bags, the degree of
increase in use of paper carryout
bags would be limited. Alternative
5 will not result in significant
cumulative GHG emissions from
the manufacture and distribution of
paper carryout bags, but GHG
emissions from the disposal of
paper carryout bags in landfills
may remain cumulatively
considerable.
Comparative Impact: Positive
51TABLE V-2
COMPARATIVE ANALYSIS OF IMPACTS OF THE PROPOSED ORDINANCES AND ALTERNATIVES, Continued
Ordinances to Ban Plastic Carryout Bags in Los Angeles County FOF/SOC
November 3, 2010 Sapphos Environmental, Inc.
W:\Projects\1012\1012-035\Documents\Fof.Soc\Section 05 (V) Alternatives.Doc Page V-5
Resource Originally Proposed Ordinances No Project
Ban Plastic and Paper
Carryout Bags in Los Angeles
County
Ban Plastic Carryout Bags and
Impose a Fee on Paper Carryout
Bags in Los Angeles County
Ban Plastic Carryout Bags for All
Supermarkets and Other Grocery
Stores, Convenience Stores,
Pharmacies, and Drug Stores in
Los Angeles County
Ban Plastic and Paper
Carryout Bags for All
Supermarkets and Other
Grocery Stores, Convenience
Stores, Pharmacies, and Drug
Stores in Los Angeles County
Ban Plastic Carryout Bags and
Impose a Fee on Paper Carryout
Bags for All Supermarkets and
Other Grocery Stores,
Convenience Stores, Pharmacies,
and Drug Stores in Los Angeles
County
Hydrology and
Water Quality
The proposed ordinances may
indirectly result in an increased
demand for paper carryout bags.
The increase in demand for paper
carryout bags may result in
increased eutrophication impacts
as a result of the manufacture of
paper carryout bags, which would
be offset to some degree by
positive impacts to surface water
quality and drainage caused by
anticipated reductions in the
manufacture, transport, and
disposal of plastic carryout bags.
Impact: Impacts due to the life
cycle of paper carryout bags
would be below the level of
significance
The No Project Alternative would not
result in a potential increase in the use
of paper carryout bags, but would not
result in any decrease in the use of
plastic carryout bags. Unlike the
proposed ordinances, the No Project
Alternative would not result in
potential indirect increases in
eutrophication caused by a potential
increase in consumer use of paper
carryout bags. However, the No
Project Alternative may also result in
potential indirect impacts to surface
water quality caused by the life cycle
of plastic carryout bags and drainage
caused by plastic carryout bag litter.
Comparative Impact: Negative
Alternative 1 would not result
in a potential increase in the
use of paper or plastic
carryout bags, and would
result in a greater use of
reusable bags. Alternative 1
would not result in increased
eutrophication impacts as a
result of the manufacture of
paper carryout bags, and
would result in positive
impacts to surface water
quality and drainage caused
by anticipated reductions in
the use of plastic carryout
bags.
Comparative Impact: Positive
Alternative 2 would not result in
as much of a potential increase
in the use of paper carryout
bags, while reducing the use of
plastic carryout bags and
increasing the use of reusable
bags. Alternative 2 would not
result in the same degree of
increased eutrophication impacts
as a result of the manufacture of
paper carryout bags, and would
result in positive impacts to
surface water quality caused by
anticipated reductions in the use
of plastic carryout bags.
Comparative Impact: Positive
Alternative 3 may indirectly result
in an increased demand for paper
carryout bags. The increase in
demand for paper carryout bags
may result in increased
eutrophication impacts as a result
of the manufacture of paper
carryout bags, which would be
offset, to some degree, by positive
impacts to surface water quality
caused by anticipated reductions in
the use of plastic carryout bags.
Comparative Impact: Negative
Alternative 4 would not result
in a potential increase in the
use of paper or plastic
carryout bags, and would
result in a greater use of
reusable bags. Alternative 4
would not result in increased
eutrophication impacts as a
result of the manufacture of
paper carryout bags, and
would result in positive
impacts to surface water
quality caused by anticipated
reductions in the use of plastic
carryout bags.
Comparative Impact: Positive
Alternative 5 will result in
substantial reductions in the use of
plastic carryout bags and increased
use of reusable bags. Due to the
implementation of a fee on the
issuance of paper carryout bags,
the degree of increase in use of
paper carryout bags would be
limited. Alternative 5 will not
result in significant eutrophication
impacts as a result of the
manufacture of paper carryout
bags, and will result in positive
impacts to surface water quality
caused by anticipated reductions in
the use of plastic carryout bags.
Comparative Impact: Positive
Utilities and
Service Systems
The proposed ordinances may
indirectly result in an increased
demand for paper carryout bags.
The increased demand for paper
carryout bags may result in
increased water consumption,
energy consumption, wastewater
generation, and solid waste
generation due to the
manufacture, distribution, and
disposal of paper carryout bags,
which would be offset to some
degree by the anticipated
reduction in plastic carryout bags.
Impact: Impacts due to the life
cycle of paper carryout bags
would be below the level of
significance
The No Project Alternative would not
increase impacts to utilities and
service systems that would result from
the implementation of the proposed
ordinances as it would not result in an
increase in the consumer use of paper
carryout bags. However, due to the
fact that the No Project Alternative
would not result in significant
reductions in the disposal of plastic
carryout bags in the County, the No
Project Alternative would not create
any potential benefits to utilities and
service systems. The No Project
Alternative would not lead to reduced
operational impacts and costs
associated with storm drain system
maintenance.
Comparative Impact: Negative
Alternative 1 would not result
in a potential increase in the
use of paper or plastic
carryout bags, and would
result in a greater use of
reusable bags. Alternative 1
would lead to reduced
operational impacts and costs
associated with storm drain
system maintenance due to
the reduction in plastic
carryout bag litter. Alternative
1 would not result in
increased water consumption,
energy consumption,
wastewater generation, and
solid waste generation due to
the manufacture, distribution,
and disposal of paper carryout
bags.
Comparative Impact: Positive
Alternative 2 would not result in
as much of a potential increase
in the use of paper carryout
bags, while reducing the use of
plastic carryout bags and
increasing the use of reusable
bags. Alternative 2 would lead to
reduced operational impacts and
costs associated with storm drain
system maintenance due to the
reduction in plastic carryout bag
litter. Alternative 2 would not
result in the same degree of
increased water consumption,
energy consumption, wastewater
generation, and solid waste
generation due to the
manufacture, distribution, and
disposal of paper carryout bags.
Comparative Impact: Positive
Alternative 3 may indirectly result
in an increased demand for paper
carryout bags. The increased
demand for paper carryout bags
may result in increased water
consumption, energy consumption,
wastewater generation, and solid
waste generation due to the
manufacture, distribution, and
disposal of paper carryout bags,
which would be offset, to some
degree, by the anticipated
reduction in plastic carryout bags.
Comparative Impact: Negative
Alternative 4 would not result
in a potential increase in the
use of paper or plastic
carryout bags, and would
result in a greater use of
reusable bags. Therefore there
would be no impacts to
increased water consumption,
energy consumption,
wastewater generation, and
solid waste generation due to
the manufacture, distribution,
and disposal of paper carryout
bags or plastic carryout bags.
Alternative 4 would lead to
reduced operational impacts
and costs associated with
storm drain system
maintenance due to the
reduction in plastic carryout
bag litter.
Comparative Impact: Positive
Alternative 5 will result in
substantial reductions in the use of
plastic carryout bags and would
result in a greater use of reusable
bags. Due to the implementation of
a fee on the issuance of paper
carryout bags, the increase in use
of paper carryout bags will be
limited. Alternative 5 will not
result in significant impacts related
to increased water consumption,
energy consumption, wastewater
generation, and solid waste
generation impacts as a result of
the manufacture of paper carryout
bags. Alternative 5 will result in
positive impacts to surface water
quality caused by anticipated
reductions in the use of plastic
carryout bags.
Comparative Impact: Positive
52
Ordinances to Ban Plastic Carryout Bags in Los Angeles County FOF/SOC
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V.A NO PROJECT ALTERNATIVE
Description of Alternative
Under the No Project Alternative, the County would not pass an ordinance to ban the issuance of
plastic carryout bags by certain stores in the unincorporated territories of the County, and would not
encourage the adoption of comparable ordinances by the 88 incorporated cities within the County.
Under this alternative and as discussed in detail in Section 4.2.1 of the EIR, potential impacts to air
quality and GHG emissions would not increase in comparison with the proposed ordinances.
However, in comparison with the proposed ordinances, impacts to biological resources, hydrology
and water quality, and utilities and service systems would be exacerbated, rather than be avoided or
reduced. In addition, the No Project Alternative would not meet any of the basic objectives of the
proposed ordinances established by the County, including those relating to litter. The No Project
Alternative has been analyzed in detail in the EIR in accordance with the requirements of CEQA.
Effectiveness in Meeting Project Objectives
As shown in Table V-1, the No Project Alternative would not accomplish any of the basic objectives of
the proposed ordinances established by the County. The No Project Alternative would not facilitate
encouragement of the 88 incorporated cities of the County to adopt ordinances to ban the issuance of
plastic carryout bags. The No Project Alternative would not assist in reducing the Countywide
consumption of plastic carryout bags, would not result in a reduction of plastic carryout bag litter that
blights public spaces and marine environments, and would not reduce the County’s, cities’, and Flood
Control District’s costs for prevention, clean-up, and enforcement efforts to reduce litter in the County.
The No Project Alternative would not increase public awareness of the negative impacts of plastic
carryout bags and the benefits of reusable bags. In addition, the No Project Alternative would not
assist in reducing Countywide disposal of plastic carryout bags in landfills.
Comparison of Effects of the No Project Alternative to Effects of the Proposed Project
The regulatory framework and existing conditions would be the same as that described for the
proposed ordinances. A summary comparison of this alternative to effects of the proposed ordinances
is presented in Table V-2. The analysis presented in the table, and as further detailed in Section 4.2.1
of the EIR, shows that this alternative differs from the proposed ordinances in the assessment of air
quality, biological resources, GHG emissions, hydrology and water quality, and utilities and service
systems.
Feasibility: The Board of Supervisors finds that specific economic, legal, social, technological, or other
considerations make this alternative infeasible and therefore rejects this alternative.
Rationale: The No Project Alternative would meet none of the six objectives of the proposed
ordinances (Table V-1). The No Project alternative would not result in any reduction in the use of
plastic carryout bags within the County. Without the reduction in use, none of the six objectives of the
proposed ordinances can be met.
Moreover, in comparison with the proposed ordinances, the No Project Alternative would exacerbate
impacts to biological resources and hydrology and water quality, and would not have positive impacts
to utilities and service systems, because it would allow continued distribution of plastic carryout bags
in the County. With respect to biological resources, as discussed in the EIR, including in Sections
4.2.1.3, 3.2, and 13.0, the No Project Alternative would not assist in reducing litter attributable to
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plastic carryout bag waste, would not improve habitats and aquatic life, and would not result in
potentially beneficial impacts upon sensitive habitats, because it would not significantly reduce the use
and disposal of plastic carryout bags within the County. The No Project Alternative would continue to
exacerbate rather than avoid or reduce impacts to biological resources.
With respect to hydrology and water quality, as discussed in the EIR, including in Section 3.4, Section
4.2.1.3, and Section 13.0, the No Project Alternative would continue to exacerbate impacts because it
would not significantly reduce the use of plastic carryout bags in the County. The No Project
Alternative would not assist in meeting TMDL requirements, water quality standards, or waste
discharge requirements because it would allow continued contribution of plastic carryout bags that can
become litter in major surface water systems in the County drainage areas, the Pacific Ocean, and
inland drainages in the Antelope Valley. The No Project Alternative would also not result in
potentially beneficial impacts to surface water drainage, storm drain systems, or surface water quality
in the County, and would not assist the County in attaining TMDLs because the alternative would not
result in a decrease of the use of plastic carryout bags.
With respect to utilities and service systems, as discussed in the EIR, including in Sections 3.5, Section
4.2.1.3, and Section 13.0, the No Project Alternative would not result in significant reductions in the
use and disposal of plastic carryout bags in the County, and therefore would not result in any potential
benefits to landfills and would not lead to reduced operational impacts and costs associated with storm
drain system maintenance.
Finally, the No Project Alternative would not provide any of the benefits set forth in the Statement of
Overriding Considerations (see Section IX).
V.B ALTERNATIVE 1: BAN PLASTIC AND PAPER CARRYOUT BAGS IN LOS ANGELES COUNTY
Description of Alternative
Alternative 1 would extend the scope of the proposed ordinances to include a ban on the issuance of
both paper and plastic carryout bags in Los Angeles County, and encouraging the 88 incorporated
cities to adopt similar proposed ordinances. Alternative 1 would ban the issuance of paper and plastic
carryout bags from the same stores addressed by the proposed ordinances, that is, those within the
County that (1) meet the definition of a “supermarket” as found in the California Public Resources
Code, Section 14526.5, and (2) are buildings that have over 10,000 square feet of retail space that
generates sales or use tax pursuant to the Bradley-Burns Uniform Local Sales and Use Tax Law and
have a pharmacy licensed pursuant to Chapter 9 of Division 2 of the Business and Professions Code.
As with the proposed ordinances, Alternative 1 would affect approximately 67 stores in the
unincorporated areas of the County and approximately 462 stores in the incorporated cities of the
County.
1,2
As with the proposed ordinances and as discussed in detail in Sections 3.0 and 4.2.2 of the EIR,
Alternative 1 would not result in significant adverse impacts to air quality, biological resources,
1
As a result of the voluntary Single Use Bag Reduction and Recycling Program, the County has determined that 67 stores in
unincorporated areas would be affected by the proposed County ordinance.
2
Number of stores in the 88 incorporated cities of the County was determined from the infoUSA database for businesses with
North American Industry Classification System codes 445110 and 446110 with a gross annual sales volume of $2 million or
higher and a square footage of 10,000 square feet or greater. Accessed on: 29 April 2010.
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hydrology and water quality, and utilities and service systems, and would achieve additional benefits.
In that there would be no transition from plastic to paper carryout bags if both types of bags were
banned, impacts to air quality, biological resources, GHG emissions, hydrology and water quality, and
utilities and service systems would be eliminated, reduced, or avoided.
Effectiveness in Meeting Project Objectives
As shown in Table V-1, Alternative 1 would meet all of the ordinance objectives that were identified
by the County. In addition, Alternative 1 would also serve to reduce Countywide consumption of
paper carryout bags and the Countywide disposal of paper carryout bags in landfills.
Comparison of Effects of the Alternative to Effects of the Proposed Project
The regulatory framework and existing conditions would be the same as that described for the
proposed ordinances. A summary comparison of this alternative to effects of the ordinances is
presented in Table V-2. The analysis presented in the table shows that this alternative would result in
positive impacts to air quality, GHG emissions, hydrology and water quality, and utilities and service
systems when compared to the proposed ordinances.
Finding:
The Board of Supervisors finds that specific economic, legal, social, technological, or other
considerations make this alternative infeasible and therefore rejects this alternative.
Rationale:
This alternative meets all of the basic objectives of the proposed ordinances (Table V-1) and
would not result in an increase in the use of paper carryout bags. However, a ban on the
issuance of both plastic and paper carryout bags is infeasible because the County prefers an
option at this time for consumers to purchase carryout bags. The County anticipates a certain
transition period for consumers to become aware of and adapt to the recommended
ordinances, particularly to remember to take and use reusable bags at affected stores. In
addition, visitors to the County may not be aware of recommended ordinances and may not
know to take and use reusable bags at affected stores in the County. Further, due to the limited
number of stores that would be affected by Alternative 1 (compared to Alternatives 3, 4, or 5),
the alternative would not produce the additional benefits to biological resources that would
result from banning the issuance of plastic bags at a greater number of stores. For the same
reason, the alternative would not provide as large of a reduction in litter that is attributable to
plastic carryout bags. Therefore, it would also not provide a comparable opportunity for
reduction of costs related to litter prevention, cleanup, and disposal of plastic carryout bags,
nor a comparable reduction in litter that blights public spaces.
V.C ALTERNATIVE 2: BAN PLASTIC CARRYOUT BAGS AND IMPOSE A FEE ON PAPER
CARRYOUT BAGS IN LOS ANGELES COUNTY
Description of Alternative
Alternative 2 would extend the scope of the proposed ordinances to include a fee on the issuance of
paper carryout bags in Los Angeles County, and encouraging the 88 incorporated cities to adopt
similar proposed ordinances. Alternative 2 would require a fee for issuance of paper carryout bags by
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the same stores addressed by the proposed ordinances, that is, those within the County that (1) meet
the definition of a “supermarket” as found in the California Public Resources Code, Section 14526.5,
and (2) are buildings that have over 10,000 square feet of retail space that generates sales or use tax
pursuant to the Bradley-Burns Uniform Local Sales and Use Tax Law and have a pharmacy licensed
pursuant to Chapter 9 of Division 2 of the Business and Professions Code. As with the proposed
ordinances, the number of stores that could be affected by Alternative 2 in the unincorporated areas of
the County is approximately 67.|1010| The number of stores that could be affected by Alternative 2 in the
incorporated cities of the County is approximately 462.|1010|
As with the proposed ordinances and as discussed in detail in Section 4.2.3 of the EIR, Alternative 2
would not result in significant adverse impacts to air quality, biological resources, hydrology and water
quality, and utilities and service systems, and would achieve additional benefits. Alternative 2 would
be expected to result in a minimal transition from plastic to paper carryout bags due to a fee on the
issuance of paper carryout bags, and therefore in comparison with the proposed ordinances would
eliminate, reduce, or avoid impacts to air quality, biological resources, hydrology and water quality,
and utilities and service systems. However, because it is not possible to know the exact percentage of
increase from plastic to paper carryout bags under Alternative 2, the indirect impacts from the life
cycle of paper carryout bags may be cumulatively considerable, depending on the actual percentage
increase despite the presence of a fee.
Effectiveness in Meeting Project Objectives
As shown in Table V-1, Alternative 2 would meet all of the objectives of the proposed ordinances
identified by the County. In addition, Alternative 2 would also serve to reduce the Countywide
consumption of paper carryout bags and the Countywide disposal of paper carryout bags in landfills.
Comparison of Effects of the Alternative to Effects of the Project
The regulatory framework and existing conditions would be the same as that described for the
proposed ordinances. A summary comparison of this alternative to effects of the ordinances is
presented in Table V-2. The analysis presented in the table shows that this alternative would be
anticipated to result in positive impacts to air quality, hydrology and water quality, and utilities and
service systems when compared with the proposed ordinances.
Finding:
The Board of Supervisors finds that specific economic, legal, social, technological, or other
considerations make this alternative infeasible and therefore rejects this alternative.
Rationale:
Alternative 2 meets all of the basic objectives of the proposed ordinances (Table V-1).
Alternative 2 would also be expected to reduce consumption of paper carryout bags through
3
As a result of the voluntary Single Use Bag Reduction and Recycling Program, the County has determined that 67 stores in
unincorporated areas would be affected by the proposed County ordinance.
4
Number of stores in the 88 incorporated cities of the County was determined from the infoUSA database for businesses with
North American Industry Classification System codes 445110 and 446110 with a gross annual sales volume of $2 million or
higher and a square footage of 10,000 square feet or greater. Accessed on: 29 April 2010.
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implementation of a fee. However, due to the limited number of stores that Alternative 2
would affect (compared to Alternatives 3, 4, or 5), it would not provide the additional benefits
to biological resources that would result from banning the issuance of plastic bags at a greater
number of stores. For the same reason, it would not provide as large of a reduction in litter
attributable to plastic carryout bags. Therefore, it would also not provide a comparable
opportunity for reduction of costs related to litter prevention, cleanup, and disposal, nor a
comparable reduction in litter that blights public spaces.
V.D ALTERNATIVE 3: BAN PLASTIC CARRYOUT BAGS FOR ALL SUPERMARKETS AND OTHER
GROCERY STORES, CONVENIENCE STORES, PHARMACIES, AND DRUG STORES IN LOS
ANGELES COUNTY
Description of Alternative
Alternative 3 would extend the scope of the proposed ordinances to apply to all supermarkets and
other grocery stores, convenience stores, pharmacies and drug stores, but not including restaurant
establishments. Alternative 3 would ban the issuance of plastic carryout bags from stores within the
County that (1) meet the definition of a “supermarket” as found in the California Public Resources
Code, Section 14526.5, and (2) are buildings that have retail space that generates sales or use tax
pursuant to the Bradley-Burns Uniform Local Sales and Use Tax Law and have a pharmacy licensed
pursuant to Chapter 9 of Division 2 of the Business and Professions Code. In addition, Alternative 3
would apply to stores within the County that are part of a chain of convenience food stores,
supermarkets and other grocery stores, convenience stores, pharmacies and drug stores in the County.
The number of stores that could be affected by Alternative 3 in the unincorporated areas of the County
is approximately 1,091.|1010| The number of stores that could be affected by Alternative 3 in the
incorporated cities of the County is approximately 5,084.|1010| It was assumed that each store larger than
10,000 square feet currently uses approximately 10,000 plastic carryout bags per day,|1010| and each store
smaller than 10,000 square feet currently uses approximately 5,000 plastic carryout bags per day.|1010| It is
important to note that these numbers are likely very high, as 10,000 plastic carryout bags per day is
more than twice the bag average reported by the California Department of Resources Recycling and
Recovery (CalRecycle) in 2008 for AB 2449 affected stores. In 2008, 4,700 stores statewide affected
5
Number of stores in the unincorporated territories of the County was determined from the infoUSA database for businesses
with North American Industry Classification System codes 445110, 445120, and 446110 with no filters for gross annual sales
volume or square footage. Accessed on: 29 April 2010.
