What is the provocation necessary to reduce a murder to second degree murder?

As appellant points out, the provocation necessary to reduce first degree murder to second degree murder is based on a subjective standard. "To reduce a murder to second degree murder, premeditation and deliberation may be negated by heat of passion arising from provocation. [Citation.] If the provocation would not cause an average person to experience deadly passion but it precludes the defendant from subjectively deliberating or premeditating, the crime is second degree murder." (People v. Hernandez (2010)

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183 Cal.App.4th 1327, 1332 (Hernandez).) In contrast, the provocation necessary to reduce any murder to voluntary manslaughter requires more. "For that, an objective test ... applies: the provocation must be so great that, in the words of CALCRIM No. 570, it 'would have caused a person of average disposition to act rashly and without due deliberation, that is, from passion rather than from judgment.' " (People v. Jones (2014) 223 Cal.App.4th 995, 1000-1001 (Jones).)