6
Number of stores in the 88 incorporated cities of the County was determined from the infoUSA database for businesses with
North American Industry Classification System codes 445110, 445120, and 446110 with no filters for gross annual sales
volume or square footage. Accessed on: 29 April 2010. |1010| Based on coordination between the County Department of Public Works and several large supermarket chains in the
County, it was determined that approximately 10,000 plastic carryout bags are used per store per day. Due to
confidential and proprietary concerns, and at the request of the large supermarket chains providing this data, the names
of these large supermarket chains will remain confidential. Reported data from only 12 stores reflected a total plastic
carryout bag usage of 122,984 bags per day. A daily average per store was then calculated at 10,249 plastic carryout bags
and rounded to approximately 10,000 bags per day. |1010|Data from the infoUSA indicates that approximately 40 percent of the stores larger than 10,000 square feet in the
unincorporated territories of the County are larger than 40,000 square feet. Therefore, the average size of the stores to be
affected by the proposed County ordinance would be larger than 20,000 square feet. Accordingly, it would be reasonable
to estimate that the stores smaller than 10,000 square feet that would be affected by Alternative 3 would be at less than
half the size of the stores to be affected by the proposed ordinances and would use less than half the number of bags.
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by AB 2449 reported an average of 4,695 bags used per store per day.|10 10| While 10,000 plastic carryout
bags per store per day may not accurately reflect the actual number of bags consumed per day on
average for stores larger than 10,000 square feet in the County unincorporated and incorporated areas,
for the purposes of the EIR, this number was used to conservatively evaluate impacts resulting from a
worst-case scenario. The same may also be true of the 5,000 plastic carryout bags per store per day
estimate for stores less than 10,000 square feet. While the 5,000 plastic carryout bags per store per
day may likely be very high, this number was used for the purposes of the EIR to conservatively
evaluate impacts resulting from a worst-case scenario.
As with the proposed ordinances and as discussed in detail in Section 4.2.4 of the EIR, Alternative 3
would not result in significant adverse impacts to air quality, biological resources, or hydrology and
water quality, and would achieve additional benefits. In that there would be an increased reduction in
the consumption of plastic carryout bags, corresponding adverse impacts to air quality, biological
resources, GHG emissions, hydrology and water quality, and utilities and service systems due to
plastic carryout bags would be eliminated, reduced, or avoided. However, due to a likely increase in
the demand for paper carryout bags, indirect impacts to air quality, biological resources, GHG
emissions, hydrology and water quality, and utilities and service systems due to paper carryout bags
may be increased. As with the proposed ordinances, indirect GHG emission impacts due to the life
cycle of paper carryout bags may have the potential to be cumulatively considerable.
Effectiveness in Meeting Project Objectives
As shown in Table V-1, Alternative 3 would meet all six objectives identified by the County.
Comparison of Effects of the Alternative to Effects of the Project
The regulatory framework and existing conditions would be the same as that described for the proposed
ordinances. A summary comparison of this alternative to effects of the proposed ordinances is presented
in Table V-2. The analysis presented in the table shows that this alternative would be anticipated to result
in positive impacts to biological resources when compared to the proposed ordinances.
Finding:
The Board of Supervisors finds that specific economic, legal, social, technological, or other
considerations make this alternative infeasible and therefore rejects this alternative.
Rationale:
This alternative meets all of the basic objectives of the proposed ordinances (Table V-1).
However, as with the proposed ordinances, and consistent with the County’s evaluation of
impacts due to paper carryout bags under a conservative worst-case scenario, Alternative 3
may have the potential to result in cumulatively considerable indirect impacts to GHG
emissions because it would not limit the issuance of paper carryout bags. It would also cause
greater impacts to air quality, hydrology and water quality, and utilities and public services,
than the proposed ordinances would cause, even though those impacts are below the level of
significance.
|10 10| Dona Sturgess, California Department of Resources Recycling and Recovery, Sacramento, CA. 29 April 2010. E-mail to
Luke Mitchell, County of Los Angeles, Department of Public Works, Alhambra, CA.
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V.E ALTERNATIVE 4: BAN PLASTIC AND PAPER CARRYOUT BAGS FOR ALL SUPERMARKETS
AND OTHER GROCERY STORES, CONVENIENCE STORES, PHARMACIES, AND DRUG
STORES IN LOS ANGELES COUNTY
Description of Alternative
Alternative 4 would extend the scope of the proposed ordinances to apply to all supermarkets and
other grocery stores, convenience stores, pharmacies, and drug stores (as opposed to applying only to
stores larger than 10,000 square feet under the proposed ordinances), but not including restaurant
establishments. Alternative 4 would ban the issuance of plastic and paper carryout bags from stores
within the County that (1) meet the definition of a “supermarket” as found in the California Public
Resources Code, Section 14526.5, and (2) are buildings that generate sales or use tax pursuant to the
Bradley-Burns Uniform Local Sales and Use Tax Law and have a pharmacy licensed pursuant to
Chapter 9 of Division 2 of the Business and Professions Code. In addition, Alternative 4 would apply
to stores within the County that are part of a chain of convenience food stores, all supermarkets and
other grocery stores, convenience stores, pharmacies, and drug stores in Los Angeles County.
As with the proposed ordinances and as discussed in detail in Section 4.2.4 of the EIR, Alternative 4
would not result in significant adverse impacts to air quality, biological resources, hydrology and water
quality, and utilities and service systems, and would achieve additional benefits. In that there would
be an increased reduction in the consumption of plastic carryout bags, corresponding adverse impacts
to air quality, biological resources, GHG emissions, hydrology and water quality, and utilities and
service systems due to plastic carryout bags would be eliminated, reduced, or avoided. Unlike the
proposed ordinances, Alternative 4 would not have the potential to result in cumulatively considerable
impacts to GHG emissions.
Alternative 4 would affect approximately 1,091 stores in the unincorporated areas of the County and
approximately 5,084 stores in the incorporated cities of the County.
10
,11
It was assumed that each
store larger than 10,000 square feet currently uses approximately 10,000 plastic carryout bags per
day,
12
and each store smaller than 10,000 square feet currently uses approximately 5,000 plastic
carryout bags per day.
13
It is important to note that these numbers are likely very high, as 10,000
plastic carryout bags per day is more than twice the bag average reported by the California Department
of Resources Recycling and Recovery in 2008 for AB 2449 affected stores. In 2008, 4,700 stores
10
Number of stores in the unincorporated territories of the County was determined from the infoUSA database for businesses
with North American Industry Classification System codes 445110, 445120, and 446110 with no filters for gross annual sales
volume or square footage. Accessed on: 29 April 2010.
11
Number of stores in the 88 incorporated cities of the County was determined from the infoUSA database for businesses with
North American Industry Classification System codes 445110, 445120, and 446110 with no filters for gross annual sales
volume or square footage. Accessed on: 29 April 2010.
12
Based on coordination between the County Department of Public Works and several large supermarket chains in the
County, it was determined that approximately 10,000 plastic carryout bags are used per store per day. Due to
confidential and proprietary concerns, and at the request of the large supermarket chains providing this data, the names
of these large supermarket chains will remain confidential. Reported data from only 12 stores reflected a total plastic
carryout bag usage of 122,984 bags per day. A daily average per store was then calculated at 10,249 plastic carryout bags
and rounded to approximately 10,000 bags per day.
13
Data from the infoUSA indicates that approximately 40 percent of the stores larger than 10,000 square feet in the
unincorporated territories of the County are larger than 40,000 square feet. Therefore, the average size of the stores to be
affected by the proposed County ordinance would be larger than 20,000 square feet. Accordingly, it would be reasonable
to estimate that the stores smaller than 10,000 square feet that would be affected by Alternative 3 would be at less than
half the size of the stores to be affected by the proposed ordinances and would use less than half the number of bags.
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statewide affected by AB 2449 reported an average of 4,695 bags used per store per day.
14
While
10,000 plastic carryout bags per store per day may not accurately reflect the actual number of bags
consumed per day on average for stores larger than 10,000 square feet in the County unincorporated
and incorporated areas, for the purposes of the EIR, this number was used to conservatively evaluate
impacts resulting from a worst-case scenario. The same may also be true of the 5,000 plastic carryout
bags per store per day estimate for stores less than 10,000 square feet. While the 5,000 plastic
carryout bags per store per day may likely be very high, for the purposes of the EIR, this number was
used to conservatively evaluate impacts resulting from a worst-case scenario as well.
Effectiveness in Meeting Project Objectives
As shown in Table V-1, Alternative 4 would meet all of the six objectives identified by the County. In
addition, Alternative 4 would also serve to reduce the Countywide consumption of paper carryout bags
and the Countywide disposal of paper carryout bags in landfills.
Comparison of Effects of the Alternative to Effects of the Project
The regulatory framework and existing conditions would be the same as that described for the
proposed ordinances. A summary comparison of this alternative to effects of the proposed ordinances
is presented in Table V-2. The analysis presented in the table shows that this alternative would be
anticipated to result in positive impacts to air quality, biological resources, GHG emissions, hydrology
and water quality, and utilities and service systems when compared to the proposed ordinances.
Finding:
The Board of Supervisors finds that specific economic, legal, social, technological, or other
considerations make this alternative infeasible and therefore rejects this alternative.
Rationale:
This alternative meets all of the basic objectives of the proposed ordinances (Table V-1) and
would not result in any increase in the use of paper carryout bags. However, a ban on the
issuance of both plastic and paper bags is infeasible at this time because the County prefer to
retain an option for consumers to purchase carryout bags. The County anticipates a transition
period for consumers to become aware of and adapt to the recommended ordinances,
particularly to remember to take and use reusable bags at affected stores. In addition, visitors
to the County may not be aware of recommended ordinances and may not know to take and
use reusable bags at affected stores in the County.
14
Dona Sturgess, California Department of Resources Recycling and Recovery, Sacramento, CA. 29 April 2010. E-mail to
Luke Mitchell, County of Los Angeles, Department of Public Works, Alhambra, CA.
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V.F ALTERNATIVE 5: BAN PLASTIC CARRYOUT BAGS AND IMPOSE A FEE ON PAPER
CARRYOUT BAGS FOR ALL SUPERMARKETS AND OTHER GROCERY STORES,
CONVENIENCE STORES, PHARMACIES, AND DRUG STORES IN LOS ANGELES COUNTY
Description of Alternative
To maximize to the greatest extent feasible the potential environmental benefit from a fee on the
issuance of paper carryout bags, and to mitigate GHG-related impacts from a shift to paper carryout
bag use, the County developed Alternative 5, which combines Alternatives 2, 3, and 4. Like
Alternatives 3 and 4, Alternative 5 will affect all supermarkets and other grocery stores, pharmacies,
drug stores, and convenience stores in the County, with no limits on square footage or sales volumes.
Like Alternative 2, Alternative 5 will ban the issuance of plastic carryout bags and place a fee on the
issuance of paper carryout bags at affected stores. Alternative 5 will ban the issuance of plastic
carryout bags and impose a fee or charge of at least $0.05 on the issuance of paper carryout bags from
stores within the County that (1) meet the definition of a “supermarket” as written in the California
Public Resources Code, Section 14526.5, and (2) are buildings that have retail space that generates
sales or use tax pursuant to the Bradley-Burns Uniform Local Sales and Use Tax Law and have a
pharmacy licensed pursuant to Chapter 9 of Division 2 of the Business and Professions Code. In
addition, Alternative 5 will apply to other grocery stores, convenience stores, and drug stores within
the County. Alternative 5, like Alternative 3 and 4, which included the same broader range of stores,
will include a phased approach in that it will apply to large grocery stores and pharmacies prior to
smaller grocery stores, convenience stores, and drug stores.
Alternative 5 will affect approximately 1,091 stores in the unincorporated areas of the County and
approximately 5,084 stores in the incorporated cities of the County.
15
,
16
This is the same number of
stores analyzed for Alternatives 3 and 4. It is assumed that each store larger than 10,000 square feet
currently uses approximately 10,000 plastic carryout bags per day,
17
and that each store smaller than
10,000 square feet currently uses approximately 5,000 plastic carryout bags per day.
18
It is important
to note that these numbers are very high, as 10,000 plastic carryout bags per day is more than twice
the bag average reported by CalRecycle in 2008 for AB 2449 affected stores. In 2008, 4,700 stores
15
Number of stores in the unincorporated territories of the County was determined from the infoUSA database for
businesses with North American Industry Classification System codes 445110, 445120, and 446110 with no filters for
gross annual sales volume or square footage. Accessed on: 29 April 2010.
16
Number of stores in the 88 incorporated cities of the County was determined from the infoUSA database for businesses
with North American Industry Classification System codes 445110, 445120, and 446110 with no filters for gross annual
sales volume or square footage. Accessed on: 29 April 2010.
17
Based on coordination between the County Department of Public Works and several large supermarket chains in the
County, it was determined that approximately 10,000 plastic carryout bags are used per store per day. Due to
confidential and proprietary concerns, and at the request of the large supermarket chains providing this data, the names
of these large supermarket chains will remain confidential. Reported data from only 12 stores reflected a total plastic
carryout bag usage of 122,984 bags per day. A daily average per store was then calculated at 10,249 plastic carryout bags
and rounded to approximately 10,000 bags per day.
18
Data from the infoUSA indicates that approximately 40 percent of the stores greater than 10,000 square feet in the
unincorporated territories of the County are larger than 40,000 square feet. Therefore, the average size of the stores to be
affected by the proposed County ordinance would be greater than 20,000 square feet. Accordingly, it would be
reasonable to estimate that the stores smaller than 10,000 square feet that would be affected by Alternative 5 would be at
less than half the size of the stores to be affected by the proposed ordinances and would use less than half the number of
bags.
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throughout California affected by AB 2449 reported using an average of 4,695 bags per store per day.
19
While 10,000 plastic carryout bags per store per day may not accurately reflect the actual number of
bags consumed per day on average for stores larger than 10,000 square feet in the County, for the
purposes of this EIR this number was used to conservatively evaluate impacts resulting from such a
worst-case scenario. The same may also be true of the estimate of 5,000 plastic carryout bags per store
per day for stores smaller than 10,000 square feet. While this estimate is likely very high, this number
was used for the purposes of this EIR to conservatively evaluate impacts resulting from such a worst-
case scenario as well.
As with the proposed ordinances, Alternative 5 will not result in significant adverse impacts to air
quality, biological resources, or hydrology and water quality. Alternative 5 will achieve additional
benefits due to a greater reduction in the use of plastic carryout bags. Alternative 5 will lead to a
greater reduction in the consumption of plastic carryout bags as a result of including a greater number
of stores than the proposed ordinances; therefore, life cycle impacts of plastic carryout bags to air
quality, biological resources, GHG emissions, hydrology and water quality, and utilities and service
systems will be eliminated, reduced, or avoided in comparison with the proposed ordinances. A
minimal transition, as discussed below, from plastic to paper carryout bags will be expected to occur if
a fee or charge were placed on the issuance of paper carryout bags. Alternative 5 impacts due to the
life cycle impacts of paper carryout bags will be less than the impacts of Alternative 3, which would
ban plastic carryout bags at the expanded number of stores without imposing a fee or ban on the
issuance of paper carryout bags.
Effectiveness in Meeting Project Objectives
As shown in Table V-1, Alternative 5 meets all of the basic objectives of the proposed ordinances
established by the County. In addition, Alternative 5 will also serve to reduce Countywide
consumption of paper carryout bags and the Countywide disposal of paper carryout bags in landfills.
Comparison of Effects of the Alternative to Effects of the Project
The regulatory framework and existing conditions will be the same as that described for the proposed
ordinances. Table V-2 provides a summary comparison of Alternative 5 to the proposed ordinances.
The comparative analysis presented in the table shows that Alternative 5 will result in positive impacts
to air quality, biological resources, hydrology and water quality, and utilities and service systems.
Finding:
The Board of Supervisors finds that this alternative is feasible.
Rationale:
This alternative meets all of the basic objectives of the proposed ordinances (Table V-1). The
fee or charge on the issuance of paper carryout bags will allow for flexibility during the
anticipated transition period that the County anticipates for consumers to become aware of and
adapt to the recommended ordinances, particularly to remember to take and use reusable bags
at affected stores, and for visitors to become aware of the recommended ordinances. Further,
19
Dona Sturgess, California Department of Resources Recycling and Recovery, Sacramento, CA. 29 April 2010. E-mail to
Luke Mitchell, County of Los Angeles, Department of Public Works, Alhambra, CA.
62
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because the Alternative 5 will affect a larger number of stores, it will be expected to afford
additional benefits to biological resources because it will reduce plastic carryout bag litter, to
the greatest extent feasible, that would otherwise end up in wildlife habitats. The alternative
will provide for a larger reduction in litter attributable to plastic carryout bags; a greater
opportunity for reducing costs related to litter prevention, cleanup, and disposal; and a greater
improvement to the quality of life for County residents by reducing litter that blights public
spaces.
V.G PROPOSED ORDINANCES (ORIGINALLY PROPOSED PROJECT)
Description of Proposed Ordinances
The proposed ordinances would ban the issuance of plastic carryout bags in the County, and would
encourage the 88 incorporated cities to adopt similar ordinances. The proposed ordinances would ban
the distribution of plastic carryout bags at affected stores within the County that (1) meet the definition
of a “supermarket” as found in the California Public Resources Code, Section 14526.5, and (2) are
buildings that have over 10,000 square feet of retail space that generates sales or use tax pursuant to
the Bradley-Burns Uniform Local Sales and Use Tax Law and have a pharmacy licensed pursuant to
Chapter 9 of Division 2 of the Business and Professions Code. The proposed ordinances would affect
approximately 67 stores in the incorporated cities of the County and approximately 462 stores in the
unincorporated territory of the County.
As discussed in detail in the EIR, including in Sections 3.0 and 13.0, the proposed ordinances would
not result in significant adverse impacts to air quality, biological resources, hydrology and water
quality, and utilities and service systems, and would achieve additional benefits. However, under the
County's conservative worst-case scenario, the indirect impacts from the life cycle of paper carryout
bags, including end of life, would have the potential to be cumulatively considerable.
Effectiveness in Meeting Project Objectives
As shown in Table V-1, the proposed ordinances would meet all of the objectives identified by the
County.
Finding:
The Board of Supervisors finds that specific economic, legal, social, technological, or other
considerations make the proposed ordinances infeasible and therefore rejects the originally
proposed ordinances.
Rationale:
The originally proposed ordinances meet all of the basic objectives (Table V-1). However, due
to the limited number of stores that they would affect (compared to Alternatives 3, 4, or 5), the
proposed ordinances would not provide the additional benefits to biological resources that
would result from banning the issuance of plastic bags at a greater number of stores (as would
Alternative 5). For the same reason, the proposed ordinances would not provide the largest
reduction in litter attributable to plastic carryout bags; would not provide the greatest
opportunity for reducing costs related to litter prevention, cleanup, and disposal; and would
not provide the greatest potential improvement in the quality of life of County residents by
reducing litter that blights public spaces.
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SECTION VI
FINDINGS REGARDING MITIGATION MONITORING PROGRAM
VI.A REQUIREMENTS OF MITIGATION MONITORING PROGRAM
Pursuant to Section 21081.6 of the Public Resources Code, when a public agency is making findings
required by Section 21081, it must adopt a reporting or monitoring program for the changes made to
the project or conditions of project approval adopted to mitigate or avoid significant effects on the
environment.
The County hereby finds that the Mitigation Monitoring Program meets the requirements of Section
21081.6 of the Public Resources Code by providing a monitoring program designed to ensure
compliance of the recommended County ordinance with mitigation measures adopted by the County.
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SECTION VII
FINDINGS REGARDING LOCATION AND
CUSTODIAN OF DOCUMENTS
VII.A LOCATION AND CUSTODIAN OF DOCUMENTS
Section 15091(e) of the California Code of Regulations, State CEQA Guidelines, requires the public
agency to specify the location and custodian of the documents or other materials that constitute the
record of proceedings upon which the decision is based. Section 10.0, References, of the EIR lists
all sources used in the preparation of the environmental analysis. Unless otherwise noted,
reference materials are located at the LACDPW, which shall also serve as the custodian of the
documents constituting the record of proceedings upon which the County Board of Supervisors has
based its decision related to the proposed ordinances. The designated location and custodian of
documents is as follows:
County of Los Angeles c/o Department of Public Works
Attn: Mr. Coby Skye
Environmental Programs Division
900 South Fremont Avenue, 3rd Floor
Alhambra, California 91803
Tel: (626) 458-5163
References not available from the LACDPW are located at Sapphos Environmental, Inc., and can
be reviewed by contacting the following party:
Dr. Laura Watson
Environmental Compliance Specialist
Sapphos Environmental, Inc.
430 North Halstead Street
Pasadena, California 91107
Tel: (626) 683-3547
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SECTION VIII
CERTIFICATION REGARDING INDEPENDENT JUDGMENT
Pursuant to Section 21082.1(c) of the Public Resources Code, the County Board of Supervisors
certifies that the Chief Executive Office, the LACDPW, and other County staff, have independently
reviewed and analyzed the Final EIR on behalf of the County of Los Angeles. The Chief Executive
Office, LACDPW, and other County staff reviewed the Draft EIR prepared by the County and
required changes to the document prior to circulation for public review. The Draft EIR that was
circulated for public review reflected the independent judgment of the Chief Executive Office and
LACDPW, acting on behalf of the County of Los Angeles. The Final EIR similarly has been subject
to review and revision by County staff and reflects the independent judgment of the County of Los
Angeles.
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SECTION IX
STATEMENT OF OVERRIDING CONSIDERATIONS
As discussed in detail in Section 4.2.6 of the EIR, the indirect impacts from implementation of the
recommended ordinances (analyzed as Alternative 5) will result in increased indirect GHG
emissions from the decomposition of paper carryout bags in landfills, which will result in
cumulatively significant impacts under the County's conservative worst-case analysis. This indirect
impact is the only potentially significant impact that will result from Alternative 5. The EIR
identified mitigation measure GHG-1 to mitigate GHG emission impacts from the recommended
ordinances. While the implementation of mitigation measure GHG-1 will monitor and reduce the
consumption of paper carryout bags and, to the maximum extent feasible, indirectly offset end-of-
life GHG emissions resulting from the recommended ordinance, the County has decided that no
emission reduction credits will be taken for the measure, and for the purposes of the decision-
making process, the County will proceed with the conclusion that indirect impacts to end-of-life
GHG emissions will remain cumulatively considerable.
Section 15093 of State CEQA Guidelines states that, when a public agency approves a project that
will result in unavoidable significant impacts, it must state in writing specific reasons to support its
decision. If specific economic, legal, social, technological, or other benefits of the project
outweigh its unavoidable adverse environmental effects, the adverse effects may be considered
“acceptable.” Pursuant to Public Resources Code Section 21081(b) and Section 15093 of the State
CEQA Guidelines, the Board of Supervisors has considered the benefits of the project along with
the unavoidable environmental risks, and has adopted all feasible mitigation measures for the
unavoidable significant impact. The Board of Supervisors has also examined a range of reasonable
alternatives to the project, and has determined that adoption and implementation of the
recommended ordinance (analyzed as Alternative 5) is the most desirable, feasible, and appropriate
action. The County Board of Supervisors, as the lead agency for the project pursuant to CEQA, has
determined that the economic and environmental benefits of the recommended ordinance
outweigh the unavoidable adverse environmental effects resulting from the County's conservative
worst-case scenario, and adopts the following Statement of Overriding Considerations.
The Board of Supervisors finds that each of the following benefits is an overriding consideration,
independent of the other benefits, which warrants approval of the recommended County
ordinance. Substantial evidence in the record supports this conclusion, and can be found in the
preceding findings, EIR, Record of Proceedings documentation, and public hearings and
proceedings for ordinances.
IX.A ADVERSE ENVIRONMENTAL RISKS
Section 3.3 and Section 4.0 of the EIR identified and evaluated potentially significant cumulative
impacts related to GHG emissions. Based on a conservative worst-case analysis, the indirect
impacts to GHG emissions from the end-of-life of paper carryout bags may have the potential to be
cumulatively considerable, depending on the actual percentage increase in conversion to paper
carryout bags, the number of stores affected, the actual bag usage per day, the size of the fee or
charge, and other relevant factors that are specific to each of the 88 incorporated cities within the
County. In the development of this EIR, the County has recognized and acknowledged that each
city has the authority to render an independent decision regarding implementation of its own
ordinance. For the purposes of this EIR, the County has extended the worst-case scenario for the
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County ordinance and alternatives to a scenario where all 88 cities adopt comparable ordinances.
However, an individual determination, including for cumulative impacts, for each city would be
contingent on the exact parameters of the city’s proposed ordinance, consideration of the above-
identified factors, the city’s adopted thresholds of significance, and its projected AB 32 GHG
emissions target.
Although the decomposition of paper carryout bags in landfills results in emissions of methane gas,
a GHG, it is important to note that the results presented in the EIR are highly conservative and are
likely to be overestimates for the County, as emissions from active landfills in the County are
strictly controlled by SCAQMD Rule 1150.1, AVAQMD Rule 1150.1, and the new State
requirements that regulate methane emissions from landfills in accordance with the goals of AB 32.
The USEPA’s Landfill Methane Outreach Program states that methane collection efficiency ranges
from 60 to 90 percent.
1,2
The conclusion that GHG emissions from the decomposition of paper carryout bags in landfills is
expected to be cumulatively considerable is based on the County’s conservative assumption of a
50-percent conversion from plastic carryout bags to paper carryout bags. However, if the paper
carryout bag fee has the effect of decreasing conversion to paper carryout bags by 80 to 90 percent,
similar to what occurred with the Ireland and Washington, DC, bag fees, indirect impacts to GHG
emissions would be reduced. Although implementation of a fee of $0.10 on the issuance of paper
carryout bags will be an incentive for consumers to reduce their consumption of paper carryout
bags, the recommended ordinances are expected to result in a limited increase in the use of paper
carryout bags, so GHG emission impacts will still have the potential to remain as significantly
adverse on a cumulative level.
The EIR analyzed Alternatives 1 and 4, which would ban the issuance of paper carryout bags and
therefore would avoid any potentially significant cumulative GHG emission impacts due to a
potential increase in disposal of paper carryout bags. However, County determined that a ban on
the issuance of both plastic and paper carryout bags is infeasible at this time because the County
requires an option for consumers to purchase carryout bags at this time. The County anticipates a
certain transition period for consumers to become aware of and adapt to the recommended
ordinances, particularly to remember to use reusable bags at affected stores. In addition, visitors to
the County may not be aware of recommended ordinances and may not know to take and use
reusable bags at affected stores in the County.
The economic and environmental benefits, as well as public policy considerations, resulting from
implementation of the recommended ordinances override the potential cumulative indirect impacts
associated with GHG emissions. Implementation of a fee on the issuance of paper carryout bags
will minimize the number of paper carryout bags used in the County, as well as any corresponding
GHG emissions due to the decomposition of paper carryout bags in landfills. The recommended
ordinances will require each affected store to issue a quarterly report of the total number of paper
carryout bags sold along with a summary of efforts, if any, undertaken by the store to promote the
use of reusable bags. The County will keep records of these reports to ensure that consumers in
the County are using fewer carryout bags and more reusable bags as a result of the recommended
1
California Air Resources Board. 17 June 2010. Methane Emissions from Municipal Solid Waste Landfills. Available at:
http://www.arb.ca.gov/regact/2009/landfills09/landfillfinalfro.pdf |1010| U.S. Environmental Protection Agency. Accessed on: 7 October 2010. “Landfill Methane Outreach Program.” Web site.
Available at: http://www.epa.gov/lmop/basic-info/index.html#a03
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ordinances. The County will also use the reports to assess whether the desired effects of the
recommended ordinances are being obtained. As part of mitigation measure GHG-1, the County
will also implement and/or expand public outreach through an education program to increase the
percentage of paper carryout bags that are diverted from landfills. There is nearly universal access
to curbside recycling throughout the County, where paper bags can be recycled by homeowners
conveniently. Additional public education and outreach would increase the number of bags
recycled and further reduce indirect impacts to GHG emissions. Any remaining cumulative GHG
emission impacts are overridden by the purpose of the recommended ordinances to substantially
reduce the operational costs and environmental impacts associated with the use of plastic carryout
bags in the County.
IX.B OVERRIDING CONSIDERATIONS
The recommended ordinances are consistent with the County’s commitment to environmental
stewardship. The County determined that the economic and environmental benefits of
implementing the recommended ordinances, as discussed below, outweigh and override the one
adverse effect of the recommended ordinances, and any effect remaining after mitigation is
deemed acceptable due to several overriding considerations.
It is a benefit that the recommended ordinances will assist the County in meeting all six of its basic
objectives, which aim to reduce plastic carryout bag use and the associated litter that is found
throughout the County:
• The recommended ordinances include outreach to all 88 incorporated cities of the
County to encourage adoption of comparable ordinances.
• The recommended ordinances will assist in reducing the Countywide consumption
of plastic carryout bags from the current estimate of 1,600 plastic carryout bags per
household in 2007 to fewer than 800 plastic bags per household in 2013.
• The recommended ordinances will assist in reducing by 50 percent by 2013 the
Countywide contribution of plastic carryout bags to litter that blights the County’s
public spaces.
• The recommended ordinances will assist in reducing by $4 million the County’s,
cities’, and Flood Control District’s costs for prevention, cleanup, and enforcement
efforts to reduce litter in the County.
• The recommended ordinances will assist in substantially increasing awareness of
the negative impacts of plastic carryout bags and the benefits of reusable bags, and
reach at least 50,000 residents (5 percent of the population) with an environmental
awareness message.
• The recommended ordinances will assist in reducing Countywide disposal of plastic
carryout bags in landfills by 50 percent from 2007 annual amounts.
The benefit that the recommended ordinances meet the County's basic objectives in conjunction
with additional benefits described below outweigh and override the adverse environmental effect
identified in the EIR.
Economic Considerations
It is a benefit that the recommended ordinances will help to reduce the costs associated with
plastic carryout bag litter, and this consideration alone outweighs and overrides the one adverse
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effect identified in the EIR. The recommended ordinances will help to reduce the amount of litter
in the County attributable to plastic carryout bags and the associated costs to government for litter
prevention, cleanup, and enforcement efforts. Research conducted by the LACDPW found that
approximately 6 billion plastic carryout bags are consumed in the County each year, which is
equivalent to approximately 1,600 bags per household per year.
3,4,5
California public agencies
spend more than $375 million each year for litter prevention, cleanup, and disposal. In the
County, specifically, the County Flood Control District alone exhausted $24 million of these public
funds in 2008–2009 (the most recent data available), while LACDPW expended additional
resources separate from and in addition to state funds to address litter.
6,7
By banning the issuance
of plastic carryout bags at all supermarkets and other grocery stores, convenience stores,
pharmacies, and drug stores in the County, the recommended ordinances will significantly reduce
the number of plastic carryout bags used in the County, along with the associated litter attributable
to plastic carryout bags.
Paper carryout bags are less likely than plastic carryout bags to be littered and to end up in storm
water runoff because they are heavier (anywhere from 6 to 10 times) than plastic bags, and are
therefore less likely to become airborne and scattered as litter.|1010| Survey data received by LACDPW
staff indicate that plastic carryout bag litter is a major operational problem for landfills within the
County’s incorporated and unincorporated areas. Landfill operators noted that plastic bags cause
serious litter issues due to their lightweight nature and propensity to become airborne.|10 10| Each
survey respondent indicated that it was costly and time consuming to provide cleanup crews to
address the plastic bag litter problem in neighborhoods in County’s unincorporated and
incorporated areas that are adjacent to these landfills.
10
Unlike regular plastic, paper is biodegradable and compostable;
the paper used to make standard
paper carryout bags is originally derived from wood pulp, which is a naturally biodegradable
material.
11
Due to the biodegradable properties of paper, paper bags do not persist in the marine
environment for as long as plastic bags.
12
A study performed in Washington, DC, showed that
plastic bag trash accounted for 45 percent of the trash collected in tributary streams, and was the
3
California Integrated Waste Management Board. 12 June 2007. Board Meeting Agenda, Resolution: Agenda Item 14.
Sacramento, CA. |1010| U.S. Census Bureau. 2000. “State & County Quick Facts: Los Angeles County, California.” Web site. Available at:
http://quickfacts.census.gov/qfd/states/06/06037.html |1010| At an average of slightly fewer than three persons per household |1010| California Department of Transportation. Accessed: September 2009. “Facts at a Glance.” Don’t Trash California.
Available at: http://www.donttrashcalifornia.info/pdf/Statistics.pdf |1010| County of Los Angeles. October 2009. Los Angeles County Municipal Storm Water Permit (Order 01-182) Individual
Annual Report Form. Available at: http://dpw.lacounty.gov/wmd/NPDESRSA/AnnualReport/2009/Appendix%20D%20-
%20Principal%20Permittee%20Annual%20Report/Principal%20Permittee%20Annual%20Report.pdf |1010| Cadman, J., S. Evans, M. Holland, and R. Boyd. 2005. Proposed Plastic Bag Levy – Extended Impact Assessment Final
Report. Prepared for: Scottish Executive. |10 10| County of Los Angeles Department of Public Works. 2007. Survey: All Solid Waste Facilities: Plastic Bag Analysis for
the County of Los Angeles. Los Angeles, CA.
10
County of Los Angeles Department of Public Works. 2007. Survey: All Solid Waste Facilities: Plastic Bag Analysis for
the County of Los Angeles. Los Angeles, CA.
11
County of Los Angeles, Department of Public Works. Accessed on: 28 April 2010. Backyard Composting. Web site.
Available at: http://dpw.lacounty.gov/epd/sg/bc.cfm
12
Andrady, Anthony L. and Mike A. Neal. 2009. “Applications and Societal Benefits of Plastics.” In Philosophical
Transactions of the Royal Society B: Biological Sciences, 364: 1977–1984.
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most abundant type of trash in the streams, probably due to the amount of brush and vegetation in
streams that can snag the bags. More than 20 percent of the trash in rivers was also attributed to
plastic bags. Paper products were not found in the streams except in localized areas, and were not
present downstream. The study stated that political action to eliminate the use of free plastic
carryout bags would effectively remove a significant portion of trash from streams and rivers.
13
The
recommended ordinance will remove a significant source of litter from the County, thereby
improving the quality of life for Los Angeles residents by reducing litter that blights public spaces
and reducing the costs of litter cleanup.
Environmental Considerations
It is a benefit that the recommended ordinances will help to reduce the environmental impacts
associated with plastic carryout bag use, and this consideration alone outweighs and overrides the
one adverse environmental effect identified in the EIR. The County has approximately 75 miles of
shoreline along the Pacific Ocean, into which the County’s storm drain and flood control system
empties. The CIWMB estimates that approximately 147,038 tons of plastic grocery and other
merchandise bags were disposed of in California in 2003, about 0.4 percent of the state’s overall
waste stream by weight.
14
CIWMB states, “plastic film, especially grocery bags, constitutes a high
percentage of litter, which is unsightly, costly to clean up, especially when it enters marine
environments, and causes serious negative impacts to shore birds and sea life.”
15
The CIWMB
estimates that approximately 3.9 percent of plastic waste can be attributed to plastic carryout bags
related to grocery and other merchandise. Several organizations have studied the effects of plastic
litter: Caltrans conducted a study on freeway storm water litter;
16
the Friends of Los Angeles River
conducted a waste characterization study on the Los Angeles River;
17
the City of Los Angeles
conducted a waste characterization study on 30 storm drain basins;
18
and LACDPW conducted a
trash reduction and a waste characterization study of street sweeping and trash capture systems
near and within the Hamilton Bowl, located in Long Beach, California.
19
These studies concluded
that plastic film (including plastic bag litter) composed between 7 to 30 percent by mass and
between 12 to 34 percent by volume of the total litter collected.
20
13
Anacostia Watershed Society. December 2008. Anacostia Watershed Trash Reduction Plan. Prepared for: District of
Columbia Department of the Environment.
14
California Integrated Waste Management Board. December 2004. Statewide Waste Characterization Study. Sacramento, CA.
15
California Integrated Waste Management Board. Accessed on: 1 March 2010. Plastic Film Cooperative Recycling
Initiative. Problem Statement. Available at: http://www.calrecycle.ca.gov/Plastics/Film/#Problem
16
Combs, Suzanne, John Johnston, Gary Lippner, David Marx, and Kimberly Walter. 2001. Results of the Caltrans Litter
Management Pilot Study. Sacramento, CA: California Department of Transportation. Available at:
http://www.owp.csus.edu/research/papers/papers/PP020.pdf
17
City of Los Angeles. 18 June 2004. Characterization of Urban Litter, p.1–5. Prepared by: Ad Hoc Committee on Los
Angeles River and Watershed Protection Division. Los Angeles, CA.
18
City of Los Angeles. 18 June 2004. Characterization of Urban Litter, p.1–5. Prepared by: Ad Hoc Committee on Los
Angeles River and Watershed Protection Division. Los Angeles, CA.
19
County of Los Angeles, Department of Public Works, Environmental Programs Division. August 2007. An Overview of
Carryout Bags in Los Angeles County: A Staff Report to the Los Angeles County Board of Supervisors. Alhambra, CA.
Available at: http://dpw.lacounty.gov/epd/PlasticBags/PDF/PlasticBagReport_08-2007.pdf
20
County of Los Angeles, Department of Public Works, Environmental Programs Division. August 2007. An Overview of
Carryout Bags in Los Angeles County: A Staff Report to the Los Angeles County Board of Supervisors. Alhambra, CA.
Available at: http://dpw.lacounty.gov/epd/PlasticBags/PDF/PlasticBagReport_08-2007.pdf
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During the 2008 International Coastal Cleanup led by the Ocean Conservancy, 400,000 volunteers
picked up 6.8 million pounds of trash from lakes, rivers, streams, and ocean beaches around the
world. One in every 10 items collected was a plastic bag. Plastic bags accounted for 12 percent of
the total number of items collected, with a total of 1,377,141, and were the second most prevalent
form of marine debris collected during the cleanup, after cigarettes / cigarette filters.
21
A survey by the National Marine Debris Monitoring Program, funded by the USEPA, used
standardized methodology to monitor marine debris in the United States over a 5-year period. The
most abundant debris items found during the survey were straws, plastic beverage bottles, and
plastic bags. According to survey data, approximately 50 percent of all marine debris in the United
States originates from land-based activities, and approximately 30 percent of all marine debris
originates from general sources, including plastic bottles and plastic bags. Plastic bags with a seam
of less than 1 meter in length made up 9 percent of the total number of items recorded.
22
Furthermore, the survey saw a substantial increase in general-source items over the 5-year
monitoring period, with an average annual increase of 5.4 percent.
Plastics break down into smaller pieces over time, eventually forming tiny particles of plastics
called microplastics.
23
However, plastics are chemically resistant and do not biodegrade, so they
persist in the marine environment.
24
A study of the coastal ocean conducted in 2002 near Long
Beach, California, showed that on average there were eight pieces of plastic per cubic meter of
coast. The average mass of plastic was 2.5 times greater than that of plankton, and was even
greater after a storm.
25
Plastic fragments and plastic resin pellets used in the manufacture of plastic
products can serve as vehicles for persistent organic pollutants such as polychlorinated biphenyls
(PCB) and dichlorodiphenyltrichloroethan (DDT), which can cause adverse impacts to biological
resources if ingested, including internal blockages and toxic poisoning.
26,27,28,29
As discussed in Section 3.2 of the EIR, according to the RWQCB for the Los Angeles Region, trash
can be harmful to wildlife species, and plastic bags are one of the more common items of trash
observed by RWQCB staff.
30
Seabirds, sea turtles, and marine mammals that feed at or near the
ocean surface are especially prone to ingesting plastic debris that floats, and can die as a result of
21
Ocean Conservancy. A Rising Tide of Ocean Debris and What We Can Do About It. International Coastal Cleanup
2009 Report. Available at: http://www.oceanconservancy.org/pdf/A_Rising_Tide_full_lowres.pdf
22
Sheavly, S.B. 2007. National Marine Debris Monitoring Program: Final Program Report, Data Analysis and Summary,
76 pp. Prepared by: Ocean Conservancy, Grant Number X83053401-02. Prepared for: U.S. Environmental Protection
Agency, Washington, District of Columbia.
23
Thompson, R. C. 7 May 2004. "Lost at Sea: Where Is All the Plastic?" In Science, 304 (5672): 843.
24
Andrady, Anthony L. and Mike A. Neal. 2009. “Applications and Societal Benefits of Plastics.” In Philosophical
Transactions of the Royal Society B: Biological Sciences, 364: 1977–1984.
27
Takada, H. et. al. Pellet Watch: Global Monitoring of Persistent Organic Pollutants (POPs) using Beached Plastic Resin
Pellets. Available at: http://www.tuat.ac.jp/~gaia/ipw/documents/takadaproceeding.pdf
28
Teuten, E. L. et. al. 2009. “Transport and release of chemicals from plastic to the environment and to wildlife.” In
Philosophical Transactions of the Royal Society B: Biological Sciences, 364: 2027-2045.
29
Todd, Peter, A. et. al. 2010. “Impacts of Pollution on marine life in Southeast Asia.” In Biodiversity and Conservation
19: 1063–1082.
30
Regional Water Quality Control Board, Los Angeles Region. Revised 27 July 2007. “Trash Total Maximum Daily Loads
for the Los Angeles River Watershed.” Los Angeles, CA.
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ingestion, starvation, suffocation, infection, drowning, and entanglement.
31,32,33,34,35
The recovery
plan drafted by the National Marine Fisheries Service and the U.S. Fish and Wildlife Service for the
endangered leatherback turtle (Dermochelys coriacea) lists ingestion of marine debris, including
plastic bags, as one of the factors threatening this species.
36
The recovery plan states that
leatherback turtles consume floating plastic, including plastic bags, because they mistake the
floating plastic for jellyfish.
37
The recovery plans for the threatened green turtle (Chelonia mydas),
loggerhead turtle (Caretta caretta), and olive ridley turtle (Lepidochelys olivacea) also note that
ingestion of plastic bags is a serious threat to those species.
38,39,40
The recovery plan for the short-
tailed albatross (Phoebastria albatrus) also indicates that ingestion of plastics is a serious threat to
the federally endangered species.
41
Based on this evidence, the prevention of trash, such as plastic
carryout bags, from entering the water bodies like the Los Angeles River can help improve habitats
and benefit aquatic species.
42
Jared Blumenfeld, the USEPA’s regional administrator for the Pacific
Southwest, said recently that the ban on plastic carryout bags in American Samoa “will decrease
the amount of plastic waste in the territory and directly protect marine and bird life in the
Pacific.”
43
Although the recommended ordinance could increase the production, distribution, and disposal of
paper carryout bags, the paper bags have the potential to biodegrade if they are sufficiently
exposed to oxygen, sunlight, moisture, soil, and microorganisms (such as bacteria); they are denser
and less susceptible to becoming airborne than plastic bags; and they generally have a higher
31
California Ocean Protection Council. 20 November 2008. An Implementation Strategy for the California Ocean
Protection Council Resolution to Reduce and Prevent Ocean Litter. Available at:
http://www.opc.ca.gov/webmaster/ftp/pdf/opc_ocean_litter_final_strategy.pdf
32
National Research Council, Committee on the Effectiveness of National and International Measures to Prevent and
Reduce Marine Debris and Its Impacts. 2008. Tackling Marine Debris in the 21st Century.
33
U.S. Environmental Protection Agency. August 2002. Assessing and Monitoring Floatable Debris. Washington, DC.
34
California Ocean Protection Council. 20 November 2008. An Implementation Strategy for the California Ocean
Protection Council Resolution to Reduce and Prevent Ocean Litter. Available at:
http://www.opc.ca.gov/webmaster/ftp/pdf/opc_ocean_litter_final_strategy.pdf
35
Gregory, Murray R. 2009. “Environmental Implications of Plastic debris in Marine Settings --Entanglement, Ingestion,
Smothering, Hangers-on, Hitch-hiking and Alien Invasions.” In Philosophical Transactions of the Royal Society B:
Biological Sciences, 364: 2013–2025.
36
National Marine Fisheries Service and U.S. Fish and Wildlife Service. 1998. Recovery Plan for U.S. Pacific Populations
of the Leatherback Turtle. Available at: http://www.nmfs.noaa.gov/pr/pdfs/recovery/turtle_leatherback_pacific.pdf
37
National Marine Fisheries Service and U.S. Fish and Wildlife Service. 1998. Recovery Plan for U.S. Pacific Populations
of the Leatherback Turtle. Available at: http://www.nmfs.noaa.gov/pr/pdfs/recovery/turtle_leatherback_pacific.pdf
38
National Marine Fisheries Service and U.S. Fish and Wildlife Service. 1998. Recovery Plan for U.S. Pacific Populations
of the East Pacific Green Turtle. Available at: http://www.nmfs.noaa.gov/pr/pdfs/recovery/turtle_green_eastpacific.pdf
39
National Marine Fisheries Service and U.S. Fish and Wildlife Service. 1998. Recovery Plan for U.S. Pacific Populations
of the Loggerhead Turtle. Available at: http://www.nmfs.noaa.gov/pr/pdfs/recovery/turtle_loggerhead_pacific.pdf
40
National Marine Fisheries Service and U.S. Fish and Wildlife Service. 1998. Recovery Plan for U.S. Pacific Populations
of the Olive Ridley Turtle. Available at: http://www.nmfs.noaa.gov/pr/pdfs/recovery/turtle_oliveridley.pdf
41
U.S. Fish and Wildlife Service. September 2008. Short-tailed Albatross Recovery Plan. Available at:
http://alaska.fws.gov/fisheries/endangered/pdf/stal_recovery_plan.pdf
42
Regional Water Quality Control Board, Los Angeles Region. Revised 27 July 2007. “Trash Total Maximum Daily Loads
for the Los Angeles River Watershed.” Los Angeles, CA.
43
U.S. Environmental Protection Agency. 30 September 2010. “U.S. EPA applauds American Samoa’s decision to ban
plastic shopping bags.” Available at:
http://yosemite.epa.gov/opa/admpress.nsf/0/921A87D72D9AAFC1852577AE007394F1
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recycling rate than do plastic bags. The USEPA reported that the recycling rate for high-density
polyethylene plastic bags and sacks was 11.9 percent in 2007, compared to a recycling rate of 36.8
percent of paper bags and sacks.
44
Currently, CIWMB estimates that less than 5 percent of plastic
film in California is recycled.
45
The high recycling rate for paper bags and sacks is due in part to
the availability of curbside recycling programs. The County currently has an education outreach
program for curbside recycling, which includes paper carryout bags.
46
There is nearly universal
access to curbside recycling throughout the County, where homeowners can conveniently recycle
paper bags. The paper used to make standard paper carryout bags is originally derived from wood
pulp, which is a naturally biodegradable and compostable material, and stores in the County are
already using paper carryout bags composed of a minimum of 40 percent post-consumer recycled
content. Therefore, based upon the available evidence, paper carryout bags are less likely to
become litter than are plastic carryout bags.
Public Policy Considerations
The recommended ordinances are consistent with the County’s commitment to environmental
stewardship and its commitment to reduce carryout bag use and litter, while increasing the use of
reusable bags and recycling in the unincorporated areas of the County.
47
This consideration is a
benefit and alone outweighs and overrides the one adverse effect identified in the EIR. The
County’s commitment to this policy is demonstrated by its adoption of the County’s voluntary
Single Use Bag Reduction and Recycling Program in January 2008, which was a comprehensive
strategy to reduce the consumption and disposal of plastic and paper carryout bags that sought to
join the interests of supermarkets and retail stores, environmental groups, the plastic bag industry,
local government, and the public. Further, from November 15 to December 17, 2009, the
LACDPW conducted a Brag About Your Bag campaign to promote reusable bags Countywide,
during which it distributed over 50,000 reusable bags at supermarkets throughout the County.
48
The recommended ordinances are also consistent with the County’s policy and agenda to support
and/or sponsor Statewide legislation regarding carryout bags. The County's current policy is to
“support legislation which reduces the environmental impacts of single-use carryout bags and
decreases the financial burden on local governments to address those impacts, including legislation
44
U.S. Environmental Protection Agency. November 2008. “Table 21: Recovery of Products in Municipal Solid Waste,
1960 to 2007.” Municipal Solid Waste in the United States: 2007 Facts and Figures. Washington, DC. Available at:
http://www.epa.gov/waste/nonhaz/municipal/pubs/msw07-rpt.pdf. The referenced table included the recovery of post-
consumer wastes for the purposes of recycling or composting, it did not include conversion/fabrication scrap. The report
includes the recovery of plastic bags, sacks, and wraps (excluding packaging) for a total of 9.1 percent of plastic
recovered in this category. The County of Los Angeles conservatively estimates that the percentage of plastic bags in this
category for the County of Los Angeles is less than 5 percent.
45
California Integrated Waste Management Board. Accessed on: 1 March 2010. Plastic Film Cooperative Recycling
Initiative. Problem Statement. Available at: http://www.calrecycle.ca.gov/Plastics/Film/#Problem
46
County of Los Angeles, Department of Public Works. Accessed on: 12 October 2010. Outreach Programs. Web sites.
available at: http://dpw.lacounty.gov/epd/recycling/outreach.cfm and http://dpw.lacounty.gov/epd/recycling/crm.cfm
47
County of Los Angeles Board of Supervisors. 19 December 2006. “Policy No. 3.045, Energy and Environmental
Policy.” Board of Supervisors Policy Manual. Available at: http://countypolicy.co.la.ca.us/
48
County of Los Angeles. “Los Angeles County’s Voluntary Single Use Bag Reduction and Recycling Program.” Web site.
Available at: http://www.bragaboutyourbag.org/
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which seeks to promote the use of reusable bags, reduce the use of plastic or paper carryout bags,
and/or increase at-store recycling of carryout bags.”
49
In addition, the recommended ordinances further the goals of the Countywide Strategic Plan,
which directs the provision of operational effectiveness and community and municipal services.
The recommended ordinances will reduce carryout bag use and associated litter, while promoting
the use of reusable bags. The recommended ordinances will also help meet the goals of the
Countywide Strategic Plan by implementing environmentally responsible practices to reduce the
County’s impacts and promote environmental stewardship, and by coordinating departmental
resources effectively to cost effectively implement environmentally beneficial programs. The
recommended ordinances will assist in reducing direct costs related to maintaining the County's
storm water and flood control infrastructure. The recommended ordinances will also help reduce
blight, litter, and other negative environmental impacts associated with carryout bags, while
promoting sustainability, thereby improving the well-being of County residents. The County’s
efforts to reduce carryout bag consumption and litter, while increasing the use of reusable bags and
recycling, are ongoing.
49
County of Los Angeles Chief Executive Office. 1 June 2010. Board Letter: Motion To Support AB 1998 (Brownley)
Related to Single-Use Carryout Bags and Revise The County's State Legislative Agenda to Expand Existing Legislative
Policy on Single-Use Carryout Bags (Item No. 64-C - Agenda of June 1, 2010). Los Angeles, CA.
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SECTION X
FINDINGS
Based on the foregoing findings and the information contained in the record, the Board of
Supervisors of the County of Los Angeles makes the following findings with respect to the
significant environmental impacts resulting from the Ordinances to Ban Plastic Carryout Bags in
Los Angeles County pursuant to Section 15091 of the State CEQA Guidelines:
• Changes or alterations have been required in, or incorporated into, the
recommended ordinance to avoid or substantially lessen the significant
environmental effects as identified in the Final EIR.
• The changes and alterations for the recommended ordinance for the unincorporated
area of the County are within the responsibility and jurisdiction of the County.
• With respect to the impacts that could occur if the County’s 88 incorporated cities
adopted similar ordinances, the Board of Supervisors finds that incorporation of
changes or alterations similar to those set forth in mitigation measure GHG-1 are
within the responsibility and jurisdiction of those agencies and not the County.
Such changes have been adopted by such other agencies or can and should be
adopted by such other agencies. However, the Board of Supervisors acknowledges
that the feasibility of such changes or alterations similar to those set forth in
mitigation measure GHG-1, including the feasibility of each element of such
mitigation measure, is within the sole discretion of such other agencies.
• The mitigation measure identified in the Final EIR is feasible and will be required as
a condition of approval of the recommended ordinance.
Based on the foregoing findings and the information contained in the record, the Board of
Supervisors makes the following additional findings regarding the environmental impacts resulting
from the Ordinances to Ban Plastic Carryout Bags in Los Angeles County:
• Comments, responses to comments, and revisions to the Draft EIR merely clarify
and amplify the analysis presented in the EIR and require recirculation of the EIR
according to the State CEQA Guidelines, Section 15088.5(b). Similarly, revisions to
the definitions contained in the Draft EIR for the proposed ordinances, alternatives,
and mitigation measures since publication of the Draft EIR do not result in any new
significant impacts or any substantial increases in the severity of an environmental
impact that was not described in the Draft EIR, and do not require recirculation
according to the State CEQA Guidelines, Section 15088.5(b).
• After careful consideration of all comments, the Board of Supervisors recognizes
that disagreements among experts still remain regarding the environmental impacts
identified in the EIR. These disagreements are addressed in throughout the EIR,
including in Sections ES.3, 3.0, 4.0, and 13.0, and the Board of Supervisors finds
that substantial evidence supports the conclusions of the EIR.
• The recommended ordinance and the adoption of similar ordinances by each of the
County’s 88 incorporated cities (identified as Alternative 5 in the EIR) is feasible and
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capable of meeting all of the basic objectives of the proposed ordinances. In
Section 4.2.6, the EIR provides a detailed analysis of impacts resulting from
adoption of the recommended ordinance and adoption of similar ordinances by the
County’s 88 incorporated cities.
• In the development of the EIR, the County recognized and acknowledged that each
city has the authority to render an independent decision regarding implementation
of its own comparable ordinance. For the purposes of this EIR, the County has
extended the conservative worst-case scenario for the proposed ordinances and
alternatives to a scenario where all 88 cities adopt comparable ordinances.
However, each city has sole discretion in making an individual determination,
including for cumulative impacts, regarding the exact parameters of the city’s
proposed ordinance, the actual percentage increase in conversion to paper carryout
bags, the number of stores affected, the actual bag usage per day, the size of the fee
or charge, if any, its projected AB 32 GHG emissions target, and any other relevant
factors specific to each incorporated city.
Based on the foregoing findings and the substantial evidence contained in the record, and as
conditioned by the foregoing findings:
• All effects on the environment due to the recommended ordinances have been
eliminated or substantially lessened where feasible.
• Alternative 5 has been deemed feasible and capable of meeting all of the basic
objectives of the proposed ordinances, and has been chosen to be carried forward
for adoption.
• Any remaining significant environmental effects that have been found to be
unavoidable are acceptable due to the overriding concerns set forth in the foregoing
Statement of Overriding Considerations.
77
City of Culver City
Plastic Carryout Bag Ordinance
Addendum to the
Ordinances to Ban
Plastic Carryout
Bags in Los
Angeles County
Final EIR
April 2013
78
Plastic Carryout Bag Ordinance
Addendum to the Ordinances to Ban Plastic
Carryout Bags in Los Angeles County Final EIR
Prepared for:
City of Culver City
Department of Public Works
9770 Culver Boulevard
Culver City, CA 90232
Contact: Helen B. Kerstein, Management Analyst
(310) 253-5618
Prepared by:
Rincon Consultants, Inc.
180 North Ashwood Avenue
Ventura, California 93003
April 2013
79
This report is printed on 30% recycled paper with 30% post-consumer content
and chlorine-free virgin pulp.
80Plastic Carryout Bag Ordinance
Environmental Impact Report Addendum
City of Culver City
Plastic Carryout Bag Ordinance
Addendum to the Ordinances to Ban Plastic Carryout Bags in
Los Angeles County Final EIR
TABLE OF CONTENTS
Page
Introduction .......................................................................................................................1
Project Description ..........................................................................................................1
Environmental Impacts ..................................................................................................5
Air Quality ..............................................................................................................5
Biological Resources ..............................................................................................9
Greenhouse Gas Emissions ..................................................................................9
Hydrology and Water Quality ..........................................................................14
Utilities and Service Systems ..............................................................................16
Conclusion ....................................................................................................................22
List of References ...........................................................................................................23
List of Preparers .............................................................................................................24 22
Appendix
Appendix A: Potential Regulated Retailers in Culver City
Impact Worksheets (Ecobilan and Boustead data)
GHG Calculations for Truck Trips
URBEMIS Results for Truck Trips
Appendix B: Culver City Draft Ordinance
Appendix C: Mitigation Monitoring and Reporting Program (MMRP)
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1
INTRODUCTION
This document is an addendum to the Ordinances to Ban Plastic Carryout Bags in Los Angeles
County Final Environmental Impact Report (EIR) that was adopted by the County of Los
Angeles Board of Supervisors on November 16, 2010 (SCH #2009111104). As one of the 88
incorporated cities within Los Angeles County, Culver City proposes an ordinance to ban
plastic carryout bags consistent with the ordinance analyzed in the County’s Final EIR and
adopted by the Board of Supervisors. The addendum is required to address the possible
environmental effects associated with adoption of such an ordinance within Culver City. Culver
City’s proposed Ordinance would ban the provision of plastic carryout bags and would place a
minimum ten (10) cent charge on the issuance of recyclable paper carryout bags by an affected
store, as defined (please see Project Description below for definition of “store”). The proposed
Ordinance would also require affected stores to provide reusable bags to customers, either for
sale or at no charge.
According to Section 15164 of the California Environmental Quality Act (CEQA) Guidelines, an
addendum to a previously adopted Final EIR is the appropriate environmental document in
instances when “only minor technical changes or additions are necessary” and when the new
information does not involve new significant environmental effects beyond those identified in
an adopted Final EIR. The action being contemplated involves adopting a Plastic Carryout Bag
Ban Ordinance in the City that is similar to the County’s adopted Ordinance. The City is one of
the 88 incorporated cities that were included in the EIR analysis for the County’s Ordinance.
The City would adopt the County’s Plastic Carryout Bag Ordinance with a few minor changes
that are specific to Culver City. These minor revisions are discussed below in the project
description. The City’s proposed Ordinance would have no new significant environmental
effects beyond those identified in the County’s Certified EIR. Since the proposed Ordinance
does not require substantial changes to the County’s Ordinance, major revisions of the EIR
analysis are not warranted. As such, a subsequent EIR pursuant to Section 15162 of the CEQA
Guidelines would not be warranted and an addendum is the appropriate environmental
document under CEQA.
This addendum includes a description of the currently proposed Ordinance in Culver City and
a comparison of the impacts of the proposed Ordinance to those identified for the County’s
approved Ordinance, which was studied in the Final EIR that the County certified on
November 16, 2010.
PROJECT DESCRIPTION
The proposed Plastic Carryout Bag Ordinance (“Ordinance”) would ban the issuance of plastic
carryout bags and impose a minimum ten (10) cent charge on the issuance of recyclable paper
carryout bags at “stores”, as defined by the Ordinance. The Ordinance would also require stores
to provide reusable bags to customers, either for sale or at no charge. Under the Ordinance and
for the purposes of this Addendum, “stores” that would be affected are those located within the
City limits and defined as follows:
83Plastic Carryout Bag Ordinance
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2
1. A full-line, self-service retail store with gross annual sales of two million dollars
($2,000,000), or more, that sells a line of dry grocery, canned goods, or non-food
items and some perishable items; or
2. A store of at least 10,000 square feet of retail space that generates sales or use tax
pursuant to the Bradley-Burns Uniform Local Sales and Use Tax Law (Part 1.5
[commencing with Section 7200] of Division 2 of the Revenue and Taxation Code)
and that has a pharmacy licensed pursuant to Chapter 9 (commencing with Section
4000) of Division 2 of the Business and Professions Code; or
3. A drug store, pharmacy, supermarket, grocery store, convenience store, food mart,
of other entity engaged in the retail sale of a limited line of goods that includes milk,
bread, soda, and snack foods, including those stores with a Type 20 or 21 license
issued by the Department of Alcoholic Beverage Control.
The proposed Ordinance includes compostable and biodegradable plastic carryout bags in the
definition of plastic carryout bags, and, as a result, these types of plastic bags would be banned
as well. The proposed Ordinance would impose a minimum ten (10) cent charge on recyclable
paper carryout bags and requires that the paper bags be one hundred percent (100%) recyclable,
contain a minimum of forty percent (40%) post-consumer recycled material, and be accepted for
recycling in curbside programs in the City, among other criteria. With respect to reusable bags,
the Ordinance would require that the reusable bag be designed for a minimum lifetime of 125
uses, be washable (either by machine or by hand), and not contain lead, cadmium, or any other
heavy metal in toxic amounts, among other criteria. Plastic bags that are a minimum of 2.25 mils
thick and meet the criteria listed above, are considered to be reusable bags, per the definition in
the Ordinance.
The proposed Ordinance would exempt from the minimum ten (10) cent charge those
customers who are participating either in the California Special Supplemental Food Program for
the Women, Infants, and Children or the Supplemental Food Program. Stores must provide at
the point of sale, free of charge, either reusable bags or recyclable paper carryout bags or both,
to these customers, at the store’s option. Customers may also opt to use their own reusable bags
or not use any bag.
Utilizing the bag use estimate assumptions contained in the County’ EIR, as shown in Table 1, it
is anticipated that the proposed Ordinance would reduce 440,000 plastic bags per day that are
currently used in the City, and would replace those bags with approximately 220,000 paper
bags and 1,760 reusable bags per day. This would equate to reducing 160.6 million plastic bags
per year with approximately 80.3 million recyclable paper bags and 642,400 reusable bags.
Further, utilizing the City’s database for business licenses, it is anticipated that approximately
72 retailers in Culver City would be subject to the proposed Ordinance. A list of these potential
retailers is provided in Appendix A.
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Table 1
Plastic Checkout Bag
Replacement Assumptions in Culver City
Type of Bag
Replacement
Assumption
Net Change in
Bags used
Post-Ordinance
(per Day)
Net Change in
Bags used
Post-Ordinance
(per Year)
Explanation
Single-use Plastic
440,000 Plastic
Bags per day
(160,600,000 per
year) currently
used at 72|1010| stores
in Culver City to
be removed
(440,000)|1010| (160,600,000)
Because the proposed Bag
Ordinance would apply to 72
stores included under the
ordinance, no plastic bags
would remain in circulation at
these locations
Recyclable Paper
50%|1010| of current
plastic bags used
220,000 80,300,000
Although the volume of a single-
use paper carryout bag is
generally 150% of the volume of
a single-use plastic bag, such
that fewer paper bags would be
needed to carry the same
number of items, it is
conservatively assumed that
paper would replace plastic at a
1:1 ratio.
Reusable
50%|1010| of current
plastic bags used,
but used
approximately 125
times
1,760 642,400
Because the proposed
Ordinance requires that
reusable bags be designed to
have a minimum lifespan of at
least 125 uses, it is assumed
that each reusable bag would
be used 125 times (thus
220,000 plastic bags per day
are replaced by 1,760 per day
(=220,000 bags / 125 uses).
Total 221,760 80,942,400
¹ This estimate was derived from the City’s database of business licenses. Businesses with relevant business tax code categories
(i.e.: 300 – Liquor Store, 144- Retail Misc, 444-Gasoline Service Stations, etc.) were included, and stores that were clearly not
covered (i.e.: retail but only sold clothing, not food items) were removed. If there was a question about a business, the business was
included so that the estimate is a conservative estimate. Estimated 16 stores >10,000 square feet and 56 stores < 10,000 square
feet in size. |1010| Conversion assumptions based on the Los Angeles County Final EIR ((SCH #2009111104). |1010| Parenthesis ( ) denotes a negative number as the number of single-use plastic bags would be reduced compared to existing
conditions as a result of the proposed Ordinance.
The differences between the City’s proposed Ordinance and the ordinance adopted by the
County include the following:
• Under the City’s Ordinance, any store that provides a recyclable paper carryout bag
to a customer must charge the customer “at least” 10 cents ($0.10) for each bag
provided. The County’s Ordinance required that the fee was 10 cents ($0.10) (not a
minimum fee). Thus under the City’s Ordinance stores can charge fees higher than
$0.10 if they desire.
• The City’s Ordinance allows the City Council to raise the minimum 10 cent charge
for paper carryout bags by resolution.
• The City’s Ordinance requires all stores to post signage clearly indicating the per bag
charge for recyclable paper carryout bags.
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• Under the County’s Ordinance stores affected by the ordinance must provide
quarterly reports to the Director of Public Works that summarize the money
collected for recyclable paper carryout bags and the efforts undertaken to promote
the use of reusable bags. Under the City’s Ordinance, affected stores are required to
keep records of the total number of recyclable paper carryout bags provided, the
total amount of monies collected for providing recyclable paper carryout bags, and a
summary of any efforts a store has undertaken to promote the use of reusable bags
by customers in the prior year. These reports must be made available for the Public
Works Director or his/her designee to review at any time.
• The City’s Ordinance would take effect for stores with gross annual sales of $2
million or more and stores of at least 10,000 square feet six months after its effective
date. For stores of less than 10,000 square feet, the City’s Ordinance would take effect
twelve months after its effective date. The County’s Ordinance operative date was
July 1, 2011 for stores of at least 10,000 square feet and January 1, 2012, for stores of
less than 10,000 square feet.
• The City’s Ordinance does not specify where fines collected shall be deposited,
whereas the County’s Ordinance specifies that fines collected shall be deposited in
the Solid Waste Management Fund.
The differences between the City and County Ordinances as listed above are minor changes that
would not result in any changes to the environmental impacts that were identified in the
County’s Final EIR (adopted November 2010). It should be noted that the “minimum” $0.10 fee
for the City’s proposed Ordinance in comparison to the County’s ordinance which required that
the fee was $0.10 (no minimum fee) would not result in impacts greater than analyzed in the
County’s Final EIR. The bag use assumptions used in the environmental analysis contained in
the County’s Final EIR analyzed a $0.10 fee on recyclable paper bags because under a $0.10 fee,
more customers would likely pay for recyclable paper bags in comparison to a higher fee (say at
$0.15 or $0.25 per paper bag). The bag use assumptions used in the Addendum utilizes this
same approach as a “worst case” scenario. Because more paper bags would be used under a
$0.10 fee rather than with a higher fee, and thus greater environmental impacts associated with
paper bags, this Addendum utilizes the $0.10 fee as a “worst case” scenario in analyzing
environmental impacts. Any fee higher than $0.10 per paper bag would be considered
“environmentally superior” to a $0.10 fee as any fee higher than $0.10 would result in the use of
fewer recyclable paper bags (and more reusable bags). Thus, the City’s proposed Ordinance
which provides a minimum fee of $0.10 would not result in any impacts greater than the
County’s adopted ordinance analyzed in the Final EIR. As such, the City’s proposed Ordinance
is consistent with the County’s Ordinance, but would be specific to Culver City.
The City’s objectives for the proposed Ordinance would be similar to the County’s objectives for
the countywide ordinance. The objectives as described in the County’s Final EIR include:
• Conduct outreach to all 88 incorporated cities of the County to encourage adoption of
comparable ordinances
• Reduce the Countywide consumption of plastic carryout bags from the estimated 1,600
plastic carryout bags per household in 2007, to fewer than 800 plastic bags per household in
2013
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• Reduce the Countywide contribution of plastic carryout bags to litter that blights public
spaces Countywide by 50 percent by 2013
• Reduce the County’s, Cities’, and Flood Control District’s costs for prevention, clean-up, and
enforcement efforts to reduce litter in the County by $4 million
• Substantially increase awareness of the negative impacts of plastic carryout bags and the
benefits of reusable bags, and reach at least 50,000 residents (5 percent of the population)
with an environmental awareness message
• Reduce Countywide disposal of plastic carryout bags in landfills by 50 percent from 2007
annual amounts
Similarly, the City’s proposed Ordinance has five objectives that are consistent with those
outlined in the County’s Final EIR:
• Reduce the Citywide use of plastic carryout bags
• Reduce litter
• Assist the County in reducing costs for prevention, clean-up, and enforcement efforts to
reduce litter
• Substantially increase awareness of the negative impacts of plastic carryout bags and the
benefits of reusable bags
• Reduce Citywide disposal of plastic carryout bags
ENVIRONMENTAL IMPACTS
This section addresses each of the environmental issues studied in the Final EIR, comparing the
effects of the proposed Culver City Plastic Carryout Bag Ordinance (“proposed Ordinance”)
with the effects of the County of Los Angeles Plastic Carryout Bag Ordinance that was the
subject of the adopted Final EIR. In addition to stating the County’s finding for each impact
statement, the analysis includes a discussion of the City’s impact related to adopting its own
plastic carryout bag ban ordinance and the impacts associated with implementation of such an
ordinance citywide.
The City’s proposed Ordinance would not change any of the impacts identified as less than
significant in the County’s Final EIR Initial Study (Volume II: Section D of the Final EIR). Each
of those impacts would remain less than significant for the City’s proposed Ordinance. As such,
further discussion of these issues in this addendum is not warranted.
Air Quality
The City’s proposed Ordinance would have impacts related to Air Quality similar to those of
the previously studied County Ordinance (identified as Alternative 5 in the County’s Final EIR)
since the City’s proposed Ordinance is consistent with the County’s adopted Ordinance and
would apply to an estimated 72 stores within the City.|1010| |1010| This estimate was derived from the City’s database of business licenses. Businesses with relevant business tax
code categories (i.e.: 300 – Liquor Store, 144- Retail Misc, 444-Gasoline Service Stations, etc.) were included, and
stores that were clearly not covered (i.e.: retail but only sold clothing, not food items) were removed. If there was a
question about a business, the business was included so that the estimate is a conservative estimate.
These stores were considered in the
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County’s Final EIR analysis, which considered approximately 5,084 stores in the incorporated
cities (which included Culver City). Therefore, all of the stores that would be subject to the
City’s proposed Ordinance have already been analyzed for air quality impacts as part of the
County’s Final EIR and, as shown below, impacts would be no greater than what was already
determined in the County’s Final EIR. Like the County’s Ordinance, the City’s proposed
Ordinance does not involve any construction activities; therefore, there would be no regional or
localized construction impacts and consideration of construction impacts is not relevant. Thus,
this analysis focuses on operational impacts. As studied in the County’s Final EIR, operational
impacts include indirect emissions based on life cycle assessments, criteria pollutant emissions
resulting from disposal of paper carryout bags in landfills, and emissions resulting from
increased delivery trips.
Indirect Emissions Based on Life Cycle Assessments. As described on pages 12-41 of the
County’s Final EIR, based on a conservative scenario of 50 percent conversion from the use of
plastic carryout bags to the use of paper carryout bags, and using life cycle data from the
Ecobilan study (2004), the County’s ordinance would be expected to result in an overall
decrease in emissions of carbon monoxide (CO), particulate matter (PM), sulphur oxide (SOx)
and volatile organic compounds (VOCs), but would result in an increase in nitrogen oxide
(NO x). Table 2 shows the estimated daily emission changes that would result if each of the
incorporated cities in the County (including Culver City) were to implement a plastic bag ban
ordinance similar to the County’s Ordinance. As stated in the County’s Final EIR, these results
cannot reasonably be evaluated in relation to the operational thresholds of significance set by
SCAQMD because the operational thresholds are intended for specific projects located in the
South Coast Air Basin (Basin), whereas LCA data cover all stages of production, distribution,
and end-of-life procedures related to a particular product which is not limited to the Basin. As
noted above, the City’s approximately 72 stores that would be required to adhere to the City’s
proposed Ordinance are included within the approximately 5,084 stores considered in Table 2.
The emissions related to converting from plastic to paper bags as a result of the City’s proposed
Ordinance are also shown in Table 2. As shown, emissions related to CO, PM, SO x and VOCs
would decrease in Culver City and NO x emissions would increase. Therefore, similar to the
County’s determination in the Final EIR, impacts as a result of criteria pollutants from the
conversion of plastic bags to paper bags would be expected to result in both beneficial impacts
(CO, PM, SO x and VOCs) and adverse impacts (NO x) to air quality.
In addition to increasing the use of paper bags, by banning the use of plastic carryout bags the
proposed Ordinance would be expected to result in increased use of reusable bags which may
also increase emissions. However, as described in the County’s Final EIR, because reusable bags
must be designed to have a minimum lifespan of at least 125 uses, air quality impacts due to the
life cycle of a reusable bag would be expected to be lower than those of a plastic or paper
carryout bag when considered on a per-bag basis. Thus, consistent with the findings of the
County’s Final EIR, any conversion from the use of plastic carryout bags to reusable bags would
reasonably be expected to result in an environmental benefit.
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Table 2
Estimated Daily Emission Changes Due to the
County’s Ordinance and the City’s Ordinance Based on the Ecobilan Data (lbs/day)
Emission Source VOCs¹ NO x CO Sox PM
County Ordinance – 5,084 stores in incorporated
areas plus 1,091 stores in unincorporated areas
-2,729² 1,058 -5,004 -1,190 -1,936
City Ordinance – 72 stores within Culver City³ -25.9 39.2 -62.4 -6.5 -23.8
Source: Ecobilan. February 2004. Environmental Impact Assessment of Carrefour Bags: An Analysis of the Life Cycle of
Shopping Bags of Plastic, Paper, and Biodegradable Material. Prepared for: Carrefour Group. Neuilly-sur-Seine, France.
NOTES:
1. Total VOCs include all compounds defined as contributors to the formation of photochemical oxidants in the Ecobilan
Study, apart from methane, ethane, and acetone, which are not included in the SCAQMD definition of VOCs under Rule 102.
2. A negative number for emissions indicates the extent of the reduction in air pollutants generated by paper carryout bags in
comparison to the air pollutants generated by plastic carryout bags by subtracting the data for plastic carryout bags from the data
for paper carryout bags.
3. Emissions related to the 72 stores in Culver City are also included as part of the 5,084 stores in the incorporated areas in the
County’s Ordinance emissions.
Criteria Pollutant Emissions Resulting from Disposal of Paper Carryout Bags in Landfills. As
shown in Table 3, the County’s Final EIR determined that if the County’s Ordinance was
implemented in all 88 incorporated cities, including Culver City, NOx emissions resulting from
decomposition of carryout bags at a landfill (known as end of life data) would increase by
approximately 110 pounds per day. NOx emissions resulting from implementation of the City’s
proposed Ordinance would be approximately 2.7 pounds per day as shown in Table 3.
Nevertheless, any emissions resulting from the end of life of paper carryout bags, including
from truck trips transporting paper carryout bag waste to landfills in the County, are currently
controlled by regional and state regulations such as CARB’s Solid Waste Collection Vehicle Rule
and SCAQMD Rule 1193, Clean On-road Residential and Commercial Refuse Collection.
Therefore, similar to the County’s significance finding, the impacts from the City’s proposed
Ordinance to air quality due to end of life (disposal to/in landfills) would be less than
significant.
Table 3
Estimated Daily NO
x
Emission Increases Due to End of Life (Disposal)
Based on the Ecobilan Data
Emission Source NO
x
(lbs/day)¹
County Ordinance – 5,084 stores in incorporated areas plus
1,091 stores in unincorporated areas
110
City Ordinance – 72 stores within Culver City 2.7
Sources:
1. Ecobilan. February 2004. Environmental Impact Assessment of Carrefour Bags: An Analysis of the Life
Cycle of Shopping Bags of Plastic, Paper, and Biodegradable Material. Prepared for: Carrefour Group. Neuilly-
sur-Seine, France.
2. U.S. Environmental Protection Agency. November 2008. Municipal Solid Waste in the United States: 2007
Facts and Figures. Washington, DC. Available at: http://www.epa.gov/waste/nonhaz/municipal/pubs/msw07-
rpt.pdf
NOTES: Assuming 36.8 percent of paper carryout bags are diverted from landfills and 11.9 percent of plastic
carryout bags are diverted from landfills, based on the 2007 USEPA recycling rates for bags and sacks.
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Emissions Resulting From Increased Delivery Trips. Similar to the County’s Ordinance, the
City’s proposed Ordinance would be expected to cause a potential increase in delivery truck
trips required to transport paper and reusable carryout bags to affected stores. As stated in the
County’s Final EIR, the County’s Ordinance would result in an overall increase of
approximately 96 truck trips per day to deliver paper carryout bags. Because reusable bags are
expected to be used 125 times, fewer truck trips would be required to deliver reusable bags.
Using the County’s method to determine truck trips, with implementation of the City’s
proposed Ordinance, the overall increase in truck trips to City stores would be approximately 3
truck trips per day.|1010|
As shown in Table 4, similar to the County’s Ordinance, the increase in
truck trips in the City would not result in an exceedance of any thresholds of significance set by
the South Coast Air Quality Management District (SCAQMD). As with the County’s Ordinance,
impacts related to mobile emissions from the City’s proposed Ordinance would be less than
significant.
Table 4
Estimated Daily Operational Emissions From Increased Truck Trips
Emission Source VOCs NO x CO SOx PM 2.5 PM 10
County Ordinance – 96 delivery trucks
trips in the incorporated cities of the
County and unincorporated areas
(paper only)
0.80 1.90 12.02 0.01 0.46 0.40
City Ordinance – 3 delivery truck trips
per day in the City (paper and
reusable bags)
0.04 0.52 0.20 <0.01 0.07 0.03
SCAQMD Threshold 55 55 550 150 55 150
Significant Impact? No No No No No No
County Ordinance Significant
Impact?
No No No No No No
Source: Los Angeles County Final EIR, November 2010; and, URBEMIS output (see Appendix A).
As with the County’s Ordinance, the City’s Ordinance would not conflict with or obstruct the
implementation of any applicable air quality plan; would not violate any air quality standard or
contribute substantially to an existing or projected air quality violation; would not result in a
cumulatively considerable net increase of any criteria pollutant for which the region is in non-
attainment under an applicable federal or state ambient air quality standard; would not expose
sensitive receptors to substantial pollutant concentrations; and would not create objectionable
odors affecting a substantial number of people. Consistent with the findings in the County’s
Final EIR, impacts to air quality would be below levels of significance and would not result in a
cumulatively considerable contribution to a significant cumulative impact.
|1010| (16 stores x 10,000 plastic carryout bags per day/2,304,000 plastic carryout bags per truck) + (56 stores x 5,000
plastic bags per day/2,304,000 plastic bags per truck) x 6.5 the number of truck trips for paper rather than plastic x 2
(paper and reusable bags)= 2.5 daily truck trips, rounded up to 3 daily truck trips
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Biological Resources
As with the County’s Ordinance, the City’s proposed Ordinance would result in a reduction in
the use and disposal of plastic carryout bags (reduction of approximately 440,000 plastic bags
per day or approximately 160.6 million per year). As such, the City’s Ordinance would achieve
reductions in litter composed of plastic carryout bag waste found in freshwater and coastal
environments, which has been shown to have significant adverse impacts upon biological
resources. The City’s Ordinance would also be anticipated to increase consumer use of reusable
carryout bags, which, as discussed in the County’s Final EIR, have not been widely noted to
have adverse impacts upon biological resources. Although reusable bags may become a part of
the waste stream, they can be reused multiple times (at least 125 times under the proposed
Ordinance) and are heavier than plastic carryout bags; therefore, the number of reusable bags
that would likely end up as litter that could impact biological resources would be lower than
the number of plastic or paper carryout bags. The City’s Ordinance may indirectly increase the
number of paper carryout bags used in the City. However, due to their weight, paper bags are
less likely to become litter. In addition, because paper is compostable (unlike plastic), paper
bags do not persist in the marine environment for as long as plastic bags.
For the reasons stated above, consistent with the findings of the County’s Final EIR, the City’s
proposed Ordinance would have the potential to reduce impacts to wildlife habitats and aquatic
life, and would result in potentially beneficial impacts to sensitive habitats; federally protected
wetlands; rare, threatened, and endangered species; and species of special concern. The City’s
proposed Ordinance would not have a substantial adverse effect on any species identified as
candidate, sensitive, or special status; would not have a substantial adverse effect on riparian
habitats or other sensitive natural communities, including federally protected wetlands as
defined by Section 404 of the CWA; would not interfere substantially with the movement of any
native resident or migratory fish or wildlife species or with established native resident or
migratory wildlife corridors, or impede the use of native wildlife nursery sites; and would not
conflict with any City or County General Plan policies requiring the protection of biological
resources. As with the County’s Ordinance, the City’s proposed Ordinance would not result in
any significant adverse impacts to biological resources and would achieve additional benefits
due to a reduction in the use of plastic carryout bags. Similarly, like the County’s Ordinance, the
City’s proposed Ordinance would not result in a cumulatively considerable contribution to a
significant cumulative impact to biological resources.
Greenhouse Gas Emissions
Carryout bags have the potential to contribute to the generation of greenhouse gas emissions
(GHGs) either through emissions associated with manufacturing process of carryout bags, truck
trips delivering carryout bags to retailers or through disposal during landfill degradation. For
the County’s Final EIR (County’s Final EIR, page 12-47, November 16, 2010), it was determined
that the County’s proposed ordinance would have a significant impact to greenhouse gas
emissions when the potential for any one of the following two thresholds was reached:
• Generate greenhouse gas emissions, either directly or indirectly that may have a significant
effect on the environment
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• Conflict with any applicable plan, policy or regulation adopted for the purpose of reducing the
emissions of greenhouse gases
The second threshold was further explained by two additional significance criteria in the
County’s Final EIR:
• Inconsistency with laws and regulations in managing GHG emissions
• Inconsistency with the goal to reduce GHG emissions to 1990 levels (approximately 427
metric tons or 9.6 metric tons of carbon dioxide equivalents (CO 2e) per capita) as required by
AB 32
Based on data provided by the California Department of Finance (2012), the existing population
in Culver City is approximately 39,004.
Manufacturing Process. As discussed in the County’s Final EIR, based on a conservative
scenario of a 50 percent conversion from the use of plastic carryout bags to the use of paper
carryout bags, and using life cycle data from Ecobilan, the County’s Ordinance would be
expected to contribute indirectly to an overall decrease of approximately 12,015 metric tons of
GHG emissions per year, as shown in Table 5. Thus, the County’s Final EIR determined that the
County’s Ordinance would not be expected to conflict with the County’s 2020 target GHG
emissions (108 million metric tons per year) and, therefore, impacts related to the manufacture
of paper bags would be less than significant. Similarly, for the City’s proposed Ordinance, the
conversion of plastic to paper bags would reduce GHG emissions in the City by approximately
32 metric tons per year, as shown in Table 5. As such, consistent with the findings of the
County’s Final EIR, the City’s proposed Ordinance would have a beneficial effect related to
GHG emissions from the manufacturing process.
Table 5
Estimated GHG Emissions From Manufacturing Process based on Ecobilan Data
Emission Areas
CO 2e Emission Sources
Plastic Carryout
Bags
Increase from 50% Conversion from
Plastic to Paper Carryout Bags
Metric Tons
per Day
Metric Tons
per Day
Metric Tons
per Year²
Metric Tons per
Year per Capita¹
County Ordinance
– 5,084 stores in
incorporated areas
plus 1,091 stores in
unincorporated
areas
568 -32.92 -12,015 -0.001
City Ordinance – 72
stores within Culver
City³
6.6 -0.09 -31.6 -0.0008
Source: Ecobilan. February 2004. Environmental Impact Assessment of Carrefour Bags: An Analysis of the Life Cycle of
Shopping Bags of Plastic, Paper, and Biodegradable Material. Prepared for: Carrefour Group. Neuilly-sur-Seine, France.
Notes:
1. Per capita emissions are calculated using the estimated 2010 population in the County (10,615,700).
2. A negative number for emissions indicates the extent of the reduction in air pollutants generated by paper carryout bags
in comparison to the air pollutants generated by plastic carryout bags by subtracting the data for plastic carryout bags from
the data for paper carryout bags.
3. Emissions related to the 72 stores in Culver City are also included as part of the 5,084 stores in the incorporated areas in
the County’s Ordinance emissions.
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The City’s proposed Ordinance would promote an increase in the use of reusable bags, which
also emit GHG emissions during the manufacturing process. However, because reusable bags
would have a minimum lifetime use of 125 times under the proposed Ordinance, the number of
reusable bags required (approximately 1,760 reusable bags per day or approximately 642,400
per year) would be expected to be less than the number of plastic carryout bags (approximately
440,000 plastic bags per day or approximately 160.6 million per year) currently used in the City.
Therefore, the conversion of plastic to reusable bags would not result in an increase in GHG
emissions from the manufacturing process.
Truck Trips. Delivery trucks that transport carryout bags from manufacturers or
distributors to the local retailers in Culver City would also contribute GHG emissions. GHG
emissions from truck trips result primarily from the combustion of fossil fuels and include CO 2,
CH 4, and N 2O. As discussed in the County’s Final EIR, it is anticipated that implementation of
the County’s Ordinance in all 88 incorporated cities and in the unincorporated areas would
require approximately 96 additional truck trips per year to deliver paper bags. For the City’s
proposed Ordinance, as discussed above in Air Quality, approximately 3 truck trips per day
would be required to deliver paper and plastic bags to the estimated 72 stores located within
Culver City. The estimated increase in GHG emissions associated with truck trips (both
countywide and just within the City are shown in Table 6). As shown, the additional truck trips
countywide would generate approximately 260 metric tons of GHG emissions per year while in
Culver City the 3 additional truck trips would generate 19 metric tons of GHG emissions per
year. The total indirect GHG emissions due to mobile sources as a result of a 50-percent
conversion of plastic to paper bags within Culver City would represent an increase of
approximately 0.000004 percent of California's GHG emissions target for 2020 of 427 million
metric tons per year, and approximately 0.000018 percent of the County’s target emissions for
2020 (108 million metric tons), or 0.0005 metric ton per capita per year, which would not conflict
with the emission reduction goals established to reduce emissions of GHGs in California down
to 1990 levels by 2020 as required by AB 32 (approximately 427 million metric tons in total or 9.6
metric tons per capita by 2020). Therefore, the indirect GHG emissions due to mobile sources for
the City’s proposed Ordinance would be less than significant, similar to the determination
related to mobile GHG emissions in the County’s Final EIR.
Table 6
Estimated GHG Emissions From Daily Mobile Emissions
Due to Increased Vehicle Trips
Emission Sources
CO 2 Emissions
(lbs/day)
CO 2 Emissions
(metric tons/year)
Metric Tons per Year
per Capita¹
County Ordinance – 96 delivery trucks trips
in the incorporated cities of the County and
unincorporated areas (paper only)
1,572.35 260.32 0.000025
City Ordinance – 3 delivery truck trips per
day in the City|1010| (paper and reusable bags)
114 19 0.0005
Source: Ecobilan. February 2004. Environmental Impact Assessment of Carrefour Bags: An Analysis of the Life Cycle of
Shopping Bags of Plastic, Paper, and Biodegradable Material. Prepared for: Carrefour Group. Neuilly-sur-Seine, France.
Notes:
1. Per capita emissions are calculated using the estimated 2010 population in the County (10,615,700).
2. A negative number for emissions indicates the extent of the reduction in air pollutants generated by paper carryout bags
in comparison to the air pollutants generated by plastic carryout bags by subtracting the data for plastic carryout bags from
the data for paper carryout bags.
3. Emissions related to the trips in Culver City for bag delivery are also included in the 96 trips in the incorporated areas in the
County’s Ordinance emissions.
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Landfill Degradation/End of Life Emissions. Once disposed of by customers, carryout bags
that are not recycled are deposited to a landfill where they are left to decompose and degrade.
Depending on the type and materials used, a carryout bag will degrade at various rates. When
carryout bag materials degrade in aerobic conditions at a landfill, methane (CH 4) is emitted.
This contributes to global climate change.
As shown in Table 7, using the Ecobilan data for the end of life of plastic and paper carryout
bags, disposal of paper carryout bags at landfills would yield approximately 70,250 metric tons
of GHG emissions per year, which is equivalent to approximately 0.007 metric tons per capita,
based on the County’s Ordinance if applied countywide (incorporated cities and
unincorporated areas). For the City’s proposed Ordinance, emissions related to the disposal of
paper bags at landfills would generate approximately 1,353 metric tons of GHG emissions per
year, which is equivalent to approximately 0.03 metric tons per capita per year in Culver City.
This increase would not exceed the 9.6 metric tons CO 2e per capita per year threshold. Impacts
would be less than significant.
Table 7
Estimated GHG Emissions Increases Due to End of Life Based on Ecobilan Data
Emission Sources
Increase of CO 2e Emissions
(metric tons/year)¹
Metric Tons per Year per
Capita
County Ordinance – 5,084 stores in
incorporated areas plus 1,091 stores in
unincorporated areas
70,250 0.0066
City Ordinance – 72 stores within
Culver City
1,353 0.03
Source: Ecobilan. February 2004. Environmental Impact Assessment of Carrefour Bags: An Analysis of the Life Cycle of
Shopping
Bags of Plastic, Paper, and Biodegradable Material. Prepared for: Carrefour Group. Neuilly-sur-Seine, France.
U.S. Environmental Protection Agency. November 2008. Municipal Solid Waste in the United States: 2007 Facts and
Figures. Washington, DC. Available at: http://www.epa.gov/waste/nonhaz/municipal/pubs/msw07-rpt.pdf
Notes:
1. Assuming 36.8 percent of paper carryout bags are diverted from landfills and 11.9 percent of plastic carryout bags are
diverted from landfills, based on the 2007 USEPA recycling rates.
The Boustead data uses slightly higher emission rates per bag than the Ecobilan data for end of
life emissions. As such, based on the Boustead data as shown in Table 8, the County’s Final EIR
determined that countywide emissions from disposal of paper carryout bags at landfills would
generate approximately 184,621 metric tons of GHG emissions per year. For the City’s proposed
Ordinance, emissions related to disposal of paper bags according to the Boustead data would
yield approximately 2,255 metric tons of GHG emissions per year, which is equivalent to
approximately 0.058 metric tons per capita per year in Culver City.
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Table 8
Estimated GHG Emissions Increases Due to End of Life Based on Boustead Data
Emission Sources
Increase of CO 2 Emissions
(metric tons/year)¹
Metric Tons per Year per
Capita
County Ordinance – 5,084 stores in
incorporated areas plus 1,091 stores in
unincorporated areas
184,621 0.01739
City Ordinance – 72 stores within Culver
City
2,255 0.058
Source: Boustead Consulting and Associates Ltd. 2007. Life Cycle Assessment for Three Types of Grocery Bags –
Recyclable
Plastic; Compostable, Biodegradable Plastic; and Recycled, Recyclable Paper. Prepared for: Progressive Bag Affiliates.
U.S. Environmental Protection Agency. November 2008. Municipal Solid Waste in the United States: 2007 Facts and
Figures. Washington, DC. Available at: http://www.epa.gov/waste/nonhaz/municipal/pubs/msw07-rpt.pdf
Notes:
1. Assuming 36.8 percent of paper carryout bags are diverted from landfills and 11.9 percent of plastic carryout bags are
diverted from landfills, based on the 2007 USEPA recycling rates.
The Boustead results are likely to be overestimates as emissions from active landfills in the
County are strictly controlled by SCAQMD Rule 1150.1 and AVAQMD Rule 1150.1, Control of
Gaseous Emissions from Active Landfills, as well as the new state requirements that regulate
methane emissions from landfills in accordance with the goals of Assembly Bill 32 as
implemented in the California Air Resources Board Climate Change Scoping Plan (County’s
Final EIR, page 12-49, November 2010). Nevertheless, at the time the County’s EIR was adopted,
there were no local, regional, State, or federal regulations establishing significance on a
cumulative level. According to the EIR, because of this, and “because certain representatives of the
plastic bag industry have claimed that paper bags are significantly worse for the environment from a
greenhouse gas (GHG) emissions perspective, on this basis, and specific to this project only, and because
the County is attempting to evaluate the impacts of the project from a very conservative worst-case
scenario, it can be determined that the impacts may have the potential to be cumulatively significant.”
Subsequently, the SCAQMD has recommended a project-level threshold of 4.8 metric tons CO 2e
per service population (population plus employees). Though end of life emissions based on the
conservative estimate of 0.058 metric tons of CO 2e using Boustead data is below the
recommended threshold, the City is following the findings of the County’s EIR, which identifies
a potentially significant impact from “end of life” GHG emissions and recommends adoption of
the Mitigation Measure MM-GHG-1. This mitigation measure would be required for the City’s
proposed Ordinance to reduce impacts related to GHG emissions. This mitigation measure and
the impact related to GHG emissions for the City’s proposed Ordinance is similar to the impact
determination in the County’s EIR as the GHG emissions from the City (as one of the 88
incorporated cities evaluated in the EIR) were considered within the impact analysis of the
County’s EIR. Therefore, the City’s proposed Ordinance would not result in any greater
impacts related to GHG emissions than the analysis contained in the County’s EIR.
Mitigation Measure MM-GHG-1 Implement and/or expand public outreach and
educational programs to increase the percentage of
paper carryout bags that are recycled curbside.
Distribute reusable grocery bags free of charge to
encourage further transitions to reusable bags; consider
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public/private partnerships to offset costs of
distribution.
Implement an outreach program for affected stores to
encourage consumer transition to reusable bags, to
reduce double bagging, and to encourage reuse and in-
store recycling of paper carryout bags.
Hydrology and Water Quality
Hydrology and water quality impacts would be similar to those identified in the County’s Final
EIR. The following discusses the impacts related to drainage, surface water quality,
groundwater, flooding, and seiche, tsunami and mudflows that would result from
implementation of the City’s proposed Ordinance.
Drainage. Consistent with the findings of the County’s Final EIR, the City’s proposed
Ordinance would not require construction of new structures or additional storm water
infrastructure. Consequently, the capacity of existing storm water drainage would remain
unchanged and redirecting storm water flows would be unnecessary. By banning plastic
carryout bags within the City, the Ordinance would improve the existing drainage capacity by
removing a substantial source of trash that can clog features of the system and reduce its
capacity (County’s Final EIR, 2010). Therefore, consistent with the findings of the County’s Final
EIR, the proposed Ordinance would not result in significant adverse impacts to hydrology and
water quality related to drainage.
Surface Water Quality. As noted in the County’s Final EIR, certain representatives of the
plastic bag industry have argued that similar proposed ordinances have the potential to result
in environmental impacts that could result in violations of water quality standards due to the
increased reliance on paper carryout bags, which can potentially cause increased water
eutrophication during the manufacturing process. Eutrophication occurs when high levels of
nutrients, such as fertilizers, enter a water body and cause excessive growth of plants, such as
algae, resulting in a reduction in water quality.
Several life-cycle-assessments (LCAs) have analyzed the impacts of bag manufacturing upon
eutrophication and concluded that paper carryout bag manufacturing releases more pollutants,
such as nitrates and phosphates, into water than does plastic carryout bag manufacturing
(County’s Final EIR, 2010). However, as shown in Table 9 below, using the Ecobilan LCA, the
County’s EIR determined that a 50 percent conversion from the use of plastic carryout bags to
the use of paper carryout bags would be expected to increase eutrophication by approximately
51 additional kilograms of phosphate per day if all 88 incorporated cities of the County adopted
plastic bag ordinances. Since Culver City is one of the 88 incorporated cities in the County, the
County’s Final EIR accounts for impacts from eutrophication associated with the City’s
proposed Ordinance. As shown in Table 9, the increase in eutrophication just from the City’s
proposed Ordinance would be approximately 0.77 kilograms of phosphate, or about 1.5% of the
50.87 kilograms of phosphate for the entire County.
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As further stated in the County’s Final EIR, since there are no significance thresholds related to
eutrophication and since there are no known paper bag manufacturing facilities within the
County, determining the level of significance of eutrophication impacts from bag
manufacturing would be inapplicable and speculative. As such, since there appears to be no
manufacturing and production of paper carryout bags in the County (or in Culver City) there
would be no expected impacts to water quality resulting from eutrophication during the
manufacturing process. Further, any indirect increase in pollutant discharge from
manufacturing plants due to increased demand for paper carryout bags would be regulated and
controlled by local, regional, and federal laws applicable to each manufacturing plant. Within
the United States, pollutant discharges from bag manufacturing facilities would be required to
comply with National Pollutant Discharge Elimination System (NPDES) requirements and
permits. Thus, similar to the findings of the County’s Final EIR, impacts of the City’s proposed
Ordinance upon surface water quality outside of the Southern California region due to
eutrophication would be less than significant. Therefore, similar to the County’s findings,
indirect impacts to water quality from eutrophication due to a potential increase in the demand
for paper carryout bag manufacturing as a result of the City’s proposed Ordinance would be
less than significant.
Table 9
Eutrophication Due to Plastic and Paper Carryout Bags Based on Ecobilan Data
Eutrophication Sources
Eutrophication (kilograms phosphate equivalent)
Eutrophication from Plastic
Carryout Bags
(existing conditions)
Increase Due to Conversion
from Plastic to Paper Carryout
Bags
(with implementation of
Ordinance)
County Ordinance – 5,084 stores in
incorporated areas plus 1,091 stores in
unincorporated areas
10.39 50.87
City Ordinance – 72 stores within Culver
City
0.14 0.77
Source: Ecobilan. February 2004. Environmental Impact Assessment of Carrefour Bags: An Analysis of the Life Cycle of
Shopping Bags of Plastic, Paper, and Biodegradable Material. Prepared for: Carrefour Group. Neuilly-sur-Seine, France
Reusable bags could also indirectly increase eutrophication impacts related to facilities that
manufacture reusable bags. However, as stated in the County’s Final EIR, studies have shown
that when used at least 104 times, the environmental impacts associated with a reusable bag are
substantially less than impacts resulting from paper and plastic carryout bags (County’s Final
EIR, page 12-58, 2010). Like the County’s Ordinance, the City’s proposed Ordinance would
require reusable bags to have a minimum lifespan of 125 uses; therefore, any conversion from
the use of plastic carryout bags to reusable bags would be environmentally beneficial.
Any adverse indirect impact upon water quality due to eutrophication would likely be offset by
positive impacts associated with the proposed Ordinance. The City’s proposed Ordinance,
similar to the County’s Ordinance, would reduce the amount of litter associated with plastic
carryout bags and, therefore, would decrease the amount of litter in water bodies within and in
the vicinity of Culver City. As such, the proposed Ordinance would generally improve water
quality. This is a beneficial effect.
97Plastic Carryout Bag Ordinance
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Groundwater. Similar to the findings of the County’s Final EIR, the City’s proposed
Ordinance would not result in significant adverse impacts to hydrology or water quality in
relation to groundwater. Because the proposed Ordinance does not require the construction of
new structures, it would not result in the creation of impervious surfaces that would potentially
reduce ground water levels. Further, although manufacturing facilities for paper and plastic
carryout bags could potentially release pollutants that may affect groundwater, the discharge of
pollutants locally and nationally is regulated by the USEPA and the Regional Water Quality
Control Boards (RWQCBs) under the federal Clean Water Act (CWA). Pollutant discharges
from manufacturing facilities would be required to comply with the CWA. Further, as noted
above, since there is no known manufacturing or production of paper carryout bags in the
County (or in Culver City), there would be no expected impacts to ground water quality due to
a potential increase in demand associated with conversion from plastic carryout bags to paper
carryout bags. Therefore, impacts to groundwater quality related to the City’s proposed
Ordinance would be less than significant.
Flooding. Although some areas in Culver City that would be affected by the City’s
proposed Ordinance are located within a 100-year Flood Zone area, the proposed Ordinance
does not involve the construction of new development and drainage patterns would not be
affected upon implementation of the proposed ordinances. Therefore, similar to the finding of
the County’s Final EIR, the City’s proposed Ordinance would not result in significant impacts
related to the 100-year Flood Zone.
Seiche, Tsunami and Mudflows. The City’s proposed Ordinance would affect areas in
Culver City that are located near the Pacific Ocean and, thus, may be subject to a seiche or
tsunami. However, implementation of the Ordinance would not involve the construction of
new development and would not result in an increase in population. As such, the proposed
Ordinance would not increase the risk and hazard to individuals residing within areas that lie
in the vicinity of coastal waters of being subject to a seiche or tsunami. Therefore, similar to the
finding of the County’s Final EIR, implementation of the City’s proposed Ordinance would
have a less than significant impact in relation to seiche, tsunamis, and mudflows.
Utilities and Service Systems
Impacts to utilities and service systems as a result of the City’s proposed Ordinance would be
similar to impacts discussed in the County’s Final EIR. The following summarizes the impacts
related to wastewater generation, water supply, solid waste, and energy consumption for the
City’s proposed Ordinance compared to the findings contained in the County’s Final EIR.
Wastewater Generation. As noted in the County’s Final EIR, no known manufacturing
facilities for paper carryout bags are located within the County or Culver City. Therefore, any
increase in wastewater generation due to paper carryout bag manufacturing would not affect
wastewater treatment providers in the County. Nevertheless, in the County’s Final EIR, using
the Ecobilan LCA data and assuming that 50 percent of consumers switch from plastic carryout
bags to paper carryout bags, there was an expected increase in wastewater of approximately
0.04 million gallons per day (MGD) for the 1,091 affected stores in the unincorporated territory
of the County, and up to an additional 0.17 MGD if similar ordinances to the County’s
Ordinance were to be adopted by the 88 incorporated cities of the County (as shown in Table 10
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below). Based on these data, the increase in wastewater generated in Culver City as a result of
the City’s proposed Ordinance would be approximately 0.008 MGD. The Sanitation Districts of
Los Angeles County currently treat approximately 510 MGD (County’s Final EIR, page 12-60,
November 2010). The Hyperion Treatment Plant (HTP) provides wastewater treatment for
Culver City. The HTP was designed to provide full secondary treatment for 450 MGD. The
HTP is located in the community of Playa Del Rey which is approximately five miles southwest
of Culver City. Typically, the average wastewater treated at the HTP is 305 MGD (City of Santa
Monica, Village Trailer Park Final EIR, SCH#2010061036, November 2012). Thus the HTP has a
remaining capacity of approximately 145 MGD per day. Therefore, an additional 0.21 MGD
due to paper carryout bag use throughout the County, including approximately 0.008 MGD in
Culver City, would not be a significant increase in wastewater, would not exceed the capacity at
any wastewater treatment facilities (including the HTP which serves Culver City), and would
not necessitate construction of new wastewater treatment facilities or expansion of existing
facilities. The City’s proposed Ordinance would not change the conclusions regarding
wastewater generation since the estimated increase of wastewater and impacts related to
wastewater generation for the City’s proposed Ordinance would be less than significant.
Table 10
Wastewater Generation Due to Plastic and Paper Carryout Bags Based on Ecobilan Data
Wastewater Sources
Wastewater Generation (MGD)
Wastewater Generation from
Plastic Carryout Bags
(existing conditions)
Increase Due to Conversion from
Plastic to Paper Carryout Bags
(with implementation of
Ordinance)
County Ordinance – 5,084 stores in
incorporated areas plus 1,091 stores in
unincorporated areas
0.69 0.21
City Ordinance – 72 stores in Culver City 0.009 0.008
Source: Ecobilan. February 2004. Environmental Impact Assessment of Carrefour Bags: An Analysis of the Life Cycle of
Shopping Bags of Plastic, Paper, and Biodegradable Material. Prepared for: Carrefour Group. Neuilly-sur-Seine, France
Water Supply. Carryout bags would indirectly result in water use through the
manufacturing process of carryout bags. As discussed in the County’s Final EIR, the conversion
from plastic bags to paper carryout bags and reusable carryout bags would result in an increase
of water use from the manufacturing process of paper and reusable bags. The increase of water
use for conversion to paper bags varies depending on which LCA data is utilized. As shown in
Table 11, the Ecobilan data used in the County’s Final EIR determined that due to a 50 percent
conversion from plastic to paper carryout bags, the water demand from manufacturing facilities
would increase by 0.47 MGD countywide compared to consumption due to plastic carryout
bags. Culver City’s contribution to this countywide increase would be 0.014 MGD as a result of
the City’s proposed Ordinance. In addition, as shown in Table 12, the Boustead data determined
that water demand would increase by 10.21 MGD countywide. As noted above, Culver City’s
approximately 72 stores were included within the approximately 5,084 stores in the
incorporated cities of the County and the increase of water consumption at the 72 stores using
the Boustead Data was estimated to be approximately 0.2 MGD, as shown in Table 12.
99Plastic Carryout Bag Ordinance
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Table 11
Water Consumption Due to Plastic and Paper Carryout Bags Based on Ecobilan Data
Water Consumption Sources
Water Consumption (MGD)
Water Consumption from
Plastic Carryout Bags
(existing conditions)
Increase Due to Conversion
from Plastic to Paper
Carryout Bags (with
implementation of Ordinance)
County Ordinance – 5,084 stores in incorporated
areas plus 1,091 stores in unincorporated areas
0.72 0.47
City Ordinance – 72 stores within Culver City 0.009 0.014
Source:
Ecobilan. February 2004. Environmental Impact Assessment of Carrefour Bags: An Analysis of the Life Cycle of
Shopping Bags of Plastic, Paper, and Biodegradable Material. Prepared for: Carrefour Group. Neuilly-sur-Seine, France
Table 12
Water Consumption Due to Plastic and Paper Carryout Bags Based on Boustead Data
Water Consumption Sources
Water Consumption (MGD)
Water Consumption from Plastic
Carryout Bags
(existing conditions)
Increase Due to Conversion
from Plastic to Paper Carryout
Bags (with implementation of
Ordinance)
County Ordinance – 5,084 stores in
incorporated areas plus 1,091 stores in
unincorporated areas
1.30 10.21
City Ordinance – 72 stores within Culver
City
0.02 0.2
Source: Boustead Consulting and Associates Ltd. 2007. Life Cycle Assessment for Three Types of Grocery Bags –
Recyclable Plastic; Compostable, Biodegradable Plastic; and Recycled, Recyclable Paper. Prepared for: Progressive Bag
Affiliates.
As noted in the County’s Final EIR, the water districts within the County supplied
approximately 1,563 MGD of water in fiscal year 2007/2008 (County’s Final EIR, page 12-61,
November 2010). Golden State Water Company (GSWC) is the main water supplier for Culver
City. However, a small portion of Culver City residents and businesses west of the 405 Freeway
receive their water from the Los Angeles Department of Water & Power (LADWP). Based on
the GWSC’s 2010 Urban Water Management Plan (UWMP) for the portion Culver City under
their jurisdiction, the estimated water supply for the year 2015 is 6,638 acre-feet per year and
currently the City uses approximately 5,024 acre-feet per year (Culver City UWMP, August
2011). Thus there is a surplus of approximately 1,614 acre-feet per year. Based on the LADWP’s
UWMP, the estimated water supply (including LADWP’s entire service area, not just that
portion in Culver City) for the year 2015 is 651,700 acre-feet per year and currently the LADWP
service area (including that portion in Culver City) uses approximately 555,477 acre-feet per
year (LADWP, 2011). Thus LADWP has a surplus of approximately 96,223 acre-feet per year.
The daily increase of water use countywide due to the conversion from plastic to paper carryout
bags based on the Ecobilan data would represent approximately 0.03 percent of the total water
supplied by water districts in the County. Within Culver City, the daily increase of water
consumption (0.014 MGD or 0.043 acre-feet per year) would increase the City’s current demand
but would not exceed the anticipated 2015 supply of water from either LADWP or GWSC. The
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increase of water countywide based on the Boustead data would represent 0.65 percent of the
total water supplied in the County and the City’s increase of water (0.2 MGD or 0.613 acre-feet
per year) would increase the City’s current demand but would not exceed the anticipated 2015
supply of either LADWP or GWSC. These increases would not have significant effects. As noted
above, there is no known manufacturing or production of paper carryout bags in the County (or
in Culver City). Therefore, any increase in water demand associated with paper carryout bag
manufacturing would not impact suppliers in the County and the proposed Ordinance,
consistent with the findings in the County’s Final EIR, would not be anticipated to necessitate
new or expanded entitlements for water.
As noted in the County’s Final EIR, banning plastic bags would result in an increase in the use
of reusable bags by consumers, the production of which would consume less water than the
production of both paper carryout bags and plastic carryout bags when considered on a per bag
basis. The City’s proposed Ordinance, like the County’s Ordinance, would require that reusable
bags be designed for a minimum lifetime of 125 uses; therefore, water supply impacts
associated with reusable bags would be reduced compared to use of plastic carryout bags. In
addition, since manufacturing facilities that produce reusable bags are not located within the
Los Angeles County or within Culver City, water supply required for the manufacture of
reusable bags may be supplied by water districts outside the County or outside of California.
Thus, water districts within the County would not be directly affected and, consistent with the
findings of the County’s Final EIR, any increase associated with reusable bag manufacturing as
an indirect result of the City’s proposed Ordinance would not necessitate new or expanded
entitlements for water and impacts would be less than significant.
Solid Waste. As described in the County’s Final EIR, based on the Ecobilan data, it was
concluded that a 50 percent conversion scenario would result in less solid waste per day at
landfills. Also, as shown in Table 13, the City’s proposed Ordinance would also result in a
reduction of approximately 5 tons of solid waste per day. However, as shown in Table 14, using
the Boustead data, the County’s Final EIR determined that a 50 percent conversion from plastic
to paper carryout bags would result in an increase of approximately 255 tons of solid waste per
day. Of this total countywide, approximately 15 tons of solid waste per day would be directly
related to implementation of Culver City’s proposed Ordinance. Nevertheless, as stated in the
County’s Final EIR, the permitted daily maximum capacity of all the County landfills is
approximately 43,749 tons per day and currently the landfills combined accept an average of
21,051 tons per day (County’s Final EIR, page 12-65, November 2010). Thus, the potential
increase of 255 tons of solid waste per day would represent approximately 1.1% of the
remaining total daily maximum capacity of approximately 22,698 tons per day.
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Table 13
Solid Waste Generation Due to Plastic and Paper Carryout Bags Based on
Ecobilan Data
Solid Waste Sources
Solid Waste Generation (tons per day)
Plastic Carryout Bags
(existing conditions)
Increase Due to Conversion
from Plastic to Paper
Carryout Bags, Assuming
2007 EPA Recycling Rates,¹
,
²
County Ordinance – 5,084 stores in
incorporated areas plus 1,091 stores in
unincorporated areas
241 -17
City Ordinance – 72 stores within Culver
City
3.2 -1.0
Source: Ecobilan. February 2004. Environmental Impact Assessment of Carrefour Bags: An Analysis of the Life Cycle of
Shopping Bags of Plastic, Paper, and Biodegradable Material. Prepared for: Carrefour Group. Neuilly-sur-Seine, France.
Notes:1. Negative numbers indicate the extent of the decrease in solid waste generation that would be expected from a
conversion from the current use of plastic carryout bags, to a 50 percent use of paper carryout bags.
2. Assuming 36.8 percent of paper carryout bags are diverted from landfills and 11.9 percent of plastic carryout bags are
diverted from landfills, based on the 2007 USEPA recycling rates.
Table 14
Solid Waste Generation Due to Plastic and Paper Carryout Bags
Based on Boustead Data
Solid Waste Sources
Solid Waste Generation (tons per day)
Plastic Carryout Bags
(existing conditions)
Increase Due to Conversion
from Plastic to Paper
Carryout Bags, Assuming
2007 EPA Recycling Rates,¹
,
²
County Ordinance – 5,084 stores in
incorporated areas plus 1,091 stores in
unincorporated areas
173.29 255
City Ordinance – 72 stores within Culver
City
2.0 3.2
Source: Boustead Consulting and Associates Ltd. 2007. Life Cycle Assessment for Three Types of Grocery Bags –
Recyclable Plastic; Compostable, Biodegradable Plastic; and Recycled, Recyclable Paper. Prepared for: Progressive Bag
Affiliates.
Notes: 1. Negative numbers indicate the extent of the decrease in solid waste generation that would be expected from a
conversion from the current use of plastic carryout bags, to a 50 percent use of paper carryout bags.
2. Assuming 36.8 percent of paper carryout bags are diverted from landfills and 11.9 percent of plastic carryout bags are
diverted from landfills, based on the 2007 USEPA recycling rates.
In Culver City, refuse is taken to the Puente Hills landfill and the Chiquita Canyon landfill. It
should also be noted that a portion of refuse in Culver City is taken to the Southeast Resource
Recovery Facility (SERRF) in Long Beach where the refuse can be converted to energy. Puente
Hills receives an average of 5,116 tons of municipal solid waste each day, with a capacity of
13,200 tons per day and Chiquita Canyon receives an average of 4,264 tons of solid waste per
day with a daily capacity of 6,000 tons per day (Los Angeles County, 2012; CalRecycle, 2013).
For the City’s proposed Ordinance, using the worst case scenario (the Boustead data), even with
an increase of approximately 3.2 tons of solid waste per day, the increase of solid waste as a
result of the City’s proposed Ordinance would not exceed the existing capacity of 8,084 tons per
day at Puente Hills and 1,736 tons per day at Chiquita Canyon. Thus, the existing waste
102Plastic Carryout Bag Ordinance
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disposal facilities in the County and in the City could accommodate any indirect increases in
solid waste related to the City’s proposed Ordinance. Similar to the findings in the County’s
Final EIR, impacts related to solid waste would be less than significant.
Energy Conservation. Energy use for carryout bags is primarily related to the
manufacturing process. Utilizing the Ecobilan data, the County’s EIR determined that non-
renewable energy consumption would actually decrease due to the conversion from plastic to
paper carryout bags. As shown in Table 15, based on the Ecobilan data energy use as a result of
the County’s Ordinance would decrease by approximately 2 million kilowatt hours (kWh) per
year. Also shown in Table 15, energy use would be reduced by approximately 0.05 million kWh
(or approximately 55,000 kWh) per year with implementation of the City’s proposed Ordinance.
Table 15
Non-Renewable Energy Consumption Based on Ecobilan Data
Energy Consumption Sources
Energy Consumption (million kWh)
Plastic Carryout Bags
(existing conditions)
Change Due to Conversion from
Plastic to Paper Carryout Bags,¹
County Ordinance – 5,084 stores in
incorporated areas plus 1,091 stores in
unincorporated areas
4.14 - 2.01
City Ordinance – 72 stores within Culver City 0.05 -0.01
Source: Ecobilan. February 2004. Environmental Impact Assessment of Carrefour Bags: An Analysis of the Life Cycle of
Shopping Bags of Plastic, Paper, and Biodegradable Material. Prepared for: Carrefour Group. Neuilly-sur-Seine, France.
Notes: Negative numbers indicate the extent of the decrease in solid waste generation that would be expected from a
conversion from the current use of plastic carryout bags, to a 50 percent use of paper carryout bags.
The Boustead data, as shown in Table 16, found different results and determined that the
County’s Ordinance would increase energy use per year countywide by approximately 3.6
million kWh. Based on the Boustead data, implementation of Culver City’s proposed Ordinance
would increase energy use in the City by approximately 62,170 kWh. However, even based on
Boustead data (which is a worst-case scenario), the total increase of 3.6 million kWh countywide
would represent less than 0.01 percent of the total energy use in the non-residential sector of the
County (County’s Final EIR, page 12-66, November 2010). Further, as stated above paper bag
manufacturing facilities appear not to be located within the County and, therefore, the energy
supply required for paper carryout bag manufacturing may be supplied by districts outside of
the County or outside of California, so impacts may not directly affect the County. Even in the
conservative worst case scenario which would increase energy use by approximately 3.6 million
kWh per year countywide and approximately 98,000 kWh in Culver City, impacts would be less
than significant.
103Plastic Carryout Bag Ordinance
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Table 16
Total Energy Consumption Due to Plastic and Paper Carryout Bags
Based on Boustead Data
Energy Consumption Sources
Energy Consumption (million kWh)
Plastic Carryout Bags
(existing conditions)
Increase Due to Conversion from
Plastic to Paper Carryout Bags,¹
County Ordinance – 5,084 stores in
incorporated areas plus 1,091 stores in
unincorporated areas
4.74 3.61
City Ordinance – 72 stores within Culver
City
0.06 0.10
Source: Boustead Consulting and Associates Ltd. 2007. Life Cycle Assessment for Three Types of Grocery Bags –
Recyclable Plastic; Compostable, Biodegradable Plastic; and Recycled, Recyclable Paper. Prepared for: Progressive Bag
Affiliates.
Notes: Negative numbers indicate the extent of the decrease in solid waste generation that would be expected from a conversion
from the current use of plastic carryout bags, to a 50 percent use of paper carryout bags.
Energy use for the conversion of plastic to reusable bags would be expected to decrease as a
result of the City’s proposed Ordinance. Similar to the findings in the County’s Final EIR,
because reusable bags, by definition, are required to be used at least 125 times, the energy
demands to manufacture a reusable bag are reduced compared to paper and plastic carryout
bags. As such, impacts related to conversion from paper to reusable carryout bags would have
beneficial effects relative to energy conservation.
Conclusion
As discussed above, impacts from the City’s proposed Ordinance related to air quality,
biological resources, hydrology and water quality, and utilities and service systems were
determined to have similar impacts as the County’s Final EIR. All of these issues were
determined to result in either less than significant impacts or beneficial impacts. For greenhouse
gas emissions, the City may have a potentially significant impact similar to the determination in
the County’s Final EIR and, therefore, Mitigation Measure MM-GHG-1 is required. No new
significant environmental effects beyond those already analyzed in the County’s Final EIR
would occur.
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LIST OF REFERENCES
Boustead Consulting and Associates Ltd. 2007. Life Cycle Assessment for Three Types of
Grocery Bags – Recyclable Plastic; Compostable, Biodegradable Plastic; and Recycled,
Recyclable Paper. Prepared for: Progressive Bag Affiliates.
California Department of Resources Recycling and Recovers (CalRecycle). Solid Waste
Information System Facility/Site Search. Accessed March 2013. Available at:
http://www.calrecycle.ca.gov/SWFacilities/Directory/Search.aspx
Culver City. Draft Plastic Carryout Bag Ban Ordinance.
Ecobilan. February 2004. Environmental Impact Assessment of Carrefour Bags: An Analysis of the Life
Cycle of Shopping Bags of Plastic, Paper, and Biodegradable Material. Prepared for: Carrefour
Group. Neuilly-sur-Seine, France.
Golden State Water Company. Culver City Urban Water Management Plan, 2010. Prepared by
Kennedy/Jenks Consultants. August 2011.
Hyder Consulting. 18 April 2007. Comparison of existing life cycle analyses of plastic bag
alternatives. Prepared for: Sustainability Victoria, Victoria, Australia.
Los Angeles, County of. Ordinances to Ban Plastic Carryout Bags in Los Angeles County Final
Environmental Impact Report (SCH#2009111104). Certified by the Los Angeles County
Board of Supervisors November 16, 2010.
Los Angeles, County of. Staff Report prepared by the Department of Public Works – Single-use
Plastic and Paper Carryout Bags. November 16, 2010.
Los Angeles, County of. Title 12 – Environmental Protection of the Los Angeles County Code
Chapter 12.85 (Amended to include the Plastic Carryout Bag Ordinance).
Los Angeles, County of, Department of Public Works. August 2012. County of Los Angeles
Countywide Integrated Waste Management Plan, 2011 Annual Report.
http://dpw.lacounty.gov/epd/swims/docs/pdf/CIWMP/2011.pdf
Los Angeles Department of Water and Power. 2010 Urban Water Management Plan. January
2011.
Santa Monica, City of. Village Trailer Park Final EIR, SCH#2010061036, November 2012.
South Coast Air Quality Management District. “Proposed Tier 4 Performance Standards”.
Greenhouse Gas CEQA Significance Threshold Stakeholder Working Group Meeting
#15. September 28, 2010.
105Plastic Carryout Bag Ordinance
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U.S. Environmental Protection Agency. November 2008. Municipal Solid Waste in the United
States: 2007 Facts and Figures. Washington, DC. Available at:
http://www.epa.gov/waste/nonhaz/municipal/pubs/msw07-rpt.pdf
LIST OF PREPARERS
Joe Power, AICP CEP, Principal in Charge
Matt Maddox, MESM, Project Manager
Karly Kaufman, MESM, Associate Environmental Planner
Katie Stanulis, Production Coordinator
106Appendix A
Potential Regulated Retailers in Culver City
Impact Worksheets (Ecobilan and Boustead data)
GHG Calculations for Truck Trips
URBEMIS Results for Truck Trips
107Business Name Name Business Address Business City State ZIP
7 - Eleven 5900-02 Washington Blvd Culver City, CA 90232
7-Eleven #39396B 5495 Sepulveda Blvd L Culver City, CA 90230
99c Only Stores Inc (#114) 12741 Washington Blvd Los Angeles, CA 90066
Albert's Liquor 5565 Sepulveda Bl Culver City, CA 90230
Albertsons #6104 13401 Washington Bl Culver City, CA 90232
Al's Liquor 6142 Washington Blvd Culver City, CA 90232
Bharat Bazaar 11510 W Washington Bl Los Angeles, CA 90066
Big Lots #4166 5587 Sepulveda Blvd Culver City, CA 90230
C V S/Pharmacy #9573 6299 S Bristol Pk Culver City, CA 90230
Centinela Chevron 5975 Centinela Ave Los Angeles, CA 90045
Chris's Market 8636 Washington Bl Culver City, CA 90230
Crescent Drugs, Inc 5915 Blackwelder St Culver City, CA 90232
Culver City Blue Gas 6300 W Slauson Ave Culver City, CA 90230
Culver City Chevron 11197 Washington Pl Culver City, CA 90232
Culver City Union 76 10638 Culver Bl Culver City, CA 90230
Culver Liquor 10548 Culver Bl Culver City, CA 90232
Dollar Tree Store #4187 11455 Jefferson Blvd Culver City, CA 90230
Don Felix Meat Market 3987 Sawtelle Blvd Los Angeles, CA 90066
Family Food Center 12469 Washington Bl Los Angeles, CA 90066
Famima!! 10704 Venice Blvd Culver City, CA 90232
Hillcrest Liquor Jr Market 11300 Venice Blvd Culver City, CA 90230
Jackson Market 4065 Jackson Av Culver City, CA 90232
Jasmine Asian & Chinese Islamic 4135 Sepulveda Bl Culver City, CA 90230
Jaspal, Inc 11181 Washington Bl Culver City, CA 90230
Jays Liquor 11305 Washington Pl Los Angeles, CA 90066
Jerry's Market 3969 Higuera St Culver City, CA 90232
Jin's Shell Service 10332 Culver Blvd Culver City, CA 90232
Kwik Mart Am/pm 5884 Washington Bl Culver City, CA 90232
Liquor Barrel 3923 Sepulveda Bl Culver City, CA 90230
Lucky 7 Liquor 12408 Washington Bl Los Angeles, CA 90066
Nickanthony's Wine And Spirits 10725 Jefferson Bl Culver City, CA 90230
One Stop Liqour Inc. 12012 Washington Bl Los Angeles, CA 90066
Overland Mini Market 4273 Overland Av Culver City, CA 90230
Pavilions #2212 11030 Jefferson Blvd Culver City, CA 90230
R & Z Liquor 8582 Washington Bl Culver City, CA 90232
Rainbow Acres 13208 Washington Bl Los Angeles, CA 90066
Ralphs #284 10772 Jefferson Bl Culver City, CA 90230
Ralphs Grocery #86 3827 Culver Center Culver City, CA 90230
Regal Fine Spirits 6295 Bristol Pkwy Culver City, CA 90230
Rite Aid #5457 4046 Centinela Ave Los Angeles, CA 90066
Rite Aid #5463 3802 Culver Center Culver City, CA 90232
Rite Aid #5464 11096 Jefferson Blvd Culver City, CA 90230
Rumi 19/Arco Am-Pm 6300 Slauson Ave Culver City, CA 90230
S P Super Petrol Inc 11284 Venice Blvd Culver City, CA 90230
Sepulveda Shell 3801 Sepulveda Culver City, CA 90230
Page 1 of 2
108Business Name Name Business Address Business City State ZIP
Seven Eleven Store #16040 11001 Washington Bl Culver City, CA 90230
Seven Eleven Store #18350 11299 Washington Bl Culver City, CA 90230
Shell Gas Station 3801 Sepulveda Blvd Culver City, CA 90230
Shelly's 98c And More 11469 Washington Blvd Los Angeles, CA 90066
Sorrento Italian Market 5518 S Sepulveda Blvd Culver City, CA 90230
Sprouts Farmers Market 5660 Sepulveda Blvd Culver City, CA 90230
Sun Liquor 12827 Washington Bl Los Angeles, CA 90066
Sunland Mobil 6100 Sepulveda Blvd Culver City, CA 90230
Supermercado Brazil 10826 Venice Blvd Culver City, CA 90232
Surfas Inc 3975 Landmark St Culver City, CA 90232
Surfas, Inc 8777 Washington Blvd Culver City, CA 90232
Target Store T-2632 6000 Sepulveda Blvd 2250 Culver City, CA 90230-6423
Target Stores T-198 10820 Jefferson Bl Culver City, CA 90230
Trader Joe's #36 9290 Culver Bl Culver City, CA 90232
Vics Union 76 11305 Culver Bl Los Angeles, CA 90066
Vons #2270 4030 Centinela Av Los Angeles, CA 90066
Washington Mobil Service 5776 Washington Bl Culver City, CA 90232
Washington Place Chevron 11197 Washington Pl Culver City, CA 90230
Z Newstand 6000 Sepulveda Blvd 1490 Culver City, CA 90230
Zam Zam Market Deli 11028 Washington Bl Culver City, CA 90232
Express Rx Pharmacy Culver City 4340 Overland Ave Culver City, CA 90230
Flaming Sky Pie Ranch 11011 Culver Bl Culver City, CA 90230
Gourmet Food Connection 5757 Uplander Way 209 Culver City, CA 90230
Gourmet Grains, LLC 8432 Steller Dr Culver City, CA 90232
L'Epicerie Market 9900 Culver Blvd Culver City, CA 90232
Precise Compounding Pharmacy 10810 Washington Blvd C Culver City, CA 90232
The Redd Collection 8440 Warner Dr C Culver City, CA 90232
Page 2 of 2
109City of Culver City Plastic
Carryout Bag Ordinance
Number of Stores in City 72 Conversions
Number of Stores 10,000 sf or
more 16 liters to gallons 0.264172
Number of Stores < 10,000 sf 56 Kg to short tons 0.001102
MJ to kWh 0.277778
Plastic Bag Size (liters) 14
Paper Bag Size (liters) 20.48
Reusable bag size (liters) 37
Plastic bags used per day at
stores >10,000 sf 10,000
Plastic bags used per day at
stores < 10,000 sf 5000
Number of plastic bags used in
City per day 440,000
Ordinance - Assume 50% switch
to paper/reusable
Number of paper bags per day
with 50% conversion 220,000
Number of reusable bags per day
with 50% conversion 220,000
110Eutrophication - Ecobilan Data Plastic bag Paper bag
Reusable bag
used 125 times
grams phosphate per 9000 liters
groceries 0.2 2.35 0.0044
grams phospate per bag 0.00031111 0.00534756 1.80889E-05
grams phosphate per day
citywide 136.888889 1176.46222 3.979555556
kg phosphate per day 0.13688889 1.17646222 0.003979556
Increase in phoshpate per day
from Ordinance (kg) 1.03957333 -0.132909333
Increase kg from Ordinance (50%
conversion to paper and
reusable ) 0.769775111
Water Use - Ecobilan Plastic bag Paper bag
Reusable bag
used 125 times
Liters water per 9000 liters
groceries 52.6 173 1.096
Liters water per bag per day 0.08182222 0.39367111 0.004505778
Liters water in City per day 36001.7778 86607.6444 991.2711111
Gallons per day 9510.66344 22879.319 261.8661215
Millions gallons per day (MGD) in
City 0.00951066 0.02287932 0.000261866
MGD per year 3.47139216 8.35095143 0.095581134
Increase in water use per year
(MGD) 4.87955927 -3.375811021
Increase as a result of Ordinance
(50% conversion to paper and
reusable). 0.013630522
111Wastewater - Ecobilan Plastic bag Paper bag
Reusable bag
used 125 times
Liters water per 9000 liters
groceries 50 130.7 1.096
Liters water per bag per day 0.07777778 0.29741511 0.004505778
Liters water in City per day 34222.2222 65431.3244 991.2711111
Gallons per day 9040.5546 17285.1271 261.8661215
Millions gallons per day (MGD) in
City 0.00904055 0.01728513 0.000261866
MGD per year 3.29980243 6.3090714 0.095581134
Increase in water use per year
(MGD) 3.00926897 -3.204221295
Increase per day (MGD) 0.008244573
Increase as a result of Ordinance
(50% conversion to paper and
reusable) per year 3.009268967
Solid Waste - Ecobilan Plastic bag Paper bag
Reusable bag
used 125 times 2007 recycle rate
kg waste per 9000 liters
groceries (w/EPA recycling) 4.19356 3.83624 0.10488 plastic bags 11.90%
kg waste per bag per day 0.00652332 0.00872958 0.000431173 paper bags 36.80%
kg waste in City per day 2870.25884 1920.50699 94.85813333
Tons per day (w/recycling) 3.16391503 2.11699406 0.000836505
Tons per year 1154.82898 772.702833 0.305324161
Increase in solid waste per year
(MGD) -382.126151 -1154.523661
Increase as a result of Ordinance
(50% conversion to paper and
reusable). Tons/day -1.046084458
112Increase as a result of Ordinance
(50% conversion to paper and
reusable). Tons/year -2691.478797
Energy - Ecobilan Plastic bag Paper bag
Reusable bag
used 125 times
MJ per 9000 liters groceries 286 295 6.44
MJ per bag per day 0.44488889 0.67128889 0.026475556
MJ in City per day 195751.111 147683.556 5824.622222
kWh in City per day 54375.3091 41023.2102 1617.95063
million kWh in City per day 0.05437531 0.04102321 0.001617951
Increase in million kWh per day -0.0133521 -0.052757358
Increase as a result of Ordinance
(50% conversion to paper and
reusable). Million kWh -0.011734148
Increase in kWh -11734.14824
Water Use - Boustead Plastic bag Paper bag
Gallons per 1000 paper bags
(1500 plastic bags) 58 1004
Gallons per bag 0.03866667 1.004
Gallons water in City per day 17013.3333 220880
Millions gallons per day (MGD) in
City 0.01701333 0.22088
MGD per year 6.20986667 80.6212
Increase in water use per year
(MGD) 74.4113333
Increase in water per day 0.203866667
113Solid Waste -Boustead Plastic bag Paper bag
Reusable bag
used 125 times 2007 recycle rate
kg waste per 1000 paper bags
(1500 plastic bags) 6.20224 21.4248 0.10488 plastic bags 11.90%
kg waste per bag per day 0.00413483 0.0214248 0 paper bags 36.80%
kg waste in City per day 1819.32373 4713.456 0
Tons per day 2.00545874 5.19568968 0
Tons per year 731.992442 1896.42673 0
Increase in solid waste per year
(MGD) 1164.43429
Increase as a result of Ordinance
(50% conversion to paper and
reusable). Tons/day 3.190230939
Increase as a result of Ordinance
(50% conversion to paper and
reusable). Tons/year 432.4418509
Energy - Boustead Plastic bag Paper bag
Reusable bag
used 125 times
MJ per 1000 paper bags (1500
plastic) 763 2622
MJ per bag per day 0.50866667 2.622 0
MJ in City per day 223813.333 576840 0
kWh in City per day 62170.3709 160233.335 0
million kWh in City per day 0.06217037 0.16023333 0
Increase in million kWh per day 0.09806296
Increase as a result of Ordinance
(50% conversion to paper and
reusable). Million kWh 0.098062964
Increase in kWh 98062.96375
114Air Quality - Ecobilan - Plastic
Bags VOCs NOx CO SOx Particulates
Emissions (grams) per 9000 liters
groceries 37.929 27.1 48.2 23.4 19.2
grams to
pounds 0.0022046
Emissions (grams) per bag per day 0.059000667 0.042155556 0.07497778 0.0364 0.029866667
Emissions (pounds) per day per
bag 0.000130074 9.29371E-05 0.0001653 8.025E-05 6.58447E-05
Emissions (pounds) citywide 57.2326499 40.89232019 72.7309901 35.309236 28.97168072
Air Quality - Ecobilan - Paper
Bags VOCs NOx CO SOx Particulates
Emissions (grams) per 9000 liters
groceries 28.37487101 72.6 9.34 26.1 4.72
Emissions (grams) per bag per day 0.064568595 0.165205333 0.02125369 0.059392 0.010740622
Emissions (pounds) per day per
bag 0.000142349 0.000364215 4.6856E-05 0.0001309 2.3679E-05
Emissions (pounds) citywide 31.31686489 80.12739126 10.3083999 28.806128 5.209384115
Change from Plastic to Paper -25.91578501 39.23507107 -62.4225902 -6.503108 -23.76229661
115Air Quality Just End of Life NOx -
Ecobilan - Plastic Bags NOx
Emissions (grams) per 9000 liters
groceries 0.97
Emissions (grams) per bag per day 0.001508889
Emissions (pounds) per day per
bag 2.93067E-06
Emissions (pounds) citywide 1.289496312
Air Quality - Ecobilan - Paper
Bags NOx
Emissions (grams) per 9000 liters
groceries 5.74
Emissions (grams) per bag per day 0.013061689
Emissions (pounds) per day per
bag (w/EPA recycling) 1.81991E-05
Emissions (pounds) citywide 4.003809018
Change from Plastic to Paper
(pounds) 2.714312706
116GHG - Ecobilan Plastic bag Paper bag
Reusable
bag used
125 times
GHG Emissions (metric tons) per
9000 liters groceries 0.0109 0.0205 0.000228
grams to
metric tons 0.000001
metric tons per bag per day 1.49378E-05 2.9482E-05 9.373E-07
metric tons citywide per day 6.572651556 6.48606151 0.2062133
metric tons per year 2399.017818 2367.41245 75.267867
Increase in metric tons per year -31.6053662 -2323.75
Increase as a result of Ordinance
(50% conversion to paper and
reusable). Metric Tons/day -0.086590044
Culver City
Population 39004
Increase as a result of Ordinance
(50% conversion to paper and
reusable). Metric Tons/year -31.60536622
per capita increase -0.000810311
GHG End of Life- Ecobilan Plastic bag Paper bag
GHG Emissions (grams) per 9000
liters groceries 84.4879 7520.8
grams per bag per day 0.131425622 17.1139982
metric tons per bag per day 1.31426E-07 1.7114E-05
metric tons citywide per day 0.057827274 3.76507961
metric tons per year 21.10695493 1374.25406
Increase in metric tons per year 1353.1471
Increase as a result of Ordinance
(50% conversion to paper and
reusable). Metric Tons/day 3.707252335
117Increase as a result of Ordinance
(50% conversion to paper and
reusable). Metric Tons/year 1353.147102
per capita annual 0.034692521
GHG End of Life- Boustead Plastic bag Paper bag
metric tons for 1000 paper and
1500 plastic bags (w/EPA
recycling) 0.002643 0.0316
metric tons per bag per day 0.000001762 0.0000316
metric tons citywide per day 0.77528 6.952
metric tons per year 282.9772 2537.48
Increase in metric tons per year 2254.5028
Increase as a result of Ordinance
(50% conversion to paper and
reusable). Metric Tons/day 6.17672
Increase as a result of Ordinance
(50% conversion to paper and
reusable). Metric Tons/year 2254.5028
Per capita increase 0.057801836
1183/7/2013 3:42:38 PM
Page: 1
Urbemis 2007 Version 9.2.4
File Name:
Project Name: Culver City Bag Ordinance
Project Location: South Coast AQMD
On-Road Vehicle Emissions Based on: Version : Emfac2007 V2.3 Nov 1 2006
Off-Road Vehicle Emissions Based on: OFFROAD2007
Summary Report for Summer Emissions (Pounds/Day)
TOTALS (lbs/day, unmitigated) 0.04 0.52 0.20 0.00 0.07 0.03 114.09
SUM OF AREA SOURCE AND OPERATIONAL EMISSION ESTIMATES
ROG NOx CO SO2 PM10 PM2.5 CO2
TOTALS (lbs/day, unmitigated) 0.04 0.52 0.20 0.00 0.07 0.03 114.09
OPERATIONAL (VEHICLE) EMISSION ESTIMATES
ROG NOx CO SO2 PM10 PM2.5 CO2
1193/7/2013 3:40:16 PM
Page: 1
OPERATIONAL EMISSION ESTIMATES (Summer Pounds Per Day, Unmitigated)
Bag Ordinance - Truck Trips 0.04 0.52 0.20 0.00 0.07 0.03 114.09
TOTALS (lbs/day, unmitigated) 0.04 0.52 0.20 0.00 0.07 0.03 114.09
Source ROG NOX CO SO2 PM10 PM25 CO2
Analysis Year: 2014 Temperature (F): 80 Season: Summer
Emfac: Version : Emfac2007 V2.3 Nov 1 2006
Does not include correction for passby trips
Does not include double counting adjustment for internal trips
Bag Ordinance - Truck Trips 3.00 1000 sq ft 1.00 3.00 26.92
3.00 26.92
Summary of Land Uses
Land Use Type Acreage Trip Rate Unit Type No. Units Total Trips Total VMT
Light Truck < 3750 lbs 0.0 1.4 95.9 2.7
Light Auto 0.0 0.4 99.4 0.2
Vehicle Fleet Mix
Vehicle Type Percent Type Non-Catalyst Catalyst Diesel
File Name:
Project Name: Culver City Bag Ordinance
Project Location: South Coast AQMD
On-Road Vehicle Emissions Based on: Version : Emfac2007 V2.3 Nov 1 2006
Off-Road Vehicle Emissions Based on: OFFROAD2007
Urbemis 2007 Version 9.2.4
Detail Report for Summer Operational Unmitigated Emissions (Pounds/Day)
1203/7/2013 3:40:16 PM
Page: 2
Other Bus 0.0 0.0 0.0 100.0
Heavy-Heavy Truck 33,001-60,000 lbs 100.0 0.0 0.0 100.0
Motor Home 0.0 0.0 88.9 11.1
School Bus 0.0 0.0 0.0 100.0
Motorcycle 0.0 50.0 50.0 0.0
Urban Bus 0.0 0.0 0.0 100.0
Light Truck 3751-5750 lbs 0.0 0.4 99.6 0.0
Med-Heavy Truck 14,001-33,000 lbs 0.0 0.0 22.2 77.8
Med Truck 5751-8500 lbs 0.0 0.9 99.1 0.0
Lite-Heavy Truck 10,001-14,000 lbs 0.0 0.0 60.0 40.0
Lite-Heavy Truck 8501-10,000 lbs 0.0 0.0 82.4 17.6
Vehicle Fleet Mix
Vehicle Type Percent Type Non-Catalyst Catalyst Diesel
% of Trips - Residential 32.9 18.0 49.1
Trip speeds (mph) 30.0 30.0 30.0 30.0 30.0 30.0
% of Trips - Commercial (by land
use)
Bag Ordinance - Truck Trips 2.0 1.0 97.0
Rural Trip Length (miles) 17.6 12.1 14.9 15.4 9.6 12.6
Urban Trip Length (miles) 12.7 7.0 9.5 13.3 7.4 8.9
Travel Conditions
Home-Work Home-Shop Home-Other Commute Non-Work Customer
Residential Commercial
1213/7/2013 3:40:16 PM
Page: 3
Operational Changes to Defaults
122Appendix B
Culver City Draft Ordinance
123Chapter 11.16 PLASTIC CARRYOUT BAG REGULATIONS
11.16.010 Definitions.
11.16.020 Plastic carryout bags prohibited.
11.16.030 Permitted bags.
11.16.040 Regulation of recyclable paper carryout bags.
11.16.050 Use of reusable bags.
11.16.060 Exempt customers.
11.16.070 Operative date.
11.16.080 Enforcement and violation--penalty.
11.16.090 Severability.
11.16.100 No conflict with federal or state law.
11.16.010 Definitions.
The following definitions apply to this Chapter:
A. “Customer” means any person purchasing goods from a store.
B. “Operator” means the person in control of, or having the responsibility for, the operation of a store,
which may include, but is not limited to, the owner of the store.
C. “Person” means any natural person, firm, corporation, partnership, or other organization or group
however organized.
D. “Plastic carryout bag” means any bag made predominantly of plastic derived from either petroleum
or a biologically-based source, such as corn or other plant sources, which is provided to a customer at
the point of sale. “Plastic carryout bag” includes compostable and biodegradable bags but does not
include reusable bags, produce bags, or product bags.
E. “Postconsumer recycled material” means a material that would otherwise be destined for solid waste
disposal, having completed its intended end use and product life cycle. “Postconsumer recycled
material” does not include materials and by-products generated from, and commonly reused within, an
original manufacturing and fabrication process.
124F. “Produce bag” or “product bag” means any bag without handles used exclusively to carry produce,
meats, or other food items to the point of sale inside a store or to prevent such food items from coming
into direct contact with other purchased items.
G. “Recyclable” means material that can be sorted, cleansed, and reconstituted using available recycling
collection programs for the purpose of using the altered form in the manufacture of a new product.
“Recycling” does not include burning, incinerating, converting, or otherwise thermally destroying solid
waste.
H. “Recyclable paper carryout bag” means a paper bag that meets all of the following requirements: (1)
contains no old growth fiber, (2) is one hundred percent (100%) recyclable overall and contains a
minimum of forty percent (40%) post-consumer recycled material; (3) is capable of composting,
consistent with the timeline and specifications of the American Society of Testing and Materials (ASTM)
Standard D6400; (4) is accepted for recycling in curbside programs in the City; (5) has printed on the bag
the name of the manufacturer, the location (country) where the bag was manufactured, and the
percentage of postconsumer recycled material used; and (6) displays the word “Recyclable” in a highly
visible manner on the outside of the bag.
I. “Reusable bag” means a bag with handles that is specifically designed and manufactured for multiple
reuse and meets all of the following requirements: (1) has a minimum lifetime of 125 uses, which for
purposes of this subsection, means the capability of carrying a minimum of 22 pounds 125 times over a
distance of at least 175 feet; (2) has a minimum volume of 15 liters; (3) is machine washable or is made
from a material that can be cleaned or disinfected; (4) does not contain lead, cadmium, or any other
heavy metal in toxic amounts; (5) has printed on the bag, or on a tag that is permanently affixed to the
bag, the name of the manufacturer, the location (country) where the bag was manufactured, a
statement that the bag does not contain lead, cadmium, or any other heavy metal in toxic amounts, and
the percentage of postconsumer recycled material used, if any; and (6) if made of plastic, is a minimum
of at least 2.25 mils thick.
J. “Store” means any of the following retail establishments located within the incorporated area of
Culver City:
1. A full-line, self-service retail store with gross annual sales of two million dollars ($2,000,000), or more,
that sells a line of dry grocery, canned goods, or nonfood items and some perishable items;
2. A store of at least 10,000 square feet of retail space that generates sales or use tax pursuant to the
Bradley-Burns Uniform Local Sales and Use Tax Law (Part 1.5 (commencing with Section 7200) of
Division 2 of the Revenue and Taxation Code) and that has a pharmacy licensed pursuant to Chapter 9
(commencing with Section 4000) of Division 2 of the Business and Professions Code; or
3. A drug store, pharmacy, supermarket, grocery store, convenience food store, foodmart, or other
entity engaged in the retail sale of a limited line of goods that includes milk, bread, soda, and snack
foods, including those stores with a Type 20 or 21 license issued by the Department of Alcoholic
Beverage Control.
125
11.16.020 Plastic carryout bags prohibited.
A. No store shall provide to any customer a plastic carryout bag.
B. This prohibition applies to bags provided for the purpose of carrying away goods from the point of
sale and does not apply to produce bags or product bags.
11.16.030 Permitted bags.
All stores shall provide or make available to a customer only recyclable paper carryout bags or reusable
bags for the purpose of carrying away goods or other materials from the point of sale, subject to the
terms of this Chapter. Nothing in this Chapter prohibits customers from using bags of any type that they
bring to the store themselves or from carrying away goods that are not placed in a bag, in lieu of using
bags provided by the store.
11.16.040 Regulation of recyclable paper carryout bags.
A. Any store that provides a recyclable paper carryout bag to a customer must charge the customer at
least 10 cents ($0.10) for each bag provided, except as otherwise provided in this Chapter.
B. The City Council may increase the 10 cent ($0.10) minimum charge by Resolution.
C. No store shall rebate or otherwise reimburse a customer any portion of the minimum charge required
in Subsection A, except as otherwise provided in this Chapter.
D. All stores must post signage clearly indicating the per bag charge for recyclable paper carryout bags.
E. All stores must indicate on the customer receipt the number of recyclable paper carryout bags
provided and the total amount charged for the bags.
F. All monies collected by a store under this Chapter will be retained by the store and may be used only
for any of the following purposes: (1) costs associated with complying with the requirements of this
Chapter, (2) actual costs of providing recyclable paper carryout bags, or (3) costs associated with a
store’s educational materials or education campaign encouraging the use of reusable bags, if any.
G. All stores must keep records of the total number of recyclable paper carryout bags provided, the total
amount of monies collected for providing recyclable paper carryout bags, and a summary of any efforts
a store has undertaken to promote the use of reusable bags by customers in the prior year. Such
records must be made available for the Director of Public Works or his/her designee to review at any
time.
126
11.16.050 Use of reusable bags.
A. All stores must provide reusable bags to customers, either for sale or at no charge.
B. Each store is strongly encouraged to educate its staff to promote reusable bags and to post signs
encouraging customers to use reusable bags.
11.16.060 Exempt customers.
All stores must provide at the point of sale, free of charge, either reusable bags or recyclable paper
carryout bags or both, at the store’s option, to any customer participating either in the California Special
Supplemental Food Program for Women, Infants, and Children pursuant to Article 2 (commencing with
Section 123275) of Chapter 1 of Part 2 of Division 106 of the Health and Safety Code or in the
Supplemental Food Program pursuant to Chapter 10 (commencing with Section 15500) of Part 3 of
Division 9 of the Welfare and Institutions Code.
11.16.070 Operative date.
This Chapter shall become operative six (6) months after its effective date for stores defined in
Subsections J(1) and J(2) of Section 11.16.010. For stores defined in Subsection J(3) of Section 11.16.010,
this Chapter shall become operative twelve (12) months after its effective date.
11.16.080 Enforcement and violation--penalty.
A. The Director of Public Works has primary responsibility for enforcement of this Chapter. The Director
of Public Works is authorized to promulgate regulations and to take any and all other actions reasonable
and necessary to enforce this Chapter, including, but not limited to, investigating violations, issuing fines
and entering the premises of any store during business hours.
B. If the Director of Public Works determines that a violation of this Chapter has occurred, he/she will
issue a written warning notice to the operator of a store that a violation has occurred and the potential
penalties that will apply for future violations.
C. Any store that violates or fails to comply with any of the requirements of this Chapter after a written
warning notice has been issued for that violation shall be guilty of an infraction.
D. If a store has subsequent violations of this Chapter that are similar in kind to the violation addressed
in a written warning notice, the following penalties will be imposed and shall be payable by the operator
of the store:
127A fine not exceeding one hundred dollars ($100.00) for the first violation after the written warning
notice is given;
A fine not exceeding two hundred dollars ($200.00) for the second violation after the written warning
notice is given; or
A fine not exceeding five hundred dollars ($500.00) for the third and any subsequent violations after the
written warning notice is given.
E. A fine shall be imposed for each day a violation occurs or is allowed to continue.
F. Any store operator who receives a written warning notice or fine may request an administrative
review of the accuracy of the determination or the propriety of any fine issued, by filing a written notice
of appeal with the Director of Public Works no later than 30 days after receipt of a written warning
notice or fine, as applicable. The notice of appeal must include all facts supporting the appeal and any
statements and evidence, including copies of all written documentation and a list of any witnesses, that
the appellant wishes to be considered in connection with the appeal. The appeal will be heard by the
Director of Public Works. The Director of Public Works will conduct a hearing concerning the appeal
within 45 days from the date that the notice of appeal is filed, or on a later date if agreed upon by the
appellant and the Director of Public Works, and will give the appellant 10 days prior written notice of
the date of the hearing. The Director of Public Works may sustain, rescind, or modify the written
warning notice or fine, as applicable, by written decision. The Director of Public Works will have the
power to waive any portion of the fine in a manner consistent with the decision. The decision of the
Director of Public Works is final and effective on the date of service of the written decision, is not
subject to further administrative review, and constitutes the final administrative decision.
11.16.090 Severability.
If any section, subsection, sentence, clause, or phrase of this ordinance is for any reason held to be
invalid by a decision of any court of competent jurisdiction, that decision will not affect the validity of
the remaining portions of the ordinance. The City Council hereby declares that it would have passed this
ordinance and each and every section, subsection, sentence, clause, or phrase not declared invalid or
unconstitutional without regard to whether any portion of this ordinance would be subsequently
declared invalid.
11.16.100 No conflict with federal or state law.
Nothing in this ordinance is intended to create any requirement, power or duty that is in conflict with
any federal or state law.
128Appendix C
Mitigation Monitoring and Reporting Program (MMRP)
129Mitigation Monitoring and
Reporting Program
Plastic Carryout Bag Ordinance
Environmental Impact Report Addendum
Prepared for:
City of Culver City
Department of Public Works
9770 Culver Boulevard
Culver City, CA 90232
Contact: Helen B. Kerstein, Management Analyst
(310) 253-5618
Prepared by:
Rincon Consultants, Inc.
180 North Ashwood Avenue
Ventura, California 93003
April 2013
130Plastic Carryout Bag Ordinance
Mitigation Monitoring and Reporting Program
City of Culver City|1010|MITIGATION MONITORING AND REPORTING PROGRAM
CEQA requires that a reporting or monitoring program be adopted for the conditions of project approval that are necessary to mitigate or avoid
significant effects on the environment (Public Resources Code 21081.6). The mitigation monitoring and reporting program is designed to
ensure compliance with adopted mitigation measures during project implementation. For each mitigation measure recommended in the EIR,
specifications are made herein that identify the action required and the monitoring that must occur. In addition, a responsible agency is
identified for verifying compliance with individual conditions of approval contained in the Mitigation Monitoring and Reporting Program (MMRP).
To implement this MMRP, the City of Culver City will designate a Project Mitigation Monitoring and Reporting Coordinator (“Coordinator”). The
coordinator will be responsible for ensuring that the mitigation measures incorporated into the project are complied with during project
implementation. The coordinator will also distribute copies of the MMRP to those responsible agencies identified in the MMRP, which have
partial or full responsibility for implementing certain measures. Failure of a responsible agency to implement a mitigation measure will not in
any way prevent the lead agency from implementing the proposed project.
The following table will be used as the coordinator’s checklist to determine compliance with required mitigation measures.
131Plastic Carryout Bag Ordinance
Mitigation Monitoring and Reporting Program
City of Culver City|1010|Mitigation Measure/Condition of
Approval
Monitoring Milestone/
Frequency
Responsible
Agency or
Party
Action Indicating
Compliance
Compliance Verification
Initials Date Comments
GREENHOUSE GAS EMISSIONS
Mitigation Measure MM-GHG-1
? Implement and/or expand public
outreach and educational programs
to increase the percentage of paper
carryout bags that are recycled
curbside.
? Distribute reusable grocery bags free
of charge to encourage further
transitions to reusable bags; consider
public/private partnerships to offset
costs of distribution.
? Implement an outreach program for
affected stores to encourage
consumer transition to reusable bags,
to reduce double bagging, and to
encourage reuse and in-store
recycling of paper carryout bags.
-For at least two years, add
information to the City's website
about recycling paper bags curbside.
Explore the feasibility of other
distribution channels such as
physical mailers and the TV crawler.
-Distribute bags at the following
locations for at least five years:
- City Hall (annually)
- Fiesta La Ballona (annually)
- A minimum of at least one other
event annually
-At least once, prior to the operative
date of the Ordinance, send mailers
to affected stores with information
on the Ordinance and tips on
encouraging consumer transition to
reusable bags, reducing double
bagging, and encouraging reuse and
in-store recycling of paper carryout
bags.
Public Works
Department
-Review and
update quarterly the
City’s website
regarding paper
bag recycling.
-Annual review
confirming that
bags were
distributed at the
locations and
events identified.
-Receipt of mailers
sent to affected
stores prior to the
operative date of
the Ordinance.
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